Responding to Extreme Heat: HUD Offers Help to PHAs
Notice offers multiple strategies PHAs can take to protect residents.
In recent weeks, many parts of the country have been experiencing extreme temperatures. And above-average summer heat is expected to increase in frequency and duration for the remainder of July into early August. In anticipation of high temperatures this summer, HUD has taken recent action to ensure public housing residents can stay cool during the scorching summer months.
Public health experts recognize that extreme heat events can pose a hazard to public health. The Centers for Disease Control and Prevention (CDC) defines extreme heat as “summertime temperatures that are much hotter and/or [more] humid than average.” Broadly speaking, severe or extreme heat could be any period of high temperatures or high humidity that poses a health risk, regardless of whether the heat is above average for that time of year or a recurring annual risk.
Each year, over 1,200 people in the United States die due to extreme heat, and thousands more are hospitalized for illnesses including heat exhaustion and heat stroke. The CDC notes that while older adults, people with disabilities, and children are disproportionately affected, extreme heat can create immediate health risks for everyone. And families with lower incomes are at higher risk for heat-related illnesses, since they may have limited access to air conditioning, other cooling technologies, or other means of avoiding extreme heat.
Last month, HUD issued Notice PIH 2024-20 clarifying guidance on the use of HUD funding to help mitigate the impacts of extreme heat for nearly 1.6 million residents in public housing. The notice offers steps PHAs can take immediately to reduce the threat of extreme heat for residents by providing families with relief during severe or extreme heat periods, to help them afford to cool their homes.
With the release of the notice, Principal Deputy Assistant Secretary Richard Monocchio sent an email to PHA directors urging them to “think broadly and comprehensively about how you can reduce the risks of extreme heat for all of your residents.” Here’s a summary of the key points and how PHAs can leverage their resources to address the challenges of extreme heat events.
Capital Funds vs. Operating Subsidies
PHAs receive two primary types of funding from HUD, capital funds and operating subsidies. HUD’s notice provides a framework for how PHAs can use these funding mechanisms to address the challenges of extreme heat for their residents.
Capital Funds are designated for significant improvements and modernization projects, including structural and building system upgrades. These funds are typically used for long-term investments that enhance the overall quality and sustainability of public housing. And operating subsidies cover day-to-day operational costs such as maintenance, utilities, and administrative expenses. These funds are essential for the routine management and upkeep of public housing units.
Due to their specific nature, these funds are limited to certain expenses. Capital funds typically can’t be used for regular maintenance tasks that fall under the scope of operating subsidies, and vice versa. This distinction ensures that funds are used appropriately and according to federal regulations. The notice identifies eligible uses of capital funds and operating subsidies for cooling.
Eligible uses of capital funds. PHAs can use capital funds to install air conditioning and other cooling technologies in living units and common areas. This includes purchasing and installing equipment such as air conditioners, smart thermostats, ceiling fans, radiant cooling, attic ventilation, evaporative cooling systems, heat pumps, and passive cooling systems.
Passive cooling methods work to reduce the amount of heat entering the building and/or increase the amount of heat exiting the building by modifications to the building design or materials used to lower the indoor temperature with the use of mechanical or electrical devices. These methods include window coverings or tinting, nature-based solutions such as green roofs, reflective roofs and reflective paint that radiates heat away from the building, passive venting, and site and landscaping improvements that remove heat island effects by adding tree cover or artificial shade to the grounds surrounding buildings.
Temporary air conditioning devices, such as window or portable units, are an eligible capital fund expenditure. Capital funds may also be used for costs associated with storing such units when they are not in use. Capital funds can also cover building modifications necessary for installing cooling devices, such as electrical upgrades and structural reinforcements for window units.
However, capital funds can’t be used to cover the cost of cyclical installation, such as installing and uninstalling window units every summer. In such cases, the installation cost would be an eligible maintenance expense and, thus, an eligible use of operating subsidies.
Eligible capital fund modernization activities include complementary improvements, such as weatherization and energy-efficient upgrades. These enhancements improve the efficacy of cooling systems and reduce overall energy consumption.
Eligible uses of operating subsidies. Operating subsidies can be used to cover the costs associated with cooling common areas within public housing properties. This includes the operational expenses of air conditioning in spaces like lobbies, hallways, and community rooms.
