HomeMy WebLinkAbout962382.tiff STATE OF COLORADO
OFFICE OF ENERGY CONSERVATION F�/pFpo<py
1675 Broadway
Suite 1300 q p
Denver,Colorado 80202.4613
Phone(303)620-4292 'rave'
FAX(303)620-4288
Roy Romer
...5overnor
Jade Buchanan
December 20, 1996 Director
Dear Coloradan:
Attached is the final decision document for the restructuring of the Weatherization 1
Program in Colorado. Also attached is a compilation of all comments and questions
received during the final comment period, along with responses where appropriate. With=
these documents,we end the decision-making phase of this restructuring process.
As you will see, our final decision is that, beginning with the new fiscal year on July 1,
1997, the Weatherization Program in Colorado will be administered through subgrantees
in ten territories. These territories are outlined in the attached decision document. They
are largely the territories outlined in the"Interim Final"decision document, except that
we have gone back to county boundaries everywhere but in the City and County of
Denver. A competitive bidding process will begin in early 1997 to select a service
delivery agency for each of the territories.
During the final comment period,we received a number of suggestions about adjustments
that could or should be made to the boundaries of the proposed territories. We chose not
to make most of these changes, for a variety of reasons. However,we do want to point
out that, under the existing program, an agency may contract with another agency in an
adjacent territory to serve specific areas. We anticipate nothing that would preclude
agencies in adjacent territories from making similar arrangements by mutual agreement in
the future.
We understand that this has been a long and difficult process. However, we are confident
that the new delivery structure will make the Weatherization Program more efficient and
will result in increased service to all regions of the state. We appreciate the comments,
patience and cooperation of all parties throughout this process. We commit to working
closely and cooperatively with the existing as well as any new service agencies to ensure
the Weatherization Program in Colorado remains one of the best in the country.
Again, thank you for your input and cooperation throughout this process.
Sincerely,
CG„C--
"- r1 , Wade Buchanan Tom Carter
i730/& Office of Energy Consrvation Public Service Company 1O6
de; 5); '& 962382
FINAL DECISION
SERVICE DELIVERY STRUCTURE
for the
COLORADO WEATHERIZATION PROGRAM
December 20, 1996
This document constitutes the final decision on the structure of the service delivery
territories for the Colorado Weatherization Program. This ends the decision-making
process which began in May, 1996. These service territories will take effect with the new
program year on July 1, 1997.
This document contains a description of the ten new territories along with back-up
materials and an explanation of the next steps. Attached to this document is a
compilation of all questions and comments received by OEC concerning the "interim
final" structure, along with OEC's responses where appropriate.
SERVICE DELIVERY STRUCTURE
Beginning July 1, 1997, the Colorado Weatherization Program will be administered
through regional service providers or subgrantees in ten (10) regional service territories.
These territories are described below and reflected in the attached maps. In response to
comments received these territories have been adjusted from those outlined in the
"Interim Final"decision issued on October 24, 1996, in the following ways:
• Rio Blanco and Garfield counties will not be divided, and both will be
included entirely in the"High Country"territory (Region V).
• The area of Weld County including the town of Lochbuie will be included in
Region I rather than Region VII, as we originally proposed. This means that
Weld County's boundaries will be intact and that the county will be entirely
within one service territory.
• The small area of Douglas County just south of Centennial Airport will be
included in Region X rather than Region VII, as we originally proposed. This
means that Douglas County's boundaries will be intact and that the county
will be entirely within one service territory.
• All of Adams County will be included in Region VII, including those zip
codes originally assigned to one of the other two metro regions (regions VIII
and IX). This means that Adams County's boundaries will be intact and that
the county will be entirely within one service territory.
• All of Arapahoe County will be included in Region VII, including those zip
codes originally assigned to one of the other two metro regions (regions VIII
and IX). This means that Arapahoe County's boundaries will be intact and
that the county will be entirely within one service territory.
• All of Jefferson County will be included in Region VIII, including those zip
codes originally assigned to one of the other two metro regions (regions VII
and IX). This means that Jefferson County's boundaries will be intact and
that the county will be entirely within one service territory.
• The Montbello area of Denver County was added back into Region IX from
Region VII, but portions of the City and County of Denver will be included in
the other two metro regions (regions VII and VIII) in order to reduce the large
size of Region IX and better equalize the size of metro territories. The Denver
County portions of zip codes 80212, 80211 and 80235 will be served by
Region VIII. The Denver County portion of zip codes 80221, 80249, 80230,
80231 and 80014 will be served by Region VII.
These changes will result in territories that conform to existing county boundaries, except
along the borders of the City and County of Denver.
SERVICE TERRITORIES:
•
The final territories are listed below and reflected on the attached maps.
I. Northeast Plains— The counties included within this service territory are: Weld,
Logan, Sedgwick, Phillips, Morgan, Washington, Cheyenne, Lincoln, Kit Carson, and
Yuma. All county boundaries remain intact.
