[hua7450]

Pays California's regular HEAP utility benefit to households with no heating that pay a gas or electric bill, including those whose only energy cost is an electric bill for cooling.

Fixes #10731

What and why

CSD pays one regular LIHEAP HEAP, Fast Track or WPO benefit per program year (FY2026 state plan, guide 1.1, p. 193) and reports HEAP payments on electricity bills from July 1 through October 31 as cooling (plan attachment to item 1.2, p. 55). The FY2026 ACF plan's cooling range, $283 to $932 (item 3.6), is the HEAP utility range. On main, the utility-account test accepts any known heating fuel with a gas or electric bill (guide p. 221), but heating_type NONE fails it, so a no-heat home with a utility bill got $0.

ca_liheap_utility_eligible keeps every other condition and widens the account test:

utility_account = utility_heat | ((heating_type != UNSPECIFIED) & (pre_subsidy_electricity_expense + gas_expense > 0))

The guide asks only that the household be responsible for energy costs (1.1 and 1.6, p. 193), and the applicant names the utility account that takes the benefit. So a home without heating now qualifies on a gas or electric bill, with no cooling-cost condition. This follows California's text rather than the all-state cooling-only definition, which also requires has_cooling_expense and an electric bill. UNSPECIFIED still gets $0.

The amount formula is unchanged: the county base benefit for the poverty group plus $19 per added member through six, with no bill cap. The Madera priority test, the one-component rule and the income test apply as before. The two variable labels now say "heating or cooling", and the registry note says the benefit also pays homes without heating on either bill.

Test plan

Tests were not run locally. CI is their first run and starts when this PR leaves draft.

• YAML tests with expected values from the FY2026 county HEAP table (plan pp. 182-184):
  • Eligibility, new case: a home without heating is eligible on an electric bill it pays for cooling, and on a $600 gas bill with no cooling cost. It is ineligible with UNSPECIFIED fuel or with wages above the one-person limit.
  • Payment, new case: a single adult in Imperial County with no heating, poverty group 1, gets $621 on an electric bill, with or without a cooling cost.
• Two existing cases change. Their inputs are unchanged, and each changed value has a "Was …, now …" comment:
  • Eligibility Case 3, unit 7, a home without heating with an electric bill: false to true.
  • Utility-heating Case 15, unit 6, a home without heating in Alameda County: $0 to $484 (poverty group 1).
• Source-conflict register: not applicable.
• make format (ruff)
• Changelog fragment in changelog.d/

Not modeled

• Cooling included in rent: guide 3.3 makes eligible applicants who pay their utility costs as part of their rent. This PR does not read tenant_pays_utilities, so a home without heating whose only energy cost is cooling in its rent gets $0.
• FY2027: period 2027 carries the FY2026 county tables forward, as main already does for heating. CSD's draft FY2027 plan prints FY2027 county base amounts (pp. 190-192) and WPO tables (pp. 193-196), and every county amount moves; its lowest and highest cells match the accepted FY2027 plan's $246 to $887 range (item 3.6). Those tables change heating for every California household, so they are left to a follow-up: Update California LIHEAP utility and WPO tables for FY2027 #10848.
• The July to October season is a reporting label, so the model stays annual with one benefit.
• Fast Track cooling help is crisis assistance and out of scope.

axiom: TheAxiomFoundation/rulespec-us#2178 queued

🤖 Generated with Claude Code

[DTrim99]

PR Review: Pay California's regular HEAP utility benefit to cooling-only households

Head reviewed: 102b65bba8724d4132c4e28afda20956c9948fe0.

Summary

The change is one term in ca_liheap_utility_eligible: a home with heating_type NONE now passes the utility-account test on a positive gas or electric bill. I researched the FY2026 CSD plan, its Eligibility and Verification Guide, the county table, the Madera local plan and the FY2027 documents before reading the code. The rule, the amount, the page citations in the code and the tests all hold for FY2026, and the three regular components stay mutually exclusive.

