CITY OF SMYRNA TREE CANOPY COVER STUDY FINAL · PDF fileplaced one-half inch apart, ... They...

CITY OF SMYRNA TREE CANOPY COVER STUDY FINAL REPORT OF RESULTS

February 5, 2010

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INTRODUCTION

In November 2009, as part of the city’s 2009 Urban and Community Forestry Grant, the City of

Smyrna conducted a measurement of its existing tree canopy and other land cover within the

city limits. The study was sponsored by the City of Smyrna and the Smyrna Tree Board and was

completed with the support of Ms. Sharon Harper, horticulture and agriculture teacher in the

Science Department at Campbell High School, and 60 of her students who analyzed and

measured the land cover. The study was coordinated by Connie Head, Consulting Urban

Forester with Technical Forestry Services, who also prepared this report.

The 60 student volunteers and Ms. Harper

collectively dedicated more than 420

hours, first in a 1-hour classroom

orientation exercise on Monday,

November 16 and then in a 6-hour analysis

and measurement session at the Smyrna

Community Center on November 18.

Additionally, Smyrna Tree Board volunteer

members Michael Streger, Gretchen

Musser, Carl Valenzano, and Mary Long

spent several hours preparing for the study and a total of 15.5 hours on the day of the study

guiding the students.

METHODOLOGY

The study was completed using aerial photography flown in February 2009. Printed aerial

photographs were produced by Mr. Clarence Blalock, GIS Manager in the Community

Development Department of the city of Smyrna. Mr. Blalock, with the assistance of the city’s

GIS intern April Herrett, designed and printed the 39 aerial photographs, each 18 by 18 inches

in size. The photographs were printed at a scale of 1 inch on the photograph equal to 300 feet

on the ground. Figure 1 shows an index map with the layout of the 39 photographs or “tiles”.

They are arranged in rows A through I, and numbered A1 beginning at the upper left to I1

located at the bottom.

City of Smyrna Tree Canopy Cover Study Final Report of Results February 5, 2010

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Each photograph was covered with a grid of yellow dots, one-sixteenth inch in diameter and

placed one-half inch apart, equivalent to 150 feet on the ground, as shown in Figure 2. These

dots essentially represent measurement plots. The students, working in teams of two (2),

Figure 1. Index Map of the City of Smyrna and Location of Aerial Photograph Tiles


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identified the land cover type beneath each yellow dot (within each plot), color coded the dot

directly on the photograph, then counted the dots by category, and finally recorded the results

on tally sheets. Each photograph was reviewed and the dots re-counted at least one (1)

additional time by another team of students. Then, the consultant reviewed, re-coded in some

Figure 2. Sample Aerial Photograph with Dot Grid, City Limit Line (purple), and Photograph Match Line (red)


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cases, and recounted all dots on all photographs to ensure the consistency of the categorization

and accuracy of the dot counts.

Land cover was divided into five (5) categories, as described below.

Tree canopy. This category includes all trees, whether hardwoods or conifers, deciduous or

evergreen, and of any size as long as they were distinguishable on the photographs. Since the

land was photographed in February, the majority of the hardwood trees were without leaves,

but hardwoods were still recognizable. Dots that fell on tree shadows that projected beyond

the tree’s canopy were not counted as tree canopy cover, but were instead categorized

according to the land cover type beneath the shadow. Tree canopies intercept precipitation

and slowly release it, increasing penetration of water into the soil and decreasing overland

flow. Tree canopies also cool the air temperature through evaporative cooling (evapo-

transpiration) of water from their leaves, and reduce surface temperatures by shading them.

Trees improve air and water quality, sequester carbon, and reduce heating and cooling costs.

They contribute to a community’s economic base by enhancing quality of life and increasing

property values. They also provide recreational opportunities and wildlife food and habitat.

Their functions and benefits are many.

Other vegetation. Shrubs, turf grass, vines (such as kudzu), and herbaceous vegetation that is

not covered by tree canopy was categorized as other vegetation. This other vegetation occurs

on pasture land, in vacant lots, on cut-over sites, on lawns, and along roads and in road

medians. Very small trees that were not recognizable as trees and did not project a shadow

were also included in this category. This other vegetation intercepts some precipitation, but

overland flow is increased on these surfaces as compared to tree canopy. And similarly this

other vegetation helps to cool surface air temperatures, but to a considerably lesser extent

than trees. The more the layering and complexity, the greater the texture, and the greater the

total surface area of the vegetation, the more benefits it provides.

