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RFQ#20-100: Environmental and Planning Services CHAMBERS <br />City of Santa Ana <br />GROUP <br />connection with proposals for agency action. Some key changes to NEPA involve the use of categorical exclusions (CEs), <br />as well as cumulative impacts and GHG analyses. The final rule provides that agencies may use CEs to define actions <br />that normally do not have a significant effect, and may adopt another agency's CE determination or portions thereof if <br />the two actions subject to the determinations are substantially similar. Additionally, the cumulative impacts analysis is <br />no longer required as part of a NEPA review. With respect to GHG, CEQ explains in the preamble to the final rule that <br />"the analysis of the impacts on climate change will depend on the specific circumstances of the proposed action" and <br />that agencies "will consider predictable trends in the area in the baseline analysis of the affected environment." <br />Although cumulative impact analyses are not required, CEQ clarified that consideration of the cumulative and indirect <br />effects of climate change are not precluded by the final rule. <br />If Project development schedule allows, there could be advantages to pushing Project schedules to take advantage <br />of a favorable regulatory environment prior to January of 2021, dependent on the results of the election. CEQ has set <br />the effective date of the final rule as September 14, 2020, thus working to get Notice of Intent (NOI) s filed or other <br />relevant project milestones for Project development prior to January would take advantage of those regulations for <br />Project NEPA documentation, which are likely to be reversed if a new administration were to assume office in <br />January, 2021. <br />NEPA Literature Review and Scoping Meeting(s) <br />After receiving a NTP from the City, Chambers Group will be prepared to meet with the City and project Applicant(s), <br />when applicable, at a Project Initiation/Kick-off Meeting to discuss the project. Chambers Group will receive project <br />plans, and other project related information and studies. This information will be reviewed in order to determine the <br />appropriate NEPA documentation to be prepared. Chambers Group will assist City Staff in developing Scoping meetings <br />and identify the appropriate responsible/trustee agencies and other relevant stakeholders should the project require <br />these meetings (such as during the preparation of an EIS. While it is not necessary to conduct scoping meetings during <br />the preparation of Environmental Assessment, this could be helpful in data collection for a project. <br />NEPA Documents <br />NEPA Categorical Exclusion (CE) <br />There are certain conditions under which NEPA does not apply to an action. These conditions include, but are not <br />limited to statutory exemptions, emergencies, and classified information. Any of these, and some additional exempted <br />actions, may involve the City to some degree, by way of location of the action within the City. Thus, the City may have <br />a role in the NEPA process as a Review Agency, or as a Lead or Co -Lead Agency. As such, the City may be responsible <br />for preparation of some type of record of environmental consideration, documenting the applicability of the NEPA CE. <br />EA / Findings of No Significant Impact (EAIFONSI) <br />An EA is to be a concise public document that focuses on those environmental areas where potential adverse impacts <br />are anticipated. It will provide sufficient evidence and analysis to determine whether or not an EIS is required. The EA <br />would be limited to an analysis of potential significant environmental issues which area identified through a Scoping <br />process with the public and review agencies. The EA will include brief descriptions of the need for the proposed project, <br />alternatives to the proposed project, the environmental impacts of the proposed project and its alternatives, and a <br />listing of agencies and persons consulted. Based on the Final EA, Chambers Group will prepare the Finding of No <br />Significant Impact (FONSI) that outlines the reasons why the federal agency has concluded that no significant <br />environmental impacts would result from implementation of the proposed action. The FONSI will inform the decision <br />record for the federal agency. <br />EIS <br />An EIS would be required if a federal action would result in the significant effects of the quality of the human <br />environment. If the need for an EIS is identified, Chambers Group would follow a similar approach as applicable for an <br />EA. Chambers Group would prepare the N01 for publication in the Federal Register for the Project. The comments <br />received on the NOI will be used to further refine those impact areas that will be analyzed in the EIS, if needed. The <br />comments reviewed will be discussed with the City and federal agency to determine whether the scope of the EIS <br />should be expanded. The N01, comments received, and all correspondence will be included in the EIS appendices. The <br />EIS will address direct, indirect, and cumulative impacts relevant to the proposed action. Following the public review <br />period, the Final EIS would incorporate comments, responses, and changes to the Draft EIS (DEIS). The EIS process ends <br />lP�/, <br />Est b <br />�ilt`� 1979 ,35-t w%vw.chambersgroupinc com <br />