Federal Register Notice Docket Number 2026-06804, “Proposed Information Collection Activity; Annual Report on Households Assisted by the Low Income Home Energy Assistance Program (LIHEAP)”

Census and Data Equity Resources 06.9.26

A PDF copy of this letter can be found here

June 8, 2026

Corine Frank
Acting Director, Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
330 C Street SW 5th Floor
Washington, D.C. 20201

Submitted via [email protected]

Re: Federal Register Notice Docket Number 2026-06804, “Proposed Information Collection Activity; Annual Report on Households Assisted by the Low Income Home Energy Assistance Program (LIHEAP)”

Dear Acting Director Frank,

On behalf of The Leadership Conference on Civil and Human Rights, our Census Task Force co-chairs, Asian Americans Advancing Justice | AAJC and NALEO Educational Fund, and the undersigned organizations, we appreciate this opportunity to provide comments in response to this information collection, published in the Federal Register on April 9, 2026 (“Notice”) (Docket Number 2026-06804).

The Leadership Conference is a coalition charged by its diverse membership of more than 240 national organizations to promote and protect the rights of all persons in the United States. The Leadership Conference Education Fund builds public will for state and federal policies that promote and protect the civil and human rights of all persons in the United States. Our coalition views the collection of useful, objective data about our nation’s people, housing, economy, and communities to be among the most important civil rights issues of our day. The Census Task Force works to ensure the fair and accurate collection of data of the U.S. population by the Census Bureau, including data on race and ethnicity, because of the important role census data play in ensuring proper representation, fair allocation of federal dollars, and effective and efficient planning and policy decisions by private and public sectors. We believe that other federal agencies should subscribe to the same standards of data collection as the Census Bureau, which provides the backbone for much of our federal statistics, including the implementation of the revised Statistical Policy Directive 15 standards.

We are therefore deeply concerned with the proposal to remove reporting requirements related to sex, race, and ethnicity from the Department’s Annual Report to Congress. As energy costs continue to rise and communities struggle to make ends meet, truly effectuating Congress’s intent with regard to the Low Income Home Energy Assistance Program (LIHEAP) requires a full and accurate accounting of who the program is serving and who is being left behind.

While this comment focuses specifically on the value of race and ethnicity data for program administration, we wish to make clear our opposition to the removal of data fields to document and understand LIHEAP utilization on the basis of sex. A recent analysis from the State of California using American Community Survey data suggests that women, particularly older women living alone and women-headed households with children, experience disproportionately high rates of energy burden and energy insecurity compared to men-led households.[1]  Other studies have found that Black women-led households face higher energy burdens compared to white, Hispanic, Native Hawaiian or Pacific Islander, or American Indian or Alaskan Native women, underscoring the importance of maintaining collection of both sex- and race-disaggregated data to evaluate whether LIHEAP resources are effectively reaching vulnerable households experiencing elevated energy burden.[2]

Congress Designed LIHEAP to Reach Households Experiencing the Greatest Energy Burden

As passed by Congress, LIHEAP was designed to assist low-income households in meeting their home energy needs, particularly low-income households and those for whom a significant proportion of their household income is used to pay for home energy.[3]  Congress later amended the statute to require states to prioritize households with “the highest home energy costs or needs in relation to income” and vulnerable populations, including older adults, individuals with disabilities, and families with young children.[4]

Research makes clear that these burdens are not distributed evenly across the population. A summary of research on energy insecurity by the Center on Global Energy Policy at Columbia University documents that in the United States, Black, Indigenous, and Hispanic households experience substantially higher rates of utility hardship, inability to maintain safe home temperatures, and risk of utility shutoffs than white households.[5]

Importantly, researchers have concluded that these disparities cannot be explained by income alone and reflect structural differences in housing quality, residential segregation, exposure to inefficient housing stock, and related conditions affecting household energy costs.[6]  These structural differences leave many people of color, particularly Black people, disproportionately vulnerable to high energy costs and energy insecurity.[7]

High energy burden can force households to choose between paying utility bills and paying for food, medication, housing, or transportation. For example, survey data from the federal Residential Energy Consumption Survey show that millions of households experiencing energy insecurity in the United States report reducing or foregoing food and medicine expenses in order to manage energy costs.[8] Utility shutoffs and inability to maintain safe indoor temperatures are associated with serious health and safety consequences, particularly for older adults, children, and medically vulnerable individuals.[9]  Because Congress specifically directed LIHEAP to prioritize households experiencing the greatest energy burden, information that helps identify which households and communities are disproportionately affected is directly relevant to effective program administration, sound use of taxpayer dollars, and implementation of Congressional intent.

Race and Ethnicity Data Are Necessary to Evaluate Whether LIHEAP Is Reaching the Communities Congress Intended to Prioritize

Demographic reporting provides the information necessary to evaluate whether the program is effectively reaching eligible households experiencing the greatest energy burden. When revising LIHEAP household reporting to require collection of race and ethnicity information for program participants, the Department explained that demographic reporting would improve understanding of the populations served by LIHEAP and strengthen evaluation of whether assistance was reaching households with the greatest need.[10]  The Department has therefore previously understood the connection between Congressional intent and the value of demographic reporting for program oversight and administration.  Without standardized demographic data, federal and state administrators cannot meaningfully assess whether barriers to participation disproportionately affect certain communities, whether outreach efforts are reaching populations with the highest need, or whether program implementation aligns with Congress’s statutory objectives.

