Energy Performance Contracting-Request for Comments on Proposed Guidance and Policy Clarifications, 33329-33332 [2011-14049]
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Federal Register / Vol. 76, No. 110 / Wednesday, June 8, 2011 / Notices
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
[Docket No. FR–5485–N–01]
Notice of Proposed Information
Collection, Comment Request;
Application for HealthyHomes and
Lead Hazard Control Grant Programs
and Quality Assurance Plans
Office of Healthy Homes and
Lead Hazard Control, U.S. Department
of Housing and Urban Development.
ACTION: Notice.
AGENCY:
The proposed information
collection requirement described below
will besubmitted to the Office of
Management and Budget (OMB) for
review, as required by the Paperwork
Reduction Act. The Department is
soliciting public comments on the
subject proposal.
DATES: Comments Due Date: April 15,
2011 .
ADDRESSES: Interested persons are
invited to submit comments regarding
this proposal. Comments should refer to
the proposal by name and/or OMB
Control Number and should be sent to:
Reports Liaison Officer, Department of
Housing and Urban Development, 451
7th Street SW., Washington, DC 20410,
Room 9120 or the number for the
Federal Information Relay Service (1–
800–877–8339).
FOR FURTHER INFORMATION CONTACT:
Jeffrey Simpkins, Technical Assistance
Specialist, Department of Housing and
Urban Development, 451 7th Street,
SW., Room 8236, Washington, DC
20410; e-mail
Jeffrey.W.Simpkins@hud.gov, or
telephone (202) 402–7180.
SUPPLEMENTARY INFORMATION: The
Department will submit the proposed
information collection to OMB for
review, as required by the Paperwork
Reduction Act of 1995 (44 U.S.C.
chapter 35, as amended). This Notice is
soliciting comments from members of
the public and affected agencies
concerning the proposed collection of
information to: (1) Evaluate whether the
proposed collection of information is
necessary for the proper performance of
the functions of the agency, including
whether the information will have
practical utility; (2) Evaluate the
accuracy of the agency’s estimate of the
burden of the proposed collection of
information; (3) Enhance the quality,
utility, and clarity of the information to
be collected; and (4) Minimize the
burden of the collection of information
on those who are to respond; including
through the use of appropriate
automated collection techniques or
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SUMMARY:
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other forms of information technology,
e.g., permitting electronic submission of
responses.
After the award of grants, HUD’s
Office of Healthy Homes and Lead
Hazard Control requires its Healthy
Homes Demonstration, Healthy Homes
Technical Studies grantees, and Lead
Technical Studies grantees which are
conducting research or significant
evaluation activities, to submit a Quality
Assurance Plan (QAP) to the Office for
approval before they initiate data
collection. This requirement also
applies to Office of Healthy Homes and
Lead Hazard Control contractors who
conduct such research or evaluation
activities. This requirement has been
established because quality assurance
procedures ensure the accuracy and
validity of data. The use of quality
assurance plan templates helps to
ensure that quality assurance activities
are well planned and thorough, and
standardizes the formatting of the plans,
which aids both the respondents in plan
development and HUD staff in their
review. The use of different templates
for technical studies and demonstration
projects was designed to reduce
respondent burden by requiring more
detailed information only for the
technical studies (research) projects,
consistent with their more rigorous
quality assurance requirements.
Title of Proposal: Application for
Healthy Homes and Lead Hazard
Control Grant Programs and Quality
Assurance Plans.
OMB Control Number, if applicable:
2539–0015.
Description of the need for the
information and proposed use: This
information collection is required in
conjunction with the issuance of
Notices of Funding Availability for
approximately $150,000,000 for Healthy
Homes and Lead Hazard Control
Programs that are authorized under Title
X of the Housing and Community
Development Act of 1992, Public Law
102–550, section 1011, and other
legislation.
Agency form numbers, if applicable:
HUD 96008, 96012, 96013, 960014,
96015, and standard grant forms.
Estimation of the total numbers of
hours needed to prepare the information
collection including number of
respondents, frequency of response, and
hours of response: Number of
respondents: 330; frequency of
responses: 1; hours per response:25;
burden hours: 8250.
Status of the proposed information
collection: This is a revision of a
currently approved collection.
Authority: The Paperwork Reduction Act
of 1995, 44 U.S.C., Chapter 35, as amended.
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33329
Dated: June 2, 2011.
Jon L. Gant,
Director, Office of Healthy Homes and Lead
Hazard Control.
[FR Doc. 2011–14109 Filed 6–7–11; 8:45 am]
BILLING CODE 4210–67–P
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
[Docket No. FR–5524–N–01]
Energy Performance Contracting—
Request for Comments on Proposed
Guidance and Policy Clarifications
Office of the Assistant
Secretary for Public and Indian
Housing, HUD.
