2009 CPEO Brownfields List Archive

From: "Schnapf, Lawrence" <Lawrence.Schnapf@srz.com>
Date: Fri, 16 Oct 2009 09:42:22 -0700 (PDT)
Reply: cpeo-brownfields
Subject: [CPEO-BIF] HUD adopts Risk-Based Cleanup Approach (or should I say cost-based cleanups)
 
Title: HUD adopts Risk-Based Cleanup Approach (or should I say cost-based cleanups)

LPS Note: This policy change seems to contravene the policy of HUD NEPA regulations at 50.3(i)(1) that states "It is HUD policy that all properties proposed for use in HUD programs be free of hazardous materials..." 

The United States Department of Housing and Urban Development (HUD) has issued a revised contamination policy for HUD-assisted multi-family housing projects (LPS-see page 14, Section E).

>
The new policy was transmitted on September 18 to FHA-Approved Multifamily Mortgagees, as well as local grantees, HUB centers, and field offices.

>
HUD’s previous contamination policy was characterized by brownfields practitioners as “dig-to-clean” or complete removal of contamination to de minimis levels.

>
The revised policy allows “incomplete removal of contamination” when it can be demonstrated that “costs are deemed to be exorbitant and/or the feasibility deemed impractical for remediation of on-site contamination to de minimis levels.”

>
Risk based cleanups must be reviewed by HUD, approved by state voluntary cleanup or other oversight programs, and meet follow EPA and ASTM protocols.

For more information see:
> http://www.hud.gov/offices/hsg/mfh/map/mapguide/chap09.pdf

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