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

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

HUD Physical Needs Assessment Requirements for PublicHousing Authorities

Additional changes to the HUD Public HousingPhysical Needs Assessment requirements include a twenty yearplanning period (previously was five years), requiring HUD CapitalPlanning Tool instead of PHA Capital Planning Tool, andestablishing minimum qualifications for Physical Needs Assessmentprovider. Currently some Pubic Housing Authorities directlyemploy staff people to perform Physical NeedsAssessments that are not qualified to do so. The proposedrule would establish minimum qualifications for the PNA provider,which standards would include experiential qualifications inproperty inspection and evaluation, cost estimating, energyefficiency and green capital upgrade and construction practices,and working knowledge of common information technologysoftware.

HUD Energy Audit Requirements for Public HousingAuthorities

Additional changes to the HUD PublicHousing Energy Audit requirements include following 24 CFR 905audit protocol instead of 24 CFR 965, establishing content andsubmission requirements, and establishing minimumqualifications for Energy Audit provider. Currently somePHAs directly employ staff people or hire auditors to performEnergy Audits that are not qualified to do so. Theproposed rule would establish minimum qualifications for theauditor, which standards would include state or nationalqualifications, including Professional Engineer or Certified EnergyManager.

Goals for the HUD Green Physical NeedsAssessment

The primary goals of the Public Housing Green PNA are:

• Enable HUD to measure the impact of the annual Capital Fundappropriations on the physical needs of the public housinginventory
• Evolving the Management practices of PHAs toward project-basedcapital planning
• Furthering the objectives of 2005 Energy Policy Act
• Producing data on green activities for the Capital Fund insupport of HUD’s High Priority Performance Goal to create energyefficient housing
• Enabling PHAs to better assess the position of their portfoliosto take advantage of potential opportunities

Currently capital planning requirements only address short ormoderate term needs of Public Housing Authorities and do notprovide PHAs a mechanism to complete long term capitalplanning. The new Green Physical Needs Assessment tool allowsPHAs to address the life cycle needs of their portfolios byrequiring 20 year projections. The project-based PNAs, inconjunction with HUD’s new focus on the project-based AssetManagement Program, bring PHAs closer to standard industrypractices for efficient capital planning.

Over $2 billion Capital Funds are provided annually to PHAs tomodernize or develop public housing. Currently HUD has no assessment tool to measure the impact ofthese funds on the public housing portfolios, and only as directedby Congress approximately every 10 years conducts a statisticalsampling of PHAs to estimate the accrual and backlog needs ofPHAs. As an alternative to this study, the PNA will enableHUD to aggregate the needs data at any point in time with everyproject in the public housing portfolio. The needs numberwill be updated annually to reflect the Capital Fundappropriations.