II. Southeast Plains— The counties included within this service territory are: Kiowa,
Prowers, Baca, Las Animas, Huerfano, Custer, Pueblo, Crowley, Otero, and Bent.
All county boundaries remain intact.
III. San Luis Valley—The counties included within this service territory are: Costilla,
Conejos, Mineral, Saguache,Alamosa, and Rio Grande. All county boundaries
remain intact.
IV. West/Southwest- The counties included within this service territory are: Mesa,
Delta, Montrose, Gunnison, Ouray, Hinsdale, Archuleta, La Plata, Montezuma, San
Juan, Dolores, and San Miguel. All county boundaries remain intact.
V. High Country—The counties included within this service territory are: Moffat,
Routt, Jackson, Grand, Eagle, Summit, Clear Creek, Pitkin, Lake, Park , Chaffee,
Garfield and Rio Blanco. All county boundaries remain intact.
VI. Northern Front Range—The counties included within this service territory are:
Larimer, Boulder, and Gilpin. All county boundaries remain intact.
VII. East Metro Area— This area includes all of the zip codes within Adams and
Arapahoe Counties. The East Metro Area also includes the Denver County
portions of zip codes 80221, 80249, 80230, 80231, and 80114.
VIII. West Metro Area—This area includes all of the zip codes within Jefferson
County. The West Metro Area also includes the Denver County portions of zip
codes 80211, 80212, and 80235.
IX. Core Metro Area—This area includes the zip codes within Denver County, except
as noted above.
X. Pikes Peak—The counties included within this service territory are: Douglas,
Elbert„ El Paso,Teller, and Fremont. All county boundaries remain intact.
NEXT STEPS
As previously mentioned,the selection process that will be used to determine service
providers will be a competitive Request For Proposal (RFP)process. This process will be
initiated and conducted through the State of Colorado Division of Purchasing, using their
BIDS automated distribution system. We are hoping to have the RFP,with the changes to
the service delivery structure as well as "functional" changes to the program, released by
February 15, 1997, and interested bidders will have four(4) weeks (up to March 15,
1997) in which to prepare their bids and submit them to The Division of Purchasing. If
this schedule holds up, decisions (announcement of successful bidders) should be made
by April 15, 1997. A public hearing will be held by May 1, 1997, on the State Plan for
the 1997-98 E$P program. The State Plan will be submitted to DOE on or about May 15,
1997. On July 1, 1997, the 1997-98 E$P program will begin.
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STATE OF COLORADO
OFFICE OF ENERGY CONSERVATION /oF co
1675 Broadway ;tee/
Suite1300 I ' A A
Denver,Colorado 80202.4613
Phone(303)620-4292 � �
1ass.�
FAX(303)620-4288 ---
Roy Romer
Governor
December 20, 1996 u
Wade Buchanan
Director
Mr. Peter King
Director
Colorado Counties, Inc.
1177 Grant Street
Denver, Colorado 80203
Dear Peter:
In response to your letter to the Governor, and the Resolution approved by the
Commissioners on December 5, 1996, I want to report to you on changes to our final
decision to restructure and reduce the number of territories in the state weatherization
program. The final structure, while not responding to all concerns raised in the CCI
Resolution, includes some significant changes that are of interest to counties and which
we hope are responsive to their concerns. In addition, the state will conduct a full
evaluation of the new structure to be completed no later than June, 1999, to determine if
in fact it achieves the benefits it is designed to achieve. I commit to work with CCI and
county commissioners to help establish the criteria and methods by which this evaluation
will be conducted.
The specific changes that have been made in this final decision are:
• Rio Blanco and Garfield counties will IIoi be divided, and both will be included
entirely in the "High Country"territory(Region V).
• The area of Weld County including the town of Lochbuie will be included in Region I
rather than Region VII, as we originally proposed. This means that Weld County's
boundaries will be intact and that the county will be entirely within one service
territory.
• The small area of Douglas County just south of Centennial Airport will be included in
Region X rather than Region VII, as we originally proposed. This means that
Douglas County's boundaries will be intact and that the county will be entirely within
one service territory.
• All of Adams County will be included in Region VII, including those zip codes
originally assigned to one of the other two metro regions (regions VIII and IX). This
means that Adams County will be intact and that the county will be entirely within
one service territory.
• All of Arapahoe County will be included in Region VII, including those zip codes
originally assigned to one of the other two metro regions (regions VIII and IX). This
means that Arapahoe County will be intact and that the county will be entirely within
one service territory.
• All of Jefferson County will be included in Region VIII, including those zip codes
originally assigned to one of the other two metro regions (regions VII and IX). This
means that Jefferson County will be intact and that the county will be entirely within
one service territory.
• Portions of the City and County of Denver will be included in the other two metro
regions (regions VII and VIII) in order to reduce the large size of Region IX and
better equalize the size of metro territories.
