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The Weatherization Assistance Program (WAP) is administered by the Department of Energy (DOE) and seeks to reduce energy costs for income-eligible households by increasing the energy efficiency of their homes. The DOE WAP program will receive $257 million dollars for FY 2018 to be funneled through all 50 states, the District of Columbia, Native American Tribes, and the five U.S. territories to local agencies that implement the program. The opportunities for using weatherization funds to address lead hazards in the home lie in using funds for health and safety measures. Up to 15% of a state’s weatherization fund can be used for eligible health and safety measures, outlined in the 2017 Weatherization Program Notice 17-7 for Weatherization Health and Safety Guidance which supersedes the WAP 11-6 Health and Safety Guidance.
According to the guidance document, WAP Grantees are allowed to perform health and safety measures if actions are needed to perform energy efficiency measures and costs of performing such measures are reasonable, as decided by DOE1. While it is not required, grantees are encouraged to budget the health and safety measures separately from energy efficiency measures so that costs for the former do not have to be cost-justified and can be excluded from cost-benefit calculations in program evaluations.2
The guidance also points out that certain measures can be classified as energy efficiency measures and health and safety measures. The official classification of such measures is determined by the savings-to-investment ratio (SIR). The SIR is used to determine whether the potential savings of the measure can justify the cost associated with performing the measure. Any measure that is completed through the WAP program must pass the cost-effectiveness test, that is the SIR must be greater than or equal to 1.3 An SIR of 1 indicates that the energy cost savings over the lifetime of the measure, discounted to present value, are equal to at a minimum the cost of materials, installation, and on-site supervisory personnel. SIR calculations are performed by DOE for every proposed measure highlighted by the energy audit in every weatherization job and any measure that does not meet the SIR equals 1 threshold cannot be completed. A measure that can be classified as energy efficiency or health and safety will be classified as an energy efficiency measure if the SIR is greater than or equal to 1.4 Otherwise, the measure will be classified as health and safety and should be budgeted accordingly.5
One case to note from the guidance document is that window and door replacements are not an allowable cost unless cost justified through an SIR calculation or the window is inoperable.6 This is unfortunate because for homes built before 1978, windows and doors (and their many components) are often at high risk for containing lead-based paint. Still, it is possible for these measures to be cost-justified since fixing windows and doors that are broken or inoperable can be an effective method of eliminating inefficiencies and saving energy. However, window and door replacements can be expensive, resulting in the likelihood that these interventions will not meet the SIR threshold for investment of WAP funds. A local policy objective that can be pursued is to advocate to the designated WAP agency in your state to adopt an SIR for lead free, Energy Star window replacement in pre-1978 properties that includes in the SIR calculation the lead poisoning prevention health benefits for the occupants of the home.
According to the guidance, addressing lead-based paint hazards is an allowable action as long as EPA’s Lead Renovation, Repair, and Painting (RRP) program rules are adhered to and weatherization crews that are working in pre-1978 housing are trained in Lead Safe Weatherization (LSW) practices.7 However, if it is determined by a certified risk assessor that addressing lead-based paint hazards could exacerbate health and safety hazards, then the weatherization job should be deferred until the hazards are safely addressed prior to weatherization work commencing.8
Local weatherization agencies can address lead-hazards in a property that is eligible for weatherization services by:
- Performing an energy audit and health and safety assessment to identify both potential energy-saving measures and potential health hazards, including the presence of lead-based paint
- Conducting any lead specific inspections or testing to determine the presence of lead-based paint hazards
- Pricing out the cost of eliminating the health and safety hazards and using health and safety funds where allowable and within the local health and safety budget or partnering with other lead hazard reduction grant programs
- Using certified and trained contractors and personnel to conduct any lead hazard reduction work in accordance with the EPA RRP Rule and any local or state lead related regulations