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**acknowledgements**

This Public Housing Utility Allowance Guidebook was prepared by The
Nelrod Company under the U.S. Department of Housing and Urban
Development (HUD) Contract Number C-OPC-22394, Task Order DEN-TO003, and
through the excellent guidance of **Richard D. Santangelo, Energy
Program and Project Manager and the HUD Management and Occupancy Team:
John H. Miller, Leroy Ferguson, and Darlene Felton.** The authors want
to give a special recognition and extend a special thanks to the
following people who provided invaluable contributions:

**[U.S. Department of Housing and Urban Development
(HUD)]{.underline}:**

**Gregory A. Byrne,** Public and Indian Housing

**Joan DeWitt,** Policy Development and Research

**Laurence Doxsey,** Community Planning and Development

**Michael Freedberg,** Policy Development and Research

**Robert Groberg,** Policy Development and Research

**Marie L. Lihn,** Policy Development and Research

**Anna R. Lloyd,** Public and Indian Housing

**Clamentine V. Melvin,** Public and Indian Housing

**Lynn A.. Rodgers,** Policy Development and Management

**Brian Ruth**, Public and Indian Housing

**Richard L.. Schmehl,** Public and Indian Housing

**Wayne W. Waite,** Field Policy and Management

**HUD Field Offices**

**[Other Agencies]{.underline}:**

**Michelle A. Marean,** Princeton University

**Dr. Jeff S. Haberl,** PH.D., P.E. FASHRAE, Texas A&M University

**Don Gilman,** P.E., Assistant Research Engineer, Texas A&M University

**[The Nelrod Company]{.underline}:**

**Nelson Rodriguez,** President/CEO

**Valencia Barber,** Project Manager

**Cheryl Lord,** Manager, ResidentLife Utility Allowances Division

**C.T. Loyd,** Director, Energy Systems Division

**Mark Vogeler,** Vice President, Planning & Development

**Vicki Brower,** Operations Director

**Maci McDaniel,** Development Director

**Joshua Rodriguez,** Jarco Ventures, LLC-IT Services

**Special thanks go to all the Housing Agencies that participated in the
interview process, data gathering process, and review of draft UA
Guidebook with comments.**

**Table of Contents**

**Page**

**INTRODUCTION: Basic Information** 1

What Are Utility Allowances? 1

What Are Consumption Allowances? 3

Why Are Accurate Utility Allowances Important? 3

The Impact of Utility Allowances on Asset Management 4

The Impact of Energy Performance Contracting on Utility Allowances 4

HUD Regulations for Public Housing Utility Allowances Highlights 5

**CHAPTER 1: Determining the Types of Utility Allowance Study Needed** 6

Determination of Types of Study Needed 6

*Consumption Study* 6

*Update Study for Ten Percent Rate Change* 7

*Determination Process Diagram* 7

Determining the Methods to Use if Performing a Consumption Study 9

*Actual/Historical Consumption-Based Method Overview* 9

*Engineering-Based Method Overview* 11

Selecting a Method for Determining Consumptions 12

Other Considerations 13

**CHAPTER 2: Procedures to Establish Average Total Consumptions and
Utility**

**Allowances Using the Actual/Historical Consumption-Based Methodology**
15

Allowable and Non-Allowable Utility Consumptions 15

*Allowable Utility Consumptions* 15

*Non-Allowable Utility Consumptions* 16

Developing Average Total Consumption Using the Actual/Historical-Based
Consumption Method 18

**Step 1.** Obtain Information Release Forms from Residents 18

**Step 2.** Identify Timeframes for Consumption Data Collection 19

**Step 3.** Understand the Different Data Types and Collection of the
Data 20

*Utility Consumption Data* 20

*Utility Rates and Charges Data* 21

*Housing Occupancy Data* 21

*Air Conditioning Consumption Data* 21

*Optional: Climate Data* 22

**Step 4.** Define Utility Allowance Categories 22

**Step 5.** Assess the Data Report Format and Information Provided 23

**Step 6.** Sort the Data into Allowance Categories 24

**Step 7.** Determine the Sampling Size Needed 25

*Eliminating Problem Data from a Spreadsheet Tables* 26

*Eliminating Data Due to Limited PHA Resources* 26

**Step 8.** Calculate Typical Consumption Averages 27

**Step 9.** Adjust Consumption Data Utilizing a Spreadsheet 28

*Adjusting Problem Data* 29

*Optional Adjusting for Climate Changes -- Heating Only* 30

*Adjusting the Average Total Consumptions for High Users and Low Users*
32

**\
Page**

**Step 10.** Convert Consumption Allowances into Utility Allowances 33

*Estimating the Consumption Requirements for Trash/Garbage* 33

*Utility Allowance Schedule* 34

**CHAPTER 3: Establishing Utility Allowances Using the
Engineering-Based**

**Methodology** 35

Various Utility Estimates 36

*Base Loads* 36

*Space Heating Estimates* 36

*Air Conditioning Estimates* 37

*Domestic Hot Water Heating Estimates* 38

*Estimating the Energy Consumption Requirements for Laundry* 39

*Estimating the Consumption Requirements without Water* 40

*Cooking and Lighting* 40

*Refrigerators* 40

*Water* 41

Conversion Charts 41

Report 43

Energy Efficient Utility Allowances 43

**CHAPTER 4: Calculating Utility Allowances** 44

Utility Rates and Charges 44

*Deregulation of Utilities* 44

*Metering Systems* 45

Rate Structures 45

Verify Calculations with Sample Utility Bills 47

Calculating Utility Allowances 48

*Totaling Component Consumption Amounts for Each Utility* 7

*Electricity* 48

*Natural Gas* 48

*Propane or Fuel Oil* 48

*Water* 49

*Sewer/Wastewater* 49

Individually Metered Utilities: Establishing Equal Monthly Allowances 49

Complete Utility Allowance Schedule 50

*Totaling All Resident-Paid Utility Allowances by Housing Dwelling Unit*
50

**CHAPTER 5: Annual Review of Allowances** 51

**CHAPTER 6: Implementation of Consumption Allowances and**

**Utility Allowances** 54

Support Documentation 54

Notice to Residents 55

Individual Relief 56

Adopting Utility Allowances 57

HUD Review of Allowances 57

**Page**

**CHAPTER 7: Energy Efficiency** 58

System Management, Control and Behavior Issues 59

Using an Energy Audit in Capital and Maintenance Planning 62

*Physical Inspection and Equipment/System Testing* 62

*Utility Bill Analysis* 62

*Energy Efficiency Opportunities* 63

*Incremental Investment Analysis* 63

Energy Audit Regulations 64

Energy Service Companies (ESCOs) -- A Way to Control Utility Costs 65

**APPENDIXES**

Appendix A: Information Resources (including websites) 68

Appendix B: Sample Forms and Helpful Information

1\. Sample Request for Proposal (RFP) 71

2\. Sample Request for Quotation (RFQ) 77

3\. Descriptions of Unit (Building/Structure) Types 81

4\. Sample Resident Release of Information Form 82

5\. Sample Individual Relief Request Form 83

6\. Sample Board Resolution 85

7\. Residential Consumption of Electricity by End-Use, 2001 86

Appendix C: Copy of HUD Regulations 24 CFR 965, Subpart E

Resident Allowances for Utilities 88

Appendix D: Glossary of Key Terms and Definitions 92

Appendix E: Acronyms 100

Appendix F: ENERGYSTAR® Products 101

**Page**

**FIGURES**

Figure 1 Which Type of Study is Needed? 9

Figure 2 Physical Feedback in a Thermostat 66

Figure 3 Informational Feedback 67

**TABLES**

Table 2-1 Allowance Categories for Two Developments 26

Table 2-2 Sample Spreadsheet Layout 30

Table 2-3 Normalizing Data with Heating Degree Day Factor 33

Table 2-4 Sample Consumption Allowance Schedule 34

Table 3-1 Water Conservation 44

Table 3-2 Fuel Energy Content and Conversion 44

Table 3-3 KBtu Conversion 45

Table 4-1 Sample Utility Allowance Schedule 54

**INDEX** 102

**\
**

# 

# **INTRODUCTION: Basic Information**

> **OVERVIEW: The purpose of the Basic Information section is to define
> utility allowances and their importance, and to describe the purpose
> and use of this Utility Allowance Guidebook.**

This Utility Allowance Guidebook replaces the Utility Allowance
Guidebook for Optional Use by Public Housing Agencies, 1998.

While use of this Utility Allowance Guidebook (hereinafter referred to
as UA Guidebook) is not a regulatory requirement, this UA Guidebook
provides Public Housing Agencies (PHAs) with acceptable methods to use
in the development of utility allowances (UAs). The U.S. Department of
Housing and Urban Development (HUD) continues to allow individual PHAs
to develop their own approaches to calculate UAs as long as the method
or approach is consistent with HUD regulations found in the Code of
Federal Regulations (CFR), Title 24, Part 965 (see Appendix C for a copy
of these regulations).

This UA Guidebook focuses primarily on the consumption-based method for
calculating computations, and the implementation of consumption and
utility allowances (see Chapter 2). The other method, known as the
engineering-based method, is discussed extensively in Chapter 3. The
Appendix to this UA Guidebook also includes information resources
(including websites-Appendix A), sample forms and helpful information
(Appendix B), HUD regulations related to Public Housing UAs: 24 CFR 965,
Subpart E Resident Allowances for Utilities (Appendix C), as well as a
Glossary of Key Terms and Definitions (Appendix D) and a listing of
common Acronyms used in this UA Guidebook (Appendix E).

This UA Guidebook is intended for the Public Housing Program. The
Housing Choice Voucher Program and other HUD programs also utilize
Utility Allowances. However, there are significant regulatory
differences between Utility Allowances in this UA Guidebook and other
HUD programs. Please do not use Public Housing Program Utility
Allowances for other programs.

## What Are Utility Allowances?

A utility allowance (UA) is a dollar amount provided to residents to
help them pay their utility bills. UAs combine the costs, in dollar
amounts, of allowable utilities paid by residents in dwelling units
managed by a PHA.

-   ***Utility Allowance (cost) -- for Resident-paid utilities:*** The
    cost (dollar) associated with the average resident's reasonable use
    of utilities that the resident pays directly to utility suppliers.

UAs are based on an estimate of a reasonable amount of utilities
consumed by an energy-conservative household of modest circumstances
consistent with requirements of a safe, sanitary and healthful living
environment \[24 CFR 965.505\].

Utility Allowances are provided for the following allowable utilities:

-   **Electricity** (for space heating, cooking, hot water heating,
    lighting, refrigeration, microwave, television, computer, and
    appliances)

-   **Natural gas**, **bottle gas/propane**, **fuel oil**, **wood** or
    **coal** (for space heating, cooking, and hot water heating)

-   **Water and sewer** service (sometimes referred to as waste
    management)

-   **Trash and garbage** collection (may also include recycling and
    landfill charges)

    These items will be explained in more detail in Chapter 2:
    Procedures to Establish Utility Allowances Using the
    Actual/Historical Consumption-Based Method.

Consumption based UAs are generally determined by multiplying the
"average measured amount for utilities use" (i.e., the term
"consumption" is commonly used to describe this measured amount) by
residents with the utility supplier's current residential rates and
charges. Consumption amounts involve different fuel type (e.g., natural
gas, propane, etc.) and utility type (e.g., water and sewer, etc.) and
are defined in common units of measuring energy or commodity (e.g.,
gallons, kWhs, therms, etc.).

UAs vary with the physical characteristics of the dwelling units in each
housing development, such as building construction type, size of
dwelling unit and age of building and equipment. To account for such
factors, allowances are grouped and calculated by similar
characteristics into categories such as housing developments, sites or
Asset Management Projects (AMPs).

The UA amount is usually deducted from the resident's monthly rent.
Although for residents whose "Total Tenant Payment (TTP) is less than
the utility allowance, the PHA must make a monthly utility reimbursement
equal to the difference between the TTP and the utility allowance."
(*HUD Public Housing Occupancy Guidebook, June 2003*). A PHA may pay the
utility reimbursement either to the resident or directly to the utility
supplier as credit on the resident's behalf.

Accurate calculations and implementation of UAs affect both rental
integrity and regulatory requirements. In the federally subsidized
Public Housing program, a resident's share of rent and utilities should
not exceed 30% of the household\'s adjusted monthly income or 10% of the
family's monthly income \[24 CFR Part 5.628 (a) Determining Total Tenant
Payment (TTP)\].

**What Are Consumption Allowances?**

PHAs who furnish utilities to their residents use consumption allowances
as a point of reference for calculating a surcharge amount (based on
utility rates charged to the PHA) to bill residents who exceed the
determined average usage by other residents in the same housing
development and in the same bedroom (BR) size dwelling unit.

-   ***Consumption Allowance (usage) -- for PHA-furnished utilities:***
    The average amount of utilities consumed by a resident that the PHA
    determines is necessary to cover a resident's reasonable use of
    utilities that are PHA-furnished. The PHA pays for the cost of
    utilities. Consumption allowances are used to calculate surcharges
    for excessive consumption usage (consumption that exceeds the
    allowance).

    The development of the consumption allowances is the same as the
    development of the consumption base for UAs. Consumption Allowances
    stop with the consumption average and are implemented differently
    from UAs.

**It is important to remember that if utilities are master-metered (one
utility meter for each building) and not individually check-metered, the
PHA will not provide UAs or surcharge residents for excess usage,
although the PHA may charge a resident a reasonable amount for having an
extra freezer or refrigerator.**

**Why Are Accurate Utility Allowances Important?**

The purpose of developing accurate UAs is to fulfill the regulatory
requirement of establishing UAs for "a reasonable consumption of
utilities by an energy-conservative household of modest circumstances
consistent with the requirements of a safe, sanitary, and healthful
living environment." UAs should not be unrealistically high or low. UAs
that are too high will cost the government and tax payers more money.
UAs that are too low are unfair to residents and may violate
regulations. As this is an area in which there has been litigation, it
is important that the PHA document and defend the method used to develop
the UAs and perform an annual review of the UAs.

## The Impact of Utility Allowances on Asset Management

The ability to accurately calculate UAs is a critical factor in a PHA's
ability to prosper financially under asset management.

Each property in the PHA's portfolio operates under its own budget,
allowing the property to track both revenues and expenses more
accurately and to operate more efficiently.

With the rising costs of utilities, it is important that the PHA realize
that it does not fully bear the burden of UAs increases, but that the
burden is shared by HUD through the operating subsidy calculation.

If the PHA implements energy conservation measures resulting in
decreased consumption, the operating subsidy formula currently allows
the PHA to retain 75% of the cost savings. Additionally savings may be
realized as the PHA can also revise UA schedules for PHA-provided
utilities to reflect the reduced consumption.

**The Impact of Energy Performance Contracting on Utility Allowances**

To encourage energy conservation, HUD has provided two different
incentives to PHAs which include resident-paid utilities. One incentive
is the called "frozen base" and the other is "add-on". Both incentives
require PHAs to obtain financing from non-federal sources to fund
utility conservation measures. Both incentives require a PHA to receive
HUD field office approval. \[Regulations at 24 CFR 990\] When approved
for the additional subsidy incentive, the PHA is provided additional
subsidy eligibility to cover project expenses and debt service for the
implementation of energy conservation measures. \[24 CFR 990.107
(f)(2)\]

Savings are calculated from the difference in UAs determined before and
after the conservation measure are implemented. The PHA reduces its
rental income by the amount of the savings, which preserves its subsidy
eligibility for paying project and debt service cost. The PHA must use
at least 75% of the savings from resident-paid utilities toward project
expenses and debt amortization. Allowances must not be "arbitrary" or
"capricious" \[24 CFR 965.502 (e)\] and must reflect the energy
conserving behavior of a "household of modest circumstances" \[24 CFR
965.505 (a)\].

This topic will be discussed further in Chapter 7: Energy Efficiency.

**HUD Regulations for Public Housing Utility Allowances Highlights**

As mentioned earlier in this introduction, HUD's regulations related to
Public Housing UAs are found in 24 CFR 965, Subpart E Resident
Allowances for Utilities (see Appendix C). The following items are
obtained from these regulations and it is important to keep these in
mind as the PHA develops its allowances:

-   Units with no check-meters to measure the actual utilities
    consumption (master-metered) -- residents are subject to charges for
    extra appliances such as freezers and refrigerators. But no UAs are
    provided \[Sec. 965.501(b)\];

-   Maintain a record that documents the basis on which allowances are
    established and revised \[Sec. 965.502(b)\];

-   Give residents 60-day notice of proposed allowances and 30-day
    comment period \[Sec. 965.502(c)\];

-   It is the PHA's objective to calculate allowances for a "reasonable
    consumption by an energy-conservative household" \[Sec. 965.505(a)\]
    and the PHA may choose the complexity and elaborateness of the
    method used to achieve the foregoing objective dependent upon their
    housing stock and administrative resources \[Sec. 965.505(c)\];

-   Air conditioning consumption not included in UAs \[Sec.
    965.505(e)\], but surcharge relief can be provided by the PHA
    through a HUD requested waiver \[Sec. 965.508\];

-   Review at least annually the basis on which UAs have been
    established (consumption and rates) \[Sec. 965.507(a)\];

-   Revised UAs if there is a change of 10 percent or more from the
    rates on which such allowances were based \[Sec. 965.507(b)\]; and

-   Notify residents of the option to request individual relief from
    surcharges for excess consumption for PHA-provided utilities, or
    from billing in excess of the UAs for resident-paid utilities \[Sec.
    965.508\].

    All of the above items are addressed in this UA Guidebook and in
    detail in the following chapters.

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**CHAPTER 1: Determining the Types of Utility Allowance Study Needed**

> **CHAPTER OVERVIEW: The purpose of this chapter is to help PHAs make
> basic utility allowance decisions, such as:**
>
> **● Does the PHA need to conduct a utility allowance update or a new
> utility allowance consumption study? And,**
>
> **● If a new study is needed, does the PHA want to use the
> actual/historical method or the engineering method?**

The U.S. Department of Housing and Urban Development (HUD) gives Public
Housing Agencies (PHAs) freedom in how they develop allowances
(consumption and utility) for public housing dwelling units. Although
the federal regulations dictate the various factors that should be taken
into account, they do not require that any particular approach or method
be used to calculate allowances. Instead, it is at the discretion of the
PHA to decide how to establish allowances. The most appropriate approach
to choose depends on a PHA's particular characteristics, the information
(data) resources and expertise that are available.

**Determination of Types of Study Needed**

First, the PHA must determine [annually]{.underline} if it needs to
perform a new consumption study with utility rate adjustments or just an
annual review (update study) of utility rates with adjustments, if
required. Below are several issues that should be taken into
consideration when making this decision:

**[Consumption Study]{.underline}**

A consumption study is recommended if the following conditions exist at
the PHA:

-   ***Significant Change:*** Review any significant changes to
    buildings, equipment, or appliances that would affect the
    consumption requirements of the utility for which the allowance is
    provided since the time when the allowances were last calculated.
    Examples of such changes include modernization or weatherization,
    the installation of space heating or hot water heating systems, the
    replacement of a large portion of the refrigerators in a housing
    development. If there have been any significant changes that would
    affect the consumption requirements of dwelling units, then the
    allowance consumption amounts for the affected dwelling units should
    be recalculated.

-   ***Time Period:*** Check to see when the last time the consumption
    allowance amounts were calculated. If these consumptions [have
    not]{.underline} been recalculated in the last five years it is
    highly recommended (as a best practice) that the consumptions be
    recalculated to take into account any changes over time that have
    affected the consumption usage of the dwelling units.

-   ***Lack of Support Documentation:*** In addition to the current
    "Utility Allowance Schedule", check to see if there is complete
    documentation supporting the method used for determining average
    consumptions, the utility rates and charges used to calculate the
    allowances, the actual calculations of the allowances, plus any
    other documents used in the last study.

    **[Update Study for Ten Percent Rate Change]{.underline}**

    If the utility rates change by ten percent or more (increase or
    decrease) compared to the rates used when the current UAs were
    calculated, then the regulations require the PHA to recalculate the
    UAs based on the new/current rates and charges.

-   ***Change in Utility Rates and Charges:*** Contact the local utility
    suppliers to gather current rates and charges. Perform a comparison
    of the new/current utility rates and charges and the rates and
    charges used to calculate the current UAs. Determine if there has
    been a change of ten percent or greater in the rate changes and fuel
    adjustment charges.

**[Determination Process Diagram]{.underline}:** See chart (figure 1) on
next page. An explanation of each step in the chart will be addressed in
later chapters.

***Figure 1:*** Which Type of Study is Needed?

![](media/image4.wmf)

Next, the PHA must determine which staff member(s) will be assigned the
task to either develop the new average consumptions and/or calculate UAs
and/or perform the annual review and update of the UAs if appropriate.

## Determining the Method to Use if Performing a Consumption Study

There are two primary methods for determining consumption allowances,
the Actual/Historical Consumption-Based Method and the Engineering-based
Method. The **Actual/historical Consumption-Based Method** considers the
amount of utilities residents living in similar dwelling units ***have
consumed within a specific billing period in the past***, and the
**Engineering-Based Method** is a projection of the amount of utilities
people living in similar dwelling units are ***expected to consume
within a specific billing period**.* These two methods are explained
further below and in the following two chapters.

### [Actual/Historical Consumption-Based Method Overview]{.underline}

The amount of actual utilities consumed by residents is recorded by
individual residential (retail) utility meters. This method typically
uses a sampling of residents' utility bills or billing records (usually
for 1 to 3 year period, from the utility supplier) to determine monthly
utilities consumed by residents in similar dwelling units within a
housing development. The PHA determines the similarity of dwelling units
by assessing the building type (e.g., apartment or walk-up, row house or
townhouse, semi-detached duplex, detached house, etc.) (See Appendix B
for descriptions of each building/structure type), important
architectural features (e.g., wood siding or brick, single story or
multiple stories), bedroom sizes, the condition, maintenance and
efficiency of the installed heating/cooling equipment, and household
appliances. These *physical characteristics* must be considered when
determining reasonable (fair) amount of utilities consumed by residents.
PHA staff can be trained to develop consumption allowances (the average
amount of utilities consumed by a resident that is necessary to cover a
resident's reasonable use of utilities) using an actual/historical
consumption-based method since it uses readily available information
(commonly known as "data") and straightforward arithmetic calculations.

There are pros and cons to utilizing an actual/historical
consumption-based method.

***Pros:***

-   Method requires less information research and calculations;

-   Actual consumption records can usually be obtained from most local
    utility suppliers for little or no cost;

-   Does not require special software;

-   Does not require advanced technical skills;

-   Actual consumptions should include the lifestyle issues of residents
    living in a particular housing development and bedroom size.

    ***Cons:***

-   *Cost* - In recent years, some utility suppliers have been imposing
    fees for providing historical data to housing agencies.

-   *Privacy Issues* -- Residential utility usage and cost information
    is considered private information, and the utility supplier may not
    release the information without a signed release form with account
    numbers and the signature of the person listed on the account. Some
    utility suppliers require the use of their own authorized form for
    release of information.

-   *Time Consuming* -- Most PHAs do not have signed resident release
    forms readily available. Therefore, hours of staff time could be
    involved in obtaining the releases from as many residents as
    possible; presenting the forms to the utility supplier; and
    obtaining the actual historical consumption data from the utility
    suppliers. Since most utility suppliers provide the data to their
    customers without charge, as a courtesy, they tend to take their
    time returning the consumption data to the PHA. Often the data is in
    a non user friendly format, making it difficult to work with.

-   *Incomplete Data* - Sometimes data is unavailable for an entire
    housing development or for certain bedroom sizes. Often historical
    data received has less than a 12-month consumption history, (12
    months is the preferred timeframe). This may be due to disconnects,
    vacancies, utility service being in the name of someone other than
    the head-of-household, etc.

-   *Efficiency/Costs* -- For medium to large agencies, multiple staff
    may be involved in the gathering, sorting and calculation of
    consumption averages. This can result in additional staff time due
    to communication or lack of understanding to the importance of the
    task.

-   *Deregulation of utility suppliers and large jurisdictions* -- In
    deregulated states, PHAs may have to contact and work with multiple
    electric and natural gas utility suppliers. Additionally, larger
    states such as Texas, California, Arizona, and Illinois have many
    PHAs with jurisdictions covering multiple cities/towns, counties,
    metropolitan areas, and regional areas. This often results in
    multiple utility suppliers servicing an area. Dealing with multiple
    utility suppliers can be difficult. They often have their own
    individual privacy rules and rate calculations.

