Date Published: May 2014
HUD has developed 2 forms which together complete the Part 50 environmental review for CoC Program leasing, Project Based Rental Assistance (PBRA), and Sponsor Based Rental Assistance (SBRA) projects. These include a form to be prepared by the recipient and submitted to HUD and a second form to be completed by HUD staff upon receipt of the recipient’s form. There should not be a need for Part 50 CENST reviews in the CoC Program.
The process for completion by HUD staff is as follows:
HUD has made a determination in the CoC Program No Potential to Cause Effects Memorandum that CoC Program leasing and rental assistance projects with no associated repairs or rehabilitation have No Potential to Cause Effects under Section 106 of the National Historic Preservation Act. This finding should significantly streamline the Section 106 process, as Responsible Entities need only include the memorandum with this finding in their Environmental Review Records to document compliance with that section. No consultation under Section 106 is required for projects that conform to the requirements described in this memorandum.
NOTE: These steps DO NOT require HUD staff to be physically onsite of a CoC Program project.