Transcript EERE Programs Briefing

2011 Orientation for State WAP Directors and Staff
State Plan and Application
February 28, 2011
Michael Peterson, Warren Cunningham,
Jean Diggs, Trev Hall, Erica Burrin, &
Ryan Middleton
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WAP State Plan
Instructions and Forms
 Why?
– 10 CFR 440.14
– WPN 06-3, Revised WAP Application, Instructions and Forms
– Formerly two “Files”
 “Annual File” – application components that changed annually
 “Master File” – application components that were generally
unchanged from previous year
 What is DOE looking for?
– States no longer required to submit a Master File every year
 Must maintain current information consistent with Program
guidance “On-File” at the Grantee Office
 Will be monitored by DOE staff during routine monitoring
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Annual File
Instructions and Forms
 State Plan Annual File Format
II.1
Grant Application – Standard Form 424, Version 02
II.2
Budget – SF 424 A
II.2.3
Budget Justification – PMC 140.2 or equivalent
II.3
Subgrantees - DOE F 540.5
II.4
Production Schedule
II.5
Energy Savings
II.6
Training, Technical Assistance and Monitoring Activities
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Annual File
Instructions and Forms
 State Plan Annual File Format (cont’d)
II.7
DOE-Funded Leveraging Activities
II.8
Policy Advisory Council
II.9
Hearings and Transcripts
II.10
Adjustments to “On-File” Information
II.11
Miscellaneous
II.12
Certification regarding Lobbying (SF-LLL) only if applicable
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Annual File
Section II.1 – Grant Application
 Grant Application Standard Form 424 (SF-424)
– SF-424, Version 2, dated 10/05
– Required of each agency applying to DOE’s Weatherization
Program for grants
– Also, required for subsequent funding changes (federal and
non-federal)
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Annual File
Section II.2 – Budget Information
 Budget Information (SF-424A)
Section A – Budget Summary
– Lines 1 – 5, Columns a – g
– Line 1, enter new, or unexpended (e.g. carry-over) DOE
and/or grantee funds.
– Use separate lines for each “other” funding source
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Annual File
Section II.2 – Budget Information
 Budget Information (SF-424A)
Section B – Program, Function or Activity (Columns)
–
–
–
–
–
–
–
–
–
–
Grantee Administration
Subgrantee Administration
Grantee T&TA
Subgrantee T&TA
Program Operations
Health and Safety
Vehicles and Equipment
Liability Insurance
Leveraging
Financial Audits
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Annual File
Section II.2 – Budget Information
 Budget Information (SF-424A)
Section B – Object Class Categories (Rows)
–
–
–
–
–
–
–
–
–
–
–
Personnel
Fringe Benefits
Travel
Equipment
Supplies
Contractual
Construction
Other
Total Direct Charges
Indirect Charges
Object Class Totals
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Annual File
Section II.2 – Budget Information
 Budget Information (SF-424A)
Section B
– The “Total” Column on page 1 should reflect the sum of all
three pages
– Section B total should equal Section A total
– In Section B, subgrantee budgeted expenditures should all be
reported in the contractual category (row f)
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Annual File
Section II.2 – Budget Information
 Budget Information (SF-424A)
Section B
– Health & Safety Exclusion: Budgeted expenditures under
Health and Safety are not included in the calculation of the
average cost per unit.
– Liability Insurance: Pollution Occurrence Insurance should be
budgeted under this activity
– Financial Audits: Grantees should not budget financial
expenditures for subgrantees expending less than $500,000 in
federal funds (OMB Circular A-133)
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Annual File
Section II.2 – Budget Information
 Budget Justification
GO-PF20A
– Required annually and with subsequent amendments
– Budget detail corresponding to Object Class Categories
(rows a – j) from Section B of SF-424A
– Totals for each category must add up to the amount reported
in Section B
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Annual File
Section II.3 – Subgrantees
 Subgrantees
– List of subgrantees including the name, tentative allocation,
number of units to be weatherized,
– Subgrantee contact information including name, address,
contact information, labor source, Congressional district(s), and
counties served.
