| Comments on Funding Allocations (LIHWAP Model Plan Section 1) |
Topic |
Decision - Action Taken |
| 1.1 Good option, but please clarification on what a rate reduction looks like. Is it a rate reduction (dollar amount, volume amount, or percentage amount) of rate reduction to wastewater and drinking water fee schedules? Also, please clarify the duration of the rate reduction, such as monthly, bi-monthly, annually. Estimated allocation should not be answered until LIHWAP formally announces how much funding is awarded to each state/administrator. For example, if Corona Federal Relief funding was awarded to a the California Housing and Community Development and that program helped water debt, where 20% at $20 million of water debt in the state was paid off, then only 80% at $80 million needs to go to offset water debt. On the flip side of the coin, $0 assistance has been provided to sewer and the backlog of that is also $80 million dollars. How does one guess what percentage will be allocated where to ensure effectiveness of program administration. |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| Re Model Plan Section 1: HHS should define “rate reduction” in the context of the intent of the COVID relief bills that are designed to provide emergency relief to low-income households with water arrearages and who face challenges affording current bills. While “rate reduction” carries with it a particular understanding in utility rate cases (e.g., the development of a Low-Income Percentage of Income Payment Program), in more general contexts, the term has been used more broadly to mean consumer bills. In the context of the LIHWAP, with its focus on low-income household water and wastewater assistance, “rate reduction” should be defined broadly to include bill payment assistance to address the types of charges that can make water and wastewater bills unaffordable and thus jeopardize continued access to essential water and wastewater services. Likewise, the LIHWAP “arrearage” assistance should also be defined broadly to capture the additional charges, fees and penalties related to water and wastewater arrearages (e.g., disconnection fees, reconnection fees, flushing and plumbing costs related to safe reconnection practices (see e.g., https://www.michigan.gov/documents/egle/egle-tou-dweh-WaterReconnectionActions_683801_7.pdf). |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| It is unclear whether “rate reduction” is analogous with “bill payment assistance.” If it is, the latter wording is much clearer. |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| What is the meaning of "Rate Reduction"? Does this simply mean that the program will give grants to households that they can then apply to their water bills? When I read "Rate Reduction" it implies changing the actual amount charged the customers per gallon of usage by the water entities. Also, why does it matter if the assistance goes to helping people pay their bills (if that is what "rate reduction" means) or helping with arrearages? Why make that distinction. The more significant data point is whether the assistance prevented or restored service. |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| What is meant by "wastewater/drinking water rate reduction?" Is this accomplished by making a direct payment on the applicant's bill? Is the arrearage program similar to the crisis program in LIHEAP? Provide examples of how we might ensure there is no difference in the treatment of categorically eligible households from those not receiving other public assistance when determining eligibility and benefit amounts? There are several categories listed under applicable forms of income. Are those decisions made at the State level, and can each State make their own interpretation of what sources will be included in calculating income? |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| Clarification on Rate Reduction for Wastewater and Drinking Water components. What will this entail and how can we use LIHWAP funds for these components? |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| 1.1 Are we reducing their rates? Or are we reducing what is due currently? And then what is in arrears (late payments)? We would need to create new rate codes for these qualifying customers. And again, it feels disingenuous to charge something other than 'cost of service.' I would prefer to give a discount than to change rates. |
Define Rate reduction/Arrearages |
Maintained terminology. Removed first question and restructured Section 1. Created defintion in instructions document. |
| There is not space here to identify funding used for reconnection fees. It was my understanding that reconnections were a key piece of the purpose for these funds. If so, that should be added as an option for what funds will be used for. |
Define Rate reduction/Arrearages |
Added definitions that now clearly specify reconnection fees are part of allowable expenses under arrearages. |
| Too long and involved. Needs to be parred down and simplified. If customer already is receiving benefits that are income based, why go through another reverification process. (food stamps, Section 8 other assistance) make it automatic for this assistance and only those who are not receiving any assistance already would have to go through income verification. Make documents needed simple and easy for client to provide. |
Eligibility |
Clarified with instructions that 1.9 only applies to households not already categorically eligible. |
| On question 1.3, if someone answers "no", I think you should ask why. |
Eligibility |
Added row indicating that if answer was "no" to 1.3, grantee must a justification. |