-   *Removal of air conditioning consumptions* -- As required by HUD
    regulations. This can be a difficult task since utility suppliers
    provide consumption data in a lump-sum format and not by end-use
    (e.g., space heating, cooling, cooking, hot water heating, etc.).
    Removing the air conditioning portion of usage may requires a
    complex engineering calculation to determine the amount of
    electricity used by a dwelling unit for central or window unit air
    conditioning. Sometimes it is difficult to determine dwelling units
    which are air conditioned, especially when resident furnish there
    own window air conditioners. See Chapters 2 and 3 for more details
    on removing air conditioning consumption.

### [Engineering-Based Method Overview]{.underline}

An engineering-based method relies on engineering calculations and
assumptions. It utilizes standardized consumption information for energy
using equipment such as: heating, air conditioning, and appliances. This
method considers utilities consumed due to building performance (e.g.,
energy usage or efficiency), utility end-uses (e.g., electric heating,
electric cooking, electric water heating, etc.), and heat loss (e.g.,
insulation levels) and energy type. Accuracy requires detailed
information about buildings and the utilities consumed. This method
utilizes data from historical studies (weather information) and
engineering models to compute consumption used. Engineering-based
allowances should be compared to actual utility bills to determine if
the projections measure up to reasonable allowance levels.

When utilizing an engineering-based method, specific technical
information and building characteristics of housing
developments/dwelling units must be gathered. This includes air leakage,
duct leakage, insulation levels and insulation, window types, etc.

There are pros and cons to utilizing an engineering-based method.

***Pros:***

-   This method focuses on what consumption usage should be, thus
    promotes energy-conservative behavior;

-   Method does not require time consuming process of gathering personal
    utility use data from residents. Beneficial to larger PHAs with
    large number of dwelling units;

-   Limited sampling consumption data or missing consumption data is not
    a concern;

-   Technical information and data needed to model consumption usage can
    usually be found on the internet;

-   Provides a method for removal of air conditioning consumption since
    utility companies provided usage in a lump sum format;

-   This method can be utilized in conjunction with the
    actual/historical consumption-based method.

    ***Cons:***

-   Information regarding standardized consumption for energy using
    equipment such as: heating, air conditioning, and appliances, is not
    always readily available;

-   Gathering technical information and data can be very time consuming;

-   Often assumptions (guesses) must be made as to reasonable
    consumption usage, such as resident lifestyle issues (e.g., length
    of time resident spends in dwelling unit, number of appliances and
    how often appliances are used, etc.);

-   The difference between consumptions developed by engineering
    approach and actual consumption usage can be great;

-   Not all PHAs have trained personnel in building science and energy
    consumption measures to properly gather building, facility,
    equipment, and other data needed for accurate engineering
    calculations;

-   Not all PHAs are trained or licensed to use an acceptable energy
    consumption software program to determine accurate consumptions.

**Selecting a Method for Determining Consumptions**

Either method implemented properly can be used by smaller PHAs due to
the small number of dwelling units. However, availability of staff, and
lack of skills necessary to complete a study can be a determining
factor.

An ***actual/historical consumption-based*** method works well for a
majority of the PHAs across the nation. Most PHAs base their UAs on
recorded actual historical utility data. This method requires no special
software and does not require advanced technical skills. Because it
focuses on recent information (data) from residents' utility accounts,
using this method generally reflects changes in the condition of the
physical dwelling units (deterioration or improvements), in space
heating and water heating equipment operation, and in resident
population and behavior (lifestyle). In addition, as public housing is
transitioning to asset management, the calculation of UAs by averaging
actual historical utility data is in agreement with this transition.

Calculating allowances using a history of residents' consumption data
does not prohibit also using engineering calculations. On the contrary,
engineering-based calculations are often used in combination with actual
historical consumption usage to separate the utility end-uses (e.g., gas
heating, gas cooking, and gas water heating) or to provide a basis for
determining allowances where actual historical data is not available. If
the process is performed properly, there should be similarity in the
results (average consumption totals) for the consumption-based method
and engineering-based method.

A properly executed ***engineering-based method*** may be the best
method for the larger PHAs due to their large number of dwelling units
(some in the thousands) and the number of utilities paid by residents.
**Those PHAs with the capacity and resources should check the
consumption allowances developed using engineering calculations, against
actual historical utility data.**

Not all PHAs have personnel trained in building science and energy
consumption measures to properly gather building, facility, equipment,
and other information needed for accurate engineering calculations. Not
all PHAs are trained or licensed to use an acceptable energy consumption
software program to determine accurate consumptions. This should be
considered when determining if the PHA is capable of completing the
study in-house.

The next two chapters provide a detailed process to calculating UAs
using each of these methods mentioned above.

**Other Considerations**

For many medium, large and very large PHAs (with a numerous housing
developments containing hundreds and thousands of dwelling units, and
with many bedroom sizes), the task of developing consumption and UAs can
be very difficult and time consuming.

Some PHAs may prefer to explore third-party options to assist in the
development or update their UAs when utilizing the engineering approach
due to the higher degree of building science knowledge that is required.

Third-party participants might include, but not be limited to: qualified
engineering firm; certified energy home rater; certified energy manager,
energy audit firms, and energy services companies (ESCOs), energy
services providers (ESPs), Home Energy Rating System Providers (HERS),
etc.

An important aspect of selecting a third-party is to follow \[24 CRF
85.36\] the PHA's written Procurement Policy procedures. Since the
procedures may require the preparation and distribution of a Request for
Proposal (RFP), a Request for Quotation (RFQ), or Quotation for Small
Purchase. Sample RFP and RFQ documents are provided in Appendix B.

![](media/image5.png){width="8.501388888888888in" height="11.0in"}

# **CHAPTER 2: Procedures to Establish Average Total Consumptions and Utility Allowances Using the Actual/ Historical Consumption-Based Methodology**

> **CHAPTER OVERVIEW: This chapter provides a step-by-step process to
> apply an Actual/Historical Method when developing consumption and
> utility allowances. Nine steps are provided to determine the average
> utility consumptions. After the average utility consumptions are
> developed they are applied to the utility rates and charges to
> calculate the new utility allowances as explained further in Chapter
> 4, Calculating Utility Allowances.**

**Allowable and Non-Allowable Utility Consumptions**

Before beginning the task of establishing utility consumption, the PHA
must understand the definitions of allowable and non-allowable utility
consumptions.

**[Allowable Utility Consumptions]{.underline}**

HUD has determined that only services that are essential for a "safe,
sanitary and healthful living environment" are allowable and that all of
the *allowed* uses are limited to those who are the legal occupants of
the dwelling. Providing housing for long-term visitors and/or doing
something that causes unreasonable consumption that will be reflected in
the calculation of consumption data (e.g. washing other people's
laundry, washing cars, filling swimming pools, etc.) is not allowable.
The PHA should provide consumption and utility allowances (UAs) for the
following utility end-use categories:

-   Space heating

-   Cooking

-   Hot Water heating

-   Water

-   Sewer

-   Trash/Garbage collection

-   Lights and approved appliances/equipment

    The following paragraphs provide a more detailed explanation of the
    above allowable utilities.

    ***Space Heating and Cooling***

Heating a dwelling to maintain interior temperatures of 68°F to 72°F
continues to be the standard of a healthy living environment. **Air
conditioning is not included in the utility allowance** **for Public
Housing residents** unless a HUD waiver is granted (e.g., designated
elderly developments in severe heat climates) \[HUD Regulations 24 CFR
965.505(e)\]. If the dwelling unit has central air conditioning the
resident should have the choice of not utilizing the air conditioning
system. Residents with PHA-provided master-metered utilities will be
surcharged for the use of air conditioning. Resident-paid utilities will
not include air conditioning in their UA. In either case, the PHA may
grant relief if a waiver is received from HUD for individual relief \[24
CFR 965.508\].

***Sanitation***

Water that is consumed for hot water heating, bathing, and electric
appliances used for laundry (clothes washer and/or dryer), cleaning
house, and cleaning dishes is allowed. Water and sewer charges, waste
and garbage removal (including recycling) are also allowable utility
costs.

***Health***

Electricity for appliances used for food preparation (stove, microwave,
toaster, mixer, etc.) and electricity for lighting and ventilating are
allowable utility costs. Gas, fuel oil, coal or wood used for cooking
are also allowable utility costs.

***Other Electric Appliances***

The other electric appliance category includes minor household
appliances or equipment used by residents. As examples of other
electric, regulations allow for a microwave, radios, televisions, and
computers as minor items of electric equipment. These items are
considered recreational and communications use of electricity and our
society's norm for the use of minor items of equipment has been
increasing rapidly. "The resident lease must state the utilities,
services and equipment that will be supplied by the PHA without any
additional cost, the utilities and appliances that will be paid or
directly supplied by the resident, and the utility allowance for
resident-paid or PHA-supplied utilities and appliances." (*HUD Public
Housing Occupancy Guidebook, June 2003*). It should be noted however,
that PHAs still retain the responsibility for determining the reasonable
amounts of utilities used by residents.

## [Non-Allowable Utility Consumptions]{.underline}

HUD has determined that air conditioning; telephone service, cable TV,
satellite TV subscription and internet services are all non-allowable
utility costs.

Additionally, some residents may have in their dwelling units an
additional refrigerator and a separate freezer appliance. These
appliances use additional electricity and the residents will not be
compensated for their use. For PHA-paid electric utilities, the PHA
should surcharge those residents with an additional electric
appliance(s) based on the average amount of kilowatt hours those
appliances are expected to use. For estimates of residential consumption
of electricity by end-use, see Appendix B or visit The Department of
Energy's (DOE) website at http://www.eia.doe.gov/emeu/recs/
recs2001/publicuse2001.html.

***Air Conditioning***

Air conditioning is a common example of a utility cost that is
non-allowable for Public Housing residential dwelling units. Air
conditioning can be supplied through a central system or a window
unit(s). The following paragraph discusses some options the PHA might
take to remove this non-allowable utility consumption.

To remove the air conditioning usage from the actual/historical data for
housing developments where only some of the dwelling units have window
air conditioning units, the PHA may simply want to delete from their
data those dwelling units with window air conditioners.

A PHA may want to compare the actual/historical consumption used during
the hottest summer months to those months just before and after
(shoulder months) those hottest months. The hottest summer months would
most likely include air conditioning usage. If the hottest months are
significantly higher than the shoulder months the PHA may want to remove
the hottest months and average the shoulder month's consumption to use
as the base electric consumption.

For those PHAs with central air conditioning installed in the entire
housing development or with window air conditioner installed in every
dwelling unit, the process of removing non-allowed air conditioning
consumptions is more difficult. An engineering calculation process is
needed. This process will be discussed in Chapter 3.

***Individual Relief***

Elderly, disabled or ill residents with additional equipment or
appliances that are necessary for their well-being do not necessarily
fall under the non-allowable consumption category. Residents with these
special needs can request relief, from the PHA, from surcharges for
excess consumption of PHA-provided utilities, or from payment of the
utility supplier billings in excess of the UAs for resident-paid
utilities (see Chapter 6 for more details on Individual Relief.)

## Developing Average Total Consumption Using the Actual/Historical-Based Consumption Method

This process involves the steps listed below. Each step is explained in
more detail in this chapter. These steps demonstrate how the overall
approach represents a **\"best practice\"** for establishing allowances
based on a history of resident's actual utility consumption records.

  --------- -------------------------------------------------------------
  ***Step   Obtain Information Release Forms from Residents
  1***      

  ***Step   Identify Timeframes for Consumption Data Collection
  2***      

  ***Step   Understand the Different Data Types and Collection of the
  3***      Data

  ***Step   Define Utility Allowance Categories
  4***      

  ***Step   Assess the Data Report Format and the Information Provided
  5***      

  ***Step   Sort the Data into Allowance Categories
  6***      

  ***Step   Determine the Sampling Needed
  7***      

  ***Step   Calculate Typical Consumption Averages
  8***      

  ***Step   Adjust Consumption Data Utilizing a Spreadsheet
  9***      

  ***Step   Convert Consumption Allowances into Utility Allowances
  10***     
  --------- -------------------------------------------------------------

Note that in the following steps "PHA" is used to refer to both the
housing agency and/or a designated staff member of the agency.

## Step 1. Obtain Information Release Forms from Residents

The purpose of this step is to develop a strategy and procedures to
obtain data from utility suppliers by first obtaining a proper release
of information form signed by each resident.

Residential utility use and cost information is considered private
information, and most utility suppliers (especially electric and natural
gas) will not release the information to a third-party without a signed
release form with account numbers from the resident head-of-household or
person named on the account. Some utility suppliers require the use of
their own authorized form for release of information. Sending letters to
residents or contacting residents door-to-door to get their release form
signed generally results in insufficient participation. A more effective
way to collect the release form is at the Lease signing or during
recertification process. As part of the Leasing process, the PHA can ask
residents to sign a *release of information form* as described above.
The PHA should contact the local utility suppliers to verify their
requirements for collection consumption information. (See Appendix B for
sample Resident Release of Information Form the PHA can modify and
utilize.)

An alternative method could be to make a single form (like a petition)
with all the dwelling units listed, and with all needed signatures and
account numbers listed. This may eliminate the need for a separate form
for each dwelling unit when sending the documents to the utility
supplier. Please check with local utility suppliers to determine if this
method is acceptable.

After the release forms have been collected the PHA should sort the
forms by development and then by bedroom size. The utility supplier will
generally provide the reports in the same order as the release forms;
therefore, this will help expedite the sorting process of the
consumption reports when they are received. Often PHAs will also send a
copy of a resident address list (sorted by development and bedroom size)
along with the request. This will also help the utility supplier
determine which reports to run. The PHA should prepare a request letter,
on PHA letterhead, to the utility suppliers. This letter should request
consumption history for the nearest 12-month period for each of the
accompanying signed Release of Information Forms.

## Step 2. Identify Timeframes for Consumption Data Collection

In this step the PHA identifies time periods for which the data will be
collected either from the utility suppliers or the PHA's meter reading
records.

Accurately calculating utility consumption amounts from actual utility
data depends upon using information gathered from a full 12 month cycle,
which includes all seasons. When requesting the historical data from the
utility suppliers or gathering check-metered utility readings, the most
recent 12-month period is preferable.

Where data is limited due to comprehensive modernization, a new housing
development, or other reasons, the PHA may include data from earlier
years or use an engineering-based method to determine the missing
information. (See Chapter 3)

**Step 3. Understand the Different Data Types and Collection of the
Data**

This step identifies the different data types needed to conduct a UA
study and gives helpful guidance in collecting data from each resource.
A brief description of each data type is provided below.

**[Utility Consumption Data]{.underline}**

Utility consumption data is one type of data a PHA must collect. Actual
consumption data for resident-paid utilities are provided in the form of
utility billing records from the utility supplier, while actual
consumption data for PHA-provided utilities is gathered from individual
utility meter readings. PHAs with individual check-metered utilities
should read the check-meters at regular intervals, preferably every
month, although some PHAs choose to read check-meters bi-monthly or
quarterly. Often check-meters are read by the utility suppliers and the
records are made available to the PHA.

If the PHA does have the utility consumption data readily available, it
must request that data from the local utility suppliers (see Step 1 for
guidance). Calculating accurate allowances requires access to utility
data for as many dwelling units as possible. Therefore, the goal of the
PHA should be to obtain consumption data for all the dwelling units in
an allowance category (housing development, housing project, or AMP).

Prior to the calculation of average consumption totals, the PHA should
review the utility supplier's metering method and ask the following
questions: What does the utility supplier do when it cannot read a
meter? Does the utility supplier use estimated readings? What is the
common unit of measuring consumption? How often does the utility
supplier read meters? What is the pattern of meter reading dates?
Answers to these questions will be critical in determining how the PHA
will calculate UAs for its housing developments.

The PHA must calculate average monthly consumption totals by bedroom
size and development (or AMP) from the collected utility consumption
data. Calculations must include each utility type (e.g., electricity,
natural gas, water, etc.) that is resident-paid or PHA-provided. The PHA
will use this calculated average consumption amount as the base on which
it will calculate the UAs using local utility supplier's current rates
and charges. These utility consumption bases will also serve and the
Consumption Allowances for check-metered utilities paid by the PHA.

### [Utility Rates and Charges Data]{.underline}

Residential utility rates and charges are utilized in the calculation of
UAs. Gathering utility rates and charges is not always an easy task.

The PHA must gather and document all residential utility rates and
charges currently in effect and those approved with future effective
dates within the next year, paying special attention to applicable
taxes. The process of gathering the applicable utility rates and charges
is discussed in more detail in Chapter 4: Calculating Utility
Allowances.

Additionally, the PHA should collect one actual billing record (sample
residential utility bill) for each utility supplier to use in the
verification of appropriate rates and the utility supplier's calculation
process. Many utility suppliers have complicated calculation methods, so
a cross-check with a sample residential utility bill is a good Quality
Control (QC) process. Other useful information to inquire about or
gather includes:

-   Does the utility supplier have a reduced rate schedule which is
    available to all low-income families?

-   Does the utility supplier provide the option of a uniform payment
    plan?

-   Is the selected utility supplier billing reasonable rates and
    charges, as compared to other local utility suppliers for the same
    fuel?

### [Housing Occupancy Data]{.underline}

The PHA will need to gather housing occupancy data in order to make
decisions regarding adjustments to the actual consumption data before
calculating accurate average consumption totals. The following items
should be obtained and the information should be sorted by housing
development (site, project or AMP) and by bedroom size:

-   Address list of all dwelling units;

-   Address list of Over-Housed and Under-Housed residents (sometimes
    contained in PHA's "transfer list");

-   Address list of vacant dwelling units.

    The collected lists will assist the PHA in removing the less than
    ideal sample consumption records due to higher or lower number of
    occupants in a dwelling unit and inadequate or incomplete billing
    data due to vacancies.

**[Air Conditioning Consumption Data]{.underline}**

As mentioned previously in Chapter 1, air conditioning (A/C) is a
non-allowable utility cost for Public Housing residential dwelling
units. Therefore, either the air conditioning consumption amount will
have to be removed from the total electric consumption amount (i.e., for
central air conditioning or window A/C units in all dwelling units) on
all PHA-furnished air conditioners. Some PHAs allow resident-furnished
window air conditioners. This can affect the validity of the sample and
cause an overstatement of utilities, especially if over 10 percent of
the dwelling units in the development have resident-furnished window air
conditioners. In this case, the PHA may remove consumption averages for
units with air conditioners from the sample. If the PHA removes these
from the sample, the PHA should document which dwelling units were
removed and why.

### [Optional: Climate Data]{.underline} 

The PHA has the option to adjust the averaged consumption totals to
account for future significant weather changes. If the averaged
consumption totals are adjusted for climatic changes, the PHA does not
have to perform an actual consumption study each year due to extreme
weather changes. This climatic adjustment uses the Heating Degree Day
(HDD) data (see Glossary) gathered from the National Oceanic and
Atmospheric Administration's (NOAA) National Climatic Data Center
website: www.ncdc.noaa.gov. This data is available by publication for
weather center locations throughout the United States. Most locations
have 30-year average HDD data as well as the current year average HDD
data. This is the best information to use for this adjustment.

## Step 4. Define Utility Allowance Categories

This step provides guidance in identifying which categories need to be
included to accurately calculate UAs.

There are many items to consider when categorizing UAs. Some methods of
defining categories are more complex and other more simplified. Either
method is acceptable. The more complex methods might include allowances
based on the location of the unit in the building (e.g., inside unit,
end unit, etc.) whereas the simplified method averages all units in the
building by bedroom size.

PHAs can categorize and calculate their allowances by grouping them as
follows:

-   First by PHA housing development (site, housing project or AMP). The
    units have the same weather conditions, and generally have similar
    appliances and use the same fuels;

-   Second by utility type provided (e.g., electric, natural gas, water,
    etc.);

-   Third by building/structure type (e.g. row house, detached house,
    etc.). These have similar energy usage; and

-   Fourth by each bedroom size (similar number of occupants).

    Separating utility data by these categories listed above will
    provide the residents with unique and more appropriate allowance.

    As indicated above, if a housing development has more than one
    building/structure, they should be grouped separately (See Appendix
    B for a listing of building/structure types and a common description
    of each).

**Step 5. Assess the Data Report Format and Information Provided**

This step assists the PHA in identifying how the data reports are
formatted (e.g., by dwelling unit or by month) and other important items
to look for, such as which column has the consumption data, what is the
measure for the utility reading, and does the report contain the most
recent 12-month period.

After the PHA has obtained the consumption history reports from the
utility supplier, copies of residential utility bills, or records of
meter readings, it should then review these documents to see what format
was used to provide this data. The format of the consumption report
documents can vary from one source to another. These reports can contain
much more information than is needed to develop UAs. It is important to
assess the information provided before sorting and calculating
consumptions. The two most common formats provided by the utility
supplier are: 1) a separate page report for each dwelling unit address
or 2) a multi-page report listing one particular month's readings for
all dwelling unit addresses, then the next month's reading for all
dwelling unit address, and so on. The easiest and fastest format to work
with is a separate page report for each housing unit address with the
complete 12-month history of consumption used listed in columns by the
appropriate billing date. This format also makes it easier to sort the
data by allowance categories. The other format can also be utilized, but
it is more challenging to use and may require creative steps to organize
and sort data. If the PHA is working with a copy of 12 monthly utility
bills from each resident, it may also want to utilize a spreadsheet to
organize (see Table 2-2 later in this Chapter for example) and sort the
data into an easier format for calculating average consumptions.

It is important to look for and understand the following items on the
reports or records before attempting to calculate the consumption
allowances:

-   which column provides the monthly consumption amounts needed to
    calculate consumption averages;

-   what is the utilities common unit of measuring the consumption
    amount provided? Electricity is simple since consumption is always
    in kilowatt hours (kWhs). Natural gas can be listed in terms, cfs or
    ccfs. Water can be listed in gallons, 1000 gallons, ccfs, etc.

-   which dates listed document the most recent 12-month period?

**Step 6. Sort the Data into Allowance Categories**

This step provides assistance in separating the data reports into the
allowance categories determined in Step 4, previously discussed, and
suggests what to do when problem data is observed during the sorting
process.

The PHA should now sort or group together the utility bills or billing
reports by hand according to the allowance category. The order of
sorting the allowance categories may be first by housing
development/site or AMP, second by utility type (e.g., electric, natural
gas, etc.), third by building type (e.g., row house/townhouse,
semi-detached/duplex, etc.) and fourth by bedroom (BR) sizes.

Sorting of consumption data, provided for all dwelling units by month,
is more difficult and the PHA may wish to enter the data into a
spreadsheet table to help organize (see Table 2-2 later in this Chapter
for example) and sort into allowances categories before calculating
average consumptions.

Table 1 (below) provides two examples of the allowance categories that
would be necessary for two different housing developments and the number
of separate utility calculations that will be necessary for each housing
development.

**Table 2-1:** **Allowance Categories for Two Developments** (for
illustration purposes only)

+-------------------------------------------+--------------------------+
| **XYZ Family Development**                | **ABC Elderly            |
|                                           | Development**            |
| **(6 UA calculations)**                   |                          |
|                                           | **(4 UA calculations)**  |
| **(Semi-Detached/Duplex)**                |                          |
|                                           | **(High Rise)**          |
+-------------------------------------------+--------------------------+
| 3-BR gas heating, gas cooking, gas water  | 2-BR all electric        |
| heating                                   | appliances               |
+-------------------------------------------+--------------------------+
| 4-BR gas heating, gas cooking, gas water  | 3-BR all electric        |
| heating                                   | appliances               |
+-------------------------------------------+--------------------------+
| 3-BR electric lights and appliances only  | Water                    |
+-------------------------------------------+--------------------------+
| 4-BR electric lights and appliances only  | Trash                    |
+-------------------------------------------+--------------------------+
| Water                                     |                          |
+-------------------------------------------+--------------------------+
| Trash                                     |                          |
+-------------------------------------------+--------------------------+

During the sorting process the PHA should flag (e.g., mark, tab,
separate, etc.) any particular report or record which indicates one or
more of the following problems with recorded data:

-   Less than 12-months history of recorded consumption data;

-   A "0" consumption amount or significantly low consumption amount for
    one or more months;

-   An excessively high consumption amount for one or more months.

Any of the problems listed above would serve as a good reason for
eliminating that particular dwelling unit's consumption history report
from the sample that will be used to calculate the average consumption
amount used for that allowance category.

**Step 7. Determine the Sampling Size Needed**

This step provides assistance in identifying and eliminating problem
data (like those tabbed in Step 6 during the sorting process), and how
to determine if the data sampling is adequate.

In order to accurately determine UAs, the sampling of residents' utility
bills or billing records should include the *complete* data for *all*
dwelling units for each UA category. This is not always possible due to
inaccurate, missing, or questionable data reports (i.e., containing
problematic data). To make sure that the sampling is consistent, the PHA
should eliminate those records or reports with problematic data before
calculating the average consumption totals.