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Annual File
Section II.4 – Production Schedule
 Production Schedule
– Total number of planned weatherized and reweatherized units
under the program rule and with grant funds
– Vehicles and Equipment ($5,000 or more) Average Cost per
Dwelling Unit calculation – for those states that plan to amortize
the cost of vehicles and equipment
– Average Cost per Dwelling Unit – calculation of expected
average cost including vehicles and equipment
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Annual File
Section II.5 – Energy Savings
 Energy Savings
–
Provide estimate of expected energy savings (440.14(c)(4))
–
Include the methodology used to calculate savings including
the information sources for energy savings/unit
–
If no methodology has been developed by the grantee, use
DOE-provided formula (estimated homes to be weatherized x
30.5 MBTU)
 This may skew state-level energy savings estimates – DOE
is revisiting the approach used to estimate energy savings
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Annual File
Section II.6 – T&TA and Monitoring
 Training, Technical Assistance,
and Monitoring Activities
– Indicate method used to ensure quality of work and financial
management at the local level
– Include description of activities to be undertaken during the
program year with funds budgeted under T&TA or Admin for
training and technical assistance and/or monitoring
– Establish milestones and estimate due dates
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Annual File
Section II.7 – DOE Leveraging
 DOE – Funded Leveraging Activities
– Explain how DOE funds (as indicated on SF-424A) will be used
to increase the amount of assistance provided to eligible clients
– Leveraging = obtaining additional program-targeted non-federal
cash or in-kind contributions as a result of Weatherization
Program-funded activities
– Explanation of (1) how funds will be used to obtain non-federal
resources, (2) how funds leveraged will support the DOE
Weatherization Program, (3) the leveraging effect of those
funds, and (4) rationale for the amount of funds used
– DOE funds must be used to obtain non-federal resources to:
 Increase the number of homes weatherized and/or
 Increase the scope or type of services provided
 Goal: At least a dollar for dollar return
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Annual File
Section II.8 – Policy Advisory Council
 Policy Advisory Council
– Policy Advisory Council (PAC) or State commission/council
must be established in accordance with 10 CFR 440.17
– Provide names, groups, organization or agencies represented
by members
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Annual File
Section II.9 – Hearings & Transcripts
 Hearings and Transcripts
– One or more hearing(s) must be held to receive comments on
the proposed application. Provide location and dates of
hearing(s).
– Requirement to give public notice 10 days prior to the hearing.
Provide dates of public notices.
– Unofficial notes/minutes or the official transcript must be
submitted to DOE. Include grantee responses to any questions
which were not resolved at the hearing.
– Reminders:
 Plans are to be made available for review throughout the
state prior to the hearing
 Include in Plan, all of the agencies which may be funded
during the PY, whether funded initially or serve as alternates
 Emphasize the state allocation formula, process used to
determine local funding levels, anticipated allocations
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Annual File
Section II.10 – Revisions to “On-File”
 Adjustments to On-File Information
– Include any revisions, since the previous program year, to the
On-File Information (previously the Master File)
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Annual File
Section II.11 – Miscellaneous
 Miscellaneous
– Can include notes from public hearing and Policy Advisory
Council meetings here
– Other activities not routinely administered as part of the
Weatherization Program
– Disaster Relief Plan, Energy Crisis Response, etc.
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Annual File
Section II.12 – Lobbying Disclosure
 Lobbying Disclosure
– Standard Form - LLL is required ONLY if the grantee performs
lobbying activities
– Other Assurances and Certifications that used to be listed
under Section II.12 are no longer required. Grantees agree to
these assurances when signing the new SF- 424, and check
Box 21.
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Annual File
Administrative Funds
 Administrative Funds
– Funds Based on Total Grant
– CAP of 10%
 Not more than 5% for Grantee
 Not less than 5% for Subgrantee
– EXCEPT:
 Local agencies receiving less than $350,000 of new DOE
funds, up to an additional 5% may be used
 Procedures required
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Annual File
Administrative Funds
 Administrative Funds (cont’d)
– New DOE and/or Stripper Well funding used for administrative
purposes can’t exceed 10% of NEW funding
– EXAMPLE:
 Total New DOE Funds ($2,000,000)
 Plus New EXXON Funds ($200,000)
 Plus New Stripper Well Funds (1,000,000)
 Total Funding - $3,200,000
 Of this Total Funding, $320,000 may be used
 The whole $320,000 may be taken out of DOE funds
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Annual File
Administrative Funds
 Administrative Funds (cont’d)
– Allowable uses of administrative funds Include:
 Salaries
 Telephone Costs
 Space
 Copying
 Supplies
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Annual File
Administrative Costs Worksheet
 Allowable Administrative Costs Worksheet
– How to include carryover funds
– How to allocate additional 5% to agencies receiving less than
$350,000
– How to determine the maximum allowable administrative costs
under the grant
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Annual File
Administrative Costs Worksheet - 1
Item I.
