Speak Your Piece: Simplify Rural Definition

Proposed changes in how the USDA defines eligibility for its development programs will improve the department’s service to rural communities, says the deputy undersecretary in charge of those programs.

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EDITOR’S NOTE: This article is part of a series of responses to a USDA report on how to define “rural” for the department’s development programs. The report recommends creating a single definition (50,000 or fewer residents) for program eligibility and using other criteria to ensure that small communities remain competitive in development funding. The author of today’s column is Doug O’Brien, deputy undersecretary for rural development at USDA.

USDA’s recommendations for how to simplify the statutory definitions of rural have generated a lot of discussion. This is an important issue, and we want to explain the value of moving to a more consistent definition of “rural area” for USDA’s development programs.

Rural Development (which is a mission area within the U.S. Department of Agriculture) is dedicated to helping improve the economy and quality of life in rural America. Congress has authorized and directed Rural Development to administer more than 40 programs to support vibrant rural economies. Over time, Congress has provided numerous different definitions of rural areas. 

In the last farm bill (2008), Congress wisely suggested that these different definitions, which were created over decades, deserved a second look and asked USDA to 1) assess the varying definitions of rural, 2) describe what effect those varying definitions have on USDA programs and 3) make recommendations on ways to better target the funds provided through rural development programs. This third part of the request has created the most discussion.

First off, we’d like to note that an earlier article on this topic (by Aleta Botts) makes an excellent point that the different Rural Development programs (such as business development, infrastructure improvements, and community facilities) have different goals, so one definition may not be ideal for all programs.  We take this point, and also recognize that there is a trade-off between tailoring the definition to each program and having over-all consistent definition that is easier for people to understand.  The fact that we have a dozen different definitions in statute now is not necessarily an indication of fine-tailoring but rather reflects over half a century of legislation on rural programs and the different interests in front of Congress at the time the definition was created for a particular program. Congress is now stepping up to the difficult task of re-examining these definitions to see if they make sense in today’s rural communities. We applaud that and will continue to assist Congress in this work. 

Most of the statutes that define rural use population caps for certain programs, and many programs also provide priority points to help prioritize applications from communities that are well below the cap. These priorities sometimes appear in statute and sometimes in regulation. In discussing the priority point system for small rural areas, Aleta Botts’ article raises the possibility that priority points for smaller rural places will not work. She writes, “an attachment to the USDA report provides a fuller picture of these priority points and suggests instead that large communities will easily be able to make up those points simply by responding to any one of several other priorities USDA identifies.”

Since we administer the programs, we have the luxury of not working in hypotheticals.  We have data on the distribution of our program resources and know exactly how well these priority points work, in practice, to prioritize small, rural places. For example, currently Rural Business Service programs can serve rural areas of up to 50,000 people. The priority point system works well to ensure the largest areas within this category do not dominate. In fact in 2012, 83% of projects were in communities with populations that are less than half of that cap, and 61% were in communities of fewer than 10,000. We see similar results in other programs where smaller areas are prioritized, such as the water programs.

The earlier article also mentions that certain priority categories would advantage larger areas, such as:  “reuses a developed site” and “addresses water quality or air quality problems in the service area.”  These priority points are not new. They have been part of the selection criteria for years in certain programs and have not undermined Rural Development’s ability to prioritize smaller rural places in the past. There is no reason to think they will operate differently the future.

This discussion begs the question: If Rural Development thinks smaller rural places are important enough for priority points, why not just suggest that Congress choose a lower population cap?  What’s to be gained by recommending that the cap standardize at 50,000? The first thing to mention is that this cap is already the default as directed by the Consolidated Farm and Rural Development Act and is common for many of our programs. But more importantly, setting the limit at 50,000 allows and facilitates collaboration among rural communities.

Doug O’Brien, deputy undersecretary for USDA Rural Development

The earlier post voices a concern we hear frequently. What incentive will larger rural towns have to work with smaller towns if these large towns qualify on their own? As USDA Secretary Tom Vilsack has said, this every-town-for-itself thinking is just not what we are seeing in rural areas. Across the United States, rural regions are thinking about infrastructure and development in regional terms. Many times, these approaches are the best chance for rural communities to make the most of their assets and create good jobs for their citizens. We think that USDA should be able to support this type of collaborative work, and unfortunately sometimes the many different definitions stand in the way of these efforts.

For example, Yolo County Food Bank in California used a Rural Business Enterprise Grant to do youth education projects on local foods. Yolo County Food Bank hoped to also apply to the Community Facilities program to purchase a truck to help haul fresh produce around to schools for the demonstrations and to make food deliveries. Despite the fact the truck would be serving a very needy rural population, the project was determined ineligible because the truck would be based at the food bank facility in Woodland, a community over the 20,000 population limit for the Community Facilities program.

Our staff in the state report that the different definitions cause confusion for our stakeholders and sometimes cause communities to walk away from possible deals because either the definitions cause roadblocks or they are not interested in contorting the different projects in such a way that may meet the letter of the rural definition. At the end of the day, we are always looking for ways that Rural Development can be a better partner in supporting businesses, individuals and communities in capturing economic opportunity. We believe that the proposal for a common definition, with the ability to target resources to the most rural areas, the most needy, and where the dollars can make the greatest impact would make it easier for folks to work with us and would result in better outcomes.  

 

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