Energy Performance 

Contracting in HUD’s 

Public Housing Stock:

A Brief Overview

U.S. Department of Housing and Urban Development | Office of Policy Development and Research
Energy Performance 

Contracting in HUD’s Public 

Housing Stock: 

A Brief Overview

U.S. Department of Housing 

and Urban Development

Office of Policy Development and Research

Affordable Housing Research 

and Technology Division

Prepared by 

Michael J. Early 

Michael D. Blanford

Will R. Zachmann 

Barry L. Steffen

June 2017
Acknowledgments 

Energy Performance Contracting in HUD’s Public Housing Stock: A Brief Overview has benefited 

from the generous contributions of many individuals. Development of this report was made 

possible by funding from the U.S. Department of Housing and Urban Development (HUD), 

Office of Policy Development and Research (PD&R). The authors particularly appreciate the 

thoughtful support and advice provided by Elizabeth Cocke of PD&R’s Affordable Housing 

Research and Technology Division. They thank Christopher Golden of the HUD Office of Public 

and Indian Housing for his insight and guidance, and they are indebted to the leaders and staff 

of the housing authorities we visited: Wilmington Housing Authority (DE001), Clinton County 

Housing Authority (PA040), Greenwood Housing Authority (MS107), North Little Rock Housing 

Authority (AR002), Kansas City, Kansas Housing Authority (KS001), Denver Housing Authority 

(CO001), Housing Authority of the County of Chester (PA046), Metropolitan Development and 

Housing Agency (TN005), and Watervliet Housing Authority (NY025). They also thank all those 

who reviewed the report and provided helpful comments. Without the combined efforts of all 

those listed, this report would not have been possible.

Disclaimer

The contents of this report represent the views of the authors and do not necessarily reflect the 

views or policies of the U.S. Department of Housing and Urban Development or the U.S. 

government.
iii

Preface 

The U.S. Department of Housing and Urban Development (HUD), Office of Public and Indian 

Housing (PIH) administers the Energy Performance Contracting (EPC) program, an innovative 

approach to providing Public Housing Authorities (PHAs) with the financial flexibility to install 

cost-effective, utility-related improvements with little or no upfront expenditure.

Since the EPC program’s inception in the 1980s, PIH reports that approximately 315 EPCs

(affecting approximately 250,000 units) have been approved, representing nearly $1.5 billion in 

utility cost reduction investments. These performance contracts have been executed in all 10

HUD regions and in PHAs with sizes ranging from very small (fewer than 250 units) to very large 

(6,600 units or more); however, no substantive review of program performance has been 

conducted. 

To better understand how EPCs have helped improve conditions and reduce operating costs in 

our nation’s public housing stock, a multidisciplinary team from HUD’s Office of Policy 

Development and Research undertook a pilot study to assess the program’s overall 

effectiveness and value. The research team’s findings and observations provide PIH with a set 

of proposed actions that could significantly expand the adoption of EPCs within the PHA 

community. By giving PHAs the financial flexibility to use resultant utility cost savings to fund 

utility-related capital improvements, EPCs encourage PHAs to make more strategic and 

comprehensive utility upgrades than limited capital funding would otherwise support. 

I do hope that PIH policymakers will carefully consider the research team’s observations and 

use them to inform policies that will encourage and support more PHAs to use the EPC program 

as a viable tool for improving the properties under their control. 
iv

Contents

Executive Summary........................................................................................................................vii 

Introduction .................................................................................................................................... 1 

Objective ................................................................................................................................... 1 

History....................................................................................................................................... 2 

Overview of the Program.................................................................................................... 3 

Federal Incentives for Funding Energy Conservation in Public Housing ............................ 3 

Key Aspects of an Energy Performance Contract............................................................... 4 

EPC Financing ...................................................................................................................... 6 

HUD’s EPC Approval Process............................................................................................... 7 

Methodology ................................................................................................................................... 8 

PHA EPC Data Set...................................................................................................................... 8 

Selection of Participating PHAs............................................................................................... 11

Questionnaire ......................................................................................................................... 12

Site Visits Performed............................................................................................................... 13

EPC-Related Data .................................................................................................................... 15

Participants in the Field of Energy Performance Contracting ................................................ 15

Discussion...................................................................................................................................... 16

Results of the Questionnaire .................................................................................................. 16

EPC Benefits and Savings.................................................................................................. 16

Use of Excess Savings........................................................................................................ 16

Level of Effort on Application Process.............................................................................. 16

Resident Training and Awareness..................................................................................... 16

Analysis of Measurement and Verification, Utilities Expense Level Data, and HUD 

Assessment Data............................................................................................................... 17

Normalizing Utility Consumption Data ............................................................................. 18

Methodology and Limitations........................................................................................... 18

Average Percentage Change Estimates............................................................................ 18

Example Calculation.......................................................................................................... 21

Public Housing Policy Inquiries............................................................................................... 21

Apply EPC Utility Savings Toward Non-Energy-Related and Non-Water-Related Capital 

Improvements............................................................................................................. 21

Provide a Compensatory Fee to PHAs That Self-Manage an EPC..................................... 23

Is the Rigor of the Application Process Necessary To Ensure a Cost-Effective Project? .. 24

Summary ....................................................................................................................................... 25
v

Observations Supporting EPC Program Objectives ...................................................................... 26

Objective: Reducing the Approval Time of an EPC Application.............................................. 26

Observation: Develop a PHA-EPC working group............................................................. 26

Objective: Providing Greater Transparency in the Department’s Application Review Efforts..26

Observation: Revise the duration metric of the EPC application approval time.............. 27

Objective: Providing Further Guidance on the Collaborative Use of an EPC and RAD........... 27

Observation: Develop a decision logic tree in support of using an EPC in conjunction 

with RAD ..................................................................................................................... 28

Objective: Providing More Transparency in the Realized Savings of an EPC.......................... 28

Observation: Annually update cash flow spreadsheets ................................................... 29

Observation: Align the reporting periods of the annual M&V reports with annual UEL 

quantities .................................................................................................................... 29

Conclusion..................................................................................................................................... 31

References .................................................................................................................................... 32

Appendix A: Questionnaire Administered to Study Participants ................................................. 33 

Appendix B: Aggregate and Open-Ended Questionnaire Responses........................................... 54 

Appendix C: Utility Expense Level Quantities............................................................................... 81

Appendix D: Sidebars and Photos................................................................................................. 86

Lighting Systems ..................................................................................................................... 86

Water and Water Heating....................................................................................................... 87

Appliances............................................................................................................................... 88

HVAC ....................................................................................................................................... 89

Programmable Thermostats and Controls ............................................................................. 90

Renewable Energy Sources..................................................................................................... 91

List of Tables

Table 1: Distribution of EPCs and PHAs, and EPC Adoption Rate, by PHA Size .............................. 9 

Table 2: Distribution of EPCs and PHAs, and EPC Adoption Rate, by HUD Region......................... 9 

Table 3: Distribution of EPC and PHA Unit Count, and Affected Unit Rate, by PHA Size ............. 10

Table 4: Distribution of EPC and PHA Unit Count, and Affected Unit Rate, by HUD Region........ 11

Table 5: Diverse Mix of Participating PHAs................................................................................... 12

Table 6: Details Related to the Nine Participating PHAs .............................................................. 14

Table 7: Average Percentage Change Relative to Funding Year 2005 Consumption Quantities . 19

Table 8: Average Percentage Change Relative to First EPC.......................................................... 20

Table 9: Average Percentage Change Relative to Second EPC..................................................... 20

Table 10: Average Percentage Change Relative to Third EPC ...................................................... 20
vi

Table 11: DE001 ............................................................................................................................ 81

Table 12: PA04 .............................................................................................................................. 82

Table 13: MS107 ........................................................................................................................... 82

Table 14: AR002 ............................................................................................................................ 83

Table 15: KS001............................................................................................................................. 83

Table 16: CO001............................................................................................................................ 84

Table 17: PA046 ............................................................................................................................ 84

Table 18: TN005 ............................................................................................................................ 85

Table 19: NY025 ............................................................................................................................ 85

List of Figures

Figure 1: Public Housing Authorities (PHAs) in Lower 48 States and Puerto Rico That Have 

and Have Not Executed an Energy Performance Contract....................................................... 8 

Figure 2: Public Housing Authorities (PHAs) Visited During the Energy Performance 

Contracting (EPC) Study .......................................................................................................... 13

Figure 3: CFL Lighting, Nashville Site Visit..................................................................................... 86

Figure 4: Energy-Efficient Lighting, North Little Rock Site Visit.................................................... 86

Figure 5: Natural Gas Water Heater, Denver Site Visit................................................................. 87

Figure 6: Dual Flush Water-Efficient Toilet, Greenwood Site Visit............................................... 87

Figure 7: Tankless Water Heater, Watervliet Site Visit................................................................. 87

Figure 8: Energy-Efficient Dryers, Clinton Site Visit...................................................................... 88

Figure 9: Energy-Efficient Refrigerator, Denver Site Visit............................................................. 88

Figure 10: Residential Unit Mini-Split Heat Pump System, Nashville Site Visit............................ 89

Figure 11: Energy-Efficient Natural Gas Boiler, Wilmington Site Visit.......................................... 89

Figure 12: Programmable Thermostat, Clinton Site Visit............................................................. 90

Figure 13: HVAC Control Panel, Nashville Site Visit...................................................................... 91

Figure 14: These Townhouse-Style Apartments Rely on Geothermal Heat Pumps To 

Substantially Reduce Both Demand and Associated Costs; Chester Site Visit....................... 91

Figure 15: Geothermal Heat Pump, Chester Site Visit.................................................................. 92

Figure 16: Solar Panels Used for Domestic Hot Water, Chester Site Visit.................................... 92

Figure 17: Rooftop Solar Photovoltaic Panels, Kansas City Site Visit ........................................... 93

Figure 18: Solar Water Heaters, Kansas City Site Visit.................................................................. 93

Figure 19: Rooftop Solar Photovoltaic Array, Watervliet Site Visit .............................................. 93
vii

Executive Summary

This report summarizes an exploratory study of the effectiveness and value of the U.S. 

Department of Housing and Urban Development (HUD), Office of Public and Indian Housing’s 

(PIH’s) Energy Performance Contracting (EPC) program. In August and September 2015, HUD’s

Office of Policy Development and Research (PD&R) staff made onsite visits to nine public 

housing authorities (PHAs) that have either executed a new EPC or exercised an option to an 

existing EPC in place since 2010. The research effort compiled and analyzed data derived from a 

questionnaire for PHA staff, in-person discussions with PHA staff, an inspection of EPC-installed 

improvements, a collection of EPC documents, and discussions with multiple participants in the 

field of energy performance contracting. 

During the development of the research protocol, PIH requested that we explore three policyrelated issues that could be informed by the study: 

1. Whether to allow PHAs to use utility savings from EPCs for non-energy-related or nonwater-related capital improvements. 

2. Whether to provide a compensatory fee to PHAs that choose to self-manage their EPC. 

3. Whether the degree of rigor of the EPC application process is necessary to ensure the 

cost-effectiveness of projects. 

The findings from this research helped PD&R understand the strengths and weaknesses, 

regulatory intent, and general effectiveness of the EPC program. We developed a set of 

observations to assist HUD in improving the EPC program. Because the study involved a 

relatively small and therefore unrepresentative sample of PHAs, PD&R may revise these 

suggestions based on the results of its forthcoming nationwide study of the EPC program, which 

is intended to provide a more conclusive evaluation and better understanding of the program’s 

value and overall effectiveness.

Both the current project and the proposed evaluation efforts will be key to HUD’s long-term 

strategies for reducing utility consumption within its housing portfolio, in part because the EPC 

program is being affected by the advent of HUD’s Rental Assistance Demonstration (RAD),

which removes certain units from HUD’s public housing inventory and therefore from the EPC 

funding stream.

The PD&R team drew on findings from the current study to develop the following set of 

observations for PIH:

• The nine PHAs visited are not a perfect representation of the 247 PHAs that have 

executed an EPC project. But they have enough diversity in size and experience for us to 

make some observations about the EPC program.

• The EPC program has provided value to the nine PHAs studied. Eight of the nine 

participants felt the program to be (1) a benefit to their housing authority, (2) to have 

funded improvements that otherwise would not have been made; and (3) either was 

outperforming or performing as projected. Five of the housing authorities reported cost 

savings in excess of the EPC debt service.
viii

• Our conversations with these nine PHAs and discussions with program staff suggest 

some areas that are working well and others that might be improved.

• The rigorous application process is clearly important for both the PHAs and HUD. The 

application is key to program success. Yet the burden and challenge of completing an 

application could be lessened by HUD establishing with its Technical Assistance funds a 

peer learning network that connects some of the 247 PHAs that have successfully 

implemented EPCs with PHAs applying for the first time. For example, that peer network 

could provide guidance on how to design EPC projects that will not unduly harm a PHA’s

operating budget when there are HUD Operating Fund shortfalls.

• The program could be slightly less burdensome, and more appealing to PHAs, if fewer 

restrictions were put on how PHAs can use their cost savings, currently they are limited 

to spending those cost savings on either energy or water savings improvements.

Perhaps this flexibility could be offered as an incentive to PHAs if they self-manage their 

EPC. Self-management appears to improve oversight and efficiency.

Finally, there are a number of likely improvements to the metrics and data being collected by 

HUD from the PHAs that would provide better information on the benefits and costs of the 

performance contracts.
1

Introduction

Objective

This report summarizes an exploratory study of the effectiveness and value of the Office of 

Public and Indian Housing’s (PIH’s) program on Energy Performance Contracting (EPC).

1 During 

fiscal year (FY) 2015, staff from HUD’s Office of Policy Development and Research (PD&R) made

site visits to nine public housing authorities (PHAs) that have executed an EPC. The research 

effort compiled and analyzed data derived from a questionnaire for PHA staff, in-person 

discussions with PHA staff, an inspection of EPC-installed improvements, a collection of EPC

documents, and discussions with multiple participants in the field of energy performance 

contracting. 

During the development of the research protocol, PIH requested that we explore three policyrelated issues that could be informed by this study. 

1. Whether to allow PHAs to use utility savings from EPCs for non-energy-related or nonwater-related capital improvements. 

2. Whether to provide a compensatory fee to PHAs that choose to self-manage their EPC. 

3. Whether the degree of rigor of the EPC application process is necessary to ensure the 

cost-effectiveness of projects. 

The findings from this research helped PD&R understand the strengths and weaknesses, 

regulatory intent, and general effectiveness of the EPC program. We developed a set of 

observations to assist HUD in improving the EPC program. Because the study involved a 

relatively small and therefore unrepresentative sample of PHAs, PD&R may revise these 

suggestions based on the results of its forthcoming nationwide study of the EPC program, which 

is intended to provide a more conclusive evaluation and better understanding of the program’s 

value and overall effectiveness. The findings of this initial study clarify the costs incurred and 

hurdles encountered by participating PHAs in implementing EPCs and will inform a two-phase, 

more comprehensive, nationwide cost-benefit evaluation of the EPC program that is proposed 

to begin in FY 2016. 

Phase one of the upcoming study would involve a more extensive analysis of PHAs that have 

EPCs, working with a larger sample of housing authorities with a more representative variation 

in size, location, installed improvements, and energy conservation incentives deployed. Phase 

two would focus specifically on very small and small PHAs (fewer than 250 and 500 units, 

respectively) and on their interest in and efforts at applying for and administering EPCs. 

The research team has learned that many very small and small PHAs lack the capability to 

complete the EPC application process, the volume of potential improvements needed to attract

the services of an Energy Service Company (ESCo), and the capability to effectively assess and 

self-manage an EPC (Board of Trustees of the University of Illinois, 2015). The Department does 

 

1 http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/programs/ph/phecc/eperformance. 
2

not presently have the capacity to provide the technical assistance required to boost adoption 

by very small and small PHAs, nor does it have the resources required to incentivize ESCos to 

take on projects that may prove to be of higher risk or to yield lower returns. 

Both the current project and the proposed follow-on efforts are intended to inform HUD’s longterm strategies, in part because the EPC program is being affected by the advent of HUD’s 

Rental Assistance Demonstration (RAD). RAD allows PHAs to leverage public and private debt 

and equity to reinvest in the public housing stock. 

In RAD, public housing units move to a Section 8 platform with a long-term contract that, by 

law, must be renewed. This renewal clause ensures that the units will remain permanently 

affordable to low-income households; however, it also removes the units from HUD’s public 

housing inventory and possibly from the EPC funding stream. 

If a PHA wishes to convert all or a portion of its EPC-related properties to RAD, it must first 

determine how it plans to satisfy the existing EPC obligation. Housing authorities have the 

option of either paying off the EPC debt or assuming the debt and continuing to make the EPC 

debt payment after conversion to RAD. Regardless of the option chosen, a letter must be 

submitted to the corresponding field office that formally requests for HUD to end the EPC 

incentives at the time of conversion and describes how the PHA will address the EPC debt. In 

instances in which only a portion of a property is converted to RAD, a new baseline utility 

consumption measurement must be established for the portion of the project that remains in 

public housing and continues to receive EPC incentives. HUD has recently released a frequently 

asked questions2 (FAQ) document that provides additional information related to using an ECP 

in conjunction with RAD. 

History

EPC is an innovative financing technique designed to provide PHAs with cost-effective 

improvements—energy conservation measures (ECMs)—that are installed with low or no 

upfront expenditures by the PHA. The costs of the improvements are typically borne by the 

performance contractor, who is repaid using a portion of the cost savings resulting from the 

improvements. 

As of FY 2015, PIH reports that since the 1980s, when this type of financing technique began,3

the Department has approved approximately 315 EPCs (affecting approximately 250,000 units), 

totaling nearly $1.5 billion in investments. EPCs have been executed in all 10 HUD regions4 and 

in PHAs ranging from very small (fewer than 250 units) to very large (6,600 units or more). Until 

now, however, no substantive review of the program’s performance has been conducted.

 

2 http://portal.hud.gov/hudportal/documents/huddoc?id=RAD_EPC_FAQs_030316.pdf. 3 See http://portal.hud.gov/huddoc/2011EPCInventory.xls and 

http://portal.hud.gov/hudportal/documents/huddoc?id=EPCInventory2012-2015.xlsx. The “EPC Database: Summary Statistics” 

spreadsheet contains documentation on EPCs from 1987 through 2011; the “(NEW) EPC Inventory” spreadsheet contains 

documentation on EPCs executed between 2012 and 2015. 4 http://portal.hud.gov/hudportal/HUD?src=/localoffices/regions. 
3

Overview of the Program

Section 118(a) of the Housing and Community Development (HCD) Act of 1987 (Oak Ridge 

National Laboratory, 1992) instituted adjustments to HUD’s Performance Funding System (PFS) 

that enabled PHAs to take advantage of innovative financing techniques (such as energy 

performance contracting) that are not dependent on additional federal funding. Section 118(a) 

consisted of two new incentives aimed at encouraging PHAs to reduce utility consumption and 

a third incentive that favors utility purchase arrangements that reduce the cost of energy 

consumed. HUD implemented the energy conservation incentives of the HCD Act through 

revised PFS regulations at 24 CFR 990, which were published as a final rule on September 11, 

1991. 

Current EPC rules5 include the following two requirements for funding energy conservation 

improvements: (1) the ECMs must be financed by an entity other than HUD (that is, a private 

loan); and (2) reasonably anticipated energy savings must be sufficient to cover all of the EPCrelated debt service that will accrue within 20 years of executing the contract. 

In support of these regulations, the Department also issues notices to clarify the EPC-related 

financial incentives. The Department’s most recent EPC notices are hosted on PIH’s EPC

webpage,6 which provides resources about all aspects of the EPC program.

Federal Incentives for Funding Energy Conservation in Public Housing 

HUD’s current EPC program provides PHAs with three incentives: Frozen Rolling Base Incentive 

(FRB), Add-On Subsidy Incentive (AOS), and Resident-Paid Utility Incentive (RPU). These 

incentives adjust the federal operating subsidies7 available to PHAs to enable utility 

conservation improvements in public housing that reduce utility consumption from baseline 

levels. The Department also offers the Rate Reduction Incentive (RRI), which can be included in 

an EPC but can also be used as a separate incentive independent of the EPC program. The RRI 

allows PHAs to recoup costs of interventions that reduce the rates paid for utilities. RRIs may be 

used in conjunction with the FRB, AOS, or RPU incentives (HUD, 2014). A description of 

requirements associated with each incentive follows. In total, the incentives are designed to 

enable PHAs to allocate more of their operating subsidy toward needed repairs and other 

eligible expenses. 

 

5 Utilities expense level: Incentives for energy conservation/rate reduction, 24 CFR 990.185. 

https://www.gpo.gov/fdsys/pkg/CFR-2011-title24-vol4/pdf/CFR-2011-title24-vol4-sec990-185.pdf. 6 http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/programs/ph/phecc/eperformance. 7 Operating fund formula, 24 CFR 990.110. https://www.gpo.gov/fdsys/pkg/CFR-2011-title24-vol4/pdf/CFR-2011-title24-vol4-

sec990-110.pdf. Section 9(f) of the United States Housing Act of 1937 establishes an Operating Fund for the purposes of making 

assistance available to PHAs for the operation and management of public housing. The Operating Fund provides operating 

subsidy to assist PHAs to serve low-income families. In general, the annual contributions (operating subsidy) that each PHA is 

eligible to receive is determined by a formula and is based on the difference between formula expenses and formula income.
4

Frozen Rolling Base Incentive 

A PHA may request that the Department freeze its 3-year rolling base utility consumption level

(RBCL),

8

 used to calculate operating subsidies, at the level of consumption that existed prior to 

the installation of the EPC improvements. Under the FRB, PHAs may retain 100 percent of the 

cost savings throughout the term of the contract; they must use at least 75 percent of the 

annual savings for payment of the EPC loan, however. 

Add-On Subsidy Incentive 

An add-on (additional operating) subsidy is an increase in the total operating subsidy for a PHA

to amortize the costs of EPC improvements and other direct costs of the performance contract. 

PHAs that use the AOS are limited to receiving the lesser of the project’s costs or savings

achieved. Any savings associated with overperformance of the installed improvements cannot 

be retained; such excess savings, however, can be applied to additional improvements (that is, 

expanding the current project) or used to accelerate debt service on the existing contract.

Resident-Paid Utility Incentive 

The RPU allows a PHA to exclude from its Operating Fund rental income calculations, for the 

duration of the EPC, any increased rental income that results from decreased utility allowances

achieved through reduced utility consumption. The change in utility allowances is based on the 

difference between the baseline and revised allowances of the projects.

Rate Reduction Incentive 

If a PHA takes action—beyond normal public participation and effective management in 

ratemaking proceedings—to reduce its utility cost structure, then HUD will allow the PHA to 

retain 50 percent of the annual savings. Examples of such PHA actions include purchasing 

natural gas at the wellhead, making administrative appeals, or taking legal action to reduce its 

utility rates. Although there are no time limits on the RRI, the incentive is subject to annual 

review, meaning that the actions taken must continually prove to be innovative and cost

effective. Furthermore, the Department has issued recent guidance that expands the RRI 

incentive to assist housing authorities in capturing the cost savings associated with renewable 

energy technologies (HUD, 2014). 

Key Aspects of an Energy Performance Contract 

EPC is a turnkey service that provides customers with a comprehensive set of energy efficiency, 

renewable energy, and distributed generation measures. Many EPCs are accompanied by 

guarantees that the savings produced by a project will be sufficient to finance the full cost of 

 

8 The RBCL is equal to the average of yearly consumption levels for the 36-month period ending on June 30, that is, 18 months 

prior to the first day of the applicable funding period. A yearly consumption level is the actual amount of each utility consumed 

during a 12-month period ending June 30. For example, for the funding period January 1, 2015, through December 31, 2015, 

the RBCL will be the average of three yearly consumption levels: Year 1 = July 1, 2010, through June 30, 2011; Year 2 = July 1, 

2011, through June 30, 2012; Year 3 = July 1, 2012, through June 30, 2013.
5

the project. ESCos are often retained to install and maintain the utility improvements of an EPC.

In an EPC, the ESCo can provide the full range of services required to complete the project. 

These services can include the following.

Energy Audit

An EPC generally requires the activity to begin with an energy audit of the property, which 

consists of an inspection, a survey, and an analysis of existing energy use in a building or 

property. The energy audit is the first step in assessing how much energy the building or 

property consumes and in evaluating what measures can be taken to make it more energy 

efficient. The audit will establish a baseline against which the savings achieved through 

performance enhancements may be measured, and will identify any problems that, when 

corrected, may save significant amounts of energy over time.

Design Engineering 

Usually, the next step is preparation of an engineering design by the ESCo that can range from 

simply specifying energy-efficient lighting and water conservation measures to more complex 

projects that integrate renewable energy sources (such as solar panels, solar water heaters, or 

geothermal heat pumps), or that replace or upgrade inefficient heating and cooling equipment. 

Construction Management and Commissioning 

Once the design is approved, the ESCo provides construction management expertise and helps 

arrange for long-term project financing. At the end of the construction phase, the ESCo will 

commission the property by conducting an intensive quality assurance process. The purpose of 

commissioning is to ensure that the energy upgrades are operating as intended and that 

building staff are prepared to properly operate and maintain the new systems and equipment. 

Operations and Maintenance 

After commissioning has been completed, the EPC may require the ESCo to continue providing 

daily operations and maintenance (O&M) services to augment those performed by building 

staff. This O&M assistance may be limited to any innovative new technologies (for example,

advanced heat pumps or solar panel arrays) that may have been incorporated as a result of the 

EPC. The parameters of any assistance to be provided by the ESCo should be negotiated at the 

outset and clearly stipulated in the EPC. 

Savings Measurement and Verification 

The final major element of a performance contract is the measurement and verification (M&V) 

process that quantifies the savings attributable to the installed improvements. This element is 

critical, because the facility owner is depending on the EPC project savings to pay for its 

financing obligations, and the ESCo is guaranteeing the level of energy savings that will be 

achieved as a result of its work. As such, the careful design and implementation of M&V 

protocols serve as the foundation for the long-term success of an EPC project. 
6

A typical EPC project today employs the International Performance Measurement and

Verification Protocol (NREL, 2002) to estimate the utility savings that will be achieved through 

an EPC (ICF International and National Association of Energy Services Companies, 2007). Not 

every EPC includes all of the elements and activities described previously. The choice of building 

components, systems, and the responsibilities of all parties to the agreement will reflect the 

PHA’s unique project needs, the skills and capabilities of in-house staff, and available resources. 

On projects where the performance contract is self-managed, the PHA generally serves as the 

general contractor and oversees all aspects of the performance contract.

EPC Financing

Arrangement of Long-Term Project Financing 

Most EPC projects are financed with long-term debt or leases, though some customers are able 

to pay a portion of an EPC project with capital budget allocations. In the early days of EPC, 

ESCos typically provided both project technical services and project financing, as financial 

institutions rarely understood how EPCs worked and therefore were unwilling to finance them. 

Some ESCos also acted as product distributors, because many mainstream construction 

materials and systems distributors were unwilling to stock emerging technology products such 

as electronic ballasts for compact fluorescent lighting. 

Many EPC projects include a guarantee from the ESCo to the customer that projected energy 

savings will be sufficient to pay the full cost of long-term project financing. The form of the 

guarantee varies by project, because the guarantees are crafted to suit the requirements of 

specific customers and federal and state legislation and regulations.

When an EPC has a financing transaction involving a security interest or other encumbrance in 

public housing property, HUD requires PHAs to obtain written approval for the security interest 

or encumbrance pursuant to Section 30 of the U.S. Housing Act of 1937 (HUD, 2013).

9 Under 

some lease-purchase agreements, the ownership of the energy retrofit equipment may reside 

with the third party, for example, a bank, ESCo, or other entity. When equipment ownership 

resides with a third party, a Section 30 approval is not required. 

Third-Party Financing Marketplace 

Almost all EPC projects are financed by third-party finance companies—usually banks and other 

financial institutions. Major financial institutions like Bank of America, Citibank, GE Capital, and 

PNC Bank are important funding sources. In addition, specialized EPC project finance brokers

(somewhat analogous to mortgage brokers) originate project financing deals and then locate a 

bank or direct lender to make the loan. 

 

9 The guidebook provides further information on Section 30 requirements.
7

Available Capital

Funding appears to be contingent on the size of the project, and larger PHAs have more ready 

access to funds. A recent study by the University of Illinois found that small and medium PHAs 

are often unable to attract investors for energy financing at reasonable market rates (Board of 

Trustees of the University of Illinois, 2015). 

Typical Rates and Terms 

A typical EPC project is financed directly with the customer (rather than through the ESCo), 

because many customers can secure better interest rates than those available to the ESCos. The 

customers generally borrow money to finance the projects, with the ESCo guaranteeing the 

lender that payments from project savings will be sufficient to cover the finance costs. 

HUD’S EPC Approval Process

To participate in the EPC program, PHAs must first determine who will oversee the 

performance contract. The PHA may elect either to hire an ESCo or to manage the contract

itself. 

An ESCo can offer a comprehensive range of energy solutions to the PHA, including energy 

auditing, design engineering, construction management, O&M, and M&V. When the EPC is selfmanaged, the PHA typically serves as the general contractor, overseeing all aspects of the 

performance contract and receiving technical support from a third-party consultant.

HUD has developed flow diagrams that outline the steps necessary for application approval

under either scenario. In general terms, both approaches require developing and advertising a 

request for proposal (RFP), conducting an energy audit, developing an EPC contract package, 

and submitting the contract package for HUD review; the contract is awarded upon receipt of 

HUD approval. The Department’s review process comprises multiple stages—RFP technical 

review, completeness review checklist, technical review checklist, and panel review—intended 

to ensure that PHAs are complying with HUD regulations and guidance, and to minimize any 

risks to the Department. The flow diagrams (under “EPC Process Review”) and checklists (under 

“Checklists”) can be found on the PIH EPC webpage.10 

Under 24 CFR 965.308(b),11 HUD field offices are the departmental entities that review all EPC 

solicitations and contract packages. In support of field office review, the Office of Field 

Operations (OFO) Energy Center was established in circa 2010 to provide quality control (QC) 

reviews of new contracts and associated savings, quality assurance reviews of existing 

contracts, and technical assistance to both PHAs and the HUD field offices.

 

10 http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/programs/ph/phecc/eperformance. 11 https://www.gpo.gov/fdsys/pkg/CFR-2012-title24-vol4/pdf/CFR-2012-title24-vol4-part965-subpartC.pdf. 
8

Methodology

PHA EPC Data Set

Since the inception of EPCs as a financing mechanism for energy retrofits, the Department 

reports12 that approximately 315 EPCs (affecting approximately 250,000 units; see Figure 1) 

have been implemented, resulting in a total investment of nearly $1.5 billion in energy 

improvements. EPCs have been executed in all 10 HUD regions in PHAs ranging from very small 

(fewer than 250 units) to very large (6,600 units or more). In addition, PIH maintains 

spreadsheets13 that document the EPCs that were executed from 1987 through 2015. These 

documents contain summary-level EPC information, presented on a fiscal year basis. 

Figure 1: Public Housing Authorities (PHAs) in Lower 48 States and Puerto Rico 

That Have and Have Not Executed an Energy Performance Contract (EPC) 

Tables 1 and 2 illustrate the distribution of the Department’s EPCs by PHA size category and 

HUD region. Also displayed are the number of housing authorities in the respective category or 

region that the Department assists, and the percentage of housing authorities that have 

executed an EPC relative to the total number of housing authorities of the same PHA size 

category and HUD region. Because multiple housing authorities have executed additional 

phases to their initial EPC, EPCs outnumber PHAs that have executed an EPC.

 

12 See http://portal.hud.gov/huddoc/2011EPCInventory.xls and 

http://portal.hud.gov/hudportal/documents/huddoc?id=EPCInventory2012-2015.xlsx. 13 See http://portal.hud.gov/huddoc/2011EPCInventory.xls and 

http://portal.hud.gov/hudportal/documents/huddoc?id=EPCInventory2012-2015.xlsx. 
9

Table 1 illustrates that the likelihood that a PHA has adopted an EPC varies by the PHA size 

category. While most PHAs operating low-income public housing are very small and small—

fewer than 500 units—(74.3 percent and 14.2 percent, respectively), the EPC adoption rates for 

these PHAs (1.5 percent and 15.3 percent, respectively) are the lowest among the five size 

categories. Across all the PHAs, 247 had executed an EPC through FY 2015, for an overall EPC 

adoption rate of 7.9 percent.

Table 2 similarly shows that EPC adoption rates vary by HUD region. Regions IV, V, VI, VII, VIII, 

and X have EPC adoption rates below 10 percent, and four of these six regions include 10 

percent or more of all PHAs with public housing programs. 

Table 1: Distribution of EPCs and PHAs, and EPC Adoption Rate, by PHA Size

PHA Size EPCs Through FY15 PHAs That Have

Executed an EPC

PHAs

(Low-Income)

EPC Adoption 

Rate

percent (number) percent (number) percent (number) percent

Very small (fewer than 250) 11.7 (37) 14.2 (35) 74.3 (2,318) 1.5

Small (250–499) 24.8 (78) 27.5 (68) 14.2 (444) 15.3

Medium (500–1,249) 27.9 (88) 30.4 (75) 7.1 (221) 33.9

Large (1,250–6,599) 32.1 (101) 25.5 (63) 3.9 (121) 52.1

Very large (6,600+) 3.5 (11) 2.4 (6) 0.4 (14) 42.6

100.0 (315) 100.0 (247) 100.0 (3,118) 7.9a

EPC = Energy Performance Contract. PHA = public housing authority.

a The total adoption rate (7.9 percent) is the quotient of the “PHAs that have executed an EPC” and “PHAs (LowIncome)” (247/3,118 = 0.0792).

Note: Due to rounding, not all reported percentages precisely equal 100.0 percent. 

Table 2: Distribution of EPCs and PHAs, and EPC Adoption Rate, by HUD Region

HUD Region EPCs Through FY15 PHAs That Have 

Executed an EPC

PHAs 

(Low-Income) EPC Adoption Rate

percent (number) percent (number) percent (number) percent

I 16.5 (52) 16.2 (40) 5.4 (169) 23.7

II 14.6 (46) 13.8 (34) 5.3 (165) 20.6

III 17.5 (55) 15.8 (39) 5.5 (173) 22.5

IV 20.3 (64) 21.1 (52) 25.4 (793) 6.6

V 19.0 (60) 19.0 (47) 17.1 (533) 8.8

VI 3.5 (11) 4.0 (10) 22.6 (704) 1.4

VII 1.3 (4) 1.6 (4) 11.1 (346) 1.2

VIII 2.5 (8) 2.8 (7) 3.6 (112) 6.3

IX 4.4 (14) 5.3 (13) 2.2 (68) 19.1

X 0.3 (1) 0.4 (1) 1.8 (55) 1.8

Totals 100.0 (315) 100.0 (247) 100.0 (3,118) 7.9a

EPC = Energy Performance Contract. HUD = U.S. Department of Housing and Urban Development. PHA = public 

housing authority.

a The total adoption rate (7.9 percent) is the quotient of the “PHAs that have executed an EPC” and “PHAs (LowIncome)” (247/3,118 = 0.0792). 

Note: Due to rounding, not all reported percentages precisely equal 100.0 percent. 
10

Tables 3 and 4 illustrate the distribution of units affected by an EPC by PHA size category and 

HUD region. These tables also display the overall unit count of the PHAs that have executed an 

EPC, and the percentage of units that have been affected by an EPC relative to the total number 

of PHA units of the same PHA size category and HUD region.

Table 3: Distribution of EPC and PHA Unit Count, and Affected Unit Rate, by PHA Size

PHA Size

PHA Unit Count

(Executed an EPC)

Unit Count

(Affected by an EPC)

PHA Unit Count

(Low-Income)

Affected Unit Rate

percent (number) percent (number) percent (number) percent

Very small (fewer than 250) 1.2 (5,858) 2.1 (5,273) 17.1 (204,751) 2.6

Small (250–499) 5.2 (24,960) 8.9 (22,350) 12.9 (153,964) 14.5

Medium (500–1,249) 12.4 (59,736) 21.8 (54,738) 14.1 (168,472) 32.5

Large (1,250–6,599) 32.7 (157,063) 49.4 (123,775) 25.4 (303,911) 40.7

Very large (6,600+) 48.4 (232,232) 17.8 (44,486) 30.4 (363,120) 12.3

100.0 (479,849) 100.0 (250,622) 100.0 (1,194,218) 21.0a

EPC = Energy Performance Contract. PHA = public housing authority.

a The total affected unit rate (21.0 percent) is the quotient of the “Unit Count (Affected by an EPC)” and “PHA Count 

(Low-Income)” (250,622/1,194,218 = 0.2098).

Note: Due to rounding, not all reported percentages precisely equal 100.0 percent. 

Table 4: Distribution of EPC and PHA Unit Count, and Affected Unit Rate, by HUD Region

HUD Region

PHA Unit Count

(Executed an EPC)

Unit Count

(Affected by an EPC)

PHA Unit Count

(Low-Income) 

Affected Unit Rate

percent (number) percent (number) percent (number) percent

I 8.6 (41,318) 10.9 (27,343) 6.3 (75,161) 36.4

II 43.8 (209,963) 15.8 (39,478) 21.5 (256,372) 15.4

III 11.0 (52,847) 18.1 (45,271) 10.3 (123,389) 36.7

IV 11.2 (53,548) 18.2 (45,665) 25.2 (301,239) 15.2

V 16.3 (78,314) 21.8 (54,623) 15.5 (184,802) 29.6

VI 2.5 (11,869) 4.6 (11,503) 9.9 (118,331) 9.7

VII 0.7 (3,540) 1.4 (3,526) 3.4 (40,339) 8.7

VIII 1.3 (6,444) 2.1 (5,378) 1.4 (16,750) 32.1

IX 4.0 (19,275) 5.8 (14,537) 4.6 (54,458) 26.7

X 0.6 (2,731) 1.3 (3,298) 2.0 (23,377) 14.1

Totals 100.0 (479,849) 100.0 (250,622) 100.0 (1,194,218) 21.0a

EPC = Energy Performance Contract. HUD = U.S. Department of Housing and Urban Development. PHA = public 

housing authority.

a The total affected unit rate (21.0 percent) is the quotient of the “Unit Count (Affected by an EPC)” and “PHA 

Count (Low-Income)” (250,622/1,194,218 = 0.2098).

Note: Due to rounding, not all reported percentages precisely equal 100.0 percent.
11

Table 3 illustrates that a majority of the units affected by an EPC are, not surprisingly, within 

the three larger PHA size categories: medium (54,738 units), large (123,775 units), and very 

large (44,486 units). After controlling for housing authorities that have executed multiple EPCs, 

it was determined that 250,622 units14 (244 PHAs) have been affected by an EPC through FY 

2015, for an overall affected unit rate of 21.0 percent.

