HUD Environmental Review Online System HEROS Training for Tribes and Partners JULY 18, 2018
Purpose of Conducting Environmental Reviews Assurance that HUD projects are decent, safe, and sanitary ◦ Analysis of the impact of a project on the surrounding environment and the impact the surrounding environment will have on a project Documentation of compliance with up to 17 federal environmental laws and authorities ◦ Public documents that encourage public participation ◦ Requirement under the National Environmental Policy Act (NEPA) • Requires all Federal agencies to adopt a systematic interdisciplinary approach to decision‐making to ensure environmental values are considered *For training resources on environmental review, please view the WISER modules and environmental resources on the HUD Exchange
Environmental Review Record (ERR) NEPA administrative record for each project ◦ Includes maps, correspondence, determinations, findings, photographs, plans, public notices, etc. Public has the right to review ◦ Maintain with the public’s interest in mind Must use correct formats ◦ Previously: Form HUD‐4128, Form 7015.15, Form 7015.16 ◦ Now: HEROS‐Form HUD‐4128, HEROS Form 7015.15, HEROS Form 7015.16
What is HEROS?
What is HEROS? HEROS is a HUD system that replaces HUD’s current paper‐based environmental review process: Form 4128 Form 7015.15 Form 7015.16 Worksheets and paper formats HEROS walks users through the entire environmental review process from beginning to end, including compliance with related laws and authorities. It works for Part 50 and Part 58 environmental reviews in all HUD programs.
HEROS Availability HEROS was introduced to programs/users on a rolling schedule. ONAP is participating in a HEROS pilot through October 2018. ONAP pilot participants (Tribes, TDHEs, consultants, and PHAs) may register for HEROS and use it to conduct environmental reviews. Pilot participants will provide feedback during the pilot period ONAP and the HEROS team will hold monthly webinars to gather feedback on the functionality of HEROS for ONAP programs and grantees. Starting in November 2018, HUD will open up HEROS registration to all Tribes and their partners. The Partner User Role in HEROS is only available to ONAP pilot participants, FHA Multifamily, and the RAD program at this time. • HUD plans to allow Partners to use HEROS for Public Housing and CPD reviews later in 2018
HEROS Pilot Participants • North Circle Indian Housing • Aleutian Housing Authority Authority with Agdaagux Tribe of King Cove • Cherokee Nation • Confederated Tribes of Siletz • Chickasaw Nation Indians • Metlakatla Regional Housing • Hannahville Indian Authority Community • Tlingit Haida Regional Housing • Aroostook Band of Micmacs Authority • Department of Hawaiian • Knik Tribe Homelands • Interior Regional Housing • Eastern Shoshone Housing Authority Authority • Choctaw Naton • Paiute Indian Tribe of Utah • Rosebud Sioux Tribe • Crow Tribe
Who’s Who in HEROS? Responsible Entity (RE) HUD Preparer Tribe Partner ECO TDHEs FEO/REO review and comment 3 rd Party Consultants on EAs over 200 units
HEROS has HUD Responsible Entities Four Basic • Perform Part 58 reviews •Perform Part 50 reviews •Approve, monitor Part 58 User Roles reviews User Roles in HEROS Partners State Agencies •Assist HUD and REs with •Act as HUD for certain Part 50 and Part 58 CPD programs reviews
Environmental Reviews: Part 58 : Tribes prepare the environmental review and Request for Release of Funds, submit to HUD for completion of the Authority to Use Grant Funds. • If the Tribe works with a TDHE or third‐party consultant, those partner users may enter supporting documentation into HEROS. • The Tribe must independently evaluate their work & complete the environmental reviews before submitting to HUD. Part 50 : HUD prepares the environmental review and may work with TDHEs or their consultants to assist with the supporting documentation. • If HUD works with a TDHE or their consultant, those partner users may enter supporting documentation into HEROS. • HUD must independently evaluate their work & finalize the environmental reviews. Certain aspects of environmental review (e.g. agency consultation) must be completed by the Tribe or HUD.
