On August 6, an industry coalition submitted a comment letter and a technical report to the Federal Housing Finance Agency (FHFA) on proposed changes to the multifamily radon testing protocols for loans purchased by the Enterprises (Fannie Mae and Freddie Mac). As previously reported, the comment letter was a follow up to a listening session held by FHFA to hear industry comments on the proposed change. NMHC staff and members participated in the listening session.
The letter provided additional support to the industry’s positions expressed in a March 31 letter to FHFA and stressed during the listening session. Specifically, the industry letter outlined the following two objectives and implementation steps that should be met:
- First, to ensure that any changes to protocols protect the health and safety of our residents and are technically practical to implement; and
- Second, to ensure that the science of radon testing supports any changes in protocols.
To meet the first objective, the implementation and impact of far-reaching changes to testing protocols must be formulated to ensure:
- Adequate testing capacity exists;
- Accurate and reproducible testing methodologies that take into consideration the unique features of occupied multifamily properties;
- Any such testing prioritizes the safety of residents; and
- Minimal impact to the flow of capital to the multifamily industry.
To meet the second objective, FHFA should adopt regulations that are:
- Based on sound science;
- Developed with input from stakeholders in the regulated industries; and
- Able to adapt the referenced standard or code to account for local conditions
The coalition also engaged Exponent, an engineering and scientific consulting firm, to perform a peer review of two scientific studies on radon testing for multifamily properties to ensure that FHFA was fully informed prior to relying on these studies to support their decision. Exponent’s analysis showed that the reviewed scientific study conclusions were deeply flawed. The full review can be accessed here.
NMHC and the coalition will continue to work with FHFA to ensure the final decision meets the industry objectives outlined in the letter. For more information on NMHC’s advocacy work in this space, please visit the NMHC Radon webpage.
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