Environmental Review Process for the Neighborhood Stabilization Program 24 CFR Part 58
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Neighborhood Stabilization Program Environmental Review Requirements
Official Welcome: Charles Bien, Director, Environmental Review Division
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Environmental Training
Today’s Instructors: Linda Poythress, Regional Environmental Officer, Atlanta Office David Blick, Deputy Federal Preservation Officer, Washington, DC
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Goals for the Course
When is an ER required? What is the process? What is qualified documentation? What is the timing? How can the ER process be expedited?
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First Principle:
Call Your Field Environmental Officer
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Second Principle:
Find more information on the environmental website:
www.HUD.gov/offices/cpd/environment/index.cfm
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Next Principle:
The ER process must be complete PRIOR to commitment of funds
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One More Principle:
The environmental review is a study of the site
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Why?
Project is Federally Funded In whole, or In Part
Requires Compliance with NEPA
and the Laws and Authorities
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National Environmental Policy Act
NEPA: •Federal Environmental Policy •Federal Law
Protect, Restore and Enhance the Human Environment
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NEPA
Shared Responsibility:
The
President
The Courts
The Federal
Agencies (RE)
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NEPA
Environmental Study
• Agency Comments
• Public Document
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NEPA
Environmental Study
• Agency Comments • Public Document
Scientific Analysis Relevant Issues
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NEPA
Established the CEQ
• Exec. Office of the President • CEQ Regs 42 CFR 1500 • Agency Regs Consistent w/NEPA • Oversees Federal Agencies ERs • Cooperating Agreements
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HUD Regulations
24 CFR Part 58 Procedure for REs 24 CFR Part 51 Hazards 24 CFR Part 55 Floodplains 24 CFR Part 50 HUD Procedure
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TERMS
Activity Project Individual Action Recipient Responsible Entity Certifying Official
Exempt CENST Categorically Excluded RROF NOI/RROF EA FONSI
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Who’s Responsible? --58.4
Grant to a Unit of Local Government
Must assume Part 58 for: • Formula Grants • Neighborhood Stabilization Grant is a formula grant
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Who’s Responsible? --58.4
State Funds
Grants to LG • LG Responsible • RROFs to State Grants to Others • State Responsible • RROF to HUD
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Overview
Steps In the Process
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Steps
Define the project Aggregate Alternatives Level of Review Conduct Review Publish or Post When required RROF Receive ATUGF Commit Funds and Implement Project
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Overview
Steps In the Process: Define the Project
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Define the Project
Project Area: Existing Conditions Features Character Resources Trends
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Define the Project
Activities:
HUD Funded Programs Used Other Funding Time Frame Action Plan Maps/location
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Overview
Steps In the Process: Aggregate activites into projects
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Aggregation 24 CFR Part 58.32
A logical way to group activities into projects for the purpose of environmental review.
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Types of Aggregation 24 CFR part 58.32
--Geographic
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Types of Aggregation 24 CFR part 58.32
Geographic
Functional
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Overview
Steps In the Process: --Alternatives
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Overview
Steps In the Process: -- Level of Review and Public Notice
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Level of Review
Full Assessment Categorically Excluded, Subject to 58.5/6 Categorically Excluded NOT Subject to 58.5
Exempt
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Exempt Activities 24 CFR Part 58.34(a)
Environmental, planning & design costs Information & financial services Administrative/management activities Public services (no physical impact) Inspections Purchase of tools/insurance Technical assistance & training Temporary assist. for imminent threats Payment of principal and interest on HUD loan
