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Exploring HUD’s proposal on energy benchmarking

To help reduce energy costs in affordable housing, HUD has issued a proposal for “spot check” utility benchmarking in HUD-assisted multifamily housing and to require benchmarking in public housing. Last week, I attended an information session hosted by HUD on benchmarking for multifamily housing to enhance my understanding as NHC drafts its comments on the proposal. As many NHC members may be reviewing the proposal, I wanted to share some highlights and resources from the event. For members interested in working with NHC on a comment letter, please email me.  Energy benchmarking tracks the utility consumption of a multifamily development, calculating the energy and water efficiency of the development and comparing it to that of similar developments. It can help owners understand their buildings’ energy performance, detect malfunctioning equipment and billing errors, prioritize capital improvements and plan for future budget needs. Under the proposal, HUD will require multifamily building owners to use the Environmental Protection Agency’s (EPA’s) Portfolio Manager, ideally using whole-building data to create each building’s energy baseline. If whole-building data is not available, HUD will accept a sample of tenant utility data combined with owner utility data.

At the information session, HUD staff gave an overview of the proposal and EPA reviewed the Portfolio Manager tool. Presenters also shared their expertise on the value of benchmarking and the perspective of utilities. Studies have shown the benefits of benchmarking in terms of reduced energy and water use as well as providing an important baseline for exploring energy retrofits. NHC appreciates HUD’s leadership in this area to move the portfolio further towards energy and water efficiency. One primary concern with the proposal is the ability of owners to access utility data, especially at the tenant level. Some utilities are reluctant to provide this data, even if aggregated and anonymized to address privacy concerns. Many utilities also do not have the systems in place to provide this data. Getting the data necessary for benchmarking from utilities could be a time- and labor-intensive process which is an important factor to consider when analyzing the proposal.

HUD has resources available to owners to help with the benchmarking process, and HUD reviewed the many resources available on utility benchmarking at the event. These resources include case studies on benchmarking from participants in the Better Building Challenge as well as instructions on how to collect utility data. HUD has also provided information on how to use Portfolio Manager. HUD has created a database to look up how to request tenant utility data for the 40 largest utility companies in the U.S., and HUD will expand this database to the 100 largest utility companies. In November 2016, HUD will open an application process for 12 Environmental Defense Fund Climate Core Fellows who will help owners set up benchmarking in the summer of 2017. HUD will host webinars to train housing providers and hopes to build additional functionality around Portfolio Manager to make the process more valuable for owners. HUD will also issue a housing notice with operational guidance to help with implementation of the proposal.

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