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1 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov State Plan and Application February 28, 2011 2011 Orientation for State WAP Directors and Staff Michael Peterson, Warren Cunningham, Jean Diggs, Trev Hall, Erica Burrin, & Ryan Middleton
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2 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.14 –WPN 06-3, Revised WAP Application, Instructions and Forms –Formerly two “Files” “Annual File” – application components that changed annually “Master File” – application components that were generally unchanged from previous year What is DOE looking for? –States no longer required to submit a Master File every year Must maintain current information consistent with Program guidance “On-File” at the Grantee Office Will be monitored by DOE staff during routine monitoring WAP State Plan Instructions and Forms
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3 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov State Plan Annual File Format II.1Grant Application – Standard Form 424, Version 02 II.2Budget – SF 424 A II.2.3Budget Justification – PMC 140.2 or equivalent II.3Subgrantees - DOE F 540.5 II.4Production Schedule II.5Energy Savings II.6Training, Technical Assistance and Monitoring Activities Annual File Instructions and Forms
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4 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov State Plan Annual File Format (cont’d) II.7DOE-Funded Leveraging Activities II.8Policy Advisory Council II.9Hearings and Transcripts II.10Adjustments to “On-File” Information II.11Miscellaneous II.12Certification regarding Lobbying (SF-LLL) only if applicable Annual File Instructions and Forms
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5 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Grant Application Standard Form 424 (SF-424) –SF-424, Version 2, dated 10/05 –Required of each agency applying to DOE’s Weatherization Program for grants –Also, required for subsequent funding changes (federal and non-federal) Annual File Section II.1 – Grant Application
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6 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Information (SF-424A) Section A – Budget Summary –Lines 1 – 5, Columns a – g –Line 1, enter new, or unexpended (e.g. carry-over) DOE and/or grantee funds. –Use separate lines for each “other” funding source Annual File Section II.2 – Budget Information
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7 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Information (SF-424A) Section B – Program, Function or Activity (Columns) –Grantee Administration –Subgrantee Administration –Grantee T&TA –Subgrantee T&TA –Program Operations –Health and Safety –Vehicles and Equipment –Liability Insurance –Leveraging –Financial Audits Annual File Section II.2 – Budget Information
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8 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Information (SF-424A) Section B – Object Class Categories (Rows) –Personnel –Fringe Benefits –Travel –Equipment –Supplies –Contractual –Construction –Other –Total Direct Charges –Indirect Charges –Object Class Totals Annual File Section II.2 – Budget Information
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9 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Information (SF-424A) Section B –The “Total” Column on page 1 should reflect the sum of all three pages –Section B total should equal Section A total –In Section B, subgrantee budgeted expenditures should all be reported in the contractual category (row f) Annual File Section II.2 – Budget Information
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10 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Information (SF-424A) Section B –Health & Safety Exclusion: Budgeted expenditures under Health and Safety are not included in the calculation of the average cost per unit. –Liability Insurance: Pollution Occurrence Insurance should be budgeted under this activity –Financial Audits: Grantees should not budget financial expenditures for subgrantees expending less than $500,000 in federal funds (OMB Circular A-133) Annual File Section II.2 – Budget Information
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11 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Budget Justification GO-PF20A –Required annually and with subsequent amendments –Budget detail corresponding to Object Class Categories (rows a – j) from Section B of SF-424A –Totals for each category must add up to the amount reported in Section B Annual File Section II.2 – Budget Information
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12 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Subgrantees –List of subgrantees including the name, tentative allocation, number of units to be weatherized, –Subgrantee contact information including name, address, contact information, labor source, Congressional district(s), and counties served. Annual File Section II.3 – Subgrantees
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13 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Production Schedule –Total number of planned weatherized and reweatherized units under the program rule and with grant funds –Vehicles and Equipment ($5,000 or more) Average Cost per Dwelling Unit calculation – for those states that plan to amortize the cost of vehicles and equipment –Average Cost per Dwelling Unit – calculation of expected average cost including vehicles and equipment Annual File Section II.4 – Production Schedule
