Targeted Employment Areas (TEAs) – “Political Subdivision”

Question: What is the meaning of a “political subdivision” in 8 CFR § 204.6(i)? What are the limitations in labeling an area as political subdivision? (Assume that the high unemployment data yields a qualifying rate.) Explanation: The common meaning of the term political subdivision refers to a civil administrative unit of the government such as a county or city. Yet, the US census Bureau provides data based on elections districts. Are elections districts such as congressional districts, state representative districts, state senatorial districts, county supervisor districts, city council member districts qualify as political subdivisions for the purposes of high unemployment are designation?

Answer: According to Black’s Law Dictionary (8th ed. 2004), a political subdivision is a division of a state that exists primarily to discharge some function of local government. The examples provided above appear to meet the legal definition of a political subdivision.