6600-N-31 HUD OLHCHH FY2022 Lead Hazard Reduction Capacity Building Program Appendices A-D 4 13 (2).docx
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HUD OLHCHH FY 2022 LEAD HAZARD CONTROL CAPACITY BUILDING NOFO APPENDICES
APPENDIX A: Program Definitions
· Capacity Building is support, investment, or training used to increase an entity’s level of operational, programmatic, financial, or organizational capability, so it may more effectively and efficiently implement its mission. It is a process in which entities improve and increase skills, knowledge, tools, and other resources needed to serve low- and moderate- income families in local communities that need increased or improved affordable housing and community development.
· Equipment Purchase means the purchase of equipment such as an X-ray fluorescence (XRF) analyzer needed to execute lead hazard control interventions.
· Inspections/Testing means performing lead dust, soil/paint-chip testing, XRF testing, lead-based paint inspections, risk assessments, clearance examination, and engineering and architectural activities that are required and in direct support of interim control and lead hazard control work. Inspections and testing assess eligible housing units constructed prior to 1978 to determine the presence of lead-based paint and/or lead hazards from paint, dust, or soil using the mentioned testing procedures.
· Insurance means securing liability insurance for housing-related environmental health and safety hazard evaluation and control activities, if the scope of the insurance is restricted to work under this grant.
· Lead-Based Paint Hazard Control means the control or elimination of all lead-based paint hazards identified in housing units and in common areas of multi-family housing through either interim controls or lead-based paint abatement, or a combination of both. For a complete description of interim controls and abatement, see HUD’s 2012 Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (“HUD Guidelines”), located at HUD Guidelines.
· Program Manager is expected to be the center of the program communication. They must have experience in housing rehabilitation, public health, lead hazard control, childhood lead poisoning prevention, project management, or related work and must be technically prepared and experienced to take on the oversight and administration of these funds. In addition, the program manager needs to have knowledge on outreach and enrollment efforts for families enrolling in the program and communicate effectively to help establish community-based partnerships. The value of placing the right staff in this key position must be evident by the description in the letter of commitment and planning being taken by the applicant to ensure the position is or will be in place within 90 days of award. The Program Manager must be trained and certified in lead hazard control activities, or explain how they will receive the training and certification within 90 to 120 days of being hired.
· Project Director is responsible for the management and implementation of a grant funded project. The Project Director is the lead role for the grant and may oversee other grant roles, such as Program Manager, Outreach and Recruitment Specialist, Finance Manager, or other program staff roles. The responsibilities of the Project Director include overall management and compliance with the grant requirements. Depending on what the project and budget entails, this may include the following: Initiating requisitions for allowable expenditure, maintaining an inventory for items purchased with grant funds, posting and hiring for grant funded positions, maintaining time and effort documentation for personnel involved in the grant (in-kind or funded by the grant), initiating requisitions for travel, completing programmatic report.
· Target housing means any housing constructed prior to 1978, except housing for the elderly or persons with disabilities, or any 0-bedroom dwelling (unless any child who is less than 6 years of age resides or is expected to reside in such housing for the elderly, persons with disabilities, or 0-bedroom dwelling.) In the case of jurisdictions which banned the sale or use of lead-based paint prior to 1978, the Secretary, at the Secretary's discretion, may designate an earlier date.
· Worker Protection means a standard for worker rights adopted by the Occupational Safety and Health Administration’s (OSHA’s) Lead Standard for the Construction Industry, title 29 Code of Federal Regulations 1926.62. This regulation covers lead, including metallic lead, all inorganic lead compounds, and organic lead soaps; therefore, the standard includes workers in the lead-based paint abatement industries. Additionally, lead-based paint abatement contractors must protect their workers in accordance with 29 CFR 1926.62. At a minimum, workers shall be provided with appropriate respiratory protection and disposable clothing. Other protections of section 1926.62 may also apply depending on the levels of lead exposure to the workers. Hygiene practices should also be used to prevent exposure and prevent take-home of lead dust.
