HUD released a Request for Information (RFI) with the aim of moving to product-specific (general applicability) waivers for BABA, as opposed to project-specific waivers.

HUD is asking for information on domestic availability of manufactured products in specific categories:

  • Heating, ventilation, and air conditioning (HVAC) systems, including:
    • Variable refrigerant flow (VRF) systems; exhaust fans; and gas furnaces;
    • Heat pumps, including cold climate air-source, ducted split, ductless mini-split, geothermal/ground source, and water source systems; and
    • Packaged terminal air conditioner (PTAC) units/vertical terminal air conditioner (VTAC) units and portable and room air conditioners.
  • Plumbing fixtures, including toilets, lavatory sinks, kitchen sinks, faucets, bathtubs and shower systems and accessories;
  • Door hardware, including electronic access control systems and digital locksets;
  • Elevators;
  • Fire alarm systems and fire suppression systems;
  • Solar panels;
  • Wood trusses; and
  • Electrical components, including:
    • Interior and exterior LED lighting fixtures, surge protection devices, and security cameras;
    • Unit load centers, panelboards, and distribution panels; and
    • Ground fault circuit interrupter (GFCI) receptacles, cover plates, and wiring devices.

Why This Matters: This is likely the fastest moving opportunity for relief on BABA. The RFI has a 30-day comment period with comments due on July 20.

Call to Action: Please submit a comment before the deadline and ask your contractors/procurement teams to do so as well. Please share this request widely. NH&RA plans to submit a comment and is happy to help others draft comments.