1. Since it appears that HUD is requiring that housing authorities hire outside parties to do both the physical needs assessments and energy audits, I would suggest that HUD do one central solicitation and create a list of eligible contractors for both the PNAs and the energy audits rather than every HA doing their own search for qualified firms.
2. In the past, the local utility companies or the state Energy Trust has performed energy audits for free. I would hope that this is still an option as long as their energy audit meets the new HUD requirements.
3. Five years is too frequent for the energy audits. We can't afford to go through the whole process that often- there are too many other needs for our capital funds and our staff time. Energy audits should only be required every 10 years. Even if the energy conservation measures are done via energy contracts, it still requires an investment of staff time to conduct the energy audits, prioritize the needs and administer conservation contracts.
Comment Submitted by Terry Frazier, Housing Authority of the City of Salem
This is comment on Proposed Rule
FR–5507–P–01 Public Housing Energy Audits
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