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Item 15 - On-Call Environmental Review Services for Federally Funded Programs
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Item 15 - On-Call Environmental Review Services for Federally Funded Programs
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Agenda Packet
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Clerk of the Council
Item #
15
Date
7/6/2021
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RFP #21-017: On-Call Environmental Review Services for the <br />Housing Division <br /> City of Santa Ana Community Development Agency <br /> <br />4 <br /> 63675 <br /> <br /> <br />Negative Declaration (ND)/ Mitigated Negative Declaration (MND) <br />The process for preparing a ND is the same as a MND with the exception that a Mitigation Monitoring and Reporting <br />Program (MMRP) is not required under an ND. Therefore, only the MND process is described. A MND will be prepared <br />when a project will have a significant effect on the environment, but such effects can be mitigated to a less than <br />significant. <br />If after preparation of the IS, it is identified that one or more significant impacts would occur, CEQA allows the <br />preparation of an MND when those impacts can be mitigated to a less than significant level. Based on CEQA defined <br />significance criteria, Chambers Group will determine the potential for any adverse or significant adverse impacts and <br />present mitigation measures to reduce any such impacts to a level below significance. <br />Environmental Impact Report (EIR) <br />Preparation of an EIR is a more detailed process and requires more effort than the preparation of a MND. An EIR would <br />be prepared if there is a potential for significant impacts which cannot be mitigated to a level less than significant or if <br />significant public controversy or scrutiny exists. In which case, an EIR would be the more legally defensible document. <br />Preparing an EIR will require completion of several important steps, from study initiation through development of the <br />project description and Draft EIR, to attendance at public hearings and Final EIR preparation. The process for a more <br />complex EIR would likely include additional scoping meetings (if the project is deemed to be controversial), complexity <br />of technical issues, number of alternatives assessed, possibility of extra internal review cycles, more complexity in <br />responding to public comments for the final document, a more in-depth mitigation monitoring plan, and additional <br />public meetings. <br />NEPA <br />We assume that a majority of the environmental documents for the City will be required to also comply with CEQA; <br />however, we have prepared an overview below focusing on compliance with NEPA, should the projects have federal <br />funding or permitting. <br />NEPA Approach <br />The NEPA climate is quickly changing under the current administration, with NEPA regulations being updated more <br />in the past few years than they have since enaction in 1970. Chambers Group staff work hard to stay up to date on <br />the changing regulatory environment surrounding NEPA in order to utilize streamlining opportunities to deliver more <br />concise documents, faster timelines, and lower costs than their competitors. <br />Below is a brief summary of the recent updates to the NEPA regulations and how Chambers Group has adapted. <br />Executive Order 13807 <br />Executive Order (EO) 13807 was signed on August 15, 2017 with the purpose of streamlining environmental review and <br />authorization decisions for major infrastructure projects to two years. Following EO 13807, the Department of the <br />Interior signed Secretarial Order (SO) 3355 on August 31, 2017 to streamline the NEPA process for all projects in all <br />Interior Departments, followed by many other Secretaries. In a series of memorandums on implementation of SO 3355, <br />page numbers and timelines of Environmental Impact Statement (EIS) and Environmental Assessment (EA) documents <br />were limited. EIS documents are required to be 150 pages or less for a standard project and 300 pages or less for <br />unusually complex projects. Additionally, EIS documents must be completed within one year from the issuance of a <br />Notice of Intent (NOI). EA documents are required to be 75 pages or less, excluding appendices, and review of the <br />document is required to be concluded within 180 calendar days from commencement. Chambers Group will actively <br />coordinate with the City and other reviewing agencies to create a detailed schedule including submittal deadlines and <br />review periods in order to maintain compliance with SO 3355 time limits. Further, Chambers Group has internal <br />processes in place to budget page limits in accordance with SO 3355. <br />EO13927 <br />On June 4, 2020, an EO was signed to provide federal agencies the foundation, under the National Emergencies Act, to <br />speed up environmental permitting in response to the National Emergency Concerning the Novel Coronavirus Disease <br />(COVID-19) Outbreak. The EO allows agencies to take all reasonable measures to accelerate actions that will strengthen <br />EXHIBIT 2
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