| The category of cost allocations to the different types of assistance is unreasonable. How can we anticipate the % of where we will spend if we haven't run this program before, not sure why this is needed upfront and not in the final reporting. |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| Having no history, estimating percentages per component is difficult. We advocate that changing the percentages as needed throughout the life of the grant be made simple. We understand that at no time, can the administrative and planning costs exceed 15% |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| OHCS has no historical data related to drinking water or wastewater expenses and use; it will be difficult if not impossible to determine the percentage of funding dedicated to either the rate reduction or arrearages of household accounts; if there are other programs using the same income eligibility markers in Oregon—administered by OHCS—are they available to use under categorical eligibility. The upfront costs to develop this program will require far more than 15% of whatever program awards are provided by OCS given the historical operational needs and costs of the LIHEAP operational experiences. |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| It seems like the first section to allocate funds to is confusing and needlessly wordy. The options that seem pertinent would just be water assistance and waste water assistance. Seems unnecessary to break it down further; however, I understand if congressional language requires that. It makes it more complex to operate and report on in the future when it is so broken down. I have had issues with grants.gov in the past when reporting and being able to complete and submit a report when my % did not match those exact initial estimates as my plan & that seems wrong and causes undo burden. |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| Section 1.2 Allocation: Please clarify whether estimated amounts to be spent on each component can be modified. Needs are not predictable at the local level. Section 1.8 Countable Income: States should be encouraged to make countable income the same as for the current LIHEAP program. |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| For tribes, one bill is issued by our Utility department and does not separate waste water and drinking water. This may become an issue when determining components and funding allocation. Can crisis be included? (I.e. verge of disconnection or HH has been disconnected to due to arrearages) |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| Section 1.2 requires an estimate of how much of the grantee’s funds will go toward “rate reduction” vs “arrearages”. Will states be held to that estimate, or can they adjust as they go, based on what they learn about actual need? Most states have little if any data on need. |
Percentage estimates |
Revised Section 1.2 to request percentages for Household Benefits, Outreach/Eligibilty Determination, and Admininstration. Administration is separateed into two rows… one for state or tribe administration and another for subgrantee admininstation). Additional details provided in instruction document. |
| Include “stormwater” in relation to arrearages and rate reduction in 1.1. NYC DEP does not charge separately for stormwater, but many utilities do, and there are also exclusive stormwater utilities. |
Storm water |
Clarified in instructions that stormwater may be included as a component of wastewater. Added definitions of both stormwater and wastewater in instructions. |
| DC Water does not differentiate between wastewater and drinking water; it would be helpful to consider overall water expenses (similar to energy utilities - we don't differentiate between generation and transmission costs). Suggest using the same terminology as LIHEAP - regular benefits (to address energy burden) and emergency/crisis (to address emergency issues, disconnection or risk of disconnection). |
Wastewater vs drinking water |
Added instructions for grantees when water utliies have a combined bill. |
| How do we address service providers that bill water and sewer as one item? We cannot determine how much is water and how much is sewer. |
Wastewater vs drinking water |
Added instructions for grantees when water utliies have a combined bill. |
| Comments on Benefits (LIHWAP Model Plan Section 2) |
Topic |
Decision - Action Taken |
| Under Section 2 (Benefits) of the Model Plan, a category for “Elderly” applicants is inexplicably excluded from the list of possible Priority application timeframes. This oversight should be corrected to ensure that elderly persons are included in the Priority groupings. See also https://www.nclc.org/images/pdf/special_projects/covid-19/NRDC_HHS_Emergency_Water_Assistance_Program.pdf In addition, this section of the Model Plan asks Grantees whether they provide individuals who are physically disabled the means to submit applications for benefits without leaving their homes. Access to remote processing of applications is critical at any time for the homebound or physically disabled, but in particular during a pandemic, when most community action agencies remain closed to in-person enrollment. The allocation of LIHWAP funds by grantees should follow current state LIHEAP allocation policies, which typically examine county-level poverty detailed in the U.S. Census American Community Survey. Subgrantees would get a percentage allocation of funding by percent of poverty within their jurisdiction. Allocations should be accompanied by dispersal timeline requirements so that grantees can re-allocate funds where most needed, and to ensure that low-income customers are actually receiving the benefits that have been allocated. |
Add category for elderly |
Added "Older Adult/Seniors (60 and Over)" as option in Question 2.8. Addressed in instructions. |
| 2.8, we would include elders, age 60 and older as another priority group. |
Add category for elderly |
Added "Older Adult/Seniors (60 and Over)" as option in Question 2.8. Addressed in instructions. |
| 2.7. Benefit Periods Is this a one-time benefit? Does this mean a HH can be assisted once per FFY or once for the entire duration of the funding period (from program start through 09/30/2023)? |
Benefit |
Added instructions clarifying that frequency is a grantee level decision. Revised 2.6 to remove reference to fiscal year and replaced with project period. |
| This section should be modeled after section 2.1 of the LIHEAP Model Plan, allowing further flexibility for states to use the higher of the Federal Poverty Guidelines or State Median Income. |
clarify |
Added instructions indicating that selection of Federal Poverty Guidelines vs. State Median Income is based on grantee policies and recommending modeling after LIHEAP policies. |
