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The indirect costs of complying with new regulations for the emission of carbon dioxide and other greenhouse gasses could make it more difficult for home builders to provide affordable, energy-efficient housing, NAHB told the U.S. Environmental Protection Agency on Dec. 28.
In its response to the “Prevention of Significant Deterioration/Title V Greenhouse Gas Tailoring Rule,” NAHB acknowledged that the EPA’s proposed rulemaking may not directly affect home builders and developers because emissions from their activities are significantly smaller than those from the large commercial enterprises, utilities and other businesses that will have to comply with these new Clean Air Act regulations.
However, “Because those industries directly regulated under the [Clean Air Act] will pass along compliance costs, any additional regulations will hinder the ability of our members to provide affordable and energy-efficient housing,” the NAHB letter said.
“Likewise, these rules could prevent our industry from recovering from the current economic climate and prevent the creation of new home building jobs,” the comments said.
NAHB also pointed to other initiatives that could provide a more significant reduction in the carbon emissions from residential and commercial buildings, which account for an estimated 40% of the total emissions from all sources.
These initiatives — including energy retrofits as well as incentives and rebates for more resource-efficient construction techniques and products — have not been included in any Clean Air Act regulatory plan, which is another indication that the act is inappropriate as a regulatory tool to address this problem, the letter said.
“While energy codes and green building for new housing are important steps to future sustainability, addressing the legacy housing stock is the most cost-effective means of reducing greenhouse gas emissions from the residential sector,” NAHB said.
“Over the past two decades, NAHB and its members have facilitated the adoption of energy-efficiency practices by designing and disseminating green building resources for the residential construction, land development and remodeling industries so members could begin to incorporate these sustainable practices into their daily routines,” the letter said.
Today’s new homes are significantly more energy-efficient than those of a generation ago and homes built to the 2009 International Energy Conservation Code can expect to use between 12% and 16% less energy than homes of similar size constructed to the 2006 IECC.
“NAHB and its members have developed a significant amount of experience and expertise in this arena, which we believe can provide a blueprint for success,” the letter said.
“We are hopeful that the agency will rely on NAHB and the successes we have garnered as the EPA develops its action plan to boost energy savings and create green jobs. NAHB’s efforts have shown that voluntary initiatives and not mandates are one key to obtaining builder and consumer buy-in that garners measurable results,” NAHB said.
For more information, e-mail Calli Schmidt at NAHB, or call her at 800-368-5242 x8132.