On November 18, 2011, NMHC/NAA submitted comments to the Department of Energy (DOE) 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 to support the government’s code advocacy efforts. Of concern, the methodology does not adequately reflect the real-world conditions of the apartment sector.
Instead, the DOE is relying on single-family data and cost assumptions, which are not generalizable to multifamily properties. NMHC/NAA 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.