| Is it possible to use the a combination of FPL and SMI? For example, our LIHEAP uses SMI up to about 4 people per HH, then FPL takes over because the threshold is higher. If so, how do we denote that in the form? |
HH Need |
Adde an option for "Hybrid Federal and State" to Question 2.1. Also addressed in instructions. |
| Section 2 of the Model Plan should require states to identify any data they have concerning magnitude of need for low-income water assistance, which was used or could be used to inform decisions about the state benefits matrix and eligibility criteria. |
HH Need |
No narrative section or additional data requested (because of additional burden for grantees), but OCS will address in technical assisatnce regarding benefits determination. |
| Not a suggestion for clarification, but NYC DEP is interested in HHS’s / partners’ experience administering LIHEAP benefits to renters that have utilities included in their rents to better understand how NYC DEP can target similar populations on water bills. |
T/TA |
No change to Model Plan but OCS will consider in future guidance and techncial assistance. |
| Same feedback as above - please allow states/DC to consider water costs overall instead of bifurcating between waste/drinking water. |
Wastewater vs. drinking water (addressed in other section) |
Addresed through instructions. |
| Not sure why we need to address the break out of renters, subsidized as that is not really applicable here. I understand to duplicate the \LIHEAP form, but not everything should have to be in those section if not needed for this program. |
|
No change to model plan. |
| Comments on Outreach (LIHWAP Model Plan Section 3) |
Topic |
Decision - Action Taken |
| Another method we have found useful are automated outbound phone calling campaigns that alert customers to the program and invite them to apply. We also use social media frequently to reach our community. |
Automated outbound calls |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Utilities should have to consider calling or texting potentially eligible homes. Utilities should also have to consider having informational tables in highly trafficked areas. |
Automated outbound calls |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| The list includes good ideas for reaching customers via existing programs. Utilities may also have existing channels not on the list for reaching customers, including social media and door to door; existing efforts should be encouraged to continue at the utility's discretion, potentially in lieu of other specified approaches. Utilities may have existing outreach materials designed and printed, and any costs to update these due to LIHWAP availability should be considered as part of reimbursable administrative expenses. |
door to door |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Suggest adding flyers to food distribution boxes. |
food distribution boxes |
Not added, but other content was added to outreach options and "other" category will allow this. |
| Section 3.1 should include ‘multi-lingual announcements in all languages spoken by low income households within utility service area’ and ‘notification in ethnic language news and broadcast media outlets’; ‘notification through public health outreach pathways utilized for COVID-19 information dissemination‘; outreach to faith institutions serving low income, people of color, and non-English speaking congregations’. |
Multi lingual, ethnic centered media outlets, faith based outlets |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| should include ‘multi-lingual announcements in all languages spoken by low income households within utility service area’ and ‘notification in ethnic language news and broadcast media outlets’; ‘notification through public health outreach pathways utilized for COVID-19 information dissemination‘; outreach to faith institutions serving low income, people of color, and non-English speaking congregations’. |
Multi lingual, ethnic centered media outlets, faith based outlets |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Outreach may need to occur in multiple languages. Also we know that many immigrants did not take advantage of other COVID benefits out of concern of impact on path to citizenship. |
Multi lingual, ethnic centered media outlets, faith based outlets |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Outreach has always been a hurdle with customer assistance programs (CAPs) in water. Language considerations will be important. There should also be an effort to connect with local charitable and religious organizations such as the Salvation Army, that routinely assist low-income households. |
Multi lingual, ethnic centered media outlets, faith based outlets |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| 3.1 - Include option to “Work directly with utilities to identify potential recipients.” This is a more targeted approach in addition to mass mailings to all utility bill recipients. |
outreach through water utility providers |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Need government to provide information to water districts so they understand the program and eligibility. Found less buy-in with small districts in local cities. |
outreach through water utility providers |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Provide Water venders with publications to their clients they can send with their billing. |
outreach through water utility providers |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Get arrearage $ amounts from the districts, not directly from customers that fall within the unsustainable formulas used to determine assistance needs. |
outreach through water utility providers |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Consider adding selection about working with water providers to communicate about LIHWAP to customers. |
outreach through water utility providers |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| We would like to increase the mandate from monthly PSAs to include a mandate to have dedicated staff to manage program. The State should stress to CAA's and partner organizations to be more flexible in getting the word out, with the goal of making it more convenient for households to sign up. |
