NMHC/NAA issued a comment letter on December 5, 2016, opposing a proposed rule that would require every building backed by a Federal Housing Administration (FHA) multifamily loan to track and submit energy benchmarking data through EPA’s ENERGYSTAR Portfolio Manager. While NMHC/NAA support methods to improve the operational efficiency of the apartment industry, including voluntary benchmark building performance, we oppose FHA’s efforts to mandate benchmarking across their entire portfolio.
To correctly benchmark a building, owners need access to the whole building energy data, but regulations in many localities prevent property owners from obtaining that data which challenges the ability of owners to comply with the rule. The newly proposed rule recognizes that access to whole building data may be expanding in some areas, but fails to layout an effective process that will allow owners to access such data on a national level.
While the rule does allow owners to use a sampling protocol, the reality is that it would be costly and difficult to analyze and would produce little informational value. Therefore, the apartment industry recommends that if the proposed rule moves forward, it should only be applicable in areas where whole building data is available.
Finally, the rule references the future use of water benchmarking through a tool that the EPA is currently developing. The industry requested that any reference to this tool be removed as it is not known how the tool will be used or implemented.
NMHC/NAA will continue to work with the Department of Housing and Urban Development (HUD) to ensure that the proposed rule is either not implemented or proceeds in a way that produces the most value for the apartment industry.
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