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Apartments & Pets - To Allow or Not

Owners of multifamily housing often struggle with whether or not to permit pets at their properties. Until recently, in some areas, it was nearly impossible to find apartment communities that permit pets. While that has begun to change, there are still a lot of properties that do not permit pets. This article will outline the pros and cons of permitting pets at apartment complexes and if the decision is made to allow pets, we will provide some recommended policies to make the experience the best possible for both landlords and renters. A November 2020 survey by PetScreening and J. Turner Research showed that nearly 40% of renters have a pet. Another 21% planned to get a pet in 2021. Since March 2020 (the start of the pandemic), based on a study by the SPCA, about 20% of U.S. households have obtained a pet. Surveys in July 2021 found that 75% of rental properties allow pets - this is a big increase since 2005 when only 50% accepted pets. There is no doubt that landlords who do not accept pets are at a competitive disadvantage to those who do. The question remains - do the benefits of allowing pets in an apartment community outweigh the disadvantages? Perhaps the best comprehensive study of pets in rental housing is the "Pet-Inclusive Housing Initiatives Report," published by Michelson Found Animals and The Human Animal Bond Research Institute in 2021. Here are some of the major findings of the study: 72% of tenants said that pet-friendly housing was hard to find (which seems at odds with the 75% figure cited above) and 59% said it was too expensive.Residents in pet-friendly housing stay 21% longer.83% of pet-friendly landlords say that vacancies are filled more quickly. Clearly, there are concerns with allowing animals to live in communal housing and many of the objections are what non-pet-friendly landlords hang their hats on. Some of the most common concerns are - Damage: animals may certainly damage property, but these concerns are easily offset by (1) careful screening of the animals; and (2) requiring high upfront deposits {with most of the deposit being refundable}. These high initial deposits will separate the serious from the casual pet owner. Serious pet owners are much more likely to be responsible pet owners. It should be noted that virtually all affordable housing programs - including LIHTC, HUD, and Rural Development allow for pet fees or, in the case of HUD and RD, refundable deposits.Important Reminder: No fees or deposits may be charged for assistance animals for the disabled.Odor: This issue is dealt with by making tenants responsible for any disturbance by their animal - including odor - and dealing with problems quickly.Liability: All landlords that accept pets should require renter s insurance with pet riders. Other concerns are a disturbance of neighbors, possible allergies of other residents (making sure everyone knows this is a pet-friendly property can alleviate this concern), and insurance policy exclusions for certain dog breeds. Despite these negative issues, the advantage of allowing pets far outweighs the disadvantages. By far the most important benefit to allowing pets is increased income. In addition to the extra income from upfront or monthly fees, properties will have happier tenants (people with pets have been shown to have less stress), increased renewals (due to the scarcity of pet-friendly rentals, there is a built-in advantage - especially when owners do away with weight limits in the pet policies), and a larger tenant pool. It is also true that in general, responsible pet owners make for responsible tenants. If someone is mature enough to take care of an animal - and put up the large deposit for having the animal - there is a good chance they will treat your property with the same respect. Allowing pets will also go a long way in eliminating the problem of fake "support" animals since applicants will not have to find a way to get the animal into the property by showing that the animal is needed due to a disability. While some pet owners will still attempt this in pet-friendly properties in order to avoid the pet fees and deposits, it is much less a problem in pet-friendly apartments. While the pet fees will increase property revenue, the real cost savings comes from a lowered turnover rate and a decrease in vacancy losses. Owners who decide to allow pets should develop a comprehensive and strict pet policy. Again, serious pet owners will not object because the policy will not require more than they would normally do with regard to their animal(s). Following are some elements of a good pet policy that should be considered (always note that the pet policy does not apply to assistance animals): Allow only common household pets. The following language is typical:One four-legged, warm-blooded pet (two cats are often permitted);Two birds or small caged animals; andA ten-gallon fish tank (the number of fish is not limited).Request that residents not feed or house stray animals.Define a "pet:"A common household pet is defined as a domesticated animal, such as a dog, cat, bird, rodent (including a rabbit), fish or turtle that is traditionally kept in the home for pleasure rather than for commercial purposes. Common household pets do not include reptiles (except turtles). If this definition conflicts with any applicable state or local law or regulation defining the pets that may be owned or kept in dwelling accommodations, the state or local law or regulation will apply.Location of Pets in the BuildingPets are not allowed in public lobbies, dining areas, playgrounds, or other public gathering areas. When dogs or cats are moved through the building, they must be moved from the resident s apartment to the nearest outside exit, avoiding public areas. Pets may not be left tied or unattended on any part of the property.Sizes & BreedsThere is no size limit for dogs. However, the following breeds are prohibited: Presa Canaro, Chow Chow, Doberman Pinschers, Rottweilers, Cane Corsos, Malamutes, Wolf-Dog Hybrids, and Pit Bulls. (I also recommend in this section that you check with the locality for any prohibited animals (e.g., NYC prohibits ferrets), and check your insurance policy for any prohibitions).Licensure & TagsEvery dog and cat must wear the appropriate local animal license, a valid rabies tag, and a tag bearing the owner s name, address, and phone number. All licenses and tags must be current.RegistrationEvery dog and cat must be registered with the manager prior to admission and annually during the resident s re-certification and/or lease renewal. Registration of dogs and cats requires (1) proof of licensure; (2) proof of up-to-date inoculations; (3) verification that the pet has been spayed or neutered (or documentation from a veterinarian that such surgery would be detrimental to the animal s health); (4) evidence of a flea control program; and (5) verification of alternate caretakers.Prior to the admittance of a pet into a community, residents should be required to complete the following forms:Pet ApplicationKennel Release Residents may keep only the pet described in the Pet Application with no substitution or addition of other pets without the prior consent of management. Management will maintain a photograph of the pet in the household file. Fish are not covered under this rule.Pet DepositEach dog or cat owner must provide a pet deposit of $300.00 (or an amount required by state law, whichever is less), in addition to the standard rental security deposit. This deposit will be maintained in a separate account as provided for by state law and applicable agency regulations for the maintenance of security deposits. Upon termination of residence by the pet owner or removal of all dogs or cats from the owner s apartment, all or part of the pet deposit will be refunded minus reasonable expenses directly attributable to the presence of the pet. HUD-based communities - If the resident is unable to provide the complete deposit at the time the pet enters the community, then a payment schedule can be used. For HUD properties, the initial deposit cannot exceed $50 at the time the pet is brought into the community. Installments of $10 may be made until the deposit is reached. A resident must be allowed to pay the entire amount or in increments that are greater than $10 if he or she chooses to do so.Tax Credit communities - the pet deposit may exceed $300, and management may require the entire deposit at one time.SanitationDogs and cats are required to be "house-broken." Cats must be litterbox trained and dogs must be able to eliminate outside the building in designated pet exercise locations. Pet owners are responsible for the immediate clean-up of the feces of their dogs. Resident dog owners must bag and securely tie dog feces and deposit it in outside trash receptacles or other specified locations if applicable. Fines may apply if this requirement is not met. Cat owners must change litter frequently. It is not acceptable to drop pet waste down the trash chute. Litter must be placed in a bag, tied securely, and dropped in outside trash receptacles or other specified locations if applicable.NoisePets that make noise that disrupts other residents are unacceptable.Pet BehaviorNo pet that bites, attacks or demonstrates other aggressive behavior toward humans may be kept in the community. Pet owners shall assume liability for any injury sustained by residents, guests, or staff members that are caused by the owner s pet.Control of PetsDogs and cats must be effectively restrained and under the control of a responsible individual at all times outside the confines of the pet owner s apartment and while in the community. Alternate CaretakerResident must not leave a pet unattended for more than 24 consecutive hours. When applicable, the pet owner must provide the names of at least two people who are willing to assume immediate responsibility for the pet in case of an emergency, such as when the pet owner is absent or unable to adequately maintain the pet. Written verification of the willingness of these people to assume alternate caretaker responsibility is required. It is the responsibility of the pet owner to inform the manager of any change in the names, addresses, or telephone numbers of alternate caretakers.In cases of emergency, when management is unable to reach the alternate caretakers, the pet owner must agree to allow management to enter the unit and place the pet in an appropriate boarding facility for a maximum of 30 days. The pet owner will be responsible for the cost of the animal care facility. Within 30 days of such an emergency, the resident, his agent, family, or estate must make arrangements with the animal care facility as to the disposition of the pet and will be responsible for all obligations, financial and otherwise, in such disposition.Sick or Injured AnimalsNo sick or injured pet will be accepted for occupancy without consultation and written acknowledgment of a veterinarian as to the condition of the pet s ability to live in an apartment situation. Acceptance regardless of documentation and consultation is the prerogative of the manager. Admitted pets that suffer illnesses or injury, must be immediately taken for veterinarian care at the pet owner s expense.RefusalManagement can refuse to admit a pet for the following reasons:The pet is not a common household petPet does not comply with the pet policyPet owner fails to provide complete registration information or fails to annually update the pet registrationIt is reasonably determined based on the pet owner s habits and practices, that the pet owner will be unable to keep the pet in compliance with the pet rules and other lease obligations. NoticesIn the case of a violation of these rules, including management s refusal to register a pet, management will give the applicant/resident a written notice with an explanation in accordance with HUD requirements. For the sake of full disclosure, I am an animal lover and have multiple animals living under my roof. Having said that, I am also a businessman, and every apartment community I owned allowed pets. Not just because I love animals, but because I enjoyed the financial benefit of permitting animals at my properties. A well-thought-out and comprehensive set of pet policies will present a financial benefit to any property.