One item needs attention. The body and the queued rulespec-us issue both say that no FY2027 county table was found. CSD's FY2027 draft state plan, linked from the same CSD page as the FY2026 plan, prints it. Every county amount changes, so period 2027 pays the newly covered households the FY2026 amount.

• Critical: 0
• Should address: 1
• Suggestions: 5

Sources read:

#	Source	Used for
1	CSD FY2026 LIHEAP State Plan, final (442 pages)	Plan items 1.1, 1.2, 2.x, 3.x, 9.x (pp. 5-12, 24); attachment to 1.2 (p. 55); county table (pp. 182-184); guide 1.1 (p. 193), 1.6 (p. 205), 1.13 (p. 221), 3.1 (pp. 254-255), 3.2 (p. 257), 3.3 (p. 279); contract 8.1 (p. 363)
2	CAP of Madera County board packet, October 9, 2025	Priority plan (pp. 189, 191) and minimum threshold (pp. 233-234)
3	CSD FY2027 LIHEAP State Plan, draft (433 pages), linked from CSD's LIHEAP page	Items 1.1, 2.6, 3.6 (pp. 5, 10, 12); attachment to 1.2 (p. 51); 2027 county table (pp. 190-192); guide 1.1 (p. 200)
4	California FY2027 Detailed Model Plan, Clearinghouse copy (54 pages, "Submission Accepted by CO (Revision #1)")	Item 3.6 (p. 11)

Limit of this review: I could read the text layer only, not page images. The Yes/No check boxes in plan items 2.2-2.3, 3.2-3.3 and 3.5 are not in the text layer, so I did not verify them. No finding below rests on a check box.

Critical (must fix)

None.

Should address

S1. A FY2027 county table is published, but the body and rulespec-us#2178 say none was found, and period 2027 pays the FY2026 amounts

• Where: PR body, "Not modeled", FY2027 bullet; rulespec-us#2178, interpretation 12; policyengine_us/parameters/gov/states/ca/csd/liheap/payment/utility_base_amount.yaml (every county has one 2025-10-01 entry, unchanged by this PR); policyengine_us/variables/gov/states/ca/csd/liheap/ca_liheap_utility_heating.py:24.

• What the body says: "no FY2027 county table was found, so a carried-forward 2027 amount can exceed the published FY2027 maximum."

• What the source shows: CSD's FY2027 draft state plan, p. 190 prints "2027 LIHEAP County Base Benefit Amounts (BBA) / Benefit Amounts Listed Apply to Household Size 1 ONLY" for all 58 counties (pp. 190-191). Page 192 keeps the size rule: "Household sizes 2 through 6 each receive an additional $19. Household sizes 6 and higher receive the same payment amount."

  • The table reconciles with the accepted FY2027 plan. Its lowest cell is San Luis Obispo group IV, $246. Its highest is Nevada group I, $792, and 792 + 5 × 19 = 887. The accepted plan, item 3.6, p. 11 prints "Minimum Benefit $246 Maximum Benefit $887".

  • Sample rows, groups I to IV:

    County	FY2026 (final plan pp. 182-183)	FY2027 (draft plan pp. 190-191)
    Alameda	$484 / $404 / $356 / $308	$456 / $372 / $321 / $270
    Imperial	$621 / $512 / $447 / $382	$560 / $454 / $390 / $326
    Madera	$702 / $576 / $501 / $426	$636 / $514 / $441 / $368
    Nevada	$837 / $684 / $591 / $499	$792 / $638 / $545 / $452
    Del Norte	$674 / $554 / $482 / $411	$737 / $594 / $508 / $422

• Households, period 2027:

  • Imperial County, one adult, wages $12,000, heating_type NONE, electric bill $1,200. FY2027 table: group I, $560. Head: $621.
  • Nevada County, six qualified members in group I, any utility bill. FY2027 table: 792 + 95 = $887, the published maximum. Head: 837 + 95 = $932.
  • Del Norte County, one adult in group I. FY2027 table: $737. Head: $674. The carry-forward underpays here, so it is not only an overpayment.

