NAHMA HUD Update: Energy Benchmarking Reporting for Properties with Project Rental Assistance Contracts - Information Collection

October 10, 2016

HUD's Office of Multifamily Housing today published the following notice allowing for 60 days of public comments on requiring energy benchmarking reporting for properties with Project Rental Assistance Contracts, Housing Assistance Payment contracts, and multifamily properties that are already or about to be FHA insured.
The notice aligns with both the President's Climate Action Plan as well as HUD's efforts to improve the energy and water-efficiency of affordable housing. The stated purpose of the benchmarking initiative is to allow property owners to make data-driven decisions, hopefully resulting in reduced operating costs and improved performance over time.
Covered properties for this reporting requirement include:
  • Section 202 Project Rental Assistance Contracts (PRAC)
  • Section 811 PRAC and Project Rental Assistance contracts
  • Section 202/162 Project Assistance Contracts
  • Section 202 Senior Preservation Rental Assistance Contracts
  • Section 8 Housing Assistance Payment contracts
  • Multifamily Housing properties insured under Sections 223(a)(7), 223(f),
    221(d)(3) 221(d)(4), 220, 231, 236, and 241(a).
Owners of covered properties are encouraged to voluntarily submit water and energy benchmarking data to HUD on an annual basis.  HUD will require that owners submit benchmarking information on the following schedule, subject to revision:
  • For HUD-assisted properties with a utility allowance, at the time of a triennial utility allowance baseline calculation; 
  • For HUD-assisted properties where there is no utility allowance, every third year at the time of financial statement submission;
  • Prior to issuance of new FHA mortgage insurance under Sections 223(a)(7), 223(f), and 241(a);
  • With a Capital Needs Assessment submission required by the Office of Asset Management and Portfolio Oversight in HUD's Office of Multifamily Housing Programs on a 10-year cycle; and
  • With a Capital Needs Assessment submission required as part of any enforcement action.
If you would like to provide comments or recommendations for this benchmarking notice, please send your comments to NAHMA staff by November 11, 2016.

The first scheduled submission date for a majority of assisted-housing respondents is estimated to occur in 2019. UD has dedicated technical assistance resources to help owners collect, track, and analyze energy data.  This includes building a website with tools, case studies, and links to federal resources.

The benchmarking notice may be found on the NAHMA website here