HUD Environmental Review - Environmental Assessment Requirements

The U.S. Department of Housing and Urban Development (HUD) requires environmental reviews for housing projects to be completed prior to approval of financial assistance. The objective of the review process is to ensure that due diligence has been undertaken in identifying potential impacts, including both environmental and non-environmental impacts, associated with projects that use HUD funds.

The HUD Environmental Review process is driven by two regulations: 24 CFR Part 50 and 24 CFR Part 58. Part 50 pertains to the Department of Housing and Urban Development and those entities that have legal responsibilities to the Secretary of the Interior and Part 58 pertains to those entities that do not have legal responsibilities to the Secretary (e.g., community housing and “faith-based” organizations).

The level or extent of the HUD Environmental Review is dependant on the type of proposed work, the number of units, or a percentage of total area can be a threshold. Under both Part 50 and Part 58, exemptions, categorical exclusions, documented categorical exclusions exist.

Caltha LLP provides expert consulting services to public sector and non-profit sector clients around the county to address HUD Environmental Review and HUD Environmental Assessment requirements.

Caltha Environmental Review Website

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EPA Withdraws Emission Comparable Fuels Rule

EPA has withdrawn the Emission Comparable Fuels (ECF) Rule, which had been finalized in December 2008. The ECF rule sought to reduce regulatory burdens by reclassifying fuels that would otherwise be regulated as hazardous waste, but generate emissions similar to fuel oil when burned.

Due to difficulty of ensuring that emissions from burning ECF are comparable to emissions from burning fuel oil, EPA has now withdrawn the rule. The ECF rule was criticized for potentially allowing hazardous waste to evade the hazardous waste regulatory system, and for being difficult to administer. Industry members have also criticized it because of the detailed conditions for reclassification, which they believe will limited the rule’s use.

Caltha LLP provides expert environmental consultant services in Ohio to obtain environmental permits, evaluate regulatory requirements, and to develop cost effective compliance programs.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Amended Greenhouse Gas Mandatory Reporting Rule

On September 22, 2009, EPA finalized the Greenhouse Gas (GHG) Mandatory Reporting Rule. This rule requires facilities with direct GHG emissions over 25,000 metric tons of carbon dioxide equivalent (CO2e), suppliers of petroleum, natural gas, and industrial gases as well as vehicle and engine manufacturers outside the light duty sector to report to EPA annually.

The data collection starts on January 1, 2010, and the first reports to EPA are due on March 31, 2011. As part of that first report, EPA is now proposing that reporters also include the name of their Corporate Parent and North American Industry Classification System (NAICS) code. In developing the final rule, EPA received comments that this type of information would be useful to the public and EPA, particularly in assisting corporations in assessing emissions at their different facilities and operations. Therefore, EPA has proposed to include these two data elements in the reports and is seeking public comments on the most efficient way of defining and collecting these elements. EPA is also taking comment on whether or not to have reporters list the existence of a co-generation unit at their facility. Timeline

The Comment Period on the proposed amendments to reporting requirements will close June 11, 2010 and EPA anticipated the final rule will be published in October 2010

Caltha LLP provides specialized expertise to clients in Ohio in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website