The Problem: Energy Use Transparency in the Multi-Family Housing Sector
Understanding ratepayer energy use is a key obstacle in the effort to pursue energy
efficiency upgrades in the multi-family housing sector. Without transparency
around energy use and ratepayer energy costs, it is difficult to analyze and evaluate
the best ways to target energy efficiency efforts.
This problem is true across the residential and commercial markets, however
recently some cities have begun to adopt data disclosure ordinances that make it
mandatory for certain building subsets to report and make public both energy use
and asset data. Most city’s mandatory disclosure policies, with the exception of
Austin, TX, do not require disclosure from the building subset that typically includes
multi-family housing units.
In thinking about designing a pilot program to address energy efficiency in the
multi-family housing sector in Cambridge, we have operated under the assumption
that a mandatory disclosure policy for the subset is unlikely within the next year or
so, despite the fact that mandatory disclosure for buildings 50,000 square feet and
up seems imminent.
Instead, we have thought about how to solicit voluntary disclosure from the
community of renters and owners who make up the multi-family housing market in
Cambridge. Since post-secondary students make up 30% of the rental market in
Cambridge, we set this group as our initial target community.
Program Element: University-led Student Data Share
Although energy use data disclosure is not required, some Cambridge residents
voluntarily release their energy use data by sharing their NSTAR account
information with local third party companies like New Ecology Inc.’s WegoWise.
Voluntary participation in WegoWise suggests that ratepayers do have interest in
sharing and learning from their energy use data, however, the multistep sharing
process required to allow a third party access to a utility account can be perceived
as somewhat onerous and participation in WegoWise is low.
This led us to hypothesize that if voluntary disclosure is successful in our
Cambridge pilot, the various stakeholders involved will be more supportive of a
more expansive program or a mandatory disclosure policy. In order to increase the
number of Cambridge residents who voluntarily share energy use data with third
parties, a voluntary disclosure program will be detailed with consideration given to
the following priorities:
1. Ratepayers should receive meaningful or even tangible benefit for sharing
their energy use data voluntarily
2. Terms like “disclosure” and “transparency” have a negative connotation that
evokes suspicion
3. Programming should address the high rental turnover rate given that nearly
30% of Cambridge residents are students
4. Data should be managed so that NSTAR, the City, and anchor institutions, like
universities, can all find benefit in this process.
A best-case scenario pilot program would entail that those Cambridge residents
willing to donate energy use data could opt in to (or out of) a data sharing
agreement that would allow NSTAR to automatically release their energy use data
each month to a predetermined third party. There would be no need for a ratepayer
to release account information to a third party, however the ratepayer would still be
able to learn and act on the results of any analytics performed on their data.
In light of these considerations, we proposed piloting a voluntary disclosure
program built on a partnership between NSTAR, MIT, Harvard University, other
local post-secondary educational institutions, and other potentially interested
community groups.
This program would be anchored by at least MIT or broader coalition of institutions
and consist of two key components.
1) University-led student data share
- University registrar would include an online energy data sharing
permissions agreement as part of its student registration materials giving
NSTAR permission to share the student’s utility data with the academic
institution.
- In return for agreeing to share energy data, students would receive some
sort of benefits membership that could potentially offer transit discounts,
food coupons, a home energy kit, etc.
- MIT or a broader coalition would manage a shared database with NSTAR
and the City of Cambridge that they would be permitted to use for research
purposes.
- NSTAR would have the opportunity to test privacy concerns in a limited
environment.
2) Landlord participation:
- Universities would require landlords interested in posting “For Rent” ads
on their student rental forums to submit asset data to the university for each
individual listing.
- The universities would match or group student energy use data by landlord
asset data and match that with city tax assessor records to produce a more
comprehensive multifamily energy database”
The benefits of this pilot element could include:
1) A model that could be expanded to include other community groups affiliated
with religious institutions, athletics, and more.
2) A repository of energy use data that could be used by universities for more
research, though the value of this hinges on participation
3) A cohort of Cambridge residents comfortable with sharing energy use data —
a key concern voiced by NSTAR in meetings with our class
4) Greater awareness of energy use amongst students which could potentially
translate to savings on energy bills or increased comfort if students are
empowered to approach landlords about the energy efficiency of their units.
5) Greater visibility of this issue in the community which could facilitate efforts
to put pressure on landlords to initiate upgrades to buildings with outdated
or energy intensive assets.
To vet this element of the pilot, we interviewed key stakeholders at MIT, including
representatives from the MIT Sustainability office, Housing and Residential Life,
IS&T, and Facilities. We also spoke with a representative from the City of Cambridge
who is responsible for any forthcoming mandatory disclosure policy.
Findings:
The City, MIT, and Harvard are planning to announce a compact formalizing a
partnership in commitment to sustainability in Cambridge.
Steve Lanou TITLETK
Multifamily housing stock is not a key priority for the City’s Environment department
and thus for impending mandatory disclosure
John Bolduc TITLETK explained that since the commercial building represented
such a significant portion of energy use, achieving reduction in energy use amongst
that building subset was a central first priority of his department. He recommended
a report produced by Josh Sklarsky of the Peregrine Energy Group which does
confirm this explanation but also found that multi-family housing still accounts for
about 25% of Cambridge energy use (when you combine a few different land use
classifications. See Figure 3 in the report).
