Dear Director Santos:
We are writing to express our concern regarding the Census Bureau's March 2022 Urban Area Final Criteria published in the Federal Register (87 FR 16706), which decreased the maximum jump distance to 1.5 miles for undeveloped land to connect two cities to qualify as a joint urban area.
As you know, this jump distance has been 2.5 miles since the 2000 Census, and the Census Bureau abandoned its 2010 attempt to reduce this distance to 1.5 miles. Therefore, this change has split formerly joint urban areas that have held this status for 20 years.
While we recognize that the Census Bureau proposed the initial criteria for public comment in February 2021, we do not believe there was sufficient notice to the joint urban areas at risk of losing both this status and the federal funding for which it enabled them to qualify. The most important public comments for the Census Bureau to review to understand the weight of this change would have been from the local governments and residents of these jurisdictions.
As such, we respectfully request that the Census Bureau open an appeals process for this decision--one that allows for proper notice to the affected areas in our constituencies and provides them with a sufficient opportunity to comment on the ramifications of such a change. Otherwise, beginning with Fiscal Year 2024 funding, these areas stand to lose substantial federal funding. This includes a significant change in Federal Transit Administration funding, as many of these areas will lose the former, higher amount of 5337 Urbanized Area Formula Funding they previously have received in exchange for lower 5311 Formula Grants for Rural Areas. Additionally, these areas may also face operability issues and forced staffing cuts as a result of decreased funding and splitting of jurisdiction.
We ask for your timely response to this issue, and in enabling all presently split, but formerly joint urban areas to appeal and the aforementioned Final Criteria. We stand ready to answer any questions on this matter or provide further information.