Partner Users and Organizations Partner User Jane Doe Joe Consultant Partner Enviro TDHE Consultants Inc. Organization (or also TDHE) Responsible HUD Tribe Entity/HUD
HEROS Process for Partners 1. With this pilot, Tribal partners can now input this information directly into HEROS. HEROS screens are equivalent to the Partner Worksheets on the HUD Exchange. 2. Partners can enter information in HEROS up to a certain point in the review, after which they will be required to assign the review to the Tribe or to HUD.
Part 50: HEROS Process for HUD Preparers HUD preparer reviews information directly in HEROS ◦ Follow up with partners for any missing information ◦ Complete all findings and determinations that must be made by HUD ◦ Get all required signatures in HEROS
Part 58: HEROS Process for RE Preparers Tribe reviews information directly in HEROS ◦ Follow up with partners for any missing information ◦ Complete all findings and determinations that must be made by the Tribe/RE ◦ Submit the Request for Release of Funds (RROF) to HUD
Part 58 Example Process Partner User (TDHE/Consultant) initiates review, enters project information Partner User (TDHE/Consultant) conducts initial analysis, uploads maps and documents Responsible Entity (Tribe) reviews information entered by third party provider, makes findings and determinations, submits RROF to HUD HUD User reviews RROF, authorizes AUGF
Conducting A Review in HEROS
Cheat Sheets Cheat sheets will have detailed information on how to comply with Program requirements
Initiate the review in HEROS and define project I nitiate the review in HEROS and define project •Tribe or Partner must initiate review •Tribe or Partner must initiate review Initiate Determine the level of review Determine the level of review •Partners may make initial recommendation, •Partners may make initial recommendation, but final determination must be made by the but final determination must be made by the Determine Tribe or HUD Tribe or HUD Steps in the Environmental Conduct the analysis and comply with related Conduct the analysis and comply with related Review environmental laws and authorities environmental laws and authorities •Partners should initiate, but many steps must •Partners should initiate, but many steps must Comply be completed by the Tribe or HUD be completed by the Tribe or HUD Finalize review Finalize review •The Tribe or HUD must make findings and •The Tribe or HUD must make findings and determinations, sign and post environmental determinations, sign and post environmental Finalize review record review record
Logging In B12345
HEROS Dashboard
Getting Started
Initial Screen 22
Entering Partner Information
Text Tips
Project Summary Screen
Project Summary Screen Field on Screen 1125 Response for Either Program Description of the Provide a project description that captures the maximum anticipated proposed project scope of the proposal. It should include all contemplated actions which logically are, either geographically or functionally, a composite part of the project, regardless of the source of funding. Describe all physical aspects of the project, such as plans for multiple phases of development, size and number of buildings, and activities to be undertaken. Include details of the physical impacts of the project, including whether there will be ground disturbance. If more space is required, upload a separate document below. Address Provide a representative street address for the project Location Information If the project involves new construction, affects more than one street address, or otherwise requires further explanation, describe the full geographic scope of the project in this space Upload Upload any site maps, photos, and other information on the project description and location Field Inspection Leave this section for HUD or the Tribe to complete
Project Description: Meaningful project descriptions include… Location —describe so the public can locate Purpose and Need —describe what is being done and why it is necessary Project Beneficiaries (i.e. affordable housing project, mixed use housing project, market rate housing project) Description —provide complete details about the project/what will be done All activities (e.g. new construction of multifamily or single family housing, rehabilitation of existing buildings) Physical description of existing and/or proposed new buildings Timeframe for implementation Size of the project (area coverage, disturbance footprint, number of units, population served) All funding sources All development partners Note for Partners: Review by the HUD (for Part 50 reviews) or Tribal preparer (for Part 58 reviews) for accuracy and completeness is required
Determining Level of Review • If the review is started by a partner (TDHE, consultant), the preparer may make a preliminary level of review selection • Only the Tribe or HUD can make the final level of review determination, and must approve Partner’s selection • Refer to the HUD Exchange for information on determining level of review
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