In my review of various post and documents, I was glad to see that " middle income" was a phrase used when speaking on qualifying. Many agencies offer various types of assistance to lower income households, leaving the working paycheck to paycheck type households to struggle. Especially with inflation rising so quickly. Thank you to whoever decided to include homeowners on the edge of "middle income". We need help with keeping our homes insulated and not energy hogs.

It looks like utilities can apply.  This concerns me since at least in Norfolk their record on effective weatherization for low-income homes is not good.  In addition, utilities have the inherent conflict of interest that they want to sell more of their product (electricity or gas).  We need to have organizations apply that have a proven record of being able to reach into, communicate and build trust with the marginalized neighborhoods — same as they are requiring applicants for the multi-family and shared solar programs to do — i.e., tell us how you are actually going to reach out to low-income folks and what proves you have the experience in doing that.  If your organization does not have that experience, you should be partnering with an organization that does.  This should be in the evaluation criteria specifically.

Certifying baseline energy usage, and measuring effects after, is very important, I am glad to see that in there.

It seems counter-productive that solar is not eligible.  GiveSolar is a great program to put solar on Habitat for Humanity houses — why couldn’t we install solar in concert with energy retrofit?  Solar is just another low-cost simple way to reduce a resident’s utility bill.  It should not be done alone, but in concert with an energy retrofit, it is an effective tool to reduce energy burden for those homes.

Eligible costs should say specifically that none of the funds can be used to advertise the program, other than to the intended applicants — that means no full-page ads in the Pilot saying what a great job they’re doing.

It seems to me that the criteria “Innovation" should not be 40% of the scoring.  This is not rocket science.  You don’t have to be innovative to get this done.  There are many simple and non-innovative ways that we could be doing this.  There are dozens of programs like this around the country – we can learn from those.  More important than innovation is that you know how to win the trust of marginalized communities who need this, so you can get it done.

I think the “Need” criteria should be higher than 30% - this is the main thrust and purpose of the program.

There needs to be a specific criteria for the organization’s ability that includes the experience and plan in terms of ability to get this done in their outreach plan.  That could be added to the current Feasibility criteria.  But to me the feasibility criteria should just include things like whether you have a good plan and have picked good buildings.  I would have a criteria specifically for Qualifications which shows that they have the knowledge and experience to get this done, including both the actual building modifications actions and also the outreach — what shows they have a plan for, and demonstrated ability in, communication and trust-building with low-wealth neighborhoods and homes and residents?

My suggestion would be Innovation 20%, Need 40%, Feasibility 20%, Qualifications 20%.

In the Occupant Satisfaction section, there should be something about Occupant utility bill decrease (if they are paying their own utility bills).  You have that listed under energy use, but none of this helps the resident if the landlord doesn’t pass on those savings.

Under Outreach, you should ask them to show an effective way they are getting the news on this out to other marginalized neighborhoods, not just presenting at conferences!  There needs to be effective communication so that this can spread.  An outcome listed is applying at scale in other projects, but there needs to be something showing how you get there in terms of gaining trust of other communities, and having the word spread in the affected communities themselves.

Observations on DHCD’s Housing Innovation Partnership Grant RfP Draft by LEAP

In general, LEAP is concerned about what could be construed as a focus on affordable housing throughout the RfP rather than energy efficiency. It manifests itself in many portions of the RfP with the most indicative example being the top line goal of energy cost savings rather than energy unit savings and/or GHG emission reductions. LEAP is also concerned that there could be bias against non-multifamily housing types and potential grant applicants that are not one of DHCD’s existing clients or WAP agencies. Most importantly though, perfection should never stand in the way of making incremental progress and LEAP does want to see the grant application process open promptly and funding made available to ensure as much energy saving can be done as soon as possible.

Summary of important concerns about the existing draft that should be addressed:

? 50% Energy Cost Savings goal may be cost-prohibitive for the much of the available
low-income housing when factoring in ROI of certain measures. A 20% energy cost
savings goal along with an additional total energy unit savings and/or home energy GHG
reduction goals should be considered.

? 10% match requirement biases towards existing DHCD grantees and ignores funding
cycles and other dynamics of potential organization types. Not requiring a match or
taking it down to 5% is suggested.

? Multifamily building-type seems to be favored over single-family detached to the
detriment of larger potential energy reductions and cost savings per household.

? Reporting and engagement requirements are overly burdensome, should be outsourced
to 3rd parties, and are narrowly focused on the housing sector instead of also
considering the energy efficiency and energy spaces also.

