>> HI, THANK YOU FOR JOINING ME TODAY ON THE TRAINING FOR ENVIRONMENTAL REVIEWS FOR CONTINUUM
OF CARE OR COC PROJECTS.
I'M IN THE OFFICE OF ENVIRONMENTAL IN HUD HEADQUARTERS.
I'M HERE TO TALK TO COC RECIPIENTS AND RESPONSIBLE ENTITIES EITHER NEW TO THE PROCEDURES OR STRUGGLING
TO APPLY THE PROCEDURES TO COC PROJECTS.
I AM GOING TO ASSUME, HOWEVER, THAT YOU ARE COMFORTABLE WITH COC REQUIREMENTS AND THE
PROGRAM GENERALLY.
WE ARE JUST GOING TO TALK ABOUT ENVIRONMENTS REVIEWS TODAY.
IF YOU HAVE BEEN WORKING WITH COC FOR A FEW YEARS YOU MIGHT RECALL THERE IS BEEN BUMPS
ALONG THE WAY.
WE THINK WE HAVE AN IMPROVED PROCESS NOW THAT SHOULD MAKE CONDUCTING COC REVIEWS AS FAST
AND PAINLESS AS POSSIBLE.
WE WOULD LIKE TO WALK YOU THROUGH THE PROCESS AND OUR RECOMMENDATIONS FOR HOW TO CONDUCT
COC ENVIRONMENTAL REVIEWS.
WE ARE GOING TO START WITH AN OVERVIEW OF THE HUD ENVIRONMENTAL REVIEW REQUIREMENTS.
THIS IS A REALLY BIG TOPIC.
USUALLY WE COVER ENVIRONMENTAL REVIEW 101 IN TWO OR THREE-DAY TRAININGS.
IF YOU ARE INTERESTED IN ATTENDING ONE OF THOSE CHECK THE WEBSITE OR TALK TO YOUR LOCAL
ENVIRONMENTAL OFFICER FOR INFORMATION ON UPCOMING TRAININGS IN YOUR AREA.
WE DON'T HAVE ENOUGH TIME TODAY TO PROVIDE A FULL UNDERSTANDING BUT WE WANT TO GIVE YOU
A GENERAL IDEA OF NOT JUST WHAT YOU NEED TO DO TO MEET THE MINIMUM REQUIREMENTS BUT ALSO
GET AN UNDERSTANDING OF WHY WE ARE ASKING YOU TO MEET THE STANDARDS AND REQUIREMENTS.
ONCE WE HAVE GONE OVER THE BASICS WE WILL APPLY THE CONCEPTS TO COC ELIGIBLE ACTIVITIES
SPECIFICALLY AND WALK THROUGH HOW TO COMPLETE AN ENVIRONMENTAL REVIEW FOR COC PROJECT.
WE WILL BE CONDENSING A LOT OF INFORMATION AND A LOT OF TECHNICAL GUIDANCE INTO A SHORT
WEBINAR.
YOU WILL NOT GET ALL OF THE DETAILS YOU NEED TODAY BUT WE HAVE A LOT OF RESOURCES ONLINE
THAT YOU COULD REFER BACK TO LATER AND WE WILL TELL YOU HOW TO ACCESS ALL OF THOSE AT
THE END.
LET'S START WITH A GENERAL OVERVIEW SO IN THE NEXT SECTION WE CAN APPLY THE PRINCIPLES
TO COC REVIEWS.
WHAT IS AN ENVIRONMENTAL REVIEW?
THE PROCESS OF TAKING A CLOSE LOOK AT A PROPOSED PROJECT AND EVALUATING ITS ENVIRONMENTAL IMPACTS.
THIS SHOULD LOOK BOTH AT THE POTENTIAL IMPACTS OF THE PROJECT ON THE SURROUNDING ENVIRONMENT.
FOR EXAMPLE WILL IT DESTROY A WET LAND, REDUCE THE VALUE OF A HISTORICAL PROPERTY OR INCREASE
AIR POLLUTION?
IT IS JUST AS IMPORTANT TO CONSIDER THE EFFECTS THE ENVIRONMENT WILL HAVE ON THE PROPOSED
PROJECT.
FOR EXAMPLE WHEN CONSIDERING WHETHER A SITE IS APPROPRIATE FOR HOUSING WE WHERE WHETHER
IT IS AT RISK FOR FLOODING, CONTAMINATED AND WHETHER NOISE LEVELS MIGHT BE DETRIMENTAL
TO ENVIRONMENTAL USE.
THE PURPOSE IS TO DOCUMENT THE COMPLIANCE AND SHARE THE BACKGROUND ANALYSIS WITH THE
PUBLIC.
THE ENVIRONMENTAL REVIEW RECORD IS A PUBLIC DOCUMENT THAT THE AFFECTED COMMUNITY HAS THE
RIGHT TO REVIEW AND COMMENT ON.
AS I SAID, THE ENVIRONMENTAL REVIEW RECORD IS A PUBLIC RECORD SHOWING THAT IT WAS COMPLETED.
IT DEFINES THE SCOPE OF THE PROJECT, ANALYZES ALL REQUIRED ENVIRONMENTAL LAWS AND AUTHORITIES
AND DEMONSTRATES COMPLIANCE WITH THEM.
IT ALSO DOCUMENTS ANY REQUIRED MITIGATION MEASURES OR CONDITIONS AND IS SIGNED BY ALL
RESPONSIBLE PARTIES.
IT INCLUDES BOTH WRITTEN ANALYSIS AND WILL USUALLY REQUIRE MAPS AND DOCUMENTATION TO
BACK UP THE CONCLUSIONS.
THE NATIONAL ENVIRONMENTAL POLICY ACT OR NEPA REQUIRES ALL FEDERAL ACTIONS INCLUDING ANY
PROJECT THAT RECEIVES HUD FINANCIAL ASSISTANCE TO COMPLETE AN ENVIRONMENTAL REVIEW.
IN ADDITION TO NETA THERE ARE OTHER LAWS LIKE THE ENDANGERED SPECIES ACT AND SOME YOU MAY
NOT HAVE HEARD OF LIKE THE COASTAL BARRIER SERVICES ACT.
HUD HAS ITS OWN REGULATIONS THAT DESCRIBE HOW HUD PROJECTS CAN COMPLY WITH NEPA AND
ALL ENVIRONMENTAL LAWS AND AUTHORITIES.
ONCE AN APPLICATION HAS BEEN SUBMITTED ENVIRONMENT REVIEWS MUST BE PERFORMED BEFORE FUNDS ARE
SPENT OR COMMITTED.
THIS MEANS A RECIPIENT WITH SUB AWARD FUNDS BUT NEITHER A RECIPIENT, SUB RECIPIENT OR
ANY CONTRACTORS OR PARTNERS MACON DUCT ANY CHOICE LIMITING ACTIONS.
A CHOICE LIMITING ACTION IS ANYTHING THAT WOULD LOCK IN IT PARTICULAR COURSE OF ACTION
SUCH AS SIGNING A LEASE.
THIS IS IMPORTANT BECAUSE THE ENVIRONMENTAL REVIEW MUST HAVE VALUE.
IF YOU HAVE SIGNED LEASE BEFORE YOU CONDUCT THE ENVIRONMENTAL REVIEW, THEN IT IS TOO LATE
TO MAKE A CHANGE IF YOU FIND THAT THE SITE HAS ELEVATED LEAD LEVELS OR IS LOCATED IN
A FLOODWAY.
AT THAT POINT THE ENVIRONMENTAL REVIEW HAS LESS VALUE.
IT IS REALLY IMPORTANT TO START THE ENVIRONMENTAL REVIEW AS SOON AS POSSIBLE TO PREVENT POTENTIAL
DELAYS.
IF YOU HAVE A GOOD SITE, THE ENVIRONMENTAL REVIEW SHOULD BE PRETTY SIMPLE AND EASE.
BUT YOU NEVER KNOW WHAT YOU MIGHT FIND.
IF IT TURNS OUT THE SITE HAS SIGNIFICANT PROBLEMS THAT COULD SLOW DOWN THE PROCESS QUITE A BIT.