$
New DOE Funding (formula allocation
and/or DOE funds transferred from previous
grant)
+$
Other new funding this action
$
Total new funding subject to the “10%
Administrative Cost” Rule
(Allowable Grantee Administration)
$
Grantee Administration total from line k(1)
of the budget
-$
Item II.
Item
III.
Less Grantee Administration carryover
Grantee Administration subject to the “10%
Administrative Cost” Rule
$
0.0
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Divide Item II. by Item I and write out to
four decimal places (Item III may not exceed
5% or 0.0500)
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Annual File
Administrative Costs Worksheet - 2
(Allowable Subgrantee Administration)
Item
IV.
$
Subgrantee Administration total from line
k(2) of the budget
-$
Less Subgrantee Administration carryover
$
Subgrantee Administration subject to the
“10% Administrative Cost” Rule
Item V.
0.0
Divide Item IV. by Item I and write out to
four decimal places (Item V. must exceed
5% or 0.0500 but should not exceed the
subgrantee limitation.)
Item
VI.
0.
Add Items III. and V. and write to answer to
four decimal places and must be less than
15% or 0.1500
Yes /
No
If Item VI. Is greater than 10% or 0.1000, the grantee has specified criteria under 10 CFR
440.18(d) for which subgrantees will receive additional administrative funds and how much
extra they will receive.
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Annual File
Administrative Costs Worksheet - 3
Only if Item VI is greater than 10% or 0.1000, determine theoretical subgrantee
administrative cost limitation to compare with amount budgeted.
5%
Item I.
Subgrantee administration allowance for
new funds
$
+ 5%
of
Sum of local agencies allocations below
$350,000
+$
Item
VII.
Subgrantee Administrative Cost Pool
Component Limit
$
The maximum pool of new administration funds is 5% for the grantee (5% of Item
I.) plus the amount calculated for the administrative cost pool component limit (Item
VII). The grantee may transfer some of it’s funds to subgrantees. Any carryover
needs to be questioned and reprogrammed for production if not properly justified.
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Annual File
Training & Technical Assistance
 Regulatory Citation for Training & Technical Assistance
(T&TA)
– Section 440.23 - Oversight, Training, and Technical
Assistance
– The Secretary may reserve from the funds appropriated for any
fiscal year an amount not to exceed 10 percent to provide,
directly or indirectly, training and technical assistance to any
grantee or subgrantee. Such training and technical assistance
may include providing information concerning conservation
practices to occupants or eligible dwelling units.
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Annual File
Training & Technical Assistance
 Training & Technical Assistance (cont’d)
– Intended to maintain or increase the efficiency, quality, and
effectiveness of the Weatherization Assistance Program at all
levels
– Should be designed to maximize energy savings, minimize
production costs, improve program management and
crew/contractor “quality of work,” and or reduce the potential for
waste, fraud, abuse, and mismanagement
– Local service providers should be the primary recipients of
T & TA activities
– Annual File of the State Plan should describe how State will
identify and address the needs of subgrantees in this area
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WAP State Plan On-File, Section
III.3.1, Type of Work To Be Done
 Why?
– 10 CFR 440.14(b)(1) and (c)(3)
– Also described in WPN 06-3, Revised Weatherization
Application, Instructions and Forms
 What is DOE looking for?
– Does the description of type of work to be done correspond to
H&S Plan? Priority List or NEAT Protocols?
– Does the description outline allowable measures, including base
load?
– If refrigerators are allowable, how are old units disposed of?
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On-File, Section III.3.1, Type of Work
To Be Done
 How to complete or review this section of the Plan?
– If your Policy and Procedures Manual or Field Guide outlines the
type of allowable measures, then include that language or
reference the correct Grantee document in this section of your
plan.
– If your field protocols or energy audit has been reapproved since
the last State Plan approval or if you have had an amendment,
make sure that the ‘Type of Work To Be Done’ section is updated
in the On-File Section and in the ‘Miscellaneous Section’ of your
Annual File.
– Grantees can also simply list the typical measures installed and
make sure that measures are pulled from approved energy audit
protocols.
