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Public Opposition Comment – Food Bank of Contra Costa and Solano

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Public Opposition Comment – Food Bank of Contra Costa and Solano April 1st, 2019 Certification Policy Branch SNAP Program Development Division Food and Nutrition Service, USDA 3101 Park Center Drive Alexandria, Virginia 22302 RE: Proposed Rule: Supplemental Nutrition Assistance Program (SNAP): Requirements for Able- Bodied Adults without Dependents RIN 0584-AE57 Dear Certification Policy Branch: The Food Bank of Contra Costa and Solano has been fighting hunger since 1975, giving out free food to community members in need. We store donated and purchased perishable and nonperishable food items, distributing them through our own programs and via our community partners. We operate 8 direct distribution programs and make food available for nearly 200 other nonprofit organizations serving people in need of food assistance. Our organization has grown dramatically over the last decades, and an alarming 1 in 8 people within Contra Costa and Solano counties turn to the Food Bank for emergency and supplemental food. In order to meet this incredible demand for our services, the Food Bank has grown to rely on more than 1,000 volunteers a month, over 70 staff members, a large fleet of trucks and two facilities totaling 70,000 square feet to procure and distribute food and grocery items. In Contra Costa and Solano alone, we serve about 178,000 individuals every month and distribute over 22 million pounds of food each year, over half of which is fresh produce. The Food Bank serves our community passionately and efficiently, but we know there continues to be unmet need. Many of the people we serve are only able to make ends meet through the combination of Food Bank groceries and Supplemental Nutrition Assistance Program (SNAP) benefits. For every meal we distribute, SNAP provides 12. If a significant number of community members were to lose eligibility for SNAP, our Food Bank would not be able to fill the gap and people would go hungry. It is for that reason that we take the opportunity to comment in opposition to USDA’s Proposed Rulemaking on SNAP requirements and services for Able-Bodied Adults without Dependents Ending hunger together (ABAWDs). Harshening SNAP time limits and taking away someone’s food increases hunger, not employment. According to the USDA itself, up to 570,000 Californians could have their food assistance threatened if this proposed rule were to go into effect. Contra Costa County’s ABAWD waiver is already set to expire in September 2019, and an estimated 3,900 - 4,600 people will lose the entirety of their food assistance as a result. We have been working diligently with Contra Costa County for over a year to prepare for these time limits and the expected increase in hunger (See Appendix 1.) If this proposed rule goes into effect, thousands more individuals in Solano County and across the vast North State region that our organization also services would suddenly be impacted as well, increasing their demand for our limited resources with very little time to prepare. SNAP Works In Contra Costa County Contra Costa County’s current ABAWD waiver will expire on August 31, 2019, and the Food Bank has been working for over a year to convene county administrators, Employment and Training (E&T) providers, community based organizations, and other stakeholders in preparation for the re-instatement of ABAWD time limits. (See Appendix 1) Despite the overall improvements to our local economy, the need for SNAP (CalFresh) remains high. Currently 10.1% of Contra Costa residents live below the official poverty level. The California Poverty Measure, which takes into account the cost of living and in-kind benefits, calculates that the poverty rate is really 14.8% in Contra Costa. According to the Public Policy Institute of California, poverty in the Bay Area would increase by 4% without safety net programs like CalFresh. According to a recent Contra Costa Employment and Human Services Department report, there were an average of 27,743 CalFresh cases in 2017. This represents 64,666 individuals. Forty- eight present of these individuals are children under the age of 18. The average monthly benefits issued in Contra Costa equaled an average of $8,816,127 each month. Given that every $1 provided in CalFresh benefits generates $1.79 in economic activity, in 2017 CalFresh brought $189 million into our local economy. The 2017 unemployment rate in Contra Costa was 3.6%. While this is less the current national unemployment rate of 3.8%, certain groups experience more barriers to work and much higher rates of unemployment. For example, the unemployment rate in Richmond, a predominantly- Ending hunger together African American city in West Contra Costa, was 4.5%. In spring 2018, California's overall unemployment rate sat at 4.2 percent. However, the Black unemployment rate was more than twice that of white Californians and 1.6 times higher for Hispanics. The