1. HUD’S 8-Step Process – Potential Pitfalls
Step 1: Determine if a proposed action is in a floodplain or wetland
Key Point: Accurate Site Characteristics (ALTA, Wetland Delineation, Area of Disturbance, Off-Site etc.)
Step 2: Early public review
Key Point: HUD involvement for Language & Syntax (and ensure site description accuracy!)
Step 3: Identify and evaluate practicable alternatives to locating in the floodplain
Key Point: Discuss with Developer (this action can be considerable work for the borrower)
Step 4: Identify and evaluate impacts of the proposal
Key Point: Abundance of paperwork, so be organized and have ALL documents
Step 5: Minimize, restore, and preserve
Key Point: This should be completed as Step 1A, possibly to avoid the 8-Step! Let me explain……
Step 6: Re-evaluate alternatives
Key Point: Easy Peasy – redo Step 3, but in light of new information from Steps 4 and 5
Step 7: Findings and public explanation.
Key Point: HUD communication for Language and Syntax; as well as informal approval of Steps 1 through 6
Step 8: Implementation
Key Point: Reporting is prescriptive based upon Steps 1-7; and then there is HUD’s technical review…..