ESBD_404455_1749755321554_Exhibit 7 - DOEHER_HEAR Narrative.pdf
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- Attached to
- Home Energy Rebates
- Solicitation number
- 907-25-1902KW
- Issued by
- Texas
About this file
This document is a Narrative Document Template for the Home Electrification and Appliance Rebates State Program (Section 50122) submitted by the State of Texas to the U.S. Department of Energy (DOE) under the State and Community Energy Programs (SCEP). The document outlines Texas's plan to implement home electrification rebates, with an estimated total administrative fund of $63,571,590.00 representing 18.48% of current formula funds, and a total rebate fund annual cost of $280,435,000.00. Texas plans to reserve a minimum of 40% of rebate funds for low-income households and 10% for multifamily households, aligning with the state's low-income population of 38.7%.
The program will utilize the DOE Rebate Tracking System and CEJST maps to identify disadvantaged communities, verify income eligibility, and process rebates. Texas intends to work with an implementation contractor to develop user interfaces, systems for rebate processing, and tools for income verification. The state will defer many specific implementation details to a future State Implementation Blueprint, which will be developed after selecting an implementor and receiving approval from the State Energy Conservation Office (SECO). The program aims to support clean energy economy transformation, provide consumer protection, and facilitate electrification projects for single-family and multifamily homes across Texas.
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Narrative Document Template
IRA Section 50122: Home Electrification & Appliance Rebates June 2024
Table of Contents Introduction
Home Electrif ication and Appliance Rebates State Programs (50122)
Use of Funds and Rebate Eligibility
Section 4.1.1 Use of Funds
Section 4.1.2 Rebate Conditions and Levels
Section 4.1.3 Low-Income Households
Section 4.1.4 Community Benefits Plan
Section 4.1.5 Processing and Delivering Rebate Funds to Eligible Rebate Recipients
Section 4.1.6 Verify Income Eligibility
Section 4.1.7 Data Collection and Evaluation
Consumer Experience
Section 4.2.1: Education and Outreach Strategy
Section 4.2.2 Qualif ied Electrif ication Projects
Section 4.2.3 Installation Incentives
Section 4.2.4 Home Assessments
Section 4.2.5 Consumer Protection Through Quality Assurance
Requirements to Maximize Rebate Impact
Section 4.3.1 Supporting the Clean Energy Economy Through Market Transformation ... 16
Section 4.3.2 Integrating with Other Programs
Section 4.3.3 Quick Starts
VERSION 2
Published on June 27, 2024
Modification Note: This version updates text in accordance with the Version 2 modifications of the Program Requirements & Application Instructions. This version makes clerical fixes, including reference corrections. Changes are highlighted in the text in yellow.
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Introduction
This is an optional document that is not required by the ALRD. A state may use this to submit their ALRD 2 State Application.
This Narrative Document should demonstrate the state’s ability and intent to implement the program in accordance with the requirements of the ALRD and the Program Requirements document. The Narrative Document must provide a comprehensive framework and description of all aspects of the proposed rebate program(s). States may use existing programs/infrastructure to implement this work. States may not provide these funds to existing programs to implement non-rebate work.
The Narrative Document must be succinct, self-explanatory, and well-organized so that DOE reviewers can understand program design and delivery. A state must address the following in its application package and corresponding Standard Form 424 Application for Federal Assistance, Standard Form 424A Budget Information, and Budget Justification Workbook. A state may defer some responses to its State Implementation Blueprint, to be provided to DOE after award but prior to program launch. The questions are marked as such, and applicants should check the appropriate box if deferring their response. All other requirements are mandatory within the state application package. If there is no box offering the “Defer response to State
Implementation Blueprint” option, then it is required as part of the application package.
Identify whether the application is for a Quick Start program.
☐ Yes, this is for a Quick Start Program.
☒ No, this is not for a Quick Start Program.
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Home Electrification and Appliance Rebates State Programs
(50122)
Use of Funds and Rebate Eligibility
Section 4.1.1 Use of Funds
1. Please provide the types of allowable costs the state proposes within each category of administrative funds and rebate funds within those categories.
Note: These responses should correspond with the Standard Form 424, Standard Form 424A, and Budget Justification Workbook.
Texas plans to use administrative funds to cover the following types of activities. In sum, these estimated administrative funds total of $63,571,590.00 or 18.48% of the current formula funds for Texas for HOMES and are inclusive of the early administrative funds already awarded for a total administrative fund annual cost of $10,595,265.00 (see also 1.a below).
• Program planning and design $2,292782.75 or $16.30 per project.
o The State Energy Conservation Office (SECO) will contract with an organization with expertise in designing and delivering efficiency programs, with proven success in market uptake, sound installations, income verification, and delivering benefits to low-income households. Depending on the initial organization’s experience reaching disadvantaged communities, the state may contract with another organization better suited to addressing this need.