• Why should, not critical: 2027 is not a claimed year. programs.yaml keeps verified_years: "2026", every test is period 2026, and the body lists FY2027 under "Not modeled". Main already carries the same FY2026 table into 2027 for every gas- and electric-heated household, and this PR adds no parameter. So the PR does not create the gap. It extends it to the households it newly pays.

• Why not a suggestion: the reason the body gives for the gap is not accurate, and the same sentence is in the queued issue that the encoder will work from. The FY2027 values have been in force since October 1, 2026. This is the pattern of Add New Jersey LIHEAP regular heating assistance #9745 S4 (published FY2027 tables not used).

• Caveat: the CSD file is labelled draft. No final FY2027 plan is posted at the matching CSD address. The draft table's lowest and highest cells reproduce the accepted plan's item 3.6 range exactly, so I expect the final table to match, but check it when CSD posts the final plan.

• Fix: either of these clears the finding.

  1. Add 2026-10-01 values to utility_base_amount.yaml from the FY2027 table, with a 2027 test. The same plan prints the 2027 WPO table at pp. 193-196, so the liquid parameters should move together.
  2. Keep the code as it is. Correct the FY2027 bullet in the body and interpretation 12 of rulespec-us#2178 to say that the FY2027 draft plan prints the table, and link a follow-up issue for the FY2027 utility and WPO values.

Suggestions

G1. The body places guide 1.6 on p. 193; it is on p. 205

• Where: PR body, "What and why": "The guide asks only that the household be responsible for energy costs (1.1 and 1.6, p. 193)".
• Source: p. 193 holds guide 1.1 only: "5. Be responsible for energy costs and provide copies of energy bills". Guide 1.6, Household Composition, is on p. 205: "A household is defined as an individual or group of individuals, related or unrelated, who share residential energy and have an energy cost."
• The code is right: the reference comment in ca_liheap_utility_eligible.py:11 lists both 193 and 205, the test comments cite p. 193 for the 1.1 sentence only, and rulespec-us#2178 cites p. 205 for 1.6.
• Fix: write "(1.1, p. 193; 1.6, p. 205)" in the body.

G2. No test runs a home without heating through Madera's priority minimum

• Where: ca_liheap_utility_eligible.py:46-48; ca_liheap_utility_heating.yaml Case 16 (line 5365) tests the minimum with NATURAL_GAS homes only, and the new Case 17 is in Imperial County, which has no recovered priority plan.
• The guard is not new, and Case 16 would fail if it were removed, so this is not a mutation gap. But the body says "The Madera priority test ... apply as before", and the widening sends a new group of households through it.
• Source: Madera packet p. 233 answers Yes to "Does your agency apply your priority plan points to assess every application for Utility Assistance benefits?" and marks the minimum threshold Yes for HEAP. Page 234: "Customers must meet a minimum threshold of 20 points to qualify for the LIHEAP Program."
• By hand, traced through the head formula: Madera County, one adult, wages $12,000, NONE.
  • Electric bill $2,040: 2,040 / 12,000 = 17.00%, the 16.01%-100% band, 10 points. Group I adds 10. 20 points meets the minimum: $702.
  • Electric bill $1,200: 10.00%, the 0%-10.92% band, 4 points. 14 points: $0.
• Fix: add these two units to Case 16 or Case 17. rulespec-us#2178 row 9 already lists them as companion tests.

G3. Cooling in the rent stays at $0 (disclosed)

• Where: ca_liheap_utility_eligible.py:34. A NONE home with no bill of its own fails the account test.
• Source: guide 3.3, p. 279: "Applicants that pay their utility costs as a portion of their rent are eligible to receive LIHEAP, ESLIHEAP, and SLIHEAP assistance." Plan 9.1, p. 24: "On those few occasions when utilities are included in the rent or sub-metered, warrants are issued directly to the client."
• Household: Imperial County, one adult, wages $12,000, NONE, tenant_pays_utilities: false, no electric or gas bill. Rule: eligible, $621. Head: $0. An electric-heated tenant with heat_expense_included_in_rent gets $621 on main.
• The body discloses this, and the Oregon sibling Pay Oregon's LIHEAP standard payment to cooling-only households #10736 leaves the same gap ("Cooling costs included in rent have no input"). A follow-up could read utilities_included_in_rent for NONE homes. No change needed here.

