9.1.2 — HUD Multifamily Accelerated Processing (MAP)

A. A complete project description is necessary to determine the correct approach to an environmental review. The project description should capture the maximum anticipated scope of the activity. All physical aspects of the project, such as plans for multiple phases of development, size and number of buildings, size of parcel(s), and activities to be undertaken should be included in the description, as well as details of the physical impacts of the project, including whether there will be ground disturbance.

HUD must aggregate together related activities when determining what should be included as part of the project. Where a multifamily parcel that secures the FHA mortgage is part of a larger site, the project should be defined as the multifamily parcel plus the parts of the rest of the site that are directly related to the multifamily development (access roads, parking, storm water detention systems, open spaces, utility connections, etc.). What gets defined as directly related is contextual; it depends on project circumstances and may vary from project to project.[20] Note that off-site improvements that may be included as part of an aggregated environmental review are not to be considered for the purposes of calculating Davis-Bacon wage rates.
- For all projects, the environmental review can and often must extend beyond the defined project boundaries in order to comply with the laws and authorities. The area of impact may differ based on the individual 50.3(i) or 50.4 authority under review and the type of activity undertaken. For example, an Area of Potential Effect considered under the National Historic Preservation Act can extend beyond the boundaries of a project site, especially if a project is in a historic district. Similarly, off-site endangered species may be impacted by the FHA action.

In most cases, the Lender is required to cover only the FHA collateral parcel for the Phase I Environmental Site Assessment conducted under ASTM E1527-13. (This applies to ASTM E152713 in-scope items only). However, the Phase I Environmental Site Assessment must consider the impact of contamination from offsite parcels on the collateral parcel. Remediation would be required for non-collateral areas only to the extent the hazard could affect the health and safety of occupants of the property securing the mortgage or conflict with the intended utilization of the property and as per Section 9.4.7.

B. Housing staff are considering an application for FHA mortgage insurance at a particular site and therefore are limited to considering three alternatives: the action as proposed, modifications within the aggregated project site, or no action, i.e., rejection of the application. This applies to the Environmental

20 For examples, visit https://www.hudexchange.info/programs/environmental-review/housing/#faq.

MAP Guide, March 2021 Go to beginning of Chapter 9

Bookmarked Version Go to Acronym and Abbreviation List, Glossary, Index

Chapter 9 Page 9-2

To return to this page after clicking a link, press ALT + Back Arrow

Chapter 9 Environmental Review and Requirements 9.1 Introduction

Go to Table of Contents

Assessment, floodplain and wetland 8-step, and any other law and authority that requires alternative analysis.