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On-File, Section III.3.2, Energy Audit
Procedures
 Why?
– 10 CFR 440.21
– WPN 01-4 and 05-5
 What is DOE Looking For?
– Were energy audits approved within the last five years for each
dwelling type – single family, mobile home, and multi-family?
– If Grantee is using a Priority List, is a site specific audit still
required?
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On-File, Section III.3.2, Energy Audit
Procedures
 How to complete or review this section of the Plan?
–
–
–
–
–
–
Submission requirements outlined in WPN 01-4
Analytic methods and assumptions
Description of measures considered
Sample audit
Field procedures
Administrative requirements for each building type served
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On-File, Section III.3.3, Final
Inspections
 Why?
– 10 CFR 440.16 (g)
 What is DOE Looking For?
–
–
–
–
What does the final inspection process look like in your State?
What percentage of homes require a final inspection?
Is there a requirement for client sign off/satisfaction?
Does the final inspection process provide for a signed and dated
inspection form?
– Is each measure installed reviewed as part of the final
inspection?
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On-File, Section III.3.3, Final
Inspections
 How to complete or review this section of the Plan?
– Review the regulation 10 CFR 440.16(g)
– Consult your audit protocols/ priority list to incorporate review of
measures into final inspection process
– Consult your field standards
– Get input from your subgrantees and/or technical committees.
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On-file, Section III.3.4, Assessment of
Effectiveness
 Why?
– 10 CFR 440.23(e)
– WPN 11-1, Section 3.1, D:
How the Grantee compares productivity and energy savings
between subgrantees and how these comparisons are used in
the development of T&TA activities and priorities
– WPN 11-1, Section 3.1, F:
An assessment of Grantee T&TA activities to determine whether
these funds are being spent effectively.
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On-file, Section III.3.4, Assessment of
Effectiveness
 What is DOE Looking For?
– Is there a process for assessment of effectiveness of the
subgrantees other than monitoring reports?
– Has the Grantee used WAP funds to complete an energy
savings evaluation?
 How to complete or review this section of the Plan?
– Set aside Grantee T&TA or Grantee Administration funds to
procure an energy evaluation of the program.
– A number of Midwestern states have regular evaluation cycles
that range from a simple pre and post weatherization utility
usage analysis to a more comprehensive approach with
individual measure evaluation.
– ORNL may be able to provide technical assistance in this area.
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On-File, Section III.5, Rental
Procedures
 Why?
– 10 CFR 440.22(3)(b)
– WPN 11-1, Section 5.2 and 5.4
 What is DOE Looking For?
– Written permission is obtained from the building owner to
perform Wx services.
– Not less than 50% of units are income eligible for duplexes and
four unit buildings
– 66% of units are income eligible for buildings over four units
– Benefits of WAP accrue primarily to low-income tenants
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On-File, Section III.5, Rental
Procedures
 What is DOE Looking For? (continued)
– Tenants will not be subjected to rent increases as a result of
WAP services
– No undue or excessive enhancement shall occur to the value of
the dwelling
– Does the Grantee require financial participation of the landlord?
– Is there a statewide agreement template required between
landlord and subgrantee?
 How to complete or review this section of the Plan?
– Review your current State Plan
– Does your State Plan, Policy and Procedures or Admin Manual
say the same thing?
– Review the regulation and WPN, do you need to add or change
anything?
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III.6.1-6. Describe Your Approach
 On File Sections
–
–
–
–
–
III.6.1 Description of Organization
III.6.2 Administrative Expenditure Limits
III.6.3 Monitoring Approach
III.6.4 Training and Technical Assistance Approach
III.6.5 Energy Crisis Plan
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III.6.1-6. Describe Your Approach
 These Sections Describe Your Team and Approach
– Who are you?.
– Describe your administrative forecast.
 How much are you going to spend on admin?
 What are your goals and objectives?
 How will you measure yourself?
– How will you monitor and verify effectiveness?
– How will you train the weatherization workforce?
– How does your organization respond to crisis?
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III.6.1-6. Describe Your Approach
 How to complete or review these sections of the Plan?
