Spreadsheet: aa2ce6f2-dd47-4393-9b68-33c940dda1fb
Sheet: 223f-Environmental_Checklist

 | Sample 232/223(f) Environmental Checklist
 | Project Name: |  |  |  |  |  |  |  |  |  |  | Yes |  | No
 | 1. | Coastal Barrier Resources | Is the subject property located within a designated Coastal Barrier Resources System (CBRS) unit?
 |  |  |  | The CBRS is a system of protected coastal areas that serve as barriers protecting the Atlantic, Gulf, and Great Lake coasts and Other Protected Areas (OPAs).  State locator maps are available on the U.S. Fish & Wildlife Service website at www.fws.gov/CBRA/Maps.  A project that is located within a CBRS unit, or includes a facility (such as a water main) to a CBRS unit, is not eligible for mortgage insurance.
 | 2. | Floodplain Management | FEMA Flood Insurance Rate Map (FIRM) Number:
 |  |  | FIRM Effective Date:
 |  | (24 CFR Part 55) | Flood Zone(s):
 |  |  | (If Zone X, state whether it is in shaded Zone X or unshaded [NAME])
 |  |  |  | Flood Insurance Rate Maps (FIRMs) are available on the FEMA website in the Map Service Center at www.msc.fema.gov.  Also check for interim information, such as Future and Preliminary Flood Maps, and Advisable Base Flood Elevations (ABFEs).  Interim information may be available in the FEMA Map Service Center on the Product Catalog tab. If FEMA information is unavailable or insufficiently detailed, other Federal, state, or local data may be used. However, base flood elevations from an advisory or preliminary map may not be used if the elevations are lower than the elevations on the current FIRM used for ratemaking purposes
 |  |  | Is the project site located in a 100-year or 500-year floodplain?
 |  |  |  | If yes, HUD’s environmental review of a 232/223(f) application will include a 5-step decision making process for floodplains as required by 24 CFR 55.20. One of the steps requires the project to include items a. through d. below. Provide the documentation with the application.
 |  |  | a.  Preparation and participation in an early flood warning system.  Indicate the specific method(s) used to monitor weather conditions and flooding alerts (e.g., NOAA weather radio continuously monitored by staff and an emergency alert agreement with the state or municipal emergency services agency.) b.   An emergency evacuation and relocation plan, including names and addresses of like facilities (i.e., similar residential healthcare facilities) that have agreements or contracts with the subject to serve as temporary relocation sites for the subject’s residents.  (The Centers for Medicare & Medicaid Services (CMS) has issued an Emergency Preparedness Checklist for health care facilities as a recommended tool for emergency planning.) c.   Identification of evacuation route(s) out of the 500-year floodplain. Provide road maps and the flood zone designations of the relocation sites. d.  Identification marks of past or estimated flood levels on all structures. (When estimating flood levels, see the FIRM and the Flood Insurance Study (FIS) for flood  level elevations.)
 |  |  | In addition, all new and renewal leases or contracts must contain an acknowledgement signed by the resident (or their agent) indicating they have been advised of the portions of the site that are in a floodplain and that flood insurance is available for their personal property.  An example of the acknowledgement and an owner certification of compliance must be provided prior to closing.
 | 2. | Floodplain Management  (continued) | Is there a Floodway or Coastal High Hazard Area on the site?
