Item 15 - On-Call Environmental Review Services for Federally Funded Programs

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