WAP Monitoring - Part 1

TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRS
wlUw.tdhca.state. fx.Us
Rick Perry BOARD MEMBERS
GOVERNOR C. Kent Conine, Chait'
Gloria Ray, Vice Chair
Leslie Bingham Escarefio
Michael Gerber Tom H. Gallo
EXECUTIVE DIRECtOR Lowel1 A. Kcig
Juan S. Munoz, Ph.D.
August 12, 2010
Mark Lisheron
Texas Watchdog
8303 Forest Heights Lane
Austin, TX 78749
Re: Open Records Request
Dear Mark:
This letter is in response to your August 2, 2010, request under the Texas Public Information Act,
Chapter 552, Texas Government Code, in which you request the following information:
Copies of all audits and evaluations done by your department of work done between
June 1 and the current date, Aug. 2., in Texas through the Weatherization Assistance Program
funded through the American Recovery and Reinvestment Act.
The Texas Department of Housing and Community Affairs has reviewed its files and located the
enclosed documents responsive to your request. I am in hope that you will accept these files with
certain entries redacted. If you do not accept these redacted files, the Department must request a
determination by the Office of the Attorney General whether it can release these files without the
redactions.
While Texas Government Code §552.267 allows a governmental body to charge for copying
documents, these documents are being provided to you at no charge. The Department reserves the
right to charge for document copies in the case of future requests.
If you wish to discuss this matter further, please contact me at 512/475-4743.
Sincerely,
~.~:n- TDHCA Public Information Officer
221 EAST 11''' • P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525-0657 • (512) 475-3800
() Primed 011 recJehd paper
wtllw.tdlJca.state.tx.us
RkkPerry BOARD MnMBBRs
GOVERNOR C. Kent Cl;tnlnc, Chair
Glotla Ray. Vice Chah'
Lealie Bingham Escareflo
Michael Gerber Tom H. Gahh
ExecUTlVB DIRECTOR Lowell' A. Keig
Juan S. Munoz. Ph.D.
June 7, 2010
Mr. David Zappasodi

Executive Director
Arlington Housing Authority
501 W. Sanford, Suite 20
Arlington, Texas 76011
Reo: ARRA Weatherization Assistance Program Contract #16090000746

Dear Mr. Zappasodi:
Enclosed is a report that details the monitoring review of your Weatherization Assistance
Program contract with the Texas Department of Housing and Community Affairs. This
infOrmation is provided to ensure that compliance with the contract(s) is maintained and that
services to the poor, elderly, and disabled are offered in the most expeditious and economical
manner.
The Department has identified seven (7) findings and one (1) recommendation .for the
Weatherization Assistance Program. Please submit a response to this report to this office within
thirty (30) days of the date of this letter.
If we can be of any assistance, please contact Jason A. Seale, Program Officer, at (512) 463-
0172. The assistance provided to the Program Officer by City of Arlington is greatly
appreciated.
Sincerely,
Sharon Gamble
Manager
Energy Assistance Section
221 EAST 11'" • P. O. Box 13941 • AUSTIN, TBXAS 78711·~941 • (800) 525-0657 • (512) 475·3800
(J P,lm,J DlI rtlJdttl pnl"
PY09 WEATHERIZATION MONITORING REPORT
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CITY OF ARLINGTON
Directory of Monitoring Sections
Section I. Financial Review
Section II. Travel and Timesheets
Section III. General Liability and Pollution Occurrence Insurance
Section IV. Property Management
Section V. Procurement
Section VI. Audit
Section VII. Personnel Policies and Procedures
Section VIII. Performance Review/Onsite Inspections
Section IX. Administrative
Section X. Client FilelMultifamily Review
Section XI. Denied Files
2
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CITY OF ARLINGTON
Dates of Review: April 26, 2010 - April 29, 2010
Focus of Review
"
CONTRACT NAME CONTRACT CONTRACT CONTRACT DATES

NUMBER AMOUNT
ARRA 16090000746 $1,091,787.00 9/1/2009 to 8/31/2011
On-site review of City of Arlington's implementation of the American Recovery and

Reinvestment Act of 2009 Weatherization Assistance Program (WAP). Specific areas of review
included Financial Reporting, Contract Agreements, Procurement, Personnel and the
Management of the American Recovery and Reinvestment Act of 2009 contract.
Program Evaluation
The evaluation of the program consisted of: Interviews with the City of Arlington personnel,
analysis of the fiscal system, review of programmatic records, on-site inspections, client file
reviews and inventory review.
The following was noted during the review:
• Lack'ofDocumentation for LSW Practices

• Missing Material Specification Sheets
• Low Expenditures for ARRA WAP Contract
• Incomplete Client File Documentation
• Contl'actor HVAC Pricing Discrepancies
• Missing Contract Provisions
3
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CITY OF ARLINGTON

EXPENDITURES AS OF MARCH 2010
CONTRACT YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS IN

NAME EXPENDITURES CONTRACT COMPLETED PROGRESS
AMOUNT
ARRA $95,796.81 8.77% 35 35
Recommended Improvement #1 Review of the March 2010 expenditure report for the ARRA
contract revealed Administrative expenditures were above the maximum allowable of 5%.
Current Administrative expenditures for the ARRA contract are 12.15%. The Department
reminds City of Arlington that Administrative expenditures must be at 01' below the maximum by
contract closeout 01' be subject to disallowed cost.
Finding #1 Low Expenditures As of the March 2010 monthly expenditure reports,

City of Arlington had expended 8.77% of ARRA WAP Contract
#16090000746. The ARRA WAP Contract requires the development and
implementation of equitable WAP services throughout the entire service
area.
Action
Required The Department requires City of Arlington to submit a detailed plan of
action to include increased production and adherence to the DOE
Production Schedule in the response to this report. Failure to submit a
plan to the Department may result in suspension of the ARRA WAP
contract. Reference: ARRA Contract Section 4
Finding #2 Missing Contract Provisions Review of the current vendor contract
revealed foul' (4) provisions that are required to be included in the
contractor agreement. The four (4) provisions that weren't included in the
current agreement are:
A) For contracts in excess of $10,000, compliance with Executive Order

11375 Amending Executive Order 11246 "Equal Employment
Opportunity"
B) Utilizing ARRA funds for use in political activity and lobbying
C) Assuring legal authority to sign the contract
D) For contracts in excess of $100,000, compliance with Clean Ail' and

Clean Water Acts
4
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CITY OF ARLINGTON
Action
Required City of Arlington is currently in the process of procuring an additional
contractor for the ARRA WAP program. Once the preceding provisions
have been added to amend existing contracts, City of Arlington must
submit a copy to the Department in the response to this report.
Reference: OMB Circular A-110 - Appendix A, ARRA Contract
Section 30, 10 TAC §5.10
Section VIII. Onsite Inspections

Finding #3 Inadequate Final Inspections On-site review revealed that the City of
Arlington was not conducting thorough final inspections of units
weatherized. The units require a return to 7 out of the 10 units inspected
for additional work to assure compliance with current program
requirements. City of Arlington installed 1/2" sheetrock in the garage of
09WAP 102 under health & safety. This installation Is not an allowable
cost under this category.
Actiou
Required In order to ensure program compliance, the City of Arlington must return
and address units as indicated in Attachment A of this report. As part of
the response to this report, the City of Arlington must submit a written
plan that outlines how final inspections will be more thorough and
comprehensive. City of Arlington must transfer the cost of the sheetrock
(09WAPI02) to unrestricted funds and submit supporting documentation
or reimburse the Department $384.00 from unrestricted funds for the
sheetrock that was installed under Health & Safety. Reference:
Weatherization Field Guide, Chapter 1
Finding #4 Inadequate Lead Work Practice Documentation On-site unit

inspections revealed a deficiency in minimum. documentation standards
for Lead Safe Work Practices. Review of client file documentation
affirmed t1).e potential of lead hazards in pre-1978 units that were
recipients of weatherization services provided by City of Arlington.
Action
Required The City of Arlington is reminded of EPA's LRRPP (Lead; Renovation,
Repair and Painting Program) Final Rule effective April 22, 2010. The
listed reference will provide Minimum Standards for LSW, found in WPN
08-6, Attachment A. Failure to follow EPA guidelines for LSW could
result in fines administered by the EPA as well as disallowed costs
administered by the Department. Reference: WPN 08-6, WPN 08-6,
Attachment A - Minimum Standards for LSW, WPN 09·6
5
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CITY OF ARLINGTON
Finding #5 Missing Material Specifications Documentation At the time of

monitoring, City of Arlington could not provide Material Specifications
for air conditioning equipment, gas water heaters, electric water heaters,
gas furnaces, electric furnaces, weatherstripping and replacement windows
being utilized in the ARRA WAP program by its current contractor.
Action
Required The City of Arlington must submit as a response to this report the material
specifications of the preceding equipment in accordance with Department
of· Energy (DOE) specifications. Any materials not meeting DOE
specifications will be considered disallowed costs. Reference: 10 CFR
440, Appendix A - Standards For Weatherization Materials
Section X. Client File Review

Finding #6 Incomplete Client File Forms A review of the client files revealed that
the· City of Arlington is not completing the forms as required by the
contract.
All Files - Start date on Building Weatherization Report were from the
assessment date and must be from the work start date.
09WAPI02" Income documentation is not current for PVSH1504. File
is missing income documentation or the Declaration of Income Statement
for PUSHI504.
09WAP78 - Failed to obtain complete 30 days of income for HAL6205
and JMI6205. Failed to obtain 30 days of income for YMI6205 from
Fuente de Sodas Letty's.
09WAPI02 • Sheetrock was installed in the garage under the Health &
Safety line item. .
09WAP24 • Priority sheet shows the water heater under the Health &
Safety category but the Building Weatherization Report indicates it was
paid under the Other Measures category.
09WAP44 • Building Weatherization Report is missing agency and client
signatures with dates.
09WAP62· Contractor invoiced agency $1,200.00 to replace a 13 SEER
NC. The material price list indicates that the price is $900.00.
09WAP4 - Contractor invoiced the agency $2,075.00 to replace a 75 BTU
Furnace. The material price list indicates that the price is $900.00.
Action
Required The City of Arlington must provide the Department a written procedure
6
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CITY OF ARLINGTON
indicating how the agency will adhere to complying with the requirement
of filling out the forms as required by the contract. The written procedure
must be submitted in response to this report. The City of Arlington must
obtain current income documentation from PVSH1504 and for PUSH1504
(09WAP102). The agency must obtain current income documentation or
Declaration of Income Statement from HAL6205 and JMI6205
(09WAP78). A copy of the income documentation for HAL6205,
PUSH1504 and PVSH1504 must be submitted with the response to this
report. Failure to provide the required income verification documentation
will result in disallowed costs for all weatherization measures performed
and all materials installed.
The City of Arlington must request from the contractor an adjusted
invoice in the amount of $1,475.00 for files 09WAP62 and 09WAP4.
Reference: 10 TAC §5.20 (c), ARRA Contract Section 13, Record
Keeping Requirements
City of Arlington must review the above noted client files, and complete
the required BWR certification of final inspection page. A copy of the
properly completed BWR certification of final inspection page must be
submitted with the response to this report. Failure to provide the BWR
celtification of final inspection page will result in disallowed costs. The
City of Arlington must also assure the Department in its response to this
repolt that better quality control measures will be implemented to prevent
future instances of BWR certification of final· inspection page forms not
being properly reviewed and/or completed. Reference: Contract Section
13, (B), (4)
Finding #7 09WAP22 received a 75,000 Btu Energy Star Furnace charged to the
Health and Safety line item. The pricing revealed in the Building
Weatherization Report was not the stated price as submitted in the Bid
Modification submitted by E3 Solutions. Material cost for the furnace is
shown at $2,425.00 with a labor cost of $2,075.00 on the complete
Building Weatherization Report. The current price, according to the
agreed Bid Modification is $2,250.00 for materials and $900.00 for the
associated labor.
Action
Required In order to ensure program compliance, the City of Arlington must request
immediate reimbursement from E3 Solutions for the difference in pricing
as stated in the Bid Modification in the amount of$1,350.00 ($175.00 for
.materials and $1,175.00 for labor). As part of the response to this report,
the City of Arlington must submit support documentation that outlines the
reimbursement to the City of Arlington from E3 Solutions. Reference:
10 TAC §5.10, 10 CFR 440.21
7
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CITY OF ARLINGTON
Program Officers Jason A. Seale and Walter Griner conducted an exit interview with the
following staff members from City of Arlington:
Mindy Cochran, Housing Operations Manager

Donna Wall, Weatherization Specialist
Amy Trevino, Financial Manager
Medria Browhow, Account Analyst
Juan Serrano, Project Coordinator
David Zappasodi, Executive Director
Brett Clark, Project Coordinator
Nicolette Arceneaux, Urban Development Specialist, LSO
Tahseen Khan, Rehabilitation Specialist
s~:=:.---..::::.---~ ~:04-C_'-'- - - -
Jason A. Seale
Energy Assistance Program Officer
Signature
Walter Griner Date
Energy Assistance Program Officer
8
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CITY OF ARLINGTON
ATTACHMENT A
Units Reviewed Comments

lO units reviewed lODOEARRA Returns noted below
Units
Fund Source Return Comments
Inspected
09WAP4 DOEARRA No No Return
09WAPlO2 DOEARRA Yes Return to adjust kitchen exterior door to close correctly.
Adjust water heater vent pipe. Block central heat source in
0
attic.
Texas Weatherization Field Guide Pg.68 2.4 Water-
Heating Measures Pg. 32 Texas Meehanical Systems
Field Guide 3.2 Venting Combustion Gases Pg.31
09WAP44 DOEARRA Yes Return to clean inside the return that was sealed upstairs
and downstairs. Install masonite siding on the west side up
by the roof.
09WAP78 DOEARRA Yes Return to repair the pressure and temperature relief valve
line.
Texas Weatherization Field Guide Water-Heating
Measures Pg. 32
09WAP24 DOEARRA Yes Return to seal five central registers correctly. Replace 4
defective bulbs.
Texas Weatherization Field Guide
09WAPlO DOEARRA Yes Return to address additional air infiltration in the back
dining room. Seal around the return and tighten register in
bathroom.
Texas Weatherization Field Guide Attic Ventilation Pg.
52
09WAP92 DOEARRA Yes Return to attach board behind washer to wall. Address
additional air infiltration by caulkiug all pipe penetrations
and around the French doors.
Texas Weatherization Field Guide Sealing major air
leaks and bypasses Pg. 43
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CITY OF ARLINGTON
09WAP62 DOEARRA Yes Return to add ventilation to attic. Address additional air
infiltration by caulking all pipe penetrations, by the beam
on ihe ceiling of the living room. Seal around the plenum in
the Ale closet.
Texas Weatherization Field Gutde Attic Ventilation Pg.
52 Sealing major air leaks and bypasses Pg. 43
09WAP53 DOEARRA No No return.
09WAP3 DOEARRA No No return.
Action Required: Retu1'll and address. Upon completion, verification of returns must be
submitted to the Department within thirty (30) days of this report.
10
www.tdhca.state.tx.us
R1ckPe,ry BOARD MEMBERS
GOVJ!JtNOR
C. Kent Conine, Chair
Gloria Ray, Vice Chair
Leslie Bingham EBcarefio
Michael Gerber Tom H, Gann
ExnCUTIVB DIRECTOR Lowell A. Kel8
Juan S. Mulioz, Ph,D.
June 28, 2010
Mr. Karl R. Rabago

VP for Distributed Energy Services
Austin Energy
721 Barton Springs Rd.
Austin, Texas 78704
Re: DOE/ARRA Weatherization Assistance Program Contract #16090000753
Dear Mr. Rabago:
Enclosed is II report that details the monitoring of the City of Austin (COA) Weatherization
Assistance Program contract with the Texas Department of Housing and Community Affairs
(The Department). This information is provided to ensure that compliance with the contract is
maintained and that services to the poor, elderly, and disabled are offered in the most expeditious
and economical manner.
The monitoring report includes four (4) findings resulting in questioned costs and one (I)
recommended improvement. Please submit a response to this report to this office within thirty
(30) days of the date ofthis letter.
If we can be of any assistance, please feel free to contact J.R. Mendoza, Senior Program Officer,
at (512) 936-7811. The assistance provided to the Program Officers by the agency is greatly
appreciated.
Sincerely,
-
Sharon D. Gamble
Manager
Cc: Mr. Marc A. Ott, City Manager
221 EAST liT" • 1'. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 525-0657 • (512) 475-3800
2009 WEATHERIZATION MONITORING REPORT
CITY OF AUSTIN
Section I. Financial RepOlting
Section VI. Audit
Section VII. Personnel Policies and Practices
,Section VIII. Perfolmance Review
Section IX. .Administration
Section X. Multifamily
PAGE 2 OF 7
CITY OF AUSTIN
Dates of Review: May 17-20,2010
Focus OF REVIEW