Table 4 similarly shows that the rate of units affected by an EPC varies by HUD region. Regions 

VI, VII, and X have affected unit rates below 15 percent, and each of these regions contains less 

than 10 percent of the Department’s public housing unit count. 

Selection of Participating PHAs

In June 2015 the research team conducted preliminary discussions with a pool of 16 

prospective PHAs to determine their willingness and availability to participate in the EPC study. 

This subset of PHAs was selected from the Department’s 2011 EPC data set; the only 

prerequisite for participation was that the PHA must have completed EPC improvements after 

2009. The timing aspect of this prerequisite coincides with establishment of the OFO-Energy 

Center team, which is based in HUD’s Buffalo Field Office and serves as the Department’s 

central point for review and approval of EPCs. Based on conference calls and email 

communication, the team classified potential study participants into three groups: nine PHAs 

expressed an interest in participating, four indicated disinterest, and the remaining three were 

listed as potential alternates.

As illustrated in Table 5, the nine participating PHAs were selected to represent a diverse mix of 

housing authorities based on factors such as PHA size, complexity of installed improvements, 

HUD region, EPC dollar amount, and phase of the EPC. Cost-effective travel by the research 

team was another factor in the selection.

15 A majority of the identified potential PHAs that 

expressed disinterest or were listed as a potential alternate site indicated either that the units 

under their existing EPC were being transited to RAD or that a majority of their current staff 

were not familiar with the executed EPC and how it benefited the housing authority. The team 

conducted site visits at all nine participating PHAs during August and September 2015.

Due to the pilot’s small sample size, and because some PHAs did not wish to participate, the 

research team recognizes that the conclusions drawn from this effort may be based on an 

unrepresentative group of PHAs. PD&R’s followup study is expected to present a clearer view of 

the EPC universe.

 

14 For PHAs that have executed multiple EPCs (that is, have executed more than one EPC phase), the EPC phase that had the 

largest number of affected units was retained. If the number of affected units was identical for the multiple phases, then the 

number of affected units for the most recent EPC phase was retained. If a PHA’s number of affected units was missing from the 

EPC data set, the PHA and its overall unit count were excluded from this analysis.

15 PD&R staff were granted FY15 travel funds to visit the nine participating housing authorities. The site visits were performed 

between August and September 2015. 
12

Table 5: Diverse Mix of Participating PHAs

PHA Name PHA 

Code State PHA 

Regiona

PHA 

Sizeb

Total 

Units

Units 

Affected by 

EPC

Wilmington Housing Authority DE001 DE III large 1,556 1,472

Clinton County Housing Authority PA040 PA III small 457 457

Greenwood Housing Authority MS107 MS IV small 408 408

North Little Rock Housing Authority AR002 AR VI medium 1,042 1,040

Kansas City, Kansas Housing Authority KS001 KS VII large 2,058 2,046

Denver Housing Authority CO001 CO VIII large 3,922 3,379

Housing Authority of the County of Chester PA046 PA III small 331 207

Metropolitan Development and Housing Agency TN005 TN IV large 5,383 4,580

Watervliet Housing Authority NY025 NY II small 307 307

EPC = Energy Performance Contract. PHA = public housing authority.

a U.S. Department of Housing and Urban Development, “HUD’s Regions,” 

http://portal.hud.gov/hudportal/HUD?src=/localoffices/regions. b Very small (fewer than 250 units); small (250–499 units); medium (500–1,249 units); large (1,250–6,599 units); and very 

large (6,600+ units).

Of the PHAs that confirmed interest in participating, two (DE001 and CO001) were currently 

self-managing their EPCs; the remaining seven had hired an ESCo to manage the contracts on 

their behalf.16 Four of the PHAs (AR002, KS001, MS107, and PA040) were in the initial phase of 

the contract, four (CO001, DE001, NY025, and PA046) had executed a second phase, and the 

remaining housing authority (TN005) had executed a third phase of the term contract.

Questionnaire

Between July and September 2015 the research team administered the study’s questionnaire to 

the participating PHAs. The questionnaire was designed so that only respondents who understood

the executed EPC would be able to complete it. The questionnaire covered four topical 

sections—general EPC-related information, utility conservation and utility savings, developing 

and self-managing an EPC, and resident-related matters pertaining to the executed EPC. 

In conjunction with the EPC-specific documents, the questionnaire also served as a means of 

examining whether long-term utility savings are being achieved; how the resulting cost savings 

are being used; the process, time commitment, and workload (from the PHA’s perspective) 

associated with applying to the EPC program; and barriers to greater EPC adoption by PHAs. A 

copy of the questionnaire is included as appendix A.

The questionnaire was administered over an 8-week period and was sent to participating PHAs 

via email in either Word or Acrobat format. On average, respondents were given 7 days prior to 

the research team’s site visit to complete and submit the questionnaire. All nine participating 

PHAs completed and submitted the questionnaire in a timely manner.

 

16 Although Watervliet hired an ESCo to manage the second phase of their EPC, the first phase of their EPC was self-managed.
13

Site Visits Performed

In August and September 2015, the research team made site visits to each of the participating 

PHAs (see Figure 2). Each visit lasted approximately half a day and consisted of a roundtable 

discussion with PHA management and staff, followed by a walkthrough (tour and engineering 

review) of the installed EPC improvements. For research purposes, the team requested and 

received permission from each participating PHA to record the roundtable meeting discussions. 

The site visits performed and key details relating to each of the executed performance 

contracts are described in the following text and in Table 6. 

During the roundtable discussions, the PHA’s responses to the completed questionnaires were 

discussed and PHA staff were given an opportunity to speak about their experiences and 

lessons learned from their participation in the EPC program. All PHA participants were frank in 

their discussions and provided first-hand insights about what they would have done differently 

had they elected to complete another phase of their performance contract; they also candidly 

offered advice for other PHAs that may be interested in applying to the program.

Figure 2: Public Housing Authorities (PHAs) Visited During the Energy Performance 

Contracting (EPC) Study
14

Table 6: Details Related to the Nine Participating PHAs

PHA Name PHA Code Type of 

Improvements

EPC 

Phase

EPC Term

(Years) 

EPC 

Incentives

Contract 

Costsa

1st-Year 

Estimated 

Savings

Wilmington Housing Authorityb DE001

building

envelope, HVAC, 

water, 

appliances

2 15 FRB, AOS, 

RPU $3,058,724 $662,697

Clinton County Housing Authorityc PA040

lighting, water, 

building

envelope, HVAC 

1 12 FRB, RPU $1,127,749 $128,128

Greenwood Housing Authorityd MS107 lighting, water, 

HVAC 1 15 AOS $3,165,742 $278,706

North Little Rock Housing 

Authoritye AR002

lighting, water, 

building

envelope, HVAC

1 12 AOS, RPU $3,559,665 $365,273

Kansas City, Kansas Housing 

Authorityf KS001

building

envelope, HVAC, 

lighting, water, 

appliances 

renewable 

energy, 

miscellaneous

1 20 FRB, AOS, 

RPU $16,242,534 $1,030,364

Denver Housing Authorityg CO001

lighting, water, 

HVAC, 

appliances, 

building

envelope

2 16 AOS $20,738,802 $2,431,363

Housing Authority of the County of 

Chesterh PA046

lighting, water, 

building

envelope, 

appliances, 

HVAC

2 15 FRB $3,000,000 $407,825

Metropolitan Development and 

Housing Agencyi TN005

building

envelope, 

appliances, 

lighting, HVAC

3 5 FRB, RPU $3,079,703 $68,964

Watervliet Housing Authorityj NY025

building

envelope, HVAC, 

lighting, 

appliances 

2 15 FRB, RPU $1,014,851 $88,422

EPC = Energy Performance Contract. PHA = public housing authority.

a For the purposes of this analysis, contract costs correspond to the investment costs for the respective EPC Phase. b DE001’s Phase 2 EPC is self-managed and extends the existing EPC incentive term from 12 to 20 years. DE001’s Phase 1 ESCo 

was Honeywell, Inc. c

 PA040’s Phase 1 ESCo is Pepco Energy Services. d MS107’s Phase 1 ESCo is Siemens Industry, Inc. e AR002’s Phase 1 ESCo is Honeywell, Inc. f KS001’s Phase 1 ESCo is Johnson Controls. g

 CO001’s Phase 2 EPC is self-managed and extends the existing EPC incentive term from 12 to 20 years. CO001’s Phase 1 ESCo 

was Honeywell, Inc. h PA046’s Phase 2 extends the existing EPC incentive term from 15 to 20 years. PA046’s Phase 1 and Phase 2 ESCo is Johnson 

Controls, Inc. i TN005’s Phase 3 extends the existing EPC incentive term from 15 to 20 years. TN005’s Phase 1, Phase 2, and Phase 3 ESCo is 

Siemens Industry, Inc.

j

 NY025’s Phase 2 extends the existing EPC incentive term from 12 to 15 years. NY025’s Phase 2 ESCo is Siemens Industry, Inc.
15

EPC-Related Data

The OFO-Energy Center team hosts a SharePoint site that contains detailed information on a 

large number of the EPC projects that the Department has executed. The research team was 

granted access to this website and gathered contractual information from it on EPC application 

files, baseline consumption levels, approval documents, and M&V data—all of it pertaining to 

the performance contracts for each of the participating PHAs. Most of the contractual 

information was available through the SharePoint site; some data gaps existed, however. In an 

effort to fill these gaps, the local PIH field office staff (and in some cases the participating PHAs) 

were asked to obtain any required documentation that was unavailable on the SharePoint site.

Participants in the Field of Energy Performance Contracting

Upon completion of the site visits, the research team contacted a number of internal and 

external participants in the EPC field. Discussions with these individuals provided a range of 

perspectives on the EPC program and its application process, and suggested approaches to both 

improving the EPC program and increasing its adoption rate among members of the PHA 

community. During each of these discussions, the research team described the purpose of the 

in-house research project and received feedback on the various participants’ experiences with

HUD’s EPC program.
16

Discussion

Results of the Questionnaire

Each participating PHA completed a questionnaire about its EPC, its utility savings, the process 

of developing and managing an EPC, and resident-related matters. The questionnaire consisted 

of 90 questions and was designed so that, in order to respond appropriately and fully,

respondents had to have a working knowledge of their EPC. A summary of the completed 

questionnaires’ major takeaways follows; both aggregate and open-ended responses to all of 

the questions can be found in appendix B.

EPC Benefits and Savings 

Key questionnaire responses suggest that the EPCs for this set of PHAs were a success. Eight of 

nine participants stated that their performance contracts were overperforming or performing 

as projected (Q35). Similarly, eight of nine participants responded that they believe their 

executed EPC was of benefit to their housing authority (Q55). 

When considering their EPC experiences from a counterfactual perspective (that is, what would 

conditions have been like in the absence of the EPC), eight of nine respondents indicated that 

only a portion of the improvements installed through the EPC program would have been 

made (Q62), and six of seven respondents believe they would not have been able to achieve 

the same amount of savings (Q63).

Use of Excess Savings 

From an excess savings perspective, five of nine respondents reported achieving savings after 

paying the annual debt service on their executed EPC (Q38). Respondents were asked to 

elaborate on how their savings were used. Four responding PHAs used the savings to pay 

eligible operating expenses, three specified installing additional improvements by expanding 

their current EPC, and one used the savings to accelerate payment on its EPC debt (Q39).

Question 39 allowed respondents to make multiple selections. 

Level of Effort on Application Process

The team was unable to quantify the level of effort that the participating housing authorities 

applied to the EPC application process. Only one of the nine participants responded that it

kept a record of the workload (that is, labor hours) associated with applying to the EPC 

program (Q58). The respondent specified that housing authority staff allocated 

approximately 320–640 labor hours (8–16 weeks) toward the EPC application process (Q59).

Resident Training and Awareness

The results of the questionnaire illustrate that participating housing authorities were energy 

conscious to some degree and made efforts to raise residents’ awareness of their role in the 

conservation process. All nine participants instituted some form of outreach or training 

program to encourage greater utility conservation among residents (Q81), and eight of nine 

respondents believe that notifying residents of the executed EPC and the resulting building 
17

upgrades—by posting flyers, distributing PHA newsletters, and holding discussions during 

resident meetings—would help residents understand the importance of utility conservation

and how their actions can either support or diminish a given project’s success (Q87). When 

asked whether these programs resulted in observable changes in residential utility use, two 

of nine respondents stated that they had observed noticeable changes; the remainder either 

observed no changes in behavior (three of nine) or indicated that they could not make the 

determination (four of nine) (Q88). 

A majority of affected residents are not required to pay their own utility bills because they

live in buildings that are master metered, which may partly explain the somewhat marginal 

change in resident behavior. Another contributing factor may be the relatively low resident 

turnout at the (PHA-provided) outreach and training programs. Seven of the nine 

respondents specified that turnout among their respective residents was no higher than 

25 percent (Q86). 

With increasing interest on the part of PHAs in promoting energy conservation partly countered 

by minimal engagement on the part of residents, it may be in HUD’s best interests to develop 

and disseminate resources aimed at energy conservation initiatives that draw on the rapidly 

developing literature on behavioral economics, with a particular focus on resident behavior 

modification strategies. Currently, in keeping with EPC regulations and guidance, projected 

savings from resident behavior modification strategies cannot be considered an EPC, although 

these strategies can be funded as a supporting project (soft) cost. As a result, any such

information dissemination will need to be conducted in parallel to the EPC program. Supporting 

this premise, the questionnaire found that eight of nine respondents would be willing to take

part in a future HUD research effort to identify viable strategies for promoting resident 

involvement in utility conservation (Q90). 

Analysis of Measurement and Verification, Utilities Expense Level Data, and 

HUD Assessment Data

In an effort to quantify the utility consumption savings associated with the study’s EPCs, the 

research team sought to gather and analyze M&V, utilities expense level (UEL), and HUD 

assessment data for each of the participating PHAs. M&V data document the installed 

improvements’ quantified savings based on the contractual agreements between the PHA and 

the ESCo or energy consultant, and are provided annually in accordance with each EPC’s unique 

schedule. UEL data (HUD administrative data) are self-reported by PHAs, and are recorded and 

submitted in accordance with HUD guidelines (that is, on a July 1 to June 30 basis). HUD 

assessment data document the achieved EPC savings and factors used by the Department to 

verify the savings as provided by agreements between the PHA and HUD.

Although the research team experienced difficulties with incomplete M&V datasets and did not 

find any HUD assessment data, an analysis was performed on the participating PHAs’ UEL data; 
18

annual development-level consumption quantities from Funding Years 2005–201517 (actual 

consumption spanning July 1, 2003 to June 30, 2014). The UEL data sets for each of the study’s 

participating PHAs can be found in appendix C.

Normalizing Utility Consumption Data 

When analyzing consumption data, the research team is cognizant that it is common practice to 

normalize the data in order to remove any variations associated with weather and buildingoccupancy conditions. Normalization allows a building’s performance to be compared against 

itself under normal operating conditions. Weather normalizing is typically based on daily or 

monthly measurements, while occupancy normalizing is generally analyzed from a monthly 

perspective.

For this study, neither of these normalizing approaches was performed. With the UEL data 

collected only on an annual basis, plausible correlations with respect to annual heating degreeday (HDD) and cooling degree-day (CDD) measurements were not observed. In addition, the 

research team assumed that the participating PHAs’ occupancy patterns were similar over the 

analyzed Funding Years.

Methodology and Limitations 

The research team’s approach toward analyzing the UEL data consisted of comparing the 

average consumption quantities of before and after the respective EPC phase was executed. 

This approach was chosen because (1) the UEL data sets consist of EPC and non-EPC related 

consumption quantities, and (2) each performance contract consists of a unique start date, 

which increases the likelihood that the reporting periods for a majority of the PHAs’ EPC 

incentives do not align with the UEL reporting cycle. Thus, with all of this taken into 

consideration, the research team’s intent is to provide a general analysis describing the 

effectiveness of the executed EPCs. 

Average Percentage Change Estimates 

Tables 8, 9, and 10 illustrate, for each applicable utility type, the average percentage savings 

observed after each PHAs’ first, second, and third EPC, respectively (if applicable). As previously 

mentioned in this report, four of the PHAs (AR002, KS001, MS107, and PA040) were in the 

initial phase of their performance contract, four (CO001, DE001, NY025, and PA046) had 

executed a second phase, and the remaining housing authority (TN005) had executed a third 

phase. In addition, Table 7 has been included to provide context regarding each PHA’s average 

percentage change, for applicable utility types, relative to their Funding Year 2005 UEL 

measurements.

 

17 Each Funding Year consists of 12 months of utility consumption data, starting 18 months prior to the beginning of the 

respective Funding Year. For example, Funding Year 2005 consists of consumption data from July 1, 2003–June 30, 2004.
19

Table 7: Average Percentage Change Relative to Funding Year 2005 Consumption Quantities

PHA Electricity Natural Gas Sewer/Water Sewer Water

PA046 20.95% -3.28% 17.09% N/A N/A

TN005 -11.75% -6.94% -39.65% N/A N/A

KS001 -0.85% -8.34% N/A -1.98% -8.04%

NY025a 0.06% -23.28% -------- N/A N/A

CO001 -33.77% -40.77% -32.59% N/A N/A

PA040 5.66% -10.21% N/A -9.40% -9.48%

DE001 -14.45% -38.16% -37.08% N/A N/A

MS107b -40.81% -47.05% -------- N/A N/A

AR002 0.21% -31.29% -12.08% N/A N/A

a The UEL data sets do not contain any measurements for NY025’s owner-paid sewer and water utility. b The UEL data sets do not contain any measurements for MS107’s owner-paid sewer and water utility.

The research team is cognizant that this analytical approach is not ideal and does not provide 

an accurate depiction of the value or savings associated with the installed EPC improvements.

However, considering that the UEL data sets are administrative data and the only consistently 

available resource for utility consumption analysis, the research team believes that the chosen 

approach is defensible. For the purposes of this study, the Funding Year in which the incentives 

for each PHAs’ EPC were initially observed mark the beginning of the post-EPC consumption 

period and span through Funding Year 2015. Similarly, all years prior to the Funding Year in 

which the incentives were initially observed mark the end of the pre-EPC consumption period

and span back to Funding Year 2005.

Table 8 displays that seven of nine PHAs observed average percentage decreases across all of 

their reported utilities after their first executed EPC, which positively illustrates reductions in 

consumption for a majority of the study’s participating PHAs. The two remaining PHAs were 

TN005 and MS107. TN005 executed its first EPC in Funding Year 1998; however, UEL data sets 

were not available until Funding Year 2005. MS107 observed an average percentage increase in 

utility consumption since executing its first EPC; however, from a positive perspective, Table 7 

illustrates that the housing authority has observed an overall average percentage decrease 

relative to its Funding Year 2005 UEL quantities.

Relative to the PHAs’ second EPC, Table 9 illustrates that all five PHAs in this subgroup observed 

average percentage decreases for at least one of their utilities. On a further positive note, Table 

9 reveals that two of the PHAs (PA046 and DE001) observed average percentage decreases for 

two of their utilities, while the remaining two PHAs (CO001 and TN005) observed average 

percentage decreases for all of their utilities.

