Does reporting the use of emergency hotel/motel vouchers as leasing trigger any environmental review requirements?
No, not beyond the documentation made prior to undertaking the activity as a categorical exclusion. The use of emergency housing vouchers to place homeless families in temporary housing, such as short-term use of hotel/motel units, is considered a short-term payment for rent costs under HUD environmental regulations. Note. Any “short-term payments for rent/mortgage/utility costs” for temporary housing and related supportive services listed at 24 CFR 58.35(b)(2) are eligible as categorical exclusions from the National Environmental Policy Act (NEPA) [except in extraordinary circumstances under §58.35(c)] and are not subject to compliance with §58.5 environmental laws and authorities. A recipient does not have to submit an RROF and certification. However, for the environmental review record, the responsible entity (i.e., the unit of general local government or the State agency, if applicable) must document in writing the determination of short-term payment for rent costs as listed in the
