HUD Updates Small Rural Frozen Rolling Base Guidance
On October 6, HUD issued PIH Notice 2022-32, updating the guidance from Notice 2020-30 for the Small Rural Frozen Rolling Base (SR-FRB) program. This notice applies to small, rural PHAs who operate public housing. The program allows PHAs to receive subsidy amounts based on their average energy usage for the three-year period before entering the program. The money saved from improving efficiency while receiving funding at their prior energy usage level can be used to supplement either Public Housing Operating or Capital Fund needs for up to 20 years. This new notice provides additional updates for calendar year 2023 beyond those described in Notice 2021-30. The four significant updates in Notice 2022-32 are discussed below.
First, PHAs will now join the SR-FRB program via the Operating Fund web portal, unlike in years prior to 2021. Participants will use it to opt in and out of the program as well as make any changes to utility data. HUD notes that they provide a user guide.
Each year, the operating subsidy processing notice and the operating subsidy grant calendar will include the official Notification date. This date is the deadline for joining, leaving, and updating specific data for the program. For 2023 funding, the Grant Submission Schedule currently shows SR-FRB submissions opening November 7, 2022 and closing November 18, 2022. Inclusion in the submission schedule is a change from calendar year 2022.
Like previous years, PHAs may still request one adjustment to their Heating Degree Days (HDD); however, to be eligible, this change must now modify usage by at least 10%. Prior HDD regulations still apply, and this change must be completed by the submission deadline listed above.
Finally, the notice describes a new appeals process. Any denials can be appealed for seven business days after receiving the denial and must be submitted to SRFRB@hud.gov.
Like prior notices, this updated version discusses eligibility, program requirements, entering and leaving the program, modifying program data, specific participation requirements, debt service, and example scenarios. HUD includes a list of eligible PHAs here.
Notice 2022-32 can be found here.