• SECO program staff for $4,763,794.50 or $33.86 per project.
o SECO plans to hire four (4) full-time staff members, with the intent that two
(2) staff members time will be split amongst the 50121 and 50122 awards. Our accounting systems can separately track these different funding sources and internal policies are in place to ensure the time is accurately tracked.
o Development of tools and systems for program administration, including websites, applications, rebate processing, and reporting for $6,410,00.00 or $45.56 per project.
o Texas plans to fund a program implementation contractor or a separate qualified entity to develop user interfaces and systems for households, contractors, and others to use to apply for rebates, submit required documentation, etc., including income verification.
o Depending on the interest of other state agencies with low-income programs, the state may also fund an IT firm to develop an application programming interface (API) that allows several low-income programs to automatically share information regarding their enrollees, thereby substantially expediting income verification.
• Program evaluation and consumer satisfaction surveys for $1,400,000.00 or $9.95 per project.
o SECO will conduct the required customer satisfaction questions included in the program requirements. The state is also planning to conduct a process and impact evaluation, which is described in question 44.
• Program monitoring and audits for $3,600,000.00 or $25.59 per project o In addition to state staff monitoring program delivery and overseeing the implementation contractor(s), the state may require outside assistance to respond to state or federal inquiries. The implementation contractor(s) and other providers
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(e.g., income verification services) will also be required to fulfill data reporting and analysis per the contract(s).
o Consumer protection functions including resolution procedures, data review, contractor management, installation standards, continuous improvement for $4,125,000.00 or $29.32 per project.
o In response to findings from periodic assessments of program performance (as well as any identified problems that arise throughout implementation), the state or its implementation contractor(s) will institute changes to address deficiencies in program delivery (or design).
o SECO will develop consumer protection guides or one-pagers that will be provided to all rebate applicants as one part of the consumer protection strategy.
o SECO created a dedicated email address SECO.Rebates@cpa.texas.gov and state staff are dedicated to respond to consumer questions and/or complaints.
o SECO staff will fulfill contractor management needs with regular reviews of program implementer/other contractor data submissions.
• Marketing, education, and outreach, including the funding of local governments and place-based organizations to assist with these activities for $4,080,000.00 or $29.00 per project.
o SECO Held two community engagement sessions on August 27, 2024, and additional sessions are planned as the program design matures.
o SECO will conduct separate outreach to retailers, manufacturers, and distributors.
o SECO, potentially with assistance from its implementation contractors or outside experts and partners, will develop marketing and education information for homeowners, tenants, retailers, contractors, and others as needed.
• Implementation contract cost not including rebates and costs for activities directly related to rebate for $63,571,590.00 or $451.83 per project.
o The implementation contractor(s) will use administrative funds for data review and reporting, and to fulfill other programmatic management requirements.
o SECO oversight of implementation contractor and other service provider costs/contract management; data review and reporting.
• Contractor training for $2,650,000.00 or $18.83 per project.
o Contractor training and/or review of a contractor’s certification(s) will be required before a contractor is placed on the qualified contractor list.
o Training specifically to assist contractors in participating in the rebate program.
• Activities to improve access to rebates, facilitating leverage of private funds and financing mechanisms (e.g., loan loss reserves, interest rate reductions) where beneficial to efficiency and/or electrification projects for $11,055,012.50 or $78.57 per project.
o Depending on availability of resources, the state will engage financing organizations (e.g., green banks) to assist in making low-cost financing (or other incentives including the potential to establish and apply loan loss reserves) available to rebate applicants and providers (e.g., contractors).
• Technical assistance for $4,000,000.00 or $28.43.
o Depending on availability of resources, SECO and/or its implementation contractor(s) may provide technical assistance either directly or through specialized organizations to assist entities focused on serving disadvantaged communities and/or other priorities.
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Texas certifies that costs will not be duplicated on the Home Efficiency Rebates (Section 50122) award, or other awards, and are not duplicative from costs captured in the Indirect Rates.
Texas plans to use rebate funds to cover the following types of activities, for a total rebate fund annual cost of $280,435,000.00 or $1,993.17 per project.
a. Provide the total amount of estimated administrative funds to be expended annually:
$10,595,265.00 based on $63,571,590.00 divided by six (6) years. September 1, 2025, through September 30, 2031.
b. The total amount of estimated project-related costs as a portion of the rebate funds to be expended annually.
c. If requesting additional funds for project-related activities, describe and justify each activity and associated budget in the budget justification worksheet as well as below.
N/A
d. Confirm that the state will have a process for handling returns of rebated items as applicable in the Consumer Protection Plan.
☒ Yes, the state confirms the above statement.
Section 4.1.2 Rebate Conditions and Levels
e. Describe how the state will manage and ensure that rebate minimums and administrative maximums are adhered to over the duration of the program.
DOE Rebate Tracking System
Texas plans to use DOE-approved tools and systems to track recipient rebate statuses, work within established program spending limits, minimize costs and errors, maintain databases, and ensure rebate amounts comply with program requirements. Texas is motivated to utilize resources that provide real-time data and reporting to maintain program quality and efficiency. The details for what specific methods Texas will employ will be included in the State Implementation Blueprint.