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14 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Energy Savings – Provide estimate of expected energy savings (440.14(c)(4)) – Include the methodology used to calculate savings including the information sources for energy savings/unit – If no methodology has been developed by the grantee, use DOE-provided formula (estimated homes to be weatherized x 30.5 MBTU) This may skew state-level energy savings estimates – DOE is revisiting the approach used to estimate energy savings Annual File Section II.5 – Energy Savings
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15 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Training, Technical Assistance, and Monitoring Activities –Indicate method used to ensure quality of work and financial management at the local level –Include description of activities to be undertaken during the program year with funds budgeted under T&TA or Admin for training and technical assistance and/or monitoring –Establish milestones and estimate due dates Annual File Section II.6 – T&TA and Monitoring
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16 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov DOE – Funded Leveraging Activities –Explain how DOE funds (as indicated on SF-424A) will be used to increase the amount of assistance provided to eligible clients –Leveraging = obtaining additional program-targeted non-federal cash or in-kind contributions as a result of Weatherization Program-funded activities –Explanation of (1) how funds will be used to obtain non-federal resources, (2) how funds leveraged will support the DOE Weatherization Program, (3) the leveraging effect of those funds, and (4) rationale for the amount of funds used –DOE funds must be used to obtain non-federal resources to: Increase the number of homes weatherized and/or Increase the scope or type of services provided Goal: At least a dollar for dollar return Annual File Section II.7 – DOE Leveraging
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17 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Policy Advisory Council –Policy Advisory Council (PAC) or State commission/council must be established in accordance with 10 CFR 440.17 –Provide names, groups, organization or agencies represented by members Annual File Section II.8 – Policy Advisory Council
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18 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Hearings and Transcripts –One or more hearing(s) must be held to receive comments on the proposed application. Provide location and dates of hearing(s). –Requirement to give public notice 10 days prior to the hearing. Provide dates of public notices. –Unofficial notes/minutes or the official transcript must be submitted to DOE. Include grantee responses to any questions which were not resolved at the hearing. –Reminders: Plans are to be made available for review throughout the state prior to the hearing Include in Plan, all of the agencies which may be funded during the PY, whether funded initially or serve as alternates Emphasize the state allocation formula, process used to determine local funding levels, anticipated allocations Annual File Section II.9 – Hearings & Transcripts
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19 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Adjustments to On-File Information –Include any revisions, since the previous program year, to the On-File Information (previously the Master File) Annual File Section II.10 – Revisions to “On-File”
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20 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Miscellaneous –Can include notes from public hearing and Policy Advisory Council meetings here –Other activities not routinely administered as part of the Weatherization Program –Disaster Relief Plan, Energy Crisis Response, etc. Annual File Section II.11 – Miscellaneous
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21 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Lobbying Disclosure –Standard Form - LLL is required ONLY if the grantee performs lobbying activities –Other Assurances and Certifications that used to be listed under Section II.12 are no longer required. Grantees agree to these assurances when signing the new SF- 424, and check Box 21. Annual File Section II.12 – Lobbying Disclosure
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22 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Administrative Funds –Funds Based on Total Grant –CAP of 10% Not more than 5% for Grantee Not less than 5% for Subgrantee –EXCEPT: Local agencies receiving less than $350,000 of new DOE funds, up to an additional 5% may be used Procedures required Annual File Administrative Funds
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23 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Administrative Funds (cont’d) –New DOE and/or Stripper Well funding used for administrative purposes can’t exceed 10% of NEW funding –EXAMPLE: Total New DOE Funds ($2,000,000) Plus New EXXON Funds ($200,000) Plus New Stripper Well Funds (1,000,000) Total Funding - $3,200,000 Of this Total Funding, $320,000 may be used The whole $320,000 may be taken out of DOE funds Annual File Administrative Funds
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24 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Administrative Funds (cont’d) –Allowable uses of administrative funds Include: Salaries Telephone Costs Space Copying Supplies Annual File Administrative Funds