ACTION: Notice.
AGENCY:
This notice solicits public
comment on certain key issues that will
be addressed in HUD’s forthcoming
guidance on the Energy Performance
Contracting (EPC) program. HUD will
consider all comments as it updates its
guidebook entitled ‘‘Energy Performance
Contracting for Public and Indian
Housing’’ (Greenbook). This notice also
clarifies existing guidance related to
EPCs.
DATES: Comments Due Date: July 8,
2011.
ADDRESSES: Interested persons are
invited to submit comments regarding
HUD’s updated Greenbook, as
announced in this notice, to the
Regulations Division, Office of General
Counsel, Department of Housing and
Urban Development, 451 7th Street,
SW., Room 10276, Washington, DC
20410–0001. There are two methods for
submitting public comments. All
submissions must refer to the above
docket number and title.
Submission of Hard Copy Comments.
To ensure that the information is fully
considered by all of the reviewers, each
commenter submitting hard copy
comments, by mail or hand delivery,
should submit comments or requests to
the address above, addressed to the
attention of the Rules Docket Clerk. Due
to security measures at all federal
agencies, submission of comments or
requests by mail often result in delayed
delivery. To ensure timely receipt of
comments, HUD recommends that any
comments submitted by mail be
submitted at least 2 weeks in advance of
the public comment deadline.
Electronic Submission of Comments.
Interested persons may submit
comments electronically through the
Federal eRulemaking Portal at https://
www.regulations.gov. HUD strongly
encourages commenters to submit
SUMMARY:
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Federal Register / Vol. 76, No. 110 / Wednesday, June 8, 2011 / Notices
comments electronically. Electronic
submission of comments allows the
commenter maximum time to prepare
and submit a comment, ensures timely
receipt by HUD, and enables HUD to
make them immediately available to the
public. Comments submitted
electronically through the https://
www.regulations.gov Web site can be
viewed by interested members of the
public. Commenters should follow
instructions provided on that site to
submit comments electronically.
No Facsimile Comments. Facsimile
(Fax) comments are not acceptable.
Public Inspection of Comments. All
comments submitted to HUD regarding
this notice will be available, without
charge, for public inspection and
copying between 8 a.m. and 5 p.m.
weekdays at the above address. Due to
security measures at the HUD
Headquarters building, an advance
appointment to review the documents
must be scheduled by calling the
Regulations Division at 202–708–3055
(this is not a toll-free number). Copies
of all documents submitted are available
for inspection and downloading at
https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Shauna Sorrells, Director, Public
Housing Programs, Office of Public and
Indian Housing, Department of Housing
and Urban Development, 451 7th Street,
SW., Room 4232, Washington, DC
20410–4000, telephone number 202–
402–2769 (this is not a toll-free
number). Persons with hearing- or
speech-impairments may access this
number through TTY by calling the tollfree Federal Relay Service at 800–877–
8339.
SUPPLEMENTARY INFORMATION:
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I. Background
Section 9(e) of the United States
Housing Act of 1937 (1937 Act) (42
U.S.C. 1437 et seq.), as amended,
establishes an Operating Fund for the
purpose of making assistance available
to public housing agencies (PHAs) for
the operation and management of public
housing, including the management of
energy costs associated with public
housing units, with an emphasis on
energy conservation. HUD’s regulations
implementing the Operating Fund are
located at 24 CFR part 990. Section
990.185 provides that PHAs may qualify
for financial incentives when
undertaking conservation measures that
are financed by an entity other than
HUD. PHAs that take advantage of
HUD’s third-party financed energy
reduction incentives typically do so
through EPCs. An EPC is a financing
technique that uses the cost savings
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b. What obstacles or roadblocks, if
any, exist in the current approval
process?
c. What can HUD do to streamline the
II. Updating the Greenbook and
approval process?
Request for Public Comment
d. What alternatives to current
HUD issued the Greenbook in
procurement procedures would
February, 1992, and it is available at
expedite the approval process?
e. How would a formal appeal process
https://www.huduser.org/publications/
pdf/energy.pdf. The Greenbook serves as for disapproved EPCs benefit PHAs,
Energy Services Companies (ESCOs), or
the principal policy guidance for PHAs
other stakeholders?
interested in pursuing EPCs. The
Greenbook defines and clarifies how
2. Net Present Value
PHAs may undertake EPCs in
Currently, HUD is considering
accordance with HUD regulations, and
requiring that the Investment Grade
provides PHAs, HUD field staff,
Energy Audit incorporate Net Present
potential performance contractors, and
Value calculations. Does the industry
other stakeholders with information
use a standard rate of return for these
about HUD incentives, required
calculations?
documentation, and other necessary
approvals in the EPC process.