Table 10 illustrates that the only PHA to have executed a third EPC (TN005) observed an 

average percentage decrease in utility consumption for all of its reported utilities.
20

Table 8: Average Percentage Change Relative to First EPC

PHA Electricity Natural Gas Sewer/Water Sewer Water Funding Year in Which Incentives 

Were Initially Observed 

PA046 -6.09% -38.62% -5.82% N/A N/A 2010

TN005 N/A N/A N/A N/A N/A 1998

KS001 -0.68% -11.85% N/A -7.98% -12.52% 2012

NY025a -2.57% -24.37% -------- N/A N/A 2008

CO001 -40.16% -56.70% -42.38% N/A N/A 2008

PA040 -2.05% -12.70% N/A -41.31% -41.03% 2013

DE001 -17.24% -43.57% -24.20% N/A N/A 2009

MS107b 45.58% 55.92% -------- N/A N/A 2011

AR002 -2.84% -44.87% -26.76% N/A N/A 2009

a The UEL data sets do not contain any measurements for NY025’s owner-paid sewer and water utility. b The UEL data sets do not contain any measurements for MS107’s owner-paid sewer and water utility.

Table 9: Average Percentage Change Relative to Second EPC

PHA Electricity Natural Gas Sewer/Water Sewer Water Funding Year in Which Incentives 

Were Initially Observed 

PA046 13.95% -43.56% -28.92% N/A N/A 2015

TN005 -9.83% -5.70% -33.57% N/A N/A 2009

KS001 N/A N/A N/A N/A N/A N/A

NY025a 4.47% -34.20% -------- N/A N/A 2011

CO001 -35.32% -50.47% -34.00% N/A N/A 2012

PA040 N/A N/A N/A N/A N/A N/A

DE001 23.40% -12.76% -7.88% N/A N/A 2015

MS107 N/A N/A N/A N/A N/A N/A

AR002 N/A N/A N/A N/A N/A N/A

a The UEL data sets do not contain any measurements for NY025’s owner-paid sewer and water utility.

Table 10: Average Percentage Change Relative to Third EPC

PHA Electricity Natural Gas Sewer/Water Sewer Water Funding Year in Which Incentives 

Were Initially Observed 

PA046 N/A N/A N/A N/A N/A N/A

TN005 -13.02% -11.36% -46.44% N/A N/A 2013

KS001 N/A N/A N/A N/A N/A N/A

NY025 N/A N/A N/A N/A N/A N/A

CO001 N/A N/A N/A N/A N/A N/A

PA040 N/A N/A N/A N/A N/A N/A

DE001 N/A N/A N/A N/A N/A N/A

MS107 N/A N/A N/A N/A N/A N/A

AR002 N/A N/A N/A N/A N/A N/A
21

Example Calculation 

To illustrate the procedure that was followed, the research team offers the following example.

The Kansas City Housing Authority (KS001) began observing its EPC incentives in Funding Year 

2012. KS001’s pre-EPC consumption period consisted of consumption from Funding Years 

2005–2011; having averages of 10,813,312 kWh (electricity), 25,457,333 kWh (natural gas), 

69,739,780 gal. (sewer), and 77,734,938 gal. (water). While the post-EPC consumption period 

spanned from Funding Years 2013–2015; having averages of 10,739,763 kWh (electricity), 

22,440,725 kWh (natural gas), 64,171,668 gal. (sewer), and 68,000,867 gal. (water). 

Therefore, by KS001’s average percentage changes for its utilities are:

Electricity: (10,739,763−10,813,312)

10,813,312

× 100% = −0.68%

Natural Gas: (22,440,725−25,457,333)

25,457,333

× 100% = −11.85%

Sewer: (64,171,668−69,739,780)

69,739,780

× 100% = −7.98%

Water: (68,000,867−77,734,938)

77,734,938

× 100% = −12.52%

By averaging each PHA’s utility consumption quantities from before and after their executed 

EPCs, the research team is able to provide rough estimates regarding the effectiveness of the 

EPCs.

Public Housing Policy Inquiries

At the outset of this project, PIH requested that we explore three policy-related issues that 

could be informed by the study:

1. Whether to allow PHAs to use utility savings from EPCs for non-energy-related or nonwater-related capital improvements. 

2. Whether to provide a compensatory fee to PHAs that choose to self-manage their EPC. 

3. Whether the degree of rigor of the EPC application process is necessary to ensure the 

cost-effectiveness of projects. 

To address these considerations, the research team incorporated relevant content in the 

questionnaire. The following discussion describes feedback derived from the questionnaire and 

observations proposed by the research team. However, since these observations were based 

on a relatively small and therefore unrepresentative sample of PHAs, PD&R may revise these 

observations based on the results of its larger, nationwide study of the EPC program.

Apply EPC Utility Savings Toward Non-Energy-Related and Non-Water-Related

Capital Improvements 

The questionnaire asked participants if their housing authority would benefit if HUD allowed 

achieved utility savings from EPCs to be applied toward non-energy-related and non-waterrelated capital improvements. 
22

Current PIH guidance specifies that any savings generated by the installed EPC improvements 

and retained by the PHA may be used to pay for—18 

1. Any eligible operating expense. 

2. EPC debt service on other projects under the same EPC contract. 

3. Additional energy-efficient or green building improvements that can be achieved by 

expanding the current project. 

4. The acceleration of debt service on the existing project, if permitted under the financing 

contract. 

Six of eight respondents believed that allowing excess EPC savings to be applied toward 

capital improvements would be beneficial. One respondent did not believe that such change 

would help, and the remaining respondent indicated that it was not sure (Q40). One of the 

study’s nine participants did not respond to this question.

In terms of providing maximum flexibility for grantees and providing incentives for the further 

adoption of EPCs at additional PHAs, the research team views as compelling the favorable 

response by a majority of respondents to the question about allowing EPC savings to be applied 

toward capital improvements. 

Observation: Allow EPC savings for capital needs and provide guidance on incorporating 

a contingency reserve into a project’s total costs.

Based on the findings in this report, we recommend that HUD should consider whether the four 

existing EPC categories of eligible uses can be expanded to allow for savings generated to be 

used for capital improvements. This fifth category of eligible use would allow for greater 

flexibility for participating PHAs and provide additional incentives for additional PHAs to 

consider entering into new EPC arrangements. We would also recommend that if HUD 

determines it lacks the authority to make this change based on existing statutory requirements, 

then HUD should consider proposing such a change to Congress. Such an observation could be 

included in an annual budget request.

One constraint identified by some respondents is the requirement that the EPC’s anticipated 

savings need only be sufficient to reasonably cover all of the debt service within 20 years of 

executing the contract. Such a stipulation implies that for an EPC, in some circumstances the 

achieved savings will not be enough to cover the debt service, in which case a housing authority 

might have to use additional Operating Fund resources to make up the difference.

Such a situation may also occur as a result of a lower than expected Operating Fund allocation, 

for instance in the event of a proration. Each fiscal year, Congress has the authority to 

appropriate a percentage of the requested funding level that HUD submits in support of the 

funds needed to operate and maintain the nation’s public housing stock. Since FY 2005, the 

 

18 The only exception to this specification is when the term of the EPC contract is complete and the PHA requests a regulation 

waiver to use excess EPC cost savings for purposes other than eligible Operating Fund expenses.
23

average Operating Fund subsidy has only been 90 percent,19 which forces housing authorities 

to alter their operations and prioritize the services and maintenance they provide and the staff 

they employ. Such funding levels may create a dilemma for PHAs in which the funds are

insufficient to service the EPC debt while physically maintaining public housing properties. To 

guard against this potential appropriations risk, the research team recommends that future 

HUD guidance should emphasize the benefit of incorporating a contingency reserve into the 

project’s total costs. Such a reserve could be used to cover EPC debt service in the event of a 

reduced appropriation. Such a provision might be an important incentive for smaller PHAs that 

have a low margin for error in a limited annual Operating Fund environment.

Provide a Compensatory Fee to PHAs That Self-Manage an EPC

Participants also were asked whether a PHA that chooses to self-manage an EPC should be 

compensated for this effort. 

Six of nine respondents specified that they do believe that a PHA should be compensated for 

the effort of self-managing an EPC; the other three respondents indicated that they do not 

believe compensation should be provided for such actions (Q51).

In addition to the complexities associated with applying to the EPC program, self-managing an 

EPC requires the housing authority to serve as general contractor, which can be complex and 

cumbersome regardless of the type of improvements that are installed. Self-managing PHAs 

must take on the additional burden of coordinating and overseeing all of the work performed 

by their subcontractors. 

Observation: Allow compensatory incentives.

Considering the challenges of meeting the additional requirements of self-managing an EPC, the 

research team believes that instead of being provided a compensatory fee, this subgroup of 

PHAs should be compensated for their efforts by being provided greater flexibility in how a 

project’s resultant cost savings may be used. Such flexibility may include broadening the ways 

in which the cost savings may be used20 or decreasing the required percentage of annual cost 

savings paid toward EPC debt services (HUD, 2011).

21 

PD&R is cognizant that the initial intent of this policy-related issue was to inquire about 

whether to provide PHAs a compensatory fee for EPC self-management. However, after careful 

consideration, the research team is hesitant to recommend a fee that will take away from the 

bottom-line dollar amount that PHAs can use toward financing improvements and other 

project-related expenses. 

 

19 On December 23, 2015, HUD’s Real Estate Assessment Center provided a historical proration table (1981–2015) of the Public 

Housing Operating Fund.

20 As described earlier in the report, any savings generated by the installed improvements may be used to pay for: (1) eligible 

operating expenses, (2) EPC debt service on other projects under the same EPC contract, (3) additional energy-efficiency or 

green building improvements, or (4) accelerating the debt service of the existing project.

21 PIH guidance specifies that 75 percent of the annual utility savings must be utilized toward the payment of EPC project costs. 

In cases in which less than 75 percent of the savings is used for debt service, HUD will retain the amount of the difference by 

reducing the project’s subsidy by that amount.
24

Providing such incentives would likely encourage more PHAs to self-manage their EPCs, which 

will promote greater oversight and overall efficiency of the funded project because the 

participating housing authorities would be more vested in the executed contracts and an 

innovative Department incentive aimed at reducing the public housing portfolio’s utility 

consumption would be illustrated. 

Is the Rigor of the Application Process Necessary To Ensure a Cost-Effective Project? 

Participants were asked if they thought that the rigor of the EPC application process was 

necessary for HUD to ensure the cost-effectiveness of the project. 

Seven of nine respondents indicated their belief that the present degree of rigor on HUD’s 

part is necessary to ensure the cost-effectiveness of a given project is (Q60). 

The research team finds this viewpoint to be well founded, given the large sums of money 

involved,

22 the technical documentation that must be submitted, and the risks inherent in 

complex EPC agreements. As previously stated, process flow diagrams (under “EPC Process 

Review” on the PIH EPC webpage)23 have been developed that outline the multiple steps that 

PHA applicants and HUD must complete before an application can receive approval.

Observation: Maintain the rigor of the EPC application requirements.

The research team has observed that thorough application reviews are key in the success of the 

EPC program, and that these reviews benefit both the PHAs and HUD. Therefore, this report 

recommends maintaining the rigor of the current application process requirements, as the 

benefits outweigh the costs of complying with those requirements.

The team observed a data limitation that affects the measurement of how rigorous the EPC 

review efforts are, however. The ideal approach to analyzing applications would assess 

approval times relative to achieved savings. As described in more detail in the “Observations” 

section that follows, data on achieved savings are not currently collected. Data on achieved 

savings could support a new evidence-based metric on cost-effectiveness of review efforts. This 

limitation and an observation to address it are discussed in the following section. 

 

22 Of the 315 EPCs listed within the PIH Excel data sets, 294 had a plausible “Total Cost of EPC Project” quantity. The research

team found that the EPC project costs ranged from $63,400,000 to $38,000, wherein the average EPC Project Cost was 

$4,800,000. 

23 http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/programs/ph/phecc/eperformance. 
25

Summary

The goal of this pilot study was to conduct an initial inquiry into the value and effectiveness of 

PIH’s EPC program to inform a more comprehensive nationwide study of the use of energy 

performance contracts by PHAs. EPCs are a regulatory tool providing flexible financing options 

for PHAs to use resultant utility cost savings to fund utility-related capital improvements. By 

providing enhanced financial flexibility to PHAs, EPCs encourage them to make more strategic 

and comprehensive utility upgrades than they could undertake with limited capital funds. 

As HUD administers the EPC program to promote long-term benefits, a core aspect is ensuring 

regulatory compliance and minimizing risks to the Department and taxpayers. A successful EPC 

program will reduce utility consumption within the federally assisted housing stock, ease the 

financial burden on taxpayers, alleviate negative impacts on the environment, and create green 

jobs.

The study’s survey demonstrated that the EPCs for this set of PHAs were a success. The 

following findings support this contention— 

• Eight of nine respondents stated that their performance contract was of benefit to their 

housing authority (Q55).

• Eight of nine respondents indicated that only a portion of installed improvements would 

have been made without the flexibility provided by the EPC program (Q62).

• Five of nine respondents noted having achieved cost savings after paying the annual 

debt services on their EPC (Q38).

• Eight of nine respondents stated that their executed performance contract was either 

overperforming or performing as projected (Q35).

• Six of seven respondents believe they would not have been able to achieve the same 

amount of savings in the absence of the EPC (Q63).

• Six of eight respondents believe that allowing excess EPC savings to be applied toward 

capital improvements would be beneficial (Q40).

• Six of nine respondents believe that a PHA should be compensated for the effort of selfmanaging an EPC (Q51).

• Seven of nine respondents believe that rigorous review on HUD’s part is necessary to 

ensure the cost-effectiveness of projects (Q60). 
26

Observations Supporting EPC Program Objectives

The preceding section summarized the research team’s findings and observations related to the 

three policy questions posed by PIH. In the following section the team offers five additional 

observations on the basis of this research. However, because these observations were based on 

a relatively small and therefore unrepresentative sample of PHAs, PD&R may revise these 

observations based on the results of its larger, nationwide study of the EPC program. 

In proposing these observations, the research team kept these four EPC program objectives in 

mind— 

1. Reducing the approval time of an EPC application. 

2. Providing more transparency in the Department’s application review efforts. 

3. Providing PHAs with further guidance on the collaborative use of an EPC and RAD. 

4. Providing more transparency in the realized savings of an EPC. 

Objective: Reducing the Approval Time of an EPC Application

Observation: Develop a PHA-EPC working group.

Establish a PHA-EPC working group to allow PHAs that have executed an EPC to serve as 

champions of the EPC program and as mentors to housing authorities that are new to the EPC 

application process. Such a working group would serve as a peer-review mechanism that can be 

beneficial to the Department and participating housing authorities by establishing a costeffective strategy to promote the EPC program and provide assistance and guidance from a 

more hands-on perspective, and to reduce the overall burden placed on HUD staff during 

application review.

As noted previously, results from the questionnaire indicate that, from a utility performance 

perspective, eight of nine participants had executed an EPC that was performing as projected or 

above the initial estimated savings projections (Q35). In addition, five of the nine participants had 

executed at least a second phase of their existing EPC. Taken together, these results indicate that 

the program is of value from a utility performance perspective, and that many of the participating 

PHAs can be considered well versed in the intricacies of the application process.

Considering that only approximately 10 percent of the public housing stock (approximately 

20 percent of the overall public housing unit count) has been covered by an EPC since the 

program’s inception, an important opportunity lies in leveraging the first-hand knowledge and 

experiences of participating PHAs to strengthen the EPC program by establishing a working 

group. Such a collaborative approach would entail ongoing, reciprocal communication among

the PHAs and HUD’s EPC staff, and would likely encourage more housing authorities to inquire 

about and apply to the program. Gaining active support among members of the PHA 

community would also be likely to encourage buy-in from the representative trade groups that 

advocate for the PHA community—primarily the Public Housing Authorities Directors 

Association (PHADA), National Association of Housing and Redevelopment Officials (NAHRO), 

and Council of Large Public Housing Authorities (CLPHA). 
27

Such a working group could also prove beneficial in light of the limited programmatic resources 

currently available to housing authorities in the EPC application process. During the site visits 

and interviews with subject matter experts, the research team observed that a significant 

programmatic hurdle encountered by many participants is the time required to receive EPC 

approval. The research team is aware that the application process is highly complex, given the 

number of factors that must be taken into account. In analyzing the approval times for the 

participating PHAs, the team found that for seven of the nine housing authorities, the average 

approval time took 250 calendar days24 (roughly 8 months) and included the time in which 

PHAs or ESCos made revisions to the applications. 

By instituting a peer-review mechanism for PHAs that are new to the EPC application process, 

the potential exists to substantially reduce the amount of time the Department spends in 

assuring that all required application forms are appropriately submitted. This in turn would 

allow the Department to focus its resources toward reviewing the technical aspects of an EPC 

application and to providing more detailed technical support and guidance when necessary. 

Objective: Providing Greater Transparency in the Department’s Application 

Review Efforts

Observation: Revise the duration metric of the EPC application approval time.

For this effort, the research team measured the overall approval time for an EPC application 

from the date when the application package was received to the date when the 

corresponding EPC approval letter was sent to the subject PHA. For the study’s nine 

participating PHAs, the average approval time was 250 calendar days24 (approximately 8 

months) and included the time in which PHAs or ESCos made revisions to the applications. 

Within the past 3 years, the Department has further refined this metric to account separately

for the time HUD is reviewing the application and the time the PHA is revising the application. 

Although it is logical for accounting purposes to measure how long the Department has the 

EPC application and how long the PHA has it, this approach doesn’t fully take into account the 

level of effort the Department expends in reviewing the application. The research team 

recommends supplementing the approval time metric with a metric and additional discussion 

that captures the Department’s review efforts related to an approved EPC’s total project 

costs. 

Results from the questionnaire indicate that seven of nine respondents believed the rigor 

associated with the application process was necessary to make sure that the EPC was cost-

 

24 For the purposes of this analysis, the approval times were calculated as the difference between the dates listed in the 

“Package Received” and “Date FO sent Approval/Disapproval to PHA” columns of the Contract_Status_Database.xlsx 

spreadsheet. These dates were chosen to illustrate the overall time that it takes for an EPC application package to receive 

approval, including the time in which PHAs or ESCos made revisions to the applications. The spreadsheet did not contain any 

information pertaining to the North Little Rock Housing Authority (AR002), and the Housing Authority of the County of Chester 

(PA046) did not have a date listed in the “Date FO sent Approval/Disapproval to PHA” column. In total, the spreadsheet listed

133 EPCs on its “ESA” (Energy Service Agreement) tab, wherein 72 of the entities had plausible “Package Received” and “Date 

FO sent Approval/Disapproval to PHA” dates. For these 72 entities, the research team found that the approval times ranged 

from 9 to 1,013 calendar days, wherein the average approval time was 193 calendar days (roughly 6 months).
28

effective (Q60). The research team believes that this viewpoint is well founded, considering the 

large sums of money involved25 and the risks inherent in complex EPC contractual agreements. 

For an EPC, the PHA is held accountable for the total project costs of the contract: debt service 

payments, M&V fees, and equipment replacement costs. 

As previously mentioned, the Department conducts multiple stages of review during the EPC 

application process to ensure compliance with HUD regulations and guidance and to minimize

risk to the Department. During these review periods, HUD may require adjustments to the PHA

applicant’s cost and saving estimates, which in turn have an effect, either directly or indirectly,

on the total project costs for which the housing authority will be held accountable. 