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Exempt “Level of Review” 24 CFR Part 58.34
Document determination in writing Document compliance with 58.6 SIGN and DATE No RROF or further approval from HUD or the State is required
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Categorically Excluded Activities not subject to 58.5 at 24 CFR Part 58.35(b)
Tenant-based Rental Assistance Supportive Services (Hsg. Counseling) Operating Costs (maintenance, supplies) ED Costs (non-construction) Down-payment Assistance on Existing Pre-development Costs Supplemental Assistance (NEW to Regs)
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Categorically Excluded Not subject to 58.5
SAME AS EXEMPT:
Document determination in writing Document compliance with 58.6
SIGN and DATE
No RROF or further approval from HUD
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or the State required
Categorically Excluded subject to 58.5
24 CFR Part 58.35(a)(1)
Public Facilities: • Acquisition • Repair • Reconstruction • Improvement If Facility in place 20% or less change in size or capacity
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Categorically Excluded subject to 58.5
24 CFR Part 58.35(a)(2)
Special Projects for removal of: • Material • Architectural Barriers That restrict mobility and accessibility
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Categorically Excluded subject to 58.5 (24 CFR Part 58.35(a)(3(i))
Rehabilitation of 1 to 4 family Dwellings • Density is not > 4 units • Land use is not changed • The site is not in FP • The footprint is not expanded
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Categorically Excluded subject to 58.5
24 CFR Part 58.35(a)(3)(ii)
Rehab of Multifamily residential when: • Density is not changed > 20% • Does not involve change in land use • Cost is < 75% cost of replacement
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Categorically Excluded subject to 58.5
24 CFR Part 58.35(a)(3)(iii)
Rehab of Nonresidential when: • < 20% change in size and capacity • does not change land use
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1. An individual action on a 1-to-4 family dwelling 2. A project of five or more units more than 2,000 ft apart
Categorically Excluded subject to 58.5 24 CFR Part 58.34(a)(4)
developed on scattered sites
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Categorically Excluded subject to 58.5 24 CFR Part 58.35(a)(5)
Acquisition or Disposition Existing Structure or Land IF Structure will be used for the same use Land will be used for the same use
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Categorically Excluded Clearance
Complete Statutory Checklist If Compliance is triggered: • • • • Publish/Post NOI/RROF Wait 7 /10days, Send RROF to HUD/State HUD Waits 15 days
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Categorically Excluded Clearance
Complete Statutory Checklist
If Compliance is NOT triggered: • Project reverts to exempt • document determination in writing (58.34(a)(12) and (b)) • place all documentation in ERR (sign and date)
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Environmental Assessment Activities
24 CFR 58.36
Project Activities that are: • Not Categorically Excluded See Conditions 58.35(a) • Change in Use • Major Rehab • Increase in size or capacity > 20% • New Const > 4 SF together Require a FULL ASSESSMENT
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Environmental Assessment Activities
Greater potential for Impact Always requires a FONSI and RROF Determines if EIS is required Requires study of alternatives
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Environmental Assessment
Requires NEPA study • Includes the Laws and Authorities at 58.5 and 6 Studies: • Human Environment • Built Environment
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Environmental Assessment Clearance
Complete EA Checklist Make Finding
Publish/Post Combined Notice
Wait 15/18 days RROF and certifications to HUD) HUD waits 15 days
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Environmental Impact Statement “EIS” 24 CFR Part 58.37
Completed for:
Controversial Projects
Findings of Significant Impacts (FOSI)
Large projects (2,500 or more units)
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Overview of Public Notification
EA: Combined Notice (FONSI and NOI) CE that “trigger” compliance: NOI/RROF only CE No Compliance Triggered None CE Not Subject to 58.5 : None Exempt: None
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Public Comment Periods 24 CFR part 58.45
NOI/FONSI - 15 days from Publication or 18 days from Posting NOI - 7 days from Publication or 10 days from Posting RE must consider comments prior to submitting its RROF to HUD
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Local Period - Objections
Basis for Objections: • ANYTHING!!!
