Scope of Work
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F. Scope of Work
Project Understanding and Approach to CEQA
Rincon’s approach and scope of work is based on
numerous conversations with the City, and review of the RFP and other provided materials, including the 2005
Final EIR for the Mendocino Coast Regional Park and
Golf Course, and biological technical studies completed to-date for the project site. We understand that the
Water Reservoir and Community Forest Project includes
the construction of three new water storage reservoirs
on approximately 30 acres of land within the 582-acre
project site. The Project also includes the establishment of a community forest on the remainder of the parcel,
and a caretaker unit and storage facility. The City is
seeking an environmental consultant to prepare the
necessary documentation to satisfy the requirements of
CEQA and potential federal funding programs. The City
is also seeking assistance with permit approvals for the Raw Water Line Replacement Project, which includes
the replacement of several Noyo River culvert crossings.
Based on the sensitivity of on-site habitats, such the rare and endemic Mendocino Cypress Woodland, and the proposed level of disturbance, we anticipate that an EIR will be necessary for CEQA compliance, due to the potential for significant and unavoidable impacts to biological resources. As such, an EIR will provide legally defensible documentation for the City’s decision-makers. To the extent feasible, we propose to screen out certain environmental topics in an Effects Found Not to be Significant section of the EIR, to focus and streamline the EIR to the extent feasible. This strategy is necessary to maintain the tight overall project timeline. We considered the utility of preparing an Initial Study with the NOP (see Task 2 below) to scope out these topics; however, the project schedule would be delayed as a result, so our approach does not include an Initial Study, as a means to save time and budget.
We intend to use the background information and studies provided by the City that have been conducted on the project site and/or in adjacent areas to inform the existing setting of the environmental analysis. This includes the Vegetation and Special-Status Plants Assessment (2023), Geotechnical Engineering Report for Summers Lane Reservoir (2010), Summers Lane Reservoir Site Plans (2016), and Raw Water Line Replacement Project Site Plans (2024). Additional technical studies are proposed as part of the scope of work to provide projectspecific information related to biological and cultural resources in particular.
As part of our scope of work, we have included all necessary tasks related to the preparation of an EIR, including AB 52 consultation assistance, which is required for all EIRs. Optional tasks have also been included to provide additional support to the City through the EIR and project design process.
Key Issues
Project Schedule
Adherence to the overall project timeline will be a key challenge for this project. The City needs to complete the CEQA process in order to be construction-ready by January 2026. The EIR process includes public review periods and hearings for certification of the EIR, which provide constraints to the timeline. Rincon has experience completing EIRs within an accelerated timeline to meet funding deadlines and/or other schedule restrictions. We propose to complete the EIR for this project within 12 months. Additionally, as noted above under Project Understanding, we propose to prepare an Effects Found Not to be Significant section of the EIR to screen out issues that would have no impact or a less-than-significant impact without mitigation. This strategy City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
28 eliminates the need to conduct an Initial Study prior to the release of the NOP and will quicken the delivery of the first Administrative Draft EIR. As described further below, our adherence to strict Project Management and Quality Assurance/Quality Control (QA/QC) procedures will also keep our schedule on track.
NEPA Compliance
If federal grant funding is pursued and received, the project would be required to comply with NEPA. As described below in our scope of work, Optional Tasks 4.6, 4.7, 4.8, and Federal Cross-Cutters Analysis under Task 6 would be required if NEPA compliance is determined to be necessary. Because the decision to pursue federal funding has not been made at this time, we propose to conduct a CEQA-only analysis, but would be able to pivot to a CEQA-Plus analysis to include the necessary additional details required for NEPA compliance.
Rincon’s Funding Group regularly supports our water market clients with grant applications, securing nearly $62 million for water districts, municipalities, and public utilities to address water resource management and climate adaptation. We bring experience with a wide variety of federal, state, regional, and local grant and funding agencies, including the California Department of Water Resources, SWRCB, United States Bureau of Reclamation, USEPA, the Federal Emergency Management Agency, and California Office of Emergency Services, as well as specific programs such as the Title XVI WaterSMART program and Water Infrastructure Finance and Innovation Act program. This expertise directly informs our CEQA/NEPA strategy – to provide flexibility to pursue a variety of federal funding.
Site Selection and Coordination with Design Engineer
The City’s goal is to achieve CEQA compliance and 100 percent engineering design by January 2026.
Rincon regularly works closely with both engineering partners and with design team staff on projects throughout the state. Successful collaboration ensures a positive outcome related to both the siting of project features, avoidance of environmentally sensitive areas, and cost savings. With the design process and environmental review process occurring in tandem, coordination and communication efforts across the environmental, design, and City teams will be key to ensure the best option for project siting is selected, Regular check-in meetings and email communications will be necessary to ensure that the project schedule stays on-track and that collaboration is occurring, particularly during the early phases of the design process and in developing the project description for CEQA technical studies and the EIR. We have budgeted to attend regular check-in meetings with City and Design Team staff in order to facilitate information sharing early and often. In particular, it will be important to provide preliminary findings and results from Rincon’s technical analyses to the City and Design Team in order to help inform the decisions related to the reservoir siting and design. Rincon will provide the results of our technical analyses for biological and cultural resources in real time, to allow the design process to proceed in parallel with the CEQA process and supporting the goal to reach 100 percent design by January 2026.
Biological Resources
The project site includes important biological resources, which will constrain the project design and affect the environmental analysis.