Impervious surfaces. Any surface that is impervious to water, such as concrete, asphalt, and

metal, and any structure covered with such surfaces, such as streets, parking lots, driveways,

sidewalks and buildings, was categorized as impervious surface. Impervious surfaces that are

directly covered by tree canopy were categorized as tree canopy, however. All of the

impervious surfaces and structures shed precipitation, increasing overland water flow and

potentially flooding. They also absorb radiant heat and increase surface air temperatures.

However, if theses surfaces are covered with tree canopy, these negative attributes will be

somewhat reduced.


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Bare soil and gravel. This category includes areas where the soil was exposed or gravel was

present, such as on graded land, unpaved roads, some parking areas, in quarries, and along

railroad tracks. While water does penetrate these surfaces to some extent, the more compact

the surface the more similar it becomes to paved or impervious surfaces.

Water. Open water was found on the photographs in ponds, creeks, marshes, and swimming

pools.

RESULTS

There were 18,790 dots within the city limits and all were categorized, color coded, and

counted. Each dot represents an area of 22,500 square feet (150 feet by 150 feet) or

approximately .5165 acre. The total area of the city, based upon the number of dots that fell

within the city limits, is estimated to be 15.165 square miles, equivalent to approximately 9,706

acres. This total area estimate is within .005 square mile of the GIS Manager’s estimate of

15.17 square miles.

As shown in the summary on the right and by the raw data

in Table 1, tree canopy covers 39 percent of the land

within the city limits of Smyrna. Other vegetation covers

25.2 percent. Impervious surfaces cover 34.4 percent of

the city. Bare soil or gravel and water each cover less than

1 percent of the area within the city.

The amounts of tree canopy cover and impervious surfaces greater than 50 percent by map are

highlighted in bold type and shading in Table 1. There are seven (7) aerial photographs with 50

percent or greater tree canopy cover, and nine (9) aerial photographs with 50 percent or

greater impervious surface.

Land Cover in Smyrna (Feb. 2009)

P Tree canopy = 39.0% P Other vegetation = 25.2% P Impervious surfaces = 34.4% P Bare soil and gravel = 0.9% P Water = 0.5%


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Table 1. City of Smyrna 2009 Tree Canopy Cover Measurement Results

Photo ID

Total Dots

Tree Canopy Other

Vegetation Impervious

Surfaces Bare Soil or

Gravel Water Total Dots Dots Percent Dots Percent Dots Percent Dots Percent Dots Percent

