Beneficiary Criteria Input

Department of Energy
Washington, DC 20585
June 21, 2024
REQUEST FOR:

DAVID STAUDT
ASSOCIATE DIRECTOR, FINANCIAL ASSISTANCE
NATIONAL ENERGY TECHNOLOGY LABORATORY
[email protected]

FROM:

ARIEL HOROWITZ
DEPUTY DIRECTOR, GRID MODERNIZATION
GRID DEPLOYMENT OFFICE
U.S. DEPARTMENT OF ENERGY
[email protected]

SUBJECT:

Puerto Rico-Energy Resilience Fund (PR-ERF) DE-FOA0003096, Revision to Definition of “Very Low-Income SingleFamily Household”

Dear Mr. Staudt:
On June 6, 2024, DOE requested PR-ERF Topic Area 2 awardees feedback on additional programs
DOE should consider as potential approaches for validating the eligibility of very low-income
beneficiaries under the program. Importantly, DOE must be able to independently validate
beneficiary eligibility regardless of the approach by which eligibility is demonstrated. On June 10,
DOE received responses from Barrio Eléctrico (BE), Solar United Neighbors (SUN) and
Environmental Defense Fund (EDF). On June 14, DOE received a response from Comunidad Toro
Negro (TN). Let’s Share the Sun (LSTS) did not respond to the request.
In summary, GDO recommends including Plan Vital and USDA Section 502 and 504 programming
as modalities for verifying very-low-income status. GDO also recommends including age
verification as an appropriate modality for verifying energy-dependent disability status and
including temperature control devices as eligible medical equipment for energy-dependent critical
load purposes.
Below is the summary of the recommendations provided by awardees and GDO’s analysis.
Appendix A includes the responses submitted by awardees.

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1. Awardee recommendation: Plan Vital beneficiaries- all awardees recommended Plan Vital
as one alternative for proof of verification of very-low-income beneficiaries.
a. GDO analysis: DOE can verify proof of eligibility by requesting the beneficiary
the certification letter received annually from the PR Department of Health
(PRDoH) or a copy of their insurance plan card (recommended by PRDoH
officials). The certification letter includes the issued and expiration dates.
i. Plan Vital has 13 eligibility categories under which beneficiaries can
qualify. The categories are:
1. Parent/Caregiver
2. Medicaid for underage children
3. Adults
4. Pregnant women
5. Newborn
6. Title IV-E for underage children
7. Foster care
8. CHIP
9. ABD category (elderly, blind and disabled)
10. Due to medical conditions
11. Safety (Red de Seguridad)
12. Government employees
13. ADAP (HIV patients
ii. Income Levels: For 2024, the monthly income level for eligible Plan Vital
beneficiaries is $1,677 for a family composition of one (1) individual, for
an estimated annual income of $20,124. For a family composition of two
(2) the monthly income is $2,800, for an estimated annual income of
$33,600. Table 1 includes data as of April 2023. GDO does not anticipate
substantive changes for the 2024 eligibility levels. Similarly, to Plan Vital,
the Nutritional Assistance Program (NAP) follows one island-wide income
formula. It does not vary by municipality. Table 2 includes NAP’s
Maximum Monthly Net Income by Household Size.
b. GDO recommendation: As previously discussed, GDO recommends including
Plan Vital as an acceptable approach for verifying beneficiary eligibility.
Table 1: Plan Vital: Income Levels

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Table 2: Maximum Monthly Net Income by Household Size, NAP 2021