Administrative Controls Texas understands the importance of developing methods to ensure administrative maximums are adhered to over the duration of the program. Once an Implementor is selected, the State Energy Conservation Office (SECO) will approve forecasting tools and accounting practices in order to reduce administrative costs where possible. Texas will closely track and report this spending bucket as well as rebate funds and contractor incentive funds and aims to follow Generally Accepted Accounting Principles and conduct internal audits. These expectations will be extended to the selected Implementor and will be included in the Blueprint following SECO approval.
f. Describe how the state will monitor contractor costs and ensure that costs are not artificially inflated compared with market averages.
Texas plans to closely monitor contractor costs through program participation requirements, risk-based and/or randomly selected project audits, and a Corrective Action Plan that will establish
$0.00
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remedies for qualified contractors not adhering to market averages or other instances of noncompliance. The Corrective Action Plan will include measures such as requiring contractors to increase or improve their reporting, refunding of rebate funds, and as well as corrections for improper costing to end-users. The selected Implementor will provide more details in the Blueprint and Consumer Protection Plan with the processes approved by SECO.
g. Identify the maximum rebate amounts that will be offered to eligible entities and eligible entity representatives if lower than the allowed amounts.
Texas plans to use the maximum rebate amounts allowed by federal law (as defined in Table 7 of the Program Requirements and Application Instructions document) but reserves the right to alter rebate amounts based on participation of eligible participants and real-world program implementation. The details for exact rebate amounts to eligible actors will be included in the Blueprint after the Implementor is selected for Texas and the process is approved by SECO.
h. Identify the maximum allowable project costs for determining project cost rebate levels.
Texas plans to use the maximum allowable project costs allowed by federal law (as defined in Table 7 of the Program Requirements and Application Instructions document) but reserves the right to adjust allowable project costs with DOE approval and Implementor-guidance. The details for how Texas will determine project cost rebate levels will be included in the Blueprint after the Implementor is selected for Texas and the process is approved by SECO.
i. Describe the documentation requirements related to project costs from eligible entities and eligible entity representatives.
For each project, the eligible entity or eligible entity representative must provide an invoice with (at a minimum) the following information:
• Line-item costs of rebated equipment and materials
• Model numbers
• Labor costs of specific work performed and any onsite pre-assessment work
• Contractor name and contact information
• Dates of work performed
• Total project costs prior to rebate and rebate amount
• Other project costs (as applicable)
Texas will detail any additional project cost proof requirements in the Blueprint after the Implementor is selected for Texas and the process is approved by SECO.
j. List the installation incentives the state will provide eligible entity representatives for each eligible product or service up to $500 (in total).
Texas will use the federal maximum incentive amounts allowed for qualifying activities (as defined in Table 9 in the Program Requirements and Application Instructions document) and will further detail Texas’ approach to installation incentives in the Blueprint after an Implementor is selected and the method is approved by SECO.
k. Describe the approach for ensuring that eligible entities will not receive multiple federal rebates or grants for the same Qualified Electrification Project (QEP).
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Texas plans to use the DOE Rebate Tracking System to safeguard against duplicative rebates for the same product and households. Texas plans to utilize the system to query a database to see if the specific type of rebate has already been issued for that address when an eligible entity or eligible entity representative applies to reserve a rebate. If a rebate has already been issued, the request will be rejected, and the applicant will be informed. Texas plans to have a resolution process for applicant disputes and will include this process and protections against multiple rebate awards in the Blueprint after the Implementor is selected and the process is approved by SECO.
l. Confirm that the state will provide information via API or DOE-provided spreadsheet to the
DOE central database to ensure that rebates limited to a single or a combination of products are tracked and managed, and no duplicate rebates are awarded.
☒ State will provide information via API.
☐ State will provide information via a DOE-provided spreadsheet.
m. Describe how the state will approach providing rebates to multifamily building owners and qualified households who live in multifamily units.
☒ Defer response to State Implementation Blueprint.
Texas will encourage and facilitate 50122 rebates access to various types of eligible recipients and multifamily households. The details for how Texas will approach providing rebates to multifamily building owners and qualified multifamily unit households will be included in the Blueprint after the Implementor for Texas is selected and the process is approved by SECO.
n. Identify the date after which upgrade projects must be completed for the purposes of being eligible for a rebate under the state program.
Qualified electrification projects (QEP) must be initiated after Texas receives DOE approval for program launch, i.e., retroactive rebates will not be applicable. Specific timelines, coupon details, and contractor deadlines will be included in the Blueprint after the Implementor for Texas is selected and the process is approved by SECO.
o. Describe how eligible rebate recipients will be informed of additional program funding available from non-federal funds and grants.
Eligible rebate recipients will be informed by a variety of means, including, but not limited to, contractor marketing, mail, emails, retailer placements, and local organization involvement. The Education and Outreach Plan will be critical in designing effective workflows to properly inform eligible recipients; this will be included in the Blueprint after the Implementor for Texas is selected and the process is approved by SECO.
