Text version for the WPN 22-8 Regional Priority Lists webinar. 

This recorded webinar provides an overview of WPN 22-8 and the related regional priority lists provided by DOE WAP. It highlights pertinent details, provides clarification for some common questions, and points weatherization programs towards other appropriate resources for the immediate implementation of these new regional priority lists.

>>Male: Welcome to this prerecorded webinar provide by the Department of Energy's Weatherization Assistance Program. The purpose of this webinar is to provide a brief overview of the recently released Weatherization Program Notice 22-8: Streamlining the Energy Audit Process – Optional Regional Priority Lists.

Let's get started with a brief introduction to priority lists and their place in the Weatherization Assistance Program. Historically, priority lists, or PLs, have been an option for grantees of the Weatherization Assistance Program since 1993, though priority lists do not replace site-specific energy audits. The move towards energy modeling of homes in the Weatherization Assistance Program continues to increase the accuracy of savings predictions and therefore targeting the most cost-effective retrofits for that site. Over the years, many grantees have chosen to implement priority lists in their program. However, DOE recognizes creating, validating, and maintaining priority lists can be cumbersome for the WAP grantee network. In anticipation of recent need to increase staffing and training, DOE has created an additional option for grantees: regional priority lists, which DOE created and validated and will continue to maintain.

Notice of these new regional priority lists was provided to the WAP network in June of 2022 with the issuance of WPN 22-8. It provided grantees with the option to use these DOE-supplied regional priority lists for single-family, site-built, manufactured homes and low-rise multifamily projects.

You may have noted we say "optional." Yes, these priority lists are optional for grantees who wish to supplement the existing energy audit approval. Again, it does not replace the energy audit and will only be approved for a grantee that has a current and unexpired energy audit approval. There is no requirement that grantees adopt these PLs. It is simply one more option that DOE is providing to assist grantees in implementing higher levels of production.

As grantees contemplate whether or not to adopt the regional priority lists, they should keep in mind that there are certain advantages and disadvantages to implementing the priority list. Some of the primary advantages are that it establishes a broad package of measures that are already approved and can be safely installed. Implementation of a priority list also minimizes point-in-time cost fluctuations by taking the average cost of materials and labor as well as the energy source, and this results in more measures being installed consistently in every home we address across the region. And using a priority list does reduce time and cost associated with that time for energy audits, additional training, as well as improves your efficiency of your procurement, being able to procure larger quantities, knowing what you will be installing. 

And then, there are disadvantages to adopting a priority list. The primary one is that it's not as precise as a site-specific energy audit for a particular dwelling. This means that the priority list may not include every measure that is really applicable to the specific home, and that is the reason why DOE still requires an electronic energy audit to be an option for any home that does not fit within the boundaries of the priority lists as they are currently designed. 

The regional priority lists as designed by the Department of Energy are broken into three housing types and three climate regions each. This was done intentionally to try to keep the adoption of these regional priority lists as simple as possible. And DOE recognizes that there is significantly more climate diversity within the United States than this map reflects. However, generally speaking, these three climate zone designations do reflect relatively similar sets of cost-effective measures. These general regions are broken into region one for hot climates, region two for more moderate climates, and region three, which represents the colder climates of the country. In a later slide we'll discuss more how you can apply for multiple regional climate zones for your particular territory.

These regional priority lists are also broken into three primary housing types. First, site-built, single-family homes. Then, manufactured housing, both single-wide and double-wide homes. And finally, a low-rise multifamily category. This is more inclusive than "small multifamily," as previously discussed and defined in WPN 19-4.

Now, we'll briefly consider the requirements for a home to fit within the DOE regional priority list for each housing type. Our first housing type to consider are site-built single-family homes. Keep in mind that these priority lists are specifically designed to apply to only wood-framed, single-family, site-built dwelling units that meet the following checklist. They should be no more than three stories in height above grade. They should not have a primary heating system which is a sealed-combustion natural gas furnace originally rated for 90 AFUE or greater, nor should they have a heat pump manufactured after 2006. And lastly, the job must not exceed $500.00 in incidental repairs billed to WAP meeting the definition outlined in WPN 19-5. 

Next, manufactured homes. These priority lists apply to any single-wide or double-wide manufactured home that meets the following checklist. First, it is manufactured prior to 2010. It has an accessible and unconditioned subspace, meaning its foundation is unconditioned but accessible. It does not have any attached condition additions. Fourth, the primary heating system is not a natural gas furnace originally rated for greater than 80 percent AFUE. And similar to the site-built, the job will not exceed in $500.00 in incidental repairs billed to WAP meeting the definition outlined in WPN 19-5.

And last, low-rise multifamily. Low-rise multifamily projects are defined for the purposes of this priority list as any single development where all buildings contain five or more dwelling units per building and all buildings are three stories or less above grade. This is regardless of the total number of buildings or dwelling units. This is a change from the previous definition many people will think of as small multifamily, which had a limit of 25 units per building. It also contained limits that related to individual heating/cooling systems. The purpose of the low-rise multifamily priority list is to try to expand the coverage of multifamily building eligibility for the priority list, so we've tried to make it as simple as possible to utilize this priority lists on low-rise multifamily buildings. 