Remote Work - Here to Stay

Now that the pandemic is showing signs of waning and life is beginning to return to normal, we are all eager to see if the workplace will also look like it did pre-pandemic. The answer is becoming increasingly clear - it will not. We are now experiencing the largest change to American living and working practices since the end of World War II. The case for how well remote work functions has been largely settled. Even as offices stay vacant, the wheels of productivity hum right along. Employees stayed home and learned how to live and work in the same place - and throughout 2021, the profits rolled in. It is becoming increasingly clear - never again will most office workers spend five-day, 40-hour weeks in physical buildings, full of co-workers. As COVID fades, its legacy of teaching millions of people how to work from anywhere will last. We are now entering the world's Virtual Reality era. This new habit of convenience and comfort will be impossible to break for any company that relies on hard-to-find workers. An increasing number of big companies - Nationwide Insurance, Pinterest, Coinbase, Dropbox - have permanently switched to remote-first, closing most or all of their offices. Some CEOs remain in denial, believing things will return to the old normal. But reality tells us something else. A Pew study has found that 17% of office workers say they are working remotely because they moved away from their office location. The truth of this can be seen in the new boomtowns and tech hubs: Murfreesboro, TN, a suburb of Nashville, has grown 20% during the pandemic.While 75% of executives want to return to the office three or more days per week, only 37% of rank-and-file employees do, according to a new Slack Future Forum report.11 million jobs are open in America. If a company tries to force people to return to the physical office, that staff will just go look for jobs at companies offering remote work. Those companies offering the remote option have a huge advantage over those requiring a return to the office. According to a survey from the HR consultancy firm Robert Half, 50% of workers would rather quit than be told to return full-time to the office. There are substantial benefits to a remote workforce. These include more flexibility, less time commuting, and lower real estate and operating costs for companies. At the same time, there are downsides to remote work, the primary being the negative effect on mentorship and person-to-person interactions that shape a company s culture. These concerns are most prevalent in investment banks, consulting firms, and sales organizations since mentorship is often tied to advancement. For this reason, giants in this area such as JP Morgan Chase and Goldman Sachs are planning to return to the office in the coming weeks. However, many companies have put their return-to-work plans on hold based on resistance from staff. These include Google, Microsoft, and Apple. In January 2022 Google showed that it is all-in on a return to the office when it announced that it was spending $1 billion to buy the office space it uses in London - just down the road from where it is already building a massive new headquarters. The rise of the hybrid workweek is a matter of market realities. In a labor market where workers are leaving jobs at record rates - the "Great Resignation" - executives are being forced to listen to employee calls for flexibility and challenge their own ideas about what can be done outside the traditional workspace. It is becoming increasingly clear that the days of the 9-to-5, Monday-through-Friday workweek are a thing of the past. In the fourth quarter of 2021, 3 million professional jobs went permanently remote. At the end of 2021, 18% of all professional jobs were remote and that number may approach 25% by the end of 2022. While the jury is still out on productivity when working remotely, early studies show that it actually increases. A study by Stanford University of 16,000 workers over nine months found that working from home increased productivity by 13%. This increase in performance was due to more calls per minute attributed to a quieter more convenient working environment and working more minutes per shift because of fewer breaks and sick days. ConnectSolutions is a private-cloud solutions provider for Adobe Connect and Microsoft Lync. They released a study titled, The Remote Collaborative Worker Survey way back in 2015. In this survey, 77% of those who worked remotely at least a few times per month showed an increase in productivity, with 30% doing more work in less time and 24% doing more work in the same period of time. Ultimately, a "hybrid" work model may be the solution for many companies. A hybrid workforce consists of employees who work remotely and those who work in an office or central location. Workers decide where they are most productive - or choose a combination of both - based on their preferences. In a hybrid work situation, some employees work remotely on a full-time basis, while other employees work only in the office. Finally, some employees will work at home for two or three days per week and work in the office for the remaining days of the workweek. This helps offset the need for mentoring and human interaction. As I noted in an article that was posted in January 2021, work patterns will never be the same again, and long-term planning and preparation is a key. The hybrid work model, in particular, appears to hold great promise for the multifamily housing industry, and owners who adjust to this reality will be ahead of the curve when it comes to attracting and hiring high-quality staff.

