1.18K views
0

The MAP Guide requires a complete HEROS submission at pre-application (see MAP Section 9.2.3)in order to make an early evaluation of any environmental issues so HUD can determine if all environmental issues can be resolved or a plan for mitigation can be approved prior to issuance of the Firm Commitment.

However, the MAP guide recognizes that certain environmental issues cannot be resolved until the project has final plans and specs, and Section 106 may fall into this category. The Section 106 review is also complicated by the Section 106 Delegation memo, and the requirement to coordinate with HUD’s tribal consultation for projects that include ground disturbance. HUD would accept a pre-application from a lender following the Section 106 Delegation Memo if the lender has reached out to coordinate HUD’s tribal consultation or if the Lender has initiated consultation with the SHPO but has not yet heard back. HUD would also accept a pre-application with an incomplete SHPO review for a project where the lender chose not to follow the Section 106 Delegation, because in this case HUD will reach out to the SHPO directly.

Greg Hunter Changed status to publish July 6, 2021
Copyright © 2021 HUD221d4.com. HUD221d4.com is a PHA Capital company. This website is owned by a private company that offers business advice, information and other services related to multifamily, commercial real estate and other financing. We do not provide legal, accounting, or brokerage advice. We have no affiliation with any government agency and are not a lender. By using this website, you agree to our use of cookies, our Terms of Use and our Privacy Policy. We use cookies to provide you with a great experience and to help our website run effectively. You also understand that we are not affiliated with the Department of Housing and Urban Development (HUD) or the Federal Housing Administration (FHA). If you need to visit the FHA directly please visit www.hud.gov.