Dear Secretary Mnuchin,
Thank you for your engagement with the U.S Congress to provide critically needed economic stimulus during the ongoing COVID-19 public health and economic crisis. We write to support the certification of the Toledo Metropolitan Area Council of Governments (TMACOG) for the Coronavirus Relief Fund to receive direct federal assistance from the Department of the Treasury. As it stands now, Toledo, Ohio is the only major Ohio city without direct access to relief mechanisms enacted by the CARES Act, falling short by merely 70,000 residents under the formula unless the SMSA is taken into account.
As you know, the CARES Act (H.R. 748) contains a critical provision that will be used to assist state and local governments in their response to the crisis engulfing our nation. Indeed, local governments are bearing the heavy burden of response with dwindling resources while helping struggling Americans manage as best they can. As the entities closest to the ground, these local governments are on the front line of the fight, and we must ensure they have adequate funding in the face of dire budget shortfalls and increased expenditures.
Section 5001 of the CARES Act provides that Treasury will provide assistance directly, and not through the State intermediary to units of local government of more than 500,000 people. The provision, allows for a significantly broad definition of local governments and specifies that ""[t]he term "unit of local government' [includes] . . . other unit of general government below the State level with a population that exceeds 500,000." Section 5001 explicitly allows any government that represents more than 500,000 and includes regional councils of government which are chartered under state law.
In Ohio, Chapter 167 of the revised code provides broad authority for a regional council of government to act as a local unit of government, to plan, enter cooperative agreements related "to matters affecting health, safety, welfare, education, economic conditions, and regional development." See Ohio Revised Code, Sec. 167.03.
As such a local unit of government, TMACOG encompasses more than 500,000 people in Lucas County (home to Toledo), as well as Ottawa, Sandusky, and Wood counties in Ohio. As a unit of local and general government as envisioned by the statute, TMACOG plays a leading role in coordinating policy solutions to complex regional challenges, such as COVID-19. Direct eligibility would allow for more robust capacities to contain the virus at the strategic national transit center on the crossroads of two major interstate highway corridors (Interstates 75 and 80/90), that would otherwise be left out of direct funding. For these reasons, extending eligibility to TMACOG would improve economic recovery in this important region, while also boosting the public health responses of localities.
We fully support the effort by TMACOG for certification and would appreciate your favorable consideration of its recent submission. We look forward to hearing from you.