The local agency shall weatherize mobile homes in accordance with the State of Washington Weatherization Manual (Policies and Procedures, and Supporting Documents). The following more specific mobile home requirements in Policy 5.9.1, Mobile Homes take precedence over the general policies.
Underfloor insulation: Contractors blowing insulation into the cavity between rodent barrier and sub-floor shall install fiberglass insulation only, at a density of 1.5 pounds per cubic foot (lb/cu.ft.). Insulation shall be in substantial contact with the underfloor. Open floor cavities shall be insulated per Policy 5.4.4, Floor Insulation.
The belly board (flexible rodent-barrier) must be complete and intact in areas where insulation is blown-in. The rodent barrier shall be supported as required to avoid sagging.
Holes in the rodent barrier shall be patched with like or similar materials that are stitch stapled or mechanically fastened and glued to the existing rodent barrier with adhesive, mastic, or caulk.
Stitch staples shall be at a minimum size 9/16, type galvanized or stainless, and gauge 4M. Patches must be sealed with caulk, glue, mastic, or adhesive (peel & seal) and have a minimum number of 4 staples per patch.
Holes in the rim joist used to install insulation in the cavity between the belly board and sub-floor shall be plugged with wooden plugs glued in place with an exterior-rated sealant.
Skirting: Repair or replacement is considered a weatherization related repair and must be included in the package of measures and meet an SIR of 1 or greater. If skirting is not present all insulation and ductwork installed by the program must be protected.
Ceiling insulation: Installation of ceiling insulation in crowned and flat roofs shall be installed to a minimum R-38 or the highest practical R-value, filling the entire attic cavity.
Ventilation: Attics with pitched roofs where the insulation does not fill the cavity shall be ventilated per Section 6, Attic/Ceiling Insulation.
Patching insulation access holes in roofing: Contractors shall patch all holes created to install attic insulation. Holes shall be patched to prevent intrusion of bulk moisture. Patches on roofs shall be installed in a manner that ensures they are as durable as and last the life of the existing roofing.
Access holes created to install attic insulation shall not compromise the structural integrity of the roof system.
Exterior roof insulation: Contractors shall determine that the ceiling/roof system is structurally adequate to support the combined weight of all materials imposed on the ceiling/roof system including insulation that may be installed in the attic cavity.
Attic cavity fill: Contractors shall fill the attic cavity between the ceiling and roof with insulation prior to applying exterior ceiling/roof insulation.
Insulation and membrane: Contractors shall install a minimum 2 inches of rigid extruded polystyrene or polyisocyanurate insulation covered with an EPDM or PVC membrane.
Securing insulation boards: Contractors shall secure insulation boards to the roof structure using fender washers with a minimum diameter of 1 inch, and screws long enough to penetrate the roof trusses a minimum of 1 inch.
Screws shall be attached to the roof trusses every 30 inches. The maximum distance between screws is 30 inches.
Screw heads shall not project above the rigid board insulation.
Roof membranes: Roofing membranes shall cover the existing roof and extend down the wall. The membrane shall be secured to the wall in a manner that prevents water intrusion into the wall cavity. The roofing system shall be sufficiently rigid and sloped to prevent “ponding” or “pooling” of water on roof surface after installation.
Roofing projections: All existing exhaust fan terminations, plumbing vent stacks, and combustion appliance vent stacks must extend through the new exterior roof insulation and terminate in an air-tight and water-tight manner.
All combustion appliance vent stacks shall be extended, if necessary, to meet applicable HUD code and appliance manufacturers’ specifications for minimum height of the vent stack termination above the new roof level.
New vent caps for exhaust fans must not be of smaller diameter than the duct or pipe projecting through roof, must allow free flow of air, and must supply a net free ventilation area (NFA) not less than 60% of the size of the duct or pipe (Example: A vent cap installed on a 7 inch diameter bathroom fan exhaust duct must have a minimum diameter of no less than 7 inches, and provide an NFA of no less than 23 square inches).
Ducts or pipes must be sealed to the inside of the vent cap to prevent the entrance of exhaust air or gases into the ceiling cavity. Where the existing vent duct or fan housing does not adequately project above the roof surface to allow sealing it to the inside of the new vent cap, add a section of not less than 26 gauge galvanized steel duct of the same diameter as the existing duct or fan housing. The rigid duct section must overlap the existing duct or fan housing by a minimum of 1 inch and not extend above the bottom of the vent openings in the vent cap.
Fan/duct extensions must be sealed to the outside of the existing duct or fan housing and to the inside of the vent cap with a continuous bead of silicon caulk.
Vent caps for all kitchen exhaust fans must be made of metal and sealed to the fan exhaust duct and roof cap with high temperature silicon.