• Forestry Resources. Construction of Reservoirs and Creation of Community Forest • Biological Resources. Construction of Reservoirs within Mendocino Cypress Woodland (aka, pygmy forest) • Fisheries Resources. Water Line Improvements at Stream Crossings Rincon understands the forestry resources that occur within the proposed project site and has therefore, included our International Society of Arboriculture-Certified Arborists to lead develop of the Community Forest Technical Report and augmented our team’s expertise to include a local Registered Professional Forester, Christopher Blencowe of Blencowe Watershed Management to lead preparation of a Timber Harvest Plan, if needed and requested. We also understand the unique nature of the botanical resources that occur within and surround the proposed project site and have therefore, also augmented our team’s expertise to include WRA botanists and plant ecologists who will provide technical review and recommendations specific to potential restoration techniques for the special status plant species (i.e., pygmy manzanita [Arctostaphylos nummularia ssp. mendocinoensis], Mendocino cypress [Hesperocyparis pygmaea], Bolander’s beach pine [Pinus contorta var. bolanderi]) and sensitive vegetation communities (i.e., Mendocino Cypress Woodland Alliance and Scope of Work
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Associations) known to occur on the project site. Rincon will develop, in coordination with WRA, measures to avoid, minimize, and/or mitigate impacts to the aforementioned botanical resources that are endemic to the North Coast. Furthermore, Rincon will address potential impacts to waters of the United States and State, riparian habitat, and/or fish passage for federally listed salmonids associated with one of more of the stream crossings and culvert replacements associated with the raw water line.
Project Management and Quality Assurance/Quality Control Rincon project managers and analysts are skilled at assisting agencies in not only meeting the legal requirements of the CEQA and NEPA processes, but also in ensuring a project is consistent with the City’s ordinances and codes and the relevant standards of other local and state agencies (e.g., California Department of Transportation, County of Mendocino, North Coast RWQCB, and the CDFW). Rincon’s project management team will drive the Project schedule through proactive leadership and initiative, alleviating the workload of City staff. In this way, Rincon will act as an extension of staff, with a strong focus on achieving the City’s goals for the Project.
At Rincon, we believe that project management and QA/QC is an integral part of a project’s success, and we employ a variety of standards of practice to provide clear, thorough, and effective management of tasks and schedules. Our project management team knows that close project tracking, early identification of issues, consistent QC, and effective client communication are essential. We take pride in our structured management of complex, multidisciplinary environmental review projects. The following techniques result in meeting project objects and outcomes of high quality:
• Technical Direction and Control. Our team operates in accordance with its rigorous QA/QC Manual, which establishes clear roles and responsibilities for each client, as well as protocols for the execution of each assignment, and protocols for internal/external communication. • Cost and Schedule Control. Rincon believes in finding creative solutions to maintain low budgets and completing work in the most efficient and cost effective way achievable. Rincon uses Deltek Ajera®, a project-based accounting system that controls all aspects of project management and accounting with realtime project information. • Project Reporting and Editorial Review. We work closely with clients for the duration of the project to ensure that progress is carefully tracked, attention is drawn to any difficulties encountered, and the project is conducted in a highly professional manner. We hold formal monthly status review meetings in which assigned staff meet with the Project Manager for a technical, schedule, and budgetary assessment of progress. This provides a continuing forum for mutual discussion and peer review of the quality of our work. • Problem Anticipation and Management. Rincon recognizes its obligation to anticipate, identify, and resolve all problems—technical, managerial and financial—as early as possible. Problems can most often be avoided by thoroughly planning the program; realistically budgeting time, labor and costs; clearly communicating with clients; and closely monitoring the actual performance of Rincon staff and subcontractors. Problems that do occur may be practical (e.g., conditions at field sites delay test operations) or conceptual and relate to steps in the technical approach. Many can be quickly solved by the involved staff members; otherwise, they are brought to the immediate attention of the Project Manager, who will decide the best resolution. • Ensuring Comprehensiveness and Legal Adequacy. At Rincon we take pride in offering our clients Principallevel staff involvement in all projects, with decades of experience in interpreting State CEQA Statute and Guidelines to help ensure that a client’s documents meet accepted standards for comprehensiveness and legal adequacy. We understand the importance of strict adherence to CEQA process and procedures including scoping, notification, filing/posting of documents, statutory timelines and content guidelines to avoid or withstand legal challenges on procedural grounds.
Environmental Impact Report Scope of Work
Based on the information provided by the City in the RFP, as well as our preliminary evaluation of the proposed project, an EIR appears to be the appropriate document under CEQA. Our detailed work program is provided below.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
30 Task 0 Project Management
Project Oversight
This task includes management and coordination through the duration of the project, including coordination with the City and internal project team, project oversight, budget and schedule management, and project accounting, including billing and accounts receivable efforts.
Project Meetings
Rincon’s EIR Project Manager will attend remote monthly or biweekly meetings (scheduled as needed) with City and Design Team staff during preparation of the EIR. This proposal assumes attendance at up to 20 meetings held via conference call, lasting an average of 60 minutes each. Rincon’s EIR Principal-in-Charge and technical staff will attend meetings as needed, for up to eight meetings each.
Rincon will provide meeting agendas at least 4 working days prior to scheduled meetings, including project schedule updates. Rincon will also provide meeting minutes within one week following each meeting.
Deliverables
• Meeting Agendas (Adobe PDF)
• Meeting Minutes (Adobe PDF)
Task 1 Project Initiation and CEQA Kickoff Meeting
In coordination with the Design Engineer, Rincon will facilitate a CEQA kickoff meeting with City staff. This meeting will serve as a forum to review and confirm study objectives and establish an operational protocol for the EIR process. The goals of the meeting will be to finalize the CEQA scope, discuss the project schedule, discuss the project design features and construction methods, and discuss areas of controversy.,. Rincon’s principal in charge will attend virtually, and Rincon’s project manager and lead biologist will attend the meeting in person, which is anticipated to last no more than 1 hour, with a site tour to follow.
Rincon will also prepare a data needs list for transmittal to the City and/or Design Engineer. Rincon will request existing information and studies applicable to the project site and will review the existing documents.
