Pipelines, power lines and oil and gas wells near an FHA multifamily property

Section 9.6.19 of the Multifamily Accelerated Processing (MAP) Guide of the Department of Housing and Urban Development (HUD) sets how far residential structures must stand from pressurized pipelines, high voltage transmission lines, towers and oil and gas wells on a project seeking Federal Housing Administration (FHA) multifamily mortgage insurance. This page rests on the 2020 MAP Guide, revision of March 19, 2021, as changed by Mortgagee Letter 2026-04, the only later letter or notice whose title touches the chapter as of October 9, 2026. On May 4, 2026 the letter replaced the section's paragraphs B (pipelines) and C (power lines and fall hazards) for applications that had not reached initial endorsement (Mortgagee Letter 2026-04, IV).

Who the rule binds

Transactions. All types, except as a paragraph notes and except those the guide holds categorically excluded from all environmental review: Section 223(a)(7) projects and refinancing under Section 223(f) of a mortgage HUD already insures, with no new construction, rehabilitation or physical change beyond maintenance (MAP Guide, 9.6.19.A, 9.1.3.C.1, 9.1.3.C.2).
The lender submits the environmental report and any engineer's report the section calls for (MAP Guide, 9.2.1.A; Mortgagee Letter 2026-04, III.c.2).
HUD decides, and may require mitigation of other nuisances and hazards on the property that would affect residents' health and safety and the collateral's security (MAP Guide, 9.6.19.F).

What it asks

Pressurized pipelines. Every part of a residential structure must keep 10 feet or more from the outer boundary of a pressurized pipeline's easement. Such a pipeline transfers flammable or combustible liquids and gases at more than 200 psi operating pressure. Residential structures include those residents or property staff occupy for a regular duration in the day, such as a management office or club house. Distribution lines supplying only the mortgaged property are outside the rule. In limited cases HUD may, at its sole discretion, consider a headquarters level waiver of the 10-foot buffer, on appropriate justification and documentation (Mortgagee Letter 2026-04, III.b.2).
Power lines and fall hazards. No residential structure, in that sense, and no playground may be located inside an overhead high voltage transmission line's easement. All residential structures must also stand off from any support structure for a high voltage transmission line, any free-standing radio, TV or cell tower and any like free-standing structure, by at least 50% of its height. Items affixed to the multifamily building (an antenna or a satellite dish, for example) are excluded, as are local service electric lines and poles. Where a proposed or existing residential structure is nearer, the lender must submit a licensed professional engineer's report that the support structure was designed for wind, ice and seismic loads under ASCE-7 or TIA ANSI/TIA-222-I, that it is structurally sound, and that it has been properly maintained (Mortgagee Letter 2026-04, III.c.2).
Drilling sites and wells. Residential structures are barred within 300 feet of an operating or planned drilling site's boundary, and within 75 feet of an operating well unless three mitigating measures are taken: nuisance controls, controls on pumping noise, and spill controls to reduce contamination risk (MAP Guide, 9.6.19.D.1, 9.6.19.D.2).
Abandoned and sour gas wells. Where the State government confirms that a well has been abandoned safely and permanently, residential structures are barred within 10 feet of it; with no confirmation letter, within 300 feet. For a sour gas well, a Petroleum Engineer must determine the separation distance, with the State government's concurrence (MAP Guide, 9.6.19.D.3, 9.6.19.D.4).
Slush pits. A slush pit, used for drilling mud mixes, requires a hazards analysis under the guide's contamination section, 9.4, on the site or off it. On the site, mitigation must include removing all drilling mud and backfilling with clean compacted material (MAP Guide, 9.6.19.D.5).
Hydraulic fracturing. Within or adjacent to the site, residential structures are barred within 300 feet of a fracking well pad's boundary, existing or planned. For a pad beyond 300 feet but within 1,000 feet of a proposed multifamily project, HUD requires a hazard analysis by a qualified party (a geologist or geotechnical engineer, for example) evidencing that lateral fracking would not harm soil stability, release petroleum or otherwise put the property or residents at risk. HUD requires mitigation of issues identified and may reject the project if none is possible (MAP Guide, 9.6.19.D.6).
Filled ground. Where part of a site is to be built on filled ground, HUD may require all grading properly controlled against differential earth movement, sliding, erosion or other occurrences that could damage dwellings, streets or other improvements (MAP Guide, 9.6.19.E).

The regulation on tanks differs: its hazard is a stationary container, its distance is determined hazard by hazard, and its definition leaves out pipelines that are underground or meet the safety standards that apply (24 CFR 51.201); this section mostly prints distances.

What it means for the Phase I and the consultant

The decisive facts are measurements: where a pipeline's easement ends and its operating pressure; a support structure's height and distance from each residential structure; a well's status and distance.

A Phase I Environmental Site Assessment under ASTM E1527-21 looks for hazardous substances or petroleum products, crude oil and natural gas among them, released, likely released or posing a material threat of release at the subject property (E1527-21, 1.1.1, 3.2.61). What it covers:

Wells and pits. The site visit looks for wells on the subject property, abandoned ones included, and for pits, ponds or lagoons (E1527-21, 9.4.22, 9.4.27).
Pipelines. A site plan suggested in a non-mandatory appendix shows wells and marked pipelines (E1527-21, X5.12.1).
Off the property. Adjoining properties and the surrounding area are observed from the subject property's edge and from public thoroughfares (E1527-21, 9.2.5).
Records. No list of pipelines, transmission lines, towers or oil and gas wells is among the government records the standard requires (E1527-21, 8.2.2, Table 2).

The site visit's list names no pipeline, transmission line or tower, and a listed feature that cannot be seen or physically observed need not be identified (E1527-21, 9.2.4.1, 9.4.1 to 9.4.28); the standard asks for no operating pressure, easement boundary, structure height or distance from a well or tower to a building.

The replaced paragraphs called, on some projects, for identifying pressurized pipelines within one mile and for an engineered fall distance (MAP Guide, 9.6.19.B.2, 9.6.19.C.2); the letter's text holds neither.

What the rule says

The term “hazard” does not include:

24 CFR 51.201, edition revised as of April 1, 2025

(1) Pipelines for the transmission of hazardous substances, if such pipelines are located underground, or comply with applicable Federal, State and local safety standards;