All roof penetrations shall be flashed with membrane compatible materials.
Wall insulation: Mobile home wall insulation can be installed on a case by case basis, where the Savings to Investment Ratio (SIR) is 1 or greater, depending on the type and construction of the mobile home. If installing wall insulation it should be done in a manner that fills the wall cavity.
Installation Insulation shall be installed between the exterior side of the existing insulation and the interior side of the exterior wall.
Insulating wall cavities with an existing vapor-retarder When a vapor-retarder is present on the interior side of the existing insulation, install the new insulation on the exterior side of the existing insulation.
Securing siding If metal siding panels have been removed or opened to facilitate installation of insulation reinstall panels in a secure manner to prevent panel separation and water intrusion.
Fasteners used for securing wall panels must be gasketed, corrosion resistant, self-tapping screws.
Exterior water heater closets: Where it is not practical to insulate water heaters the water heater closet exterior door shall be insulated to minimum R-11. The exterior door and interior of the closet shall be air sealed to prevent air infiltration.
Exterior water heater closet with combustion appliance Exterior water heater closets with a combustion appliance shall have combustion air inlets that meet International Mechanical Code standards.
Mobile Home Airsealing All considerations from Specifications Section 5 should be included in the air sealing of a mobile home with attention to all accessible marriage lines in a multi-section unit.
Replaces: Section 6.2 – July 2012 OMB 2 CFR Part 200, Uniform Guidance
Policy 6.2 GENERAL STANDARDS OF FISCAL ACCOUNTABILITY Method of Compensation: Commerce will reimburse local agencies for all allowable costs upon receipt of authorized requests for reimbursement as directed by Commerce. See Section 8.7, Reporting and Reimbursement of Expenses.
Accounting and Auditing: Local agencies are responsible for complying with all applicable guidelines and procedures, demonstrating responsible management of cash flow, inventory control, equipment purchase, and administrative costs. See Section 6.8, Audits.
Subcontractors must be selected using competitive procedures among potential bidders for weatherization services. See Section 8.4, Subcontracting.
Procurement procedures and pertinent contracts will be reviewed during the annual monitoring process.
Record-keeping: Local agencies must keep records that fully disclose the following:
Amount and disposition of funds received.
Total Installed Measure Cost of a weatherization project.
Total Building Cost by funding source,
Source and amount of funds used from all funding sources.
Wx Policy 6.2 General Standards of Fiscal Accountability Page 2 of 2
Records must be retained for six years from the last financial audit or the completion of the length of commitment, whichever is later.
Reporting: Local agencies will provide reports or answers in writing to specific questions or surveys requested by Commerce or its funding sources by the specified deadline. See Chapter 8, Program Management, Administration, and Reporting. Purchasing Equipment: All purchases of equipment with values exceeding $5,000 require Commerce written approval.
Requests for vehicles purchased with DOE funding require prior written DOE approval. Allow 90 days for DOE review.
See Section 6.6, Equipment for additional policies, including procurement with multiple fund sources and equipment sharing with non-weatherization programs.
Securing Commerce's Interest in Motor Vehicles, Equipment, and Fixtures: Local agencies are responsible for ensuring Commerce's financial interest in motor vehicles, equipment, and fixtures with purchase values of $10,000 or more, purchased under Commerce contracts. See Section 6.6, Equipment, for additional policies.
Inventory Control Local agencies are required to maintain an inventory of materials and non-expendable tools and equipment. See Section 8.12, Inventory Control.
Authorized Expenditures OMB 2CFR Part 200, Uniform Guidance is used as general guidelines for determining which weatherization costs are allowed.
Exceptions exist where costs conform to specific categories in the applicable contract, policies and procedures, weatherization budget, state law, or local ordinance.
Commerce determines the proper interpretation of the federal or state procedures as they relate to costs allowed or prohibited under this program.
Policy 6.3 Administrative Costs Defining Administrative Costs: Administrative costs are costs associated with those functions of a general nature not clearly identifiable with a program. These functions include planning, budgeting and accounting, and establishment and direction of local agency policies, goals, and objectives.
Allowing Administrative Costs: Allowable administrative costs include costs associated with functions such as:
General board/committee meetings.
General staff meetings.
Accounting, auditing, and budgeting.
Corporate legal services.
Purchasing and distribution of supplies.
Insurance and bonding.
Receptionist, switchboard, mail distribution, filing, and other central clerical services.
Word processing and computer services.
Computer equipment used for administrative functions.
Organizational and procedure studies.
General record keeping.
Office space/facilities lease or rental – including outstations.
Utilities in the office space/facilities.