The result of these changes is that all county boundaries will be preserved with the sole
exception of the City and County of Denver. Still, approximately 75 percent of the
eligible population in the City and County of Denver will fall within Region IX.
The evaluation of the new structure will be completed no later than June, 1999—two
years after its implementation. We believe this will provide sufficient time for the
changes to take effect and the benefits of these changes to be realized. Should
performance not meet expectations— either statewide or in any specific region—we will
reconsider territorial issues in order to further improve performance.
We will work with CCI and interested commissioners to establish evaluation criteria and
information needs so that we can implement the evaluation procedure in July, 1997,when
the new structure takes effect. We would propose to base the evaluation on the criteria
already stated—reducing administrative costs and increasing the number of units served in
all regions and counties. I would be very interested in adding criteria that other parties—
including counties—believe are important, and in working with CCI to design an
evaluation process that is fair and open and meets their needs.
Sincerely,
al
Wade Buchanan
Director
CC: Meg Porfido
Larry Kallenberger
Weatherization agency directors
Responses to Comments
on
Weatherization Interim Final Structure
The Office of Energy Conservation(OEC) and the Governor's Office together received
nearly fifty(50) separate letters during the comment period on the "Interim Final
Structure for the Colorado Weatherization Program". These included twenty three(23)
from local elected officials(county commissioners, mayors and city council members);
three from state legislators, nineteen(19) from board members,management and staff of
existing weatherization agencies; and several from a private citizens and other interested
parties. Two legislators also called the OEC offices during the comment period and
spoke at length with the Director. On December 5, 1996, Colorado Counties Inc. (CCI)
passed a resolution urging OEC to reconsider the decision outlined in the"Interim Final"
document. As a result of that resolution, OEC delayed the final decision in order to
consult further with CCI Staff and specific County Commissioners and County Staff.
Because of the extent of the comments received, OEC was unable to respond individually
to each letter. Instead, OEC has compiled this list of questions and comments and, where
appropriate,has provided responses to them. Our responses are in italics. For purposes
of this document, it was necessary often to rephrase or shorten questions or comments
and, in some cases, to combine a number of comments on the same topic. However, we
have tried to be accurate in conveying the true spirit and content of the question. Issues
raised by CCI also are included in this document.
Questions and comments have been categorized into ten general areas of interest as
follows:
A. Need and Authority for Restructuring
B. Decision Process and Timing
C. Service Territories and Boundaries—General
D. Service Territories and Boundaries—Specific
E. Data Used as Basis of the Decision
F. Staff Impacts
G. Request for Proposal and the Competitive Bidding Process C ---
H. Functional Changes and Streamlining the Program �1
I. Funding and the Allocation Formula 1
J. Next Steps and Miscellaneous Comments
A. Need and Authority for Restructuring
A number of comments and questions were received around the need or authority for
OEC to make this decision, or to do so in the manner in which it has been done. Specific
comments included:
•
1. OEC has never adequately established the need for changing the current
delivery system.
The existing agencies have done a good job providing services under the
current structure. Nevertheless,for at least five reasons, we believe there
is an opportunity for significant savings through restructuring.
First, we believe that having nineteen separate territories creates
significant administrative duplication. The program currently spends
$370,000 on state administration and another$2.15 million on local
administration and overhead(one-third of total budget).
Second, we believe some territories are too small to remain viable if
funding levels drop any further. We estimate that a territory should
support a minimum of 120 units per year(two field crews) to be viable
into the future. Eight of the current territories are below this minimum,
and five are less than half the minimum.
•
Third, some current boundaries clearly do not leand themselves to
maximizing the program's efficiency For example, under the current
structure, Pueblo agency must leap frog the Otero County territory to
serve Prowers and Baca counties.
Fourth,funding has been erratic for at least the last eight years—
increasing as much as 25 percent in some years and declining by almost
30 percent in others. In addition,federal finding is on a downward trend.
These sources have been cut nearly 40 percent recently, and may face
more cuts in the future.
Fifth, Public Service contributes its funds on a performance basis. At
current production levels, the program is not able to use all of these funds
and leaves $400,000 on the table each year.
For all of these reasons, we believe there are significant opportunities for
savings through restructuring.
2. OEC has eliminated agencies without affording them appropriate due process.
This is not correct. OEC has eliminated no agencies. All existing
agencies will continue to provide service to existing territories according
to the terms of their existing contracts. However, these contracts
terminate June 30, 1997. On July 1, 1997, the new service territories will
take effect. Providers for those territories will be chosen during the first
half of 1997 in accordance with all appropriate State and Federal Rules
2
and Regulations. No agencies have been eliminated, and no due process
issues are involved. OEC has full authority as grantee to make these
decisions.
3. OEC skirted the federal rules which clearly require that subgrantees may be
only community action agencies (CAAs),public entities or non-profit
entities.