APPENDIX B: Sample Budget Narrative [This budget example can be used for the Master Budget and for any other sub-recipient or contractor that requires a separate budget narrative and budget worksheet Form HUD-424-CBW. The lists of personnel, travel activities, equipment, supplies and materials, and contracts, and their quantity and dollar values are all just examples to prompt development of the applicant’s proposal, so “Example:” has been added to each item in this appendix to make explicit that these are not the only, or even necessarily the best or preferred, approaches to addressing the ten categories in the worksheet form, nor are the quantities and amounts necessarily the best or preferred numbers.] (Grantee name) is applying to become a grantee under HUD’s FY 2022 Lead Hazard Reduction Capacity Building Grant Program to implement (Program name, e.g. My-Town Makes Homes Healthy and Safe Program) that will (summary of the program goals and approach). The program will contain the following expenses as direct costs, administrative costs, and match:
1. Personnel (Total Amount) List of Personnel Duties and Roles Project Director: List description of duties and roles by admin and direct categories for each personnel per policy. You also need to list the costs for each subtitle. Example :(Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) Program Manager: List description of duties and roles by admin and direct categories for each personnel per policy. You also need to list the costs for each subtitle. Example :(Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) Outreach and Enrollment Specialists: List description of duties and roles by admin and direct categories for each personnel per policy. You also need to list the costs for each subtitle. Example :(Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) Staff Accountant: List description of duties and roles by admin and direct categories for each personnel per policy. You also need to list the costs for each subtitle. Example :(Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00)
2. Fringe Benefits: (Total Amounts) Include the type of benefits for each personnel by stating name and benefits: Fringe benefits include Public Employees Retirement System contribution, Medical/Health Insurance, Workers Compensation, Medicare and development. (Admin Cost:)
3. Travel: (Total Amounts) Examples of travel descriptions and calculations 3a: Transportation‐Local Private Vehicle The total for this subcategory is $12,600.
The agency reimburses mileage at the rate of $.56 per mile which is ABC organizational rate.
Program Manager, Specialist, or Project Director, calculate to travel to client homes for enrollment assistance, education/training development of landlords, tenants, owners, and program compliance, over the 24‐month project was determined; this is based Ex. Education and Outreach Events at 50-mile avg ‐ 50 community events*50 miles=2500*$.56= $1400 (100% Other Direct) 3b) Transportation – Airfare: $5,792.87 (Admin Cost: 0.00, Match: 2,000) OLHCHH required travel the program director and Program manager; calculated for one start up conference and five additional annual lead conferences (two conferences per year). Conservatively calculated at a unit cost of $482.74 (includes actual costs of the NGO and estimates for future conferences).
3c) Transportation / Other $15,907.47 (Admin Cost: 12,789.95, Match: 3,117.52) Conference registration- costs associated with registration fees for five annual lead conferences. Calculated for five lead conferences for the PD and PM (two conferences per year). Calculated at a unit cost of $200 for a total of $2,000.00.
Lodging- consists of overnight stay for six HUD conferences averaging four nights per conference for the PD and PM at $226.09 a night. (Admin: $10,400.14, Match:)
Airport shuttle- transportation from airport to hotel during required lead conferences. $25 per trip for the PD and PM 12 round trips; $300. (Admin Cost: $300, Match:)
Lead Training and conference mileage- includes in-state travel mileage for LBPHC staff lead certification classes @ $0.535/mile. Item also includes travel to airport and return for OLHCHH NGO. $3,207.33 (Other Direct Cost $89.81; Match $3,117.52) -Lead Unit Travel – (Direct Cost) 3d) Per Diem or Subsistence $2,087.25 (Admin $1,821.60, Match $265.65) HUD conferences- out of state per diem totals $37.95 per day for the PD and PM for the NGO and five additional conferences (three meals a day and a tip). $1,821.60 (Admin $1,821.60) Licensing Training Per Diem - in-state per diem totals $37.95 per day for seven days (three meals a day and a tip). Calculated for City staff for recertification trainings for Lead and assessor licensing. $265.65 (Match: $265.65)
4. Equipment (Total Amount) X-Ray Fluorescence (XRF) analyzer (Other Direct Cost ) 5.Supplies and Materials -Describe each line-item justification: (Total Amount) General Office Supplies: File folders, note pads, pens, paperclips, etc. calculated conservatively at $2,069.94. (Admin $2,069.94) Outreach and Enrollment Supplies: This includes the purchase of various consumable supplies, including program specific general office supplies for client applications and educational items, postage for direct client outreach, printing of promotional items such as flyers and giveaways. (Direct Cost $20,069.94).
