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The gray area in FHA regarding room heating

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prasercat

Senior Member
Joined
Oct 24, 2007
Professional Status
Certified Residential Appraiser
State
Colorado
I have an two story home, first story has GFA throughout, furnace in basement (so far, pretty typical); however, no ducts were run up to the second floor. There is an "open to below" opening over the greatroom from the master bed and office on the second floor; there is also a standard type stairwell at the center of the second floor area that comes up to a hallway (pretty typical). The second floor has two additional bedrooms and a bathroom besides the two rooms mentioned.

So, the owners are relying upon warm air convecting up the stairwell to the second floor hallway and up the "open-to-below" area above the great-room to flow into the overlooking second floor master bed and office.

There is no way to block the convective source of heat to the master and office, so although each of these rooms does not have a separate heating unit, it is thermally connected to the great-room below - So I don't see an FHA automatic repair issue for these two rooms. It seems to be a minor issue that doesn't require repair, only disclosure in the report).

However, the two remaining bedrooms, if their doors are closed, would be blocked from convective heating from the first floor. They could receive that heat from the stairwell and from the office and master bed if their doors are left open; however, this seems to be not only very unusual in the market, and it is not only a functional obsolescence/inadequacy but it should be an automatic repair issue, since these bedrooms may be cut off from a heating source since closing a bedroom door during sleep hours is quite normal for humans.

So, the way I see it, those two bedrooms at the back need to either have electric baseboards installed with concealed wiring and a thermostat for each room or the ducting from the GFA must be extended to at least those two bedrooms. I'm not sure about the bathroom, it seems to be more of a grey area since leaving a door locked in a bathroom for extended periods is not normal. However, that's way too much psychological analysis and I will want to included the same requirement for the bathrooms as the two bedrooms mentioned.

Is there any flaws in this interpretation of FHA guidelines and in characterizations of Minor Property Conditions and those requiring automatic repair?

The guidance I found with FHA is a bit vague since each room must have a "heating source" but a heating device doesn't need to be in each room. Someone at FHA got lazy, because I could swear that there was supposed to be further explanation of that seemingly contradictory statement at least a paragraph long after that statement. I'm pasting the applicable FHA guidance here:

****************
In general, all habitable rooms must have a heat source. This does not mean that each room must contain a heating device but that each room must receive sufficient heat. In some situations where it is not feasible to extend the capacity of the main system, an electric and thermostatically controlled baseboard unit is acceptable provided it is permanently installed with concealed wiring.

Heating must be adequate for healthful and comfortable living conditions. This is defined as providing and maintaining a temperature of at least 50 degrees Fahrenheit in all living areas and areas containing plumbing systems. Further more, all permanent primary heating systems must be thermostatically controlled and properties with electric heat sources must have an acceptable electric service that meets the general requirements of the local municipal standards.

Wood stoves and solar systems: Homes with wood burning stoves or solar systems as the primary heat source must have permanently installed conventional heating systems that can maintain at least 50 degrees Fahrenheit in all living areas and those containing plumbing systems. These systems must be installed in accordance with the manufacturer's recommendations.

Wall heaters: Wall heaters are acceptable as long as they are installed to code and designed to heat the size and layout of the entire house.

Floor heaters: Due to the inherit dangers of a floor heater, it is highly recommended that floor heaters in need of repair be replaced with another permanent heat source. They are acceptable as long as they are properly functioning and meet current code.

Non-conventional heating systems: All non-conventional heating systems, such as space heaters and others, must comply with local jurisdictional guidelines. Often these are not acceptable as the primary source of heat.

***************
 
I have an two story home, first story has GFA throughout, furnace in basement (so far, pretty typical); however, no ducts were run up to the second floor. There is an "open to below" opening over the greatroom from the master bed and office on the second floor; there is also a standard type stairwell at the center of the second floor area that comes up to a hallway (pretty typical). The second floor has two additional bedrooms and a bathroom besides the two rooms mentioned.

So, the owners are relying upon warm air convecting up the stairwell to the second floor hallway and up the "open-to-below" area above the great-room to flow into the overlooking second floor master bed and office.

There is no way to block the convective source of heat to the master and office, so although each of these rooms does not have a separate heating unit, it is thermally connected to the great-room below - So I don't see an FHA automatic repair issue for these two rooms. It seems to be a minor issue that doesn't require repair, only disclosure in the report).