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25 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Allowable Administrative Costs Worksheet –How to include carryover funds –How to allocate additional 5% to agencies receiving less than $350,000 –How to determine the maximum allowable administrative costs under the grant Annual File Administrative Costs Worksheet
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26 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov $New DOE Funding (formula allocation and/or DOE funds transferred from previous grant) +$Other new funding this action Item I. $Total new funding subject to the “10% Administrative Cost” Rule (Allowable Grantee Administration) $Grantee Administration total from line k(1) of the budget -$Less Grantee Administration carryover Item II. $Grantee Administration subject to the “10% Administrative Cost” Rule Item III. 0.0Divide Item II. by Item I and write out to four decimal places (Item III may not exceed 5% or 0.0500) Annual File Administrative Costs Worksheet - 1
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27 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov (Allowable Subgrantee Administration) $Subgrantee Administration total from line k(2) of the budget -$Less Subgrantee Administration carryover Item IV. $Subgrantee Administration subject to the “10% Administrative Cost” Rule Item V.0.0Divide Item IV. by Item I and write out to four decimal places (Item V. must exceed 5% or 0.0500 but should not exceed the subgrantee limitation.) Item VI. 0.Add Items III. and V. and write to answer to four decimal places and must be less than 15% or 0.1500 Yes / No If Item VI. Is greater than 10% or 0.1000, the grantee has specified criteria under 10 CFR 440.18(d) for which subgrantees will receive additional administrative funds and how much extra they will receive. Annual File Administrative Costs Worksheet - 2
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28 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Only if Item VI is greater than 10% or 0.1000, determine theoretical subgrantee administrative cost limitation to compare with amount budgeted. 5% Item I. Subgrantee administration allowance for new funds $ + 5% of Sum of local agencies allocations below $350,000 +$ Item VII. Subgrantee Administrative Cost Pool Component Limit $ The maximum pool of new administration funds is 5% for the grantee (5% of Item I.) plus the amount calculated for the administrative cost pool component limit (Item VII). The grantee may transfer some of it’s funds to subgrantees. Any carryover needs to be questioned and reprogrammed for production if not properly justified. Annual File Administrative Costs Worksheet - 3
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29 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Regulatory Citation for Training & Technical Assistance (T&TA) –Section 440.23 - Oversight, Training, and Technical Assistance –The Secretary may reserve from the funds appropriated for any fiscal year an amount not to exceed 10 percent to provide, directly or indirectly, training and technical assistance to any grantee or subgrantee. Such training and technical assistance may include providing information concerning conservation practices to occupants or eligible dwelling units. Annual File Training & Technical Assistance
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30 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Training & Technical Assistance (cont’d) –Intended to maintain or increase the efficiency, quality, and effectiveness of the Weatherization Assistance Program at all levels –Should be designed to maximize energy savings, minimize production costs, improve program management and crew/contractor “quality of work,” and or reduce the potential for waste, fraud, abuse, and mismanagement –Local service providers should be the primary recipients of T & TA activities –Annual File of the State Plan should describe how State will identify and address the needs of subgrantees in this area Annual File Training & Technical Assistance
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31 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.14(b)(1) and (c)(3) –Also described in WPN 06-3, Revised Weatherization Application, Instructions and Forms What is DOE looking for? –Does the description of type of work to be done correspond to H&S Plan? Priority List or NEAT Protocols? –Does the description outline allowable measures, including base load? –If refrigerators are allowable, how are old units disposed of? WAP State Plan On-File, Section III.3.1, Type of Work To Be Done
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32 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov How to complete or review this section of the Plan? –If your Policy and Procedures Manual or Field Guide outlines the type of allowable measures, then include that language or reference the correct Grantee document in this section of your plan. –If your field protocols or energy audit has been reapproved since the last State Plan approval or if you have had an amendment, make sure that the ‘Type of Work To Be Done’ section is updated in the On-File Section and in the ‘Miscellaneous Section’ of your Annual File. –Grantees can also simply list the typical measures installed and make sure that measures are pulled from approved energy audit protocols. On-File, Section III.3.1, Type of Work To Be Done