The statistical validity (accurate representation) of the sample focuses
on determining whether the number of dwelling units in the sample will
provide an accurate calculation of consumption used by dwelling units in
that UA category. This is generally not a problem if there are a large
number of dwelling units in a particular UA category, but may be a
problem if the number of total dwelling units is small.

There are two basic reasons why a PHA might not be able to use the data
from *all* dwelling units for each UA category.

-   Data is inaccurate due to meter reading error, data entry error,
    missing data for one or more months, or questionable amount (e.g.,
    abnormally low or high).

-   The PHA does not have the resources to enter the data from all
    dwelling units into spreadsheet tables. This could be especially
    true for PHAs with a large number of dwelling units. This might not
    be an issue if data is imported into spreadsheet tables
    electronically, but may be an issue when all consumption data is
    input by hand.

    Eliminating dwelling units with problematic data ensures all data in
    the sampling is consistent but, by definition, also reduces the
    number of dwelling units used to calculate consumption and the UAs.
    The elimination process can take place during the sorting process
    (as mentioned earlier in Step 6) and/or after the data has been
    placed in a spreadsheet table (see Table 2-2 later in this Chapter
    for example).

### [Eliminating Problem Data from a Spreadsheet Table]{.underline}

The first, and easiest, approach is for the PHA to eliminate from the
spreadsheet table any dwelling units that have data problems or
questionable data. For example, the PHA may want to eliminate data on
any dwelling units that have estimated (rather than actual) readings
that have not been corrected by subsequent meter readings. This will
ensure that the consumption data for the period represents actual
consumption and is not an approximation of actual experience. The PHA
may also decide to eliminate data for all dwelling units that changed
hands in the middle of the year, underwent major renovation during the
year, or were vacant for more than one month during the year. A PHA that
decides to eliminate data may either eliminate the entire dwelling unit
from the analysis or eliminate only those months that have problem data.
(See Table 2-2 later in this Chapter for example)

**[Eliminating Data Due to Limited PHA Resources]{.underline}**

A large PHA that has, for example, 5,000 2-bedroom apartments will have
a labor intensive task to manually enter all dwelling units and their
respective consumption records for gas, electric, and water into
spreadsheet tables. Since the PHA has a large sampling, it could reduce
the amount of the study sampling by selecting a percentage of the
dwelling units to calculate the consumption averages.

To ensure an adequate sample the PHA should be sure that:

-   The dwelling units selected for inclusion are randomly selected in
    all bedroom sizes rather than selected for their characteristics. A
    PHA can select every 10^th^ dwelling unit, every 14^th^ dwelling
    unit, or every 20^th^ dwelling unit, etc.

-   Enough dwelling units are included in the sample for the PHA to
    think that the UA consumption calculated reflects overall
    consumption. A common practice is to make sure the sampling used
    meets the 95 percent confidence level with a +/-5 confidence
    interval. There are numerous resources available online that a PHA
    can use to calculate the minimum sample size a PHA should have if
    its wants to use a sample and meet these sampling criteria.

**Step 8. Calculate Typical Consumption Averages**

This step provides the PHA with examples of how to calculate the
consumption averages for each allowance category.

The next step is to determine typical consumption. Adding up all the
monthly consumption amounts (12 months worth), and then dividing the
total by the number of records (12) to determine the average consumption
for that utility category. Where averages are for periods other than
months, these averages should be converted to monthly amounts.

In the case of the individual consumption 12-month history report
provided by dwelling unit address, the PHA does not have to enter the
monthly consumption data into a spreadsheet to calculate the average
monthly consumption total for each address. The PHA can simply use a
calculator to add together the 12 monthly amounts and divide that total
amount by 12 (one full year). The total average monthly consumption for
that address can be neatly written right on the copied documentation.
The PHA would repeat this process until all calculations are complete
for each address in that category. When the PHA comes across a flagged
report it should be pulled out and not calculated into the average, but
places it in the back of the other reports for that allowance category.

For consumption data provided on monthly documents for all dwelling
units the PHA should create a simple spreadsheet table using Microsoft
Excel software or other comparable spreadsheet software. (See example
chart on next page.) The spreadsheet tables should include the data for
all like dwelling units. The data should be arranged in columns for ease
of calculating. The first column should contain the dwelling unit number
or address. Next there should be a separate column for each of the
twelve months. Following that there should be a column for the 12-month
totals and a column listing the number of months calculated. The last
column should be for the total averages. This format will assist the PHA
in sorting and calculating the consumption averages for each utility
category. The first row should contain the type of information in each
column (header row). The rows following the header row should list each
unit and its related consumptions. The final two rows should contain the
calculated total of each column with consumption figures and the total
average of each column with consumption figures. In cases where the
utility amounts are charged annually (e.g., propane, fuel oil, etc.) the
table will have a single column.

For check-metered utilities paid by the PHA, these consumption averages
serve as the Consumption Allowances for which the PHA will surcharge
residents who exceed these amounts (utilizing the utility rates charged
to the PHA by the utility supplier). See example below.

![](media/image6.wmf){width="6.179166666666666in"
height="2.1756944444444444in"}**Table 2-2:** **Sample Spreadsheet
Layout** (for illustration purposes only)

**1644 Main Street -- ABC Elderly Development -- 2 Bedroom Units**

**Step 9. Adjust Consumption Data Utilizing a Spreadsheet**

This step provides guidance on how to adjust the calculated average
consumption totals for future significant weather changes and therefore
reduce the annual recalculating of the consumption allowances. It will
also provide steps to eliminate the high-users and low-users, thus
providing the resulting "estimate of a reasonable consumption of
utilities used by an energy-conservative household", as required by HUD
regulations.

There are several reasons for adjusting the consumption data:

-   PHA does not have an adequate number of data reports for a
    particular bedroom size in an allowances category (e.g., electric,
    natural gas, etc.) at a housing development due to inaccurate,
    missing, or questionable data.

-   PHA does not want to calculate average consumptions each year
    therefore they choose to climatically adjust the consumptions.

-   To develop allowances based on an "energy-conservative household",
    as required by HUD regulations.

Adjusting data begins with reviewing the consumption data entered into
spreadsheet tables for each UA category.

**[Adjusting Problem Data]{.underline}**

There are basically two approaches for dealing with, or adjusting
problem data: (1) eliminating problem data and, (2) revising problem
data. It is always a good idea to include a record of any changes you
make in data along with the date such changes is made.

### *Eliminating Problem Data* 

A PHA that decides to eliminate data may either eliminate the entire
dwelling unit from a spreadsheet or eliminate only those months that
have problem data and divide the total by less months. When only partial
data is eliminated (e.g., for 3 consecutive months) for a dwelling unit,
it is important that the averages (or medians or modes) are also based
on this reduced data set (total number of months = 9). In this case the
average utility consumption for these three months is based on nine
months, rather than 12 months. Please note that if the three months are
in a high volume or low volume season (e.g., summer or winter) this
method may overstate or understate totals.

### *Revising Problem Data*

The second approach is to make changes in the data recorded in a
spreadsheet table. In most cases, "bad" data in a table is a function of
mistakes in data entry; but they may also be a function of errors in
meter reading, estimated readings, or any number of reasons.

Occupancy, maintenance, and modernization staff can provide valuable
insight into apparent patterns (e.g., when vacancies or modernization
has occurred). As the reasons for erratic consumption become evident,
the decision of whether to use the information "as is," delete it, or
modify it can be made with greater confidence. If there are many very
similar dwelling units in the allowance category, it is reasonable, and
quick, to delete erratic data. In many cases where limited data is
available, it may be wiser to make corrections and estimates. In either
case, understanding as much as possible about the data will improve a
PHA's confidence in its UAs.

Deciding which, if any, data elements are problematic; and then, which
data, if any, should be eliminated or revised, and finally what method
to use to revise problem data will be based on each PHA's own
experiences and data.

-   ***Option 1. Review source data and change incorrect data in
    spreadsheet***

> The PHA staff member responsible for utility allowance data should go
> back to the original source documents, check the consumption numbers
> that were entered in the spreadsheet table, and make the appropriate
> changes if there has been an error.

-   ***Option 2. Substitute averaged data for missing data***

> In some cases, it may be preferable to substitute average consumption
> for missing data or data that a PHA knows is incorrect, when the
> correct data cannot be located. The process for making this
> substitution is as follows:

● Calculate the average usage, for the month in question, for all
dwelling units.

● Substitute missing or incorrect data with the average for all dwelling
units.

### *Sporadic Readings*

Utility meter readings are ideally made at regular intervals, but they
are often made sporadically or at irregular intervals. The records from
these readings should not be used or should be adjusted to reflect
consistent time periods. This adjustment can often be accomplished by
dividing the reading by the number of days between readings to get
average use per day and multiplying that number by a standard number of
days.

### *Estimated Readings*

There are many reasons why a particular meter is not read: bad weather,
a busy schedule, a sick meter-reader, or a broken meter. In cases of
estimated readings, the PHA may decide to separate the data and then
delete this dwelling unit from the data (if the PHA has sufficient good
data) or draw a line that mimics normal use patterns. Estimated readings
are common and rarely ruin the validity of the analysis. Billing data
that were "estimated" can be highlighted on a spreadsheet.

**[Optional Adjusting for Climate Changes -- Heating Only]{.underline}**

An alternative to establishing consumption allowances based on a single
year database is to establish allowances based on one or more years\'
worth of consumption data that have been normalized for weather
conditions based on 30-year Heating Degree Day (HDD) averages. This
approach is only appropriate for utilities used for space heating. **If
allowances are based on normalized consumption data, the PHA does not
need to obtain new consumption data every year.** This approach may be
especially attractive for PHAs that have individually metered utilities.

### Normalizing the data requires the following information: 

-   ***One or more years' worth of consumption data.*** Data from at
    least one year (12 consecutive months) are required. If the PHA has
    not obtained actual consumption data in the last two years, then the
    PHA should obtain more recent data. If the PHA has been using a
    three-year rolling database, then this database may be used as well
    for this alternative approach. By doing so, the PHA can simplify
    what needs to be done annually as part of the review of allowances.

-   ***Total heating degree-days (HDD).*** This information must be
    obtained for the year or years from which the consumption data is
    taken. This information (HDD) may be obtained from the NOAA National
    Climatic Data Center or an area weather monitoring station. This
    data should be from the same source as the 30-year average
    degree-days used in this process (see below).

-   ***Thirty-year average annual heating degree-days (HDD).*** The
    30-year average annual degree-days should be from the same source as
    the degree-days for the year in which the consumption data is
    recorded.

-   ***Thirty-year average monthly heating degree-days (HDD).***
    Thirty-year average monthly degree-days are required only for
    check-metered utilities, or for individually metered utilities for
    which the PHA provides seasonally adjusted allowances.

Once the PHA gathers the Heating Degree Days (HDD) data for the current
year and 30-years, the next step is to determine a HDD factor to
calculate with the consumption average totals. To accomplish this, the
30-Year Average HDD should be divided by the Total Annual HDD amount.

*Example:* 30-year Average HDD = 7348 divided by 6386 Current Year
Average HDD = **1.15 HDD Factor**

The resulting factor will then be used to calculate a new adjusted
consumption average.

*Example:* Proposed Winter Consumption Average for 0-BR unit: (See chart
below)

752 kWhs times 1.15 HDD Factor = **865 Adjusted kWhs**

***Table 2-3: Normalizing Data with Heating Degree Day Factor** (for
illustration purposes only)*

  ----------------------- ------------- ---------- -- ---------- -- ------- -- ------- -- ------- -- ----------- ----
  **Check-Metered                                                                                                
  Electric Consumption                                                                                           
  Allowances**                                                                                                   

  **Actual Consumptions                                                                                          
  from Study**                                                                                                   

  (Normalized for 30-year                                                                                        
  average Heating Degree                                                                                         
  Days Factor: 1.15)                                                                                             

                                                                                                                 

  Development             Proposed                                                                               
                          Consumption                                                                            
                          Averages                                                                               

  **ABC Elderly           0 BR          1 BR          2 BR          3 BR       4 BR       5 BR       **Heating   
  Development**                                                                                      Degree**    

  Winter Average          **865**       **1268**      **1570**      ** **      ** **      ** **      **Days      
                                                                                                     Factor**    

  Summer Average          381           504           659                                 ** **      **1.15**    
  ----------------------- ------------- ---------- -- ---------- -- ------- -- ------- -- ------- -- ----------- ----

*Note: Bold figures have been adjusted (normalized) for climate
changes.*

**[Adjusting the Average Total Consumptions for High Users and Low
Users]{.underline}**

This step assists the PHA in removing those average consumption totals
that are higher or lower than normal usage. After the PHA has entered
into the spreadsheet tables all data from the utility records for each
allowance category the PHA must calculate the average (or mean) total
consumption levels. The first step is to utilize the "sort" function of
the spreadsheet and sort the data records from highest usage to lowest
usage. The next step is to remove the consumption averages for
approximately 10-15 percent of the high users, in order to meet the
regulatory requirements of "an estimate of a reasonable amount of
utilities consumed by an energy-conservative household", and 5-10
percent of the low users. These percentage amounts are commonly used.
The data records that are removed should be documented in another
section of the report listing the dwelling unit or addresses and the
consumption amounts. The final step is to calculate the average total
consumption by adding together the remaining consumption averages and
dividing by the number of records that were added together.

This is the final step for PHA's with check-metered utilities which are
PHA-paid. Now the PHA should prepare a chart for the **Consumption
Allowance Schedule**. This chart should show the monthly consumption
allowances separated by housing development (or AMP), bedroom size and
all applicable utilities (See example chart below). This consumption
allowance schedule will be used as the basis for which the PHA will
surcharge residents who exceed these amounts (utilizing the utility
rates charged to the PHA by the utility supplier). PHA Boards may adopt
a "grace factor" usually between 5% and 10% above this base schedule in
order not to penalize energy conservative residents during unusually
high usage months beyond their control (e.g., very cold weather). See
Chapter 6 for implementation.

***Table 2-4: Sample Consumption Allowance Schedule** (for illustration
purposes only)*

  --------------------------------------- --------- --------- --------- --------- ---------
  **LOW-RENT MONTHLY CONSUMPTION                                                  
  ALLOWANCE SCHEDULE**                                                            

  **for PHA-Furnished Check-Metered                                               
  Utilities**                                                                     

                                                                                  

  **High Rise - ABC Elderly Development** **0BR**   **1BR**   **2BR**   **3BR**   **4BR**

  Electricity (kWhs) Winter (Dec-Mar)     711       872       1083                 

  Electricity (kWhs) Summer (Apr-Nov)     691       852       1063                 

  Water (Gallons)                         2463      4013      5563                 
  --------------------------------------- --------- --------- --------- --------- ---------

  --------------------------------------- --------- --------- --------- --------- ---------
                                                                                  

  **Semi-Detached -- XYZ Family AMP**     **0BR**   **1BR**   **2BR**   **3BR**   **4BR**

  Electricity (kWhs)                                231       297       364        

  Natural Gas (therms) Winter (Dec-Mar)             35        52        59         

  Natural Gas (therms) Summer (Apr-Nov)             15        32        39         

  Water (Gallons)                                   4013      5563      7750       

                                                                                  
  --------------------------------------- --------- --------- --------- --------- ---------

**Check-Meter Consumption Allowances**

![](media/image7.wmf){width="1.117361111111111in"
height="1.0583333333333333in"}

***Utility Allowances Continue***

## Step 10. Convert Consumption Allowances into Utility Allowances  {#step-10.-convert-consumption-allowances-into-utility-allowances .Style-Heading-2}

After the average total consumption is calculated, the final step in
determining UAs for resident-paid utilities is to convert the
consumption levels calculated in the above steps into a monetary utility
cost or dollar allowance. In its simplest form, this means multiplying
the average consumption total (e.g. kWh) by the current residential
utility rates and charges (in dollars) provided by the utility supplier.
(See Chapter 5 for a more detailed discussion of Utility Rates and
Calculating UAs.)

Once the PHA has established UAs for each type of dwelling unit (e.g., 1
bedroom gas heated), for a specific building, all residents living in
similar dwelling units in that building will receive the same UA.

**[Estimating the Consumption Requirements for
Trash/Garbage]{.underline}**

Trash/garbage pickup is generally charged as a flat rate which sometimes
includes recycling. This rate should serve as the amount of the trash
collection dollar allowance. PHAs should schedule several times during
the year when residents may exceed the trash allowance to accommodate
greater disposal needs due to certain circumstances, such as residents
moving in or out, spring cleaning, and the holidays. PHAs are advised to
take measures to ensure that the trash services are used solely by the
public housing community.

**[Utility Allowance Schedule]{.underline}**

Finally, the PHA should prepare a **Utility Allowance Schedule** showing
the individual monthly UAs for each utility type and the total monthly
UA amount (including all applicable utilities) for each bedroom size at
each applicable housing development. See example of Utility Allowance
Schedule in Chapter 4.

It is important to note here that the HUD regulations 24 CFR 965,
Subpart E Resident Allowances for Utilities the PHA is required to
retain all support documentation used in the development or updating of
UAs.

![](media/image8.png){width="8.501388888888888in" height="11.0in"}

# **CHAPTER 3: Establishing Utility Allowances Using the Engineering-Based Methodology**

> **CHAPTER OVERVIEW: This chapter provides a description of the
> engineering approach to developing utility allowances so the PHA is
> aware of what is involved in this process. As this method can be
> highly technical, it is not necessarily meant to be a "how-to"
> chapter. To assist the PHA, utility measurement conversion charts have
> been included at the end of the chapter and a resource website has
> been provided in the text.**

The engineering-based method uses engineering assumptions created from
utility consumption benchmarks, weather patterns and modeling. It
emphasizes the physical science of utility consumption using building
performance, end-use profile behaviors, and performance factors.
Detailed information on buildings and their equipment is required.
Beginning with utility data gathered from historic studies of buildings
with similar construction types, thermal or equipment efficiencies, and
in varying geographical or climatic locations, software modeling tools
are created which simulate the buildings consumption patterns over a
period of time. The increased knowledge specificity, and accuracy
required in an engineering-based method can result in what appears to be
a time-consuming and more complicated process. While untrained (or
minimally trained) PHA staff could use engineering tools to calculate
utility allowances (UAs), third-parties such as engineers, certified
energy raters, energy managers, energy auditors, and energy service
companies (ESCOs), energy service providers (ESP), and home energy
rating system (HERS) providers are generally contracted to conduct these
calculations and studies.

The actual/historical consumption-based method and the engineering-based
method ideally should rely on each other to ensure accuracy and
precision. By comparing the average engineered consumption to
actual/historical consumption data, the PHA will be able to make a
better judgment about whether a range above the average is appropriate
in setting the standard for an energy-conservative household, and how
large that range should be. Engineering-based allowances should include
utility bill comparisons as a means of crossing-checking the resulting
consumptions and to insure reasonable allowance levels.

## Various Utility Estimates

### [Base Loads]{.underline}

Base load is the term given to the sum of all allowable utility
consumptions. The space heating and air conditioning consumptions vary
significantly with the seasons. Other uses vary based on the number of
occupants and their lifestyle. Because lifestyle patterns of families
with a similar number of occupants are usually the same over several
months of time, the consumptions are fairly uniform. Princeton
University used this knowledge as the core in developing its' PRISM®
normalization software. The premise of individuals being very consistent
in their daily and seasonal usage patterns allows for a relatively
accurate assumption to be made of the building. Consumption for each of
these can be estimated if the equipment's estimated time in use and fuel
efficiency characteristics is known.

### [Space Heating Estimates]{.underline}

In Public Housing, space heating is generally provided by electricity,
natural gas, propane or fuel oil. Electricity and natural gas are the
most common. The space heating requirements of a dwelling unit depend on
various factors including dwelling unit size, arrangement within the
building, the design/construction of the housing development, the
physical condition (maintenance) of the housing development, the local
climate, the energy efficiency of the heating system, and the indoor
temperature set points.

Heat loss is the rate of heat transfer, per hour from an occupied space
to the outdoors. Loss occurs through walls, ceilings, floors, windows
and doors of a structure.

Methods for calculating heat loss are available from engineering texts
and societies, including the American Society of Heating, Refrigeration,
and Air Conditioning Engineers (ASHRAE). They include the following:

-   Heating degree day methods

-   Monthly temperature Bin methods

-   Hourly temperature models

There are numerous software programs that use these methods, most
commonly used is the DOE-2 simulation engine created by Lawrence Berkley
Laboratories for the United States Department of Energy (DOE). Other
tools include REM/Rate, Energy Gauge (both require user licensing), and
the web-based Home Energy Saver created jointly by the Environmental
Protection Agency (EPA) and DOE. These tools use information about the
physical condition and design of buildings to estimate performance.
These require information such as infiltration (air leakage), duct
leakage, and equipment efficiencies, which are not usually known
precisely for individual buildings without performance testing. As a
result, the engineering estimates should be compared to actual utility
data in order to adjust for discretionary variables. In some cases,
professional consultation may be required.

Once the PHA has selected a tool and has gathered the other necessary
information, it can calculate the annual energy requirement for space
heating.

Monthly requirements should not be determined by simply dividing the
annual consumption requirement by 12 months. Many utilities rates vary
seasonally (e.g., winter versus summer). Energy requirements for space
heating, for example, are concentrated in the winter months and are
generally non-existent in the summer months. To compute the appropriate
consumption for each month, add the heating load to the base load
consumption to each month, and then compute the UA for each month of the
year. The average of these monthly estimated costs is used in the
process of setting a uniform monthly UA.

**[Air Conditioning Estimates]{.underline}**

Air conditioning (A/C) can be determined from actual isolated or metered
consumption data or through engineering estimates when actual
consumption data is unknown. Air conditioning is made available through
window units and central systems. The monthly consumption of electricity
required for air conditioning depends on outside temperature, window
orientation (west versus north facing), shading type (multi-pan/low
emissive), and A/C equipment configuration and efficiency.

Using actual data, the PHA would determine electricity consumption for
summer months and compare that consumption to the base load period. For
households not heated electrically, the base load period would be winter
months. For households using electric heating, the base load period
would be the swing months between winter and summer.

Air conditioning calculations are largely dependent on solar incidence
and building orientation. These calculations are automated in many
commercial off-the-shelf software programs. To get the best results,
software should use monthly Bin or hourly simulation techniques. For
window air conditioners, an approximation can sometimes be made. Window
units only cool a portion of the dwelling and often do not have
temperature controls. As a result they run until the occupant turns them
off. A simplification can be made by assuming hours of use per day and
the power draw (wattage) for a typical window unit, usually found on a
nameplate located on the unit itself. The PHA should conduct a survey of
air conditioners in use and determine the nameplate efficiency and power
draw or make an estimate of the power used. The total allowance is the
hours of use multiplied by the power draw (wattage) of the equipment.

It is beneficial to keep in mind that air conditioning consumption
varies with climate, equipment, building design, and specialty
consumption requirements (e.g., medical condition or elderly). Accurate
air conditioning consumptions cannot be calculated without knowing
site-specific information.

### [Domestic Hot Water Heating Estimates]{.underline}

Domestic hot water can be heated using electricity, natural gas,
propane, fuel oil, or solar energy. The monthly energy requirement for
domestic hot water heating is the energy required to heat a volume of
water to a specified discharge or tank temperature (usually 130°F). The
energy use required to heat the water depends on the fuel type, inlet
water temperature, amount of water consumed, and the efficiency (energy
factor/EF) of the hot water system. The system efficiency depends on
whether the equipment is a direct tank-type, indirect tank storage water
heater, or a direct fired tank-less water heater.

The temperature rise is the difference between the cold-water inlet
temperature and the hot water outlet temperature. The cold-water
temperature depends on the geographical location; it tends to vary
seasonally, which can be between 35°F and 99°F. The hot water
temperature at the tap may range from 100°F to 140°F. The suggested
temperature for hot water at the tap is 120°F. Most water utility
suppliers can provide the average temperature of the water in their
service area or can be measured at a faucet nearest the water system
entry point to the home.

The number of gallons of hot water per-unit per-month depends on the
number of people per dwelling unit and if the dwelling unit has
water-saving devices such as low-flow showerheads (2.0 GPM or less) or
faucet aerators (.50 GPM). In addition, the presence of certain
water-using appliances (e.g., dish washers, clothes washing machines,
etc.) can drastically affect hot water requirements. On average, a
person requires roughly 20 gallons of hot water per day (e.g., 140
gallons per week); actual hot water consumption may vary widely
depending on the age and lifestyle of the residents. If the dwelling
units are not equipped with water-saving devices, or there are hot water
leaks in some of the dwelling units, hot water requirements may be
higher.

