For the two years after a baseline utility analysis is completed, the Utility Allowance Factor (UAF) can be used. According to the notice, the O/A “should compare the adjusted utility analysis to their paid utilities over the previous twelve months. If the results indicate a “significant disparity” between the two, the O/A should complete a baseline analysis.” Please clarify what constitutes a “significant disparity,” and whether the paid utilities analysis documentation needs to be provided to the CA/HUD in order to use the UAF. Please also clarify the “paid utilities” – does this represent the common area utilities paid by the property?

A new baseline analysis is not mandated. MFH wants owners to look closely at the results of a factor-based analysis and expect that they will make an appropriate decision about further analysis if those results appear very different from what their own paid utilities suggest (i.e., their common area utilities). This analysis does not need to be provided to the CA/HUD. The comparison is intended to have owners take a “second look” at the factor-based results. If it is suspected that special circumstances cause year- to-year fluctuations that materially differ than the utility adjustment factor, owners and CAs may consider completion of a new baseline.