NUMBER AMOUNT
DOEARRA 16090000753 $5,964,892.00 9/1/2009 to 8/31/2011
PROGRAM EVALUATION
The May 17-20, 2010 on-site monitoring consisted of a review of the City of Austin (COA)
implementation of the Department of Energy's ARRA Weatherization Assistance Program.
Specific areas of review included Financial Reporting, Contract Agreements, Procurement,
Personnel, and the Management of the Department of Energy and Low Income Home Energy
Assistance Program contracts.
The evaluation of the program consisted of: interviews with the COA personnel, analysis of the
fiscal system, review of programmatic records, on-site inspections, client interviews, and
inventory review. This is the first year that COA has operated a Weatherization Program from
TDHCA. The process to obtain the weatherization contract was lengthy as there were protocols
that requited review by several City Departments and ultimately the City Council approval.
Shortly after the contract was approved and signed by the council, Austin Energy commenced
the procurement process to acquire sub contractors to complete unit assessments, final
inspections and to install the weatherization measures. This process was completed in March
2010 and contracts were approved in the subsequent month. At the time of monitoring, COA had
weatherized five (5) units, but had not reported them to the Department since the contractors had
not provided invoices; therefore no Building Weatherization Report had been completed. As a
result, there were no expenditures reported to the Department.
The following was noted dnring the review:
• Lack of production of weatherized units
• Lack of documentation of compliance with Weatherization Material Standards
• Work Orders did not detail where ail' infiltration measures were to be completed.
• Income documentation was missing on two of five client files
• Files contained excess forms
PAGE 3 OF 7
CITY OF AUSTIN
Section I. Financial Reporting

AMOUNT
DOEARRRA $0 0% 0 5
Finding #1: At the time of monitoring, COA had not reported any completed units. Whereas,
the contract period ends August 31, 2011, COA faces deobligation of funds if
minimum completion benchmarks are not met tln'oughout the program year. Two
benchmarks include COA reporting 100 (cumulative) completed units, at an
. average unit expenditure rate of $5,380.00, by June 30, 2010 and 371 (cumulative)
units by August 31, 2010. In addition, COA must have expended at least 20%
($538,000) of its original contract by June 30, 2010 and 35% ($1,995,980) by
August 31, 2010.
Action
Required: As part of the response to this report, COA must document a plan of action that
will detail how it will assure units will be weatherized and how it anticipates
meeting the production schedule that was submitted to the Department (June 10,
2010 production schedule). At a minimum, specifics of the plan of action should
include Outreach, Intake, Assessments, Contractors, Final Inspections; Financial
payments and Reporting. COA must understand that providing the required
response does not guarantee its DOE ARRA contracted funds will not be
deobligated.
Reference: DOE ARRA contract section 4
Finding #2: At the time of monitoring, COA did not have documentation that all
weatherization materials installed by its contractors met the minimum standards as
required by DOE. Failure to ensure each product meets DOE requirements may
result in questioned or disallowed costs.
Required
Action: A copy of data sheets for all material products used by each of contractor must be
maintained. In addition, each product must conform to the DOE minimum
standards. As part of the response to this report, COA must provide a copy of the
materials specifications· from each contractor. In addition COA must provide an
assurance that a file will be maintained to ensure all materials installed meet DOE
requirements.
Reference: DOE 10 CFR 440 Appendix A
PAGE40F7
CITY OF AUSTIN
Finding #3: A review of work orders for the weatherized units· revealed generic details on
which air infiltration measures should be taken. Having a generic work order may
lead to work that may not be required and may result in over expenditure of air
infiltration measure funds. A thorough unit assessment must detail what air
infiltration measures will be required. In turn, this detail will allow COA to
determine which measures are most cost effective and if the cost is over the
maximum allowable expenditure. Any costs over the maximum allowable
expenditure will be disallowed.
Required
Action: As part of the response to this report, COA must provide an assurance and detail
what steps will be taken to guarantee all future work orders will be detailed as to
the specific need for any weatherization measure.
Reference: DOE ARRA Contract Section 11
Finding #4: A review of five (5) client files revealed two (2) files mIssmg income
documentation for certain individuals within the household. Client file
EVILL4402 was missing income documentation for the wife and file LRIBB0408
had two (2) individuals within the household missing income documentation. All
encumbered weatherization expenses ($2,896.00) for these two units are
considered questioned until the income documentation is obtained.
Action
Required: As part of the response to this report, COA must obtain and provide the missing
income documentation for each file noted above. COA must also provide the
existing client income information on file and verify if the household is still
eligible to receive DOE ARRA weatherization services. COA must provide an
assurance on how it will ensure all weatherization client files will have income
documentation for each household member over eighteen (18) years of age.
Reference: DOE ARRA Contract Section 13
Recommended
Improvement: A review of the client files revealed excess documents in each file. COA had
copies of the Priority Rating Sheet Instructions and the Blower Door Standard
Instructions in each client file. Whereas these instructions are important to ensure
the priority rating sheet and the Blower Door Standard are followed correctly,
copies are not required to be in each file. It is recommended that each assessor,
final inspector and quality assurance staff member have a central file containing a
copy ofthese instructions.
PAGE 5 OF 7
CITY OF AUSTIN
Texas Department of Housing and Community Affairs representative, J.R. Mendoza participated
in an exit conference with Mr. Steven Saenz and Joseph Guerrero.
~F?'-- _ ~/Z8/ZCJID
Celedonio Mendoza Jr. Date
Seniol' Program Officer
PAGE60F7
CITY OF AUSTIN
ATTACHMENT A
JAMAD3409 ARRA Clean fan in the Central System'air handler
LRlBB0408 ARRA Insulate the attic hatch
SBR004905 ARRA No Return
EVILLA4402 ARRA No Return
PAGE70F7
www.tdhca.state.tx.1U
R1,kr.,ry BOARD MI!MimRS
GOVBRNOR C. Kent Conine, Ch"b'
Glor!ft Ray, Vice Chait,
Leslie BJngblllU Bscarefio
MIchael Gerber Tom H, Gann
ExECOTIVE DumCTOR Low.1I A.. K.lg
Juan S. Multoz. Ph.D.
June 7, 2010
Ms. Anna Simo

Executive Director
Bee Community Action Agency
POBox 1540
Beeville, TX 78104
Re: DOE Weatherization Assistance Prograin Contract # 56090000446

LIHEAP Weatherization Assistance Program Contract #81090000480
DOE/ARRA Weatherization Assistance Program Contract #16090000650
Dear Ms. Simo:
Enclosed is a report that details the monitoring and desk review of Bee Community Action Agency
Weatherization Assistance Program contracts with the Texas Department of Housing and Community
Affairs (The Department). This information is provided to ensure that compliance with the contracts is
maintained and that services to the poor, eldel'ly, and disabled are offered in the most expeditious and
economical manner.
The monitoring report includes fonr (5) findings, two (2) recommended improvements, and one (1) note.
Please submit a response to this report to this office within thirty (30) days of the date of this letter..
If we can be of any assistance, please feel fi'ee to contact Kevin Glienke, Program Officer, at (512) 475-
3852. The assistance provided to the Program Officers by the agency is greatly appreciated.
Sincerely,
Sharon Gamble
Program Manager
-
Cc: Randy Kopplin, Community Services Director

Reverend Bill Duke, BCAA Board Chair
221 EAST BTH • P. 0, Box 13941 • AUS'I'IN, TEXAS 78711-3941 • (800) 525·0657 • (512) 475·3800
BEE COMMUNITY ACTION AGENCY
Section 1. Financial Reporting
Section VI. Audit
Section VIII. Performance Review
Section IX. Administration
Section X. Multifamily
PAGE20F7
2009 WEA1'HERIZATJON MONITORING REPORT
BEE COMMUNITY ACT JON AGENCY
Dates of Review: May 3 - May 7, 2010
Focus OF REVIEW

NUMBER AMOUNT
DOE 56090000446 $131,208,00 4/1/2009 to 3/31/2010
LIHEAP 81090000480 $134,768,00 4/1/2009 to 3/31/20 I0
DOE/ARRA 16090000650 $568,597,00 9/1/2009 to 8/31/2011
On-site review of Bee Community Action Agency (BCAA) implementation of the Department of
Energy's and Low Income Home Energy Assistance Program's Weatherization Assistance
Program (WAP). Specific areas of review included Financial Reporting, Contract Agreements,
Procurement, Personnel, and the Management of the Department of Energy and Low Income
Home Energy Assistance Program contracts.
PROGRAM EVALUATION
The evaluation of the program consisted of: interviews with the BCAA personnel, analysis of the
inventory review.

. .
• DOE and LIHEAP administrative expenditures were high.
• Contractor contracts lacked the "Rights to Inventions Made Under a Contract 01'
Agreement" clause,
• Subcontractor workmanship deficiencies on foul' (4) client units inspected
• Questioned costs for energy audits in client files reviewed
• Incorrect income verification for one (1) client file
PAGE30F7
2009 WEATHERIZATION MONITORING REPORT.
Section I. Financial Reporting
Recommended Improvemcnt #1: At the time of monitoring, BCAA had DOE administrative
expenditures of 6.07 percent and LIHEAP administrative expenditures of 9.84 percent. BCAA is
reminded that DOE administrative expenditures must be at 5.0 percent and LIHEAP
administrative expenditures must be at 7.22 percent by the end of the contract period.
Reference: DOE lind LIHEAP Contract Attachment A
Finding #1: As of the February 2010 monthly expenditure reports. BCCA had
expended 2.5% of ARRA WAP Contract #16090000650. The ARRA
WAP Contract requires the development and implementation of equitable
WAP setvices thtoughout the eome setvice area.
Action Reqnlred: The Depmtment requires BCCA to submit a detailed plan of action to
include increased production and adherence to the DOE Production
Schedule in the response to this report. Failure to submit a plan to the
Depmtment may result in suspension of ARRA WAP contl'llcts.
Reference: ARRA Contract Section 4
Finding #2: A review of BCANs procurement contracts revealed the lack of the
provision for "Rights to Inventions Made Under a Contract or Agreement"
clause within the subcontractor contracts,
Action Required: BCAA must amend their current subcontractor contacts to provide for the
inclusion of the above mentioned contract clause.
Reference: OMB A·1l0 Appendix A

Note #1: At the time of monitoring, BCAA had not serviced Refugio county with their DOE or
LIHEAP contracts. The Department recognizes that BCAA was servicing Refugio cOlUlty with
DOE/ARRA funds.
Recommended Improveme"t #2: At the time of monitoring, BCAA did not have material
specifications for all materials installed readily available. Upon further review, it was found that
materials being installed were acceptable. BCAA is reminded that any materials that do not meet
the DOE specifications are subject to disallowed costs, BCAA is reminded that evidence of
material specifications m'e needed for all weatherization materials installed, including, but not
limited to: insulation (attic, walls, floor), replacement windows, storm windows, replacement
doors, caulking(sealants/glazing, weather-stripping, electric and gas furnaces, electric and gas
water heaters, air conditioners, window screens, and refrigel'lltors.
Reference: 10 CFR 440 Attachment A Material Specifications
PAGE40F7
Finding #3: Onsite home inspection of weatherized units revealed that foul' (4) of the
ten (10) units inspected would require a retuI'D to address deficiencies in
subcontractor workmanship.
Action Required: BCAA must retuI'D to the client units listed in Attachment A, and address
the deficiencies noted on each unit. BCAA must also assure the
.Depaliment in its response to this report that proactive measures will be
taken to prevent future instances of poor workmanship from its
subcontractors and ensure that the quality of work that is being performed
meets BCAA's requirements, and the Department's expectations.
Reference: 10 CFR Part 440; §440.16 (g)
Finding #4: $73,056.78 Questioned Costs on energy audits reviewed during

monitoring visit.
(A) $49,001.35 questioned costs: review of NEAT energy audits in
client files revealed that weatherization measures were being
inst!llled despite the savings-to-investment ratio (SIR) being below
the required minimum value of 1.0. Additional measures were also
being installed in homes with the household's cumulative SIR
below the required minimum value of 1.0.
a. Client 9B-006 - questioned cost $8,462.14
b. Client 9B-007 - questioned cost $8,861.51
c. Client 9B-OIO - questioned cost $9,006.46
d. Client 9R-DA-002 - questioned cost $4,489.52
e. Client 9R·DA-005 - questioned cost $4,490.51
f. Client 9R·DA·006 - questioned cost $4,096.96
g. Client 9R·DA·007 - questioned cost $5,364.07
h. Client 9R·DA-008 - questioned cost $4,230.18
(B) $24,055.43 questioned costs: review of the EZ3 energy audits
revealed deficiencies in every audit. There were substantial
differences between the amount of money estimated for the
household from the audit and the actual amount of money spent on
the household. The measures listed in the audit were installed, but
the additional measures and costs installed in the home were not
supported by the audit. The questioned costs listed below represent
the difference between the total audit price and the total amount
spent on the household.
a. Client 9B-00 I - questioned cost $905.40
b. Client 9B-004 - questioned cost $2,548.56
c. Client 9LO-001 - questioned cost $2,008.22
d. Client 9LO·002 - questioned cost $13,846.78
e. Client 9M-00I - questioned cost $4,746.47
Action Required:· As part of the response to this report, BCAA must return to the energy
audits for the files inspected, and run the audits properly, with all the
PAGE 5 OF 7
information and measures listed. Copies of these audits must be provided

to the Department in the response to this report. Any measures installed in
homes that do not rank on properly run audits are subject to disallowed
.costs. BCAA must also assure the Department that proper procedures are
followed to ensure the proper inputting of information into the Energy
Audit system. Reference: ARRA Contr!lCt Section 11 (B); DOE and
LIHEAP Contract Section 9 (B); 10 CFR 440; §440.21 (d)
Section X: Client File Review

Finding #5: A review of BCAA client files revealed insufficient income
documentation in file 9R-DA-007.
Action Required: BCAA must submit to the Department sufficient income documentation
for the above mentioned file to complete the income documentation for
the household. Reference: Texas Administrative Code; Title 10; Part 1;
Chapter 5; Subchapter E; Rule §5.507 (d)(t)
Texas Department of Housing and Community Affairs representative, Kevin Glienke,

participated in an exit conference with Bee Community Action Agency representatives Ms. Anna
Simo, Ms. Julie Hernandez, and Mr. Randy Kopplin.
Signature: •
t:1f .' (J
'~ j ~ "'/"///1)
KevinGlienke,HJHt;A Proll.ram Officer Date:
PAGE 6 OF 7
ATTACHMENT A
Units
Inspected
9RDA002 ARRA Yes Return to completely seal AC supply plenum.