Wx Policy 6.3 Administrative Costs Page 2 of 3
Telephone equipment and services.
Administrative staff training.
Applicable state and local taxes.
General personal liability and property insurance (Liability insurance for onsite work is a program cost. See Section 6.4, Program Operation Costs.).
DOE allows general personal liability and property insurance to be charged to the liability line item of the contract.
Charging Program Services to Program Support, not Administration:
Personnel typically identified as administration may relate, at times, more directly to program activities than to administration. Even some hours of “management staff” may be properly allocated to program support costs, but only if the positions are not included in an indirect cost pool.
Cost Allocation Plans: Local agencies must ensure their Cost Allocation Plans used to spread central administrative costs across local agency programs are in accordance with the OMB circulars.
Indirect Rates: Local agencies may apply a federally approved indirect cost rate to charge administrative costs only if both of the following conditions are met:
The agency has an approved indirect cost agreement with a cognizant federal agency.
The indirect cost agreement precludes the application of the indirect rate to direct client benefits in this program.
The application of indirect cost charges may not result in exceeding applicable contract budget limits.
Submitting Cost Allocation Plans: Each local agency must annually submit a copy of its cost allocation plan to Commerce with its General Weatherization Work Plan.
Wx Policy 6.3 Administrative Costs Page 3 of 3
Documenting Administrative Costs: Local agency files must include the following documentation:
All applicable administrative costs.
Auditor approval of cost allocation plan.
Indirect cost agreement approval letter.
SECTION 6.4 PROGRAM OPERATION COSTS
Program operation costs are costs that can be clearly identifiable with a program and are comprised of Weatherization Measures, Health and Safety Measures, Weatherization-Related Repair Measures, Program Support, Vehicle and Equipment, and Other Program Operations (See Exhibit 6.1, Weatherization Program Fiscal Definitions)..
Weatherization, Health and Safety, and Weatherization-Related Repair Installed Measure Costs – Examples include:
Securing building permits when necessary for the installation of weatherization measures.
Approved renewable energy systems (DOE funds only). See Section 5.7, Renewable Energy Systems
Material costs charged by a subcontractor.
Purchase and delivery of materials. See Section 6.4.1, Compliance with Federal Rules for Use of Recycled Insulation Materials, for procurement guidance for recycled insulation materials.
Storage or warehousing of weatherization materials.
Payment of staff involved in purchasing, inventory, and distribution of weatherization materials.
Payment for labor involved in fabricating materials.
Labor costs charged by a subcontractor.
Local agency weatherization crew costs (salary and benefits).
Supervisory on-site labor such as crew chiefs.
Program Support Costs - Examples include:
Weatherization audit and inspection.
Consumer Conservation Education.
Direct supervision of program services and other direct program management/oversight responsibilities.
Intake and outreach staff.
Office space and utilities.
Equipment, vehicle, and tool maintenance—including computer and other electronic equipment and software used by weatherization program activities.
Lease or rental of tools, equipment, and vehicles.
Low-Cost/No-Cost Wx Activities. See Policy 5.1.5 Low-Cost/No-Cost.
Vehicle and EquipmentCosts- Examples include:
Purchase of vehicles.
Equipment and tool purchase—including computer and other electronic equipment and software used by weatherization program
Other Program Operations Costs - Examples include:
Program-related liability insurance—including POI insurance.
Payments for liability insurance covering personal injury and property damage for on-site work.
Liability insurance for onsite work.
Leveraging expenses used to increase the amount of weatherization assistance from non-Federal sources, including private sources such as utilities.
When non-Commerce funds (such as utility funds) are combined with Commerce funds on a weatherization project, Commerce's share will be the minimum amount necessary to complete the weatherization work after funds from the other sources are used.
Commerce funds for weatherization must not be used to supplant other funds or programs.
Building Cost and Unit Cost Calculations
For each Weatherization project, Building Costs are calculated for any given time period and funding source(s) and are the sum of the following:
Installed Measure Costs (IMC) from WIDS
Weatherization Measures (Wx)
Weatherization-Related Repair Measures (WRR)
Program Support Costs from the monthly Requests for Reimbursement. The Program Support costs are allocated in a reasonable and consistent manner in accordance with OMB circulars.
Single Family Projects are one unit per building. The Unit Cost (cost per unit) is the same as Building Cost.
Multi-Family Projects are multiple units per building. To determine Unit Cost for each building, divide the total calculated Building Cost by the total number of units entered in WIDS.
Program Support costs calculated on a Monthly and Quarterly basis for use in assessing agency performance will be considered to be temporary only.
The final total Building and Unit Costs will be determined for each funding source at contract closeout.
