As the weather turns colder, many of us are pulling out our bulkiest sweaters and diving headlong into hygge. But as we reach for all of our coziest creature comforts to stay warm this winter, there’s one thing that no one should have to worry about: choosing between our heating bill and our grocery list.
Last month, the Trump administration proposed yet another rule that would cut Supplemental Nutrition Assistance Program (better known as SNAP, or food stamps) benefits for families across the country. And the target this time is a provision called the standard utility allowance, or SUA. It’s an estimate of the average cost of utilities, including heating and cooling, that a household participating in SNAP pays each month, and it’s used to help calculate household monthly benefits. In other words, the SUA exists to make sure that families never have to choose between paying for their water or electric bills and receiving the SNAP benefits they need to put food on the table.
Currently, states have the power to determine how SUAs are calculated and to set a threshold that meets the needs of their populations. The administration wants to change that, setting a uniform standard that would result in a net loss of $4.5 billion in benefits over a period of five years. Some states stand to lose as much as 20 percent of their total benefits.
This is the fourth rule of this kind that has been proposed by the Trump administration—all of which have been proposed in the name of integrity or equity, and all of which would cut benefits for households receiving SNAP. We’re not buying it.
The public comment period for this rule is open through December 2nd. See our comment below, and visit the federal register to submit your own.
Re: Docket No. FNS-2019-0009: Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowances
On behalf of the Union of Concerned Scientists (UCS), I submit this comment to the United States Department of Agriculture (USDA) to express opposition to the proposed regulatory changes to the Supplemental Nutrition Assistance Program (SNAP) that would result in a net loss of $4.5 billion in benefits for households nationwide over the course of five years. Through the proposed modifications to the standard utility allowance (SUA), the rule would further contribute to the cumulative harm caused by a series of recent regulatory changes to the program, resulting in greater economic hardship, food insecurity, and health risks among low-income individuals, with disproportionate impacts for rural residents. Furthermore, the rule undermines the will of Congress and the general public, who overwhelmingly rejected proposed farm bill provisions that would have reduced SNAP benefit levels or participation.
A national science-based nonprofit working for a healthy environment and a safer world, UCS combines independent scientific research and citizen action to develop innovative, practical solutions to secure responsible changes in government policy, corporate practices, and consumer choices. The Food and Environment Program at UCS makes evidence-based policy recommendations to shift our nation’s food and agriculture system to produce healthier, more sustainable and just outcomes for all people. During the development of the 2018 Farm Bill, we produced scientific research and materials communicating the public health and economic benefits of SNAP, and engaged with dozens of policymakers and organizational partners and thousands of citizens to support the passage of a strong bipartisan bill maintaining the core structure and function of the nation’s most effective anti-hunger program.
Our opposition to the proposed rule is grounded in the following:
1. Cuts to SNAP result in greater food insecurity, health risks, and economic vulnerability.
As documented in the UCS report, Strengthening SNAP for Rural and Urban America, there is a substantial body of research demonstrating the public health benefits of SNAP participation. In 2017, SNAP lifted 3.4 million people out of poverty and resulted in food insecurity rates up to thirty percent lower than would be expected in the absence of SNAP benefits. According to a 2013 USDA report, lower food security is associated with increased rates of chronic diseases such as hypertension, coronary heart disease, hepatitis, stroke, cancer, asthma, diabetes, arthritis, chronic obstructive pulmonary disease, and kidney disease. Young children’s participation in SNAP is also linked to a higher likelihood of high school completion and lower rates of obesity and metabolic syndrome in adulthood.
The health benefits of program enrollment are accompanied by substantial savings in health care costs: recent research has found that SNAP participants, compared to eligible non-participants, incur $1,400 less each year in total medical costs, due in part to fewer hospitalizations for complications related to diabetes. Regulatory changes that function to reduce SNAP benefits or decrease program participation pose substantial threats to public health and are likely to increase associated medical costs. According to the USDA, the adoption of the proposed rule could result in as many as 8,000 households losing program eligibility. Based on research evaluating the medical costs of non-participants, and assuming one adult per household, the proposed rule could result in an increase of $11.2 million in medical costs (2019 USD) over five years among those losing benefits.
Abundant data also show that SNAP is a smart investment in the nation’s economic well-being. When SNAP participants spend benefits at a market or store, it catalyzes a chain reaction of economic activity generating what is known as the “multiplier effect.” The standard USDA model estimates that, during a weak economy, $1 in SNAP spending generates about $1.80 in economic activity. During economic downturn and conditions of high unemployment, when the program is most needed, SNAP benefits are countercyclical and yield a high economic multiplier, meaning the influx of spending helps entire communities and industries recover more quickly from the fallout. According to UCS research, $65 billion in SNAP spending generated an estimated $114 billion in economic activity supporting an estimated 567,000 jobs in 2017— including nearly 50,000 in agriculture.
The role SNAP plays in providing economic stimulus also means that entire communities feel the effects of program cuts. According to the USDA, the proposed rule would decrease SNAP benefits by $4.5 billion over a period of five years. Applying the USDA’s own economic model, these benefits would have the potential to generate as much as $8.1 billion in economic activity, driving broad economic benefit in the agricultural sector, food and grocery industries, and beyond.