Deliverables
• Kickoff Meeting Agenda (Adobe PDF)
• Data Needs Request (Microsoft Word)
• Attendance (two Rincon staff members in person, one virtual) at the Kickoff Meeting Task 2 Notice of Preparation and Scoping Meeting
Notice of Preparation
Rincon will prepare a draft NOP for City staff to review. The NOP will include all required details, including project description, location, dates of public review and dates/location of the public scoping meeting. Rincon will submit a draft NOP in Microsoft Word for City review. Upon receipt of one round of consolidated comments on the draft NOP, Rincon will prepare a final PDF copy of the NOP for City staff to post on its website and for distribution to public agencies. Rincon will prepare an NOP distribution list for the City to review. It is assumed that the City will be responsible for any direct mailing of hard copies of the NOP. Rincon will review and make suggestions regarding the list. It is assumed that City staff will be responsible for filing the NOP with the State Clearinghouse/Office of Planning and Research (OPR) and Mendocino County Clerk.
The NOP and all correspondence received in response to the NOP will be attached as an Appendix to the Draft EIR. A finalized scope for the Draft EIR will be defined after all comments on the NOP have been received.
Because we anticipate that the EIR will address all issues on the environmental checklist, we do not propose to prepare an Initial Study.
Scope of Work
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Scoping Meeting
Rincon will facilitate a public and agency scoping meeting associated with the release of the NOP. The Scoping Meeting will be held during the 30-day NOP review period to introduce the community and responsible agencies to the EIR process and obtain input on the EIR scope of work. All agencies and interested parties would be invited to attend the scoping meeting, and it is assumed that separate individual meetings would not be required. It will include a brief presentation, followed by public comment and input from meeting attendees. Rincon will prepare a summary of all input gathered, which will be included in the Draft EIR along with any written public comments received during the NOP comment period. We assume that the City will organize the Scoping Meeting, including determining the time and location, and coordinating use of a virtual platform and/or physical venue. For the purposes of this scope, we have assumed the scoping meeting will be held in person, with virtual attendance as an option. Notice of the scoping meeting would be provided in the NOP.
Deliverables
• Draft and Final NOP (Microsoft Word and Adobe PDF)
• Draft and Final NOC (Adobe PDF)
• Scoping Meeting materials (e.g., agenda, presentation) • Attendance (one Rincon staff member) at an in-person Scoping Meeting Task 3 Project Description
Rincon will prepare the EIR project description. Organization of this information is critical, since it forms the basis for environmental evaluation under CEQA. The project description will rely upon project details provided by the City. This section will include a description of the project objectives and required permits and discretionary approvals. The project description will include a discussion of the project purpose, need, and objectives; project design characteristics; construction methods and maintenance activities; and any environmental protection measures incorporated into project design, construction, and operation. The project description will include textual, tabular, and up to four graphics to fully describe the project and form a basis for the environmental analysis. The project description will be submitted to the City in Microsoft Word format, and we will address one round of consolidated comments from the City. This scope assumes that project details will not change following City acceptance of the project description.
Deliverables
• Draft and Final Project Description (Microsoft Word)
Task 4 Technical Reports
Task 4.1 Community Forest Technical Report
Rincon understands it is important to the City that the creation of the community forest be included as part of the Project. The following tasks are included to prepare a comprehensive Community Forest Technical Report for the property.
Project Management and Kick Off Meeting
This task involves direct coordination between the consultant team and the City, as well as the public and committees over the course in developing the Community Forest Technical Report.
Rincon will collaborate with City staff to organize an initial kick-off meeting with the City’s Project Team and discuss overall project goals and objectives. The kick-off meeting will provide an opportunity to present the draft Work Plan and refine the scope of work and proposed schedule, as well as identify existing documents, existing policies, and key interested parties. Following this kick-off meeting, the Rincon Team will provide meeting minutes, an adjusted scope and schedule as well as a final list of existing applicable documents, data, and policies. As part of the project management duties under this task, Rincon will facilitate bi-weekly coordination calls and provide related meeting minutes.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
32 Baseline Assessment
The first step in creating a community forest is to gather information on the existing conditions of the site. The Vegetation and Special-Status Plants Assessment for Proposed Reservoirs report prepared by WRA (2023) and Biological Resources section of the EIR that will be prepared by Rincon under Task 6 will provide information for understanding sensitive biological resources that occur or may occur on the project site, such as special-status plants and wildlife, sensitive vegetation and forested communities (e.g., Mendocino Cypress Woodland and Redwood Forest Alliances), riparian and aquatic resources, and wildlife nursery sites and movement corridors.
The Biological Resources section of the EIR will also include a vegetation communities map that depicts and quantifies the distribution of vegetation and forested areas on the site as well as areas that have been previously disturbed. Blencowe Watershed Management will also assist with this task, including completion of field surveys evaluating the existing conditions on the site.
Other relevant technical studies that may be prepared for the project will also be reviewed to understand opportunities and constraints, such as, but not limited to, the hydrology report, Cultural Resources Technical Report Study (Task 4.3), and preliminary reservoir design. In addition, a field reconnaissance survey will be performed by a Certified Arborist and/or Registered Professional Forester to see first-hand the overall condition of the site to generally understand which areas of the property are most suitable for managing and maintaining a community forest and to effectively make recommendations, such as which existing access roads should be retained or improved, and which should be abandoned and restored as native forest and woodland. Additionally, the arboricultural evaluation will consider areas of the property where existing native woodlands and forests can be preserved, areas where degraded forests and woodlands may be enhanced through active restoration practices, and suitable areas for creating and/or reintroducing native forests and woodlands.
Community Outreach and Engagement
A key component of this task will be engaging the public through outreach and consensus building to ensure the Community Forest Technical Report provides recommendations that are rooted in an understanding of the City’s and community’s vision of the property. The Rincon team will present their findings of existing conditions and make recommendations on forest and woodland improvement areas, and evaluate any recommendations received from the public.
The primary goal of community outreach and engagement is to build consensus and vision from community stakeholders regarding a desirable, achievable, and sustainable community urban forest. First, Rincon will meet with the City to review any existing policies and programs related to managing a community forest, and to understand any budget limitations in establishing, managing, and maintaining a community forest in perpetuity.
