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NASCSP Response to AP article by Ms. Garance Burke

Since the passage of the American Recovery and Reinvestment Act (Recovery Act), there has been much negative press concerning the Weatherization Assistance Program (WAP) and its ability to deliver on the promise of the Act to put people back to work quickly while significantly reducing home energy costs for vulnerable low-income households. Many news articles, including the recent “Stimulus Watch: Weatherization Program falling short” by AP reporter Garance Burke, reiterate that the anticipated number of jobs and weatherized units have not yet materialized. For those who read beyond the pessimistic headlines and gloomy opening paragraphs, the stories also acknowledge some of the significant obstacles that confronted the Weatherization Program network. These obstacles have largely been overcome and those knowledgeable about the program expect the network to reach full production in the next 60-90 days and fulfill the goals set by the Obama Administration.

Perhaps the greatest challenge to a timely start to program expansion was the directive to pay and administer Davis-Bacon prevailing wages for all Recovery Act funds; the WAP has had a waiver of those requirements for the past 30 years. This meant a delay while the Department of Labor decided whether a new wage should be determined, and further delays as they obtained wage determinations in every county in the U.S. for a previously non-existent “Weatherization Worker” job classification. The wage determinations were not finalized until September 2010, several months after the start-up of the Recovery Act.

Since a large percentage of low-income households live in older housing stock, in many states historic preservation rules slowed the start up of ARRA weatherization due to requirements for State Historic Preservation Offices to review work on houses older than 45 years. A Prototype Programmatic Agreement, developed by the Department of Energy (DOE), in coordination with the Advisory Council on Historic Preservation (ACHP) and the National Conference of State Historic Preservation Officers (NCSHPO), appears to address the concerns in a workable manner and is a major step to help enable work to move forward on these older units.

Perhaps the most disturbing characterization of WAP in the news is the perception that it is a very simple retrofit program performing isolated energy efficiency measures, a “$5 billion program to install weather-tight windows and doors” as Ms. Burke writes. Actually, windows and doors are rarely installed because they typically do not have the energy paybacks of other measures, and are often too expensive for the cost limitations of the program. Weatherization professionals use a whole house approach, where they address a home as a single energy-consuming system, rather than a loose collection of unrelated systems. Using this technique, the best combination of measures for reducing total energy consumption is tailored to each home. The process involves an energy audit, selection of measures based on energy paybacks and cost-effectiveness, installation of measures, and a post-work inspection.

This is a comprehensive approach that is considered state-of-the-art by energy efficiency experts, but misunderstood by most of the public, who have been conditioned to believe that the most heat loss in a home is through the windows and that spending $15,000 for replacements will reduce their energy bills enough to pay for the expense quickly. WAP uses energy audits that are required to account for the interaction of all proposed measures. WAP also utilizes sophisticated diagnostic equipment, such as blower doors to measure and detect air leakage, digital combustion analyzers to measure steady state efficiency and carbon monoxide, duct leakage diagnostic tools, and infrared cameras.

Along with using advanced energy audits and diagnostic equipment, the WAP has integrated many high-tech installation practices into the program, including advanced techniques for dense pack sidewall insulation, mobile home insulation, blower door guided air sealing, and electric baseload measures. There have also been major advancements addressing indoor air quality and other health and safety concerns. Taken together, the advanced diagnostic and installation procedures give taxpayers the greatest “bang for their buck” in every home weatherized through the program.

The Weatherization Assistance Program has been arguably the single major contributor to residential energy efficiency technology by developing and practicing the state-of-the-art methods that the newly emerging green retrofit industry is adopting. In many areas, utility companies have recognized this and partnered with both State and local WAP managers to enhance existing weatherization programs for the utility’s customers.

WAP has evolved to incorporate sophisticated analysis of the energy needs of a home, high tech diagnostic tools and installation techniques, and extensive training of workers to be a program with effective results and real energy savings. As the Weatherization network overcomes the barriers of ARRA implementation there are positive indications that the Obama administration goals for WAP will be met. All evidence points toward rapidly increasing expenditures and production since the last official reports from DOE in December 2009. The network is already weatherizing homes at a greater rate than any time in the history of the program, with projected production rapidly growing to a projected level of 25,000 homes per month by late spring. All levels of the WAP, from the Department of Energy to the State Grantees to the local agencies, are committed to working together to accomplish the goals of the American Recovery and Reinvestment Act. As originally projected in WAP State Plans, we believe that 600,000 homes will be weatherized using ARRA funds by March 2012.

The National Association for State Community Services Programs is a professional membership organization for the state and territorial administrators of the Department of Energy Weatherization Assistance Program (WAP) and the Department of Health and Human Services Community Services Block Grant (CSBG).

NASCSP Response to Department of Energy Office of Inspector General Special Report on Weatherization and the American Recovery and Reinvestment Act

WASHINGTON, Feb. 25 /PRNewswire/ -- The U.S. Department of Energy, Office of Inspector General Special Report OAS-RA-10-04 entitled "Progress in Implementing the Department of Energy's Weatherization Assistance Program (WAP) Under the American Recovery and Reinvestment Act" is correct in asserting that the existing Weatherization network has been confronted with unprecedented challenges in implementing the American Recovery and Reinvestment Act of 2009 (ARRA) funds effectively. However, the State and local agencies of the Program are now fully ready, willing and able to meet the goals of the Obama Administration and the Department of Energy (DOE).