The efficiency of the hot water heating system depends on the fuel type,
and on the age, maintenance, and type of the system. Electric water
heaters with storage tanks can have an efficiency of up to 97%, and the
efficiency of gas water heaters with storage tanks can be in the range
of 50 to 65%. Newer water heaters tend to have higher efficiency ratings
due to increased levels of tank insulation. Where the water heating
system has a lengthy distribution system or a separate storage tank, the
system efficiency is lower than that of the water heater itself because
of storage and distribution heat losses and increased water usage (e.g.,
clearing line of cold water). This can be reduced by insulating exposed
lines. Water at the tap is cooler than water at the hot water heater. In
such cases, a qualified individual should estimate the efficiency of the
system.

The temperature of the water and fuel type is inserted into the formula
resulting in the required amount of Btus (British thermal units) in
order to maintain water temperature. The Btus are then converted into
other units of measure, such as therms for gas, kWh for electricity, and
hundred cubic feet (ccf) for water.

### [Estimating the Energy Consumption Requirements for Laundry]{.underline}

Where clothes washer and/or clothes dryer hook-ups are provided by the
PHA, an allowance may be provided for the energy used by those
appliances. The electricity consumption requirement of a clothes washer
depends on the wattage of the clothes washer, the number of loads per
dwelling unit per month, and the length of an average wash cycle. The
energy (gas or electricity) consumption requirements of a clothes dryer
depends on the wattage or gas consumption of the dryer, the number of
loads per dwelling unit per month, and the length of an average drying
time. Manufacturer data and performance estimates are available on the
world-wide web and in the information provided in the owners manuals for
laundry equipment. These figures can be adjusted to reflect actual
conditions, or more importantly, when a PHA has to seek redress when
laundry equipment fails to perform at a manufacturer's specifications
and/or standards of performance.

If laundry is deemed an allowable end-use, 140 gallons per person per
week may not be sufficient to cover hot water consumption. A
conventional washer uses about 25-35 gallons per load. If a household
washes one load of hot-water laundry (or two loads of warm-water
laundry) per-person per-week, then the hot water requirement increases
to 165 gallons at a minimum per-person per-week (140+25=165)). Using
hot-water cycles for laundry, uses about twice as much hot water as
warm-water cycles, especially for the rinse cycle. If a household washes
one load of warm-water laundry per-person per-week, then the hot water
requirement increases to 155 gallons per-person per-week (140 + 15 =
155). If a household washes two loads of warm-water laundry per-person
per-week, then the hot water requirement increases to 170 gallons
per-person per-week (140 + 15+ 15 = 170), etc.

### [Estimating the Consumption Requirements without Water]{.underline} 

Miscellaneous base load uses include cooking, lighting, refrigeration,
and *plug loads* (all electrical use except space heat, air
conditioning, and water heating). Refrigeration and cooking are
sometimes added to this list of exclusions using actual data, these
loads are generally consistent month-to-month.

### [Cooking and Lighting]{.underline}

Cooking and lighting requirements depend on household size and are
captured when data are segmented by bedroom.

### [Refrigerators]{.underline}

Refrigerators are used year-round and are dependent on their size. Most
PHAs use a consistent refrigerator size for all dwelling units
regardless of bedrooms, except that five- or six-bedroom households may
receive larger models.

If engineering estimates are required, the loads are considered
separately. Refrigerator use depends on equipment age and condition
(maintenance). The consumption can be obtained from manufacturer data
for the equipment as provided on the yellow Energy Guide (see example
below). These can be downloaded from the manufactures website in most
cases.

![](media/image9.png){width="1.6125in" height="2.189583333333333in"}

Cooking and plug load estimates are available through the U.S.
Department of Energy's Residential Energy Consumption Survey 2001 (RECS)
these are available at
http://www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html. Estimating
the hours of use for each fixture location and multiplying the use by
the fixture wattage determines lighting consumption. A 60-watt
incandescent lamp, for example, uses 60 watts; a 2-lamp, 4-foot, T12
linear fluorescent fixture uses the combined wattage of its lamps and
ballasts, or 96 watts.

**[Water]{.underline}**

The level of water consumption that is reasonable depends on the number
of occupants in a dwelling unit and on whether the dwelling unit has
low-volume toilets (1.5 gallons per flush or less), faucet aerators (.5
gallons per minute (GPM) or less), and low-flow showerheads (2.0 gallons
per minute (GPM) or less). For dwelling units where these water-saving
measures have been installed, 20 gallons per-person per-day can
generally be considered a reasonable amount. (This amount is consistent
with literature from several utilities. The 20 gallons includes water
used for laundry.) If water-saving measures are not in place, the
allowable amount should be higher. The per-person per-day amount should
be multiplied by the number of legal occupants in the dwelling unit and
by 31 days to get a per-unit per-month figure. As an example, four
occupants x per-person amount x 31 days would equal per-unit per-month.
Outdoor watering by residents will need to taken into account as this
will result in increased consumption.

Water utility suppliers typically charge for usage per hundred cubic
feet (ccf) or per thousand gallons. The PHA may need to convert the
consumption amount estimated in this step from thousand gallons to ccf
(or visa versa) before calculating the UAs. (See the following
conversion tables)

**Conversion Charts**

  ---------------------- --- ----------------- --- -------------------------
  **Water Conversion                               
  Table 3.1**                                      

  1 gallon of water      =   8.34 lbs          =   0.134 cubic feet

                                                    

  1 cubic foot (CF)      =   7.48 gallons      =   62.4 lbs of water

                                                    

  100 Cubic feet (CCF)   =   748 gallons       =   46,675.2 lbs of water

                                                    

  1 cubic foot per       =   7.48 gallons      =   448.800 gallons per
  second (CFS)                                     minute (gpm)

                                                    

  1 cfs for 24 hrs       =   646,317 gallons        

                                                    

  1 cfs for 30 days      =   235,889,280            
                             gallons               

                                                    

  1 million gallons      =   133,689.8 cubic        
                             feet                  
  ---------------------- --- ----------------- --- -------------------------

  ----------------- -----------------------------------------------------------
  **Fuel Energy     
  Content &         
  Conversion Table  
  3.2**             

  **1 Therm any     
  Fuel = 100,000    
  BTU**             

  The exact values  
  will vary         
  depending on the  
  quality of the    
  fuel and in some  
  cases the         
  pressure.         

  **Electricity**   1 kWH electricity = 3,413 BTU

  **Natural Gas**   1 cubic foot = 1,050 BTU

  **Propane**       1 gallon = 91,500 BTU

                    1 cubic foot = 2,500 BTU

                    1 pound = 21,500 BTU

                    4.24 lbs = 1 gallon

                    36.39 cubic feet = 1 gallon

  **Fuel Oils**     1 gallon kerosene = 135,000 BTU

                    1 gallon #2 oil = 138,500 BTU

  **Other Fuels     1 lb wood = 7,870 BTU
  (dry)**           

                    1 lb coal (subituminous) = 8,800 BTU

                    1 lb coal (bituminous) = 11,500 BTU

                    1 lb coal (anthracite) = 12,700 BTU
  ----------------- -----------------------------------------------------------

  ----------------- --- --------------------- --- ---------------------------
  **KBtu Conversion                               
  Table 3.3**                                     

  The below table                                 
  provides the                                    
  multiplier to                                   
  convert a unit of                               
  measure **to                                    
  kBtu:**                                         

  1\. Locate the                                  
  energy source and                               
  the applicable                                  
  unit of measure.                                

  2\. Select the                                   
  conversion                                      
  multiplier from                                 
  the right column.                               

  3\. Multiply                                    
  non-kBtu units of                               
  energy by                                       
  multiplier and                                  
  this converts the                               
  energy unit to                                  
  kBtu equivalent.                                

  .                                                

  **Energy Source**     **Unit of Measure**       **Multiplier**

  **Electricity**       kWh (thousand             3.412
                        Watt-hours)               

  ** **                 MWh (million              3412
                        Watt-hours)               

  ** **                 MBtu (million Btu)        1000

  **Natural Gas**       MBtu (million Btu)        1000

  ** **                 ccf (hundred cubic        100
                        feet)                     

  ** **                 therms                    100

  ** **                 kcf (thousand cubic       1123.9
                        feet)                     

  ** **                 cf (cubic feet)           1.1239

  ** **                 MCF (million cubic        1123900
                        feet)                     

  **Propane**           MBtu (million Btu)        1000

  ** **                 kcf (thousand cubic       1000.06
                        feet)                     

  ** **                 Gallons                   90.0054

  ** **                 cf (cubic feet)           1.0336235

  **Fuel Oil (No.       kBtu/Sq. Ft.              1
  1)**                                            

  ** **                 MBtu (million Btu)        1000

  ** **                 Gallons                   134.9999811

  **Fuel Oil (No.       MBtu (million Btu)        1000
  2)**                                            

                        Gallons                   139.99998
  ----------------- --- --------------------- --- ---------------------------

**Report**

Insert results of engineering method study into similar schedules and
charts illustrated in Chapters 2 and 4. Maintain documentation on
rationale, software, assumptions, rates and charges, building
characteristics, adjustments and other data utilized in developing total
consumptions and UAs (explained in detail in subsequent chapters).

**Energy Efficient Utility Allowances**

An increasing number of PHAs are developing Energy Efficient Utility
Allowances for housing developments that meet above energy code
standards (e.g., ENERGY STAR® labeled homes). Many tax credit and mixed
finance developments are being built to these above code specifications.
Developers for tax credit properties and mixed finance developments are
increasingly using PHA-approved Section 8 Energy Efficient Utility
Allowance schedules to do financial projections and feasibilities of
development. This also gives the PHA an opportunity to develop an Energy
Efficient Public Housing Utility Allowance schedule for these above code
built or retrofitted dwelling units.

The Energy Efficient Utility Allowances should be determined by
utilizing ENERGY STAR® Home Rating standards. This will require the PHA
to contract with an accredited ENERGY STAR® provider or rater to conduct
a Home Energy Rating including performance testing. The rating will
determine if the dwelling units meet the above code standards and will
also provide support data, engineering calculations, utility usage and
an annual utility cost which the PHA may convert to monthly Energy
Efficient Utility Allowances. We encourage PHAs who have incorporated
above code modernization or new construction programs to have dwelling
units rated in order to provide Energy Efficient Utility Allowances.

![](media/image10.png){width="8.501388888888888in" height="11.0in"}

**CHAPTER 4: Calculating Utility Allowances**

> **CHAPTER OVERVIEW: Now that the consumptions are calculated using
> either of the methods in Chapter 2 or Chapter 3, this chapter provides
> instruction to apply utility rates and charges to the average
> consumption data, to develop the actual Utility Allowance Schedule.
> *[PHAs performing the Annual Utility Allowance (UA) Update and not a
> new UA Consumption Study, can by-pass the steps in Chapters 2 and 3,
> and start at this chapter.]{.underline}***

**Utility Rates and Charges**

A multitude of utility and supply rate systems exist across the country.
Rates can vary by season (e.g., summer, winter), fuel type (e.g.,
natural gas, electricity), location (e.g., city, county), tariff, and
meter type/size. Utility suppliers and their respective rate structures
are major factors in the development of utility allowances (UAs). The UA
schedules established by PHAs are based on existing residential rates
and charges billed to the residents. The utility rate calculation
includes fixed and volumetric charges. If there are state taxes these
would be part of the calculation. For surcharge calculations for
PHA-provided utilities, most PHAs are exempt from state taxes. Allowance
calculations require the use of a variety of utility rates and charges,
and establishing and implementing the correct rates.

**[Deregulation of Utilities]{.underline}**

In many states the electric and natural gas suppliers are deregulated
causing PHAs to deal with multiple utility suppliers. Additionally,
larger states such as Texas, California, Arizona, and Illinois have a
large number of PHAs with jurisdictions covering multiple cities/towns,
counties, metropolitan areas, and regional areas. This often results in
multiple utility suppliers servicing a jurisdiction. Dealing with
multiple utility suppliers can be difficult. They often have their own
privacy rules and methods of calculating costs.

Currently, HUD regulations do not address deregulated utilities. PHAs
who have this dilemma with multiple electric and/or natural gas
suppliers are dealing with this issue by utilizing one of the following
methods:

-   Utilize the rates from a local utility supplier with the best
    (consistently lowest) rates;

-   Utilize the rates from a local utility supplier with the higher
    rates;

-   Utilize the utility supplier which the majority of their residents
    are customers;

-   Utilize the rates from two or three utility suppliers, calculate the
    utility costs, then average the costs together for one amount;

-   Calculate separate utility costs for each local utility supplier.

A PHA should choose the method that best fits their situation and that
provides a satisfactory confidence level. Additionally, a PHA should
check with neighboring PHAs to see which method they are currently
utilizing.

**[Metering Systems]{.underline}**

The utility industry computes rates by utilizing one of three accepted
metering systems. They are:

-   **Master-meter**: A master-meter is a single meter that records
    consumption for an entire building and the PHA pays the utility
    costs to the utility supplier. Residents living in buildings with a
    single master-meter do not receive UAs and are not surcharged for
    over usage.

-   **Check-meter**: Some PHAs install separate sub-meters (commonly
    called check-meters) in addition to the master-meter to measure
    consumption by individual dwelling units. As with master-metered
    utilities, the PHA pays the utility cost directly to the utility
    supplier. With check-metered utilities the PHA provides each
    residential dwelling unit a reasonable ***consumption allowance***
    that it may consume. When the reasonable level of consumption is
    exceeded, the resident is charged a surcharge based on the PHAs
    billing rates.

-   **Individual meter**: Each residential dwelling unit has its own
    individual meter. Residents living in these dwelling units have
    separate accounts with the utility supplier, are sent bills from the
    utility supplier, and pay their utility bills directly to the
    utility supplier. The PHA provides a ***utility allowance*** to
    residents that have individual meters and this amount is usually
    subtracted from their rent or the total tenant payment.

**Rate Structures**

The PHA's UAs are developed using the current basic residential rates
billed to the residents. If a utility supplier's new rate is only under
review or proposed, this rate should not be used to calculate UAs. If
the rate is approved but not implemented, the transition date should be
noted, and UAs computed for both the current rate and the future rate.
In the case of surcharges, the cost of the utility is computed by the
utility rate charged to the PHA. The PHA's utility billing rates are
usually not the same residential rates charged to the residents. The PHA
may be charged a commercial rate or special rate. There are several rate
types that go along with the metering and supply of utilities.

-   ***Service Flat Fee/Charge (fixed)**:* Fixed monthly service charges
    are not based on consumption usage. Some utility suppliers have a
    per day fixed charge (multiply per day rate by 31 days to get
    monthly charge). Example labels for this type of fee/charge are:
    *Customer Charge, Basic Service Charge, Facilities Charge, Monthly
    Minimum Charge, Ready-to-Serve, etc.*

-   ***Monthly Fee/Charge (fixed):*** This is a fixed monthly service
    charge that is not based on consumption usage. A monthly fixed
    charge is a standard for some utility types such as trash or garbage
    collection. Some water and sewer suppliers charge only a monthly
    charge not based on usage. These costs are added directly into the
    dollar utility allowance. Additional example labels for these
    monthly charges are: *Drainage Charge, Fire Fee, Extermination Fee,
    Recycling Fee, etc.*

-   ***Monthly Minimum Charge:*** This is a fixed monthly minimum charge
    that includes consumption usage and serves as the first level/tier
    of the consumption range. Example labels for this type charge are:
    *Monthly Minimum Charge, Minimum Service Charge, Minimum Monthly
    Rate/Charge, etc.*

-   ***Base Energy Rate (per usage):*** These are rates based on
    consumption usage and are the most common system for metered
    utilities. Some utility suppliers have multi-levels with different
    rates and/or different consumption ranges per level. Utility
    suppliers may also have different base rates for winter and summer
    seasons. Example labels for this type of rate are: *Energy Charge,
    Commodity Charge, Residential Rate, Base Rate, Delivery Charge,
    Supply Charge, Baseline Quantities, Excess of Baseline, Transmission
    Rate, Distribution Rate, etc.*

-   ***Cost of Fuel Charge (per usage):*** This rate is a pass-on rate
    factor based on the utility supplier's cost of fuel. This rate can
    vary monthly, quarterly or yearly. Since this factor can vary
    greatly during a 12-month period due to the cost of fuel, it is best
    to obtain a history of the factor for the most recent 6-12 months
    and calculate an average. Example labels for this type of rate are:
    *Cost of Gas, Gas Cost Adjustment (GCA), Gas Cost Factor, Purchased
    Gas Cost Adjustment, Purchased Gas Adjustment (PGA), Purchased Gas
    Cost Recovery (PGCR), Fuel Factor, etc.*

-   ***Fees and Surcharges*:** Many utility suppliers now charge
    additional fees and surcharges that change from time to time. The
    fee or surcharge may be calculated by consumption usage or for a
    percentage of the total cost. These charges may also have a maximum
    cost. Example labels for surcharges based on consumption are:
    *Franchise Fee/Charge, Generation Service Fee/Charge, Renewable
    Energy Charge, Competitive Transition Assessment, Securitization
    Bond/Tax, Nuclear Decommissioning Charge, State Gross Receipts Tax,
    Environmental Surcharge, etc.* Example labels for surcharges based
    on percentage of cost are: *Franchise Tax, Generation Tax; State
    Regulatory Tax, Gross Receipts Tax, State Tax Adjustment, Utility
    Tax, Revenue Tax, etc.*

-   ***Bulk purchased utilities:*** This involves large quantities of
    fuel delivered with long intervals between deliveries. They are
    typically delivered and stored at the dwelling unit. Fuel oil, coal,
    and cordwood are examples. Bulk purchased utilities have a unit cost
    just as metered utilities do. They have similarities to all of the
    metering methods. Since these rates can vary greatly during a
    12-month period due to the cost of fuel, it is best to obtain a
    history of the factor for the most recent 6-12 months and calculate
    an average rate.

-   ***Taxes (% of cost):*** Taxes may apply to any of the above rates
    or charges. This is a factor calculated on the total monthly cost or
    a percentage of the cost: Example labels are: *City Tax, County Tax,
    State Tax, Municipal Utility Tax, Public Utility Tax, Excise Tax,
    State Occupancy Tax, Legislation Reduction, Base Rate Reduction,
    Municipal Charge, etc.*

The PHA should prepare a separate document listing the each applicable
utility company's name, phone number and current utility rates and
charges that will be used in the calculating of UAs.

There are generally three billing methods used by utility suppliers:

-   Monthly

-   Bi-Monthly

-   Quarterly

Keep in mind that UAs are provided on a monthly basis, therefore if the
utility supplier has bi-monthly or quarterly fixed charges, these
charges will need to be converted to monthly charges.

**Verify Calculations with Sample Utility Bills**

Because of the details of many utility supplier's rate formulas or rate
systems (how they calculate costs) and possibly unfamiliar language used
in the utility industry, sample computations based on actual residential
bills should be used to ensure the correct mathematical formula is being
used. Additionally, the sample utility bill can be used to verify that
all applicable rates and charges have been included in the cost
calculation. These sample utility bills serve as a great quality control
(QC) tool.

**Calculating Utility Allowances**

**[Totaling Component Consumption Amounts for Each
Utility]{.underline}**

Once the monthly consumption requirements of various end-uses (e.g.
space heating, hot water heating, cooking, lighting) have been
determined for each allowance category, the next step is to establish a
total consumption allowance for each utility (e.g. gas and electricity)
within each allowance category. This is done by adding together the
end-use consumption amounts for that utility. For example, if space
heating, hot water heating and cooking are all fueled by natural gas,
then the consumption amounts for space heating, hot water heating and
cooking should be added together to obtain a total natural gas
consumption allowance. For PHA-provided utilities these consumption
totals become the Consumption Allowances which are the basis for which
the PHA will surcharge residents for excess usage.

Next the total monthly consumption allowances should converted into a
dollar amount or utility allowance.

***Electricity**.* Consumption amounts of electricity are measured in
kilowatt hours (kWhs). The kWh amounts are converted to dollar amounts
by multiplying the consumption totals with the residential utility rates
and charges levied by the electric utility supplier. Some electric
utility suppliers charge one rate for consumption up to a certain level
and another rate for consumption beyond this level (tiered rate
structure). If the electric utility supplier has seasonal rates, the PHA
should multiply the seasonal consumption amounts by the appropriate
seasonal rate. For example, if the utility has one rate for September
through May, and another rate for June through August, then the
consumption amounts in June, July, and August should be multiplied by
the summer rate, and the consumption amounts in the other months should
be multiplied by the off-season rate. Additionally, fixed fees and other
fees should be prorated on a monthly basis and added to the allowance.

***Natural Gas.*** Consumption amounts for natural gas are usually
measured in therms, cubic feet (cf), hundred cubic feet (ccf) or
thousand cubic feet (mcf). The consumption totals for natural gas are
converted to dollar amounts by multiplying them by the rate per therm,
cf, ccf, or mcf and adding any other charges levied by the utility
supplier. As with electricity, if the natural gas supplier has seasonal
rates, these rates should be used accordingly. *Note: 1 therm is equal
to 1 ccf or 100 cf or .1 mcf*. Be sure your consumption totals used the
same unit measurements (e.g., therms, ccf, etc.) as the rate measurement
(e.g., therms, ccf, etc.)

***Propane or Fuel Oil**.* Consumption amounts for propane and fuel oil
are measured in gallons. The rate per gallon of propane or fuel oil
varies from day-to-day based on the cost of fuel at that time.
Therefore, since the UAs will be in effect for at least one year, it is
best to utilize an average rate from the utility supplier. The
consumption totals for propane or fuel oil are converted to dollar
amounts by multiplying the consumption totals by the average price per
gallon of propane or fuel oil.

***Water**.* Consumption amounts for water are usually measured in ccf
or 1000 gallons. The consumption amounts for water are converted to
dollar amounts by multiplying them by the rate per ccf or 1000 gallons.
Where water is individually metered and a monthly flat fee is charged,
this amount should be added to the total dollar utility allowance.

***Sewer/Wastewater**.* In most areas, there is an additional charge for
sewer service and/or this service is provided by a different company
than the water supplier. In some cases the sewer charge is a flat
monthly charge not dependent on water usage. Like water service,
consumption amounts for sewer are usually measured in ccf or 1000
gallons. If the sewer company charges a usage rate, then this charge
should be multiplied by the ccf or 1000 gallons of water used. In some
cases the sewer cost is multiplied by a percentage of the water used or
on the average water used in the winter months (December, January and
February).

**Individually Metered Utilities: Establishing Equal Monthly
Allowances**

PHAs with individually metered utilities generally provide equal monthly
UAs to their residents. The monthly UAs calculated for each allowance
category should be added together to obtain a total monthly utility
allowance for each bedroom size at each applicable housing development.
Many PHAs round UAs up to nearest dollar to simplify rent calculations.

If the utility supplier does not offer residents a uniform payment plan,
the PHA may provide for seasonal variations in its UAs.

**Complete Utility Allowance Schedule**

**[Totaling All Resident-Paid Utility Allowances by Housing Dwelling
Unit]{.underline}**

Under 24 CFR 965.503, separate allowances shall be established for each
utility and for each category of dwelling units determined by the PHA.

The PHA should also prepare a **Utility Allowance Schedule** to publish
(post) and communicate with the residents and Board of Commissioners
(see Appendix B6: Sample Board Resolution). The Utility Allowance
Schedule is public information and should be made available to anyone
who requests a copy of it. The size of the schedule is dependent upon
the number of housing developments, number of bedroom sizes, and
utilities paid by residents. See Sample below.

For the purposes of Asset Management Projects (AMPs), the PHA may
combine or group the UAs by AMPs.

***Table 4-1: Sample Utility Allowance Schedule (for illustration
purposes only)***

  --------------------- -------------- ------------------------ -------------- -------------- --------- -----
  **UTILITY ALLOWANCE                                                                                   
  SCHEDULE**                                                                                            

                                                                                                        

                                       **Building Type: High                                            
                                       Rise**                                                           

  **ABC Elderly         **0BR**        **1BR**                  **2BR**        **3BR**        **4BR**   
  Development**                                                                                         

  Electricity           \$44.00        \$51.00                  \$59.00                                 

  Water                 \$19.00        \$22.00                  \$24.00                                 

  Sewer                 \$40.00        \$47.00                  \$49.00                                 

  **Totals**            **\$103.00**   **\$120.00**             **\$132.00**                            

                                                                                                        

                                       **Building Type:                                                 
                                       Semi-Detached/Duplex**                                           

  **Anytown Family      **0BR**        **1BR**                  **2BR**        **3BR**        **4BR**   
  AMP**                                                                                                 

  Electricity                          \$37.00                  \$42.00        \$45.00                  

  Natural Gas                          \$56.00                  \$65.00        \$72.00                  

  Water                                \$22.00                  \$24.00        \$26.00                  

  Sewer                                \$47.00                  \$49.00        \$51.00                  

  **Totals**                           **\$162.00**             **\$180.00**   **\$194.00**             
  --------------------- -------------- ------------------------ -------------- -------------- --------- -----

***Note: These utility allowances are rounded up to nearest dollar.***

![](media/image11.png){width="8.501388888888888in" height="11.0in"}

**CHAPTER 5: -- Annual Review of Allowances**

> **CHAPTER OVERVIEW: This chapter is used if, after reading Chapter 1,
> the PHA decided that an annual review and/or update of its utility
> allowances is needed rather than a new consumption study. This UA
> review may result in a new Utility Allowance Schedule. An explanation
> is provided concerning comparing the current utility rates and charges
> with the ones used to establish the current Utility Allowances.**

Federal regulations 24 CFR 965.507 [require that PHAs review their
utility allowances (UAs) on an annual basis]{.underline} to ensure that
their UAs and surcharges for excess usage are: (1) reasonable and (2) in
regulatory compliance. The extent of the review process is driven almost
entirely by the methodology that was initially used to calculate the
allowances and should always include an examination of changes in
utility rates. When utility rates and charges change by 10 percent or
more (increase or decrease), the PHA must revise its allowances
accordingly.