To account for the level of effort the Department invests in reviewing each application to 

ensure cost-effectiveness, minimize associated risks, and ensure adherence to HUD regulations 

and guidance, PIH should supplement the approval time metric to take into account changes in 

total project costs relative to the proposed EPC, as well as the overall duration of the 

application process.26 Instituting a policy that employs such metrics would assist PIH in 

justifying (and being more transparent about) the duration and level of effort involved in the 

EPC application review process. 

Objective: Providing Further Guidance on the Collaborative Use of an EPC 

and RAD

Observation: Develop a decision logic tree in support of using an EPC in conjunction 

with RAD.

HUD recently released a FAQ27 document that describes the use of an EPC in 

conjunction with RAD. RAD allows PHAs to leverage public and private debt and equity 

in order to reinvest in the public housing stock. Through RAD, units move to a Section 8 

platform with a long-term contract that, by law, must be renewed periodically. This 

renewal clause ensures that the units remain permanently affordable to low-income 

households, thus removing the units from HUD’s public housing inventory and possibly 

from the EPC funding stream. 

As previously mentioned, if a PHA wishes to convert all or a portion of its EPC-related 

properties to RAD, it must first determine how it plans to satisfy the existing EPC 

obligation. Housing authorities have the option of either paying off the EPC debt or 

assuming the debt and continuing to make the EPC debt payment after conversion to 

 

25 Of the 315 EPCs listed within the PIH Excel data sets, 294 had a plausible “Total Cost of EPC Project” quantity. The research

team found that the EPC project costs ranged from $63,400,000 to $38,000, wherein the average EPC Project Cost was 

$4,800,000. 

26 For example, a PHA submitted, on April 1, an EPC application that spanned 12 years and consisted of $100,000 in total project

costs. During the PIH review process, it is determined that incorrect utility rates were used to estimate the installed 

improvement’s projected savings, resulting in a decrease in total project costs by $5,000. As a result, the application is 

approved on August 15 and consists of a total project costs amount of $95,000. The Revised Duration Metric would consist of 

an approval time of 136 calendar days (~ 4.5 months) and a change in total project costs of -$5,000 (5 percent decrease in total 

project costs).

27 http://portal.hud.gov/hudportal/documents/huddoc?id=RAD_EPC_FAQs_030316.pdf. 
29

RAD. In instances such as this, PHAs must notify the Field Office of their intent and 

establish a new baseline utility consumption measurement for the portion of the project 

that remains in public housing and continues to receive EPC incentives.

The research team is hopeful that the FAQ document will be well received by the PHA 

community, because several PHAs that participated in the study stated that they did not 

clearly understand whether a RAD conversion would benefit them. In addition, during 

preliminary discussions with potential study participants, several of the non-selected 

PHAs declined or were hesitant to participate in this study because they were 

considering a RAD conversion. Given both the complexities and the level of effort that 

PHA and HUD staff invest in preparing and approving an EPC application, the research 

team recommends that the FAQ document be expanded to include a logic-based 

decision tree (similar to the flow diagrams necessary for application approval) that will 

assist PHAs in working through the decisions that should be taken into account when 

considering a conversion of EPC-related PHA units (Section 9) to RAD units (Section 8). 

Objective: Providing More Transparency in the Realized Savings of an EPC

Observation: Annually update cash flow spreadsheets.

A PHA’s finalized cash flow spreadsheet for an EPC establishes benchmarks in the form of 

annual costs and savings that can be expected to accrue on the PHA’s behalf. Embedded within 

these projections are critical assumptions about factors that are beyond the PHA’s control and 

that can affect actual cost savings.

Examples of critical assumptions include the escalation rates associated with future energy 

savings and the annual maintenance costs of replacement equipment. A typical assumption for 

electrical service rates is that the rates will increase 3 percent per year. In many localities these

rates are not fixed and may periodically observe either reductions or modest increases over the 

course of the performance contract. Similarly, the replacement costs for EPC-installed 

equipment are generally correlated to the equipment’s useful life expectancy and scheduled 

maintenance intervals. As a performance contract unfolds, multiple factors may cause this 

equipment to be replaced more frequently than projected in the life expectancy developed by 

the manufacturer. Due to actual versus projected energy savings and maintenance costs, the 

PHA that has executed the EPC may retain smaller annual excess cash-flow amounts than those 

initially projected. 

To assist both the Department and the PHAs in evaluating the performance of EPCs, the 

research team recommends that PIH should require annually updating the spreadsheets’ 

projected costs and savings with realized quantities. Instituting such a policy would substantiate 

the EPC program’s inherent benefits and would provide a valuable comparison of the 

performance contract’s projected and actual savings. 
30

Observation: Align the reporting periods of the annual M&V reports with annual 

UEL quantities. 

HUD’s EPC guidance requires PHAs to submit annual M&V reports to HUD field offices for 

reconciliation of estimated savings amounts. The submitted reports display the annual 

consumption and cost quantities, typically on a monthly basis, for the project’s affected 

properties. The reporting periods for the respective reports are dependent on the completion 

of the installed EPC improvements and may not coincide with HUD’s UEL reporting period of 

July 1 to June 30.

While analyzing the submitted M&V reports, the research team consistently encountered 

difficulties in verifying reported savings quantities relative to annual UEL quantities submitted 

by the PHAs. During site visits, several PHAs noted this same difficulty. 

The research team recommends requiring that the reporting periods for the submitted annual 

M&V reports align with the annual cycle in which PHAs report UEL quantities (July 1 to June 30); 

in this way the proposed EPC savings can be verified. PD&R is cognizant of the different 

reporting periods for the varying EPC incentives (July 1 to June 30 for the FRB and RPU 

incentives and January 1 to December 31 for the AOS incentive) but believes that a uniform 

M&V reporting period will be beneficial to the EPC program. 

Key benefits stemming from such an approach would include creating greater transparency in 

the savings reported by the serving ESCo or third-party consultant while providing an additional 

QC measure for the submitted M&V reports. For PHAs that receive the AOS incentive, the 

research team does not believe that it will be too burdensome for the servicing ESCo or thirdparty consultant to approximate or combine savings quantities from adjacent AOS reporting 

periods. 
31

Conclusion

Even with a small sample of PHAs, the pilot research described in this report provided 

numerous observations about the relative strengths and weaknesses, regulatory intent, and 

general effectiveness of the EPC program. The responses and viewpoints of the participating 

public housing staff were central to the development of the study’s major observations.

Although participating PHAs were fairly diverse in size and location, they are in no way 

representative of all PHAs. PD&R’s followup study of the EPC program will be a more 

representative, nationwide effort intended to provide a more complete picture, definitive 

understanding, and comprehensive evaluation of the EPC program. 
32

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———. 2011. Guidance on Energy Performance Contracts. Washington, DC: U.S. Department of 

Housing and Urban Development. 

https://portal.hud.gov/hudportal/documents/huddoc?id=pih2011-36.pdf. 

———. 2014. Guidance on On-Site Utility Technologies and the Rate Reduction Incentive in 

Public Housing. Washington, DC: U.S. Department of Housing and Urban Development. 

http://portal.hud.gov/hudportal/documents/huddoc?id=pih2014-18.pdf.
33

Appendix A

Questionnaire Administered to Study Participants

Evaluation of Energy Performance Contracts 

in Public Housing Authorities 

Pre-Site Visit Questionnaire

INTRODUCTION

Welcome to the Evaluation of Energy Performance Contracts (EPCs) in Public Housing 

Authorities (PHAs). This questionnaire is part of research being conducted by the U.S. 

Department of Housing and Urban Development (HUD), Office of Policy Development and 

Research (PD&R), which provides reliable and objective research to help the Department make 

policy decisions.

HUD’s Office of Public and Indian Housing (PIH) reports that the Department has approved over 

250 EPCs, totaling nearly $1 billion in investments since this type of financing technique began 

in the 1980s1. EPCs have been executed in all 10 HUD regions and in PHAs ranging from very 

small (fewer than 250 units) to very large (6,600 units or more). To date, however, there is 

limited research on the effectiveness and value of these contracts.

PD&R’s current research is a preliminary examination and documentation of the savings, 

benefits, and lessons learned from the EPC program at a small number of PHAs. In addition to 

this questionnaire, PD&R intends to conduct site visits and in-person discussions with PHA staff, 

examine installed utility improvements, and collect other EPC-related data.

This baseline study will provide a better understanding of the costs incurred by participating 

PHAs as they have implemented their PHAs. Furthermore, the study will be used to design a 

more informed and comprehensive cost-benefit analysis proposed to begin in FY16.

These research efforts will be key to HUD’s long-term strategies, in part because the EPC 

program is being affected by the advent of HUD’s Rental Assistance Demonstration2 (RAD), 

which removes projects from HUD’s public housing inventory and possibly from the EPC funding 

stream.

 

1 U.S. Department of Housing and Urban Development, “EPC Database: Summary Statistics,” 

http://portal.hud.gov/huddoc/2011EPCInventory.xls. 

2 U.S. Department of Housing and Urban Development, “Rental Assistance Demonstration,” 

http://portal.hud.gov/hudportal/HUD?src=/RAD. 
34

Please submit (via email) your completed survey to: michael.j.early@hud.gov and 

michael.d.blanford@hud.gov. 

If you have questions regarding the questionnaire and/or the study, please contact Mr. Michael 

J. Early, Research Engineer, Office of Policy Development and Research, HUD at: (202) 402-2566 

or michael.j.early@hud.gov or Mr. Michael D. Blanford, Research Engineer, Office of Policy 

Development and Research, HUD at: (202) 402-5728 or michael.d.blanford@hud.gov. 

BACKGROUND

EPCs are an innovative financing technique designed to provide customers with cost-effective 

improvements—energy conservation measures (ECMs)—that are installed without up-front 

expenditures. The costs of the improvements are borne by the performance contractor and 

repaid using a portion of the cost savings resulting from the improvements. Due to the 

complexities and risks associated with estimating the savings and acquiring the improvements, 

EPCs are often performed by Energy Service Companies (ECSOs)—firms that provide a broad 

range of energy services, including design, acquisition, installation, testing, operation, and 

measurement and verification (M&V) of the installed improvements.

An ESCo’s business model is driven by the upfront cost of the installed improvements and 

estimated flow of savings that will accrue during the improvement’s payback period. As a 

result, ESCos may have incentives not to favor projects with high initial costs and long payback 

periods, but instead, to focus on ‘low hanging fruit’ (i.e., those of low cost, simpler complexity, 

and shorter payback periods).

HUD’s EPC program provides PHAs with four incentives3 to fund energy conservation 

improvements: Frozen Rolling Base Incentive (FRB), Add-On Subsidy Incentive (AOS), ResidentPaid Utility Incentive (RPU), and Rate Reduction Incentive (RRI). The FRB, AOS, and RPU 

incentives are designed to reduce PHA utility consumption relative to an established baseline, 

while the RRI allows PHAs to collect resultant cost savings from actions aimed at reducing the 

utility rate paid. Each of these incentives consists of unique requirements. But in total, they are 

designed to provide PHAs cost savings that enable them to allocate more of their operating 

subsidy toward needed repairs and other eligible expenses.

GUIDE TO THE QUESTIONNAIRE

Your housing authority is being asked to complete this questionnaire because you have 

expressed an interest and availability to participate and PD&R has selected your PHA for this 

study. 

 

3 U.S. Government of Publishing Office. Code of Federal Regulations. Title 24, Section 990.185. Utilities expense level: Incentives 

for energy conservation/rate reduction. 2011.
35

This questionnaire will examine PHAs that have executed an EPC and examine: 1) the achieved 

long-term utility savings; 2) how the resultant cost savings have been utilized; 3) the process, 

time, and workload, from the PHA’s perspective, associated with applying to the EPC program, 

and 4) the identified barriers to entering the EPC program.

There are a total of 4 sections to this questionnaire. 

• Section A asks about general EPC-related questions.

• Section B asks about utility conservation and cost savings.

• Section C asks about developing and managing an EPC.

• Section D asks about resident-related matters pertaining to the executed EPC.

To respond to the questionnaire, the respondents will need to have an understanding of the 

EPC that has been executed at your housing authority.

Generally, respondents should provide information about their housing authority’s EPC and 

viewpoints as they exist today. Some questions, however, will specifically ask for historical 

information (e.g., a question may include a phrase such as “in hindsight”) or projected 

information (e.g., a question may include a phrase such as “in the future”).

Please answer the questions by providing a response that comes closest to describing details 

related to your Housing Authority’s perspective on the executed EPC. 

A response is required for all questions marked with an asterisk (*). 

If your EPC has performed multiple phases for the executed EPC, please provide your responses 

relative to the information described in the Summary of Energy Performance Contracts (EPC) 

table listed on page. 4. 

PD&R will use responses to this questionnaire only for research purposes. No information 

provided for this study will be used for compliance monitoring. 

Following collection and analysis, aggregated results will be published for all interested parties 

(independent of participation in the collection) to use. The published data will consist of 

aggregated results and NOT contain information that can be used to identify specific housing 

authorities. 
36

SUMMARY OF ENERGY PERFORMANCE CONTRACTS (EPCS) 

For the purposes of this study, Departmental records indicate the following information related to your PHA’s executed EPC. Please 

review the information below to ensure that the PD&R Research Team has an accurate account of the executed EPC. 

If any of this information is incorrect or missing, please select this box ☐ and provide the correct information further below. 

Public Housing Authority

PHA Characteristics Total Contract Costs: HUD Incentives

(% of Project Costs) M&V Risk

# of Affected Units Financing Costs Frozen Rolling Base Measured

# of Developments

(Projects / Sites) M&V Costs Add-On Subsidy Stipulated 

ESCo Maintenance Costs Resident Paid Utilities

Contract Term (yrs) Replacement Costs Rate Reduction 1st Year

Est. Savings

EPC Phase Total Other Costs Proj. Savings

(over EPC term)

Total Project Costs

In the area below, please describe any necessary corrections to the information listed above.
37

Section A: General EPC-Related Questions

*1. For the executed EPC, who performed the investment grade energy audit (IGEA)?

☐ ESCo that managed/managing the EPC (SKIP TO Question 3)

☐ 3rd-party Consultant

☐ Other

2. Please identify the entity that performed the IGEA.

*3. Is your PHA satisfied with the completed IGEA?

☐ Yes (SKIP TO Question 6)

☐ No

4. If you were not satisfied with the completed IGEA, what are the reasons for your 

dissatisfaction? (Check all that apply) 

☐ Audit didn’t correctly scope out the necessary work

☐ Audit didn’t reveal any information that wasn’t 

already known

☐ Other (GO TO Question 5)

5. If you selected “Other” for Question 4, please identify the other reasons for your 

dissatisfaction with the IGEA. 

*6. During the development process of the executed EPC, who developed the list of 

recommended improvements? (Check all that apply) 

☐ ESCo that managed/managing the EPC

☐ Third-party Consultant

☐ PHA staff

☐ Other (GO TO Question 7)
38

7. If you selected “Other” for Question 6, please identify the other entities that developed the 

list of recommended improvements for your executed EPC? 

*8. What factors were considered when developing the list of recommended improvements? 

(Check all that apply) 

☐ Findings from the performed IGEA

☐ Capital Fund Program Five-Year Action Plan

☐ REAC Physical Inspection

☐ Routine inspections performed by PHA staff

☐ Concerns raised by residents

☐ Other (GO TO Question 9)

9. If you selected “Other” for Question 8, please identify the other factors that were considered 

when the recommended list of improvements was developed. 

*10. Were all of the recommended improvements incorporated in to the Energy Service 

Agreement (ESA) and installed under the executed EPC? 

11. If only a portion of the recommended improvements were installed, why was that? (Check 

all that apply) 

☐ Lack of funding

☐ Additional improvements were or will be performed 

using other funds (e.g., Capital Improvement)

☐ Additional improvements were or will be deferred to a 

subsequent period of time

☐ Executed EPC would not have been cost-effective if 

additional improvements were installed

☐ Yes (SKIP TO Question 13)

☐ No
39

☐ Other (GO TO Question 12)

12. If you selected “Other” for Question 11, please identify the other reasons for installing only 

a portion of the recommended improvements. 

*13. Was or will the total cost of the executed EPC be within the Energy Service Agreement’s 

(ESA) initial estimated budget?

☐ Yes (SKIP TO Question 17)

☐ No

14. If cost overruns occurred, how much more was or will the total cost of the executed EPC be 

relative to the contract’s initial estimated budget?

☐ <25%

☐ 26-50%

☐ 51-75%

☐ >75%

15. What were the reasons for the cost overruns? (Check all that apply) 

☐ Incorrect improvements were bought or installed

☐ Changes in the type or quantity of installed improvements 

☐ Initial cost of improvements or services changed

☐ Other (GO TO Question 16)

16. If you selected “Other” for Question 15, please identify the other reasons why cost overruns 

occurred. 
40

*17. Was the work associated with the construction phase of the executed EPC completed on 

schedule? 

☐ Yes (SKIP TO Question 20)

☐ No

18. If schedule (construction phase) delays occurred, what were the reasons for the delays? 

(Check all that apply) 

☐ Incorrect improvements were installed

☐ IGEA did not correctly scope out the work

☐ EPC work could not be performed until other improvements 

(e.g., capital improvements) were completed

☐ Other (GO TO Question 19)

19. If you selected “Other” for Question 18, please identify the other reasons why the schedule 

(construction phase) delays occurred. 

Currently, HUD guidance specifies that the term of an EPC, including any applicable extensions, 

can be no more than 20 years. Questions 20-23 ask questions related to this limit.

*20. If permissible under HUD guidelines, would your PHA consider completing another phase 

of the executed EPC?

☐ Yes

☐ No

*21. If HUD extended the maximum term of an EPC beyond 20 years, would your PHA consider 

adding another phase to your executed EPC? 

☐ Yes

☐ No

*22. In hindsight, if the maximum term of an EPC was extended beyond 20 years, would your 

PHA have installed improvements that would have been more cost effective over the term of 

the EPC (i.e., provided greater long-term savings)? 
41

☐ Yes

☐ No

*23. Does your PHA believe that extending the maximum term of an EPC beyond 20 years 

would encourage more PHAs to participate in the EPC program? 

☐ Yes

☐ No

☐ Don’t Know

*24 Is your PHA satisfied with the EPC incentives used? 

☐ Yes

☐ No

*25. Does your PHA wish that other EPC incentives were used? 

☐ Yes

☐ No (SKIP TO Question 27)

26. Excluding the incentives used in your executed EPC, what additional incentives would your 

PHA have used? (Check all that apply) 

☐ Frozen-Rolling Base

☐ Add-On Subsidy

☐ Resident Paid Utility

☐ Rate Reduction Incentive

*27. Did your PHA leverage funds other than EPC funds to install additional improvements in 

conjunction with the executed EPC?

☐ Yes

☐ No (SKIP TO Question 30)

28. If other funds were leveraged, what type of funds were they? (Check all that apply) 

☐ Capital Funds / Capital Reserves

☐ Direct Purchase

☐ Third-Party Leasing

☐ Power Purchase Agreement (PPA)

☐ Rebate Program

☐ Grant Program

☐ Bond Program

☐ Other (GO TO Question 29)
42

29. If you selected “Other” for Question 28, please identify the other leveraged funds. 

Section B: Energy Conservation and Cost Savings

*30. How does your PHA monitor the performance of your executed EPC? (Check all that apply) 

☐ Annual ESCo provided measurement and 

verification (M&V) reports

☐ PHA-based monitoring

☐ Independent third-party monitoring

☐ Other (GO TO Question 31)

31. If you selected “Other” for Question 30, please identify the other approaches toward 

monitoring your executed EPC. 