**Deficiency addressed while still on monitoring visit
9LO-001 DOE/LIHEAP Yes Return to re-align vent pipe for domestic water heater
and install missing CO detector.
9B·007 DOE/LIHEAP Yes Return to address home below BTL with mechanical
ventilation.
9B·010 DOE/LIHEAP Yes Return to address home below BTL with mechanical
ventilation.
Bee Community Action Agency must return and address all units as indicated and include in it"s
response to this repOlt a summary of all actions and measures taken to address the units indicated
above.
PAGB70F7
WWlu,tdhca.state,tx.us
Rick Perry BOAI\D MBMBBRS
GOVERNOR C. Kent Conlne , CIJ"Jp·
Gloria Ray, Vice Gllah'
Leslie Bln·gham Escarefio
Michael Gerber Tom H, Gann
ExncUTrVll DIRECTOR Lowell A, Kcig
Juan S. MUtiO?:1 Ph.D.
July 16,2010
Ms. Emma Vasquez

Executive Director
Big Bend Community Action Committee, Inc.
200 West San Antonio St.
Marfa Texas 79843
Re: Monitoring Report for Weatherization Contracts

DOE Weatherization Assistance Program Contract #56090000448
LIHEAP Weatherizatio.n Assistance Program Contract #81090000481
DOE AREA Weatherization Assistance Program Contract #16090000651
Dear Ms. Vasquez:
Enclosed is a report that details the monitoring review of Big Bend Community Action Committee,
Inc., (BBCAC) Weatherization Assistance Program contracts with the Texas Department of
Housing and Community Affairs (The Department). This information is provided to ensure that
compliance with the contracts is maintained and that services to the poor, elderly, and disabled are
offered in the most expeditious and economical mauner.
The monitoring report includes five (5) findings, five (5) recommended improvements and three
(3) notes. Please submit a response to this repOit to this office within thirty (30) days of the date of
this letter.
If we can be of any assistance, please feel free to contact Enrique H. Trejo, Program Offiqer, at
(512) 475·2299. The assistance provided to the Program Officer by the agency is greatly
appreciated.
Sincerely,
7}J-
Sharon D. Gamble
Manager
cc: Johnny Calderon, Board Chair
221 EAST liTH. P. O. Box 13941 • AUSTIN, TBxAS 78711-3941 • (800) 525-0657 • (512) 475-3800
.Section IV. Property Management
Section VI. Audit
Section X. Client File Review Worksheet
Section XI. Multi-Family Review
Section XII. Denied Files
Section XIII. Summary

OF
BIG BEND COMMUNITY ACTION COMMITTEE, INC.
Dates of Review: April 26 - 30, 2010
Foeus of Review
CONTRACT CONTRACT CONTRACT

CONTRACT NAME
NUMBER AMOUNT DATES
DOE 56090000448 *$256,429,00 4/1/09 to 3/31/10
LIHEAP 81090000485 *$299,638,00 4/1/09 to 3/31110
DOEARRA 16090000651 **$1,188,461.00 9/1/09 to 8/31/11
• Latest contract amendments •• 50% of proposed total allocation
TDHCA staff conducted an on-site review of the Big Bend Community Action Committee,\ Inc.,
(BBCAC) implementation of the Department of Energy and the Low Income Home Energy
Assistance Program Weatherization Assistance Programs (WAP). Specific areas of review
included Financial Reporting, Contract Agreements, Procurement, Personnel, and the
Management of the Department of Energy and Low Income Home Energy Assistance Program
contracts.
Program Evaluation
The evaluation of the program consisted of: interviews with BBCAC personnel; analysis of the
fiscal system; review of programmatic records; on-site inspections; client interviews; and
inventory review,
• High Administrative and Health Safety Expenditures

• Lack of a Contl'act Provision to Prevent and Correct Waste, Fraud and Abuse
• Lack of a Written Policy on Client Education
• On-Site Inspections Requiring Returns
• Lack of Weatherization Measures - Not Insulating Walls
• Lack of Weatherization Measures - Not Installing CFLs
• Inadequate Record Keeping in Client Files
• Development of a Quality Assurance Plan
Page 2 of9
OF
SECTION I. FINANCIAL REVIEW
EXPENDITURES AS OF THE TIME OF MONITORING
CONTRACT YEAR-TO-DATE %OFAMENDED #UNlTS # UNITS IN

NAME . EXPENDITURES CONTRACT COMPLETED PROGRESS
AMOUNT
*OOE $169,038.46 65,92% 36 0
..
*LIHEAP $220,474.89 73.58% 45 0
*DOEARRA $126,553.12 10,65% 21 4
*Expendltul'es as of March 2010
Recommended Improvement #1: At the time of monitoring, BBCAC's Administrative

expenditure ratio was above the maximum allowable of 5.0% for DOE Contract #56090000448.
The Administrative expenditure ratio was 9.88% for DOE. The Department reminds BBCAC's
that the Administrative expenditure ratio must be at 01' below the maximum allowed percentage
by the end of the cOntract period. Expenditures above the allowable percentage will be
disallowed. See DOE ARRA Contract Attachment A,
Recommended Improvement #2: At the time of monitoring, BBCAC's Health and Safety
expenditure ratio was above the maximum allowable of 20,0% for LIHEAP Contract
#81090000485. The Administrative expenditure ratio was 23.8% for LIHEAP. The Department
reminds BBCAC's that the Health and Safety expenditure ratio must be at 01' below the
maximum allowed percentage by the end of the contract period. Expenditures above the
allowable percentage will be disallowed. See DOE ARRA Contract Attachment A.
Note #1: The March closeout Expenditures Report for DOE WAP has an Administrative
expenditure ratio of 9,88%. The March closeout Expenditure Report for LIHEAP WAP has a
Health and Safety expenditure ratio of 23.67%. The Department will send a separate letter
indicating the amount that BBCAC must reimburse TDHCA.
SECTION II. TRAVEL AND TIMESHEETS
Note #2: At the request of BBCAC. the Program Officer provided a model time sheet used by
other community action agencies,
Page 3 of9
OF
SECTION IV. PROPERTY MANAGEMENT
Recommended Improvement #3: BBCAC uses vehicles from the Transportation Division to
assess and inspect units in the service area. The vehicles BBCAC uses are not always available
nor are they practical for the Weatherization Assistance Program. It is highly recommended that
BBCAC purchase a vehicle for each Weatherization Assessor.
SECTION VII. PERSONNEL POLICIES AND PRACTICES
Finding #1: Lack of Contract Provision to Prevent and COl'I'ect Waste. Fraud and
Abuse
BBCAC lacks a required provision in the Personnel Policies manual. The
Personal Policies manual lacks a provision to establish, maintain, and utilize
internal control systems and procedures sufficient to prevent, detect, and
correct incidents of waste, fraud and abuse. BBCAC is not in compliance
with applicable regulations.
Action Required: BBCAC must amend the Personal Policies manual by establishing intel'llai
control systems sufficient to prevent, detect, and correct incidents of waste,
fraud and abuse. Specifically, include a statement in Chapter 14 Employee
Conduct that it is the responsibility of each employee to prevent and correct
incidents of waste, fraud and abuse. BBCAC must submit a revised Personal
Policies manual with the required provision as part of the response to the
monitoring report.
Reference: DOE ARRA Contract Section 26 Prevention of Fraud &
Abuse, DOE & LIHEAP Contracts Section 22 Prevention of Fraud &
Abuse
SECTION VIII. PERFORMANCE REVIEW
Recommended Improvement "4: BBCAC provides client education in the form of printed
energy conservation tips that are discussed with individual clients. It is highly recommended
that BBCAC develop a written policy on client education. The policy will include identifying
the documents to be used and when conservation and/or energy tips are discussed with clients.
Page 4 of9
OF
Recommended Imllrovement #5: The Program Officer recommends that BBCAC develop a
policy/procedure to verify compliance with the EPA Lead Renovator Rule. The policy should
include how, when and how often subcontractors will be inspected. Contractors performing
weatherization work must be certified and follow specific work practices to prevent lead
contamination. Failure to follow EPA Lead Renovator Rule guidelines may result in fines up to
$37,500.00 for each violation. The EPA Lead Renovator Rule went into effect on Allril22, 2010.
Finding #2: On-Site Inspections Requiring Returns

Program Officer inspected foul' (4) DOE ARRA units on April 28, 2010 and
five (5) DOE ARRA units on April 29, 2010. Department on-site
inspections of weatherized units require foUl' (4) returns out of the nine (9)
units inspected. Returns are necessary to address the insufficient installation
of weatherization measures and/or the lack of weatherization measures.
Action Required: BBCAC. must establish a Quality Assurance Plan that includes assurance
that subcontractors will install weatherization measures to Department of
Energy, International Residential Code and Texas Department of Housing
and Community Affairs standards. Please provide the Quality Assurance
Plan as part of the response to the monitoring report. Specifically,BBCAC
must correct the following issues and provide documentation that the issues
were resolved:
a. 09Martl 021: Conduct additional air sealing around a leaky window in

the kitchen. Provide a blower door reading as part of the response to
this monitoring report.
b. 09Hern304: Weatherstrip a closet door that leads to room that is open

to the attic. Conduct additional ail' sealing in the hallway and kitchen.
Provide a blower door reading as part of the response to this
monitoring report.
c., 09Silv1202: Mising CO readings for combustion appliances. Return

to take CO readings.
d. 09Espu308: There is R-II batts in some portions of the attic while

other areas have no insulation. Install R-30 insulation in the attic,
Reference: DOE ARRA, DOE and LIHEAP Contracts and 10 CFR 440
Final Rule
Page 5 of9
OF
Finding #3: Lack of Weatherization Measures - Not Insulating Walls

Department review of client files and on-site inspection of weatherized units
indicate a lack of certain weatherization measures. Weatherized units are not
receiving wall insulation. The main contractor for weatherization services,
D.W. Construction professes an inability to install wall insulation. A lack of
wall insulation creates a weakness in the thermal boundary that moderates
temperature differences between the inside and outside of a house resulting
in energy waste due to excessive heating and cooling usage.
Action Required: BBCAC must ensure that clients in need of wall insulation will be provided
that weatherization measure. One option available to BBCAC is to procure
for an insulation provider that can install wall insulation. Another option is
to ensure that D.W. Construction receives training in installing wall
insulation. BBCAC must provide a plan of action to address the avoidance
of insulating walls as part of the response to this monitoring report.
Reference: DOE ARRA Contract Section 11: Allowable Expenditures
and DOE and LIHEAP Contracts Section 9: Allowable Expenditures
Finding #4: Lack of Weatherization Measures- Not Installing CFLs

Department review of client files and on-site inspection of weatherized units
indicate a lack of certain weatherization measures. Weatherized units are not
receiving compact fluorescent light bulbs as a base load measure. Compact
fluorescent light bulbs are not being installed due to a lack of understanding
that CFLs are an acceptable weatherization measure. Compact fluorescent
light bulbs use 70% less energy than standard incandescent light bulbs
resulting in less energy usage for lighting.
Action Required: As part of a whole house assessment, BBCAC must make CFLs available as
a base load measure to reduce energy consumption. BBCAC must develop
criteria to determine how many CFLs could be replaced in a home when
using the EZ Audit and/or Priority List. The NEAT and MHEA has an
assessment tool for recommending CFLs. Piease provide the criteria for
selecting CFLs as part of the response to the monitoring report.
Reference: DOE ARRA Contract Section 11: Allowable Expenditures
and DOE and LIHEAP Contracts Section 9: Allowable Expenditures
Page6of9
OF
BIG BEND COMMUNITY ACTION COMMITTEE, INC,
Finding #5: Inadequate Record Keeping in Client Flies

Department review of client files indicates inadequate record keeping.
Examples of inadequate record keeping include incomplete and missing
Blower Door Forms; incomplete and missing Refl'igerator Forms· and
incomplete Attic and Wall Inspection Forms, Inadequate record keeping
may lead to questioned costs and poor program performance, Subrecipients
are required to have all necessary assessment forms indicated in the WAP
contracts. In addition, subrecipients are expected to completely fill out all
assessment forms. .
Action Required: BBCCA must provide wl'itten assurance that client files will have the
required assessments forms that are completely fill out. In addition,
BBCAC must provide a Quality Assurance Plan that includes a policy 01' a
protocol for client file review.
Reference: DOE ARRA Contract Section 13: Record Keeping
Requirements and DOE and LIREAP Contl'acts Section II: record
Keeping Requirements
Note #3: A Quality Assurance Plan is a set of internal policies and pl'Ocedures to assure
compliance with Weatherization Assistance Program Contracts, the Texas Administrative Code
and the International Residential Code, Specifically, the Quality Assurance Plan includes a
written policy or standard opel'llting protocol for I) Unit Assessment; 2) Energy Audits; 3) Final
Inspections; 4) Client File review; 4) compliance with Interagency Agreement regarding historic
properties; and 5) compliance with EPA Lead Renovator Rule.
Page 7 of9
OF
Texas Department of Housing and Community Affairs representative, Enrique H. Trejo, Program
Officer patticipated in an Exit Conference with Emma Vasquez, Executive Director; Lucy
Polanco, Bookkeeper II; Katie Sanchez, Bookkeeper; and William Gonzales, Assistant
Weatherization Director and Labor Standards Officer.
Signature:
() 7)??/~()/O
Date
Page 8of9
OF
ATTACHMENT A
Units
Inspected
09Esto416 ARRA No Installed CO and smoke detector; 8 windows; 2 space heaters and one
room air conditioner. Caulking and weatherstripping was ptovided.
Installed CO and smoke detector. Installed R-19 insulation. Replaced

09Martl021 ARRA Yes domestic water heater. Leaky window around a toom air conditioner in
the kitchen. Return to conduct air sealing around room air conditioner.
No Blower Door Form.
09Silv1202 ARRA Yes Installed CO and smoke detector; R-30 attic; and a new refrigerator.
Caulking provided. Missing CO readings.
09Hern304 ARRA& Installed CO and smoke detector; refrigerator; and domestic water heater.
LIHEAP Yes Vented primary space heater. Blower door 3.520 CFM. Return for more
alr sealing.
09Ramil02 ARRA No Installed CO and smoke detector; R-19 insulation; solar screens; and new
refrigerator. Fixed two window panes.
09Espu308 ARRA Yes Installed CO and smoke detector; 123 VI windows; and solar 'creens.
Caulking and weatherstripping provided. Some R-ll in the attic but not
completely covercd. Return to en'ure R-30 installed in the attic.
09Rive305 ARRA No Installed CO and smoke detecto1'j gas range; R-19 attic insulation) solar
screens; and a new refrigerator. Caulking was provided.
09Vasq304 ARRA No Installed CO and smoke detector; R-19 attic insulation; solar screens; and
room air conditioner. Caulking and weatherstripping was provided.
09Corrl0l ARRA No Installed CO and smoke detcctor; gas stove; R-30 atlic insulation; solar
scteens: new teftigeratof; and room air conditionet. Caulking and
weatherstripping wa, provided.
Page 9 of9
www.tdhca.state.1X,tls
Rick Perty BOARD MSMBBRS
GOVBRNOR C. Kent Conine, Clu#r
Gloria Ray, Vic, ChflJr
Leslie Bingham Ellcaref\o
Michael Gerber Tom H. Gann
ExEClITlVE DJRECI'OR Lowen A. Kelg
June 7, 2010
Ms. Karen Garber

Executive Director
Brazos Valley Community Action Agency
1500 University Drive E, Suite 100
College Station, Texas 77840
Re: DOE Weatherization Assistance Program Contract #56090000449

ARRA Weatherization Assistance Program Contract #16090000652
ARRA Weatherization Assistance Program Contract #16090000780
Dear Ms. Garber:
Program contracts with the Texas Department of Housing and Community Affairs. This
information is provided to ensure that compliance with the contract(s) is maintained and that
manner.
The Department has identified four (4) findings and three (3) recommendations for the
Weatherization Assistance Program. Please submit a response to this report to this office within
thitty (30) days of the date of this letter.
If we can be of any assistance, please contact Jason A. Seale, Program Officer, at (512) 463-
0172. The assistance provided to the Program Officer by Community Action Program, Inc. is
greatly appreciated. '
Sincerely,
~O-'
Sharon Gamble
Manager
221 EAST nTH • P. O. Box 13941 • AUSTIN, TEXAS 78711-3941 • (800) 5:.15-0657 • (512) 475-3800
() I'rlll1,;/ 6/1 ruyd,d lapu
Section VI. Audit
Section VII. Personnel Policies and Procedures
Section VIII. Performance Review/Onsite Inspections
Section X. Client File/Multifamily Review
2
OF
BRAZOS VALLEY COMMUNITY ACTION AGENCY
Dates of Review: March 22, 2010 - March 26, 2010
Focus of Review

NUMBER AMOUNT
DOE 56090000449 $623,604.00 4/1/2009 to 3/31/2010
LIHEAP 81090000482 $783,072.00 4/1/2009 to 3/31/2010

.
ARRA 16090000652 $3,006,045.00 911/2009 to 8131/2011
ARRA - City of Huntsville 16090000780 $250,000.00 9/1/2009 to 8/31/2011
On-site review of the Brazos Valley Community Action Agency (BVCAA) implementation of
the Department of Energy, Low Income Home Energy Assistance Program and American
Recovery and Reinvestment Act of 2009 Weatherization Assistance Program (WAP).· Specific
areas of review included Financial Reporting, Contract Agreements, Procurement, Personnel and
the Management of the Department of Energy, Low Income Home Energy Assistance Program
and American Recovery and Reinvestment Act of 2009 contracts.
Program Evaluation
The evaluation of the program consisted of: Interviews with the BVCAA personnel, analysis of
the fiscal system, review of programmatic records, on-site inspections, client file reviews and
inventory review.
• Low expenditures for ARRA contracts

