Just Solutions’ latest brief analyzes two Inflation Reduction Act (IRA) and Infrastructure Investment and Jobs Act (IIJA) programs that provide targeted investments in housing, the Green and Resilient Retrofit Program (GRRP) and Weatherization Assistance Program (WAP). This brief also examines four innovative model policies from California, New York, Oregon, and Pennsylvania that are filling the gaps in federal funding.¹

Making the connection between housing and climate justice

The history of discriminatory housing practices such as redlining, along with poor quality housing, serious home health hazards, and housing affordability, are having lasting impacts on environmental justice communities.² In these critical times, housing and climate efforts must be tailored to mend the harms and meet the needs of environmental justice communities.³ 

Green and Resilient Retrofit Program (GRRP)

One of the few programs directly addressing housing and climate justice is the Housing and Urban Development’s (HUD) new Green and Resilient Retrofit Program(GRRP). This Program provides grants and loans to owners of HUD-assisted multifamily housing⁴ to make upgrades that reduce carbon emissions, improve energy and water efficiency, incorporate renewable energy sources, and reduce climate hazards. Because this funding is exclusive to HUD-assisted multifamily housing, all the investments are made to affordable housing serving low-income families and individuals. These properties must extend their existing affordability provisions for at least 5 years beyond their current restrictions, up to a maximum of 25 years for grants and 15 years for loans. 

Challenges include application and outreach issues and design and implementation omission of tenant protections that could result in displacement of low-income tenants. 

• There are little to no incentives for owners to apply. This “split incentive” issue arises when the benefit of an investment does not accrue to the person who is required to apply for or pay for the investment upfront.⁵ Research shows that the split incentive problem has resulted in landlords underinvesting in energy efficiency measures, especially in situations where landlords do not pay the energy bill.⁶ 
• There is no evidence to suggest HUD is actively identifying high need areas and potential eligible owners who may have deteriorating housing and whose tenants may benefit the most from upgrades. Supporting applicants through the application process could also result in better uptake of the program. These barriers could result in lower participation in the program. 
• There is no requirement that owners provide relocation assistance during the renovations. Rather, the required provision of relocation assistance is mainly contingent on the local housing laws where the upgrades are happening.  HUD could offer affected tenants tailored support to find suitable alternative housing and moving assistance for major renovations. These gaps in GRRP’s design and implementation demonstrate the need for programs that prioritize low-income tenants. 

Weatherization Assistance Programs (WAP)

The IIJA provides much-needed funding for existing programs focused on assisting and easing household energy burdens and providing relief for household budgets. This includes $3.5 billion for the Department of Energy’s (DOE) Weatherization Assistance Program (WAP), a program tasked with reducing energy costs for low-income households by increasing the energy efficiency of their homes.⁷ According to DOE’s Weatherization Program Notice from December 2022, DOE will continue to develop “resources to address identified barriers and promote approaches to target and serve the highest energy burden and disadvantaged communities”.⁸ In addition, DOE will provide technical assistance to subgrantees to increase the application and utilization of funding in disadvantaged communities, especially households with the highest energy burden.

Although programs like WAP have the potential to benefit the communities that are most impacted by energy insecurity and related hardships, they also fall short in meeting the needs of communities most in need.

• WAP is often a one-off, non-recurring capital investment in energy efficiency measures. WAP has weatherized 7 million households, however, nearly 40 million households remain income-eligible for energy efficiency assistance.⁹ Research shows that low-income communities experience less access to residential energy-saving appliances and other energy efficiency upgrades.¹⁰
• Similar to GRRP, property owners are not incentivized to invest in energy efficiency and can also pose other obstacles even when weatherization investments are available to them at no cost. For instance, WAP assistance is provided entirely as a grant that does not need to be repaid, but landlords must provide access to their properties so that audits can be done and retrofits implemented. Ultimately, it is key to address the health and safety conditions of peoples living conditions even before the weatherization process. 

Model policies at the intersection of housing and climate justice

In addition to these federal programs, states and localities are leading the way in passing innovative policies to address housing quality and reduce their climate footprint. At the local level, we highlight New York City’s Local Law 97 and Portland’s HEART Standards. We also highlight Pennsylvania Whole Home Repair Program and California’s Solar on Multifamily Affordable Housing as two statewide policies working at the intersection of housing and climate justice. Below is a short glimpse of the policy, for full review please visit the full brief here. 

