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RFQ #20-100: Environmental and Planning Services CHAMBERS <br />City of Santa Ana <br />GROUP <br />Environmental Impact Report (EIR) <br />Preparation of an EIR is a more detailed process and requires more effort than the preparation of a MIND. 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 (ED) 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. EA documents are required to be 75 pages or less, excluding appendices, and review of the document <br />is required to be concluded within 180 calendar days from commencement. Chambers Group will actively coordinate <br />with the City and other reviewing agencies to create a detailed schedule including submittal deadlines and review <br />periods in order to maintain compliance with SO 3355 time limits. Further, Chambers Group has internal processes in <br />place to budget page limits in accordance with SO 3355. <br />Executive Order 13927 <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 />the economy and return Americans to work, while providing appropriate protection for public health and safety, natural <br />resources, and the environment, as required by law. The leaders of all agencies are directed to use, to the fullest extent <br />possible and consistent with applicable law, emergency procedures, statutory exemptions, categorical exclusions, <br />analyses that have already been completed, and concise and focused analyses, consistent with NEPA, the Council for <br />Environmental Quality's NEPA regulations, and agencies' NEPA procedures. With this knowledge, Chambers Group staff <br />will pursue streamlined NEPA processes and push project timelines to the greatest extent possible to take full advantage <br />of the allowances under EO 13927. <br />Council on Environmental Quality Revisions to NEPA Rules <br />On July 16, 2020 the Council on Environmental Quality (CEQ) published their final rule to update the regulations for <br />Federal agencies to implement NEPA for the first time in 40 years. The final rule revises, modernizes, and clarifies the <br />regulations with the intention to facilitate more efficient, effective, and timely NEPA reviews by Federal agencies in <br />Est 5 <br />�"n 1979 "5S7 www.chainbersgroupinc.com <br />