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Environmental Review Requirements

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ENVIRONMENTAL REVIEW (ER) 

An environmental review is the process of reviewing a project and its potential environmental impacts to determine whether it meets federal, state, and local environmental standards. 

The environmental review process is required for all HUD-assisted projects to ensure that the proposed project does not negatively impact the surrounding environment and that the property site itself will not have an adverse environmental or health effect on end users. 

An environmental review must be performed before any funds, regardless of source, are committed to a project.

Admin dollars are cleared on the front end and does not require action by the recipient. However, below is an exception:

  • Federal funds pays for the recipient’s office space - move or secure additional space
  • The new office must be environmentally cleared prior to you signing a lease. 

All other activities, funded in part or whole with federal funds, require an individual environmental review prior to expending funds. 

Requirements for Housing Development / Construction Projects

  • Request for environmental review form
    • Complete address – N, S, SW, NW…..
    • Zip code
  • Section 106 Review
    • Conditions that can be cleared initially
    • Mitigation Plan for conditions that cannot be cleared initially
  • Detailed Scope of Work
  • Tax Assessor Information Page and Map
  • After Rehabilitation Value
  • Photos of property
  • Phase I environmental site assessment - if required

Requirements for Public Service Projects

  • Request for environmental review form
    • Complete address – N, S, SW, NW…..
    • Zip code
  • Description of activity

Service Level Agreement - SLA

  • Exempt & Categorically Excluded Not Subject-to (CENST)
    • Administrative expenses; shelter operations; down payment assistance; tenant based rental assistance; project design and engineering costs; etc.
    • Requirements:  7-10 business days for preparation and execution
  • Categorically Excluded Subject-to (CEST)
    • Owner-occupied rehabilitation; rehabilitation of vacant single family or multi-family properties; disposition of property; demolition; project based rental assistance; master leasing; upgrading existing public facilities; Park improvements; ADA improvements; business improvement loans; etc.
    • Requirements, if exemptions apply: 10-15 business days
    • Requirements, if exemptions do not apply: minimum of 37 days -15 days for preparation of assessment and 22 day public comment period
  • Environmental Assessment (EA)
    • New construction; significant land use changes; construction of industrial complexes or new recreation centers in parks; acquisition and acquisition/reconstruction;
    • Requirements: a minimum of 45 business days - 15 business days for preparation of assessment 30 day public comment period

Choice Limiting Actions (24 CFR 58.22) 

All environmental review requirements must be met PRIOR to taking any choice limiting actions. Choice limiting actions include physical activities or other actions that limit options to choose another site for the project.  

Under no circumstances can DGCD commit or expend HUD funds prior to the completion of the environmental review.  

The following actions are "choice-limiting" and CANNOT be taken prior to the environmental review:

  • Purchasing or leasing property
  • Executing a legally binding agreement or contract
  • Initiating the procurement process
  • Taking any physical actions on the property that could have an adverse impact or limit the choice of reasonable alternatives, including demolition, dredging, filing, excavating, repairing, rehabilitating or constructing 

Aggregation 

All pre-determined work MUST be identified for the project scope. Activities will be aggregated into a single ER. 

Aggregating projects increases efficiency and evaluates the entire project footprint for environmental impact. 

For example – If the scope of work for your organization’s project is to acquire a property now with the intent to start new construction thereafter, your ER Request must state “Acquisition and New Construction.” 

Project

Project means an activity, or group of integrally related activities, designed by the recipient to accomplish in whole or in part, a specific objective.

Submission Instructions

All submissions and communications should be submitted to the Environmental Review inbox - gmenvironmentalreview@AtlantaGa.Gov

Forms and Resources