EPA Greenhouse Gas Finding Could Raise Cost of Housing
NAHB has submitted comments that call in to question whether the U.S. Environmental Protection Agency (EPA) fully considered its proposed endangerment finding for greenhouse gases under the Clean Air Act.
A positive finding, NAHB said in its comment letter, will affect whether home builders can “provide safe, affordable housing for a growing population.”
The proposed endangerment finding states that greenhouse gases — mainly carbon dioxide — are a threat to public health and welfare and that emissions from cars and light-duty trucks are a cause of this dangerous pollution.
While an endangerment finding enables the EPA to establish emission standards for vehicles, it can also eventually lead to the agency’s regulation of other sources, including so-called stationary sources, which include homes.
“NAHB has concerns that subsequent regulations will subject our members to constraints on the use of construction equipment, delays and costs in new permitting requirements, availability of construction materials and increased cost of energy, all of which affect accessibility to affordable housing,” the comments said.
The agency should “defer any final endangerment determination until both EPA and the regulated industry are prepared for the full consequences of the final decision,” the letter said.
The endangerment finding will have a direct effect on many of the industries that supply home builders with the raw materials used in construction — and the additional costs of those materials now subject to new permitting and other requirements.
A 2008 NAHB study on the embodied energy of a typical home — the greenhouse gas emissions generated from the production, installation, maintenance and disposal of products used during construction — amounted to 55.42 metric tons of carbon dioxide.
If the carbon dioxide emissions on these materials are calculated at $156 a metric ton — a figure used in a recent congressional proposal — the end result is an additional $11,340 average increase in the price of a home, which would price out more than 2 million potential buyers, NAHB has determined.
Meanwhile, the endangerment finding is not designed to address the greatest source of energy inefficiency in the residential sector — namely, older, less-efficient homes. Renovating these homes with better insulation, more efficient heating and air conditioning equipment and other improvements would result in a more significant impact on emissions.
NAHB urged the EPA to revisit the proposal and take a closer look at “the unavoidable, adverse direct and indirect impacts on all sectors of the economy . . .and address the full consequences . . . including any inadvertent consequences that cascade from an endangerment finding.”
For more information, e-mail Calli Schmidt at NAHB, or call her at 800-368-5242 x8132.