Background on HUD Energy Audit Requirements

1. U.S. Department of Housing and Urban Development Office of Public and Indian Housing Office of Public Housing Investments Background on HUD Energy Audit Requirements Bruce Rieder Public Housing Revitalization Specialist-OPHI/HUD

2. Energy Audit • PHAs have been required to complete Energy Audits for over 20 years. • While Energy Audits (EAs) and Physical Needs Assessment (PNAs) involve a review of the same building systems, EAs have historically been completed independently of PNAs. • The industry is moving to integrate EAs and PNAs.

3. Energy Audit • The vanguard of affordable housing owners, PNA providers, and energy audit companies are already completing both actions in an integrated manner. • HUD’s Mark to Market program is an industry leader in this regard, having fully integrated PNAs and EAs and has served as an inspiration in Public Housing’s work to develop a new PNA that integrates energy auditing.

4. Energy Audit • The 2005 Energy Policy Act takes Public Housing in the same direction the industry is heading. • The 2005 Energy Policy Act encourages the integration of utility management and capital planning to maximize energy conservation and efficiency measures. • As you know, HUD is developing a new PNA tool. A major goal of the new PNA tool is to integrate PNAs and EAs. • In order to accomplish this, HUD will be proposing a new Energy Audit rule to improve upon current guidance.

5. Energy Audit • The 1996 EA Rule requires PHAs to analyze all of the energy conservation measures and payback period for those measures that are pertinent to the type of buildings and equipment operated by the PHA. • Standards for EAs were tied to State standards for EAs. • Few States have standards for EAs

6. Energy Audit • HUD is developing a Proposed EA rule to revise the existing 1996 EA rule. • Goals of the Proposed EA Rule: • Introduce consistency in what is reviewed and how the data is presented. • Present data in a way that shows the benefits of Energy Conservation Measures and permits the data to be integrated into the new PNA tool. • Establish a requirement for energy auditors to have qualifications. • Integrate the PNA and EA requirements in the spirit of the 2005 Energy Policy Act.

7. Energy Audit • Introduce consistency in what is reviewed • Delineate Categories of Energy Conservation Measures (ECMs) to be reviewed • If after an initial assessment the energy auditor determines that an ECM is likely to achieve payback within a specified period, it could be required to be included in the EA. • HUD will seek public comment on how the requirement to review ECMs is structured. • Differentiate between Core ECMs and Advanced ECMs • Core ECMs=Proven paybacks, “low hanging fruit” • Advanced ECMs=still developing or experimental technologies • Non-energy systems may be part of energy audit (e.g. low VOC paint, low gas emitting cabinetry).

8. Energy Audit • Present data in a way that shows the benefits of Energy Conservation Measures and permits the data to be integrated into the new PNA tool. • Payback analysis would be required, as is the case with the 1996 EA Rule. To complete analysis, the following data would be required: • Acquisition and installation cost of Standard and Green • Projected energy usage cost of Standard and Green • EUL of Standard and Green • Proposed rule would focus on incremental costs. • Data should be presented to decision makers in a manner that shows the additional cost of ‘going green.’ • Incremental costs are much smaller. • Makes payback analysis easier – but also more realistic.

9. Energy Audit • Establish a requirement for energy auditors to have qualifications. • Requirement will introduce a higher and more consistent level of quality to energy audits. • Energy Auditors would need: • Experience in performing Energy Audits • Certification(s) from a State EA certifying agency or a nationally recognized energy audit certification provider. • PIH will seek comment on qualification requirements

10. Energy Audit Integrate the PNA and EA requirements in in the spirit of the 2005 Energy Policy Act PNAs and EAs would be required to be completed in conjunction with each other. PIH assessing capacity of industry PIH signaling industry that it is moving in this direction. As noted previously, market is already moving in this direction. PIH’s actions will provide further impetus. PIH considering grandfathering in EAs that have been completed recently and provide the required data. For small PHAs, PIH considering provisions for those unable to find qualified auditors

11. Energy Audit Questions and answers