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  County Administrator's Report     11. 2.    
BCC Regular Meeting Discussion  
Meeting Date: 07/18/2017  
Issue:    HUD Environmental Review for Continuum of Care Programs
From: Tonya Gant
Department: Neighborhood & Human Svcs  
CAO Approval:

RECOMMENDATION:
Recommendation Concerning the U.S. Department of Housing and Urban Development Environmental Review for Continuum of Care Programs - Tonya Gant, Neighborhood & Human Services Director

That the Board consider whether the County will be the responsible entity for U.S. Department of Housing and Urban Development (HUD) Environmental Reviews for the Continuum of Care Programs, whether the Neighborhood Enterprise Division can undertake the Reviews for Escambia and Santa Rosa Counties, and whether to authorize the County Administrator to sign off on the reviews.
BACKGROUND:
HUD has recently starting requiring the local homeless Continuum of Care (COC) programs to undertake National Environmental Policy Act (NEPA) reviews for its projects. The only agencies that can serve as responsible entities under 24 CFR Part 58 are either the local government or HUD. The environmental reviews must be performed before any funds can be expended on a HUD project. The local COC has inquired as to whether the County can undertake these reviews for them. The reviews encompass six projects receiving awards from HUD through the COC, with EscaRosa Coalition on the Homeless (ECOH) serving as the lead agency. The Projects totaling $784,376 are as follows:

1. Lakeview Center-Permanent Supportive Housing
2. Lakeview Center-Permanent Supportive Housing
3. Loaves and Fishes Soup Kitchen-Transitional Housing
4. ECOH-HMIS
5. ECOH-COC Planning Grant
6. ECOH-Centralized Coordinated Entry (Supportive Services)

The ECOH projects are exempt under 24 CFR Part 58 and should take minimal staff time to review and complete. The supportive and transitional housing projects will require a bit more of a review, but most should fall under a limited scope review  due to the leasing activities being supported by Lakeview Center and Loaves and Fishes Soup Kitchen.  The housing activities encompass both Escambia and Santa Rosa counties. Due to the timing of the request received by COC partners, HUD will be performing the environmental review for one of the Lakeview Center housing projects so as not to delay project start, so County staff will only be reviewing 5 projects at this time. It is anticipated that it will take staff a few days to complete paperwork (sample attached) and associated backup required by HUD unless some unforeseen finding is discovered during the environmental review.

The Environmental Review is required on an annual basis by HUD. If the Board supports County staff preparing the review, staff will need direction as to whether this approval is good for one year or continuously.
BUDGETARY IMPACT:
Not applicable. The Continuum of Care funding does not come through the County, but is directly granted to COC agencies. It is not anticipated that any of the current proposed projects will require the County to publish a public notice and request for release of funds. If a public notice were needed, there COC would have to support the cost of publication as there is not currently funding budgeted for this purpose in County funds.
LEGAL CONSIDERATIONS/SIGN-OFF:
Not applicable.
PERSONNEL:
Neighborhood Enterprise Division (NED) staff would have to perform the reviews in addition to their usual responsibilities.
POLICY/REQUIREMENT FOR BOARD ACTION:
Board authorization is required for the County Administrator to sign off on the Environmental Review record as prepared by NED staff.
IMPLEMENTATION/COORDINATION:
If approved by the Board, NED will coordinate information needed from the COC, including ECOH, Loaves and Fishes, and Lakeview Center for completion of the environmental review and subsequent submission to HUD.

Attachments
ERR Exempt-CENST

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