OREGON HOUSING AND COMMUNITY SERVICES

Hearing Officer’s Report to Agency on Public Hearing

Public Hearing

The public hearing on the Draft 2026 Low-Income Home Energy Assistance Program (LIHEAP) State Plan for Oregon was convened at 11:00 am.

Virtual attendees were asked to provide their name and indicate if they wished to comment on the proposed state plan. They were informed of the procedures for taking comments and that the hearing was being recorded. Before receiving comments, we briefly

summarized the purpose of the public hearing and cited the location of the state plan.

The hearing was adjourned at 11:30 am. The public comment period closed at 5:00 pm on Friday, August 29, 2025.

List of Attendees:

Three (3) people attended. Two (2) people provided oral comments, and one (1) person had no comment. One (1) person, who had also provided oral comments during the public hearing, submitted written comments.

Summary of Oral Comments with Agency Response:

The following summarizes the people who testified at the hearing, provides a summary of their testimony, and OHCS’ response.

Nicole Sergi, Klamath-Lake Community Action Services (KLCAS):

Where does the additional $21.00 for Supplemental Nutrition Assistance Program (SNAP) participants originate?

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Agency response: Those funds come from LIHEAP.

Can you further define “48 hours” and “in-kind benefits” in program terms?

Agency response: A crisis exists when a household faces a sudden or unexpected event beyond their control resulting in the inability to pay household heating or

cooling costs. Crisis applications will be addressed within 48 hours of a completed application if such household is eligible to receive such benefits. All authorized

crisis payments must be pledged to the vendor/utility within 48 hours. If a pledge is unable to be made, agencies must provide some sort of assistance that addresses the energy crisis. In the event of household energy related emergencies, in-kind

benefits may be used to augment crisis assistance payments. These include, but are not limited to sleeping bags, clothing, blankets, and/or emergency disaster kits etc. (please check with energy staff at OHCS to ensure in kind benefits are appropriate).

Could OHCS consider the implications of the increased Oregon Energy Assistance Program (OEAP) funds, especially for Community Action Agencies (CAA) who do not receive them, when finalizing the LIHEAP benefit matrix?

Agency response: The LIHEAP funding formula was developed and agreed upon with the CAA network and CAPO and an agreed upon formula was developed. A similar exercise would need to occur to implement a change. OHCS does intend to conduct community engagement related to OEAP, and we look forward to hearing recommendations that might impact a LIHEAP formula change consideration. This is not a change that can be made swiftly and in time to be effective for the 2026 LIHEAP State Plan for Oregon. There is only one CAA that does not receive OEAP

funds. Regarding the benefit matrix, those benefit amounts are intended to address energy burden and are not dependent on funding levels.

Lauren Kolojejchick-Kotch, Community Action Partnership of Oregon (CAPO):

What is the reasoning for the changes to administrative rates, carryover percentage, and Assurance 16 category percentages?

Agency response: There were no changes to those rates for sub-grantees. The changes in the state plan were directed by HHS and are only reflective of statewide estimates at the end of the program year. Regarding the changes to the Assurance 16 percentages, only five of the CAAs have requested Assurance 16 funds for Program Year 2026, which means the total allocation would be less than the maximum allowed.

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(No question) This person showed support for the wood and pellet stove repair and replacement as allowed costs.

Could generators be an eligible cost for rural clients through LIHEAP’s Weatherization Assistance Program funds?

Agency response: Generators are allowable through energy assistance under extreme circumstances or in disasters through the LIHEAP energy assistance program. Please reach out to OHCS Weatherization Assistance Program staff for information regarding Weatherization program questions.

Could OHCS clarify the timeline for responses to these comments and questions?

Agency response: As addressed during the hearing, the responses to these

questions will be provided in writing with the Hearing Officer’s Report, which can be found at this website. This report is compiled after the close of the public comment period, once OHCS staff has had sufficient opportunity to review all received public comments. OHCS will make all attempts to post the report in a timely manner, but this timeline is dependent upon the comments received and the efforts required to address them.

