U.S. DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
CAPITAL FUND
GREEN PHYSICAL NEEDS ASSESSMENT (GPNA)
LARRY WOOD
APRIL 9, 2014
CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Current Rule

24 CFR 905 – Capital Fund. Includes the formula, eligible
expenses, obligations and expenditures, and Capital Fund
Financing Program (CFFP).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Rule Changes
HUD published three proposed amendments to the Capital
Fund regulation at 24 CFR 905 in 2010 and 2011:

Consolidated 24 CFR 905.
 Merge development, old CIAP/CGP, and current Capital
Fund requirements.

Requires all PHAs to conduct a Physical Needs Assessment
(PNA) as part of the Capital Fund requirements.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Rule Changes

Final Consolidated Capital Fund Rule at 24 CFR 905
published on October 24, 2013.


Final Rule for GPNA and Energy Audit pending.


Effective November 25, 2013.
Will move Energy Audit requirement from 24 CFR 965
to 24 CFR 905.
HUD to issue Implementation Notices once Final GPNA and
Energy Audit Rules are published.
 Implementation Notice to give rollout details—when it
will be effectective for which PHAs.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

All PHAs, regardless of size, must prepare and submit a GPNA
to HUD.

GPNA will include PHA-level summary information, as well as
detailed data on each public housing project/Asset
Management Project (AMP).

GPNA will reflect current and future needs over a 20-year
period based on life-cycle considerations.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

Will be conducted without regard to the amount of funding
available to perform work identified in the PNA.

The cost of the PNA is an eligible Capital Fund expense.

Will be completed in the form and manner prescribed by
HUD.
 PHAs
must use the new GPNA software (the “GPNA Tool”)
to submit PNA data to HUD.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA
 The first GPNA will be due on the basis of a schedule
published in an implementation notice that will be issued
concurrently with or after the final rule.

HUD anticipates that PHAs will have a minimum of 6
months advance notice of the due date for their specific
PNA data submittal.

May include data from PNA collected up to 3 years prior to
the submission due date for the first GPNA if the data meet
new standards (e.g., 20-year assessment, integration with
energy audit; see notice PIH 2010-46).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA Submission Dates



First GPNA submittal due date no sooner than 6 months from publication
of the PNA Rule.
No due dates anticipated before December 1, 2014.
All GPNAs submitted by September 2015 based on fiscal year.
Fiscal Year End (FYE)
Due Date
March 31
December 1
June 30
March 2
September 30
June 2
December 31
September 1
Note that submission dates presented are examples. Actual submission
dates will be per the Final Rule and subsequent Implementation Notice.
The cycle of submission may vary in the initial submission.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

Example of timeline for submission to HUD:

Assume Final Rule published: 4/30/2014.

Effective date of Final Rule: 5/31/2014.

First PNAs due after: 11/30/2014.

Due date: 12/1/2014 (FYE- 3/31).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

PHA must use the software provided by HUD, known as the
GPNA Tool. (GPNA produces the required format of submittal
to HUD.)

Must be performed in conjunction with energy audit and
integrated in the GPNA.

Energy audits done within 3 years of the due date of the
initial GPNA will not have to be redone if they meet the new
rule standards.

After the GPNA is completed by the PHA, data extract will be
emailed to HUD.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

After the first GPNA is completed, the PHA submits an annual
update to HUD until the next scheduled GPNA is due.
 Annual
updates will include only modernization work
completed during the past year.
 Annual
updates are not expected to be as labor-intensive
as initial GPNA submissions.

GPNA is not a commitment document.

GPNA should be used to prepare PHA 5-Year and Annual
Plans, including Capital Fund projections.

EPIC—Energy Performance Information Center.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

PHAs will import PIC building and unit data characteristics
into the GPNA.

PIC download data available from EPIC will be updated
daily.

As we transition to EPIC, PHAs may still request data from
PHAPNA@hud.gov.

