Call Us: (800) 419-4923
 Call Us: +44 (0)20 3865 7701
 Call Us: (787) 822-8377
 Call Us: (437) 855-4925
Partner Engineering and Science, Inc.
Partner Engineering and Science, Inc.
You are here: Home » Resources » Articles » Environmental Requirements for Concentrated Animal Feeding Operation SBA Loans

January 25, 2017

Environmental Requirements for Concentrated Animal Feeding Operation SBA Loans

By Janet Annan

IN RESPONSE TO A RECENT LAWSUIT, SBA IS NOW CURRENTLY REQUIRING ADDITIONAL ENVIRONMENTAL REVIEW ON LOANS INVOLVING ANIMAL FEEDLOTS

In response to a recent lawsuit that was filed against SBA with regard to a feedlot loan, SBA is currently requiring additional environmental review for loans involving concentrated animal feedlots, including dairy, cattle, hog, and poultry. Environmental reviews under the National Environmental Policy Act (NEPA) are not specified in SOP 50 10 5(H), however, the results of the recent lawsuit made it clear that SBA is required to consider the potential for future environmental impacts associated with feedlot loans. So what does this mean for due diligence on loans involving concentrated animal feeding operations (CAFOs)?

Well, two things are clear: In addition to the already required SBA Environmental Questionnaire and Records Search Risk Assessment (RSRA), the SBA is asking for two additional completed forms as the first step in the process: 1) Farm Loan Checklist and 2) Environmental Worksheet.

But the following questions remain unclear as the SBA continues to consider how best to assess environmental impact: Will the level of environmental due diligence increase? Will the SBA begin to consider CAFOs as a sensitive industry (currently it is not) which would require the environmental due diligence begin with a Phase I ESA? What level of a NEPA will be required to understand other potential impacts?

The NEPA process requires Federal agencies to consider environmental effects that include, but are not limited to, impacts on social, cultural, economic, and natural resources. There are different levels of NEPA review that can be done. Will the SBA require a NEPA with 1) Categorical Exclusion Determination (CATEX), 2) Environmental Assessment/Finding of No Significant Impact (EA/FONSI), and/or 3) Environmental Impact Statement (EIS)?

Continue reading the Coleman Report blog here.

About the Authors

Janet Annan

Janet Annan

Client Manager, Principal
Janet Annan is a Principal and Client Manager, who is specialized in environmental due diligence and other services supporting Partner including institutional and private equity clients, Fannie Mae, Freddie Mac, and SBA. She provides technical expertise and senior review to ensure ASTM, AAI, and SBA requirements are completed for the client requirements on all levels of environmental due diligence. Her responsibilities include project and team oversight, report review, client liaison, education to internal and external clients, and technical expertise. Specifically, Ms. Annan has nearly 20 years of experience and has performed and supervised Phase I and Phase II Site Assessments, Baseline and Exit Assessments, SBA Farm Loans, TSAs, Subsurface Investigations, RSRAs, Peer Reviews, Limited Compliance Overviews, Asbestos Surveys, Radon Measurement and Mitigation Surveys, National Environmental Policy Protection Act (NEPA), “hands-on” field investigations, remediation projects, formerly-used defense (FUD) sites, CERCLA sites with Community Involvement, and hazardous material emergency response.

Other Resources You Might Like


Let us be your Partner

Learn how we can support your next project or share insights via our newsletter.
Terms and Conditions  |  Privacy Policy   |  Website Terms of Use  |  © 2025 Partner ESI. All rights reserved.
crossmenuarrow-up linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram