New York State Office of Temporary and Disability Assistance
Albany, NY 12243
VIA E-MAIL: NYSHEAP@otda.ny.gov
RE: Comments on Needs Assessment for 2014-2015 state Home Energy Assistance Program (HEAP) plan
Dear OTDA HEAP bureau:
I am writing on behalf of the Empire Justice Center, a statewide, multi-issue, multi-strategy public interest law firm focused on improving the “systems” within which poor and low income New York State families live.
Thank you for providing us with the opportunity to comment on the development of New York’s 2014-2015 state HEAP plan.
We are extremely grateful that Governor Cuomo took swift action during the 2013-2014 HEAP season to prevent a devastating cut in Supplemental Nutrition Assistance Program (SNAP) benefits, after Congress enacted changes to the federal SNAP statute which disproportionately hurt New York.
New York’s investment of $6 million in HEAP funds, through the provision of supplemental HEAP renters’ benefits, averted the loss of approximately $457 million in federal SNAP benefits to nearly 300,000 households. The supplemental payments were critical to ensuring that some of the poorest and most vulnerable SNAP recipients – public/subsidized housing tenants and residents of group homes – could continue to be credited with a heating/cooling standard utility allowance (SUA) in their SNAP budget. Without the benefit of the SUA, many of these households faced a huge cut in their monthly SNAP allotment, on top of the benefit reduction that affected all SNAP households in November 2013. The overwhelming majority of these households – over 75% – contain an elderly or disabled member,  and it would have been very difficult, if not impossible, for them to absorb any further reductions in their monthly food assistance out of their limited monthly income.
For the 2014-2015 HEAP season, it remains just as critical that New York continue to protect these vulnerable households.
We respectfully request that New York’s 2014-2015 state HEAP plan include a provision for a $21 minimum grant for public/subsidized housing tenants and residents of group homes. We also recommend that OTDA amend the references in 18 NYCRR section § 393.4(c)(4) to reflect the change from $1 to $21.
Thank you for your consideration of these comments.