Document Type
Article
Publication Title
Harvard Journal on Legislation
Abstract
This article takes a step beyond Professor Ferrey’s prior article published at Harvard, “Cold Power: Energy and Public Housing,” 23 HARV. J. ON LEGIS. 33 (1986), to review and document housing energy problems at the federal and local levels. It offers concrete proposals for a revised federal utility allowance system that, while recognizing technological
limitations facing public housing authorities, would employ more sophisticated statistical tools to administer better the federal utility allowance system.
Public and Section 8 housing are the two largest sources of low-income rental housing in the nation, subsidizing several million units in more than 3000 communities nationwide. The federal utility allowance system for these housing units affects millions of low-income, elderly, and handicapped tenants. The federal government subsidy of utility expenses is in billions of dollars annually.
The current "deregulated" system fails to provide tenants with equitable allowances; this article recommends the use of more sophisticated statistical techniques to set allowances and investments in energy efficiency to minimize variations in energy consumption that are beyond tenants' control. The article analyzes statistical tools to redesign and recalculate utility allowances and concludes that the current utility allowance calculation lacks statistical robustness and misallocates utility allowances in many or most housing authorities nationwide.
The article introduces three models for calculating utility allowances and examines the benefits and limitations of each model. The article presents several additional statistical tools to reflect the central tendency, range, and skew of federal housing energy use, ultimately recommending a more statistically robust utility allowance scheme intelligently incorporating these tools. It also suggests that a key to reform is implementation of available energy efficiency measures to narrow the range and variation of energy consumption in subsidized housing units. This Article also introduces legislative and administrative suggestions to improve the system at all levels and to bring it into compliance with current statutes, and consistent with the interests of the various affected stakeholders.
First Page
145
Last Page
206
Publication Date
Winter 1995
Recommended Citation
Steven Ferrey, In From the Cold: Energy Efficiency and the Reform of HUD's Utility Allowance System, 32 Harv. J. on Legis. 145 (1995).
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