24 CFR 990.185 contains the regulatory language around the four basic HUD energy reduction incentives. Understanding impact and interaction of the Frozen Rolling Base (FRB) incentive, the Subsidy Add-On (typically referred to as Add-On Subsidy or AOS) incentive, the Resident Paid Utility (RPU) incentive and finally the Rate Reduction incentive is difficult as stand-alone regulations.
As with many federal regulations, the US Department of Housing and Urban Development (HUD) has layered dozens of Public and Indian Housing (PIH) Notices and various guidance related to these incentives dictating how they are to be used and how they create revenue for public housing authorities.
Most public housing authorities (PHAs) utilize the HUD incentive(s) at the direction and recommendation of the Energy Services Company (ESCo). This is not always to the optimum benefit of the PHAS and further, the ESCo can be somewhat distant when it comes to assisting your PHA with the HUD required forms and documentation, leading to loss of revenue.
EPC Solutions can help your PHA navigate the HUD incentives and ensure your agency is maximizing revue and reducing financial risk through proper structure of the incentives.