• Late Submittal of DOE, LIHEAP and ARRA Expenditure Reports
• Lack of Documentation for Lead Safe Work Practices
• Incomplete Energy Audits
• Incorpplete Blower Door Data Sheets
• Incomplete Wall Inspection Forms
• Incomplete Rental Homeowner Agreement
3
OF

EXPENDITURES AS OF FEBRUARY 2010

AMOUNT
DOE $481,639.56 77.23% 84 8
LIHEAP $413,061.57 52.75% 83 32
ARRA $17,535.72 .58% 3 32
ARRA- $5,118.12 2.05% 1 5

Huntsville
Recommended Improvement #1 Review of client file data showed adequate support

documentation in relation to current contractor pricing and submitted invoices. However, some
ofBVCAA's contractors are providing invoices that detail a flat fee for services rendered instead
of a pricing allocation for material and labor costs. Throughout the client file review process, it
was unclear per the Building Weatherization Repolt which costs were being allocated and
ieveraged to the appropriate weatherization program. The Department recommends that
BVCAA's current contractors implement an invoicing system with material and labor pricing
breakdown in order to better distinguish how costs are being allocated and charged to the various
weatherization contracts.
Recommended Improvement #2 Review of the Febl'Uary 2010 expenditure reports for DOE,
DOE ARRA and LIHEAP contracts revealed Administrative expenditures were above the
maximum allowable of 5%. Current Administrative expenditures for the DOE contract are
6.46%. Current Administrative expenditures for the DOE ARRA contract are 21.26%. Current
Administrative expenditures for the LIHEAP contract are 13.33%. The Department reminds
BVCAA that Administrative expenditures are required to be below the maximum allowable by
contract end. Any costs above the maximum allowable will be subject to disallowed cost.
4
OF
Finding #1 As of the February 2010 monthly expenditure reports, BVCAA had

expended .58% Of ARRA WAP Contract #16090000652 and 2.05% of
ARRA WAP Contract #16090000780. The ARRA WAP Contract
requires the development and implementation of equitable WAP services
throughout the entire service area.
Action
Required The Department requires BVCAA to submit a detailed plan of action to
include increased production and adherence to the DOE Production
Schedule in the response to this report. Failure to submit a plan to the
Department may result in suspension of ARRA WAP contracts.
Reference: ARRA Contract Section 4
Findiog#2 At the time of monitoring, BVCAA was responsible for submitting DOE,
LIHEAP and ARRA expenditure reports late for PY09. DOE and
LIHEAP expenditure reports for July 2009 were submitted past the
contract deadline. ARRA expenditure reports for December 2009 and
January 20 I0 were submitted past the contract deadline.
Action
Required The Department reminds BVCAA that DOE and LIHEAP programmatic
and expenditure reports are to be submitted to the Department no later
than fifteen (15) days after the end of each month of the Contract term,
ARRA programmatic and expenditure reports are to be submitted to the
Depaltment no later than five (5) days after the end of each month of the
Contract term. Reference: DOE Contract Section 11 (A), LIREAP
Contract Section 11 (A)
Section VIII. Onsite Inspections

Finding #3 On-site unit inspections revealed a documentation deficiency in minimum
standards for Lead Safe Work Practices as outlined by DOE. Review of
client file documentation affirmed the potential of lead hazards in pre-
1978 units that were recipients of weatherization services provided by
BVCAA.
Action
Required BVCAA is reminded of EPA's LRRPP (Lead; Renovation, Repair and
Painting Program) Final Rule effective April 22, 2010, The listed
reference will provide Minimum Standards for LSW, found in WPN 08-6,
Attachment A. Failure to follow EPA guidelines for LSW could result in
fines administered by the EPA as well as disallowed costs administered by
the Depaltment. Reference: WPN 08-6, WPN 08-6, Attachment A -
Minimum Standards for LSW
5
OF
Section X. Client File/Multifamily Review
Recommended Improvement #3 The cul':t:ent unit assessment form being utilized by BVCAA
lacks substantial information in regards to the whole house approach. By not having a detailed
and organized unit assessment form for BVCAA staff to conduct a thorough assessment, the
client could potentially not benefit from substantial energy-efficient measures. A unit
assessment template will be provided to BVCAA weatherization staff in order to provide an
adequate document to conduct a detailed unit assessment.
Finding #4 At the time of monitoring, a review of PY09 WAP client files noted five
(5) deficiencies. One (1) client file oontained an incomplete blower door
data sheet, one (I) client file contained an incomplete Wall Inspection
Form, two (2) client files contained inoomplete energy audits and one (I)
client file oontained an incomplete Rental Homeowner Agreement.
Action
Required BVCAA is reminded that all client files must contain, at minimum, the
list of record-keeping requirements found in all WAP contracts. BVCAA
must also develop procedures for quality assurance to ensure adequate
support dooumentation is retained in all client files. These prooedures
must be submitted in the response to this report. Reference: ARRA
Contract Section 13, DOE Contract Section 10, LIHEAP Contract
Section 10.
Signature
Jason A. Seale
Program Officer
6Mb
Date'
Energy Assistanoe
6
OF
ATTACHMENT A
Units Reviewed Comments

9 units reviewed 7 DOE/LIHEAP, 2 ARRA/LIHEAP - Returns noted below
Client Return(s) To Address

NMC3003 Return to address TPV discharge pipe on hot
water heater.
THE7006 Return to address incomplete weather-
stripping at attic access.
CBE401 Return to address weather-stripping at attic
access.
MMI5418 Return to address collar installation at ceiling
penetration for hot water heater.
Return to address weather-stripping at attic
access.
DNEIIOO Return to address collar replacement at
ceiling penetration for hot water heater.
Return to address window infiltration measures
on Wall 2 and Room 5 (see client energy audit
diagram)
ER01703 Return to address weather-stripping at attic
access.
Return to damn and block 2 sides of exposed
attic access. Also install batt insulation on
top of attic access.
Action Required: Return and address. Upon completion, verification of returns must be
submitted to the Department within thirty (30) days of this repOli.
7
www.tdhca,state.ex.ul
1Uck Perry BOARD MEMBERS
GOVERNOR C. Kent Conine, Chair
Gloria Ray, Vict' CIJair
Le8lie Bingham Escarefio
ExecuTIVB DIRECTOR Lowell A. Keig
July 19,2010
Ms. Karen Garber

Executive Director
1500 University Dr, E, Ste 100
College Station, TX 77840
Re: DOE/ARRA Weatherization Assistance Program Contract #16090000652
Deal' Ms. Garber:
Enclosed is a report that details the unit inspection review of Brazos Valley Community Action Agency
(BVCAA) Weatherization Assistance Program contracts with the Texas Department of Housing and
Community Affairs (the Department), This information is provided to ensure that compliance with the
contracts is maintained and that services to the poor, elderly, and disabled are offered in the most
expeditious and economical manner.
The repOlt includes three (3) fillllillgs. Please submit a response to this repOlt to this office within thirty
(30) days ofthe date of this letter.
Ifwe can be of any assistance, please feel free to contact Jason A. Seale, Program Officer, at (512) 463·
0172. The assistance provided to the Program Officer by BVCAA is greatly appreciated.
Sincerely,
Sharon Gamble
Manager
--
Cc: Bryan Jones; Housing Coordinator
2il EAST IP" • p, O. Box 13941 • AUSTIN, TnXAs 78711·3941 • (800) 525-0657 • (512) 475-3800
() Prlllltd "" Nt/elrd pllp"
PY09 ARRA WAP Unit Inspection Report
WEATHERIZATION ASSISTANCE PROGRAM (WAP)

CORRECTIVE ACTIONS REQUIRED
Dates of Review: June 17-18, 2010
Focus OF REVIEW
CONTRACT NAME CONTRACT. CONTRACT CONTRACT DATES

NUMBER AMOUNT
DOE/ARRA 16090000652 $4,889,348.00 9/1/2009 to 8/31/2011
PROGRAM EVAIJUATION
The evaluation of the program consisted of twenty-four (24) client file reviews, twenty-four (24)
on-site inspections (Willow Oaks Apartments), interviews with clients, and analysis of both
quality of subcontractor workmanship and final inspection techniques.

• Incomplete BWR documentation for twenty-four (24) client files.
• No Attic Inspection Form for twenty-four (24) client files.
• No Wall Inspection Form for twenty-four (24) client files.
• No Whole House Assessment completed for all twenty-four (24) units inspected.
• Incomplete HVAC Assessment for all twenty-four (24) units inspected.
• Subcontractor workmanship deficiencies on all twenty-four (24) units inspected.
• No billing history in three (3) client files.
I
Client File Review
Finding #1: Inadequate Client File Documentation A review of BVCAA client files
revealed a lack of required client file documentation. Of the twenty-four
(24) client files reviewed, none contained a Wall Inspection Form or Attic
Inspection Form. All twenty-four (24) flies contained an incomplete
Building Weatherization Report (BWR), due to the final certification form
not filled out completely. Three (3) of the twenty-four (24) files were
missing the consumer billing history
Action
Required: The Department reminds BVCAA that all WAP client flies must adhere to
the minimum record keeping requirements as defined by the ARRA
contracts. In order to maintain compliance with WAP regulations, the
Department is requiring BVCAA to submit a Quality Control Procedure as
part of the monitoring response. These procedures should entail, at a
minimum, the necessary steps taken by BVCAA to ensure the record
keeping requirements are adhered to. Reference: ARRA Contract
Section 13
Performance Review
Finding #2: Whole House Asessments During the client file review process, it was
noted that, in addition to the deficiencies noted in Finding #1 that a whole
house assessment was not conducted' on any unit in the multifamily
complex. By not completing an assessment, all clients were unable to
receive the maximum benefit allowed under the WAP. In addition, it was
noted that an incomplete HVAC assessment was utilized to justify
replacement of all twenty-four (24) central systems in the multifamily
complex. By not completing an HVAC assessment, an accurate and
complete list of weatherization measures to be installed into each unit was
unattainable. Proper documentation was not on file to support
replacement of all twenty-foul' (24) central systems. Therefore, the
Department is questioning costs for all twenty-four (24) systems in the
amount of $91,920.00.
Action
Required: Prior to completing the returns noted in Attachment A of this report,
BVCAA must return to each unit and complete a whole house assessment.
This assessment should include items that were not addressed and could
potentially provide a greater amount of savings and benefit for the client.
Upon completion of all assessments, BVCAA must submit to the
Department all assessments for review before being allowed to conduct a
new audit on each unit. A plan of action to ensure that all future WAP
2
clients of BVCAA receive a complete and accurate HVAC assessment to
justify proper sizing and specifications of all replaced systems is required
in the response to this report. Reference: TAC §5.529, 10 CFR §440.21
Finding #3: On-Site inspections On-site inspection of weatherized units revealed that
all twenty-four (24) of the units inspected would require a return "to
address deficiencies in subcontractor workmanship. Deficiencies include,
but are not limited to, additional patching/sealing to furnace closets,
sealing plumbing penetrations under kitchen and bathroom sinks,
adjustment or replacement of weatherstripping on front door entrances and
attic access insulation and weatherstripping.
Action Required: BVCAA must return to the client units listed in Attachment A, and
address the deficiencies noted on each unit. BVCAA must also assure the
Department in its response to this report that proactive measures will be
taken to prevent future instances of poor workmanship from its
subcontractors. Those measures at a minimum should include periodic
visits to client units while work is in progress, to ensure that the quality of
work that is being performed meets BVCAA's requirements, and the
Department's expectations. The Department will also require BVCAA to
submit a Quality Control Procedure to ensure compliance with WAP
regulatio1;ls. These procedures should entail, at a minimum, the necessary
steps taken by BVCAA to ensure all weatherization measures completed
on the eligible unit are verified at the time of final inspection. Reference:
10 CFR Part 440; §440.16 (g)
Jason A. Seale Date

Program Officer, Energy Assistance Section
3
ATTACHMENT A-Page 1 of4
Units Inspected - 24 ARRA Unit Returns - 24 ARRA
Unit # Program Materials Installed Comments

Correctlv
- ARRA NO Return to seal

penetrations In furnace
closet ceiling.
- ARRA NO Return to install

additional ventilation to
bring unit above BTL
(780 @ 50F'a during unit
Inspection)
- ARRA NO
. Unable to run BD, unit
vacant during Inspection
and no electricity. Final
BD reading from
BVCAA final Inspection
appears Inaccurate.
Open ceiling from
plenum to allie,
therefore return to
seal/patch ceiling In
furnace closet then
rerun 80 to determine
accurate final BO
reading.
- ARRA NO Return to seal/patch

ceiling In furnace closet.
Return to adjusllreplace
weatherstripping and
adjust striker plate at
front door.
Return to seal
til ARRA NO penetrations In furnace
closet. Return to
adjusliinstall new
weatherstripping at front
door.
- ARRA NO
Retu rn to seal
closet. Return to
Install missing AlC
filter.
4
ATTACHMENT A-Page2 of4

Correctlv
- ARRA NO No returns necessary

(materials noted as not
Installed correctly due
to lack of HVAC
assessment showing
proper sizing of new
.. ARRA NO
heat pump installed).
Return to replace attic

access (noted as
cracked and unstable
during Inspection).
Install missing AlC
-
filter.
ARRA NO Return to adjust/Install
new weatherstripping
at front door.
- ARRA NO Return to seal

closet.
-
I
ARRA NO No returns necessary

(materials noted as not
Installed correctly due
to lack of HVAC
assessment showing
proper sizing of new
heat pump Installed).
- ARRA
ARRA
NO
NO
Return to patch hole
beneath kitchen sink.
Return to seal
penetrations and air
Infiltration In furnace
closet. Return to
Install Ale filter
.. ARRA NO
(missing).
Return to seal/patch
ceiling In furnace
closet. Install missing
AlC filter.
5
ATTACHMENT A - Page 3 of 4

Correctlv
- ARRA NO Return to patch/seal

plumbing penetrations
in kitchen. Return to
seal/patch open air to
attic in furnace closet.

ce1l1ng In furnace
closet. Return to seal
-
under bathroom sink.
ARRA NO Return to seal/patch
ceiling in furnace
under kitchen sink.
Install missing AlC
filter. Replace
weatherstripping at
front entrance.
~ ARRA NO Return to seal/patch

ceiling In furnace
under bathroom sink.
Install missing AlC
-
filter.
ARRA NO Return to seal/patch
ceiling In furnace
under bathroom and
kitchen sink. Install
missing AlC filter.
Insulate attic access
and weatherstrip attic
access. Replace
weatherstripping at
front entrance.
6
ATTACHMENT A - Page 4 of 4

Correctlv
- ARRA NO Return to patch/seal

ceiling at plenum in
furnace closet, patch 2
holes in wall near floor
In hallway, patch hole
In wall near floor in
.. ARRA NO
bedroom.
Return to seal
In bathroom sink.
Return to seal attic
access and insulate
hatch. Return to
replace
..
weatherstripping at
front door.
ARRA NO Return to seal

beneath kitchen and
bathroom sink. Return
to seal/patch ceiling at
plenum in furnace
closet.

beneath kitchen and
bath sinks. Return to
seallpalch open air at
plenum In furnace
closet. Install missing
.. ARRA NO
AlC filter.
Return to seallpatch
beneath kitchen sink.
Return to seal/patch
ceiling at plenum In
fu rl1ace closet. Install
missing AlC filter.
BVCAA must retllrn and address all units as indicated (lIId include in its respollse to tllis report within
tltlrty (30) days a summary ofall actions and measures taken to addre~s the IInits indicated above.
7
tUIlItO. tdhca.Jtate. IX. us
Rick Perry BOARD MBMDRRS
GOVERNOR C. Kent Conine. Chair
Gloria Ray, Vice GIMh'
Leslie BIngham Escarefio
Michael Gerber Tom H. Cann
ExECUTIVE DIRECTOR Lowell A. Keig
Juan S. Mufioz, Ph.D.
July 26, 2010
Mr. Ben Medina

Director of Planning and Community Development
City of Brownsville
1150 E. Adams St.
Brownsville Texas 78520
Re: Monitoring Report for Weatherization Contract

