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Environmental Review and Section 106

Environmental Review Record and Section 106 Historic Review Process

The National Environmental Policy Act of 1969 (NEPA) requires that environmental consequences are reviewed and alternatives considered for most federally assisted actions before decisions are made and before actions are taken. Therefore, an "Environmental Review Record" is required as part of the development due diligence process.

The National Historic Preservation Act of 1966 requires agencies to consider the impact of their federally funded developments on historic properties. This process is commonly known as "the Section 106 review".

The ERR and the Section 106 processes are separate and distinct processes with different guiding regulations. IHCDA has combined the two processes into one process because both are federally required for the following IHCDA funding sources received from the Department of Housing and Urban Development: Community Development Block Grant (CDBG and CDBG Disaster), HOME Investment Partnerships Program (HOME), HOME Tenant Based Rental Assistance, National Housing Trust Fund, and Neighborhood Stabilization Program.

The Environmental Review Record (ERR) and Section 106 Historic Review User’s Guide and the ERR Workbook provides additional background information about the federally required processes including why the review is necessary, how to perform the review, and other resource information to help you complete the ERR Workbook. The ERR Workbook is the document where applicants will answer questions and submit supporting documentation regarding the project to satisfy the federal requirements for both the ERR and the Section 106 reviews. Applicants filling out the ERR Workbook will need to follow the User’s Guide and all appendices in order to fill out the ERR Workbook. Specifically, the User’s Guide and Appendix 3 Resources Document, will provide the information necessary to fill out the ERR Workbook.

The User’s Guide, all appendices, and fillable versions of the ERR Workbooks are available below.

Environmental Review Record and Section 106 Historic Review User’s Guide


On-Demand Trainings

IHCDA is pleased to partner with the Indiana Department of Natural Resources - Division of Historic Preservation and Archaeology (DHPA) and Green 3, LLC to offer a series of on-demand trainings. Many of the funding sources utilized in IHCDA’s Real Estate Department have their own set of historic and environmental reviews that must be completed prior to starting construction. The review processes are governed by different regulations and might be performed by various state or federal agencies. The trainings will help clarify the different review processes for our development partners and will help them plan their development timeline appropriately.

Historic Review Processes: Describes the various historic review processes and explains which funding sources/programs trigger the reviews. Explains basic steps for each review process. Provides recommended approaches to streamline the reviews.

Section 106: Explains why and when Section 106 is needed, the basic steps in the process, the type of information needed for a timely review, potential review outcomes, and how the overall process can impact a development timeline.

NEPA Part 1 – Overview of the National Environmental Policy Act. This training explains what the National Environmental Policy Act (NEPA) is and why it matters. Additionally, the training discusses the implementation of NEPA through U.S. Department of Housing and Urban Development and IHCDA.

NEPA Part 2 – The Application of NEPA. This training explains the IHCDA ERR and Section 106 User’s Guide, the four possible classifications of an ERR, and explains how to fill out the ERR Workbook with the appropriate supporting documentation.

Certificate of Approval Process (required for the Development Fund Historic Review) – This training will cover when a Certificate of Approval is required, go over the Certificate of Approval form, and explain the timelines for review.

Federal Historic Tax Credits – This training will cover the basics of how the Federal Historic Tax Credit (FHTC) program works. This training should help partners understand how FHTC relates and impacts other funding reviews and how to plan ahead for a streamlined application and review process when utilizing FHTC with other funding sources.

Third-Party Reviewer

IHCDA is now utilizing a third-party to review current and future ERR and Section 106 review submissions. As in the past, all initial ERR and Section 106 materials will be submitted to IHCDA with the appropriate funding application. Any required follow-up ERR and/or Section 106 information will be requested by and sent directly to IHCDA’s third-party reviewer, as of the date of June 1, 2017. Contact information found below:+

Attn: Karen Wood
9102 N. Meridian Street, Suite 200
Indianapolis, IN 46260