HUD 221(d)4 Wetlands Confusion

A recent HUD 221(d)(4) Environmental Review created confusion related to the initial wetlands evaluation at the subject Site. Indications of wetlands were not present during the site visit, however, the Wetlands National Inventory was showing a potential riverine wetland on Site. Typically, in a case like this, a wetland delineation is required which can be both time consuming and expensive.

We pursued this case further to obtain a determination from FWS and USACE. Ultimately, USACE agreed to meet us on site to make a final determination, concluding that the riverine indicated on the NWI was an artifact thus clarifying that no wetland was present on Site.

It is critical — when performing HUD Environmental Reviews — that you understand the most expeditious and scientifically appropriate procedures for resolving environmental concerns.

For more information, contact Fabien Cinus at


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