Will there be an opportunity to view the LIHEAP benefit matrix before it is finalized?

Agency response: The LIHEAP benefit matrix is currently being developed with the assistance of APPRISE, a contractor with extensive experience in this field. We

anticipate the receipt of the matrix by September 15th. Upon receipt, OHCS will add the matrix to the manual and post it on this website. OHCS will notify the CAA

network once this is completed.

Summary of Written Comments with Agency Response:

The following summarizes the people who submitted written comments before the end of the comment period, a summary of their testimony, and OHCS’ response.

Lauren Kolojejchick-Kotch, Community Action Partnership of Oregon (CAPO): What is the reasoning for OHCS not electing the full 10% administrative costs?

Agency response: The changes in the state plan were directed by HHS and are only reflective of statewide estimates of final expenses at the end of the program year.

There are no changes to the percentages allocated to each CAA.

What is the reasoning behind removal of the categorical eligibility for SNAP participants?

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Agency response: As required by HHS, this was only a clarification to align with actual practices as neither OHCS nor Oregon Department of Human Services (for

the Heat and Eat Program) utilize categorical eligibility. Both agencies, currently and historically, use the income guidelines to determine eligibility. This was a change to a prior request from HHS.

Could OHCS consider the implications between the increased OEAP funds and the LIHEAP benefit matrix in terms of addressing energy burden?

Agency response: This question was addressed with the oral comments received above. The benefit matrix is intended to address energy burden and is not

dependent on funding levels. The increased OEAP funding has no impact or relationship to how LIHEAP functions or to the payment matrix.

(No question) This person showed support for the addition of wood and pellet stove repair and replacement as allowable costs.

Can OHCS provide further definition of the “48 hours” in program terms for crisis applications?

Agency response: This question was addressed with the oral comments received above.

(No question) This person showed support for OHCS’ continued work with the CAA network on bulk fuel benefit payments and the benefits and cost for different approaches.

Appendices:

A – Transcript of public hearing

B – Submitted written comments

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6 In the Matter of the:

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IN THE STATE OF OREGON PUBLIC HEARING

8 2026 Draft Low-Income Home Energy Assistance Program (LIHEAP) State Plan for Oregon

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16 Transcript of Hearing Procedures

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18 Date: Wednesday, July 30, 2025

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20 Time: 11:00 am to 11:30 am

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1. Place: Microsoft Teams Meeting, hosted online

2. Oregon Housing & Community Services

3. 725 Summer St NE, Suite B

4. Salem, OR 97301

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1. Before: David Kaufman, Energy Assistance Program Coordinator & Hearing Officer

2. Joy Aldrich, Energy Services Business Analyst

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1. KAUFMAN David * HCS

2. My name is David Kaufman, and I will be serving as the Oregon Housing and

3. Community Services’ hearing officer. The purpose of this hearing is to take public

4. comment on the Draft 2026 Low-Income Home Energy Assistance Program State

5. Plan. Copies of the state plan are available on the OHCS website by e-mail or through

6. the United States Postal Service upon request.

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1. Because we won't have a traditional attendance list, we'll attempt to ask each

2. person in attendance if they would like to offer comments. Before offering

3. comments, please state your name and the organization you represent, if any, and

4. then present your comments. If you have written material to enter into the record,

5. please say so, and if you wish, summarize it briefly. If you have not already

6. submitted your comments to OHCS, please provide us a copy via either e-mail, in

7. person, or Postal Service.

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1. No responses to questions or comments will be provided at this time. OHCS will

2. review issues raised during the public comment period and the hearings

3. officer’s report will contain all comments provided to us.

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1. In addition to presenting oral comments at this hearing, anyone may submit written

2. comments until 5:00 PM August 29, 2025, which is the close of the public comment

3. period. Comments received after this time will not be reviewed or considered by the

4. agency unless the agency decides to extend the public comment period for

5. everyone.