Treasury Announces ERA1 Reallocation for Round 2

The Department of Treasury has announced the Round 2 reallocations for the Emergency Rental Assistance 1 (ERA1) funds. This was a reallocation of funds that were not used by the entities to whom the funds were initially allocated. A total of $564,271,928 was reallocated - $78,381,533 from the State Pool and $485,890,395 from the National Pool. Funds were reallocated to the following states: Alabama, Alaska, Arizona, California, District of Columbia, Florida, Idaho, Illinois, Louisiana, Maryland, Minnesota, Missouri, Nebraska, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Dakota, Texas, Utah, Virginia, Washington, and Wisconsin. The largest single reallocation went to the State of California ($136,442,353), and the smallest to the Bear River Band of the Rohnerville Rancheria in California ($1,482). Treasury also announced the Voluntary Round 2 Reallocations. These are voluntary reallocations between separate entities. A total of $455,123,265 was moved in voluntary reallocations. The largest transfer was $51,233,576 from the State of Ohio to Cuyahoga County. Two states (Delaware and Wyoming) gave a total of $167,500,000 back to the National Pool. Landlords wishing to assist residents struggling with rent in the states noted above should contact the appropriate ERAP agencies to review the possibility of obtaining additional assistance.

A Reminder to Owners of HUD Multifamily Properties Regarding Rising Utility Costs

