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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
<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. I he 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, conslstent wlth 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 EC) 13927.
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<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 />connection with proposals for agency action. Some key changes to NEPA involve the use of CEs, as well as cumulative
<br />impacts and CHC analyses. The final rule provides that agencies may use CFs to define actions that nnrmnlly an not
<br />have a significant effect and may adopt another agency's CE determination or portions thereof if the two actions subject
<br />to the determinations are substantially sirnilar. Additionally, the cumulative impacts analysis is no longer required as
<br />part of a NEPA review. With respect to GHG, CEQ explains in the preamble to the final rule that "the analysis of the
<br />impacts on climate change will depend on the specific circumstances of the proposed action" and that agencies "will
<br />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 />rhange are not prerluded by the final rule.
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<br />After receiving a NTP from the City, Chambers Group will be prepared to meet with the City and project Applicant(0,
<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 />Lhese meetings (such as during the preparation of an EIS. While iL is noL necessary Lo conduCL scoping meetings during
<br />the preparation of Environmental Assessment, this could be helpful in data collection for a project.
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<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.
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<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 HIS 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. I he LA 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 FONSI that outlines
<br />the reasons why the federal agency has concluded that no significant environmental impacts would result from
<br />implementation of the proposed action. The FONSI will inform the decision record for the federal agency-
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<br />Chambers Group will prepare on EA in accordance with HUD's format for EA Determinations and Compliance Findings
<br />for I IUD -assisted Projects (24 CFR Part 58).
<br />tll��.�oi City Council
<br />Est
<br />7979
<br />5 15-89
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<br />7/6/2021
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