vermont community development program · what do you mean i can’t go out to bid for construction...

Environmental Review TrainingVermont Community Development Program

Quin Mann, Environmental Officer

July 2019

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Overview- Environmental Reviews (ER’s)• Introduction: Why & When• Choice-Limiting Actions/Activities• The Environmental Review Process

1. Define the Project (Project Description)2. Determine the Level of Review3. Perform the ER Analysis and Document

Compliance (Supporting Documents and Checklist)4. Finalize ER and publish applicable notice5. Receive the ER Release6. Expend Project Funds7. Post Review Consideration- confirm required

mitigation measures were implemented (Environmental Review Conditions)

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Why Environmental Reviews?

The purpose of the ER is to assess the impacts of the project on the environment and the impacts of the environment on the project;involve the public in the decision-making

process; and make better-informed decisions.

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Why Environmental Reviews?

• Clients: Protect health and safety• Environment: Avoid or mitigate harm• Ensure: Funds can be used as desired• Avoid: Litigation• Required (Federal Funds):

National Environmental Policy Act (NEPA)

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Federal Funds

ACCD/DHCD receives and administers Community Development Block Grants (CDBG)

allocated to the State of Vermont by the U.S. Department of Housing & Urban

Development (HUD)

CDBG Funds $

Vermont Municipalities(State Grantee,

Subrecipient of Federal Funds)

ACCD/DHCD (Federal Grantee)

Vermont Community Development Program

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When Does an ER Need to be Completed?

•Short Answer: As Early in the Process as Possible

• Open the ER at the same time an application is opened (or before)

•Long Answer: It depends…

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Choice Limiting ActivitiesEngaging in these activities prior to the

approval of the ER compromises the unbiased consideration of alternatives and

is therefore disallowed.

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Choice Limiting Activities (as defined by HUD)• Acquisition or Leasing of property (Allows an Option

Agreement but NOT a Purchase and Sales Agreement)• Commitment or expenditure of CDBG funds or non-CDBG

funds (for choice-limiting activities)• Entering into commitment for repair, rehabilitation,

construction or demolition• Commitment=legally binding contract or agreement

• Going out to bid for construction activities• Initiating project activities (on the ground work)

NOTE: Planning Activities are NOT Choice-Limiting(Except for Planning Grants!)

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What do you mean I can’t go out to bid for construction activities!?

Pre-development work is tied directly to future construction and I need start pre-development work

early on (and to adequately complete the Environmental Review)!

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Going out to Bid for a Construction Manager• Initial Bid: Scope of work limited to Preconstruction &

Bid Services• Note the potential for an award of a construction

contract PENDING funding/HUD Environmental Review Approval

• See Language that should be included in the RFP and Contract for a Construction Manager Provided

The Solution…

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CM will be awarded a contract for preconstruction services. The CM selected for preconstruction services may be awarded a separate contract for construction services.

The contract for construction services would not be awarded until after the Vermont Department of Housing and Community Development has issued an Environmental

Review Release, which will signify the completion of the Environmental Review and the proposed project’s compliance with the provisions of the National Environmental Policy Act of 1969 and HUD regulations at 24 CFR Part 58. The Entity may terminate the CM’s preconstruction phase contract prior to the construction phase and seek competitive public bids for the construction phase. There is no guarantee the construction phase

contract will be awarded.

Language to include in RFP for CM (Handout)

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Contracting with a Construction ManagerTwo Part Contract: • AIA Document A133-2009- Standard Form of Agreement

Between Owner and Construction Manager • Contract for pre-development work signed before

ER Release• AIA Document A201-2007 General Conditions of the

Contract for Construction• Contract for Construction Signed after ER Release

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There is no guarantee the construction phase contract will be awarded. The construction phase contract would not be awarded until after the Vermont

Department of Housing and Community Development has issued an Environmental Review Release, which will signify the completion of the Environmental Review and the proposed project’s compliance with the

provisions of the National Environmental Policy Act of 1969 and HUD regulations at 24 CFR Part 58.

Language to include in Contract for CM (Handout)

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Quick Note on ProcurementIf you plan on using VCDP Funds to pay for project activities (planning and implementation work), these services need to be procured properly!

Specific Procurement Processes are Required for Costs >$10,000

Questions on Procurement Requirements: [email protected]

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mailto:[email protected]

When Does an ER Need to be Completed?

•Long Answer: It depends…• Appropriate timing for a specific

project’s ER is mostly dependent on the project’s anticipated timeline for initiating choice-limiting activities.

• Completed ER is not required as part of the application.

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Who Should Complete the ER?• A Consultant? (with experience in completing HUD ER’s)

• Not Required, but…• Recommended for larger or more complex projects

• Anyone who is involved with the project can complete the ER, including (but not limited to):

• Project Managers• Town Employees• Community Development Consultants• Planning Commission or Dev. Corp. Employees

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PLEASE NOTE: If the individual who has been tasked with completing the ER is unfamiliar

with the ER process, a meeting with the Environmental Officer before initiating the ER

process is required.

Who Should Complete the ER?

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Environmental Review Process0. Open the Environmental Review in the GEARS System1. Define the Project (Project Description)2. Determine the Level of Review3. Perform the ER Analysis and Document Compliance

(Supporting Documents and Checklist)4. Finalize ER and publish applicable notice5. Receive the ER Release6. Expend Project Funds7. Post Review Consideration- confirm required mitigation

measures were implemented (Environmental Review Conditions)

NOTE: These ERs are being completed at the EXEMPT LEVEL, they are NOT EXEMPT from the ER process. 18

Handouts that Have Been Provided..1. Compliance Guidance & Checklist Requirements2. Construction Manager RFP & Contract Language3. Level of Environmental Review Regulations

(24 CFR 58.34, 58.35 & 58.36)4. VCDP Section 106 Preliminary Review Form5. ACHP Policy Statement on Affordable Hosing6. VCDP Architectural & Archaeological Consultant List 7. Floodplain Management Worksheet8. Floodplain Management Exemptions (24 CFR Part 55.12)9. 8-Step Decision Making Process Guidance


https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-ComplianceGuidance.pdf

https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-Regulations.pdf

https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HPIntake.docx

https://www.achp.gov/digital-library-section-106-landing/achp-policy-statement-affordable-housing-and-historic

http://accd.vermont.gov/sites/accdnew/files/documents/HP/Vermont%20Community%20Development%20Approved%20Consultants%202017-2018.pdf

https://www.hudexchange.info/resources/documents/Floodplain-Management-Worksheet.docx

https://www.law.cornell.edu/cfr/text/24/55.12

https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-8StepGuidance.pdf

Handouts that Have Been Provided..10. Wetland Protection Worksheet11. Using a Phase I Environmental Site Assessment to Document Compliance with HUD Environmental Standards at 24 CFR 58.5(i)(2) or 50.3(i)12. Environmental Assessment Questions/Guidance

13. Act 250 Coordination Guidance Document

14. HTF Review Cheat Sheet


https://www.hudexchange.info/resources/documents/Wetlands-Protection-Worksheet.docx

https://www.hudexchange.info/resource/4829/using-a-phase-i-environmental-site-assessment-to-document-compliance-with-hud-environmental-standards-at-24-cfr-585i2-or-503i/

http://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-AssessmentQuestions.pdf

https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HTFCheatSheet.pdf

Step 0. Open the Environmental Review in the GEARS System

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Communication with Municipality is Key!The Municipality is the Responsible Entity• If the municipality hasn’t yet opened up a CDBG application for

the potential project, explain that the ER part of the planning process and initiating and completing the ER needs to be done to allow for CDBG funds to be an option for the project.

• Opening the ER does not mean the municipality is fully supporting the project/a future application at this time. There is a public hearing process that the community must go through prior to submitting an application for CDBG funds.

• Contact myself to help support this communication if needed.

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Step 1. Define the Project

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The Project Description is…VERY IMPORTANT !

• If an activity or project component is being added after the ER Release and that component was not included in the project description for the ER, a new ER may be required

• All project components need to be included in the scope of the Environmental Review for adequate analysis of project impacts

• If there are some components that are potential project activities, still include them in the project description and identify them as potential activities (ex. use of solar panels)

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Project Description• Capture the maximum scope of

the proposal, not just what the HUD funding will be covering

• Include activity type such as acquisition, new construction, major rehab, minor rehab, demolition, repair, etc.

• If a housing project, include details about number and type of units

• Size of parcel and any existing buildings

• Existing conditions/property use • Scope of work to be performed• Approximate area of proposed

ground disturbance• Changes that will be made to

the structure(s)/land (ex. increase in building footprint)

• Funding sources: HUD funded amount and total project cost (including Section 8 Project Based Vouchers and Risk Share!)

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Step 2. Determine the Level of ReviewDetermined by Scope of Project Activities

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Level of Environmental Review

3 Potential Levels of Review for our Purposes

• Exempt/CEST: Exempt/Categorically Excluded NOT Subject to (58.5)• CEST: Categorically Excluded Subject to (58.5)• EA: Environmental Assessment

Graphic courtesy of HUD WISER Webinar• EIS: Environmental Impact Statement (N/A for our purposes) 27

Exempt ER’s (58.34 & 58.35(b))• Planning Grants• Public Service Grants• Homeowner Assistance Grants• Equipment purchase or working capital for economic

development (when NO expansion of business or construction is involved)

• Urgent Need Grants (Federally Defined)

NOTE: These ERs are being completed at the EXEMPT LEVEL, they are NOT EXEMPT from the ER process.