OEC cannot and is not skirting the federal rules. All weatherization
agencies are currently CAAs or other public or non-profit entities. This
will not change in the future. Only those categories of agencies will be
eligible to serve the new territories.
4. A number of comments--especially from existing agencies, some county
commissioners, and CCI -- argued strongly that this decision contradicts or
violates Governor Romer's Smart Growth Initiative and Executive Order.
We believe this decision is consistent with the Governor's executive order
for the following reasons. First, the executive order pertains primarily to
issues of growth and development. The Whereas clauses of the executive
order clearly state it is in response to a recommendation of the
Interregional Council of the Governor's Smart Growth and Development
Initiative, and that its purpose is to establish "responsible growth related
practices. " The weatherization program is not primarily related to
growth or development issues.
Second, the executive order directs state agencies to "consider local and
regional visions"and to "actively consult"with local interests when
setting growth or development policy. Again, while we do not see this as a
growth or development-related program, we have tried to abide by the
spirit of the order through three comment periods and extensive, in-depth
discussions with local weatherization agencies. Clearly we
underestimated the level of interest Counties had in these changes, but we
have fried to rectify that oversight in the two weeks since the passage of
the CCI resolution. The final decision reflects several significant changes
in response to CCI's concerns.
Therefore, it is our interpretation that, to the extent the Governor's
executive Order applies to this process, we have complied with its
provisions.
B. Decision Process and Timing
Several comments raised concerns about the decision-making process and its timing.
3
Specifically, some asserted that the decision did not include or reflect input from the
coalition of existing agencies or the advisory panel that was established for this purpose.
Some argued that elected officials had not been adequately consulted or advised of the
process. The CCI resolution also reflected this concern.
This issue has been debated for over a year and a half. The Interim Final
Decision was made following a process that lasted more than seven months. It
included input from many parties including the coalition and the advisory panel.
It included issues discussed during a two-day Coalition meeting in Glenwood
Springs, two days of meetings with the advisory panel, and input received during
two comment periods. However, it must be understood that while input was
considered the decision we made was not, and was never intended to be, a
consensus decision. This was stated up front in the first memorandum dated May
23, 1996 that announced the restructuring process. The final decision has always
rested with the Director of OEC in consultation with PSCO.
County Commissioners were notified in writing of the issue as far back as
December 20, 1995 and as recently as November 6, 1996. On December 5, 1996,
Colorado Counties Inc. (CCI)passed a resolution asking Governor Romer to
intervene in the restructuring process. As a result, the Governor's Office asked
OEC to meet with County Commissioners to discuss their concerns. A meeting
was arranged by CCI and scheduled in Denver for December 16, 1996.
Unfortunately, a severe winter storm hit most of Colorado that day and none of
the Commissioners were able to attend the meeting. As an alternative to
rescheduling another meeting and further affecting the timeline, the Director of
OEC placed telephone calls to a number of County Commissioners who expressed
concerns to CCI. During the telephone calls, revisions to the Interim Final
Structure that OEC had intended to discuss at the meeting, as well as revisions
made in response to the CCI resolution, were discussed. In addition, the Director
of CCI also placed telephone calls to County Commissioners and worked with the
Director of OEC to ensure their concerns were received and responded to by the
Director of OEC.
As stated above, OEC underestimated the level of interest Counties had in these
changes. Because only six Counties currently are service providers, we made the
assumption that most other Counties would not be interested. We also assumed
that working with the staffs from those six Counties was adequate. Both
assumptions were incorrect and we regret the oversight. Nevertheless, we worked
hard to respond to County concerns, and the final decision reflects that
Comments were received from several agencies suggesting that public hearings need to
be held before this decision is finalized.
There will be no public hearings held specifically to address the new structure.
There is no requirement for such hearings and the schedule and timeline is too
4
tight to accommodate any. As required by program regulations, the new structure
will be included in the state plan and, as always, there will be a public hearing on
the state plan prior to its submittal to the U. S. Department of Energy (DOE) near
the end of May, 1997. All those who submitted comments will be notified of the
hearing date and location.
One comment argued that there was not enough time allowed for input and preparations,
and that the final decision should be delayed as a result. Another suggested that the
timeline was too slow,that too much time was allowed and that OEC needs to speed up
the stages of this process.
The timetable was announced in the May 23, 1996 memorandum and has been
adjusted several times to accommodate specific requests. Extensive input has
been received during the announced time frame.
Moving back the timetable would cause difficulties in meeting important
milestones (such as Request For Proposal preparations,public hearing, or state
plan submission). On the other hand, moving up the timetable would rush
important decisions and is not likely given established state and federal
procedures. It therefore is unlikely the timetable will be adjusted significantly
one way or the other.
C. Service Territories and Boundaries— General
A number of comments received focused generally on the appropriateness of the new
territories and their boundaries. The CCI resolution focused specifically on these
concerns. Comments included:
1. Questions about the decision to base several territorial boundaries on zip
codes which some suggested would "cause chaos;"
The final decision relies much less on zip codes than the Interim Decision.
