Comment Submitted by Saundra Holloway

Docket ID: HUD-2026-0661-0001 RIN: 2502-AJ82 Title: Comment on Interim Final Rule: Removal of Environmental Clearance Officer Review and Comment for Assessments for Projects Over 200 Lots/Dwelling Units or Beds ​I am writing to express strong opposition to the Department of Housing and Urban Development’s (HUD) interim final rule that removes the mandatory review and comment by Field Environmental Clearance Officers (FECOs) or Program Environmental Officers (PECOs) for Environmental Assessments (EAs) of large-scale projects exceeding 200 housing units, lots, or beds. ​HUD justifies this rollback by citing the need to prioritize "efficiency and expediency" under Executive Order 14154 (Unleashing American Energy) and by classifying FECO/PECO reviews as "extraneous" and "duplicative." This rationale fundamentally mischaracterizes the nature of robust environmental oversight. Removing specialized internal experts from high-impact developments undermines HUD’s core compliance under the National Environmental Policy Act (NEPA), increases long-term litigation risks, and compromises local accountability. ​1 - High-Density Projects Require Specialized, Independent Oversight - Developments exceeding 200 units or beds are, by definition, large-scale actions with significant community footprints. These projects heavily impact local stormwater infrastructure, floodplain vulnerability, environmental justice considerations, and municipal resource capacity. FECOs and PECOs possess regional expertise that project-level preparers and program supervisors may lack. Stripping this specialized layer of review removes a critical internal check-and-balance, opening the door to flawed assessments that fail to account for cumulative local environmental degradation. ​2 - Efficiency at the Expense of Accuracy Increases Legal Vulnerability - While HUD claims this rule cuts out a "third or fourth round of review" to save processing times, bypassing comprehensive oversight invites severe downstream delays. Flawed EAs are highly vulnerable to citizen lawsuits and administrative challenges under NEPA. By rushing the front-end review process to satisfy expedited timelines, HUD increases the likelihood that these large-scale housing projects will face judicial injunctions and costly delays after investments have been made. Robust administrative records—solidified by expert FECO review—are a defense against litigation, not a bureaucratic hurdle. ​3 - Misalignment of Deregulatory Pretext with Housing Realities - HUD explicitly relies on Executive Order 14154, a directive explicitly titled Unleashing American Energy that targets fossil fuel production, mining, and energy infrastructure. Applying an energy-sector deregulation mandate to weaken the environmental scrutiny of high-density urban and suburban residential housing is a regulatory overreach. Residential infrastructure directly dictates human health, exposure to lead, radon, urban heat islands, and severe weather vulnerability. Expedited energy sector frameworks should not serve as a blueprint for reducing oversight in the places where American families live. ​4 - The Flaw of "Good Cause" Interim Final Rules - Bypassing the standard notice-and-comment rulemaking process to implement this change immediately as an interim final rule deprives the public, environmental professionals, and municipal planning partners of their statutory right to shape HUD policy before it takes effect. Regulatory convenience does not constitute "good cause" to erode environmental protections. ​Conclusion - Bypassing Field Environmental Clearance Officers does not streamline housing development; it removes the very experts responsible for ensuring those developments are safe, resilient, and lawful. HUD should immediately rescind this interim final rule and restore full FECO/PECO review mandates for all projects exceeding the 200-unit threshold. Respectfully submitted for the record Saundra Holloway, Yuma, Arizona