Section 4.1.3 Low-Income Households
p. Identify the portion of the rebate funds the state will reserve for low-income and low-income multifamily households.
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Texas plans to reserve, at a minimum, 40% and 10% of rebate funds for low-income households and multifamily households, respectively. 40% meets and exceeds the percentage of low -income households in Texas, which is 38.7% as reflected in Program Requirements Table 13.
q. Provide a brief description of the procedures and penalties the state will provide to ensure that renters are not subject to unjustified rent increases.
In accordance with Program Requirements, Texas will require building owners to sign renter protection agreements which will mandate that the owner, at a minimum, cannot evict a tenant to obtain a higher paying tenant after improvements are completed and/or cannot increase the rent as a result of the energy improvements outside of specified expenses. If the owner does not comply, rebate refunds, fines/penalties, legal fees, etc. are all possible penalties Texas will issue to owners. Further details and procedures will be included in the Blueprint after the Implementor for Texas is selected and the process is approved by SECO.
r. Describe how the state program will define a disadvantaged community. If not using the default disadvantaged community definition of low-income households located in a disadvantaged community identified by the CEJST, a state must explain how the proposed definition will meet the following three criteria as described in DOE J40 implementation guidance:1
• The communities of concern identified by the state tool or definition must conform to the definition of communities established in U.S. Office of Management and Budget
(OMB) guidance:
o a group of individuals living in geographic proximity to one another that experiences common conditions.
o a geographically dispersed set of individuals (such as migrant workers or
Native Americans) that experiences common conditions.
• The state tool or definition must consider two or more of the following indicato rs when identifying communities that should be classified as disadvantaged for the purposes of directing federal investments under Justice40:
o Low income, high and/or persistent poverty o High unemployment and underemployment o Racial and ethnic residential segregation, particularly where the segregation stems from discrimination by government entities o Linguistic isolation o High housing cost burden and substandard housing o Distressed neighborhoods o High transportation cost burden and/or low transportation access o Disproportionate environmental stressor burden and high cumulative impacts o Limited water and sanitation access and affordability o Disproportionate impacts from climate change o High energy cost burden and low energy access
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o Jobs lost through the energy transition o Access to healthcare
• The communities of concern identified by the state tool or definition must be currently mapped in software or must be easily overlayed in GIS so that communities can be easily identified by stakeholders.
Texas will use the DOE-provided definition of disadvantaged communities and use the federally issued CEJST map to identify disadvantaged communities.
s. Identify the tool(s) the state will provide for eligible entity representatives to identify households that qualify for the installer incentive available for work in disadvantaged communities.
Texas will provide contractors location-specific data to determine if an address qualifies for the disadvantaged community incentive. Texas will be using the DOE Rebate Tracking System and the CEJST to identify disadvantaged communities. Any additional tools and details will be included in the Blueprint after the Implementor for Texas is selected and the process is approved by SECO.
t. Confirm that the state’s intake system for users to provide income information will compare household income to 80% and 150% AMI values associated with that household's county and household size to determine rebate levels prior to signing statements regarding their income.
Texas plans to use the DOE provided API to compare an applicant’s household income, occupancy number, and address to the appropriate AMI level (80% or 150% AMI) to determine income eligibility and rebate levels prior to signing statements regarding their income.
u. If the state does NOT intend to use a federally provided web-based tool to determine whether a home is in a disadvantaged community, confirm that the state will provide the
ZIP codes or a preferred more granular geography (e.g., census tract) with all disadvantaged communities as defined by the state to the DOE system.
☐ Yes, the state confirms the above statement.
☒ N/A. The state will use a federally provided web-based tool to determine whether a home is in a disadvantaged community.
Section 4.1.4 Community Benefits Plan
v. Confirm that the state will develop and submit a Community Benefits Plan prior to program launch.
☒ Yes, the state confirms the above statement.
Section 4.1.5 Processing and Delivering Rebate Funds to Eligible Rebate Recipients
w. Describe what types of systems will be put into place to allow effective processing of rebates, including ensuring the ability to apply rebates at point of sale and/or as part of an invoice. And confirm that the system will link to federally provided systems via API.
☒ Yes, the system will link to federally provided systems via API OR information will be
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sent as part of DOE-provided spreadsheet.
☐ Defer response to State Implementation Blueprint.
x. Describe how the state will ensure processing of rebates within 4 weeks of receipt (e.g., through a processing company, through program implementers, or other entities or methods). Include information on corrective actions that the state will implement in the event of lengthier processing times.
Texas will use an Implementor to carry out rebate processing. The state will require rebate processing to occur within 4 weeks or shorter of receipt of required and acceptable information and require the Implementor to develop a method for obtaining updates on processing times.
Should processing time exceed those detailed above, the Implementor will institute a resolution plan. Details of this process will be further explained in the Blueprint.
y. Describe how the proposed processing system will be integrated with a system for processing rebates under Section 50121. Note if the state plans to use separate systems.