YOU WANT THE PLANS TO BE FLEXIBLE SO YOU CAN REJECT A POTENTIAL PROBLEM RATHER THAN GETTING
INVOLVED IN IT.
PART 50 SUSTAINS THE PROCEDURES THAT HUD FOLLOWS TO COMPLY WITH NEPA WHEN HUD PERFORMS ENVIRONMENTAL
REVIEWS ITSELF.
51 AND 55 ARE REGULATIONS THAT CREATE HUD SPECIFIC STAN CARDS TARGETING ENVIRONMENTAL
ISSUES OF PARTICULAR CONCERN TO HUD.
PART 51, NOISE EX-PLOWTIVE AND FLAMMABLE HAZARDS AND AIRPORT RUNWAY CLEAR ZONES.
55 CONTAINS FLOODPLAIN MANAGEMENT AND WET LAND PROTECTION.
PART 58 IS PROCEDURES.
THAT OUTLINES THE PROCEDURES FOR UNITS OF LOCAL, STATE OR TRIAL GOVERNMENT KNOWN AS
RESPONSIBLE ENTITIES OR RES WHO PERFORM REVIEWS.
THIS IS A PROCESS UNIQUE TO HUD.
INSTEAD OF HUD PERFORMING ITS OWN ENVIRONMENTAL REVIEWS AS A FEDERAL AGENCY A RESPONSIBLE
ENTITY MAY TAKE THE ENTITY AND PERFORM THE REVIEW AT THE LOCAL STATE OR TRIAL LEVEL UNDER
PART 58.
ONLY CERTAIN ORGANIZATIONS NAMELY UNITS OF GENERAL LOCAL STATE OR TRIBAL GOVERNMENT MAY
ACT AS RESPONSIBLE ENTITIES OR RES.
UNDER PART 58 HUD TAKES A HANDS OFF APPROACH TO THE ENVIRONMENTAL REVIEW PROCESS AND TAKES
FULL RESPONSIBILITY FOR CONDUCTING THE ENVIRONMENTAL REVIEW AND ENSURING THAT ALL PROJECTS PROCESSED
UNDER PART 58 COMPLY WITH ALL APPLICABLE ENVIRONMENTAL LAWS AND AUTHORITIES.
THE RESPONSIBLE ENTITY CERTIFYING THE OFFICER USUALLY THE MAYOR OR CHIEF ELECTED OFFICIAL
IS THE PARTY WHO IS LEGALLY RESPONSIBLE FOR THE REVIEW.
HUD IS INVOLVED IN THE PROCESS AT TWO PHASES.
FIRST, FOR CERTAIN TYPES OF PROJECTS THE RESPONSIBLE ENTITY IS REQUIRED TO SUBMIT FORM 741515 OR
REQUEST FOR FUNDS AND CERTIFICATION TO HUD TO CERTIFY THAT THE ENVIRONMENTAL REVIEW WAS
COMPLETE.
HUD REVIEWS ONLY THAT FORM, NOT THE ENTIRE ENVIRONMENTAL REVIEW RECORD.
IF HUD APPROVES THE FORM 701515 IT WAS RESPOND BY GIVING A FORM 701516 A FORM TO USE GRANT
FUNDS.
THE RESPONSIBLE ENTITY'S ENVIRONMENTAL REVIEW IS NOT COMPLETE UNTIL IT RECEIVES THE 701516
AND WE WILL TALK ABOUT THAT IN A FEW MINUTES.
WE DON'T LOOK AT THE SUBSTANCE OF THE ENVIRONMENTAL REVIEW UNTIL THE SCHEDULED AFTER THE FACT
MONITORING.
FOR MANY BLOCK GRANTS AND HOME THE SAME PORTION IS THE RECIPIENT OF HUD FUNDS AND RESPONSIBLE
ENTITY.
IN OTHER PROGRAMS INCLUDING COC MOST RECIPIENTS ARE NOT GOVERNMENT ENTITIES WHICH MEANS THEY
CANNOT ACT AS RESPONSIBLE ENTITIES THEMSELVES.
THEREFORE, COC NEED TO FIND AND WORK WITH A RESPONSIBLE ENTITY.
IN SHOULD BE A UNITE OF GOVERNMENT WITH LAND USE NORTH OVER THE PROJECT LOCATION AND COULD
BE A CITY, COUNTY, STATE OR TRIBAL.
JUST BECAUSE A RECIPIENT ISN'T AN RE DOESN'T MEAN IT IS OFF THE HOOK FOR ENVIRONMENTAL
REVIEWS.
RECIPIENTS NEED TO GATHER UP INFORMATION ON THE PROJECT AND ENVIRONMENTAL IMPACTS AND
GIVE THAT INFORMATION TO THE RESPONSIBLE ENTITY TO ASSIST THEM WITH THE ENVIRONMENTAL REVIEW.
TO RETAP.
WE HAVE GO DIFFERENT PROCEDURES FOR CONDUCTING ENVIRONMENTAL REVIEWS.
PART 58 A RESPONSIBLE ENTITY COMPLETES THE ENVIRONMENTAL REVIEW.
UNDER PART 50 HUD CONDUCTS THE REVIEW EITHER WAY IT IS THE RESPONSIBILITY OF ANY NONRE
TO HELP PREPARE THE REVIEW BY SYMBOLING THE INITIAL DOCUMENTATION AND SUBMITTING TO THE
PENCE RESPONSIBLE FOR COMPLETING THE REVIEW.
THERE ARE DIFFERENT WAYS OF DEFINING THE STEPS IN THE ENVIRONMENTAL REVIEW PROCESS.
FIRST YOU DEFINE THE PROJECT.
USE THE PROJECT DESCRIPTION TO DETERMINE THE LEVEL OF REVIEW.
ONCE YOU HAVE THE LEVEL OF REVIEW, YOU KNOW WHAT STEPS YOU NEED TO COMPLETE, WHICH LAWS
AND AUTHORITIES THE PROJECT WILL HAVE TO COMPLY WITH.
AT THAT POINT YOU CAN COMPLY WITH ALL THOSE LAWS AND AUTHORITIES.
COMPLETE ALL STEPS TO FINALIZE THE REVIEW POTENTIALLY PROVIDING PUB LIVE NOTICE AND
GETTING HUD'S APPROVAL.
LET'S START WITH STEP ONE AND TALK ABOUT THE PROJECT DESCRIPTIONS.
THE ENVIRONMENTAL REVIEW IS DIFFERENT FOR SUPPORTIVE SERVICES OR CONSTRUCTION OR REHABILITATION.
WE CAN'T GET STARTED UNTIL WE HAVE A CLEAR COMPLETE DESCRIPTION OF EVERY ACTIVITY PART
OF THE PROPOSED PROJECT.
YOU NEED TO DESCRIBE THE PROPOSAL IN AS MUCH DETAIL AS POSSIBLE SO THE RESPONSIBLE ENTITY
CAN UNDERSTAND THE ENVIRONMENTAL IMPACTS.
THIS ISN'T AS SIMPLE AS JUST NAMING THE ELIGIBLE ACTIVITY.
SAYING TENANT BASED RENTAL ASSISTANCE IS HELPFUL BUT DOESN'T TELL THE WHOLE STORY.
IT IS COMMON TO DO REPAIRS TO A UNIT BETWEENANTS.
WILL THAT BE A PROGRAM.
ROUTINE MAINTENANCE LIKE REPLACING A BROKEN OR FILE OR SOMETHING THAT RISES TO A FULL
HE KITCHEN REMODELING.
WHERE WILL THEY BE WENTED?
IN A CITY?
ALL OVER THE COUNTY?
OR JUST IN ONE OR TWO NEIGHBORHOODS.
ALL OF THIS IS INFORMATION IMPORTANT TO THE ENVIRONMENTAL REVIEW.
ONCE YOU HAVE THE PROJECT DESCRIPTION YOU CAN USE THAT TO DETERMINE THE LEVEL OF REVIEW.
THIS DECISION HAS TO BE MADE BY THE RESPONSIBLE ENTITY OR HUD UNDER PART 50 ALTHOUGH THE RECIPIENT
CAN MAKE AN INITIAL RECOMMENDATION.