A1 511 106 20.7% 141 27.6% 262 51.3% 1 0.2% 1 0.2% 512

A2 705 212 30.1% 126 17.9% 364 51.6% 3 0.4% 0 0.0% 706

A3 315 85 27.0% 149 47.3% 75 23.8% 4 1.3% 2 0.6% 316

A4 272 80 29.4% 39 14.3% 145 53.3% 0 0.0% 8 2.9% 273

A5 405 208 51.4% 45 11.1% 145 35.8% 1 0.2% 6 1.5% 406

A6 33 2 6.1% 9 27.3% 22 66.7% 0 0.0% 0 0.0% 34

B1 525 155 29.5% 146 27.8% 217 41.3% 3 0.6% 4 0.8% 526

B2 870 303 34.8% 224 25.7% 340 39.1% 3 0.3% 0 0.0% 871

B3 882 141 16.0% 251 28.5% 462 52.4% 26 2.9% 2 0.2% 883

B4 802 300 37.4% 212 26.4% 285 35.5% 4 0.5% 1 0.1% 803

B5 830 227 27.3% 152 18.3% 448 54.0% 1 0.1% 2 0.2% 831

B6 221 32 14.5% 36 16.3% 148 67.0% 0 0.0% 5 2.3% 222

C1 167 89 53.3% 41 24.6% 36 21.6% 1 0.6% 0 0.0% 168

C2 646 205 31.7% 133 20.6% 308 47.7% 0 0.0% 0 0.0% 647

C3 870 425 48.9% 223 25.6% 195 22.4% 27 3.1% 0 0.0% 871

C4 841 357 42.4% 207 24.6% 261 31.0% 16 1.9% 0 0.0% 842

C5 508 241 47.4% 95 18.7% 168 33.1% 4 0.8% 0 0.0% 509

C6 11 5 45.5% 5 45.5% 1 9.1% 0 0.0% 0 0.0% 12

D1 299 77 25.8% 121 40.5% 99 33.1% 2 0.7% 0 0.0% 300

D2 859 323 37.6% 320 37.3% 216 25.1% 0 0.0% 0 0.0% 860

D3 870 349 40.1% 258 29.7% 253 29.1% 0 0.0% 10 1.1% 871

D4 865 444 51.3% 195 22.5% 224 25.9% 0 0.0% 2 0.2% 866

D5 328 147 44.8% 79 24.1% 98 29.9% 0 0.0% 4 1.2% 329

E1 170 79 46.5% 53 31.2% 38 22.4% 0 0.0% 0 0.0% 171

E2 797 476 59.7% 180 22.6% 127 15.9% 10 1.3% 4 0.5% 798

E3 549 246 44.8% 148 27.0% 151 27.5% 0 0.0% 4 0.7% 550

E4 218 89 40.8% 44 20.2% 85 39.0% 0 0.0% 0 0.0% 219

E5 96 16 16.7% 26 27.1% 54 56.3% 0 0.0% 0 0.0% 97

F1 412 194 47.1% 120 29.1% 88 21.4% 3 0.7% 7 1.7% 413

F2 833 473 56.8% 113 13.6% 230 27.6% 13 1.6% 4 0.5% 834

F3 719 310 43.1% 186 25.9% 223 31.0% 0 0.0% 0 0.0% 720

F4 198 72 36.4% 41 20.7% 85 42.9% 0 0.0% 0 0.0% 199


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Table 1. City of Smyrna 2009 Tree Canopy Cover Measurement Results

Photo ID

Total Dots

Tree Canopy Other

Vegetation Impervious

Surfaces Bare Soil or

Gravel Water Total Dots Dots Percent Dots Percent Dots Percent Dots Percent Dots Percent

G1 153 85 55.6% 27 17.6% 41 26.8% 0 0.0% 0 0.0% 154

G2 456 236 51.8% 130 28.5% 85 18.6% 4 0.9% 1 0.2% 457

G3 582 244 41.9% 156 26.8% 154 26.5% 10 1.7% 18 3.1% 583

G4 425 92 21.6% 111 26.1% 214 50.4% 7 1.6% 1 0.2% 426

H1 172 71 41.3% 49 28.5% 51 29.7% 0 0.0% 1 0.6% 173

H2 231 98 42.4% 63 27.3% 43 18.6% 17 7.4% 10 4.3% 232

I1 144 38 26.4% 83 57.6% 23 16.0% 0 0.0% 0 0.0% 145

TOTALS 18,790 7,332 39.0% 4,737 25.2% 6,464 34.4% 160 0.9% 97 0.5% 18,790

The Natural Resources Spatial Analysis Laboratory (NARSAL) in the College of Agricultural and

Environmental Sciences at the University of Georgia, under the direction of Dr. Liz Kramer, has

measured Georgia land use trends using 1991, 2001, and 2005 satellite imagery and aerial

photography1. The data is available by county and metropolitan statistical area. While the data

developed using satellite imagery cannot be directly compared to the results from this study

using aerial photography, the findings from each study appear to support the findings from the

other.

The NARSAL data for Cobb County shows the following trends:

P In 1991 tree canopy in Cobb County was 53 percent and decreased to 47 percent in

2001 and to 44 percent in 2005, a loss of 19 percent of total acres of tree cover over the

period. Tree canopy cover in Smyrna in 2009 is 39 percent. The Smyrna results are

consistent with this downward trend in tree canopy cover across the county.

P In 1991 impervious surface was measured at 10 percent, and increased to 17 percent in

2001 and then to 21 percent in 2005, for a total increase over the period of 102 percent,

more than double. Impervious surface in Smyrna in 2009 is 34 percent. The Smyrna

results are consistent with this upward trend in impervious surface cover within the

county.

1 For information on the methodology used by NARSAL, please visit http://narsal.uga.edu/glut.html


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Tree canopy cover studies using the same dot grid methodology used in Smyrna have been

completed by the consultant in the last 3 years in Cartersville, Rome, and Jefferson, Georgia.