☐ N/A State is not planning to run 50121.
Texas plans to work with an Implementor to develop an effective, integrated system for processing rebates both under Section 50121 and Section 50122 and apply the DOE/PNNL provided workflows as approved by SECO. Further details regarding the rebate processing system will be included in the Blueprint after the Implementor is selected and the system is approved by
SECO.
Section 4.1.6 Verify Income Eligibility
z. Describe how the state will define household income for verification purposes.
Texas will use categorical eligibility to establish participation eligibility in the program. In the case of auditing or monitoring the effectiveness of the program, Texas will define household income as cash receipts earned and/or received by all Household members 18 years of age and older before taxes during applicable tax year(s), but not the excluded income listed in subsection Texas Administrative Code Title 10, Part 1, Chapter 6, Subchapter A, Rule §6.4. Income will be based on the Gross Annual Income.
aa. For single-family households, how will claimants be able to establish their household income for income qualification? States may select from the following options:
☒ Documentation of household income (for example, 1040)
☒ Documentation of enrollment in a pre-qualifying program
☐ Self-attestation of income level
☐ Self-attestation of enrollment in a pre-qualifying program
Texas’ selected Implementor will apply a variety of means to verify categorical enrollment which may include visual review of documentation, technological automation, and communication with the programs. Further details will be included in the Blueprint.
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Listed below are the following programs Texas is considering (at a minimum) to allow categorical eligibility (Tables A-3 and A-4 in DOE-provided appendix):
• Medicaid
• Supplemental Nutrition Assistance Program (SNAP)
• Head Start
• Lifeline Support for Affordable Communications (Lifeline)
• Food Distribution Program on Indian Reservations (FDPIR)
• National School Lunch Program – Free (NSLP)
• Housing Improvement Program (HIP)
• Housing Opportunities for Persons with AIDS
• Supplemental Security Income (SSI)
• Weatherization Assistance Program (WAP)
• Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
• Verified government or non-profit program serving Asset Limited income Constrained
Employees (ALICE) persons or households
• For multifamily buildings:
▪ Public Housing (housing owned and operated by Public Housing Authorities)
▪ Privately-owned multifamily buildings receiving project-based assistance (Section 8, Section 202, Section 811)
▪ Privately-owned multifamily buildings that house residents receiving tenant-based assistance
• Section 42 Low Income Housing Tax Credit (LIHTC)
The Implementor will confirm this list with SECO approval.
bb. For multifamily buildings, describe what combination of methods will be used to verify that at least 50% of dwelling units consist of households with incomes less than 80% AMI.
Provide documentation that demonstrates that one of the following categories applies to 50% of the units in the multifamily building:
• Public Housing (housing owned and operated by Public Housing Authorities)
• Privately owned multifamily buildings receiving project-based assistance (Section 8, Section
202, Section 811)
• Privately-owned multifamily buildings that house residents receiving tenant-based assistance
• Section 42 Low Income Housing Tax Credit (LIHTC)
These programs align with what is outlined in the federal guidance. ODOE may add additional state programs in the Implementation Blueprint. For buildings that are not qualified for a pre-existing program, applicants will have to provide household income documentation for at least 50% of dwelling units impacted by the upgrade. Tenants must be given the option to submit this information directly to the implementer, without having to disclose this information to the building owner or contractor.
a. For multifamily buildings, describe what combination of methods will be used to verify that at least 50% of dwelling units consist of households with incomes less than 150% AMI (but not less than 80% AMI).
Unless the building pre-qualifies as a low-income property, applicants will be required to have at least 50% of dwelling units impacted by the upgrade submit household income documentation.
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cc. Confirm the following:
• Claimant will be required to note the number of individuals who occupy the dwelling unit.
• Claimant will be required to sign a statement affidavit attesting to the validity of all information provided (e.g., enrollment documents, household income, number of full-time occupants) irrespective of the method of income qualification (e.g., categorical eligibility, self-attestation).
☒ Yes, the state confirms the above statements.
dd. Describe how the 80% AMI and 150% AMI levels for each location will be kept up-to- date and linked to DOE systems. Provide additional information if proposing NOT to use a federally provided link or API.
☒ Defer response to State Implementation Blueprint.
Confirm that these levels will correspond to:
• The address of the home at which rebates will be applied
• The applicable number of household occupants
☒ Yes, the state confirms the above statements.
Texas plans to use the DOE provided API to compare an applicant’s household income, occupancy number, and address to the appropriate 80% or 150% AMI level to determine income eligibility and level of rebate.
ee. Confirm that the state will do the following:
• Review information provided to support income eligibility for all applicants applying for rebates;
☒ Yes, the state confirms the above statement.
• Take steps to verify income eligibility for all applications (100%) that use self-attestation to support income eligibility (e.g., confirm enrollment in at least one program that the applicant asserted enrollment in; confirm household income via
IVES; calls to employers);
☒ Yes, the state confirms the above statement.
• After six months and not longer than one year after program launch, report to DOE the percentage and number of applicants that received rebates but were subsequently found to not meet eligibility requirements; and
☒ Yes, the state confirms the above statement.