UAs that were established based on consumption data or engineering
calculations should also include an annual review of any major changes
to the buildings, equipment, and appliances that would impact UA
consumption requirements (e.g., modernization efforts and/or other
energy conservation measures implemented by the PHA). Those UAs that
were calculated using a single year non-normalized consumption data
should include an annual recalculation of the utility allowance changing
the data as appropriate from year-to-year. There are two changes that
can impact this particular regulatory requirement and therefore require
annual assessment:

-   Changes in utility rates and charges;

-   Changes in the consumption usage of a household (e.g., energy
    improvements).

As stated above, the annual review process is driven almost entirely by
the methodology used to calculate UAs and surcharges. PHAs that utilize
the engineering-based method (see Chapter 3, for the Engineering-based
Method) for establishing allowances must have available detailed
information regarding each building and housing development. They must
also have the capacity to utilize engineering calculations and
benchmarks. PHAs using the engineering-based method must be aware of
gradual changes in buildings, not just major changes. Examples of
gradual changes include the settling of insulation, a possible decline
in the efficiency of equipment, additional resident-owned appliances,
and any shift in resident consumption patterns driven by societal or
other concerns.

PHAs that elect to utilize single year non-normalized data in their
consumption-based method must have an annual process of recalculating
the allowances after collecting new data for the year in which the
utility allowance is being established.

In summary, there are three issues that should be taken into
consideration when conducting the annual review of UAs and surcharges:

-   **Significant Change:** Review any significant changes to buildings,
    equipment, or appliances that would affect the consumption
    requirements of the utility for which the allowance is provided
    since the time when the allowances were last calculated. Examples of
    such changes include modernization or weatherization, the
    installation of space heating or hot water heating systems, the
    replacement of a large portion of the refrigerators in a housing
    development. If there have been any significant changes that would
    affect the consumption requirements of dwelling units then the
    allowance consumption amounts for the affected dwelling units should
    be recalculated.

-   **Time Period:** Check to see when the last time the consumption
    allowance amounts were calculated. If these consumptions [have
    not]{.underline} been recalculated in the last five years it is
    highly recommended (as a best practice) that the consumptions be
    recalculated to take into account any changes over time that have
    affected the consumption usage of the dwelling units.

-   **Change in Utility Rates and Charges:** Contact the local utility
    suppliers to gather current rates and charges. Perform a comparison
    of the new/current utility rates and charges and the rates and
    charges used to calculate the current UAs. If the rates have changed
    by ten percent or more (increase or decrease) compared to the ones
    used when the current UAs were calculated, then the regulations
    require the PHA to recalculate the UAs based on the new/current
    rates and charges.

Whenever a consumption allowance adjustment is needed, the PHA can
recalculate the average base consumptions by utilizing the original
method of calculation. Additionally, if a utility allowance adjustment
is needed due to the ten percent change in rates, the PHA should use the
new rates and charges recently gathered from utility suppliers to
recalculate allowances.

Changes in utility rates due to passed-through costs (such as a fuel
adjustment charge/rate, purchased gas adjustment charge/rate, or gas
recovery charge/rate) by utility suppliers are considered a rate change
as mentioned above. These type of rate changes are not subject to the
60-day notice requirement \[24 CFR 965.507(b)\]

![](media/image12.png){width="8.501388888888888in" height="11.0in"}

**CHAPTER 6: Implementation of Consumption Allowances and Utility
Allowances**

> **CHAPTER OVERVIEW: This chapter provides guidance in the
> implementation process of the new Consumption Allowances or Utility
> Allowances Schedules.**

The amount that a PHA determines necessary to cover the resident's
reasonable utility costs is the utility allowance (UA). It is intended
to enable participating families to pay typical costs for utilities and
services for households occupying dwelling units of similar size and
type in the same locality.

Both the Consumption Allowance Schedule and Utility Allowance Schedule
must include the utilities and services necessary to provide housing
that is in compliance with Uniform Physical Conditions Standards (UPCS).
PHAs are required to implement and maintain a reasonable consumption
allowance schedule for PHA-provided utilities and a utility allowance
schedule for resident-paid utilities and other resident-paid housing
services such as trash collection.

**Support Documentation**

The PHA must maintain a record of all support documents detailing the
basis upon which consumption and utility allowances (UAs) were
established. \[24 CFR 965.502(b)\] Such documents may include, but not
be limited to:

-   complete documentation supporting the method used for determining
    average consumptions;

-   the utility rates and charges used to calculate the allowances;

-   the actual calculations of the allowances;

-   software utilized;

-   assumptions made;

-   building characteristics,;

-   adjustments made;

-   data utilized in developing total consumptions and UAs;

-   plus any other documents used in the study.

**Notice to Residents**

The PHA must notify all residents of proposed allowances, scheduled
surcharges, or revisions to allowances at least 60 days prior to the
date the allowances are to become effective \[24 CFR 965.502(c)\].

The notice to residents [must]{.underline} include the following:

-   A description of the basis on which the allowances and surcharges
    have been established or revised, including specification of which
    equipment and functions are included in the allowance;

-   Information on the availability of individual relief;

-   Disclosure of where residents can review the documentation that
    explains how the allowances and surcharges have been calculated;

-   Notification to the residents of their right to submit written
    comments regarding the allowances and surcharges. The period for
    submitting written comments must extend at least 30 days before the
    allowances or surcharges become effective \[24 CFR 965.502(c)\].

Additionally, PHAs should contact local utility providers or conduct
research to determine if lower rates are available to their residents.
Some electric and/or natural gas utility suppliers offer special lower
rates for low-income families. Although not required by HUD regulations,
the notice may include information regarding the availability of such
special low-income rates or life-line rates. An example of life-line
rates are special water and sewage conservation rate structures as
provided in part by the U. S. Department of Environmental Protection
Agency Notice EPA 816-R-98-002, 1998.

The PHA should review the resident's comments, received during the
30-day comment period) and answer or address any questions that the
residents' present. The PHA is not required to change allowances due to
residents' complaints, but this comment period allows the PHA another
opportunity to review its determinations.

The PHA should post (display) a copy of the new Utility Allowance
Schedule(s) and/or Schedule of Surcharges in the PHA's main office.
Notification to residents shall be given in the manner provided in the
lease or homebuyer agreement. Examples are posting a notice at each
housing development/site were resident's live, delivering or mailing a
notice to each resident's dwelling unit, or a written announcement in a
monthly residential newsletter.

***Changes in utility rates due to passed-through costs (such as a fuel
adjustment charge/rate, purchased gas adjustment charge/rate, or gas
recovery charge/rate) by utility suppliers are not subject to the 60-day
notice requirement \[24 CFR 965.507(b)\]***

**Individual Relief**

In some cases, PHAs may allow individual relief from resident utility
bills that have exceeded the PHA's UA. HUD regulations \[24 CFR
965.508\] specifically permit PHAs to grant individual relief on
reasonable grounds when the resident's utility consumption exceeds the
PHAs' UA because of the special needs of the elderly, ill or disabled
residents, or special factors affecting utility consumption beyond the
resident's control.

When granting individual relief, the regulations require that the PHA
have a written policy in its Annual Plan/Agency policies that spells out
the criteria under which this relief would be granted. The plan/policy
should include a PHA contact name and number and the PHA's criteria for
granting such relief and how the PHA advises residents to request
individual relief.

PHAs should consider the following as valid criteria for granting
individual relief:

-   The resident's consumption was mistakenly portrayed as excessive due
    to defects in the meter or errors in the meter reading.

-   The resident's over consumption is caused by a characteristic of the
    dwelling unit or PHA-supplied equipment that is beyond the
    resident's control such as an energy-deficient refrigerator or
    inadequate insulation. The UA under these circumstances would have
    to be adjusted to reflect the higher consumption associated with the
    dwelling unit until the situation is remedied.

-   The resident's over consumption is due to special needs of a
    resident household member and is not within a resident's ability to
    control. Special needs might include having as part of the household
    elderly, ill or disabled residents that have special needs requiring
    higher energy or water consumption. The allowance should be adjusted
    to reflect the higher consumption needs associated with the
    household's special circumstances.

Individual relief should only be granted when excessive consumption is
beyond the resident's control. Should the resident's consumption be
excessive and within the ability of the resident to control, then no
individual relief would be granted. The PHA must provide residents
notice on the proposed UAs and scheduled surcharges, and the notice
should include the availability of individual relief, the procedures for
seeking that relief, and the PHA's criteria for granting such relief.
(See Appendix B for Sample Individual Relief Request form.)

**Adopting Utility Allowances**

Although not required by HUD regulations, the proposed Consumption
Allowances and/or Utility Allowances should be presented to the PHA's
Board of Commissioners for approval and adoption. (See Appendix B6:
Sample Board Resolution.) The PHA should then establish a date for which
these UAs will be effective. The date must be at least 60 days after
posting notice.

All residents should have any new UAs reflected in their rent within 30
days of the effective date \[24 CFR 965.507(b)\].

The PHA's determinations of allowances, scheduled surcharges, and
revisions thereof shall be final and valid unless found to be arbitrary,
capricious, an abuse of discretion, or otherwise not in accordance with
the law. \[24 CFR 965.502(e)\]

**HUD Review of Allowances**

UAs for federally assisted public housing [are not]{.underline} subject
to approval by HUD before becoming effective. HUD may, however, review
the allowances and surcharges during the course of regular audits or
reviews of PHA operations.

![](media/image13.png){width="8.501388888888888in" height="11.0in"}

**CHAPTER 7: Energy Efficiency**

> **CHAPTER OVERVIEW: This chapter provides information regarding energy
> conservation education and energy efficiency measures that help lower
> utility costs. It also discusses how management of utility systems and
> resident's behavior issues can affect utility allowances. This chapter
> also addresses Energy Audits and ESCOs and their relationship to
> utility allowances.**

Public Housing Agencies (PHAs) should recognize the importance of an
ongoing energy conservation education effort, particularly aimed at
residents whose consumption exceeds their allowance. Such outreach and
education efforts that result in energy conservation by residents will
not only benefit the individual households experiencing surcharges, but
will also reduce the PHA's overall utility use and costs.

The PHA should remain alert to weatherization measures and equipment
upgrading that the agency could undertake that would reduce resident
utility consumption.

Following more than four years of debate, the United States enacted a
comprehensive energy bill in 2005. The Energy Policy Act of 2005 (Pub.L.
109-058, H.R.6) was signed into law by President George W. Bush on
August 8, 2005. The first comprehensive revision to energy policy since
1992, this Act has the following sections impacting energy issues as
they relate to public housing.

***Section 151***

Section 151 of the bill permits funds from the Public Housing Capitol
Fund to be used for improvements to maximize energy and water use
efficiency in public housing. It also permits PHAs to engage in
contracts with outside vendors that maximize energy efficiency.

***Section 152***

Section 152 directs PHAs to purchase appliances designated by ENERGY
STAR® or by Federal Energy Management Program (FEMP) as designated
products, unless the purchase of energy-efficient appliances is not cost
effective to the PHA.

***Section 153***

Section 153 requires new public housing that is funded by HOPE VI
revitalization grants to meet the 2003 International Energy Conservation
Code (IECC) by September 30, 2006.

***Section 154***

Section 154 legislation requires HUD to develop a strategy to reduce
utility cost through energy-efficiency measures and energy-efficient
design and construction of public and assisted housing. The Department's
first report was submitted to Congress on August 8, 2006, Promoting
Energy Efficiency at HUD in time of Change Report, and subsequent
updates biennially.

Optimizing the energy efficiency in public housing ultimately rests not
only on changes in the structure and equipment of the buildings, but
also on the actions of PHA management, staff, and residents. This
includes understanding proper use of equipment and energy costs,
training for operating and maintenance, establishing accountability, and
providing the correct balance of human versus automatic and mechanical
control.

**System Management, Control and Behavioral Issues**

It is through the management and control of a building's energy-using
components that the physical and behavioral aspects of energy use are
linked. Approaches for controlling a building's energy use include
individual meter reading, thermostatic controls, and Energy Management
Systems (EMS). Decisions regarding the control of energy within PHAs are
affected by staff training and responsibilities, resident awareness and
responsibilities, and specifications for control devices such as
radiator valves and thermostats.

It is important to include feedback into the development of EMS.
Feedback entails observing the outcome of a process and then feeding the
information back to whomever or whatever controls they process. Feedback
is crucial at many levels -- some physical and some informational. A
thermostat is the archetypical physical feedback mechanism; it senses
the temperature inside a building and provides a signal back to a boiler
about whether or not heat is required. Conservation practitioners know
that if there is a failure to understand operation, thermostats can be
one of the biggest problem areas in a building.

![](media/image14.wmf)

The other level of feedback regards informational feedback. Unlike the
physical feedback loop described above, informational feedback goes in
both directions: from the PHA to the residents and from the residents to
the PHA. The most effective informational feedback will not be limited
to PHA line staff, but will go up to the Executive Director. This
feedback is particularly critical for it involves the resident who may
pay part of the bill, as well as, those who make decisions concerning
utility allowances (UAs) and building equipment choice and operation.

![](media/image15.wmf)

The nature of system management and control depends on the physical and
operational mechanisms for measuring energy use and comfort, and then
conveying this information back to a building's staff and residents.
Those PHAs who promote positive interactive feedback with their
residents can experience a spirit of collaboration, which in turn can
create a positive effect on building operations.

Energy efficiency should be an integral part of every PHA's operations
and capital improvement planning process. The most compelling reason for
any PHA to make energy conservation improvements is the potential for
significantly reduced energy costs. The extent to which reduced energy
costs will impact a PHA's operating budget depends on the method of
funding the improvements. If a PHA chooses to utilize the services of an
Energy Service Company (ESCO), after implementation of the EMSs, the PHA
updates the UAs in accordance with provisions in 24 CFR Part 965,
Subpart E. The new allowances should be lower than baseline allowances;
the PHA uses at least 75 percent of the savings for paying the cost of
the improvement (the PHA will be permitted to retain 100 percent of the
difference between the baseline allowances and revised allowances) for
the life of the loan. Additional resource information may be found in
Appendix A.

The key to a sound energy improvement program and an EMS is a good
Energy Audit (EA) \[24 CFR 990.301\]. Regulations require an EA to be
completed every five years for each property in a PHA's portfolio, but
an EA can be conducted any time to support comprehensive modernization
or equipment purchases. An EA provides analysis of a building's energy
systems and offers planning information that allows building managers to
assess opportunities for excessive utility cost avoidance. Properly
completed, an EA supports integrated planning of capital investments,
operating improvements, and maintenance cost reductions.

There are three kinds of EAs: walk-through audits, general engineering
audits, and investment grade audits (or detailed engineering studies):

-   ***Walk-through energy audit:*** A walk-through EA is used to rank
    development opportunities and establish a scope for a more detailed
    EA that, if warranted, will determine costs and savings for each
    measure. A walk-through EA should provide a brief discussion of
    existing conditions, a snap shot of utility consumption and costs,
    and offer a brief discussion of potential conservation measures at
    each development. The auditor in a walk-through is often an
    experienced energy auditor or a certified home energy rater who has
    completed numerous, more detailed energy audits. Optional: systems
    performance testing (e.g., blower door) may be utilized.

-   ***General engineering audit:*** In the engineering audit, an energy
    auditor completes an analysis of utility costs and savings for all
    cost effective conservation measures and savings at each property.
    Utility data is analyzed, trended, and benchmarked and then used to
    establish the available savings for each recommended conservation
    measure. Costs are generally developed through industry norms or
    available historical development information, and the energy auditor
    is often an experienced engineer, architect, certified
    auditor/inspector, an accredited home energy rating system (HERS)
    provider, or a team of auditors overseen by a licensed engineer or
    other qualified individual. Optional: systems performance testing
    (e.g., blower door) may be utilized.

-   ***Investment grade energy audit:*** An investment grade EA (or
    detailed engineering study) adds equipment testing and energy
    monitoring to the engineering audit to more accurately development
    savings for specific end-uses. The detailed engineering study may
    also request actual prices for construction and project management.
    A detailed energy study is more expensive to complete but warranted
    where capital investments will be financed from the resulting energy
    savings. Systems performance testing (e.g., blower door, duct
    blower, thermo imaging, flow rate \[GPM\], etc.) is generally
    required for this type of audit. Licensed architects or engineers,
    accredited HERS providers, certified energy managers, energy
    services companies (ESCO), energy services providers (ESP), or other
    qualified entities generally conduct these audits.

**Using an Energy Audit in Capital and Maintenance Planning**

HUD requires PHAs use EAs in planning capital projects. To better plan
for implementing EAs and to more effectively utilize EA results in
capital planning, it is important for a PHA to consider what information
an EA can provide and how that information can be used. EAs generally
include the following four components: physical inspection and
equipment/systems testing, utility bill analysis, recommended energy
efficient opportunities, and incremental investment analysis.

**[Physical Inspection and Equipment/System Testing]{.underline}**

An EA begins with a physical inspection and data collection for all
facilities and energy-related equipment. The inspection and data
collection would review equipment conditions, past maintenance
schedules, remaining useful life, and system performance. Evaluations
should also consider such factors as heat exchanger damage, high
humidity, poor temperature control, and comfort concerns. Additionally
the EA could include testing of air infiltration (blower door), duct
leakage, Carbon Monoxide/Exhaust Gas efficiency analysis, pressure
testing, and flow rate testing for water conservation devices.

**[Utility Bill Analysis]{.underline}**

Utility bills for each property are collected and analyzed to evaluate
the effects of weather and irregular behavior. The utility bill analysis
also separates end-uses. Where resident-paid utilities are involved, the
energy auditor should review the PHA's most recent UA study, which will
either provide samples of resident-paid utility bills or an engineering
calculation of estimated consumption by use. The analysis should compare
normalized energy consumption among the housing developments in the
PHA's portfolio and, where available, against available actual
consumption data from the properties.

**[Energy Efficiency Opportunities]{.underline}**

Energy efficiency recommendations should be based on engineering and
economic analyses of such factors as operating hours, equipment
efficiency, and building and occupant energy demand characteristics. The
analyses should discuss important assumptions and provide summary
recommendations. Recommendations should be in the form of Energy
Conservation Measures (ECMs) with estimated pay back periods on PHA
investments. See U.S. Department of Housing and Urban Development Energy
Conservation for Housing: A Workbook, 1998. (See website:
http://www.abtassoc.com/ reports/D19980034.pdf)

**[Incremental Investment Analysis]{.underline}**

A concern in energy audits has been the failure to complete incremental
investment analysis, which is an important consideration for
modernization and routine maintenance projects. Equipment nearing the
end of useful life or failing catastrophically will require a
replacement whether or not the retrofit can pay for itself. A heating or
cooling system, for example, may fall into this category. Simple
paybacks for these systems can often be longer than 25 years due to the
high first costs for equipment and installation. If the equipment must
be replaced to prevent unscheduled failure, an economic analysis should
be conducted that evaluates installed costs (i.e., first cost).
Comparisons can then be made to consider alternative equipment options
using incremental cost and savings differences against a base.

Modernization projects typically develop capital plans based on a
physical needs assessment (PNA) that ranks investment priorities prior
to developing capital funding plans. Capital Fund Program planning
resides in a different budget center for PHAs than utilities, PHA
Executive Directors seeking to better integrate their utility management
practices into spending decisions will need to coordinate their decision
making with all those involved. Having a well-developed EA and using the
results in coordination with PNA will allow a PHA to incorporate
effective utility management in capital investment priorities.

PHAs often outsource their EAs. This is logical since EAs are completed
infrequently and qualified auditors require specialized skills and
ongoing training. To get an EA that fits a PHA's planning requirements,
it is important to develop a clear scope of work and identify the skills
and capabilities required from potential firms. The scope should outline
the requirements for the EA, minimum methods to be used, and skill
levels sought (e.g., certified energy home rater/auditor). Where a PHA
may need to complete a UA study EA, and/or a PNA, these requirements are
complimentary to the project and may produce economies of sale in a
combined procurement. A properly specified procurement package will
result in the selection of firms with the necessary experience or
capability.

**Energy Audit Regulations**

HUD regulations at 24 CFR 965 Subpart C provides requirements to PHAs on
completing EAs. These regulations only apply to public housing and do
not apply to Indian Housing Authorities, Section 8 Project-Based
assisted housing developments, and resident-based Section 8 Housing
Choice Voucher Program (HCVP) assisted developments.

PHAs must complete an energy audit for each applicable property every
five years. The EA must analyze all ECMs that pertain to each building
type and provide the associated payback periods. All cost effective
measures must be implemented within capital funds that are available.
HUD suggests that ECMs be ranked by payback and funded in increasing
payback order. The order can be adjusted if funds are insufficient for
all cost effective measures or where long payback items would be more
effectively completed under modernization. Regulations require that PHAs
fund conservation measures first from operating funds to the extent
feasible, and then seek alternative sources such as operating reserves,
capital funds, or redevelopment funds where available. PHAs may also use
third-party financing, but HUD must agree to provide adjustments to
subsidy eligibility that allows the debt service to be paid from
anticipated utility cost reductions.

HUD requires replacement equipment to meet or exceed minimum efficiency
requirements established by the U.S. Department of Energy (DOE) and
requires PHAs to manage operations to maximize energy conservation.
ENERGY STAR® rated equipment and appliances is strongly recommended.

Where available from states and utility companies, funding for
efficiency improvements should be identified and quantified in the EA.
Currently there are 17 states where electricity restructuring is active
and 18 states where natural gas unbundling is available. In many of
these states (e.g., California, New York, Wisconsin) system benefit
charges are applied to utility consumption and the funds are set aside
for energy management and efficiency programs. In states fully
regulated, many utilities and state energy offices may have limited
funding available for efficiency developments.

Third-party financing, known as Energy Performance Contracting (EPC), is
a potential funding source for modernization projects \[24 CFR 990\].
Performance contracts require an assessment of project potential,
selection of a qualified energy services firm, review of financial and
engineering calculations, independent commissioning and measurement and
verification. These projects require expertise in energy management.
PHAs might consider working with an experienced professional familiar
with performance contracting to plan and develop these kinds of energy
projects, especially on initial or complicated efforts. Numerous PHAs
are implementing self-directed projects and acting as ESCOs. Advantages
for PHAs to be self-directed include: lower costs, not overhead, profit,
increasing staff knowledge of operating systems, better integration with
Capital Funds and asset management strategies. The PHAs staff workload
must be flexible, and staff must have at least moderate construction
administration experience and a high level of interest about the EPC
process. \[EcoWise articles: July 2008 and September 2008\]

PHAs receive funding for large, non-recurring maintenance improvements
through the Capital Fund program, which requires five year and annual
planning. Under 24 CFR 968.115, PHAs must incorporate cost-effective
ECMs as identified in their most recently updated EAs.

**Energy Service Companies (ESCOs) -- A Way to Control Utility Costs**

Along with the requirements of successful asset management projects, the
digital economy and an expanded energy market have boosted PHA managers'
and Executive Directors' interest in controlling energy costs and
increasing power quality and reliability for their respective
developments. PHAs are large consumers of power, so they should begin to
leverage that power by establishing relationships with utility
companies. Advances in power generation equipment and efficiencies, as
well as expanded information-gathering options and energy services, make
the time ripe to explore energy management alternatives that heretofore
may have been overlooked.

PHAs are today more than ever searching for ways to retrofit their
agencies with the latest equipment designed to facilitate energy
conservation. An ESCO, or Energy Service Company, is a business that
develops, installs, and finances projects designed to improve the energy
efficiency and maintenance costs for developments over a 20-year time
period. ESCOs generally act as project developers for a wide range of
tasks and assume the technical and performance risk associated with the
project. Typically, they offer the following services:

-   Develop, design, and finance energy efficiency developments;

-   Install and maintain the energy efficient equipment involved;

-   Measure, monitor, and verify the development\'s energy savings;

-   Assume the risk that the development will save the amount of energy
    guaranteed.

