ENERGY PERFORMANCE STANDARD IN AFFORDABLE MULTIFAMILY HOUSING
Introduction
The report titled “Energy Performance Standard in Affordable Multifamily Housing” addresses the urgent need to align energy performance goals with affordable housing initiatives. It focuses on Washington, D.C.’s Building Energy Performance Standards (BEPS), introduced through the Clean Energy DC Omnibus Act of 2018, which sets minimum energy efficiency thresholds for large buildings to meet. The policy aims to reduce greenhouse gas (GHG) emissions and improve energy efficiency across the city, including the affordable housing sector.
Affordable multifamily housing plays a critical role in ensuring low-income families have access to stable homes. However, energy performance requirements must be tailored so that they do not negatively affect affordability, ownership stability, or tenant livelihoods. This report thoroughly examines how BEPS can be equitably implemented across various affordable housing types in D.C.
Affordable Housing Landscape in D.C.
Washington, D.C., has a broad spectrum of affordable housing types, including:
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Public Housing
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Project-based Section 8
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Low-Income Housing Tax Credit (LIHTC) properties
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Local rent-subsidized housing
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Naturally Occurring Affordable Housing (NOAH)
These housing types vary widely in ownership, financing mechanisms, management, and tenant demographics. Approximately 43,000 housing units fall under these categories, and many will be directly impacted by BEPS mandates.
What Is BEPS?
BEPS establishes minimum energy performance thresholds that buildings must meet or improve upon over a 5-year compliance cycle. For privately owned buildings over 50,000 square feet, the first BEPS cycle began in 2021. The Department of Energy and Environment (DOEE) defines property types and sets the performance standards based on median Energy Star scores or equivalent energy use intensity (EUI) metrics.
Challenges for Affordable Housing under BEPS
1. Financial Constraints
Affordable housing providers typically have limited access to capital, leaving little room for expensive energy efficiency upgrades. Many buildings are already under strict funding agreements and rent control regulations, limiting revenue increases. Without grants, tax incentives, or subsidies, achieving compliance can strain budgets or threaten housing affordability.
2. Staff and Capacity Limitations
Many owners lack the technical expertise and staffing needed to undertake detailed energy benchmarking, plan retrofits, or navigate compliance options. This especially affects smaller nonprofit developers and housing cooperatives.
3. Health and Safety Repairs as Prerequisites
In numerous older buildings, basic infrastructure problems such as lead paint, mold, asbestos, HVAC inefficiencies, and outdated electrical systems must be addressed before energy retrofits can be implemented.
4. Split Incentives Between Landlords and Tenants
A split incentive exists where landlords are responsible for retrofits, but tenants pay utility bills. This discourages investment unless tenants can benefit from reduced utility costs or landlords can recuperate expenses through rent adjustments or tax credits.
5. Tenant Displacement Risk
Unfunded mandates can lead owners to pass costs to tenants, indirectly threatening housing stability or causing displacement, especially in NOAH or privately owned low-income buildings.
Recommendations for Equitable Implementation
1. Adjust BEPS Property Type Definitions
DOEE should ensure that affordable multifamily buildings are accurately represented in property type categories. A broad label like “Multifamily Housing” is insufficient because energy usage and financial conditions vary widely among different types. Creating dedicated categories such as “Affordable Public Housing” or “LIHTC-funded Housing” allows for more realistic performance expectations.
2. Flexible Compliance Pathways
Introduce customized or extended compliance pathways for affordable housing:
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Longer time frames
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Milestone-based progress
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Phased retrofits
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Alternative compliance measures like participation in energy assistance programs
This would recognize unique limitations without compromising the end goal of reducing emissions.
3. Financial Assistance Programs
Public funding will be crucial. The report recommends:
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Low-interest or forgivable loans
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Energy retrofit grants
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On-bill financing options
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Utility rebates and incentives
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Expanded federal funding access (e.g., HUD, DOE)
Programs should prioritize deep retrofits and address both health & safety and energy performance improvements.
4. Technical Support Hubs
Create centralized technical assistance centers to support affordable housing providers. These centers can offer:
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Help with benchmarking and energy audits
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Pre-qualified lists of contractors
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Sample scopes of work
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Templates for project planning and reporting
This lowers the barrier to compliance, especially for nonprofit and community-based housing developers.
5. Coordinated Policy Planning
Cross-agency coordination between DOEE, DC Housing Authority, DHCD, and DCRA is essential. Policies related to energy efficiency should be aligned with those on affordable housing preservation, financing, and development to prevent unintended consequences like lost affordability or non-compliance.
Case Studies and Examples
The report provides several anecdotal case studies and modeling scenarios that underscore its recommendations:
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A small nonprofit housing provider in Ward 7 lacked the staff to manage an energy upgrade project without external technical help.
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A LIHTC property struggled to meet BEPS targets due to outdated infrastructure but succeeded with phased retrofits and funding from the DC Sustainable Energy Utility (DCSEU).
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A public housing complex required significant health and safety upgrades before it could even consider BEPS-related work.
Equity Lens and Social Justice Considerations
The report emphasizes that environmental justice and social equity must guide implementation. Energy Performance Standards should reduce utility burdens for tenants, improve indoor air quality, and contribute to climate resilience—without putting the financial burden on vulnerable populations.
Recommendations include:
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Protect tenants from rent hikes associated with retrofits
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Guarantee right of return in cases of temporary relocation
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Prioritize retrofits that lower tenant utility costs
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Monitor impacts to ensure compliance doesn’t increase evictions or displacement
Compliance Metrics and Reporting
The report stresses the need for clear, measurable outcomes:
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Use third-party verified energy audits
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Track tenant utility savings and owner costs
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Evaluate compliance progress through public dashboards
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Collect demographic and affordability data to assess equity
Implementation Roadmap
To meet BEPS mandates and maintain affordability, the report recommends a multi-phase implementation roadmap:
Phase 1: Assessment & Education
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Identify at-risk affordable housing properties
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Launch outreach and technical education campaigns
Phase 2: Infrastructure & Funding
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Launch targeted funding programs
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Coordinate with local/federal agencies to address repair backlogs
Phase 3: Pilot Projects
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Implement pilot retrofits in diverse housing types
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Document lessons learned for scale-up
Phase 4: Full Implementation
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Ensure phased, equitable rollout
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Track compliance and adjust policies based on outcomes
Conclusion
The BEPS initiative is a bold and necessary step toward making Washington, D.C., a carbon-neutral and climate-resilient city. However, for its success to be truly equitable, it must consider the complexities of the affordable housing sector. With tailored compliance pathways, adequate funding, and technical support, the city can achieve its energy efficiency goals without sacrificing affordability or displacing vulnerable populations.
The report urges policymakers to view this as an opportunity not only for energy reform but for transformative housing justice.
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