6. Consultant: The intended use of funds in this category are to fund various types of consultants if needed to support the work of the Capacity Building Program. This budget expenses are optional and usually not needed in this category.
7. Contracts and Subgrantees (Total Amount) Could include as applicable:
Subrecipients/ Partners:
(Head Start and Early Head Start) - Describe duties and roles to the grant. (Direct) -Health Association: List roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) -Regional Health District: List roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00)
- Local Community Organization: List the roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) -Lead Inspections/ Risk Assessments and Clearances - List estimated costs of inspections and clearance lab activities, 6 months prior to Period of Performance (POP) end date - Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00)
-Lead Unit Activities: List estimated average costs of units completed 6 months prior to Period of Performance (POP) end date - Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) -Outreach and Enrollment Partnership List the roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) -Contractor Development Education Partnership List the roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00
9. Other Direct Costs Capacity Building activities: List is described various capacity building actives as provided example below.
-Outreach and Enrollment Events: events held in local communities by Project Director, Program Manager, and Specialist. Describe in summary activities overview. Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00).
- Public relations/marketing: List PR provides indirect marketing such as TV or Radio spots for public consumption and social media campaigns. etc. (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00).
- Interpreter Services: List the roles to the grant (Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) -Training/Educations Development: List various trainings anticipated for Project staff and contractors for capacity building. Those trainings are as follows:
(Direct Cost $2,700; Other Direct Cost: $300 Admin Cost: $1,000 Match: $0.00) APPENDIX C: Targeting Disadvantaged Communities for Lead Hazard Reduction Capacity Building Grants
This appendix provides instructions for selecting census tracts in which you plan to do lead hazard reduction (LHR) work so that at least 40 percent of the housing units where LHR work is completed will be in disadvantaged communities (as that term is discussed below) and for determining what percentage of units completed were in disadvantaged communities.
Under this Lead Hazard Reduction Capacity Building (LHRCB) NOFO, you do not need to select the disadvantaged communities within your overall target area in which you will perform a substantial amount of LHR work as part of your application, but just report on whether each unit on which you completed LHR work is or is not in a disadvantaged community. Under your grant agreement (as per the NOFO), you are required to select housing units and complete LHR work with at least 40 percent of the housing units being in disadvantaged communities.
HUD advises you to select housing units based, in part, on assessing the status of the census tracts in which they are located (e.g., by refining their target area) before the work is undertaken. Specifically, HUD recommends that you select census tracts in which you plan to do such work so that at least 40 percent of the housing units will be in disadvantaged communities. HUD further recommends that, to make such a selection you use the HUD OLHCHH 2022 Grants Target Area Mapping Tool; note this is an optional tool that can be used for this grant program. In using the tool, you will select an area for doing LHR work; the tool will determine and show you what percentage of census tracts within that area are disadvantaged communities, as have been designated by the Council on Environmental Quality (see the note on the designation of disadvantaged communities below).
The tool will allow you to revise your selection of census tracts by adding tracts, removing tracts, and restoring removed tracts, until you are satisfied with your selected tracts’ locations and the percentage of those tracts that are disadvantaged communities. The step-by-step procedures for using the tool follow. (If you have a visual or motor disability and would like a reasonable accommodation for selecting your target area, contact the Lead Regulations hotline at Lead.Regulations@HUD.gov, 202-402-7698, or 711 TTY.)
