NEEP Helps Develop National Energy Rating Program for Homes

By Jim O'Reilly, Director of Public Policy

Developing a national system to measure and label home energy use would help buyers, sellers, realtors and banks truly understand and value a building's efficiency. The Obama administration has taken the position that providing consumers with greater levels of information on a home's energy performance would not only encourage greater levels of energy retrofit activity - creating potentially millions of new jobs - but would also save consumers billions of dollars in energy costs.

Per a June 8 Request for Information (RFI), NEEP is gathering regional input into the National Energy Rating Program for Homes being developed by the U.S. Department of Energy (DOE). This voluntary program would focus on existing homes and seek to implement key elements of Vice President Biden's Middle Class Task Force Report on "Recovery through Retrofit." The objective, according to DOE, is to "facilitate a new level of investment in home energy efficiency by overcoming a range of informational and market barriers frequently identified as hindering these investments." After homes, DOE is expected to undertake a similar process for commercial buildings.

NEEP's response to DOE's request for information is a continuation of the work that included publication of our November 2009 report, Valuing Building Energy Efficiency through Disclosure and Upgrade Policies: A Roadmap for the Northeast U.S. This widely-cited report laid forth a strategy for developing and implementing a building energy rating system for both residential and commercial buildings. Part of that strategy included working with the DOE to develop a consistent, national building rating system that states could adopt and/or a model to develop their own mandatory public policies for building energy labeling and disclosure.

NEEP's comments on the draft National Energy Rating Program for Homes are focused on a few principal areas, and include the following:

Guiding principles - NEEP generally supports the guiding principles DOE has enunciated, including that any such rating information must be:

• Credible, reliable, and replicable.
• Transparent and easy to understand.
• Affordable in its implementation costs.
• Include effective quality assurance.

  

NEEP suggests these additions:

• Information should encourage retrofit measures, which, ultimately, is the purpose of labeling a building for energy performance.
• Information needs to be valuable not only to end users but also to other pertinent stakeholders, including those who may be involved in a financial transaction regarding the property (realtors, banks, assessors, etc).
• The program should align with existing programs, systems and professionals, such as ENERGY STAR, HERS, etc.

Basic Metric/Information Provided to Consumers - NEEP disagrees with DOE's initial approach to use ‘source energy' as the basic consumption metric on the label, and would instead advocate that ‘site energy' use be the metric. In addition to being more easily understood by homeowners, site energy would account for the discrepancy between fuel sources that exists in different regions of the country. For a label to be transparent and easy to understand, consumption data should more closely resemble what the homeowner sees on his/her energy bills. However, we would also urge DOE to include on this label greenhouse gas emissions associated with the home's energy use, as carbon is a key policy driver and, increasingly in the public's consciousness. A regional conversion factor that accounts for various fuel types would be needed as well.

• Asset vs . Operational Rating - We agree with DOE in that, while a home's energy use is clearly dependent upon occupant behavior, it is the rating of the building itself, or the ‘asset,' that is most important to drive retrofit decisions, particularly at the point of sale or finance.
• Scales and Reference Points - NEEP agrees with DOE's initial approach to use an ‘absolute numeric scale' but, in contrast to DOE, suggests that a ‘non-numeric' grading or ‘binning' system be overlaid based on region and number of bedrooms so that end users can better understand how the home's efficiency compares to others in the region of similar assumed occupants.
• Recommendations for Improvements - DOE intends to develop a standardized, consistent system to recommend energy-saving improvements for each house and to estimate the initial cost and the potential energy and cost savings from these improvements. But NEEP suggests that any such recommendations for upgrades be reserved as an option within a regional customization portion of the la bel, primarily because estimates of costs for and savings for and from such measures will vary by region.
• National Home Energy Registry - NEEP strongly supports DOE's idea to create a national registry for data accumulated through the program to better understand the nation's building stock energy use and to more accurately determine benchmarking practices.
• Quality Assurance - While DOE hasn't defined a specific path on quality assurance, NEEP suggests that it pursue one that is consistent with that of the ENERGY STAR for Homes program requirements.
• Other Issues - One item not included in the DOE RFI that NEEP suggests should also be examined is the development of a Residential Energy Consumption Survey (RECS), similar to the existing Commercial Building Energy Consumption Survey (CBECS), which feeds into programs such as ENERGY STAR Portfolio Manager to help benchmark commercial buildings.

To see the RFI, or for more information on the National Energy Rating Program for Homes, please visit: http://www.buildings.energy.gov/home_rating_rfi.html. For more information on NEEP's Building Energy Rating Project, please contact Mark Tebbets at mtebbets@neep.org.