It is not our intention to rehash the problems and obstacles that slowed the progress of ARRA funds in the WAP, but to address concerns raised in the report and move forward constructively. While it is accurate to assert that the ramp up of expenditures and production has been slower than anticipated, this has been due largely to variables outside of the control of network providers. For instance, from late March, when the first States received their initial award, to June of 2009, States had access to just 10% of the funds, which could only be used for training, hiring and equipment purchases. States were not allowed to use funds for production purposes until the restriction was lifted in June of 2009.

Since its inception, the Weatherization Assistance Program has had a waiver from Davis-Bacon prevailing wages. The applicability of Davis-Bacon labor rates for all WAP ARRA projects posed significant planning and management challenges due to rigorous administrative requirements such as exponentially increased record keeping requirements and the introduction of weekly certified payrolls. In June 2009, the Department of Labor (DOL) decided that Davis-Bacon prevailing wages would apply to the WAP. Between June and July 2009 there was much uncertainty within the network whether and to what extent wage determinations would be made for a weatherization worker classification. In July, it was decided that a full wage determination of every county in the Nation would occur for the new weatherization worker classification. The resulting confusion during this time made Program managers wary of moving ahead with production until weatherization worker wages had been finalized. DOL finalized wage determinations for residential weatherization workers in September 2009.

Though not quite as far reaching as the Davis-Bacon requirements, another stipulation that any dwelling older than 50 years must be reviewed by the State Historic Preservation Office (SHPO) before weatherization became another serious roadblock. Most SHPOs were not staffed or prepared for the magnitude of reviews that could be necessary, as a large number of the low-income homes eligible for weatherization are over 50 years old.

To the credit of the Department of Energy, they confronted both the problems with Davis-Bacon and Historic Preservation head on. In addition to the swift response to the Davis-Bacon issue, DOE developed, in coordination with the Advisory Council on Historic Preservation (ACHP) and the National Conference of State Historic Preservation Officers (NCSHPO), a Prototype Programmatic Agreement to address historic preservation requirements for the Weatherization Assistance Program. We believe the recently released guidance is effective and addresses the concerns in a very workable manner.

Weatherization Program Managers are well aware of the increased scrutiny inherent with ARRA funds, and are working diligently to ensure both proper accountability and transparency. While the report asserts that there may be an increased possibility of wasteful, inefficient, and perhaps even abusive practices, due to an environment where there is a desire to spend WAP funds on a catch-up basis, we believe the contrary. As States and local agencies have proceeded with caution, they are now well equipped to tackle the challenge of ARRA production efficiently, properly, and with utmost accountability.

Additionally, while the weatherization of homes with ARRA funds has not been at the pace anticipated, it is important to note that homes have continued to be weatherized using regular 2009 Department of Energy, Low Income Home Energy Assistance Program, utility, and other funds. The WAP network is fully capable of meeting the goals of the American Recovery and Reinvestment Act and is well on the way to doing so. While there have been significant delays at all levels of the Program, these have since been ironed out.

Now that the major obstacles, such as the Davis-Bacon and Historic Preservation requirements, have been resolved, we expect the Weatherization Assistance Program will soon be back on target in meeting ARRA objectives in the very near future. NASCSP works extensively with the Department of Energy, States (our members) and the National Community Action Foundation, which represents the approximately 900 Community Action Agencies in the Weatherization network. All levels of the WAP, from the Department of Energy to the State Grantees to the local agencies, are committed to working together to accomplish the goals of the American Recovery and Reinvestment Act. We are confident that, in spite of the slow start, that the obstacles have been overcome and that production and expenditure goals will be met.

The National Association for State Community Services Programs is a professional membership organization for the state and territorial administrators of the Department of Energy Weatherization Assistance Program (WAP) and the Department of Health and Human Services Community Services Block Grant (CSBG).

$300 Million for Weatherization: President's FY 2011 Budget

The President’s FY 2011 budget contains a significant increase for the Weatherization Assistance Program to $300 million. As with the 2010 allocation, there is $30 million for the continuation of the Innovations in Weatherization activity.

A relevant part of the Introduction section of the Department of Energy budget request states:

Energy Efficiency

In August 2009, President Obama said, “If we want to reduce our dependence on oil, put Americans back to work and reassert our manufacturing sector as one of the greatest in the world, we must produce the advanced, efficient vehicles of the future.” In FY 2011, the Department will promote energy efficiency in vehicles technologies, at $325 million. No less important to achieving the President’s stated ambitions is decreasing energy consumption through developing and advancing building technologies ($231 million) and industrial technologies ($100 million). Federal assistance for state-level programs, such as State Energy Program grants ($75 million, a 50 percent increase from FY 2010) and Weatherization Assistance grants ($300 million, a 43 percent increase from FY 2010), will help States and individuals take advantage of efficiency measures for buildings and homes, lower energy costs and greenhouse gas emissions, and develop an ever-evolving, technically proficient workforce.

The two links below provide detail about the proposed FY 11 budget for WAP.

Source: http://www.mbe.doe.gov/budget/11budget/Content/FY2011Highlights.pdf

Details: http://www.mbe.doe.gov/budget/11budget/Content/Volume%203.pdf (p. 425) (p. 436-440)

Administration Releases $490 million in LIHEAP Emergency Funds

The Administration released $490 million of the $590.3 million available in emergency LIHEAP funds on January 20, 2010. The following is a link to the state-by-state table released by the Administration. Additional information is expected from the Administration during the week of January 25 explaining the formula allocation.

HHS State Allocations