THE LOWEST REVIEWS AT HUD ARE THE ENVIRONMENTAL IMPACT STATEMENT, ENVIRONMENTAL ASSESSMENT
CATEGORICALLY EXCLUDED SUBJECT TO 58.5 AND NOT SUBJECT TO AND EXEMPT.
VERY QUICKLY FOR PEOPLE WHO LIKE FLOWCHARTS.
THIS IS AN OVERVIEW OF THE REQUIREMENTS FOR EACH LEVEL OF REVIEW.
AS THE LEVEL OF REVIEW GOES UP, THE REQUIREMENTS INCREASE.
SOMETIMES IT GETS TRICKY AND MACON VERT FROM ONE LEVEL TO ANOTHER.
THE LOWEST LEVEL IS EXEMPT AND CATEGORICALLY NOT SUBJECT TO 58.5.
THESE ARE PRESENTED IN THE REGULATIONS AS TWO DISTINCT LEVELS OF REVIEW BUT THERE IT
NO REAL DIFFERENCE BETWEEN THEM SO WE LUMP THEM TOGETHER.
OUR REGULATIONS LIST MANY, MANY EXEMPT AND CENST ACTIVITIES AT 24 CFR 58.34 AND 58.35-B
BUT A LOT OF KEY ONES ARE LISTED HERE.
THESE ARE PRIMARILY ACTIVITIES WITHOUT ENVIRONMENTAL IMPACTS.
SUPPORTIVE SERVICES, PLANNING COSTS, ADMINISTRATIVE.
TENANT BASED ASSISTANCE WITHOUT ANY REPAIRS OR REHAB.
IF YOU THINK YOUR PROJECT MIGHT BE EXEMPT, CHECK THE REGULATIONS.
AND MAKE SURE THAT IS FITS INTO ONE OF THESE EXCLUSIONS.
IF ALL OF THE ACTIVITIES INVOLVED IN A PROPOSED PROJECT ARE EXEMPT OR CENSD, THEN THE ENTIRE
PROJECT FALLS INTO THIS CATEGORY.
IF ONE OR MORE IS NOT LISTED AS EXEMPT OR CENST THEN THE ENTIRE PROJECT REQUIRES A HIGHER
LEVEL OF REVIEW.
FOR EX-EMAND CENST PROJECTS ENVIRONMENTAL REVIEW ARE MINIMAL.
MAKE SURE THAT THE PROJECT COMPLIES WITH THE LAWS AND AUTHORITIES LISTED IN A 8.6, THE
NATIONAL FLOOD INSURANCE PROGRAM, COASTAL BARRIER RESOURCES ACT AND AIRPORT RUNWAY CLEAR
ZONES.
ONCE IT COMPLIES WITH THE THREE REQUIREMENTS THEN THE PROCESS MAY FREED.
THERE IS NO NEED TOISH LU PUBLIC NOTICE OR GET HUD APPROVAL.
MOVING ON THE NEXT LEVEL OF REVIEW IS CATEGORICALLY EXCLUDED SUBJECT TO 58.5.
ALSO KNOWN AS CTSD OR CAT X. THE REGULATIONS AT 35-A PROVIDE A COMPLETE
LIST BUT THE BASIC TYPES OF PROJECTS ARE MINOR REHAB, PROJECT-BASED RENTAL ASSISTANCE, LEASING
AND NEW CONSTRUCTION OF LESS THAN FIVE HOUSING UNITS.
IF YOU ARE WONDERING IF A PROPOSED PROJECT IS MINE NOR REHAB, WHICH WOULD BE CATEGORICALLY
EXCLUDED, BE SURE TO CHECK 58.
A 3.
FOR MULTIFAMILY BUILDINGS WE LAB IS CATEGORICALLY EXCLUDED IF THE UNIT DENSITY IS NOT CHANGED
BY MORE THAN 20% IF THE BUILDING IS NOT CONVERTING FROM ONE LAND USE TO ANOTHER.
FOR EXAMPLE COMMERCIAL OR INDUSTRIAL TO RESIDENTIAL AND THE ESTIMATED COST OF REHAB IS LESS THAN
75% OF THE TOTAL ESTIMATED LAST LOST OF REPLACEMENT AFTER REHAB.
IN DID IATION CEST PROJECTS BECAUSE COMPLY WITH THE MANY MORE LAWS AND AUTHORITIES.
PLUS, WHEN COMPLETING A REVIEW THE RE MUST MAKE IS DETERMINATION WHETHER IT WILL REQUIRE
FORMAL STEPS OR MITIGATION.
IF NOT, IT CONVERTS TO EXEMPT.
TREATED AS IF IT WERE EXEMPT AND NO PUBLIC NOTICE OR HUD APPROVALS ARE REQUIRED.
HOWEVER, IF ANY COMPLIANCE STEPS ARE TRIGGERED THE RESPONSIBLE ENTITY MUST GIVE NOTICE OF
THE PROJECT AND SUBMIT THE REQUEST NOR RELEASE OF FUNDS AND CERTIFICATION BEFORE PROCEEDING
WITH THE PROJECT.
SO THESE ARE THOSE ADDITIONAL ENVIRONMENTAL LAWS AND AUTHORITIES LISTED IN 58.5 THAT CEST
PROJECTS HAVE TOPPLE PLY WITH.
A COLLECTION OF FEDERAL LAWS THAT APPLY TO ALL AGENCIES AND HUD SPECIFIC REGULATIONS.
UNDER NEPA -- IF A CATEGORY IS NOT EXCLUDED OR EXEMPT, A FULL NEPA ANALYSIS IS REQUIRED.
MOST NEW CONSTRUCTION, DEMOLITION AND CONVERSION REQUIRE A FULL EA.
AND THIS IS THE REVIEW FOR MAJOR REHAB.
ANY REHAB THAT DOES NOT CONFORM TO THE REQUIREMENTS LISTED IN 58.35 A 3.
FOR MULTIFAMILY REHAB AN EA WOULD BE REQUIRED IF.
IF THE BUILDING IS CONVERTING FROM NONRESIDENTIAL USE OR THE ESTIMATED COST OF REHAB IS MORE
THAN 75% OF THE TOTAL COST OF REPLACEMENT AFTER REHAB.
EEAS MUST COMPLY WITH THE LAWS LISTED IN 58.5 AND 58.6 AND CONDUCT A FULL NEPA ANALYSIS.
AS WITH CAT X REVIEWS EAS CONCLUDE WITH A FIND.
THE RESPONSIBLE ENTITY MUST DETERMINE WHETHER THE PROJECT WILL HAVE A SIGNIFICANT IMPACT
ON THE HUMAN ENVIRONMENT.
IF NOT, THAT IS A FINDING OF NO SIGNIFICANT IMFACT OR A FONE IS AND THE REVIEW CAN CONCLUDE
THERE AFTER GIVING PUBLIC NOTICE AND SUBMITTING FORM 701515 TO HUD AND RECEIVING 701516 IN
RETURN.
IF THE RESPONSIBLE ENTITY MAKES A FINDING THE PROJECT MAY HAVE A SIGNIFICANT IMPACT
ON THE HUMAN ENVIRONMENT THEN THE RESPONSIBLE ENTITY HAS TO COMPLETE AN ENVIRONMENTAL IMPACT
STATEMENT WHICH IS THE NEXT LEVEL OF REVIEW.
THERE ARE TWO CIRCUMSTANCES AN EIS IS REQUIRED.
MAY HAVE ASSAILING IMPACT ON THE HUMAN ENVIRONMENT AND SECOND IF THE PROJECT WILL AFFECT MORE
THAN 2,500 UNITS OR BEDS YOU JUMP STRAIGHT TO AN EIS WITHOUT DOING ENVIRONMENTAL ASSESSMENT
FIRST.
BOTH SITUATIONS ARE RELATIVELY UNUSUAL AT HUD.
WHEN IT COMES UP MAKE SURE TO REACH OUT TO THE LOCAL FIELD ENVIRONMENTAL OFFICER FOR
ASSISTANCE.