As with any change there will be some rough spots during start up. We
are confident that adjustments can be made and the rough spots will
smooth out over the course of the first year.
Applicable data or information exists by zip codes as well as by counties,
and HHS has stated that they foresee adjustments within the Low Energy
Assistance Program (LEAP) without great difficulty.
2. Arguments for keeping county lines intact, and for keeping council of
government(COG) lines intact;
The final decision conforms to County boundaries everywhere except for
the City and County of Denver. However, we were unable to retain COG
5
boundaries in every case and achieve the size of territories we believe are
necessary.
3. Concerns that the large size of at least four of the territories raised very
difficult issues such as travel(especially in the high country);
Large geographical areas with sparse population density leave us with no
other alternative than to have large territories, but with manageable
production numbers. Territories are largely administrative units. For this
reason, we are hoping and will encourage successful bidders to examine
all options for establishing local satellite crews, thereby minimizing
production travel. It must be remembered that local agencies are allowed
and in some cases encouraged to contract with other local agencies for
service delivery in outlying areas.
4. Concerns that the territories did not conform to a variety of existing regional
programs, including programs at the Department of Health and Human
Services (HHS) and the Department of Local Affairs (DOLA), and including a
specific question about whether OEC had consulted with the Division of
Housing(DOH) about the effect the change in territories might have on the
Rehab program administered by that agency.
Making our delivery system coincide with other programs'regional
schemes was not seen as a necessity because regions didn't coincide
before OEC began the restructuring process. In addition, the fact that
there are several different regional divisions would make it impossible to
coincide with all of them; therefore, there would always be non-matching
divisions.
We have provided this plan to DOH and have had discussions with them
about it as well as the impact our plan may have on their programs. We
have been told that they have no intention to retract any of their programs
or funding from agencies that currently receive it. They have told us that,
in most part, who receives their funding is determined by the counties
which receive the services and that it would be up to the counties as to
who would receive funds, such as Community Service Block Grant
(CSBG). We have not been told of any significant concerns they might
have due to the implementation of our restructuring plan.
D. Service Territories and Boundaries— Specific
A number of questions concerned specific boundaries or specific territories:
1. There were some comments specifically asking why Rio Blanco and Garfield
counties had been divided by zip codes rather than left intact.
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The main reason for dividing these counties was our belief that existing
transportation corridors would make it most cost-effective to serve the
western portions of the counties with crews that also serve the Grand
Junction area. By the same principle, we believe existing transportation
corridors made it more efficient to serve the eastern portions of these
counties with the same crews serving Eagle, Moffat, Pitkin, and Routt
counties.
We have further reviewed this decision based on comments received and
the CCI resolution. We have chosen to include Rio Blanco and Garfield
Counties back into Region V. We have done so knowing that this area is
quite large, however, we feel it is a prime candidate for taking advantage
of the allowable (and encouraged) option to subcontract, or establish
satellite crews with existing trained agency staff in the area.
2. One question received asked about the inclusion of Douglas County in Region
X (Pikes Peak)rather than in one of the metro area regions.
We believe Douglas County could be served well in either region, and we
acknowledge that it is well served now by Arapahoe County. However,
the primary reason for including Douglas County in Region X was to
include Public Service Company territory in that region. Under the new
structure, each of the ten territories has at least some Public Service
territory, which means that all regions will receive some level offunding
from PSCO. We believe this will benefit not just that territory, but the
entire state.
3. Adams County strongly objected to the large number of its residents-(over 50
percent) who were included in the West Metro Area under the interim final
structure.
Upon further review, we agreed with Adams County and CCI that the lines
of the metro area territories should conform to existing county boundaries.
Therefore, we have adjusted the new boundaries of the three metro
regions accordingly. Some adjustments to the boundaries of the City and
County of Denver have been made in order to reduce the large size of that
territory with regard to eligible population. These new boundaries are
indicated on the map accompanying the final decision document.
4. The staff and board of the Southwest Resource Center(SCR), several
legislators and a number of boards of county commissioners questioned the
appropriateness of placing those counties currently served by SCR in a much
larger territory that extends north to Grand Junction. They argued that this
area is geographically unique and isolated by mountains, which would make
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service by an agency to the north problematic.
While it is true that some areas of the state are geographically isolated
from others, this by itself was not seen as sufficient reason to establish a
fully-staffed agency to serve the area. We understand the geographic and
cultural uniqueness of the region currently served by SCR, as we do with
other regions that have been included in larger territories. We would
refer you to our response to C-2 (above) concerning the larger size of a
number of territories. We would also like to point out that, should the
main office of the agency selected to serve the new southwest territory be
outside the current SCR area, it makes sense that existing crew staff
should be retained to serve the area, and we will encourage bidders on the
area to look closely at establishing existing crews as "satellites"to their
main office. This would allow for the retention of local expertise and
knowledge of the area, and would help to ensure year-round service,
especially in the area of emergency services.