PLEASE NOTE: These ERs are being completed at the EXEMPT LEVEL, they are NOT EXEMPT from the ER process.

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Categorically Excluded vs. AssessmentCategorically Excluded• Minor Rehab• Increase in Occupancy or Footprint <20%• No Change in Land Use• 7 day comment period, 15 day objection periodAssessment Level• Everything Else!! (ex. New Construction)• 15 day comment period, 15 day objection period

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Categorically Excluded Thresholds (58.35)

(1) Acquisition, repair, improvement, reconstruction, or rehabilitation of public facilities and improvements (other than buildings) when facilities and improvements are in place and will be retained in the same use without change in size or capacity of more than 20 percent

(2) Special project directed to the removal of material and architectural barriers that restrict the mobility of and accessibility to elderly and handicapped persons

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Categorically Excluded Thresholds (58.35)(3) Rehabilitation of buildings and improvement when the following

conditions are meti. In the case of building for residential use (with one to four units), the density is

not increase beyond four units and the land use is not changedii. In the case of multifamily buildings:

A. Unit density is not changed more than 20 percent; B. The project does not involve changes in land use from residential to non-residential; andC. The estimated cost of rehabilitation is less than 75 percent of the total estimated cost of

replacement after rehabilitationiii. In the case of non-residential structures, including commercial, industrial and

public buildings: i. The facilities and improvements are in place and will not be changed in size or capacity by

more than 20 percent; andii. The activity does not involve change in land use, such as from non-residential to

residential, commercial to industrial, or from one industrial use to another

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Categorically Excluded Thresholds (58.35)(4)

i. An individual action on up to four dwelling units where there is a maximum of four units on any one site. The units can be four one-unit buildings or one four-unit building or any combination in between; or

ii. An individual action on a project of five or more housing units developed on scattered sites when the sites are more than 2,000 feet apart and there are not more than four housing units on any one site.

iii. Paragraphs (a)(4)(i) and (ii) of this section do not apply to rehabilitation of a building for residential use (with one to four units)(see paragraph (a)(3)(i) of this section.

(5) Acquisition (including leasing) or disposition of, or equity loans on an existing structure, or acquisition (including leasing) of vacant land provided that the structure or land acquired, financed or disposed of will be retained for the same use(6) Combination of above activities.

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Step 3. Perform the Environmental Review Analysis and Document

ComplianceSupporting Documentation & Checklist

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Overview of what Factors are looked at for Each Level of Review

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Exempt ER’s: Factors that are Considered• Flood Insurance• Airport Clear Zones• Coastal Barrier Resources

• Historic Preservation• Wild & Scenic Rivers• No Public Notice Period

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Compliance Factors For Categorically Excluded and Environmental Assessment Level Reviews• Historic Preservation

• Floodplain Management

• Wetland Protection

• Endangered Species Act

• Wild and Scenic Rivers Act

• Farmland Protection

• Explosive and Flammable Hazards

• Noise

• Toxic Sites (Site Contamination, Lead, Asbestos, Mold)

• Environmental Justice

• Radon

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Additional Compliance Factors Specific to Environmental Assessments (Also known as NEPA Analysis)

Land Development

Socioeconomic

Community Facilities and Services

Natural Features

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Level of Environmental Review

• 58.6: Flood Insurance, Airport Clear Zones, Coastal Barrier Resources

• 58.5: AdditionalStatutory Requirements

• Exempt/CEST: Exempt/Categorically Excluded NOT Subject to (58.5)• CEST: Categorically Excluded Subject to (58.5)• EA: Environmental Assessment Graphic courtesy of HUD

WISER Webinar• EIS: Environmental Impact Statement (N/A for our purposes) 38

Statutory Requirements24 CFR 58.5 and 58.6 Laws and Authorities

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Statutory Requirements24 CFR 58.6 Laws and Authorities

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Flood InsuranceFlood Disaster Protection Act of 1973 & National Flood

Insurance Reform Act of 1994[42 USC 4001-4128 and 42 USC 5154a]

Linked Closely to Floodplain Management Requirements-Discussed Later

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Coastal Barrier ResourcesCoastal Barrier Resources Act (as amended)

N/A- Vermont has no Coastal Barrier Resources

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Airport Clear Zones/Hazards24 CFR Part 51, Subpart D

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Airport Clear Zones/Hazards-Compliance


1. Locate the two Part 139-Certified Airports in Vermont• Burlington International Airport• Rutland Regional Airport2. Determine if the subject property is located within 2,500 feet (approx. 0.5 miles) from the end of the runway from either Part-139 Certified Airports• If within 2,500 feet, then the project area may fall within the Runway

Protection Zone/Clear Zone (RPZ/CZ)3. To determine the exact size, of the RPZ/CZ, the airport operator or the Federal Aviation Administration (FAA) should be contacted to obtain a map of the airfield.Documentation• Map showing outline of project property, location of both airports and

corresponding distances

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Statutory Requirements24 CFR 58.5 Laws and Authorities

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Historic PreservationNational Historic Preservation Act of 1966 (Sections 106 & 110)

36 CFR Part 800

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Historic Preservation (Section 106)- Compliance1. Complete a Section 106 Preliminary Review Form

(PRF) for the project (include all potential work)2. Submit to the VT Division for Historic Preservation

(DHP) or the Environmental Officer (for exempt properties and/or activities)

3. If additional consultation is required hire a consultant from the VCDP Approval Consultant List (be sure to provide your hired consultant with the PRF so they are aware of any comments from DHP)

4. Receive concurrence from DHP


Historic Rehabilitation Tax Credit Approval by the NPS CAN SATISFY

Section 106 Review Requirements except for ground disturbance!

Section 106 Review Approval CANNOT SATISFY

Historic Rehabilitation Tax Credit Review

If Your Project Involves Federal Historic Preservation Tax Credits, Please Remember…

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Projects applying for Historic Tax Credit must be reviewed by the National Park Service for adherence to the Secretary of Interior

Standards in a SEPARATE and DISTINCT PROCESS. Review for tax credit process is more comprehensive than Section 106 Review.

Section 106 Review is NOT Rehabilitation Tax Credit Review.

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Completing the Section 106 Preliminary Review Form


• Anyone can fill out this form!

• Initiates Section 106 required for the HUD ER Process

• Functions as an administrative tool for VCDP Environmental Officer tracking

• Provides a clear response from the SHPO on if additional consultation is needed or not

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1) Replace roof…


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Question 5F: The only projects that answer “Yes” to this question are Scattered Sites Revolving Loan Funds, majority of projects will answer “No” to this question.

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Question 5G: This question is VERY important. If a project indicates Tax Credits are NOT being pursued, receives Section 106 concurrence from DHP, but THEN determines Tax Credits will be pursued at a later time, the existing Section 106 approval in NO WAY guarantees that a project will receive Tax Credit Approval from the National Park Service.

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Question 5H: If your project is a housing project and you are eligible for funding through the VCDP, your answer to Question 5H will be Yes. (Unless...your project is an economic development project that also includes market-rate housing).

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ACHP Policy Statement


Implementation Principles

I. Rehabilitating historic properties toprovide affordable housing is a soundhistoric preservation strategy.

II. Federal agencies and State and localgovernment entities assuming HUD’senvironmental review requirements areresponsible for ensuring compliancewith Section 106.

III. Review of effects in historic districtsshould focus on exterior features.

IV. Consultation should consider the overallpreservation goals of the community.

V. Plans and specifications should adhere tothe Secretary’s Standards when possibleand practical.

VI. Section 106 consultation shouldemphasize consensus building.

VII. The ACHP encourages streamlining theSection 106 process to respond to localconditions.

VIII. The need for archeologicalinvestigations should be avoided.

http://www.achp.gov/docs/fr7387.pdf

Advisory Council on Historic Preservation Policy Statement on Affordable Housing and Historic Preservation

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Historic Preservation- ThresholdsExempt Properties (5a-d on PRF)

• Building is less than 50 years old;• Building is not listed (or eligible to be listed) on the

National Register of Historic Places, or located within a historic district, AND

• Project does not involve ground disturbanceExempt Activities (5k on PRF)

• Appendix A of VCDP Programmatic Agreement


*Every project requires a PRF regardless of if it qualifies as Exempt

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Question 5k: Not a rehash of the project narrative, but rather an explanation of how the project scope follows the ACHP policy statement implementation guidelines.

Question 5J: Refer to Appendix A of the Programmatic Agreement to answer this question. Form Is being updated to link directly to Appendix A, as it did previously.

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ACHP Policy Statement


Implementation Principles

I. Rehabilitating historic properties toprovide affordable housing is a soundhistoric preservation strategy.

II. Federal agencies and State and localgovernment entities assuming HUD’senvironmental review requirements areresponsible for ensuring compliancewith Section 106.

