[HOT] California State TEA Procedure Info

California is now allowing a special "third-step" option of qualifying census tracts (by combining 12 or fewer contiguous census tracts), in addition to the pre-approved areas composed of counties, cities, MSAs and CDPs.

See: http://business.ca.gov/Programs/EB5Program.aspx

Now, what I don't understand is the content of the recommended EDC Template Letter which contains the language stating that the signing entity "concur that the project will draw employment from the list of contiguous Census Tracts provided." I guess this is not problematic since this language can be read as saying the project will draw employment from the regional center geographic area which contains the area carved out by the attached contiguous Census Tracts.

I think this is due to CA state realizing that 1) other states are more liberal than CA when it comes to the TEA designation requirements; and 2) EB-5 statutes, regs and USCIS policies do not prohibit TEA certifications based on a large or small subarea composed of contiguous Census Tracts.