City of Stockton Housing and
Urban Development
(HUD) Support
May 1, 2023
Attachment A
01 02
03 HR Process Improvement
PROJECT OVERVIEW
SCOPE AND APPROACH
PRIOR HUD FINDING STATUS
2 Overview
Attachment A
Project
Overview
HUD Support
The City of Stockton requested HUD
environmental response support to help address
the results of the Community Planning and
Development (CPD) Monitoring Report 2019.
The primary objective of this engagement was to
assist the Economic Development Department
(EDD) in drafting a response to HUD and assist
in addressing several findings and corrective
actions including drafting several policies and
procedures.
EDD was able to provide responses to HUD on
time and was able to address 11 out of 12
corrective actions, pending one action from a
developer. The latest response was sent at the
end of March and HUD has yet to provide a
response.
3 Attachment A
INITIATION
• This phase concentrated
on comprehensive project
planning and
management, including:
• Identifying staff to
interview.
• Identifying documents
to review.
• Establishing regular
communication on
project status.
Timing and Approach
HUD Support
PLANNING
• Attended interviews with
staff and key
stakeholders.
• Reviewed documents
including prior policies
and guidance documents,
HUD reports, reports from
developers, and
environmental reviews.
• Developed a corrective
action plan to clear HUD
findings
ANALYSIS
• Researched best
practice and applicable
standards.
• Assisted in drafting the
HUD response letters in
alignment with industry
standards and best
practices.
• Drafted recommended
policies and procedures
and review standards.
DELIVERABLES
• Two drafted response
letters to HUD, one on
12/12/22 and the other on
3/31/23.
• Environmental Review
Policy and Procedures
• Environmental Review
Standards
• Floodplain Management
Policy and Procedure
TIMING
These consulting services were provided between September 2022 and March 2023 and consisted of the following four phases.
4 Attachment A
Findings
Status
Prior HUD Finding 1: a) The City did not
ensure through its environmental reviews that
HUD-assisted properties were free of
hazardous materials, contamination, toxic
chemicals and gases, radioactive substances
that could affect the health and safety of
occupants or conflict with the intended
utilization of the property.
b)Environmental Review Reports failed to
sufficiently and accurately characterize
impacts on the human or natural environment
resulting in conclusion of the Environmental
Review before the significance of recognized
impacts had been fully evaluated and
appropriate mitigation measures been
adopted.
HUD Support5
Corrective Action Current Status
1. Update Environmental Review
policies and procedures.
Submitted to HUD 3/31/23, pending
HUD approval.
2. Submit comprehensive building
surveys for 2 sites.
Cleared by HUD, 2/28/23
3. Obtain a commitment from
developers to abate all presumed
asbestos and lead based paint
along.
Submitted to HUD 3/31/23, pending
HUD approval.
4. Update site-specific Operations
and Maintenance (O&M) plans.
Submitted to HUD 3/31/23, pending
HUD approval.
5. Obtain commitment from
developer to install a passive, sub-
slab depressurization system.
The developer, Visionary Home
Builders, is working on system
updates.
6. Submit a Categorially Excluded
Subject to §58.5 environmental
review.
Submitted to HUD 3/31/23, pending
HUD approval.
7. Submit WISER training
certifications for all staff conducting
environmental reviews.
Submitted to HUD 3/31/23, pending
HUD approval.
Attachment A
Findings
Status
Prior HUD Finding 2: An environmental
review was improperly converted to “Exempt”
status.
HR Process Improvement6
Corrective Action Current Status
1. Update Environmental Review
policies and procedures
Submitted to HUD 3/31/23, pending
HUD approval.
Attachment A
Findings
Status
Prior HUD Finding 3: Compliance was
inadequately evaluated and documented for
Floodplain Management, Explosive and
Flammable Hazards, Airport Hazards, Historic
Preservation, Noise Abatement and Control,
and Endangered Species Act. Source
Documentation was inadequate.
HUD Support7
Corrective Action Current Status
1. Fully reevaluate determinations
for Explosive and Flammable
Facilities.
Submitted to HUD 3/31/23, pending
HUD approval.
2. Fully reevaluate the Floodplain
Management determination for a site
and provide the 8-step decision
making process compliant with
§55.20.
Submitted to HUD 3/31/23, pending
HUD approval.
3. Updated policies and procedures
related to Floodplain Management,
Explosive and Flammable Hazards,
Airport Hazards, Historic
Preservation, Noise Abatement and
Control, and Endangered Species
Act.
Submitted to HUD 3/31/23, pending
HUD approval.
4. Submit WISER training
certifications for all staff conducting
environmental reviews.
Submitted to HUD 3/31/23, pending
HUD approval.
Attachment A
Findings
Status
HUD Concern 1: A corollary to Finding No. 1,
the City did not thoroughly comply with
§58.S(i) HUD Environmental Standards. The
City sited "sensitive land uses" near specific
sources of air pollution; namely high traffic
freeways and roadways, without conducting
an appropriate health risk assessment.
HUD Support8
Corrective Action Current Status
Develop procedures to require all
developments that include sensitive
receptors, to undergo a screening-
level health risk analysis.
Submitted to HUD 3/31/23, pending
HUD approval.
Attachment A
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HUD Support9
Attachment A