In a letter sent Sept. 22, NAA/NMHC questioned the need for a National
Asset Rating Program for Commercial Buildings (AR Program) proposed by
the Department of Energy (DOE).
The AR would rate new and existing buildings on their expected energy
performance. Notably, AR “ratings” would be based on the building’s physical characteristics or “as-built” features and not operational considerations or actual utility data.
While voluntary energy efficiency and benchmarking programs such as EPA’s Energy Star are generally designed as energy management tools, the AR Program is specifically designed to impact valuation and transactional decisions.
The NAA/NMHC letter questions the market need for another energy measurement program, when numerous well-established governmental and private sector programs already exist—such as EPA’s Energy Star. Instead, NAA/NMHC suggest that reinvestment in existing programs is a “more effective and resource-efficient path to achieving” energy efficiency goals.
In a positive move, the DOE has indicated its intention to develop the AR Program in stages and phase-in various building types. As proposed, multifamily properties would not be included in the initial program, but the DOE is committed to expanding the program throughout the real estate sector. NAA/NMHC will continue to educate the Obama Administration about the unique characteristics of the apartment sector and the need for carefully tailored industry metrics.