G4. Wording left over from the heating-only gate

• policyengine_us/programs.yaml:1074: full_name still reads "California Home Energy Assistance Program utility heating component", while the note on line 1078 and both variable labels now cover homes without heating.
• eligibility/ca_liheap_utility_eligible.yaml:221: Case 3 is still named "a gas or electric bill opens the utility benefit to every known fuel", and its unit 7 is now a home with no fuel.
• eligibility/ca_liheap_utility_eligible.yaml:1: the header page list lacks 55, which the new Case 4 comment cites.

G5. Linked issue and queued issue text

• Implement California LIHEAP regular HEAP utility benefit for cooling-only households #10731 proposes the narrower rule ("heating_type NONE, has_cooling_expense and a positive electricity bill"). The PR is wider, on sourced grounds. A line on the issue would keep the record straight when it closes.
• rulespec-us#2178 says the tests "have not yet passed in CI at this head". They have now (see CI status).

Verified correct

The rule (questions 1 and 3)

• One regular benefit a year. Guide 1.1, p. 193: "An applicant can only receive one LIHEAP, one ESLIHEAP, and one SLIHEAP utility assistance (Home Energy Assistance Program (HEAP), Fast Track, or Wood, Propane and Oil (WPO)) benefit per program year." Contract 8.1.2 (p. 363) says the same for HEAP/WPO. Quote and page match the body.
• Regular HEAP on an electric bill is the cooling benefit. Plan 1.1 (p. 5) lists cooling assistance from 10/01/2025 to 09/30/2026. The attachment to item 1.2, p. 55: "For reporting purposes, CSD's cooling season has been determined to be from July 1 through October 31. Households to be reported under 'Cooling' are tied specifically to applicants who have been assisted with their electricity bill under the non-crisis Home Energy Assistance Program (HEAP) component." Quote and page match.
• Account test. Guide 1.13, p. 221: "For Utility Assistance or Wood, Propane or Oil, the name of the utility company and the account number the applicant wants the benefit applied to must be answered on the application." Quote and page match.
• A home without heating qualifies on a gas bill with no cooling cost. This is the rule's text, so leaving out has_cooling_expense is correct for California.
  • Guide 1.1 item 5 asks only that the applicant "Be responsible for energy costs and provide copies of energy bills".
  • Guide 1.6 (p. 205) defines a household as people who "share residential energy and have an energy cost".
  • Guide 1.13 (p. 221): "Questions must be answered regarding all home energy costs (natural gas, electricity, wood, propane, and fuel oil)."
  • Guide 3.2 (p. 257): "Total Energy Cost = Electric + Natural Gas + Wood + Propane + Oil".
  • I searched guide pp. 189-284 for a heating-source, primary-fuel or cooling-use condition on utility assistance and found none. The only such conditions in the plan are in the contract's appliance repair and replacement rules (pp. 374-376), which are out of scope.
  • Page 55 would report a payment on a gas bill as heating, not cooling. That is a reporting label and does not change who is paid.
  • Main already pays wood, propane, kerosene, coal and "other" homes on either bill by the same reading, so the widening is consistent with the merged heating code.
• UNSPECIFIED stays at $0, the Default heating_type to electricity and remove the UNSPECIFIED-gated state heating adapters #9754 convention (ca_liheap_utility_eligible.py:25).
• Subsidized tenants. Guide 1.6 item 1 excludes "Subsidized households that do not pay any out of pocket energy costs". A subsidized home without heating that pays its own bill qualifies, and the gate does not read housing assistance. A home without heating and without a bill stays ineligible (eligibility Case 2, unit 8).
• The rule is the same in FY2027. The FY2027 draft keeps guide 1.1 (p. 200) and the cooling attachment (p. 51) with the same operative sentences. Only the amounts move (S1).
• No source conflict. Plan, guide and contract agree, so "Source-conflict register: not applicable" is right. The diff adds no conflict-sounding comment.