PSAs |
Added new content and outreach options (including reference to PSAs), reorganized the section and added some instructions. |
| 3.1 Ads on radio stations, YouTube, Facebook, Instagram, Hulu, Gmail banners, Credit Karma, water bill inserts, news paper articles every month, network with partnering state and local assistance programs. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. Section includes "other" option as well. |
| Most of these outreach methods work. We have had good experience with automated telephone notices and direct telephone calls. Websites and other social media also work but may not reach everyone. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Are these suggestions for the Sub-Grantee? If not, and the State makes elections, can the Sub-Grantee utilize other means not listed, such as social media outreach. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Use of social media (Facebook, nextdoor) to reach customers. Use community centers (recreation centers, churches, senior centers, school homework packets that go home to parents) to reach customers. Use direct dial messaging services to reach customers. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| The outreach is minimal at best and must incorporate the use of digital more, walking and proactive outreach, and must not depend on the use of bill inserts as much. It must also depend on the use of community agencies far more than just traditional methods of bills and dependence on the utilities. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| How would outreach be recommended? Through internet and websites, we currently aren't able to use any community halls yet due to covid-19. It's difficult getting the word out to everyone that doesn't use social media. |
social media |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| The scale of the delinquency problems requires new ways to reach families. The outreach needs to move beyond ways that require the household to go in to a Community Action Org. Technology could be used to reach thousands of families quickly in each city and town. Utilities know that bill inserts and fliers are no longer effective. |
texting |
Added new content and outreach options (e.g. automated phone, social media, multi-lingual outreach), reorganized the section and added some instructions. |
| Comments on Agency Designation (LIHWAP Model Plan Section 5) |
Topic |
Decision - Action Taken |
| Allow for a narrative explanation. |
Add narrative |
No change made to Model Plan Instructions clarify that a narrative explanation may be provided. |
| Local Community Action Agencies DHHS Salvation Army, etc. |
Add to list |
No change made to Model Plan. |
| Add water agencies to list. They could administer and should have a role. |
Add to list |
No change made to Model Plan. |
| Add utility provider to the list. |
Add to list |
No change made to Model Plan. |
| Add: 5.5a ‘Who ensures racial equity in approval of benefits? 5.6 What is your process for selecting local administrative agencies [add: ‘with cultural competency in reaching the most-impacted communities?’] Add 5.8 “Describe your accountability process for ensuring reconnection of service and continuation of service, and the process by which vendors will assure the use of payments follows the terms set out in the vendor agreements”. |
Racial equity |
No change made to Model Plan in this section. Section 3 now includes items related to multilingual/multicultural outreach and Section 7 now includes more specific prompts on nondiscrimination. Terms and conditions and reporting requirements will include information on accountabilty process. |
| Add: 5.5a ‘Who ensures racial equity in approval of benefits? 5.6 What is your process for selecting local administrative agencies [add: ‘with cultural competency in reaching the most-impacted communities?’] Add 5.8 “Describe your accountability process for ensuring reconnection of service and continuation of service, and the process by which vendors will assure the use of payments follows the terms set out in the vendor agreements”. |
Racial equity |
No change made to Model Plan in this section. Section 3 now includes items related to multilingual/multicultural outreach and Section 7 now includes more specific prompts on nondiscrimination. Terms and conditions and reporting requirements will include information on accountabilty process. |
| CONTINUATION OF RESPONSE TO QUESTION 27 (MODEL PLAN SECTION 4): -Any assistance that is specific to investor-owned utilities or other utility commission-regulated water and wastewater utilities -Any other local water and wastewater assistance programs operated at the utility or municipal level -Any use by the state or local governments of other federal COVID relief funds for water and wastewater assistance -Any direct state appropriations or other state funding sources directed to water and wastewater assistance -Rules concerning utility deferred payment agreements or arrearage management plans -Add to the examples of federal programs that must be coordinated with – e.g., the Homeowner Assistance Fund run by the Treasury Dept. should be added. It should also be added to Terms and Conditions 11.d and 11.e. (https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/homeowner-assistance-fund) 2- Regarding coordinated outreach and intake for multiple programs, the Model Plan should prompt grantees to clearly explain how this coordination will be useful and effective from the customer’s perspective, and not just a matter of pointing an applicant to another office or agency and send them off. |
Section 4 |
OCS added to the list of programs for coordination (specifically added Department of Treasury Emergency Rental Assistance Program and Homeowner Assistance Program. While the other proposed changes are useful, OCS did not significantly expand this section and will address other areas of coordination (e.g. leveraging funds and ensuring that coordination is useful from a customer perspective) through training and technical assistance. |
| Under 5.1 it states if “Welfare Agency” is selected 5.2, 5.3, and 5.4 must be completed; however there plan jumps to 5.5. |
Typo |
Correct and check all numbering. Remove reference to 5.2-5.4 from the heaader |
