Weatherization Action Plan for the city of San Antonio

8/9/2019 Weatherization Action Plan for the city of San Antonio

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Executive Director



City of San Antonio

WAP Mitigation Action Plan

June 2010

Table of Contents:

Background............................................................................................................................................... 2

Issue .......................................................................................................................................................... 2

Section 1: Explanation of why one or more of the criteria for deobligation in the ARRAWeatherization Rule on Deobligation/Reobligation occurred:................................................................. 2

Section 2: Explanation of how the criteria under §5.902 of this chapter will be immediately,permanently, and adequately mitigated. ................................................................................................... 3

Section 3: Revised Production Schedule reflecting how Unit Production and Expenditure targets willbe achieved for each remaining month, including compensation for prior months of missed production,for all Awarded Funds. ............................................................................................................................. 6

Section 4: Explanation of how remaining criteria under §5.902 of this chapter will be avoided. ........... 6

Section 5: Description of activities currently being undertaken including an accurate description of thenumber of units in progress, broken down by number of units that have been qualified, audited,assessed, contracted, inspected, and invoiced and as reflected in an updated Production Schedule........ 6

Section 6: Provide any request for a reduction in Awarded Funds, reasons for the request, desiredAwarded Fund and revised Production Schedule reflecting the reduced Awarded Fund. ....................... 6

Table of Attachments:

Attachment 1: Letter from CPS Energy

Attachment 2: City of San Antonio July 2010 Production Tool

Attachment 3: WAP Progress Update to TDHCA, 7/6/2010

Attachment 4: Dashboard detailing WAP progress through 7/2/2010



Background: The City of San Antonio is a subrecipient of Weatherization Assistance Program (WAP) funds from theTexas Department of Housing and Community Affairs (TDHCA). The City is partnering with CPS

Energy, its municipally owned utility, for implementation of WAP. CPS Energy, thus, is a 2nd

tiersubrecipient of WAP funding. Each subrecipient of weatherization funds is required to forecast units to becompleted and funds expended by month through the grant term. April 2010 was the start for thisrequirement. City of San Antonio target production forecast for April 2010 was 83 units and $226,604.Actual production numbers were 84 units and $248,762. May target production target was 132 units and$654,874. Actual production numbers were 97 and $241,548.

Failure to be within 5% of the production targets triggers deobligation protocols per the Texas

Administrative Code Title 10, Part 1, Chapter 5, Subchapter 1. The City of San Antonio has missed theproduction target by more than 5% and thus is subject to the protocol outlined in the Texas AdministrativeCode. The protocol calls for a “notice of possible deobligation” to be provided to the subrecipient and therequirement for the subrecipient to produce a “mitigation action plan” within 15 days of the date of the“notice of possible deobligation.” This document constitutes the City of San Antonio’s Mitigation ActionPlan.

In Texas, 29 of 44 subrecipients were subject to deobligation notices based on April production numbers.San Antonio is in the class of new large city subrecipients created specifically for the weatherizationstimulus funds. San Antonio was not in that group for April. San Antonio is the number 2 performeramong the 11 new subrecipients in quantity and percent of units completed.

Issue:

Production numbers and program expenditures for May did not reach the May targets. This triggers theweatherization program deobligation rule, which requires the submission of a WAP Mitigation Action Plan.The City of San Antonio has experienced significant difficulties associated with the Texas Departmentof Housing and Community Affairs’ administration of the program. Particularly we have haddifficulty in three areas: (1) not being permitted to use the same audit tool as existing subrecipients, (2)inconsistent guidance and direction from TDHCA staff, and (3) lack of responsiveness from TDHCAto requests for assistance.

Included as Attachment 1 is a letter from the General Manager of CPS Energy which provides furtherbackground regarding the status of WAP in San Antonio and highlights the difficulties associated with stateadministration of the program.

Section 1: Explanation of why one or more of the criteria for deobligation in the ARRA

Weatherization Rule on Deobligation/Reobligation occurred:

Meeting the forecasted monthly WAP production and expenditures requires keeping a sufficient quantity of applications/units in process at every stage in the WAP production pipeline An early stage in production is



Background on how this happened:

Unit assessments have operated on an interim arrangement with the TDHCA since TDHCA changed its

position on using weatherization contractors to conduct assessments and the subsequent work.Originally, the TDHCA approved the WAP RFP that allowed contractors to perform assessments(email from Stephen Jung to Maria Koudouris, dated 11/11/2009); however, during a weeklyWeatherization Progress Check on 1/25/10, the City’s Program Officer, J.R. Mendoza, made thedetermination that it is not permissible for weatherization contractors to perform unit assessments. Aninterim arrangement agreed to by the Program Officer allowed the contractors to perform assessmentsfor a different contractor that would do the work. When the new assessors were hired, the primarycontractor performing unit assessments pulled its capability to do assessments and assigned their staff

to other work for a different subrecipient. The new assessors, however, failed to deliver assessed unitsas contractually obligated. Under pressure from CPS Energy, the new assessors have started producingassessments the subsequent week.

