In our first blog post, we discussed our team’s work on incentive programs and compliance, and our advocacy efforts at the local and state levels. Since the passage of the Inflation Reduction Act (IRA) last summer, Bright Power’s Policy and Programs team has also been engaging at the federal level to understand how building owners can leverage the $369 billion in energy efficiency funding.
The IRA marks the federal government’s first significant commitment to improving energy efficiency in the built environment across the country. However, there is plenty of work to be done to ensure that an adequate share of this historic investment gets directed to multifamily properties. This is where our work comes in. Our Policy and Programs team works hard to advance the interests of our partners, advocating on behalf of the multifamily sector to numerous federal agencies involved in the new IRA programs: Department of Energy (DOE), Treasury Department, Environmental Protection Agency (EPA), and Department of Housing and Urban Development (HUD). The risks of not engaging with these agencies as they develop and implement new energy efficiency programs are not inconsequential. Because the majority of housing in the United States consists of single-family homes, there is a historical tendency for energy efficiency programs to overlook multifamily properties, especially affordable housing. Without the work of the Policy and Programs team partnering with stakeholders, trade groups, and even competitors, the tendency to neglect the multifamily sector could be replicated in the new IRA programs.
Fortunately, the considerable amounts of funding flowing through these federal agencies required significant stakeholder engagement, and our Policy and Programs team has participated at every available opportunity. Our team contributed to joint responses to DOE’s Request for Information (RFI) on the state-run Home Energy Efficiency and Electrification rebate programs and EPA’s RFI on the Greenhouse Gas Reduction Fund (GGRF). In the rebate programs RFI response, our team emphasized the importance of setting funding aside specifically for multifamily properties, and especially for affordable housing. Additionally, our team highlighted the critical need for energy savings requirements to consider the complexity of modeling and measuring savings in large, multifamily properties. In the GGRF RFI response, we joined in advocating for including energy efficiency and electrification upgrades in the scope of the fund’s programs.
In the fall of 2022, HUD released two RFIs, one for their new Green Resilient Retrofit Program (GRRP) and another for their new benchmarking program. The Policy and Programs team’s response to the GRRP RFI suggested four principles for the program to adhere to:
- Work with other federal agencies to push for better utility data
- Expand data collection beyond utility bills alone
- Engage benchmarking experts
- Consider both tenant and owner impacts of energy efficiency.
By committing to these principles, HUD will provide the greatest impact to multifamily property owners that participate in the GRRP. For the Benchmarking RFI, the Policy and Programs team collaborated with Bright Power’s Strategic Initiatives team to provide a detailed overview of the process behind our successful benchmarking platform, EnergyScoreCards, as a paradigm for HUD’s program.
Home Energy Efficiency & Electrification Rebates
The New York State Energy Research and Development Authority (NYSERDA) will receive over $315 million from the IRA for the Home Energy Efficiency and Electrification rebate programs. At the end of July, DOE released program administration guidance for the rebate programs, allowing NYSERDA to begin the process of designing their incentives. The DOE guidance includes minimum required allocations for low-income households and low-income multifamily properties. Moreover, the guidance outlines flexibility for energy savings measurement and modeling for multifamily buildings. It may seem like New York will have a big pot of money for the rebate programs, but funding will move quickly and our team’s continued engagement with NYSERDA on program design and implementation is critical to building owners’ ability to capitalize on these new resources. At the moment, NYSERDA anticipates launching the Home Energy Efficiency and Electrification rebate programs towards the end of this year or the beginning of 2024.
EPA Greenhouse Gas Reduction Fund (GGRF)
In April, the EPA released the GGRF implementation framework through which they will distribute $27 billion in grant funding to drive investment in clean energy solutions. There are also required set-asides for investment in low-income and disadvantaged communities. The framework describes three competitions: (1) National Clean Investment Fund (NCIF), (2) Clean Communities Investment Accelerator (CCIA), and (3) Solar for All. At the end of June, EPA released the Notice of Funding (NOFO) for the Solar for All competition, which will help promote increased uptake of solar and also critically includes electrical, building, and energy efficiency upgrades as eligible program costs. Two weeks later, EPA released the NOFOs for the NCIF and CCIA as well. The various GGRF grants will be awarded largely to non-profits, green financing lenders, and state and municipal government agencies, but there is an important role for Technical Assistance providers, like Bright Power, to play in the implementation and verification of EPA funded projects.
HUD Green Resilient Retrofit Program (GRRP)
In May, HUD released the program notice for the Green Resilient Retrofit Program (GRRP) with more than $830 million in funding. The funding will be distributed through three Notices of Funding (NOFO), one for each of the three program cohorts: Elements, Leading Edge, and Comprehensive. Each cohort will address different project needs with the Elements cohort offering gap funding to expand a scope of work, the Leading Edge cohort offering funding for projects to achieve net-zero high-performance building certification, and the Comprehensive offering funding for deep retrofit scopes of work, as well as guidance and technical assistance to building owners throughout the process. All of the cohorts are focused on implementing measures that will improve energy and water efficiency; enhance indoor air quality and sustainability; implement the use of zero-emission electricity generation, low-emission building materials or processes, energy storage, or building electrification strategies; and address climate resilience in HUD-assisted multifamily properties.
The Policy and Program team here at Bright Power continuously engages with partners, trade groups, and other critical stakeholders to advocate for the interests of the multifamily building sector in this complex, post-IRA landscape. The team’s policy analysts stay abreast of all the updates, deadlines, and changes to the IRA programs laid out above and keep our partners informed of the opportunities that exist for their properties. The critical work that our team does, and will continue to do, is part and parcel of Bright Power’s thought leadership in the multifamily energy efficiency space. We know that these new IRA programs are complicated and can seem daunting. But, we are here to talk through all of the options available to you, your properties, and your projects, and help figure out what makes the most sense. Reach out to your Bright Power Account Manager today to connect with the Policy and Programs team and start a conversation around leveraging these new and exciting IRA funds.
Disclaimer: This material about the IRA tax credit has been prepared for informational purposes only using the best available information and guidance from the Internal Revenue Service (IRS), Department of the Treasury, and the Department of Energy (DOE), and project information. Bright Power does not provide tax advice and the information provided about the IRA tax credit should not be relied upon as tax advice. Recipients should consult their own tax and professional advisors prior to acting on the information herein. Bright Power is not responsible for any incorrect tax credit and deduction determinations.