right uh it's 201 so i'm gonna go ahead and get 
started good afternoon everyone uh thank you for   joining today's webinar uh redefining non-metro uh 
what does the ombs propose change changes to the   metropolitan definition mean for rural america 
my name is dan stern i'm the communications and   outreach manager at the housing assistance council 
and i'll be the host for today's webinar all the   participants are in listen only mode which 
means your line is muted however we do want   to hear from you and are interested in uh getting 
your feedback to submit a comment or a question   you can use the chat function which should appear 
in the menu bar at the top of your screen it looks   like a little chat bubble uh so go ahead and type 
in your questions and we'll be monitoring that as   the presentation goes along and try to get to as 
many as we can by the end of the presentation as   you may have seen from a pop-up today's webinar is 
being recorded the the recording and presentation   will be available on hacks website within the 
next couple of days after the presentation we   will also be emailing it out to everyone who 
attends uh so hacks website is www.ruralhome.org so if you're not familiar with us uh the housing 
assistant council or hack as we often go by is a   national nonprofit that's focused on um where we 
that builds homes and communities in rural areas   we've had a we've been around for 50 years 
or right about it's our 50th and a birthday   i guess you would say this year and we uh so 
we were founded in 1971 for those of you who   are good at math uh we the way we build affordable 
homes is through financial products like loans and   certain grant opportunities we also have uh 
we offer technical assistance and training   um trainings like today's webinar uh we also 
have um sort of uh a lot of we produce a lot   of research around rural housing and rural issues 
and if you're not a subscriber to our hack news   newsletter and our other information products you 
want to be you can find all that information at   our website as i said earlier rural home.org and 
uh i'm going to introduce you to our presenter   for today um a lot of you are probably 
familiar with him but this is lance george   he's our director of research and 
information at the housing assistance council   and i am going to turn the presentation over 
to lance now thank you all for joining us   hi everyone i'm lance george with the housing 
assistance council thank you for joining us today   for this discussion on the office of management 
budgets changes to their metropolitan areas   definition it's good to see everyone i'll be the 
first to admit that i'm a little tired of this   forum or medium i look forward to the day when we 
can all kind of meet in person and see one another   again but thank you for your participation and 
attention it was stated earlier that the housing   assistance council is a national non-profit that 
supports affordable housing efforts in rural areas   of the united states and we do that through an 
array of activities one of those is to help inform   strategies solutions and policies oftentimes it's 
to help her i think most importantly to inform at   the local community based level to inform rural 
communities what policies and strategies and   issues mean for their community but also to help 
inform the larger debate and that's what we'll   try today we to do today we really look forward 
to your participation in your discussion on this   issue because it'll help inform i think our 
processes going further and the larger debate   thank you we're primarily looking forward to 
your insights and discussion on this issue today   but to help inform that discussion we prepared 
some really basic background information with   four major components the first of which is 
what are omb's metropolitan areas and what   are the proposed changes it's a really primer 
on the on the concept the second is how have mo   omb's metropolitan areas intersected with rural 
communities traditionally third we just really   briefly look at what are some descriptive what 
are the potential for some descriptive statistical   changes in the areas what would this mean and 
the fourth is what are the implications for this   change programmatically and practically on the 
communities you serve and the work that you do   we'll start with a really basic overview of the 
ombs metropolitan area concept and what are some   of the proposed changes to that long-term concept 
i could recite a really technical definition   but at its essence omb's metropolitan area is 
really in is a measure of economic connection   or connectivity to a core urban area and that 
urban area has traditionally been defined as   uh popular that one with a population of 50 000 
or more the kind of core area and then it also   encapsulates surrounding communities that have a 
social economic connection with that core urban   area primarily through commuting to work i 
mean then finally a fourth major component   is that it's county-based so it includes counties 
as its primary unit of geography although it   aggregates up to a combined metropolitan area 
it's a little more complicated than that and   i can elaborate more in the discussion but i'll 
leave it at those four major areas and that it is   unique in the concept in the area that 