HERE IS A VISUAL REPRESENTATION OF THE LEVELS OF REVIEW.
PAY SPECIAL ATTENTION TO THE CEST LEVEL WHICH WILL NORMALLY REQUIRE NOTICE AND A REQUEST
FOR RELEASE OF FUNDS AND CERTIFICATION BUT MACON VERT TO EXEMPT MEANING THAT THE STEPS
ARE NOT REQUIRED.
I DIDN'T MENTION THIS BEFORE, BUT IT IS ALSO POSSIBLE TO MAKE A FINDING OF EXTRAORDINARY
CIRCUMSTANCES.
WHICH WOULD BE THE CASE IF A PROJECT IS UNIQUE OR PRECEDENT-SETTING CONTROVERSIAL OR HAS
THE POTENTIAL TO HAVE A SIGNIFICANT IMPACT ON THE ENVIRONMENT.
IN IT CASE, A CEST REVIEW COULD JUMP UP TO AN ENVIRONMENTAL ASSESSMENT.
NUMBER BEFORE WE MOVE ON TO THE NEXT SLIDE.
TAKE A MOMENT TO NOTE THE LEE LEVELS THAT REQUIRE PUBLIC NOTICE AND REQUEST FOR RELEASE
OF FUNDS AND CERTIFICATION.
THE CEST REVIEWS THAT DO NOT CONVERT TO EXEMPT AND ALL ENVIRONMENTAL ASSESSMENTS AND IMPACT
STATEMENTS.
I REFERRED TO GIVING PUBLIC NOTICE AND SUBMITTING FORM 701515.
THESE ARE THE REQUIREMENTS.
EITHER WHICH PUBLISHING IN A NEWSPAPER OF GENERAL CIRCULATION IN THE AFFECTED COMMUNITY
OR BY POSTING FOR AN EXTRA THREE DAYS IN A PUBLIC BUILDING SUCH AS A POST OFFICE IN THE
PROJECT AREA.
AFTER GIVING THE APPROPRIATE NOTICE AND RESPONDING TO COMMENTS FROM THE PUBLIC THE RESPONSIBLE
ENTITY AND THE RECIPIENT SHOULD PREPARE AND SIGN A FORM 701515 THE REQUEST FOR RELEASE
OF FUNDS AND CERTIFICATION AND SUBMIT TO HUD.
AT THAT POINT THERE IS AN OBJECTION PERIOD AND THE PUBLIC MAY SUBJECT OBJECTIONS TO HUD
AND WHEN THAT IS OVER ASSUMING HUD DOES NOT RECEIVE ANY VALID OBJECTIONS IT WILL COMPLETE
701516 TOO USE FRAT FUNDS.
THEY MAY BEGIN SPENDING FUNDS ONLY AFTER RECEIVING THE AUTHORITY EASE BRAND FUNDS.
THIS IS FORM 701515 THE REQUEST FORELEGS 6 FUNDS AND CERTIFICATION.
CERTIFIES THAT IT PROPERLY COMPLETED THE ENVIRONMENTAL REVIEW.
HUD TOES NOT CONFIRM THAT -- DOES NOT CONFIRM UNTIL MONITORING VISITS TO THE RESPONSIBLE
ENTITY.
IN THE FINAL SECTION OF THE FORM IT IS SIGNED BY THE RESPONSIBLE ENTITY, CERTIFYING OFFICER
AND AUTHORIZED OFFICER REPRESENTING THE RECIPIENT IF THERE IS A NONRESPONSIBLE ENTITY RECIPIENT.
NOW THAT WE HAVE GOTTEN THROUGH THE BASICS LET'S APPLY TO COC SPECIFICALLY.
BIG PICTURE ENVIRONMENTAL REVIEWS SHOULD BE FAST AND EASE.
GENERALLY, ENVIRONMENTAL REVIEWS FOR COC PROJECTS REQUIRE A LOWER LEVEL OF REVIEW TRIGGER FEW
LAWS, LEERINK AND CAN BE PERFORMED QUICKLY.
NOT TO SAY THAT EVERY REVIEW WILL BE FAST AND EASY SINCE REHAB AND NEW CONSTRUCTION
ARE ELIGIBLE ACTIVITIES WE DO ENCOUNTER MORE COMPLEX ENVIRONMENTAL REVIEWS FROM TIME TO
TIME.
THE GOAL ON AVERAGE IS TO MAKE THE PROCESS AS STEAMLINED AND EFFICIENT AS POSSIBLE FOR
RENTAL ASSISTANCE AND LEASING.
A COMMON MISCONCEPTION IS THAT A RE NEEDS TO PREPARE A NEW ENVIRONMENTAL REVIEW FOREVERRY
UNIT EVERY YEAR AND THAT IS NOT THE CASE.
EVERY UNIT THAT IS WENTED AND RELEASED -- HOWEVER, NOT EVERY UNITE NEEDS ITS OWN ENVIRONMENTAL
REVIEW.
YOU COULD TEE FINE AS LEASING ONE UNIT IN A PARTICULAR BUILDING.
THEN EVERY UNIT WOULD REQUIRE ITS OWN ENVIRONMENTAL REVIEW.
IT IS EASEOR DEFINE EACH PROJECT AS BROADLY AS POSSIBLE SO YOU ONLY HAVE TO DO FEWER INDIVIDUAL
REVIEWS.
FOR PROJECT-BASED RENTAL ASSISTANCE A GOOD SCALE IS TO REVIEW AN ENTIRE BUILDING OR COMPLEX.
WE RECOMMEND LOOKING AT THE ENTIRE LOCALITY A IS A WHOLE.
IT IS ALSO NOT NECESSARY TO DO A NEW REVIEW EVERY TIME A LEASE IS RENEWED, A NEW TENANT
MOVES IN OR EVERY YEAR.
A GOOD RULE OF THUMB IS TO REVISIT EVERY FIVE YEARS TO CONFIRM THAT CONDITIONS HAVEN'T CHANGED.
WORKING WITH RESPONSIBLE INITIES IS AN AREA WHERE COC CAN BE INTERESTICKY.
A SPONSIBLE ENTITY SHOULD BE RESPONSIBLE FOR PERFORMING THE ENVIRONMENTAL REVIEW.
AS WE DISCUSSED, ONLY A UNIT OF GENERAL LOCAL GOVERNMENT CAN ACT AS RESPONSIBLE ENTITY.
BECAUSE MOST COC RECIPIENTS CANNOT ACT AS RESPONSIBLE ENTITY THEMSELVES THEY NEED TO
FIND AND PARTNER WITH A UNIT OF GENERAL LOCAL GOVERNMENT WHO CAN ACT AS THE RESPONSIBLE
ENTITY.
GENERALLY THIS WILL BE THE LOCAL GOVERNMENT IN THE AREA BUT DEPENDING SON THE SCALE OF
THE PROJECT AND HOW MUCH DIFFICULTY THE RECIPIENT HAS FINDING A RESPONSIBLE ENTITY IT COULD
BE THE COUNTY OR EVEN STATE.
IF YOU DON'T HAVE ANY EXISTING RELATIONSHIP WITH THE GOVERNMENT CONTACT THE CPD REP AND
THEY SHOULD HELP YOU GET IN CONTACT WITH THE YECT OFFICE TO PERFORM THE PART 58 REVIEW.
IN LARGE CITIES THERE WILL BE AN OFFICE FAMILIAR WITH HUD ENVIRONMENTAL REVIEW PROCESS AND
REQUIREMENTS AND SHOULD GO SMOOTHLY.
IN SMALL AREAS IT THE ENTITY MAY BE NEW.
STILL, WE THINK THE STREAMLINED DESIGN PROCESS FOR COC SHOULD MAKE THIS RELATIONSHIP LIVETY
GREASE FOR EVERYONE.
BECAUSE MOST COC RECIPIENTS CANNOT ACT AS AN RE THEMSELVES THEY NEED TO FIND AND ADEBTIFY
A GOVERNMENT ENTITY.
GENERALLY THE LOCAL SOFT IN THE SPENDING AREA.