The shortfall in assessments in the 2nd week of May resulted in a shortage of units with work orders inthe 3rd week of May; consequently, production fell during the middle weeks of May.

The May expenditure forecast was developed assuming 75% of the units forecasted to be weatherizedin May and 50% of the units weatherized in would be invoiced by month’s end to be included in theMay expenditure report; this would total 140 invoices. In actuality, only 41 invoices were processed bymonth’s end due to the production shortfall and delayed invoicing by the contractors.

Section 2: Explanation of how the criteria under §5.902 of this chapter will be immediately,

permanently, and adequately mitigated.

The new assessment firms have been warned and are being held to the terms of their contract. The numberof assessments completed weekly has shown increase since the shortfall in the 2nd week of May. Since theassessment numbers are the primary cause of the production shortfall in May, the City of San Antoniobelieves that WAP production has been adequately addressed.

Week endingNew

Assessmentscompleted

May 14, 2010 17

May 21, 2010 45May 28, 2010 90June 4, 2010 48June 11, 2010 78June 18, 2010 114June 25 2010 80



Additionally, a number of staff are being added to the Casa Verde team to accelerate production past thetargets:

WAP Activity Current Staffing level Staff being added Outreach/Intake 2 Permanent 2 Temporary 2 Permanent

1 Summer Prequalification 2 Permanent

2 Temporary 1 Summer Issue Work Orders 1 Permanent 1 Permanent (returning from FMLA)

1 Permanent 1 Summer

Inspection 2 Permanent 1 Permanent Supervisor who supplements

1 Temporary (begins 6/1/10) 1 Permanent 1 Permanent (FMLA returning employee will transition to field if doctor allows) Can also requested contract inspectors to perform this activity

Payment of Invoices

1 Permanent 1 Permanent

The City of San Antonio and CPS Energy are working to continue to increase contractor capacity andagency staffing. To meet future production and expenditure guidelines, we will continue to expandproduction capacity through October 2010

The City of San Antonio and CPS Energy anticipate that not all of the remaining TAC performance criteriacan feasibly be met by the required deadlines. This is due to a number of circumstances which are beyond

the City and CPS Energy’s control, which need to be addressed by TDHCA, including:

1. Issue: New subrecipients are not permitted to use the same audit tool as existing subrecipients; theaudit tool in question allows for greater unit expendituresConsequence: If TDHCA does not allow new subrecipients to use the Easy audit tool, unit spendingwill remain low and the City and CPS Energy will have difficulty meeting expenditure benchmarks.Currently the average spending per unit on materials, labor, and program support is approximately half of the allowable amount. Experienced contractors who have worked with the different audit tools and

Priority list have indicated that they have been able to do more work with measures determined throughthe Easy audit tool.Local actions taken: The City and CPS Energy have requested training from TDHCA to ensure that alleligible measures under the priority list and NEAT can be implemented in order to increase unitspending. Additionally, the Production Tool forecasts have been adjusted to reflect additional units dueto the low spending per unit.



during a weekly Weatherization Progress Check (dated 1/25/2010), the City’s Program Officer,J.R. Mendoza, made the determination that it is not permissible for weatherization contractorsto perform unit assessments.

c. Qualification of Multifamily Units: TDHCA originally allowed using income documents onfile for HUD complexes designated by DOE as 100% qualified multifamily properties, per anemail from J.R. Mendoza dated 4/9/10. Then, in the 4/16/10 bi weekly conference call, thiswas reversed and TDHCA required use of 30 day income. Finally, on 6/4/10 in email from J.R.Mendoza, TDHCA permitted the use of income documentation on file

Consequence: Significant time has been lost sorting through the inconsistent guidance, changingprogram policies and procedures, and redoing work that was previously completed under previousguidance from TDHCA

Local actions taken: CPS Energy and the City have worked swiftly to respond to the changes inguidance from TDHCA and have sought clarification where inconsistencies were noted.Recommendation to TDHCA: TDHCA provide consistent, written guidance for all WAP guidelines toall subrecipients. TDHCA follow verbal guidance with written notification in all cases.

3. Issue: TDHCA responsiveness to assistance requests. Examples:a. Training: The following requests have received no response from TDHCA:

Field training to address issues related to new contractor ramp up (Emails to MarcoCruz dated 5/14 and 5/26)

Assessment training for shelters (Email to Marco Cruz dated 5/26)

Training regarding the NEAT audit tool (Email to Marco Cruz dated 4/12)

Training regarding the Priority List (Email to Marco Cruz dated 4/12)b. Tax Credit Housing Qualification Assistance: on the 4/16 statewide conference call TDHCA

stated that it would provide a list of 100% qualified tax credit housing buildings by county by4/21. TDHCA offered to provide a list of partially qualified buildings for subrecipients whosecounty has no 100% qualified buildings.

The 100% qualified list was provided on 5/14; there were no properties in BexarCounty.

In email on 5/17 the City requested the partially qualified list for Bexar County, asoffered on 4/16.