it is a connection to a core urban area recently the office of management budget proposed 
some changes to its metropolitan area standards   this is really not that uncommon often 
in conjunction with the decennial census   they've presented changes and many of those 
are traditionally tweaks are relatively   innocuous or minor to help continually 
improve the product in this designation   but in this iteration there was one more 
substantial change than what we typically see   and that is that would basically change the 
core threshold of what defines the core urban   area and it doubles the threshold increases it 
from fifty thousand to one hundred thousand so   now in the proposed change um to qualify as a 
metropolitan area you'd have to have a core urban   area of one hundred thousand or more and that's a 
relatively substantial change to this designation to help put the proposed changes in perspective 
here's a really brief timeline of omb's   metropolitan area definitions over the long 
term and the very near term so this concept   was first developed in the late 1940s and 
was first really implemented in the 1950   census or after the 1950 census and changed 
every 10 years with the in conjunction with   the decennial census those were the major 
changes from the 1950s up until present day   again most of them the major changes came 
every 10 years and they were incorporated   oftentimes two to three years after 
the release of the decennial census   i know in 2000 the changes weren't incorporated 
until 2003 and similarly in the 2010 census they   came around 2013 the most recent set of standards 
there are minor changes from year to year are   from 2019.

So on january 19th 2021 omb submitted 
the proposed changes that we're discussing today   and those and comments on those changes are due 
on march 19 2021 and consistent with past years   the proposed changes are implemented 
or proposed to be implemented in 2023 to present an illustration of 
that omb timeline here's a map   of the original metropolitan 
areas in 1950 shaded in green and here are omb metropolitan areas in 1960 1970 1980 1990 2000 2010 and the most recent designation in 2019 which has 
relatively minor changes from the 2013 designation and we'll discuss this in more detail in a 
few minutes but the areas shaded in blue on   this map are communities that are estimated to 
lose their metropolitan area status as a result   of the proposed changes again this is just 
an estimate we don't have a definitive list   yet but these are the estimates based 
on the threshold populations in 2010. so you probably noticed in looking at those maps 
that they progressively got more green as the   years went on in essence there were just many 
more metropolitan areas and more metropolitan   territory and population added over the last 70 
years and this is another way to illustrate that   just from the inverse looking at i think what uh 
the dynamic that many of us on this discussion   are interested in the outside metropolitan areas 
so in 1950 around 45 percent of the population   lived outside of a metropolitan area but you'll 
notice this kind of steady trend line moving   down the proportion of the population to 2019 
where it's estimated about 14.1 percent of the   nation's population live outside a metropolitan 
area so a pretty standard and dramatic decline   in the outside metropolitan population and 
just a continued trend towards urbanization   and suburbanization in the united states over that 
period of time at least measured by this indicator and then an estimate of the proposed change so 
if those new thresholds were implemented it would   increase the outside metropolitan population an 
estimate up to around 19 or 20 percent again that   is an estimate but indicated in the line but blue 
in 2023 you would see an increase in the outside   metropolitan area designation simply because 
you would take away so many metropolitan areas before we get into a discussion of the 
changes the proposed changes the o and b   definitionaries i thought it might be instructive 
or helpful to briefly look at how this designation   has intersected with rural communities 
in rural areas over the long term   and currently so i will just qualify my comments 
here that at least from my perspective there is   no perfect definition of rural um some of you 
may remember um the the famous demographer from   the economic research service calvin beal and 
i often say if calvin didn't find the perfect   definition of rural it simply doesn't exist it 
kind of i think he had a career the holy grail   looking for that i would be interested to see 
what calvin thinks of this current circumstance   but i really do think there are pros and cons 
to every definition but i think increasingly   metropolitan and having a kind of an equation here 
that says outside metropolitan area does not equal   rural and i would say outside metro is qualify 
this is increasingly a bad proxy for rural um areas where the omb designation has some 
helpful elements but in many respects i   i think it's my consensus and a lot of my 
colleagues consensus that it is increasingly   not a good proxy for rural areas it's becoming 
more outdated and outmoded and just one comment   on semantics i know i think it's even the title 
of our presentation and you'll often hear the   term non-metropolitan or non-metro colloquially 