III. Review of effects in historic districtsshould focus on exterior features.

IV. Consultation should consider the overallpreservation goals of the community.

V. Plans and specifications should adhere tothe Secretary’s Standards when possibleand practical.

VI. Section 106 consultation shouldemphasize consensus building.

VII. The ACHP encourages streamlining theSection 106 process to respond to localconditions.

VIII. The need for archeologicalinvestigations should be avoided.


Advisory Council on Historic Preservation Policy Statement on Affordable Housing and Historic Preservation

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FAQ: Where Can I Find the VCDP PA?1. Linked at the end of the Section 106 Preliminary

Review Form (To Be Updated):


FAQ: Where Can I Find the VCDP PA?2. Environmental Review Webpage on VCDP’s Website:http://accd.vermont.gov/community-development/funding-incentives/vcdp/env-review


http://accd.vermont.gov/community-development/funding-incentives/vcdp/env-review

VERMONT COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAMHistoric Preservation Project Review

Appendix A – HUD-Funded CDBG Programs Exempt Activities

As noted in Section II (1)(c): If activities are limited solely to those activities listed in Appendix A then such activities are considered exempt from this Programmatic Agreement. This determination is made in consultation with the Recipient and VDHP through submittal of the Preliminary Review Form to VDHP for concurrence and for VDHP and Agency files. No further review is required.

The following activities will not require review by the SHPO or Council:

1. Non-Historic Buildings and Structures. Rehabilitation of non-historic buildings and structures, (i.e. those less than 50 years old),except when alteration to the existing building or structure may impact a surrounding historic district. New construction is not an exempt activity.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities2. Mechanical, Electrical, Plumbing (MEP) Systems. Repair, replacement and installation of MEP systems provided that such work does not involve ground disturbance, alter or permanently change the appearance of the interior or the exterior of the building, affect character-defining features of the building, or require the installation of new ducts through the interior: electrical work; plumbing pipes and fixtures; heating system improvements; installation of fire and smoke detectors; ventilation systems; and bathroom improvements where work is contained within the existing bathroom. Please refer to Preservation Briefs 24: Heating, Ventilating, and Cooling Historic Buildings: Problems & Recommended Approaches, and other technical briefs, as appropriate, for guidance.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities3. Exterior painting. Repainting of exterior surfaces provided that destructive surface preparation treatments, including, but not limited to waterblasting, sandblasting, destructive sanding and chemical cleaning are not used. Please refer to Preservation Briefs 10: Exterior Paint Problems on Historic Woodwork, and other technical briefs, as appropriate, for guidance.

4. Exterior Repairs. Repair or partial replacement of deteriorated porches, cornices, exterior siding, doors, balustrades, stairs, or other trim when the repair or replacement is done in-kind to closely match existing material and form and does not involve ground disturbance. The removal of distinctive materials or alterations of features, spaces, and spatial relationships that characterize a property will be avoided. Please refer to Preservation Briefs 47: Maintaining the Exterior of Small & Medium Size Historic Buildings, and other technical briefs, as appropriate, for guidance.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities

5. Windows. Caulking; weather-stripping; reglazing and repainting of windows; installation of new window jambs or jamb liners; repair, replacement or installation of storm windows (exterior, interior, metal or wood) provided they match the historic shape and size of the historic prime windows and that the meeting rail coincides with that of the prime window. Color should match trim, if possible.

Replacement windows is not an exempt activity. If replacement windows are being proposed, the Consultant must provide a statement as to the condition of existing windows, why the existing windows cannot be retained, and/or cost considerations of retaining existing windows vs. installing replacements, and rationale for the design and selection of new windows, along with how these will meet the Secretary of the Interior’s Standards for Rehabilitation.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities6. Roof Repair. Roof repair of historic roofing with material that closely matches the existing design and form. When repairing existing roofing, corrugated fiberglass roofing is not appropriate.

Replacement of non-historic roofing is not an exempt activity. Preservation Briefs 4: Roofing for Historic Buildings, and other technical briefs, as appropriate, for guidance.

7. Gutters. Repair, replacement or installation of gutters and above ground downspouts.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities8. Insulation. Insulation in ceilings, attic, and basement spaces provided it is installed with appropriate

vapor barriers, such as the following: a) Air sealing of the building shell, including caulking, weather-stripping, and other air infiltration

control measures on windows and doors, and installing thresholds in a manner that does not harm or obscure historic windows or trim.

b) Thermal insulation, such as non-toxic fiberglass and foil-wrapped, in walls, floors, ceilings, attics, and foundations of wood-framed structures in a manner that does not harm or damage historic fabric and a mechanical ventilation system is present to direct moisture out of the building.

c) Dense-pack cellulose wall insulation in wood frame structures where no holes are drilled through exterior siding or where holes have no permanent visible alteration to the structure, and a mechanical ventilation system is present to direct moisture out of the building.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities9. Interior Surfaces (floors, walls, ceilings). Repainting, refinishing, repapering, replacing sheetrock

with sheetrock, replacing failing asbestos-containing plaster with traditional plaster system or veneer plaster on gypsum board, laying carpet or sheet flooring, or replacement of suspended ceiling tile.

10. Interior Trim. Repairing and retaining interior historic trim and features including doors, baseboards, chair rails, wainscoting, paneling, cornice trim, fireplace mantels, stair balusters, newel posts, window and door casings and other decorative features or replacement of flat stock trim.

12. Interior Floor Plan. Removal or alteration of non-historic interior walls.

15. Asbestos Abatement. Necessary removal of asbestos found in MEP and ventilation pipe joints provided it does not involve the removal of contributing historic elements.

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Appendix A – HUD-Funded CDBG Programs Exempt Activities14. Lead Paint Abatement. Interior lead paint abatement when it is limited to washing, scraping and repainting, wallpapering, and chemical stripping of lead-painted surfaces, installation of new window jambs or jamb liners, installation of metal panning in window wells, and replacement of flat stock trim. Exterior Lead Paint Abatement that includes scraping and repainting of exterior wood and masonry surfaces, so long as treatments follow established protocols and best practices as established by EPA Renovation, Repair & Painting Program (RRP Rule) and Vermont Essential Maintenance Practices – Lead Law Compliance. Please refer to Preservation Briefs 37: Appropriate Methods of Reducing Lead-Paint Hazards in Historic Housing, and other technical briefs, as appropriate, for guidance.

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VERMONT COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAMHistoric Preservation Project ReviewAppendix A – HUD-Funded CDBG Programs Exempt Activities

11. Site Improvements. Repair of existing roads, driveways, sidewalks, parking lots and curbs, if repairs are done with like material, and there are no changes in dimension or configuration of these features. Repair of fencing when work is done in-kind to closely match existing material and form.

13. Underground Utilities. Emergency repair of water, gas, electric, storm and waste water systems if it occurs within the original trench or footprint.

16. Minor Ground Disturbance due to Maintenance Activity. Soil disturbance to a depth of six (6) inches or less within an area of 100 square feet or less is permissible.

17. Plantings. Planting of grass, flowers, shrubs, or bushes in existing gardens or landscaped areas.

18. Test Holes and Wells. Structural test borings, well drilling and monitoring activities that do not require a temporary or permanent new access road to a site.

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Attachments are Crucial!!

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The Division for Historic Preservation (DHP) will check existing inventories:

• National Register of Historic Places• State Register of Historic Places• VT Historic Sites and Structures

Survey• VT Archaeological Inventory• Properties previously determined

eligible• Other SHPO files• Predictive Model

Section 106 PRF: DHP’s Review

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Section 106 PRF: DHP’s Review

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Where can I find the List of Approved Consultants?1. Linked at the end of the Section 106 Preliminary Review Form:


Where can I find the List of Approved Consultants?2. Environmental Review Webpage on VCDP’s Website:http://accd.vermont.gov/community-development/funding-incentives/vcdp/env-review



Archaeology-Compliance

1. Archaeological Resource Assessment (ARA)2. Phase IB3. Phase II4. Phase III

Be aware of time constraints!Archaeology cannot be conducted under winter conditions. If a site is found, it will take time to conduct investigations


• Project activities that trigger the need to consult these tribes include significant ground disturbance and new construction in undeveloped natural areas, full list of activities in Appendix E of the Programmatic Agreement.

• Stockbridge–Munsee Community has interest in Vermont• Rutland, Addison and Bennington Counties

• It is the responsibility of the Grant Recipient (or the qualified professional consultant on their behalf) to contact Tribal communities and provide them with the opportunity to comment.

• Please work with SHPO to contact the Tribal communities.

Archaeology-Potential for Tribal Consultation

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1. Archaeological Resource Assessment (ARA)A. Also known as a desk reviewB. Conducted by VDHP

a. Known sites in the vicinityb. Environmental Predictive Modelc. Historic Mapsd. Site visit


Archaeology-Compliance1. Archaeological Resource Assessment (ARA)2. Phase IB

A. Performed by an Approved ConsultantB. Systematic testing (surface collection, shovel test or trenching)C. Recommendations for further testing or mitigation



1. Archaeological Resource Assessment (ARA)2. Phase IB3. Phase II AND 4. Phase III

In the event that a site is found, subsequent phases serve to determine if the site is eligible for the National Register, and, if so, if the site can be avoided or adverse effects mitigated through further investigations.


Architectural Review-Compliance

1. Specifics of building rehabilitation/design need to be known for a Section 106 Letter with a Recommendation of Effect

2. Consultant can work with you to develop plans or review plans to provide recommendations to avoid, minimize, or mitigate adverse effects on historic resources.


SMMA-Potential Mitigation

If a Standard Mitigation Measures Agreement (SMMA) or a Memorandum of Agreement (MOA) is needed, this needs to be finalized and signed before completion of the Environmental Review.

Appendix D of the Programmatic Agreement lists the available SMMs such as photographic documentation, relocation, public education, historic contexts, data recovery etc.


Historic Preservation-Tips for a Successful Section 106 Review!