Next, Rincon will support the City in hosting one community meeting that reaches appropriate community planning groups, residents, nonprofit organizations, businesses, academia, community leaders, and City staff to solicit unique ideas and create alignment with the purpose of the community forest.
Through our involvement in numerous natural resource planning programs, we understand the importance of engaging both responsible agencies and the community throughout the plan development and environmental review process. Our approach to community participation is one of transparency and inclusiveness. The development of the Community Forest Technical Report will require public feedback to consider what the community forest would/could include, to secure community support for concepts presented, and to provide a venue for the community to responsibly engage additional stakeholders who might not otherwise be aware of the efforts. For this project, Rincon will work diligently to actively engage with stakeholders and public officials to communicate information clearly. Our outreach process will be interactive and hands-on, and in direct contact with the City and public stakeholders to make sure the approach reflects the environmental and cultural best interests of the community forest.
Example groups that to consider may include, but are not limited to:
• Fire Department
• Active special interest groups within the City
• Stakeholder groups
• City Departments and Commissions, including Public Works, Planning, Parks and Recreation, and Health and Safety
• City Council
Scope of Work
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Following the community outreach meeting, Rincon will summarize findings regarding public opinion of components to consider when developing a community forest, such as, but not limited to access, forest management (including wildfire management), and natural/cultural resource preservation. We will provide a summary of the community engagement and outreach conducted as part of this scope of work.
Develop Work Plan
The Rincon Team will coordinate with the City in developing goals, objectives, and a work plan with defined milestones for implementing a community forest. This task will include an in-depth review of the project work scope, schedule, and budget with City staff and other key stakeholders to allow for work plan refinement. The information gathered for the work plan through collaboration with the City and stakeholders will identify specific tasks for establishing a community forest, such as, but not limited to: 1) creating a shared vision, 2) the need to maintain the benefits of the community forest, 3) community-specific challenges, 4) potential tree planting locations based on baseline conditions, 5) goals, objectives and actions, 6) implementation plan, and 7) monitoring plan.
Comprehensive goals and objectives for developing a community forest on the property will be developed through a collaborative process. Based on our current understanding of the proposed project, it is anticipated that goals and objectives will focus on establishing criteria for identifying existing areas where native forest and woodland can be preserved, enhanced, and created within the property, while managing and maintaining sensitive natural resources of the biological region. This will include, but not limited to, establishing specific goals and objectives to monitor and manage the community forest in perpetuity, identifying key stakeholders, establishing performance standards and success criteria for long-term maintenance and management, monitoring and reporting procedures, and adaptive management strategies.
Explore Opportunities and Constraints
The Community Forest Technical Report will identify potential opportunities and constraints and will describe effective, commonly accepted means of managing the restoration and preservation of the community forest. The report will include conservation objectives that include, at minimum, the following:
• Specific measures to reduce threats to the long-term management and preservation of the community forest, such as introduction of exotic species
• Procedures and personnel for maintaining the community forest • Monitoring procedures to document species richness, distribution, and overall health of forested areas that are preserved, enhanced, and restored
Recommendations
The Rincon team will develop recommendations for establishing a community forest based on the information gathered from the subtasks described above. Several strategies and techniques will be incorporated to maximize the use of limited City resources such as labor and equipment. We will assess the current staffing levels and supplies available and provide recommendations and justification for use of outside contract labor to allow the City to make decisions on a case-by-case basis. This task will incorporate information collected during field surveys and assessment of past and current efforts and practices to assist the City in developing a maintenance plan for the community forest.
Throughout the course of the project, we will work closely with the City staff while considering feedback from community engagement to gain a comprehensive understanding of the opportunities and challenges and solicit ideas from all invested parties to develop solutions and identify areas/issues for further study and evaluation.
Development of Long-range Strategic Framework
The Rincon team will develop a long-range framework (approximately 40 years) that identifies a set long-term goal through an iterative process that is informed by results of research, field surveys, evaluation and analysis, stakeholder outreach, and project scoping. The framework will provide a feasible and implementable roadmap for the City to utilize a plant palette that is both environmentally appropriate and represents the surrounding forested area. The framework will focus on implementation, including tree planting, establishment, preservation, and maintenance. Blencowe Watershed Management will also assist with this task.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
34 The framework will establish key performance indicators (KPI) that will help define successful implementation as well as to measure progress over time. Upon completion of the first draft, the document will be provided to City staff for review. The City will provide feedback and edits in one consolidated set and the Rincon team will draft a Public Review Draft that reflects edits in response to City comments.
We will provide a summary of all outreach efforts and reports conducted as part of this scope of work and provide a clear overview of the existing conditions, baseline report, implementation, and monitoring. Rincon will provide an electronic copy of the document, printing or providing hardcopy documents has not been included as part of this work scope.
Community Forest Technical Report
The Community Forst Technical Report will be prepared that meets the expectations of the City. The report will incorporate the results of research, evaluation and analysis, field reconnaissance surveys, stakeholder outreach, and project scoping. We will submit a draft report for review by the City during a study session and will coordinate publication of the draft document with the City and other project stakeholders as necessary. We anticipate and have budgeted for receipt of up to 10 substantive public comment letters and emails. Any additional comments above and beyond will be addressed on a time and materials basis in accordance with our standard fee schedule.
Rincon will incorporate comments from the City and submit a final Community Forst Technical Report for review.
The report will be a concise document that is easy to understand and feasible to implement that enables the City to preserve, enhance, and manage the community forest for the next 40 years.