32. If performance monitoring occurs in addition to the annual ESCo provided M&V reports, 

how frequently does this monitoring occur?

☐ Monthly

☐ Quarterly

☐ Every 6 months

☐ Randomly

*33. What is monitored and reported during the M&V process? (Check all that apply) 

☐ Utility Consumption

☐ Utility Expenditures

☐ Equipment Life Expectancy
43

☐ Operation and Maintenance (O&M) Practices

☐ Other (GO TO Question 34)

34. If you selected “Other” for Question 33, please identify any other elements that are 

monitored during the M&V process. 

*35. Since the completion of the construction phase for your executed EPC, how are the actual 

utility savings compared to the initial estimated savings?

☐ Performing as Projected (SKIP TO Question 38)

☐ Under Performing

☐ Over Performing (SKIP TO Question 37)

36. Please explain, to the best of your knowledge, why the improvements are Under 

Performing. 

SKIP TO Question 38 

37. Please explain, to the best of your knowledge, why the improvements are Over Performing. 

*38. After paying the annual debt services on your executed EPC, does your PHA realize any 

excess savings? 
44

☐ Yes

☐ No (SKIP TO Question 40)

39. How has your PHA used the achieved annual cost savings? (Check all that apply) 

☐ Installed additional improvements by expanding the current EPC

☐ Accelerated debt service on the executed EPC

☐ Paid eligible operating expenses

*40. If HUD permitted PHAs to apply achieved utility savings from EPCs toward capital 

improvements, would this be of benefit to your PHA?

☐ Yes

☐ No

HUD guidance on the payment of EPC debt specifies that at least 75 percent of cost savings 

must be paid toward annual EPC debt services and project costs. Questions 41-43 ask questions 

related to this requirement.

*41. Would your PHA have undertaken different or additional improvements if it was not 

required to pay 75 percent of the cost savings toward EPC debt services and project costs? 

☐ Yes

☐ No

*42. Would lowering the amount (percentage) of cost savings that must be paid toward the 

debt service of an executed EPC be of benefit to your PHA?

☐ Yes

☐ No

*43. Similarly, do you think that lowering this amount (percentage) would encourage more 

PHAs to participate in the EPC program?

☐ Yes

☐ No

☐ Don’t Know

Section C: Developing and Managing an EPC

*44. What selection factors did your PHA use to select the ESCo to develop and manage your 

executed EPC? (Check all that apply) 

☐ Performed prior work for your PHA
45

☐ Performed prior work for your PHA

☐ Referred by another PHA

☐ Well known / established company

☐ PHA does not have the technical capacity to develop 

and manage an EPC

☐ N/A, the executed EPC is self-managed by our PHA (SKIP Question 46)

☐ Other (GO TO Question 45)

45. If you selected “Other” for Question 44, please identify the other factors that were used in 

choosing the selected ESCo.

SKIP TO Question 51

46. What were your reasons for self-managing the executed EPC? (Check all that apply) 

☐ PHA staff is very knowledgeable of the known 

problems

☐ Prior experience with ESCos has illustrated that 

they are not of benefit

☐ Executed EPC consisted of improvements that do

not require advanced technical skill

☐ PHA possess the necessary technical capacity to 

develop and manage an EPC

☐ Other (GO TO Question 47)

47. If you selected “Other” for Question 46, please identify the other reasons why your PHA 

chose to self-manage the executed EPC.

48. Was or is self-managing the executed EPC a burdensome process?

☐ Yes

☐ No
46

49. Were there any other issues related to self-managing the executed EPC that were 

particularly a positive or negative experience? 

☐ Yes

☐ No (SKIP TO Question 51)

50. Please describe your positive or negative experiences related to self-managing your EPC

(please be sure to specify whether you view each experience as positive or negative).

*51. If a PHA chose to self-manage an executed EPC, do you believe that the PHA should be 

compensated for this effort? 

☐ Yes

☐ No (SKIP TO Question 54)

52. Please specify your recommended approach toward compensating a PHA for self-managing 

an executed EPC.

☐ Percentage ___ % (write-in) of the total cost of the 

executed EPC

☐ Percentage ___ % (write-in) of the total annual 

federal subsidy that the PHA receives from HUD

☐ Other (GO TO Question 53)

53. If you selected “Other” for Question 52, please identify the other recommended 

approaches for compensating a PHA for self-managing an EPC.

*54. If your PHA were to add an additional phase to your existing EPC or execute a new EPC in 

the future, would your PHA hire an ESCo or self-manage the contract?
47

☐ Hire an ESCo

☐ Self-manage

In order for a PHA’s EPC to be approved, HUD must have determined that the contract’s 

projected cost savings will reasonably cover the project’s costs. The application process for 

applying to the EPC program requires PHAs to complete a Completeness Review Checklist and 

Technical Review Checklist. Reponses to these two checklists provide necessary information that 

is required for HUD to review an Energy Service Agreement (ESA). Questions 20-23 ask 

questions related to the benefit of executing and effort associated with applying to the EPC 

program.

*55. Overall, do you believe that your executed EPC was of an actual benefit to your PHA?

☐ Yes (SKIP TO Question 58)

☐ No

56. Please specify the reasons why the executed EPC was not of benefit to your PHA. (Check all 

that apply) 

☐ Additional EPC debt made it more difficult to 

manage our PHA

☐ After paying annual debt services, our PHA did or 

does not realize any excess savings.

☐

The realized cost savings are insignificant or 

minimal relative to the time and effort that was 

put in to applying to and managing the executed 

EPC.

☐ Other (GO TO Question 57)

57. If you selected “Other” for Question 56, please specify the reasons why the EPC was not of 

benefit to your PHA.

*58. In terms of the EPC application process, did your PHA keep record of the workload (i.e., 

labor hours) associated with applying to the program?

☐ Yes

☐ No (SKIP TO Question 60)
48

59. Please specify the aggregate amount of time (write-in) or range of time that your PHA staff 

dedicated to the executed EPC during the application process?

☐ ______ hours

☐ <160 hours (<4 weeks)

☐ 160 - 320 hours (4-8 weeks)

☐ 320 - 640 (8 - 16 weeks)

☐ >640 hours (>16 weeks)

*60. Do you think the rigor of the EPC application process is necessary for HUD to ensure that 

the project is cost effective?

☐ Yes

☐ No

*61. In hindsight, has it or would it have been, of benefit to your PHA to hire a staff member 

whose sole responsibility was to develop, apply to, and manage the executed EPC?

☐ Yes

☐ No

*62. In the absence of the executed EPC, would your PHA have made the installed 

improvements anyway? 

☐ Yes

☐ No (GO TO Question 64)

☐ Only a portion

63. Would your PHA have expected to achieve a similar amount of savings?

☐ Yes

☐ No

*64. In terms of installing additional utility improvements in the future, has the executed EPC 

enabled such work to be performed or hindered it? 

☐ Enabled

☐ Hindered

*65. Please describe the ways in which the executed EPC has enabled or hindered future 

improvements. 
49

*66. Has your PHA staff observed any specific issues with your executed EPC that you would 

advise other PHAs to avoid?

☐ Yes

☐ No (SKIP TO Question 68)

67. Please describe the issues that your PHA staff has observed. 

*68. Does your PHA have any ‘lessons learned’ relating to the executed EPC?

☐ Yes

☐ No (SKIP TO Question 70)

69. Please describe the ‘lessons learned.’ 

*70. Does the executed EPC have any specific clauses that were of benefit to your PHA?

☐ Yes

☐ No (SKIP TO Question 72)

71. Please describe the clauses and their benefit.
50

*72. Does the executed EPC have any specific clauses that were harmful or financially 

burdensome to your PHA?

☐ Yes

☐ No (SKIP TO Question 74)

73. Please describe the clauses that were harmful or financially burdensome. 

*74. Is your PHA considering a conversion under the Rental Assistance Demonstration (RAD) 

program that involves EPC units?

☐ Yes

☐ No (SKIP TO Question 77)

75. From a utility performance and management perspective, does your PHA believe that the 

RAD conversion will be of benefit to your PHA? 

☐ Yes

☐ No

☐ Don’t Know (SKIP TO Question 77)

76. Please describe the reasons as to why the RAD conversion with EPC units will or will not be 

beneficial to your PHA. 
51

Section D: Resident-Related Matters 

*77. Were residents affected by the EPC informed of it (i.e., performance contract) significantly 

in advance of the contract’s construction phase? 

☐ Yes

☐ No

*78. Did the residents voice any concern about the improvements that were made under 

executed EPC? 

☐ Yes

☐ No (SKIP TO Question 81)

79. What concerns did the residents raise? 

80. Did your PHA have the necessary resources (e.g., money, staff time) to address residents’ 

concerns?

☐ Yes

☐ No

81. To encourage greater utility conservation, were any resident outreach or training programs 

provided? 

☐ Yes

☐ No (SKIP TO Question 90)

82. Who provided the outreach or training programs? (Check all that apply) 

☐ PHA

☐ ESCo

☐ Third-party Consultant

☐ Other (GO TO Question 83)

83. If you selected “Other” for Question 82, please identify the other entities that provided the 

outreach or training programs. 
52

84. How were the affected residents notified about the outreach or training programs?

☐ Posting of flyers

☐ PHA newsletters

☐ Resident meetings

☐ Other (GO TO Question 85)

85. If you selected “Other” for Question 84, please describe the other methods that were used 

to notify the affected residents about the provided outreach or training programs?

86. What percentage of the affected residents took part in the provided outreach or training 

programs?

☐ <10%

☐ 11-25%

☐ 26-50%

☐ 51-75%

☐ >75%

☐ Don’t Know

87. Did the outreach or training programs assist the affected residents in their understanding of 

the importance of utility conservation?

☐ Yes

☐ No

☐ Don’t Know

88. Since providing the outreach or training programs, has your PHA observed any changes in 

resident utility usage? 
53

☐ Yes

☐ No

☐ Don’t Know

89. Has your PHA found that the outreach or training programs resulted in supplemental 

savings relative to the improvements installed under the executed EPC?

☐ Yes

☐ No

☐ Don’t Know

90. Would your PHA have an interest in participating in future HUD research about influencing 

resident behavior for utility conservation? 

☐ Yes

☐ No

Thank you for completing this questionnaire! Your input is valuable to us, and we are grateful 

that you have shared your time and expertise.
54

Appendix B

Aggregate and Open-Ended Questionnaire Responses

Section A: General EPC-Related Questions

NOTE: For the purpose of confidentiality, the names of the respondents and their responses 

have been modified so that the information below cannot be used to identify specific housing 

authorities. 

*1. For the executed EPC, who performed the investment grade energy audit (IGEA)?

Response % (N)

ESCo that managed/managing the EPC 66.7 (6)

3rd-party Consultant 22.2 (2)

Other 11.1 (1)

Total 100.0 (9)

2. Please identify the entity that performed the IGEA.

Response (N)

Entity identified (see below) (3)

Public Housing Authority Response

PHA 1 Company A

PHA 2 Company B

PHA 3 We had multiple audits. Company C & Company 

D.

*3. Is your PHA satisfied with the completed IGEA?

Response % (N)

Yes 88.9 (8)

No 11.1 (1)

Total 100.0 (9)

4. If you were not satisfied with the completed IGEA, what are the reasons for your 

dissatisfaction? (Check all that apply) 

Response % (N)

Audit didn’t correctly scope out the necessary work 0 (0)

Audit didn’t reveal any information that wasn’t already known 0 (0)

Other 100.0 (1)

Total 100.0 (1)

Note: Percentages may not equal 100.0 because multiple responses could be selected.
55

5. If you selected “Other” for Question 4, please identify the other reasons for your 

dissatisfaction with the IGEA. 

Response (N)

Other reasons for dissatisfaction with IGEA (see below) (1)

Public Housing Authority Response

PHA 4

The initial effort to start the installation, the change in 

equipment proposed, and the resulting cost to ESCo 

vs. charges to PHA 4.

*6. During the development process of the executed EPC, who developed the list of 

recommended improvements? (Check all that apply) 

Response % (N)

ESCo that managed/managing the EPC 77.8 (7)

Third-party Consultant 33.3 (3)

PHA staff 100.0 (9)

Other 0.0 (0)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 Third-party Consultant - selected high return ECMs

PHA staff - selected high value ECMs

7. If you selected “Other” for Question 6, please identify the other entities that developed the 

list of recommended improvements for your executed EPC? 

Response (N)

Other reasons for other entities that developed the list of 

recommended improvements (0)

*8. What factors were considered when developing the list of recommended improvements? 

(Check all that apply) 

Response % (N)

Findings from the performed IGEA 100.0 (9)

Capital Fund Program Five-Year Action Plan 100.0 (9)

REAC Physical Inspection 77.8 (7)

Routine inspections performed by PHA staff 77.8 (7)

Concerns raised by residents 44.4 (4)

Other 11.1 (1)

Note: Percentages may not equal 100.0 because multiple responses could be selected.
56

9. If you selected “Other” for Question 8, please identify the other factors that were considered 

when the recommended list of improvements was developed. 

Response (N)

Other factors that were considered when the recommended 

improvements were developed (see below) (1)

Public Housing Authority Response

PHA 1 Utility Conservation

*10. Were all of the recommended improvements incorporated in to the Energy Service 

Agreement (ESA) and installed under the executed EPC? 

Response % (N)

Yes 14.3 (1)

No 85.7 (6)

Total 100.0 (7)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 N/A. No ESA was in place

11. If only a portion of the recommended improvements were installed, why was that? (Check 

all that apply) 

Response % (N)

Lack of funding 33.3 (3)

Additional improvements were or will be performed using 

other funds (e.g., Capital Improvement) 22.2 (2)

Additional improvements were or will be deferred to a 

subsequent period of time 22.2 (2)

Executed EPC would not have been cost-effective if 

additional improvements were installed 66.7 (6)

Other 11.1 (1)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

12. If you selected “Other” for Question 11, please identify the other reasons for installing only 

a portion of the recommended improvements. 

Response (N)

Other reasons for installing only a portion of the 

recommended improvements (see below) (1)
57

Public Housing Authority Response

PHA 5

The then Executive Director made decisions alone 

without input of others including staff and Board. This 

was a big mistake.

*13. Was or will the total cost of the executed EPC be within the Energy Service Agreement’s 

(ESA) initial estimated budget? 

Response % (N)

Yes 100.0 (8)

No 0.0 (0)

Total 100.0 (8)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 N/A. No ESA - but project was under budget.

14. If cost overruns occurred, how much more was or will the total cost of the executed EPC be 

relative to the contract’s initial estimated budget?

Response % (N)

<25% 11.1 (1)

26-50% 0.0 (0)

51-75% 0.0 (0)

>75% 0.0 (0)

Total 100.0 (1)

15. What were the reasons for the cost overruns? (Check all that apply) 

Response % (N)

Incorrect improvements were bought or installed 0.0 (0)

Changes in the type or quantity of installed improvements 0.0 (0)

Initial cost of improvements or services changed 0.0 (0)

Other 11.1 (1)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

16. If you selected “Other” for Question 15, please identify the other reasons why cost overruns 

occurred. 

Response (N)

Other reasons why cost overruns occurred (see below) (1)

Public Housing Authority Response
58

PHA 6

A contingency was incorporated in the agreement to 

address issues with unknowns (i.e., rotted floors needing 

replacement prior to installation of toilets, problems 

with installation of HVAC equipment, etc.)

*17. Was the work associated with the construction phase of the executed EPC completed on 

schedule? 

Response % (N)

Yes 66.7 (6)

No 33.3 (3)

Total 100.0 (9)

18. If schedule (construction phase) delays occurred, what were the reasons for the delays? 

(Check all that apply) 

Response % (N)

Incorrect improvements were installed 11.1 (1)

IGEA did not correctly scope out the work 11.1 (1)

EPC work could not be performed until other improvements 

(e.g., capital improvements) were completed 0.0 (0)

Other 22.2 (2)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

19. If you selected “Other” for Question 18, please identify the other reasons why the schedule 

(construction phase) delays occurred. 

Response (N)

Other reasons why schedule (construction phase) overruns 

occurred (see below) (2)

Public Housing Authority Response

PHA 1

The project was delayed due to the planting and 

establishment of draught tolerant/water efficient 

grasses, an ECM. During the construction period there 

was a drought and the water company placed water 

restricting on landscape irrigation. Therefore the 

planting of water efficient grasses had to be postponed 

until drought restrictions were lifted.

PHA 4 ...related to the manner in which installation start was 

attempted/delayed.

Currently, HUD guidance specifies that the term of an EPC, including any applicable extensions, 

can be no more than 20 years. Questions 20-23 ask questions related to this limit.
59

*20. If permissible under HUD guidelines, would your PHA consider completing another phase 

of the executed EPC?

Response % (N)

Yes 77.8 (7)

No 22.2 (2)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 4 Not necessary.

*21. If HUD extended the maximum term of an EPC beyond 20 years, would your PHA consider 

adding another phase to your executed EPC? 

Response % (N)

Yes 66.7 (6)

No 33.3 (3)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 4 Not necessary.

*22. In hindsight, if the maximum term of an EPC was extended beyond 20 years, would your 

PHA have installed improvements that would have been more cost effective over the term of 

the EPC (i.e., provided greater long-term savings)? 

Response % (N)

Yes 77.8 (7)

No 22.2 (2)

Total 100.0 (9)

Response (N)

Additional comments (see below) (2)

Public Housing Authority Response

PHA 1 Potentially

PHA 2 Solar
60

*23. Does your PHA believe that extending the maximum term of an EPC beyond 20 years 

would encourage more PHAs to participate in the EPC program? 

Response % (N)

Yes 62.5 (5)

No 12.5 (1)

Don’t Know 25.0 (2)

Total 100.0 (8)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 But I think it would drive new/additional phases of 

existing EPCs

*24 Is your PHA satisfied with the EPC incentives used? 

Response % (N)

Yes 100.0 (9)

No 0.0 (0)

Total 100.0 (9)

*25. Does your PHA wish that other EPC incentives were used? 

Response % (N)

Yes 25.0 (2)

No 75.0 (6)

Total 100.0 (8)

26. Excluding the incentives used in your executed EPC, what additional incentives would your 

PHA have used? (Check all that apply) 

Response % (N)

Frozen-Rolling Base 11.1 (1)

Add-On Subsidy 11.1 (1)

Resident Paid Utility 11.1 (1)

Rate Reduction Incentive 33.3 (3)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

*27. Did your PHA leverage funds other than EPC funds to install additional improvements in 

conjunction with the executed EPC?

Response % (N)

Yes 62.5 (5)
61

No 37.5 (3)

Total 100.0 (8)

28. If other funds were leveraged, what type of funds were they? (Check all that apply) 

Response % (N)

Capital Funds / Capital Reserves 44.4 (4)

Direct Purchase 0.0 (0)

Third-Party Leasing 22.2 (2)

Power Purchase Agreement (PPA) 0.0 (0)

Rebate Program 44.4 (4)

Grant Program 11.1 (1)

Bond Program 0.0 (0)

Other 11.1 (0)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

29. If you selected “Other” for Question 28, please identify the other leveraged funds. 

Response (N)

Other leveraged funds (see below) (1)

Public Housing Authority Response

PHA 7 ARRA Funds

Section B: Energy Conservation and Cost Savings

*30. How does your PHA monitor the performance of your executed EPC? (Check all that apply) 

Response % (N)

Annual ESCo provided measurement and verification (M&V) reports 77.8 (7)

PHA-based monitoring 66.7 (6)

Independent third-party monitoring 33.3 (3)

Other 11.1 (1)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

31. If you selected “Other” for Question 30, please identify the other approaches toward 

monitoring your executed EPC. 

