MEMORANDUM OPINION AND ORDER
KRAM, District Judge.
The Federal Low Income Home Energy Assistance Program ("HEAP"), authorized by the Low-Income Home Energy Assistance Act of 1981 ("LIHEAA"), 42 U.S.C. §§ 8621 et seq., provides funds through the states to help eligible low income households meet home energy costs. The New York State Department of Social Services ("DDS") regulates HEAP in New York while county social services districts administer...
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