Texas Department of Housing & Community Affairs - Building Homes and Strengthening Communities

Emergency Solutions Grants (ESG) Environmental Review Process

HUD published new ESG Guidelines to provide new resources and better tools to prevent and end homelessness. As part of the update, HUD brought ESG under 24 CFR Part 58 Environmental Regulations to be consistent with the other programs

Limitations on Activities Prior to Environmental Clearance

Awardees cannot engage in any choice-limiting activities prior to environmental clearance per 24 CFR §58.22. Choice-limiting activities include but are not limited to these examples:

  • Acquisition of land;
  • Closing on loans including loans for interim financing;
  • Signing a contract; and
  • Commencing construction

HUD requires a signed Certification as part of all contracts and environmental documents. This certification affirms an awareness of and intention not to take any "choice limiting" actions until environmental clearance is obtained. The consequences of moving forward on a project without environmental clearance will result in both in a loss of time and loss of funding.

This regulation extends to the use of other funds utilized for the same project regardless of funding source, including private sources.

Sub-recipients that prematurely engage in a choice-limiting activity will NOT be reimbursed for that activity, and the entire project becomes ineligible for reimbursement from the funding program.

Level of Review and Timelines

Level of Review

Types of Projects

Timeline for completion of Review

Categorically Excluded NOT SUBJECT to 58.5

Tenant Based Rental Assistance, Supportive Services, Operating Costs, Maintenance as defined by HUD (HUD maintenance guideline update - PDF).

30 minutes

Categorically Excluded SUBJECT to 58.5, converting to Exempt*

Leasing (shelter leases/renewals), Rehabilitation, Acquisition

5 – 45 days (no publication required)

Categorically Excluded SUBJECT to 58.5

Leasing (shelter leases/renewals), Rehabilitation, Acquisition

65 – 100 days including publication & comment periods

Environmental Assessment

New Construction, Major Rehabilitation, Expansion of Building, Change in Use

93 – 143 days including publication & comment periods

Mandatory Format for Submitting Environmental Review Documents Required for ESG Projects (effective May 2016)

All HUD Part 58 Environmental Review Submissions must follow the format suggested by HUD found on the HUD Exchange website under the right side toolbar titled “Suggested Formats and Sample Notices,” see https://www.hudexchange.info/programs/environmental-review/. The reviewer chooses the appropriate forms based on the level of review. HUD’s current format now incorporates the project description and determination of level forms; a separate document is no longer needed for these items. Environmental submissions for ESG must be submitted in electronic form to the environmental e-mail, environmental@tdhca.state.tx.us. Jump drives or disks mailed to TDHCA are acceptable as well and should be sent to the attention of Environmental, Program Services.


The Environmental Submission should follow the document order as listed below:


The Environmental Submission should follow the document order as listed below:

  • Location Map, showing address of project (be sure to indicate if the address is sensitive and must be protected from open records requests such as a women’s shelter), and a broader map view to show location in the State
  • HUD Form Categorically Excluded Subject to §58.5 or Environmental Assessment (which now incorporates the project description, level of review and all required checklists into one document)
  • All Supporting Documentation in the order of the HUD checklist with attachment letters or numbers for identifiers for each support section
  • Support must include all data utilized for the review including maps submitted with correspondence to State or Federal Agencies.

*The locality where your project is located can prepare this higher level of review for you or TDHCA staff will work with you to complete the review.

HUD Environmental Forms and guidance can be found at: