Despite this split incentive problem, HUD has considerable leverage to reduce utility costs in its portfolio, which can benefit both HUD and households receiving a rental subsidy. While certain changes to HUD’s utility scheme would require congressional action and are therefore outside of HUD’s direct power to change, HUD administrators could change regulations and guidance documents without seeking outside approval. Specifically, as further detailed in the policy recommendations section, HUD can issue rules and guidance to:
incentivize owners and tenants to conserve energy, encourage project owners to retrofit buildings, more accurately project utility consumption, and create transparency on how allowances are calculated. Such changes will improve the financial viability of existing
properties and free resources that can be repurposed for other HUD goals.