These services are bundled into the development\'s capital improvement
cost and are repaid through the energy cost savings generated.

As mentioned previously, numerous PHAs are acting as self-directed
ESCOs. Self-directed EPCs make a lot of sense for PHAs of all sizes, but
especially for those PHAs with fewer than 500 dwelling units. PHAs will
need to be familiar with HUD's streamlined EPC procedures. They will
need to obtain or research such information as: 3 years of utility
consumption history, local utility rates, and building characteristics
(e.g., what's old, what's new, what works and what doesn't work).
\[EcoWise articles: July 2008 and September 2008\]

ESCO projects are comprehensive, which means that the ESCOs employ a
wide array of cost-effective measures to achieve energy savings. These
measures often include the following: water conservation, high
efficiency lighting, high efficiency heating and air conditioning,
efficient motors and variable speed drives, and centralized EMSs.

What sets ESCOs apart from other firms that offer energy efficiency such
as consulting firms and equipment contractors is the concept of
performance-based contracting? When an ESCO undertakes a project, the
company\'s compensation, and often the project\'s financing, is directly
linked to the amount of energy that is actually saved.

Typically, the comprehensive energy efficiency retrofits inherent in
ESCO projects require a large initial capital investment and offer a
relatively long payback period for public housing. The PHA's debt
payments are tied to the energy savings offered under the project so
that the PHA pays for the capital improvement with the money that comes
out of the difference between pre-installation and post-installation
energy use and other costs. For this reason, ESCOs have led the effort
to verify, rather than estimate energy savings. One of the most accurate
means of measurement is the practice of metering, which is direct
tracking of energy savings according to sanctioned measurement and
verification protocols. These are available at the HUD Public Housing
Environmental and Conservation Clearinghouse (PHECC) website.
(http://www.hud.gov/offices/pih/ programs/ph/phecc/eperformance.cfm)

Most performance-based energy efficiency projects include the
maintenance of all or some portion of the new high-energy equipment over
the life of the contract. The cost of this ongoing maintenance is folded
into the overall cost of the project. Over the life of the contract, the
PHA receives the benefit of reduced maintenance costs in addition to
reduced energy costs. As an additional service in most contracts, the
ESCO provides specialized training needed so that the PHA's maintenance
staff can take over at the end of the contract performance period.

Another critical component of every energy efficiency project is the
education of PHA staff and residents about their energy use patterns.
Understanding how their energy use is related to lifestyle is critical
for the development of an \"energy efficiency partnership\" between the
ESCO and the PHA. This component is most critical in a public housing
environment where residents may not be used to paying the utility bills
generated by their own consumption.

Included in the ancillary services provided in a typical
performance-based energy efficiency contract are the removal and
disposal of hazardous materials from the PHA's facility. When, for
example, existing fluorescent lighting equipment, ballasts that contain
PCBs (Poly Chlorinated Biphenyl), and fluorescent light tubes that
contain traces of mercury are replaced, the old equipment must be
disposed of as hazardous waste. Upgrades to heating, air conditioning,
and ventilation systems may involve the removal of asbestos and would
also be properly disposed of by the ESCO.

![](media/image16.png){width="8.501388888888888in" height="11.0in"}

**APPENDIX A: INFORMATION RESOURCES**

***The following resources are provided for information purposes only.
The U.S. Department of Housing and Urban Development (HUD) does not
endorse or necessarily agree with all the content contained in the
following resources. These resources and contact information is subject
to change.***

**[HUD's Resources:]{.underline}**

**HUD\'s Client Information and Policy System (HUDCLIPS)**

**On-line resource for forms, handbooks, policies, and other related
information:**

http://www.hudclips.org/cgi/index.cgi

**HUD Public Housing Environmental and Conservation Clearinghouse
(PHECC)**

**On-line resource for information related to Energy Performance
Contracting:**

http://www.hud.gov/offices/pih/programs/ph/phecc/eperformance.cfm

**On-line resource for overview of some of the key principles underlying
the establishment of utility allowances:**

http://www.hud.gov/offices/pih/programs/ph/phecc/allowances.cfm

***HUD Public Housing Occupancy Guidebook, June 2003***

**[Weather or Climate Data Information:]{.underline}**

**National Oceanic and Atmospheric Administration (NOAA) National
Climatic Data Center (NCDC)**

**On-line resource for heating degree days data (can order by state and
weather center location):**

http://www5.ncdc.noaa.gov/cgi-bin/climatenormals/climatenormals.pl

**On-line resource for U.S. weather recorded normals (CLIM81):**

http://www.ncdc.noaa.gov/oa/climate/normals/usnormals.html

**[Energy Information:]{.underline}**

***HUD Energy Conservation for Housing: A Workbook, 1998***

**U.S. Department of Energy (DOE)**

http://www.eia.doe.gov/

**On-line resource for average amount of kilowatt hours used by
household appliance and plug load estimates:**

http://www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html

**On-line resource for building energy software tools:**

**U.S. DOE's Energy Efficiency and Renewable Energy (EERE)**

http://www.eere.energy.gov/buildings/tools_directory

**APPENDIX A: INFORMATION RESOURCES (continued)**

**[Energy Information: (continued)]{.underline}**

**On-line resource for information related to Energy Conservation
Measures (ECMs):**

http://www.abtassoc.com/reports/D19980034.pdf

On-line resource for building energy performance:

**Residential Energy Services Network (RESNET)**

http://www.natresnet.org/programs/software/directory.htm

**On-line resource for green building performance education:**

**Energy and Environmental Building Association (EEBA)**

http://www.eeba.org/

**On-line resource for advanced energy technologies:**

**U.S. Department of Energy (DOE)-Oak Ridge Office**

http://www.ornl.gov/sci/btc/apps/

**Environmental energy Technologies Division**

http://eetd.lbl.gov/coolroof/

**[Efficient Lighting Information:]{.underline}**

**On-line resource for efficient lighting fixtures, lighting education,
and frequently asked questions:**

http://www.elflist.com/

**[Water Information:]{.underline}**

**Environmental Protection Agency (EPA)**

**On-line resource for residential water conservation techniques:**

**Software for Environmental Awareness (SEAHOME)**

http://www.epa.gov/seahome/watcon.html

**On-line resource for water information:**

**EPA Office of Water (OW)**

http://www.epa.gov/OW/you/chap3.html

**[Utility and Energy Software and Services:]{.underline}**

**Abraxas Energy Consulting-Utility bill tracking software:**

http://www.energy-accounting.com

**Energy Watchdog-Energy tracking and utility management software:**

http://www.energywatchdog.com

**APPENDIX A: INFORMATION RESOURCES (continued)**

**[Utility and Energy Software and Services: (continued)]{.underline}**

**Utility Management Services**

**On-line resource for utility management services and software:**

http://www.utilityaccounting.com

**Stellar Processes, Inc.**

**On-line resource for utility management services and software:**

http://www.ezsim.com/

**Gathering Utility Rates and Charges:**

**Database of State Incentives for Renewables and Efficiency**

**On-line resource for state, local, utility and federal incentives:**

www.dsireusa.org

**Many utility provides maintain an individual website and post their
rates and charges**

**State Public Utility Commission's have websites and sometimes list
local utility company electric or gas rates.**

**APPENDIX B: SAMPLE FORMS AND** **HELPFUL INFORMATION**

> **1: SAMPLE REQUEST FOR PROPOSAL (RFP)**

***(For Advertising/Posting)***

**SAMPLE**

**REQUEST FOR PROPOSALS (RFP)**

**Solicitation No.: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Low-Rent Public Housing Utility Allowance Study**

The \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Housing Authority
(hereinafter referred to as the Agency) will accept competitive sealed
proposals for an experienced consulting firm to conduct a Low-Rent
Public Housing Utility Allowance Survey and Study for it\'s \_\_\_\_\_\_
conventional housing units which utilize utility allowances and which
would approximate a reasonable consumption of utilities by an
energy-conservative household of modest circumstances consistent with
the requirements of a safe, sanitary, and healthful living environment.

Utility allowances will be determined using an ***(Note to PHA: choose
both methods or one method**)* **actual/historical consumption-based
method** **/** **an engineering-based method** and will be conducted in
accordance with 24 CFR Part 965, Subpart E, Tenant Allowances for
Utilities.

Deadline to submit proposals and credentials is 4:30 p.m. on
[\_\_\_\_\_\_\_]{.underline} at the address listed below. RFP\'s can be
obtained Monday through Friday between the hours of 9:00 A.M. and 4:00
P.M. at [\_\_\_\_\_\_\_\_]{.underline} . All proposals should be sent
to:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, Executive Director

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_Housing Authority

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

For information contact at ( ) . The Agency reserves the right to reject
any or all proposals. The Agency is an equal opportunity employer and
contracting agency.

**SAMPLE**

**Request for Proposals (RFP)**

**Solicitation No.: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**LOW-RENT PUBLIC HOUSING UTILITY ALLOWANCE STUDY**

I. **SCOPE OF SERVICES**

> The \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Housing Authority
> (hereinafter referred to as the Agency) will accept competitive sealed
> proposals for an experienced consulting firm to conduct a Low-Rent
> Public Housing Utility Allowance Study for it\'s \_\_\_\_\_\_
> conventional housing units located at \_\_\_\_\_\_ developments/sites
> which utilize utility allowances and which would approximate a
> reasonable consumption of utilities by an energy-conservative
> household of modest circumstances consistent with the requirements of
> a safe, sanitary, and healthful living environment. Utility allowances
> will be determined using an ***(Note to PHA: choose both methods or
> one method)*** **actual/historical consumption-based method** **/**
> **an engineering-based method** and will be conducted in accordance
> with 24 CFR Part 965, Subpart E, Tenant Allowances for Utilities.
>
> The contractor will establish utility allowances for the following
> housing developments:
>
> ***(Note to PHA: Complete the chart below and check the appropriate
> box(s) for resident-paid utilities. Write C-M if utilities are paid by
> the Agency and units are individually metered.)***

  ----------------- -------- ----------- --------------- --------- -------- --------------- --------
  Development Name  Total    Structure   Resident-Paid                      Air             
  and Number        Number   Type        Utilities                          Conditioning?   
                    of Units                                                                

                                         Electric        Natural   Water/   Central         Window
                                                         Gas       Sewer                    

                                                                                            

                                                                                            

                                                                                            

                                                                                            

                                                                                            

                                                                                            
  ----------------- -------- ----------- --------------- --------- -------- --------------- --------

> A. [Collection of Data and Analysis]{.underline} ***(If utilizing an
> actual/historical consumption-based method)***
>
> Due to privacy issues, the Agency will assist in the requisition of
> adequate actual historical data from the local utility companies for
> Resident-Paid Utilities for each dwelling unit category and unit size
> by development. If the utility company requires signed resident
> releases (with or without account numbers) the Agency will gather
> these resident releases and provide a copy to the appropriate utility
> companies along with a specific request for actual historical data, on
> agency letterhead. The study should be conducted using a U. S.
> Department of Housing and Urban Development (HUD) acceptable
> statistical model and methodology. Necessary adjustments should be
> made for climatic conditions, unit vacancies, etc.
>
> B. [Recommended sources of data shall be, but not limited
> to:]{.underline}
>
> \- Consumption information from the Agency, residents, and/or utility
> suppliers
>
> \- Energy audits
>
> \- Physical inspections of representative units
>
> \- building plans and modernization documentation
>
> \- Interviews of residents to obtain insight into energy usage
>
> \- Interviews of maintenance personnel and project managers to gain
> understanding of HVAC equipment and how housing facilities are used by
> residents.
>
> C. The study should be conducted with Agency staff and resident
> participation.
>
> The timeframe for completing the above services will be 120 days from
> the date of contract execution.
>
> Interested proposers must respond with:
>
> 1\. Detailed description of how proposed services will be provided.
>
> 2\. Listing of the deliverables the Agency will receive.
>
> 3\. Proposals demonstrating an understanding of the required services
> of the Agency, meeting regularly recognized HUD policies, guidelines,
> and procedures governing the administration of a Public Housing
> Authority.
>
> 4\. Provide written evidence of the firm\'s ability to perform the
> services.
>
> 5\. Summary profiles of the firm\'s principals, staff and associates
> who will be assigned to the project.
>
> 6\. At least 3 references
>
> 7\. Fixed Price cost estimate to provide the proposed services.
>
> 8\. Any additional information that will assist the Agency in
> evaluating the firm's capability to perform the proposed services.
>
> ***(Note to PHA: the following items can also be requested at this
> time or before awarding the contract)***
>
> 9\. Proof of Insurance Coverage
>
> 10\. Non-Collusive Affidavit
>
> 11\. Equal Opportunity Statement
>
> 12\. Certifications and Representations of Offerors (Form HUD-5369-C)
>
> 13\. Certification Regarding Debarment and Suspension
>
> (Form HUD-2992)
>
> The Agency will accept one faxed, mailed, or delivered proposal until
> 4:30 p.m. on\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ (date).
> Please address all proposals to:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, Executive Director

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_Housing Authority

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

II\. **ELIGIBILITY TO SUBMIT PROPOSAL**

> In order to be considered eligible to submit proposal, each
> organization, individual, or firm must submit written evidence with
> its proposal demonstrating that it fulfills the following eligibility
> criteria:
>
> 1\. The proposer has a minimum of one year experience working for or
> contracting with a housing agency and/or related housing or government
> agencies. Must have experience in conducting utilities studies, needs
> assessments, regulation compliance, tenant services, the Capital Fund
> Program, and/or other public housing programs.
>
> 2\. A minimum of 3 references with telephone numbers of housing
> agencies where work has been performed and/or Agency staff
> participating in training sessions.

3\. A certification statement that the proposer is not debarred,
suspended, or otherwise prohibited from professional practice by any
federal, state, or local agency.

III\. **FACTORS FOR AWARD OF CONTRACT**

> In addition to eligibility criteria and requirements addressed in 24
> CFR Part 965, Subpart E, Tenant Allowances for Utilities, the
> following criteria is relative to this RFP and the proposer should
> address each of these factors as they will be considered when
> determining the contract award.
>
> A. Experience in working with Public Housing Authority programs, HUD
> programs, and/or other government or private entities. Responsiveness
> to the RFP's Scope of Services. (30 points maximum).
>
> B. Approach and experience in conducting utility allowance studies.
> (30 points maximum)

C. Staff. Description of organization\'s staff and experience in HUD
programs, and previous Agency technical assistance, Agency energy
surveys, and physical and management needs assessment projects. (30
points maximum)

D. Acceptance by HUD Field Office of proposer organization.

> E. All proposers must carry the following insurance policies: required
> workmen\'s compensation, general liability and professional liability
> of no less than \$1 million and non-owners auto insurance. (15 points
> maximum)
>
> F. Price. Total cost of services to be provided shall be described. (5
> points maximum)

G. Timing. Proposer shall describe start and schedule of activities to
be performed. (15 points maximum)

H. Minority business enterprise, Section 3 business concern, and/or
women owned business. (5 points maximum)

I. Subject to Other Documents. The contract is subject to the terms and
conditions of the State of Mississippi as they exist at the time the
agreement is signed.

J. Binding Effect. The contract shall be binding upon and shall inure to
the benefit of the successors and the assigns of the Agency, and to the
heirs and personal representatives of the consultant.

K. Conflict of Interest. The consulting firm warrants that it presently
has no interest and will not acquire any interest direct or indirect,
which would conflict in any manner or degree with the performance of
services under this contract.

L. Award of Contract. The award shall be made to the responsible party
whose proposal is most advantageous to the Agency, taking into
consideration the evaluation factors set forth in this request for
proposals.

M. Envelopes. Proposal envelopes and/or fax cover page shall be clearly
marked to indicate that a proposal is enclosed. Please identify at lower
left hand corner of envelope or top of fax cover page \"Low-Rent Public
Housing Utility Allowance Study".

N. The Proposer warrants adhering to civil rights, equal opportunity,
fair housing, and Section 3 regulations.

O. Responsibility. It shall be the responsibility of the Proposer to see
that their proposal is received by the PHA by the date and time set for
the opening of the proposals. Proposals received after the time stated
shall not be considered.

P. Rejection of Proposals. The PHA reserves the right to accept or
reject any or all proposals which are determined to be non-responsive.

IV\. **MATERIALS**

> All assessment materials and manuals and/or software necessary for the
> execution of this contract will be developed by the contractor.

V. **PAYMENT OF CONSULTANT/CONTRACTOR FEES**

> Upon execution of contract, contractor shall receive initial payment
> for start-up labor, materials and miscellaneous expenses. Thereafter,
> Contractor shall submit itemized invoices to the Agency on a monthly
> basis. Contractor\'s invoices shall be processed and payment made to
> Contractor in accordance with the policy and procedure of the Agency.

VI\. **AWARD OF CONTRACT**

> The proposals which are received will be evaluated by a committee
> consisting of the Executive Director, another staff person, and a
> representative from the Board of Commissioners. All proposals will be
> evaluated on eligibility criteria and factors for awards previously
> stated above.
>
> The Agency reserves the right to reject any or all proposals, to waive
> any informality in proposals and unless otherwise specified by the
> Agency or proposer to accept any items in the proposal.

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **2: SAMPLE REQUEST FOR QUOTATION (RFQ)**

**SAMPLE**

**Request for Quotation (RFQ)**

**Solicitation No.: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**LOW-RENT PUBLIC HOUSING UTILITY ALLOWANCE STUDY**

## TO: All Prospective Offerors

**TRANSMITTED VIA \_\_\_ E-mail \_\_\_ Fax**

**SUBJECT: Request for Quotations (RFQ) for Low-Rent Public Housing**

> **Utility Allowance Study**

## DATE: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

The \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_Housing Authority (PHA) has
an immediate requirement to solicit an experienced consulting firm to
conduct a Low-Rent Public Housing Utility Allowance Study for its
\_\_\_\_\_\_ conventional housing units located at \_\_\_\_\_\_
developments/sites which utilize utility allowances. The PHA is
utilizing its Statement of Procurement Policy for small purchases.

**I. [STATEMENT OF WORK]{.underline}**

Utility allowances will be determined using an ***(Note to PHA: choose
both methods or one method**)* **actual/historical consumption-based
method** **/** **an engineering-based method** and will be conducted in
accordance with 24 CFR Part 965, Subpart E, Tenant Allowances for
Utilities.

> The contractor will establish utility allowances for the following
> housing developments:
>
> ***(Note to PHA: Complete the chart below and check the appropriate
> box(s) for resident-paid utilities. Write C-M if utilities are paid by
> the Agency and units are individually metered.)***

  ------------- -------- ----------- --------------- --------- -------- --------------- --------
  Development   Total    Structure   Resident-Paid                      Air             
  Name and      Number   Type        Utilities                          Conditioning?   
  Number        of Units                                                                

                                     Electric        Natural   Water/   Central         Window
                                                     Gas       Sewer                    

                                                                                        

                                                                                        

                                                                                        

                                                                                        

                                                                                        

                                                                                        
  ------------- -------- ----------- --------------- --------- -------- --------------- --------

> [Collection of Data and Analysis]{.underline} ***(If utilizing an
> actual/historical consumption-based method)***

The Agency will assist in the requisition of adequate actual historical
data from the local utility companies for Resident-Paid Utilities for
each dwelling unit category and unit size by development. If the utility
company requires signed resident releases (with or without account
numbers) the Agency will gather these resident releases and provide a
copy to the appropriate utility companies along with a specific request
for actual historical data, on agency letterhead. The study should be
conducted using a U. S. Department of Housing and Urban Development
(HUD) acceptable statistical model and methodology. Necessary
adjustments should be made for climatic conditions, unit vacancies, etc.

**II. [REQUIRED INFORMATION]{.underline}**

######## 

######## A. Required Certifications and Affidavits

> The following forms are attached and are part of the RFQ documents.
> Some forms require completion and your signature; these forms **[must
> be returned]{.underline}** with your quotation.

-   Firm Profile ***(Return with Quote)***

-   Certification and Representation of Offerors (Form HUD 5369-C)
    **(*Return with Quote)***

-   Certification for a Drug-Free Workplace (Form HUD 50070)

**(*Return with Quote)***

-   Instruction to Offers (Form HUD-5369-B)

-   General Contract Conditions (Form HUD 5370-C)

B. Documentation of Insurance

> Evidence of General Liability insurance in the amount of \$1,000,000
> and Workers' Compensation insurance in the amount required by the
> State of Alabama must be provided upon the award of a contract. 

III. **[TIMEFRAME FOR COMPLETION]{.underline}**

> The timeframe for completing the above services will be 120 days from
> the date of contract execution.

The PHA may not necessarily proceed with an award based on the initial
proposal quotations received and reserves the right to discuss contents
of such proposals, to obtain additional information, and to negotiate
changes in the proposals.

The PHA reserves the right to reject any or all quotations and to waive
any informality.  The PHA may also reject any proposals that are
incomplete or non-responsive and any proposals that are submitted after
the deadline. The PHA reserves the right to accept or reject, in part,
or reject all proposals and to re-solicit new proposals.

**IV. [SUBMISSION DEADLINE:]{.underline}**

> Please submit your quotation **no later than 4:30 p.m**. on
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**.**
>
> Facsimile and electronic transmissions [will be accepted]{.underline}.
>
> **[SUBMIT TO:]{.underline}**
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
>
> \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Housing Authority
>
> Fax Number: (\_\_\_\_) \_\_\_\_-\_\_\_\_\_\_\_\_
>
> E-mail: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**V. FIRM-FIXED PRICE (FFP) Fee:**  Compensation should be based on a
firm-fixed price (FFP) with no additional charges for routine expenses. 

#######  \$ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ 

***  (**Includes travel, if applicable, and expenses)*

NAME OF OFFEROR:   
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

ADDRESS:                 
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

CITY:                          
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

STATE & ZIP CODE: 
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

PHONE NO.:          \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ FAX
NO.:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

EMAIL:                       
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

SIGNATURE OF PERSON AUTHORIZED TO SIGN QUOTE:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

DATE

TITLE: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

PRINT NAME

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **3: DESCRIPTION OF UNIT (BUILDING/STRUCTURE) TYPES**

1.  **[Apartment/Walk-Up/Condominium/Garden Apartment/Low
    Rise]{.underline}**

> Building with a group of individual units with 2 or more common walls;
> attached to other units; separate entrances with common staircases; 3
> or more stories.
>
> • Each building will have an end unit, inside unit, top unit, bottom
> unit, etc.
>
> • Usually have units on both sides of building.
>
> • Apartments usually have one owner while condominiums are usually
> individually owned.

2.  **[High Rise Apartment]{.underline}**

> A multi-unit building; 5 or more stories; sharing one or more common
> entrances.

3.  **[Row House/Townhouse/Triplex/Fourplex/Multiplex]{.underline}**

> An individual unit attached to 2 or more other individual units; 2 or
> more common walls; separate ground level entrances; 1 or 2 story
> units.
>
> • Each building will have end units and inside units.
>
> • Fourplex units usually share 2 common walls; can be square-shaped or
> L-shaped.
>
> • Triplex building can be V-shaped.

4.  **[Semi-Detached/Duplex]{.underline}**

> Building with 2 individual housing units; with separate entrances; one
> common wall; 1 or 2 story units.

5.  **[Detached House]{.underline}**

> A detached building intended to house one family; sits on its own
> piece of land; not attached to another dwelling.

6.  **[Manufactured/Mobile Home]{.underline}**

> A detached movable or portable housing structure; at least 32 feet in
> length and over 8 feet in width; constructed to be towed on its own
> chassis and designed to be installed with or without a permanent
> foundation.
>
> • May be 2 or more units fitted together to make one residence.

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **4: SAMPLE RESIDENT RELEASE OF INFORMATION FORM**

**SAMPLE**

TO WHOM IT MAY CONCERN:

I agree that as long as I remain a resident of the Housing Authority of
\_\_\_\_ **([Agency Name)]{.underline}** \_\_\_\_, I authorize the
release of Utility Consumptions, costs and rates from \_\_\_\_\_\_
**[(utility supplier's name]{.underline})** \_\_\_\_\_**.** I understand
that this information will be kept confidential and will be used only
for program purposes. I further agree that a copy of this release shall
serve the same as an original.