3. Measurement and Verification (M&V)
Since the publication of the
Requirements
Greenbook, HUD has updated guidance
Under PIH Notice 2009–16, HUD
related to EPCs through a series of
currently recommends that PHAs obtain
notices, checklists, and by providing
independent 3rd party M&V reports
technical assistance to PHAs
annually for projects over $10 million,
contemplating energy projects. HUD is
and every three years for projects
currently drafting a comprehensive
costing less than $10 million.
update of the Greenbook to consolidate
a. What benefits are there to
all current EPC procedures into a single implementing mandatory independent
source. A major benefit for updating the 3rd party M&V for all projects? What
Greenbook is to standardize the
considerations should be made in
submission, review, and approval
implementing such a requirement?
processes in an effort to streamline EPC
b. What qualifications should be
processing time, while preserving
required of parties performing 3rd party
HUD’s responsibility to approve
M&V? Should such requirements for 3rd
qualified projects within regulatory
party M&V companies include a
requirements.
requirement that they hold ‘‘current’’
In advance of issuing a revised
certifications? And how should a
Greenbook, HUD is seeking public
‘‘current’’ certification be defined (e.g.,
comment to inform its development of
certification received in the past two
comprehensive guidance regarding the
years)?
use of EPCs. HUD’s goal is to provide a
c. How could significant differences
meaningful opportunity for PHAs,
between a 3rd party report and the
energy engineers, energy service
ESCO’s M&V report be reconciled?
companies, financial analysts reviewing
d. How can the measurement and
EPCs, and the general public to
verification of energy cost savings be
participate in the development of useful improved?
and effective guidance that promotes
e. What additional controls, if any, are
and streamlines the use of EPCs. HUD
needed to ensure that utility cost
will consider all comments submitted in savings are properly calculated and
response to this notice in developing its reported in M&V reports? Should such
updated and revised Greenbook.
controls include a requirement that the
The following is a list of topics on
calculated cost savings be certified by a
which HUD specifically seeks
Professional Engineer (PE)?
f. What additional controls, if any, are
comments.
needed to ensure that the costs of EPCs
1. Streamlining the Process
are properly repaid from energy
Currently, the approval process for
savings?
EPCs takes approximately 14–18
4. Removing Barriers to EPCs
months, from the time the PHA
Over the lifetime of HUD’s EPC
develops their Request for Proposal/
program, there have been approximately
Qualifications until there is a Notice to
240 EPCs executed by PHAs. The vast
Proceed from the Department. HUD
majority of these EPCs have been
plans to reduce this time, and seeks
completed by medium and large PHAs.
comments on the following specific
HUD would like to involve more PHAs
questions:
in the EPC program, especially small
a. What is a reasonable approval
PHAs.
timeline for an EPC?
from reduced energy consumption to
pay the cost of installing energy
conservation measures (ECMs).
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a. How can HUD improve PHAs’
capacity to perform self-developed
EPCs?
b. What can HUD do to improve
access to EPCs for small PHAs? For
instance, should HUD allow for EPCs for
several small PHAs to be bundled
together and performed by one (1)
ESCO? By bundling EPCs together,
would the overall scope be more
attractive and provide a large enough
investment/incentive for the ESCOs?
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5. Section 3 Compliance
The Section 3 program requires that
recipients of EPC incentives, to the
greatest extent possible, provide job
training, employment, and contract
opportunities for low- or very-low
income residents and qualified
businesses in connection with the EPC
project (see 24 CFR part 135). How can
HUD improve Section 3 compliance and
employment associated with EPCs?
6. Energy and Water Auditing and
Investment Standards
Energy and water conservation
investment opportunities are typically
determined by an investment grade
audit of a portfolio’s energy and water
usage and costs and the various factors
affecting consumption. In some cases,
EPCs have been found to be impractical
because sufficient savings from low-cost
conservation measures could not be
leveraged. HUD is interested in knowing
whether the current approach for
identifying cost-effective energy and
water conservation measures enables or
impedes the development of
comprehensive retrofit strategies for
materially reducing utility costs.
a. Are some high-cost measures not
reachable through EPCs because the
ratio of savings is too low relative to the
investment and transaction costs?
b. How can renewable energy
investments be encouraged under EPC?
c. Should EPCs permit the
investments of green building measures
if sufficient savings or other resources
can be leveraged to cover investment
costs?
d. Should HUD adopt an alternative
assessment and auditing protocol for
PHA’s undertaking self-direct EPCs?
