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City agrees to act as responsible entity for MMHA HUD environmental review, with reimbursement protections

5383601 · July 14, 2025
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Summary

Medina finance committee approved a memorandum of understanding allowing the city to serve as the HUD "responsible entity" for an environmental review tied to a proposed 11‑unit MMHA housing project, subject to law director approval and an added one‑page reimbursement agreement and emergency clause.

The Medina Finance Committee approved a memorandum of understanding for the city to serve as the HUD "responsible entity" for an environmental review tied to a proposed 11‑unit multifamily building at 81 Lafayette Road, designed for people at risk of homelessness. Committee members also required a separate, one‑page agreement protecting the city from unreimbursed costs and approved the action with an emergency clause so the sponsor could meet federal deadlines.

Patrick (staff) told the committee the Moneta Metropolitan Housing Authority (MMHA) had acquired the site and that August Mac Environmental Inc. completed the environmental review; the full report is in the council packet and runs roughly 780 pages. He said federal rules prevent MMHA from acting as the "responsible entity" for HUD funding and that either the city or a similar agency must assume that role. He said staff and representatives from HUD advised this is the usual process when a housing authority is the project sponsor.

Committee members discussed the need for a separate reimbursement agreement between MMHA and the city to cover any costs the city might incur while performing the environmental review and to limit the city's liability. The law director and other staff said they had reviewed a typical single‑page reimbursement agreement; an MMHA representative, Mike Larabee, provided a draft agreement to the city. The committee added language to the motion to make final approval subject to the law director's review and to include the reimbursement paragraph.

The motion to approve the MOU with MMHA included an emergency clause and passed by voice vote. The committee chair directed staff to circulate the one‑page reimbursement agreement to MMHA and to finalize the law director's sign‑off before full council action.

Why it matters: HUD requires a federally compliant environmental review before community project funding is released. Without a local entity to act as responsible entity, the HUD funds for the proposed project cannot proceed. The committee approved the step but required legal safeguards to protect the city from unexpected costs.