Accuracy of PIC data is critical:
•
PHA GPNA upload to HUD will not be accepted unless
the building and unit counts match PIC EXACTLY.
•
The GPNA tool does permit minor editing to conform
inventory data.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

PHA can either purchase commercial cost indices of its
choosing and input cost data into GPNA, or use supportable
cost data, such as a custom cost database prepared for the
PHA.
 Commercial
cost indices (or PHA cost data) can be used by
the PHA (or its vendor) to build the “cost library” in the
GPNA.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

The cost library input effort may be very staff-intensive for
the first GPNA.
 Subsequent
GPNAs will not require the same level of preassessment work.
 Data
can be carried over and then updated as appropriate.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

The GPNA will require detailed data from individual
projects/AMPS, such as:
 Architectural “takeoffs”
for individual building components,
such as amount of square or linear feet of a component
(entered on inspection form).
 The
effective useful life (EUL) of each individual building
component (entered on cost library).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

The GPNA will require detailed data from individual
projects/AMPS, such as:
 Replacement cost
for each individual building component
(entered on cost library).
 The
remaining useful life (RUL) of each individual building
component (entered on inspection form).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
GPNA

GPNA may be performed by either PHA staff or contractors,
as the PHA determines appropriate, as long as they meet the
HUD qualifications. There is NO HUD-required certification.

PHA must make the results of the PNA available to the
residents and Resident Advisory Board at the time of
submission to HUD.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

The new energy audit requirements are more detailed than
before.
 Approximately a Level 2 ASHRAE (American Society of
Heating, Refrigerating and Air-Conditioning Engineers)
audit.

They will provide PHAs with more standardization and
practical information to assist PHAs in:
 Identifying cost-effective energy conservation measures.
 Reducing both capital and operating costs.

No HUD-required software or format.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

PHAs not required to implement specific energy conservation
measures (ECMs), unless required by statute.

PHA must integrate utility management with capital planning
to maximize energy conservation (2005 Energy Policy Act).
 Energy
audit must be done in conjunction with the GPNA.
 Energy
audit collects more data than required for the
GPNA.
 Energy
audit IS NOT required to be submitted to HUD, but
IS subject to HUD review.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

New energy audit not required if:
 Current
energy audit is less than 3 years old and meets
the standards of the new rule.
 Demolition/disposition
approved by HUD.
 Project
is less than 5 years old at the time the energy
audit is due

Timing (pending publication of the Final Rule).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

As before:
 All
PHAs, regardless of size, will do an energy audit for each
public housing project/AMP.
 Energy
audit will be performed not less than once every 5
years.

These requirements will continue.
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

Energy audit will review projected costs, savings, and
payback periods related to a variety of ECMs.

ECMs reduce utility and energy consumption.

Energy audit:
 May
include “green measures” that do not save energy.
 May
provide information on environmental or potential
health benefits of green measures (e.g., air quality).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

Core ECMs: Proven track record at reducing energy and
water consumption required review by auditor:
 Building
envelope (e.g., insulation).
 Heating,
cooling, and other mechanical systems.
 Water
conservation.
 Power,
lighting systems, and controls (e.g., compact
fluorescent lamp).
 Appliances
(e.g., ENERGY STAR).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit

Advanced ECMs: advanced, experimental, or difficultoptional additional review
 Fuel
conversion.
 Conservation
technologies (energy management systems).
 Energy-generating
technologies and renewable-energy
systems (e.g., solar, geothermal).
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CAPITAL FUND – GPNA NEW HUD REQUIREMENTS
Energy Audit
Energy audit must, at minimum, address Core ECMs and:

Categorization of ECMs into payback periods:
5
years or less,
5
to 10 years, and
 Greater
than 10 years.
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GPNA
Energy Audits
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ENERGY AUDIT STANDARDS
Establishes Min. Quals
 BPI, RESNET, CEM, CEA.
Establishes Min. Standards
 Goal is to equal State standards.
 Equal to ASHRAE Level 2.
Content and Submission requirements
 Utility analysis.
 Core ECMs—MUST be discussed in report.
Payback analysis required.
 Reporting must group by 12 year and 20 year.

