What level of environmental review is required for Tenant Based Rental Assistance (TBRA) in the CoC Program?

Date Published: May 2014

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For purposes of conducting an environmental review, “tenant-based rental assistance” is defined as rental assistance that is attached to the program participant and not the unit (meaning that the program participant would be free to select their own unit). Where the program participant selects the location, providing TBRA is Categorically Excluded Not Subject to 58.5 (CENST) (see 24 CFR 58.35(b)(1)). The environmental review record for TBRA is very limited and can generally be completed quickly. View formats for completion of a CENST review.

In the CoC Program, recipients and subrecipients providing TBRA may limit where program participants may live when necessary to facilitate the coordination and delivery of supportive services. Recipients may require program participants to live in a specific area for their entire period of participation, in a specific structure for the first year, and in a specific area for the remainder of the period of participation. In addition, program participants receiving rental assistance in transitional housing may be required to live in a specific structure for their entire period of participation in transitional housing (see 24 CFR 578.51(c) for more information). When this occurs and the recipient defines the location where the program participant may rent, the project is considered leasing for purposes of the level of review. In this case, the project requires a “limited scope” Categorically Excluded Subject to 58.5 (CEST) environmental review. View format and instructions for completion of a limited scope CEST review.

Tags: CoC Environmental Review

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