 |  |  | Floodways are graphically identified on FIRMs from 1986 and later as diagonally hatched areas; before 1986, [NAME] were issued separately from the FIRMs. Coastal High [NAME] are designated on FIRMs as Zone V1–30, VE, or V.  HUD's floodplain management regulations at 24 CFR Part 55 prohibit mortgage insurance when any portion of the site is located in a Floodway or Coastal High Hazard Area. Exceptions: 24 CFR 55.12 lists categories of actions to which the floodplain management requirements in 24 CFR 55 are not applicable.  As such, the floodway and coastal high hazard area prohibitions do not apply to Section 232 projects if only an incidental portion of the project site is in the floodplain (including all 100-year or 500-year floodplains), and the following conditions are met:
 |  |  |  | a. All construction (including existing improvements) or landscaping activities (except for minor grubbing, clearing of debris, pruning, sodding, seeding, etc.) must not occupy or modify the relevant floodplain. Due to the constraint that activities must “not occupy or modify” the floodplain, the 100-year or 500-year floodplain cannot be utilized in the development or support of any project activity, except as passive open or green space.  b. Appropriate provision is made for site drainage; and  c. In accordance with 24 CFR 55.12(c)(7)(iii), a protective covenant or comparable restriction must be placed on the property’s continued use to preserve the 100-year or 500-year floodplain. The covenant or comparable restriction must run with the land to provide for permanent preservation of the floodplain, and must not be dependent on the mortgage instrument.
 |  |  | When invoking the "incidental portion" exception at 24 CFR 55.12(c)(7), provide a site survey with elevations and flood hazard zones delineated based on the best available data, a description of how the project qualifies for the exception, and a copy of the permanent covenant or comparable restriction that will be placed on the property’s continued use to preserve the floodplain.
 | 2a. | Flood Insurance | Is any portion of a site structure located within a 100-year flood zone?
 |  |  |  | If yes, flood insurance is required.
 | 3. | [NAME] (36 CFR Part 800) | Was the State Historic Preservation Officer (SHPO) contacted?
 |  |  |  | If the SHPO was contacted, include all correspondence to and from the SHPO with the application.  In addition, if a response is received from the SHPO after the application's submission, provide the response to HUD when it is received.  It is important to submit complete information to the SHPO when conducting a Section 106 consultation.   Some states have their own process and submission requirements.  Check the SHPO’s website (see http://www.ncshpo.org/find/index.htm) prior to submitting a request for consultation.  Assure that the information is specific about the scope of work that is being completed as part of the FHA-insured project, and include a map, photos, and project plans as applicable.   While SHPOs have 30 days to review a submission, the submission must be complete and correct, or the SHPO may require additional information, which can add to the review time.
 |  |  | Does the project involve activities that exceed the level of routine maintenance?
 |  |  |  | If yes, then SHPO consultation is required.  The activity must not begin before HUD completes its environmental review.  Confirm that the SHPO has been contacted and include a copy of the consultation in the application.  Guidance for clarifying the difference between routine maintenance and a repair can be found on the HUD website, at http://portal.hud.gov/hudportal/documents/huddoc?id=DOC_13720.pdf, or by contacting a HUD environmental specialist.
 |  |  | Does the project involve activities that require Tribal consultation?
 |  |  |  | Activities that require HUD consultation with federally-recognized tribes include: Ground disturbance (digging), new construction in undeveloped natural areas, introduction of incongruent visual, audible, or atmospheric changes, work on a building with significant tribal association, and transfer, lease or sale of properties that may have religious and cultural significance to tribes.  Tribal consultation must be initiated by HUD, and the activity must not begin before HUD completes its environmental review.   If Tribal consultation is required, notify ORCF upon submission of the application.
 | 4. | Noise Abatement (24 CFR 51  Subpart B) | Does noise from sources such as major roadways, railroads, airports or military airfields have a negative effect on the project's marketability?
 |  |  |  | For existing projects, environmental noise is a marketability factor which HUD will consider in determining the amount of mortgage insurance or other assistance that may be given. When noise is considered to have a negative impact on the project's marketability, a noise mitigation plan may be proposed.  For modernization projects located in all noise exposed areas, HUD will encourage noise attenuation features in alterations. For major or substantial rehabilitation projects in the Normally Unacceptable and Unacceptable noise zones, the proposal should incorporate noise attenuation features, given the extent and nature of the rehabilitation being undertaken and the level or exterior noise exposure.
 | 5. | Hazardous Operations (24 CFR 51 Subpart C) | Are there aboveground containers of explosive or flammable hazards located on-site or directly visible from the site?   Excepted are: Containers with a capacity of 100 gallons or less when they store common liquid industrial fuels, such as gasoline, fuel oil, [NAME] and crude oil since they generally would pose no danger in terms of thermal radiation or blast overpressure to a project. (Explosive hazards such as aboveground tanks that store propane are not excepted.)
