Continuum of Care Special Needs Assistance Contract with HUD_Phoenix Copyright 2014
City of Dubuque Consent Items # 9.
ITEM TITLE: U.S. Department of Housing and Urban Development Contract -
Continuum of Care Special Needs Assistance Program
SUMMARY: City Manager recommending approval of the execution of the contract with
the U.S. Department of Housing and Urban Development for
administration of the Continuum of Care Special Needs Assistance
Program (formerly Shelter Plus Care).
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Approve
ATTACHMENTS:
Description Type
❑ Continuum of Care Program Contract-MVM Memo City Manager Memo
❑ Memo Staff Memo
❑ Contract Supporting Documentation
THE CITY OF Dubuque
UBE I
erica .i
Masterpiece on the Mississippi 2007-2012-2013
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Continuum of Care Program Contract
DATE: August 13, 2015
Housing and Community Development Department Director Alvin Nash recommends
City Council approval of the execution of the contract with the U.S. Department of
Housing and Urban Development for administration of the Continuum of Care Special
Needs Assistance Program (formerly Shelter Plus Care).
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Micliael C. Van Milligen
MCVM:jh
Attachment
cc: Barry Lindahl, City Attorney
Cindy Steinhauser, Assistant City Manager
Teri Goodmann, Assistant City Manager
Alvin Nash, Housing and Community Development Director
THE CITY OF E Dubuque
DUBAll-America City
11111.1
Masterpiece on the Mississippi 2007.2012.2013
August 3, 2015
To: Michael C.Van Milligen, City Manager
From: Alvin Nash, Housing and Community Development Director
RE: Continuum of Care Program Contract
Introduction
The purpose of this memorandum is to request City Council approval of the contract with the
U.S. Department of Housing and Urban Development (HUD) for administration of the
Continuum of Care Special Needs Assistance Program (formerly Shelter Plus Care).
Discussion
Attached is the July 29, 2015 memorandum awarding the City of Dubuque funds to administer
the program. The grant is a result of the Federal Fiscal Year 2014 Homeless Assistance Grants
competition awarded in the amount of$76,531. The program provides for rental assistance to
homeless individuals/families with disabilities.
As the grantee, the City of Dubuque has oversight responsibility for the administration of the
program. Project Concern provides the case management and supportive services to program
participants as the sponsor agency. The Housing Department will monitor all operations to
ensure compliance with program requirements. Funds for the program will be electronically
deposited to the Finance Department's account and disbursed monthly for rental assistance
payments to area landlords.
Action Requested
respectfully request your approval along with City Council's approval to execute the contract
with HUD and authorize the Director of Housing and Community Development's signature on
the HUD Contract.
Dubuque@Home is an initiative of the City of Dubuque Housing&Community Development Department
350 W.6t"St.,Dubuque,Iowa 52001 1 Phone:563.589.4230 1 www.cityofdubuque.org/dubuqueathome
o�eP��MQ N�oFyoil U.S.Department of Housing and Urban Development
Omaha Field Office
y° II11101 ` Edward Zorinsky Federal Building
1616 Capitol Avenue,Suite 329
01�9AAt DEVOe Omaha, Nebraska 68102-4908
July 29, 2015
Mr. Alvin Nash
Director
City of Dubuque
350 W 6" St., Ste. 312
Dubuque, IA 52001
Dear Mr. Nash:
SUBJECT: Transmittal of Continuum of Care Program Grant
CoC Number and Name: IA-501 —Iowa Balance of State CoC
Project Name: Phoenix Housing Special Needs Assistance
Project Number: IA0061L7D011404
Congratulations on your final selection for funding under the Department of Housing and Urban
Development's (HUD) FY 2014 Homeless Assistance Grants competition. All conditions attached to
your award for this project have been met. Addressing homelessness is one of the Department's top
priorities and your project will make a significant contribution toward developing a continuum of care
system in your community.
Enclosed are three copies of the Scope of Work Exhibit for your grant funded with FY 2014
Continuum of Care Program funds. The enclosed Exhibit should be attached to the FY 2012 Continuum
of Care Program Agreement between HUD and your agency. The FY 2012 Agreement and the attached
Exhibit will be used to administer your award. Please sign all copies of the enclosed Exhibits and return
two to this office within 10 days of the date of this letter. Retain one executed Exhibit for your records.