The results from those studies are as follows:

P The amount of tree canopy cover in Cartersville, Bartow County, as of February 2007

was found to be 50 percent, and the amount of impervious surface was found to be 18

percent. A total of 34,292 dots were categorized, color coded, and counted.

P The amount of tree canopy cover found in Rome, Floyd County, as of February 2008 was

49 percent. The amount of impervious surface was 23 percent. A total of 38,401 dots

were coded and counted.

P The amount of tree canopy cover found in Jefferson, Jackson County, as of February

2009 was 56 percent, and the amount of impervious surface was 11 percent. A total of

26,990 dots were coded and counted.

Compared to these communities, Smyrna’s tree canopy cover of 39 percent is considerably

lower and the impervious surface cover of 34 percent is considerably higher.

DISCUSSION

In general the greatest amount of tree canopy cover in Smyrna is found on undeveloped land,

in rural areas, and in older residential neighborhoods. The least amount of tree canopy is found

in commercial districts, especially in parking lots, on industrial sites, and in new residential

subdivisions, where significant amounts of trees are removed and replaced with impervious

surfaces and turf. Table 2 provides information on the general land use and zoning within the

area covered by each photograph. The land use descriptions were developed from looking

both at the photographs themselves, and a zoning map for the city of Smyrna.

Older, traditional neighborhoods contain an abundance of trees, which partially cover the

houses, driveways, and streets. In new residential developments, significant tree cover is

lacking and much of the land cover is other vegetation, primarily turf as well as impervious

surfaces in the form of non-canopied streets, houses, garages, and driveways.


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Table 3. General Land Use and Cover Percentages by Photograph

Photo ID General Land Use Description

Tree Canopy

Other Vegetation

Impervious Surfaces

Percent Percent Percent

A1 General Commercial, Single-Family Residential, Multi-Family Residential, Office Distribution 20.7% 27.6% 51.3%

A2 Single-Family Residential, General Commercial, Multi-Family Residential 30.1% 17.9% 51.6%

A3 Single-Family Residential (golf course), General Commercial, Neighborhood Shopping 27.0% 47.3% 23.8%

A4 Multi-Family Residential, Single-Family Residential, Industrial 29.4% 14.3% 53.3%

A5 General Commercial, Multi-Family Residential, Single-Family Residential, Office Institutional, Wooded Areas 51.4% 11.1% 35.8%

A6 Multi-Family Residential, General Commercial 6.1% 27.3% 66.7%

B1 Single-Family Residential, General Commercial, Wooded Areas 29.5% 27.8% 41.3%

B2 Single-Family Residential, Multi-Family Residential, School Site 34.8% 25.7% 39.1%

B3 Single-Family Residential, General Commercial, Central Business District 16.0% 28.5% 52.4%

B4 Single-Family Residential, Multi-Family Residential, General Commercial 37.4% 26.4% 35.5%

B5 General Commercial, Single-Family Residential, Multi-Family Residential 27.3% 18.3% 54.0%

B6 General Commercial, Office Institutional, Office Distribution, Single-Family Residential 14.5% 16.3% 67.0%

C1 Single-Family Residential, Wooded Areas 53.3% 24.6% 21.6%

C2 General Commercial, Single-Family Residential, Wooded Areas 31.7% 20.6% 47.7%

C3 Single-Family Residential, Central Business District, General Commercial 48.9% 25.6% 22.4%

C4 Single-Family Residential, Industrial, Multi-Family Residential, Office Institutional, Wooded 42.4% 24.6% 31.0%

C5 Single-Family Residential, Multi-Family Residential, Wooded 47.4% 18.7% 33.1%

C6 Multi-Family Residential, Wooded 45.5% 45.5% 9.1%

D1 Single-Family Residential 25.8% 40.5% 33.1%

D2 Single-Family Residential 37.6% 37.3% 25.1%

D3 Single-Family Residential, Multi-Family Residential, General Commercial, Wooded Areas 40.1% 29.7% 29.1%

D4 Single-Family Residential, Multi-Family Residential, Office Institutional, Wooded Areas 51.3% 22.5% 25.9%

D5 Single-Family Residential, Wooded Areas 44.8% 24.1% 29.9%


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The table shows that except for photograph A5, the areas with the highest tree canopy cover

are single-family residential areas that also contain a substantial amount of wooded areas. The

development that has occurred within the photograph A5 area is less dense and there are

substantial wooded areas that exist within the developments. The areas with the greatest

amount of impervious surface, and often the lowest amounts of tree canopy, are general

commercial and industrial areas, and in some cases include multi-family residential use.