 |  |  |  | If there are no aboveground explosive or flammable hazards located on-site or directly visible from the site, skip the remainder of this section and move to Section 6.
 |  |  | Record the size, number, type of fuel, and location (distance from structures and outdoor areas of congregation including parking areas) of all containers storing explosive or flammable hazards:
 |  |  | Does the project involve an increase in residential density?
 |  |  |  | If yes, then full compliance with 24 CFR 51C for Acceptable Separation Distances from explosive/flammable hazards is required.  Submit a mitigation plan if required.  For guidance contact [NAME], HUD's Hazardous Operations Specialist, [EMAIL], (202) 708-4225 Ext. 4455.
 |  |  | If an aboveground storage tank (AST) containing explosive or flammable hazards exists at a project that involves no increase in residential density, was a conformance letter requested from the Fire Department? (required)
 |  |  |  | When the project does not involve an increase in residential density and an AST containing explosive or flammable hazards exists on the site, a conformance letter must be requested from the local fire department that specifically addresses the safety of the AST. Provide HUD with a copy of the letter that was sent to the Fire Department and any response received.
 |  |  |  | If a conformance letter was requested but cannot be obtained, was an acceptable separation distance (ASD) calculation completed? |  | N/A
 | 5. | Hazardous Operations (continued) |  | In cases where conformance letters cannot be obtained for existing ASTs, then ASD calculations must be included in the application, and mitigation may be required.  HUD will evaluate the risk considering the type of fuel stored in the tank, and the size, location and condition of the AST.  HUD's ASD calculator is available online at http://www.hud.gov/offices/cpd/environment/asdcalculator.cfm
 |  |  | Is a new AST being added, or is an off-site explosive or flammable hazard directly visible from the property?
 |  |  |  | In cases where a new AST containing an explosive or flammable hazard is being added, or where an off-site hazard is directly visible from the subject property, include the ASD calculations in the application.
 |  |  | Is mitigation of an explosive/flammable hazard proposed?
 |  |  |  | If yes, submit the mitigation plan with the application.
 |  |  | If mitigation is proposed, does the mitigation plan involve ground disturbance (such as burial of a tank)? |  |  | N/A
 |  |  |  | If a mitigation plan involves ground disturbance, the Historic Preservation requirements for SHPO and Tribal consultation apply.  See the Historic Preservation section above.
 | 6. | [NAME] (24 CFR Part 51 Subpart D) | Is the project located in a runway clear zone at a civil airport, or a clear zone or accident potential zone (APZ) at a military airfield*?
 |  |  |  | If yes, inform the borrower that the property is in a Runway Clear Zone, APZ or Clear Zone, and of what the implications of such a location are; e.g., safety, potential eminent domain acquisition, etc.  Include the borrower's signed acknowledgement of the information in the application.  *This part applies to all military airfields and to civilian, commercial airports identified in the National Plan of Integrated Airport Systems prepared by the FAA.
 | 7. | Protection of Wetlands (24 CFR Part 55) | Are wetlands, either identified on the USFWS National Wetlands Inventory Map or other wetlands as defined in 24 CFR 55.2(b)(11), located on or adjacent to the site?
 |  |  |  | If the answer is yes, will the project involve construction activities that may impact a wetlands, including draining, dredging, channelizing, filling, diking, or impounding? |  | N/A
 |  |  |  | If the project will involve construction activities that may impact a wetlands, including draining, dredging, channelizing, filling, diking, or impounding, HUD must conduct the 8-step decision making process described at 24 CFR 55.20. Provide the necessary information in the application (plans, wetland determinations, permits, expected impacts, etc.).