• Timing: Start as Early as Possible!• 30 day review window for every submission to DHP• Actual architectural/archeological review work takes

time as well• Include a thorough/detailed project description for

the PRF!• If a consultant is required, reach out to multiple

consultants for quotes and be sure to communicate the project’s timeline

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Historic Preservation-Tips for a Successful Section 106 Review!


• If a consultant is required, be sure to provide them with the PRF so they are aware of any comments made by DHP!

• Provide your consultant with detailed scope of work and proposed material selection

• In the consultant’s budget proposal, ask about including potential cost for Consultant Compliance Confirmation (CCC), if not already included

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Floodplain ManagementExecutive Order 11988 (Section 2(a))

24 CFR Part 55

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Floodplain Management-Compliance


1. Determine if the proposed project is located in a floodway, 100 or 500-year floodplain by creating a map using the FEMA Flood Map Service Center.• If the project is located in the floodway: determine if the

project qualifies as a functionally dependent use • If project is located in 100 or 500-year floodplain:

determine if the project qualifies as a critical action2. Complete HUD’s Floodplain Management Worksheet3. Determine if the project requires the 5-step or 8-step

decision making process4. Determine all other compliance and mitigation

requirements (ex. elevation and flood-proofing)

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Functionally Dependent Use


Functionally dependent use means a land use that must, by necessity, be conducted in close proximity to water.Including but not limited to:• Dam• Marina• Port facility• Waterfront Park• Bridges• Stream bank restoration

Please Note: All Federal Funds/Permits are subject to EO 11988, but the “Functionally Dependent Use” Restriction is HUD-Specific (55.1(C))

88

Critical Actions


Any activity for which even a slight chance of flooding would be too great, because such flooding might result in loss of life, injury to persons, or damage to property.Critical actions include activities that create, maintain or extend the useful life of those structures or facilities that:

• Produce, use or store highly volatile, flammable, explosive, toxic or water-reactive materials;• Provide essential and irreplaceable records or utility or emergency services that may become

lost or inoperative during flood and storm events (e.g., data storage centers, generating plants, principal utility lines, emergency operations centers including fire and police stations, and roadways providing sole egress from flood-prone areas); or

• Are likely to contain occupants who may not be sufficiently mobile to avoid loss of life or injury during flood or storm events, e.g., persons who reside in hospitals, nursing homes, convalescent homes, intermediate care facilities, board and care facilities, and retirement service centers. Housing for independent living for the elderly is not considered a critical action.

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Critical Actions


Critical actions include (but are not limited to) the following:• Emergency Services• Housing for sensitive populations, including hospitals and

nursing homes• Structures that hold sensitive documents• Facilities that store hazardous materials• Important public facilities

90

Determine if project is located in a floodway, 100 or 500-year floodplain by

creating a map using the FEMA Flood Map Service Center.

91

Include this information in the Checklist

92

If “Digital Data Not Available,” the FIRMettewill look like…

93

A project may be in an unmapped area: Now What..?

96

If a project location is outdated, unmapped or if there is any other uncertaintyaround whether a project is located in the floodway, 100-year or 500-year floodplain, contact the appropriate Department of Environmental Conservation Floodplain Manager.


Complete HUD’s Floodplain Management Worksheet

98


Question 1: Part 55 ExemptionsFloodplain Management Worksheet

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Floodplain Management-Exemptions (24 CFR 55.12(c))


(1) HUD-assisted activities described in 24 CFR 58.34 and 58.35(b); (AKA Projects completing an Environmental Review at the Exempt Level)(2) HUD-assisted activities described in 24 CFR 50.19, except as otherwise indicated in § 50.19; (N/A for our purposes, Part 50 is only applicable when HUD is carrying out the Environmental Review)(3) The approval of financial assistance for restoring and preserving the natural and beneficial functions and values of floodplains and wetlands, including through acquisition of such floodplain and wetland property, but only if:

(i) The property is cleared of all existing structures and related improvements;(ii) The property is dedicated for permanent use for flood control, wetland protection, park land, or

open space; and(iii) A permanent covenant or comparable restriction is placed on the property's continued use to

preserve the floodplain or wetland from future development.

(4) An action involving a repossession, receivership, foreclosure, or similar acquisition of property to protect or enforce HUD's financial interests under previously approved loans, grants, mortgage insurance, or other HUD assistance; (N/A for our program-as far as I know)

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(5) Policy-level actions described at 24 CFR 50.16 that do not involve site-based decisions; (N/A for our purposes, Part 50 is only applicable when HUD is carrying out the Environmental Review)(6) A minor amendment to a previously approved action with no additional adverse impact on or from a floodplain or wetland; (Update to Project Description/Environmental Review Record after Release has been issued)(7) HUD's or the responsible entity's approval of a project site, an incidental portion of which is situated in an adjacent floodplain, including the floodway or Coastal High Hazard Area, or wetland, but only if:

(i) The proposed construction and landscaping activities (except for minor grubbing, clearing of debris, pruning, sodding, seeding, or other similar activities) do not occupy or modify the 100-year floodplain (or the 500-year floodplain for critical actions) or the wetland;

(ii) Appropriate provision is made for site drainage that would not have an adverse effect on the wetland; and(iii) A permanent covenant or comparable restriction is placed on the property's continued use to

preserve the floodplain or wetland;


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(8) HUD's or the responsible entity's approval of financial assistance for a project on any non-wetland site in a floodplain for which FEMA has issued:

(i) A final Letter of Map Amendment (LOMA), final Letter of Map Revision (LOMR), or final Letter of Map Revision Based on Fill (LOMR-F) that removed the property from a FEMA-designated floodplain location; or

(ii) A conditional LOMA, conditional LOMR, or conditional LOMR-F if HUD or the responsible entity's approval is subject to the requirements and conditions of the conditional LOMA or conditional LOMR;

(9) Issuance or use of Housing Vouchers, Certificates under the Section 8 Existing Housing Program, or other forms of rental subsidy where HUD, the awarding community, or the public housing agency that administers the contract awards rental subsidies that are not project-based (i.e., do not involve site-specific subsidies);

(10) Special projects directed to the removal of material and architectural barriers that restrict the mobility of and accessibility to elderly and persons with disabilities;

(11) The approval of financial assistance for acquisition, leasing, construction, rehabilitation, repair, maintenance, or operation of ships and other waterborne vessels that will be used for transportation or cruises and will not be permanently moored. (N/A for our purposes-as far as I’ve seen)


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Projects that Require a(n) 5/8 Step Process


• Any project in the 100-year floodplain• A project that includes a critical facility in the

500-year (or 100-year) floodplain• A functionally dependent project in the floodway

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8-Step Decision Making Process• Defined in EO 11988• Analysis of the

proposed action• Analysis of

alternatives• Identify Mitigation• Two additional

public notices

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https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-8StepGuidance.pdf

Executive Order 11988 RequirementsRequires Federal agencies to avoid development in floodplains, wherever practicable, and requires HUD to develop regulations that establish standards (24 CFR Part 55)• When practicable, design or modify the proposed action to minimize the potential

adverse impacts within the floodplain and to restore and preserve its natural and beneficial values

• Minimization techniques may include measures such as use of permeable surfaces, storm water capture and reuse and green roofs

• New construction and substantial improvement projects must be elevated at or above the 100-year floodplain (Please Note: local floodplain management regulations may be more restrictive than federal requirements)

• Critical actions must be modified to include early warning system and emergency evacuation plans

Floodplain Management-Mitigation

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Executive Order 11988• Permeable surfaces• Natural landscape enhancements that maintain or restore

natural hydrology

• Planting or restoring native plant species • Bioswales• Evapotranspiration

Floodplain Management-Mitigation Options

• Stormwater capture and reuse• Green or vegetative roofs with drainage provisions

• Natural Resources Conservation Service conservation easements or similar easements

• Floodproofing of structures• Elevating structures including freeboarding above the

required base flood elevations

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Executive Order 11988

• Reinforcement of walls and foundation• Elevation of electrical and wiring and mechanical equipment• Plumbing and appurtenances will be located above flood

elevation or will be watertight and anchored • Submersible pumps will be provided to remove any seepage • ASCE 24-14 Flood Resistant Design and Construction

Floodplain Management-Mitigation Options

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• All critical actions in the 500-year floodplain shall be designed and built at or above the 100-year floodplain and include:• Preparation of and participation in an early warning system;• An emergency evacuation and relocation plan;• Identification of evacuation route(s) out of the 500-year

floodplain; and• Identification marks of past or estimated flood levels on all

structures.

Floodplain Management-MitigationCritical Actions

108

Flood InsuranceFlood Disaster Protection Act of 1973 & National Flood

Insurance Reform Act of 1994[42 USC 4001-4128 and 42 USC 5154a]

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Flood Insurance-ThresholdFlood Disaster Protection Act of 1973 (42 U.S.C. 4012a) requires that projects receiving federal assistance and located in an area identified by the Federal Emergency Management Agency (FEMA) as being within a Special Flood Hazard Areas (SFHA) (100-year floodplain) be covered by flood insurance under the National Flood Insurance Program (NFIP).• To be able to purchase flood insurance, the community

must be participating in the NFIP (and in good standing)


Flood Insurance-Exemptions• Formula grants made to states• Self-insured state-owned property within states approved

by the Federal Insurance Administrator consistent with 44 CFR 75.11

• Small loans ($5,000 or less)• Assisted leasing that is not used for repairs,

improvements, or acquisition


Flood Insurance-Compliance• For grants, flood insurance coverage must be continued for

the life of the building, irrespective of the transfer of ownership

The amount of insurance coverage required:• For loans, the amount of flood insurance coverage must at

least equal the outstanding principal balance of the loan or the maximum coverage of the NFIP, whichever is less.

