Is an environmental review required for units assisted with CoC Program rental assistance funds [Tenant-Based Rental Assistance (TBRA), Sponsor-Based Rental Assistance (SBRA), and Project-Based Rental Assistance (PBRA)]?

Date Published: March 2014

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Yes, all CoC Program projects require environmental reviews. Reviews for TBRA, SBRA, and PBRA may be conducted by the CoC Program recipient under Part 58 if the recipient is a unit of government or HUD per Part 50 if the recipient is not of a unit of government and a Responsible Entity does not have the capacity to conduct an environmental review. Tenant-based rental assistance is Categorically Excluded Not Subject to 58.5 (CENST), because the rental assistance is attached to the program participant and not the unit. CoC Program leasing, sponsor-based rental assistance, and project-based rental assistance are a higher level of review, Categorically Excluded Subject to 58.5 (CEST), because the rental assistance is attached to the unit.

If a CoC Program recipient is completing an environmental review for one of these activities under Part 58, consult with your Field Environmental Officer for information on how to conduct a limited scope review. Again, environmental reviews should cover the entire building or site, and are generally good for five years. 

Tags: CoC Environmental Review

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