Finding 516538 (2024-004)

Finding 2024-004: Environmental Review Capital Funds – 14.872 Material Weakness/Noncompliance – Special Tests and Provisions Criteria: An environmental review must be completed for any project or activities before a PHA may acquire, rehabilitate, convert, lease, repair, or construct property, or commit HUD or local funds at an assisted or to-be-assisted site. Environmental review procedures for PHAs are given in PIH Notice 2016-22 HA, “Environmental Review Requirements for Public Housing Agencies.” The environmental reviews are not tied to specific grants but apply to all the operating and capital activities of the PHA for a five-year period. The Notice cites the governing regulations at 24 CFR parts 50 and 58 and describes the methods of review and types of determinations. All of these methods and types culminate in a final approval document signed by a HUD Approving Official. To be in compliance a PHA must have such an approval document with an approval date that is not over five years old. Condition: The last environmental review the Authority was able to provide was done in 2015 and was beyond the requirement of having an environmental review that is not more than five years old. Cause: The Authority did not have a system in place to ensure it had a current environmental review. Effect or Potential Effect: The Authority did not comply with the environmental review requirements. Recommendation: The Authority should establish a system to be proactive in ensuring it has a current environmental study covering future projects funded by capital fund grants. View of the Responsible Officials of the Auditee: The auditee's management agrees with the finding.