June 04, 2025
Gregory Palomino, Administrative Assistant
Richmond Housing Authority
450 Civic Center Plaza 2nd Floor
Richmond, California 94804
Submitted via email: [email protected]
Re: Richmond Housing Authority 24 CFR 50 Review, Richmond Village/Easter Hill Property / P99008 Dear Gregory Palomino:
SWCA Environmental Consultants (SWCA) appreciates the opportunity to provide the Richmond Housing Authority (RHA) with our scope of work and cost estimate for preparation of a National Environmental Policy Act (NEPA) document for the conversion of 167 units of public housing at the Richmond Village/Easter Hill property to Section 8 Project-Based Vouchers through the U.S. Department of Housing and Urban Development (HUD) Section 18 Disposition/Rental Assistance Demonstration (RAD) program (projects). Our firm and project manager qualifications reflect experience with HUD regulations and relevant NEPA requirements, as well as a clear understanding of the various issues and multiple stakeholders that will be involved in the environmental review process.
The SWCA team, led by Project Manager Alaina Callinan, who has 10 years of HUD NEPA and HUD grant management experience, knows what is required to produce quality environmental documents and provide efficient and quick responses with minimal oversight and correction. Navigating environmental requirements for federally funded projects can be complex and, if not done correctly, will cause substantial implementation delays or negative audit findings from HUD. For the following reasons, SWCA is the best firm to execute these types of environmental analyses for the RHA:
• Understanding of HUD Processes. Our team brings comprehensive understanding and lessons learne d
f
rom more than a decade of working on HUD-funded projects across the country. Having completed t
housands of HUD NEPA environmental reviews, we know what HUD requires for these types of projects, eliminating unnecessary learning-curve delays.
• Regulatory Knowledge. As a company, we have more than 40 years of experience working for federal and s
tate agencies, Tribes, cities, counties, and other agencies, making our staff versatile and efficient. SWCA considers NEPA compliance services to be a core area of expertise. Over the past 40 years, SWCA has prepared countless NEPA documents across the United States, including Environmental Impact Statements, Environmental Assessments, and Categorical Exclusions; we are well-versed in tiering and agency adoptions, as well as in how to ensure a successful HUD monitoring event. • Project Manager–Specific Experience. Alaina has overseen or prepared more than 1,000 HUD NEPA Environmental Review Records. She has developed Environmental Review Procedures and Policy Manuals that have been used by HUD Field Environmental Officers as a best practice example for other Grantees in t
he region. Her programs have undergone HUD Environmental Monitoring without any findings or concerns.
Our proposal demonstrates that SWCA is the right team with the relevant experience as well as a proven track record of providing HUD environmental and site-specific analyses to federal, state, and local agencies across the United States. We have prepared our response per the requirements of the Request for Proposals.
If you have any questions regarding our experience or project approach, please feel free to contact Alaina Callinan at (845) 253-2794 or [email protected]. W e are always willing to negotiate our approach and team to suit your expectations. Thank you for the opportunity to submit a proposal for this project, and we look forward to the possibility of working with you.
Sincerely,
A
laina Callinan Brooke Langle
Project Manager Vice President, Northern and Central California
Richmond Housing Authority 24 CFR 50 Review, Richmond Village/Easter Hill Property Page | 1
SCOPE OF WORK
SWCA Environmental Consultants (SWCA) understands that the Richmond Housing Authority (RHA) owns and operates 167 units of public housing located at the Richmond Village/Easter Hill property at 700 South 26th Street, Richmond, California. The property will be converting to Section 8 Project-Based Vouchers through the U.S.
Department of Housing and Urban Development’s (HUD’s) Section 18 Disposition/Rental Assistance Demonstration (RAD) program (projects). The property will be sold as-is to an affiliate of the RHA for a nominal value; maintenance activities may be required, however, no rehabilitation will be completed. All projects converting from Section 9 public housing subsidy to Section 8 subsidy must meet the requirements of the National Environmental Policy Act (NEPA) and 24 Code of Federal Regulations (CFR) 50 HUD Environmental Review Regulations prior to receiving HUD approval to use grant funds. SWCA anticipates the level of review to be Categorically Excluded Not Subject To 50.4 (CEST). Although no physical repairs are being completed, SWCA understands that HUD requires a minimum review level of CEST for any RAD conversion projects. Our approach outlines the requirements for a CEST level of review.
TASK 1. HUD NEPA ENVIRONMENTAL REVIEW RECORD
1.1 KICKOFF CALL
SWCA will coordinate a kickoff meeting with the RHA following receipt of written notice to proceed on the project. The purpose of this meeting will be to familiarize the environmental team with the proposed project description and confirm the contract scope of work and target schedule. If requested, SWCA will prepare and share the kickoff meeting agenda with all meeting attendees prior to the meeting. This task includes attendance by SWCA Project Manager Alaina Callinan; attendance is assumed to be virtual. Anticipated key topics that will need to be addressed early in the process include defining the project boundary, identifying key information needs, and establishing a communication protocol. This task also includes attendance at two general coordination meetings with the RHA, as needed, to discuss progress made toward project deliverables, environmental determination findings, schedule updates, RHA staff reviews/comments on deliverables, etc.
This task also includes general management of the SWCA team, coordination and correspondence with the RHA, management of the project scope and budget, and quality assurance and quality control (QA/QC). Alaina Callinan will be the day-to-day contact and responsible for overseeing all aspects of the environmental analysis, communicating and coordinating with the RHA, and ensuring adherence to the schedule and budget.