Could a Green Physical Needs
Assessment provide a useful mechanism
for developing an investment plan for
reducing utility costs? Could a Home
Energy Rating System program (HERS)
audit be used by very-small and smallPHA’s undertaking EPC’s and if so how
should the projected energy savings be
estimated?
e. What steps can be taken to lower
and control non-investment transaction
costs?
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7. Leveraging
PHAs are encouraged to leverage
external resources to offset the costs of
energy and water conservation
investments. In some cases, accessing
available rebates and incentives can be
difficult and not well aligned with the
EPC process and implementation
period. HUD is interested in knowing
how leveraging can be increased in
conjunction with EPCs.
a. What challenges exist in aligning
EPCs with the processes and
requirements established for available
external energy efficiency and water
conservation programs? Are different
auditing protocols used or required? Do
requirements for using business process
improvement (BPI) certified contractors
pose implementation barriers? Are
inspection and quality assurance
requirements duplicative? Are there
load-ordering investment requirements
that conflict with EPC investment
priorities?
b. How can or should the EPC process
be modified to enable greater leveraging
of incentives and rebates available from
external sources such as utility and
local governmental programs?
c. What approaches or mechanisms
are needed to enable PHAs to access and
leverage energy efficiency and
renewable energy tax credits?
III. Policy Clarifications
HUD is also using this Federal
Register notice to clarify existing policy
regarding EPCs.
1. Allowable M&V options for EPCs
Several stakeholders have questioned
whether HUD intended to limit the use
of certain M&V options currently
available in HUD’s EPC program. In
response to this concern, the
Department wishes to clarify that it will
continue to allow all M&V options
detailed in the International
Performance Measurement &
Verification Protocol (IPMVP). These
M&V options are accepted methods for
measuring and verifying the amount of
utilities consumed by a building or the
change in the amount of utilities
consumed by a building due to a
retrofit. The Department finds that these
M&V methods can be conducted
accurately and represent the utility
consumption or change of utility
consumption in EPCs.
2. Resident Paid Incentive
HUD has been asked whether the addon subsidy incentive, found at 24 CFR
990.185(a)(3), is available to finance
ECMs where the utilities are residentpaid. HUD re-affirms that PHAs may not
use the add-on incentive for that
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33331
purpose. PHAs undertaking energy
conservation measures that are financed
by an entity other than HUD may
include resident-paid utilities under the
consumption reduction incentive
consistent with 24 CFR
990.185(a)(2)(iii). This approach allows
a PHA to exclude from its Operating
Fund rental income calculations any
rents received that are as a result of
decreased utility allowances resulting
from decreased consumption. The PHA
must exclude from its calculation of
rental income the increased rental
income due to the difference between
the baseline allowance and the revised
allowances of the projects for the
duration of the contract period.
3. Prohibition Against Liens
HUD re-affirms that, when using an
ESCO as part of an EPC, no lien or
encumbrance is to be placed on public
housing rental property (real or personal
property, such as fixtures). Similarly, if
the PHA is considering financing of an
EPC with another third party, such as a
bank, no liens may be placed on public
housing rental property including any
bank account, reserve or other personal
property (including the energy
improvement fixtures) of the PHA. All
public housing property is subject to the
Declaration of Trust and use
requirements of the Annual
Contributions Contract and section 9 of
the United States Housing Act of 1937.
All public housing property is required
to have a currently effective and
recorded Declaration of Trust. Any
secondary lien must be reviewed and
approved by HUD Headquarters. Any
Capital Fund financing or Operating
Fund financing under section 9 or
section 30 of the 1937 Act must also be
approved by HUD Headquarters.
4. Funds resulting from the Operating
Fund Benefit
Funds resulting from the Operating
Fund Benefit may not be included in an
approved EPC cash flow. There are two
types of incentives offered for reduced
utility consumption. The first is the
Rolling Base Consumption Level (RBCL)
(24 CFR 990.170). The purpose of the
RBCL is to encourage PHAs to make
management and maintenance decisions
that result in energy-efficiency
improvements, whether large or small,
through the normal course of operation.
This incentive is part of a PHA’s normal
operating subsidy eligibility and results
in excess subsidy that decreases over a
four year period and is an Operating
Fund Benefit. The Operating Fund
Benefit is not an EPC incentive. The
second type of utility cost reduction
incentive are those incentives offered
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Federal Register / Vol. 76, No. 110 / Wednesday, June 8, 2011 / Notices
under the EPC program (24 CFR part
185). To qualify for these incentives, the
PHA must obtain third-party financing
and ensure that the projected savings
are sufficient to cover the costs of the
improvements. These are large-scale
projects that require effort beyond the
normal course of operation. The
Operating Fund regulations do not
allow the combining of these two
incentive types to increase savings and
to include more energy conservation
measures within an EPC.
Dated: May 27, 2011.
