Navigating HUD’s MAP Environmental Requirements

In order to obtain FHA Mortgage Insurance for market rate and affordable multi-family housing projects, owners must strictly comply with requirements of HUD’s Multi-Family Accelerated Processing (MAP) Guide (revised January 2016). The prospect of non-recourse loans with long(er) terms and fixed rates make the process worth it for many, particularly not-for profit organizations and larger organizations.

MAP may be used for the following National Housing Act (NHA) programs:

  • 220 – new construction or substantial rehab of apartments
  • 221(d)(4) – new construction or substantial rehab of apartments
  • 223(a)(7) – refinance of FHA-insured mortgages
  • 223(f) – refinance or purchase of existing apartments
  • 231 – new construction or substantial rehab of housing for the elderly

Chapter 9 of HUD’s MAP Guide clearly defines the Environmental Review and Requirements for each of the NHA programs listed above. Every project includes an environmental consultant, a MAP-approved lender, and HUD’s Multi-Family Regional personnel – working together.

A Contamination Analysis must be completed in accordance with Section 9.3 of the MAP Guide. The first step is always a Phase I ESA in accordance with ASTM E1527-13 and a Tier 1 Vapor Encroachment Screen (VES) in accordance with ASTM E2600-11, as well as a discussion of Additional Nuisances or Hazards (Section 9.5P of MAP Guide). When needed, a follow-on Phase II ESA, which includes a Tier 2 VES, is conducted in accordance with ASTM E1903-11 and ASTM E2600-15, respectively. If necessary, remediation plans and implementation of found contamination on-site or off-site must adhere to Section 9.3 and 9.4 of the MAP Guide.

Lead-based paint; Asbestos; and Radon must be evaluated and must be compliant with Federal and local requirements. These requirements are discussed in Sections 9.5A, 9.5B and 9.5C of the MAP Guide.

National Environmental Policy Act (NEPA) and the laws and authorities of 24 CFR 50.4, 58.5, and 58.6 must be addressed as follows (NEPA Environmental Factors): Historical Preservation; Flood Management & Flood Insurance; Wetlands Protection; Endangered Species; Noise; Explosives; Coastal Barrier Resources; Coastal Zone Management; Sole Source Aquifers; Airport Hazards and Runway Clear Zones; Environmental Justice; and Wild Scenic Rivers – Farmland Protection – Clean Air Act.

Larger projects such as new construction, major rehabs and conversions require compliance with additional Environmental Assessment Factors (40 CFR 1508.8 & 1508.27), including Land Development, Socioeconomic, Community Facilities and Services, and Natural Features.

HUD has created an Environmental Review Partner Submission Form and Partner Worksheets to assist “Partners” such as consultants with gathering, completing and submitting information to MAP Lenders and HUD for NEPA Environmental Factors and additional Environmental Assessment Factors.

To view the full MAP Guide, click here.