Concerns and answers about HES

By Restoring Earth Connections

With Updates by Thurston Climate Action Team

March 24, 2026

1. Concern: HES will disproportionately impact older homes and lower income households.

Response: There is no evidence that lower income households systematically receive lower HES scores. HES may devalue older homes if they are less efficient than new homes, but devaluation is subjective to the buyer who considers many factors to determine the value of the home to them.  There will be subsidies for low income households for conducting the HES audit and for energy efficiency improvements (the latter through the Energize Thurston program).

1. Concern: Risks reducing marketability or sales proceeds without clear consumer benefit.

Response: Available evidence indicates that low ratings do not hurt the sale of inefficient homes. (ACEE, 2025) Additionally, it is a great benefit to buyers to know what the energy efficiency of the home is, so that they can plan to make any needed changes. Many members of the community have already testified at the County that they see this as a benefit.

1. Concern: Stand alone HES inspections duplicate existing home inspection process.

Response: HES is not the same as a home inspection. A home inspection may mention the heating system but not all other items that make up energy efficiency and not in an apples-to-apples way.

1. Concern: No clarity about the cost of HES assessments.

Response: Costs are consistently $150-$350 per audit. (Source: Home Energy Assessment (HES) Model Ordinance Policy Review and Recommendations, authored by local jurisdiction staff, and included in a June 24, 2024 memorandum to the TCMC’s Community Advisory Workgroup). The price variation has reasonably to do with different size homes and geography.  The highest priced assessments were in California. Oregon costs were in the $150-200 range, likely related to transportation costs.

1. Concern: No clarity regarding quantity, availability, and qualifications of HES assessors.

Response: Staff have been clear and consistent about the number of HES assessors needed to launch a mandatory program (6-8) and the process to get certified. In other jurisdictions with HES ordinances, the market for these jobs responded quickly. Tumwater has already heard from people who want to get trained and many folks who do home inspection have realized they could learn to do this and do it at time of inspection which will help improve the speed of the process. Unions favor this measure because it does create jobs and helps their members who may be in the market for a home. (The Thurston Lewis Mason Central Labor Council and Amalgamated Transit Union 1765 have adopted resolutions supporting it.) Recruiting and training assessors will be part of the work accomplished during the one year implementation period.

1. Concern: No clarity on timelines, transaction delays, or enforcement.

Response: Timeline of adoption is up to the jurisdictions. It will go into effect one year after passage. The average wait time for a HES assessment is 3 days. Portland, OR is actually experiencing a 2 day turnaround for HES assessments. (Source: “Energy Ratings for Home Sales,” American Council for an Energy Efficient Economy, July 2025.)  Enforcement strategies and penalties are up to the jurisdictions, and will be designed in detail during the one-year implementation period. Enforcement will be aided by including this score as a required item in the Northwest Multiple Listing Service.

1. Concern: No clear mechanism on HES oversight or enforceability.

Response: The fact HES has to be listed on the Northwest Multiple Listing Service listing makes this almost self-enforcing. MLS shared a strategy and examples for how to increase enforceability upon listing in MLS. Jurisdiction staff will periodically review MLS listings to verify compliance.  Additional enforcement will occur on a complaint basis, like other codes.

1. Concern: Low income and private sales are exempt from this ordinance even though they are equal, if not greater, contributors to carbon emissions.

Response: People with lower incomes do not contribute to greater carbon emissions than higher income folks. The inverse has actually been found to be true (Diffenbaugh & Burke, 2019). For sale by owners and low-income households are not exempt from the model ordinance, though they may qualify for a subsidy; sales included in RCW 64.06.010 are exempt. Portland has not seen an increase in sales by owner and private sales due to HES.

1. Concern: The ordinance requires scoring, not improvements.

Response: Yes, that is correct. However, the Energy Trust of Oregon recently assessed improvement rates of scored homes and found that 8.8% of homes scored received energy efficiency rebates primarily for measures recommended in the inspection report. The Energy Trust found that rebates were 10 times higher for homes that received HES reports compared to unscored homes.

1. Concern: No evidence that mandatory disclosure alone meaningfully reduces emissions.

Response: Meaningfully is a subjective term. We are in a climate crisis and analysis has shown that this policy is poised to reduce emissions from one of the highest emitting sectors in Thurston County.

1. Concern: Voluntary and incentive-based programs may achieve a greater impact.

Response: A 2025 report from ACEE summarizes research on the impact of voluntary energy rating programs, finding exceptionally low participation ranging from 0.5% to 13% of homes participating. Voluntary programs are much more expensive for jurisdictions to administer because they require substantial incentives, subsidies, and marketing to drive demand.

1. Concern: Appraisers and lenders were not meaningfully engaged.

Response: TCMC staff included lenders as a target group in the focus groups and reached out to a number of mortgage lenders requesting participation. Ultimately, only the WA State Housing Finance Commission chose to attend. The earlier effort 5 years ago had both lenders and appraisers involved and they were positive about the idea.

1. Concern: Unclear how low scores may affect valuation or financing.

Response: In markets with required HES disclosure, appraisers may consider energy information as one of many inputs, but it has not emerged as a dominant or determinative factor in valuation. Impacts on sale price from a 1-point change in HES average about 0.5%, or roughly $2,000 on a median priced US home. This suggests buyers and appraisers value the information, but at a relatively modest level compared to factors like location, square footage, or bedroom count.

This can be something that is bargained about during inspection resolution. It also means that people taking out a mortgage can ask for a bigger mortgage to install energy saving measures that will pay for themselves. This would be a win/win for both parties.

1. Concern: $250 out of pocket is a lot of money for some people.

Response: The ordinance provides subsidies and makes exceptions to some low-income households. Additionally, many people take out home equity loans right before selling a home in order to make a myriad of small repairs and improvements that their realtor suggests for improving salability. This fee could be rolled into such a loan or arranged for payment once the home sells – as is sometimes done with the inspection costs.

1. Concern: Claims have been made that RCW 82.46.037 prohibits jurisdictions from passing something like this.

Response: This takes words out of context to get to that conclusion. The RCW says no jurisdiction can impose a tax at the point of sale. This ordinance would not impose a tax. It also says a jurisdiction cannot force an owner to make physical improvements or modifications to the property at the point of sale. Again, this ordinance does force anyone to change anything (they may decide to do so.) It only requires the collection of information. If this were true, inspections would not be allowed either. Legal advice has been rendered that this is not a germane argument.

16. Concern: This would be better accomplished as state law.

Response:  While that would be ideal it is hypocritical for this claim to be made when there was an effort this year to bring such a bill in the legislature and it was killed by having the opposition offer 100 amendments, so that by the rules of House procedures the time it would have taken to call up each amendments and vote it, killed it due to lack of time.  In the meantime, the climate crisis continues.