5. Arapahoe County also suggested that combining the bulk of Arapahoe and
Adams counties into one territory, while leaving Jefferson County essentially
its own territory, awarded an inefficient service agency at the expense of two
of the states best performing agencies.
No agencies have been selected to serve any of the new territories. All
existing agencies will have the opportunity to bid on any territory. The
data that was presented was based on projected budgets not actual
expenditures, and did not include in-kind contributions. It is the intention
of OEC to work with all agencies in the future to assure efficiencies in
administrative and support costs, as well as measures per unit.
In addition, in order to reduce the metro area down from four territories
to three, this combination seemed to be the most logical Denver County
is too large(population) to combine with other areas and Jefferson
County is too large (geographically) to combine with either Adams or
Arapahoe County. Also, both Adams and Arapahoe Counties had listed
working together as an option in their proposals to OEC.
6. Most existing agencies asked to have the territories they currently serve
reinstated for the 1997-98 program year.
To do so would not meet the goal and criteria that we are trying to
accomplish by restructuring. The primary reasons for establishing new
territories, as stated before, are to achieve cost savings by reducing
administrative and support costs at both the state and local level, and by
ensuring each territory is sized appropriately to ensure the efficient use
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and support offield crews. We understand this is very disruptive to a
number of existing agencies. However, we believe the changes are
justified by the increased service we expect under the new structure.
E. Data Used as Basis of the Decision
A number of comments questioned the existence or validity of data to support the
changes in territories and the claim by OEC that these changes will result in increased
service. In general, OEC was asked to provide more detail and facts to support is
decision. Specifically:
1. A number of questions were directed at what appeared to be insufficient data
to support the premise that fewer territories will result in cost savings and
increased production in the field. Several specifically asserted that the
opposite would occur--that 200 additional units would not be achieved
statewide, and that per unit averages would increase with the new territories;
Because the new structure has not yet been implemented, it is true that
there are not enough iron-clad "facts" to prove without doubt that what
we believe will actually occur. It would, in fact, be impossible to make a
decision like this without relying at least in part on assumptions and
calculations rather than proven facts. Nevertheless, we have spent a great
deal of time questioning the assumptions upon which we are making this
decision, and we have a high level of confidence that the projected savings
and increased production will occur. We have also committed to CCI to
work with them to establish an evaluation procedure and criteria to
determine whether the benefits we expect actually are achieved.
The pivotal assumption that leads us to believe this new structure will
result in at least 200 additional units per year is that consolidating the
administrative and support functions into fewer agencies will save at least
50 percent of the average cost of these f motions per agency eliminated.
Because we have not selected the new service providers, it would be
inappropriate to speculate which agencies will be eliminated. However, a
conservative estimate could be based on the average of the sixteen existing
agencies with the lowest administrative expenditures, which we calculate
to be$91,500 per year. Assume that the nine agencies eliminated average
that level of expenditure (9 x$91,000 = $823,500). Multiply that total by
50 percent ($823,500 x 0.5 = $411,750) and you get what we believe is a
conservative estimate of savings. If the per unit average cost remains at
the current$2,000, then dividing the total savings expected by that number
will give you the projected number of additional units we expect to be able
to do under this restructuring($411,750 x$2,000 = 206).
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In addition to this calculation, Public Service will provide another$700
per additional unit in its territory. PSCO serves roughly 70 percent of the
state's population. Assuming the new units are evenly distributed, then
144 should be in PSCO territory, resulting in 144 x$700, or$100,800, in
additional funding to the program. Again, dividing by the per unit
average of$2,000, that should mean an additional 50 units on top of the
206 already calculated,for a total of 256 additional units as a result of
restructuring.
To be conservative, we have projected 200 additional units rather than
256.
2. Several requests were made for more explanation and support for the assertion
that it is not cost effective for an agency to be expected to serve less than 120
nits or more than 600 units per year; and
This decision was based on input provided by various agency personnel
and advisory panel discussions. This input.and the discussion that evolved
centered around looking at a minimum number of units necessary to keep
a crew busy, and a maximum number before additional administrative
support is necessary. Because these numbers can vary depending upon
each agency's method for providing services and other factors such as
geographical characteristics, there is no steadfast factual number of units.
However, during the discussions, 50-60 units per crew, and 300-400 units
per agency kept coming up as workable numbers.
3. One request was made for an explanation of how OEC arrived at its projection
of units produced for next year. They specifically asked if the numbers used
in the interim final decision included the anticipated 200 additional units.
Projections for units to be completed was based on the number of units
served per county for 1995. For agencies serving more than one county,
the reduction was kept proportional to last year's actual production. If
individual agency service to a particular county was different last year
than normal, this was not taken into account. If aberrations exist, it was
not thought to adversely impact the overall structure. No, it does not
include the 200 additional units the plan assumes.