· Note on designation of disadvantaged communities: As part of implementing J40, OMB issued its Memorandum 21-28, Interim Implementation Guidance for the Justice40 Initiative, which identified, in its Appendix A, HUD’s Lead Hazard Reduction and Healthy Homes Grants as J40 pilots that are “to maximize the benefits that are directed to disadvantaged communities.” OMB’s interim guidance lists 13 factors that may be included in determining if a community is disadvantaged; among these are factors regarding environmental or climate indicators and socioeconomic indicators. The Council on Environmental Quality has developed a Climate and Economic Justice Screening Tool (CEJST) that identifies, for each census tract in the U.S., whether that small-population area (averaging 4,400 people, and 1700 housing units, nationally) is a disadvantaged community according to the OMB guidance. HUD OLHCHH and the Office of Policy Development and Research adapted the CEJST to allow selection of more than one census tract at a time and determine the percentage of the tracts selected that are disadvantaged communities.
(1) Open the HUD OLHCHH 2022 Grants Target Area Mapping Tool at https://hud.maps.arcgis.com/apps/webappviewer/index.html?id=4655926fe98946b2990c11f066a7096f.
(a) The tool will open with a view of part of North America (the map below is just an example).
(b) The tool works most easily if the map is on the right and a panel with a black background on the left that has three panels (Step 1 – Choose State; Step 2 – Choose tracts, and Step 3 – Confirm Percentage).
(c) If the black panel is on the left, go to item (2), below.
(d) If the black panel is on the right:
adjust the Zoom setting of your browser’s display to show the panel on the left:
(i) For example, using the Chrome browser, In the upper right of the browser screen is a symbol of three dots arranged vertically (like a colon with an extra dot), and using the Edge browser, the symbol is three dots arranged horizontally.
(ii) Click the symbol and a menu will drop down. One of the menu items is Zoom. Decrease the zoom percentage (such as by clicking the minus sign to the left of the percentage). If the screen changes to have the black panel move to the left, go to item (2) below. If the black panel is still on the right, decrease the zoom percentage again. Repeat until the black panel moves to the left.
(2) In the tool’s left panel, in the upper block, “Step 1 – Select State,” click the pull-down triangle in the right of the box and scroll down until you see the (or a) state you are interested in targeting and click the state’s name. After a few seconds, your state’s map will appear.
(a) Small areas – which are census tracts – will be shown within your state. (If your target area involves more than one state, you will repeat the target area selection process for each state and then combine your results.)
(b) The census tracts that are disadvantaged communities are colored green; those that are not disadvantaged communities are colored red.
(c) You can zoom in or out (clicking the map’s boxed plus and boxed minus signs at its top left), or move the geographic area examined (putting your mouse arrow in the map area holding the right mouse button and moving the mouse).
(i) Each census tract has a six-digit identifying number. If you don’t see the number within the tracts, zoom in until you do see them. This will allow you to have more precise control over your selection of tracts, below.
(3) In the tool’s left panel, in the middle block, “Step 2 – Choose tracts (CENSUS TRACTS box below MUST be checked),” the “Layer” portion of the block has a box to the left of the label “CENSUS TRACTS.” Determine if that box is checked. If it is not checked, click the box so that it has a check.
(4) In the upper part of the Step 2 block, click the pull-down triangle in the right of the “Select” box and scroll down until you reach the selection method you want to use and click it. (Suggestion: Start with “Select by circle.” If you don’t like the results, even after editing your draft target area as shown below, you can click the “Clear” box and start over within your state.)
(5) Move your mouse to roughly the center of the area you want to target, hold the left mouse key and slowly move your mouse away from the center point to create a circle that roughly encompasses the target area you want. (If you use another selection method, such as a rectangle, start at one point and move your mouse to create the selection shape you have chosen.) If you don’t like the results, you can click the “Clear” box and start over within your state.
(6) In the tool’s left panel, in the bottom block, “Step 3 – Confirm 40%,” the circle will adjust the green arc at the upper left – representing the percentage of tracts that are disadvantaged communities – to show the percentage in the area you have selected. Move your mouse arrow onto the YES arc to view the percentage disadvantaged communities in your draft target area. (The red NO arc shows the percentage of tracts that are not disadvantaged communities in your draft target area; it is 100% minus the YES percentage.) If you are satisfied with the percentage of disadvantaged communities, go to item (8) below to create a spreadsheet listing your selected tracts.
