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RFP #24-038A: On-Call Environmental Review Services for CHAMBERS
<br /> the Housing Division
<br /> City of Santa Ana GROUP
<br /> NEPA
<br /> We assume that a majority of the environmental documents for the City will be required to comply with CEQA;however,
<br /> we have prepared an overview below focusing on compliance with NEPA,should the projects have federal funding or
<br /> permitting.
<br /> NEPA Approach
<br /> The NEPA climate is quickly changing under the current administration,with NEPA regulations being updated more in
<br /> the past few years than they have since enaction in 1970.Chambers Group staff work hard to stay up to date on the
<br /> 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(E0)13807: EO 13807 was signed on August 15,2017 with the purpose of streamlining environmental
<br /> review and authorization decisions for major infrastructure projects to 2 years.Following EO 13807,the Department of
<br /> the 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 EIS and EA documents were limited.EIS documents are required to be 150 pages or less
<br /> for a standard project and 300 pages or less for unusually complex projects. Additionally, EIS documents must be
<br /> completed within 1 year from the issuance of a Notice of Intent(N01). EA documents are required to be 75 pages or
<br /> less, exduding appendices, and review of the document is required to be concluded within 180 calendar days from
<br /> commencement. Chambers Group will actively coordinate with the City and other reviewing agencies to create a
<br /> detailed schedule including submittal deadlines and review periods in order to maintain compliance with SO 3355 time
<br /> limits. Further,Chambers Group has internal processes in place to budget page limits in accordance with SO 3355.
<br /> E01392 7: On June 4, 2020, an E0 was signed to provide federal agencies the foundation, under the National
<br /> Emergencies Act,to speed up environmental permitting in response to the National Emergency Concerning the Novel
<br /> Coronavirus Disease(COVID-19)Outbreak.The EO allows agencies to take all reasonable measures to accelerate actions
<br /> that will strengthen the economy and return Americans to work, while providing appropriate protection for public
<br /> health and safety,natural resources,and the environment,as required by law.The leaders of all agencies are directed
<br /> to use,to the fullest extent possible and consistent with applicable law,emergency procedures,statutory exemptions,
<br /> categorical exclusions,analyses that have already been completed,and concise and focused analyses,consistent with
<br /> NEPA,the Council for Environmental Quality's NEPA regulations,and agencies'NEPA procedures.With this knowledge,
<br /> Chambers Group staff will pursue streamlined NEPA processes and push project timelines to the greatest extent
<br /> possible to take full advantage of the allowances under EO 13927.
<br /> Council on Environmental Quality Revisions to NEPA Rules:On July 16,2020,the Council on Environmental Quality(CEQ)
<br /> published their final rule to update the regulations for Federal agencies to implement NEPA for the first time in 40
<br /> years. The final rule revises, modernizes, and clarifies the regulations with the intention to facilitate more efficient,
<br /> effective, and timely NEPA reviews by federal agencies in connection with proposals for agency action. Some key
<br /> changes to NEPA involve the use of Categorical Exclusions, as well as cumulative impacts and GHG analyses. The final
<br /> rule provides that agencies may use Categorical Exclusions to define actions that normally do not have a significant
<br /> effect and may adopt another agency's Categorical Exclusion determination or portions thereof if the two actions
<br /> subject to the determinations are substantially similar. Additionally, the cumulative impacts analysis is no longer
<br /> required as part of a NEPA review.With respect to GHG,CEQ explains in the preamble to the final rule that"the analysis
<br /> of the impacts on climate change will depend on the specific circumstances of the proposed action"and that agencies
<br /> "will consider predictable trends in the area in the baseline analysis of the affected environment."Although cumulative
<br /> impact analyses are not required, CEQ clarified that consideration of the cumulative and indirect effects of climate
<br /> change are not precluded by the final rule.
<br /> NEPA Literature Review and Scoping Meeting(s): After receiving a NTP from the City,Chambers Group will be prepared
<br /> to meet with the City and project Applicant(s),when applicable,at a Project Initiation/Kick-off Meeting to discuss the
<br /> project.Chambers Group will receive project plans,and other project related information and studies.This information
<br /> will be reviewed in order to determine the appropriate NEPA documentation to be prepared. Chambers Group will
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