NAA/NMHC submitted comments to the Department of Energy (DOE) on Nov. 18 questioning a proposed methodology for calculating the costs of new residential energy codes published in the Federal Register (76 FR 56413).
DOE intends to use this methodology to analyze new code proposals, assist the private code-making bodies and support the government’s code advocacy efforts.
Of concern, the methodology does not adequately reflect the real-world
conditions of the apartment sector.
Instead, DOE is relying on single-family data and cost assumptions, which are not generalizable to multifamily properties. NAA/NMHC have recommended that a
separate financial analysis be conducted for multifamily buildings and other
apartment-related calculations be expanded to capture the diversity of multifamily building types. The comments are available at
http://tinyurl.com/4td5kr.