DOE ARRA WAP Contract #16090000755
Deal' MI'. Medina:
Enclosed is a report that details the monitoring review of the City of Brownsville's Weatherization
Assistance Program contract with the Texas Department of Housing and Community Affairs (The
Department). This information is provided to ensure that compliance with the contract is
maintained and that services to the poor, elderly, and disabled are offered in the most expeditious
and economical manner.
The monitoring report includes eight (8) findings, six (6) recommended improvements and one (l)
note. Please submit a response to this report to this office within thirty (30) days of the date of this
letter.
If we can be of any assistance, please feel free to contact Enrique H. Trejo, Program Officer, at
(512) 475-2299. The assistance provided to the Program Officer by the agency is greatly
appreciated.
Sincerely,
'61j~
Sharon D. Gamble
Manager
cc: Charlie Cabler, City Manager'
~~1 EAST 11 TH • P. O. Box 13941 • AUSTIN, TBXAS 78711-3941 • (800) 5~5-0657 • (51~) 475·3800
Section VI. Audit
"
" '
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CITY OF BROWNSVILLE
Dates of Review: May 24 - 28, 2010
Focus of Review

CONTRACT NAME NUMBER AMOUNT DATES
DOEARRA WAP 16090000755 **$1,638,351.00 9/1/09 to 8/31/11
* 50% ofpl'oposed total allocatIOn
TDHCA staff conducted an on-site review of the City of Brownsville's implementation of the
Department of Energy (DOE) Weatherization Assistance Program (WAP). Specific .areas of
review included Financial Reporting, Contract Agreements, Procurement, Personnel, and the
Management of the Department of Energy contract.
Program Evaluation
The evaluation of the program consisted of: interviews with City of Brownsville personnel;
analysis of the fiscal system; review of programmatic records; on-site inspections; client
interviews; and inventory review.
The following was noted dul'ing the review:
I) Low DOE ARRA WAP Contract Expenditures

2) Not Following Procurement Reporting Requirement
3) Lack of Materials Standards Documentation
4) Lack of Attic Tags and Attic Rulers
5) Units Weatherized with a Primary Unvented Space Heater
6) Not Metering Refrigerators
7) On-Site Inspections Requiring Returns
8) Inadequate Record Keeping in Client Files
9) Development of a Quality Assurance Plan
1
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CITY OF BROWNSVILLE
CONTRACT YEAR-TO-DATE % OF AMENDED # UNITS # UNITS IN

AMOUNT
·DOEARRA WAP $71,223.87 4.35% 15 11
·Expendltures as of AprIl 2010
Finding #1: Low DOE ARRA WAP Contract Exuemlltures

At the time of monitoring, the City of Brownsville had expended $71,223.87
01' 4.35% of the DOE ARRA contract #16090000755 according to submitted
Expenditure Reports to TDHCA. The City of Brownsville was asked to
produce a Plan of Action to Implement DOE ARRA WAP as a result of the
Preliminary Monitoring held on January 5, 20 I O. The City of Brownsville
received a Notice of Possible Deobligation letter on May 26, 2010 with the
requirement to submit a Mitigation Action Plan. The Mitigation Action
Plan submitted to TbHCA on June 11,2010 includes hiring additional staff
and requiring subcontractors to add additional crews.
Action Required: City of Brownsville must provide assurance that that they will adhere to the
Mitigation Action Plan and revise as needed. TDHCA will provide continual
monitoring of the DOE ARRA WAP contract including weekly calls, Desk
Reviews of Monthly Expenditure and Performance Reports and review of
Production Schedules.
Reference: DOE ARRA WAP Contl'act Section 4. Subrecipient
Performance
Recommended Improvement #1: At the time of monitoring, City of Brownsville's

Administrative expenditure ratio was above the maximum allowable of 5.0% for DOE ARRRA
WAP Contract #16090000755. The Administrative expenditure ratio was 13.3%. The
Department reminds the City of Brownsville that the Administrative expenditure ratio must be at
or below the maximum allowed percentage by the end of the contract period. Expenditures above
the allowable percentage will be disallowed. See DOE ARRA WAP Contract Attachment A.
Recommended Improvement #2: A review of financial expenditures indicates that the City of
Brownsville does not have a separate chart of accounts for Travel and Training expenditures in
the· General Ledger. Although the Program Officer was able to track expenditures charged to
Travel and Training on Expenditures RepOlts submitted to TDHCA, the Program Officer
recommends creating a sub account for Travel and Training expenditures associated with DOE
ARRA WAP. Expenditures in the Travel and Training subaccount in the General Ledger should
cOl'I'espond to the Travel and Training line item in the Monthly Expenditure Reports submitted to
TDHCA.
2
OF
I
. CITY OF BROWNSVILLE
Recommended Improvement #3: At the time of monitoring, Health and Safety expenditures
were included in the Material/Labor/Program Support category in the Monthly Expenditure
Reports, Subsequent Monthly Expenditure Reports have expenditures charged to the Health and
Safety budget line item. The Program Officer recommends. creating a subaccount for Health and
Safety expenditures associated with DOE ARRA WAP in the General Ledger. Expenditures in
the Health and Safety subaccount in the General Ledger should correspond to the Health and
Safety line item in the Monthly Expenditure Reports submitted to TDHCA.
SECTION V. PROCUREMENT
Finding #2: Not Following Procurement Reporting Requirements

The City of Brownsville did not post contract related job opportunities on
Workintexas.com. In addition, the City of Brownsville did not provide the
Department with an electronic version of a notice of procurement
opportunity on the Department website. City of Brownsville staff was made
aware of these requirements during the monitoring review.
Action Required: The City of Brownsville must provide written assurance that future contract
related job opportunities will be posted in Workintexas.com, The City of
Brownsville recently hired additional Weatherization staff. Please provide.
verification that the DOE ARRA contract related job opportunities were
posted in Workintexascom. Also, provide written assurance that the City of
Brownsville will post any future procurement opportunity on the Depaltment
website.
Refel'cnce: DOE ARRA Contract Section 33. Job Postings on
WOI'klntexas.com . and Section 19. P,'ocurement Standards &
Subcontracts
SECTION VII. PERSONNEL POLICIES AND PRACTICES
Recommended Improvement #5: A review of the City of Brownsville Personnel Policy Manual
states in the narrative on page 2 that "political affiliation" is a protected category for non-
discrimination. The Program Officer recommends strengthening the Equal Employment section
by adding "political affiliation" and "political belief' as a protected category for non-
discrimination in Section 104 Equal Employment Policy on page 4.
3
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CITY OF BROWNSVILLE
Finding #3: Lack of Materials Standards Documentlltion

At the time of monitoring, the City of Brownsville did not have materials
standards documentation for material used in weatherization. Any materials
not meeting DOE specifications will be disallowed. Material standards
documentation for weatherization materials purchased with DOE WAP
program funds must be maintained by the Subrecipient and comply with
Attachment A of 10 CFR 440 Final Rule.
Action Required: The City of Brownsville must provide material standards documentation for
all weatherization materials supplied from each subcontractor. The Program
Officer provided technical assistance to City of Brownsville stafr" by
supplying an example of material standards documentation for Cocoon Green
Fiber cellulose insulation. Please provide material standards documentation
for all weatherization m.aterials as part of the response to the Monitoring
RepOit.
Reference: DOE ARRA WAP Contract Section 13 Record Keeping
Finding #4: Lack of Attic Tags and Attic Rulers

Department on-site inspections of weatherized units indicated that all
weatherized units receiving attic insulation did not have attic tags and attic
l'ulers. Weatherized units receiving attic insulation are not in compliance
with International Residential Code standards. According to Section 102.1.1
BuIlding thermal envelope Insulation, the insulation installer shall provide
a celtification listing the type, manufacturer and R-value of ,insulation
installed in each element of the building thermal envelope. For blow-in 01'
sprayed insulation (fiberglass and cellulose), the initial installed thickness,
settled thickness, settled R-value, instaIled density, coverage area and the
number of bags installed shall be listed on the certification. The insulation
installer shall sign, date and post the certification in a conspicuous location
on the job site. In addition, insulation markers (attic rulers) shall be
provided fol' every 300 square feet of attic area, attached to the trusses,
rafters 01' joists, and indicate in I inch high numbers the installed thickness
of the insulation.
Action Required: The City of Brownsville must provide wl'itten assurance that units receiving
attic insulation will have attic tags and attic rulers. In addition, submit a
sample cel'tification with the required information from each subcontractor
that installs attic insulation as pmt of the response to this Monitoring Report.
Reference: International Residential Code (2006) Section 11: Energy
Efficiency & DOE ARRA Contract Section 4 Subrecipient Performance
4
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CITY OF BROWNSVILLE
Finding #5: Units Weatherized with Il Primllrv Unvented Space Heater

On-site Inspection of weatherized units Indicated that units were weatherized
with a primary unvented space heater. The City of Brownsville Is not In
compliance with the applicable T.A.C. rule and DOE Weatherization
Program Notice. According to Weatherization Program Notice 08-4, DOE
will not allow weatherization to be conducted on a house with an unvented
primary space heater. All units with a primary unvented space heater must be
vented If weatherization is to occur.
Action Required: The City of Brownsville must vent 01' provide a vented space heater to: I)
2010-06; 2) 2010-22; and 2010-23. In addition, the City of Brownsville must
provide written assurance that the City of Brownsville understands and will
comply with T.A.C. §5.607 Space Heater Requirements and Weatherization
Program Notice 08-4. Please provide this assurance as part of the response to
the Monitoring Report.
Reference: T.A.C. §5.607 Space Heater Requirements and
Weatherlzlltion Progrllm Notice 08-4 Space Hellter Policy
Finding #6: Not Metering Refrigerators

Department review of client files indicates that refrigerators are not being
metered. Refrigerator replacement Is a baseload measure that is being
inadequately addressed due to the lack of metering. According to Texas
Administrative Code Rule §5.606, refrigerators must be metered for a
minimum of two hours under DOE WAp· rules.
Action Required: The City of Brownsville must provide written assurance that refrigerators
will be metered for a minimum of two (2) hours as part of a whole house
assessment. Please provide this assurance as part of the response to the
Monitoring Report.
.Reference: Texas Administrative Code Rule §5.606 Electric Baseload
Measures
5
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CITY OF BROWNSVILLE
Finding #7: On-Site Inspections Requiring Retums

The Program Officer inspected ten (10) DOE ARRA units on May 26 and
May 27, 2010. Department on-site inspections of weatherized units require
eight (8) returns out of ten (10) units inspected. Returns are necessary to
address the insufficient installation of weatherization measures and/or the
lack of weatherization measures. All units were weatherized using the
Priority List.
Action Required: The City of Brownsville must establish a Quality Assurance Plan that
includes assurance that subcontractors will install weatherization measures
to Department of Energy, International Residential Code and Texas
Department of Housing and Community Affairs standards. Please provide
the Quality Assurance Plan as part of the response to the monitoring report.
Specifically, the City of Brownsville must address and/correct the following
issues and provide documentation that the issues were resolved:
a. 20I0-06: I) Replace the unvented space heater with a vented space

heater. 2) Seal the accordion wings of the room ail' conditioner. 3)
Install a vent in the bathroom.
b. 20 I0-17: I) Replace cOl'l'oded electric water heater with a gas water

heater. 2) Attach insulation to the attic hatch.
c. 2010-22: I) Replace the.unvented space heater with a vented space

heater.
d. 2010-23: I) Replace the unvented space heater with a vented space

heater.
e. 2010-27: I) Add a vent above the stove and one in the bathroom. Unit
below the BTL.
f. 2010-16: I) Add a vent above the stove and one in the bathroom. Unit
below the BTL. 2) Replace water heater door.
g. 20 I0-19: I) Clean and service ail' handler 2) Replace condenser
h. 20 I0-24: I) Install insulation on the attic hatch 2) Install R-7

(approximately 2 inches) attic insulation.
Reference: DOE ARRA WAP ContI'act and 10 CFR 440 Final Rule
6
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CITY OF BROWNSVU,LE
SECTION X. CLIENT FILE REVIEW
Finding #8: Inadequate RecOl'd Keeping in Client Files

Department review of client files indicates inadequate record keeping.
Examples of inadequate record keeping include incomplete Blower Door
Forms; missing Refrigerator Forms; and missing Lead Occupant
Confirmation Form. Inadequate record keeping may lead to questioned costs
and poor program performance, Subrecipients are required to have all
necessary assessment forms indicated in the DOE ARRA WAP contract. In
addition, subrecipients are expected to completely fill out aU assessment
forms.
Action Requh'ed: The City of Brownsville must provide written assurance that client files will
have the required assessments forms that are completely fill out. In
addition, the City of Brownsville must provide a Quality Assurance Plan
that includes a policy or a protocol for client file review.
Recommended Improvement #6: In regards to the Weatherization Assistance Program, the

Program Officer recommends that the City of Brownsvllle develop a policy/procedure to verify
compliance with th~ EPA Lead Renovator Rule. The policy should include how, when and how
often subcontractors will be inspected by City of Brownsville Weatherization staff. Contractors
performing weatherization work must be certified and follow specific work practices to prevent
lead contamination. Failure to follow EPA Lead Renovator Rule guidelines may result in fines
up to $37,500.00 for each violation. The EPA Lead Renovator Rule went into eff\1ct on April 22,
2010.
Note #1: A Quality Assurance Plan for the City of Brownsville Weatherization Assistance
Program is a set of internal policies and procedures to assure compliance with the Weatherization
Assistance Program Contract, the Texas Administrative Code and the International Residential
Code. SpecificaUy, the Quality Assurance Plan includes a written policy or standard operating
pl'otocol for I) Unit Assessments; 2) Energy Audits; 3) Final Inspections; 4) Client File review;
4) compliance with Interagency Agreement regarding historic properties; and 5) compliance with
EPA Lead Renovator Rule. Please contact TDHCA if you have questions Or comments.
7
OF
CITY OF BROWNSVILLE
Officer participated in an Exit Conference with Ben Medina, Director of Planning and
Community Development; Lucy Garza, Community Development Manager; and Jose Mendez,
Economic Development Specialist.
07P#d/()
Date
8
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CITY OF BROWNSVILLE
ATTACHMENT A
Units Fund
Inspected
Return Comments
Source
2010-06 ARRA Yes Installed 8 tubes of caulk; 2 door sweeps; weatheristripping; 20 CFLs; and
R-30 attic insulation. Did not tneter refrigerator. Did not take CO
measurement of stove,.No attic tag or attic tulets.
2010-17 ARRA Yes Installed caulkl R-30 attic insulation; and 16 CFLs. No attic tag or attic
rulers, No attic dam. No insulation attached to the attic hatch,
Installed caulk; door sweep; weatherstripping; R-30 attic insulation; R-13

20iO-22 ARRA Yes wall insulation; 25 CFL,; and minor AC repair. No CO detector. No attic
tag. No attic ruler. No attic dam. Unvented gas space heater. No CO
measurement of stove.
ARRA Yes Installed caulk; weathersl'1pping; R-30 attic insulation; R-13 wall
2010·23 insulation; solar screens; and 10 CFLs, No attic tags Of rulers. Unvented
prithS11 space heater.
2010-27 ARRA Yes Installed caulk; weatherstrippingi R-30 attic insulation; and air conditioner
and rUinace. No attic tags or attic rulers. No attic dam. House below
BTL.
ARRA Yes Installed caulk; weatherstripping; R-30 attic insulation; 10 CFL.; and
2010-16 minor roof repair. No CO measurements. No attic tags or attic rulers.
Ho",e below BTL.
2010-21 ARRA No Installed ,caulk; weathecistripping; R-30 attic insulation; exhaust fans; and
28 CFL•. No attic tag or attic rulers,
2010-28 ARRA No In.talled caulk; spray foam; R-l1 attic insulation; R-l1 belly in.ulation;
and 22CFL,. .
ARRA Yes Installed caulk; weatherst11pping; R-30 attic insulation; and 15 CFL•.
2010-19
ARRA Yes Installed caulk; weatherstripping; CFLs; and solar screens. Assessment of
2010-24 attic indicates less than R~30,
Units Inspected: ARRA ......llL Unit Returns: ARRA -L
9
tlJWw. tdlJca. state. ex. ItS
RickPe,ry BOARD MnMDBRS
GOVERNOR C. Kent Conine, Chai,'
Gloria Ray, Vice CIJlth'
Leslie Binghaln Escareno
EXECUTiVE DIIU!CTOR Lowell A. Keig
Juan S. Mufioz, Ph.D.
July 23, 2010
Ms. Amalia C. Garza

Executive Director
Cameron and Willacy Counties Community Projects, Inc.
3302 Boca Chica, Suite 209
Brownsville, Texas 78521-5705
Re: DOE ARRA Weatherization Assistance Program Contract #16090000653
Dear Ms. Garza:

Program contracts with the Texas Department of Housing and Community Affairs. This
information is provided to ensure that compliance with the contract(s) is maintained and that
manner.
The Department has identified ten (10) findings and two (2) recommendations for the
Weatherization Assistance Program. Please submit a response to this repolt to this office within
forty-five (45) days of the date ofthis letter.
If we can be of any assistance, please contact Enrique Trejo, Program Officer, at (512) 475-2299.
The assistance provided to the Program Officer by Cameron and Willacy Counties Community
Projects, Inc. is greatly appreciated.
~,---
Sharon Gamble
Manager
Cc: Enrique Trejo, TDHCA Program Officer

Honorable Sallie Gonzalez, CWCCP Board Chair
221 EAST 11 TH • P. O. Box 13941 • AUSTIN, TBXAs·7B7t1·3941 • (800) 525·0657 • (512) 475·3800
-() Prh",d (111 T{(Jdtd pllp"
2009-11 WAP UNIT INSPECTION REPORT
CAMERON AND WILLACY COUNTISS COMMUNITY PROJECTS
WEATHERIZATION ASSISTANCE PROGRAM (WAP)

CORRECTIVE ACTION REQUIRED AND RECOMMENDED IMPROVEMENTS
Dates of Review: June 21-24,2010
Focus OF REVIEW

NUMBER AMOUNT
DOE/ARRA 16090000653 $2,626,732.00 9/112009 to 8/3112011
PROGRAM EVALUATION
The evaluation of the program consisted of client file reviews, on-site inspections, interviews with
clients, and analysis of both quality of subcontractor workmanship and final inspection techniques.