• Work with the state's DOE project officer to institute additional safeguards or determine if a lesser level of review for applicants using self -attestation is justified depending on the percentage/number of rebates issued without meeting eligibility requirements.
☒ Yes, the state confirms all the statement.
If applicable, propose the types of information that the state will provide to DOE to warrant reducing these requirements (e.g., allowing implementers to verify income of a
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subset of claimants through random sampling).
☒ N/A. The state will not reduce this requirement.
ff. Provide additional information as needed to demonstrate that the proposed approaches for income verification will address all types of households; not create undue burden for claimants; and include safeguards to minimize error and abuse in the process of verifying income.
Texas is aware of the importance of verifying income of recipients for program integrity and that guardrails need to be implemented. Equally as important, though, is the ease of applying to the program and not creating an unnecessary burden to applicants that may be a barrier to the application process. Texas is looking into the balance of these two needs to understand what approach will suit the need of Texas. The details for how, when, and what exact items Texas will require to verify income will be included in the Blueprint after the Implementor for Texas is
gg. Describe how the state will verify (confirm legitimacy) of income information for all claimants (e.g., verification within 2 days through IRS, cross-check with enrollment databases of approved programs, calls to employers). If applicable, a state may propose the types of information that it will provide to DOE to warrant reducing this requirement
(e.g., allowing implementers to verify income of a subset of claimants through random sampling).
As stated in the proposed response to question 25, Texas is aware of the importance of verifying income of recipients for program integrity and that guardrails need to be implemented. Equally as important, though, is the ease of applying to the program and not creating an unnecessary burden to applicants that may be a barrier to the application process. Many of the approaches to verify income are resource intensive and Texas is looking into the balance of these needs to understand what approach will suit the need of Texas. The selected Implementor will provide more details of the income verification requirements in The State Implementation Blueprint with the processes approved by SECO.
hh. Identify how the state will resolve instances when rebates are provided to those who have falsified their incomes.
☒ Defer response to State Implementation Blueprint.
If Texas determines that a rebate recipient has provided falsified income information, a variety of correction procedures may be utilized, including, but not limited to, cancelling the rebate coupon, inform the applicant of cancellation, and/or request a refund. More details will be included in the Blueprint after the Implementor is selected and the process is approved by SECO.
ii. If proposing to allow self-attestation as a means for initial income qualification, provide a
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detailed description of how and when this approach will be used. Include statements, language, and detailed information regarding follow-up steps that will be used for this process. Additional topics to address include:
• Describe how those applying for rebates will be warned of potential liability associated with falsifying information.
• Explain how signed statements of self-attestation will be securely stored.
• Identify what level of falsified attestations will signal that the system needs to shut down either permanently or be restarted only after sufficient improvements.
☒ N/A. The state has chosen not to allow self-attestation.
jj. Describe how the state program will verify, where applicable, that at least one member of a household has been enrolled in a program within the Federal Programs Approved for Categorical Eligibility document, or other state-proposed program approved by DOE, within the prior 12 months.
The selected Implementor will apply a variety of means to verify categorical enrollment which may include visual review of documentation, technological automation, and communication with the programs. If verification documentation is insufficient or unclear, Texas will have a review process to investigate further into eligibility determination. The details for this process will be included in the Blueprint after the Implementor is selected and the process is approved by SECO.
kk. Identify the federal or other programs by which the state plans to allow categorical eligibility.
Texas’ selected Implementor will confirm this list with SECO approval. Listed below are the following programs Texas is considering (at a minimum) to allow categorical eligibility (Tables A-3 and A-4 in DOE-provided appendix):
• Low Income Home Energy Assistance Program (LIHEAP)
• Medicaid
• Supplemental Nutrition Assistance Program (SNAP)
• Head Start
• Lifeline Support for Affordable Communications (Lifeline)
• Food Distribution Program on Indian Reservations (FDPIR)
• National School Lunch Program – Free (NSLP)
• Housing Improvement Program (HIP)
• Housing Opportunities for Persons with AIDS
• Supplemental Security Income (SSI)
• Weatherization Assistance Program (WAP)
• Special Supplemental Nutrition Program for Women, Infants, and Children
(WIC)
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• Verified government or non-profit program serving Asset Limited income Constrained Employees (ALICE) persons or households
• For multifamily buildings:
o Public Housing (housing owned and operated by Public Housing Authorities) o Privately-owned multifamily buildings receiving project-based assistance (Section 8, Section 202, Section 811) o Privately-owned multifamily buildings that house residents receiving tenant-based assistance o Section 42 Low Income Housing Tax Credit (LIHTC)
ll. If applicable, propose any additional federal and other programs to be considered for categorical eligibility. For any programs not already approved, describe how the program’s eligibility aligns with the Section 50122 income requirements (Section 4.1.6 of the Program
Requirements & Application Instructions).
☐ Defer response to State Implementation Blueprint.