1.2 PROJECT DESCRIPTION COORDINATION
A comprehensive and stable project description, including the project purpose and objectives, is essential to successful completion of the environmental documentation process. SWCA will prepare a draft project description based on the project details provided by the RHA and existing documentation available for each project site. SWCA will review all materials associated with the project and submit a data request (if needed) to the RHA where additional information or clarification may be needed to support the NEPA documentation. Upon receipt of requested project information, SWCA will prepare a preliminary project description for the RHA’s review and approval for each project site. This task assumes one round of review of the project description by the RHA.
1.3 ENVIRONMENTAL RECORD OF REVIEW
SWCA understands our role is to assist the RHA and enable the HUD grant funds to be used expeditiously and in compliance with all federal, state, and local laws and authorities. A key component to HUD programs is documenting that each project complies with HUD’s NEPA requirements and review procedures under 24 CFR 50 and the associated environmental laws and requirements under 24 CFR 50.4, including but not limited to 24 CFR 51, Environmental Criteria and Standards; 24 CFR 55, Floodplain Management; 35 CFR 800, Protection of Historic Richmond Housing Authority 24 CFR 50 Review, Richmond Village/Easter Hill Property Page | 2
Properties; 40 CFR 1500–1508, Council on Environmental Quality Implementation of NEPA Procedural Provisions; and 50 CFR 402, Interagency Cooperation–Endangered Species Act of 1973, as amended.
Based on our understanding of exempt activities and categorically excluded activities not subject to the related federal laws and authorities, we propose a CEST level of environmental review to comply with NEPA under 24 CFR 50. An individual CEST will be required for the property.
The CEST will be prepared for the RHA’s review based on the requirements of HUD regulations (24 CFR 50) using the HUD-recommended format and will be based on information obtained during the project kickoff meeting and required Environmental Site Visit, information from the project application, and any special environmental studies conducted by the RHA. The scope of this proposal covers only the items necessary to complete that review. SWCA does not anticipate needing to complete additional studies such as a Phase I Environmental Site Assessment, studies for radon, asbestos, or lead-based paint, or geotechnical, biological, archaeological, noise, or traffic studies, etc. at this stage. However, SWCA understands that if these studies are determined to be required and known during the scoping stage, they shall be supplied to SWCA by the RHA. If not already obtained, SWCA can provide these services for an additional fee through a change order proposal once determined necessary through discussion with the RHA.
The contents of the Environmental Review Records (ERR) package will include all NEPA- and HUD-required sections and will be organized consistent with HUD’s recommended format. One electronic copy (in MS Word format) of the CEST package will be submitted to the RHA for review and approval. Once the RHA has approved the CEST package, SWCA will produce electronic copies (in MS Word format [internal] and Adobe PDF format [distribution]) and submit the final Public Review CEST, should public review be required (i.e., if the review does not convert to exempt and a Notice of Intent to Request a Release of Funds [NOI-RROF] is required). It is assumed that all identified sources and supporting documentation will be produced electronically. Additionally, SWCA has a HUD Online Environmental Review System (HEROS) Partner User Account and will transfer all partner-level user data from each electronic CEST to HEROS for the RHA’s assigned HUD reviewer to finalize.
Deliverables
The CEST ERR package will contain the following sections:
• Introduction (project location, description, level of review determination, and funding information) • HUD CEST Statutory Checklist
• Summary of Findings and Conclusions
• Mitigation Measures
• List of Preparers
• Copies of any special studies reports
• HUD Environmental Review Partner Worksheets
The ERR will become final when HUD approves the ERR in HEROS.
COST ESTIMATE AND ASSUMPTIONS
SWCA is proposing a time-and-materials, not-to-exceed budget of $17,500 for completion of the NEPA documentation for the project.
Richmond Housing Authority 24 CFR 50 Review, Richmond Village/Easter Hill Property Page | 3
ASSUMPTIONS
1. SWCA assumes that all reporting and investigations are being prepared in support of NEPA. If compliance r
elated to the California Environmental Quality Act (CEQA) is required, this may be provided as an additional service.
2. Costs associated with this scope of work include one round of comment and review by the RHA before finalizing the deliverables.
3. SWCA assumes the appropriate level of NEPA review will be a CEST. If a different level of review is determined to be appropriate, SWCA can provide a revised scope to facilitate a contract amendment.
4. SWCA assumes the project description will not be substantially altered after finalization by the project team.
5. The project site is not known to be located within a special flood hazard area or mapped wetland feature; therefore, compliance with Executive Orders 11988 and 11990 and associated noticing is not anticipated to be required.
6. SWCA assumes the Determination of "No Potential to Cause Effects" under Section 106 of the National Historic Preservation Act for Rental Assistance Demonstration (RAD) Projects Limited to Maintenanc e
A
ctivities and Carried Out Under 24 CFR Part 50 will be used to satisfy this section of the Environmental Review.
7. SWCA assumes all deliverables will be provided in electronic format (MS Word and Adobe PDF); no hard c
opies will be provided.
8. SWCA assumes in-person attendance at meetings will not be required.
9. SWCA reserves the right to utilize the overall project funding and will not be held to phase or task limits so l
ong as the overall budget is not exceeded.
10. This cost estimate is valid for 90 days from the date of the proposal, after which time SWCA reserves the right to submit a new cost estimate.
11. Any task not expressly described herein is not included in the proposal cost.