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33 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.21 –WPN 01-4 and 05-5 What is DOE Looking For? –Were energy audits approved within the last five years for each dwelling type – single family, mobile home, and multi-family? –If Grantee is using a Priority List, is a site specific audit still required? On-File, Section III.3.2, Energy Audit Procedures
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34 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov How to complete or review this section of the Plan? –Submission requirements outlined in WPN 01-4 –Analytic methods and assumptions –Description of measures considered –Sample audit –Field procedures –Administrative requirements for each building type served On-File, Section III.3.2, Energy Audit Procedures
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35 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.16 (g) What is DOE Looking For? –What does the final inspection process look like in your State? –What percentage of homes require a final inspection? –Is there a requirement for client sign off/satisfaction? –Does the final inspection process provide for a signed and dated inspection form? –Is each measure installed reviewed as part of the final inspection? On-File, Section III.3.3, Final Inspections
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36 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov How to complete or review this section of the Plan? –Review the regulation 10 CFR 440.16(g) –Consult your audit protocols/ priority list to incorporate review of measures into final inspection process –Consult your field standards –Get input from your subgrantees and/or technical committees. On-File, Section III.3.3, Final Inspections
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37 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.23(e) –WPN 11-1, Section 3.1, D: How the Grantee compares productivity and energy savings between subgrantees and how these comparisons are used in the development of T&TA activities and priorities –WPN 11-1, Section 3.1, F: An assessment of Grantee T&TA activities to determine whether these funds are being spent effectively. On-file, Section III.3.4, Assessment of Effectiveness
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38 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov What is DOE Looking For? –Is there a process for assessment of effectiveness of the subgrantees other than monitoring reports? –Has the Grantee used WAP funds to complete an energy savings evaluation? How to complete or review this section of the Plan? –Set aside Grantee T&TA or Grantee Administration funds to procure an energy evaluation of the program. –A number of Midwestern states have regular evaluation cycles that range from a simple pre and post weatherization utility usage analysis to a more comprehensive approach with individual measure evaluation. –ORNL may be able to provide technical assistance in this area. On-file, Section III.3.4, Assessment of Effectiveness
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39 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Why? –10 CFR 440.22(3)(b) –WPN 11-1, Section 5.2 and 5.4 What is DOE Looking For? –Written permission is obtained from the building owner to perform Wx services. –Not less than 50% of units are income eligible for duplexes and four unit buildings –66% of units are income eligible for buildings over four units –Benefits of WAP accrue primarily to low-income tenants On-File, Section III.5, Rental Procedures
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40 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov What is DOE Looking For? (continued) –Tenants will not be subjected to rent increases as a result of WAP services –No undue or excessive enhancement shall occur to the value of the dwelling –Does the Grantee require financial participation of the landlord? –Is there a statewide agreement template required between landlord and subgrantee? How to complete or review this section of the Plan? –Review your current State Plan –Does your State Plan, Policy and Procedures or Admin Manual say the same thing? –Review the regulation and WPN, do you need to add or change anything? On-File, Section III.5, Rental Procedures
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41 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov On File Sections –III.6.1 Description of Organization –III.6.2 Administrative Expenditure Limits –III.6.3 Monitoring Approach –III.6.4 Training and Technical Assistance Approach –III.6.5 Energy Crisis Plan III.6.1-6. Describe Your Approach
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42 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov These Sections Describe Your Team and Approach –Who are you?. –Describe your administrative forecast. How much are you going to spend on admin? What are your goals and objectives? How will you measure yourself? –How will you monitor and verify effectiveness? –How will you train the weatherization workforce? –How does your organization respond to crisis? III.6.1-6. Describe Your Approach
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43 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov How to complete or review these sections of the Plan? –Local & Non-local In-depth Knowledge & Feedback –Regulations & Program Guidance –How to find more information Past Examples & Best Practices Additional Online & Traditional Resources III.6.1-6. Describe Your Approach
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44 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov On File Sections –III.6.1 Description of Organization –III.6.2 Administrative Expenditure Limits WPN11-1 1.4 –10% Total / 5% Grantee –Less than 350k Additional 5% –III.6.3 Monitoring Approach 10 CFR 600.240 Subpart C –Must cover each program, function, or activity –Annual Reporting WPN 10-09, 10-01, 9-1B, 01-6 5% Unit Minimum III.6.1-6. Describe Your Approach
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45 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Monitoring goals include determining… –Program compliance –Accountability –Program performance –Quality of Work –Problems areas and deficiencies –Assistance and Training Needs III.6.1-6. Describe Your Approach
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46 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov DOE Monitoring Rules –Comprehensive monitoring of each subgrantee at least once a year. –Must include review of client files and subgrantees records. –Actual inspection of at least 5 percent of the completed units. –Subgrantee should be briefed on the observations and findings. –Within 30 days after each visit, the Grantee will prepare a written report on its findings and send it to the subgrantee for corrective action III.6.1-6. Describe Your Approach
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47 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov DOE Rules Cont… –Noncompliance findings unresolved within forty-five days should be reported to the PMC. Sensitive or significant noncompliance findings should be reported to the PMC immediately. –Major findings should be tracked by the Grantee to final resolution. –Annually the Grantee will summarize and review each subgrantee’s audit, program monitoring reports and findings for internal monitoring. –Grantee will evaluate subgrantee needs, strengths, and weaknesses and provide assistance as needed for improvement. –The results of this annual monitoring should be considered during annual planning and documented for future use by Grantee and PMC DOE monitoring staff. III.6.1-6. Describe Your Approach
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48 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Past Examples & Best Practices –State of Georgia Monitoring Approach –University of Georgia Extension Office Monitoring Partnership 10% Units Monitored 12 Field Monitors / 12 File Monitors Energy Education Program –370 Outreach Presentations reaching 5000+ people. –Translated Education Material Customer Survey (185 Surveys) Program Evaluation (Longitudinal Study) –11 Energy Educators following 50 households each III.6.1-6. Describe Your Approach
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49 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov On File Sections –III.6.4 Training and Technical Assistance Approach WPN 11-2 Grantee Allocation Maintain quality and efficiency throughout all program levels –State Personnel –Agency Personnel –Contractors (Retention Agreement) Minimum –Training needs assessment –What training Grantee will provide –Certification requirements –Subgrantee Comparisons and T&TA Integration –Grantee Oversight & Monitoring –Effectiveness Assessment III.6.1-6. Describe Your Approach
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50 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Past Examples & Best Practices –SC Office of the Governor, Office of Economic Opportunity (OEO) & SC Technical College System Partnership –7 Regional Energy Efficiency Training Centers Hot Climate - Whole House Weatherization training BPI, RESNET, HERS Rater 1800 People Trained Props built onsite by each college Other Participants –Electric Cooperatives –Utilities –Home Builders III.6.1-6. Describe Your Approach
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51 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Past Examples & Best Practices –State of Georgia and T&TA Approach Southface T&TA Provider Partnership –1200 People Trained –Typical BPI Oriented Curriculum –Training Innovation Center Award –Health And Safety Training –Circuit Rider Training Program III.6.1-6. Describe Your Approach
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52 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Additional Online & Traditional Resources WAPTAC –Guidance/Regs –Best Practices –Technical Tools »Monitoring Tools –Training Resources –Message Board –Ask the Expert Economic Opportunity Studies (EOS) –Weatherization PLUS Newsletter –Facebook Page –Twitter Feed III.6.1-6. Describe Your Approach
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53 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov WAP Health & Safety Authority from 10 CFR 440.21 (c) DOE Issued Revised H&S Guidance WPN 11-6 –Response to concerns with clarity and consistency in how health and safety issues are approached by grantees. –DOE reconvened Health and Safety Committee to review trends and practices of the WAP network to update guidance. Primary goal of Program remains “energy efficiency”. –Energy-related health & safety measures are those actions necessary to maintain the physical well being of both the occupants and/or weatherization workers where: Costs are reasonable as determined by DOE in accordance with the grantee’s approved Grantee Plan; AND The actions must be taken to effectively perform weatherization work; OR The actions are necessary as a result of weatherization work. Grantees encouraged to budget H&S costs as a separate category to exclude costs from the overall average per-unit costs and avoid cost justification.