Signed this Day of , [\_\_\_\_\_\_]{.underline}

Development Name: Number of Bedrooms: \_\_\_\_\_

Authorized Signature:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name: (please print clearly)
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Street Address:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

City, State, Zip Code:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

My **Electric** Company Account#
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

My **Gas** Company
Account#\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

My **Water** Company
Account#\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

***Important Note: Most utility suppliers will accept a copy this
Resident Release of Information Form. However, there are some utility
suppliers with their own authorized form, and some utility suppliers may
require additional information. Check with your local utility suppliers
to obtain their requirements for requesting release of information.***

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **5: SAMPLE INDIVIDUAL RELIEF REQUEST FORM**

Anytown PHA

555 Main Street

City, State, Zip

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Resident's Name Resident's Phone Number

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Resident's Address City, State, Zip

Type of Relief Requested:

\_\_\_ Surcharge(s) on excess consumption from Consumption Allowances

\_\_\_ Payment of utility billings in excess of my Utility Allowance

1\. Are there any members of your household that are 62 years of age or
older?

\_\_\_ Yes \_\_\_ No \_\_\_ Number

2\. Are there any disabled or ill members of your household?

\_\_\_ Yes \_\_\_ No \_\_\_ Number

3\. Does anyone in your household use medical equipment powered by a
utility?

\_\_\_ Yes \_\_\_ No

4\. If yes, what medical equipment is used?
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

5\. What utilities does your household pay for?

\_\_\_ Electric \_\_\_ Gas \_\_\_ Water \_\_\_Sewer \_\_\_Trash

6\. Which utility heats your home?

\_\_\_Electric \_\_\_ Gas \_\_\_Coal \_\_\_Wood \_\_\_Propane

\_\_\_Other (Please specify)
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

7\. Does your home have an air conditioner?

\_\_\_ Yes \_\_\_ No

8\. If yes, which type of system?

\_\_\_Window \_\_\_Central

Please state reason(s) for requesting relief:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

To the best of my/our knowledge, the information provided here is true
and correct. I/We understand that if we knowingly provide false,
misleading information, or failed to provide information, that this
request may be terminated and all surcharges will be re-instated.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Resident Head-of-Household Signature Date

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Interviewer Signature (if other than Manager) Date

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Housing or AMP Manager's Signature Date

+-----------------------------------------------------------------------+
| **FOR OFFICE USE ONLY**                                               |
|                                                                       |
| Account Number                                                        |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_      |
|                                                                       |
| Current Monthly Utility Allowance (total)                             |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                            |
|                                                                       |
| Amount for each applicable utility: Electric \$\_\_\_\_\_\_\_\_\_\_\_ |
| Gas \$\_\_\_\_\_\_\_\_\_\_                                            |
|                                                                       |
| Water \$\_\_\_\_\_\_\_\_\_\_ Sewer \$\_\_\_\_\_\_\_\_\_\_ Trash       |
| \$\_\_\_\_\_\_\_\_\_\_\_                                              |
|                                                                       |
| **Additional Information:**                                           |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\                                         |
| _\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ |
|                                                                       |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\ |
| _\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ |
|                                                                       |
| **MONTHLY AMOUNT OF RELIEF PROVIDED: \$ \_\_\_\_\_\_\_\_\_\_\_\_\_**  |
|                                                                       |
| Approved By: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ |
| Date \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                     |
|                                                                       |
| Denied By:                                                            |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Date     |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_                          |
|                                                                       |
| Reason(s) for Denial:                                                 |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\                                     |
| _\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ |
|                                                                       |
| \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\ |
| _\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ |
+-----------------------------------------------------------------------+

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **6: SAMPLE BOARD RESOLUTION**

**SAMPLE**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Housing Authority

Board Resolution No.:

**Resolution to Adopt Utility Allowance Schedule for Public Housing**

**Developments (as attached) Resident-Purchased Utilities**

**WHEREAS**, HUD regulation 24 CFR 966.502 requires that Public Housing
Agencies (PHA) establish allowances for resident purchased utilities for
all utilities purchased directly from the utility suppliers, and

**WHEREAS**: HUD requires the PHA to review their Utility Allowances at
least annually; and

**WHEREAS**, the PHA must revise its allowances for a utility category
if there has been a change of 10% or more in the utility rate since the
last time the utility allowance schedule was revised; and

**WHEREAS**, the PHA has completed its annual review and complied with
the provision to inform the residents of the planned allowances,
surcharges, and revisions; and

**WHEREAS**: It is the desire and intent of the Board of Commissioners
to comply with HUD regulations,

**NOW THEREFORE** **BE IT RESOLVED** that the Board of Commissioners of
the \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Housing Authority hereby approves and
adopts the Public Housing Utility Allowance Schedule for
resident-purchased utilities as presented on this the \_\_\_\_\_\_ day
of \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, 200\_\_\_\_\_.

The revised Public Housing Utility Allowance Schedule shall become
effective the day of , 200\_\_\_\_\_.

Signatures:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Chairperson - Board of Commissioners Secretary

**APPENDIX B: SAMPLE FORMS AND HELPFUL INFORMATION**

> **7: RESIDENTIAL CONSUMPTION OF ELECTRICITY BY END-USE**

  ---------------------- --------------- ------------- --------------- ------------- ---------- ------------- -- -- --
  **End Use/Appliance**  **Households\   **Units\      **Electricity                                                
                         (millions)**    (million)**   Consumption for                                              
                                                       2001**                                                       

                                                       **Annual                      **Total\   **Percent**         
                                                       Consumption**                 (billion                       
                                                                                     kWh)**                         

                                                       **kWh per\      **kWh per                                    
                                                       unit**          household**                                  

  Total Households       107.0                                         10,656        1,139.9    100.0               

                                                                                                                    

  Refrigerators          106.8           126.0         1,239           1,462         156.1      13.7                

                                                                                                                    

  Air-Conditioning                                                                                                  

    Central              57.5                                          2,796         160.6      14.1                
  Air-Conditioners                                                                                                  

    Room                 23.3            38.2          580             950           22.2       1.9                 
  Air-Conditioners                                                                                                  

    Total                                                                            182.8      16.0                

  Space Heating                                                                                                     

    Main Space-Heating   30.9                                          3,524         109.0      9.6                 
  Systems                                                                                                           

  Secondary              12.9                                          503           6.5        0.6                 
  Space-Heating                                                                                                     
  Equipment                                                                                                         

    Total                                                                            115.5      10.1                

                                                                                                                    

  Water Heating          40.8                                          2,552         104.1      9.1                 

                                                                                                                    

  Lighting (indoor and   107.0                                         940           100.5      8.8                 
  outdoor)                                                                                                          

                                                                                                                    

  Other Appliances       107.0                                         4,495         480.8      42.2                
  (total of list below)                                                                                             

    Clothes Dryer        61.1                                          1,079         65.9       5.8                 

    Freezer              34.2            37.9          1,039           1,150         39.3       3.5                 

    Furnace Fan          76.3                          500                           38.2       3.3                 

    Dishwasher           56.7                                          512           29.0       2.5                 

    Electric Range Top   59.7                          536                           32.0       2.8                 

    Electric Oven        47.8                          440                           21.0       1.8                 

    Microwave Oven       92.1                          209                           19.3       1.7                 

    Electric Toaster     36.1                          50                            1.8        0.2                 
  Oven                                                                                                              

    Coffee Makers        51.3                          116                           6.0        0.5                 

    Color TV             105.8           242.6         137             313           33.1       2.9                 

    VCR/DVD              96.1            161.9         70              118           11.3       1.0                 

    Cable Boxes          24.4                          120                           2.9        0.3                 

    Satellite Dish       13.9                          130                           1.8        0.2                 

    Personal Computer    54.2            65.8          262             318           17.2       1.5                 
  (Desk Top)                                                                                                        

    Personal Computer    14.2            16.6          77              90            1.3        0.1                 
  (Lap Top)                                                                                                         

    Printer with         12.6                          216                           2.7        0.2                 
  Fax/copier                                                                                                        

    Printer without      40.2                          45                            1.8        0.2                 
  Fax/copier                                                                                                        

    Pool Filter/pump     6.5                           1,500                         9.8        0.9                 

    Pool/Hot Tub/Spa     3.3                           2,300                         7.6        0.7                 
  Heater                                                                                                            

    Ceiling Fan          69.6            192.8         50              138           9.6        0.8                 

    Clothes Washer       84.1                          120                           10.1       0.9                 

    Waterbed Heater      5.5             6.4           900             1,035         5.7        0.5                 

    Well Water Pump      13.8                          400                           5.5        0.5                 

    Dehumidifier         12.1                          400                           4.8        0.4                 

    Evaporator Cooler    2.7                           1,183                         3.2        0.3                 

    Compact Stereo       36.5                          81                            3.0        0.3                 
  System                                                                                                            

    Component Stereo     36.3                          55                            2.0        0.2                 
  System                                                                                                            

    Portable Stereo      26.1                          19                            0.5        0.0                 
  (Boom Box)                                                                                                        

    Other Stereo System  3.1                           55                            0.2        0.0                 

    Large, Heated        4.5                           548                           2.5        0.2                 
  Aquarium                                                                                                          

    Answering Machine    65.7                          35                            2.3        0.2                 

    Cordless Telephone   81.5                          26                            2.1        0.2                 

    Rechargeable Tools   47.7                          43                            2.1        0.2                 

    Humidifier           15.6                          100                           1.6        0.1                 

    Automobile           2.3                           200                           0.5        0.0                 
  Block/Engine/Battery                                                                                              
  Heater                                                                                                            

    Residual                                                                                                        
  ---------------------- --------------- ------------- --------------- ------------- ---------- ------------- -- -- --

**Source: U.S. Department of Energy's Residential Energy Consumption
Survey 2001 (RECS) these are available at
http://www.eia.doe.gov/emeu/recs/recs2001/ publicuse2001.html**

**APPENDIX C: COPY OF HUD REGULATION 24 CFR 965, SUBPART E RESIDENT
ALLOWANCES FOR UTILITIES**

**TITLE 24\--HOUSING AND URBAN DEVELOPMENT**

**CHAPTER IX OFFICE OF ASSISTANT SECRETARY FOR PUBLIC AND INDIAN**

**HOUSING, DEPARTMENT OF HOUSING AND URBAN**

**DEVELOPMENT**

**PART 965: PHA-OWNED OR LEASED PROJECTS GENERAL PROVISIONS**

**Subpart** **E**\--**Resident Allowances for Utilities**

Source: 61 FR 7971, Feb. 29, 1996, unless otherwise noted.

**Sec. 965.501 Applicability.**

**(a)** This subpart E applies to public housing, including the Turnkey
III Homeownership Opportunities program. This subpart E also applies to
units assisted under sections 10(c) and 23 of the U. S. Housing Act of
1937 (42 U.S.C. 1437 et seq.) as in effect before amendment by the
Housing and Community Development Act of 1974 (12 U.S.C. 1706e) and to
which 24 CFR part 900 is not applicable. This subpart E does not apply
to Indian housing projects (see 24 CFR part 950).

**(b)** In rental units for which utilities are furnished by the PHA but
there are no check-meters to measure the actual utilities consumption of
the individual units, residents shall be subject to charges for
consumption by resident-owned major appliances, or for optional
functions of PHA-furnished equipment, in accordance with Sec. 965.502(e)
and 965.506(b), but no utility allowance will be established.

**Sec. 965.502 Establishment of utility allowances by PHAs.**

**(a)** PHAs shall establish allowances for PHA-furnished utilities for
all check-metered utilities and allowances for resident-purchased
utilities for all utilities purchased directly by residents from the
utilities suppliers.

**(b)** The PHA shall maintain a record that documents the basis on
which allowances and scheduled surcharges, and revisions thereof, are
established and revised. Such record shall be available for inspection
by residents.

**(c)** The PHA shall give notice to all residents of proposed
allowances, scheduled surcharges, and revisions thereof. Such notice
shall be given, in the manner provided in the lease or homebuyer
agreement, not less than 60 days before the proposed effective date of
the allowances or scheduled surcharges or revisions; shall describe with
reasonable particularity the basis for determination of the allowances,
scheduled surcharges, or revisions, including a statement of the
specific items of equipment and function whose utility consumption
requirements were included in determining the amounts of the allowances
or scheduled surcharges; shall notify residents of the place where the
PHA\'s record maintained in accordance with paragraph (b) of this
section is available for inspection; and shall provide all residents an
opportunity to submit written comments during a period expiring not less
than 30 days before the proposed effective date of the allowances or
scheduled surcharges or revisions. Such written comments shall be
retained by the PHA and shall be available for inspection by residents.

**(d)** Schedules of allowances and scheduled surcharges shall not be
subject to approval by HUD before becoming effective, but will be
reviewed in the course of audits or reviews of PHA operations.

**(e)** The PHA\'s determinations of allowances, scheduled surcharges,
and revisions thereof shall be final and valid unless found to be
arbitrary, capricious, an abuse of discretion, or otherwise not in
accordance with the law.

**Sec. 965.503 Categories for establishment of allowances.**

Separate allowances shall be established for each utility and for each
category of dwelling units determined by the PHA to be reasonably
comparable as to factors affecting utility usage.

**Sec. 965.504 Period for which allowances are established.**

**(a)** PHA-furnished utilities. Allowances will normally be established
on a quarterly basis; however, residents may be surcharged on a monthly
basis. The allowances established may provide for seasonal variations.

**(b)** Resident-purchased utilities. Monthly allowances shall be
established. The allowances established may provide for seasonal
variations.

**Sec. 965.505 Standards for allowances for utilities.**

**(a)** The objective of a PHA in designing methods of establishing
utility allowances for each dwelling unit category and unit size shall
be to approximate a reasonable consumption of utilities by an
energy-conservative household of modest circumstances consistent with
the requirements of a safe, sanitary, and healthful living environment.

**(b)** Allowances for both PHA-furnished and resident-purchased
utilities shall be designed to include such reasonable consumption for
major equipment or for utility functions furnished by the PHA for all
residents (e.g., heating furnace, hot water heater), for essential
equipment whether or not furnished by the PHA (e.g., range and
refrigerator), and for minor items of equipment (such as toasters and
radios) furnished by residents.

**(c)** The complexity and elaborateness of the methods chosen by the
PHA, in its discretion, to achieve the foregoing objective will depend
upon the nature of the housing stock, data available to the PHA and the
extent of the administrative resources reasonably available to the PHA
to be devoted to the collection of such data, the formulation of methods
of calculation, and actual calculation and monitoring of the allowances.

**(d)** In establishing allowances, the PHA shall take into account
relevant factors affecting consumption requirements, including:

**(1)** The equipment and functions intended to be covered by the
allowance for which the utility will be used. For instance, natural gas
may be used for cooking, heating domestic water, or space heating, or
any combination of the three;

**(2)** The climatic location of the housing projects;

**(3)** The size of the dwelling units and the number of occupants per
dwelling unit;

**(4)** Type of construction and design of the housing project;

**(5)** The energy efficiency of PHA-supplied appliances and equipment;

**(6)** The utility consumption requirements of appliances and equipment
whose reasonable consumption is intended to be covered by the total
resident payment;

**(7)** The physical condition, including insulation and weatherization,
of the housing project;

**(8)** Temperature levels intended to be maintained in the unit during
the day and at night, and in cold and warm weather; and

**(9)** Temperature of domestic hot water.

**(e)** If a PHA installs air conditioning, it shall provide, to the
maximum extent economically feasible, systems that give residents the
option of choosing to use air conditioning in their units. The design of
systems that offer each resident the option to choose air conditioning
shall include retail meters or check-meters, and residents shall pay for
the energy used in its operation. For systems that offer residents the
option to choose air conditioning, the PHA shall not include air
conditioning in the utility allowances. For systems that offer residents
the option to choose air conditioning but cannot be check-metered,
residents are to be surcharged in accordance with Sec. 965.506. If an
air conditioning system does not provide for resident option, residents
are not to be charged, and these systems should be avoided whenever
possible.

**Sec. 965.506 Surcharges for excess consumption of PHA-furnished
utilities.**

**(a)** For dwelling units subject to allowances for PHA-furnished
utilities where check-meters have been installed, the PHA shall
establish surcharges for utility consumption in excess of the
allowances. Surcharges may be computed on a straight per unit of
purchase basis (e.g., cents per kilowatt hour of electricity) or for
stated blocks of excess consumption, and shall be based on the PHA\'s
average utility rate. The basis for calculating such surcharges shall be
described in the PHA\'s schedule of allowances. Changes in the dollar
amounts of surcharges based directly on changes in the PHA\'s average
utility rate shall not be subject to the advance notice requirements of
this section.

**(b)** For dwelling units served by PHA-furnished utilities where
Check-meters have not been installed, the PHA shall establish schedules
of surcharges indicating additional dollar amounts residents will be
required to pay by reason of estimated utility consumption attributable
to resident-owned major appliances or to optional functions of
PHA-furnished equipment. Such surcharge schedules shall state the
resident-owned equipment (or functions of PHA-furnished equipment) for
which surcharges shall be made and the amounts of such charges, which
shall be based on the cost to the PHA of the utility consumption
estimated to be attributable to reasonable usage of such equipment.

**Sec. 965.507 Review and revision of allowances**.

**(a)** Annual review. The PHA shall review at least annually the basis
on which utility allowances have been established and, if reasonably
required in order to continue adherence to the standards stated in Sec.
965.505, shall establish revised allowances. The review shall include
all changes in circumstances (including completion of modernization
and/or other energy conservation measures implemented by the PHA)
indicating probability of a significant change in reasonable consumption
requirements and changes in utility rates.

**(b)** Revision as a result of rate changes. The PHA may revise its
allowances for resident-purchased utilities between annual reviews if
there is a rate change (including fuel adjustments) and shall be
required to do so if such change, by itself or together with prior rate
changes not adjusted for, results in a change of 10 percent or more from
the rates on which such allowances were based. Adjustments to resident
payments as a result of such changes shall be retroactive to the first
day of the month following the month in which the last rate change taken
into account in such revision became effective. Such rate changes shall
not be subject to the 60 day notice requirement of Sec. 965.502(c).

**Sec. 965.508 Individual relief.**

Requests for relief from surcharges for excess consumption of
PHA-purchased utilities, or from payment of utility supplier billings in
excess of the allowances for resident-purchased utilities, may be
granted by the PHA on reasonable grounds, such as special needs of
elderly, ill or disabled residents, or special factors affecting utility
usage not within the control of the resident, as the PHA shall deem
appropriate. The PHA\'s criteria for granting such relief, and
procedures for requesting such relief, shall be adopted at the time the
PHA adopts the methods and procedures for determining utility
allowances. Notice of the availability of such procedures (including
identification of the PHA representative with whom initial contact may
be made by residents), and the PHA\'s criteria for granting such relief,
shall be included in each notice to residents given in accordance with
Sec. 965.502(c) and in the information given to new residents upon
admission.

**APPENDIX D: GLOSSARY OF KEY TERMS AND DEFINITIONS**

This glossary defines terms applicable to the development of utility
allowances (UAs). It also defines programmatic terms where they have
impact on utility allowances.

**30-Year Averages:** Are used for the process of normalizing
consumption data for weather. When adjusting utility consumption with
the 30-year Heating Degree Day factor, the PHA does not to obtain
consumption data every year.

**Actual Savings:** The difference in consumption before and after
implementation of efficiency improvements. 

**Additional Subsidy or Add-on Subsidy:** A HUD incentive for
resource-efficiency improvements in housing authorities. The housing
authority obtains non-HUD financing to pay for the retrofit work and HUD
provides an additional operating subsidy in an amount sufficient to
amortize payments for the loan. The term of the loan is limited to 12
years. 

**Allowable Utility Consumption Level (AUCL):** The level of consumption
of fuel, water and sewer usage to be used when budgeting for
authority-provided utilities (using HUD Form 52722A). The AUCL is
computed using the rolling base. 

**Allowable Utilities Expense Level (AUEL):** The estimated level of
cost for utilities, computed using the HUD Form 52722A, for the upcoming
year\'s budget. The AUEL is computed by multiplying the rolling base by
the rates in effect at the time of the budgeting process. 

**Asset Management**: The process of maximizing the value of a real
estate asset based on the investment objectives or mission of an
organization or owner.

**Base Load:** The sum of all allowable utility consumptions (except air
conditioning for Public Housing).

**Bin:** Ranges of temperatures grouped together for analysis purposes.

**Block Rate:** Refers to a block or stepped rate structure in utility
rate schedules.

**British Thermal Unit (Btu):** The amount of energy required to heat a
pound of water 1 degree Fahrenheit. The Btu is the unit commonly used in
calculating energy requirements. (It can apply to any energy use, not
just heating water; for example, air conditioners are often rated by
their Btu capacity.)  

**Burnertip:** The final point of delivery of fuel in gas-fired
furnaces, boilers and other equipment where the gas mixes with oxygen
and the flame is produced. 

**CCF:** One hundred cubic feet of natural gas or water. For natural
gas, a CCF is approximately equivalent to one therm of energy.

**Calibration:** The process of checking or adjusting a measuring
instrument, such as a check-meter. Check-meters need to be calibrated
periodically to ensure accurate measurement.

**Central Tendency:** A measure of the \"typical\" value in a collection
of numbers or a data set. The mean (average) and the median are two
different measures of central tendency.

**Check-meters:** Sub-metering installed to record the energy use of
individual apartments where master meters (or one meter per building)
record the energy use of the entire building or series of buildings. 

**Check-metered Utilities:** PHAs install separate sub-meters (commonly
called check-meters) in addition to the master-meter. These check-meters
are used to measure consumption by individual dwelling unit. The PHA
owns these check-meters, and as with master-metered utilities, the PHA
pays the utility cost directly to the utility provider.

**Compliance Audits:** Energy or water use audits required by HUD to be
performed on housing authority buildings every 5 years. These audits are
regulated by 24 CFR 965.304.

**Consumption-Based Methodology:** One of two suggested methods that can
be used to establish utility allowances. (See also engineering-based
methodology.) This method is based on actual consumption data from
utility bills or check-meter readings. These data are used to estimate
the amount of energy or water a household should reasonably require.

**Consumption Data:** Records obtained from the utility company or from
check-meter readings that show how much energy or water was consumed
within a given period of time.

**Cooling Degree Days (CDD):** A measure of the severity of the summer
in a given locality: the more cooling degree days, the hotter the
summers. Cooling degree days are the difference between 65 degrees F and
the daily mean (average) temperature when the latter is more than 65
degrees F.  

**Curtailment:** A notice issued by a utility to a customer with
interruptible service to stop or reduce the use of its product (gas or
electricity) during peak system usage periods.

**Customer Charge:** See meter charge.

**Data Set:** A set of consumption records for individual dwelling units
used to establish an allowance for a given allowance category.  

**Demand-Side Management (DSM):** Utility programs developed to reduce
demands on the utilities\' generation, transportation, and distribution
systems by improving the efficiency with which their customers use
energy or shifting the time of energy use.

**Design Temperature Differential:** The design temperature
differential, or design range, is the difference between the indoor
temperature in winter and the outdoor design temperature in winter. The
design temperature differential is used in calculating the space heating
requirements of a dwelling unit under the engineering-based methodology.

**End-Use:** The functional application or use of a utility, such as
space heating, water heating, cooking, lighting, operating appliances,
or air conditioning.  

**Energy Efficiency Rating (EER):** A measure of the energy efficiency
of an appliance or piece of equipment.

**Energy Performance Contracting (EPC):** See Performance Contracting.

**Engineering-Based Methodology:** One of two suggested methods that can
be used to establish utility allowances. (See also consumption-based
methodology.) This method is based on engineering calculations and other
technical information that is used to estimate the amount of energy or
water a household should reasonably require.

**Equal Payments Plan:** A payment plan offered by the local utility
company to the resident whereby the seasonal variation in monthly bills
is eliminated. A resident on an \"equal payments plan\" pays 12 equal
monthly bills every year, even though utility use may go up or down with
the seasons.  

**Energy Savings Guarantee:** See Savings Guarantee. 

**Energy Services Agreement:** A written agreement, between a housing
authority and an energy services company outlining the work to be done
under a performance contract. For housing authorities, it must contain
the following elements: savings guarantee, scope of work, savings
calculation methodology and financing terms. It must be approved by the
local HUD office and should incorporate the HUD regulations for
performance contracting.

**Energy Services Company (ESCO):** A company that specializes in
managing energy and water conservation retrofit projects. The ESCO may
perform any or all of the following services: auditing, developing
packages of recommended measures, arranging financing, installing or
overseeing installation of measures, resident and staff education,
equipment commissioning, maintenance, measuring, verifying, and
guaranteeing savings. 

**Escalation Rate:** The rate of change over time of a value such as
energy costs. In many performance contracts, it is a stipulated rate of
increase in utility rates used in energy savings calculations and
guarantees.

**ESCO:** See Energy Services Company. 

**Excess Savings:** The difference between the amount needed to cover
the debt in a performance contract and the actual savings.

**Firm Service:** Utility service that is provided to the customer at
all times, even during peak usage periods such as very hot or cold
weather. The utility is required to have enough capacity and product to
serve the customer during these peak periods. The non-interruptible
nature of this type of service results in a much higher rate for firm
service than for interruptible service. 