| There is not a question for 5.3 and 5.4 for Welfare Agencies. |
Typo |
Address numbering issue. |
| In Section 5.8 of the Plan LOCAL AGENCIES We believe grantees should not only identify their selected subgrantees but provide assurances that those organizations have demonstrated experience in outreach to low-income households and utilities and in delivering emergency services to the eligible population. Community Action agencies that now deliver LIHEAP and /or COVID Relief emergency assistance should be assumed to be subgrantees for delivering water assistance. |
|
No change made to Model Plan. Community Action Agencies are already specifically highlighted as a potential provider. |
| Comments on Water Suppliers (LIHWAP Model Plan Section 6) |
Topic |
Decision - Action Taken |
| Change language of 6.5: Do you make payments contingent on all vendors (regulated and unregulated) taking all appropriate measures to alleviate the water burdens of all eligible households? Describe accountability measures taken to withhold payments if eligible households are not identified and restored service or granted assistance. |
Accountability |
This question was removed. For now, the question of "unregulated" vendors (which would relate to water delivery companies or potentially well-maintenance or septic companies) will be addressed through other guidance. |
| Question 6.3 may be impossible to answer beyond having this as a clause in the vendor agreement. Enforcement may be difficult. |
difficult requirement |
No change to model plan. |
| Add “stormwater” to the note at the beginning of Section 6. The note should read as: “Water suppliers refers to drinking, wastewater and/or stormwater suppliers as they may be different entities at the local level” |
Drinking water/stormwater/wastewater |
No change to model plan, but instructions now specifically address stormwater. |
| Can you provide examples of appropriate measures that unregulated vendors may take to alleviate the water burden of eligible households? |
Examples |
This question was removed. For now, the question of "unregulated" vendors (which would relate to water delivery companies or potentially well-maintenance or septic companies) will be addressed through other guidance. |
| Is EFT the same as ACH? What is an unregulated water vendor? All water utilities are regulated to some degree. |
Instructions/Definitions |
The model plan was modified to spell out Electronic Funds Transfer (EFT). This item was also added to definitions in an instructions section which also discusses Automated Clearinghouses and wire transfer. |
| The following language is a bit unclear, but it seems it will be burdensome: "6.3 How do you assure that the home water supplier will charge the eligible household, in the normal billing process, the difference between the actual cost of the water and or wastewater and the amount of the payment?" |
Plain language |
Question was modified to read as follows: "How do you notify the household of the amount of assistance paid, and the timing of the assistance payment?" |
| Again, many of these requirements will mirror our LIHEAP plan, except it will be water vendors. Since we do not even know yet, for sure, how these benefits will be issued - by check or EFT - this model plan is asking for information that has not yet been decided, When we do not know how much money we are receiving it is hard to determine the most efficient and economical way to administer these benefits, |
Planning sequence |
No change to Model Plan. |
| Plan section 6.5 We believe the language should apply to all vendors. The protections are essential, and are generally not guaranteed by any utilities at present. We do not understand the basis of this distinction in the plan. |
Vendors |
This question was removed. For now, the question of "unregulated" vendors (which would relate to water delivery companies or potentially well-maintenance or septic companies) will be addressed through other guidance. |
| Section 6.5 asks “Do you make payments contingent on unregulated vendors taking appropriate measures to alleviate the water burden of eligible households?” This Model Plan provision should not be limited to “unregulated vendors”. There’s no reason to distinguish here between water utilities that are or aren’t regulated by utility commissions. Moreover, in some states, regulated water utilities aren’t subject to the same consumer protections as regulated energy utilities, and in most they don’t have the same assistance available as regulated electric/gas utilities. It certainly can’t be assumed that states have this issue covered for regulated water systems. Additionally, Section 6.5 should list the following potential measures, which states should indicate whether they are doing or not: -COVID-specific: ----Disconnection moratorium ----No late fees, interest, or penalty charges ----Ability to enter into payment plan of 6 months or longer ----Reconnection of service for disconnected customers ----Enrollment in a discounted rate -General (not COVID-specific) ----Consumer protections regarding shutoffs (e.g., minimum notice period, protection of vulnerable populations, minimum amount overdue before disconnection allowed, opportunity for payment plan before disconnection, other procedural or substantive restrictions on shutoffs) ----Data reporting requirements for utilities – on a permanent basis – e.g., periodic reporting on number of shutoffs (as in CA) ----Percentage of income payment plan ----Lifeline rates ----Water efficiency assistance |
Vendors |
Move 6.5 to Section 2 Benefits. OCS added the list of items from this comment in Section 2. |
| Comments on Timely and Meaningful Public Participation (LIHWAP Model Plan Section 8) |
Topic |
Decision - Action Taken |
| 8.1 Add:“Survey of households with arrearages”; “Stakeholder meetings with consumer advocacy and water advocacy organizations serving communities of color and low income communities”; “Community design and consultation sessions to inform program design and efficacy.” |
Add category |
OCS added a box to question 8.1 for "Comments are solicited during outreach activities." OCS did not consider surveys our households with arrearages to be immediately feasible. |
