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November 23, 2022 Kathi Markan

November HUD-REAC Newsletter: Inoperable HVAC – Heating/Ventilation/Air Conditioning (Units/Common Areas)


HUD is going on the road with a NSPIRE Get Ready Series! 

Click here to register for a location near you (it’s free to attend)   

Have a healthy and happy Thanksgiving everyone!

In this November 2022 issue of our HUD-REAC Monthly Newsletter, I am going to discuss the deficiency: HVAC – Inoperable because it is a very high scoring item for both Common Areas and Units.  Also, it’s the season to ignite those pilot lights because inspectors are testing your heaters!


Interesting Notes

  1. There is no ‘Inoperable HVAC’ deficiency under Systems! Remember, a System is defined as “when the equipment services MORE THAN ONE specific area of a building.”  The fact that there is no ‘Inoperable HVAC’ deficiency under Building Systems is an oversight by HUD.  Just know that this deficiency can only be recorded under Common Areas and Units.
  2. There is nothing in writing from HUD instructing inspectors WHEN to test heat or the air conditioning. Last week on a conference call with HUD, I received the following clarification: “Inspectors should test heat in the winter, air conditioning in the summer, and for the other seasons dependent on the weather on the day of inspection.  In some areas of the country, you’ll test heat in the morning and air conditioning in the afternoon.  Inspectors should test one or the other – NOT BOTH as it could damage the equipment.”

Per the Federal Register

Deficiency: HVAC – Inoperable

  • The heating, cooling, or ventilation system does not function.
  • NOTE:
    1. If the HVAC system does not operate because of seasonal conditions, do not record this as a deficiency. (For example, trying to test heat in the summer, but the gas pilot light is turned off for the season.)

Level 1: N/A

Level 2: N/A

Level 3: The HVAC system does not function; it does not provide the heating or cooling it should.  The system does not respond when the controls are engaged.


Common issues observed during my 15-year HUD-REAC career:

  1. Resident does not want the heater pilot light on because of the utility costs or other reason(s).
  • During a REAC inspection (in the appropriate season) we have to test it. Most of us will allow you to light the pilot, but if it takes more than 5 minutes (or electric igniter is inoperable)…generally it gets recorded as a deficiency.  If the gas is disconnected, we are required to indicate that the gas is shut off and then record as deficient EVERYTHING the disconnected utility impacts.
  1. The air conditioning is not set low enough to turn on.
  • The A/C has to be set lower than the ambient temperature in the room or the compressor will not kick on.
  1. Maintenance cannot get the pilot light to stay lit.
  • Don’t wait for the REAC inspection to discover you have a blockage in the pilot tube or need a new thermocouple!
  1. The thermostat batteries are inoperable.
  • There is nothing in writing stating REAC inspectors can or should allow you to replace the batteries during the inspection. If that were the case, we would never write up smoke alarms!
  1. Resident owns the air conditioner, and it doesn’t work.
  • REAC inspectors inspect tenant-owned refrigerators, stoves AND air conditioners (Compilation Bulletin pg 75). If it doesn’t work, it will be recorded as ‘Inoperable,’ but you can appeal based on ownership issues.