North Carolina Department of Commerce
Small Cities Community Development Block Grant Program (CDBG)
Environmental Review Record at the Community Level
__________County
Tier 1 Written Strategy for Non-Specified Sites
Step I: Project Details
Project Name: ____ County Scattered Site Program
Project Description:
SAMPLE: The ___ County intends to use CDBG funds to acquisition and rehabilitate single-family dwellings.
Rehabilitation work will include bringing the buildings up to current local codes (including energy conservation measures),
replacing roofs, repainting the interior and exterior surfaces, and installing landscaping.
Timeframe: March 2010-April 2013
Funding Source/Amount: $400,000 of CDBG grant funds and $100,000 of local government matching funds.
Geographic Area: Specify Census Tracts and/or Zip Codes
Step II: Determination
The following elements of this project are categorically excluded at 24 CFR 58.35(a)(6). Each site, once identified and
purchased, will need to be reviewed under a site-specified checklist.
Step III: Written Strategy
This written strategy describes the method(s) for the tiered Environmental Review for the (program/project
name/location) CDBG Scattered Site Program. This portion of (program/project name/location) County’s CDBG
Scattered Site Program consists of (describe actions).
The site specific review must be used ONLY for activities described in the attached project description. Each individual
site will be reviewed using the attached Site-Specific review checklist template. All documentation for compliance factors
included in the site specific review must be completed prior to committing funds for individual sites.
1. Planning: (Local Zoning/Unresolved Conflicts)
SAMPLE: The (program/project name/location) CDBG Scattered Site Program will only be addressing single-family
homes that are currently in compliance or conformance with local zoning. Since the use will not change, it is not
anticipated that any conflicts will arise. Each site-specific review will include confirmation of local zoning compliance and
explain any unresolved conflicts that should arise. Confirmation from the local planning department will be obtained.
2. Air Quality [Clean Air Act, Sections 176 (c) and (d), and 40 CFR 6, 51, 93]
SAMPLE: Rehabilitation of single-family dwellings will have no long-term impact on air quality as they do not involve
construction of transportation facilities. Temporary air quality factors will be monitored during construction.
3. Historic and Cultural Preservation [36 CFR 800]
SAMPLE: We do not anticipate building in or adjacent to any historic districts. Nor do we anticipate that the property’s
area of potential effects will include a historic district or property. However, should that occur, a State Historic Evaluation
Form will be submitted directly to the State Historic Preservation Office and consultation will be requested.
The appropriate tribes will be contacted for any project involving land disturbance.
4. Floodplain Management and Insurance (24 CFR Part 55, E.O. 11988)
SAMPLE: In response to Executive Order 11988, Floodplain Management as interpreted in HUD regulations at 24 CFR
Part 55, and the Flood Disaster Act of 1973. Each site will be reviewed to determine if the site is in the 100-year flood
plain using the FIRMs available on FEMA’s website. The Community Panel number and date will be obtained and listed
in the Site Specific Review Checklist. Each site will be reviewed to determine if the site is in the 100-year flood plain using
the FIRMs available on FEMA’s website. A complete set of FIRM Maps will be filed with the Environmental Review
Record in the (insert location).
For activities not excluded at 24 CFR Part 55.12, the “Eight Step Decision making Process” will be conducted to
determine if there is an alternative to funding the project in the flood plain. If there is no alternative to funding the site in
the floodplain, mitigating measures will be developed to minimize the effect. All actions located in the flood plain require
flood Insurance as a condition of funding.
5. Protection of Wetlands (E.O. 11990)
SAMPLE: Department of Interior Wetland Maps and dated site visits will be reviewed to determine presence/absence of
wetlands.
6. Wild and Scenic Rivers Act [16 U.S.C. 1271 et seq. Sections 7 (b), (c)]
SAMPLE: Maps will be reviewed if the sites are in proximity to listed wild and scenic rivers and if necessary, mitigation
proposed.
7. Noise Abatement [24 CFR 51, Subpart B]
SAMPLE: For projects project involving development of noise-sensitive uses (e.g. reconstruction, new construction),
noise levels will be estimated using the HUD Day Night Average Noise (DNL) calculator if the project is within 5 miles of a
civil airport, 15 miles of a military airfield, 1,000 feet of a major highway or busy road, or 3,000 feet of a railroad. Individual
DNL calculations will be attached.
8. Airport Hazards [24 CFR Part 51, Subpart D]
SAMPLE: The target area is not within the existing Runway Protection Zone, proposed future Runway Protection Zone or
the proposed area for expansion of the local municipal airport and/or nearest military airfield. Once individual sites are
identified, compliance and certification will be noted on the individual site-specific checklist.
9. Explosive and Flammable Hazard Operations [24 CFR Part 51, Subpart C]
SAMPLE: Projects involving rehabilitation of existing single-family homes with no potential increase in level of occupancy
do not involve making a vacant building habitable. Therefore, compliance with this part for those sites is not required. For
new construction projects or projects that increase the number of persons exposed to hazards the hazard study will be
conducted as required at 24 CFR Part 51.
108. Toxic Chemicals and Radioactive Materials [24 CFR 58.5(i)]
SAMPLE: Each project site will be evaluated to assure it is not listed on an EPA Superfund National Priorities or CERCLA
List, or equivalent State list; located within 3,000 feet of a toxic or solid waste landfill site; does not have an underground
storage tank (which is not a residential fuel tank); or suspected of contamination by toxic chemicals or radioactive
materials. Information will be gathered to ensure that the site is safe for the intended users of the project as required at
24 CFR 58.5(i).
11. Endangered Species [50 CFR part 402]
SAMPLE: Where ground disturbance, vegetation removal, or unusually loud noise will occur, the list of endangered
species will be reviewed and USF&W contacted where necessary.
12. Sole Source Aquifers [40 CFR 149]
There are no sole source aquifers in North Carolina. http://www.epa.gov/region4/water/groundwater/r4ssa.html
13. Farmland Protection [7 CFR Part 658]
SAMPLE: Rehabilitation of single family homes does not involve conversion of land use. The area is zoned as
residential.
14. Environmental Justice [E.O. 12898]
SAMPLE: Individual sites will be evaluated to determine if they are located in a predominantly minority and low-income
neighborhood, and if so, whether there will be disproportionately adverse environmental effects on minority and lowincome populations relative to the community-at-large.
15. Compliance with 24 CFR Part 58.6.
SAMPLE: If the structure (building with four walls and a roof) is in the 100 year flood plain flood insurance will be required
for the structure. If the site is in the airport clearzone, the Clearzone Notification Form must be signed by the homeowner.
Since we checked and documented that our project area is not in a Coastal Barrier Island we did not include that item on
the strategy.
Step IV: Site Specific Review Checklist
A sample Tier 2 Site Specific Review Checklist is attached and will be completed as sites are identified.
Step V: Process for Individual Site Reviews
As individual sites are identified, the Tier 2 Site Specific Review Checklist will be completed by _________ department
(Insert who) and will be maintained in files located _________ (Insert where). No funds will be committed to the
individual site until the review is completed.
Step VI: Environmental Review Record
The Site Specific Review Checklist and supporting documentation for each activity/site will be placed in the Environmental
Review Record.