ENERGY PERFORMANCE STANDARD IN AFFORDABLE MULTIFAMILY HOUSING

energy performance standard

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:

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:

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:

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:

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:

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:

Compliance Metrics and Reporting

The report stresses the need for clear, measurable outcomes:

Implementation Roadmap

To meet BEPS mandates and maintain affordability, the report recommends a multi-phase implementation roadmap:

Phase 1: Assessment & Education

Phase 2: Infrastructure & Funding

Phase 3: Pilot Projects

Phase 4: Full Implementation

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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