However, operating subsidies cannot typically be used to subsidize in-unit air conditioning expenses unless individual relief policies are adopted. The PHA may not charge the resident when in-unit air conditioning is provided as a reasonable accommodation.
Individual Relief Policies for Extreme Heat
PHAs have discretion to define severe or extreme heat, and to adopt corresponding individual relief policies that indicate they will provide relief of varying lengths and degrees, as they deem appropriate. With this flexibility, PHAs can establish policies that provide individual relief to residents facing excessive utility charges due to extreme heat. This means that PHAs can adjust utility allowances or waive surcharges for air conditioning use during periods of severe heat, ensuring residents aren’t penalized for staying cool.
The regulations require PHAs to provide notice to all residents about the availability of and criteria for granting individual relief. This information must be provided when a PHA notifies all residents about utility allowances, scheduled surcharges, and revisions. Newly admitted households must also be given this information.
For 2024, PHAs may immediately grant individual relief requests based on severe or extreme heat before providing a new utility allowance notice or updating their Admissions and Continued Occupancy Policies (ACOP) or lease. Severe or extreme heat poses a risk even to healthy individuals, and residents may have few safe alternatives to using air conditioning or cooling-related utilities. Thus, severe or extreme heat may provide reasonable grounds for individual relief for all residents for use of cooling technologies.
The notice says PHAs may establish that all residents have reasonable grounds to request relief due to severe or extreme heat, regardless of age, disability status, or other special circumstances. Because the regulations require a household to request relief, a PHA can’t automatically grant individual relief for extreme heat to all residents.
Also, PHAs may immediately announce their intention to approve all requests for individual relief from severe or extreme heat. The announcements must ensure accessibility for all residents. And, rather than requiring every household to write an explanation of their request for individual relief due to extreme heat, the notice allows PHAs to provide all households with a streamlined option for requesting relief or a streamlined request form, which could simply involve checking a box on a form. This will allow PHAs to provide individual relief to families quickly to respond to the threat of extreme heat in 2024 while updating the requisite policy documents.
HUD's guidance encourages PHAs to develop criteria for what constitutes severe or extreme heat, allowing for flexibility in response to varying climatic conditions; implement streamlined processes for residents to request relief, making it easier for families to access necessary adjustments; and communicate these policies clearly to all residents, ensuring everyone knows their rights and the available support during heat waves.
Symptoms of Heat-Related Illnesses
According to the Federal Emergency Management Agency (FEMA), extreme heat often results in the highest annual number of deaths among all weather-related disasters. Older adults, the very young, and people with mental illness and chronic diseases are at highest risk. However, even young and healthy people can be affected if they participate in strenuous physical activities during hot weather. The following are the warning signs and symptoms of serious heat-related illnesses published by the U.S. Centers for Disease Control and Prevention:
Heat Stroke
What to look for:
o High body temperature (103°F or higher)
o Hot, red, dry, or damp skin
o Fast, strong pulse
o Headache
o Dizziness
o Nausea
o Confusion
o Losing consciousness (passing out)
What to do
o Call 911 right away—heat stroke is a medical emergency
o Move the person to a cooler place
o Help lower the person’s temperature with cool cloths or a cool bath
o Do not give the person anything to drink
Heat Exhaustion
What to look for:
o Heavy sweating
o Cold, pale, and clammy skin
o Fast, weak pulse
o Nausea or vomiting
o Muscle cramps
o Tiredness or weakness
o Dizziness
o Headache
o Fainting (passing out)
What to do:
o Move to a cool place
o Loosen your clothes
o Put cool, wet cloths on your body or take a cool bath
o Sip water
Get medical help right away if:
o Individual is throwing up
o Symptoms get worse
o Symptoms last longer than one hour
Heat Cramps
What to look for:
o Heavy sweating during intense exercise
o Muscle pain or spasms
What to do:
o Stop physical activity and move to a cool place
o Drink water or a sports drink
o Wait for cramps to go away before you do any more physical activity
Get medical help right away if:
o Cramps last longer than one hour
o Individual is on a low-sodium diet
o Individual has heart problems