To: Sandra Henriquez, Assistant
Secretary for Public and Indian Housing, U.S. Department of Housing and Urban
Cc: Meryl Finkel, Senior Associate, Abt Associates
Fr: Council of Large Public Housing Authorities
RE: Capital Needs Assessment Survey Addendum
DATE: November 13, 2009
Unfortunately, HUD chose not to share the survey questions with members of the Capital Needs Assessment Study Group before it was widely distributed. There are several areas where clarification is needed and where additional questions are required to gather the necessary information to properly estimate capital needs. We are reiterating our request that an addendum be part of the survey.
Below are our concerns.
Each year, the percentage of seniors in public housing increases, requiring more senior and/or disabled accessible units, and more retrofits of existing units. However, there is no reliable national estimate of the number of units needed to address this growing sector of public housing residents.
The study is an opportunity to change that with the addition
of the crucial question about projected local needs for Uniform Federal
Accessibility Standards (UFAS) units. Question 32 (page 21) asks whether or not
demand for UFAS units exceeds a housing authority’s ability to supply the
units. In order to reliably estimate the cost of making a sufficient amount of
units UFAS accessible, there needs to be an estimate of both cost and projected
need for such units.
Question 26 needs some clarification. The question asks “how much on an average per unit basis” has the housing authority spent over the past three years on UFAS modifications. Does this mean the average spent on only those units that were modified? It could be interpreted as including all units, regardless of whether they were modified (e.g., the total amount spent divided by all ACC units). In order to get a reliable renovation estimate, it would be better to provide an estimate of the average cost on only those units that were modified.
Healthy Homes Improvements
The healthy homes section (page 22) only includes questions
about lead paint abatement/removal. Unfortunately, this section is an
inadequate depiction of the possible healthy homes improvements that can, and
are, being made. For example, many housing authorities are renovating or
building units using non-toxic materials to improve indoor air quality,
utilizing integrated pest management, and making strides towards mold
prevention. All of these improvements are known to have a positive impact on
resident health, and lower maintenance costs over the useful life of the
project. Excluding the numerous possibilities of healthy homes improvements
from this study will underestimate the actual capital improvement costs.
· Proper Ventilation
· Indoor Air Quality
· Moisture Control
· Rodent Control
· Radon Exposure Prevention and Remediation
· Pesticide Control
· Mold Prevention
· Dust/Dust Mite Prevention
· Carbon Monoxide Exposure Prevention
· Arsenic Exposure Prevention
· Asbestos Removal or Abatement
Energy Efficiency Improvements
In order to establish a threshold for determining whether an energy
efficient upgrade has been made,
Question 39 (page 23) needs clarification. The questions ask about the potential savings identified by an energy audit. It is unclear whether this means energy consumption savings or utility cost savings. We ask the department to clarify the type of savings and whether the question applies to each type of utility.
Questions 41a-41g ask for information on the percentage of
ACC units that have received energy efficiency upgrades, with categories are
divided into 25 percent increments.
Questions 43a-43g should require more specificity about the energy efficiency upgrades purchased. The potential energy savings from two different heating systems replacements can be drastically different. For example, if one housing authority replaces the heating system in a building with more energy efficient boilers, while another replaces the heating with geothermal heating, neither the possible energy savings nor the costs involved are the same. By asking for information on the upgrade specifications the survey could provide information on the level of upgrades being made, and outliers that affect the overall estimate of costs could better be accounted for.
In addition to the comments raised above,
Beginning on page 8, there are several questions about the
proportion of a housing authority’s ACC units that are “marketable to the
low-income, public housing market.”
CLPHA recommends that the study make two important changes. First, rather than using “occupiable” as the design standard, the study should use the same standard used to determine Total Development Cost (TDC). This standard is widely accepted and used in a variety of HUD programs, and is the basis for public investment in many development projects. Secondly, all cost estimates should be shared with the housing authority to compare the estimate with recent capital improvement costs. If the authority finds that the cost estimates are too low, they should be able to appeal the CNA estimates and replace the estimate using recent, verifiable cost data.
While the CNA will provide a needed and valuable snapshot of current capital needs and the likely cost to repair and replace PHA portfolios in the future, it does not provide information on how housing authorities have been able to build sustainable affordable housing, absent a sufficient capital funding stream, in the recent past. As we transition to a project-level asset management model, we believe that case studies of various capitalization strategies would prove extremely useful in helping authorities envision individual projects and determine the best method of financing.
We welcome the opportunity to talk with HUD staff further about how these case studies could be conducted, and the kind of information they would provide.