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56 So, does anyone have any comments that they would like to provide?

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1. Nicole Sergi

2. Good morning. My name is Nicole Sergei from Klamath Lake Community Action

3. Services. I would like to provide some comments.

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1. Thank you so much for the opportunity to provide feedback on the LIHEAP draft

2. state plan. We facilitated a meeting with the network and we just are seeking

3. clarification on several points and a few of the points we would like to request:

4. (1) Clarification regarding the additional $21.00 that was provided to SNAP

5. participants specifically. Could you clarify whether this amount is funded through

6. Oregon Department of Human Resources, Services Resources? Sorry.

7. And then I have a few others.

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70 Would you like me to pause?

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1. KAUFMAN David * HCS

2. No, you can keep going. We won't be providing any responses here. So, go ahead

3. and you can read your questions into the into the record.

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1. Nicole Sergi

2. Thank you.

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1. (2) We also wanted to flag for your consideration that implications of light of OEAP

2. increases when finalizing the LIHEAP matrix, especially for those agencies who did

3. not, do not receive OEAP.

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1. (3) And then on 4.2, could you please clarify whether the 48 hours refers to calendar

2. hours or business hours?

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1. (4) And additionally, we would appreciate further information regarding in-kind

2. benefits.

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89 And those are all my clarification questions. Thank you.

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1. KAUFMAN David * HCS

2. Thanks, Nicole. Lauren, good morning. Did you have any comments you wanted to

3. provide?

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1. Lauren Kolojejchick-Kotch

2. Good morning. I do. I apologize for any background noise. I was displaced with a

3. wildfire and I’m still kind of moving back to my house. But, so, I apologize if there's

4. any background noise, but for the record, I'm Lauren Kololjejchick-Kotch, the Utility

5. Policy Manager for the Community Action Partnership of Oregon. And I'll just kind of

6. add to what Nicole has started, just a few points for clarification.

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1. (1) In section 1.2., we would like additional care, excuse me, clarification specifically

2. about the changes to the administrative rate, the percentage of carryover to the

3. following fiscal year, and changes to Assurance 16 percentages. We’re concerned

4. about the impact to agencies around, especially around those admin rates, and we’d

5. just like some… I understand that the changes were made at the request of HHS. I

6. was wondering if there's additional context to add to those draft reductions or draft

7. changes.

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1. (2) Next, I am wondering, I just want to, I guess, state that we support the

2. compatibility kind of pieces around in section 4.15 around repair and replacement of

3. wood and pellet stoves.

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1. (3) And then additionally, this isn't kind of specific to any of the changes to the state

2. plan that were called out, but I have heard from weatherization program staff that

3. there is, there's interest—and I don't know exactly where this fits in in the kind of

4. draft state plan—but there's interest in potentially adding the purchase of

5. generators. This is specifically for rural clients, for emergency use, particularly in

6. situations where existing heating or cooling systems are non-functional or heating is

7. unavailable. So, they're wondering if generators could possibly or may be considered

8. for emergency use for those for those rural clients.

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1. (4) And then just a couple more process points of clarification. I'm, I've been on this

2. job for how many months now… three? Coming up on four months.

3. But I'm curious about this. I know we've talked to you more specifically, David, but

4. curious about the process now for feedback. Or, kind of, how responses to our

5. points of clarification. We intend to submit written comments as well and ask for,

6. you know, responses to our… kind of those key points for clarification.

7. But I'm curious about the timeline for responses and what that process might be?

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1. (5) And specific to section 3.6, I am wondering if again… this is, I'm new to this

2. process, so I'm curious if we will be able to see the finalized benefit matrix before

3. the state plan is submitted in September?

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1. And those, I believe, are the points I have right now, but I will chime back in if I

2. missed something.

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1. KAUFMAN David * HCS

2. Okay, thank you. So, since we have. Oh, I'm sorry. I'm sorry.

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1. Lauren Kolojejchick-Kotch

2. And thank you for the opportunity. I just wanted to say thank you for the

3. opportunity. I'm going on mute now.