• For grants, the amount of coverage must at least equal total project cost (excluding land costs) or the maximum coverage limit of NFIP, whichever is less.


Flood Insurance-ComplianceNFIP Maximums


Note: Primary coverage is for the building, contents are not automatically covered and generally require an additional premium

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Flood Insurance-Compliance

Responsible Entities (Municipalities) should be listed in the “2nd mortgagee/other” box on the Flood Insurance Application Form (or be listed as the loss payee). This will ensure that notice will be sent to that address if the policy is canceled or any changes are made.• Functions as an administrative tool to help ensure

that flood insurance is maintained for the life of the building or the term of the loan.


Wetland ProtectionExecutive Order 11990 (Sections 2 & 5)

24 CFR Part 55

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Wetland Protection Management-Compliance


1. Determine if project involves ground disturbing activities (defined on next slide)2. Identify any wetlands or potential for wetlands on or adjacent to proposed project

location3. Complete HUD’s Wetland Protection Worksheet4. Determine if the project requires the 8-Step Decision Making Process5. Determine all other compliance and mitigation requirements (ex. permit

requirements)

116

Wetlands-ThresholdsPotential for impact to wetlands needs to be considered when project involves:• Ground disturbing activities have the potential to

impact on site or nearby wetlands: new construction, expansion of a buildings footprint, draining, dredging, channelizing, filling, diking, impounding and related activities.


IMPORTANT NOTE:ALL wetlands are protected and must be considered, even if

they’re not mapped and even if they’re not under the jurisdiction of any regulating agency (ex. VT ANR or the Army

Corp of Engineers).

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• Create a Map on National Wetland Inventory

• Create a Map on Vermont Agency of Natural Resources’ Atlas

• A site visit to identify any potential wetlands must be conducted for every project. Consider the presence of drainage ways, streams, rivers, ponds, marshes, bogs, swamps, or other wetlands.

Identify the Potential for Wetlands

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If wetlands or potential for wetlands is identified, contact the appropriate Department of Environmental Conservation District Wetlands Ecologist.


Complete HUD’s Wetland Protection Worksheet

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https://www.hudexchange.info/resources/documents/Wetlands-Protection-Worksheet.docx


8-Step Decision Making Process• Analysis of the

proposed action• Analysis of

alternatives• Identify Mitigation• Two additional

public notices

Please Note: Should be combined with the 8-Step for Floodplain Management if both are applicable to a project

122

http://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-8StepGuidance.pdf

Executive Order 11990Instructs federal agencies to “avoid to extent possible the long and short term adverse impacts associated with the destruction or modification of wetlands and to avoid direct or indirect support of new construction in wetlands where there is a practicable alternative” (HUD implements EO 119900 in 24 CFR Part 55)After analyzing the impact, consider actions to minimize the negative impacts and restore and preserve the natural and beneficial functions and values of the wetland(s)• Limiting fill of wetlands• Minimizing the proposed construction• Natural landscaping enhancements• Conservation easements• Compensatory mitigation is recommended for unavoidable adverse impacts to more

than one acre of wetland

Wetland Protection-Mitigation

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Coastal Zone ManagementCoastal Zone Management Act (Section 370 (c) & (d))

N/A- Vermont has no Coastal Zones

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Sole Source AquifersSafe Drinking Water Act of 1974 (as amended) (Section 1424 (e))

40 CFR Part 149

N/A- Vermont has no designated sole source aquifers

125

Endangered Species ActEndangered Species Act of 1973 (Section 7)

50 CFR Part 402

126

Endangered Species-Compliance1. Create an Official Species List from the U.S. Fish &

Wildlife Service for the proposed project location (required for all Categorically Excluded and Assessment Level Environmental Reviews).

2. Review the habitat requirements for the species identified (consult ECOS) and compare them with the habitat found in the proposed project area.

3. If potential for impact is determined, applicable staff at Vermont ANR will need to be consulted.


https://ecos.fws.gov/ecp/

Endangered Species-Compliance

One of these Findings of Effects needs to be determined:

1. No Effect2. May Affect, Not Likely to Adversely Affect

3. May Affect, Likely to Adversely Affect


Endangered Species-Findings of EffectNo Effect

• This effect can be determined by consultation with VT ANR• No activities involved in the project which have the potential to

effect species or habitats• No listed species or critical habitats in action area (based on

official species list)• No potential habitat in action area • Include supporting documentation such as photos, maps, surveys

and biological reports as necessary


Endangered Species-Findings of EffectMay Affect, Not Likely to Adversely Affect

• Requires informal consultation with U.S. Fish & Wildlife Service• Seeks to accomplish 3 goals:

1. Define potential effects, explore ways of reducing or removing impacts, establish whether formal consultation is required.

2. Done voluntarily, collaboratively, and informally between the Services and the Responsible Entity. It is often possible to resolve all effects, modify the project as necessary, and conclude consultation without going to formal consultation.

3. Concurrence: The Service may concur with the finding that the project is not likely to adversely affect listed species or critical habitat, in which case consultation is complete. The ER must include all documentation of the dialogue with the Service. Proceed with project and follow recommendations.


Endangered Species-Findings of EffectMay Affect, Not Likely to Adversely Affect

• This determines appropriate if all potential effects will be one of the following:

• Beneficial effects are positive responses without any negative response• Discountable effect are unlikely to occur• Insignificant effects are responses that are incapable of being detected,

measured or evaluated

• If no concurrence, a Finding of Likely to Adversely Affect will be made and the Responsible Entity must proceed to formal consultation with the U.S. Fish & Wildlife Service


Endangered Species-Findings of Effect

May Affect, Likely to Adversely Affect• Requires formal consultation

• This determination must be made if the project results in any effects that are potentially greater than beneficial, discountable, or insignificant.


Common Endangered/Threatened Species in VT

• Northern Long-Eared Bat (Threatened)• Indiana Bat• Dwarf Wedgemussel (Endangered)• Northeast Bulrush (Endangered)


Endangered Species-BatsFor most projects in Vermont, the Official Species List will identify the Northern Long-Eared Bat as a potential threatened species• U.S. Fish & Wildlife Service Habitat Requirements


Endangered Species-BatsFor most projects in Vermont, the Official Species List will identify the Northern Long-Eared Bat as a potential threatened species.

• Examples of activities that have potential to impact the Northern Long-Eared Bat:

• Removing trees or structures such as barns or sheds• A project area close to any hibernacula such as caves or

mines


Endangered Species-VT ANR Contacts

For Bats:• Alyssa Bennett- [email protected]• Scott Darling- [email protected]

Any other threatened or endangered species• Jodi Shippee- [email protected]





Wild & Scenic Rivers ActWild & Scenic Rivers Act of 1968 (Sections 7(b) & (c))

138

Wild & Scenic Rivers in Vermont• 46.1 miles of the

Upper Missisquoiand Trout Rivers are designated as Wild & Scenic

• Designated River Segments are located in Franklin and Orleans Counties


rivers.gov

139

National Rivers Inventory in Vermont• This regulation also

requires consideration of potentially eligible rivers listed on the National Rivers Inventory (NRI).

• A river segment is potentially eligible if it has at least one outstandingly remarkable value.


nps.gov

140

Wild & Scenic Rivers-ThresholdsCompliance is triggered with-

• Acquisition of Land• New Construction• Change of Land Use• Major Rehabilitation• Demolition• Reconstruction/Redevelopment • New Infrastructure or Expansion projects (dams, road,

bridges, water/sewer main lines)


Wild & Scenic Rivers- Compliance• Project area is within close proximity of Wild & Scenic or

NRI River (within one-quarter mile of the river bank)• Consider impacts if a project is upstream, downstream or

located in a tributary• Determination of if a project renders the river ineligible

is required, consider the river’s “Outstandingly Remarkable Value”


• Scenery• Recreation

• Geology• Fish

• Wildlife• Prehistory

• History• Other Values

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https://www.nps.gov/orgs/1912/upload/ORV_9_2011.pdf

Wild & Scenic Rivers- Compliance• Projects with the potential to

• Have direct and adverse effect within the Wild & Scenic or NRI River boundaries;

• Invade the area; or• Unreasonably diminish the river outside the Wild & Scenic

boundaries

Must consult with the National Park Service (NPS), Northeast Regional Office to ensure avoidance or mitigation of adverse effects. NPS Consultation Instructions

• James MacCartney- [email protected]• Jamie Fosburgh- [email protected]


https://www.nps.gov/subjects/rivers/consultation-instructions.htm



Wild & Scenic Rivers-Compliance


1. Provide maps to show the distance of the proposed project to designated Wild & Scenic and NRI rivers

2. If project is within close proximity (1/4 mile) of any of the designated river segments determine if the project has the potential to render the river(s) ineligible

3. If project has potential to adversely impact the designated river, consult with the National Park Service (NPS), Northeast Regional Office to ensure impacts are avoided

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Air QualityClear Air Act (as amended) (Sections 176(c) &(d))

40 CFR Parts 6, 51 & 93

N/A- Vermont has no “non-attainment” or “maintenance areas”

145

Farmland ProtectionFarmland Protection Policy Act of 1981 (Section 1504(b) & 1541)

7 CFR Part 658

146

Farmland Protection-Thresholds• Compliance with this regulation is triggered if a project involves:

• New construction• Acquisition of undeveloped land, or• Conversion that could potentially convert one land use to another


• Exempt Activities:• Purchase, maintenance renovation or

replacement of existing structures• Construction limited to on-farm structures

needed for farm operations• Construction limited to new minor

secondary (accessory) structures such as a garage or storage shed

• Projects on land used for water storage

147

Farmland Protection-Thresholds• Exempt Areas/Locations:

• Project on land already in or committed to urban development (7 CFR 658.2(a)). This exemption does not include areas simply zoned for development.

