The U.S. Department of Housing and Urban Development (HUD) issued a proposed rule that would require all public housing authorities (PHAs), regardless of size, to conduct physical needs assessments (PNAs). If implemented, it would require the following:

  • Assessments of life-cycle replacement, repair, and modernization costs for public housing projects for a 20-year period (currently, the required assessment period is five years)
  • Annual updates, with completion of new PNAs every five years
  • PNAs by all PHAs, including those with fewer than 250 units and Moving to Work (MTW) participants
  • Completion of new PNAs in conjunction with energy audits, with audit results incorporated into and addressed in the PNAs
  • Electronic submission of PNA results via a new HUD system, which will be used to analyze data and as another HUD monitoring tool
  • Minimum qualifications for PHA staff or outside consultants who conduct PNAs
  • Alignment of the timing and completion of new PNAs with PHA submissions of five-year plans

HUD estimates that the new PNAs will be more costly to PHAs to implement than current PNAs, averaging approximately $65.22 per unit compared with a HUD estimate of $50 per unit for current PNAs.

Comments on the proposed rule are due to HUD on September 19, 2011. HUD is soliciting comments, in particular, about the following:

  • The benefits and challenges of preparing energy audits in conjunction with PNAs
  • The appropriate qualifications for PNA providers and the appropriateness of PHA staff performing PNAs used for internal strategic planning purposes
  • Whether HUD should require that PHAs use a third-party provider to conduct PNAs

Click here for the full text of the proposed rule.