9.6.20 — HUD Multifamily Accelerated Processing (MAP)

A. An Environmental Assessment (EA) level review requires compliance with NEPA in addition to the laws and authorities listed at Section 9.3.G.1 and the additional Housing Specific requirements at Section 9.6.19 When an EA level of review is required (See Section 9.1.3.C.5), HUD will require and analyze information to determine if the project results in any significant impact and if an environmental impact statement is needed.

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Chapter 9 Environmental Review and Requirements 9.6 Environmental Laws and Authorities

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B. The following are EA requirements that must be included in the HEROS submission[60] :

Purpose and Need : HUD’s EA review requires a project justification that outlines the objectives of the environmental review. The purpose and need statement provides a framework for environmental decision-making.
Existing Conditions and Trends : HUD’s EA review must determine existing physical conditions of the project area and also describe the character, features and resources of the project area and its surrounding. This section should identify the trends that are likely to continue in the absence of the project.
Effects Analysis : HUD’s EA review must consider any changes to the human environment that are reasonably foreseeable and have a reasonably close causal relationship to the HUD project. Consistent with 40 CFR 1508.1(g), HUD’s EAs must discuss both effects that occur at the same time and place as the proposed project and any effects that are farther removed in time or distance from the project area (e.g. potential changes to the land use and development patterns of the surrounding community.) This analysis must include the full aggregated project site.
Alternatives : Projects must always consider the No Action alternative. HUD staff are considering an application for FHA at a particular site and therefore are limited to considering three alternatives: the action as proposed, modifications within the site controlled by the applicant, or no action, i.e., rejection of the application.
Environmental Assessment Factors : The EA must analyze the project’s impacts on land development, socioeconomic factors, community facilities and services, and natural features.[61] The analysis will vary from project to project. For example, a project designed to house families will focus on access to schools, parks and recreation while a project designed to house seniors would instead focus on healthcare and social services. Some EA factors are listed below. For a full list with suggested resources, see footnotes in this section.
- Conformance with comprehensive plans, zoning compatibility, site safety, energy consumption, and urban impact.

Availability of services like educational facilities, commercial facilities, health care and social services.
Availability of supporting infrastructure such as solid waste, wastewater, storm water, and access to municipal water supply, public safety (Police, Fire, and Emergency Medical Services), open space and recreation, cultural facilities, and transportation.

60 Additional details and examples of the EA requirements provided at

https://www.hudexchange.info/programs/environmental-review/housing/#faq. The HEROS Partner EA form also gives a good overview of EA requirements, which can be found at https://files.hudexchange.info/resources/documents/Environmental-Assessment-Factors-and-Analysis-PartnerWorksheet.docx.

61 Guidance on considering EA factors can be found at

https://files.hudexchange.info/resources/documents/Environmental-Assessment-Factors-Guidance.pdf.