PUMP Opposes USDA’s Proposed SNAP Rule: Standardization of State Heating and Cooling Utility Allowances

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On October 3rd, for the third time in 2019, the USDA proposed a new rule to the Supplemental Nutrition Assistance Program that would result in benefit cuts to Americans who depend on SNAP to access healthy, affordable food and feed themselves and their families. PUMP opposes this rule change. On December 2nd, we submitted a comment to the USDA voicing our opposition to the rule, which is called “Standardization of State Heating and Cooling Standard Utility Allowances.”

If it goes into effect, the proposed rule would require all states to use the same standard calculation to estimate utility expenses, which are a factor in determining the monthly amount of benefits a family recieves. This would result in benefits being underestimated for many families, especially in cold-weather states with high heating utility expenses, such as Pennsylvania.

The USDA’s 60-day public comment period ended on Dec. 2nd, 2019. The USDA must respond to every unique comment on the proposed rule before making a final decision about its implementation. Review the proposed rule and comments here.

Read the comment PUMP submitted to the USDA below.

November 26, 2019
SNAP Program Design Branch,
Program Development Division
Food and Nutrition Service
3101 Park Center Drive
U.S. Department of Agriculture
Alexandria, VA 22302

Dear Secretary Perdue and SNAP Program Design Branch:

On behalf of PUMP, a 501(c)3 nonprofit in Pittsburgh, Pennsylvania, we appreciate the opportunity to comment on USDA’s proposed Standardization of State Heating and Cooling Standard Utility Allowances. We submit this letter in opposition to the proposed rule and ask that it be withdrawn.

Founded in 1996, PUMP’s mission is to make the Pittsburgh region the most dynamic and diverse place by engaging, educating, and mobilizing all young people to create change in our community. Each year, we serve nearly 30,000 individuals, primarily under the age of 40, through our advocacy, civic, and social programming.

In 2017, our constituents helped design our advocacy and public policy agenda, which reflects our vision for regional equity and includes a focus on efforts that support equitable access to health and wellness, as well as equitable opportunities, for everyone. We believe that everyone should have access to affordable, healthy food, because it is essential for the wellbeing and success of people and families. The proposed rule change would result in a reduction of benefits for many Americans that would impede their ability to provide healthy food for their families.

Currently, states have flexibility in how they calculate a household’s utility expenses for the purposes of allotting SNAP benefits. Many states use Standard Utility Allowances to approximate utility costs for families in their state without the added bureaucracy and administrative cost of having SNAP recipients submit bills every month.

The use of state-specific Standard Utility Allowances is important to address the needs of families in each state. It allows cold-weather states, for example, to factor the high cost of heating during the winter in their calculations. But the proposed rule would require all states to calculate heating and cooling utility costs using the same Standard Utility Allowance. This calculation frequently underestimates what people spend on utilities, especially in cold-weather states. As a result, 19% of households on SNAP would see a decrease in their benefits of up to $75 per month. While other households, approximately 16%, would see an increase in benefits under this new rule, the increase would only be up to $33 per month. In total, $4.5 billion would be cut from SNAP spending, a significant net loss for families who depend on SNAP.

The cut of $4.5 billion is a negligible percentage of SNAP’s total budget. Yet a loss of up to $75 per month for a low-income family can create lasting harm – children may be malnourished, people may sacrifice other basic needs in order to put food on the table, and families may not be able to gain steady footing in order to become financially independent.

Nearly 8,000 households would lose SNAP benefits entirely, primarily in cold, northern states like Pennsylvania. More than half of Pennsylvania families on SNAP would see a reduction in their benefits, and the total amount of benefits given to Pennsylvanians would drop by nearly 10%. This rule would harm many of our most vulnerable residents – especially children, older adults, and people with disabilities – who depend on SNAP to put food on their table. We believe that Pennsylvania understands the needs of our residents best. We should be trusted to continue fairly assessing utility costs for SNAP recipients in the way that works best for Pennsylvania.

This rule is just the latest attempt by the USDA to cut SNAP benefits for American families. When coupled with proposals such as the revision of Broad-Based Categorical Eligibility, it serves as a reminder of the barriers we are up against in ending food insecurity. We strongly oppose the proposed rule because of the harm it would cause to people in the Pittsburgh region, across Pennsylvania, and throughout the United States.

Thank you for your time and consideration.


Brian Magee