DEPENDING ON HOW MUCH KALE AND HOW MUCH DIFFICULTY THEY HAVE FINDING THE ENTITY IT COULD BE THE
COUNTY ORACIT.
>> IT YOU ARE COC AND DON'T HAVE A RELATIONSHIP CONTACT YOUR REPRESENT FOR ASSESSANCE.
THIS LARGER CITIES THERE SHOULD BE AN OFFICE FAMILIAR WITH THE REVIEW PROCESS AND SHOULD
BE A RELATIVELY SMOOTH PROCESS.
IN SMALLER CITIES AND RURAL AREAS THE LOCALITY MAY BE NEW TO THE HUD ENVIRONMENTAL REVIEW
REQUIREMENTS.
STILL, WE THINK THE PROCESS WE DESIGNED MAKES THIS RELATIVELY EASE.
>> AT EVERY LEVEL.
BECAUSE THE GOVERNMENT ENTITY IS NOT THE RECIPIENT OF HUD FUNDS THEY MAY DECLINE TO ACT AS RESPONSIBLE
ENTITY.
IF AN APPROPRIATE RESPONSIBLE ENTITY CANNOT BE FUND HUD WILL STEP IN AND PERFORM THE JIMMAL
REVIEW UNDER PART 50.
MOST OFFICES TAKE THE TIME TO TRY TO GET A WAY TO GET THE LOCAL GOVERNMENT TO ACT AS
RESPONSIBLE ENTITY AND WILL REQUIRE A FORMAL REVIEW IN WRITING.
IF AS A COO RECIPIENT YOU ARE HAVING TESTY FINDING AN RE, REACH OUT TO YOUR FIELD REP.
THEY WILL HAVE THE RELATIONSHIPS NEEDED TO GET YOU SOME ASSISTANCE.
LET'S TALK ABOUT HOW TO TRANSLATE COC ELIGIBLE ACTIVITIES INTO LEVELS OF REVIEW.
REMEMBER THAT THE LOWEST LEVEL OF REVIEW IS EXEMPT/CENST.
AND THERE ARE A LOT OF COC ELIGIBLE ACTIVITIES THAT FALL INTO THIS LEVEL.
SUPPORTIVE SERVICES AND OPERATING AND ADMINISTRATIVE COSTS.
AND TENANT-BASED RENTAL ASSISTANCE AND LEASING WITHOUT REPAIRS BEYOND ROUTINE MAINTENANCE.
THEN WE HAVE A SPECIAL LEVEL OF REVIEW JUST FOR COC THAT WE CALL CEST LIMITED SCOPE.
THESE PROJECTS ARE CEST BUT BECAUSE THE IMPACTS ARE MINUTE MILLION WE CREATED A SPECIAL ENVIRONMENTS
REVIEW FORMAT TAILORED TO THE LIMITED REVIEW.
THIS WOULD BE PROJECT-BASED RENTAL ASSISTANCE.
SPONSOR BASED RENTAL ASSISTANCE AND EASING OF OFFICE WITHOUT REHAB OR REPAIRS BEYOND
MENU TEEN MAINTENANCE.
ANY PROJECT THAT LOVES REPAIRS, REHAB, COP STRUCK OR DEMOLITION WILL REAR EITHER REVIEW
OR ENVIRONMENTAL ASSESSMENT.
IT DEPENDS ON THE SCALE OF THE PROJECT.
YOU MIGHT WONDER WHY TENANT-BASED LEASING ARE DISTINCT FROM PROJECT-BASED RENTAL ASSISTANCE
AND SPONSOR BASED AND THE DIFFERENCE HAS TO COULD WITH WHO SELECTS THE SPITE.
THE RECIPIENT OR THE PARTICIPANT.
IN DEPARTMENTIAN-BASED, THE ASSISTANCE -- IN TENTANT BASED THEY CAN SELECT THEIR OWN UNIT.
IN PROJECT BASED THE ASSISTANCE IS TIED TO THE UNIT RATHER THAN THE PERSON AND BECAUSE
THE RECIPIENT SELECTS THE UNIT THEY HAVE MORE RESPONSIBILITY FOR ENSURING THE SUITABILITY
OF THAT UNIT AND THEREFORE A HIGHER LEVEL OF REVIEW.
WE MADE THIS TO HELP YOU WHEN WORKING AND A COC REVIEW.
ONCE YOU HAVE THE PROJECT DESCRIPTION FOR A PROPOSED COC PROJECT YOU CAN USE THE CHA
ARE THE TO FIGURE OUT THE APPROPRIATE LEVEL OF REVIEW AND LINKS DIRECTLY TO THE RIGHT
FORM TO USE TO COMPLETE AN ENVIRONMENTAL REVIEW FOR THAT UP TOO ACTIVITY.
SH AVAILABLE ON THE HUD EXCHANGE.
GOOGLE COC ENVIRONMENTAL REVIEWS AND IT SHOULD POP UP AND THERE IS A LINK AT THE END OF THE
PRESENTATION.
ANYTHING THAT INVOLVES REHAB, DEMOLITION OR CONSTRUCTION CAN GET FAIRLY COMPLEX AND REHAVE
RESOURCES AND TRAINING TO GET INTO HOW TO CONDUCT ENVIRONMENTAL REVIEWS FOR THOSE TYPES
OF PROJECTS.
I WOULD LIKE TO TAKE A FEW MINUTES TO TAKE A CLOSE LOOK AT CONDUCTING REVIEWS FOR LEASING
AND RENTAL ASSISTANCE BECAUSE IT IS A LITTLE MORE SPECIALIZED FOR COC.
TENANT BASED LEASING AND RENTAL ASSISTANCE WHERE THE PARTICIPANT RATHER THAN THE GRANTEE
SELECTS HIS OR HER OWN UNIT.
THESE ACTIVITIES ARE CLASSIFIED AS CENST UNDER 24 CFR 5825 B 1 AS LONG AS THERE ARE NO REPAIRS
AND REHAB OTHER THAN ROUTINE MAINTENANCE.
THAT REONLY TO TENANT-BASED RENTAL ASSISTANCE NOT LEASING.
IT DOESN'T MATTER IF IT IS CALLED LEASE OR RENTAL ASSISTANCE AS LONG AS THEY ARE ABLE
TO SELECT THEIR OWN UNIT IT IS CED ENST.
THE OPERATING INSTRUCTIONS HAD A COUPLE MAJOR CHANGED TO THE PROCEDURES.
IN CASE YOU MISSED THEM THEN, THESE CHANGES HAVE SIGNIFICANTLY DECREASED THE AMOUNT OF
TIME THAT RECIPIENTS AND RES NEED TO SPEND ON ENVIRONMENTAL REVIEWS FOR TENANT BASED
RENTAL ASSISTANCE PROJECTS.
WE ENCOURAGE RESPONSIBLE ENTITIES TO CONDUCT ONE PROGRAMATIC REVIEW THAT COVERS ALL ANTICIPATED
TENANT BASED RENTAL ASSISTANCE AND LEASING PROJECTS FOR AN ENTIRE PROGRAM.
ALL UNITS WITHIN A COC.
IN THE PAST WE WERE SEEING RESPONSIBLE ENTITIES CONDUCTING INDIVIDUAL CENST REVIEWS FOR EACH
UNIT WHICH WAS TIME CONSUMING AND UNNECESSARY.
BASED ON THIS GUIDANCE, RESPONSIBLE ENTITIES SHOULD BE CONDUCTING ONE REVIEW THAT CLEARS
ALL TENANT BASED UNITS THROUGHOUT THE ENTIRE COC.
ONLY ONE FEDERAL ENVIRONMENTAL LAW FOR THESE TYPES OF PROJECTS AND THAT IS COASTAL BARRIER
RESOURCE AROUND WE WILL TALK MORE ABOUT THAT IN A FEW SLIDES.
BEFORE 2003 DIVE INTO HOW TO DO A REVIEW, FOR -- BEFORE WE DID DIVE IN, LET'S TALK ABOUT
THE DIFFERENCE BETWEEN ROUTINE MAINTENANCE AND REHAN.
IN 206, HUD DISTRIBUTED NOTICE CPD 602 WHICH PROVIDES GUIDANCE ON CATEGORIZING ACTIVITIES
AS MAINTENANCE FOR THE HUD REVIEW REQUIREMENTS.
IT DOES NOT AFFECT THE DEFINITION OF MENTION FOR ANY PROGRAM REQUIREMENTS.
A RULE, MAINTENANCE ACTIVITIES SLOW OR HALT THE DEER TOORIATE, OF A BUILDING AND DO NOT
MATERIALLY ADD TO ITS VALUE OR ATTACH IT TO NEW USES.
CLEANING, REPLACEMENT OF APPLIANCES THAT ARE NOT PERMANENTLY AFFIXED TO THE BUILDING, PROTECTIVE
OR PREVENTATIVE MEASURES.
AND REPLACING OF DAMAGED OR MALFUNCTIONING COMPONENT PARTS OF A BUILDING FEATURE OR SYSTEM.
ON THE OTHER HAND, REPLACING ALL OR MOST FEATURE OR SYSTEM IS NOT MAINTENANCE THAT WOULD RISE
TO THE LEVEL OF REHAB WHICH WOULD BE CEST.
COMPARED TO ACTIVITIES CONSIDERED REHAB.
IF YOU ARE NOT SURE IF A PARTICULAR ACTION WOULD BE MAINTENANCE, THE ODDS ARE GOOD THAT
YOU WILL FIND IT IN THIS CHART.
SO THIS IS IMPORTANT TO DEFINE.
BECAUSE MAINTENANCE ACTIVITIES COULD BE CENST WHEREAS A REHABILITATION ACTIVITY WOULD BE
CATEGORICALLY EXCLUDED SUBJECT TO.
SO IT IS IMPORTANT TO DEFINE THE LEVEL OF REVIEW.
TURNING BACK TO TENANT BASED RENTAL ASSISTANCE AND LEASING WHICH IS CENST IF IT IS LIMITED
MAINTENANCE.
THIS IS THE FORMAT WE PREPARED SPECIFICALLY FOR CONDUCTING PROGRAMATIC REVIEWS FOR CENST
TENANT BASED RENTAL ASSISTANCE AND LEASING.
HERE THE FIRST PAGE WHICH IS HOPEFULLY FAIRLY SELF-EXPLAN THAT TORRE.
YOU NEED TO NAME THE PROJECT.
IT DOESN'T NEED TO BE COMPLICATED.
JUST A RECOGNIZABLE REPRESENTATIVE NAME AND PROVIDE THE NAMES OF THE RESPONSIBLE ENTITY
AND RECIPIENT AS WELL AS THE PERSON AT THE RESPONSIBLE ENTITY PREPARING THE REVIEW.
NOTE WE ASK FOR STATE OR LOCAL EYE DENTINER.
THAT IS AN OPTIONAL FIELD.
USE THAT IF THERE IS A FILING SYSTEM YOU WOULD LIKE TO KEEP TRACK OF.
NEXT THE PROJECT LOCATION.
THIS COULD BE A FULL CITY OR COUNTY.
SOME RES FIND IF MAKES MORE SENSE TO BREAK DOWN INTO ENAGREE GRAPHIC AREAS AND SOME CLEAR
AN ENTIRE CITY AT ONCE.
IT IS WHATEVER MAKES SENSE FOR YOUR PROJECT.
THEN YOU SHOULD PROVIDE A PROJECT DESCRIPTION THAT DEEJAYS THE SCALE AND SCOPE OF THE PROPOSAL
-- THAT DESCRIBES THE SCALE AND SCOPE.
AND IF YOU AREN'T PROPOSING ANY MAINTENANCE AS PART OF THE PROJECT OR PROGRAM THE SPECIFIC
PROPROSED ACTIVITIES SHOULD BE LISTED.
RELIEVE THE LEVEL OF REVIEW AND APPROPRIATE CITATION BLANK BECAUSE THAT IS A DETERMINATION
THAT HAS TO BE MADE BY THE RESPONSIBLE ENTITY.
AS WE MENTIONED, THE PROJECTS SHOULD BE CENST UNDER 58.35 B 1.
THE NEXT PAGE OF THE FORM GETS INTO THE SUBSTANCE OF COMPLYING WITH THE RELATED FEDERAL ENVIRONMENTAL
LAWS AROUND AUTHORITIES LITED IN 2358.6.
SO LET'S TAKE A QUICK LOOK AT THOSE.
TENANT-BASED ACTIVITIES AUTOMATICALLY COMPLY WITH HUD'S AIRPORT HAZARD REGULATIONS SO THERE
IS NO NEED TO TAKE FURTHER ACTION INCLUDING MAPPING THE PROJECTS.
SIMILARLY, RENTAL ASSISTANCE AND LEASING ACTIVITIES ALONE DO NOT TRIGGER FLOOD INSURANCE REQUIREMENTS.
ALTHOUGH WE ALWAYS RECOMMEND FLOOD INSURANCE IT IS NOT A REQUIREMENT FOR TENANT BASED RENTAL
ASSISTANCE FOR LEASING.
THE COASTAL BARRIERS ACT IS THE ONLY REQUIREMENT THAT WE NEED TO WORRY ABOUT FOR COC UNITS.
FOR COC UNITS ALL OF THEM DO NEED TO BE OUTSIDE OF THE COASTAL BARRIER RESOURCE SYSTEM WHICH
CAN BE DETERMINED QUICKLY WITH A MAPPING TOOL THAT THE U.S. FISH AND WILDLIFE SERVICE PROVIDES
ONLINE.
FOR THOSE UNFAMILIAR, THIS ACT PROTECTS RELATIVELY UNDEVELOPED COASTAL BARRIERS ALONG THE COASTS.
THESE ARE PARTICULARLY VULNERABLE AND VOLATILE SITES SO WE DO WANT TO ENSURE THAT WE DON'T
POUTINE PROGRAM PARTICIPATES IN THESE LOCATIONS.
IF YOUR COC DOES NOT CONTAIN ANY OF EASE NEW KNITS THE PROJECT IS AUTOMATICALLY IN COMPLIANCE
ALTHOUGH WE DO ASK THAT YOU INCLUDE A PLAN SHOWING THE PROJECT LOCATION NEAREST TO THE
UNITS IF THERE ARE ANY IN THE STATE.
THE RENTAL UNITS NEED TO BE INDIVIDUALLY MAPPED TO ENSURE THAT THEY ARE NOT?
A COASTAL BARRIER RESOURCE UNIT.
SO RETURNING TO THAT FORM WE WERE LOOKING AT.
HERE IS HOW IT APPROACHES THE RELATED ENVIRONMENTAL LAWS AND AUTHORITIES.
YOSKY CAN SEE THE COMPLIANCE DETERMINATIONS FOR AIRPORT HAZARDS AND FLOOD INSURANCE ARE
FILLED IN FOR YOU.
COASTAL BARRIER RESOURCES THERE ARE SEVERAL CHOICES FOR PREFILLED COMPLIANCE DEPENDING
ON THE PROXIMITY TO COASTAL BARRIER RESOURCES.
WHEN THE FORM IS FINISHED THERE SHOULD NOT BE ANY REST ITALIC SIZED TEXT ANYMORE.
THAT IS IT FOR TENANT BASED RENTAL ASSISTANCE AND LEASING.
NOW THE SOME WHAT MORE COMPLEX PROJECT BASED AND SPONSOR BASED ASSISTANCE.
IN THESE TYPES OF PROJECTS THE RECIPIENT CHOOSES THE PROJECT LOCATION WHICH MEANS THEY ARE
MORE RESPONSIBLE FOR THE SAFETY SUITABILITY OF THE HOUSING UNITS AND WE REQUIRE A HIGHER
LEVEL OF REVIEW OF CEST.
HOWEVER, BECAUSE THE ENVIRONMENTAL REVIEW -- THE ENVIRONMENTAL IMPACTS ARE SO MINIMAL,
FOR RENTAL ASSISTANCE WE ONLY REQUIRE A LIMITED SCOPE CEST REVIEW FOR SPONSOR BASED AND PROJECT
BASED RENTAL ASSISTANCE WITHOUT REPAIRS OR REHAB.