Where tree canopy covers pavement, summer temperatures are lower, the urban heat island

effect is reduced, the production of ground level ozone is reduced, and pavement life is

extended. The addition of more trees, especially near and throughout the impervious surfaces,

will further increase these benefits as tree canopies grow and extend over parking lot

pavement, buildings, walkways, and roadways. It should be noted that the amount of

impervious surface within the city is in fact greater than the 34.4 percent found in this study.

Some of the impervious surface is covered with tree canopy and counted as tree canopy.

Increases in tree canopy cover will occur as young and newly planted trees grow and can be

identified on the aerial photography. This growth will occur in new developments where trees

have been planted to meet tree ordinance requirements. It will occur in abandoned fields and

E1 Single-Family Residential, Wooded Areas 46.5% 31.2% 22.4%

E2 Single-Family Residential, Wooded Areas 59.7% 22.6% 15.9%

E3 Single-Family Residential 44.8% 27.0% 27.5%

E4 General Commercial, Single-Family Residential, Wooded Areas 40.8% 20.2% 39.0%

E5 General Commercial, Single-Family Residential 16.7% 27.1% 56.3%

F1 Single-Family Residential, Wooded Areas 47.1% 29.1% 21.4%

F2 Industrial, Wooded Areas, Single-Family Residential 56.8% 13.6% 27.6%

F3 Single-Family Residential, Office Institutional, General Commercial, Wooded Areas 43.1% 25.9% 31.0%

F4 Multi-Family Residential, Single-Family Residential, General Commercial, Industrial, Wooded Areas 36.4% 20.7% 42.9%

G1 Single-Family Residential, Wooded Areas 55.6% 17.6% 26.8%

G2 Single-Family Residential, Wooded Areas 51.8% 28.5% 18.6%

G3 Single-Family Residential, Office Institutional, Industrial, School 41.9% 26.8% 26.5%

G4 Industrial, General Commercial, Single-Family Residential 21.6% 26.1% 50.4%

H1 Single-Family Residential, Wooded Areas 41.3% 28.5% 29.7%

H2 Industrial, Wooded Areas 42.4% 27.3% 18.6%

I1 Single-Family Residential 26.4% 57.6% 16.0%

TOTAL PERCENT COVERAGE ACROSS THE CITY 39.0% 25.2% 34.4%


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pastures where in-growth of trees takes place where mowing is eliminated. It will occur as

trees in general grow to reach maturity throughout the city. It will occur as the vacant street

tree planting sites identified in the 2008 and subsequent street and park tree inventories are

filled.

Decreases in tree canopy cover will take place where trees are removed and replaced with

substantially fewer trees, as is the case in most new developments. Decreases in tree canopy

cover will also take place as Smyrna’s aging large canopy trees decline and are removed along

street rights-of-way, in parks, in residential yards, and on commercial sites. If these trees are

not quickly replaced with an equivalent amount of large tree canopy, Smyrna’s tree canopy

cover in the future will be considerably less than it is today.

CONCLUSIONS

The amount of tree canopy cover found within Smyrna as of February 2009 is an alarmingly low

39 percent. It is below the 40 percent minimum recommended by American Forests, a non-

profit tree advocacy group that has been a pioneer in the measurement of tree canopy and its

benefits. Equally alarming is the amount of impervious surface found by the study, 34.4

percent. More than one-third of the area of the city is impervious surface and is not available

as rooting space for trees or any other vegetation.

Adding tree canopy cover in Smyrna and reducing the amount of exposed (not covered by tree

canopy) impervious surfaces, is critical. A policy of no net loss should be adopted immediately,

and then a long-term tree canopy cover percent goal should be established. Without a no net

loss policy and without the active conservation, maintenance, and replacement of trees in the

city, a loss of tree canopy cover will quickly occur. Every square foot of tree canopy cover that is

removed must be replaced for the current amount of tree canopy cover to be maintained.

The study results also show that tree canopy cover in Smyrna is not evenly distributed. It is

generally abundant on undeveloped land and in older neighborhoods, where impervious

surfaces are absent or limited in extent. Tree canopy is generally lacking in commercial districts

and on industrial properties, where impervious surfaces dominate the land cover, and in new

subdivisions where most trees are removed and replacement is minimal. A better distribution

of tree canopy is needed to take advantage of the environmental functions of trees and to

realize their many economic and social benefits.