but technically that is an obsolete term it was   these communities were referred to as 
non-metropolitan prior to the 2013 designation   but that was changed in the 2013 designation 
and replaced by the term outside metropolitan   core based statistical area which is a mouthful 
so i know i still use the term non-metropolitan   non-metro from time to time but we primarily 
try to adhere to the outside metro vernacular i know this is going to sound like an 
airing of grievances but there are three   or four structural or systemic elements of the 
omb classification they're just simply problematic   in the rural context and the first of which 
is what we would classify as the either or   problem i mean this is not exclusive to omb 
like many classifications it is dichotomous   meaning there are only really two indicators for 
example metropolitan or outside metropolitan our   census defined urban or census defined rural or 
another example is usda's eligible area definition   for its housing programs either you're eligible 
or you're not and in reality this dichotomous   component really ignores the fundamental reality 
of residential patterns in the united states   so to put a finer point on this approximately 
half of all americans live in a suburban community   but in this binary context that suburban 
population invariably gets lumped within into   either urban or rural or metro or outside metro 
populations and it distorts and often distorts or   dilutes that dynamic in that in that context just 
to show give you a geographic example in addition   to the population standard the map to the left 
all those areas indicated in yellow or orange   light orange are suburban or x-urban communities 
classified by the housing assistance council   the omb designation also suffers 
from the residual problem   in that it's a very urban centric classification 
so it goes into great detail about   how a metropolitan area is defined but if you 
are not in that metropolitan area there is no   definition you're just the other than you're 
the residual you're outside of that so it   provides no discussion or analysis of rural 
residential patterns it's simply based on   the omb metropolitan area and if you don't 
meet that classification you really are just   outside of that simply stated that's what that's 
what those communities are there's no designation   or no analysis for that particular dynamic 
it's just outside other than or the residual the omb classification increasingly has structural 
concerns and i think this is a problem or concern   regardless of whether it's inside metropolitan 
or outside metropolitan so the omb classification   is traditionally relied on two major indicators 
one of which is just basic population counts and   other commuting patterns but increasingly 
many modern definitions of residential   residential pattern rely on population density 
or housing density and i think some of that is   just because we have more computing capacity 
we have the ability to actually do this now but   in some respects this dynamic or this paradigm 
might be coming increasingly outmoded or outdated   to provide a potential illustration of that 
structural problem here's a map and all of   the areas outlined are the metropolitan areas that 
we've previously seen in the maps that were green   on in this shade in this map there's a different 
shade of green where we believe at the housing   assistance council all of those areas shaded in 
green even though they are metropolitan areas   where they have an outline in those shaded 
and green are actually what we would classify   as rural or small town territory so you 
see again that incongruity between the   rural and small town population i think this 
is probably a function increasingly a function   of that structural problem on the unit of analysis so this is the end of the airing of grievances for 
outside metropolitan areas but i do think there is   another and again increasing concern what we call 
the geography problem particularly as it relates   to rural areas so the as i noted before the omb 
primary unit of analysis is the classification   at the county level while counties definitely have 
advantages most people understand where they live   and they're often associated with in social 
economic and political terms the county is not   optimal in many designations and that's because 
it just vary so much across the united states   particularly in the western united states where 
you have very large counties and i'll probably   provide an example of that and i think 
this also parlays just simply into that   discussion where in the past we we 
used the county we didn't have the   computing capacity or the ability to do 
sub-county analysis and now we simply do   this is an example of the geography problem it's 
uh with omb metropolitan areas it's often used   and i should probably find something a little 
more creative but i will resort to it as well   so san bernardino cali in california is one 
of the larger counties in the united states   very large territories combined here with 
riverside county but simply stated this   county probably has you know more land mass 
than several northeastern states combined   but yet in this area it's some of the more remote 
and forbidding territory the mojave desert so if   you learn one thing from today's presentation it's 