2. The proposed rule may disproportionately impact low-income rural residents.
Recent research on rural poverty, nutrition assistance program use, and energy costs indicates that the changes to the SUA contained in the proposed rule are likely to disproportionately harm low-income populations living in rural areas.
Previous UCS analysis has shown that rural populations rely on SNAP at a higher rate than urban populations, meaning overall program cuts would harm rural residents disproportionately. Of the top 150 counties with the highest percentage of SNAP participation by household, 136 are rural and just 14 are urban. Of the top 50 counties with the highest SNAP usage, all but a mere two are rural. The USDA recently reported that the gap between poverty rates in rural, isolated areas and other areas continues to grow, reflecting demographic changes and slower economic recovery in nonmetro areas following the 2008 recession, and highlighting the high need present in many rural communities.
The proposed changes to the SUA could also uniquely impact rural communities in states experiencing net benefit reductions due to the greater burden of energy costs for rural households. According to a 2018 report from the American Council for an Energy-Efficient Economy, households in rural areas spend a disproportionately high share of their income on energy bills, including utilities like electricity and home heating. The percent of household income spent on energy, often referred to as the “energy burden,” is estimated at 4.4 percent among all rural households, compared to the national burden of 3.3 percent. However, low- income rural households contribute a far greater share of their income, with a median energy burden of 9 percent—nearly three times greater than that of their higher-income rural counterparts. Other rural populations with high energy burdens include elderly households, who experience a median energy burden 44 percent higher than non-elderly households, and nonwhite households, whose median energy burden is 19 percent higher than their white counterparts.
According to the USDA, 29 states will experience net reductions in SNAP benefits as a direct result of the proposed rule.1 The magnitude of these reductions varies widely, from less than one percent in Alaska, California, Louisiana, and Missouri to more than 20 percent in Vermont. However, the states that will experience the highest net decrease in benefits are also among those with the highest percentage of rural inhabitants. Per USDA documentation, the four highest state-level benefit reductions resulting from the proposed rule, ranging from 10.4 percent to 20.9 percent, will all occur in the top 10 states with the highest percentage of rural residents.
The wide range in energy affordability among populations participating in SNAP, particularly between rural and urban areas in the same state, indicates that the proposed methodology for determining SUAs is both inappropriate and inequitable for calculating household benefits. It is important that states retain the ability to set these standards using the data and methodology that best reflect the needs of the diverse populations they serve, and to protect their most vulnerable populations from the consequences of food insecurity and economic instability. Such accommodations will only become more important as populations living in areas vulnerable to extreme weather face increased energy costs as a result of rising temperatures. A recent UCS report found that by midcentury, in the absence of action to reduce heat-trapping emissions, the average days per year with a heat index above 100°F will more than double, while the days above 105°F will quadruple. Extreme heat poses health risks in both rural areas, which have some of the highest heat-related hospitalization and death rates, and urban areas, which have an overall higher risk of heat-related illness, with low-income populations generally facing greater exposure and vulnerability to climate-related threats. For these populations, an inability to afford increasing energy costs will pose serious health risks.
3. Regulatory changes undermining SNAP are undemocratic.
Congress expressly rejected attempts to reduce SNAP benefits or participation in the 2018 Farm Bill, and ultimately passed a bipartisan bill maintaining the core structure and function of the program. Circumventing the policymaking process to unilaterally implement unpopular and unsubstantiated changes to SNAP through rulemaking directly contradicts the expressed wishes and stated needs of many individuals, organizations, and elected officials, and is categorically undemocratic.
For example, more than 200 public health and medical experts from across the country sent a letter to the farm bill conference committee in August 2018, urging them to agree to a bill that protected SNAP without imposing unnecessary additional work requirements. “Millions of households aren’t able to provide their families the healthy food that helps them and their communities thrive,” said Dr. Georges Benjamin, executive director of the American Public Health Association. “Any changes to SNAP should increase access to affordable and nutritious food, not leave more people hungry.”
According to polls, a majority of the general public shares largely the same sentiments. A survey commissioned by the Center for a Livable Future at Johns Hopkins University Bloomberg School of Public Health found that nearly two-thirds of registered voters (61 percent) opposed lower funding for SNAP; among those opposed, more than 73 percent were strongly opposed to cuts. A 2018 poll conducted by the Center for American Progress and GBA Strategies affirmed that two-thirds of American voters (66 percent) oppose funding cuts and eligibility restrictions for nutrition assistance programs, including SNAP. Furthermore, more than 120 national organizations signed a letter urging farm bill conferees to protect and strengthen SNAP by rejecting any cuts to the program.
The Secretary’s stated motto to “do right and feed everyone” is an empty promise if it is undermined by regulatory actions. To put this motto into practice, the administration can begin by withdrawing changes to SNAP benefit calculations that would reduce the reach and effectiveness of the nation’s primary nutrition assistance program. This proposed rule would generate greater economic hardship, food insecurity, and health risks among low-income individuals and communities across the country, with disproportionate impacts for rural residents, and would further undermine Congress and the federal policymaking process against the will of the general public.
Thank you for your consideration.