F. Staff Impacts
Several comments were concerned with the decision having a very negative impact on
existing agency staff. One said that the decision would jeopardize the jobs of trained
staff, contractors and material suppliers, and another said that OEC's expectation of
retaining trained staff was "optimistic and naive." In addition, several asked whether
program staff at OEC would be reduced proportionate to the number of agencies cut, and
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whether an advisory panel would be used to help make these decisions.
We disagree that this will be the result of this plan. We will do all that we can to
minimize this potential and, with more units being planned, there should be plenty
of work for those currently involved in producing units.
Feedback from local crews indicates that an opportunistic attitude exists, which
means some crews are looking at the restructuring as an opportunity in their
careers. We will do everything we can to encourage and facilitate the retention
of trained staff. At the same time, we understand that some loss of staff may be
unavoidable. Once the bidders are selected, we will commit to working with all
agencies to rebuild our working relationships and facilitate opportunities for
local staff
Any restructuring of the state staff will be according to workload. However,
through attrition over the past couple of years, the state staff and the amount of
program funds retained at the state level have already been reduced by a greater
percentage than the reductions being made to the local service delivery network.
For example, in the Weatherization State Plan for 1995-96, the number offull
time employees (FTE's)funded by weatherization grant funds was 10.5, and the
amount ofprogram funds retained at the state level was $700,000. The State Plan
for 1996-97 was cut back to include 5.5 FTE's (a 49%reduction), and the funds
retained at the state level was $383,226(a 46%reduction). In addition, since the
state plan was written, there have been additional reductions in FTE's to 5.1 due
to attrition, and an amendment to the state plan that will show the state budget at
approximately$370,000. In total, the state staff has been reduced by 52%, and
the state budget by 48%.
Currently, there are no intentions to involve an advisory panel in determining the
functional changes. We do intend, however, to involve agencies in helping us
review the proposed changes. .
•
G. Request for Proposal and the Competitive Bidding Process
A number of comments and questions focused on the competitive bidding process that
will be used to select the service agencies in the new territories. Specific comments or
questions included:
1. One comment suggested that only existing weatherization agencies be allowed
to compete to serve the new territories, while several others asked if existing
agencies would be given "preferential standing" in the process.
We feel the fairest competitive bidding process includes allowing all
eligible organizations to submit a bid. Weatherization agencies, by
regulations, will be given preference for their experience and good
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performance.
Existing agencies will most definitely be given preference. This is not only
required by federal program rules, but we feel this makes a lot of sense
since weatherization agencies have highly trained staff and vast
experience in providing services. However, the possibility exists that other
providers may be equally qualified and able to provide quality services
and, therefore, should have the opportunity to compete.
2. One commenter asked if an agency would be allowed to submit an application
for a territory in which it currently does not have an office.
Yes. All agencies and non-agency bidders will have the opportunity to bid
on any area they choose.
3. There were some questions asking if agencies would be allowed to bid on more
than one service territory. One suggested was made that agencies be allowed to
bid on and serve only one territory.
While it is most likely that single-area bids will be submitted,primarily
due to feasibility reasons, we choose not to preclude multi-area bids.
4. One commenter asked OEC what it will do if no existing weatherization
agency chooses to bid on one of the new territories because they consider the
new territory to be unmanageable.
We will try to recruit a neighboring agency to cover the area, will recruit
another agency, or we will attempt to recruit individuals to form an
eligible agency. The final option would be for the state to provide
services,probably through a subcontracting process. At any rate, services
will be provided to all areas of the state.
5. OEC was asked to prioritize and give a point value to the qualification
determination criteria that were listed in a previous response dated October 31,
1996.
At this point in time we cannot do this because the REP has not been
completed yet. This information will be provided in the RFP as part of the
Evaluation criteria and it must be released to all potential bidders at the
same time.
H. Functional Changes and Streamlining the Program
Many comments focused on what have been termed "functional" changes, or the
streamlining and simplification of program policies and procedures. Specifically,the
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following suggestions were made:
-- The OEC should suspend restructuring and instead focus on functional
changes,which could save considerably more money and result in an even greater
increase in units produced. Several comments pointed out that the Colorado
Energy Coalition(existing agencies) had offered a number of such ideas in a letter
dated September 29, 1996, and that an additional 150 to 200 units could be
achieved this fiscal year,with even greater savings in the coming years;
OEC should implement the same policy that Public Service Company intends
to implement in 1997, allowing agencies to use their money "where necessary"
and generally giving agencies more flexibility in the use of their grant;
-- The agencies should play a much greater role in training,monitoring and
inspecting .
OEC has always agreed that 'functional changes"need to be made, and
we intend to implement changes next year. All recommendations and
input are currently being reviewed and a document detailing the proposed
functional changes will be provided to agencies in the near future for
review and comment. However,functional changes will be made in
addition to, not in lieu of restructuring.