Response (N)

Other approaches toward monitoring (see below) (1)

Public Housing Authority Response

PHA 1

Annual third-party M&V report issued. Also, the EPC 

funded an Energy Manager position which provides 

continual oversight over the EPC, utility consumption, 
62

and other energy and water conservation measures.

32. If performance monitoring occurs in addition to the annual ESCo provided M&V reports, 

how frequently does this monitoring occur?

Response % (N)

Monthly 33.3 (3)

Quarterly 11.1 (1)

Every 6 months 0.0 (0)

Randomly 33.3 (3)

*33. What is monitored and reported during the M&V process? (Check all that apply) 

Response % (N)

Utility Consumption 88.9 (8)

Utility Expenditures 88.9 (8)

Equipment Life Expectancy 33.3 (3)

Operation and Maintenance (O&M) Practices 77.8 (7)

Other 22.2 (2)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 6 Equipment Life Expectancy -- completed at 

the energy audit phase

34. If you selected “Other” for Question 33, please identify any other elements that are 

monitored during the M&V process. 

Response (N)

Other elements that were monitored (see below) (2)

Public Housing Authority Response

PHA 1 Resident engagement programs focused on 

energy and water conservation

PHA 2

Physical Inspections are conducted to ensure 

EMC are still in place (aerators!) and operating 

according to specs, especially pressurized toilets.

*35. Since the completion of the construction phase for your executed EPC, how are the actual 

utility savings compared to the initial estimated savings?

Response % (N)
63

Performing as Projected 77.8 (7)

Under Performing 11.1 (1)

Over Performing 11.1 (1)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 8 Overall performance is to spec however 

individual ECMs are under/over performing

36. Please explain, to the best of your knowledge, why the improvements are Under 

Performing. 

Response (N)

Why improvements are Under Performing (see below) (1)

Public Housing Authority Response

PHA 6

Under performing due to not receiving full 

subsidy from HUD. Resident interference. 

Equipment control issues. Contract design 

establishes that saving at the beginning of 

contract is to be small and increase 

throughout term of contract.

SKIP TO Question 38 

37. Please explain, to the best of your knowledge, why the improvements are Over Performing. 

Response (N)

Why improvements are Over Performing (see below) (1)

Public Housing Authority Response

PHA 1 1) Aggressive O&M procedures and 2) Resident 

engagement program

*38. After paying the annual debt services on your executed EPC, does your PHA realize any 

excess savings? 

Response % (N)

Yes 55.6 (5)

No 44.4 (4)

Total 100.0 (9)
64

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 6 Not yet due to subsidy issues and contract 

design

39. How has your PHA used the achieved annual cost savings? (Check all that apply) 

Response % (N)

Installed additional improvements by expanding the current EPC 33.3 (3)

Accelerated debt service on the executed EPC 11.1 (1)

Paid eligible operating expenses 33.3 (3)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

Response (N)

Additional comments (see below) (2)

Public Housing Authority Response

PHA 1

Other - annual savings which exceed 

debt service fund EPC program costs 

including M&V activities and 

replacement equipment reserves

PHA 5 Into a subsequent phase

*40. If HUD permitted PHAs to apply achieved utility savings from EPCs toward capital 

improvements, would this be of benefit to your PHA?

Response % (N)

Yes 85.7 (6)

No 14.3 (1)

Total 100.0 (7)

Response (N)

Additional comments (see below) (2)

Public Housing Authority Response

PHA 1 Although energy related capital improvements are 

best - savings offset costs

PHA 3 Not sure

HUD guidance on the payment of EPC debt specifies that at least 75 percent of cost savings 

must be paid toward annual EPC debt services and project costs. Questions 41-43 ask questions 

related to this requirement.
65

*41. Would your PHA have undertaken different or additional improvements if it was not 

required to pay 75 percent of the cost savings toward EPC debt services and project costs? 

Response % (N)

Yes 33.3 (3)

No 66.7 (6)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 Potentially

*42. Would lowering the amount (percentage) of cost savings that must be paid toward the 

debt service of an executed EPC be of benefit to your PHA?

Response % (N)

Yes 75.0 (6)

No 25.0 (2)

Total 100.0 (8)

*43. Similarly, do you think that lowering this amount (percentage) would encourage more 

PHAs to participate in the EPC program?

Response % (N)

Yes 71.4 (5)

No 0.0 (0)

Don’t Know 28.6 (2)

Total 100.0 (7)

Section C: Developing and Managing an EPC

*44. What selection factors did your PHA use to select the ESCo to develop and manage your 

executed EPC? (Check all that apply) 

Response % (N)

Performed prior work for your PHA 11.1 (1)

Referred by another PHA 33.3 (3)

Well known / established company 44.4 (4)

PHA does not have the technical capacity to develop and manage an EPC 33.3 (3)

N/A, the executed EPC is self-managed by our PHA 22.2 (2)

Other 44.4 (4)

Note: Percentages may not equal 100.0 because multiple responses could be selected.
66

45. If you selected “Other” for Question 44, please identify the other factors that were used in 

choosing the selected ESCo.

Response (N)

Other factors used in choosing the selected ESCo (see below) (4)

Public Housing Authority Response

PHA 9 Request for proposals. Evaluation 

committee.

PHA 3 Firm selected through RFQ process. With 

other authorities.

PHA 6

The selection process was as follows:

The Housing Authority was contacted by 

an ESCo to determine if an EPC was 

possible, after a brief investigation it was 

determined that an EPC is possible. A 

Request for Proposal was prepared and 

advertised and seven responses were 

received. Those seven proposals were 

evaluated and scored using a set of 

criteria which includes the items checked 

in #44 above. The top three were 

interviewed and following the interview 

process the top three were scored again. 

The top scoring firm was then selected.

PHA 8 Stated they were primarily interested in 

small PHAs.

SKIP TO Question 51

46. What were your reasons for self-managing the executed EPC? (Check all that apply) 

Response % (N)

PHA staff is very knowledgeable of the known problems 11.1 (1)

Prior experience with ESCos has illustrated that they are not of benefit 11.1 (1)

Executed EPC consisted of improvements that do not require advanced technical skill 11.1 (1)

PHA possess the necessary technical capacity to develop and manage an EPC 11.1 (1)

Other 22.2 (2)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

47. If you selected “Other” for Question 46, please identify the other reasons why your PHA 

chose to self-manage the executed EPC.

Response (N)
67

Other factors why your PHA choose to self-manage the executed 

EPC (see below) (2)

Public Housing Authority Response

PHA 1

Prior experience with ESCos has illustrated that 

they are not of benefit too expensive

1) Significantly lower project soft costs which 

allowed for a greater investment in capital 

improvements throughout the portfolio.

2) The self-managed EPC allowed for a greater 

involvement with Maintenance staff and 

residents which ultimately makes a stronger 

project with more durable savings.

3) Project scope can be more customized to 

meet the PHA's needs.

PHA 2

Reduction in Admin Cost of project. EPC Phase 

I was successful and had a much more complex 

scope. In-house staff was qualified to deliver 

the subsequent phase’s scope so no need to 

incur substantial ESCo fees.

48. Was or is self-managing the executed EPC a burdensome process?

Response % (N)

Yes 100.0 (1)

No 0.0 (0)

Total 100.0 (1)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 Developing a self-managed EPC takes a significant amount 

of staff time, however it is well worth the investment.

49. Were there any other issues related to self-managing the executed EPC that were 

particularly a positive or negative experience? 

Response % (N)

Yes 100.0 (2)

No 0.0 (0)

Total 100.0 (2)

50. Please describe your positive or negative experiences related to self-managing your EPC

(please be sure to specify whether you view each experience as positive or negative).
68

Response (N)

Positive or negative experiences related to self-managing an EPC (see below) (2)

Public Housing Authority Response

PHA 1

Positive - Explained in question #47.

Negative -It does take a large amount of staff time, 

however the staff involvement is the exact reason the 

benefits in question #47 are achieved.

PHA 2

Positive - Reduction in soft costs was substantial down 

from more than 55% of hard cost for the initial phase to 

projected 29% in the subsequent phase. Negative - HUD 

Review took a very long time in securing financing at a 

good rate was challenging without ESCo partner.

*51. If a PHA chose to self-manage an executed EPC, do you believe that the PHA should be 

compensated for this effort? 

Response % (N)

Yes 66.7 (6)

No 33.3 (3)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 PHA 1 was 

compensated

52. Please specify your recommended approach toward compensating a PHA for self-managing 

an executed EPC.

Response % (N)

Percentage ___ % (write-in) of the total cost of the executed EPC 44.4 (4)

Percentage ___ % (write-in) of the total annual federal subsidy that the PHA 

receives from HUD 0.0 (0)

Other 11.1 (1)

Total 100.0 (5)

Response (N)

Additional comments (see below) (4)

Public Housing Authority Response

PHA 1

15 - 10% of the total cost

Similar to capital fund projects 

and/or development fees from 
69

self-development activities

PHA 4 10% of the total cost

PHA 5 18% of the total cost

PHA 7 10% of the total cost

53. If you selected “Other” for Question 52, please identify the other recommended 

approaches for compensating a PHA for self-managing an EPC.

Response (N)

Other recommended approaches for compensating a PHA self-managing an EPC 

(see below) (1)

Public Housing Authority Response

PHA 2 15% of hard cost fee to the COCC.

*54. If your PHA were to add an additional phase to your existing EPC or execute a new EPC in 

the future, would your PHA hire an ESCo or self-manage the contract?

Response % (N)

Hire an ESCo 62.5 (5)

Self-manage 37.5 (3)

Total 100.0 (8)

In order for a PHA’s EPC to be approved, HUD must have determined that the contract’s projected 

cost savings will reasonably cover the project’s costs. The application process for applying to the 

EPC program requires PHAs to complete a Completeness Review Checklist and Technical Review 

Checklist. Reponses to these two checklists provide necessary information that is required for 

HUD to review an Energy Service Agreement (ESA). Questions 20-23 ask questions related to the 

benefit of executing and effort associated with applying to the EPC program.

*55. Overall, do you believe that your executed EPC was of an actual benefit to your PHA?

Response % (N)

Yes 88.9 (8)

No 11.1 (1)

Total 100.0 (9)

56. Please specify the reasons why the executed EPC was not of benefit to your PHA. (Check all 

that apply) 

Response % (N)

Additional EPC debt made it more difficult to manage our PHA 0.0 (0)

After paying annual debt services, our PHA did or does not realize any 

excess savings. 0.0 (0)

The realized cost savings are insignificant or minimal relative to the time 11.1 (1)
70

and effort that was put in to applying to and managing the executed EPC.

Other 0.0 (0)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

57. If you selected “Other” for Question 56, please specify the reasons why the EPC was not of 

benefit to your PHA.

Response (N)

Other reasons why the EPC was not of benefit to your PHA (0)

*58. In terms of the EPC application process, did your PHA keep record of the workload (i.e., 

labor hours) associated with applying to the program?

Response % (N)

Yes 11.1 (1)

No 88.9 (8)

Total 100.0 (9)

59. Please specify the aggregate amount of time (write-in) or range of time that your PHA staff 

dedicated to the executed EPC during the application process?

Response % (N)

______ hours 0.0 (0)

<160 hours (<4 weeks) 0.0 (0)

160 - 320 hours (4-8 weeks) 0.0 (0)

320 - 640 (8 - 16 weeks) 100.0 (1)

>640 hours (>16 weeks) 0.0 (0)

Total 100.0 (1)

*60. Do you think the rigor of the EPC application process is necessary for HUD to ensure that 

the project is cost effective?

Response % (N)

Yes 77.8 (7)

No 22.2 (2)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 7

HUD approval for our 

subsequent phase took 

9 months.
71

*61. In hindsight, has it or would it have been, of benefit to your PHA to hire a staff member 

whose sole responsibility was to develop, apply to, and manage the executed EPC?

Response % (N)

Yes 44.4 (4)

No 55.5 (5)

Total 100.0 (9)

Response (N)

Additional comments (see below) (3)

Public Housing Authority Response

PHA 1 PHA 1 has such staff member which 

was funded through the EPC

PHA 5 Too Costly

PHA 8 If funding was available

*62. In the absence of the executed EPC, would your PHA have made the installed 

improvements anyway? 

Response % (N)

Yes 0.0 (0)

No 11.1 (1)

Only a portion 88.9 (8)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 7 Would not have done marginally 

cost effective measures.

63. Would your PHA have expected to achieve a similar amount of savings?

Response % (N)

Yes 14.3 (1)

No 85.7 (6)

Total 100.0 (7)

*64. In terms of installing additional utility improvements in the future, has the executed EPC 

enabled such work to be performed or hindered it? 

Response % (N)

Enabled 87.5 (7)
72

Hindered 12.5 (1)

Total 100.0 (8)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 8 Neither

*65. Please describe the ways in which the executed EPC has enabled or hindered future 

improvements. 

Response (N)

Other reasons why the EPC enabled or hindered future improvements (see below) (9)

Public Housing Authority Response

PHA 9 Future improvements were not enabled or 

hindered but the question had to be answered.

PHA 1

The EPC enhanced our staff's engagement and 

recommendations with utility improvements and 

funding from local utilities assisted in such 

improvements.

PHA 2

Have developed a good working relationship with 

Company E who also serves as the authority's bank 

of record for other business lines. Self-managed 

EPC made them more aware of our various 

programs and should make future financing easier 

to obtain. Also made staff and residents more 

aware of energy/utility impact on operations and 

cash flow.

PHA 4 The enhancement of an understanding of energysavings potential.

PHA 3

We have a clear understanding of what 

opportunities are available and the methodology 

to move forward.

PHA 6

The EPC enabled improvements to be installed 

quicker than if financed with capital fund dollars. 

With the installation of the new equipment sooner 

additional operational cost savings is realized by 

the reduction in cost to operate the more efficient 

equipment. Also feeing up additional capital fund 

dollars for other much needed improvements.

PHA 5

Freed up capital funds that otherwise might have 

been needed to do some or all of the work funded 

by EPC.

PHA 8 No further improvements have been installed 

because of the EPC. ADA compliance and 
73

replacing aging systems is priority.

PHA 7

Knowledge gained through EPC project was used 

to develop energy standards for future 

construction projects.

*66. Has your PHA staff observed any specific issues with your executed EPC that you would 

advise other PHAs to avoid?

Response % (N)

Yes 88.9 (8)

No 11.1 (1)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 4 Maybe

67. Please describe the issues that your PHA staff has observed. 

Response (N)

Other issues that your PHA staff has observed (see below) (8)

Public Housing Authority Response

PHA 9 Making sure the ESCo is monitoring and 

conducting the M&V appropriately.

PHA 2 Not sharing EPC plan with entire organization, 

including residents.

PHA 4 Temperature-controlled thermostats

PHA 3 Always question and review costs thoroughly.

PHA 6

Problems with automated building control issues

proper operation. 

Resident tampering with controls on the heating 

and cooling of their units.

PHA 5 Overhead percentage calculating of the vender 

should be carefully examined.

PHA 8 Think beyond just the systems being improved.

Other related systems may be adversely impacted.

PHA 7

Certain installed measures were maintenance 

intensive and highly technical. Also, single zone 

VRV system was not appropriate for multi-tenant 

building.

*68. Does your PHA have any ‘lessons learned’ relating to the executed EPC?
74

Response % (N)

Yes 100.0 (9)

No 0.0 (0)

Total 100.0 (9)

69. Please describe the ‘lessons learned.’ 

Response (N)

Described lessons learned (see below) (9)

Public Housing Authority Response

PHA 9 We updated units slated for redevelopment with 

major improvements.

PHA 1 Multiple. Would like to discuss in person.

PHA 2

Be sure to have potential lenders engaged early in 

process. We invested a lot of time in the project 

before determining if a lender would be 

comfortable with the self-managed program. 

Fortunately our "regular" bank also finances EPC 

contracts. The "niche" lenders for this type of 

work are not the most economically feasible to 

ensure a positive outcome.

PHA 4 The many facets of the process from procurement 

to completion.

PHA 3 Again always question costs. Also always seek 

alternative sources of funding.

PHA 6

The need for more resident training and energy 

awareness. 

Too much reliance on the ESCo for everything.

PHA 5 See above.

PHA 8 See 67.

PHA 7 Energy savings can easily be offset by increased 

maintenance costs for some measures

*70. Does the executed EPC have any specific clauses that were of benefit to your PHA?

Response % (N)

Yes 22.2 (2)

No 77.8 (7)

Total 100.0 (9)

71. Please describe the clauses and their benefit.

Response (N)

The described clauses and their benefit. (see below) (3)
75

Public Housing Authority Response

PHA 4 The annual increase in funds to satisfy the 

indebtedness

PHA 6

The Housing Authority procured legal 

counsel to review all contract documents to 

ensure our interest was protected.

PHA 7

Frozen base

Cost savings applied to debt

Duration of contract term

*72. Does the executed EPC have any specific clauses that were harmful or financially 

burdensome to your PHA?

Response % (N)

Yes 22.2 (2)

No 77.8 (7)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 4 Not that I recall.

73. Please describe the clauses that were harmful or financially burdensome. 

Response (N)

The described clauses that were harmful or financially burdensome. (see below) (2)

Public Housing Authority Response

PHA 5 M&V were excessive

PHA 7

1) Original EPC had a shared savings 

provision 

2) Monitoring of stipulated savings 

seemed unnecessary

3) Requirement that excess savings be 

used primarily for further energy 

measures

*74. Is your PHA considering a conversion under the Rental Assistance Demonstration (RAD) 

program that involves EPC units?

Response % (N)

Yes 62.5 (5)

No 37.5 (3)
76

Total 100.0 (8)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 1 Unsure

75. From a utility performance and management perspective, does your PHA believe that the

RAD conversion will be of benefit to your PHA? 

Response % (N)

Yes 33.3 (2)

No 16.7 (1)

Don’t Know 50.0 (3)

Total 100.0 (6)

76. Please describe the reasons as to why the RAD conversion with EPC units will or will not be 

beneficial to your PHA. 

Response (N)

Reasons why the RAD conversion with EPC units will or will not be beneficial to 

your PHA. (see below) (3)

Public Housing Authority Response

PHA 9

The EPC work did not modernize the PHA 

stock to make it more attractive to renters. 

The intended work to be done in 

conjunction with the RAD conversion will.

PHA 2

RAD conversion does not provide any 

specific benefits in terms of utilities or 

management. Some RAD conversions will 

however produce a financial benefit.

PHA 7

Lower utility costs or allowances. Frozen 

utility base benefit will survive term of EPC 

by being factored into contract rents.

Section D: Resident-Related Matters 

*77. Were residents affected by the EPC informed of it (i.e., performance contract) significantly 

in advance of the contract’s construction phase? 

Response % (N)

Yes 88.9 (8)

No 11.1 (1)

Total 100.0 (9)
77

*78. Did the residents voice any concern about the improvements that were made under 

executed EPC? 

Response % (N)

Yes 77.8 (7)

No 22.2 (2)

Total 100.0 (9)

79. What concerns did the residents raise? 

Response (N)

Concerns raised by residents. (see below) (7)

Public Housing Authority Response

PHA 9 Residents were upset about the limiting 

thermostats.

