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City of Santa Am On-call Environmental Review Services for Housing Division in ongoing compliance review and provide input as needed. Our architectural history staff has extensive experience supporting Santa Ana in these efforts and has a long track record of completing successful projects towards this end. Recently, we assisted the City's Housing Division in navigating a particularly delicate tribal consultation process under Section 106 for the Bewley Street Intergenerational Housing Project and,as a result, we are deeply knowledgeable in how to facilitate this process moving forward and assist the City with fostering relationships with consulting tribal and other interested historic groups.We also have a nuanced understanding of historic resources,regulations,and other considerations that guide historic compliance review in the City. Section 106 Review For each project, Rincon will coordinate with the City to determine whether Section 106 review is required. For projects requiring Section 106 review,the following tasks would typically be performed by Rincon: • Coordinate with the City and SHPO as needed to establish the Area of Potential Effects(APE) • Following APE map approval by the State Historic Preservation Officer(SHPO), initiate Section 106 outreach to interested parties and stakeholders; in accordance with 36 CFR 800.4(a)(3), outreach will include the Native American Group contact program and the local historic group/local government contact program • Request a records search of the California Historical Resources Information System from the South Central Coast Information Center to identify any previously recorded cultural resources within the APE • Complete literature review and focused archival research to characterize the construction chronology and historic setting of each of-age property;previous studies and historic context statements will be used to the maximum extent practicable to streamline project schedule and resources • Complete a historic property assessment, according to National Register of Historic Places(NRHP)criteria, for all of-age buildings,structures,sites, and other built environment features within the APE • Document the results of the historic property assessment in a Section 106 report;all properties 50 years of age and older within the APE will be recorded on Department of Parks and Recreation Series 523 forms • For APE properties found NRHP eligible, assess the effect of the proposed undertaking on the historic properties;the report will make one of three findings:"No Effect, No Adverse Effect,or Adverse Effect" • Analyze the proposed undertaking for compliance with the Secretary of the Interior's Standards for the Treatment of Historic Properties; where project components might not comply with the Secretary's Standards, Rincon will coordinate with the City to make recommendations for feasible project modifications that would eliminate or minimize adverse environmental effects • Incorporate the results of the analysis into the Finding of Effect report completed for the project Based on our previous work with the City, and external experience working with SHPO and HUD on similar projects, Rincon assumes the following regarding the scope of work for historic compliance review: • The APE would be limited to direct effects;should a broader indirect APE be required, cost may be higher should additional properties require assessment and recordation • A maximum of one of-age built environment property will need assessment and recordation; should additional properties require assessment and recordation,the costs may be higher • No more than one NRHP-eligible or designated historic property will require project-level review for Secretary's Standards compliance Environmental Site Assessments Rincon has provided environmental site assessment services for the City for almost 25 years. Phase I Environmental Site Assessment Phase I ESAs are used to determine current and historical site uses,are useful tools to identify the likely presence of contaminants at a site and are recommended to meet due diligence standards for property acquisition.While Phase I ESAs are typically prepared to meet ASTM standards, not all Phase I ESAs provide equal value. Rincon tailors a Phase I ESA to meet client and project specific needs and ensures that the most relevant information is clearly described and easily accessible. 8