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Question:
What must be included in the Utility Analysis?

Answer:

Summary from the owner supporting the proposed change that should include the following:

  • Identify the types of utilities covered in the UA (gas, electric, etc.)
  • State whether utility rate increases or decreases were implemented in the past 12 months and if the rates are expected to change over the next 12 months. The Owner/agent (O/A) must provide the amounts of rate changes.
  • State how any conservation initiatives will impact consumption.

The O/A must provide an appropriate sample of utility allowance recommendation once a year. The owner submission should show detailed records of the utility charges (not including telephone) for each bedroom size under contract for the last 12 months. NOTE: The sample should reflect the various characteristics of the overall complex.

Number of Units for like BR Size, BR Type and Utility Category

 

Sample Size of Units for like BR Size, BR Type and Utility Category

1 to 10

 

ALL
10 to 50

 

10 to 15
50 to 100

 

20%
Over 100

 

15%

This is the preferred submission package. Owners are encouraged to work with their utility companies and tenants to get this information. If an owner can support that his efforts to obtain their records have been unsuccessful he may use actual utility bill from the tenants, used with the tenants permission.

If the Utility Analysis decreases, the O/A must notify the tenants 30 days before submitting the request to HUD/PBCA.

If your property’s contract anniversary is before 12/20/15, you may choose to implement the new methodology as stated below or you may use the above current methodology.  If your contract anniversary is on or after 12/20/25  your MUST follow the below guidance.

 

New UA guidance outlined in HUD Notice 2015-04 instructs owner/agents to establish a baseline for each bedroom size once every three years. For two years after the baseline submission, utility allowances for each bedroom size and each utility type at the property will be adjusted by a state-specific increase factor called a Utility Adjustment Factor (UAF). The factors will be published annually by HUD.

 

Baseline Submission Requirements

  1. Request utility data from either the utility company or the tenant household for at least the number of units determined by the sample size methodology detailed below.

    1. This must be done for each bedroom size at the property;

    2. If the property consists of multiple identical buildings (or buildings that are substantially similar, then the sampling may be performed at the property level, encompassing all buildings on a site. If buildings are not identical, the sampling must be done for each bedroom size);

    3. If the analysis is performed by a third party or the utility provider, the sample size data must be submitted;

    4. The data collected must be for the same time frame;

    5. The data used must not be more than eighteen (18) months from the contract anniversary date;

    6. Samples submitted must be from units receiving Section 8 assistance;

    7. A unit should be excluded from the sample if it:

      1. Is receiving an increased UA as a reasonable accommodation;

      2. Has been vacant for 2 or more months. Units included in the sample should have at least 10 months of occupancy; or

      3. Is receiving a flat utility rate as part of a low-income rate assistance utility program.

 

 

Number of Units

Minimum Sample

1 – 20

All

21 – 61

20

62 – 71

21

72 – 83

22

84 – 99

23

100 – 120

24

121 – 149

25

150 – 191

26

192 – 259

27

260 – 388

28

389 and above

29

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. Determine the average utility cost for each bedroom size without removing any units from the sample size beyond those excluded as indicated in (G.) above. Do not remove the highest and/or lowest utility cost household when determining the average.

    1. A sample format for utility allowance submissions, which includes built-in formulas to average utility costs for each unit size, can be found here.

    2. A sample tenant release form can be found here.

  2. Recommend the UA amount to the contract administrator for approval.

  3. Follow the requirements in 24 CFR Part 245.405(a) and 245.410 to notify tenants of a utility allowance decrease

  4. Phase-in UA decreases that would exceed 15% AND $10 from the most recent (approved) UA.

    1. The phase-in applies only to decreases resulting from the initial baseline analysis.   Refer to HUD Notice 2015-04 for additional information on phase-in requirements.

 
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