– Local & Non-local In-depth Knowledge & Feedback
– Regulations & Program Guidance
– How to find more information
 Past Examples & Best Practices
 Additional Online & Traditional Resources
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III.6.1-6. Describe Your Approach
 On File Sections
– III.6.1 Description of Organization
– III.6.2 Administrative Expenditure Limits
 WPN11-1 1.4
– 10% Total / 5% Grantee
– Less than 350k Additional 5%
– III.6.3 Monitoring Approach
 10 CFR 600.240 Subpart C
– Must cover each program, function, or activity
– Annual Reporting
 WPN 10-09, 10-01, 9-1B, 01-6
 5% Unit Minimum
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III.6.1-6. Describe Your Approach
 Monitoring goals include determining…
–
–
–
–
–
–
Program compliance
Accountability
Program performance
Quality of Work
Problems areas and deficiencies
Assistance and Training Needs
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III.6.1-6. Describe Your Approach
 DOE Monitoring Rules
– Comprehensive monitoring of each subgrantee at least
once a year.
– Must include review of client files and subgrantees records.
– Actual inspection of at least 5 percent of the completed
units.
– Subgrantee should be briefed on the observations and
findings.
– Within 30 days after each visit, the Grantee will prepare a
written report on its findings and send it to the subgrantee
for corrective action
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III.6.1-6. Describe Your Approach
 DOE Rules Cont…
– Noncompliance findings unresolved within forty-five days should
be reported to the PMC. Sensitive or significant noncompliance
findings should be reported to the PMC immediately.
– Major findings should be tracked by the Grantee to final
resolution.
– Annually the Grantee will summarize and review each
subgrantee’s audit, program monitoring reports and findings for
internal monitoring.
– Grantee will evaluate subgrantee needs, strengths, and
weaknesses and provide assistance as needed for improvement.
– The results of this annual monitoring should be considered
during annual planning and documented for future use by
Grantee and PMC DOE monitoring staff.
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III.6.1-6. Describe Your Approach
 Past Examples & Best Practices
– State of Georgia Monitoring Approach
– University of Georgia Extension Office
Monitoring Partnership
 10% Units Monitored
 12 Field Monitors / 12 File Monitors
 Energy Education Program
– 370 Outreach Presentations reaching
5000+ people.
– Translated Education Material
 Customer Survey (185 Surveys)
 Program Evaluation (Longitudinal Study)
– 11 Energy Educators following 50
households each
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III.6.1-6. Describe Your Approach
 On File Sections
– III.6.4 Training and Technical Assistance Approach
 WPN 11-2 Grantee Allocation
 Maintain quality and efficiency throughout all program levels
– State Personnel
– Agency Personnel
– Contractors (Retention Agreement)
 Minimum
–
–
–
–
–
–
Training needs assessment
What training Grantee will provide
Certification requirements
Subgrantee Comparisons and T&TA Integration
Grantee Oversight & Monitoring
Effectiveness Assessment
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III.6.1-6. Describe Your Approach
 Past Examples & Best Practices
– SC Office of the Governor, Office of
Economic Opportunity (OEO) & SC
Technical College System Partnership
– 7 Regional Energy Efficiency Training
Centers
 Hot Climate - Whole House Weatherization
training
 BPI, RESNET, HERS Rater
 1800 People Trained
 Props built onsite by each college
 Other Participants
– Electric Cooperatives
– Utilities
– Home Builders
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III.6.1-6. Describe Your Approach
 Past Examples & Best Practices
– State of Georgia and T&TA Approach
 Southface T&TA Provider Partnership
–
–
–
–
–
1200 People Trained
Typical BPI Oriented Curriculum
Training Innovation Center Award
Health And Safety Training
Circuit Rider Training Program
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III.6.1-6. Describe Your Approach
 Additional Online & Traditional Resources
 WAPTAC
– Guidance/Regs
– Best Practices
– Technical Tools
» Monitoring Tools
– Training Resources
– Message Board
– Ask the Expert
 Economic Opportunity Studies (EOS)
– Weatherization PLUS Newsletter
– Facebook Page
– Twitter Feed
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WAP Health & Safety
 Authority from 10 CFR 440.21 (c)
 DOE Issued Revised H&S Guidance WPN 11-6
– Response to concerns with clarity and consistency in how health
and safety issues are approached by grantees.
– DOE reconvened Health and Safety Committee to review trends
and practices of the WAP network to update guidance.
 Primary goal of Program remains “energy efficiency”.