These PLs apply to any wood-framed, low-rise, multifamily structures that meet the following checklist. You must have five or more dwelling units per building. Any buildings that contain less than five units – so, two-to-four-unit buildings – may use the site-built, single-family priority list rather than the low-rise multifamily. They must be no more than three stories above grade in height. And third, the incidental repair measure costs, as defined in WPN 19-5, that are funded with DOE WAP funds may not exceed ten percent of the project's total energy conservation measure package. 

As mentioned earlier, DOE does provide the option for grantees to use more than one priority list within their territory. This is generally going to be the case where there's extreme climate variations within a grantee's territory. If a grantee would like to use more than the specific priority lists designated for their territory, then when they request adoption of these priority lists from the Department of Energy they should include clarification as to which PLs they wish to use within their territory and then provide a county-by-county list or map to designate where different priority lists will be used. This will also necessitate the inclusion of climate data to support the proposed priority list per county. There are many sources of data for this; however, the two most common are ASHRAE or the climate zone maps from the IECC or IRC editions of the International Code Council Codes.

Grantees should also keep in mind that PL adoption does not remove any of the DOE regulations or general requirements. It is simply a different way of performing a climate energy audit. What do we mean? Well, any project still requires a site-specific data collection or assessment or inspection, and if determined that the dwelling either does not meet the description of the priority list or additional measures are needed, then a site-specific energy model will then be completed. 

Additionally, all health and safety measures must still be installed per the DOE-approved plan. The final inspection requirements, as many people know as a QCI requirement, still applies to all units weatherized with the priority list. All your procurement requirements still apply. Additionally, the average cost per unit still applies to all weatherization projects just as it does under any other circumstance, regardless of whether a priority list is used or a standard electronic energy audit is performed for this dwelling.

Within each priority list you will note that some measures are mandatory and others are optional. First, let's address mandatory measures. Any measure labeled as mandatory must be installed and may not be skipped if it is applicable. What does that mean? If a measure already meets the minimum requirements – for instance, the attic is already insulated to the prescribed R value – then the measure is not applicable. Another example might be if it is physically impossible to install the measure. For instance, a slab floor exists and no insulation can be installed, or perhaps there's insufficient clearance underneath of the home to install floor insulation. These would be instances of where a measure is not applicable.

Optional measures are exactly as they seem: They're optional. They may be installed with DOE WAP funds if all other applicable mandatory measures are installed as well, regardless of the funding used for mandatory measures. What that means is if another funding source pays for mandatory measures on the priority list and WAP funds are still reserved, those funds may be used to fund optional measures as long as no mandatory applicable measures have been skipped.

Something else to note about optional measures. No optional measures may be installed with DOE WAP funds in low-rise multifamily common spaces using the priority list. Optional measures in low-rise multifamily buildings may only be installed in dwelling unites with DOE WAP funds. Otherwise, they would require a site-specific audit, or you can always use an alternative funding source for these measures in common spaces. 

As we are discussing optional measures in the priority lists, we must consider the optional heating and air conditioning replacements attached to these priority lists. Generally speaking, priority lists are not used to dictate heating/cooling system replacements. However, there are certain scenarios where these systems are generally cost-effective replacements and these are included in the predetermined optional measures in the regional priority lists which DOE has released. If the heating or cooling system does not fall into the specifics of the optional measure as it's already determined and the grantee still wants to use DOE WAP funds for the replacement of that heating or cooling system, then an electronic energy audit must be run, assuming that all the mandatory items have been installed in the building, and the ECM must still receive an SIR of 1.0 or greater for the replacement. 

It's important to note here that for single-family and manufactured homes, utilizing the grantee's previously approved energy audit for those housing stock may be used without additional permissions. However, for the low-rise multifamily priority lists, if an energy audit needed to be run to justify heating or cooling system replacement and the grantee does not have either a low-rise multifamily, small multifamily, or large multifamily energy audit approval, then the grantee would need to submit that energy audit to DOE for approval prior to beginning work.

One primary feature of the regional priority lists is the encouragement to use leveraged funding to install the most measures possible in every home which receives weatherization services. WPN 22-9, regarding braiding of leveraged resources, provides the most current direction on how to do this appropriately. Something to keep in mind, though, is that even though an alternative funding source may be used for any measure, if it's a mandatory measure, then it must meet the DOE minimum requirements for that measure's installation. So, for instance, if a leveraged funding source requires R-38 installation but DOE WAP's PL requires R-49, then R-49 will be installed, or otherwise no WAP funds may be spent on the project. This is to ensure that every home receives an equitable package of measures in every case. WPN 22-9 provides great flexibility in co-funding or cost-sharing of measures and its guidance should be adhered to any time these actions are performed.