FONSI NO RROF
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Request for Release of Funds
Certification Indicates: • ER Complete • Notice Published • Local Comment • Period Complete • CO Signs
Subject to False Claims Act
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RROF Submission Requirements 24 CFR Part 58.71
Signed 7015.15 from CO
Copy of Public Notice
Submit to local HUD
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Objections to HUD 24 CFR Part 58.75
Basis for Objections : • 7015.15 not signed by CO • FONSI not written • Omitted Steps (at subpart E) • Committed funds prior to RROF • Another Federal agency objects
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Environmental Review Record 24 CFR Part 58.38
Project Description - Scope Determination of Level of Review Completed review form - as required Documentation attached FONSI and RROF Information Comments and Responses/Analysis HUD Removal of Grant Condition Revisions/changes to original review
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Limitations on Activities Pending Clearance 24 CFR Part 58.22
Funds are committed when: A legally binding, irrevocable, contract is signed
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Limitations on Activities Pending Clearance 24 CFR Part 58.22
Conditional Commitment • Subject to the ER • Legally Binding Document • Must prevent commitment by 3rd party
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Limitations on Activities Pending Clearance 24 CFR Part 58.22
Upon receipt of application/proposal for funding the RE must provide notice to third party:
24 CFR Part 58.22(a)and(c) Third party cannot commit HUD funds or any other funds Third party cannot take any choice limiting action
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Limitations on Activities Pending Clearance 24 CFR Part 58.22 (d)
Options to purchase property are allowed prior to receiving ATUGF if: • Cost is nominal • Site can be rejected based on environmental finding
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Tiering 24 CFR Part 58.15
The Tiering process allows: • The ER to be conducted in 2 stages: The Broad review The Site Specific review • Allows RROF for the project Multi-year Multi-site
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Tiering 24 CFR Part 58.15
Requires: • Broad review with documentation • Written strategy • Site specific compliance
Must maintain entire record
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Steps for Tiering an ER 24 CFR part 58.15
Define Scope of PROJECT: • Include all activities anticipated • Aggregate geographically or functionally Conduct the Environmental Review Develop a WRITTEN strategy Develop an Site Specific Checklist Publish/Post a Public Notice for Project Receive ATUGF from HUD Conduct a SITE SPECIFIC REVIEW Sign, date, place in ERR Commit funds for the Site
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Overview
Steps In the Process: --Receive the ATUGF: HUD 7015.16 and Proceed
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Implement the Preferred Alternative
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Overview Part 2
Overview of the Laws and Authorities
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Laws and Authorities 58.5
Historic Preservation
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National Historic Preservation Act (16 U.S.C. 470 et. seq.)
GOALS: Establish broad agency responsibilities to protect & preserve historic properties (Section 110)
Require agencies to consider effects of their projects on historic properties (Section 106)
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What’s an historic property?
Buildings, objects, districts, sites, or structures usually 50+ years old; AND Listed on or eligible for listing on the National Register of Historic Places NR Criteria – 36 CFR Part 60.4
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Section 106 of NHPA
REQUIREMENTS: Take into account the effects of your project on historic properties
Afford the Advisory Council on Historic Preservation a reasonable opportunity to comment
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What triggers 106?
Federal funding, assistance, license, permit, or approval
Project is defined as an “undertaking”
Project has potential to cause effects to historic properties
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Is your project exempt from Section 106?
Refer to §58.34 and § 58.35(b) to see if your project is exempt or categorically excluded not subject to… • If so, then under 106, you may make the unilateral decision that the project has “no potential to cause effects”
Does an existing Programmatic Agreement exempt your activity?
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The Regulation
36 CFR Part 800, “Protection of Historic Properties” Establishes a 4-step compliance process
Mandates consultation, not preservation
Agency is the decision-maker
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The 4-Step 106 Process
1.
Initiate consultation
2.
Identify and evaluate historic properties
Assess effects
3.
4. Resolve adverse effects
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1. Initiate Consultation
Is the project an undertaking? Is it exempt or CENST? • §58.34 or §58.35(b) • Programmatic Agreement Which SHPO/THPO do you contact? What other stakeholders should be contacted? How will you involve the public?
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2. Identify historic properties
Define “area of potential effect” Gather existing information from knowledgeable sources Contact stakeholders for any new info Evaluate NR eligibility Submit finding of “no historic properties affected” or move to next step • Include supporting documentation
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3. Assess Effects
Apply criteria of adverse effect • See §800.5(a)(1) Consult with SHPO/THPO and stakeholders, the public Submit finding of “no adverse effect” or go to next step • Include supporting documentation
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4. Resolve Adverse Effects
Notify ACHP of adverse effect Continue consultation with stakeholders Involve the public Consider ways to avoid or minimize effects by modifying the project Negotiate mitigation to offset adverse effects Execute Memorandum of Agreement
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Expediting & Streamlining Section 106
Use §800.3(g) when appropriate • Combine findings into 1 submission to SHPO and stakeholders Use a Programmatic Agreement (§800.14(b)) • Tailors compliance to meet needs of your program/activities • Reduces SHPO review time • Allows you to make decisions without SHPO
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HUD Guidance Available
HUD Historic Preservation website: • http://www.hud.gov/offices/cpd/enviro nment/ review/historic.cfm CDBG Pamphlet, “Preserving America” 106 “Toolkit” for Neighborhood Stabilization programs & activities • Helpful tips and guidance • Sample correspondence • Sample Programmatic Agreement
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands
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Floodplain Management EO 11988 & 24 CFR Part 55
Goal: AVOID development in Floodplain Unless there is No Alternative Requires 8 Step Process (Part 55.20) Written analysis 2 Public notices Comment 15 and 7 days
• •
• • •
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Floodplain 24 CFR Part 55.12
Exceptions: Acquisition of existing 1 to 4 family dwellings Minor repairs to 1 to 4 family dwellings Incidental portion in FP (conditions) Projects with LOMA or LOMR Avoid the FP – reject the site
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Floodplain 24 CFR Part 55
Is the building or construction in the 100 yr Floodplain? • If Yes, compliance time increased costs are increased flood insurance required: Grant: Economic life Loan: Life of loan
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The 8-Step Process What are the Steps:
1. 2. 3.
4.
5. 6. 7. 8.
Is the site in the FP/WL? Early Public Notice Evaluate Alternatives Identify Impacts Minimize Impacts Reevaluate Alternatives Publish Final Notice Proceed and Mitigate
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Streamlining Floodplain 24 CFR Part 55.25
Area-wide Compliance: Invite agencies with knowledge to participate - scoping Requires development and publication of strategy (2 notices) Determines mitigation for actions Expires in 10 years
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Wetlands – EO 11990 24 CFR Part 58.5(B)(2)
Goal: Avoid Development in Wetland Water Marks
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Wetlands - EO 11990
Exceptions: Rehabilitation Acquisition of Existing Other projects without soil disturbance Wetland on site but avoided
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Wetlands – EO 11990
Identification Step 1: Review Documentation: • National Wetlands Inventory Map • Soil Surveys • USGS Topographic Maps • Aerial Photographs
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Wetlands – EO 11990
Identification Step • • • 2: Onsite observation: Plants Soil Water indicators
e.g. Drainage patterns
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Wetlands – EO 11990
If the site is in a Wetland the ER must contain: Alternatives analysis Mitigation Proof of Public Notice
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Environmental Standards • Noise • Above Ground Storage Tanks • Clearzones • Toxics
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24 CFR Part 51
Subpart A: General Provisions Subpart B: Noise Abatement and Control Subpart C: Above Ground Storage Tanks with Flammable Liquids and Gases Subpart D: Airport Clear zones 24 CFR Part 58.5(i) Toxics
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HUD Noise Standards 24 CFR Part 51 (b)
SOURCE
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HUD Noise Standards 24 CFR Part 51 (b)
Exceptions: Acquisition of existing structures without rehab Uses that are not noise sensitive
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HUD’s Noise Standards 24 CFR Part 51(b)
Acceptable: Less than 65 DNL Normally Unacceptable: 65 -75 DNL Unacceptable: greater than 75 DNL
Determined by exterior noise levels
Interior Goal is 45 DNL
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HUD Noise Standards 24 CFR Part 51 (b)
When is the calculation required? Is the site: 1000 feet from highway 3,000 feet from a Railroad 15 miles from a civil airport or military airport
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Above Ground Storage Tanks 24 CFR Part 51 (C)
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Above Ground Storage Tanks 24 CFR Part 51 (C)
Exceptions: Acquisition of existing single family homes, multifamily developments, other structures Rehabilitation with out expansion Because the number of persons exposed to is not increased
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Above Ground Storage Tanks 24 CFR Part 51 (C)
Exceptions:
High Pressure Pipelines
Mobile tanks en route
Underground Storage Tanks
Natural gas holders With Floating Tops
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Above Ground Storage Tanks 24 CFR Part 51 (C)
Collect the following Information: 1. size of the tank 2. contents 3. liquid or gas 4. pressurized/ not under pressure 5. distance from project site 6. Is the tank diked or undiked?
