This week HUD issued some welcomed Frequently Asked Question (FAQ) guidance on the Utility Consumption Baseline (UCB). Read it here: http://www.radresource.net/faq_gen.cfm. HUD relaxed both the milestone timing of the UCB study as well as the unit sampling size.
In more detail, excerpts of the FAQ:
Question: In a RAD FAQ (WEB11102012_22_04070), the Department offered the following response regarding capturing tenant utility data to complete the UCB: “There is no specified minimum sampling requirement, due to the different configurations of buildings. The RPCA contractor must have enough data to ensure that they can produce such a baseline in which HUD can rely.” Can the Department further clarify the sampling size for the UCB?
Answer: The PCA provider should seek to obtain data on resident-paid utilities from 25% of the units, which is a threshold percentage for the PCA provider to provide reasonable estimates of whole-building energy consumption. Please note that in the near future HUD anticipates the publication of tools that will help PHAs and other industry partners manage the UCB data, so the flexibility and the 25% threshold provided in this FAQ is subject to change pending new HUD guidance and tools. Any UCB data submitted to HUD prior to publication of these standards will be grandfathered in to this sampling standard.
Question: The RAD Notice requires that the RAD Physical Condition Assessment (RPCA) be completed within 90 days of award. We expect to complete the RPCA within this timeframe, except for the Utility Consumption Baseline (UCB), which, because of the need to obtain individual utility data from tenants, will take longer. Since the UCB isn’t actually used for underwriting purposes, can we submit the UCB along with the Financing Plan, which is due within 180 days of award?
Answer: The UCB is an important feature of the RPCA and is part of HUD’s broader initiative to establish baseline utility data for our entire rental housing stock. However, since the data is not used as part of Underwriting, HUD will consider waiver requests from PHAs to submit the UCB at the time of the Financing Plan, or after the closing/RAD conversion. If you seek a waiver, please alert your Transaction Manager in writing. Please note: this flexibility extends to non-FHA transactions. For FHA transactions, until further notice, the UCB must be part of the RPCA document submitted with the FHA Firm Commitment application. Furthermore, in the near future HUD anticipates the publication of tools that will help PHAs and other industry partners manage the UCB data, so the flexibility provided in this FAQ is subject to change pending new HUD guidance and tools.