The amount (question 2)

• No separate cooling column or matrix exists. Plan 3.5 (p. 12) repeats the heating text: county utility costs "are factored into the heating and cooling benefit formula".
• Plan item 3.6 (p. 12) prints "Minimum Benefit $283 Maximum Benefit $932". Both ends come from the county table: Santa Barbara group IV is $283, and Nevada group I is $837, with 837 + 5 × 19 = 932. So the cooling range is the HEAP utility range, as the body says.
• Notes on p. 184: "Household sizes 2 through 6 each receive an additional $19. Household sizes 6 and higher receive the same payment amounts". The formula is unchanged.
• heating_type is not a lookup key in the amount formula, so a NONE home reaches no missing key.

No double payment (question 4)

• Head against main, line by line: the only change is known_fuel (not NONE and not UNSPECIFIED) becoming heating_type_reported (not UNSPECIFIED). NONE is not in utility_heating_fuels, so the result changes only for NONE homes with a positive gas or electric bill. Every other household is unchanged.
• ca_liheap_covered_liquid_heating is defined only for PROPANE and FUEL_OIL. ca_liheap_wood_heating pays only WOOD. ca_liheap_utility_eligible requires both to be $0 (lines 36-43). So at most one component is positive for any household, and a NONE home can reach only the utility component.
• A home with both heating and cooling costs is paid once: there is one variable and one amount.

Hand-checks from the printed tables (FY2026, pp. 182-184)

One adult with wages of $12,000 is $1,000 a month, inside "$0 - $1,304.17", group I. Zero income is group I too.

#	Case	Arithmetic	Expected	Test
1	Eligibility Case 3, unit 7 (changed): NONE, Alameda, electric $1,200, no income	Energy cost yes; qualified adult; income eligible; reported type with a bill; no other component; no burden group outside Madera	true	true
2	Utility Case 15, unit 6 (changed): NONE, Alameda, wages $12,000, electric $1,200	Alameda group I $484, size 1	484	484
3	Utility Case 15, unit 7: UNSPECIFIED, same facts	Not a reported type	0	0
4	Utility Case 17, unit 1: NONE, Imperial, cooling cost, electric $1,200	Imperial group I $621	621	621
5	Utility Case 17, unit 2: same without a cooling cost	No cooling condition in the guide	621	621
6	Eligibility Case 4, unit 2: NONE, gas $600, no cooling cost	Gas bill is an energy cost and a payable account	true	true
7	Eligibility Case 4, unit 3: UNSPECIFIED with an electric bill	Convention	false	false
8	Eligibility Case 4, unit 4: NONE, wages $40,500	40,500 / 12 = $3,375.00, above $3,331.66 (39,979.92 a year); no CalFresh or CalWORKs	false	false
9	Utility Case 15, unit 1: PROPANE, Fresno, electric $1,200	Fresno group I $716	716	716
10	Utility Case 15, unit 5: PROPANE, Madera, electric $2,040, no propane bill	17% burden, 10 + 10 = 20 points; Madera group I $702	702	702
11	Utility Case 16, units 1, 3, 5	$2,500 a month is group IV (4) and 2% adds 4: 8 points, $0. 15% adds 8 to 10: 18 points, $0. Fresno group IV $434	0, 0, 434	0, 0, 434
12	Table range	Santa Barbara IV $283; Nevada I 837 + 95 = 932	283, 932	parameters match

The parameter rows for Alameda, Imperial, Madera, Nevada, Santa Barbara and Fresno match the printed table.