However, the two remaining bedrooms, if their doors are closed, would be blocked from convective heating from the first floor. They could receive that heat from the stairwell and from the office and master bed if their doors are left open; however, this seems to be not only very unusual in the market, and it is not only a functional obsolescence/inadequacy but it should be an automatic repair issue, since these bedrooms may be cut off from a heating source since closing a bedroom door during sleep hours is quite normal for humans.

So, the way I see it, those two bedrooms at the back need to either have electric baseboards installed with concealed wiring and a thermostat for each room or the ducting from the GFA must be extended to at least those two bedrooms. I'm not sure about the bathroom, it seems to be more of a grey area since leaving a door locked in a bathroom for extended periods is not normal. However, that's way too much psychological analysis and I will want to included the same requirement for the bathrooms as the two bedrooms mentioned.

Is there any flaws in this interpretation of FHA guidelines and in characterizations of Minor Property Conditions and those requiring automatic repair?

The guidance I found with FHA is a bit vague since each room must have a "heating source" but a heating device doesn't need to be in each room. Someone at FHA got lazy, because I could swear that there was supposed to be further explanation of that seemingly contradictory statement at least a paragraph long after that statement. I'm pasting the applicable FHA guidance here:

****************
In general, all habitable rooms must have a heat source. This does not mean that each room must contain a heating device but that each room must receive sufficient heat. In some situations where it is not feasible to extend the capacity of the main system, an electric and thermostatically controlled baseboard unit is acceptable provided it is permanently installed with concealed wiring.

Heating must be adequate for healthful and comfortable living conditions. This is defined as providing and maintaining a temperature of at least 50 degrees Fahrenheit in all living areas and areas containing plumbing systems. Further more, all permanent primary heating systems must be thermostatically controlled and properties with electric heat sources must have an acceptable electric service that meets the general requirements of the local municipal standards.

Wood stoves and solar systems: Homes with wood burning stoves or solar systems as the primary heat source must have permanently installed conventional heating systems that can maintain at least 50 degrees Fahrenheit in all living areas and those containing plumbing systems. These systems must be installed in accordance with the manufacturer's recommendations.

Wall heaters: Wall heaters are acceptable as long as they are installed to code and designed to heat the size and layout of the entire house.

Floor heaters: Due to the inherit dangers of a floor heater, it is highly recommended that floor heaters in need of repair be replaced with another permanent heat source. They are acceptable as long as they are properly functioning and meet current code.

Non-conventional heating systems: All non-conventional heating systems, such as space heaters and others, must comply with local jurisdictional guidelines. Often these are not acceptable as the primary source of heat.

***************

Praser,

you were only in the house a short time and I assume the temperature was above 50. What did the owner tell you about why the house was built this way and the comfort level in colder weather?
 
I think FHA is flawed in thinking 50 degrees would be comfortable for most people anyways. Unfortunately, there is no reasonable way to determine if a room is 50 degrees at night with the door closed. I suppose it may be possible to hold that temperature just by natural air rising from the first level? I think you could argue requiring getting it corrected or assuming it is capable of maintining the minimum temperature. It could probably be a a different issue to different appraisers depending on where they are located. It may be more of an issue for you in Colorado versus more southern areas.
 
think FHA is flawed in thinking 50 degrees would be comfortable for most people anyways. Unfortunately, there is no reasonable way to determine if a room is 50 degrees at night with the door closed
I don't think comfort is the FHA's issue. The issue is keeping the temperature above freezing if everyone is gone. And to that I would aver that the upper level could be a lot hotter than the main level due to heat rising...I've seen that in loft rooms. A loft with no doors would not normally have vents so this seems to be treated somewhat like a loft.

As for me it's just another reason I don't like to appraise a 2 sty and absolutely would not own one; and that list is already long (the difficulty to the arthritic, the danger to the young, danger to both to falling, fire escape issues, moving furniture, etc. etc.)
 
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I don't think comfort is the FHA's issue. The issue is keeping the temperature above freezing if everyone is gone. And to that I would aver that the upper level could be a lot hotter than the main level due to heat rising...I've seen that in loft rooms. A loft with no doors would not normally have vents so this seems to be treated somewhat like a loft.