☒ N/A. The state will not propose additional federal or other programs to be considered for categorical eligibility.
mm. Identify whether the state requests authorization to allow use of categorical eligibility determinations based on program participation outside of a one -year period (e.g., proof of enrollment within the past 12 months). If so, explain the state’s proposal and describe the rationale.
☐ Yes, the state requests authorization to allow use of categorical eligibility.
determinations based on program participation outside of a one -year period. (Explain the state’s proposal and describe the rationale.)
☐ No, the state will only allow for categorical eligibility determinations based on program participation within a one-year period.
Texas is inclined to only allow for categorical eligibility determinations based on program participation within a one-year period but will be deferring the decision to the Blueprint to include Implementor guidance and allow for program changes based on need and participation.
nn. Identify whether the state requests authorization to allow categorical eligibility for a program in a way that is not consistent with the “level of categorical eligibility” listed in the document Federal Programs Approved for Categorical Eligibility. For each deviation requested, propose, and provide documentation to justify the requested change.
Documentation must demonstrate that the state imposes income requirements equivalent to or less than 80% AMI.
Defer response to State Implementation Blueprint.
☒ N/A. The state will not allow categorical eligibility for a program in a way that is not consistent with the “level of categorical eligibility” listed in the document Federal
Programs Approved for Categorical Eligibility.
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Section 4.1.7 Data Collection and Evaluation
oo. Explain how data will be protected, specifically addressing security measures and privacy measures.
Texas understands the importance of data protection and will extend expectations to the selected Implementor and program team. Per program requirements, the state will not sell any collected data and will retain data and records for at least 3 years after the state submits the final expenditure report to DOE. More details of security and privacy measures will be addressed in the Blueprint after Texas selects an Implementor and the process is approved by SECO.
pp. Include documentation of the processes to monitor, identify, and address security and privacy threats.
Texas will include details, such as data monitoring methods, privacy/data breach remedies, contractor and Implementor data security expectations, in the Privacy and Security Risk Assessment which will be included in the Blueprint.
qq. Certify that the state will submit a Privacy and Security Risk Assessment in the State
Implementation Blueprint.
☐ Yes, the state confirms the above statement and will include it with this narrative document.
☒ Yes, the state confirms the above statement but defers a response to State
Implementation Blueprint.
Texas understands the importance of privacy protection and implementing a quality Security Risk Assessment will ensure personal data and other protected information are protected. Texas will extend expectations to the selected Implementor, and the details of The Security Risk Assessment will be included in the Blueprint after Texas selects an Implementor and the process is approved by SECO.
rr. Confirm that the state will collect required data and cooperate in program evaluation processes as listed in Section 4.1.7.2 of the Program Requirements & Application
Instructions.
☒ Yes, the state confirms the above statement.
ss. Confirm that the state will gain access to billing data when requested by DOE for program requirements and program evaluation.
☒ Yes, the state confirms the above statement.
Describe how the state will gain access to billing data when requested by DOE for
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program evaluation.
Texas will initiate work on utility data sharing agreements and has already engaged with Texas utilities. Texas will require rebate applicants to state in their reservation whether they consent for Texas to access their billing data through data sharing agreements we have established with utilities. Consent will be a requirement for all participants. Texas will provide more detail on this in the State Implementation Blueprint.
tt. Confirm whether the state is planning to conduct its own evaluation, and if so, what type(s) of evaluations.
☐ Yes, the state will conduct its own evaluation. (Describe below).
☒ No, the state will participate in the DOE-led impact and evaluation process.
If yes, what type(s) of evaluations. If no, leave blank.
If the state plans to conduct evaluations on its programs, confirm that the state will:
• Cooperate with DOE to meet the requirements listed in Section 4.1.7.2 of the
Program Requirements & Application Instructions.
☒ Yes, the state agrees to meet the evaluation requirements.
• Submit an evaluation plan for DOE review within three months of program launch.
☒ Yes, the state will submit an evaluation plan within three months of program launch.
• Provide results to DOE.
☒ Yes, the state will provide results to DOE.
uu. If the state plans to conduct evaluations on its programs, describe the evaluation objectives, high level work plan, and timing of the evaluations and whether the state would request to be excluded from DOE-led evaluations.
☐ Yes, the state agrees to meet the evaluation requirements.
☒ N/A. The state will not conduct its own evaluation.
Consumer Experience
Section 4.2.1: Education and Outreach Strategy
vv. Confirm that the state will develop and submit an Education and Outreach
Strategy consistent with Section 4.2.1 of the Program Requirements & Application
Instructions.
☒ Yes, the state confirms the above statement.
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Section 4.2.2 Qualified Electrification Projects
ww. Describe how the state will verify that rebates are provided only for qualified electrification projects, including that each of the following conditions are met for each project:
• Project includes the purchase and installation of a qualifying product, as described in Section 4.2.2 of the Program Requirements & Application Instructions
• The qualifying product is installed as part of new construction; or to replace a non-electric appliance; or as a first-time purchase with respect to that appliance
• The installation occurs at a single-family home or eligible multifamily building
Texas will use the DOE-approved tracking system. In conjunction with the selected Implementor, Texas will ensure coupons are only generated for QEPs. If selected retailers choose to use the API, they will be responsible for only accepting coupons applied to qualifying products. All other retailers will be informed through retailer outreach of qualifying products and coupon details.