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1. KAUFMAN David * HCS

2. Oh, absolutely. Okay.

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1. ALDRICH Joy * HCS

2. And I can provide the clarity on follow up. There is a hearing officer's report that

3. comes out after the end of the public comment period. So, that will be available at

4. once David and I are finished with that.

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1. Lauren Kolojejchick-Kotch

2. Thank you. And I understand that the comment period is through the last day of

3. August, is that correct?

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1. KAUFMAN David * HCS

2. Yes, well 29th, but yes, basically. Yeah, through the end of August.

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1. Lauren Kolojejchick-Kotch

2. Thank you.

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1. KAUFMAN David * HCS

2. Okay, so seeing no one else here at this time, we'll close the hearing and reopen if

3. and when someone else arrives.

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1. ALDRICH Joy * HCS

2. So, I'm going to go ahead and pause our recording, David. And then, Nicole and

3. Lauren, you're welcome to stay on to see if anyone else arrives. But the hearing

4. officer's report will capture any comments received throughout the period of this

5. public hearing. So, through 11:30.

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1. Lauren Kolojejchick-Kotch

2. Thank you very much. I might stay on just to see if there are any other comments

3. that are made, but I appreciate it. Thank you.

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1. Nicole Sergi

2. Thank you.

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1. Christina Zamora

2. [Rough connection] Yeah, it was giving me that odd screen.

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1. KAUFMAN David * HCS

2. Christina! Did you have any comments that you wanted to provide?

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1. Christina Zamora

2. Actually, I'm just attending to support Nicole and Lauren providing comments.

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1. KAUFMAN David * HCS

2. Oh, Okay. All right. Thank you.

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1. Christina Zamora

2. Uh-huh.

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1. KAUFMAN David * HCS

2. So, we've adjourned until they provided their comments. We've adjourned until

3. anyone else come in, and, if and when that happens, then we'll reconvene.

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1. Christina Zamora

2. Okay, sounds good. Thank you, David.

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1. KAUFMAN David * HCS

2. Uh-huh.

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1. Lauren Kolojejchick-Kotch

2. How you might integrate the feedback or the comments that you're receiving today,

3. does that need to be on the record or can it be posted?

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1. KAUFMAN David * HCS

2. Well, yeah, I think in order to present a fair and accurate, you know to have the

3. questions accurately, yeah, I think it should be something written. You don't have

4. to… There's no requirement for you to do that.

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1. Lauren Kolojejchick-Kotch

2. Okay. I'm happy to put it on the record here, but I guess I'm just wondering how we

3. might know understand how our feedback is being integrated into the, you know,

4. the final plan that's submitted.

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1. ALDRICH Joy * HCS

2. I can go ahead and provide a little bit of clarity on that, David?

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1. Lauren Kolojejchick-Kotch

2. Okay.

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1. ALDRICH Joy * HCS

2. Governor Kotek had established…It wasn't an executive order, it was more of a new

3. standard… as of this most recent May, at least with rulemakings. Public hearings like

4. this are a little bit different, but the public hearing officer's report kind of bridges

5. that gap. The state agencies are supposed to be providing a lot more transparency

6. than they have been in showing what public comments were received and how, at

7. the end of it, describing how the agency has considered the comments, whether

8. they will be integrated or not. It doesn't necessarily have to go really in depth, but it

9. will follow up at least on a general level with the questions or the comments. Just a

10. way to basically follow through to show what was received in the public comment

11. period versus what the agency is moving forward with it for.

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1. Lauren Kolojejchick-Kotch

2. Thank you. Okay, so in that report, there will be a kind of an indication about how

3. that if and how that comment was addressed in the final plan that was submitted? I

4. guess, this question is coming up because the comment period is just, you know,

5. days before the plan will be submitted, so I was just, I was just curious about that

6. kind of reporting.