PHA 1

Residents were involved in project design 

and execution so the majority of the ECMs 

were favorable for the residents. Residents 

did show concerns on the following ECMs:

1) CFL bulbs - comments were received on 

the brightness and temperature

2) Native grasses - the look and feel are 

different than other grasses

PHA 2

Concerns that increased amenities like 

central air would actually raise utility costs 

for them.

PHA 4 Temperature-controlled thermostats. Bulbs 

for light fixtures.

PHA 6

Limited control of thermostats in their units 

which affected the ability to control the 

temperature in their unit. (the unit is either 

too cold or too hot).

PHA 5 Reduced heat in winter.

PHA 7

Felt that energy savings measures would 

impinge on their comfort - light intensity, 

ability to control thermostats, low-flow 

showers, etc.

80. Did your PHA have the necessary resources (e.g., money, staff time) to address residents’ 

concerns?

Response % (N)

Yes 100.0 (8)

No 0.0 (0)

Total 100.0 (8)
78

81. To encourage greater utility conservation, were any resident outreach or training programs 

provided? 

Response % (N)

Yes 100.0 (9)

No 0.0 (0)

Total 100.0 (9)

82. Who provided the outreach or training programs? (Check all that apply) 

Response % (N)

PHA 66.7 (6)

ESCo 66.7 (6)

Third-party Consultant 22.2 (2)

Other 0.0 (0)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 7 Provided consultant

83. If you selected “Other” for Question 82, please identify the other entities that provided the 

outreach or training programs. 

Response (N)

Other entities that provided the outreach or training programs. (0)

84. How were the affected residents notified about the outreach or training programs?

Response % (N)

Posting of flyers 100.0 (9)

PHA newsletters 33.3 (3)

Resident meetings 88.9 (8)

Other 22.2 (2)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

85. If you selected “Other” for Question 84, please describe the other methods that were used 

to notify the affected residents about the provided outreach or training programs?

Response (N)

Other methods that were used to notify the affected residents about the 

provided outreach or training programs. (see below) (2)
79

Public Housing Authority Response 

PHA 1 Energy Fairs / Outreach programs

PHA 3 Phone calls via our robo system.

86. What percentage of the affected residents took part in the provided outreach or training 

programs?

Response % (N)

<10% 22.2 (2)

11-25% 55.6 (5)

26-50% 11.1 (1)

51-75% 0.0 (0)

>75% 11.1 (1)

Don’t Know 0.0 (0)

Note: Percentages may not equal 100.0 because multiple responses could be selected.

87. Did the outreach or training programs assist the affected residents in their understanding of 

the importance of utility conservation?

Response % (N)

Yes 88.9 (8)

No 0.0 (0)

Don’t Know 11.1 (1)

Total 100.0 (9)

88. Since providing the outreach or training programs, has your PHA observed any changes in 

resident utility usage? 

Response % (N)

Yes 22.2 (2)

No 33.3 (3)

Don’t Know 44.4 (4)

Total 100.0 (9)

Response (N)

Additional comments (see below) (1)

Public Housing Authority Response

PHA 7 Due to turnover of residents 

since program began
80

89. Has your PHA found that the outreach or training programs resulted in supplemental 

savings relative to the improvements installed under the executed EPC?

Response % (N)

Yes 11.1 (1)

No 22.2 (2)

Don’t Know 66.7 (6)

Total 100.0 (9)

90. Would your PHA have an interest in participating in future HUD research about influencing 

resident behavior for utility conservation? 

Response % (N)

Yes 88.9 (8)

No 11.1 (1)

Total 100.0 (9)

Thank you for completing this questionnaire! Your input is valuable to us, and we are grateful 

that you have shared your time and expertise.
81

Appendix C

Utility Expense Level Quantities

The tables below illustrate the Utility Expense Level (UEL) quantities for each of the study’s 

participating PHAs. These quantities span from Funding Years 200–2015 (actual consumption 

spanning July 1, 2003 to June 30, 2014) and represent the annual self-reported, owner-paid 

utilities—electricity, natural gas, sewer, and water.

Because the UEL data are self-reported, multiple assumptions were made to correct for missing 

data and inconsistent units of consumption. For purposes of consistency, electricity and natural 

gas quantities are reported in kilowatt-hours (kWh) and sewer and water quantities are 

reported in gallons (gal). In addition, each table consists of notes describing the Funding Year in 

which the respective EPC(s) was initially observed, types of improvements installed, and 

incentives used.

Table 11: DE001a 

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 5,042,802 148,729 131,446,000

2006 7/1/2004 to 6/30/2005 5,124,513 141,611 87,225,000

2007 7/1/2005 to 6/30/2006 4,566,268 127,802 98,313,000

2008 7/1/2006 to 6/30/2007 4,947,819 119,443 95,016,000

2009 7/1/2007 to 6/30/2008 3,567,527 80,535 94,037,000

2010 7/1/2008 to 6/30/2009 3,717,188 97,734 66,274,000

2011 7/1/2009 to 6/30/2010 3,642,395 73,146 80,027,000

2012 7/1/2010 to 6/30/2011 4,516,718 84,172 86,717,000

2013 7/1/2011 to 6/30/2012 3,118,544 49,741 65,812,000

2014 7/1/2012 to 6/30/2013 4,647,884 59,795 72,797,000

2015 7/1/2013 to 6/30/2014 5,292,764 85,734 80,848,000

a DE001 executed two EPC phases; the first being in Funding Year 2009 and the second in Funding Year 2015. During

these phases, building envelope, HVAC, water, and appliance improvements were installed, and the FRB, AOS, and

RPU incentives were used.
82

Table 12: PA04a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer Consumption

{gal}

Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 2,150,271 7,395,838 17,237,630 17,237,630

2006 7/1/2004 to 6/30/2005 2,213,064 7,628,810 18,603,220 18,603,220

2007 7/1/2005 to 6/30/2006 2,258,598 7,164,654 19,699,140 19,699,140

2008 7/1/2006 to 6/30/2007 2,215,474 6,840,533 15,569,880 15,569,880

2009 7/1/2007 to 6/30/2008 2,254,639 6,851,876 16,034,786 16,034,786

2010 7/1/2008 to 6/30/2009 2,316,832 6,990,621 16,801,364 16,801,364

2011 7/1/2009 to 6/30/2010 2,296,816 6,336,694 18,541,200 18,287,739

2012 7/1/2010 to 6/30/2011 2,483,074 6,391,940 19,645,543 19,657,493

2013 7/1/2011 to 6/30/2012 2,431,951 5,918,992 14,454,000 14,454,000

2014 7/1/2012 to 6/30/2013 1,915,528 5,105,305 8,705,000 8,705,000

2015 7/1/2013 to 6/30/2014 2,333,529 7,178,370 8,121,000 8,221,000

a PA040 executed one EPC phase in Funding Year 2013. During this phase, lighting, water, building envelope, and HVAC 

improvements were installed, and the FRP and RPU incentives were used.

Table 13: MS107a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}b

2005 7/1/2003 to 6/30/2004 38,256 476 0 

2006 7/1/2004 to 6/30/2005 18,474 149 0 

2007 7/1/2005 to 6/30/2006 10,776 134 0 

2008 7/1/2006 to 6/30/2007 20,339 149 0 

2009 7/1/2007 to 6/30/2008 9,550 118 0 

2010 7/1/2008 to 6/30/2009 22,199 277 0 

2011 7/1/2009 to 6/30/2010 22,070 342 0 

2012 7/1/2010 to 6/30/2011 32,518 253 0 

2013 7/1/2011 to 6/30/2012 27,939 307 0 

2014 7/1/2012 to 6/30/2013 32,001 350 0 

2015 7/1/2013 to 6/30/2014 30,560 440 0 

a MS107 executed one EPC phase in Funding Year 2011. During this phase, lighting, water, and HVAC improvements 

were installed, and the AOS incentive was used.

b The UEL data sets do not contain any measurements for owner-paid sewer and water quantities. 
83

Table 14: AR002a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 5,898,816 5,856,919 56,937,760

2006 7/1/2004 to 6/30/2005 5,889,920 8,104,750 61,084,672

2007 7/1/2005 to 6/30/2006 6,317,221 4,565,772 65,013,916

2008 7/1/2006 to 6/30/2007 5,969,673 4,936,117 61,303,088

2009 7/1/2007 to 6/30/2008 5,899,154 4,448,505 58,456,948

2010 7/1/2008 to 6/30/2009 5,780,815 4,579,103 53,973,436

2011 7/1/2009 to 6/30/2010 5,935,368 3,184,701 46,803,108

2012 7/1/2010 to 6/30/2011 5,948,630 2,803,869 38,139,024

2013 7/1/2011 to 6/30/2012 5,961,980 1,993,523 39,067,292

2014 7/1/2012 to 6/30/2013 5,578,305 2,542,907 40,866,232

2015 7/1/2013 to 6/30/2014 5,830,196 3,086,401 35,880,812

a AR002 executed one EPC phase in Funding Year 2009. During this phase, lighting, water, building envelope, and 

HVAC improvements were installed, and the AOS and RPU incentives were used.

Table 15: KS001a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer Consumption

{gal}

Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 10,870,732 26,359,222 68,955,128 80,045,724

2006 7/1/2004 to 6/30/2005 9,810,105 26,478,532 67,141,228 78,674,640

2007 7/1/2005 to 6/30/2006 10,999,419 37,983,274 54,260,668 78,180,212

2008 7/1/2006 to 6/30/2007 10,670,481 24,661,756 62,380,956 76,624,372

2009 7/1/2007 to 6/30/2008 11,102,241 21,033,928 76,313,204 75,693,860

2010 7/1/2008 to 6/30/2009 11,044,655 20,692,567 79,878,920 76,845,032

2011 7/1/2009 to 6/30/2010 11,195,548 20,992,049 79,248,356 78,080,728

2012 7/1/2010 to 6/30/2011 12,145,311 22,643,719 91,580,632 92,976,400

2013 7/1/2011 to 6/30/2012 10,409,304 17,677,864 49,366,504 49,267,020

2014 7/1/2012 to 6/30/2013 9,573,033 20,761,864 52,262,760 55,734,228

2015 7/1/2013 to 6/30/2014 10,831,402 28,679,452 63,476,776 74,025,820

a

 KS001 executed one EPC phase in Funding Year 2012. During this phase, building envelope, HVAC, lighting, water, 

appliances, renewable energy, and miscellaneous improvements were installed, and the FRB, AOS, and RPU incentives 

were used.
84

Table 16: CO001a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 46,298,257 148,176,055 594,958,000

2006 7/1/2004 to 6/30/2005 45,273,665 186,349,678 557,665,000

2007 7/1/2005 to 6/30/2006 44,390,600 141,590,621 663,058,000

2008 7/1/2006 to 6/30/2007 46,781,675 136,385,756 666,901,000

2009 7/1/2007 to 6/30/2008 25,161,237 62,318,142 312,728,000

2010 7/1/2008 to 6/30/2009 24,282,647 58,051,143 286,425,000

2011 7/1/2009 to 6/30/2010 25,489,072 66,714,068 262,354,000

2012 7/1/2010 to 6/30/2011 24,352,108 59,929,484 335,776,000

2013 7/1/2011 to 6/30/2012 23,909,289 53,765,006 338,305,000

2014 7/1/2012 to 6/30/2013 24,366,741 56,546,630 309,952,000

2015 7/1/2013 to 6/30/2014 22,603,605 56,060,346 277,238,000

a

 CO001 executed two EPC phases; the first in Funding Year 2008 and the second in Funding Year 2012. During these 

phases, lighting, water, HVAC, appliances, and building envelope improvements were installed, and the AOS incentive 

was used.

Table 17: PA046a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 1,684,918 4,530,973 14,156,449

2006 7/1/2004 to 6/30/2005 1,496,684 5,358,827 16,796,515

2007 7/1/2005 to 6/30/2006 1,798,230 5,888,735 17,361,489

2008 7/1/2006 to 6/30/2007 1,665,293 4,542,724 13,219,194

2009 7/1/2007 to 6/30/2008 3,728,914 7,523,170 22,929,549

2010 7/1/2008 to 6/30/2009 1,956,295 5,108,545 22,453,115

2011 7/1/2009 to 6/30/2010 1,950,257 3,932,763 14,635,134

2012 7/1/2010 to 6/30/2011 2,011,619 3,516,200 17,576,756

2013 7/1/2011 to 6/30/2012 1,753,170 2,638,875 13,315,092

2014 7/1/2012 to 6/30/2013 1,761,880 2,729,382 15,533,128

2015 7/1/2013 to 6/30/2014 2,256,947 2,583,317 11,939,043

a

 PA046 executed two EPC phases; the first in Funding Year 2010 and the second in Funding Year 2015. During these 

phases, lighting, water, building envelope, appliances, and HVAC improvements were installed, and the FRB and AOS 

incentives were used.
85

Table 18: TN005a

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 62,325,731 33,483,153 565,211

2006 7/1/2004 to 6/30/2005 60,515,937 31,909,397 532,351

2007 7/1/2005 to 6/30/2006 58,439,496 32,971,232 477,206

2008 7/1/2006 to 6/30/2007 56,268,782 31,839,257 263,952

2009 7/1/2007 to 6/30/2008 57,639,174 31,342,521 492,868

2010 7/1/2008 to 6/30/2009 57,653,281 31,313,296 496,867

2011 7/1/2009 to 6/30/2010 55,375,849 36,125,794 270,747

2012 7/1/2010 to 6/30/2011 53,540,620 29,995,305 211,918

2013 7/1/2011 to 6/30/2012 49,217,029 25,212,724 221,581

2014 7/1/2012 to 6/30/2013 50,027,105 29,409,206 220,149

2015 7/1/2013 to 6/30/2014 51,374,298 31,462,374 223,298

a

 TN005 executed three EPC phases; the first in Funding Year 1998, the second in Funding Year 2009, and third in 

Funding Year 2013. During these phases, building envelope, appliances, lighting, water, renewable energy, and HVAC 

improvements were installed, and the FRB and RPU incentives were used.

Table 19: NY025 

Funding

Year

Actual Consumption

Timeframe

Electrical Consumption

{kWh}

Natural Gas Consumption

{kWh}

Sewer/Water Consumption

{gal}

2005 7/1/2003 to 6/30/2004 470,498 4,052,931 0 

2006 7/1/2004 to 6/30/2005 499,593 4,000,586 0 

2007 7/1/2005 to 6/30/2006 469,099 3,596,542 0 

2008 7/1/2006 to 6/30/2007 391,097 4,783,353 0 

2009 7/1/2007 to 6/30/2008 457,186 3,153,664 0 

2010 7/1/2008 to 6/30/2009 480,829 3,113,130 0 

2011 7/1/2009 to 6/30/2010 468,163 2,896,717 0 

2012 7/1/2010 to 6/30/2011 512,518 2,811,460 0 

2013 7/1/2011 to 6/30/2012 465,479 2,208,382 0 

2014 7/1/2012 to 6/30/2013 490,054 2,232,122 0 

2015 7/1/2013 to 6/30/2014 473,932 2,298,359 0 

a

 NY025 executed two EPC phases; the first in Funding Year 2008 and the second in Funding Year 2011. During these

phases, building envelope, HVAC, lighting, and appliance improvements were installed, and the FRB and RPU incentives 

were used. b The UEL data sets do not contain any measurements for owner-paid sewer and water quantities. 
86

Appendix D 

Sidebars and Photos

Lighting Systems 

Indoor lighting systems, composed of compact fluorescent lamps (CFL) and light-emitting 

diodes (LED), were the most common improvement performed by the PHAs visited. These 

lighting systems employ bulbs that are available in a wide range of colors and light levels. 

ENERGY STAR-qualified CFL bulbs use about 75 percent less energy and can last up to 10 times 

longer than traditional incandescent bulbs. ENERGY STAR-qualified LEDs use even less energy 

than CFLs and can last up to 25 times longer than traditional incandescent bulbs. 

Figure 3: CFL Lighting, Nashville Site Visit

Figure 4: Energy-Efficient Lighting, North Little Rock Site Visit
87

Water and Water Heating

Saving water is an important part of any EPC. Installing low-flow faucets and showerheads is an

effective way to conserve water, reduce water heating costs, and save energy. The U.S. 

Environmental Protection Agency uses the WaterSense® label to identify water-efficient 

products such as showerheads, bathroom faucets, and toilets. WaterSense®-labeled products 

use a minimum of 20 percent less water compared with conventional products. 

Figure 5: Natural Gas Water Heater, Denver Site Visit Figure 6: Dual Flush Water-Efficient Toilet, Greenwood Site Visit

Figure 7: Tankless Water Heater, Watervliet Site Visit
88

Appliances

ENERGY STAR-certified appliances are often specified in EPCs. These appliances help save on 

operating costs by reducing energy use without sacrificing performance. For example, a new 

ENERGY STAR refrigerator will be about 30 percent more energy efficient than a comparably 

sized 20-year-old model. 

Figure 8: Energy-Efficient Dryers, Clinton Site Visit

Figure 9: Energy-Efficient Refrigerator, Denver Site Visit
89

HVAC

While not as commonly installed as lighting and water systems, improved heating, ventilation, 

and air-conditioning (HVAC) systems hold great energy saving potential. High-efficiency heat 

pumps and boilers were installed at several sites. The ENERGY STAR label can be used to 

identify energy-efficient HVAC equipment suitable for single family or individual dwelling units. 

A qualified engineer should be consulted when specifying energy-efficient equipment in more 

complex, multifamily buildings, as HVAC product selection must be based on demand. ENERGY 

STAR-qualified room and central air conditioners use about 15 percent less energy compared 

with conventional air conditioner systems. ENERGY STAR-qualified furnaces and boilers are 

often substantially more efficient than their conventional counterparts, with oil boilers having 

annual fuel utilization efficiency (AFUE) ratings of 87 percent or greater and gas boilers having 

AFUE of 90 percent or greater.

Figure 10: Residential Unit Mini-Split Heat Pump System, Nashville Site Visit

Figure 11: Energy-Efficient Natural Gas Boiler, Wilmington Site Visit
90

Programmable Thermostats and Controls 

Programmable thermostats can be set to reduce heating or air conditioning operations when 

residents are sleeping or not at home; for maximum efficiency, these periods of reduced 

operation should be at least 4 hours in duration. Programmable thermostats are capable of 

storing six or more daily temperature settings that can be manually overridden without 

affecting the other daily or weekly programs.

Figure 12: Programmable Thermostat, Clinton Site Visit

Figure 13: HVAC Control Panel, Nashville Site Visit
91

Renewable Energy Sources

In residential applications, the most common renewable energy systems are solar photovoltaic 

power, solar thermal energy, geothermal heating and cooling, and wind power. Biomass, 

biofuel, and hydroelectric (water turbine) systems are less commonly used in conjunction with 

an EPC but are not unknown. A qualified engineer with a background in renewable energy in 

the built environment should be consulted when considering the use of less common 

renewable sources, because some sources may yield better results in certain climates. 

Figure 14: These Townhouse-Style Apartments Rely on Geothermal Heat Pumps To Substantially Reduce Both Demand and 

Associated Costs; Chester Site Visit
92

Figure 15: Geothermal Heat Pump, Chester Site Visit

Figure 16: Solar Panels Used for Domestic Hot Water, Chester Site Visit
93

Figure 17: Rooftop Solar Photovoltaic Panels, Kansas City Site Visit

Figure 18: Solar Water Heaters, Kansas City Site Visit

Figure 19: Rooftop Solar Photovoltaic Array, Watervliet Site Visit
U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Washington, DC 20410-6000

June 2017