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Executive Director
City of San AntonioWAP Mitigation Action PlanJune 2010
Table of Contents:
Background...............................................................................................................................................2Issue..........................................................................................................................................................2Section 1: Explanation of why one or more of the criteria for deobligation in the ARRAWeatherization Rule on Deobligation/Reobligation occurred:.................................................................2Section 2: Explanation of how the criteria under §5.902 of this chapter will be immediately,permanently, and adequately mitigated....................................................................................................3Section 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..............................................................................................................................6Section 4: Explanation of how remaining criteria under §5.902 of this chapter will be avoided............6Section 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........6Section 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 EnergyAttachment 2: City of San Antonio July 2010 Production ToolAttachment 3: WAP Progress Update to TDHCA, 7/6/2010Attachment 4: Dashboard detailing WAP progress through 7/2/2010
City of San Antonio WAP Mitigation Action Plan Page 2 of 6
Background:
The Cityof 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 CPSEnergy, its municipally owned utility, for implementation of WAP. CPS Energy, thus, is a 2
nd
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 TexasAdministrative 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
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 ARRAWeatherization 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 isthe completion of an assessment of the unit, which is performed by certified vendors under contract withCPS Energy. The assessments are needed to issue work orders for health and safety and weatherizationmeasures to begin. The assessments dropped off significantly in the 2
nd
week of May which ultimately leadto the shortfall in production. Additionally, to meet expenditure goals requires that production becompleted in a timely manner and also that contractors submit invoices in a timely manner such thatprogram expenditures will closely match the completed work in the units. Lack of timely invoicing by thecontractors lead to a greater shortfall in expenditures than was warranted by the underperformance inproduction.
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