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ENERGY AUDIT LEVELS
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STEP ONE: DATA COLLECTION AND BENCHMARKING
 Data Required:
 12 months minimum of utility bills—gas, water,
electricity, propane, steam.
 Mechanical plans.
 Appliance, DHW information.
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BENCHMARKING

Benchmarking:
 Hard to manage what you do not measure.
 Identifies energy opportunities.
 Baseline analysis of energy consumption/cost.
 Provides metric to measure and compare
energy usage.
•
•
•
•
Compare your facility to similar facilities.
Compare your facility to national averages.
kBtu/ft2.
$/ft2.
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STEP 2: ENERGY AUDIT
 Review of all energy-consuming components.
 Defines ECMs: Energy conservation measures
that are feasible.
 Ranks ECMs based on payback.
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STEP 3: ENERGY PLAN AND REPORTING
 Prioritizes opportunities and budget.
 Coordinated with Replacement Reserve.
 Explores project-based incentives and grants
available.
 Recommends viable candidates for renewable
energy, solar, wind, geothermal, combined heat
power (CHP).
 Outlines process for measuring and verifying
savings.
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CORE ECMS

Core ECMs
 Insulation
 Energy-efficient mechanical systems
 Low-flow water devices
 Lighting
 Energy Star appliances

Advance ECMs
 Renewable energy
 Solar
 Geothermal
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REGIONAL ECMS

Anywhere








Boilers
Conversion From Oil, or
Electric to NG
High-Performance
Windows
Building Envelope
Warm Climate

Site Lighting
Interior Lighting
Energy Star Appliance
Domestic HW
Cold Climate






High-Performance Air
Conditioning
Cool Roofing
Window Tinting
Awnings and Shading
Green Solutions





Wind
Cogeneration
Solar PV
Solar HW
Geothermal
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MARK-TO-MARKET (M2M) GREEN ITEMS








Water Conserving
Devices
Refrigerators
Dishwashers
Heating and Cooling
Products
Water Heaters
Windows
Sliding Glass Doors
Storm Door









Exterior Doors
Insulation
Interior Lighting
Exit Signs
Ceiling Fans
Ducted Exhaust
Exhaust Fans
Cabinets/Vanities
Thermostats
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COMMON ECMS









High-efficiency HVAC
Controls on HVAC
Lighting controls
Natural Light/Shading
Point-of-Use DHW
Solar HW
Appliances
Low-Flow Plumbing
Incentivize
Cleaning/Grounds
Crew as Energy
Monitors
System
Percent Annual
Energy Usage
HVAC
56%
Lighting
17%
Water Heating
9%
Appliances/Home
Equipment
8%
Water Savers
6%
Other
2%
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MULTIFAMILY GPNA ECM FEEDBACK
Implemented ECMs






CFL Light Bulbs (Interior)
Refrigerator
Low-Flow Toilets
Shower Heads
HVAC Split System
Faucet Aerators
Number
123
149
131
174
102
162
Reduction
46%
40%
40%
32%
32%
31%
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Advanced ECMs
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WIND TURBINES
Horizontal Axis Wind Turbine




Most popular and capable of
generating high power.
Available in various sizes for serving
residential-style application to serving
large grids.
Performance goes down in turbulent
winds.
High initial investment as compared to
vertical wind turbines.
Vertical Axis Wind Turbine




Generates less power as compared to
horizontal axis turbines.
Ideal for small loads (e.g., community
building, small offices ,and singlefamily homes.
Performs well in all types of winds,
hence more efficient.
More cost-effective as compared to
horizontal wind turbines.
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ADVANTAGES OF GEOTHERMAL SYSTEM











Energy efficient.
Classified as “renewable energy.”
Lowers peak demand.
Up to 44% reduction in green house gas emission (EPA).
System is compact and requires less space.
Package equipment.
Use 25% less refrigerant than conventional systems.
No auxiliary heat (in most cases).
No more refrigerant freezing.
Space over wells/trenches can be used for parking lots or
open play fields.
Low maintenance.
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ADVANCED TOOLS AND METHODS
Air Duct Testing—Test HVAC duct for leakage:




Conditioned air leaks outside or into the attic or crawlspace.
Pull unconditioned air directly into the HVAC system.
Moist air being drawn into return air results in reduced efficiency.
Draw air into the building from crawlspaces, garages, and attics
bringing with it dust, mold spores, insulation fibers, and other
contaminants.
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CAPITAL FUND – GPNA: ADDITIONAL INFORMATION
For more information and future updates, please visit
the GPNA Resource Web page at:
http://portal.hud.gov/hudportal/HUD?src=/program
_offices/public_indian_housing/programs/ph/
capfund/gpnatool.
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