In the regional PLs you will notice that there are some measures that contain cost gaps. These individual measure cost gaps are detailed in each priority list. They generally apply to refrigerators and other general heat waste items. If a cost cap is listed, then it applies only to DOE WAP funds spent on the measure. If additional funds are spent from an additional funding source, it does not apply to this cost cap. 

Something else to keep in mind is that though there are no hard cost caps on many of the mandatory measures, the regulations of 2 CFR 200 still apply to all procurement performed under weatherization program grants. Additionally, any procurement policies from the grantee must also still be adhered to just as they ordinarily would be.

A couple more items to consider. The site-built, single-family and manufactured housing priority lists both contain air and duct sealing targets. These targets are quite progressive in some housing stock. Are they achievable? Yes. Some grantees are already meeting targets just as aggressive as are currently placed in the priority lists. The purpose of these targets is to try to increase the effectiveness of weatherization in all housing stock. Grantees should already have policies regarding target values in place, especially what to do when you are unable to meet target values or when the housing stock prevents adequate access to perform these measures effectively.

Grantees should also note that R-value targets are final values, not added values. Though they are higher than what some programs currently require, the final value should meet the requirements of the priority lists whenever DOE WAP funds are used on the project.

All grantees of the Weatherization Assistance Program are already required to have in place site-built, single-family and manufactured housing energy audit procedures. However, many grantees have no multifamily-specific procedures at all. If a grantee has a currently unexpired energy audit approval for multifamily housing, meaning five-plus units per building, then it may adopt the regional priority lists using their existing policies and procedures, which must be provided to DOE for review. 

However, if a grantee has no current energy audit approval for any multifamily housing beyond four units, then it will need to either draft a basic energy audit/final inspection procedure for implementing this priority list, or they can adopt the sample procedures provided by the Department of Energy. Once DOE approves the procedures for your low-rise multifamily PL implementation, this does not constitute an energy audit approval for this housing stock. It simply approves the priority list procedures. 

If a grantee does not already have an energy audit approval for multifamily housing, then any energy modeling of the dwelling units to justify the use of DOE WAP funds beyond the priority list must be approved by DOE prior to work commencing. So, when you begin to apply, to adopt these priority lists, keep in mind whether or not your energy audit approval memo contains any approval for any type of multifamily building five units or larger. 

Any grantee that desires to adopt one or more of the optional priority lists must submit an official request to their project officer containing the following information. First, a formal written request to adopt the regional priority list. Next, the specific priority list for use based on the region in which the grantee serves. As we noted previously, if a grantee requests to utilize multiple DOE-approved PLs for the same housing type within their territory due to climatic variation, their request must include a clear map or table showing the areas to be served, their corresponding climate data, and the priority list to be applied in each area. And their request must also include the grantee's written policies and procedures for conducting the energy audits and final inspections for the projects where the priority list will be implemented. In the case of site-built, single-family and multifamily homes, generally speaking, all grantees will already have approved policies and procedures which they may supply to DOE for their review. 

If you are requesting to implement a low-rise multifamily priority list but do not have a current multifamily approval, then please consult your project officer to determine what additional requirements may be necessary to ensure you have appropriate policies and procedures in place. Note: Any variation from the DOE-approved regional priority list will require a complete priority list submittal per the current DOE WAP Energy Audit Guidance, which at this time is WPN 19-4. Once DOE has received a complete submittal, they will review it, confirm whether or not the grantee has adequate policy and procedure in place to ensure regulatory compliance. 

If approval is granted, DOE will provide that approval via an updated energy audit approval memo, which will document the official approval. The grantee may begin to implement the priority list in accordance with the written approval once it is received. If an approval is not initially granted, DOE will provide the grantee with a written response that details any missing or incomplete information which prevents full approval. The expiration dates of all priority list approvals will be tied to the general audit approval memo for that housing type for each grantee.

Going forward, DOE will reevaluate the optional priority lists on a regular basis. If updates are necessary, DOE will release those updated priority lists via program memorandum. Any grantee who receives prior approval to sue the regional priority lists must adopt the updated PL upon the effective date of the memorandum or stop using the regional PL completely. 

To assist grantees in adopting these new priority lists, DOE has developed some optional checklists, which grantees may utilize for implementation and to assist with development of policies and procedures. These checklists consist of the following items: a regional and housing stock-specific field data collection priority list checklist, combustion safety checklist, and a health and safety checklist. DOE highly recommends that grantees utilize the priority list checklists to ensure that sufficient documentation exists in the client file for all projects using the PL. 

If the grantee chooses not to use the DOE sample forms, then they must at a minimum collect the same information for the client file. Many grantees already have existing combustion safety or health and safety checklists, and these may be used and implemented with the priority list even if the field data collection form for the priority list is adopted.

The DOE is excited to provide these regional priority lists for immediate adoption by WAP grantees. We trust that these priority lists will increase weatherization production, provide necessary improvements for our clients, and continue to decrease the climate impact of housing. For additional information, including resource checklists, an FAQ document, and other guidance, please visit the Weatherization Assistance Program guidance pages found at this address or contact your project officer of record. 

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