| Overall: Make community planning and engagement a required feature of the Model Plan. 8.1 Add: “Survey of households with arrearages”; “Stakeholder meetings with consumer advocacy and water advocacy organizations serving communities of color and low income communities”; “Community design and consultation sessions to inform program design and efficacy.” |
Add category |
OCS added a box to question 8.1 for "Comments are solicited during outreach activities." OCS did not consider surveys our households with arrearages to be immediately feasible. |
| Include virtual town halls. |
Add option for virtual meeting |
No change to Model Plan. This item could be addressed through stakeholder or consultation meetings. |
| Since this is a water funding program they should be required to engage utilities. |
Engage Water providers |
Add parentheses behind box for stakeholder consultation meetings with various potential stakeholders (e.g. water utilities, community service providers, potential program participants). |
| Requests for comments and stakeholder consultation must include opportunities for water/wastewater utilities to provide input. Utilities will be vital in ensuring the LIHWAP program is a success in their state and nationally, and their input is vital on the front end. |
Engage Water providers |
Add parentheses behind box for stakeholder consultation meetings with various potential stakeholders (e.g. water utilities, community service providers, potential program participants). |
| Consider adding questions about what was done to ensure engagement was equitable. Also consider adding something about gaining feedback from (potential) program participants. |
Ensure equitable input |
Add parentheses behind box for stakeholder consultation meetings with various potential stakeholders (e.g. water utilities, community service providers, potential program participants) |
| Make information available in several different ways (not just web based) and in various languages. |
Multi lingual option |
Addressed in Outreach section. |
| HHS must make sure public participation is real and meaningful, not just a state checking a box and burying a notice on a website that no one will see. In particular, T&C 11.l requires “meaningful public participation in the development of the [grantee’s] LIHWAP implementation plan,” but states that “publication and acceptance of comments via the grantee’s website” would be sufficient. And Model Plan 8.1 allows the outreach for solicitation of comments to be satisfied simply by checking a box that the “request for comments on draft Plan is advertised.” HHS should provide more direction to make sure that the notice of availability of the plan for comment is widely disseminated to relevant stakeholders and communities, so that people will know they have the opportunity to comment. This is a new program, so there is not a community of people that knows to look out for annual notices of a draft plan, as there may be with LIHEAP. We commend HHS for including in the model plan (sections 8.2 through 8.5) a requirement to summarize comments received and any changes made in response to comments. |
Request Comment summary |
Added question 8.4 (Summarize the comments you received on your plan here). |
| Comments on Program Integrity (LIHWAP Model Plan Section 12) |
Topic |
Decision - Action Taken |
It is critical that HHS establish an emergency program that is flexible, fair to the consumers most in need of assistance and committed to principles of equity. The Model Plan currently requires applicants to possess a social security number -- a requirement that inequitably denies any water assistance benefit to undocumented persons who are living and working in communities throughout the country. That requirement should be removed from the Model Plan to ensure that LIHWAP benefits flow to this population group as well as those possessing social security numbers. Undocumented persons have been particularly hard hit by the COVID-19 pandemic, both from a public health and economic perspective. It is estimated that there are more than 10 million undocumented immigrants in the U.S. Many of these individuals work in the hospitality and other industries negatively impacted by the pandemic. And, because undocumented immigrants are more likely to make less at these jobs to begin with, they are likely not to have savings to rely on and are therefore especially vulnerable. Many are having to make the hard choice of whether to keep working so they can pay for essentials, or keeping themselves and their families safe by following social distancing recommendations. The Centers for Disease Control continues to emphasize that handwashing is essential to limit the spread of COVID-19. Safe and affordable drinking water and wastewater services are also required for habitable housing conditions, so loss of these services jeopardizes access to housing. A recent report by Duke University researcher found that, if utility disconnections had been barred nationwide from March through November 2020, COVID-19 infections rates could have been reduced by 8.7% and deaths by 14.8%. For many low-income households, especially people of color, unaffordable water costs and the resulting threat of water service disconnections are not new. Today, as the pandemic continues, millions more risk losing running water because they cannot pay their water bills. Nationwide, the Department of Labor reports that at the end of December 2020, 10.7 million Americans were unemployed and the unemployment rate and the number of unemployed individuals was double those in February 2020.3 In California, a staggering $1 billion in household water debt affects nearly five million people, with an average debt of $500 dollars per household. The pandemic is far from over, with more than 460,000 lives lost as of February 9, 2021 and over 26.8 million active cases of COVID-19. People continue to shelter at home to protect themselves from and mitigate the spread of COVID-19, thereby increasing their household water usage and water bills. Having access to affordable water and wastewater service is tied to the very habitability of the home. The status of a person’s citizenship should not be a qualifying factor for critical water assistance relief.
