Federal Alignment Update
Common Energy Efficiency Requirements
This month’s alignment eeport focuses on the energy efficiency requirements among various Federal rental programs as they currently exist and with recommended improvements toward alignment noting challenges to implementation.
What I find most curious about this recommendation is that it seems to promote the least across-the-board alignment by suggesting a four-part strategy that delineates different energy efficiency requirements using different standards based on the funding type in combination with the type of development or rehabilitation work. Sound confusing? I agree. I guess this speaks to the complexity of the issue itself and of the different layers of federal funding in affordable rental housing. In this case, it becomes apparent that one size does not fit all — at least as far as the federal government is concerned.
The four-part strategy begins with the recommendation that new construction and “gut rehabilitation” projects that receive federal grants meet or exceed Energy Star or Builder’s Challenge Quality Criteria standards. (These requirements are defined in detail in the footnotes, which is, of course, very helpful.) For new construction projects that are financed with federal insurance, loan guarantees or public housing capital and operating funds, the current International Energy Conservation Code elements that are deemed nationally feasible is the recommended standard. This is the second component of the strategy.
The next two parts break rehabilitation into three categories: substantial, moderate, and minor. For substantial rehab, the recommendation is that a Capital Needs Assessment template tool to implement energy improvements be used to determine work that would be effective in saving energy as well as financially feasible. The template would contain a traditional, comprehensive property evaluation, an assessment of green building and energy efficiency needs and opportunities and a utility data collection component.
The recommendation for moderate or minor rehab is to replace systems and appliances as needed with Energy Star or the most energy-efficient options that are also financially feasible.
The Low Income Housing Tax Credit (LIHTC) Program and Weatherization Assistance Program (WAP) are placed into categories of their own. The basic recommendation for them is to continue following the existing regulatory requirements. In 2008, the Housing and Economic Recovery Act (HERA), required that state agencies include energy efficiency in its Qualified Allocations Plans. The only suggestion here is that the National Council for State Housing Agencies (NCSHA) work with the Department of Treasury to determine how states are implementing this and that they would possibly impose follow-up action. For WAP, which is already heavily regulated according to the report, no further requirements are recommended.
So, despite the discrepancies noted here as described in the report and the challenges that were mentioned and include more expensive up-front costs and inconsistencies between state and local building codes and enforcement nationwide, I found one paragraph that speaks volumes as to why energy-efficiency efforts should be on the federal agenda in the first place:
“…improving energy efficiency by 30 percent in the multifamily housing stock (which mostly consists of rental properties) could generate $9 billion in savings annually to renters and owners, while achieving energy savings equivalent to the annual electrical output of 20 coal plants and the entire natural gas usage of California, Oregon, and Washington states and avoid the emission of at least 50 -100 million tons of CO2 per year – equivalent to the emissions associated with the current energy use of 4 -8 million U.S. households.”
On that note, I will leave you to ponder these implications in the hope that you will be in agreement with me that even with the multi-tiered recommendations and standards, the means here just might justify the ends.