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RECOMMENDATIONS

P Using the current study results as a baseline, future measurements using aerial

photography and the same methodology should be done to monitor changes in tree canopy

cover and impervious surfaces. Using the same methodology from year to year will produce

reliable information on the trends in tree canopy and impervious surface cover, and will

provide feedback on the effectiveness of tree management policies and tree regulations.

P Adopt a baseline policy of no net loss of tree canopy cover to maintain a minimum tree

cover of 39 percent. Strategies for achieving no net loss should include tree conservation,

tree protection, proper and routine tree maintenance, and replacement tree plantings.

Offset any losses in tree canopy that occur on an individual property, along each street,

within each neighborhood, and throughout each zoning district.

P Hire an arborist to monitor tree canopy cover change within the city and develop a

comprehensive community tree management program to increase tree canopy cover. The

management program should focus on the maintenance and planting of city trees, promote

the conservation of existing trees through education and outreach on the functions and

benefits of trees, and engage all community partners in the planting of new trees wherever

vacant planting sites exist.

P The city should begin the process of filling vacant street tree planting sites identified in the

2008 tree inventory, focusing on the planting of sites suitable for large canopy trees. There

were 172 vacant sites identified that are suitable for large canopy trees, and another 40

sites identified that are suitable for planting medium canopy trees.

P Assign the responsibility of monitoring tree canopy cover change to the Smyrna Tree Board.

Monitoring will include additional tree canopy cover measurements conducted every 3

years using the same methodology used in the 2009 study.

P Assign the responsibility for tracking tree canopy cover loss and arranging for tree canopy

replacement on city property to the Public Works Director for trees on street rights-of-way

and around city facilities, and to the Director of the Parks & Recreation Department for

trees within parks. They should summarize the amount of tree canopy cover loss and

replacement as number of square feet of canopy, on property under their control on an

annual basis.


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P Assign the responsibility for tracking tree canopy cover loss and replacement on new

private property developments to the Community Development Director and City Planner,

who should summarize the amount in square feet of loss and replacement on an annual

basis.

P Enforce the tree ordinance requirements for tree density, tree conservation and

replacement tree plantings. Review the tree ordinance periodically and visit completed

developments to determine if the tree ordinance requirements are resulting in their

intended outcome and adequate tree canopy cover on development sites.

P Focus tree planting in areas where tree canopy is needed over impervious surfaces. These

areas include street rights-of-way and medians, parking lots, and around buildings. Adopt a

policy of 50 percent coverage of all parking lots.

P Increase the amount of tree canopy cover to a maximum of 50 percent. This will require an

aggressive annual tree planting program by the city, the business community, the

development community, and residents. To increase tree canopy cover 11 percent overall,

from the current 39 percent to 50 percent, the community will have to plant enough trees

to cover an additional 1.67 square miles or 46,490,020 square feet. If each tree provides an

average of 2,000 square feet of canopy at maturity (a crown width of approximately 50

feet) then an additional 23,245 trees must be planted. To increase tree canopy cover by

only 6 percent to 45 percent, the community will have to plant an additional 12,687 large

canopy trees. These trees are in addition to those that must be planted for no net loss to

replace existing trees that are removed.

P Plant large maturing, canopy trees wherever and whenever possible in lieu of planting

small, ornamental trees.

P Engage all partners in the community in maintaining and increasing tree canopy cover by

conserving natural forested areas, protecting trees, properly maintaining existing trees, and

planting additional trees. Develop education and outreach programs to support

community-wide tree conservation and planting efforts.

P Regardless of the tree canopy cover target the city chooses, an aggressive, ongoing and

long-term annual tree planting program should be developed immediately to ensure that

the city maintains a healthy level of tree canopy cover throughout the city for current and

future generations of citizens.


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Funds for this project were provided by the Urban and Community Forestry Grant Program

administered by the Georgia Forestry Commission.

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of

race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, and marital or

family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative

means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s

TARGET Center at 202.720.2600 (voice and TDD).

To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-A, Whitten Building, 14th

and Independence Avenue, SW, Washington, DC 20250-9410 or call 202.720.5964 (voice or TDD). USDA is an equal

opportunity provider and employer.

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