Affordable Housing and Housing Affordability
NCBPA began focusing on this area during the 2019 Legislative Session when we continually encountered pushback from legislators that are allies of the North Carolina Home Builders Association (NCHBA), which maintains a policy of any added up-front costs to homes contribute to housing affordability issues. This includes energy efficiency and high performance products, services and features that have positive lifetime ROIs, such as added insulation, with very low up-front costs that Builders can pass along to consumers.
Update: June 2, 2020
Prescriptive Measures Needed for NCHFA’s Multifamily Affordable Housing Program:
NCBPA has been working with staff from NC Housing Finance Agency to advocate for improvements to the Qualified Allocation Plan’s minimum energy efficiency standards, which are currently at ENERGY STAR 2.0 for low income multifamily buildings. Technically, these standards are below NC’s 2018 energy code. NCBPA shared recommendations for improved standards via a comment letter on May 4, 2020. NCBPA, our members and partners will continue to advocate for further improvements to the minimum standards as well as incentives for developers that go above and beyond.
2020 Plans and Activities
In 2020, NCBPA will continue to work on this issue in hopes of changing the way that high performance homes and buildings are considered in affordability discussions, programs and even code requirements. Our 2020 activities will include:
- We are leading code development efforts to bring official state recognition to the value of non-energy benefits found in energy efficient and high performance construction, retrofits, products and services. Doing so would improve our ability to advance North Carolina’s minimum energy code requirements while also enabling Duke Energy to expand and improve its existing energy efficiency programs, and likely add new ones, as the state recognition of the non-energy benefits would open new pathways for their cost effectiveness testing, providing more value to their energy efficiency programs.
- As we did in 2018 and 2019, we will continue to advocate and submit public comments to NCHFA in order to increase the minimum energy efficiency requirements of the state’s NCHFA 2019 Qualified Allocation Plan while also introducing developer incentives for energy efficient and high performance measures, products and services.
- Our association has heard from several developers that their current margins are too low to explore increasing energy efficiency standards, including certifying to regional or national programs, on their own. These developers have asked for points to be assigned to individual measures and programs in order to incentivize them, and also for outside rebates or incentives from utilities (NCBPA is working on this separately). Action Requested: NCBPA is seeking multifamily developers, program administrators/participants and other stakeholders to support and participate in our work to obtain QAP points for individual measures and programs.
- In addition to providing QAP points for individual measures and programs, NCBPA seeks to raise the minimum requirements from ENERGY STAR 2.0, a program that technically no longer exists, to the latest version of ENERGY STAR. Action Requested: NCBPA is seeking multifamily developers, program administrators/participants and other stakeholders to support and participate in our work to advocate for increases to the program’s minimum requirements. The 2019 QAP Public Hearing will be held on Sep 4th. Help develop and submit comments – contact us today!
In 2019, NCBPA made some progress on improving the way energy efficient and high performance construction are considered in discussions on affordability:
- Potential New Multifamily New Construction Duke Energy Program: NCBPA began proposing this new program in early 2019 through Duke Energy’s bi-monthly meeting series called the Collaborative that involves Duke program staff, regulatory staff and energy efficiency advocates like NCBPA. Fortunately, they were already having internal discussions about modifying a current program, the mostly commercial Design Assistance Program, to include multifamily projects. Additionally, the existing Residential New Construction program that provides up to $9k of builder incentives and is available for single family and multifamily up to (including) 3 stories is being looked at for potential incentives as well. Now, Duke Energy is actively exploring program modifications that would result in incentives for multifamily developers that go above and beyond NC’s minimum energy code (roughly 2012 IECC) and in particular above ENERGY STAR 2.0, which is the minimum requirement for NCHFA’s LIHTC program.