New York Local Law 97 

Local Law 97 was passed in 2019 as part of New York City’s Green New Deal. Under this law, most buildings, over 25,000 square feet, or multiple properties on the same lot totaling over 50,000 square feet, will be required to meet new energy efficiency standards and greenhouse gas emission limits.¹¹ Starting in 2024, the law will help New York City reach a 40 percent reduction in greenhouse gas emissions from buildings by 2030 and net zero emissions by 2050.¹²

Portland HEART Standards 

Portland’s HEART Standards came in response to the City Council’s climate emergency declaration in 2020. The HEART Standards are climate and health-related performance standards for existing buildings to reduce greenhouse gas emissions, improve indoor air quality, and ensure livable indoor temperatures. The policy explicitly prioritizes setting anti-displacement measures to ensure that costs are not passed on to tenants, who are predominantly Black, Indigenous, people of color, low-income, and communities on the front lines of climate change.¹³ 

Pennsylvania Whole-Home Repairs 

The Whole-Home Repairs Program addresses housing insecurity and the climate crisis by providing grant funding for county-wide agencies to address habitability and safety concerns, provide measures to improve energy or water efficiency, and make utilities accessible for individuals with disabilities. The program will do so by funding county programs supporting up to $50,000 per unit in repairs for homeowners whose household income does not exceed 80 percent of the area median income. The program also offers loans to small landlords renting affordable units, to support and upkeep weatherization.¹⁴ Additionally, the program funds counties for construction-related workforce development. Applicants eligible for this funding are county government or a nonprofit entity authorized via an adopted resolution by the county government. 

Solar on Multifamily Affordable Housing (SOMAH) 

The SOMAH Program provides financial incentives for installing solar panel systems that benefit both low-income tenants and property owners throughout California. It provides up to $100 million per year in incentives to qualifying affordable housing within certain territories in California.¹⁵ Solar photovoltaic (PV) systems incentivized by SOMAH are required to benefit the tenants, with at least fifty percent of the energy produced by the systems to be allocated to tenants via virtual net energy metering.¹⁶ SOMAH is managed by the California Public Utilities Commission and administered by nonprofit organizations that provide no-cost services, technical assistance for property owners, and job training. SOMAH will invest up to $1 billion in rooftop solar with an overall target to install 300 megawatts of generating capacity by 2031.¹⁷ 

Conclusion

Despite the historic levels of investments, programs within the IRA and IIJA fail to address the housing needs of environmental justice communities. As a result, states and localities are leading the way in passing innovative policies. Therefore, the federal government should provide more funding to allow states to implement the housing justice programs that best fit their community needs. Such investments and policy solutions are needed to protect all of our communities and ensure communities have access to healthy, affordable, and dignified housing.

1. Just Solutions would like to thank Miriam Zuk and Lin Chin from Ground Works Consulting for their invaluable research and partnership in this project. ↩︎
2. Environmental Protection Agency, “Environmental Justice.” ↩︎
3. Strategic Actions for a Just Economy, “Los Angeles Building Decarbonization: Tenant Impacts and Recommendations,” December 2021. ↩︎
4. At least 50 percent of the units in a project must be assisted by Section 8 (Housing Choice Vouchers), Section 202 (Supportive Housing for the Elderly), or Section 811 (Supportive Housing for Persons with Disabilities). ↩︎
5. Climate and Community Project,  Decarbonization without Displacement. ↩︎
6.  Jesse Melvin, “The Split Incentives Energy Efficiency Problem: Evidence of Underinvestment by Landlords.” ↩︎
7. Department of Energy Office of Energy Efficiency & Renewable Energy, Weatherization Assistance Program. ↩︎
8. Department of Energy, Weatherization Program Notice 23-1, 2022 ↩︎
9. “Recognition of and Response to Energy Poverty in the United States.” Nature News, Nature Publishing Group, 23 Mar. 2020, https://www.nature.com/articles/s41560-020-0582-0. ↩︎
10. Just Solutions, Energy Burden & the Clean Energy Transition, 2022. ↩︎
11. New York City Sustainable Buildings, Local Law 97. ↩︎
12. Id. ↩︎
13. City of Portland, Developing standards for rental apartments. ↩︎
14. Pennsylvania Department of Community & Economic Development, Whole-Home Repairs Program ↩︎
15. CalSOMAH, About Solar on Multifamily Affordable Housing (SOMAH) Program ↩︎
16. California Public Utilities Commission, Solar on Multifamily Affordable Housing (SOMAH) Program ↩︎
17. California Environmental Justice Alliance, Solar on Multifamily Affordable Housing ↩︎