that the mojave desert is metropolitan but there   you'll notice there are other large counties 
in the west that kind of suffer this problem   we have relatively large territory and some of 
that is very rural territory but it's encapsulated   into the metropolitan area because of the 
county level designation there's another really   good example in minnesota st louis county which 
includes duluth at the very bottom tip but it goes   all the way up to the canadian border a very large 
county and again some of the more remote kind of   canadian north woods and minnesota northwoods 
another example of this issue so it really   illustrates the variation in the county sizes and 
another problematic issue with metropolitan areas we discussed the progression and some 
of the structural elements of omb's   metropolitan area classifications so now we'll 
turn to some of the proposed modifications and   that how that might alter the composition 
of outside metropolitan area communities   obviously this is going to vary from market to 
market but we did provide a few estimates for   selected social economic and housing 
indicators to determine what impact   the changes may have on again the composition of 
those communities it's important to stress that   these are simply estimates and we wouldn't 
know until we got the exact census numbers so we've alluded to this dynamic of residents 
in this discussion before noting that in some   metropolitan areas you would have both urban 
suburban and rural and small town territory in   some of those communities we highlighted a 
map before and typically that dynamic goes   one way where in in metropolitan communities you 
can have all three of those dynamics but outside   metropolitan communities are are basically rural 
and small town communities as illustrated here so   under hax definition where we try to classify 
uh identify urban suburban and rural and small   town communities currently that we there are 
no suburban or ex-urban communities outside   of metropolitan areas but when you include the new 
designations about 74 percent of the population in   those estimated areas that would now revert back 
to outside metropolitan areas are suburban and   ex-urban population about nine percent is urban 
and about 20 percent is rural and small town so   that would be a dramatic change usually it goes 
the other way but this is the indication where   you would start to absorb suburban and urban 
population within outside metropolitan areas in terms of absolute population around 14 percent 
of the us population currently live outside of   metropolitan areas and about 85 percent live in 
metropolitan areas but under the new designation   that would increase to about 19.5 percent of the 
population living outside of metropolitan areas   um generally speaking i think the 14 percent of 
the population was a relatively low estimate of   if it were a proxy for rural communities but at 
the same time i don't know if the new designation   is adequately capturing a proxy for rural 
and small town population as previously noted the communities estimated to change their 
metropolitan status are slightly more racially   and ethnically diverse than current outside 
metropolitan communities as an example about   78 percent of the population in current outside 
metropolitan areas are white and not hispanic   and that declines slightly in the new 
proposed areas to about 74 75 percent   and for example african american population would 
increase from eight percent currently to about   10 percent and likewise for 
hispanics the hispanic population   would increase to about 10 percent 
in the in the new selected counties income levels are slightly higher in the 
new proposed outside metropolitan areas as   opposed to the current metropolitan areas as an 
indicator of the median household income currently   in outside metropolitan areas is roughly fifty 
fifty thousand dollars per year per household   somewhere around forty nine thousand dollars in 
the new counties that identified counties that   could change in metropolitan status the 
median income in those counties is somewhere   in the neighborhood of 53 000 or 54 thousand 
dollars annually and that in both of those   are substantially lower than the national u.s 
median income of 68 000 or somewhere above 68 000   so income levels would be a little higher in 
the communities poised for change i'm having   a little technical difficulty getting this graph 
to display but we also looked at one particular   housing indicator which i think is one of the 
more salient issues is just housing affordability   and there was um you know there are slightly more 
affordability challenges in the communities that   are poised for for change are referred to changing 
metropolitan status so the level of housing costs   burdened homes or units in those communities was 
somewhere in the neighborhood of 32 percent of the   occupied housing stock and in the current 
omb metropolitan areas it's roughly 29.2   so not a major change both of those communities 
have housing affordability challenges that are   not unsubstantial but probably not at the level 
of some higher level metropolitan areas as well i am somewhat confident that many of you joining 
us today are particularly interested in this   element of the discussion which looks at the 
programmatic implications of how this change   might impact your work and the services you 
