Recent changes on the HUD Environmental Assessment data form have made their way to the Illinois Housing Development Authority Environmental Requirements for Multifamily Affordable Housing. The IHDA guidance was just updated January 2016.
The new HUD/IHDA Part 58 form is essentially a minor reorganization of the same content with the elimination of some redundancy. The new form requires more information about project funding. It also combines related environmental assessment factors into categorical elements. For example, “Police”, “Fire”, and “Emergency Medical” previously existed as 3 separate factors. On the new form, they are 1 combined factor.
Some new sections of the form (not new to NEPA Environmental Assessment, just new to the HUD/IHDA form) include sections regarding:
- Permits Obtained
- Public Outreach, and
- Cumulative Impact Analysis.
“The Phase I MUST include the HUD Environmental Assessment form.”
Another recent, and significantly more meaningful, change is the requirement that all IHDA Phase I Environmental Site Assessments include a Part 58 Environmental Assessment. In the past, the Part 58 has only been required when HUD funding was proposed as part of the project. Within the last year, however, IHDA began requiring the Part 58 regardless of HUD funding. When scoping a Phase I for IHDA, be sure to specify that a Part 58 Environmental Assessment be included.