Sandra B. Henriquez,
Assistant Secretary for Public and Indian
Housing.
[FR Doc. 2011–14049 Filed 6–7–11; 8:45 am]
BILLING CODE 4210–67–P
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
[Docket No. FR–5415–FA–30]
Announcement of Funding Awards for
the Technical Assistance and Capacity
Building under the Transformation
Initiative Program Fiscal Year 2010
Office of the Assistant
Secretary for Community Planning and
Development, HUD.
ACTION: Notice of funding awards.
AGENCY:
In accordance with section
102(a)(4)(C) of the Department of
Housing and Urban Development
Reform Act of 1989, this announcement
notifies the public of funding decisions
made by the Department in a
competition for funding under the
Notice of Funding Availability (NOFA)
for the Technical Assistance and
Capacity Building under the
Transformation Initiative program for
fiscal year 2010. This announcement
contains the names of the awardees and
amounts of the awards made available
by HUD.
SUMMARY:
FOR FURTHER INFORMATION CONTACT:
Holly A. Kelly, Acting Director,
Technical Assistance Division, Office of
Community Planning and Development,
451 Seventh Street, SW., Room 7218,
Washington, DC 20410–7000; telephone
(202) 402–6324 (this is not a toll-free
number). Persons with speech or
hearing impairments may access this
telephone number via TTY by calling
the toll-free Federal Information Relay
Service during working hours at 800–
877–8339. For general information on
this and other HUD programs, call
Community Connections at 1–800–998–
9999 or visit the HUD Web site at https://
www.hud.gov.
SUPPLEMENTARY INFORMATION: The Fiscal
Year 2010 Technical Assistance and
Capacity Building under the
Transformation Initiative program funds
were awarded under two funding
categories:
OneCPD
The purpose of OneCPD is to provide
state government, local government and
nonprofit recipients of federal
community development, affordable
housing, economic development and
special needs funding with the
assessment tools and technical and
capacity building assistance needed to
fully understand their local market
conditions, to increase their capacity to
successfully carry out federal assistance
programs while leveraging other public
and private resources, and to achieve
positive and measurable outcomes.
Under OneCPD, technical assistance
will involve the delivery of expert
statutory, regulatory, and technical
support that improves the program
knowledge, skills and capacity of CPD’s
grantees and their partners. Capacity
building efforts will be directed at
advancing the efficiency and
performance of grantees and their
partners (e.g., for-profit and public or
private non-profit organizations) in the
administration of federal affordable
housing, community and economic
development programs, the leveraging
of other resources and the furthering of
key Departmental objectives, including
but not limited to, energy efficiency and
green building.
Core Curricula
The purpose of the HUD Core
Curricula for Skills-Based Training is to
develop and deliver training courses
and seminars to improve the core skills
of HUD grantee staff commonly needed
for the administration of many HUD
programs. Funds will be awarded to
develop ‘‘core curricula’’ in the several
areas including (1) Development
Finance, (2) Environmental Review and
Compliance, (3) Asset Management and
Preservation of HUD–Assisted Projects
and (4) Construction and Rehabilitation
Management.
The competition was announced in
the NOFA published on January 4, 2011
(FR–5415–N–30) and closed on
February 24, 2011. The NOFA allowed
for approximately $24 million for
OneCPD and Core Curricula awards.
Applications were rated and selected for
funding on the basis of selection criteria
contained in the Notice. For the Fiscal
Year 2010 competition, 17 awards
totaling $23,303,000 were awarded to 13
different technical assistance providers
nationwide.
In accordance with section
102(a)(4)(C) of the Department of
Housing and Urban Development
Reform Act of 1989 (103 Stat. 1987, 42
U.S.C. 3545), the Department is
publishing the grantees and the amounts
of the awards in Appendix A to this
document.
Dated: May 31, 2011.
Clifford Taffet,
General Deputy Assistant Secretary for
Community Planning and Development.
APPENDIX A
Recipient
State
Amount
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OneCPD
Cloudburst Consulting Group Inc ........................................................................................................................
Corporation for Supportive Housing ....................................................................................................................
Dennison Associates, Inc ....................................................................................................................................
Econometrica, Inc ...............................................................................................................................................
Enterprise Community Partners, Inc ...................................................................................................................
First Nations Development Institute ....................................................................................................................
Housing Assistance Council ...............................................................................................................................
ICF Incorporated, L.L.C ......................................................................................................................................
Minnesota Housing Partnership ..........................................................................................................................
National Association for Latino Community Asset Builders ................................................................................
National Center on Family Homelessness, Inc ...................................................................................................
Training & Development Associates, Inc ............................................................................................................
University of Texas-Pan American ......................................................................................................................