Task 4.2 Timber Harvest Plan
Blencowe Watershed Management (BWM) will develop all necessary timber harvest permits for the Fort Bragg Reservoir Project. In partnership with the City, Mendocino Land Trust and relevant agencies, BWM will evaluate the need, feasibility and scoping for all CAL FIRE-approved harvesting documents which may include a Timber Harvest Plan (THP) and/or a Timberland Conversion Permit. Specific tasks include the development/drafting of the THP, including all required THP forms in accordance with CAL FIRE’s California Timber Regulation and Environmental Evaluation System (CalTREES), through the review and approval of the THP and all required harvesting permits. This task includes:
• All required field work including, but not limited to, flagging, watercourse and timber marking • 2 years of Northern Spotted Owl (NSO) surveys in accordance with Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls (USFWS 2012) (Note: These surveys and the finalization of the THP can be completed after certification of the EIR; Assumption: A Habitat Conservation Plan for NSO will not be required.)
• Submission of all information and data required by each state agency to secure an approved harvesting document
• Meetings with the City, Rincon, Mendocino Land Trust, and/or agencies to assist with development of the THP and associated harvesting permits
• Draft and final documents
Task 4.3 Cultural Resources Technical Study
Rincon understands the Fort Bragg Reservoirs Project will be constructed on approximately 30 acres of a 582- acre property intended to be developed as a community forest. The following cultural resources tasks are intended to support CEQA-compliant review of the reservoir project. These tasks also include desktop review of the remainder of the property to support early stages of planning for the community forest aspects of the project.
Records Searches
Rincon will conduct a California Historical Resources Information System records search of the 582-acre project site and a 0.5-mile radius at the Northwest Information Center (NWIC) located at Sonoma State University. The primary purpose of the records search is to identify previously recorded cultural resources known to exist within or near the project site. The records search will also reveal the nature and extent of any cultural resources work conducted in or near the project site. In addition to the resource records and reports, an examination will be Scope of Work
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made of historical maps, the National Register of Historic Places, California Register of Historical Resources, the Built Environment Resources Directory, the Archaeological Determinations of Eligibility list, and the listing of California Historical Landmarks. Rincon assumes direct expenses associated with the records search will not exceed $1,000. Record search requests at NWIC are typically fulfilled in 4 to 6 weeks. Rincon assumes the information center will complete the records search using internal staff and that no recorded cultural resources will be identified within or adjacent to the project footprint. The records search results will be communicated to the City so they may be used to inform project design.
Additionally, Rincon will contact the Native American Heritage Commission (NAHC) to request a Sacred Lands File (SLF) search. The SLF search will indicate whether recorded Sacred Lands are present near the project site.
Rincon assumes the results of the SLF search will be negative.
Cultural Resources Survey
Upon completion of the records search and determination of the project footprint by the design team, Rincon will conduct a pedestrian survey of the area proposed for the development of the reservoir and associated infrastructure. Rincon assumes the area to be surveyed will not exceed 40 acres. Rincon cultural resources specialists will conduct a pedestrian survey using transects spaced at maximum intervals of 15 meters over all exposed ground surface within the project site. Transect accuracy will be maintained through the use of a handheld global positioning system (GPS) unit. For the purposes of this scope of work, Rincon assumes the survey will be negative for cultural resources. Should any cultural resources be identified during the survey, a scope and budget augmentation will be submitted for formal recordation or record updating on State of California Department of Parks and Recreation Series 523 forms. No testing or evaluation will be conducted, nor will any artifacts, samples, or specimens be collected during the survey. Rincon assumes that the survey will require 2 field days to complete by two cultural resources specialists, including travel time, and there will be no access issues. A single mobilization will be needed to complete the fieldwork. Results of field surveys that have schedule or budget ramifications will be communicated to City staff in a timely manner. Rincon assumes survey of the full 582-acre project site will not be required for compliance with CEQA. Rincon is available to complete surveys for the full 582-acre property at additional scope and cost upon request from the City.
Cultural Resources Technical Report
Rincon will prepare a CEQA-compliant cultural resources technical report that will present findings, recommendations, and impact assessments for the reservoir project. The report will follow the California Office of Historic Preservation’s Archaeological Resource Management Reports: Recommended Contents and Format and will provide applicable environmental and cultural contexts for the project site and vicinity, outline the regulatory framework within which impacts to cultural resources will be analyzed, present the methods and results of the California Historical Resources Information System records search, archival research, and field survey. The report findings will include recommendations for additional work or mitigation measures, if any are deemed necessary.
Additionally, the report will provide an assessment of the cultural resources’ sensitivity of the full 582-acre property in consideration of the community forest aspects of the project. The sensitivity assessment will include an overview of previously recorded cultural resources, historical aerial imagery, and geological data. The sensitivity assessment will be used to inform the Community Forest Technical Report.
Draft copies of the report will be submitted to the City for review and approval within three weeks of the end of field activities. Rincon assumes one round of comments from the City. All deliverables will be provided in electronic format (PDF and/or Word). A copy of the final report will be filed with the NWIC.
Due to the sensitive nature of archaeological resource information, cultural resources reports are typically considered confidential. Rincon assumes the technical report will be considered confidential and will not be suitable for public review. Should a public review draft be deemed necessary, Rincon will submit a scope augmentation to produce a nonconfidential version of the technical report.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
36 Task 4.4 Vehicle Miles Traveled (VMT) Assessment
Fehr & Peers understands that the proposed project involves the construction of three 45-acre-foot reservoirs and the initial stages of the development of the community forest. These uses are not anticipated to generate substantial additional trips to the roadway system after construction; as such, the project will very likely screen out of a VMT analysis and the VMT impact will be able to be presumed to be less than significant. Construction impacts, however, will need to be qualitatively identified.
Site Plan Review
The proposed site plan will be reviewed to evaluate multimodal site access and on-site circulation. Specifically, Fehr & Peers will review the project site plan in terms of:
• Site access and interface with public roadway network including adequacy of turn-pocket lengths, driveway throat lengths, sight distance and operations
• Emergency vehicle access and circulation
• Vehicular circulation within the site
• Pedestrian access and circulation within and adjacent to the site • Bicycle access and circulation within and adjacent to the site Fehr & Peers will also assess the project’s impacts with respect to the three following elements:
• Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities
• Substantially increase hazards due to a geometric design feature (e.g. sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) • Result in inadequate emergency access
Trip Generation, Distribution, and Assignment Analysis
Project scenario traffic volumes will be based on updated trip generation calculations developed using the ITE Trip Generation Manual, 11th Edition (or site-specific data) and the Mendocino County travel demand model, incorporating adjustments to reflect the proposed project’s land use type and parking accommodations. The estimated project trips will be distributed through the roadway system and assigned to roadways at the link-level.
