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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
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<br />The process for preparing a NDis 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 MIND 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 Tess than significant level. Based on CECIA 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.
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<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 aL public hearings and Final EIR preparation. The process for a more
<br />complex EIR would likely include additional seeping 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.
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<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.
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<br />Below is a briet summary of the recent updates to the NEPA regulations and how Chambers Group has adapted.
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<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, hollowed by many other Secretaries. In a series of memorandums on implementation of SO 33SS,
<br />page numbers and timelines of Environmental Impact Statement (EIS) and Environmental Assessment (EA) documents
<br />were limited. EIS documents are required to be 1S0 pages or less for a standard project and 300 pages or less for
<br />unusually rnmplex prnjerts. Additionally, FIS documents must he completed within one year frnm the issuanrp 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 33SS time limits. Further, Chambers Group has internal
<br />processes in place to budget page limits in accordance with SO 3355.
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<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 />City Council
<br />Est
<br />7979
<br />4 15-88
<br />VVWW ( Il I )i i I(J ). ) II L. 1111
<br />7/6/2021
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