Client: Southwestern Florida Public Housing Authority
Project Type: Public Housing Redevelopment
Project Timeline: 12 months during the design and application phase
Funding Sources: RAD Component 1, HUD – Project-Based Voucher (PBV)
The Southwestern Florida Public Housing Redevelopment Project was a large-scale undertaking involving the tiered demolition, tenant relocation, and redevelopment of a pre-1960 public housing project. Given the complexity of the site, early environmental consultation was critical to ensure regulatory compliance and mitigate potential risks related to HUD and FEMA requirements, floodplain management, noise assessments, and hazardous material concerns.
D3G was brought on board as the environmental consulting partner to guide the redevelopment team through the environmental review process, ensuring all project activities complied with HUD’s requirements and local municipal standards. Our team provided ongoing support, led critical assessments, and facilitated collaboration between the development team, HUD, and the Responsible Entity (RE).
The project presented multiple challenges:
1. Early Consultation and Environmental Review Alignment:
Early in the process, D3G facilitated a meet-and-greet between the project’s development team, the RE, and our subject matter experts. This step was critical in confirming the Responsible Entity and aligning environmental review reporting with the prescribed format (HEROS vs. traditional). We ensured the Environmental Review met HUD’s aggregation requirements by reviewing civil site plans to account for all on- and off-site project activities.
2. Floodplain and Elevation Compliance:
Our team conducted an in-depth review of FEMA and HUD floodplain documentation to identify the required lowest floor elevations for the new development. By addressing these requirements early, D3G enabled the development team to advance site plan development and secure municipal approvals without delays, ensuring compliance with the Federal Flood Risk Management Standard (FFRMS) and HUD’s 8-Step Process in accordance with 24 CFR Part 55 and Executive Order 11988 (Floodplain Management).
3. Weekly Consulting Calls and Ongoing Compliance Management:
D3G’s subject matter experts joined weekly consulting calls throughout the 12-month project to ensure all stakeholders remained on task and aware of the evolving regulatory landscape. As new compliance steps were identified, D3G engaged additional scopes and due diligence as necessary, ensuring all environmental and regulatory challenges were addressed promptly and accurately.
4. Fuel Storage and Noise Mitigation Solutions:
The project faced challenges related to an adjoining fuel storage tank that failed HUD’s Acceptable Separation Distance (ASD) calculations. D3G worked closely with the project’s civil engineering team to design mitigation strategies in compliance with 24 CFR Part 51, Subpart C. Additionally, D3G conducted a noise assessment using HUD’s Day/Night Noise Level (DNL) Electronic Assessment Tool, followed by Sound Transmission Class (STC) calculations with HUD’s STraCAT tool, ensuring the project met HUD’s noise attenuation requirements.
5. Hazardous Materials Assessment and Remediation:
Prior to demolition, D3G coordinated and reviewed hazardous materials reports concerning asbestos-containing materials (ACMs), lead-based paint (LBP), and radon gas. We consulted on the design of radon mitigation systems and conducted a thorough Phase I Environmental Site Assessment (ESA) and regulatory file review to ensure compliance with HUD’s contamination and toxic substance policies outlined in 24 CFR Part 50.3(i) and 24 CFR 58.5(i)(2).
6. Efficient NEPA Coordination and HEROS Submission:
D3G prepared and submitted all necessary NEPA agency consultation packages, tracked them in direct coordination with the RE, and processed the Environmental Assessment (EA) in HUD’s HEROS platform. Our team’s expertise in NEPA and HUD’s HEROS submission requirements resulted in a Finding of No Significant Impact (FONSI) determination, allowing the project to move forward without significant delays.
Seventeen members of D3G’s environmental and account management teams were actively involved in the project. Our dedicated Subject Matter Experts (SMEs) provided ongoing support in key areas, including flood concerns, Section 106/State Historic Preservation Office (SHPO) compliance, contamination assessments, noise studies, field inspections, report development, and more. The team’s deep knowledge of HUD environmental regulations and FEMA floodplain management ensured the project stayed on track, despite its complexity.
Through D3G’s expert consultation, the Southwestern Florida Public Housing Redevelopment Project successfully navigated the environmental review process, meeting all regulatory requirements on time and within budget. Our strategic approach to floodplain management, contamination mitigation, noise assessments, and hazardous materials remediation helped the development team stay ahead of regulatory challenges, securing project approvals and ensuring compliance with HUD and FEMA standards.
By joining forces with the project team early and providing consistent guidance throughout the process, D3G was instrumental in delivering a successful redevelopment project that met both environmental and municipal standards, contributing to the transformation of a long-standing public housing community.