provide to your communities and your stakeholders i really hate to disappoint you but this is 
largely where we are at with this dynamic so previously in this discussion i said 
i wouldn't recite the technical language   from the proposed rule but in this 
instance i will so this comes directly from   the proposed change omb establishes and maintains 
these areas solely for statistical purposes in   reviewing and revising these areas omb 
does not take into account or attempt   to anticipate any public or private sector 
non-statistical uses that may be made of the   delineations these areas are not designated to 
serve as a general purpose geographic framework   applicable for non-statistical activities 
or for use in program funding formula   so i remem remember reading this passage or 
something very similar to it when i first   became engaged in this in the early 2000s in the 
2003 um omb designations and thinking that's odd   um and i'll have to say we noted earlier in this 
discussion of some of the structural challenges   or some of the structural problems with the omb 
designated metropolitan areas what i have to say   this is probably the largest of those challenges 
simply stated this position by omb just rely   belies reality there are hundreds of federally 
federally funded programs that administer billions   of dollars of aid that are often statutorily tied 
to this designation yet there is no effort or due   diligence for omb to take responsibilities 
for this element of their classification   simply stated it's very difficult to estimate 
the proposed changes programmatically so while we can't provide any detailed analysis of 
the programmatic impacts here are a few examples   of several programs selected programs that 
could or could not that's the operative word   be substantially impacted by these 
changes in omb metropolitan areas   and the first of which that comes to mind is 
hud's community development block grant funds   where one could envision and we've tried to read 
the statute and regulations and it is somewhat   unclear somewhat contradictory but potentially um 
you know they're entitlement communities are tied   to metropolitan areas and if a community lost 
its metropolitan area status then conceivably   it could also lose its entitlement status and 
therefore go into the competitive pool with other   non-entitlement communities which could have a 
major implications for not only that community   but the larger competitive 
pool that's just one example at another level area median incomes which 
are often very important for administering   many of the resources and programs that you work 
with are frequently tied to metropolitan areas   and one could envision if a community lost its 
metropolitan area status that it's no longer tied   to a larger potentially a larger metropolitan 
area and would have radically you know have   a radical change in its area meeting incomes 
almost overnight i neglected to mention in this   discussion that one of the positive attributes 
often associated with omb metropolitan areas   is it's relatively simple and easy to understand 
and incorporate i cannot say the same for usda's   rural housing service eligible areas definition 
this is probably one of the more complicated   definitions of rural or eligibility that i've 
ever seen however interestingly enough within   that it actually uses usda definition uses omb 
metropolitan areas what i would classify as   an adjustment factor so i won't go into detail 
but there could be downstream ramifications or   residual ramifications from the change in the omb 
metropolitan area on usda eligible service areas again this is the map those counties shaded 
in blue would be communities that potentially   would lose their omb metropolitan status and 
revert back to outside metropolitan areas   and one could envision the changes in the usda 
provision of both single single family direct   and guaranteed mortgage originations in 
these communities it's hard to estimate   but there would definitely be likely be 
impact in these communities because of that again at another level hud's fair market rents 
are often pegged to a metropolitan or geographic   area that could have significant changes on the 
fair market rents it's again very difficult to   establish but one could imagine that there could 
be potential ramifications for the changes in fair   market rents particularly those communities 
that would lose their metropolitan status   and finally from yet another perspective 
the omb metropolitan area definition has   been relatively stable and constant over the 
last 70 years and that has allowed researchers   and analysts to conduct a large scale kind of 
longitudinal analysis over a long period of time   i'm not as sympathetic towards this particular 
issue but i'm also a researcher and it has value   again we at the housing assistance council have 
increasingly try not to use omb metropolitan   areas for statistical purposes for many of 
the reasons we identified earlier in this   discussion that it's simply not that good but in 
many instances we are at the mercy of these data   because there are no other data a good example 
is the kovid 19 analysis is really only done   at the metropolitan area similarly some of 
the impacts of coven 19 we can only look at   unemployment rates at from omb metropolitan 