– Energy-related health & safety measures are those actions
necessary to maintain the physical well being of both the occupants
and/or weatherization workers where:
 Costs are reasonable as determined by DOE in accordance with the
grantee’s approved Grantee Plan; AND
 The actions must be taken to effectively perform weatherization work;
OR
 The actions are necessary as a result of weatherization work.
 Grantees encouraged to budget H&S costs as a separate
category to exclude costs from the overall average per-unit
costs and avoid cost justification.
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Health & Safety Guidance WPN 11-6
 Guides the grantee in creating their H&S Plan, which once approved
by DOE, is used as the guiding document for subgrantees.
 Addresses Action/Allowability, Testing, Client Education, and
Training for the following Health and Safety Categories:
 Air Conditioning/Heating Systems
 Appliances/Water Heaters
 Asbestos
 Biologicals/Unsanitary Conditions
 Building Structure/Roofing
 Code Compliance
 Combustion Gases
 Drainage
 Electrical
 Fire Hazards
 Air Pollutants
 Injury Prevention
 Lead Based Paint
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 Mold/Moisture
 Occupant Preexisting/Potential
Health Conditions
 OSHA and Crew Safety
 Pests
 Radon
 Refrigerant
 Smoke/CO Detectors
 Solid Fuel Heating
 Space Heaters
 Spray Polyurethane Foam
 Ventilation
 Window/Door Replacement
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H & S Plan Minimum Requirements
 Include health and safety expenditure limits, expressed as a percentage of
average cost per dwelling unit, w/ justification and related historical
experience.
 Method to determine when DOE funds will be used and if they cannot, what
other treatment will be sought.
 System for remedy of potential health and safety issues including when
partial weatherization can be conducted.
 System for referral to other agencies.
 System for determining when deferral is necessary.
 Procedures for implementing training requirements.
 Outline of testing to be performed based on guidance.
 Protocols for informing clients of potential hazards.
 Procedures for collecting known or suspected occupant health concerns.
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H & S Plan Minimum Requirements
Cont.
 Strategy for implementation of ASHRAE 62.2 in 2012.
 Strategy for smoke/CO detector guidance implementation.
 Protocols on air conditioning and heating system repair and
installation.
 Procedures on handling problems resulting from combustion gas
testing.
 Strategy for implementing OSHA and crew safety guidance.
 Protocols for addressing mold found in the client’s home.
 Plan for implementing and verifying RRP and LSW compliance.
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Health & Safety Budget Review
 Does the state have a separate H & S budget?
– If H & S items are not included in a separate H & S budget or are
defined as incidental repairs, they must be addressed as such
consistently throughout the state and must be cost justified.
 Expenditure limits must be “reasonable” and expressed
as an per unit average.
–
–
–
–
Generally 10%.
Less assumes other funding is being utilized to address H & S.
More requires adequate justification relative to the increase.
15% and up requires additional DOE group review.
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Health & Safety Plan Review
 As described in §440.16(h), DOE will monitor the plan
based on the following criteria:
(1) elimination of such hazards is necessary before, or as a
result of, the installation of weatherization materials; and
(2) the grantee sets forth a limitation on the percent of average
dwelling unit costs that may be used to mitigate such
hazards, which is reasonable in light of the primary energy
conservation purpose of the Weatherization Assistance
Program.
 Meeting the WPN 11-6 Guidance.
– Is the required narrative/implementation strategy present?
– Is it consistent with H & S guidance (cannot conflict)?
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Health & Safety Plan Review
Cont.
 If an action/testing is “allowed” in guidance grantees can concur,
create additional requirements/limitations, or not allow.
 If “required” or “not allowed” – states must follow guidance.
 Important to consider what the guidance is specifically referring to
– in what instances the action is allowed.
 Conducting certain actions will trigger specific testing, client
education, and training requirements.
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Health & Safety Guidance Table
 Some common themes and requirements that should be
considered when utilizing the Guidance Table are as follows:
– Where removal or replacement is addressed, proper disposal is
required, and allowed as a H & S cost.
– Where hazards are identified, clients must be informed in writing and
the document must be signed by the client and a copy maintained in the
client file.
– State and local (or jurisdiction having authority) codes must be followed
while installing health and safety measures.
– Workers must be qualified and adequately trained according to state
and local (or jurisdiction having authority) codes specific to the work
being conducted (electrical, plumbing, etc.).
– Where Actions/Allowability, Testing, Client Education, and Training are
allowed or required, DOE funds may be used unless specified
otherwise.
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