CEQA Vehicle Miles Traveled Analysis Screening
The City of Fort Bragg has not formally adopted guidance on VMT analysis methodology, VMT-based CEQA Transportation metrics, or significance thresholds for visitor-use CEQA impact assessment. Fehr & Peers proposes using the guidance provided in the 2018 OPR Technical Advisory on Evaluating Transportation Impacts in CEQA to complete a VMT screening analysis.
Qualitative Construction Phase Review
Fehr & Peers will complete a qualitative review of the transportation conditions during the construction phase of the project. This qualitative review will consider the truck and worker trips generated by the project (presumed to be provided by others) and the potential routes of travel to/from the project site and State Route 20. As part of this review, recommendations will be developed to enhance multimodal circulation and safety.
Technical Memorandum
Fehr & Peers will complete a draft of a technical memorandum, which will summarize the data and work performed above. The draft of the memorandum will be submitted to City staff and the project team for one round of consolidated review and comment. We will respond to one round of comments (up to 4 hours of staff time) and prepare a final memorandum.
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Optional Task 4.5 Construction Health Risk Assessment
Potential exposure to substantial concentrations of toxic air contaminants could arise from the construction of the proposed project. Due to the location of sensitive receptors within 1,000 feet of the project site, there is a potential for health risk impacts from construction activities. A refined health risk assessment (HRA) will be performed in accordance with the latest Office of Environmental Health Hazard Assessment (OEHHA) OEHHA Guidance. The analysis will incorporate the estimated construction emissions and dispersion modeling using the USEPA AMS/EPA Regulatory Model (AERMOD) model with meteorological data from the closest meteorological monitoring station. AERMOD dispersion model outputs will be converted into specific cancer risks and noncancer chronic health hazard impacts in accordance with OEHHA Guidance. The results of the HRA will be incorporated into the Air Quality EIR section.
Optional Task 4.6 Section 106 Cultural Resources Study
Rincon understands the City may seek federal funding for construction of the reservoir which would trigger compliance with Section 106 of the NHPA (Section 106). To support compliance with Section 106, Rincon will initiate outreach with Native American contacts and local historical groups and will prepare a Section 106- compliant technical report.
Upon request of the City, Rincon will prepare and mail a letter to each of the NAHC-listed contacts on agency letterhead to see if they are aware of any Native American cultural resources within or immediately adjacent to the Area of Potential Effects. Rincon will allow 2 weeks for review, then follow-up with each contact by telephone.
As many as two telephone calls will be made to each of the contacts to document “good-faith” efforts to followup. A table documenting these efforts will be created and attached to the report in an appendix alongside an example email(s) and all replies. Please note, this outreach does not constitute formal Section 106 consultation which must be performed between the lead federal agency and local federally recognized tribes.
Additionally, in coordination with lead federal agency and as required by 36 Code of Federal Regulations Park 800.4(a)(3), Rincon will contact individuals and organizations who may have knowledge of, or concerns with, historic period cultural resources in the area. Outreach will include inquiries to applicable local governments and local historic groups regarding their knowledge of historic period cultural resources in the immediate vicinity of the Area of Potential Effects. As many as two telephone calls will be made to each of the groups to document “good-faith” efforts to follow-up. A table documenting these efforts will be created and attached to the report in an appendix alongside an example letter and all replies.
Using the results of the records searches and survey completed under the above tasks, Rincon will prepare a cultural resources technical report compliant with Section 106 of the NHPA (Section 106). Rincon assumes the preparation of a Finding of Effect or agreement document will not be required and that the lead federal agency will not require assistance with consultation with the State Historic Preservation Office. Draft copies of the report will be submitted to the City for review and approval within 3 weeks of the end of field activities. Rincon assumes one round of comments from the City and one round from the lead federal agency. All deliverables will be provided in electronic format (PDF and/or Word).
Optional Task 4.7 Federal Clean Air Act Conformity Analysis The federal Clean Air Act (CAA) Conformity Analysis will be prepared to determine whether the project would exceed de minimis levels, as required for projects pursuing federal funding.
Mendocino County meets air quality standards for all pollutants except the state standard for particulate matter measuring 10 microns or less in diameter (PM10). The CAA Conformity Analysis will be prepared to quantify air pollutant emissions associated with the proposed project. The CAA Conformity Analysis will include a summary of existing ambient air quality data from the nearest monitoring station to the project site as well as a summary of the federal attainment status of Mendocino County. The analysis will include both temporary construction and long-term operational emissions estimates for the project, which will be quantified using industry standard models and emissions factors during preparation of the Administrative Draft EIR (Task 6). The CAA Conformity Analysis will be presented in a stand-alone memorandum.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
38 Optional Task 4.8 Climate Change Worksheet
Rincon will fill out the climate change worksheet that identifies the climate change hazards that may impact the project area. Climate change hazards will be identified based on the following reports and state tools:
• Mendocino County Fire Vulnerability Assessment (2020) • California Coastal Commission Sea Level Rise Vulnerability Synthesis (2016) • Mendocino County Local Hazard Mitigation Plan (2020)
• Climate Change Assessment, North Coast Regional Report (2018) • Cal-Adapt
Potential impacts to the proposed project and adaptation strategies will be identified in consultation with City staff and the design team and will be consistent with best practices and state and regional guidance documents available at the time, including the most recently adopted iteration of the California Coastal Commission’s Sea Level Rise Policy Guidance. Mitigation measures that would result in reductions in GHG emissions will also be identified.