Tests and the mutation rule (questions 5 and 6)

• Both changed expectations are the intended ones and carry "Was …, now …" comments (rows 1 and 2).
• The new term is pinned in both directions:
  • Restoring the NONE exclusion fails eligibility Case 3 unit 7, Case 4 units 1-2, utility Case 15 unit 6 and Case 17.
  • Dropping the UNSPECIFIED exclusion fails eligibility Case 3 unit 8, Case 4 unit 3 and utility Case 15 unit 7.
  • Requiring an electric bill fails eligibility Case 4 unit 2.
  • Adding a has_cooling_expense condition fails Case 4 unit 2 and Case 17 unit 2.
  • A NONE home with no bill stays ineligible in Case 2 unit 8.
• Periods are plain.

Other checks

• Mixed-state populations (question 7): the PR adds no parameter or breakdown key. The amount formula's county masking is unchanged, and existing Case 10 covers a mixed-state run.
• Periods (question 8): every variable read is annual. The California files do not use options=[ADD], so Add a national LIHEAP total, an Illinois regular heating payment and LIHEAP cooling registry notes #10730's removal does not touch them.
• Registry (question 9): the note matches the code, the coverage line is untouched, and verified_years stays "2026". See G4 for full_name.
• National total (question 10): Add a national LIHEAP total, an Illinois regular heating payment and LIHEAP cooling registry notes #10730 already lists ca_liheap_utility_heating, ca_liheap_covered_liquid_heating and ca_liheap_wood_heating in gov.hhs.liheap.regular_payments. The variable keeps its name, so nothing needs adding here, and the exclusivity that list relies on still holds after this change.
• Income counting: not touched, so the income-list checks do not apply. The guards from Integrate modeled state unemployment insurance into income flows #9558, Count military SBP annuities in state benefit income lists #10317 and Count each Social Security benefit once in Pennsylvania CCW countable income #10408 are not affected.
• Changelog: changelog.d/ca-liheap-cooling.fixed.md is present, and the type fits.

Axiom line assessment

axiom: TheAxiomFoundation/rulespec-us#2178 queued is valid.

• The issue is OPEN and labelled pe-parity.
• It names head 102b65bba8, which is the current head.
• It is dispatch-ready: module paths, corpus citations with status, verbatim source text, required outputs with definitions, and ten companion tests derived from the plan, the guide and the Madera packet rather than from model output.
• Its definition of the changed term matches the head formula. I re-derived rows 1-5 and 8-10 from the printed tables and they agree.
• Two edits are needed: interpretation 12 repeats the FY2027 statement in S1, and the tests line is stale (G5).

CI status

All green at the current head: 37 checks pass, 3 skipped (workflow placeholders), none pending (gh pr checks 10732, run 43153857853 on 102b65bba8).

The body says tests were not run locally, so CI is the only run. The Quick Feedback job ran both changed test files at this head and they passed: 17 cases in ca_liheap_utility_heating.yaml and 4 in eligibility/ca_liheap_utility_eligible.yaml.

Branch status

• The head already contains main at 935b24ff4f: 0 behind, 3 ahead. git merge-tree against main is clean, and GitHub reports the PR mergeable.
• The head is the merged tree, so the source-conflict ratchet (Tie source-conflict markers to the register shared with Axiom #10287) and the Integrate modeled state unemployment insurance into income flows #9558, Count military SBP annuities in state benefit income lists #10317 and Count each Social Security benefit once in Pennsylvania CCW countable income #10408 guards ran in this CI run and passed.
• Siblings: the head merges cleanly with the current heads of Add a national LIHEAP total, an Illinois regular heating payment and LIHEAP cooling registry notes #10730, Pay Hawaii's LIHEAP Energy Credit on electric (cooling) accounts #10734, Pay Oregon's LIHEAP standard payment to cooling-only households #10736, Pay the Nevada LIHEAP Fixed Annual Credit to cooling-only households, assuming an energy account #10738, Pay the Florida LIHEAP Home Energy benefit to cooling-only households #10740, Pay the DC LIHEAP Regular benefit to cooling-only households #10742 and Add Delaware LIHEAP summer cooling electric benefit eligibility #10762. All of them edit programs.yaml, but on different lines. Add a national LIHEAP total, an Illinois regular heating payment and LIHEAP cooling registry notes #10730 does not touch the California files.