• Final Blower Door readings were not being performed.
• No Central HVAC assessments on file.
• Window air conditioning units were not being metered.
• Refrigerators were not being metered.
• Incomplete BWR forms.
• Labor charges were not noted in the NEAT/EASY audit or BWR.
• Improper use of Blower Door Rings.
• Units below the Building Tightness Limit (BTL).
• The Priority List was not being performed properly.
• Installation of 13 SEER HVAC units.
• Staff members have not attended Department approved trainings.
• Blow-in insulation is not considered as a weatherlzation measure.
Client File Review(WAP Only)
Finding #1: Incomplete Blower Door Forms

A review of fifteen (IS) client files revealed nine (9) files where the Final Inspector
did not complete a final blower door reading. CWCCP staff copied the initial blower
door reading and documented the number on the Final Inspection data entry location.
CWCCP must perform a separate final blower door reading on each unit that it
weatherizes and document this reading on the Blowel' Door Data Sheet. The ability
to obtain a final reading will assist in determining if the infiltration reduction
Page 1 of6
CAMERON AND WILLACV COUNTIES COM MUNITV PROJECTS
measures were effective and if the unit is not below the BTL.
Action
Requh'ed: As part of the response to this report, CWCCP must assure the Department that all
weatherized units will have a final blower door reading performed when the unit is
final inspected. Q.eference: Blower Door Standards
Finding #2: Lacl' of HVAC Assessments

A review of fifteen (15) client files revealed six (6) files not containing documented
assessments of Central HVAC systems. CWCCP paid contractors for an assessment
of the central HVAC system, .however the file did not contain the assessment that
was performed.
Action
Required: Due to the fact that assessments are mlssmg from the client files, the HVAC
assessment charges associated with units 41, 42, 46, 51, 61 and 96 are considered
questioned. As part of the response to this report, CWCCP must provide a copy of
the missing assessments for the noted files. Failure to provide a copy for each of
these units will result in disallowed costs. In addition, CWCCP must provide an
assurance that copies of all assessments and invoices will be maintained in the client
file. Reference: OMB Ch'cular A-110
Finding #3: Missing Window Unit Assessments

A review of fifteen (15) client files revealed two (2) files where the window ail'
conditioning units were not assessed. Assessors did not meter the unit to obtain the
existing efficiency. Assessments contained efficiencies of the unit at the time it was
manufactured. Obtaining efficiencies from the date the unit was manufactured may
result in unreliable SIR readings in the NEATIEASY audit and disallowed costs.
Action
Required: CWCCP must assure the Department that all window air conditioning units will be
metered to obtain the existing efficiency and that these efficiencies will be
documented in the assessment. CWCCP must also provide documentation of what
tools 01' equipment (watt meters) was purchased to obtain the required readings.
Reference: DOE ARRA Contract Section 13. 10 CFR 440.21
Finding #4: Missing Refrigerator Assessments

A review of fifteen (IS) client files revealed eleven (II) files where documentation
of refrigel'fttor assessments were missing. Interviews with weatherization staff found
refrigerator metering not being performed on all weatherized units.
Action
Required: To' ensure that all potential weatherization measures are addressed, CWCCP whole
house assessments must include refrigerators. As part of the response to this report
CWCCP must return to units 10, 11,37,41,42,46,51,81,86,90 and 96 and assess
the refrigerators. CWCCP should replace eligible refrigerators according to TDHCA
Page 20f6
CAMERON AND WILLACY COUNTIES COMMUNITY PROJECTS
and DOE requirements. Documentation of the assessment and any measures taken
must be provided as part of the response to this report. In addition, CWCCP must
provide an assurance that all refrigerators will be assessed. Reference: ARRA
Contract Section 13 B
Finding #5: Missing BWR Pages

A review of fifteen (15) client files revealed two (2) files where page two of the
BWR form, that contains information on the repair and health and safety charges,
was missing in files #10 and #42.
Action
Required: As part of the response to this report, CWCCP must locate or reconstruct the BWR
for units 10 and 42. CWCCP must pmvide a copy of the completed BWR's in the
response. In addition, CWCCP must provide an assurance that each file will contain
a complete BWR. Reference: 10 CFR 600.121
Finding #6: Exclusion of Labor Charge From Energy Audit and Priority List
A review of fifteen (15) client files revealed seven (7) files where the labor charge
was not considered in the Priority List or NEATIEASY audit when using CWCCP
staff members to complete the installation of weatherization measures. Not including
the labor charge in the Priority List of NEAT/EASY audit, may result in certain
weatherization measures being disallowed. Therefore, units 03, 10, 37, 38, 61, 86
and 96 have questioned costs.
Action
Required: CWCCP must include all associated labor costs in the NEAT/EASY audit or when
using the Priority List. As part of the response to this report, CWCCP must address
the labor costs on units 03,10,37,38,61,86 and 96. If the NEAT/EASY audit was
performed 011 these units CWCCP must make the adjustment to include the labor
cost for the specific measures. CWCCP must then rerun the audit and provide a copy
of the audit, as part of the response to this report. In addition, CWCCP must include
labor cost in the measures when utilizing the Priority List. CWCCP must provide the
new cost of the Priority list measure when including labor (to include the BWR).
Finally, CWCCP must provide an assurance that it will include and account for labor
charges in the energy audit 01' Priority list when using CWCCP to install
weatherization measures. Reference: 10 CFR 440.21
Performance Review (WAP Only)
Finding #7: Improper Blower Door Procedures

It was noted that CWCCP conducted final inspections using an open fan. CWCCP
failed to utilize the rings on the fan to create a baseline reading before performing the
blower door test. In performing a baseline reading CWCCP will obtain an average
pressure baseline when inconsistent and varying pressures exist. The use of the
blower door rings during the actual blower test will enable more accurate readings
building envelopes with lower special volume.
Page 3 of6
CAMERON AND WI~~ACY COUNTIES COMMUNITY PROJECTS
Action
Required: As palt of the response to this report, CWCCP must provide an aSSUl'ance that a
baseline reading will be obtained. The assurance should detail the use of the blower
door readings to obtain a baseline reading, while conducting unit assessments and
final inspections. In addition, if CWCCP personnel require training on the use of the
blower door rings, a training request should be documented in the response to this
repOlt. Reference: Reference: Texas Blower Door Standards; Blower Door
Manufacturel' Instructions
Finding #8; Final CFM Reading Below BTL

While conducting onsite inspections of weatherized units, foul' (4) units (10,46,81
and 96) CFM readings were below the allowable BTL. The final CFM reading must
not fall below the BTL. Falling below the BTL may result in potential health hazards
to the client and/or disallowed cost. It was noted that CWCCP conducted all final
inspections using an open fan. CWCCP was not knowledgeable on the use of the
Blower Door rings that may have better assisted the final inspector of obtaining more
accurate readings.
Action
Required: CWCCP must return to units to, 46, 81 and 96 to address the BTL reading. Failure
to address and bring the CFM readings above theBTL may result in disallowed costs
of all measures for each unit below the BTL. As prot of the response to this report,
CWCCP must document what meaSUl'es were taken to bring the CFM reading above
the BTL. In addition, CWCCP must aSSUl'e the Department that all weatherized
homes will not fall below the BTL and that proper use of the Blower Door and its
accessories will be performed. Reference: Blower Door Standards
Finding #9: Improper Prioritv List Procedures

CWCCP's implementation of the Priority List, revealed weatherization measures not
being addressed in the order that it is required. Notably, duct work was not being
considered on units that were conditioned by a central HVAC system. When
utilizing the Priority List, the assessor must address each item, in order, beginning
with the first item-Infiltration Reduction. When each item is addressed, the
weatherizatiqn measure must be performed, unless there is a justifiable and
documented reason for not performing the measUl'e. Should a future monitoring
document that certain Pl'iority List items are not being performed, CWCCP will face
questioned and/or disallowed costs.
Action
Required: As part of the response to this report, CWCCP must assure the Department that it
will address each item on the Priority List, in the order that it is listed. In addition
CWCCP must assure that any measures not performed will have a justifiable reason
that is documented in the client file. Reference: Texas Priority List
Page 4 of6
2009-11 WAP UNIT INSPECnON REPORT
CAMERON AND WILLACY COUNTIES COMMUNITY PROJECTS
Finding #10: Lack of Documentation for Installing 13 SEER HVAC Systems

During the final inspection, it was noted that CWCCP replaced new HVAC systems
with 13 SEER systems and not 14.5 SEER as required by the Department and
Energy Star.
Action
Required: The Department is questioning the costs related to the installation of the central
HVAC systems where the SEER l'ating was 13. As part of the response to this report,
CWCCP must provide the reason 13 SEER HVAC systems were installed into the
units. In addition, CWCCP must document what measures have been put in place to
ensure the minimum SEER requirement is being installed in the weatherized units.
Reference: ARRA Contract Section 13 B (13)
Recommended
Improvement #1: Interviews with CWCCP staff revealed that the majority of its' weatherization
employees have not attended Depaltment approved trainings. Many of these
trainings have free registration and CWCCP weatherization contracts contain
training and technical assistance dollars to supplement additional training related
costs. Attending the Depaltment approved trainings may reduce future findings and
may result in an efficient and effective Weatherization program. The Department
strongly recommends that CWCCP provide. opportunities for its weatherization staff
to attend Department approved trainings.
Recommended
Improvement #2: An assessment of CWCCP's requirement on attic and wall installation, revealed
a labor intensive method. CU1'l'ently, CWCCP installs batt insulation in attics and in
exterior walls. The method of "stuffing" batt insulation into the exterior walls
requires a large opening, new sheet rock and joint compound on the interior of the
weatherization unit. FUlthermore, there is a high probability that parts of the batt
insulation will be compressed in the "stuffing" prohibiting the full effectiveness of
the heat resistance value (R-value). The Depaltment strongly recommends a less
labor intensive method of insulating attics and walls. The Department recommends
the use of blown-in insulation (fiberglass or cellulose). Utilizing these products in
the walls, may provide the opportunity for a higher 01' more consistent R-Value and
coverage.
Texas Department of Housing and Community Affairs representatives J.R. Mendoza, participated in
an exit conference with CWCCP representatives Amalia Garza, Krishna Iyer and Noe Hernandez
I ]!Si~gl1ailiitul~'e:+1~.g\~'~H~Ql~~~~'S;;;;:.L~=====
C'eledonio M6ndoza ~
__ 1 7/t"l/to
. Date
Page 5 of6
CAMERON ANO WILLACV COUNTIES COMMUNITV PROJECTS
----._._--- . - - - - - -
ATTACHMENT A
ARRA UNITS INSPECTED ARRA UNITS RETURNS 11

~
-_._.--- - - - -
Units Fund Return Comments
Inspected ,
Source
96 ARRA YES Final Blower Door reading is below the BTL. Must bring unit
above the BTL. Address duct leakage. Meter the refrigerator.
86 ARRA YES Seal Furnace Door. Meter the reft·igerator. Seal sides ofwindow
air conditioner.
61 ARRA NO
above the BTL. No Cabron Monoxide detector Installed.
Address duct leakage. Meter the refrlllCerator.
10 ARRA YES Finai Blower Door reading is below the BTL. Must bring unit
above the BTL.
37 ARRA YES Meter the refrigerator
38 ARRA NO
11 ARRA YES Repair holes in the hallway. Insulate the attic hatch. Address
wall inSUlation. Meter refrigerator. Assess Duct svstem.
5 ARRA YES Meter the refrigerator. Seal duct leaks. Seal door to central
svstem.
42 ARRA YES Contractor dama.ed door bell. RefrillCerator not metered.
41 ARRA NO
S-l ARRA YES Final Blower Door reading is below the BTL. Must bring unit
above the BTL. Meter refrilzerator.
51 ARRA YES Meter the refrigerator
above the BTL.
CWCCP must return and address all units as indicated and include in it's response to this report a
summary of all actions and measures taken to address the units indicated above.
Page 6 of6
WWlv,tdhca,state.tx.us
Rick Perry BOARD MOMBBRS
GOVBRNOR C. Kent Conine, Chair
Gloria Ray, Vic, Chair
Leslie Bingham Escarefio
Tom H. Gaon
Michael Gerber Lowell A. Keig
ExBCUTlVE DIIWC1'OR
Juan S. Mulioz., Ph.D.
June 29, 2010
Ms. Rhoda M, Gersch

Executive Director
Combined Community Action, Inc.
165 W. Austin Street
Giddings, Texas 78942
Re: Monitoring Report for Weatherization Contracts

DOE Weatherization Assistance Program Contract #56090000452
DOE ARRA Weatherization Assistance Program Contract #16090000654 &
#16090000777
Dear Ms. Gersch:
.Enclosed is a report that details the monitoring review of Combined Community Action, Inc.,
(CCA) Weatherization Assistance Program contracts with the Texas Department of Housing and
Community Affairs (The Department). This information is provided to ensure that compliance
with the contracts is maintained and that services to the poor, elderly, and disabled are offered in
the most expeditious and economical manner.
The monitoring report includes three (3) findings, three (3) recommended improvements and one
(I) note. Please submit a response to this report to this office within thirty (30) days of the date of
this letter.
If we can be of any assistance, please feel free to contact Enrique H. Trejo, Program Officer, at
(512) 475·2299. The assistance provided to the Program Officer by the agency is greatly
appreciated.
Sincerely,
Sharon D. Gamble
Manager
cc: Nick Tirey, Board Chair

221 EAST 11 TH • P. O. Box 13941 • AUSTIN, TnXAs 78711-3941 • (800) 525-0657 • (512) 475-3800
Sec.tion VI. Audit

OF
COMBINED COMMUNITY ACTION, INC.
Dates of Review: l;\.prill2 - 16,2010
Focus OF REVIEW

CONTRACT NAME NUMBER AMOUNT DATES
DOE 56090000452 +$366,020.00 4/1/09 to 3/31/10
LIHEAP 81090000485 +$443,929.00 4/1/09 to 3/31/10
DOEARRA 16090000654 ++$1,730,958.00 9/1/09 to 8/31/11
DOEARRA 16090000777 *+$500,000.00 9/1/09 to 8/31/11
• Latesl contract amendments •• 500/0 of proposed total allocatIon
TDHCA staff conducted an on-site review of the Combined Community Action, Inc., (CCA)
implementation of the Depatiment of Energy and the Low Income Home Energy Assistance
Program Weatherization Assistance Programs (WAP). Specific areas of review included
Financial Reporting. Specific areas of review included Financial Reporting, Contract
Agreements, Procurement, Personnel, and the Management of the Department of Energy and
Low Income Home Energy Assistance Program contracts.
PROGRAM EVALUATION
The evaluation of the program consisted of: interviews with CCA personnel, analysis of the
inventory review.
The following WlIS noted during the review:
• Missing Contract Provision - Compliance with Executive Order 11375
• On-Site Inspections Requiring Return for Additional Ail' Sealing
• Refrigerator Metering Less than Two (2) hours under DOE WAP
PAGE20F8
2009 WEATHEnIZATION MONITORING REPORT
OF
COMBINED COMMUNITY ACTION, INC,
CONTRACT YEAR·TO·DATE %OFAMENDED # UNITS # UNITS IN