Upon execution of the Exhibit by you and HUD, HUD will obligate the funds for this project. No
funds can be disbursed to you until the Exhibit is fully executed.
The Omaha HUD Office received the Environmental Review for the City of Dubuque Phoenix
Housing project on July 17,2015.
If you have any questions regarding this matter, please c tact Mr. Charlie House, CPD
Representative, at(402) 492-3173 or email at Charlie.R.House@hud. v
Sine �3
r
im everin
Dir ctor
Community Planning and
Development Division
Enclosures
cc: Janet Walker,Assisted IIousing Supervisor
Tax ID Number: 42-6004596
Original CoC Grant Number: IA006IL7D011202
CoC Program Grant Number: IA006IL7D011404
DUNS Number: 093105302
SCOPE OF WORK EXHIBIT for the FY 2014 CoC PROGRAM COMPETITION
1. This Agreement is governed by the Continuum of Care program Interim Rule attached
hereto and made a part hereof as Exhibit 1 a. Upon publication for effect of a Final Rule
for the Continuum of Care program, the Final Rule will govern this Agreement instead of
the Interim Rule. The project listed on this Exhibit at 5., below, is also subject to the terms
of the FY 2014 Notice of Funds Availability.
2. This Exhibit,providing an additional award of funding, is added to the Continuum of Care
Program Grant Agreement identified above by the Original CoC Program Grant Number,
under the authority of the fifth paragraph of the Original CoC Program Grant Agreement.
The funding provided through this Scope of Work will be referred to by the Renewal
Award Number listed above.
3. The grant term applicable to funds shall be 1 year which shall run from 07-01-2015 to 06-
30-2016
4. The Continuum that designated Recipient to apply for grant funds is not a high-performing
community.
5. Recipient is not a Unified Funding Agency and was not the only Applicant the Continuum
of Care designated to apply for and receive grant funds and is not the only Recipient for
the Continuum of Care that designated it. HUD's total funding obligation for this grant
is $76531 for project number IA0061 L7D011404. hl accordance with 24 CFR
578.105(b),Recipient is prohibited from moving more than 10% from one budget line item
in a project's approved budget to another without a written amendment to this Agreement.
The obligation for this project shall be allocated as follows:
www.hud.gov espanol.hud.gov Page 1
a. CoC Planning cost $ 0
b. Acquisition $ 0
c. New construction $ 0
d. Rehabilitation $ 0
e. Leasing $ 0
f. Rental assistance $ 72600
i. Tenant-based rental assistance $
ii. Project-based rental assistance $
iii. Sponsor-based rental assistance $
g. Supportive services $ 0
h. Operating costs $ 0
i. HMIS $ 0
j. Administration $ 3931
6. No funds for new projects may be drawn down by Recipient until HUD has approved site
control pursuant to §578.21 and §578.25 and no funds for renewal projects may be drawn
down by Recipient before the end date of the project's final operating year under the grant
that has been renewed.
7. Nothing in this grant agreement shall be construed as creating or justifying any claim
against the federal government or the grantee by any third party.
www.hud.gov espanol.hud.gov Page 2
This agreement is hereby executed on behalf of the parties as follows:
UNITED STATES OF AMERICA,
Secretary of Housing and Urban Development
By: t;
r �-
(Signature)
Francis T Severin, Director
(Typed Name and Title)
July 29, 2015
(Date)
RECIPIENT
City of Dubuque
(Name of Organization)
By:
(Signature of Authorized Official)
Alvin Nash, Director
(Typed Name and Title of Authorized Official)
(Date)
www.hud.gov espanol.hud.gov Page 3
Tax ID Number: 42-6004596
Original CoC Grant Number: IA0061L7D011202
CoC Program Grant Number: IA006IL7D011404
DUNS Number: 093105302
SCOPE OF WORK EXHIBIT for the FY 2014 CoC PROGRAM COMPETITION
1. This Agreement is governed by the Continuum of Care program Interim Rule attached
hereto and made a part hereof as Exhibit 1 a. Upon publication for effect of a Final Rule
for the Continuum of Care program, the Final Rule will govern this Agreement instead of
the Interim Rule. The project listed on this Exhibit at 5., below, is also subject to the terms
of the FY 2014 Notice of Funds Availability.
2. This Exhibit, providing an additional award of funding, is added to the Continuum of Care
Program Grant Agreement identified above by the Original CoC Program Grant Number,
under the authority of the fifth paragraph of the Original CoC Program Grant Agreement.