area so again very difficult to to determine   but undoubtedly if you were to change radically 
alter the definition or the classifications as   much as they are proposed this would definitely 
alter research and longitudinal analysis purposes i did not purposefully include this photograph 
with the stop sign for this particular slide   but it might be a good metaphor or a good 
indication on how we do proceed or how the   omb proceeds we noted several examples of 
structural challenges of this classification   and definition particularly as they relate to 
rural communities or outside metropolitan areas   it seems as if omb had a good opportunity here 
during this process to address some of those   and really what we see is potentially even 
newer greater concerns with this particular designation so comments on this 
issue are due to omb by march 19th   and you can find a link to 
submit your comments below   on this slide the housing assistance council 
will post this presentation and additional   information such as interactive maps and the list 
of potential communities that may lose their omb   status you can also get more information at 
hacc's website www.ruralhome.org i thank you   very much for joining us today we look forward 
to the discussion and garnering your insights and   expertise and perspective on this important 
process and how we should move forward so thank   you very much i'm going to once again include 
the information on how to submit the comments all right thank you lance for that presentation 
um seeing a lot of activity in the chat so i'm   pulling up some of these questions uh do you 
have any comments right after the fact just to   uh i i do dan can you hear me yes um first of all 
i'd like to thank everybody again for joining us   we're going to get to a couple of questions 
i saw a few popping up in the chat   but again we really appreciate everyone's 
participation in attending today   this is a really important issue it's 
relatively new and complicated as you can see   and we at the housing assistance council really 
value your input and your insights to help inform   our comments on this but also they help to 
inform the entire community so we try to   provide a little bit of background information 
but we really value and look look towards your   comments to help inform this process as well 
and i would also just reiterate and reinforce   that comments are due um we i think there's a 
lot of power in the regulatory comment system   so i think we need to hear from everyone comments 
are due or would try to mar about 10 days from now   march 19 2021 and we will provide additional 
information on how to submit your comments   or upload your comments and hopefully the housing 
assistance council will have more information but   we really wanted your input before we finalize 
some of our comments or our input on this issue   so i think i'll open it up to questions i did see 
a couple that i'll probably just jump into dan and   i think i really appreciate the community that's 
one of the values of this medium i have to say   sometimes i don't have to answer the questions 
because some in the community we're already   answering those questions there was a really good 
question about micropolitan areas and this is this   is important it is it was a new designation added 
to the omb metropolitan area standards around 2003   i mean it incorporates primarily communities below 
the metropolitan area threshold the traditional   metropolitan area threshold but with a population 
of urban population from 10 000 to 49 999   the important thing here and why we didn't talk 
about it that much is it's relatively new i would   welcome conversation on this it's not widely used 
in my experience it's often used more for academic   purposes it's not as widely used as the 
delineation between outside metropolitan   traditional and metropolitan but i don't 
think that to the best of my understanding   and i could be corrected on 
this within the proposed changes   that the omb micropolitan areas are slated for any 
change and that's why we also didn't include it so   it's a relatively new concept and in my 
experience not widely used so we wanted to   primarily focus on where the where most 
of the changes were in this discussion i also saw dan and i'll just react to one other 
i'm sure i missed them but i was trying to scan   the chat um on the map so the housing assistance 
council did produce some maps as you can see   there is a map that's attached to the comments 
that the federal register presented um and and   that's an it's an appendix of what they also 
estimated although we have in some of our analysis   we have some questions on how that was calculated 
we could not entirely replicate that um we got   very close but there were a few communities that 
we just simply couldn't replicate in our analyses   and i think it's important to note that all many 
of these presentations of the data were based on   estimates and you wouldn't know the exact number 
or the exact figure until the release of the 2020   decennial census so it's very close there's also a 
little bit of confusion um within the ombs and if   this is minor this gets into more geography speak 
whether it was urban area or urbanized area so   we will present that map but you can also 