IF THERE ARE ANY PROPOSED REPAIRS OR REHAB A STANDARD CEST REVIEW WITH BE REQUIRED.
SO LET'S TAKE A LOOK AT LIMITED SCOPE REVIEWS.
HERE AGAIN, WE HAVE MADE A SPECIAL ENVIRONMENTAL REVIEW FORMAT FOR LIMITED SCOPE AND PROJECT
BASED PROJECTS.
OF THE 16 ENVIRONMENTAL LAWS AND AUTHORITIES THAT SEST PROJECTS COMPLY WITH -- CEST COMPLY
WITH 11 HAVE BEEN COMPLETED FOR YOU.
FOR EACH BUILDING OR SITE ONLY HAVE TO DEMONSTRATE WITH THE REMAINING FIVE LAWS AND AUTHORITIES.
COASTAL BARRIER RESOURCES, FLOOD INSURANCE, FLOODPLAIN MANAGEMENT, CONTAMINATION AND ENVIRONMENTAL
JUSTICE.
FOR LIMITED SCOPE WE EXTENSIVE INSTRUCTIONS AVAILABLE THAT PROVIDES STEPPY STEP CONSTRUCTION
HOW TO COMPLETE THE FORM AND COMPLY WITH ALL THAT YOUS AND AUTHORITIES.
THE FIRST NEARLY IDENTICAL TO THE CEST PROJECT.
IT SHOULD BE MAULER THAN A TENNIAN BASED RENTAL ASSISTANCE OR LEASING PROJECT.
A GOOD SCALE IS TO CONSIDER A BUILDING OR COMPLEX AS A WHOLE.
ANYTHING LARGER WOULD BE A LITTLE TOO COMPLEX FOR THIS TYPE OF REVIEW.
SO TRY TO AVOID DOING AN ENTIRE ENVIRONMENTAL REVIEW FOR AN INDIVIDUAL UNIT TO AVOID MAKING
EXTRA WORK FOR YOURSELF.
THIS IS SIMILAR TO THE FORMAT.
FOR MOST OF THE RELATED LAWS AND AUTHORITIES WE WERE ABLE TO CONCLUDE FOR YOU THAT ALL
COC PROJECT-BASED AND SPONSOR BASED RENTAL ASSISTANCE PROJECTS ARE AUTOMATICALLY IN COMPLIANCE
AND DRAFTED THE COMPLIANCE DETERMINATION FOR YOU.
HOWEVER, SOME WILL REQUIRE SITE SPECIFIC ANALYSIS.
TORE THOSE, WE LEFT THE COMPLIANCE DETERMINATION BLANK AND THE SEPARATE INSTRUCTION DOCUMENT
PROVIDES INFORMATION ON HOW TO COMPLY.
NOTICE THAT YOU WILL BE ASKED TO INDICATE WHETHER FORMAL COMPLIANCE STEPS OR MITIGATION
ARE REQUIRED EVEN THOSE WHERE THE COMPLIANCE WAS WRITTEN FOR YOU.
THAT IS A DECISION THAT MUST BE MADE TO THE ENTITY TAKE A RACK AT THE LAWS AND AUTHORITIES
THAT YOU ARE GOING TO NEED TO WORK THROUGH.
CONTAMINATION.
ALL HUD ASSISTED PROPERTIES FREE OF HAZARDOUS MATERIALS, CONTAMINATION TOXIC GASES AND RADIO
ACTIVE SUBSTANCES WHERE THE HAZARDS COULD AFFECT THE HEALTH AND SAFETY OF OCCUPANTS.
REQUIRES TWO OR THREE STEPS.
FIRST, GENERATE A REPORT OF KNOWN NEARBY TOXIC SITES AND RELEASES.
THIS IS EASY TO GENERATE USING AN ONLINE TOOL CALLED EE.ENVIRO-FACTS.
SECOND, LOOK AT PAST USES OF THE SITE AND LOOK FOR ANYTHING THAT COULD INCREASE THE
RISK OF CONTAMINATION.
THIS COULD BE AS ELABORATE AS PHASE ENVIRONMENTAL SITE ASSESSMENT BUT WE DO NOT REQUIRE COC
PROJECTS.
A FOOD AIL TERN SEVEN IS TO LOOK AT HISTORICAL AERIAL PARAGRAPHS AND THESE MAY BE AVAILABLE
AT THE LOCAL LIBRARY OR PLANNING DEPARTMENT.
AND GO BACK TO AT LEAST 1940.
YOU CAN ALSO GET A HISTORY OF THE SITE FROM SOMEONE WITH SPECIFIC KNOWLEDGE OF THE SITE.
FOR ALL PROJECTS YOU SHOULD DISCUSS ANY POTENTIAL ADVERSE IMPACTS OR RED FLAGS.
IF YOU UNDERCONNIE HAZARDS THAT COULD AFFECT THE HEALTH OR SAFETY OF OCCUPANTS EITHER MITIGATE
OR REJECT THE SITE.
REACH OUT TO THE ENVIRONMENTAL FIELD OFFICER IF YOU NEED HELP WITH THE ANALYSIS.
FLOODPLAIN MANAGEMENT.
THE FIRST STEP HERE IS TO GO TO THE FEMA ONLINE FLOOD MAP SERVICE CENTER AND LOCATE ON A FLOOD
INSURANCE RATE MA'AM OR F.I.R.M.
FLOODWAYS ARE PART OF THE FLOODPLAIN THAT CARRIES THE FLOW OF FLOOD WATERS DURING THE
INTOED AND THAT IS WHERE THE RISK IS HIGHEST SO WE DO NOT APPROVE RESIDENT PROPERTIES IN
THE FLOODWAY.
KEY CAN APPROVE IN A COASTAL HIGH HAZARD AREA OR SUBJECT TO HIGH VELOCITY WAVES DURING A
STORM ONLY IF CERTAIN CRITERIA ARE MET.
WE STRONGLY RECOMMEND AVOIDING PROJECTS IN THE AREAS.
IF THE PROJECT IS IN A 100 YEAR FLOODPLAIN THE 8 STEP DECISION-MAKING PROCESS IS REQUIRED
FOR LEASING OR RENTAL ASSISTANCE IN A MULTIFAMILY BUILDING.
DOCUMENT SHOWING THERE ARE NO PRACTICAL ALTERNATIVES TO LOCATING THE PROJECT IN A FLOODPLAIN OR
MEMBER DONE STRAIGHT THE ENTIRE BUILDING IS FULLY PROJECTED BY FLOOD INSURANCE TO PROTECT
THE REGULAR DEPARTMENTS FROM FLOOD LOSS.
TAKE A POSITIVE ACTION TO IMPRO MUCH THE SAFEPY LYING LOG ATSIDES OUTSIDE OF THE FLOODPLAIN.
YOU WITH REACH OUT FOR ASSISTANCE OR REFER TO THE WEBSITE WHICH HAD STEP-BY-STEP INSTRUCTIONS
ON COMPLETING THE PART 85 AND COMPLETING THE PROCESS.
CONTAMINATION AND FLOODPLAIN MANAGEMENT ARE THE BIGGEST ENVIRONMENTAL CONCERNS BECAUSE
WE WANT TO MINIMIZE THE HEALTH AND SAFETY RISKS TO RESIDENT.
HOWEVER, THERE ARE THREE MORE FACTOR.
WE WANT TO LOOK AT THAT AS PART OF LIMITED SCOPE REVIEW.
FLOOD INSURANCE IS NOT REQUIRED FOR LEASING OR RENTAL ASSISTANCE ALONE.
HUD RECOMMENDS GETTING FLOOD INSURANCE FOR ALL PROGRAMS.
BUT IT IS UP TO THE DISCRETION OF THE RESPONSIBILITY ENTITY.
REMEMBER, GETTH FLOOD INSURANCE CAN BE A WAY TO AVOID HAVING TO COMPLETE THE EIGHT STEP
PROCESS IN COME CASES.
WE DISCUSSED THE COASTAL BARRIER RESOURCES ACT.