2. Awardee recommendation: Social Security benefits for disabled participants (Social
Security Disability Insurance (SSDI)).
a. GDO analysis: As proof of eligibility of an individual with an energy dependent
disability, applicants can submit a certification letter from the Social Services
Administration. This certification letter is available electronically. However,
SSDI participation does not constitute validation of household income and DOE
does not have the ability to independently validate household income based only
on SSDI participation. While some beneficiaries recommended that DOE
leverage SSDI participation combined with a separate independent income
verification modality based on the HUD FY 2024 Income Limit Table, it is not
clear what such a modality would be.
b. GDO recommendation: GDO does not recommend including SSDI as an
acceptable approach for verifying beneficiary eligibility.
3. Awardee recommendation: Government Retirement Pension Systems.
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a. GDO analysis: The Government of Puerto Rico (GPR) has five retirement
systems for: 1) Employees of the GPR, 2) Teachers, 3) Judiciary System, 4)
University of Puerto Rico and 5) Employees of the Puerto Rico Electric Power
Authority. The Retirement Systems Administration (ASR) implemented a defined
contribution plan that is part of the pension reform demanded by the Fiscal
Oversight Board. An individual receiving a pension can obtain certification
through the ASR virtual platform. However, DOE would have no way of
validating whether the individual applying under PR-ERF program has additional
sources of income (for example, due to a new employment opportunity).
b. GDO recommendation: GDO does not recommend including public sector
pension systems as an acceptable approach for verifying beneficiary eligibility.
4. DOE Front Office recommendation: USDA programming
GDO also received the following recommendations from DOE’s FO on very-low- and
low-income USDA programs for consideration:
• Section 502 – Single Family Housing Direct Loans
o Eligibility: Low- and very-low-income in eligible rural areas
• Section 504 – Home Repair Loans
o Eligibility: Very-low-income homeowners
• Section 504 – Home Repair Grants
o Eligibility: Very-low-income homeowners aged 62 or older
• Section 504 – Single Family Housing Rural Disaster Home Repair Grants
o Eligibility: Very-low and low-income homeowners whose property sustained
damage as a result of a CY 2022 Presidentially Declared Disaster
• Section 504 – Single Family Housing Repair Loans & Grants in Presidentially Declared
Disasters Pilot
o Eligibility: Very-low-income homeowners whose property suffered disasterrelated damage from Presidentially Declared Disaster on or after July 18, 2022
a. GDO analysis: DOE met with USDA representatives on June 17, 2024 to discuss
eligibility criteria for the programs listed above. In addition to income level, a
FICO score between 620 (section 504) and 640 (Section 502) is required. HUD
income limits varies per municipality; for an individual, it ranges from $14,150$18,400 (income tables). USDA recommended DOE that as proof of eligibility,
applicants can submit a copy of the loan. USDA indicated that applicants also
receive a certification once eligibility criteria is verified indicating that the
individual qualifies.
b. GDO recommendation: GDO recommends including USDA Section 502 and 504
programs as an acceptable approach for verifying beneficiary eligibility.

