The Collaborative Center for Justice has submitted a public comment in opposition to the proposed new rule by the USDA that would make significant changes to how states calculate Standard Utility Allowances, and would have the effect of reducing SNAP benefits for approximately 19% of SNAP households nationally. You can read our comment below. You can click here to read our previous explanation of public comment periods, and you can submit your own public comment on this rule here. Comments are due by 11:59pm on December 2, 2019.
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Re: ID: FNS-2019-0009-0001
We write from the Collaborative Center for Justice, a faith-based advocacy organization in Hartford, CT. We write to express our opposition to this proposed change to the way Standard Utility Allowances would be calculated to determine SNAP benefits.
We are deeply concerned about how this proposed change would impact vulnerable people around the country. This proposed rule would cut SNAP benefits by $4.5 billion over 5 years. Implementing the proposed changes would have the effect of reducing life-saving benefits for approximately 19% of SNAP households, and cuts would disproportionally effect individuals living with a disability and elderly individuals.
Under current law, states can adjust household SNAP benefits based on a state-specific Standard Utility Allowance (SUA). Although calculated by the state, it is approved by the USDA. Variations in this allowance amount across states are currently allowed, as policymakers have recognized that different states have different utility rates, and thus, need to have flexibility in calculating allowances that are based on utility rates. If the USDA is concerned that some states’ SUA levels are lower than is necessary for that state, we urge the USDA to work with individual states to improve how they utilize the SUA in order to ensure that households are receiving the greatest amount of benefits that could be available to them.
During the reauthorization process for the 2018 Farm Bill, Congress reviewed the SNAP program, including that states have some options that may end up producing differences in SNAP eligibility benefit amounts from state to state. The Congress affirmed the validity and importance of such options in the passage of the 2018 Farm Bill on a bipartisan basis.
As people of faith, we firmly believe that access to an adequate amount of nutritious food is a basic human right. We believe that each and every person is made in the image of God, and we believe in the dignity of every person. Millions of adults and children across the country would not have access to enough food without SNAP benefits. The Supplemental Nutrition Assistance Program is a crucial and effective way by which this human right is protected for millions of people around the country.
According to the Center for Budget & Policy Priorities, SNAP kept 70,000 Connecticut residents out of poverty – including 28,000 children – each year from 2009 – 2012. The program works. Accounting for only 2% of the federal budget, SNAP is a safety net for approximately 44 million Americans, most of whom are children, the working poor, the elderly, and people with disabilities. According to the Regulatory Impact Analysis, over 40% of SNAP households in Connecticut would see their benefits reduced under this proposed change, which means more hungry families across the state.
People should not have to decide between buying food and paying for other expenses like utilities. Heat and food are both necessary for survival. We urge you to withdraw this proposed rule that would have significant, negative impacts on millions of people around the country.
Thank you for the opportunity to comment on this proposed regulatory change.
Respectfully submitted,
Dwayne David Paul – Director
Rachel Lea Scott, MSW – Associate Director