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MD
NY
DC
MD
MD
CO
DC
VA
MN
TX
MA
NC
TX
08JNN1
...............
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...............
...............
................
................
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...............
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$4,515,500
125,000
200,000
500,000
4,599,000
100,000
650,000
4,224,000
750,000
900,000
700,000
5,094,500
350,000
Agencies
[Federal Register Volume 76, Number 110 (Wednesday, June 8, 2011)]
[Notices]
[Pages 33329-33332]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-14049]
=======================================================================
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
[Docket No. FR-5524-N-01]
Energy Performance Contracting--Request for Comments on Proposed
Guidance and Policy Clarifications
AGENCY: Office of the Assistant Secretary for Public and Indian
Housing, HUD.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: This notice solicits public comment on certain key issues that
will be addressed in HUD's forthcoming guidance on the Energy
Performance Contracting (EPC) program. HUD will consider all comments
as it updates its guidebook entitled ``Energy Performance Contracting
for Public and Indian Housing'' (Greenbook). This notice also clarifies
existing guidance related to EPCs.
DATES: Comments Due Date: July 8, 2011.
ADDRESSES: Interested persons are invited to submit comments regarding
HUD's updated Greenbook, as announced in this notice, to the
Regulations Division, Office of General Counsel, Department of Housing
and Urban Development, 451 7th Street, SW., Room 10276, Washington, DC
20410-0001. There are two methods for submitting public comments. All
submissions must refer to the above docket number and title.
Submission of Hard Copy Comments. To ensure that the information is
fully considered by all of the reviewers, each commenter submitting
hard copy comments, by mail or hand delivery, should submit comments or
requests to the address above, addressed to the attention of the Rules
Docket Clerk. Due to security measures at all federal agencies,
submission of comments or requests by mail often result in delayed
delivery. To ensure timely receipt of comments, HUD recommends that any
comments submitted by mail be submitted at least 2 weeks in advance of
the public comment deadline.
Electronic Submission of Comments. Interested persons may submit
comments electronically through the Federal eRulemaking Portal at
https://www.regulations.gov. HUD strongly encourages commenters to
submit
[[Page 33330]]
comments electronically. Electronic submission of comments allows the
commenter maximum time to prepare and submit a comment, ensures timely
receipt by HUD, and enables HUD to make them immediately available to
the public. Comments submitted electronically through the https://www.regulations.gov Web site can be viewed by interested members of the
public. Commenters should follow instructions provided on that site to
submit comments electronically.
No Facsimile Comments. Facsimile (Fax) comments are not acceptable.
Public Inspection of Comments. All comments submitted to HUD
regarding this notice will be available, without charge, for public
inspection and copying between 8 a.m. and 5 p.m. weekdays at the above
address. Due to security measures at the HUD Headquarters building, an
advance appointment to review the documents must be scheduled by
calling the Regulations Division at 202-708-3055 (this is not a toll-
free number). Copies of all documents submitted are available for
inspection and downloading at https://www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Shauna Sorrells, Director, Public
Housing Programs, Office of Public and Indian Housing, Department of
Housing and Urban Development, 451 7th Street, SW., Room 4232,
Washington, DC 20410-4000, telephone number 202-402-2769 (this is not a
toll-free number). Persons with hearing- or speech-impairments may
access this number through TTY by calling the toll-free Federal Relay
Service at 800-877-8339.
SUPPLEMENTARY INFORMATION:
I. Background
Section 9(e) of the United States Housing Act of 1937 (1937 Act)
(42 U.S.C. 1437 et seq.), as amended, establishes an Operating Fund for
the purpose of making assistance available to public housing agencies
(PHAs) for the operation and management of public housing, including
the management of energy costs associated with public housing units,
with an emphasis on energy conservation. HUD's regulations implementing
the Operating Fund are located at 24 CFR part 990. Section 990.185
provides that PHAs may qualify for financial incentives when
undertaking conservation measures that are financed by an entity other
than HUD. PHAs that take advantage of HUD's third-party financed energy
reduction incentives typically do so through EPCs. An EPC is a
financing technique that uses the cost savings from reduced energy
consumption to pay the cost of installing energy conservation measures
(ECMs).
II. Updating the Greenbook and Request for Public Comment
HUD issued the Greenbook in February, 1992, and it is available at
https://www.huduser.org/publications/pdf/energy.pdf. The Greenbook
serves as the principal policy guidance for PHAs interested in pursuing
EPCs. The Greenbook defines and clarifies how PHAs may undertake EPCs
in accordance with HUD regulations, and provides PHAs, HUD field staff,
potential performance contractors, and other stakeholders with
information about HUD incentives, required documentation, and other
necessary approvals in the EPC process.