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54 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Health & Safety Guidance WPN 11-6 Guides the grantee in creating their H&S Plan, which once approved by DOE, is used as the guiding document for subgrantees. Addresses Action/Allowability, Testing, Client Education, and Training for the following Health and Safety Categories: Air Conditioning/Heating Systems Appliances/Water Heaters Asbestos Biologicals/Unsanitary Conditions Building Structure/Roofing Code Compliance Combustion Gases Drainage Electrical Fire Hazards Air Pollutants Injury Prevention Lead Based Paint Mold/Moisture Occupant Preexisting/Potential Health Conditions OSHA and Crew Safety Pests Radon Refrigerant Smoke/CO Detectors Solid Fuel Heating Space Heaters Spray Polyurethane Foam Ventilation Window/Door Replacement
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55 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov H & S Plan Minimum Requirements Include health and safety expenditure limits, expressed as a percentage of average cost per dwelling unit, w/ justification and related historical experience. Method to determine when DOE funds will be used and if they cannot, what other treatment will be sought. System for remedy of potential health and safety issues including when partial weatherization can be conducted. System for referral to other agencies. System for determining when deferral is necessary. Procedures for implementing training requirements. Outline of testing to be performed based on guidance. Protocols for informing clients of potential hazards. Procedures for collecting known or suspected occupant health concerns.
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56 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov H & S Plan Minimum Requirements Strategy for implementation of ASHRAE 62.2 in 2012. Strategy for smoke/CO detector guidance implementation. Protocols on air conditioning and heating system repair and installation. Procedures on handling problems resulting from combustion gas testing. Strategy for implementing OSHA and crew safety guidance. Protocols for addressing mold found in the client’s home. Plan for implementing and verifying RRP and LSW compliance. Cont.
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57 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Health & Safety Budget Review Does the state have a separate H & S budget? –If H & S items are not included in a separate H & S budget or are defined as incidental repairs, they must be addressed as such consistently throughout the state and must be cost justified. Expenditure limits must be “reasonable” and expressed as an per unit average. –Generally 10%. –Less assumes other funding is being utilized to address H & S. –More requires adequate justification relative to the increase. –15% and up requires additional DOE group review.
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58 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Health & Safety Plan Review As described in §440.16(h), DOE will monitor the plan based on the following criteria: (1)elimination of such hazards is necessary before, or as a result of, the installation of weatherization materials; and (2)the grantee sets forth a limitation on the percent of average dwelling unit costs that may be used to mitigate such hazards, which is reasonable in light of the primary energy conservation purpose of the Weatherization Assistance Program. Meeting the WPN 11-6 Guidance. –Is the required narrative/implementation strategy present? –Is it consistent with H & S guidance (cannot conflict)?
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59 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Health & Safety Plan Review Cont. If an action/testing is “allowed” in guidance grantees can concur, create additional requirements/limitations, or not allow. If “required” or “not allowed” – states must follow guidance. Important to consider what the guidance is specifically referring to – in what instances the action is allowed. Conducting certain actions will trigger specific testing, client education, and training requirements.
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60 | Weatherization Assistance Program: State Plan and Applicationeere.energy.gov Health & Safety Guidance Table Some common themes and requirements that should be considered when utilizing the Guidance Table are as follows: –Where removal or replacement is addressed, proper disposal is required, and allowed as a H & S cost. –Where hazards are identified, clients must be informed in writing and the document must be signed by the client and a copy maintained in the client file. –State and local (or jurisdiction having authority) codes must be followed while installing health and safety measures. –Workers must be qualified and adequately trained according to state and local (or jurisdiction having authority) codes specific to the work being conducted (electrical, plumbing, etc.). –Where Actions/Allowability, Testing, Client Education, and Training are allowed or required, DOE funds may be used unless specified otherwise.
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