Public Housing Physical Needs Assessment Rule Revision Proposed

HUD proposed revising existing regulations governing a public housing agency’s (PHA) physical needs assessment (PNA) on July 20. A PNA identifies all of the work that a PHA needs to undertake over time to bring each of its developments up to modernization and energy standards. The requirement to conduct a PNA has long been a part of the regulations.

HUD’s Office of Public and Indian Housing (PIH) published proposed changes to the rule on July 20 after four meetings with PHA representatives. The amended rule would require all PHAs to complete a comprehensive PNA for each project, adding PHAs with fewer than 250 units and PHAs designated as Moving to Work PHAs. In addition, while energy audits are currently required, PIH proposes requiring all PHAs to complete them in conjunction with the PNAs.

The proposed rule would require completion of a comprehensive PNA and energy audit every five years with annual updates. The specific procedures for annual PNA updates will be determined by a new PNA tool PIH is developing. HUD proposes requiring PHAs to project the current modernization and life-cycle replacement repair needs of each project over a 20-year period because that length of time more closely reflects the useful life of building components and systems. The existing PNA only looks ahead five years.

As proposed, the rule would no longer require the PNA to discuss any physical disparities between buildings occupied predominantly by one racial or ethnic group, and in such cases the physical improvements required to correct the disparities. Nor would future PNAs be required to indicate intent to demolish, partially demolish, convert, or sell a project or units in a project.

Comments are due September 19. The proposed rule is at