find maybe a more slightly more official map   uh connected to the omb rule that will also 
will also submit or will also post as well so   i hope that helps answer that particular question 
but there's somewhere in the neighborhood   of 250 counties that potentially again that's 
the operative word potentially could lose   their metropolitan area designation 
if these standards were enacted okay thank you for that lance uh there's a few 
questions out there a few along the lines of uh   this is asking you to break out your crystal ball 
but how likely do you think this is to be enacted   these the definition change considering there's 
a new director of omb and other things like that   um i'll be candid i don't know if i have 
insights on that particular process i mean   traditionally it's gone through this process this 
was nothing new we all would always get these   proposed changes or right around the decennial 
census but there were never really of this   magnitude or this gravity right that is a pretty 
substantial change when you're doubling the the   population threshold for a metropolitan area urban 
area or urban core status for a metropolitan area   so i'll be i'll be honest i don't know if i have 
a crystal ball we've been in conversations with   other colleagues and and other experts around 
around this issue um it has traditionally   proceeded but we hope that your comments and your 
input can help influence this decision candidly   and along those lines uh joshua stewart asks uh 
if omb specifically denies programmatic slash   funding impacts is something they will 
take into account when weighing comments   how can we best be persuasive 
or impactful with our comments um this uh i think this is a really robust 
discussion from um an august group i would   say so we really appreciate that we are still 
formulating our comments but i think it is   um one of the major themes that's coming out 
of this is and i would just point back to that   stop sign that omb probably needs to stop and 
revisit this entire issue notably around some of   the systemic issues that rural communities have 
been long overlooked in this designation even   before the changes so there just needs to be more 
attention and candidly just an acknowledgement   that this even though it states that they 
deny kind of any plausibility or there's uh of   impacting larger issues outside 
of that statistical definition   it does there's no doubt that you can document 
it's based in statute so um i would hope that   they would listen to some of the comments or 
the um positions from from community members   and how this might impact your actual community 
but it's very difficult to estimate that as well and uh you mentioned that county is not 
necessarily a good measure to identify   rural communities um what level of geography do 
you think we should focus on i would i would go   back and almost contradict myself dan and say 
that county is not optimum um and but there is   no probably perfect designation in many respects 
many of you know and i often say this question   um uh you probably everyone on the call knows 
what county they live in but i would challenge   almost anyone to tell me what you know the 11 
digit number census tract that they live in   so i think that's a challenge but increasingly 
we at the housing assistance council   use census tracts because it provides a more 
granular level of analysis so it has its pros and   cons as well like there's you know they're only 
around 3 000 counties and again many people are   much more familiar with that unit of analysis 
or that unit of geography because of their   political social and economic lives there are 
over 72 000 and with the new decennial census   there'll be more than 84 000 census tracts so it's 
a little more unwieldy and i noted this before   at least from the statistical purposes we didn't 
even at the housing assistance council probably   have the computing capacity to do some of this 
work uh eight or ten years ago but now we do   um and that's helped inform our work where we 
increasingly move to uh the census tract as   the unit of analysis but you can very easily 
aggregate back up to a certain community um but there's no perfect definition there 
either i'm also in that one hand other hand um okay uh are there any other changes 
um beyond the urban area threshold that   were presented in the recommendations so there 
are a few additional changes that were presented   and those would be more along the line what i 
mentioned before uh in this process every 10   or 12 years you would get some almost around 
the edges changes that would be incremental   improvements one of those uh i think there are 
there are several of them some of them i i believe   are positive to have typically instead of larger 
increments where you update the status they would   be they would become in shorter frequency so you'd 
have more updates that would be more up to date   they discontinued uh there was a special 
designation for northeastern communities and they   proposed to discontinue that that unit of analysis 
um and i think there was a more robust effort at   uh help trying to define u.s territories with with 
omb status so not all territories i think have   this designation and there were some suggestions 
around that and also to continually rely on the   american community survey in this process but they 