The funding provided through this Scope of Work will be referred to by the Renewal
Award Number listed above.
3. The grant term applicable to funds shall be 1 year which shall run from 07-01-2015 to 06-
30-2016
4. The Continuum that designated Recipient to apply for grant funds is not a high-performing
community.
5. Recipient is not a Unified Funding Agency and was not the only Applicant the Continuum
of Care designated to apply for and receive grant funds and is not the only Recipient for
the Continuum of Care that designated it. HUD's total funding obligation for this grant
is $76531 for project number IA006IL7D011404. In accordance with 24 CFR
578.105(b),Recipient is prohibited from moving more than 10% from one budget line item
in a project's approved budget to another without a written amendment to this Agreement.
The obligation for this project shall be allocated as follows:
www.hud.gov espanol.hud.gov Page I
a. CoC Planning cost $ 0
b. Acquisition $ 0
c. New construction $ 0
d. Rehabilitation $ 0
e. Leasing $ 0
f. Rental assistance $ 72600
i. Tenant-based rental assistance $
ii. Project-based rental assistance $
iii. Sponsor-based rental assistance $
g. Supportive services $ 0
h. Operating costs $ 0
i. HMIS $ 0
j. Administration $ 3931
6. No funds for new projects may be drawn down by Recipient until HUD has approved site
control pursuant to §578.21 and §578.25 and no funds for renewal projects may be drawn
down by Recipient before the end date of the project's final operating year under the grant
that has been renewed.
7. Nothing in this grant agreement shall be construed as creating or justifying any claim
against the federal government or the grantee by any third party.
www.htid.gov espanol.hud,gov Page 2
This agreement is hereby executed on behalf of the parties as follows:
UNITED STATES OF AMERICA,
Secretary of Housing and Urban Development
(Signature)
Francis T Severin, Director
(Typed Name and Title)
July 29, 2015
(Date)
RECIPIENT
City of Dubuque
(Name of Organization)
By:
(Signature of Authorized Official)
Alvin Nash, Director
(Typed Name and Title of Authorized Official)
(Date)
www.hud.gov espauol.hud.gov Page 3
Tax ID Number: 42-6004596
Original CoC Grant Number: IA006IL7D011202
CoC Program Grant Number: IA006IL7D011404
DUNS Number: 093105302
SCOPE OF WORK EXHIBIT for the FY 2014 CoC PROGRAM COMPETITION
1. This Agreement is governed by the Continuum of Care program Interim Rule attached
hereto and made a part hereof as Exhibit 1 a. Upon publication for effect of a Final Rule
for the Continuum of Care program, the Final Rule will govern this Agreement instead of
the Interim Rule. The project listed on this Exhibit at 5., below, is also subject to the terms
of the FY 2014 Notice of Funds Availability.
2. This Exhibit,providing an additional award of funding, is added to the Continuum of Care
Program Grant Agreement identified above by the Original CoC Program Grant Number,
under the authority of the fifth paragraph of the Original CoC Program Grant Agreement.
The funding provided through this Scope of Work will be referred to by the Renewal
Award Number listed above.
3. The grant term applicable to funds shall be 1 year which shall run from 07-01-2015 to 06-
30-2016
4. The Continuum that designated Recipient to apply for grant funds is not a high-performing
community.
5. Recipient is not a Unified Funding Agency and was not the only Applicant the Continuum
of Care designated to apply for and receive grant funds and is not the only Recipient for
the Continuum of Care that designated it. HUD's total funding obligation for this grant
is $76531 for project number IA0061L7D011404. In accordance with 24 CFR
578.105(b),Recipient is prohibited from moving more than 10%from one budget line item
in a project's approved budget to another without a written amendment to this Agreement.
The obligation for this project shall be allocated as follows:
www.hud.gov espanol.hud.gov Page 1
a. CoC Planning cost $ 0
b. Acquisition $ 0
c. New construction $ 0
d. Rehabilitation $ 0
e. Leasing $ 0
f. Rental assistance $ 72600
i. Tenant-based rental assistance $
ii. Project-based rental assistance $
iii. Sponsor-based rental assistance $
g. Supportive services $ 0
h. Operating costs $ 0
i. HMI $ 0
j. Administration $ 3931
6. No funds for new projects may be drawn down by Recipient until HUD has approved site
control pursuant to §578.21 and §578.25 and no funds for renewal projects may be drawn
down by Recipient before the end date of the project's final operating year under the grant
that has been renewed.
7. Nothing in this grant agreement shall be construed as creating or justifying any claim
against the federal government or the grantee by any third party.
www.hud.gov espanol.hud.gov Page 2
This agreement is hereby executed on behalf of the parties as follows:
UNITED STATES OF AMERICA,
Secretary of Rousing and Urban Development
By: ;:li
—7
1
(Signature)
Francis T Severin, Director
(Typed Name and Title)
July 29, 2015
(Date)
RECIPIENT
City of Dubuque
(Name of Organization)
By:
(Signature of Authorized Official)
Alvin Nash, Director
(Typed Name and Title of Authorized Official)
(Date)
www.liud.gov espanol.hud.gov Page 3
U.S. Department of Housing and Urban
Development
451 Seventh Street, SW
Washington, DC 20410
www.hud.gov
espanol.hud.gov
Environmental Review for Continuum of Care Leasing or Rental
Assistance Project that is Categorically Excluded Subject to Section
58.5
Pursuant to 24 CFR 58.35(a)(5)
This CoC Limited Sco • e Review Format is to be used onl for leasin ' or rental assistance activities
without any associated repairs, rehabilitation, new construction, or other activities with physical impacts
funded under the Continuum of Care (CoC) program.
Certain fields have been completed already based on the specifics of these program activities. It is the
Responsible Entity's responsibility to ensure that all required fields (those marked with an asterisk) and
analysis are completed.
Project Information
*Project Name: Phoenix Housing Special Needs Assistance
*Responsible Entity: City of Dubuque
Grant Recipient (if different than Responsible Entity):
State/Local Identifier: NA
*Preparer: Erica Haugen
*Certifying Officer Name and Title: Mayor Roy D. Buol
Consultant (if applicable):
*Project Location: Scattered site leased units in the City of Dubuque
*Description of the Proposed Project [24 CFR 58.32; 40 CFR 1508.25]:
The Phoenix Housing Project has been in operation in Dubuque since 2007. The project's
goal is to provide permanent, supportive housing to homeless individuals/families with
disabilities. Agreements in place clarify duties of participants, private housing providers,
the City of Dubuque Public Housing Authority (PHA), the Sponsor Agency, Project
Concern, and referring agencies. Project Concern is the primary contact with the client.
Both agencies take pride in operating the Phoenix Housing project utilizing the `Housing
First Model.' Project Concern provides case management to participants (clients) which
includes: setting goals related to housing, increasing income and/or skills and setting
personal goals in order to create an overall better quality of life. The goals are set by the
client; the coordinator is there to assist clients with referrals, skill building and for overall
This format is to be used for leasing or rental assistance activities funded under the Continuum of Care
(CoC) program only.
support. The coordinator prepares a monthly supportive service report for each
participant to keep track of services accessed by the client, including mental health
services, substance abuse treatment and/or job training programs, as needed. Project
Concern works with apartment owners to secure suitable housing located at scattered sites
throughout the community and schedules appointments bi-monthly at the housing unit to
assist clients with housing needs or concerns. Inspections of these units are performed by
the City, as well as, conducting rent reasonableness comparisons and rent calculations.
The duration of the rental assistance is unlimited although the goal is to provide enough
support, guidance and services so that the individual/family is able to live independently
without fear of becoming homeless again.
*Level of Environmental Review Determination:
Categorically Excluded per 24 CFR 58.35(a), and subject to laws and authorities at §58.5, per 24
CFR 58.35(a)(5).
Funding Information
*Grant Number
*HUD Program
*Funding Amount
IA0061L7D011404
Continuum of Care (CoC)
$76,531
*Estimated Total HUD Funded Amount:
$76,531
*Estimated Total Project Cost (HUD and non -HUD funds):
$76,531
Compliance with 24 CFR 58.5 and 58.6 Laws and Authorities
Record below the compliance or conformance determinations for each statute, executive order, or
regulation. Provide credible, traceable, and supportive source documentation for each authority. Where
applicable, complete the necessary reviews or consultations and obtain or note applicable permits or
approvals. Clearly note citations, dates/names/titles of contacts, and page references. Attach additional
documentation as appropriate.
Compliance Factors:
Statutes, Executive Orders,
and Regulations listed at 24
CFR §58.5 and §58.6
Are formal
compliance
steps or
mitigation
required?