Observations:

50% Energy Cost Saving goal: This should be one of many energy type of savings goals which
could include total energy unit savings and/or GHG reductions. Additionally and in LEAP’s
experience, achieving a reduction in energy cost savings of 50% or more is very, very difficult in
some housing types and considering the fuel type being used. When considering switching from a fuel oil furnace to a high efficiency electric heat pump in a 50+ year old home that also needs significant insulation and air sealing, it is very possible to achieve the 50% cost savings.
However, finding something similar in other housing types and that is also cost effective (say not including $20k worth of windows) in order to hit the cost saving target would be very difficult. Thus, DHCD should reduce the energy cost saving target to 20% while adding an additional home energy GHG emission reduction target of between 20-50% depending on fuel switching would deliver important results while better addressing the climate change problem being faced.

Required 10% match: LEAP considers this to be a hardship for not only LEAP participating, but
for many other participants because of lack of access to many existing programs that DHCD
runs and/or programs that utilize the WAP territorial system such as Dominion’s income and age qualifying programs. Without being able to potentially “braid” those programs into a proposed project, it would bias proposals to those already receiving DHCD funding or access because of DHCD’s WAP territory system that hasn’t been updated in more than a decade. Municipalities budgeting cycles would make it difficult to allocate such funding for a match and have the work start before July-August of next year. Finally, utility cooperatives are already stretched thin from an ability to subsidize directly some cooperative members over others.

Multifamily building favoritism over other types of housing stock: From the proposed funding
structure (30% upfront, 60% upon major completion, and 10% on finalization), to the “feasibility” scoring criteria on “support of building owners or managers” and “identified candidate building(s)”, and usage of the purpose’s section saying the grants should only benefit “designated as affordable housing”, the RfP looks to favor multifamily types where one
multifamily building (or complex) would score higher vis-a-vis assisting rural single-family
detached and/or manufactured home owners spread out over a large municipality and/or area. Assisting single-family detached dwellings at a potentially large scale requires payment of many smaller “jobs” such as HVAC replacement that can’t wait months for payment. For that reason, the WAP pays on each job completion and not on a year’s worth of work’s completion. Such payment flexibility should also be an option. Additionally, scoring criteria needs to be analyzed against bias for single family housing stock with flexibility given to proposals that can’t identify unique addresses for 30 single family households to be served and have secured owner permission, but rather demonstrate the need and a target area for implementation. Finally, very few single-family detached homes have an affordable housing designation because they weren’t built with subsidized funding. The household’s income qualification is what should deem the home “affordable” and not if it has a DHCD designation, which only multifamily properties who previously received some kind of DHCD funding are likely to have.

Outreach and education sections: LEAP believes adding additional requirement to grantees of
preparing case studies, web pages, videos, and presenting at Housing related conferences (no
energy or energy efficiency related spaces were noted in the draft) would be overly burdensome and reduce the amount of resources of grantees to achieve the desired results. LEAP does not keep on staff a policy analyst that could assist in preparing such work and previously contracted with 3rd parties to prepare such documents and attend such events. LEAP suggests the requirement be to collect and provide information to 3rd parties such as the Virginia Center for Housing Research to prepare the case studies and reports, which should be contracted separately by DHCD for that purpose. Let the grantees focus on delivering energy saving measures and have a third party analyze and present the results.

The Proposed HIP Grant RFP attempts to create a program that seeks innovative and scalable approaches to reduce energy use in existing residential buildings. The requirement that these innovations be applied to affordable housing units or units occupied by low income households makes sense as that aligns with DHCD’s mission. However, the RFP itself could be narrowed in focus and improved in the following ways:

1. Narrow the eligible organizations or require that non-housing provider applicants submit a joint application with a housing or other nonprofit organization who owns and/or manages the affordable housing to be retrofitted (or has an existing single family housing program). This will improve the chance that the intended housing unit(s) are identified as part of the application, and that at least one of the organizations is familiar with housing and grant requirements. 
2. Clarify the income guidelines – it is unclear from the description how to determine whether a multifamily building is eligible. Would a 4% or 9% LIHTC project be eligible? Or only buildings with 100% units at or below 80% AMI?
3. If the Uniform Relocation Act requirements apply, can the grant funding be used to support the associated relocation costs?
4. LEAP submitted a comment regarding the 50% energy cost savings goal being too ambitious and suggested 20%. I would concur. There does seem to be come conflation between energy unit savings and energy cost savings. Perhaps this goal could offer two alternatives to meet the expectations.
5. Solar and Wind are identified as ineligible, but that precludes the idea that there may be some innovations within those approaches worth considering.
6. Hazardous material abatement was identified as ineligible – however, in many communities with older housing stock this could be a burden on the grant recipient if lead is included here as hazardous material.