Study of HUD's Site Contamination Policies
(July 2003, 277 p.)
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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.
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