(7) If you want to adjust your draft target area, such as to get a higher or lower percentage of disadvantaged communities, move your mouse onto the map and select additional tracts or remove tracts:
(a) To select an additional tract:
(i) In the Step 2 block, click the pull-down triangle in the right of the “Select” box and scroll down until you reach Select by point, and click that.
(ii) Move your mouse into the census tract you wish to add, press and hold Shift, and then click your mouse. After a few seconds, the tract’s color will become lighter, indicating that it has been selected.
(iii) If you want to check the percentage of disadvantaged communities, follow the instructions in step 6 above.
(iv) You may select another tract to add by moving your mouse to that tract, pressing and holding Shift (or continuing to hold Shift from before), and then clicking your mouse.
(b) To remove a tract:
(ii) In the Step 2 block, click the pull-down triangle in the right of the “Select” box and scroll down until you reach Select by point, and click that. You need not make this selection again if you are already selecting by point.
(iii) Move your mouse into the census tract you wish to add, press and hold Ctrl (“Control”), and then click your mouse. After a few seconds, the tract’s color will become darker, indicating that it has been removed from your selection.
(iv) If you want to check the percentage of disadvantaged communities, follow the instructions in step 6 above.
(v) You may select another tract to remove by moving your mouse to that tract, pressing and holding Ctrl (or continuing to hold Ctrl from before), and then clicking your mouse.
(8) When you are satisfied with the selection of tracts, to have the tool create the spreadsheet of census tracts you have selected:
(a) In the Step 2 block’s Layer area, at the far right is a set of three horizontal dots. Click the dots.
(b) Among the list of Section actions is “Export to CSV file,” clicking it will have the tool create the spreadsheet. (“CSV” means “comma separated values”; the spreadsheet uses the numbers and names associated with your selection of tracts to create the spreadsheet.)
(c) Clicking on “Export to CSV file” will have a file named “features (1).csv” (or a higher number in parentheses if you repeat the file creation process) appear in a box at the bottom left of the tool’s screen.
(d) In that box with the filename, click the up-arrow, and then click Open. The spreadsheet will open up. Save the file to whatever location you want (e.g., your computer, a shared drive, an online space), with whatever filename you want, being sure to save the file in an Excel format. (For example, in Excel 2016, click File | Save As | Excel Workbook | Save.)
(9) Calculate the percentage of your disadvantaged communities tracts compared to the total number of tracts you selected. Whether a tract is a disadvantaged community is shown in the column headed “Identified as disadvantaged?”; you may want to widen the column to view the whole header. If the community is disadvantaged, that column in the tract’s row will be “YES”; if it is disadvantaged, that column in the tract’s row will be “NO”.
(10) There are several ways you can calculate the percentage of disadvantaged communities for entering into your application, for example:
(a) Manually count the number of YES values. Count the number of tracts; you can count this number manually or use the number of spreadsheet rows with information, minus one (for the header row). Divide the number of YES values by the number of tracts, multiply by 100, drop any figures after the decimal point (for example, 49.96 becomes 49) and add the percentage sign (“%”).
(b) In recent versions of Excel, use the Data | Filter tool to select, in the “Identified as disadvantaged?” column with the YESes and NOs, just the YES rows. Excel will show the count of selected rows in the bottom left of the screen, along with the total number of tracts (for example, “8 of 18”). As above, divide the number of YES values by the number of tracts, multiply by 100, drop any figures after the decimal point (for example, 49.96 becomes 49) and add the percentage sign (“%”).
(c) In recent versions of Excel, use the Data | Sort tool to sort the “Identified as disadvantaged?” column; it will separate the rows of YESes and of NOs. Count the number of YESes and divide that number by the number of tracts, multiply by 100, drop any figures after the decimal point (for example, 49.96 becomes 49) and add the percentage sign (“%”).
(d) In recent versions of Excel, use the COUNTIF function to count the number of YESes. For example, in a cell to the right of the cells with information, copy or type the formula =COUNTIF($I:$I,"YES") and then divide the number it returns by the number of tracts, multiply by 100, drop any figures after the decimal point (for example, 49.96 becomes 49) and add the percentage sign (“%”).
