NLIHC has joined the Housing Justice Network (HJN) in submitting a comment letter to HUD on proposed changes to regulations for the Public Housing Physical Needs Assessment (PNA), which identifies work that a PHA must do to bring its developments up to modernization and energy standards.
The proposed rule (see Memo, 7/22) would require PHAs to complete a comprehensive PNA and energy audit for each project every five years, with annual updates. HUD also proposed requiring PHAs to project the current modernization and life-cycle replacement and repair needs of each project over 20 years because that period more closely reflects the useful life of building components and systems. The current PNA looks ahead five years.
NLIHC and HJN, an informal network of legal services and affordable housing advocates, believe the PNA is a valuable planning tool. However, the existing assessment warrants revision because it does not provide the information needed on the type, location, or priority of physical needs. The organizations suggested that PHAs be required to share their PNA and annual updates with resident advisory boards and resident councils prior to submission so that residents have the opportunity to comment.
The letter conveyed objections to HUD’s proposal to eliminate statements of physical disparity in buildings occupied predominantly by one racial or ethnic group and the improvements needed to correct such disparity. It also included the organizations’ suggestion that HUD continue to require PHAs to indicate intent to demolish, partially demolish, convert, or sell a project or units.
NLIHC and HJN suggested that the regulations clearly state that the PNA include all Annual Contributions Contract units in HOPE VI and other mixed-finance projects.
The comment letter is at: http://nlihc.org/doc/HJN_NLIHC_HUD_Comment_Letter_PNA.pdf