There are five different types of environmental review and selecting the correct one is based upon the proposed project activities.
Exempt and “CENST” or Categorically Excluded Not Subject to 58.5
The Exempt level of review applies to projects that have no physical component, only planning or administration such as:
- Grant management and administration
- Environmental studies or assessments, engineering and design costs
- Information and financial services
- Public services
- Purchase of insurance, tools
- Technical assistance and training
- Inspection and testing of properties
A complete list of exempt activities can be found at 24 Part 58.34(a).
“CENST” or Categorically Excluded Not Subject to 58.5
Projects applicable for the CENST level of review have no physical component and acceptable activities include:
- Tenant-based rental assistance
- Supportive services including health care, housing services, permanent housing placement, etc.
- Operating costs, including maintenance, security, etc.
- Economic development activities
- Activities to assist homebuyers to purchase existing dwelling units
- Affordable housing pre-development costs, legal, consulting, admin costs (i.e., “soft costs”)
- Approval of supplemental assistance to a project previously approved under Part 58
A complete list of activities eligible for CENST level of review can be found here.
Both Exempt and CENST levels of environmental review use the same file that can be accessed on the HUD Exchange.
“CEST” or Categorically Excluded Subject to 58.5
The CEST level of review applies to projects that have a limited physical component, such as:
- Acquisition, repair, improvement, reconstruction, or rehabilitation of existing public facilities and improvements (other than buildings) without change in size or capacity of more than 20 percent. For example:
- Replacement of water or sewer lines
- Reconstruction of curbs and sidewalks
- Repaving of streets
- Special projects directed to the removal of material and architectural barriers that restrict the mobility of and accessibility to the elderly and handicapped persons
- Rehabilitation of building and improvements under specific conditions
- An individual action on a single family property (maximum four units on one site) or scattered sites
- Acquisition or disposition of, or equity loans on an existing structure, or acquisition of vacant land provided that the structure or land acquired, financed, or disposed of will be retained for the same use.
- Combinations of the acceptable activities
A complete list of activities eligible for CEST level of review can be found at 24 CFR 58.35(a) and the template file to use is available here. A CEST environmental review is a “mini” Environmental Assessment.
Environmental Assessment
If your project is not exempt or categorically excluded (CEST or CENST), an Environmental Assessment (EA) must be prepared. EAs are typically required when the proposed project has activities such as new construction or a change in land use. A complete list of EA requirements can be found here and the template file to use is available here.
If you believe your project may be eligible for a tiered environmental review or need an environmental impact statement (EIS), please contact the HCD Environmental Services Team.