The following costs are NOT included in Building Cost (Unit Cost):
Health and Safety Measures Costs
Other Program Operations Costs
Training and Technical Assistance Costs
Special Project Costs
State and Local Taxes
Charge applicable state and local taxes on purchases to the same budget category and funding source as the purchased item or service.
Local agencies making weatherization improvements under the weatherization program for low-income homeowners or renters are eligible for exemption from state sales tax and use tax. See Washington State Department of Revenue Special Notice: Sales and Use Tax Exemption for the Weatherization Assistance Program. Purchases of qualified materials must be accompanied by a Buyers’ Retail Sales Tax Exemption Certificate.
Local agencies must organize all bookkeeping and production records systems to account for the different cost allowances and budget categories of the various funding sources involved.
Local agencies must report program expenditures to Commerce as required.
See Chapter 5, Providing Weatherization Services, for allowable weatherization measures and fund source limitations & allowances.
SECTION 6.4.1 COMPLIANCE WITH FEDERAL RULES FOR USE OF RECYCLED INSULATION MATERIALS
Commerce and local agencies must comply with Environmental Protection Agency (EPA) regulations regarding the use of recycled materials (40 CFR 247.12, Comprehensive Procurement Guideline for Products Containing Recovered Materials (www.epa.gov/).
Local agencies are required to make good faith efforts to procure insulation products that contain recycled materials.
Exceptions to this policy may be made only if the following conditions can be documented:
Inability of the product to perform its intended purpose.
Unavailability of the product at a reasonable price.
Inability to obtain the product within a reasonable period of time.
Inadequate number of vendors for obtaining and verifying estimates of recovered materials content to insure a satisfactory level of competition at the time of procurement.
In addition to meeting procurement specifications, local agencies must establish an affirmative procurement program consisting of four items (a through d).
Preference program for purchasing designated items.
EPA regulations provide three general approaches:
Minimum content standards that identify the minimum content of recovered materials that an insulation product must contain.
Case-by-case procurement, allowing competition between insulation products made of new materials and those with recovered materials.
An alternative approach that accomplishes the same objectives as a) and b).
EPA regulations recommend that the procuring agency use minimum content amount for commercially available insulation products that may contain recovered materials. These include:
Cellulose, loose fill, and spray-on (75 percent post-consumer recovered paper by weight).
Perlite composite board (23 percent post-consumer recovered paper by weight).
Rock wool (50 percent recovered materials).
Procedures for obtaining estimates and certifications of recovered materials content and for verifying the estimates and certifications.
Annual review and monitoring of the effectiveness of the program.
Further guidance is provided in the See Field Guide, Retrofitting Washington
Local agencies must allow Commerce access to all affirmative procurement program documentation upon request.
Local agency files must contain the following documentation:
Procurement conditions that prohibit compliance with 40 CFR 247.12.
Verification the agency is in compliance with EPA’s affirmative procurement program.
See Field Guide, Retrofitting Washington
Effective Date: July 2017 Page 1 of 2
10 CFR 440.23
Exhibit 6.5A, Training and Technical Assistance Expense Form
Replaces: Section 6.5 – April 2010 Exhibit 6.5B, Peer Exchange Proposal Form
Policy 6.5 TRAINING AND TECHNICAL ASSISTANCE Expenditure of contract funds awarded specifically for training and technical assistance (T&TA) purposes are subject to the following conditions:
Training must have direct application and benefit to local agency weatherization programs and assigned staff.
Local agencies must document how other programs will share the training costs, if the training is not strictly for the benefit of the weatherization program staff.
Priority is given to direct training opportunities for staff, crews, and subcontractors.
Staff salaries while attending training, providing training, traveling to and from training, and participating in on-the-job training is an allowable expense. Equipment and materials related to training may also be purchased with these funds, with appropriate written justification and prior approval from Commerce.
Subcontractors under contract to Local agencies training fee, travel, and per diem expenses are an allowable expenses, if investment in the subcontractor is a benefit for the Wx Program.
T&TA funds cannot be used for:
Salaries not related to training activities;
Local agencies must complete the Exhibit 6.5A, Training and Technical Assistance Expense Form.
Local agencies must include all names and titles of individuals attending training.
Local agencies must keep Training and Technical Assistance Expense Forms on file for review by Commerce field representatives.
Wx Policy 6.5 Training and Technical Assistance Page 2 of 2
Commerce may occasionally reimburse local agency costs for providing, or travel to receive, training and technical assistance through the Peer Exchange Program.
Prior Commerce approval is required for this reimbursement.
Local agencies must submit the Exhibit 6.5B, Peer Exchange Proposal Form to Commerce.