Date Published: March 2014
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.