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Above Ground Storage Tanks 24 CFR Part 51 (C)
Use the Chart on Page 51 and 52 of the guide book to calculate the ASD
ASD Distance
HUD assisted Project
Stationery Above Ground Storage Tank
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Mitigation Options
Bury the assessed tank Move the building outside the ASD (exterior uses must also be mitigated) Modify the building design Choose another site Design and implement a barrier
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Airport Clear Zones 24 CFR Part 51 Subpart D
Policy: To avoid provision of HUD funds for projects that are occupied or frequently used by people Exceptions: Purchase of existing with notice and written statement by airport operator of no planned expansion or buy out planned for the site
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Airport Clear Zones
Part 51 Subpart D
Prohibits use frequented by people for: • No New Construction • No major rehab >75% • No increase in density • No purchase of land for development
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APZ
Clearzone
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Airport Clear Zones 24 CFR Part 51 Subpart D
Is there an airport in 1 mile of the site? If no, document the file with a map If yes: Obtain: • Civil: “Airport Layout Plan” • Military: “AICUZ” To determine: • Civil: Runway Clear Zone • Military: Clearzone and Accident Potential Zone
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Airport Clear Zones Part 51 Subpart D
When is an impact review required? When the project site is located at the end of a runway: • civil airport: 2,500 feet • military airport: 15,000 feet If Yes, ER must contain written determination by airport operator stating site in or out of Clearzone
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Airport Clear Zones Part 51 Subpart D
Leasing, purchase or sale in Clear Zone or APZ Requires Notice see HUD website for a copy
Notice Signature
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Toxics 24 CFR Part 58.5(i)
Must determine site is : • free of hazards, contamination toxic chemicals, gas and radioactive materials • that could affect: health and safety of occupants, and/or conflict with use of property
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Toxics 24 CFR Part 58.5(i) Emphasis on sites with likely hazards: • Landfills • Dumps • Industrial sites • Gas stations • Substations
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Toxics 24 CFR Part 58.5(i)
Very Few Exceptions: Phase I: Environmental Site Assessment ASTM standards do not apply to single family but HUD regulations do apply However, all HUD funded projects must be free from hazards that could affect the health and safety of the residents or conflict with the intended use of the property
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Toxics 24 CFR Part 58.5(i)(2)
i. Site must be free of hazards ii. Multifamily or nonresidential must study previous use iii. Emphasis on sites with known hazards iv. Current techniques by qualified professionals
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Standards Aquifers
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Sole Source Aquifers 24 CFR Part 58.5(d)
Goal: To preserve and conserve the only source of water for a community.
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Sole Source Aquifers
Exceptions: Acquisition of structures with no change in use Rehab of existing structures States and areas with out sole source aquifers
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Sole Source Aquifers
Generally applies to: New Construction Change of use Acquisition of vacant land for development
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Standards Aquifers Endangered Species
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Endangered Species Act
Goal: Conserve federally threatened and endangered species and their habitats.
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Endangered Species Act
Exceptions: Building acquisition; Rehabilitation; Reconstruction w/in existing footprint; Demolition; Other projects w/out soil disturbance, vegetation removal or excessive noise.
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Endangered Species Act
Step 1: Consult with USFWS: • Species known from county (parish) • Species known from project watershed (aquatics) If no – “No Effect”
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Endangered Species Act
Step 2: Species in community: • Basic habitat (e.g. forest, field) • Staff survey (obvious habitat absence) • Professional survey No habitat – “No Effect” Habitat, no species – “Not likely to adversely affect”.
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Endangered Species Act
Likely to Adversely Affect: Biological Assessment Biological Opinion: •Alternatives & •Measures
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Standards Aquifers Endangered Species Rivers
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Wild and Scenic Rivers Act 24 CFR Part 58.5(f)
http://www.rivers.gov/ wildriverslist.html To identify Wild and Scenic Rivers
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Wild and Scenic Rivers Exceptions:
Acquisition of existing structures Rehabilitation of existing structures
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Wild and Scenic Rivers
Applies to designated rivers Study within 1 mile of site For: • new construction • change of use, • major rehab and • acquisition of land
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Standards Aquifers Endangered Species Rivers Air
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Air Quality 24 CFR Part 58.5(g)
•
Is the site in a Non attainment Area? Local Requirements on SIP?