AMOUNT
*DOE $304,076,88 83.08% 40 2
*LIHEAP $715,762.22 63.31% 51 6
*DOEARRA $25,302,19 36.83% 91 22

16090000654
**DOEARRA $0.00 0,0% NA NA
16090000777 r
*Expendltures as of February 20 I0 **Contracts signed in January 2010
SECTION II. TRAVEL AND TIMESHEETS
Recommended Improvement #1: At the conclusion of the monitoring review, it was

recommended that CCA add a category for DOE ARRA for those employees who are paid with
DOE ARRA funds. Note: l\.t the conclusion of the Exit Conference, Darlene Stange Myers
inserted a column for DOE ARRA on the timesheet.
SECTION V, PROCUREMENT
Finding #1: Missing Contl'act Provision· Compli!!l1ee with Executive Order 11375
Department review of the weatherization services contract with All·Tex
BUilding and Restoration indicated a missing contract provision. CCA is
not in compliance with all applicable regulations regarding the
Weatherization Assistance Program. Contracts with subcontractors in excess
of $10,000.00 must be in compliance with Executive Order 11375
Amending Executive Order 11245 "Equal Employment Opportunity,"
Action Required: CCA must include language affirming compliance with Executive Order
11375 in the contract with All·Tex Building and Restoration, The Program
Officer recommends inserting the affirmation of compliance in Section 12
Special Compliance Provisjons, Note: At the conclusion of the Exit
Conference, Kelly Franke, Weatherization Coordinator added compliance to
Executive Order 11375 in Section 12 Special Compliance Provisions.
Lance Meyer, Owner of All·Tex Building and Restoration Inc., initialed the
changes and kept a copy for his records. No further action is required.
Reference: OMB A·110 Uniform Administr!!tive Requirements,
Appendix A
PAGE 3 OF 8
OF
SECTION VI. AUDIT
Note #1: CCA conducted a Request for Proposal for audit services for Fiscal Year 2006. CCA
must procure for audit services for Fiscal Year 2010.
SECTION VII. PERSONNEL POLICIES AND PRACTICES.
Recommended Improvement #2: After Department review of CCA personnel policies, it is

recommended that CCA add "political affiliation 01' belief' as a protected -categol'y for non-
discrimination. The Program Officer recommends inserting the new language in Section C.
Agency Policies C.l Equal Opportunity Employer 1.1. CCA includes a provision in Section C.
Agency Policies 1.8 stating that any employee who feels he or she has been discriminated on the
basis of race, color, sex, national origin, age, religion, politicill affiliation or disability shall
notify the EEO Officer in writing. The Program Officer recommends that language in C.l Equal
Employer 1.1 be consistent with C.l Equal Employer 1.8.
Finding #2: On-Site Inspections Requiring Return

Program Officer inspected twenty (20) DOE ARRA Wlits on Apri113, 2010
and six (6) DOE and LIHEAP unlts on Apri114, 2010. Department on-site
inspections of weatherized units require one (1) return out of the twenty six
(26)Wlits inspected. Returns are necessary to address the insufficient
installation of weatherization measures and/or the lack of weatherization
measures.
Action Required: CCA must return to 09FY06 to conduct additional air sealing. The on-site
inspection blower door reading was 5030 CFM while the target blower door
is 3018 CFM. Note: Lance Meyer, All-Tex Building and Restoration Inc.,
provided pictures at the Exit Conference that additional air sealing measures
were conducted in the kitchen, batm'oom and a utility room. CCA must
provide a blower door reading as part of the response to this monitoring
report.
Reference: DOE ARRA, DOE and LIHEAP Contracts and 10 CFR 440
Final Rule
PAGE40F8
2009 WEA THERIZATION MONITORING REPORT
OF
Finding #3: Refrigerator Metering Less than 2110urs under DOE WAP
Department review of seven (7) client files indicates that refrigerators were
not metered the minimum time of two (2) hours under the DOE WAP.
Seven Refrigerator Assessment Forms indicate that refrigerators were
metered between 30 and 70 minutes. According to Texas Administrative
Code Rule §5.606, refrigerators must be metered for a minimum of two
hOUl'S tinder DOE WAP.
Action Required: CCA must provide written assurance that refrigerators will be metered for a
minimum of two (2) hours if using DOE weatherization grant funds. Please
provide this assurance as part of the response to the Monitoring RepOlt.
Reference: Texas Administrative Code Rule §5.606 Electric Baseload
Measures
Recommended Improvement #3: The Program Officer recommends the development of a

Quality Assurance Plan that assures compliance with Weatherization Contracts, the Texas
Administrative Code and the International Residential Code. The Quality Assurance Plan
includes a written policy 01' standard operating protocol for 1) Unit Assessment; 2) Energy
Audits; 3) Final Inspections; client file review; and 4) compliance with EPA Lead Renovator
Rule.
PAGE50F8
OF
Officer participated in an Exit Conference with Rhoda Gersch, Executive Director; Kelly
Franke, Weatherization Director; Darlene Stange Myers, Chief Financial Officer and; Lance
Meyer, Owner of All Tex Building and Restoration Inc. .
cr~.hzMvo
Date
Signature: M::::iiC~~~,-- _ ~(2-7./IO

~e, TD1ICA Program Officer Date
PAGE 6 OF 8
OF
ATTACHMENT A
------,,------------,------------------
Units
Inspected
09A47-1 ARRA No Installed R-19 attic insulauon; CO monito,; 1.5 ton 13 SEER condense'
and air handler. Duct work replacement.
09A47-3 ARRA No Installed R-19 attic jnsulation; CO monitor and; 1.5 ton 13 SEER
condenser and air handler. Duct work replacement.
Installed R-19 auk insulation; CO monito,; the'mostat and; 1.5 ton 13

09A47-6 ARRA No SEER condenser and air handler. Duct work repiacement.
09A47-5 ARRA No Installed R-19 attic insulation; CO monitor; !hetroostat and; 1.5 ton 13
SEER condenser and air handier. Duct work replacement.
09A47-9 AlUtA No Installed R-19 attic insulation; CO monitor; thermostat, water heater; and
1.5 ton 13 SEER condenser and air handier. Duct wo'k replacement.
Installed R-19 attic insulation; CO monitor; thermostat, refrigerator; and

09A47-11 ARRA No 1.5 ton 13 SEER condenser and air handler. Duct work replacement.
Installed R-19 attic insulation; CO monitor; thermostat, water heater; and

09A47-14 ARRA No 1.5 ton 13 SEER condenser and air handle,. Duct work replacement.
09A47-12 ARRA No Installed R-19 attic insulation; CO monitor; thelmostat,. refrigerator; and
1.5 'ton 13 SEER condenser and ai, handle,. Duct wo,k replacement.
ARRA Installed R-19 attic insulationj CO monitor; thermostat, water heater; and
09A47-25 No 1.5 ton 13 SEER condense' and air handler. Dllct wo,k replacement.
09A47-27 ARRA No InstaUed R-19 attic insulation; CO morutofj thermostat, water heaterj
reftigerato,; and 1.5 ton 13 SEER condense' and air handle,. Duct work
replacement.
09A47-29 ARRA No Installed R-19 attic insulationj CO monitor; thermostat, water heater; gas
stove; and 1.5 ton 13 SEER condense, and air handler. Duct work
replacement.
09A47-31 AlUV\ No lnstaUed R-19 attic insulation; CO monitor; thermostat) water heater; gas
stove; and 1.5 ton 13 SEER condenser and air handler. DUCI wo,k
replacement.
09A47-33 ARRA No Installed R-19 attic insulation; CO monitor; thermostat, water heater;
refrlgerato,; and 1.5 ton 13 SEER condenser and air.handler. Duct work
replacement.
PAGE 7 OF 8
OF
COMBINED COMMUNITY ACTION.!.,:..IN=C~. _
--~"----
ATTACHMENT A
Units
Inspected
09A47-35 ARRA No Installed R-19 attk insulation; CO monitor; thermostatl water heater;
refrigerator and: 1.5 ton 13 SEER conc)enser and air handler. Duct work
replacement.
09A47-44 ARRA No Installed R-19 attic insulation; CO monitor; water heater; stovcj,and 1.5
ton 13 SEER condenser and ai, handler. Duct work replacement,
Installed R~19 attic insulation; CO monitor; thermostat; refrigerator;'

09A47-46 ARRA No stove; and 1.5 ton 13 SEER condense, and ai, handler. Duct work
replacement.
09A47-42 ARRA No Installed R-19 attic insulatiotli CO monitor; thermostat; water heater; gas
stove; and 1.5 ton 13 SEER condenser and ai, handler. Duct work
replacement.
Installed It-19 attic insulation; CO monitor; thermostat) rcftigcl'ator;
09A47.43 ARM No stove; and 1.5 ton 13 SEER condenser and ai, handler, Duct work
replacement.
Installed R~19 attic insulation; CO monitor; water heater; and 1.5 ton 13
09A47-17 ARRA No SEER condenser and air handler. Duct work replacement.
Installed R-19 attic insulation: CO monitor; refrigerator; and 1.5 IOn 13

09A47-19 ARRA No SEER condenser and air handler, Duct work replacement,
09COl13 ARRA No Installed thermostat; 30 gal water heater; and smoke detector. Window
pane replacement.
ARRA/LIHEAP Installed R-11 attic insulation; smoke detector; and 2,5 ton 14 SEER,
09FYll1 No
Installed R-19 attic insulation; CO monito!; thermostat; stove; solar
09FY104 DOE/LIHEAP No screens~ smoke detector; and 3 ton 14 SEER condenser and air handle!',
09FY117 Installed refdgerator; smoke detectorj CFLs; thermometer; and 2 ton 14

ARRA/LIHEAP No SEER condenser and air handle,.
Installed solar screens and roof AC. Inspection blower door was
09FY106 DOE Yes app,oximately 700 CFM above the target, Return for additional ai,
sealing.
09FY109 Installed R-19 attic insulation; smoke detectot; solar scteenSj and 4 ton 14
DOE/LIHEAP No SEER condense, and air handler. Inspection blower door was high.
Contractor conducted additional ait sealing around chimney. House was
brought down 200 CFM. No obvious ai, leaks,
PAGE8 OF 8
www.tdhca.state.tx.us
Rick Perry BOARD MEMBERS
GOVIJRNOR C. Kent Conine. CIJaJr
Gloria Ray, VIti Chair
Leslie Bingham Escarefi9
Mlclu\el Gerber TOM H. Gann
EXECUTIVE DIRECTOR Lowell A. Keig
Juan S. Mufio~, Ph.D.
June 21, 2010
Ms. Mary Jane Rios

Executive Director
Coinmunity Council of Reeves County
700 Daggett Street, Suite F
Pecos, rx 79772"4524
Re: Department of Energy Weatherization Assistance Program Contract #56090000456

Department of Energy ARRA Weatherization Assistance Program COiltract #16090000659
Dear Ms. Rios:
Enclosed is a report that details the monitoring review of Community Council of Reeves County's
Weatherization Assistance Program contracts with the Texas Department of Housing and
COlfl\llunity Affairs (The' Department). This information is provided to ensure that compliance
with the contracts is maintained and that services to the poor, elderly, and disabled are offered in
the most expeditious and economical maffiler.
The monitoring report includes five (5) recommended improvements and ten (l0) findings. Please
submit a response to this repOlt to this office within thirty (30) days of the date ofthis letter.
If we can be of any assistance, please feel free to contact Rosy 1. Falcon, Program Officer, at
(512) 936-7810. The assistance provided to the Program Officer by the agency is greatly
appreciated.
Sincerely,
rtJ--
Sharon Gamble
Manager
Community Affairs
cc: Mr. Rogelio Alvarado
221 BAST liT" • P. O. Box 13941 • AUSTIN, TBXAS 78711-3941 • (800) 525-0657 • (512) 475-3800
(} PrJnud 0'1 rtryrl,J p"p"

"
Section VI. Audit
Section VIII. Performance Review and Onsite Inspections
Section X. Client File Review Work Sheet and Multi-Family

Review

.'
Section XII. Summary

OF
COMMUNITY COUNCIL OF REEVES COUNTY
Dates of Review: May 17-20,2010
FOCUs OF REVIEW
CONTRACT NAME CONTRACT * CONTRACT CONTRACT DATES

NUMBER AMOUNT
DOE ~6090000456 $87,193.00 411/2009 to. 3/3112010
LIHEAP 81090000489 $89,974.00 4/112009 to 3/31/2010
DOEARRA 16090000659 $400,181.00 9/112009 - 8/3112011
lie Latest contract amendments
Oli-site review of the Community Council of Reeves County's, (CC Reeves) implementation of
the Department of Energy's and Low Income Home Energy Assistance Program's
Weatherization Assistance Program (WAP). Specific areas of review included Financial
Reporting, Contract Agreements, Procurement, Personnel, and the Management of the
Department of Energy and Low Income Home Energy Assistance Program contracts.
PROGRAM EVALUATION
The evaluation of the program consisted of: interviews with the CC Reeves personnel, analysis
of the fiscal system, review of programmatic records, on-site inspections, client interviews, and
inventory review.
• Monthly general ledger did not reconcile with the expenditure reports submitted.
• DOE ARRA Administrative expenditures are above the maximum allowed.
• DOE and LIHEAP expenditures were insufficient to fulfill their contract,
• Lack of Procurement documentation.
PAGE 2 OF 11
OF

CONTRACT YEAR-TO·DATE % OF ORIGINAL # UNITS # UNITS IN

AMOUNT *
DOE $76,601.76 87.85% 12 0
DOEARRA $153,429.81 38.34% 21 2
LIHEAP $85,974.00 95.55% 19 0
• At the time of monitormg, ARRA amounts are as ofApr1l2010
Recommended Improvement #1: A review of the January 2010 Monthly Expenditure Report
for DOE ARRA revealed an inconsistency between the reporting and the general ledger. CC
Reeves over reported their Training and Technical Assistance funds by $2,760.76. The item was
for a training that was postponed and for an employee that was terminated. The Agency voided
the check and the funds are shown as available for future training and technical assistance needs.
CC Reeves needs to keep all working papers as they pertain to variances between the general
ledger and the monthly expenditure reports in order to account for the variance. Reference:
OMB Circular A-llO, Subpart C_.21
Recommended Improvement #2: As of April 2010 the ratio of the Administrative

expenditure for DOE ARRA was at 9.20%, well above the maximum allowable expenditure. CC
Reeves is reminded that expenditure for Administration must be at or below 5% for DOE ARRA
by the end of the contact term. Immediate attention must be paid to production schedules in
order to meet the above mentioned ratio. Any expenditure above the allowable maximum
expenditure is subject to disallowed costs. Reference: DOE ARRA Contract Attachment A.
Recommended Improvement #3: A review of CC Reeves' expenditures revealed inadequate

support documentation in five (5) of the nineteen (19) expenditures reviewed. Three (3) of the
files reviewed lacked the adequate documentation showing the eligible household the materials
were installed in, two (2) contained internal forms that were inaccurately completed as well as
incomplete fOlms, one (l) procurement purchase lacked documentation providing the internal
approval needed for any purchases done on the company card. The Agency is reminded that all
expenditures must be accompanied by appropriately completed forms any future inadequacies
may result in disallowed costs. Reference: OMB Circular A-llO, Attachment C_.21 (b) (2)
(3) (4), 1 T. A. C. §5.141
PAGE 3 OF 11
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Finding #1: CC Reeves shows low expenditures, as of March 2010 CC Reeves has expended
95.55% of funds in LIHEAP, 87.85% in DOE, and 38.34 in ARRA while 100%
of their LIHEAP and DOE and 33.33% of their ARRA contract period has
expired.
Action CC Reeves must submit a plan of action detailing how they will meet production
Required: goals for Program Year 2010. Furthermore CC Reeves is urged to pay immediate
attention to production schedules in order to expedite expenditures for the
Weatherization Assistance Program. Although ARRA production is in line with
the amount of contract expired, the Department would like to recommend that CC
Reeves make use of the multifamily tools the Department has provided and seek
out a property in their area that could benefit from weatherization services. Doing
so will provide CC Reeves the benefit of not only assuring their benchmarks are
met but also of exceeding them. Reference: OMB Circular A-ll0, Subpart C
_.21 (b) (2) (3) (4), 1 T.A.C. §5.141, DOE and LIHEAP Contracts Section 4.
Finding#2: Staff timesheets had inadequate support documentation; they did not identify
charges between the grant categories. Travel documents did not have sufficient
support documentation in order to determine whether the expenditure was
allowed. Check #18143 made out to Wal-Mart for $637.00 did not contain
sufficient documentation to substantiate the wire transfer to employee Deverick
Booke; this lack of documentation creates a question as to the validity of this
expenditure. Check # 18325 made out to Chevron in the amount of $53.26 had
support documentation stating charge was for Comprehensive Energy Assistance
Program (CEAP) and it was missing the supervisor signature as required by their
fOlID, however funds were-paid out of American Recovery and Reinvestment Act
(ARRA). Upon futther review and staff interviews it was determined that the
mileage log used to support this expenditure was not accurately filled out.
Employee Jerry Orona performs work for both the WAP and the CEAP and
mistakenly entered CEAP- as the pl'ogram he was working on instead of WAP.
This review revealed $637.00 in questioned costs for the Wal-Mart expenditures.
Action CC Reeves must add the title of the employee and the category charged to their
Required: - their timesheet cost breakdown column in order to have the timesheets correctly
reflect duties performed and substantiate the expenditures. -
CC Reeves must submit to the Department support documentation detailing the