 | 8. | Toxic Chemicals and Radioactive Materials  (24 CFR 50.3(i)) | Phase I Environmental Site Assessment (ESA) prepared by (name of firm):
 |  |  | Date that the Phase I ESA was conducted:
 |  |  |  | The Phase I ESA must be conducted (meaning a visual inspection of the site and adjoining properties, the records review, and interviews) within one year of the mortgage insurance application’s submission date to HUD (i.e., the date the application entered ORCF's queue).  However, a Phase I ESA that was conducted more than 180 days prior to the submission date to HUD, but within the allowable one-year period, must be updated pursuant to Section 4.6 of ASTM E1527-13 (or similar section of the most recent edition).  A Phase I ESA originally prepared more than one year prior to submission to HUD, even if updated within 180 days of submission to HUD, is not acceptable.
 |  |  | Was the Phase I ESA conducted within the acceptable timeframe? (See Phase I Clock tab)
 |  |  |  | If not, then do not submit the application to HUD until a Phase I ESA that satisfies the timing requirements is obtained.
 |  |  | Does the Phase I ESA include a Vapor Encroachment Screen (VES) performed in accordance with ASTM E 2600 (most recent edition)?
 |  |  |  | If not, then do not submit the application to HUD until a VES is obtained. The Phase I ESA must incorporate an initial vapor (a.k.a. gas) encroachment screen to determine if there is a potential for vapors to occur in the subsurface below existing and/or proposed on-site structures.
 |  |  | Did the Phase I ESA assess the entire project site, including all parcels of land that will be subject to the mortgage?
 |  |  |  | If not, then do not submit the application until a Phase I ESA that encompasses the entire property is obtained.
 |  |  |  | Land area of the property according to the Phase I ESA:
 |  |  |  | Land area of the property according to the Legal Description/Site Survey:
 |  |  |  | Land area of the property according to the Appraisal:
 |  |  | The Phase I ESA must provide a conclusion (a or b below) regarding Recognized Environmental Conditions:
 |  |  | a. Did the Phase I ESA conclude that the assessment "has revealed no evidence of recognized environmental conditions in connection with the property"?
 |  |  |  | Or
 |  |  | b. Did the Phase I ESA conclude that the assessment "has revealed no evidence of recognized environmental conditions in connection with the property except for the following:"?
 |  |  | If "b" is yes, a Recognized Environmental Condition (REC) or Vapor Encroachment Condition (VEC) was identified.  Was further study (e.g., Phase II testing) and site characterization done in accordance with HUD guidelines?
 |  |  |  | Any Recognized Environmental Condition (REC) or Vapor Encroachment Condition (VEC) must be resolved, or must have an approved remediation plan in place, before the submission of the application.
 | 8. | Toxic Chemicals and Radioactive Materials (continued) | Is remediation required?
 |  |  |  | If the answer is yes, then evidence of approval of the remediation plan by the applicable local, state, tribal, or federal authority must be submitted with the application.  The remediation plan must cover all relevant contaminant phases: vapor (gas), liquid, solid, dissolved, and non-aqueous phase liquid (NAPL).  If a remediation plan involves ground disturbance, the Historic Preservation requirements for SHPO and Tribal consultation apply, as described in the Historic Preservation section above.
 |  |  | Is an underground storage tank (UST) containing, or previously containing, hazardous waste or petroleum products located on the site?
 |  |  | If the answer is yes: |  |  | N/A
 |  |  |  | Was the UST identified as a REC?
 |  |  |  | Is the UST regulated by the State?
 |  |  |  | If a UST is neither a REC nor regulated by the State, HUD will still require information to evaluate the environmental risk that the UST presents to the site. Information regarding the UST, such as the age of the tank and associated systems, monitoring history, an operations & maintenance plan (O&M), leak detection, any Phase II results, spill prevention, corrosion protection and, when applicable, closure documentation should be submitted with the application.
 |  |  | Was an underground storage tank (UST) containing hazardous waste or petroleum products previously located on the site?
 |  |  | If the answer is yes: |  |  | N/A
 |  |  |  | Was closure/removal documentation provided?
 |  |  |  | Was a Phase II study completed?