also state generally in that process um about uh   you know working towards improvement so we think 
that's a positive as well but what's taking up all   the oxygen in the room is this threshold increase 
to um that doubles the threshold increase and the   rationale for that was simply that well population 
has doubled since this was first enacted but that   is a pretty blunt force instrument way to 
to remedy or rectify that particular issue all right uh steve hirsch also points out that 
uh the prior change took several years uh to   implement this is offering a 60-day window so 
that's just a interesting changed a note it looks   like we don't have any more questions in the chat 
directly if you'd like we can open up the lines i   can we have a hand raised and we can allow some 
people to ask questions verbally if that works um looks like uh   bonnie nichols uh has her hand raised uh i've 
set it to allow you to unmute so go ahead and if anybody does want to ask a question you 
can go ahead and hit the raise your hand button   it's one of the emotions that's listed at the 
top of the screen and we'll get you in here um we in lieu of that we did get a question 
in chat are there any indications that the   change in classification would be accompanied with   additional funding and or resources for 
rural areas i i would i i think i could   i don't know this gets into the crystal ball 
dan i would say yeah i would i would speculate   but at the same time i do think this is if if some 
of these changes are enacted at the end of the day   i think many programs or many uh administrations 
that administer these funds can look back at that   omb designation and say this is for statistical 
purposes only and that we can make modifications   to some of our programmatic delineations under 
this relatively radical change i would hope that   that would be considered by agencies and efforts 
that command those resources at the very least okay well i am not seeing any 
additional questions um so   uh lance do you have any um final thoughts for 
anyone oh wait no tom collishaw getting in there   uh how do you think these regulations 
will line up with the 2020 census   so i like tom i can't speak directly 
to that but i think oftentimes they are   using my rural colloquialisms part and parcel 
of the decennial census so this process really   changes every 10 years um and it will it will 
align in conjunction with the 2020 census   interestingly enough i would say i'll make one 
comment since we have a couple of minutes here   when you look at this statistically 
kind of like the data geeks that we are   you see some anomalies show up in rural 
communities within this analysis many of   these communities that are potentially slated 
to lose their lose their metropolitan status   not all of them but several of them pop up 
they are university towns that are probably   influenced by uh students that are in those 
communities and when tom mentioned the 2020 census   one of the major challenges with getting the 2020 
census numbers is that most college students have   not been on campus for a year and it's been really 
hard to document and enumerate that population   and that could you know even further 
impact this particular issue because   you you do note um oftentimes we see this in 
rural analysis where you see these minor anomalies   really in cost burden and some other social and 
economic elements and you look and you say how   is that little island there what's going 
on and oftentimes it's a college town and i   think this in this instance related to the 2020 
census i know that's somewhat of a non-sequitur   tom but i would say college towns 
could be more impacted than others   purely from just looking at the map 
and making some some off the cuff projections okay well if there are no further questions um i 
think we can let you guys go a little bit early   um uh so first of all i'd like to thank lance for 
that presentation and all of you for bearing with   us through some technical difficulties early 
on um and just as a reminder uh recording this   webinar and the presentation will be available 
on our website which is www.ruralhome.org   uh later on this week and uh once again 
i'd like to thank you all for joining us   just one more plea again thank you all i had to 
dance thanks thanks the hack team for putting   this together but um a couple of points just 
to reiterate the importance of being heard here   you we really would ask that you able you're able 
to if possible to weigh in we'll try to facilitate   that if we can but that is extremely important 
this has been a relatively short process as you   know it's only 60 days and this is a lot of 
information to digest and consume but it is   it could have relatively substantial ramifications 
for rural communities so one thank you so much for   your participation and your interest but you are 
the most valuable entities here in letting people   know how this could impact you and we'll try to 
facilitate that but this is an iterative process   so don't hesitate we'll be posting materials but 
also don't hesitate to contact us if you have   additional questions or insights is what we're 
really looking for so thank you very much all right so again thank you all for joining us 
and um we hope you enjoy the rest of your day thank you take care

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