Study of HUD's Site Contamination Policies
ICF has been engaged by the U.S. Department of Housing and Urban Development (HUD) to complete a study of HUD’s site contamination policies, so as to provide recommendations for how to improve HUD’s approach to environmental review. The Office of Policy Development
and Research (PD&R) provided funds and the lead staff for this work. PD&R also coordinated an advisory group of HUD staff from HUD’s three main development offices (CPD, PIH and Housing), which provided guidance to ICF throughout the study.
There were seven tasks in this study. Each of the first six tasks resulted in a draft memorandumon a specific sub-topic. The purpose of this seventh and final task is to bring all of the taskstogether in a final document, and include this Executive Summary. A summary of each Task isprovided below.
Task 1 was entitled Review and Assess State-of-the Art Risk-Based Cleanup Technology. Work for this task consisted of reviewing published literature related to risk-based cleanup, searching Federal, State, and private Internet sources, and interviewing experts from the Federal government, state governments, and the private sector who could provide information related to current risk-based cleanup issues.
Tasks 2 and 3 were carried out concurrently, with Task 3 being delivered before Task 2 (as per the contractual requirements). Task 2 was entitled Review and Assess HUD Site Contamination Policies, Procedures and Practices. The main purpose of this task was to provide a solid grounding in HUD’s current approaches to environmental diligence, out of which recommendations could be made.
Task 3 was entitled Analyze and Assess Site Contamination Policies of Development Agencies. The main purpose of this task was to understand the approaches that other comparable development organizations take to environmental due diligence. HUD approved the study of eight development organizations, which included federal agencies, a state agency, and private for-profit financial institutions. Federal agencies included the U.S. Department of Agriculture’s Rural Housing Service (RHS), the U.S. Department of Commerce’s Economic Development Administration (EDA), the U.S. Department of Defense’s Base Realignment and Closure program (BRAC), the U.S. General Services Administration’s Public Building Service (PBS), and the U.S. Department of Veterans Affairs’ Home Loan Guaranty Services program. The state agency was the California Housing Finance Agency. Private financial institutions included Freddie Mac and PNC Bank.
The main methodological tool for these tasks was an analytic matrix, which facilitated our ability to compare and contrast how various HUD Offices and other agencies treated key themes for the study. The data for the matrix were developed and completed through interviews with staff from HUD and eight other agencies; lessons learned from a trip to HUD’s Chicago Field Office; and review of the agencies’ regulations, handbooks, procedures, diagrams, Web sites and worksheets. From these resources, ICF not only completed the data in the analytic framework (as best as was possible), we also developed descriptions of the development agencies’ policies, procedures and practices. In addition, we were able to identify common themes as well as differences. The common themes and differences were captured in the report for Task 4, Similarities and D ifferences: HUD and Other Development Agencies.
The report for Task 5, Review and Assess Views of Users of HUD Programs, was developed through discussions with representatives from cities that manage CDBG and HOME funds, developers, lenders, a public housing authority, and a state housing finance agency information. A site visit to Chicago, as referenced above, added an interactive session to Task 5 that facilitated our understanding of the views of key user types.
Task 6, Identify and Assess Alternatives do Current Site Contamination Policies, distills the research findings of this study into key conclusions and recommendations to HUD.
This final report is organized into seven main sections -- an introduction and a section for each of the six reports that were submitted earlier in this project. In the draft reports for Tasks 1, 2, 3 and 5, an Executives Summaries were parts of the deliverables. In this Final Document, these Executive Summaries have been removed for each task. In their places, we have brought the key conclusions for each task forward into this Executive Summary, to serve as an overall summary of the study.