The Current Proposal Fails to Adequately Consider the Consequences of Eliminating the Data

The Department puts forth this Notice in the absence of a more rigorous process to evaluate the functioning of the current standards and to provide the public with sufficient time to consider and comment on these proposals. This includes the opportunity to consider alternative approaches that would augment or improve – rather than eliminate – the collection of data on the race and ethnicity of program participants. Doing so runs counter to the goal of implementing reasoned and evidence-based data collection practices.

In trying to justify the removal of these questions, the current proposal does not adequately consider the substantial programmatic and oversight value of standardized demographic reporting or the consequences of eliminating those data. Elimination of the standardized reporting requirements reduces the Department’s ability to develop reliable national data regarding the populations served by LIHEAP. Prior to recent changes, the reporting framework did not provide standardized national demographic information capable of supporting meaningful oversight of whether LIHEAP was reaching households facing the greatest energy burden. The Department revised the demographic reporting requirements precisely because the absence of consistent demographic data limited the federal government’s ability to evaluate the populations served by the program. Reverting to the prior framework would reinstate a system that the agency itself recently concluded was insufficient to support effective program evaluation and implementation of Congress’s objectives. Congress designed LIHEAP to prioritize households facing the greatest energy burden and vulnerability, and race and ethnicity data provide an important mechanism for evaluating program functioning and whether eligible households experiencing severe energy insecurity are accessing assistance.

We urge you to withdraw the current proposal and retain sex, race, and ethnicity data collection requirements for the LIHEAP Annual Report.

Sincerely,

The Leadership Conference on Civil and Human Rights
Asian Americans Advancing Justice | AAJC
NALEO Educational Fund

Amherst H. Wilder Foundation
Asian Community Development Corporation
Association of Population Centers
Association of Public Data Users
Black Voters Matter Fund
CASL
Children’s HealthWatch
Clearinghouse on Women’s Issues
Coalition for a Healthier Frederick County
Coalition on Human Needs
dataindex.us
Dubois Bunche Center for Public Policy, Medgar Evers College
Empowering Pacific Islander Communities (EPIC)
Equality California
Feminist Majority Foundation
League of United Latin American Citizens (LULAC)
Legal Defense Fund
Massachusetts Law Reform Institute
Minnesota Council on Latino Affairs
Minnesota Prenatal to Three Coalition
Movement Advancement Project
National Consumer Law Center, on behalf of its low-income clients
National Disability Rights Network (NDRN)
National Low Income Housing Coalition
NCNW
NETWORK Lobby for Catholic Social Justice
New York Civic Engagement Table
PIVOT– The Progressive Vietnamese American Network
Population Association of America
Silver State Equality
The Children’s Agenda
The Data Center of Southeast Louisiana
Union of Concerned Scientists

  • [1] See High Home Energy Costs Hit Women Hardest, Gender Equity Pol’y Inst. (2023), https://thegepi.org/high-home-energy-costs-hit-women-hardest/.
  • [2] See also Sanya Carley et al., Localized Energy Burden, Concentrated Disadvantage, and the Geography of Female-Headed Households, 308 Applied Energy 118404 (2022), https://pmc.ncbi.nlm.nih.gov/articles/PMC8991312/.
  • [3] Low-Income Home Energy Assistance Act of 1981, 42 U.S.C. § 8621(a)–(b).
  • [4] Human Services Amendments of 1994, Pub. L. No. 103-252, § 302, 108 Stat. 623, 642–43 (codified as amended at 42 U.S.C. § 8624(b)(5)).
  • [5] Diana Hernández et al., Energy Insecurity in the United States, Columbia Univ. Ctr. on Glob. Energy Pol’y (2022), https://www.energypolicy.columbia.edu/publications/energy-insecurity-in-the-united-states/.
  • [6] Tony G. Reames, Energy Efficiency as Energy Justice: Addressing Racial Inequities Through Investments in People and Places, 52 Energy Rsch. & Soc. Sci. 1 (2019), https://pmc.ncbi.nlm.nih.gov/articles/PMC7966972/
  • [7] See Reames, supra note 6; see also Eva Lyubich, The Race Gap in Residential Energy Expenditures (Energy Inst. at Haas Working Paper No. 306, 2020), https://haas.berkeley.edu/energy-institute/research/abstracts/wp-306/.
  • [8] U.S. Energy Info. Admin., 2024 Residential Energy Consumption Survey, Table HC11.1: Indicators of Energy Insecurity by Household Characteristics, https://www.eia.gov/consumption/residential/data/2024/hc/pdf/HC11.1_2024.pdf.
  • [9] See Hernández et al., supra note 5.
  • [10] Proposed Information Collection Activity; Annual Report on Households Assisted by the Low Income Home Energy Assistance Program, 87 Fed. Reg. 39,442, 39,443 (July 1, 2022).