cost breakdown for the $637.00 that was wired to Mr. Bookey, as part of their
response to this report. A review of the Agency's travel documents determined
that staff, especially newly hired staff, must have further training on how to
PAGE 4 OF 11
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accurately complete the Agency's mileage log. The supervisor must assure that
the mileage submitted and all necessary fields are complete, and that they sign the
form. The Agency will highly benefit from keeping all advances, expenditures,
and reimbursements together as they pertain to specific trips. Doing so will aid in
determining if the advance given to the employee was allowable and if the
employee needs to reimburse the Agency or if the employee is owed anything.
Reference: OMB A·87 Attachment B 11, OMB A·122 Attachment B, ARRA
Contract Section 35, DOE and LIHEAP Contract Section 29
Recommended Improvement #4: The Agency has recently begun the use of in-house crews
and the housing of weatherization materials. They currently perform monthly inventory of the
materials and update the inventory as soon as the materials need to be removed from the
premises and taken to a client home. The Department would like to remind the Agency that a
yearly inventory of materials kept on hand must be performed in order to account for the
materials purchased by Weatherization Assistance Program funds. The Department sees the
potential for the current process to result in a future finding that may create questioned costs.
Cun'ently the Agency purchases stoves and refrigerators in bulk and has the vendor house them
until they are needed in a home. Someone from the Agency will call the store manager and let
them know to release which ever item is needed to the contractor that will go and pick it up. The
Agency is pre-paying for an item that has not been predetermined as needed in an income
eligible house; the Agency caunot assure the Department that the items are safeguarded as the
Agency and the vendor have a verbal agreement; there are no effective internal controls when
detelmining the release of the items; there are no efficient separation of duties to allow for
effective internal controls when ordering and maintaining inventory. The Department strongly
recommends that if CC Reeves must pre-pay for stoves and refrigerators they enter into a formal
contract with the vendor detailing the responsibilities that lay with each party and as an
attachment there should be a list of names and titles of the person(s) authorized to remove this
inventory. In addition a similar sign in sheet must be kept by the vendor and a signature must be
required prior to the removal ofthe material. The Department reminds CC Reeves that it is their .
responsibility to safeguard any material against theft, loss, 01' damage.
The Agency's internal inventory procedures lack the adequate intemal controls that will allow
for the safeguarding of materials. The WAP Coordinator initiates the purchase request and the
Executive Director reviews and approves the purchase. The WAP Coordinator receives the
shipment (if she is not available the assessor will sign); both the WAP Coordinator and the
assessor maintain the records (whoever is available); both the WAP Coordinator and the assessor
take physical inventory. together; the WAP Coordinator reconciles the records. At the minimum
a third person must be added to the current process, the person who maintains the
PAGE 5 OF 11
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records must not take the physical inventory, and the person that reconciles the inventory must
not be the person who takes the physical inventory nor the person that maintains the records.
Reference: ARRA Contract Section 21, DOE and LIHEAP Contracts Section 17, 10
CFR 600.232.
Recommended Improvement #5: A review of CC Reeves maintenance records showed that

maintenance is being conducted in the vehicles; however the receipts are not sufficient to show
. that the vehicles are maintained on a regular maintenance schedule. Failure to implement and
maintain a maintenance schedule will result in future findings.
The Agency's cost allocation plan must be used for maintenance and gasoline expenditures,
since the three vehicles are shared by all of CC Reeves programs. The expenditures reviewed
showed that ARRA was being charged for all of the vehicles maintenance. Future vehicle
expenditures will be disallowed if the cost allocation plan is not followed. Reference: 10 CFR
600.232
Finding #3: The Agency's mileage logs cannot be adequately matched to the vehicle being
used; reimbursement for mileage, gas, and vehicle maintenance is being charged
to the Weatherization Assistance Grants however it is not clear as to how the
Agency is effectively assuring that the charges are allowable. The current
mileage logs used for gas reimbursement do not differentiate between the use of a
personal vehicle or the company car.
Action The Agency is strongly urged to purchase a vehicle for the sole use of the
Required: Weatherization Department. If the Agency still chooses not to purchase a vehicle
for Weatherization, a master mileage log must be kept in each vehicle; a separate
and different mileage reimbursement form must be used when an employee must
request a reimbursement for mileage using their personal vehicle. Under no
circumstances may the employee use the company gas card to purchase gas for
their personal vehicle even when conducting business. All gas reimbursement
expenditures must coincide with the mileage logs for the corresponding vehicle.
Each reimbursement should be kept separate per vehicle. Reference: OMB A-
122
PAGE 6 OF 11
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Finding #4: CC Reeves currently utilizes an inadequate inventory process. In order to build
and replenish CC Reeves' inventory the Agency is purchasing materials and
placing a direct charge to program support prior to determining the eligibility of
the home they will be used for. Expenditures for materials necessary to
weatherize a home are only allowable when they are needed for an income
eligible home prior to the purchase. The current procedure CC Reeves has posts
expenditures to their Program Support budget line item prior to having the eligible
household and performing the Energy Audit, thus skipping the key steps that will
determine whether expenditures are allowable.
Action C C Reeves must immediately implement a new way of charging for their
Required: inventory as it cannot be charged to Program Support until it is installed in
income eligible household. The new plan'must be submitted to the Department as
part of their response to this report. Reference: 10 CFR 440.18,10 CFR 440.21,
CFR440.22.
Finding #5: CC Reeves' procurement contracts are missing contract provisions for "Rights to
Inventiolls Made Under a Contract or Agreement" and "Prevention of Fraud and
Abuse" within their contractor contracts. The· contract with Four Seasons
Insulation is the only contract missing the "Prevention offraud and abuse" clause.
Action The agency must amend their contracts to include both of the above mentioned
Required: clauses immediately. The Agency has different formats for their contracts; the
Department recommends that the Agency implement one format so as not to
exclude any required clause. Reference: 10 TAC 5.10, OMB A-110 Appendix
A.
Note: CC Reeves conducted small purchase procurement for their materials purchase,
CC Reeves is reminded that if purchases for material will reach or exceed
$25,000,00 per vendor they must perform sealed bid procurement in order to be in
compliance with all rules and regulations.
\
Section VI. Audit
Finding #6: At the time of monitoring, the' submittal of Audit Certification to the Portfolio
Management and Compliance Division had not taken place. The audit
certification for fiscal year ending February 28, 2010 was due on April 30, 2010.
PAGE 7 OF 11
OF
Action CC Reeves must submit their audit certification letter immediately and take the
Required: appropriate steps to ensure that all future items are submitted in a timely manner.
Reference: ARRA Contract Section 20, DOE and LIHEAP Contracts Section
16.

Finding #7: A review of CC Reeves March 2010 Expenditure Report revealed a lack of
services and outreach activities in Loving County.
Action CC Reeves must serve their service area equitably, and must demonstrate that
Required: outreach efforts were done to attempt to service that county. A record of outreach
performed must be kept in order to be in compliance with serving your county
equitably. Reference: ARRA Contract Section 4
Note: The Agency has not performed any work on pre-1978 homes yet, but they are
gearing up to do so. They are beginning to create a file with all the certifications
from their staff and the contractors. In addition they need to include in this file
the training provided to other non-certified staff and all other necessary support
documentation as required by the EPA RRP Final rule. The· Department
recommends CC Reeves get at least 2 digital cameras in order to provide for
better documentation for compliance. The current Lead Certified Renovator for
the Agency is the Executive Director. Given the demands that their current
position requires and the amount of responsibility the Lead Certified Renovator
has it is imperative that a member of the Weatherization Assistance Program be
sent to attain this certification.
Finding# 8: Inadequate onsite inspections are being conducted by CC Reeves on the homes
they weatherize. The Health and Safety issues, Foundation, Floor, and Wall
measures were not adequately addressed and Carbon Monoxide testing was not
properly performed. Units with combustible appliances were not provided with a
smoke detector and carbon monoxide detector in a consistent manner.
Assessment of walls with existing insulation is not being done, and assessments
of items requiring repairs are not properly documented. There were minor ail'
infiltration measures that needed to be addressed, most however, were under the
optional air sealing category.
The onsite review also revealed that CC Reeves was not conducting thorough
final inspections of the units weatherized. Three (3) out of the six (6) units
inspected had work still needing to be completed after the stated Building
PAGE 8 OF 11
OF
Weatherization Report (BWR) work end date and after the final blower door was
performed. A return is required to three (3) out of the six (6) units inspected.
Action CC Reeves must ensure all assessors are adequately trained to perform
Required: assessments/inspections taking the whole house approach. All measures that
could be addressed in the home must be assessed. All assessment forms must be
adequately completed to reflect what the assessment of each item resulted in; if a
measure must be omitted a reaSOll why must be clearly documented. Assessments
of home with existing insulation must be physically verified by the assessor in
addition to noting the "client states there is existing insulation."
In order to ensure program compliance, CC Reeves must return an address the

units as indicated in Attachment A of this report. Reference: ARRA Contract
Section 13 B (F), Weatherization Field Guide

Finding #9: Client file review revealed inadequate support documentation for repair measures,
BWR did not mirror the Audit, charges to each grant are difficult to ascertain, and
invoice amounts do not equal the charges reflected on BWR. CC Reeves
currently tries to differentiate between the funds charged for the measure by using
the Word Bold feature to bold the amount and the grant charges. However, this
method proved inefficient as there are mismatched field throughout all of the
BWRs. An adjustment to the monoxer date and time is needed, one (I) file had
an assessment performed prior to application date being signed, and all Blower
Door Data sheets need to have the target air infiltration reduction completed
correctly.
Action CC Reeves must immediately begin to use the updated Building Weatherization
Required: Report Form and make sure all employees completing this form know how to
complete it. Each measure installed must be accounted for individually in the
BWR, all measures need to be in SIR order and must mirror the Audit. Only
items that are installed in the home must be included in the BWR. CC Reeves is
currently keeping items in the BWR that are not installed and indicating so by not
adding a charge. Invoices must clearly match the amount and measure charged to
each of the Department funded grants. CC Reeves must update the date of their
monoxer immediately in order to properly document their testing. CC Reeves is
reminded that no work may be done in a home, this includes assessments, prior to
determining eligibility. Future work done prior to determining eligibility will
result in disallowed costs. The blower door data sheet must be completed fully
PAGE 9 OF 11
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and properly, the target reduction must be determined and the building tightness
limit is not to be used as the target number for air infiltration reduction.
Reference: Texas Administrative Code §5.526, DOE and LIHEAP Contracts
Section 10, ARRA Contract Section 13, Texas Administrative Code §5.20, 10
CFR440.21

Finding#10: Inadequate income calculation was performed by CC Reeves in their denial file.
They took into account· mileage reimbursement in the income calculation for
client file ESA1889. The mileage reimbursement is for the use of the client's
personal vehicle for business and is not additional income. Income verification
was recalculated and it was determined that the client's household is income
eligible.
Action CC Reeves mustre-open the file and contact client ESAl889 to set up the date of
Required: that their assessment will take place. CC Reeves must submit to the Department
documentation verifying the client was contacted and an assessment has been
scheduled as part of their response to this report. A new application is not
required as the date of the application is March 31, 2010 thus allowing for ample
time to rectify the mistake without it requiring anything further from the client.
Reference: 10 T.A.C. §6.8, 10 T.A.C. §6.108
PAGE100Fll
OF
ATTACHMENT A
Units
Inspected
WX·AI009 ARRA No No Retum required
WX·AI004 ARRA Yes Address Flex Gas Pipe in fumace.

Address the hole in the water heater closet.
WX-AIOII ARRA Yes Additional air sealing is needed around the accordion block
around the window unit, in the water heater closet, and under the
sink in the bathroom.
I· Address the duct tape covering the holes in the floor
Initial Blower Door 1531
Final Blower Door 1428
At time ofmonitoring 1604
WX·AI002 ARRA No No Retum Required.
09RV0722 DOEILIHEAP Yes Address additional sealing in Fumace closet.

Bring all attic insulation to a R·30
09RV0723 DOEILIHEAP No No Retum Required.
PAGE 11 OF11
Texas Department of Housing and Community Affairs representatives, Rosy L. Falcon,
participated in an exit conference with Mary Jane Rios, Executive Director, Amparo Valenzuela,
WAP Coordinator, and Rose Guerrero, Fiscal.
Signature: ~~
Rosy L. Falls n, TDHCA Program Officer Date

WAP Monitoring - Part 1

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TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRS

August 12, 2010

Re: Open Records Request

If you wish to discuss this matter further, please contact me at 512/475-4743.

~.~:n- TDHCA Public Information Officer

Mr. David Zappasodi

Reo: ARRA Weatherization Assistance Program Contract #16090000746

Directory of Monitoring Sections

Section I. Financial Review

Section II. Travel and Timesheets

Section III. General Liability and Pollution Occurrence Insurance

Section IV. Property Management

Section VI. Audit

Section VII. Personnel Policies and Procedures

Section VIII. Performance Review/Onsite Inspections

Section IX. Administrative

Section X. Client FilelMultifamily Review

Section XI. Denied Files

Dates of Review: April 26, 2010 - April 29, 2010

CONTRACT NAME CONTRACT CONTRACT CONTRACT DATES

ARRA 16090000746 $1,091,787.00 9/1/2009 to 8/31/2011

On-site review of City of Arlington's implementation of the American Recovery and

The following was noted during the review:

• Lack'ofDocumentation for LSW Practices

Section I. Financial Review

CONTRACT YEAR-TO-DATE % OF ORIGINAL # UNITS # UNITS IN

ARRA $95,796.81 8.77% 35 35

Finding #1 Low Expenditures As of the March 2010 monthly expenditure reports,

A) For contracts in excess of $10,000, compliance with Executive Order

B) Utilizing ARRA funds for use in political activity and lobbying

C) Assuring legal authority to sign the contract

D) For contracts in excess of $100,000, compliance with Clean Ail' and

Section VIII. Onsite Inspections

Finding #4 Inadequate Lead Work Practice Documentation On-site unit

Finding #5 Missing Material Specifications Documentation At the time of

Section X. Client File Review

Mindy Cochran, Housing Operations Manager

Units Reviewed Comments

09WAP53 DOEARRA No No return.

09WAP3 DOEARRA No No return.

Mr. Karl R. Rabago

Re: DOE/ARRA Weatherization Assistance Program Contract #16090000753

Dear Mr. Rabago:

Cc: Mr. Marc A. Ott, City Manager

Directory of Monitoring Sections

Section I. Financial RepOlting

Section II. Travel and Timesheets

Section III. General Liability and Pollution Occurrence Insurance

Section IV. Property Management

Section VI. Audit

Section VII. Personnel Policies and Practices

,Section VIII. Perfolmance Review

Section IX. .Administration

Section XI. Denied Files

Dates of Review: May 17-20,2010

CONTRACT NAME CONTRACT CONTRACT CONTRACT DATES

DOEARRA 16090000753 $5,964,892.00 9/1/2009 to 8/31/2011

The following was noted dnring the review:

• Lack of production of weatherized units

• Lack of documentation of compliance with Weatherization Material Standards

• Income documentation was missing on two of five client files

• Files contained excess forms