A Phase I Environmental Site Assessment is required for to finance all MAP projects (purchase, refinance, new construction or substantial rehabilitation) and the Phase I ESA must meet both the requirements of the American Society of Testing Materials (ASTM) Standards E1527 and the requirements of HUD “Environmental Assessment Guide for Housing Projects” and the HUD Handbook 1390.4 “Guide to HUD Environmental Criteria and Standards contained in 24 CFR 51”.
The consultant must complete HUD’s environmental form HUD-4128 “Environmental Assessment and Compliance Finding for the Related Laws.” HUD Form 4128 requires the consultant to address issue beyond the traditional ASTM Phase I ESA. For example, the consultant must opine on the site’s exposure to noise and must address asbestos and lead based paint.
Recently, HUD has began requiring a Tier 1 vapor intrusion (VI) screen as defined by ASTM E 2600 with the Phase I environmental site assessments. Per Tier I guidelines, the environmental professional must perform an initial vapor intrusion screen to determine if there is a potential for toxic vapors to exist onsite as a result of an onsite or offsite release.
HUD also wants to ensure that the environmental professionals working on their projects are experienced with HUD projects. The engineers and architects that run my firm’s HUD Group are MAP Certified and LEAN Certified, and these are important qualifications in the universe of HUD due diligence.
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