Table 3: Comparison of Monthly Income Levels per recommended program
Plan Vital Nutritional Assistance Program
USDA
HUD
$1,677
$ 619
$1,179-$1,533 $ 808
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Some awardees included additional recommendations for DOE to consider as proof of eligibility
for individuals with an energy dependent disability.
1. Awardee recommendation: Age-based qualifications for fans and air conditioning with
regards to energy-dependent disability eligibility.
a. GDO analysis: Specific age ranges can be defined as qualifiers for the need to
control body temperature, focusing on the elderly at age 65 years and older and
children at age 4 years and younger. For those that do not fall in these age ranges,
GDO suggest that a doctor's note or equivalent would be a suitable justification
for heat stress risk. By defining based on age, the PR-ERF program can more
easily streamline the application qualification process, primarily based on date of
birth, and provide greater impact to those that would most benefit.
b. GDO recommendation: GDO recommends allowing age verification as acceptable
approach for verifying energy-dependent disability status.
2. Awardee recommendation: Inclusion of air conditioning, dehumidifiers, and air
purification devices as qualifying medical devices.
a. GDO analysis: Fans are already listed as qualifying equipment and, therefore, air
conditioning and other examples of body temperature cooling equipment seem
reasonable to add to the list. As a separate need, during certain times of year when
the Sahara Desert affects air quality in PR, many seniors' breathing is affected.
The only things that help here are air conditioning units or oxygen tanks, leading
to a double benefit for air conditioning. GDO consulted with NETL’s Chief
Medical Officer, Vicki Everly. Dr. Everly concluded that it is not unreasonable
these requests be deemed appropriate for some form of cooling equipment based
on age alone.
b. GDO recommendation: GDO including temperature control devices (including air
conditioning) as eligible medical equipment for energy-dependent critical load
purposes.
Lastly, Barrio Eléctrico also requested a location deviation from the Program Guidelines for Topic
Area 2 selectees who work predominantly outside of the last mile communities (LMCs). On
February 21, 2024, DOE had addressed this request and made the following program
determination: TA2 awardees are able to install (1) low-income homeowners with energydependent disabilities in any geography, or (2) low-income homeowners inside of LMCs.
Based on the above recommended programs to add to the definition of “Very Low-Income SingleFamily Household”, GDO recommends NETL Plan Vital as an acceptable program to confirm very
low-income single-family households. DOE can request applicants the certification letter provided
by PRDoH or copy of the health insurance card. GDO also recommends NETL to consider USDA’s
sections 502 and 504 programs. Since these programs are long-standing programs, GDO
recommends establishing a cutout date for applicants to be considered eligible under the PR-ERF
program. GDO recommends as a start date either September 17, 2022, when Hurricane Fiona hit
the island, or December 29, 2022, when the Consolidated Appropriations Act was signed by
Congress. DOE requested USDA information regarding number of applications received, under
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review, rejected, approved as well as main reasons for rejected applications after the cutout dates
stated above.
If recommendations are considered favorable by NETL, DOE will proceed to engage with DOE’s
Paper Reduction Act and GC-22 for the verification of the intake form currently in used and
approved by the Office of Management and Budget (OMB).
Please do not hesitate to contact me with any questions.
Sincerely,

Ariel Horowitz

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Appendix A: Potential Approaches for Validating the Eligibility of Very Low-income
Beneficiaries submitted by TA2 Awardees, June 10, 2024
Organization
SUN

Recommendation
We think that Plan Vital, social security for disabled participants, should also be considered,
given that they are also low-income folks. We discussed this as a team and would like to support
the idea.
In addition, more importantly for our team, we would also appreciate the DOE's response to our
suggestion to consider age-based qualifications for fans and air conditioning with regard to
energy-dependent disability eligibility. Given that there is already evidence of the need for this
type of medical equipment for ages 4 or less and 65 and over, we are wondering if a medical
certification is not needed in this case.

EDF

BE

1. To support the inclusion of Plan Vital (which provides government-run health services for
low-income families)
2. To suggest the inclusion of beneficiaries of government retirement pension systems
(teachers, firefighters, police officers, and others) and Social Security
EDF and partners would like to suggest DOE investigates if Social Security Retirement
beneficiaries could be identified as potential beneficiaries for PRERF Program. Since social
security monthly or yearly benefit varies for each person or family depending on multiple factors
(total contribution, age of retirement, disabilities, payment of healthcare, etc); this criteria could
be combined with an additional verification method to identify and confirm families that
have low or very-low income using the HUD FY 2024 Income Limit Table (attached the
table with income limits for Culebra) or tables that are used in Culebra to qualify residents that
live in a local retirement home for elders, Felipa Serrano. These verification methods are used by
the Culebra Municipality, Federal Program Office, and other programs to validate families or
residents that qualify to receive federally funded services or benefits.
First, we fully endorse the addition of Plan Vital enrollment as an income qualifier. We have
surveyed our records of the more than 600 homes we have already assessed in the communities
where we operate. We find that Plan Vital would expand the number of those with qualifying
income by nearly 10%.
Second, we recommend inclusion of air conditioning, dehumidifiers, and air purification
devices as qualifying medical devices, and also request guidance on doing so. The FOA
explicitly embraced those devices for “individuals who are unable to control body temperature.”
We ask that homes with persons under 4 (infants) or over 65 be automatically qualified for air
conditioning as a necessary medical device. Infants and elderly are especially susceptible to the
humidity and high temperatures in Puerto Rico. Having access to air conditioning will improve
the quality of life for many infants and elderly who are challenged to manage their own comfort,
and may even save some from overheating.
We ask that the inclusion of a/c, dehumidifiers, and air purifiers as qualifying medical devices
also extend to those with chronic respiratory conditions such as asthma, or for any other reason
that is supported by a doctor’s recommendation. As an expansion of the qualifying medical
conditions, it would ensure the eligibility reaches a significant segment of the very low-income
residents who would experience a measurable increase in quality of life with a DOE-funded
solar system. The DOE team may be aware that Puerto Rico has one of the highest rates of
asthma in the U.S., affecting 12-15% of the population and weighted heavily towards children.
This percentage is not surprising given the tropical environment rich with humidity, mold, and
other allergens. Asthma limits one’s ability for physical exertion and degrades sleep, and can
worsen without management. Electric appliances such as a/c are a simple and effective
mitigation that is out of reach for many very low-income homes; a DOE system would lower the
cost of power and thus make temperature and air quality control accessible. A doctor’s