• Urban areas or areas that have already been developed significantly (an area is considered significantly developed if there are 30 structures/40 acres or more)

• Urban areas are identified on TIGERweb (web-based system from the Census Bureau)


https://tigerweb.geo.census.gov/tigerweb/

Farmland Protection-Compliance


1. Determine if compliance is triggered (see previous slides)2. If project is not exempt, create a Natural Resources

Conservation Soils Report3. If agricultural lands (farmland of statewide or local

importance, prime, or unique farmland soils) are identified, additional investigation is required

4. Fill out the Farmland Conversion Impact Rating AD-1006 Form (Sections I & III) and submit it to Thomas Villars, Natural Resources Conservation Service. • If the project is limited to “corridor-type” activities (ex. installation

of a water or sewer line), a NRCS-CPA-106 Form should be submitted to Thomas Villars.

149

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1045394.pdf


http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1045395.pdf

Explosive and Flammable Hazards24 CFR Part 51 Subpart C

150

Explosive & Flammable Hazards-Compliance1. Determine if compliance is triggered (next slide)2. Consider all Above Ground Storage Tanks (ASTs) near

the project & proposed as part of the project3. Determine the contents of all identified tanks

• Consider tanks greater than 100 gallons if contents are considered common industrial fuels

• Consider tanks of any capacity containing hazardous liquids or gases that are not common industrial fuels

4. If any identified, calculate the Acceptable Separation Distance (ASD)

5. Consider mitigation, if proposed project is within any tank’s ASD


Explosive & Flammable Hazards-ThresholdsThis regulation is triggered when the proposed project involves-

• development; • new construction (including projects intended for

residential, institutional, recreation, commercial or industrial use);

• rehabilitation, modernization, or conversion (that results in an increase in residential density, conversion to residential use, or making a vacant building habitable); or

• a hazardous facility (a facility that mainly stores, handles or processes flammable or combustible chemicals such as bulk fuel storage facilities and refineries)


Explosive & Flammable Hazards-Compliance• List of products considered

hazardous common industrial fuels under 24 CFR Part 51.201 (list from Appendix I)

• Above Ground Storage Tanks greater than 100 gallons containing any of these substances need to be considered under this regulation


• Propane tanks have a higher capacity threshold (in VT)…

153

https://www.gpo.gov/fdsys/pkg/CFR-2013-title24-vol1/pdf/CFR-2013-title24-vol1-part51-subpartC-appI.pdf

Explosive & Flammable Hazards-Propane

As of August 3, 2017 the State of Vermont was granted a Waiver from HUD (for CDBG and HOME programs) which exempts consideration of Small Propane Tanks (250 gallons or less-compared to the 100 gallon threshold for all other ASTs)


Explosive & Flammable Hazards-Identifying AST’s


• A database that records the presence of all ASTs does not exist

• A site visit is required• Review of publicly available satellite imagery• Create a NEPAssit Report identify RCRA Facilities• Often, local Fire Departments can provide

information about facilities storing hazardous substances

155

http://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HowToIdentifyRCRAFacilities.pdf

Explosive & Flammable Hazards-Calculate the ASD


Note: For Propane, the answer to this question is always “No”HUD’s ASD

Calculator

156

https://www.hudexchange.info/environmental-review/asd-calculator/

Explosive & Flammable Hazards-Mitigation Options• Choose Another Site• Bury the Hazard (less expensive than building a barrier)


• Modify the building design to compensate for ASD

• Design a barrier (needs to be done by a licensed professional)

• Consider existing topography, topographic features effectively provide mitigation

158

Noise Abatement and ControlNoise Control Act of 1972 (as amended)

24 CFR Part 51 Subpart B

159

Noise Abatement & Control-Compliance1. Determine if compliance is triggered (next slide)2. Calculate the Day/Night Noise Level (DNL) for the

proposes project location3. Determine if noise levels are above 65 decibels (dB)4. Consider mitigation, if DNL is above 65 dB


Noise Abatement & Control-Thresholds

This regulation is triggered when the proposed project involves-• new construction;• substantial rehabilitation of an existing residential

property; or • if a project qualifies as a noise sensitive use

• Ex. housing, mobile home parks, nursing homes, hospitals, and other non-housing uses where quiet is integral to the project’s function, e.g., libraries


Noise Abatement & Control-DNL CalculationNoise Sources that need to be considered-• Major roadways within 1,000 feet of the project location

• Vermont Automatic Vehicle Classification Report• Vermont Data Management System

• Railroads within 3,000 feet• Federal Railroad Administration (FRA), Office of Safety Analysis Mapping Tool• FRA Crossing Report Generator• Railway Operator/Supervisor

• Airports must be considered if within 15 miles• Burlington International Airport Noise Exposure Map• Rutland Regional Airport (not sufficient traffic to warrant noise study)

• Loud Impulsive Sound: Neighboring land uses that routinely create explosions include military training and testing installations, rock quarries, and sonic booms

Steps on How to Calculate Noise Levels


https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HowToCalculateNoiseLevels.pdf

Please Note: This is the final DNL Calculation that

needs to be considered

163

PLEASE NOTE:Point in time noise measurements are not comparable to a noise

calculation. Noise measurements performed by an acoustical consultant are never to be used to refute or confirm noise

calculations.

164

Noise Abatement & Control-Mitigation


Interior Noise level Goal of 45 dB

Assumption is that standard construction

provides 20 dB of sound

attenuation

165



• New Construction: HUD assistance for the construction of new noise sensitive uses is prohibited generally for projects with unacceptable noise exposures and is discouraged for projects with normally unacceptable noise exposure.

• Substantial Rehabilitation: Noise attenuation features or converting to a land use compatible with high noise levels is strongly encouraged.

• The attenuation required is dependent on severity of noise and the opportunities for attenuation within the extent and nature of the rehabilitation.

166



• Topography: Hills (barrier calculations in Noise Guidebook)• Traffic Calming Measures

• Humps and chicanes (make a route less useful as a bypass)• Reduce speed limits or remove lanes (slow traffic)

• Electrical light rail or streetcar might replace a bus route• Electrical locomotives could replace diesel locomotives on

the nearby commuter railway

167

https://www.hudexchange.info/resource/313/hud-noise-guidebook/



• Separate: A noise tolerant component of the development project may be able to make use of an area inappropriate for housing (ex. parking lot)

Building Parking Lot

Noise Source

168




Parking Lot Building

Noise Source

169




• Mitigate property• Sound barriers: berms or walls (should be tall enough

for no line of site exposure)• Trees are NOT effective barriers

• DOTs can use Federal Highway Administration funds for Type 2 noise barriers

• Parking garage to block housing

• Mitigate building• Interior goal of 45 dB• Sound attenuating building construction

• High Quality Storm Windows• New Insultation• Sounds Dampening Ceiling Tiles• Other modern building materials

170

Noise Abatement & Control-Mitigate Building


Toxic Sites24 CFR Part 58.5(i)(2)

172

Toxic SitesHUD’s Policy: 24 CFR Part 50.3(i) and 24 CFR 58.5(i)(2):

• All property proposed for use in HUD programs be free of hazardous materials, contamination, toxic chemicals and gasses, and radioactive substances, where a hazard could affect the health and safety of occupants or conflict with the intended utilization of the property.