It must be noted, too, that in particular, undocumented persons have been omitted from the many state and federal benefit programs that exist to assist those in need during this pandemic. Any immigrant, not just undocumented individuals, who does not have a social security number did not receive a $1,200 relief check authorized in the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act or a relief check from the recently enacted American Recovery Act. On top of that, even if individuals have a social security number, if they filed taxes and listed an undocumented child or family member on the returns, they will not receive a relief check. Undocumented persons do not qualify for unemployment, which is affecting thousands throughout the U.S. Moreover, excluding undocumented persons from the eligibility pool of ILHWAP applicants is inequitable. An often-overlooked fact by those who seek to exclude undocumented persons from assistance programs is that many illegal immigrants pay payroll taxes and sales taxes. NCLC urges HSS to eliminate this barrier to essential water assistance for millions of U.S. households. fns: See https://www.npr.org/local/309/2020/03/27/822475329/thousands-of-undocumented-workers-face-the-pandemic-without-a-safety-net; See also https://www.chicago.gov/city/en/sites/covid-19/home/employment-and-financial-assistance.html (“Undocumented immigrants are not eligible at this time. To be eligible, you must be authorized to work in the U.S.”) https://www.nber.org/papers/w28394 https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/covid-19watersystemsurvey.html |
Citizenship Questions |
OCS will maintain consistency with LIHEAP policy regarding citizenship as this would be a significant departure from current policies and procedures. However, the instructions make clear proportionate eligibility if household has mixed citizenship status. Note: If a household has already determined for LIHEAP it does not need to be re-tested. |
| Overall, the program operator should identify all eligible participants by those that have experienced shutoffs or that have water debt on their bills--it should NOT be incumbent on potential participants to learn about the program and submit independent applications. 12.2 ADD: ‘Medicare card’ to types of Government I.D. examples to address low income seniors who may not have other government issued i.d. 12.3 ADD: ‘Match Medicare card to HHS/CMS database’ 12.4 REMOVE THIS PROVISION: The program should allow all income-qualifying applicants eligibility regardless of documentation status. |
Documentation and Citizenship Status |
OCS will maintain consistency with LIHEAP policy regarding citizenship as this would be a significant departure from current policies and procedures. However, the instructions make clear proportionate eligibility if household has mixed citizenship status. Note: If a household has already determined for LIHEAP it does not need to be re-tested. |
| Could also include a reporting method for any discrimination taken against clients who receive a benefit through LIHWAP. |
Discrimination Reporting |
No change in this section, but Section 7 was modified to specifically request information on how grantee will enforce nondiscrimination requirements. |
| Other General Comments on LIHWAP Model Plan |
Decision Action Taken |
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| Cannot fill the form online, yet, there are a lot of boxes to tick, and explanations to write down. |
A fillable PDF will be provided upon OMB clearance. |
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| Please make this program a 2021-era program with modern technology, with fast track qualification process, funding that is expended quickly to states then to water systems to support low-income customers, transparent data about funding expenditure to the public, and any other information that can be announced far and wide. Low-income water customers have been suffering for far too long. Other programs including internet and cell phone assistance programs have outpaced this essential need. They need immediate attention to offset their high water bills through short term and long term assistance. How can this be achieved quickly and effectively? |
A fillable PDF will be provided upon OMB clearance. OCS will work with grantees on other technological outreach options in the future. |
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| HHS should consider removing the words “Low Income” from the name of this program. An alternative appropriate program name could be the “Home Water Assistance Program (HWAP).” We agree with comments made on the April 20th webinar that titling the program as “Low Income” could dissuade some qualified recipients from applying. |
The word "low-income" was in the appropriations language and will be part of the program name. However, guidance will be provided for local outreach and marketing, because the term "low-income" does not need to be highlighted in outreach and intake efforts. |
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| -Overall, the program operator should identify all eligible participants by those that have experienced shutoffs or that have water debt on their bills--it should NOT be incumbent on potential participants to learn about the program and submit independent applications. -Model program should make clear the undocumented residents are eligible for assistance. -Model program should be seen as data collection mechanism for a long term permanent program to understand trends in unaffordability and debt accrual and populations most affected. Therefore, demographic data should be collected for all applicants and noted in any eligibility or program decisions to ensure racial equity in beneficiaries. |
