HRA / Property and design
Lesson 9: Design, construction standards and energy requirements
Reading
Translate approvals into a buildable scope
The approved design must satisfy applicable codes, HOME property standards, TDHCA requirements and the household's documented needs. Under 23.28, plans must be certified by a licensed architect or engineer. The Administrator coordinates that design with the budget, environmental conditions, site information and procurement documents. A standard plan is a starting point; site-specific foundation, floodplain, utility, access and accessibility needs still require review.
- Requirements matrix. Identify code, HOME, Texas, local and household requirements.
- Certified design. Coordinate site, accessibility, energy, scope and approved household choices.
- Controlled construction. Use the current plan revision and review substitutions before installation.
- Verified completion. Collect inspections, tests, occupancy and compliance documentation.
Identify the locally adopted code and the applicable state and federal requirements. Do not label a plan compliant only because a familiar code edition appears on its cover. Identify the edition, amendments, enforcement authority and required inspections. Retain the design review and permit information with the activity file. Exceptions require the authorized decision; a contractor's substitution is not an exception approval.
Use the replacement design rule
The September 2026 replacement 23.28 retains bedroom requirements, including at least 100 square feet and the stated minimum length or width of eight feet, plus door, exterior-access window and closet conditions. It no longer includes the older rule's minimum two bedrooms or 800/1,000/1,200 square-foot whole-home minimums. Do not copy those removed provisions into HRA specifications as current statewide HRA requirements. Other applicable standards and approved plans can still govern size.
Amenities include the items in the current rule, such as window coverings, cooking facilities, bathroom exhaust to the exterior, specified wiring and parking provisions. Some appliances are household options under the rule. Use a compliance matrix rather than relying on memory. For each requirement, identify the plan sheet or specification, responsible designer and inspection evidence. Record approved household choices so the bid and contract price the same scope.
Separate federal and Texas energy sources
HUD's current HOME FAQ states that the March 5, 2026 court decision vacated the 2024 federal energy determination and the May 1, 2026 notice rescinded it. HUD describes the restored federal single-family and low-rise baseline as the 2009 IECC. Therefore the older research statement that federal HOME universally still mandates the 2021 IECC is not current.
Texas separately adopted 10 TAC 20.16, effective September 24, 2026. Its text requires applicable federal, state, local and Department energy standards and the more restrictive requirement unless prohibited by law. For federally funded single-family dwellings with funds committed on or after October 1, 2025, excluding CDBG, subsection (d)(2) specifies the 2021 IECC or a federally approved alternative pathway. Do not infer that the federal rescission automatically removes this Texas requirement. Have TDHCA and the design professional confirm the applicable pathway and any later binding guidance for the actual commitment.
Specify evidence before procurement
Energy compliance is not just an insulation note. The chosen pathway needs coordinated envelope, equipment, ventilation, installation and verification details. The current state rule lists possible evidence such as inspection reports, builder certifications, third-party reports, HERS ratings and REScheck documentation. Which evidence is acceptable depends on the applicable pathway and Department requirements. Identify the required deliverable and responsible party in the scope before bids arrive.
Accessibility also needs a project-specific standards review. Do not assume every owner-occupied house follows every commercial accessibility dimension, or that the household's preferred feature is automatically funded. Determine the applicable state and federal requirements, document the requested accommodation or accessibility feature, and obtain necessary approval. Coordinate clearances, slopes, hardware and fixtures on the certified plans rather than leaving them to field improvisation.
Control changes and inspections
Use one controlled plan and specification set for pricing and construction. Record its revision and distribute authorized changes to everyone affected. A product marked "equivalent" still needs a documented comparison with the specification and applicable standards. Verify that a change does not invalidate energy calculations, accessibility, environmental mitigation, budget eligibility or the permit.
Progress inspections should occur while concealed work can still be observed. Keep reports, photographs, tests and corrections. At completion, reconcile the built work with the approved plans, obtain the required occupancy evidence and assemble the applicable code and energy certifications. A passed practice quiz is not an inspection credential, and a contractor's assurance is not a substitute for the required qualified inspection.
Work the case
A bidder proposes a cheaper design using the 2009 IECC because HUD rescinded its 2024 determination. The HRA commitment is after October 1, 2025.
Review the decision
Review the separate Texas 20.16(d)(2) requirement and any current TDHCA guidance. The federal baseline alone does not settle the state-funded administration conditions. Have the design professional document the applicable compliant pathway before accepting the substitution or changing the energy scope.
Apply it in the file
Authorities for this lesson
- 10 TAC 23.20–23.29: text adopted without changes
- 10 TAC 20.16: adopted energy standards
- HUD HOME FAQs: current energy clarification
- 24 CFR Part 92: HOME regulations
- 10 TAC Chapter 20: current official rule portal
Practice questions
1. Who must certify plans under 23.28?
- A licensed architect or engineer
- Any material salesperson
- Only the homeowner
- Only the course instructor
2. Are the old 800/1,000/1,200 square-foot HRA whole-home minimums retained in replacement 23.28?
- Yes, without change
- No
- Yes, only in the course glossary
- Yes, whenever a bidder prefers them
3. What bedroom minimum area remains stated in 23.28?
- 50 square feet
- 200 square feet
- 100 square feet
- No bedroom conditions at all
4. What happened to the 2024 federal energy determination in 2026?
- It became every state's only code
- It replaced all local permits
- It eliminated energy standards entirely
- It was vacated and rescinded
5. What federal single-family baseline does HUD's current FAQ describe?
- 2009 IECC
- 2024 IECC in every case
- No energy code
- Only contractor custom
6. What does Texas 20.16(d)(2) specify for covered commitments?
- Automatic exemption from energy review
- 2021 IECC or a federally approved alternative
- Only the 2009 federal baseline
- Any manufacturer's brochure
7. Does HUD's rescission alone decide the Texas requirement?
- Yes, automatically
- Yes, whenever the bidder says so
- No
- Yes, because the course is federal
8. What is a compliance matrix useful for?
- Replacing the architect's certification
- Waiving every inspection
- Selecting a contractor without competition
- Linking requirements to plans and evidence
9. When should energy verification deliverables be specified?
- Before procurement and construction
- Only after final payment
- After a monitoring finding
- Only if the homeowner asks
10. Does a product labeled equivalent automatically satisfy the specification?
- Yes, if it is cheaper
- No
- Yes, if its color matches
- Yes, if already installed
11. What must be reviewed when an energy-related component changes?
- Only the invoice font
- Only the installer name
- Effects on the approved compliance pathway
- Only the shipping date
12. What is the correct use of a standard house plan?
- Use it without site review
- Ignore its foundation assumptions
- Treat it as an environmental clearance
- Adapt and certify it for the actual site
13. What should happen before concealed work becomes inaccessible?
- The required inspections and documentation
- Only a final exterior photograph
- Only the homeowner's verbal approval
- No action until retainage release
14. Does completing this course qualify someone as a code inspector?
- Yes, automatically
- No
- Yes, for every jurisdiction
- Yes, after a 70 percent exam score
Glossary
- Certified plans
- Plans certified by the required licensed design professional.
- IECC
- International Energy Conservation Code.
- Compliance pathway
- An authorized method of demonstrating compliance.
- Substitution
- A proposed replacement for a specified product or method.
- HERS
- Home Energy Rating System.
- REScheck
- A tool used for certain energy-code compliance documentation.
Print the field checklist · Sources and unresolved decisions