• The responsible entity shall use current techniques by qualified professionals to undertake investigations determined necessary


Some TerminologyPhase I Environmental Site Assessment (ESA)• The industry standard for determining whether a past release of

hazardous substances or petroleum products has occurred or there is a material threat of a future such release, on a property

• Non-intrusive investigation into historical uses of the site and visible evidence of environmental conditions

• Purpose: Identify Recognized Environmental Conditions (RECs)

NOTE: Be sure your Phase I ESA includes a Vapor Encroachment Screening (VES)

174

Some TerminologyRecognized Environmental Condition (REC)• The presence or likely presence of any hazardous substances or

petroleum products on a property under conditions that indicate an existing release, past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water, or surface water of the property

Phase II ESA• Physical testing to rule out or confirm the presence of a REC(s)• Sampling, chemical analysis, evaluate risk to receptors and compare to

relevant criteria to determine need for cleanup or risk management• Purpose: Obtain scientifically valid data concerning actual property

conditions

175

Some TerminologyCorrective Action Plan (CAP)• Details the proposed cleanup strategy

• Common types of corrective action• Removal of contaminated soil• Cleaning up groundwater• Engineering Controls: physical mechanism used to contain or stabilize

contamination or ensure the effectiveness of a remedial action• Institutional controls: mechanisms used to limit human activities at or near a

contaminated site, or to ensure the effectiveness of the remedial action over time, when contaminants remain at a site at levels above applicable remediation standards which would allow for the unrestricted use of the property

176

Some TerminologyCorrective Action Plan (CAP)-cont’d• Ensures technical feasibility of the plan, effective engineering design,

reasonable cost, public participation, compliance with applicable standards, and protection of human health and the environment

• When contaminants remain at a site at levels above applicable remediation standards which would allow for the unrestricted use of the property (cleanup plans are based on proposed future use of the property)

• Purpose: Prevent and eliminate unacceptable risk to human health and the environment caused by the release of hazardous materials into the environment

24 CFR 58.5(i)(2): “…free of hazardous materials…where a hazard could affect the health and safety of occupants..”

177

What Projects Require a Phase I ESA?• Multi-family residences (5+ units)• Non-residential properties (such as commercial

properties, a municipal property, or vacant land)• Acquisition

In short: All projects require a Phase I ESA with the exception of single-family (1-4 unit) residential properties If no RECs are identified, no additional action is required (assuming the Phase I ESA is still valid)*

*Timing associated with the validity of a Phase I discussed later

178

If REC’s are identified1. Have your consultant develop a Phase II Work Plan2. Phase I and Phase II Work Plan are sent to Vermont

Department of Environmental Conservation (DEC) for review (plan for 30 days for review)

3. Edits may be required, receive approval of Phase II Work Plan from DEC, consultant can move forward with performing Phase II ESA

4. Once complete, the Phase II ESA report is sent to DEC for review (plan for 30 days for review)

5. Edits/additional testing may be required. Once approval of Phase II from DEC is received, consultant moves forward with developing Corrective Action Plan (CAP)


If REC’s are identified (cont’d)6. Once complete, the CAP is sent to DEC for review (plan

for 30 days for review)7. Any substantial comments from DEC need to be

addressed before finalizing the ER8. A Draft CAP that has been reviewed by DEC is adequate to

finalize the ER and move forward with publication of the notice (assuming compliance with all other ER factors has been achieved)

9. The actual cleanup/implementation of the CAP happens after the ER Release is received, during implementation of the project


Toxic Sites-Timing• Phase I: 180-day/1 year threshold

• Clock Starts when the Phase I was started (most commonly the date of the site visit)

• Timing of the Phase I is very important, you want to avoid an update being needed, but also have it done to identify any potential issues early on

• Phase II: If more than a year old, needs to be reviewed (potential update)

• CAP should reflect current site conditions


Toxic Sites: Lead24 CFR Part 35, Subpart B

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Lead-ThresholdsHUD’s Lead Safe Housing Rule (LSHR)


The purpose of HUD’s Lead Safe Housing Rule is to protect young children (under 6 years of age) from lead-based paint hazards in housing that is financially assisted by the Federal government or

sold by the government.

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Lead-ThresholdsHUD’s Lead Safe Housing Rule (LSHR)


• Properties exempt from the LSHR include: • Buildings constructed in 1978 or later• Housing exclusively for elderly persons or disabilities• Zero bedroom dwellings• Unoccupied housing that will remain vacant until it is demolished• Nonresidential property

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Lead-Thresholds


• De minimis disturbance (as defined in 24 CFR §35.1350(d)): Work which disturbs less than 20 square feet on exterior surfaces; 2 square feet in any one interior room or space; 10 percent of total surface area of interior or exterior component type with a small area (sills, baseboards, etc.)

• Work on surfaces where the amount of paint disturbed is below the de minimis threshold do not need to follow lead safe work practices, although HUD recommends that caution be used to minimize the dispersal of lead in dust, paint chips, or debris.

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Lead-Compliance (Subpart J: Rehabilitation)• Rehab Work Below $5K per unit:

• Only consider the surfaces that are being disturbed• Test for LBP OR• Assume surfaces contain LBP

• Use Lead Safe Work Practices in accordance with 24 CFR §35.1350• Clearance of Worksite is performed at the end of the job to ensure that no lead

dust hazards remain.• Rehab Work $5k to $25k per unit:

• Interim Controls• LBP Risk Assessment OR• Assume all potential lead hazards are present

• Use Standard Treatments to address hazards• Rehab Work Above $25K per unit:

• Perform LBP Risk Assessment• Abate all identified Hazards

• Requires certified abatement contractors 186

1. Is the house pre-1978? If no, evaluation is complete, no mitigation is required. If yes, continue to question 2.

2. Does the project qualify as exempt from the LSHR? If yes, evaluation is complete. Is no, continue to question 3.

3. Does the amount of paint disturbance qualify as de minimis? If yes, evaluation is complete, use of lead safe work practices are strongly recommended. If no, continue to question 4.

4. Based on the dollar amount determine what mitigation measures are required.


Lead: Analysis/Questions to Ask

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• Certified Professional: List of Consultants maintained by the VT Department of Health

• All lead hazard control work, inspections and risk assessment must be performed in compliance with “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing” (2012 Edition) and EPA and/or state regulations (40 CFR 745, subparts L and Q, respectively).


Lead: Compliance

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http://www.healthvermont.gov/sites/default/files/documents/pdf/ENV_AL_lead_consult_contractor_list.pdf

Toxic Sites: Asbestos40 CFR Part 61, Subpart M

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Asbestos-Thresholds


• Buildings constructed prior to 1978• Removal of friable asbestos is required before:

• Demolition• Renovation• Rehab

• At minimum, friable asbestos must beremoved & non-friablemust be encapsulated

Learn About Asbestos

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https://www.epa.gov/asbestos/learn-about-asbestos

Asbestos-Compliance• Certified Professional: List of Consultants maintained by

the VT Department of Health• A qualified asbestos inspector must perform a comprehensive

building asbestos survey based on a thorough inspection to identify the location and condition of asbestos throughout all structures performed pursuant to the “baseline survey” requirements of ASTM E 2356-14 “Standard Practice for Comprehensive Building Asbestos Surveys.”

• If suspect asbestos is found, it should either be assumed to be asbestos or should require confirmatory testing. If the asbestos survey indicates the presence of asbestos or the presence of asbestos is assumed, the appropriate mix of asbestos abatement and an asbestos Operation & Maintenance Plan will be required.


http://www.healthvermont.gov/sites/default/files/documents/pdf/ENV_AL_asbestos_consult_contractor_list.pdf

Toxic Sites: Mold24 CFR Part 5, Subpart G, §5.703

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Mold-Compliance• HUD requires that all dwelling units and common areas have

proper ventilation and be free of mold.• If any mold is discovered (in dwelling units or common

areas), abatement will be required. • Visual Inspection required (this can be done by anyone or be

included as a non-scope item in the Phase I ESA for the project)


Environmental JusticeExecutive Order 12898

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Environmental Justice-Thresholds


Fair Treatment: No group of people should bear a disproportionate share of the negative

environmental consequences resulting from industrial, governmental and commercial

operations or policies.

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Environmental Justice-Compliance


1. Use the EPA Environmental Justice Screening and Mapping Tool to determine the demographics of the proposed project area with respect to minority and low income populations compared to the State Average.

Steps on How to Make an Environmental Justice SCREEN Report

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http://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HowToMakeAnEJSCREENReport.pdf



2. Assess if the project is surrounded by, exposed to or creates any adverse environmental impacts.

An incomplete list of adverse environmental impacts to consider are:• explosions• conflagration• air pollution of toxic intensity

from chemical processing storage or transmission chemicals

• hazardous industrial operations• slag piles

• landfills• dumps• major highways• train tracks, traffic overload• any other industrial-commercial

operation which produce high levels of pollution

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3. If any adverse environmental impacts are identified, determine if these impacts are disproportionally affecting low/moderate income individuals and/or minority populations. If so, your project has an Environmental Justice issue.

The preferred resolution would be to modify the project to eliminate or at least reduce the adverse effects, when feasible.

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RadonHUD Notice H 2013-03

Chapter 9 of the HUD MAP Guide

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https://www.hud.gov/sites/documents/13-03HSGN.PDF

https://www.hud.gov/sites/documents/4430GHSGG-BM.PDF

Radon-Thresholds

• Radon testing is required for all project that involve structures, regardless of radon zone.

• Zone 1: High potential, predicted average indoor radon screening level greater than 4 pCi/L

• Zone 2: Moderate Potential, predicted average indoor radon screening level between 2 and 4 pCi/L

• Zone 3: Low Potential, predicted average indoor radon screening level below 2 pCi/L


Radon-Compliance


• Substantial Rehab and New Construction• For new construction and substantial rehab that will

impact the building envelope, early testing is not feasible.

• Radon testing must be completed post construction/rehabilitation and before occupancy.

• Minor Rehab that does not impact the building envelope

• Testing should take place prior to implementation to determine if radon mitigation will be required.

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Radon-Compliance


•New Construction• New construction in Radon Zones 2 and 3 (there

are no Zone 1’s in Vermont) must include radon resistant construction methodologies: gas permeable layer, ground cover and foundation walls.

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Radon- Testing Compliance


• All testing and mitigation must be performed under the supervision of a Radon Professional.

• The National Radon Proficiency Program has resources available to help find a certified radon professional.