Verdict: REQUEST_CHANGES

[DTrim99]

Requesting one change, and it can be a text fix. The body and rulespec-us#2178 say no FY2027 county table was found, but CSD's FY2027 draft plan prints one (pp. 190-192), and every county amount moves. Either add the 2026-10-01 values or correct the two statements and link a follow-up (Should Address 1 in the report above).

Everything else holds for FY2026: the rule, the amount, the page citations, the changed expectations and the one-payment rule. The five suggestions are optional. CI is green at 102b65bba8.

[hua7450]

Thanks, David. I took option 2. The FY2027 bullet in the body now says CSD's draft FY2027 plan prints the county table (pp. 190-192) and the WPO tables (pp. 193-196), and that its lowest and highest cells match the accepted plan's $246 to $887 range. Interpretation 12 of TheAxiomFoundation/rulespec-us#2178 says the same. The FY2027 utility and WPO values change heating for every California household, so they are in a follow-up: #10848. No code changed in this PR.

[DTrim99]

PR Review (round 2): Pay California's regular HEAP utility benefit to cooling-only households

Summary

The head is unchanged at 102b65bba8; the round-1 change request asked for a text fix or new parameter values, and the author took the text fix. The description, the queued Axiom issue and a new follow-up issue now say what CSD's FY2027 draft plan prints. Nothing is open.

Prior findings

Finding	Status	Evidence
Should 1: the body and rulespec-us#2178 said no FY2027 county table was found	Fixed (option 2)	The body's FY2027 bullet now reads: "CSD's draft FY2027 plan prints FY2027 county base amounts (pp. 190-192) and WPO tables (pp. 193-196), and every county amount moves; its lowest and highest cells match the accepted FY2027 plan's $246 to $887 range (item 3.6)." Interpretation 12 of rulespec-us#2178 says the same and gives the two examples from round 1 ($932 against $887 in Nevada County; $674 against $737 in Del Norte County). The follow-up is #10848, open, with the draft plan and the accepted plan as sources. No code change was needed for this option, so there is nothing for a test to pin.
Suggestion 1: guide 1.6 is on p. 205, not p. 193	Not taken (optional)	The body still reads "(1.1 and 1.6, p. 193)". The code comment and the Axiom issue cite p. 205 correctly.
Suggestion 2: a Madera priority case for a home without heating	Not taken (optional)	No test change.
Suggestion 3: cooling in the rent	Disclosed, no change needed	Still listed under "Not modeled".
Suggestion 4: leftover wording (full_name, Case 3's name, the header page list)	Not taken (optional)	No change.
Suggestion 5: stale lines	Not taken (optional)	The body still says "CI is their first run", and rulespec-us#2178 still says the tests "have not yet passed in CI at this head". Both passed at this head.

New findings

Critical: none. Should address: none. Suggestions: none beyond the optional items above.

Verified

• No code change. The head is the commit reviewed in round 1, so every check in that report still stands.
• Follow-up scope. Update California LIHEAP utility and WPO tables for FY2027 #10848 covers the utility and WPO tables together, which is right: the FY2027 values change heating for every California household, so they belong in their own PR.

Axiom

axiom: TheAxiomFoundation/rulespec-us#2178 queued is valid. The issue is OPEN, labelled pe-parity, names head 102b65bba8, and was updated on 2026-11-12 with the corrected interpretation 12.

CI

All 37 checks pass at 102b65bba8; 3 workflow placeholders are skipped.

Branch

2 commits behind main; the merge with main is clean.

Verdict: APPROVE

[DTrim99]

Approving. The FY2027 statement is corrected in the description and in rulespec-us#2178, and #10848 tracks the FY2027 utility and WPO tables. The head is unchanged from round 1, so the rest of that review stands. The remaining items are optional; the quickest is the page for guide 1.6 in the description (p. 205, not p. 193).