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 (ERR) 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 is commonly known as the Section 106 Historic 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 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 Recovery), HOME Investment Partnerships Program (HOME), HOME Tenant Based Rental Assistance (HOME TBRA), National Housing Trust Fund (HTF), and Neighborhood Stabilization Program (NSP).

The Environmental Review Record and Section 106 Historic Review User’s Guide 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. Specifically, the User’s Guide and Appendix 3 Resource 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

• Environmental Review / Section 106 User's Guide - Updated June 2024
• Summary of Changes to ERR and Section 106 Documents
• Appendix 1 - ERR Workbook
• Appendix 2 - Owner-Occupied Repair (OOR) and Lead Hazard Reduction Demonstration (LHRD) Workbook - Exhibit G
• Appendix 3 - Resource Document for Completing ERR / Section 106
• Appendix 4 - Owner-Occupied Repair Priority List
• Appendix 5 - All Sample Notices
• Appendix 6 - Secretary of Interior's Standards for the Treatment of Historic Properties
• Appendix 7 - National Register of Historic Places Criteria for Evaluation
• Appendix 8 - Example of Maps for Area of Potential Effects (APE)
• Appendix 9 - Example Maps for Development Fund Historic Review
• Appendix 10 - HUD Airport Noise Worksheet
• Appendix 11 - Noise Abatement and Control
• Appendix 12 - HTF Only Worksheet
• Appendix 13 - Funds Layering Flowchart
• Appendix 14 - Tribal Consultation Letter
• Appendix 15: IHCDA Federal Flood Risk Management Standard (FFRMS) Floodplain Mapping Quick Guide
• Appendix 16 - Section 811 Project Rental Assistance (PRA) Worksheet

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.

• Training Slide Deck
• Additional Training Video - Overview and Submission Guidance

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 - This training covers the Approval Form, when it is required, and the associated timelines for review.

Federal Historic Tax Credits – This training covers the basics of the Federal Historic Tax Credit (FHTC) program.  The training should help partners understand how FHTC relates to 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 utilizes a third party for ERR and Section 106 reviews.  ERR and Section 106 materials must be submitted to IHCDA with the associated funding application.  Any required corrections or clarifications will be requested by and should be sent directly to IHCDA's third-party reviewer:

SJCA
Attn: Scott Henley
9102 N. Meridian Street, Suite 200
Indianapolis, IN 46260
317.566.0629
SHenley@sjcainc.com