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245 I appreciate that. Thank you.

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1. KAUFMAN David * HCS

2. All right. The time is 11:30 and I'm reopening the public hearing. Seeing that no one

3. else has come to present public comment, I'm now closing this hearing.

4. These proceedings are adjourned. Thank you everybody.

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August 29, 2025

Oregon Housing and Community Services 725 Summer St NE B

Salem, OR 97301

Re: LIHEAP State Plan

Introduction:

The Community Action Partnership of Oregon (CAPO) thanks Oregon Housing and Community Services (OHCS) Staff for their work to ensure Oregon has a flexible state plan for the delivery of the Low-Income Home Energy Assistance Program across the state. We know there is variation in how states approach their state plans, and we are submitting written comments today, following the July 30th State Plan public hearing to participate in the public process and reiterate some of our questions and comments. We look forward to OHCS reporting following the comment period illustrating how comments were considered or incorporated into the state plan. Comments below are referenced by section of the state plan and are consistent with what was presented at the public hearing on July 30, 2025.

1.2: We understand that percentages in this section, including the administrative rate, are both a best guess at what will actually be spent at the end of 2026 and based on direction from the U.S. Department of Health and Human Services (HHS) considering actual administrative dollars spent in the previous year. We also understand that this percentage can be amended throughout that year. That said, we still have concerns and interest, both in planning and in practice, to maximize administrative dollars to Community Action Agencies (CAAs). If this plan will not have a real effect on the percentage of administrative dollars that agencies see, why would this plan still not be reflective of the 10% admin that could be maximized between OCHS and CAAs?

1.4: We understand that there are benefits both in financial terms and in terms of reduced administrative burden, to categorical eligibility or express enrollment relationships between income-qualified programs. This type of relationship was allowed between LIHEAP and SNAP under the state plan as recently as last year. The CAA network is a critical partner in this work, and requests more information about this change to the State Plan that comes at the request of HHS, to better understand the situation and OHCS responsibilities to HHS.

2.6/3.6: We understand there are no plans to make substantial changes to the benefit matrix, and that the LIHEAP matrix may be treated differently than the OEAP matrix. However, many CAAs have noted that an increase to OEAP could have implications for the LIHEAP matrix, especially as we engage in effort to substantially address energy burden across the state. The

network would welcome the opportunity to discuss any potential changes that would balance agency needs and opportunities to address energy burden.

We also understand that the matrix is based on a long-time formula with data that has not been updated in the last 2-3 years, which surely presents a challenge at this moment. We appreciate OHCS Staff’s efforts to navigate this challenge, and in the future, the CAA network would appreciate the opportunity to see a draft matrix along with the state plan draft.

4.15: We support the addition of wood and pellet stove repair and replacement.

4.2: We acknowledge that LIHEAP is a block grant, which is fundamentally less prescriptive and ideally flexible to address regional needs and circumstances. Some members of the network, however, were seeking clarity about when the 48 hour timeline to process a crisis application would start. We now understand that the “clock” starts to process applications when a CAA might reasonably receive and be able to act on the application, based on CAA open hours. We appreciate the clarity.

Additional comments:

We also understand that there have been both long and near term discussions about bulk fuel payments, which presents a challenge to some CAAs and have recently been raised with the new CAPO Utility Policy Manager. We appreciate OHCS’ efforts to gain clarity on the opportunities for split payment for bulk fuels (as opposed to one payment amount), and to communicate the benefits and costs of each approach with the CAA network, if applicable.

Thank you for your work to ensure the program offers flexibility to energy assistance and weatherization programs that serve all Oregonians. We appreciate the opportunity to engage in this public process and on an ongoing basis with OHCS to ensure the best possible plan and program for CAAs and low-income Oregonians. We look forward to continuing to be a partner in collecting CAA network feedback and more robust and impactful LIHEAP services.

Respectfully submitted,

Lauren Kolojejchick-Kotch Utility Policy Manager

Community Action Partnership of Oregon