•
•
Will Project impact?
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Air Quality 24 CFR Part 58.5(g) Exceptions:
Actions outside non-attainment areas Emission levels below de minmus level Rehabilitation activities Acquisition for continued use Land banking (required when site is developed)
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Air Quality 24 CFR Part 58.5(g) Additional Issues:
Demolition and Rehab • Comply with EPA and State Laws (emissions, asbestos & lead) Project proximity to other sources such as: • Stack emissions • Roads
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Stadards Aquifers Endangered Species Rivers Air Farmlands
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Farmlands Protection Act 24 CFR Part 58.5(h) Avoid impact to farmlands designated as : Prime Unique State or Local Importance
• • •
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Farmlands Protection Act
Exceptions: Rehabilitation of existing buildings Acquisition of existing buildings
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Farmlands Protection Act Applies to: New construction Land acquisition Outside Urban areas
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Farmlands Protection Act If outside an urban area: Consult “Important Farmland Map” from NRCS;USDOA
www.nrcs.usda.gov/technical/NRI/maps/meta/m5970.html
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Farmlands Protection Act
If site is indicated on map: conduct analysis using form AD1006 • If it meets threshold, contact NRCS
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands HUD Env. Standards Aquifers Endangered Species Rivers Air Farmlands Coastal Zone
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Coastal Zones 24 CFR Part 58.5(c)
Coastal zone management Exceptions: Rehabilitation of structures Acquisition of existing structures
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Coastal Zones 24 CFR Part 58.5(c) Applies to: New construction Conversion of land use Major Rehabilitation Acquisition of undeveloped land
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Coastal Zones 24 CFR Part 58.5(c)
Avoid If not, • Increased compliance time • Obtain letter indicating project is Consistent with State Coastal Zone Management Plan
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Laws and Authorities 58.5
Historic Preservation Floodplain & Wetlands Coastal Zone Aquifers Endangered Species Rivers Air Farmlands HUD Env. Standards Environmental Justice
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Environmental Justice 24 CFR Part 58.5(j)
EO 12898 Addresses: • Disproportionate impact: adverse effects on human health environmental effects to low income and minority populations
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Environmental Justice
Exceptions:
Projects without adverse health effects
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Environmental Justice E.O. 12898
Is there an environmental impact or condition: • If yes, does the condition disproportionately affect: Low Income Minority
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Environmental Justice Applies to:
Disproportionate impact to low income and minority for: Acquisition of existing housing Acquisition land for development New Construction
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Laws and Authorities 58.6 OTHER Flood Insurance
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Laws and Authorities 58.6 OTHER
Flood Insurance
Coastal Barrier
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Laws and Authorities 58.6 OTHER
Flood Insurance
Coastal Barrier
Clear Zone notice
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Flood Insurance
Purchase of Flood Insurance is mandatory for properties assisted with HUD funds & located in the Special Flood Hazard Area (SFHA) 100 year flood plain
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Flood Insurance How Much – How long?
Grants: Life of the property * Even if title is transferred Amount of the project cost Loans: Life of the Loan Amount of the Loan
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Flood Insurance Exceptions
Formula Grants to State State Owned Property Loans of < $5,000 repaid in 1 year Leasing without rehab, acquisition or improvements Maintenance – very limited NOT Rehab • See maintenance memo from you FEO
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Coastal Barriers Coastal Barrier Resources Act
Prohibits Federal funding for projects in coastal barriers.
Consult DOI Maps
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Coastal Barrier Resources
Designated by: • US Fish and Wildlife • Coastal Barrier Maps and FEMA Maps Administered by: • NOAA with local CZM Agencies Covers: • Gulf of Mexico • Atlantic • Great Lakes
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Clearzone Notification
Notification mandatory for acquisition or leasing including minor rehab in Clearzone
Notice Signature
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