Relatively few students use MIT’s resources for Off Campus Housing available through
the Housing and Residential Life.
According to TITLETK Linda Patton, those that do use off campus housing services
rarely every mention energy as a concern. Cost, however, is a primary concern that
could be leveraged. That said, Patton noted that because the market for housing is
tilted so significantly in favor of landlords, students ultimately will make decisions
based purely on rent affordability even when they know the condition of the
building or the unit is subpar.
Furthermore, Patton says that students by and large use other means, like Craigslist
and brokers, to find rentals, not MIT’s off campus housing resources.
The HRL maintains a database for off campus rentals however there is limited in
interest requiring asset data from landlords as a condition of entry to the database
because the Office representative is concerned about sufficient quality landlord
participation.
Patton explained that each submission to the off campus rental database is
monitored and approved individually. Due to high numbers of false submissions to
the off campus rental database, a serious concern is that there an insufficient
number of entries available on the database. Patton said that she would be
concerned about instituting a landlord asset data disclosure mechanism because it
would not be in the interest of the utility of the database to institute any limits to
quality landlords submitting rentals to the database.
There are serious institutional and privacy challenges associated with setting up a
direct feed of energy data from NSTAR, implementing a permission system through the
MIT Registrar, and ensuring tenant consent to data disclosure (for MIT).
Jonathan McIndoe (TITLETK), noted that technically speaking, it would be possible
to implement the pilot proposed above, but not on the timeline of a pilot. He thought
the idea would be better suited to a longer term project proposal than a pilot and
enumerated the following key challenges:
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NSTAR will only disclose data if given permission from the student whose
name is on the account. He noted that it was also possible that without an
account number (unique ID), NSTAR may have a hard time identifying the
correct ratepayer.
MIT may require disclosure from all tenants in the unit, including non-MIT
students. According to McIndoe, this issue has been raised before. I was
unable to confirm or deny this obstacle with John DiFava and Joe Gifun at
MIT Facilities.
A system would be required to document when students move and/or
account for new tenants entering the unit even if the ratepayer continues to
be a tenant
IS&T is not resourced to build a project like this. That said, other IT
departments (CRON?) may have ability since the system would not be
complex to build.
Using the Registrar as the point of entry requires a long term commitment to
the project since changing absolutely anything on Registrar pages is reported
to take a very long time. Other potential points of entry may be a Touchstone
protected page (certificates can be used for authentication, etc) or an
addition to Stellar, but these ideas would require further conversation with
these individual vendors.
McIndoe’s key question in response to the pilot element proposal was: “Is the scale
you will achieve worth it?”
Joe Gifun - benefits
Conclusions:
In order to make a voluntary disclosure program meaningful for analytic purposes, a
minimum of 50% of the multi-family market would need to voluntarily disclose
their energy use data. Even if every student account holder in Cambridge (not just
MIT students) agrees to voluntarily share energy use data, we would not achieve
this analytical target within the timeline of the pilot.
Therefore, I recommend that instead of attempting to implement this program
element within the pilot, we use the findings from this analysis to inform our work
going forward.
First, the imbalance between the costs of implementing a voluntary data disclosure
program and the benefits, in terms of learning power from the data collected
clarifies the importance and necessity of a mandatory disclosure policy for this
especially opaque residential housing subset.
Second, if instead of trying to achieve scale for a voluntary data disclosure, we
measure the results of an experimental mandatory disclosure pilot in a small area of
Cambridge (Central Square) we can gauge potential community reactions to
mandatory disclosure and test the influence of mandatory disclosure on the results
of the broader pilot.
An experimental mandatory disclosure pilot element is proposed below.
Experimental Proposal: Testing Mandatory Energy Use Data Disclosure for 220 Multifamily Housing in Cambridge
How do we test the value of data transparency in a small subset of Central or some
other neighborhood?
Ideas:
1) Pilot a system to minimize disclosure burden on landlord and make optin/opt-out data share simple. Aim to achieve 95% participation? Tests
possible options for how a mandatory policy could be implemented.
2) Pilot a batch sign up for WeGoWise with 95% participation as a goal? Tests
options for mandatory policy could be implemented by building on existing
third party stakeholders.
3) Require disclosure for participation in the pilot. Show participants monthly
analytics, aggregate building analytics, and pilot area analytics. Combine
information in CBSM to see if greater access to information about energy use
improves upgrade uptake. Tests basic mandatory disclosure and will need to
address negative reactions.
Existing Condition
Blah blah blah… you guys
have got the transparency
stuff down cold.
Pilot
One neighborhood in
Cambridge has
 Energy data disclosure
for MF (aggregated
across units)
 Asset rating disclosure
(some score of EE
potential, based on
existing assessment
tools)
Long-term
Energy Data
Option 1
Mandatory disclosure of
energy data, aggregated
across MF buildings
(requires population of
databases, with sharing
directly by utility – NOT
building owner report)
Alexis may have research
on this.
Test, to see how this can
be used to enhance uptake Option 2
Voluntary data disclosure.
of EE.
Yael’s system.
Asset data
1. Develop “remote
energy assessment” /
“low-touch” asset rating
tool, that lowers the cost
of assessments in MF
properties. (Alex’s
schtick)
2. Mandatory assessment
ordinance.