Rapidly rising utility costs, especially for heat, are impacting residents of multifamily properties that are assisted under HUD programs. The U. S. Department of Energy is forecasting a three-year high in 2022 for average residential utility costs across the country. Projected increases for the period 2020 - 2022 are: Heating oil: From $2.44 per gallon in 2020 to $3.45 in 2022 (41.39% increase);Natural gas: From $10.76 per cubic foot in 2020 to $12.56 in 2022 (16.73% increase); andElectricity: From $13.16 per kilowatt hour in 2020 to $14.26 in 2022 (8.36% increase). Owners of Multifamily-assisted HUD properties for which HUD provides a utility allowance (UA) are reminded they are required to adjust their properties' utility allowances every year at the time of the annual and special adjustments of contract rents. To do this, owners/agents (O/As) must follow the guidance in Housing Notice H-2015-04, which provides instructions on how to complete a Multifamily Housing Utility Allowance. O/As should also review the associated Frequently Asked Questions for additional guidance. O/As are also required to submit documentation and a request for an increase in utility allowances to their Contract Administrator/HUD when changes in utility rates result in a cumulative increase in utility allowances of 10% or more from the most recently approved utility allowance. Other Steps O/As Should Take Request residents to report observed increases in utility bills and any outstanding unit repairs that could affect energy efficiency and household utility costs.Encourage residents with medical needs who have extraordinary utility bills to seek a reasonable accommodation for a higher UA.Use sample sizes larger than the minimum requirements in Notice H-2015-04 to derive utility allowances that more closely reflect the utility costs for all tenants of a particular property. Stay informed about utility rate changes approved by state Public Utilities Commissions (PUC) by signing up for email or text alerts or closely reviewing owner-paid utility bills for rate-change notifications.Perform routine maintenance on all building systems and components to improve energy conservation measures.Review Chapter 12 of HUD Handbook 4350.1 and the U.S. Department of Energy s Energy Saver Webpage for more tips on how to improve overall energy efficiency.

A. J. Johnson Partners with Mid-Atlantic AHMA for April 2022 Training on Affordable Housing

During the month of April 2022, A. J. Johnson will be partnering with the MidAtlantic Affordable Housing Management Association for four live webinars intended for real estate professionals, particularly those in the affordable multifamily housing field. The following live webinars will be presented: April 12: Compliance with Federal and State Fair Housing Requirements - the course "Compliance with Federal and State Fair Housing Requirements" will equip attendees with the knowledge and understanding needed to avoid fair housing violations.The course curriculum is centered around the regulations in the two major fair housing laws, The Fair Housing Act (Title VIII of the Civil Rights Act of 1968) and Section 504 of the Rehabilitation Act of 1973. The course also includes a discussion of the additional state and local protected characteristics. In addition, relevant portions of the Americans with Disabilities Act (ADA) are covered.The purpose of the Fair Housing Act is to eliminate housing discrimination, promote economic opportunity, and achieve diverse, inclusive communities. Professional fair housing training assists in this mission by ensuring that housing professionals understand both the rights of the public relative to fair housing and the duties and responsibilities of real estate professionals. April 14: Advanced LIHTC Compliance - This full-day training is intended for senior management staff, developers, corporate finance officers, and others involved in decision-making with regard to how LIHTC deals are structured. This training covers complex issues such as eligible and qualified basis, applicable fraction, credit calculation (including first-year calculation), placed in service issues, rehab projects, tax-exempt bonds, projects with HOME funds, Next Available Unit Rule, employee units, mixed-income properties, the Average Income Minimum Set-Aside, vacant unit rule, and dealing effectively with State Agencies. April 19: Violence Against Women Act - Guidance for Properties Subject to the Law The Violence Against Women (VAWA) Reauthorization Act of 2013 expanded VAWA protections to many different affordable housing programs - including the Low-Income Housing Tax Credit (LIHTC) Program. While HUD has provided detailed requirements on VAWA implementation at HUD properties, there has been no uniform guidance for LIHTC owners and managers. A proposal before Congress would legislate that LIHTC Extended Use Agreements contain VAWA requirements. The IRS has not provided guidance and while many state agencies are requiring VAWA plans, they are not providing information on what the plans should look like. This 2.5-hour training - when combined with the course materials- will review VAWA requirements and recommend best practices for developing VAWA plans at LIHTC and other non-HUD properties. The session will be presented by A. J. Johnson, a recognized expert in the affordable housing field and the author of "A Property Manager s Guide to the Violence Against Women Act." April 20: Reasonable Modification and Accommodation Requirements Under Section 504 and the Fair Housing Act. The training will focus on the specific duties and responsibilities of multifamily rental managers with regard to accommodating the needs of disabled applicants and residents. The difference between a "modification" and an "accommodation" will be covered, as well as who is responsible for paying for these modifications and accommodations. Multiple court cases will be used to illustrate the requirements of the law. These sessions are part of the year-long collaboration between A. J. Johnson and MidAtlantic AHMA that is designed to provide affordable housing professionals with the knowledge needed to effectively manage the complex requirements of the various agencies overseeing these programs. Persons interested in any (or all) of these training sessions may register by visiting either www.ajjcs.net or https://www.mid-atlanticahma.org.