OEC expects service agencies to play a strong role in training,
monitoring, and inspecting, in the future. Sharing of all the expertise in
the state makes a lot of sense, and the establishment of a peer-
monitoring/inspecting scheme will be pursued A strong training
component comprised of OEC, PSCO, and agency staff will be necessary
to help implement the functional and reporting changes envisioned for
next year. Any suggestions are welcome.
Funding and the Allocation Formula
A number of comments touched on options for increasing funding to the program or the
effect of restructuring on the current allocation formula. Specific questions and
comments included:
1. How will the projected savings from restructuring be reallocated?
Most likely any substantial increase in funds will continue to be allocated
as they have in the past, through the allocation formula or negotiated
proposals from agencies.
2. What are the funding levels and production goals for this year and for next
year? Does OEC have any projected allocation levels to go along with the
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projected increase in the number of units produced?
Next year's funding levels per service area are not known at this time, and
therefore only estimated allocations and production levels can be made.
The projected production numbers that were provided with the Interim
Final Structure were based on last year's production minus thirty(30)
percent. Detailed allocations and the number of units depend upon the
final federal allocations and any changes to the allocation formula.
3. Will there be any changes to the allocation formula? Will the $2,400 per unit
maximum be the same next year?
Yes, as part of the functional changes, there likely will be changes to the
allocation formula. The nature and extent of the changes have not been
determined yet but the proposed changes will be provided to all agencies
for review and comment prior to any final decisions.
There will probably not be a $2,400 maximum per unit policy for the
1997-98 program. The staff has discussed this during their initial reviews
of proposed functional changes and will include it as one of their
proposed changes to be made for next year.
4. Matching funds are endangered, especially if local officials are not more
involved in the decision-making process.
We disagree with the premise and the conclusion here. It is our belief that
local officials are interested in services being provided within their
communities and would not cut off the availability of matching funds to
any agency that is involved in implementing a plan with a goal of
providing more services to its citizens.
5. OEC should work with the 13 agencies which currently receive Public Service
Company money to ensure that the entire $2.6 million that is available can be
allocated.
We are hoping to address and achieve this through the new structure and
future functional changes.
6. OEC should ask the Governor to transfer funding from the LEAP block grant
to increase the weatherization program's share from 15 percent to 25 percent.
Also, OEC should ask the Governor to transfer 10 to 15 percent of Colorado's
Community Service Block Grant (CSBG) into weatherization.
These suggestions will be forwarded to the energy assistance reform
task force that the Governor has recently appointed to examine issues
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regarding low-income assistance programs in Colorado. We believe that
to work outside this task force would be unproductive and inappropriate.
We are confident that a thorough discussion of these issues will take place
in that forum.
With regard to CSBG funds, the amount available for the Governor to
appropriate is quite small, according to DOLA. The vast majority of these
funds go to the counties to be used according to local priorities. It would
be up to individual counties to increase the allocation to weatherization.
7. Fund a$35,000 action plan,proposed by existing agencies, to identify and
pursue alternative sources of funding for agencies in the weatherization
program.
Currently we have no funds available to fund such an effort. If the
coalition would like to provide more information on how this would be
implemented, we are open to considering it during the formation of the
budget for next year. Alternatively, the coalition may wish to submit an
"unsolicited proposal"to the OEC to use non-weatherization funds for
this purpose. In either case, the proposal would be evaluated on its merits
to determine both eligibility and appropriateness for funding.
J. Next Steps and Miscellaneous Comments
1. What will happen to the hundreds of thousands of dollars that the state spent
on vehicles, tools and equipment under the existing structure?
Capital equipment purchased with program funds will be redistributed
and items that are not needed will be sold and, by regulation, the money
will be put back into the program with the intent to produce additional
units.
2. What happens when OEC "disappears?"
OEC is not planning to "disappear". Because we are part of the
Governor's Office, it is possible that the new Governor who takes office in
1999 may wish to change or even close the office. It is also possible that
the new Governor may wish to keep a smaller office in operation to
oversee the weatherization program as well as the other federally funded
programs going through the OEC. In any case, the state will continue to
administer a weatherization program as long as federal funds are
available for that purpose. If OEC closes, weatherization will be
transferred to another state agency.
3. How many OEC staff hours were spent in this restructuring process and in
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redrawing the territory boundaries?
It would be difficult to quantify the number of hours OEC staff worked in
conjunction with PSCO staff on this process. However, it was significant.
A great deal of information was considered and discussed, including all
the input received from agencies, in order to arrive at the boundaries in
the Interim and Final Structures. The time and resources spent are
justified by the anticipated savings.
4. OEC should take an active role in developing and building bridges between the
many programs, cities, counties and staff involved in the weatherization
program.
We agree completely with this statement. We intend to work closely with
the agencies to build solid and trusting working relationships. We also
intend to work closely with agencies on the next step of this process,
involving functional changes to the program.
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