HUD Issuing New Physical Needs Assessment and Energy Audit Requirements

New requirements are on the way for how HUD Public Housing Authorities are to conduct Physical Needs Assessments and Energy Audits.  The U.S. Department of Housing and Urban Development’s (HUD) Office of Public and Indian Housing is issuing a rule in summer 2012 to require synchronization of Energy Audits and Physical Needs Assessments into the Green Physical Needs Assessment (Green PNA), and will require measurement of the cost effectiveness of energy conservation measures. 

Under current requirement 24 CFR 905 & CFR 965 Subpart C, Public Housing Authorities (PHAs) are required to have an Energy Audit performed every five years and Public housing Authorities greater than 250 units are also required to perform a Physical Needs Assessment every five years, with no minimum staff qualifications to perform either the Energy Audit or PNA.  New requirements are requiring all Public Housing Authorities, regardless of size, to perform a Physical Needs Assessment in conjunction with an Energy Audit every five years. 

HUD Physical Needs Assessment Requirements for Public Housing Authorities

Additional changes to the HUD Public Housing Physical Needs Assessment requirements include a twenty year planning period (previously was five years), requiring HUD Capital Planning Tool instead of PHA Capital Planning Tool, and establishing minimum qualifications for Physical Needs Assessment provider.  Currently some Pubic Housing Authorities directly employ staff people to perform Physical Needs Assessments that are not qualified to do so.  The proposed rule would establish minimum qualifications for the PNA provider, which standards would include experiential qualifications in property inspection and evaluation, cost estimating, energy efficiency and green capital upgrade and construction practices, and working knowledge of common information technology software.   

HUD Energy Audit Requirements for Public Housing Authorities

Additional changes to the HUD Public Housing Energy Audit requirements include following 24 CFR 905 audit protocol instead of 24 CFR 965, establishing content and submission requirements, and establishing minimum qualifications for Energy Audit provider.  Currently some PHAs directly employ staff people or hire auditors to perform Energy Audits that are not qualified to do so.   The proposed rule would establish minimum qualifications for the auditor, which standards would include state or national qualifications, including Professional Engineer or Certified Energy Manager.   

Goals for the HUD Green Physical Needs Assessment

The primary goals of the Public Housing Green PNA are:

• Enable HUD to measure the impact of the annual Capital Fund appropriations on the physical needs of the public housing inventory
• Evolving the Management practices of PHAs toward project-based capital planning
• Furthering the objectives of 2005 Energy Policy Act
• Producing data on green activities for the Capital Fund in support of HUD’s High Priority Performance Goal to create energy efficient housing
• Enabling PHAs to better assess the position of their portfolios to take advantage of potential opportunities

Currently capital planning requirements only address short or moderate term needs of Public Housing Authorities and do not provide PHAs a mechanism to complete long term capital planning.  The new Green Physical Needs Assessment tool allows PHAs to address the life cycle needs of their portfolios by requiring 20 year projections.  The project-based PNAs, in conjunction with HUD’s new focus on the project-based Asset Management Program, bring PHAs closer to standard industry practices for efficient capital planning.