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ENVIRONMENTAL ISSUES. Environmental Changes for 2010 NOFAS. New Requirements: Application processing stage Environmental Report New requirement 202s, 811s as Cat A Not curable deficiency To help HUD with prelim environmental review. Environmental Changes. Environmental Report

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environmental changes for 2010 nofas
Environmental Changes for 2010 NOFAS

New Requirements:

  • Application processing stage
    • Environmental Report
      • New requirement
      • 202s, 811s as Cat A
      • Not curable deficiency
      • To help HUD with prelim environmental review
environmental changes
Environmental Changes

Environmental Report

  • Separate from Phase I ESA
  • Per NOFA: should focus on
    • State environmental requirements
    • Relevant topics in SFNC and 4128
    • Per NOFA HP, FP wetlands, endangered species, noise, fire/explosive hazards, CZM, flood zones
environmental changes1
Environmental Changes

Phase I Environmental Site Assessment (ESA),

  • Phase I Environmental Site Assessment no longer curable deficiency
  • Vapor Encroachment analysis
  • Environmental Professional (EP) requirements laid out
  • Applicant to fill out “User Questionnaire “and provide to EP, to be included in Phase I ESA
  • Applicant to inform EP of reasons and requirements for the Phase I ESA
  • Findings, Opinions, and Conclusions requirements described in greater detail
  • More detailed discussion of Phase I ESA timing requirements
environmental changes contd
Environmental Changes, contd.

Phase II ESA when required

  • Must be submitted with application
  • Must address all Recognized Environmental Conditions (REC) and Vapor Encroachment Conditions (VEC) identified in Phase I ESA
  • To address on-site and off-site RECs and VECs
environmental changes contd1
Environmental changes, contd.


  • Clean-up plan and associated documentation outlined below must be submitted with application
  • Risk-based Corrective Action (RBCA) now allowed
  • Contract for any remediation not required at application processing
  • Estimate only of clean-up costs required with application
environmental changes2
Environmental Changes


  • Approval of remediation plan from the federal, State or local authorities not mandatoryat application Processing stage
  • Final clean-up plan prior to FIRM
  • Completion of work prior to final closing or initial occupancy, whichever comes first with feasibility statement to same in NOFA
  • Clarifies how clean-up an allowable cost
hazard identification and remediation
Hazard Identification and Remediation
  • Groundwater exception to complete clean-up of site
    • All contamination in GW at least 25 feet below surface
    • No groundwater use in area or active water supply wells on site
environmental changes asbestos requirements
Environmental ChangesAsbestos requirements

When Comprehensive Building Asbestos Survey required

    • ASTM E 2356-10 “Standard Practice for Comprehensive Building Asbestos Surveys.”
      • “baseline survey”
  • Not required if no pre-1978 or 4 or fewer units.
comprehensive building asbestos survey
Comprehensive Building Asbestos Survey

Not required if sponsor statement that no Pre-1978 structures or only 1-4 units residential on site

Asbestos screen not acceptable

Friable or affected by rehabilitation/demolition – abate

Other asbestos: O&M plan

floodplains and wetlands
Floodplains and Wetlands

Sponsors should try to select sites out of

  • 100-year floodplain
  • 500-year floodplain for critical actions: special care; i.e..., not independent living projects
  • Wetlands
environmental changes environmental review process

Application Processing Stage

  • Preliminary environmental Reviews
    • Except Technical reject for: floodway, coastal high hazard, 100-year flood plain
  • Not constitute HUD environmental approval of project site
environmental changes environmental review process1

Approved grantees

  • If site deemed environmentally unacceptable:
    • Pursuant to NOFA, fund reservation may be cancelled
    • So, in Environmental Report make sure to address issues
environmental changes3
Environmental Changes

Environmental Rating

  • HUD will deduct 2 points if HUD’s preliminary environmental review determines that there are obvious adverse environmental conditions and appropriate mitigation of such does not appear to be achievable within 6 months of the fund reservation date.
  • 202/811 Sponsors and HUD are partners
  • HUD wants Sponsors to
    • Find a site with no concerns/easily resolvable concerns, especially
      • Toxic Hazards
      • Historic Preservation
      • Floodplain or Wetland
hazard identification and remediation1
Hazard Identification and Remediation
  • Phase I Environmental Site Ass
  • essment (ESA) Must use ASTM 1527-05, as amended
hazard i r
Hazard I&R

Phase I ESA

  • Tech reject
    • If use earlier version of 1527
    • Failure to use Appendix X4
    • Failure to use Sections 12.5, 12.6, 12.8
    • Failure to follow new/revised requirements discussed earlier
choosing an environmentally safe site
Choosing an Environmentally “Safe” Site
  • Accessed through WEB page of 202/811 SuperNOFA
  • Excellent discussion
  • Discusses Phase I ESAs, especially for 202/811 programs
  • Special discussions on
    • Toxic & hazardous substances
    • USTs
    • Asbestos
    • LBP
choosing an environmentally safe site supplemental guidance
Choosing an Environmentally “Safe” SiteSupplemental Guidance

Accessed through Funds Available Web page for the 202/811 Programs

Discusses manmade hazards as well as items that HUD may look at during environmental review

hud form 4128
HUD Form 4128

Used to record environmental review

HUD appraiser performs site visit and records results on the “Sample Field Notes Checklist”



historic preservation
Historic Preservation
  • Sample letter to SHPO/THPO
    • Accessed through HUD WEB page of202/811 SuperNOFA
    • Developed by HUD HPO
    • Includes all information necessary for SHPO/ THPO to provide comment
    • Allows for dual response to sponsor & HUD
    • Some Field Offices might have other sample letters
historic preservation1
Historic Preservation
  • If HUD needs to contact SHPO
    • will be done only for approved applications
  • HUD will complete HP prior to FIRM
    • At application stage if HUD believes it will take longer than 6 months – minus 2 points
historic preservation2
Historic Preservation

If HUD possesses knowledge that a site might have Religious or Cultural Significance to Indian tribe or Native Hawaiian Organization

  • HUD will request their comments
hud hp archeological survey policy
HUD HP Archeological Survey Policy
  • HUD rarely requires (even if SHPO requests such)
    • HUD HP fact sheet 6 REVISED
      • http://www.hud.gov/offices/cpd/environment/review/hpfactsheet06.pdf
    • Proposed or adjacent site already determined eligible/listed
    • Preliminary site work (e.g. previous surveys or predictive models) has established eligibility
floodplains and wetlands1
Floodplains and Wetlands
  • Sponsors should try to select sites out of
    • 100-year floodplain
    • 500-year floodplain for critical actions: special care; i.e..., not independent living projects
    • Wetlands
    • Reminder: 6 months – minus 2 points
floodplains and wetlands2
Floodplains and Wetlands
  • For new construction projects deemed acceptable based on no practicable alternatives, condition on approval documents
    • CLOMA/CLOMR prior to firm
    • FLOMA/FLOMR prior to final closing
    • Flood insurance during construction