Rincon will prepare the climate change worksheet, including the three required attachments that describe climate change vulnerabilities and proposed adaptation and mitigation measures. The attachments will be brief, qualitative, and based on readily available information. The worksheet will be prepared pursuant to the application requirements for funding.
Deliverables
• Draft and Final Technical Studies (Microsoft Word and Adobe PDF) Task 5 Assembly Bill 52 Consultation Assistance
Under AB 52 (California Government Code Section 21080.3.1 (a)), the City, as the CEQA lead agency, is required to begin consultation with California Native American Tribes that are traditionally and culturally affiliated with the project site prior to the release of a negative declaration, mitigated negative declaration, or environmental impact report. If the City does not maintain an AB 52 contact list but still wishes to conduct consultation, Rincon will use the contact list provided by the NAHC with the SLF search conducted under Task 4.3. Rincon will assist the City with consultation under AB 52 by providing the City with letter templates, checklists, and detailed instructions to ensure meaningful consultation with interested Native American groups can be completed in accordance with AB 52. After receipt of letters, Native American Tribes have 30 days to reply to a request for consultation under AB 52. This task does not include meetings, outreach, consultation, or Rincon mailing letters to Tribal governments. Rincon assumes the City will officially contact all applicable Tribes.
Deliverables
• AB 52 consultation assistance package (Microsoft Word and Adobe PDF) Task 6 Administrative Draft EIR
Rincon will prepare an Administrative Draft EIR (ADEIR) in compliance with CEQA requirements and based on the project description approved by City staff (completed under Task 3). Consistent with CEQA requirements, the EIR will be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of the project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible.
The ADEIR will comprise the following sections.
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Executive Summary
The EIR will contain a summary of the project and associated environmental consequences. This section will include the following:
• A discussion of the project objectives
• A brief description of the proposed development on the project site, including the proposed reservoirs and community forest
• A summary of the environmental setting for the project site • A summary of impacts
• A summary of mitigation measures (mitigating policies) • A discussion of alternatives considered, and identification of the environmentally superior alternative among those studied
• Areas of controversy, and issues remaining to be resolved Introduction and Environmental Setting
These required introductory sections will lay the groundwork for and summarize the substantive analysis to follow. The Introduction will describe the purpose and legal authority of the EIR, the scope and content of the EIR, a discussion of lead, responsible, and trustee agencies, and a synopsis of the EIR process. The Environmental Setting will provide a general description of the existing geographic character of the project site.
The Environmental Setting will also contain a discussion of the approach to the cumulative impact analysis.
Project Description
The Project Description section will consist of the project description prepared in Task 3.
Analysis, Impacts, and Mitigation Measures
Each environmental discussion will include the following:
• Setting
• Impact analysis
• Mitigation measures
• Level of significance after mitigation
The discussion for each issue area will begin with the setting, which will describe existing conditions relevant to the topic and provide the groundwork for impact analysis. Sources will include documents and studies prepared in support of the project (including City-provided studies and studies completed under Task 4), relevant environmental documents prepared during the last five years, and data provided by the City.
The impact analysis will include a discussion of the methodology used to quantify or determine impacts and the criteria for judging significance. Where practicable, impacts will be quantified. If existing data does not allow definitive quantification, reasonable assumptions will be used to qualitatively forecast potential impacts. Rincon typically orients analyses around clear impact statements that are separately highlighted in the text. This allows a more precise statement of the specific issue at hand and sets the stage for the technical discussion that follows. If the impact warrants mitigation measures, they are indexed to and immediately follow the numbered impact in question.
Rincon’s technical approach to analyzing each environmental issue is described below under, Proposed Approach to Technical Issues.
Optional Task – Federal Cross-Cutters Analysis
If the City applies for federal funding administered through the SWRCB Clean Water State Revolving Fund program. Therefore, to assist in compliance with federal environmental requirements for the funding program, the EIR will include a Federal Cross-Cutters Analysis and documentation related to federal regulations beyond City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
40 that typically required under CEQA. This EIR section will discuss consistency of the proposed project with the relevant federal regulatory framework as well as an environmental justice analysis.
Alternatives Analysis
A range of alternatives will be considered in the ADEIR, including the CEQA-required No Project Alternative and up to two other build alternatives that would feasibly attain most of the basic project objectives but would avoid or substantially lessen any significant effects identified. It is assumed that buildout assumptions for each alternative will either be provided or approved by the City. Evaluation of alternatives will be in less detail than for the project, though the analysis will provide decision-makers and the public adequate information to decide between alternatives. This section will also identify the “environmentally superior alternative.” If the No Project Alternative is determined to be environmentally superior, the ADEIR will identify the environmentally superior alternative among the remaining scenarios.
Cumulative Impacts
Consistent with Section 15130 of the State CEQA Guidelines, cumulative impacts will be disclosed. These impacts would result from buildout of the project combined with impacts of other projects in the area. Cumulative projections in the area will be derived in consultation with the City. We propose to provide a summary of projections to inform the cumulative analysis.
Other CEQA Sections
This portion of the EIR will discuss the growth-inducing effects of the project as well as significant irreversible changes associated with potential buildout. Drawing on the information provided in the Environmental Setting and preceding issue discussion, the growth-inducing impacts will address the potential for the project to directly and indirectly induce growth and remove obstacles to growth in the area. The significant irreversible changes discussion will summarize the significant effects of the project, particularly the unavoidably significant effects.
References
This portion of the EIR will provide full citations for all in-text citations provided within the EIR. This section will identify all supporting documents that were used during preparation of the EIR which are not included as appendices to the EIR itself.
The ADEIR will be submitted to the City in Microsoft Word format, for ease of review.
Proposed Approach to Technical Issues
The technical approach to analyzing each potential environmental issue is described herein. Approaches to the impact analysis for the EIR will be discussed with City staff and will be consistent with the assumptions and methodologies used in recent CEQA documents in the City of Fort Bragg to the extent possible.