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recommendation is an “operationally viable” way to confirm the need for the appliance due to
asthma or other condition (or age), and falls within the program scope of supporting resiliency in
the home and saving lives.
Finally, we ask that the DOE team consider allowing a location deviation from the Program
Guidelines for Topic Area 2 selectees who work predominantly outside of the LMCs. All of
Puerto Rico experiences the hardship of frequent outages and also long outages in the wake of
nature events. In January, Barrio Eléctrico provided the DOE team data from its existing
installations showing the high number and frequency of area outages affecting those homes in
Isabela and Coamo. Both are municipalities where we work and that are mostly devoid of LMCs.
We ask that the DOE allow beneficiary status for very low-income homes in the communities
where we work and have been working, even if those homes do not have a qualifying medical
condition or do not sit within an LMC.
To further support this request, BE offers an informative link, below, to the research and a map
created by a University of Puerto Rico Mayagüez team, lead by professor (and BE board
member), Dr. Marcel Castro-Sitiriche. The map shows the barrios within each municipality with
outages of more than 122 days after Hurricane María. The data proves that many homes outside
of the LMC areas also suffer from no resiliency. BE’s work in these communities serving lowand moderate-income homes proves that there are many homes that fit within the PR-ERF scope
and spirit but for their location outside of an LMC. The deviation would be operationally viable
if documented in the award documents for each entity as a negotiated agreement. The envisioned
agreed deviation would extend eligibility to barrios that qualify from the matter of the map at the
link below and based on the geographic reach of that entity’s operations.
https://bit.ly/boricuaENERGYinjustice
Easing of the LMC requirement as an allowable deviation for community programs like ours
would be an excellent means to incorporate needy and deserving homes in the beneficiary ranks
of the PR-ERF.

TN

We applaud your constant review of the PR-ERF program guidelines for the purpose of ensuring
programmatic success. We are available to discuss further the above suggestions should you
have any follow-up questions.
Según lo conversado en nuestra última reunión, nuestra posición como entidad que agrupa a
veinticinco (25) suscriptores que componen a la Comunidad Solar Toro Negro, es que podemos
considerar cualquier criterio de elegibilidad que califique al grupo como un todo y que no
excluya a ninguno de nuestros suscriptores. Dentro de estos criterios podrían ser, pero no
necesariamente, varios como; la Certificación del Negociado de Energía de Puerto Rico (NEPR)
como Microrredes Registradas según dispone el Reglamento 9028 del 18 de mayo de
2018, bloques censales, tractos censales, y/o cualquier otro criterio que nos permita atender la
necesidad energética de todos nuestros suscriptores por igual.
Translation: As discussed at our last meeting, our position as an entity that brings together
twenty-five (25) subscribers that make up the Toro Negro Solar Community, is that we can
consider any eligibility criteria that qualify the group as a whole and that does not exclude any
of our subscribers. Within these criteria there could be, but not necessarily, several such as; the
Certification of the Puerto Rico Energy Bureau (PREB) as Registered Microgrids as provided
for in Regulation 9028 of May 18, 2018, census blocks, census tracts, and/or any other criterion
that allows us to meet the energy needs of all our subscribers equally.

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