Comment on FR Doc # 2010-09645

June 21, 2010 Ms. Laura Castro, Branch Chief Policy Branch Food Distribution Division Food and Nutrition Service U.S. Department of Agriculture Room 500 3101 Part Center Drive Alexandria, VA 22302-1594 RE: RIN 0584–AD12 Food Distribution Program on Indian Reservations: Resource Limits and Exclusions, and Extended Certification Periods Dear Ms. Castro: The Center on Budget and Policy Priorities is a non-profit, non-partisan organization that works to improve government policies and programs that affect low-income populations. We have a long history of working with USDA on the federal food assistance programs, and we appreciate the opportunity to provide comments on the proposed rule to address resource limits in the Food Distribution Program on Indian Reservations (FDPIR). While CBPP has not traditionally worked on FDPIR, we are concerned by the proposed rule, which would maintain asset limits for FDPIR eligibility even as USDA encourages states to eliminate asset tests in the Supplemental Nutrition Assistance Program (SNAP). We strongly encourage you to extend to FDPIR the same asset policy as exists in SNAP. As Administrator for the Food and Nutrition Service during the Carter Administration, I worked with the agency to establish the FDPIR program after its creation in 1977. FDPIR is an alternative to SNAP for low-income households, including people living on Indian reservations and American Indian families residing in designated areas near reservations and in Oklahoma. The program, which is an entitlement to these individuals, provides nearly 100,000 participants with commodities in lieu of SNAP benefits every month. It is particularly important to families that are not well served by SNAP, typically because they live in remote areas without good access to SNAP offices or authorized food stores. These individuals choose to receive commodities through FDPIR rather than EBT benefits through SNAP. USDA has worked to keep FDPIR eli