unemployment rate in East Contra Costa, where public transportation is limited and fewer jobs are available, was 6.3%, significantly higher than the county average. As rents skyrocket in the urban core communities in the Bay Area, more and more people are getting pushed out to the rural, Eastern regions of Contra Costa where rent is cheaper. However this means that they live further away from where most jobs and community resources are located. Many of these individuals don’t have cars and it can take hours by bus to get to an E&T program, a job interview, or a job itself. (See Appendix 2) Far East Contra Costa County (including the communities of Bethel Island, Knightsen, Byron, Discovery Bay) can be considered a “transit desert,” as it lacks adequate public transit service and includes populations that are deemed transit-dependent. The Contra Costa Employment and Human Service’s Department found that as of May 2018, there is no public bus service farther east than Brentwood. Bus service into Discovery Bay was eliminated at the end of May 2018. There is no public bus service farther west than Oakley. This is particularly noteworthy, considering that 43% of ABAWDs in Contra Costa live in East County. (See Appendix 1) According to a report by the Workforce Development Board of Contra Costa, the most promising job sectors for Employment & Training are the healthcare industry, transportation and warehousing, and the construction sector. However all of these sectors often experience unpredictable schedules and often requires specific educational or on-the-job training. (See Appendix 1) The Contra Costa residents that are covered under the current, but soon to expire, waiver are incredibly vulnerable, despite the overall improvement of the economy. According to a March 2018 report from Contra Costa between 3,900 and 4,600 individuals will be at risk of losing benefits due to the ABAWD time limits. The majority of ABAWDs (61%) are men, and the vast majority are English-speaking (98%) and US citizens (97%). African Americans are disproportionately impacted by the time limits, representing 33% of ABAWDs compared to 9% of the overall population. Nearly half of all ABAWDs are under 30 and 8% are under 20. ABAWDs under 20 were the age group most at risk of losing benefits due to the time limit, with 89% of 18 and 19-year-olds estimated to have their benefits cut off. (See Appendix 2) Ending hunger together According to a county survey of ABAWDs nearly one-third (30%) of were currently working, though less than half were regularly working over 20 hours per week. The most common sectors people listed working in were retail and office work. (See Appendix 3) Of those who were unemployed, nearly half (45%) had been out of work for more than one year. Although over two-thirds (68%) of respondents said they were searching for a job, respondents reported several barriers to employment. Over two-thirds (69%) said they did not know of companies who were hiring near where they lived, and roughly one-quarter of respondents said they did not have references (29%), had gaps in their work history they could not explain (23%), or did not know what pay to expect (28%). Over 21% of respondents did not have a permanent place to live, were at risk of eviction, or homeless. One-third reported having a health condition or disability that impacted their ability to work. Nearly one-fifth (18%) said they were a caregiver for a dependent child or adult. Additionally, half of respondents said they did not own a car and over one quarter (29%) did not have a driver’s license. (See Appendix 3). The vast majority (95%) of respondents had graduated from high school, with 30% having only a high school diploma or GED. The remaining two-thirds of respondents had attended some college, had a college degree, or a career certificate. Still, over one-third (36%) said they were interested in taking community college classes and 40% said they would be interested in a job training and placement program. (See Appendix 3). Participation in an E&T program can help an ABAWD meet the work requirements and maintain CalFresh eligibility, but only 36 of California’s 58 counties offered such a program in 2018. Luckily, both Contra Costa and Solano counties have E&T programs, but neither is able to provide enough slots for all ABAWDs. Contra Costa County contracts with the Foundation of California Community Colleges to offer the Fresh Success program. Fresh Success participants gain access to educational programs and training to improve basic skills and improve employability (e.g. through English language learning and high school equivalency) as well as programs that provide career technical/vocational training and education. Participants also receive services such as career counseling; interview training; resume development, job search, and placement (E&T Job Club); job retention services; and other supports to reduce barriers to program participation such as reimbursement for transportation, textbooks, and supplies.
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