• Testing• Radon testing must follow the protocols set by the American

Association of Radon Scientists and Technologists, Protocol for Conducting Radon and Radon Decay Product Measurements in Multifamily Buildings (ANSIAARST MAMF-2010, Section III)

• Results at or above 4.0 pCi/L requires mitigation• Results between 2-4 pCi/L mitigation should be considered

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http://aarst-nrpp.com/wp/database-search/

Radon-Compliance


• If test results show elevated levels (>4.0pCi/L)• Existing buildings: ASTM E 2121-13 (or most recent

edition), Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings

• Radon tests expire after 1 year• Commercial Buildings: No HUD or VT requirements for

commercial buildings, but following the action levels required for housing is strongly encouraged

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NEPA AnalysisCouncil on Environmental Quality (CEQ)

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Environmental Assessment/NEPA Analysis• Used to determine if a project will “significantly affect the quality of the human

environment” • The CEQ’s NEPA implementation regulations do not include a comprehensive list of

resources that need to be analyzed when conducting an Environmental Assessment/NEPA Analysis, each agency develops guidance on how to analyze impacts to the human environment.

• CEQ NEPA Regulations identify broad areas of effects for agencies to consider:

• Ecological• Aesthetic• Historic

• Cultural• Economic• Social• Health

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Additional Compliance Factors Specific to Environmental Assessments/NEPA Analysis

Land Development

Socioeconomic

Community Facilities and Services

Natural Features

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Environmental Assessment/NEPA AnalysisHUD’s EA Factors• Community Planning & Site Design• Soil & Storm Water Management• Sustainable Materials Management• Energy Consumption• Water Supply & Efficiency• Socioeconomics• Livability

• Transportation• Community Facilities & Services• Public Health & Safety

• Analysis should focus on significant issues, discussing insignificant issues only briefly

• Evaluation of effects should consider-

• Direct,• Indirect, &• Cumulative Impacts

• Environmental Assessment/NEPA Analysis Questions

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http://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-AssessmentQuestions.pdf

Statement of Purpose and Need, Existing Conditions and Trends &

Cumulative Impact AnalysisThese Assessment-level factors should initially be completed

early on in the process at the same time the Project Description is written. These factors help define a basis of analysis.

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Statement of Purpose and Need40 CFR 1508.9 (b)

• Need: The problem that needs fixing/the situation wanting improvement

• Purpose: Proposed Solution or desired condition you want to create• The activities included in the project can be modified only to the

extent that the project still meets the underlying purpose and need• Courts have cautioned Agencies not to put forward a purpose and

need statement that is so narrow as to define, competing “reasonable alternatives” out of consideration.

Should be done at the same time the project description is being completed

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Existing Conditions and Trends24 CFR 58.40(a)

• Determine existing conditions and describe the character, features and resources of the project area and its surroundings; identify the trends that are likely to continue in the absence of the project.

• Defines the Environmental Baseline• The threshold of acceptability for that factor• Provides context for determining an impact’s significance


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Cumulative Impacts Analysis (Project Aggregation)24 CFR 58.32 & 40 CFR 1508.25

• Responsible Entities should group together and evaluate as a single project all individual activities which are related either on the geographical or functional basis, or both, or are logical parts of contemplated actions.

• Questions that are considered:• Is this activity part of a larger project?• Is the site just one phase of a larger development?• Do the activities take place in a target area where a whole range of varying

activities are planned?


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Cumulative Impacts Analysis (Project Aggregation)24 CFR 58.32 & 40 CFR 1508.25

• Complete Analysis of project activities based on the definition of Scope provided in 40 CFR 1508.25

• Work with the Environmental Officer to complete this analysis• Should be completed early on in the Environmental Review (when the

project description is defined) to determine how the Environmental Review will be approached


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Alternatives to the Proposed Action24 CFR 58.40(e), Ref 40 CFR 1508.9

• Limited to the range of alternatives that meet the purpose and need• Those that do not meet the purpose and need can be dismissed

without detailed study

• At minimum, the No Action Alternative must be considered.

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Mitigation Measures24 CFR 58.40(d), 40 CFR 1508.20)

• Should list all the mitigation measures identified throughout the Environmental Review

• Mitigation measures should be as specific as possible to detail what will be done during implementation to ensure compliance

• Identify what individuals/entities are responsible for carry-out various mitigation measures

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HUD Environmental Review & Act 250• DIFFERENT PROCESSES: Federal v. State• BUT, share many of the same goals

• review a project to assess the impacts of the project on the environment and the impacts of the environment on the project

• involve the public in the decision-making process• consider alternatives• make better-informed decisions about development

• Coordination of an Environmental Assessment Review and Act 250 Permit Application – Handout Provided

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HUD National Housing Trust Fund (HTF) Process:Environmental Provisions(NOT Subject to Part 58)

• General Differences:oNo Level of Environmental ReviewoNo Public Comment PeriodoNo Certification or ER Release

• Analysis Factors with Different RequirementsoHTF Review Cheat Sheet

• Additional Requirement: Safe Drinking Water Act

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https://accd.vermont.gov/sites/accdnew/files/documents/CD-VCDP-ER-HTFCheatSheet.pdf

HUD National Housing Trust Fund (HTF) Process:Environmental Provisions(NOT Subject to Part 58)

• Important to Identify if HTF will be a funding source as early on as possible

• If a project has already completed a Part 58 ER, this does NOT mean it will meet all the requirements to meet the Environmental Provisions required for HTF

• If you complete an HTF-only Environmental Review, this does NOT meet Part 58 requirements

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Step 4. Finalize the ER and Publish Applicable Notice

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An Environmental Review done at the Categorically Excluded Level may not Require a Public Notice


• If no mitigation measures are triggered for compliance, the environmental review may “convert” to exempt.

• In this case, a public notice is not required.• This is NOT a possibility for Environmental

Review completed at the Environmental Assessment Level.

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Public Notice for the Environmental Review


• Templates are available in the GEARS system and from the Environmental Officer

• Important Information of the Public Notice• Mitigation Measures• ALL HUD funding sources (CDBG, HOME, and

potential for Section 8 Vouchers and/or participation in HUD’s Risk Share Program)

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Public Notice for the ER-Timeline Categorically Excluded


• 7 Day Comment Period• 15 Day Objection Period• Day of Publication does

NOT Count• Day of Certification does

NOT count and initiates the beginning of the objection period

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Public Notice for the ER-Timeline EA


• 15 Day Comment Period• 15 Day Objection Period• Day of Publication does

NOT Count• Day of Certification does

NOT count and initiates the beginning of the objection period

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The Public Process for the ER• Publication on the Municipality’s Website?• Summary of any additional public outreach that was

done for the project• Any recent public meetings or hearings at which the

project was discusses?• Public Notice should be sent directly to any known,

interested parties

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Public Comments Received?• All public comments must be responded to

individually

• Responses must officially come out of the office of theResponsible Entity

• Who can/should help you with preparing responses?

• VCDP (Environmental Officer)• Subgrantee• Developer

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Certification of the ER

• Must be done by the Municipal Authorizing Official • This responsibility cannot be delegated

• Done in GEARS (Equivalent to a Signature)• Review the full ER Record• Raise any concerns/ask any questions prior to

completing the Certification

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Step 5. Environmental Review Release is Received

Details Environmental Review Conditions (mitigation required to be addressed as part of implementation)

227

Environmental Review Release

Letter

228

7015.16 Authority to Use Grant Funds (AUGF) from HUD

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Common Environmental Review Conditions• Historic Preservation• Toxic Sites (ex. Implementation of a CAP)• Lead, Asbestos, Mold (Abatement)• Radon (Testing and/or Mitigation)• Floodplain Management/Wetlands• Endangered Species

Actions required during implementation to ensure compliance

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• Everything cannot be a condition!• The ER should provide assurance that the project

activities/location has been chosen carefully with in-depth consideration of every aspect and statutory requirement

• Conditions need to be specific, outline a plan, full understanding of the potential extent of mitigation, NOT an “it will get done…” statement

Environmental Review Conditions

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Choice Limiting Activities Now Allowed!• Acquisition or Leasing of property (Allows an Option

Agreement but NOT a Purchase and Sales Agreement)• Commitment or expenditure of CDBG funds or non-CDBG

funds (for choice-limiting activities)• Entering into commitment for repair, rehabilitation,

construction or demolition• Commitment=legally binding contract or agreement

• Going out to bid• Initiating project activities

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Questions on Going Out to Bid/Procurement?

Joe Le Clair: [email protected]

233


Project Timeline at Environmental Review Release

• If you can provide an anticipated timeline of construction/project completion, at time of ER Release this is helpful

• General Follow-up on project progress with respect to the Environmental Review conditions is done approximately 6 months after ER Release

• Be in touch throughout the project if there are any questions around satisfying the environmental review conditions!

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Step 6. Expend Project Funds

235

Step 7. Post Review Consideration-Provide Documentation to Support that

ER Conditions have been SatisfiedThis documentation is added to the Environmental Review

Record in GEARS

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Resources•Handouts Provided•Links included throughout this presentation

•HUD's Environmental Review Webpage(Laws and Authorities)

•HUD’s WISER (Web-Based Instructional System for Environmental Review) Trainings

237

https://www.hudexchange.info/environmental-review/federal-related-laws-and-authorities/

https://www.hudexchange.info/trainings/wiser/?utm_source=HUD+Exchange+Mailing+List&utm_campaign=832a0f31c0-WISER_Training_Modules_2016_11_29&utm_medium=email&utm_term=0_f32b935a5f-832a0f31c0-19367933

Resources•ER Webpage

•VT ACCD Website

•Myself: [email protected]

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Thank You for your Attendance & Have a Great Evening!

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