Comment Detail

Comment

Question 55. What, if any, ongoing monitoring should be required to measure the effectiveness of
financed energy improvements in reducing tenants’ energy and water consumption and utility
costs?

Question 62. Should the Enterprises be required to verify, after the closing of a single-family energy-
improvement loan, that the energy improvements financed actually reduced energy and water
consumption and utility costs and, if so, how can they verify this?
Responses are relevant to both Question 54 (multifamily) and 62 (single family).

• The Enterprises should require transparent tracking of performance and savings realizatikn rate on each project. Inexpensive software is available today, so there is no excuse not to. Published data should include the contractor who performed the work and the professional who projected the savings.

Remote tracking of outcomes will have the effect of dramatically improving consumer protection by creating accountability and M&V for each project. This also reduces costs as current M&V practices require expensive site visits.

RECOMMENDED PAYBACK PERIOD FOR EFFICIENCY MEASURES
Question 56. For the proposed requirement that the reduced utility costs will offset the upfront costs
of the improvements within a reasonable time period, should a reasonable time period be defined
and, if so, how?
Question 58. What is a reasonable time period for the reduced utility costs from energy efficiency
improvements to offset the upfront costs of the improvements?
Question 63. For the proposed requirement that the reduced utility costs will offset the upfront costs
of the improvements within a reasonable time period, should a reasonable time period be defined
and, if so, how?
Responses are relevant to Questions 56, 58, and 63.
• No. Since EE improvements havd durability, healt, and safety