CoC FAQ
Q

Where is the exact citation (regulation, memo, other HUD guidance, etc.) where it lists sponsor-based and project-based rental assistance as falling under leasing with regards to environmental review?

Date Published: March 2014

Print ShareThis

A

The environmental regulations specify that tenant-based rental assistance is CENST (see 24 CFR 50.19(b)(11), 58.35(b)(1)) and that leasing is CEST (see 50.20(a)(4), 58.35(a)(5)). The environmental regulations are silent regarding project based rental assistance (PBRA) and sponsor-based rental assistance (SBRA), but they have long been interpreted as being equivalent to leasing because the funding is attached the unit or structure (like leasing) and not to the program participant (like TBRA). Therefore, HUD includes PBRA and SBRA intothe leasing category listed in 50.20(a)(4) and 58.35(a)(5). 


Tags: CoC Environmental Review

FAQ ID:

1485