Since the publication of the Greenbook, HUD has updated guidance
related to EPCs through a series of notices, checklists, and by
providing technical assistance to PHAs contemplating energy projects.
HUD is currently drafting a comprehensive update of the Greenbook to
consolidate all current EPC procedures into a single source. A major
benefit for updating the Greenbook is to standardize the submission,
review, and approval processes in an effort to streamline EPC
processing time, while preserving HUD's responsibility to approve
qualified projects within regulatory requirements.
In advance of issuing a revised Greenbook, HUD is seeking public
comment to inform its development of comprehensive guidance regarding
the use of EPCs. HUD's goal is to provide a meaningful opportunity for
PHAs, energy engineers, energy service companies, financial analysts
reviewing EPCs, and the general public to participate in the
development of useful and effective guidance that promotes and
streamlines the use of EPCs. HUD will consider all comments submitted
in response to this notice in developing its updated and revised
Greenbook.
The following is a list of topics on which HUD specifically seeks
comments.
1. Streamlining the Process
Currently, the approval process for EPCs takes approximately 14-18
months, from the time the PHA develops their Request for Proposal/
Qualifications until there is a Notice to Proceed from the Department.
HUD plans to reduce this time, and seeks comments on the following
specific questions:
a. What is a reasonable approval timeline for an EPC?
b. What obstacles or roadblocks, if any, exist in the current
approval process?
c. What can HUD do to streamline the approval process?
d. What alternatives to current procurement procedures would
expedite the approval process?
e. How would a formal appeal process for disapproved EPCs benefit
PHAs, Energy Services Companies (ESCOs), or other stakeholders?
2. Net Present Value
Currently, HUD is considering requiring that the Investment Grade
Energy Audit incorporate Net Present Value calculations. Does the
industry use a standard rate of return for these calculations?
3. Measurement and Verification (M&V) Requirements
Under PIH Notice 2009-16, HUD currently recommends that PHAs obtain
independent 3rd party M&V reports annually for projects over $10
million, and every three years for projects costing less than $10
million.
a. What benefits are there to implementing mandatory independent
3rd party M&V for all projects? What considerations should be made in
implementing such a requirement?
b. What qualifications should be required of parties performing 3rd
party M&V? Should such requirements for 3rd party M&V companies include
a requirement that they hold ``current'' certifications? And how should
a ``current'' certification be defined (e.g., certification received in
the past two years)?
c. How could significant differences between a 3rd party report and
the ESCO's M&V report be reconciled?
d. How can the measurement and verification of energy cost savings
be improved?
e. What additional controls, if any, are needed to ensure that
utility cost savings are properly calculated and reported in M&V
reports? Should such controls include a requirement that the calculated
cost savings be certified by a Professional Engineer (PE)?
f. What additional controls, if any, are needed to ensure that the
costs of EPCs are properly repaid from energy savings?
4. Removing Barriers to EPCs
Over the lifetime of HUD's EPC program, there have been
approximately 240 EPCs executed by PHAs. The vast majority of these
EPCs have been completed by medium and large PHAs. HUD would like to
involve more PHAs in the EPC program, especially small PHAs.
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a. How can HUD improve PHAs' capacity to perform self-developed
EPCs?
b. What can HUD do to improve access to EPCs for small PHAs? For
instance, should HUD allow for EPCs for several small PHAs to be
bundled together and performed by one (1) ESCO? By bundling EPCs
together, would the overall scope be more attractive and provide a
large enough investment/incentive for the ESCOs?
5. Section 3 Compliance
The Section 3 program requires that recipients of EPC incentives,
to the greatest extent possible, provide job training, employment, and
contract opportunities for low- or very-low income residents and
qualified businesses in connection with the EPC project (see 24 CFR
part 135). How can HUD improve Section 3 compliance and employment
associated with EPCs?
6. Energy and Water Auditing and Investment Standards
Energy and water conservation investment opportunities are
typically determined by an investment grade audit of a portfolio's
energy and water usage and costs and the various factors affecting
consumption. In some cases, EPCs have been found to be impractical
because sufficient savings from low-cost conservation measures could
not be leveraged. HUD is interested in knowing whether the current
approach for identifying cost-effective energy and water conservation
measures enables or impedes the development of comprehensive retrofit
strategies for materially reducing utility costs.
a. Are some high-cost measures not reachable through EPCs because
the ratio of savings is too low relative to the investment and
transaction costs?
b. How can renewable energy investments be encouraged under EPC?
c. Should EPCs permit the investments of green building measures if
sufficient savings or other resources can be leveraged to cover
investment costs?
d. Should HUD adopt an alternative assessment and auditing protocol
for PHA's undertaking self-direct EPCs? Could a Green Physical Needs
Assessment provide a useful mechanism for developing an investment plan
for reducing utility costs? Could a Home Energy Rating System program
(HERS) audit be used by very-small and small- PHA's undertaking EPC's
and if so how should the projected energy savings be estimated?
e. What steps can be taken to lower and control non-investment
transaction costs?