HUD Confirms That Child Tax Credit and Earned Income Tax Credit Are Not Income

New resources and information about the Child Tax Credit (CTC) and Earned Income Tax Credit (EITC) on now available on the HUD Exchange (www.hudexchange.info). The 2021 American Rescue Plan (ARP) temporarily increased the CTC from $2,000 per child to $3,000 per child for children over the age of six and from $2,000 to $3,600 for children under the age of six. It also raised the age limit for CTC eligibility from 16 to 17. The 2021 ARP also expanded the EITC to include more workers without children as well as older workers (age 65+), temporarily raised the maximum credit for individuals without dependents from approximately $540 to $1,500, and increased the income cap to qualify for individuals without dependents from approximately $16,000 to $21,000. These income levels constitute a large percentage of residents in affordable housing properties. The CTC and EITC are not considered income for federal affordable housing programs. Receiving these tax credits will not impact anyone s eligibility for federal benefits - including federal housing benefits. The federal government along with hundreds of non-profit organizations, state and local governments, and members of Congress are engaged in an all-out push to make sure every eligible American receives the EITC and CTC. Managers of federal affordable housing projects, such as public housing, Section 8, Section 515, HOME, and LIHTC should not be counting the CTC or EITC as income for project eligibility purposes.

HUD Updates FAQ on Multifamily Housing Utility Allowance Requirements

The Department of Housing & Urban Development (HUD) has recently updated the Frequently Asked Questions Methodology for Completing a Multifamily Housing Utility Analysis. The original Notice on the UA requirement was Notice H 2015-04, which was published on June 22, 2015. HUD added three updates to the FAQ: In the years in which Owner/Agents (OAs) perform a factor-based analysis, the new UA should be calculated by considering the previous UA both before rounding and after rounding. The new UA will be whichever method provides the higher UA, which will be a benefit to the tenants.In the past few years, some O/As have been issuing utility reimbursements on debit cards. In some cases, tenants have never activated the cards even though they have been notified several times to do so. They may have several hundred dollars on the cards. The question has arisen as to whether the O/As should pull the money back off the cards and return it to HUD after giving tenants proper notice. HUD responds in the FAQ that "The balance must be left to accumulate on the debit card. For utility allowance reimbursements, once a check is made payable to the tenant, or funds are deposited to a tenant s debit card, ownership of the funds passes to the tenant. HUD does not receive the funds back, nor does the owner." This position does create some potential problems for O/As, especially in the case of uncashed checks. If you write a check and the money never leaves your account, you may develop the false belief that you can spend those funds, but the money still belongs to the payee. If the payee finally deposits the check after months of delay, you risk overdrawing the account and bouncing the check.          Businesses must track outstanding items to avoid breaking unclaimed property laws. If payments remain uncashed, the assets may eventually have to be turned over to the state as unclaimed assets. This usually occurs after a few years but depends on the state. In any case, careful tracking of these payments is required, and make sure you use an accounting system that deducts uncashed checks from your available funds. For RAD conversions that have both Project-Based Rental Assistance (PBRA) and Project-Based Voucher (PBV) units, which units should be selected for the RAD PBRA baseline UA? HUD requires that the sample selected should include only units covered under the RAD PBRA HAP Contract. These are two distinct programs, and the unit samples should not overlap. While these three issues represent to update to the FAQ, O/As should review the original notice and the complete FAQ, which may be found on HUDCLIPS.

