Comment from Bud Squirrel

DEPARTMENT OF AGRICULTURE Food and Nutrition Service 7 CFR Part 253 [FNS–2008–001] RIN 0584–AD85 Food Distribution Program on Indian Reservations: Administrative Funding Allocations CHEROKEE NATION The Cherokee Nation Food Distribution Program is strongly in favor of adopting the funding methodology which allocates program administration funds by a ratio of 65% based on number of clients served and the remaining 35% based on the number of FDPIR programs per region on a permanent basis. The previous funding methodology which had been used since the program’s inception was grossly indefensible. When we questioned Food and Nutrition Service (FNS) administrators about the inequities in funding, we would get the bureaucratic answer “that’s the way it’s always been done”. In some years, the Cherokee Nation would serve the highest number of clients on a National level and would still receive almost a million dollars less in funding than the tribe which served the second greatest number of clients. While the new funding formula would benefit the Cherokee Nation Food Distribution Program, FNS would also benefit by increasing the integrity of their operations because of having a documented procedure to distribute administrative funding on a perceivable equitable plane.