7. Leveraging
PHAs are encouraged to leverage external resources to offset the
costs of energy and water conservation investments. In some cases,
accessing available rebates and incentives can be difficult and not
well aligned with the EPC process and implementation period. HUD is
interested in knowing how leveraging can be increased in conjunction
with EPCs.
a. What challenges exist in aligning EPCs with the processes and
requirements established for available external energy efficiency and
water conservation programs? Are different auditing protocols used or
required? Do requirements for using business process improvement (BPI)
certified contractors pose implementation barriers? Are inspection and
quality assurance requirements duplicative? Are there load-ordering
investment requirements that conflict with EPC investment priorities?
b. How can or should the EPC process be modified to enable greater
leveraging of incentives and rebates available from external sources
such as utility and local governmental programs?
c. What approaches or mechanisms are needed to enable PHAs to
access and leverage energy efficiency and renewable energy tax credits?
III. Policy Clarifications
HUD is also using this Federal Register notice to clarify existing
policy regarding EPCs.
1. Allowable M&V options for EPCs
Several stakeholders have questioned whether HUD intended to limit
the use of certain M&V options currently available in HUD's EPC
program. In response to this concern, the Department wishes to clarify
that it will continue to allow all M&V options detailed in the
International Performance Measurement & Verification Protocol (IPMVP).
These M&V options are accepted methods for measuring and verifying the
amount of utilities consumed by a building or the change in the amount
of utilities consumed by a building due to a retrofit. The Department
finds that these M&V methods can be conducted accurately and represent
the utility consumption or change of utility consumption in EPCs.
2. Resident Paid Incentive
HUD has been asked whether the add-on subsidy incentive, found at
24 CFR 990.185(a)(3), is available to finance ECMs where the utilities
are resident-paid. HUD re-affirms that PHAs may not use the add-on
incentive for that purpose. PHAs undertaking energy conservation
measures that are financed by an entity other than HUD may include
resident-paid utilities under the consumption reduction incentive
consistent with 24 CFR 990.185(a)(2)(iii). This approach allows a PHA
to exclude from its Operating Fund rental income calculations any rents
received that are as a result of decreased utility allowances resulting
from decreased consumption. The PHA must exclude from its calculation
of rental income the increased rental income due to the difference
between the baseline allowance and the revised allowances of the
projects for the duration of the contract period.
3. Prohibition Against Liens
HUD re-affirms that, when using an ESCO as part of an EPC, no lien
or encumbrance is to be placed on public housing rental property (real
or personal property, such as fixtures). Similarly, if the PHA is
considering financing of an EPC with another third party, such as a
bank, no liens may be placed on public housing rental property
including any bank account, reserve or other personal property
(including the energy improvement fixtures) of the PHA. All public
housing property is subject to the Declaration of Trust and use
requirements of the Annual Contributions Contract and section 9 of the
United States Housing Act of 1937. All public housing property is
required to have a currently effective and recorded Declaration of
Trust. Any secondary lien must be reviewed and approved by HUD
Headquarters. Any Capital Fund financing or Operating Fund financing
under section 9 or section 30 of the 1937 Act must also be approved by
HUD Headquarters.
4. Funds resulting from the Operating Fund Benefit
Funds resulting from the Operating Fund Benefit may not be included
in an approved EPC cash flow. There are two types of incentives offered
for reduced utility consumption. The first is the Rolling Base
Consumption Level (RBCL) (24 CFR 990.170). The purpose of the RBCL is
to encourage PHAs to make management and maintenance decisions that
result in energy-efficiency improvements, whether large or small,
through the normal course of operation. This incentive is part of a
PHA's normal operating subsidy eligibility and results in excess
subsidy that decreases over a four year period and is an Operating Fund
Benefit. The Operating Fund Benefit is not an EPC incentive. The second
type of utility cost reduction incentive are those incentives offered
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under the EPC program (24 CFR part 185). To qualify for these
incentives, the PHA must obtain third-party financing and ensure that
the projected savings are sufficient to cover the costs of the
improvements. These are large-scale projects that require effort beyond
the normal course of operation. The Operating Fund regulations do not
allow the combining of these two incentive types to increase savings
and to include more energy conservation measures within an EPC.
Dated: May 27, 2011.
Sandra B. Henriquez,
Assistant Secretary for Public and Indian Housing.
[FR Doc. 2011-14049 Filed 6-7-11; 8:45 am]
BILLING CODE 4210-67-P