 |  |  |  | If a UST was previously removed from the property, HUD will require information to evaluate the environmental impact that the former UST may have had on the site. The Phase I ESA must determine if the former UST is considered to be REC, and if so, then the REC must be satisfactorily addressed before the application is submitted. Information such as removal documentation and Phase II study results should be submitted with the application.
 |  |  | Is a monitoring well located on the site?
 |  |  |  | Monitoring wells are only acceptable under certain conditions. See HUD environmental guidance for monitoring well requirements.  Non-operating wells must be capped over and closed out pursuant to the requirements of the local, state, tribal or federal authority.
 | 9. | [NAME] | Does the project involve any construction (e.g., a building addition) or site work (such as tree removal, site clearing/alterations) that may affect endangered species or critical habitats?
 |  |  |  | If yes, obtain a list of protected species from the US FWS website.  Include the information in the application and indicate whether or not there are endangered species or critical habitats in the project's area.
 | 10. | Sole Source Aquifers | Is the project site located on a Sole Source Aquifer AND does the project include any activities beyond acquisition, refinancing, or rehabilitation of existing buildings?
 |  |  |  | If yes, then the project must comply with EPA requirements for activities that may affect a Sole Source Aquifer.
 | 11. | Coastal Zone Management | The Coastal Zone Management Act of 1972 only applies to HUD-assisted activities proposing new construction, conversion of land use, major rehabilitation of existing structures (including substantial improvement), or the acquisition of undeveloped land. Projects that can affect the coastal zone must be carried out in a manner consistent with the state coastal zone management program
 |  |  | Does the project involve new construction, conversion, major rehabilitation, substantial improvement activities, or the acquisition of undeveloped land, and is it located in a designated Coastal Zone?
 |  |  |  | If the answer is yes, the project must be consistent with the State's coastal zone management program. Work with the state coastal commission to obtain a consistency determination and provide the information with the application.  Coastal Zone Management information for states with designated coastal zones is available on the NOAA Office of Ocean and Coastal Resource Management website.
 | 12. | Asbestos | Was any building on the property constructed in whole or in part before 1978?
 |  |  |  | For any building that was constructed in whole or in part before 1978, a comprehensive asbestos survey performed  by a qualified asbestos inspector pursuant to the “baseline survey” requirements of ASTM E 2356-10 must be provided with the application
 |  |  | Was an asbestos survey performed?
 |  |  |  | If an asbestos survey indicates that asbestos is present or is suspected to be present, then prior to closing the borrower must provide a certification stating that the facility has adopted and implemented a property-specific Asbestos Operations and Maintenance plan.   If there is asbestos that is friable or damaged, HUD requires that it be removed. Asbestos remediation may be indicated as a Firm Commitment condition if HUD approves.  If there is asbestos that is not friable or damaged, HUD recommends that at a minimum it be encapsulated, which would be incorporated in the Operations and Maintenance plan.
 | 13. | Other HUD Environmental Requirements
 |  | High Pressure Pipelines |  | All parts of any structure must be at least 10 feet from the outer boundary of the easement for any high pressure gas or liquid petroleum transportation pipeline. Is the project in compliance?
 |  | Fall Zones |  | Are all buildings located outside the engineered fall distance of any support structure for high voltage transmission lines, radio antennae, satellite towers, cellular towers, etc.?
 |  | High Voltage Line Easements |  | No structure may be located within the easement of any overhead high voltage transmission line.  Is the project in compliance?
 |  | Railroads |  | a) Is a railroad located within 100 feet of the site?
 |  |  |  | Buildings closer than 100 feet from a railroad track are often subject to excessive vibration transmitted through the ground.  New construction at such sites is discouraged.  For existing structures, the building should be examined for damage caused by vibrations.  A railroad vibration study may be required.
 |  |  |  | b)  A rail line may not bisect a property, nor should a rail line’s right-of-way encroach upon the site.  Is the project in compliance?
 |  | Radon |  | THIS SECTION RESERVED Radon testing and review requirements for Section 232 projects will be published after the release of the Large Building testing and mitigation standards by AARST.