This is a repeat of input from other sections. |
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| Some sections can be condensed to reduce the length of this plan. |
OCS removed several sections from the LIHEAP plan, but the current sections are all considered necessary at this stage. |
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| I will need to review |
N/A |
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| Keep it simple to administer |
A fillable PDF will be provided upon OMB clearance and technical assistance will be provided to assist grantees where possible. |
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| The states will have different levels of water customer debt, partly due to whether there was a state-wide moratorium on shutoffs. |
No change… benefit levels are determined on a state-by-state basis. |
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| These needs to be set up for a simplified method to be filled out and submitted without having to start a free trial or subscription with Adobe. |
A fillable PDF will be provided upon OMB clearance. Grantees will not need to have Adobe. |
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| Please see my comments in the previous section about limiting the complexity of this process as much as is feasible, given that it is a one time program at this point. Simplicity is going to be the key in getting these funds distributed to those in need sooner rather than later. |
No change…OCS will consider ways to keep simple and managable while integrating with current processes and procedures. |
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| The elements associated with items 30 to 35 are too complicated for most small utilities. There are 50,000 public utilities in the US. Average award would be $23,000 if divided evenly. The effort to expend the funds should not exceed the funds allocated. |
No immediate change to Model Plan. OCS will continue to review and provide technical assistance. |
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| This application process seems burdensome and likely to result in underutilization of the funding which we know is needed given the amount of household water debt in the country. This should be addressed to simplify and streamline. |
No immediate change to Model Plan. OCS will continue to review and provide technical assistance. |
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| Get arrearage $ amounts from the districts, not directly from customers that fall within the unsustainable formulas used to determine assistance needs. |
No immediate change to Model Plan. OCS will continue to review and provide technical assistance. |
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| accompany water assistance grants with home conservation assessments and education sessions. |
No immediate change to Model Plan. OCS will continue to review and provide technical assistance. |
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| The grant application is large and for smaller allocation Tribes does not seem worth the time. |
OCS will continue to consider assistance to tribes and has established a minimum allotment of $10,000 which will assist smaller tribes. |
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| OHCS cannot provide accurate estimations without understanding the funding allocation to Oregon. |
OCS will publish allocations with the award amounts. |
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| This benefit is not available to undocumented households who experience a disparate economic burden based on income, housing and utility costs. |
OCS will maintain consistency with LIHEAP policy regarding citizenship as this would be a significant departure from current policies and procedures. However, the instructions make clear proportionate eligibility if household has mixed citizenship status. Note: If a household has already determined for LIHEAP it does not need to be re-tested. |
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| Overall, state administering agencies should be encouraged to mirror the LIHEAP Wood, Propane and Oil program to the greatest extent possible. |
OCS will continue to consider issues and guidance around water delivery services, well maintenance and septic, but these are not clearly identified in the appropriations language and are not highlighted in the instructions. |
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| Will need more time to conduct a thorough analysis of the components of the plan. Ability to request technical assistance is key. |
No immediate change to Model Plan. OCS will continue to review and provide technical assistance. |
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| Again, is funding available for all enrolled Tribal members of SRPMIC (on/off the community), or only if residing within the boundaries? Are non-native applicants eligible for the funding that are residing within the boundaries.? |
Additional guidance and techncal assistance for tribes will be developed. |
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| The LIHWAP application is very similar to LIHEAP Model plan. We should not have any issues completing the plan. |
No change. |
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| We would like to submit the LIHWAP Model Plan via OLDC. |
A fill able PDF will be developed as the most immediately feasible approach and additional guidance will be provided on submission of the plan. |
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