Be Prepared for Disaster Season: Review HUD Guidance and Site’s Emergency Plan

When Elsa reached sustained winds of 85 mph recently, it became the strongest July storm in the Caribbean Sea since Hurricane Emily in 2005. It was a hurricane that formed far earlier than forecasters anticipated, even during what is expected to be an above average Atlantic hurricane season.

In light of last year’s record-breaking season with 30 named storms and this year’s early Atlantic hurricane activity, HUD has issued reminders to sites of their responsibilities for both property and residents in the event of a disaster. While many emergencies can’t be anticipated, some areas of the country are more prone to emergencies than others. The Gulf states are prone to hurricane damage, the Midwest states are prone to flooding, and some states have a history of earthquakes or tornadoes. For this disaster season, HUD has been reminding owners of their responsibilities to report damage and keep any disaster plans current.

Multifamily Emergency/Disaster Guidance

HUD has a website with information and guidance to follow in the event of a storm event or disaster. The website, Multifamily Housing Guidance for Disaster Recovery, can be accessed here. You should review this material before an event occurs.

According to HUD, sites should have a disaster plan that includes reporting to HUD any physical damage to a property interior or exterior. The damage could have resulted from fire, flood, wind, severe cold, or another natural disaster or weather event. According to HUD, it’s most convenient for all parties if owners proactively report to HUD by completing and forwarding damage assessments.

Preliminary assessment. For a FEMA Declared Emergency or Disaster, you can use a preliminary disaster assessment form for Multifamily Housing Properties (Appendix A-3 of Chapter 38 of Handbook 4350.1.) Upon completion of the preliminary disaster assessment, the Hub construction analyst or designee will score each property with a “disaster code,” which will be used when conducting the ongoing re-assessments. The numerical “code” designation can change over time.

The preliminary disaster assessment includes questions to determine the unmet basic needs of residents or property owners and their employees such as food, water, health risks, disability issues, life-threatening issues, etc. If unmet needs are identified, the Hub director will coordinate with HUD and/or the appropriate FEMA office, and the appropriate federal, state, and/or local resources. Life-threatening issues should be reported to FEMA emergency personnel and other local agencies immediately.

Final assessment. When possible, the Hub construction analyst or designee should be dispatched to conduct an on-site final assessment of the affected properties. The final disaster assessment is performed to confirm the extent of the damage reported and to determine which properties should be inspected or re-inspected by the company contracted to do a more thorough damage assessment if a contractor is in place. 

During the final assessment, photographs and/or video should be taken and information on the damage should be obtained from the owner/agent and documented. The list will also include inspections for all potentially affected properties in the development pipeline. Other entities (mortgagee, insurers, FEMA) may also be inspecting the properties. If available, you should obtain copies of these inspections to assist with the analysis and recovery efforts for the property.

Final recovery. The ultimate goal is to restore operations to normal after an emergency and to re-house displaced residents as soon as possible. A successful recovery strategy begins with a final assessment of damage, followed by technical assistance to owners/agents, and ultimately resumption of normal operations at the site. The emergency is over when all repairs have been made, all displaced residents have returned to the apartments they were displaced from or found other permanent housing, and the property is physically and financially sound.

Keep Disaster Plan Current

HUD Multifamily’s West Region, which navigated a damaging wildfire season during the midst of the pandemic in 2020, sent a reminder earlier this year to housing providers to update their disaster management plans. Properties are reminded to follow the emergency plan if they are impacted by a disaster, in an evacuation, or in an evacuation warning zone. Properties should also reach out to their assigned account executive as soon as it’s safe to do so. The office’s message asked owners to consider the following:

1. What is your evacuation plan?
   • Where are your residents going for staging or assistance? (Owners should reach out to local/regional/state EMA on staging or shelter locations.)
   • What is the plan once you arrive?
2. Transportation to location:
   • Is the owner/agent providing transportation services?
   • Will this include pets and/or service animals?
3. Do any residents require electrical services for oxygen and/or medicine?
4. Contact and communications with residents:
   • Owners should have contact and emergency contact information for the residents.
   • Owners should provide residents with contact information for the property manager/owner.

HUD Multifamily’s West Region stressed the need to keep track of residents’ whereabouts. The office asked that owners make sure they have residents’ phone numbers and know where they are living (such as in a shelter or with a friend).

Residents’ Communication Requirements in the Event of a Disaster

• Tell residents that if they are displaced in an emergency, they are responsible for advising the owner and/or manager of their temporary housing location and their intentions during and after the emergency/disaster.
• If displaced residents have a new, temporary address or telephone number, they should provide it to the owner or manager. 
• Tell residents that due to potentially dangerous conditions, they may not have ready access to their possessions. 
• Owners are responsible for securing the property to the best of their ability immediately after the emergency and protecting the personal property of the residents. However, residents will need to contact their rental insurance agent for any coverage on their personal property.
• Owners must dispose of any personal property in accordance with local law. Also, owners may take action to terminate a lease and dispose of personal property in accordance with local law when displaced residents indicate their intention not to return or fail to respond to the owner’s notice.
• If the rental office has to be vacated, the owner should publish where he or she can be contacted and should regularly inform residents as to progress making repairs and when they might re-occupy their residence [HUD Handbook 4350.1, Chapter 38, par. 6-10].