HUD ASSISTANCE MAY NOT BE USED FOR ANY PROJECT IN THE COASTAL BARRIER RESOURCE SYSTEM AND
ANY HAS TO BE REJECTED.
AFTER COMPLETING ALL OF THE ENVIRONMENTAL ANALYSIS, EVALUATE ENVIRONMENTAL JUSTICE.
YOU WANT TO MAKE SURE THERE ARE NO ADVERSE ENVIRONMENTAL IMPACTS THAT COULD DISPROPORTIONATELY
AFFECT MINORITY OR LOW INCOME COMMUNITIES LIKE THOSE ASSISTED BY THE COC PROGRAM.
IT THERE IS UPMITIGATED RISKS THAT PRESENTS AN VISIONAL JUSTICE ISSUE AS WELL.
THE BEST COURSE IS TO AVOID IT IN THE FIRST PLACE.
THAT IS ABOUT IT FOR THE ANALYSIS.
NOW YOU JUST NEED TO COMPLETE THE FUNNIAL STEPS BEFORE THE LIMITED SCOPE ENVIRONMENTAL
REVIEW IS COMPLETE AND PROCEED TO IMPLEMENTING THE PROJECT.
FIRST, YOU NEED TO MAKE A FINDING.
IF THERE ARE NO REQUIRED MITIGATION MEASURES OR FORMAL COMPLIANCE MEASURES THE PROJECT
CAN CONVERT TO EXEMPT AND NO NEED FOR HUD APPROVAL.
ONCE THE RESPONSIBLE ENTITY CERTIFYING OFFICER SIGNED OFF YOU MAY BEGIN DRAWING DOWN FUNDS
AND SIGNING LEASES IMMEDIATELY.
IF THERE ARE ANY REQUIRED MITIGATION OR FORMAL COMPLIANCE STEPS PROCEED TO THE NOTICE OF
INTEND TO REQUEST FOR RELEASE OF FUNDS INJURE THE RESPONSIBLE ENTITY MUST PUBLISH OR POST
PUBLIC NOTICE.
AFTER RESPONDING TO ANY COMMENTS RECEIVED, BOTH THE RECIPIENT AND THE RESPONSIBLE ENTITY
SHOULD SIGN FORM 701515 REQUEST FOR RELEASE OF FUNDS AND CERTIFICATION AND SUBMIT TO HUD.
THIS WILL RESPOND WITH 701516.
ONLY AFTER THE RECIPIENT RECEIVES THAT FORM WILL HUD CAN IT BEGIN SUBMITTING FUNDS.
THAT WAS A LOT OF INFORMATION BUT IT IS ALL AVAILABLE.
THIS DOCUMENT PROVIDES STEP-BY-STEP INSTRUCTIONS ON HOW TO COMPLETE A LIMIT THE SCOPE REVIEW
PROPERLY INCLUDING HOW TO COMPLY WITH EACH OF THE LAWS AND AUTHORITIES.
I WANT TO ADD A QUICK NOTE ON HEROES WHICH IS HUD'S JIMMAL REVIEW JON LINE SYSTEM.
WE RECOMMEND USING IT FOR ALL 58 REVIEWS BUT COC IS THE EPSCEPTION OF THAT RULE.
HEROES IS NOT COMPATIBLE WITH THE LIMITED SCOPE FORMATS.
WE RECOMMEND USING THAT RATHER THAN USING HEROS.
THEY WILL EVENTUALLY BECOME MANDATORY AND WE ANTICIPATE THAT SWITCH HAPPENING IN LATE
208 OR 2019.
SO, IF YOU ARE WATCHING THIS WEBCAST IN THOSE YEARS, PLEASE CHECK THE WEBSITE, THE LINK
IS SHOWN HERE, FOR THE MOST UP TO DATE REQUIREMENTS AND RECOMMENDATIONS.
FOR NEU HUD -- YOU DO NEED TO USE THAT RATHER THAN THE TAILORED COC FORMATS.
THAT IS JUST ABOUT IT FOR TODAY.
BEFORE WE MOVE ON TO RESOURCES I WANT TO LEAVE YOU WITH THE POINTS.
FIRST IN GENERAL A RESPONSIBLE ENTITY SHOULD BE CONDUCTING PART 50 REVIEWS FOR ALL COC
PROJECTS WHICH REQUIRES THAT THE RECIPIENT WORK WITH THE UNIT OF GENERAL LOCAL GOVERNMENT.
IF AS THE RECIPIENT YOU HAVE DIFFICULTY FINDING A RESPONSIBLE ENTITY CONTACT HUD.
HUD CAN DO THE REVIEW UNDER PART 50 BUT ONLY AFTER EXHAUSTING ALL POSSIBLE ALTERNATIVES.
REMEMBER FROM THE LAST SLIDE HUD CANNOT USE THE STREAMLINED COC SPECIFIC FORMATS SO IT
WILL BE MORE TIME CONSUMING AND A LITTLE MORE COMPLICATED PROCESSED UNDER 50.
MAKE EACH REVIEW COVER AS BROAD AN AREA AS POSSIBLE SO THAT YOU ARE CONDUCTING ONE LARGE
REVIEW INSTEAD OF MULTIPLE SMALLER REVIEWS.
TENANT BASED ASSISTANCE AND LEASING IS.
ONE REVIEW FOR ALL OF THE PROGRAM.
COMPLETE ALL OF IT FOR THE ENTIRE COC IN FIVE OR 0 MINUTES.
PROJECT BASED AND SPONSOR BASED SCALE THE REVIEWS TO CLEAR AN ENTIRE BUILDING OR COMPLEX
RATHER THAN INDIVIDUAL UNITS.
FOR LIMITED SCOPE REVIEWS WE ANTICIPATE THAT TAKING ABOUT AN HOUR UNLESS THERE ARE ANY
ISSUES WITH CONTAMINATION OR FLOODPLAINS.
FINALLY, MAKE SURE TO WAIT TO ENTER INTO ANY LEASES OR MAKING ANY OTHER CHOICE-LIMITING
ACTIONS UNTIL AFTER THE ENVIRONMENTAL REVIEW IS COMPLETE.
FAILURE TO COULD SO COULD RESULT IN SANCTIONS FROM HUD.
THAT IS IT.
QUICK PLAY REVIEW RESOURCES IT YOU CAN REFER TO LATER ON.
THIS IS A GOOD ONE-STOP SHOP FOR COC ENVIRONMENTAL REVIEW LINKS.
FIND IT AT THIS LINK BY BY GOOGLING COC ENVIRONMENTAL REVIEWS.
FIRST, ACCESS THE FLOWCHART THAT DIRECTS YOU TO THE CORRECT LEVEL OF RESUE AND FORMAT.
OR YOU CAN DO DIRECTLY TO ALL OF THE FORMATS FROM THE LINKS BELOW THE FLOWCHART.
IF YOU WOULD LIKE MORE GENERAL INFORMATION YOU CAN ACCESS THE OFFICE OF ENVIRONMENT ENERGY'S
MAIN PAGE ON THE HUD EXCHANGE AT WWW.HUDEXCHANGE.INFO/PROGRAMS/ENVIRONMENTALREVIEW AND WATCH MORE WEBINARS THROUGH THE TRAINING
HERE.
IF THEY DON'T HAVE WHAT YOU NEED COME TO US WITH QUESTIONS.
MOST QUESTIONS ABOUT COC YOU CAN GO THROUGH THE ASK A QUESTION FEATURE ON THE HUD EXCHANGE
OR GO DIRECTLY TO THE LOCAL FIELD ENVIRONMENTAL OFFICER FOR HELP WITH ENVIRONMENTAL REVIEW
QUESTIONS.
SO THANK YOU SO MUCH FOR JOINING ME TODAY.
I HOPE THAT YOU FOUND THIS HELPFUL AND THAT YOU ARE LITTLE MORE COMFORTABLE COMPLETING
ENVIRONMENTAL REVIEWS FOR COC PROJECTS.
PLEASE STAY IN TOUCH AND KEEP LETTING US KNOW WHAT WE CAN DO TO HELP.
THANK YOU. ��
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