Emergency Justification Letter

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, DC 20410-5000

OFFICE OF PUBLIC AND INDIAN HOUSING
REAL ESTATE ASSESSMENT CENTER

December 8, 2021

OFFICE OF PUBLIC AND INDIAN HOUSING
REAL ESTATE ASSESSMENT CENTER

Mr. Tyler Glotfelty
OMB Desk Officer
Office of Management and Budget
New Executive Office Building
Washington, DC 20503

Dear Mr. Glotfelty:
The Department is seeking an Emergency Paperwork Reduction Act (PRA) review and approval
in 14-days under 5 C.F.R. § 1320.13. to apply the Remote Video Inspections (RVI) protocol for the
Uniform Physical Condition Standards (UPCS), the National Standards for the Physical Inspection of
Real Estate (NSPIRE) inspections, and other habitability inspections to perform additional RVIs which
will allow the Department to collect information, assess feasibility, and make required changes to the RVI
protocols, process, and technology that will enable the implementation of RVIs for the performance of
physical inspections remotely. Nine RVIs have being successfully performed and this Emergency PRA
seeks to expand the RVIs to a total of 40 or more remote inspections necessary to test and evaluate RVI
protocols
In the COVID-19 era many Public Housing Agencies (PHAs) and Property Owner Agents (POA)
as well as families have been reluctant to conduct or allow the inspectors to conduct physical inspections
as additional COVID variants still pose threats. This means that residents may be living in undesirable or
unhealthy conditions. To address these potential concerns with minimum risk or exposure or disruption to
residents, the Department would like to employ RVI. The RVI protocol is a tool that efficiently allows
HUD to provide inspections to those properties that are unable to receive in-person inspections due to
COVID. The RVI protocol is a tool that allows HUD to provide oversight to those properties that are
unable to receive in-person inspections, including habitability inspections due to national emergencies
such as the COVID-19 pandemic.
A RVI is a flexible way to conduct physical property inspections and is a form of visual
inspection which uses a computer or smart device to allow an inspector or team of inspectors to assess the
health and safety of a property from a distance. It is anticipated RVIs will help protect residents and
owners by reducing the number of individuals entering the unit as it allows inspectors to remotely
conduct a HUD Real Estate Assessment Center (REAC) inspection. RVIs may help PHAs and POAs
prioritize maintenance and only send essential workers to the units when necessary. In addition, RVIs
may be used when items at a property are inaccessible or are in dangerous environments or circumstances
that prevent an on-site inspection. HUD may routinely conduct RVIs in the future. REAC has conducted
nine RVIs using new RVI protocols. The Notice of Paperwork Submission (copy enclosed) explains the
burden of the collection requirements. RVIs will allow REAC to increase production to see more units as

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the current pandemic continues. Please note that HUD has already received notification from some PHAs
and POAs they will not allow in-person inspections.
If HUD does not act immediately to implement RVI for high-risk properties, potential harms to residents
may include:




Prolonged exposure to potentially life-threatening hazards;
Increased prevalence or incidence of potentially unsafe or unsuitable living conditions;
and
Reduced capability to identify, generate, and resolve emergency maintenance
workorders.

HUD needs approval to collect information on three items:
(1) Information Checklist
This checklist will include information on public housing authorities (PHA) and property owners
and agents (POA) willingness and readiness to participate in an RVI using HUD’s questions.
(2) Survey of HUD assisted Residents
This survey will assess residents’ willingness and readiness to participate in an RVI, using
HUD’s questions.
(3) Survey of Proxy (Operators)
This survey will request input from proxies on the effectiveness and utility of RVIs, using HUD’s
questions.
Additionally, with ongoing concerns regarding COVID-19 transmission and potential future spikes
in local rates and newer variants, HUD is concerned that tenants may be uncomfortable with inspections of
their units. Accordingly, there will be instances where residents, inspectors and property personnel may not
feel safe with an in-person inspection. RVI is one solution to that risk. Moreover, existence of lifethreatening defects inside units may not be detected without an inspection, which could lead to harming
residents. Thus, the Department aims to minimize risk to the residents’ health and safety when other unit
inspection options may be unavailable by initiating remote video inspections as an alternative and additional
venue.
HUD Public Housing Agencies (PHAs), and Multifamily Housing Property Owners and Agents
(POAS) will expeditiously apply the findings observed during an RVI to prioritize resident health and
safety during the national security events such as the COVID-19 pandemic or when circumstances
prevent an on-site inspection. While HUD is confident this information is critical and time sensitive,
please note a similar Information Collection Request (ICR) will be submitted after this 180-day
emergency PRA period expires. Your immediate attention to this matter is greatly appreciated. Please
reach out to Kevin Laviano, RVI, Program Manager, kevin.laviano@hud.gov, 216-357-7750, with
questions. Thank you for your consideration and assistance.

Sincerely,
signed by: JUAN GARCIA ROLON
For JUAN GARCIA ROLONDigitally
DN: CN = JUAN GARCIA ROLON C = US O = U.S.
Government OU = Department of Housing and Urban
Development, Office of Public and Indian Housing
Date: 2021.12.08 11:01:26 -05'00'
___________________________________
Ashley L. Sheriff
Acting Deputy Assistant Secretary, REAC

Internal HUD Distribution:

Identification Lines:

Corresponden Originator
Concurrenc Concurrenc Concurrenc
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Name
Kevin Laviano
Ash Sheriff
Date
Official Record Copy U.S. Department of Housing and Urban Development
form HUD-713.1 (02/03)
Previous edition is obsolete.

Concurrence Concurrenc
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