MBPC Submits Comments on Proposed Rule Making Regarding SNAP Standardization of State Heating and Cooling Standard Utility Allowances

SNAP Program Design Branch,
Program Development Division
Food and Nutrition Service
3101 Park Center Drive
U.S. Department of Agriculture
Alexandria, VA 22302

Re:  Notice of Proposed Rule Making — Notice of Proposed Rule Making Regarding Supplemental Nutrition Assistance Program (SNAP) Standardization of State Heating and Cooling Standard Utility Allowances — RIN 0584-AE69

Dear SNAP Program Design Branch:

I am writing on behalf of the Montana Budget and Policy Center to express our strong opposition to the United States Department of Agriculture’s Notice of Proposed Rulemaking (NPRM) on a revision of the Standardization of State Heating and Cooling Standard Utility Allowances (HCSUA). We oppose the rule because it will result in a significant loss of benefits to thousands of Montanan households and increase food insecurity and financial hardships throughout the state.

The Montana Budget & Policy Center is a nonpartisan, nonprofit organization that provides in-depth research and analysis on tax, budget, and economic policies in order to promote opportunity and fairness for all Montanans.

The proposed rule would jeopardize the health and financial security of over 22,000 Montana households by significantly reducing their ability to purchase the food they need. [i] The proposed rule should be withdrawn.

SNAP is one of the nation’s most effective and efficient programs to reduce food insecurity and lift families and individuals out of poverty. In Montana, SNAP serves over 100,000 people, most of whom are children, elderly or have disabilities.[ii] The proposed cut to the HCSUA would endanger low-income households’ ability to pay for food, as well as have a harmful effect on Montana’s economy.

According to the Department’s own analysis, this proposal would cut $4.5 billion over the next five years. [iii] In Montana, this is a net annual cut of $13 million a year, an 8 percent reduction in the state’s program.[iv] As an agricultural state, SNAP’s benefit to Montana’s economy far exceeds that of helping low-income households obtain food security. SNAP benefits local businesses, grocery stores, and ultimately the entire agricultural sector. Such a large cut would put livelihoods at risk across the state.

This proposed rule change will negatively impact Montana SNAP beneficiaries much more so than those in states with warmer climates. An estimated 42 percent of Montana SNAP households will see a reduction in their benefits due to the proposed rule change with an average cut of $50 a month.[v] Affected households currently receive an average of $228 in benefits a month, making this an average 22 percent cut in monthly benefits.[vi] Such a significant cut totals nearly a week’s worth of food for people who are already struggling to make ends meet.

The proposed rule would cap the HCSUA at a much lower standard than what Montana is currently using, reducing the allowance by 36 percent.[vii] The proposed rule would cap HCSUAs at the 80th percentile of low-income households’ utility costs in the state, unfairly harming households with high utility costs. The Department does not explain the rationale for setting the cap at the 80th percentile when 22 states have had theirs set at the 85th percentile or higher.[viii] The USDA is able to work with states who have set their HCSUA at too low to raise their standards without reducing the benefits of those in other states.

In rural Montana, SNAP is a critical first line of defense against food-insecurity. In communities where the nearest food bank may be many miles away, SNAP allows individuals to purchase the food they need. SNAP responds quickly to economic downturns and natural disasters and helps bolster recovery from setbacks.

Nationwide, this cut will result in 19 percent of SNAP households receiving lower benefits and will disproportionately affect the elderly and people with disabilities. [ix] As Congress has expressed, SNAP’s statutory mission is “to promote the general welfare, to safeguard the health and well-being of the Nation’s population by raising levels of nutrition among low-income households.” The Administration is undermining SNAP’s statutory purpose by proposing cutting benefits for these most vulnerable groups. Furthermore, Congress refused to pass such drastic cuts to SNAP in the Farm Bill. This proposed rule change is an attempt to sidestep Congressional authority.

This rule will endanger the health and safety of thousands Montana children, people with disabilities and elderly. It will harm our state’s small businesses and agricultural economy. We strongly oppose this rule, and request that it be withdrawn.

Sincerely,

Jackie Semmens

Montana Budget and Policy Center
15 West 6th Avenue, 3E
Helena, MT 59601

[i] Analysis based on data from the USDA FNS. USDA FNS, Supplemental Nutrition Assistance Program:  Number of Households Participating.  https://fns-prod.azureedge.net/sites/default/files/resource-files/30SNAPcurrHH-11.pdf

[ii] USDA FNS, Supplemental Nutrition Assistance Program:  Number of Persons Participating. https://fns-prod.azureedge.net/sites/default/files/resource-files/29SNAPcurrPP-11.pdf, and  USDA FNS, Characteristics Of Usda Supplemental Nutrition Assistance Program Households:  Fiscal Year 2017 (Summary).  https://fns-prod.azureedge.net/sites/default/files/ops/Characteristics2017-Summary.pdf

[iii] USDA FNS, Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowance. https://www.federalregister.gov/documents/2019/10/03/2019-21287/supplemental-nutrition-assistance-program-standardization-of-state-heating-and-cooling-standard

[iv] USDA FNS. FY 2017 SNAP HCSUA Values and Proposed Rule Impacts, by State. https://fns-prod.azureedge.net/sites/default/files/resource-files/FY%202017%20HCSUA%20Values%20and%20Proposed%20Rule%20Impacts.pdf

[v] USDA FNS, FY 2017 SNAP HCSUA Values and Proposed Rule Impacts, by State https://fns-prod.azureedge.net/sites/default/files/resource-files/FY%202017%20HCSUA%20Values%20and%20Proposed%20Rule%20Impacts.pdf and Center on Budget and Policy Priorities.

[vi] Center on Budget and Policy Priorities.

[vii] USDA FNS, FY 2017 SNAP HCSUA Values and Proposed Rule Impacts, by State. https://fns-prod.azureedge.net/sites/default/files/resource-files/FY%202017%20HCSUA%20Values%20and%20Proposed%20Rule%20Impacts.pdf

[viii] USDA FNS, Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowance. https://www.federalregister.gov/documents/2019/10/03/2019-21287/supplemental-nutrition-assistance-program-standardization-of-state-heating-and-cooling-standard

[ix] USDA FNS, Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowance. https://www.federalregister.gov/documents/2019/10/03/2019-21287/supplemental-nutrition-assistance-program-standardization-of-state-heating-and-cooling-standard