Commissioners,
Thank you again for your willingness to consider energy and water efficiency standards for our community’s rental properties. As we’ve discussed in the subcommittee, this community will never reach its climate protection goals without addressing our residential building stock, and for too long the emphasis has been almost exclusively on owner-occupied building stock.
Here are my personal recommendations beyond the currently-proposed standards, after consulting with the Community Weatherization Coalition’s (CWC) tune-up process and with Dr. Wendell Porter, UAB member and CWC co-founder:
*Move attic insulation requirements to R-30 instead of the existing R-19, where attic space permits. The existing Dept. of Energy (DoE) requirements are R-38, and even upgrading from an existing R-19 to R-30 would have a significant impact and worthwhile return on investment. This would be a one-time cost for most homes.
*Re: the ductwork, the average leakage of these systems is around 20-30% according to the DoE, so this is an area that has tremendous potential. We should require evidence of a duct leakage test performed at any time over the system’s history in order to assure that the ducts were properly installed and/or have been maintained in good working order. This would be a one-time cost per HVAC system.
*Where window AC units exist, they should be properly sealed. This is an inexpensive, one-time cost that will reduce overall home leakage.
*All showerheads and faucet aerators reduced to 2.2 gallons/minute. The CWC currently installs high-quality 1.5 gpm showerheads and have high client satisfaction with our faucet aerators in the range of .5-1.5 gallons/minute. This is very inexpensive with high return investment.
*Related to water savings, I recommend requiring 1.6 gallon per flush toilets. This has been the required standard in new building construction for many years now, is inexpensive, and has a high return on investment.
*On water heaters, I recommend removing the exemption for insulating pipes on gas units beyond the first 6″ above the unit. The CWC leaves off those 6″ for fire safety reasons due to the water heater’s blowout and we believe that this method is safe, cheap, and effective.
*Finally, on HVAC units, I believe that we could loosen this requirement to maintenance every 2-3 years instead of annually. I also think it’s important that the outdoor refrigerant lines be properly insulated. The added insulation is a very inexpensive solution that will improve efficiency and care of the unit.
Feel free to let affected landlords know that the CWC is happy to inspect any rental housing units in the City, that we provide several of the smaller retrofit items that I’ve recommended for free, and that we can help identify nearly all of the other issues that have been mentioned (aside from those which require professional contractors, such as the HVAC maintenance and duct leakage testing) free of charge.
Finally, on the issue of efficiency ratings, I fully support ratings systems that can be implemented affordably and think that such tools can help tremendously in educating both our tenants and landlords. However, if we are in a position where we have to choose one or the other, I would prefer that the standards be implemented over a ratings system.
As a 10+ year veteran energy coach with the CWC, I am confident that the recommendations I am making to you can have significant impact in reducing our renters’ utility bills and that these improvements would outweigh any resultant increases in rental housing pricing.
Thanks again for your consideration and I welcome any questions or feedback you might have on this topic,
Jason Fults