>>Male: The focus of this webinar is the newly released WPN 22-13, regarding the weatherization of rental units. Let's get started.
The weatherization of rental units is not new to the Weatherization Assistance Program. In fact, it has been part of the regulations guiding the Weatherization Program since 1984, and as such assists to meet the purpose and scope of WAP by providing equitable services to person who are particularly vulnerable and it also assists in meeting WAP production goals. However, DOE recognizes it can be challenging due to the differences between single family and multifamily rental intake. There are also complications related to landlord and tenant agreements and situations where the utilities are included in rent rather than directly billed to tenants. For all these reasons, the Department of Energy has provided some additional clarification in 22-13 regarding the weatherization of rental units.
DOE continues to stress the importance of the weatherization of rental units as it relates to the Justice40 policy initiative. It is recognized that rental housing does comprise a higher percentage of disadvantaged communities where additional support is needed. As you can see from this chart, roughly one-third of all qualifying US housing units exist in a rental setting. However, only about 25 percent of WAP production is focused on rentals. By increasing our focus on rentals, the Weatherization Assistance Program hopes to increase the parity in clean energy technology, as well as energy resiliency, while still decreasing energy burden and adverse environmental exposure for some of our most disadvantaged clients.
DOE encourages grantees and subgrantees to review the current completions to see if services are being equitably distributed in states and territories to reflect the renter market of the service area. If not, are there approaches that could help to narrow that disparity by addressing barriers to service for rental units.
To facilitate these improvements, DOE has released Weatherization Program Notice 22-13, Weatherization of Rental Units, on September the 14th, 2022. This guide supersedes and provides updates to WPN 16-6, Weatherization of Rental Units. It also supersedes all information and materials in the Rental Policy Guidance of January 2, 1984 and the Rental Handbook, issued in August of 1984. Related guidance includes WPN 22-5 regarding the expansion of client eligibility, WPN 22-9, regarding managing multiple funding streams or braiding within the Weatherization Assistance Program, as well as WPN 22-12, regarding multifamily weatherization. Together, all of these guidance packages will greatly assist the Weatherization Network in providing equitable services to our clients dwelling in rental units.
WPN 22-13 focuses its primary emphasis on the regulation found at 10 CFR 440.22(b)(3), which has always been a requirement, and these specific issues were previously covered in the FAQs for WPN 16-6, but now they have been included in the body of WPN 22-13 for emphasis. This regulation stipulates some specific items that must be addressed in all rental housing regardless of the housing type. First, written permission of the building owner or its agent is obtained before commencing work. The benefits of the services must accrue primarily to the low-income tenants. And for a reasonable period of time after completion of weatherization the home will not be subject to rent increases. Additionally, the grantee and subgrantee must provide adequate procedures whereby tenant complaints can be received by the grantee and provides a method for owners to appeal these complaints. And finally, no undue or excessive enhancement shall occur to the value of the dwelling unit.
DOE wants to emphasize specifically that a properly executed energy audit that results in installing common energy conservation measures with an SIR of 1.0 or greater as well as the necessary health and safety and incidental repair measures would not constitute an undue enhancement. Specifically, DOE wants to draw attention to the fact that mechanical system replacements that meet an SIR of 1.0 or greater or are necessitated for health and safety reasons are not undue enhancements. This would include heating and cooling system replacements, domestic hot water replacements, refrigerators, and other common baseload measures. It should also be noted that the installation of measures within common spaces attached to the building should be closely considered to determine if the benefits are appropriately accrued to the low-income client rather than being undue enhancements.
In addition to following the regulations outlined in 10 CFR 440.22 as well as the approach to determining building eligibility, Weatherization Assistance Program grantees should reference the weatherization of rental units FAQs attached to WPN 22-13 to determine DOE's position on issues and questions that arise when working with tenants and landlords. Some of the common questions regarding program intake, tenant and landlord agreements, eligibility, and certification of applications are discussed in detail in these FAQs.
DOE recognizes and continues to emphasize the value and benefit of weatherizing rental units and that there is significant overlap between general multifamily weatherization and weatherization of rental units. Therefore, WPN 22-13 provides additional guidance for the nuances of rental weatherization in single-family housing and multifamily housing. WPN 22-12 further supports this guidance package, as it relates specifically to multifamily rental dwellings.
As grantees look to implement additional weatherization of rental units, information regarding DOE's policies and procedures can be found at energy.gov. Any questions should be directed to your DOE WAP technical project officer.
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