On 6/18 TDHCA staff provided a non-exhaustive list of property names that haveunits that may be eligible for weatherization in Bexar County. That same day the Cityrequested property addresses and contact information, which was provided on 7/2.

c. Email requests regarding program guidelines: written questions to the state regarding

program guidelines and reporting have been in many cases left unanswered or have requiredone or more follow up emails in order to obtain response. Examples include: monthly reportingguidelines, amendments to monthly reports, procurement requirements, production schedules,hiring requirements, and others

Consequence: The City and CPS Energy have experienced program delays while waiting for TDHCAresponse or assistance. Time has been lost and the program implementation has had to proceed withoutfull clarity or needed assistance



Section 3: Revised Production Schedule reflecting how Unit Production and Expenditure targets will

be achieved for each remaining month, including compensation for prior months of missed

production, for all Awarded Funds.

The City and CPS Energy adjusted our production schedule to show increased production in future months.Relative to our previous submittal, the new tool (submitted June 7, 2010) reflects higher production inmonths of July – December 2010 to make up for missed production in May. Additionally, per Section 5 of this Plan, a new production schedule has been created and is attached for the month of July.

Section 4: Explanation of how remaining criteria under §5.902 of this chapter will be avoided.

Regarding the criteria under §5.902(b) of this chapter, please see above for explanation.Regarding the remaining criteria the City and CPS Energy will:

Notify the TDHCA of any adverse audit, inspection or internal control finding

Address any findings or inspections regarding work quality to ensure conformance to programrequirements, that all inspections and assessments are adequate and satisfactory, inadequateassessments, and that sufficient quality control efforts are in place.

Resolve any monitoring findings that may occur and implement any necessary changes identified ina monitoring visit

Section 5: Description of activities currently being undertaken including an accurate description of

the number of units in progress, broken down by number of units that have been qualified, audited,

assessed, contracted, inspected, and invoiced and as reflected in an updated Production Schedule.

Please see Section 2 of this Plan for a description of activities being taken. Included as Attachment 2 is acopy of the City of San Antonio’s July Production Tool for July 2010. Included as Attachment 3 is themost recent progress update to our program officer dated 7/6/2010, which details the number of units inprogress, broken down by number of units that have been qualified, audited, assessed, contracted,inspected, and invoiced. Attachment 4 is the dashboard used to track progress locally and providesfurther detail regarding WAP progress.

Section 6: Provide any request for a reduction in Awarded Funds, reasons for the request, desired

Awarded Fund and revised Production Schedule reflecting the reduced Awarded Fund. The City of San Antonio and CPS Energy make no request for reduction in awarded funds. We desire toexpend all program funds and have developed strategic planning to do so.



Attachment 1



Attachment 1



Attachment 1



A t t a c h m

e n t 2



A t t a c h m

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Attachment 2



Weekly WAP Update to TDHCA 7/6/10COMMENTS:

1 How many households are on your wait list? 140

2 How many units were assessed last week? 34

3 Of units in-progress currently….

How many are applications? 2744

How many are qualified households? 792

How many have been assessed? 337

How many have work orders? 295

How many are under construction? 69

4 How many units were finaled last week? 40

5 How many will you final this upcoming week? 42

Other Questions

6 Last week you anticipated completing 40 units, why were those not finaled as expected?

7What is the capacity of the current subcontracting staff? How will they meet the production goals of the

agency?

8 How might an additional procurement be a better choice for more production capacity?

9 What can TDHCA Energy Assistance Staff do to help reach expected production?

10 Why are units pending (e.g. historic commission review) Awaiting gas permits, inspections, stoves, wall furnaces

11 What is the quality of the units like? Typical issues that come with older homes

12 Is there any training that anyone needs?

13 Are there any substantive changes to your board or staff? Contract information changes?

Comments:17 units turned in Thurs 6/24; 18 units by COB Fri 6/25/10

48 units are pending final inspection as of COB 7/2/10; 32 units turned in towards end of week

40 additional turned in late Friday but not

yet processed

40 completed; 1 inspection failed, 35 additional units turned in for final

inspection towards end of week

Gained additional 4 people this week (transfers from other departments);

summer interns began approximately 2 weeks ago

Marco Cruz and Alfred Mycue visited with CPS Energy and 1 assessor on

7/1/10; they will coordinate future NEAT training in SA

A t t a c h

m e n t 3



7/6/2010 District 4: Intake at St. Leonard's Church, 4-7pm

7/14/2010 Taping: Desde San Antonio on KWEX-41

7/20/2010 District 2: Intake at Second Baptist Church, 4-7pm


7/24/2010 District 5: Intake at the Neighborhood Place, 9-11am

7/27/2010 District 3: Holy Name Catholic Church, 4-7pm

8/4/2010 State Rep Farias event: Harlandale 6-8:30pm

8/7/2010 District 7 (tentative), location TBD


8/12/2010 Taping: Tu Estilo on KWEX-41




9/2/2010 Taping: Tu Estilo on KWEX-41





9/24/2010 Home and Garden Show







Outreach Events

WEATHERIZATION ASSISTANCE PROGRAMSTATUS THROUGH 2-JUL-10

A t t a c h m e

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