Compliance determinations
STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR 58.6
This format is to be used for leasing or rental assistance activities funded under the Continuum of Care
CoC •ro• amonl
Airport Hazards
24 CFR Part 51 Subpart D
Yes
❑
No
This project consists only of leasing or rental
and is in compliance with the
HUD's Airport Hazard regulations without
further evaluation.
•assistance
Coastal Barrier Resources
Coastal Barrier Resources Act, as
amended by the Coastal Barrier
Improvement Act of 1990 [16
USC 3501]
Yes
❑
No
*No CBRA in MO/KS/NE/IA
http://www.fema.gov/nfip/cobra.shtm
��
Flood Insurance
Flood Disaster Protection Act of
1973 and National Flood
Insurance Reform Act of 1994
[42 USC 4001-4128 and 42 USC
5154a]
Yes
No
*No sites will be selected in FEMA
Special Flood Hazard Areas.
•
•identified
STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR 50.4
& 58.5
Clean Air
Clean Air Act, as amended,
particularly section 176(c) & (d);
40 CFR Parts 6, 51, 93
Yes
❑
No
This project consists only of leasing or rental
and is in compliance with the
Clean Air Act without further evaluation.
•assistance
Coastal Zone Management
Coastal Zone Management Act,
sections 307(c) & (d)
Yes
No
This project consists only of leasing or rental
and is in compliance with the
Coastal Zone Management Act without
further evaluation.
0assistance
Contamination and Toxic
Substances
24 CFR 58.5(i)(2)
Yes
No
*No sites will be selected that require
mediation or are not in compliance with
HUD's Contamination and Toxic Substances
standards.
//
Endangered Species
Endangered Species Act of 1973,
particularly section 7; 50 CFR
Part 402
Yes
No
This project consists only of leasing or rental
assistance and is in compliance with the
Endangered Species Act without further
evaluation.
•
Explosive and Flammable
Hazards
24 CFR Part 51 Subpart C
Yes
No
This project consists only of leasing or rental
assistance and is in compliance with HUD's
Explosive and Flammable Hazards standards
without further evaluation.
0
Farmlands Protection
Farmland Protection Policy Act
of 1981, particularly sections
Yes
❑
No
This project consists only of leasing or rental
assistance and is in compliance with the
Farmland Protection Policy Act without
further evaluation.
4
This format is to be used for leasin• or rental assistance activities funded under the Continuum of Care
(CoC) program only.
1504(b) and 1541; 7 CFR Part
658
Floodplain Management
Executive Order 11988,
particularly section 2(a); 24 CFR
Part 55
Yes No
*No sites will be selected in FEMA
Special Flood Hazard Areas.
❑ Iidentified
Historic Preservation
National Historic Preservation
Act of 1966, particularly sections
106 and 110; 36 CFR Part 800
Yes No
HUD has determined that leasing and rental
assistance with no associated repairs,
rehabilitation, or other activities with
physical impacts has No Potential to Cause
Effects under 36 CFR 800.3(a)(1) (see
Appendix A). Therefore, this project is in
compliance with Section 106 of the National
Historic Preservation Act without further
obligations.
❑ ��
Noise Abatement and Control
24 CFR Part 51 Subpart B
Yes No
This project consists only of leasing or rental
assistance. HUD's Noise standards do not
apply.
❑ El
Sole Source Aquifers
Safe Drinking Water Act of 1974,
as amended, particularly section
1424(e); 40 CFR Part 149
Yes No
This project consists only of leasing or rental
and is in compliance with the Safe
Drinking Water Act without further
evaluation.
❑ 1assistance
Wetlands Protection
Executive Order 11990,
particularly sections 2 and 5; 24
CFR Part 55 wetlands provisions
Yes No
This project consists only of leasing or rental
assistance without any new construction.
Executive Order 11990 and Part 55 wetlands
provisions do not apply to projects that do
not involve new construction in a wetland.
I
Wild and Scenic Rivers
Wild and Scenic Rivers Act of
1968, particularly section 7(b)
and (c)
Yes No
This project consists only of leasing or rental
assistance and is in compliance with the
Wild and Scenic Rivers Act without further
evaluation.
® El
ENVIRONMENTAL JUSTICE
Environmental Justice
Executive Order 12898
Yes No
*Site selection will comply with 59 FR
7629. This project involves only leasing,
and no development. Selection of units for
lease will be in compliance with EJ
standards.
❑ C.
