Public Comment Opportunity Action Alert!
Another chance to speak up to protect life-saving food assistance!
Deadline to comment: December 2nd
The Issue:
The Trump Administration has released yet another proposed rule that would significantly weaken the Supplemental Nutrition Assistance Program (SNAP). The Administration is now trying to change the way Standard Utility Allowances are calculated in relation to SNAP benefit levels.
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). States can choose their own methodologies to set their SUA, which the USDA approves. Variations in this allowance amount across states are currently allowed, as policymakers have recognized that different states have different utility rates and have understood flexibility to be important. The proposed rule would standardize the way SUAs are calculated in all states, and would rely on survey data to do so.
In CT, the proposed change would have significant impacts. According to the Regulatory Impact Analysis for this proposal, 44.81 percent of CT SNAP households would see a benefit decrease (only 0.43 percent would see benefit increase) and overall, the state of CT would see benefits drop by 9.30 percent.
SNAP is a critical program. According to the Center for Budget & Policy Priorities, SNAP kept 70,000 people in Connecticut 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. We must not accept yet another attempt to take food away from some of the most vulnerable people in our state and country.
The Action Needed:
Consider submitting a public comment in opposition to the proposed rule change. CCFJ staff have submitted a comment; click here to read. Federal agencies are required to consider each unique public comment on a proposed regulation. Including data will make your comment stronger, however this should not dissuade you from making values-based comments. Do note that your comment will be publicly available.
Submitting public comments on proposed federal regulations is a simple but important advocacy strategy. We need you to join us!
This proposed rule can be found directly here. Comments for this proposed regulation are due by 11:59pm on December 2nd.
Potential talking points:
Below are some additional points you could include. Remember that your comment needs to be unique in order to be counted. Some overlap of wording and data citation is fine, but the majority of the comment must be unique, so please make sure to modify the language if you use the sample points.
• Context matters when evaluating need. Utility rates are different in different states, and thus flexibility in determining the appropriate Standard Utility Allowance is important.
• SNAP is effective. In 2015 alone, SNAP lifted 4.6 million Americans out of poverty; among them were 2 million children and 366,000 seniors. Each year, SNAP keeps nearly 30,000 of Connecticut’s children out of poverty.
• SNAP benefits the poor directly, but indirectly, it benefits us all. Separate studies conducted by both the executive branch and the legislative branch have noted that in addition to lifting people out of poverty, SNAP stimulates the broader economy. A 2010 USDA study found that every $1 spent on SNAP generated $1.80 in economic activity at the height of the financial crisis.
• As people of faith, we believe that everyone deserves to live a dignified life with their basic human rights upheld. We believe that access to adequate, nutritious food is a human right. This proposed rule that would cut food assistance benefits for millions of people is simply immoral.
• If you have used SNAP yourself, consider writing about your experience and perspective of this program’s value.
• Write from your perspective as a person of faith, faith leader, mother, teacher, other professional role, or simply a concerned community member. What do you think the impact of this proposed change would be? Why do you think the Administration should withdraw this proposal?
• Comments can vary in length, so don’t let length be a barrier to you writing something. Even something short and to the point is important.
Further reading:
Food Research and Action Center’s Toolkit for the proposed rule can be found here.
General background information and data on SNAP and its impacts from the Food Research & Action Center
Our September blog post with background on public comment periods
Thank you for your advocacy efforts!