As for me it's just another reason I don't like to appraise a 2 sty and absolutely would not own one; and that list is already long (the difficulty to the arthritic, the danger to the young, danger to both to falling, fire escape issues, moving furniture, etc. etc.)
My in-law's have an older home with no natural warm air vents at all on the second level (no heating source on the second level). It gets very cold at night and we have to use space heaters to keep warm. I think it really depends on how open the second story level is to benefit from the first level. I could see a loft situation being heated naturally if it is open to the first floor but not a full second story area.
 
Praser,

you were only in the house a short time and I assume the temperature was above 50. What did the owner tell you about why the house was built this way and the comfort level in colder weather?

The weather was cold during the inspection, but the house and second floor was warm. However, I could imagine them leaving the home for some time during cold weather with the bathroom door closed on the second floor - it would be cut-off from interior convection heat and there could be a frozen pipe issue with the bathroom, especially, with plumbing close to the exterior wall. I also wouldn't want to close a bedroom door if I was sleeping in one of those back bedrooms during cold weather - they should get down right cold, maybe even below 50.

The home originally had a about a 40% smaller foot-print - a one story with vaulted ceilings and a small loft. The foot print was later lengthened to increase the size of the family room, the small loft became a second floor with 3 beds, an office and a bath with the master bed and office overlooking the great-room. The great-room also has a wall of windows facing south, so it gets a big dose of passive solar heating.

The original house had hot water baseboard but he changed it out for a gas forced air furnace during the expansion. It would seem he had the opportunity to run heat up to the second floor during the install of the GFA - I'm guessing the owner wanted to save a buck by not running it upstairs, and, perhaps, he didn't see it as necessary.
 
I think FHA is flawed in thinking 50 degrees would be comfortable for most people anyways. Unfortunately, there is no reasonable way to determine if a room is 50 degrees at night with the door closed. I suppose it may be possible to hold that temperature just by natural air rising from the first level? I think you could argue requiring getting it corrected or assuming it is capable of maintining the minimum temperature. It could probably be a a different issue to different appraisers depending on where they are located. It may be more of an issue for you in Colorado versus more southern areas.


That is a good point! I guess I should have mentioned the home is close to 8,000 feet elevation in Colorado. It gets colder than "dog nose cold" up in those mountains!
 
I'm so sick of appraisers forum.

m2:
 
The weather was cold during the inspection, but the house and second floor was warm. However, I could imagine them leaving the home for some time during cold weather with the bathroom door closed on the second floor - it would be cut-off from interior convection heat and there could be a frozen pipe issue with the bathroom, especially, with plumbing close to the exterior wall. I also wouldn't want to close a bedroom door if I was sleeping in one of those back bedrooms during cold weather - they should get down right cold, maybe even below 50.

The home originally had a about a 40% smaller foot-print - a one story with vaulted ceilings and a small loft. The foot print was later lengthened to increase the size of the family room, the small loft became a second floor with 3 beds, an office and a bath with the master bed and office overlooking the great-room. The great-room also has a wall of windows facing south, so it gets a big dose of passive solar heating.

The original house had hot water baseboard but he changed it out for a gas forced air furnace during the expansion. It would seem he had the opportunity to run heat up to the second floor during the install of the GFA - I'm guessing the owner wanted to save a buck by not running it upstairs, and, perhaps, he didn't see it as necessary.

Based on your observation and the borrower's comments, it could be a potential market issue with possible functional adjustments, maybe cost to sure, and not so much an FHA problem.

However, I want to ask,

How long has the addition been completed and wouldn't you expect they would have realized and corrected a problem by now if it was necessary?

One thing about a heating source, it only needs to offset heat loss. So you may have a particularly efficient dwelling with very low BTU loss per hour and would not need any additional supply. The dwelling could have been designed this way and the heat contractor may have sized the downstairs heat specifically for this design. Many residential dwellings are way oversized because the installing contractor did not do a proper calculation. So I wouldn't necessarily base my opinion on the typical dwelling.

I would ask more questions of the owner before writing my comments.
 
I own an investment/second home in Kitty Hawk, NC and we set the thermostat at 52 degrees for the winter. I cannot imagine living in a house with the temperature that low. But, in many of the local homes, Cape COD's, still have floor furnaces with a vent cut out going to the second floor and that is acceptable to FHA. Just would not want to live there.

50 degrees is for property preservation as well as habitability I assume.
 
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