**Fuel Charge:** A fuel charge is an adjustment to the cost of fuel
based on the utility\'s actual cost for fuel. The utility is not allowed
to make a profit on this portion of the bill and simply passes these
costs through to the consumer.

**General Purpose Bonds:** Bonds that are financially certified by the
entity issuing the bond. Bonds are seldom used for conservation projects
because the high fixed costs of issuing this type of financing make it
an expensive option for funding the relatively small dollar amounts
needed for these projects. 

**Heat Loss:** The rate of heat transfer, in Btus per hour, from
occupied space to the outdoors. Losses occur through walls, ceilings and
floors of a structure, and through cracks around windows, doors, etc.
The heat loss depends on the dwelling unit size, construction and design
of the housing development, the physical condition of the development,
amount of insulation in the walls and ceilings, the assumed indoor
temperature, and various other factors.  

**Heating Degree Days (HDD):** A measure of the severity of the winter
in a given locality: the more heating degree days, the colder the
winters. Heating degree days are the difference between 65 degrees F and
the daily mean (average) temperature when the latter is less than 65
degrees F.  

**Housing and Community Development Act of 1987:** Key legislation that
establishes the regulatory framework for improving the energy efficiency
in public housing by providing financial incentives for PHAs to use
non-federal funds for conservation retrofits and by allowing housing
authorities to retain a portion of the savings they negotiate for rate
reductions. 

**HUD Form 52722-A:** Used by the PHA to estimate utility costs for the
upcoming year\'s budget. 

**HUD Form 52722-B:** Used by the PHA to reconcile actual utility costs
with the estimated costs. 

**HUD USER:** An information source, established in 1978 by HUD\'s
Office of Policy Development & Research (PD&R), for Federal Government
reports and information on housing-related issues.

**Hundred Cubic Feet (ccf):** A common unit of measurement for natural
gas and water. One ccf of natural gas is approximately equal to one
therm of natural gas. One ccf of water is equal to 748 gallons of water.
 

**Individual Meters (retail meters):** One utility meter per apartment.
Can be contrasted with a master meter where a single meter serves an
entire building or complex. 

**Interruptible Service:** Utility service that is available at a
reduced rate because the utility has an agreement with the customer that
it can interrupt delivery of service during peak system demand periods.

**Kilowatt-hour (kWh):** The common unit of measurement for electricity.
One kWh is 1,000 watt-hours, or the amount of electricity consumed by a
100-watt lamp in ten hours. One kWh is equal to 3,413 Btus.  

**Local Distribution Company (LDC):** The local utility company that
provides energy distribution services (i.e., wires and pipes).

**Low-Income Weatherization Assistance Program (WAP):** A
federally-funded program that provides conservation services and
weatherization assistance to households with incomes of below 150
percent of federal poverty level.

**Marketer:** A power marketer is an agent for power generation projects
that sells wholesale power or fuel. Marketers also may arrange for
transmission and distribution of the energy provided. 

**Master Metering:** One meter that serves an entire building or a
campus of buildings. 

**MCF:** A unit of measurement for natural gas or water that is equal to
1,000 cubic feet. At sea level, one MCF of gas is equal to 1,000,000
Btus.

**Mean:** A measure of the central tendency of a data set, the mean is
the average value in a data set. It is determined by adding all the
values and dividing the sum by the number of values in the data set.

**Median:** A measure of the central tendency of a data set, the median
is the middle value in a data set, when the values are ranked from
lowest to highest.  

**Meter Charge:** A flat monthly rate assigned to each utility meter to
cover the local distribution companies fixed costs in servicing the
account, such as meter reading and billing.

**Non-Allowable End-Use:** An end-use whose consumption is excluded from
the utility allowance because this use is considered to be a luxury
rather than a necessity. It is left to the discretion of individual PHA
to distinguish between luxuries and necessities based on local custom
and usage patterns. For example, in some regions ceiling fans are seen
as an allowable use because of the local climate, whereas in other
regions such fans are viewed as luxuries.

**Normalization:** A mathematical process that adjusts for differences
among data from varying sources in order to create a common basis for
comparison. In the context of utility allowances, under the consumption
based methodology, a PHA may use a fixed set of data on consumption for
one or more years, with this data normalized (adjusted) using 30-year
weather averages. The normalization corrects for the fluctuations in
weather from year to year so that the allowances are calculated on more
typical weather patterns.

**Outdoor Design Temperature:** The lowest outdoor winter temperature
that could occur in a given location, based on a 99 percent confidence
level. This temperature is used to determine the design temperature
differential, which is used in calculating the space heating
requirements of a dwelling unit using the engineering-based methodology.
 

**Peak Demand:** The greatest electric demand reading during a specified
period. Typically, an electric utility charge for the greatest monthly
demand measured in 15-minute intervals. The unit of demand is the
kilowatt (kW).

**Performance Contracting:** A mechanism to implement resource
efficiency improvements with minimal up-front costs. It uses savings
resulting from the efficiency project to pay for the work over time. 

**Persistence of Savings:** Energy or water savings that persist beyond
an initial post-retrofit period. Lack of persistence may jeopardize the
ability to re-pay loans in performance contracting, unless the ESCO
provides a guarantee of savings. 

**Per Unit Monthly (PUM):** Authority-provided utility costs computed
per apartment unit per month. 

**PHA-Provided (or Furnished) Utilities:** Utilities that are paid for
by the housing authority rather than the resident. Authority-provided
utilities may be either master-metered, master-metered with check-meters
or individual meters. 

**Plug Load:** All electrical use except space heat, air conditioning,
and water heating. Refrigeration and cooking are sometimes added to this
list of exclusions.

**Princeton Scorekeeping Method (PRISM):** A utility billing analysis in
which at least 12 months of energy consumption is adjusted for
variations in weather. 

**Project-based Utilities:** See PHA-provided utilities. 

**Public Utility Commission:** A commission at the state level that is
comprised of either state-elected or appointed officials who regulate
utilities such as electric and telephone utilities. The name for this
regulatory may differ slightly between states. Public Service Commission
is another common name. 

**Requested Budget Year:** The period of time following the current
fiscal year for which the housing authority is developing a budget. 

**Resident-Paid (or Purchased) Utilities:** Utilities that are paid for
by the resident rather than the PHA. Utilities are billed through
individual meters and the residents are responsible for paying the
bills. Residents receive utility allowances for these utilities.

**Rolling Base:** The rolling base period is the three-year period used
to calculate baseline utility use when computing the Allowable Utility
Consumption Level (AUCL) for a PHA facility. It is an average of the
three years actual consumption prior to the current fiscal year. 

**Savings Guarantee:** In a performance contract, an ESCO guarantee that
the average energy and/or water savings resulting from the conservation
retrofit will be equal to that needed to cover the debt service and
other fees associated with the project. An ESCO and a housing authority
may chose to guarantee an amount higher than that needed to cover
project costs. 

**Section 8 Housing Choice Voucher Program (HCVP):** The Section 8 HCV
program is designed to increase the housing choices available to very
low-income households by making privately-owned rental housing
affordable to them. It provides rent subsidies, either rental
certificates or vouchers, on behalf of eligible tenants. These subsidies
usually equal the difference between 30 percent of the household\'s
adjusted income and the HUD-approved fair market rent (for certificates)
or the PHA-approved payment standard (for vouchers).  

**Shortfall:** A negative difference between the amounts needed to cover
the debt service and other fees involved in a project (usually the
amount of the guaranteed savings) and the actual savings. The ESCOs
savings guarantee should cover this shortfall. 

**Step Rate:** See block rate.

**Space Heating:** The warming of a dwelling unit to a reasonable
temperature in the wintertime. Space heating can be provided by any type
of heating system; it is not limited to heating provided by portable
space heaters.

**Statistically Valid Sample:** A data set that contains enough data to
obtain a reasonable representation of the typical consumption for a
given allowance category. The number of records (or sample size)
required to make a sample statistically valid depends on how widely the
consumption data vary among dwelling units within an allowance category.

**Surcharge:** The amount a PHA charges a household, in addition to
Resident Rent, for consumption of check-metered utilities in excess of
the utility allowance, or for non-allowable end-uses.

**Resident Rent:** The amount paid monthly by the household as rent to
the PHA. Where all utilities are supplied by the PHA, Resident Rent
equals Total Resident Payment. Where some or all of the utilities are
paid directly by the resident to the utility company, then Resident Rent
equals Total Resident Payment minus the allowance for resident-purchased
utilities.  

**Tariff:** The allowed rate to be charged a utility customer. A
published, regulated rate schedule. 

**Tax-Exempt Revenue Bonds:** Traditional sources of low-interest
financing for municipal agencies. Bonds issued by a tax-exempt entity. 

**Therm:** A common unit of measurement of natural gas is equal to
100,000 Btus of energy. Depending on its quality, natural gas typically
contains approximately 1,000 Btu per cubic foot. Therefore, a therm of
natural gas usually is equal to about 100 cubic feet.

**Total Tenant Payment:** Generally 30 percent of a resident\'s adjusted
income.  

**Transportation Company:** A company that moves and delivers gas or
electricity from a generation or production facility to a local utility
company.

**Unbundling:** A term used to describe how consumers will be charged
for electricity in a restructured utility environment. It is breaking up
the current energy service package into separate components such as
supply, transmission, and distribution.

**Utility:** Electricity, gas, propane, oil, water and sewer service,
and garbage collection. Telephone service is not considered a utility
for the purposes of this Website.  

**Utility Allowance:** Per-apartment-unit allowance for resident-paid or
check-metered utility expenses that are set annually by the housing
authority using a variety of means. The utility should be set to cover
the utility costs of a reasonably conserving resident. 

**WAP:** See Low-Income Weatherization Assistance Program 

**Wattage:** A measure of the electric power required by a device such
as a light bulb or appliance.  

**Weatherization:** Improving the thermal integrity of buildings by the
installation of energy saving measures or equipment.

**APPENDIX E: ACRONYMS**

The following acronyms are applicable to the development of utility
allowances (UAs) and have been used in this UA Guidebook.

  ------------- ------------------------------------------------------------
  **ACRONYM**   **DEFINITION**

  A/C           Air Conditioning

  AMP           Asset Management Project

  ASHRAE        American Society of Heating Refrigeration and Air
                Conditioning Engineers

  BR            Bedroom

  BTU           British Thermal Unit

  CCF           Hundred Cubic Feet

  CFR           Code of Federal Regulations

  DOE           U.S. Department of Energy

  ECM           Energy Conservation Measures

  ECMs          Energy Conservation Measures

  EF            Energy Factor

  EMS           Energy Management Systems

  EPA           Environmental Protection Agency

  EPC           Energy Performance Contracting

  ESCO          Energy Services Company

  ESP           Energy Service Providers

  FEMP          Federal Energy Management Program

  GPM           Gallons per minute

  HCVP          Section 8 Housing Choice Voucher Program

  HDD           Heating Degree Day

  HERS          Home Energy Rating System

  HQS           Housing Quality Standards

  HUD           U.S. Department of Housing and Urban Development

  HVAC          Heating, Ventilation, and Air Conditioning

  IECC          International Energy Conservation Code

  IRC           HUD's Information Resource Center

  KWH           Kilowatt Hour

  NOAA          National Oceanic and Atmospheric Administration

  PHA           Public Housing Agency

  PNA           Physical Needs Assessment

  QC            Quality Control

  RECS          Residential Energy Consumption Survey (U.S. DOE's)

  TTP           Total Tenant Payment

  UAs           Utility Allowances
  ------------- ------------------------------------------------------------

**APPENDIX F: ENERGYSTAR® PRODUCTS**

Following is a partial list of ENERGYSTAR® products:

>  Air-source heat pumps
>
>  Appliances
>
>  Boilers
>
>  Ceiling fans
>
>  Central A/C
>
>  Clothes washers
>
>  Compact fluorescent light bulbs
>
>  Dehumidifiers
>
>  Dishwashers
>
>  Exit signs
>
>  Furnaces
>
>  Geothermal heat pumps
>
>  Heating & cooling equipment
>
>  Home sealing (insulation)
>
>  Lighting
>
>  Office equipment
>
>  Programmable thermostats
>
>  Refrigerators
>
>  Room A/C
>
>  Ventilating fans
>
>  Windows, doors, & skylight
>
> Note: ENERGYSTAR® also qualifies new homes to earn the ENERGYSTAR®
> certification label. (see www.energystar.gov/new homes)

**INDEX**

**(Note: bold text indicates chapter or section headings and bold
numbers indicate the main page(s) containing the heading or that topics
information.)**

**A**

**Acronyms:** **Appendix E** page **100**

**Actual/Historical Consumption-Based Method**: 6, 9, 12, **15**, 17,
35,

**Adjust Consumption Data**: **28**

**Adjusting for Climate Changes**: **30**

**Adjusting for High Users and Low Users**: 28, **32**

Adjusting for non-allowable consumption data: 21

**Adjusting Problem Data**: **29**

**Adopting Utility Allowances**: **57, Appendix B6** page **85**

Air Conditioning, 10, 11, 12, 16, 17, 21, 22, 36, 37, 38, 40, 66, 67

**Air Conditioning Consumption Data**: **21**

**Air Conditioning Estimates**: **37**

**Allowable Utility Consumption**: **15**

Allowance category/categories: 2, 15, 16, 17, 20, 22, 23, 24, 25, 27,
28, 29, 32, 48, 49, 50, 63

**Annual Review of Allowances**: 4, 5, 9, 31, **51-53**, **Appendix C**
pages **88-91**

**Annual Review Update Study**: 6, 7, 9, 13, 44, **51**

ASHRA (American Society of Heating, Refrigeration & Air Conditioning
Engineers): 36

Asset Management/AMPs: 2, 4, 12, 20-22, 24, 32, 50, 65

Average Consumption, 7, 9, 13, 20, 21, 23, 24, 25, 27, 28, 30, 32, 33,
44

**B**

**Base Loads**: **36**, 37, 40

Billing (data, dates, methods, rates, records, reports): 5, 9, 18, 20,
21, 23, 24, 25, 45, 47

**Board Resolution:** 50, 57, **Appendix B6** page **85**

Btu (British thermal unit): 39, 42-43

Building/structure types: 9, 23, 24, **Appendix B3** page **81**

Bulk purchased utilities: 47

**C**

**Calculate Typical Consumption Averages**: **27**

Calculating consumptions: 1, 19, 21, 23-25, 27-28

Calculating heat loss: 36

Calculating surcharges 3

**Calculating Utility Allowances**: 12, 13, 15, 20, 21, 33, 41,
**44-50**, 52

**Change in Utility Rates and Charges**: **7**, 51, 52

Check-meter/check-metered utilities: 3, 5, 19, 20, 28, 31, 32, 45

Climate data/climatic conditions: 16, 22, 28, 30, 31, 35-36, 38

Coal: 2, 16

Cooking: 2, 11, 12, 15-16, 40, 48

Consumption Allowance(s): 3, 7, 9, 13, 20, 23, 28, 30, 32-33, 45, 48,
52, 54, 57

**Consumption-Based Method**: **1**, 2, 9, 12, 13, **15**, 35, 52

**Consumption Study**: **6**, **9**, 21, 44, 51

Conservation measures: 4, 51, 61-63, 64

Conversion Charts: 41-43

**Converting Consumption Allowances**: **33**

**D**

Data Collection: 19, 62

Data Types: 20

Data Report(s): 23

**Define Utility Allowance Categories**: **22**

Determining average consumption: 7

Determining the sample size needed: 25

Deregulation of Utilities: 10, 44-45

DOE (Department of Energy)/RECS: 17, 36, 40, 64:

**Domestic Hot Water Heating Estimates**: **38**

Documentation: 7, 27, 34, 43, 54, 55, 73

**E**

Efficiency Characteristics: 36

Electricity: 2, 15-16, 20, 22, 24, 36, 48

**Eliminating Problem Data**: 25, 26, **29**

Energy Audit: 61-65

Energy Audit Regulations: 64

Energy conservation education: 58

Energy conservative household: 2, 3, 5, 11, 28, 32, 35

Energy conservation measures (ECMs): 4, 51, 61-63, 64

Energy conservation code (IECC): 59

**Energy Efficiency**: **58**

Energy efficiency measures: 58

**Energy Efficiency Opportunities**: **63**

**Energy Efficient Utility Allowances: 43**

Energy guide: 40

Energy Management Systems (EMS): 59, 61, 66

**Energy Performance Contracting**: **4**, 65-66

**Energy Service Companies (ESCOs):** 13, 35, 58, 61, 62, **65-67**

Energy Star®/Products: 43, 58, 65, **Appendix F** page **101**

Engineering Audit: 61

Engineering calculations & benchmarks: 11-12, 17, 35, 51

**Engineering-Based Method**: 1, 9, 11-13, 19, **35**, 51

Environmental Protection Agency (EPA): 36, 55

Equipment/system testing: 37, 43, 61-62, 63

**Estimating the Energy Consumption Requirements for Laundry**: **39**

**Estimating the Energy Consumption Requirements for Trash/Garbage**:
**33**

**Estimating the Energy Consumption Requirements without Water**: **40**

**Estimated Readings**: 18, 27, **30**

Excess usage: 3, 48, 51

Excess consumption: 5, 17

**F**

Federal Energy Management Program (FEMP): 58

Freezer: 3, 5, 17

Fuel Oil: 2, 16, 36, 49

**G**

Garbage/Trash: 2, 15-16, 33, 46, 54

Gathering utility rates and charges: 21

**General Engineering Audit**: **61**

**Glossary of Key Terms and Definitions**: Appendix D pages 92-99

Grace factor: 32

**H**

Heat loss: 11, 36, 39

Heating Degree Days (HDD): 22, 30-31

Hot water heating: 2, 6, 11, 15, 38-39

**Housing Occupancy Data**: **21**

HUD Regulations:

> Energy Audit (24 CFR 965, Subpart C): 64
>
> Energy Conservation Measures (24 CFR 968.115): 65
>
> Energy Performance Contracting (24 CFR 900): 4, 61, 65
>
> Public Housing Utility Allowances (24 CFR 965, Subpart E): 1, 5, 16,
> 34, 50, 51, 53, 61, 64, **Appendix C pages 88-91**
>
> Rental Integrity, Determining TTP (24 CFR Part 5.628(a): 3

**HUD Review of Utility Allowances**: **57**

**I**

**Implementation of Consumption and Utility Allowances**: **54**

Incomplete data: 10

**Incremental Investment Analysis**: **63**

Individual meter: 43, 49

**Individual Relief**: 5, 16, 55, **56, Appendix B 5** pages **83-84**

**Individual Relief Form Sample**: 16, **Appendix B 5** pages **83-84**

Individual check-meters: 20

**Individually Metered Utilities**: **49**

Information release form: 10, 18, **Appendix B4** page **82**

**Information Resources**: **Appendix A** pages **68-70**

**Investment Grade Energy Audit**: **62**

International Energy Conservation Code (IECC): 59

**L**

**Lack of Support Documentation**: 7

Laundry: 39, 41

Lifestyle issues: 10, 12

Lighting: 2, 16, 40, 48, 66, 67

Lower rates for low-income families: 55

**M**

Maintenance: 9, 29, 36, 39, 40, 61, 62, 63, 65, 66, 67

Master-meter: 3, 5, 45

**Metering Systems**: **45**

**Methods for Calculating/Determining Utility Allowances**: **9**

Missing data/information: 5, 11, 19, 25, 29, 30

Modernization: 6, 19, 29, 43, 51, 52, 61, 63, 64, 65

**N**

National Oceanic and Atmospheric Administration (NOAA): 22

Natural Gas: 2, 20, 22, 24, 36, 48

**New Consumption Study**: **6,** 51

**Non-Allowable Utility Consumptions/Cost**: **15-17**, 21-22

Normalizing the data for weather conditions: 36

**Notice to Residents**: **55**

Notifying residents: 5, 53, 55, 56, 57

**O**

**Other Electric Appliances**: **16**

Over-Housed and Under-Housed residents: 21

**P**

Performance testing: 37, 43, 61-62, 63

PHA-Furnished/Provided utilities: 3, 4, 5, 16, 17, 20, 22, 44, 48, 54

Physical characteristics: 2, 9

Physical conditions: 36

**Physical Inspection**: **62**

Physical Needs Assessment: 63-64

Post or display utility allowances: 50, 55, 57

Privacy issues/Private information: 10, 44

Problem/problematic data: 25, 26, 29

Propane: 2, 36, 49

**Q**

Quality control (QC): 21

**R**

**Rate Structures**: **45**

> Service Flat Fee/Charge
>
> Monthly Fee/Charge
>
> Monthly Minimum Charge
>
> Base Energy Rate
>
> Cost of Fuel Charge
>
> Fees & Surcharges
>
> Bulk Purchased utilities
>
> Taxes

Reasonable consumptions/utility costs: 3, 5, 9, 12, 28, 32, 35, 54

Recycling: 2, 16, 33

Refrigerators/refrigeration: 2, 5, 6, 17, 40

Release of Information Form: 10, 18-19, **Appendix B4** page **82**

Request for Proposal (RFP): 13, **Appendix B1** pages **71-76**

Request for Quotation (RFQ): 13, **Appendix B2** pages **77-80**

Resident lifestyle issues: 10, 12

Resident-Paid Utilities: 2, 4, 5, 18, 20, 33, 54

Residential Energy Consumption Survey (RECS): 40

Resources: **Appendix A** pages **68-70**

**Revising Problem Data**: **29**

**S**

**Sample Utility Bill**: **48**

Sampling: 9, 11, 25, 26, 27

**Sanitation**: **16**

Scheduled surcharges: 55, 56, 57

Selecting a method: 12

Sewer: 2, 15-16, 49

**Significant Change**: **6**, **52**

Sixty-day (60-day) notice requirements: 5, 53, 56

**Sort the Data into Allowance Categories: 24-26**, 29

Space Heating: 2, 6, 10-12, 15, 36

**Space Heating and Cooling**: **16**

**Space Heating Estimates**: **36**

**Sporadic Readings**: **30**

Statistical validity: 25

**Support Documents**: 7, 27, 34, 43, **54**, 55, 73

Surcharge(s): 3, 5, 17, 28, 32, 45, 51, 55, 57, 58

**System Management, Control & Behavior Issues: 59**

Spreadsheet table: 24-30

**T**

Taxes: 21, 44

Ten percent change in utility rates: 7, 52

Thirty-day (30-day) comment period: 5, 55

Thirty-year (30-year) climatic data: 31

Three-year rolling base: 31

**Timeframe for Consumption Data Collection**: **19**

Total Tenant Payment (TTP): 2, 3

Trash/Garbage/Recycling: 2, 15-16, 33, 46, 54

Twelve-month history/period: 10, 19, 23, 24, 25, 27, 46, 47

Types of utility allowances: 6

**U**

Utility Allowance: 1, 2, 45

> Adoption: 57
>
> Allowable: 15
>
> Annual review of: 4, 5, 9, 31, **51-53**
>
> Approval by Board: 50, 57
>
> Calculating: 12, 13, 15, 20, 21, 33, 41, **44-50**, 52
>
> Categories: 2, 15, 16, 17, 20, 22, 23, 24, 25, 27, 28, 29, 32, 48, 49,
> 50, 63
>
> Effective date: 57
>
> HUD review: 57
>
> Implementation: 54-57
>
> Individual Relief: 5, 16, 55, **56, Appendix B 5** pages **83-84**
>
> Notice to Residents: 55
>
> Post or display: 50, 55, 57
>
> Regulations 5, Appendix C pages 88-91
>
> Schedule: 7, 34, 47, 54, 55-56
>
> Update: 6, 7, 9, 13, 44, **51**, 61
>
> What are UAs?: 1
>
> Why Accurate UAs important?: 3

**Update Study for Ten Percent Rate Change**: **7**

**Utility Bill/Analysis**: 1, 9, 11, 21, 23, 24, 25, 35, 45, 48, 56,
**63**, 67

**Utility Consumption Data**: **20**

**Utility Rates and Charges**: 2, 7, 15, 22, **21**, 23, 43, **44**, 47,
48, 51, 52, 54, 70

**Utility Rates and Charges Data**: **21**

Uniform Physical Conditions Standards (UPCS): 54

**V**

Vacancy, Vacant or vacancies: 10, 21, 26, 29

**Various Utility Estimates**: **36**

**Verify Calculations with Sample Utility Bills: 47**

**W**

**Walk-through Energy Audit**: **61**

Washers & dryers: 16, 39

Water: 2, 15-16, 20, 22, 24, 41, 49

Weather/weatherization: 6, 11, 22, 28, 30, 31, 32, 35, 52, 58, 63

**What Are Utility Allowances?**: **1**

**Why Are Accurate Utility Allowances Important?**: **3**

Wood/cordwood: 2, 9, 16, 47