Other details regarding QEP verification will be included in the Blueprint after the Implementor is
xx. Describe how the state will collect and retain documentation to demonstrate how each criterion in Section 4.2.2 of the Program Requirements & Application Instructions was met for each installation.
Texas will use the DOE Rebate Tracking System to collect and report required information. Texas will also require documentation and geotagged photos prior to reimbursement. There will be different requirements and processes for QEPs and point-of-sale purchasing, and Texas will establish a quality assurance process to randomly audit the processes. Further detail will be included in the Blueprint after the Implementor is selected and the process is approved by SECO.
yy. If applicable, identify any additional types of “materials to improve ventilation” that the state plans to make eligible for rebates.
Defer response to State Implementation Blueprint.
☒ N/A. The state will not include any additional types of “materials to improve ventilation” in the rebates.
Section 4.2.3 Installation Incentives
zz. Describe how eligible entity representatives will be determined to be eligible for installation incentives, and how and when incentives will be paid.
Texas will use the DOE Rebate Tracking System to establish and manage requirements for coupons. More detail regarding incentives payout timelines and structures will be included in the Blueprint after the Implementor is selected and the process is approved by SECO.
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aaa. Confirm that the state program will provide a clear incentive schedule commensurate with the scale of the upgrades installed not to exceed the maximum allowable values.
☒ Yes, the state confirms the above statement.
bbb. Describe what tool(s) the state will provide for eligible entity representatives to identify households that qualify for an installer incentive for substantial installation located within a disadvantaged community.
Texas will use the DOE Rebate Tracking System and will use the CEJST maps to identify disadvantaged communities.
ccc. Confirm that the state program will automatically provide the incentive to eligible entity representatives in an amount not to exceed $500 per dwelling unit or multifamily building in a 12-month period.
☒ Yes, the state confirms the above statement.
Section 4.2.4 Home Assessments ddd. Determine and describe a pre-defined set of home pre-condition(s) and/or scope of work scenario(s) that will constitute unacceptable risk of raising utility bills.
☒ Defer response to State Implementation Blueprint.
Texas will work with the selected Implementor to select a tool that will assess utility bill impact based on the following criteria (at a minimum):
• Building age, size, climate, level of insulation, and level of air sealing/duct sealing
• Existing fuel type and if the home is switching from gas to electric
• Cost of existing fuel and cost of the fuel used after replacement
• Average annual energy use of home and anticipated energy use after installation
More detail as to home assessment guidelines will be provided in the Blueprint by the Implementor with SECO approval.
eee. Identify if the state will allow remote or virtual assessments in place of field-based assessments in cases of limited home assessments and if so, describe process.
☒ Yes, the state will allow remote or virtual assessments (describe below).
No, the state will not allow remote or virtual assessments.
Texas will allow remote or virtual home assessments prior to installation of any qualified 50122 projects. Various requirements, both on the part of the contractor and the eligible entity, will be developed by Texas and the Implementor. Texas will regularly assess the process for remote/virtual assessments pending real-world program implementation and user effectiveness. Further detail will be provided in the Blueprint after the Implementor is fff. Describe what processes will be put in place for home energy assessments for multifamily buildings, including for energy used by common areas.
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Texas will work with the selected Implementor to develop additional requirements/guidelines that will be included in the home assessment procedure for multifamily buildings, specifically requirements regarding common areas. These procedures will be included in the Blueprint with SECO approval.
Section 4.2.5 Consumer Protection Through Quality Assurance ggg. Confirm that the state will prepare and implement a Consumer Protection Plan in accordance with these requirements in Section 4.2.5 of the Program Requirements &
Application Instructions.
☒ Yes, the state confirms the above statement.
Requirements to Maximize Rebate Impact
Section 4.3.1 Supporting the Clean Energy Economy Through Market Transformation hhh. Certify that the state will prepare and implement a Market Transformation Plan within the first year after receiving the financial assistance award.
☒ Yes, the state confirms the above statement and will provide the plan with this narrative document.
Section 4.3.2 Integrating with Other Programs
iii. Identify whether the state plans to take proactive steps to encourage integration with other programs. If so, identify with which programs the state will actively seek to integrate. The state may include letters of support or other indicators of commitment from existing program partners. If the state does not plan to integrate the rebates into any existing programs, note this as “not applicable” within the application. Applications should identify whether programs will be integrated in any or the following areas:
• Integration into existing program administration, website, materials.
• Adoption of existing program standards, quality assurance (QA), workforce standards, or other practices.
• Braiding or co-funding of upgrades within individual households.
• Other integration elements, as applicable.
☒ N/A. The state does not plan to integrate the rebates into any existing programs.
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