NAHMA HUD Update: RAD Environmental Review Guidance and Resident Log

February 7, 2020

Recently, HUD announced updated resources for the Rental Assistance Demonstration (RAD) program related to environmental reviews and resident relocation tracking:

RAD Environmental Review Guidance

HUD recently published a revised guide on “Environmental Review Requirement for RAD Conversions.” This update provides improved guidance to all property types (public housing, Mod Rehab, and PRAC) converting under RAD and implements the strengthened environmental requirements introduced in Revision 4 of the RAD Notice, including:

  • Housing authorities and owners must test for radon prior to converting and, if found, must mitigate any health hazards;
  • Additional instruction is provided for a streamlined environmental review for conversions without any rehabilitation; and
  • Requiring the use of the HUD Environmental Review Online System (HEROS) for “Part 50” Environmental Reviews. This will reduce the time it takes for HUD to complete environmental reviews for PBRA and FHA-insured conversions so that transactions can proceed more expeditiously.

These improvements continue to make RAD easier to use, while ensuring that properties converted through RAD are safe for residents and free of environmental hazards.

Tracking Resident Relocation through a Resident Log

In order to monitor and track relocation and residents’ right of return for public housing conversions under RAD, a PHA or Project Owner is required to maintain a resident log that tracks residents from the time of the first resident meetings through the completion of any rehabilitation or construction. (See the RAD Fair Housing and Relocation Notice H/PIH 2016-17 for more detail.) HUD has recently posted a form of a resident log that PHAs may use to ensure they are tracking all of the data points needed to satisfy HUD’s monitoring requirements. PHAs and owners are encouraged to use this or any other form with at least this minimum level of information.

More information is available on the RAD Resource Desk website here. To join HUD’s RAD email list, please go here. Thanks,