(11) Save your Excel spreadsheet when you are finished calculating the percentage of disadvantaged communities. Include your spreadsheet as an attachment to your application to document the percentage you enter into your application and allow HUD to perform quality assurance checks on your selection and calculation.
(12) In your application, enter the percentage of disadvantaged communities (“YES” tracts), and, if asked in the notice of funding opportunity, the number of disadvantaged communities and the total number of communities selected (tracts).
APPENDIX D: Environmental Requirements
| a. | Award of an FY 2022 Lead-Hazard Reduction Capacity Building Grant does not constitute approval of specific sites or projects where activities that are subject to environmental review may be carried out. Recipients of funding under this NOFO that are states, units of general local government, and Native American tribes must carry out environmental review responsibilities as a responsible entity under 24 CFR part 58, “Environmental Review Procedures for Entities Assuming HUD Environmental Responsibilities.” For recipients that are not a state, unit of general local government, or Native American tribe, HUD will perform the environmental review of proposed activities under 24 CFR part 50. Reasonable expenses incurred for compliance with these environmental requirements are eligible expenses under this NOFO. |
| b. | For all grants awarded under this NOFO, recipients and other participants in the project are prohibited from undertaking or committing or expending HUD or non-HUD funds on a project or activities under this NOFO (other than activities listed at 24 CFR 58.34, 58.35(b) or 58.22(f), e.g., lead-based paint inspections and risk assessments until: |
| (1) | The recipient completes a tiered environmental review (see 24 CFR 58.15 Tiering) using the HUD Environmental Review Online System (HEROS), including the submission, and HUD approval, of a Request for Release of Funds and the recipient's Environmental Certification (both on Form HUD 7015.15), through HEROS, following the completion of the Tier 1 broad-level review, and completion of a project-specific review at the particular site; or |
| (2) | In the case where the recipient is not a state, unit of general local government or Native American tribe and HUD performs the review under Part 50, HUD has completed the review and notified the recipient of its approval. |
The results of a Tier 2, project specific environmental review or a HUD review under part 50 may require that proposed activities be modified, or proposed sites rejected. For applicants that are not a state, unit of general local government, or Native American Tribe, in accordance with 24 CFR 50.3(h), the application constitutes an assurance that the applicant will comply with this prohibition until HUD approval of the project is received, and that the applicant will assist HUD in complying with part 50; will supply HUD with all available, relevant information necessary for HUD to perform for each project any required environmental review; and will carry out mitigation measures required by HUD or select an alternate eligible property.
c. Recipients of a grant under this NOFO will be provided additional guidance in these environmental responsibilities. For technical assistance with environmental reviews during the period of performance of a grant under this NOFO, contact Karen Griego, the Office of Lead Hazard Control and Healthy Homes’ Program Environmental Clearance Officer at 505-346-6462 (this is not a toll-free number). If you are a hearing or speech impaired person, you may reach the telephone number above via TTY by calling the Federal Relay Service at 800-877-8339. For part 58 procedures see: https://www.onecpd.info/environmental-review/
d. Grantees under this NOFO with current Tiered Environmental Reviews for a previous award will be offered the option to validate the Tier 1 and file the validation documentation in HEROS, per 24 CFR 58.47, or, preferably, complete a new Tier 1 during the grant start-up period. A current Tiered Environmental Review is one that is dated not more than 5 years from the new award start date. Also, if substantial changes are not proposed in the new grant program, the grantee shall provide documentation as such in the current Tier 1, and no new Request for Release of Funds (RROF) and Environmental Certification (Form HUD 7015.15) to HUD is required until the original Tier 1 expires (5 years from the original dated Tier 1), substantial changes in the nature, magnitude, or extent of the project or program are proposed, or new circumstances and environmental conditions are presented, whichever comes first. Examples of substantial change include but are not limited to: adding target areas; adding 20% or more additional units; changing the pool of eligible residential buildings (ex., adding multifamily buildings). Substantial changes require an update of the Tier 1 and a new RROF and Environmental Certification.
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