Mitigation Measures and Conditions
Summarize below all mitigation measures either taken or required as a condition of approval of
the project by the Responsible Entity to reduce, avoid, or eliminate adverse environmental
This format is to be used for leasing or rental assistance activities funded under the Continuum of Care
(CoC) program only.
impacts and to avoid non-compliance or non-conformance with the above -listed authorities and
factors. These measures/conditions must be incorporated into project contracts, development
agreements, and other relevant documents. The staff responsible for implementing and
monitoring mitigation measures should be clearly identified in the mitigation plan.
No mitigation is required.
*Determination:
This categorically excluded activity/project converts to EXEMPT per Section 58.34(a)(12),
because it does not require any mitigation for compliance with any listed statutes or authorities,
nor requires any formal permit or license; Funds may be committed and drawn down for this
(now) EXEMPT project; OR
❑ This categorically excluded activity/project cannot convert to Exempt status because one or more
statutes or authorities listed at Section 58.5 requires formal consultation or mitigation. Complete
consultation/mitigation protocol requirements, publish NOURROF, submit RROF (HUD
7015.15), and obtain "Authority to Use Grant Funds" (HUD 7015.16) per Section 58.70 and
58.71 before committing or drawing down any funds; OR
❑ This project is not categorically excluded OR, if originally categorically excluded, is now subject
to a full Environmental Assessment according to Part 58 Subpart E due to extraordinary
circumstances (Section 58.35(c)).
Preparer Signature:
Name/Title/Organization:
Date: 2-0) 5
C mm n;A-1 .e‘ov — t- er; �5-
Responsib°Entity Agency Official Signature:
Name/Title: Roy D. Buol , Mayor
Date: %Iz�6
This original, signed document and related supporting material must be retained on file by the
Responsible Entity in an Environmental Review. Record (ERR) for the activity/project (ref: 24
CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program(s).
This format is to be used for leasing or rental assistance activities funded under the Continuum of Care
CoC gni am onl
Appendix A —
US. DEPARTMENT OF ROUSING AND URBAN DEVELOPMENT
WASI-IINGTON, DC 20410.7000
" o ex*,
OFFICE OF THE ASSISTANT SECRETAR Y FOR
COMMUNITY PLANNING AND DEVELOPMENT
FEB 1 2(.174
MEMORANDUM FOR: CPD Division Directors
Regional Environmen Officers
FROM: ee c opp, Dire �r, Officeo Environment and
Energy, DGE
SUBJECT:
Determination that Continuum of Care (CoC) Leasing and Rental
Assistance with no associated physical building activities have "No
Potential to Cause Effects" under Section 106 of the National Historic
Preservation Act and its implementing regulations 36 CFR Part 800
The U.S. Department of Housing and Urban Development (HUD) has determined that
leasing and rental assistance activities in the Continuum of Care (CoC) Program that include no
maintenance, repairs, or rehabilitation to the leased or rented properties have "No Potential to Cause
Effects," as described in 36 CFR 800.3(a)(1). These leasing and rental assistance activities provide
transitional or permanent housing for the homeless in existing scattered site buildings with no
associated physical changes to the buildings, and have 110 potential to cause effects on historic
properties, assuming such properties were present. Neither HUD nor the grantees participating in
the CoC Program have any further obligations for these projects under Section 106 of the National
Historic Preservation Act (Section 106) or 36 CFR Part 800. No consultation with the State Historic
Preservation Officer (SHPO), Tribal Historic Preservation Officer (THPO), or other interested
parties is required.
A copy of this memorandum in the Environmental Review Record for a qualifying
individual CoC project will document compliance with Section 106, 36 CFR Part 800, 24 CFR
Part 50, and 24 CFR Part 58 regarding historic properties.
Leasing and rental assistance with associated unit or building repairs, rehabilitation, or
new construction do not qualify for the treatment described in this memo. Likewise, other types
of projects participating in the CoC Program, including repairs, rehabilitation, and new
construction, do not qualify for the treatment described in this memo, These activities must be
fully reviewed under the Section 106 process, including consultation with a SHPO, THPO and/or
tribal authority, interested parties and the public, to aid HUD or the Responsible Entity in
making an effect determination.
Please direct any questions regarding this memorandum to Nancy E. Boone, Federal
Preservation Officer, at Nancv.E.Boone@hud.eov or 202-402-5718.
www.hud.gov espanol.hud.gov