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Board reviews edits to application guidelines; new rule would require sufficient design before environmental review and URA notifications
Summary
Staff proposed changes to application and funding guidelines that would require acquisition/construction projects to include sufficient design detail before environmental reviews and URA determinations (staff said environmental reviews require about 30% design, 60% preferred for some consultations). The board discussed certification rather than a fixed percentage and did not object to the change.
Rebecca Royce walked the board through proposed edits to the Urban County application and funding guidelines, explaining staff had moved and clarified sections to match current practices and to better inform applicants of application expectations.
One notable proposed change would require that acquisition and construction projects include sufficient design to determine the level of environmental review and whether the Uniform Relocation Act (URA) applies. "The environmental reviews cannot be conducted, until at least 30% of the design is complete," Royce said, adding that for certain consultations staff would prefer 60% completion. She said the guideline will ask proposers to certify that their design is sufficiently mature to identify likely environmental-review needs and any URA triggers at the application stage to avoid later delays.
Board members asked whether a fixed percentage should be inserted in the policy. Tracy Coleman said many federal programs use 60% as a benchmark; staff and Michael Torres cautioned that a single percentage does not reliably indicate whether URA or the proper environmental-review level will be required and that design needs vary by project. Michael Torres said staff wants applicants to certify design maturity rather than imposing a rigid percentage.
Staff said the change is intended to reduce delays and negative scoring caused when URA is triggered unexpectedly during design. The guidelines also retain a nine-month start requirement (projects should be ready to start within nine months) to account for environmental-review timing.