HUD to Enforce Carbon Monoxide Protections in HUD Projects

On January 31, 2022, HUD issued Notice H-2022-01, clarifying federal requirements for carbon monoxide (CO) alarms and detectors. CO is a byproduct of fuel-fired combustion appliances such as furnaces and water heaters. If these appliances are not properly vented, the undetectable gas can be deadly. There have been at least 11 deaths in HUD-assisted housing from CO poisoning since 2003 and HUD has been under increasing pressure to require CO alarms and detectors in HUD-supported properties. In 2019, HUD issued a notice reminding owners of their legal obligation to install working CO detectors in those jurisdictions where such devices are required. However, in areas where CO detectors are not required, HUD only "encouraged" the installation of the devices - it was not a requirement. This new HUD notice implements the requirements included in the Consolidated Appropriations Act of 2021, which requires sites to meet certain requirements within two years of the law s enactment, which was December 27, 2020. As a result of the law, public housing agencies (PHAs), and site owners that received federal rental assistance must comply with the International Fire Code (IFC) 2018 standards on the installation of CO alarms or detectors by December 27, 2022. The new requirement applies to all Housing Choice Voucher units and all Public Housing, Project-Based Voucher, Project-Based Rental Assistance, Section 202, and Section 811 properties with fire-fueled or fire-burning appliance or an attached garage. HUD is requiring that all affected sites have CO detectors installed in all dwelling units. The detectors must meet or exceed the standards of the IFC. The standards are outlined in Chapter 9, Fire Protection and Life Safety Systems, and Chapter 11, Construction Requirements for Existing Buildings of the IFC. It should be noted that if local codes are more stringent than the IFC, the local code must be followed. The IFC defines CO alarms and detectors as follows: Carbon Monoxide Alarm: A single or multiple station alarm intended to detect CO gas and alert occupants by a distinct audible signal. It incorporates a sensor, control components, and an alarm notification appliance in a single unit.Carbon Monoxide Detector: A device with an integral sensor to detect CO gas and transmit an alarm signal to a connected alarm control unit. Hard-Wire Requirements IFC-approved CO alarms must receive their primary power from the building s permanent wiring without a disconnecting switch other than that required for overcurrent protection, and when the primary power service is interrupted, serviced by a battery. UL Rating Requirements CO alarms must meet Underwriters Laboratories UL 2034 standard for sensitivity. Combination CO/smoke alarms are an acceptable alternative to CO alarms but must meet UL 2034 and UL 217 standards for sensitivity. Installation Locations CO detection must be installed in dwelling units that contain a fuel-burning appliance or fuel-burning fireplace.CO detection must be included in any dwelling units with attached private garages - even if the units do not have fuel-burning appliances or fireplaces.When required to be installed, the detectors must be installed outside each sleeping area and in the immediate vicinity of the bedroom. If a fuel-burning appliance is installed in the bedroom, a CO detector must be installed in the bedroom. The types of fuel-burning appliances likely to be present include gas/fuel-fired ranges, stoves, fireplaces, clothes dryers, furnaces, air handlers, boilers, and water heaters. Detectors are not required in dwelling units that do not have openings between the fuel-burning appliance or underground garage and the dwelling unit. This means that if you have a central heating or hot water system that does not distribute heat via forced air, CO detection is not specifically required in the units. Paying for the Required Installation According to the Notice, PHAs operating public housing units may use either operating funds or capital funds for the purchase, installation, and maintenance of CO alarms or detectors. For the HCV and project-based voucher programs, the property owner or landlord is responsible for the cost of the CO alarms or detectors. Owners of properties receiving assistance through the project-based rental assistance, Section 202 or 811 programs may use the property s reserve account, residual receipts, general operating reserves, owner contributions, or secondary financing to fund the purchase, installation, and maintenance of CO alarms and detectors. Such purchases are eligible project expenses. The price for approved detectors (not including the cost of installation) generally runs from $15 to $60 per detector, depending on the make and model. Owners who are required by this notice to install the alarms or detectors must do so by December 27, 2022. HUD MOR and REAC/INSPIRE inspections after this date will note the absence of required detectors. Now is the time for affected properties to begin pricing and planning for the required installation.

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