While all issue areas contained on the State CEQA Guidelines Appendix G Checklist will be addressed in the EIR, based on a preliminary analysis of scenic resources and the visibility of the project site, energy usage, listed hazardous materials sites, land use plans, mineral resource zones, and population growth, we anticipate the following issue areas would likely be considered less than significant and therefore suggest that these issue areas be analyzed within a “Less than Significant” section of the EIR:
• Aesthetics
• Energy
• Hazards and Hazardous Materials
• Land Use and Planning
• Mineral Resources
• Population and Housing
• Public Services
• Recreation
• Utilities and Service Systems
• Wildfire
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We anticipate that the following environmental issues will be addressed in the EIR as standalone EIR sections:
• Agriculture and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Geology and Soils
• Greenhouse Gas Emissions
• Hydrology and Water Quality
• Noise
• Transportation
• Tribal Cultural Resources
Agriculture and Forestry Resources
Although the project site does not contain any Important Farmland or Williamson Act parcels, a portion of the project site is designated as a Timberland Production Zone. The analysis will discuss the potential impacts of project implementation on timberland, including the conversion of timberland to a non-timberland use. The Agricultural and Forestry Resources chapter of the EIR will include an evaluation of potential project impacts to existing agricultural lands, forest land, and timberland near the project site. The analysis in this section will focus on potential conflicts between proposed development and other adjacent forest and timberland uses. This section will include mitigation measures to reduce impacts, if applicable.
Air Quality
Rincon will prepare an air quality analysis consistent with methodologies and significant thresholds for the Mendocino County Air Quality Management District (MCAQMD). The California Emissions Estimator Model (CalEEMod) will be used to estimate regional emissions from project construction and operation. The technical analysis will address the project’s conformance with applicable air quality management plans and whether the project would result in emissions of criteria pollutants that violate any air quality standard or contribute substantially to an existing or projected air quality violation.
A qualitative assessment of localized risk from the construction activities is proposed. However, depending on the length of construction, the amount of haul trips required, and the quantity and type of construction equipment (for example USEPA Tier 4 and/or alternatively fueled equipment) used, a quantitative HRA may be recommended. The OEHHA Guidelines for HRAs suggest that projects with construction periods of more than 2 to 6 months and within 1,000 feet of sensitive receptors, require a significant amount of excavation or grading, and/or those project sites that are greater than 1 acre have the potential to result in significant cancer risk. The proposed reservoir project area is approximately 30 acres and, depending on the reservoir locations, may be located adjacent to existing sensitive receptors. If the project design does not require construction equipment greater than 50 horsepower to meet USEPA Tier 4 certification or emissions standards, California Air Resources Board (CARB) Level 3 diesel particulate filters, or alternatively fueled (non-diesel) equipment, then a quantitative HRA is recommended for determining toxic air contaminants impacts to nearby sensitive receptors (see Optional Task 4.5).
Biological Resources
Rincon will prepare a Biological Resources section based on the biological resources technical studies described above; namely, the report prepared by WRA (2023). This section will address potential impacts to special-status species, sensitive habitats, riparian and wetland features, and conflicts with local policies and protection plans.
As part of the biological resources analysis, Rincon will collect regional background information on biological resources that could be affected by the project. The collected information will include database queries (e.g., CDFW CNDDB, California Native Plant Society Rare Plant Inventory, USFWS Information for Planning and Consultation), reviews of regional planning documents, and information provided by agency biologists. The scope of work includes a reconnaissance-level site visit to further establish baseline conditions.
The biological setting subsection will describe vegetation communities and land cover types, streams and wetlands, special-status species occurrences, and sensitive habitat types. The impact analysis will include a description of methodology and significance thresholds, project impacts and avoidance, minimization, and mitigation measures for biological resources. Rincon will compile results from database queries in the Appendix of the EIR and summarize the results, findings, and recommendations within the EIR section.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
42 Cultural Resources
Rincon will prepare a Cultural Resources section based on the cultural resources technical study described above. This section will address potential impacts to historical resources, archaeological resources, and human remains.
Geology and Soils
This section will discuss the potential for geologic hazards present within the project site to adversely affect workers and visitors to the project site. Hazards to be considered include fault rupture, ground shaking, landslides, liquefaction/slope stability, erosion, and subsidence. The analysis will rely on the California Geological Survey, United States Geological Survey, the California Division of Mines and Geology, and other CEQA documents that contain geology and soil information for the area. This section will also address paleontological resources, including a discussion of the results of a geologic map and literature review, a discussion of the regional geology and the geologic unit(s) present within the project site, characterization of the paleontological sensitivity of the geologic unit(s) present within the project site using the Society of Vertebrate Paleontology paleontological sensitivity classification system, and an assessment of the potential for significant impacts to scientifically important paleontological resources under municipal state guidelines.
It is anticipated that the geology/soils work scope will entail a mapping exercise to identify areas where potential future development could be affected by known geologic hazards. Specific mitigation measures will be provided as needed.
Greenhouse Gas Emissions
Rincon will prepare a GHG analysis consistent with the methodologies and significance thresholds outlined by the MCAQMD, which recommends that projects use the GHG thresholds of the Bay Area Air Quality Management District. CalEEMod will be used to estimate GHG emissions from project construction for informational purposes.
The analysis will consider the project’s consistency with applicable GHG regulations, plans, and policies, such as the 2022 Scoping Plan.
Hydrology and Water Quality
The hydrology and water quality analysis will evaluate potential impacts relating to hydrological conditions and flooding, as well as potential impacts to surface and groundwater quality. The existing hydrologic setting of the project site will be described generally and potential impacts relating to the proposed development will be described. Information sources will include readily available data from the RWQCB and recent CEQA documents. analysis will be qualitative in nature, relying on existing regulations (in particular, the National Pollutant Discharge Elimination System and related City requirements) to address potential impacts. This section will also address impacts related to flooding and inundation of the project site.
Noise
Rincon will prepare a noise and vibration analysis consistent with applicable standards. The project would generate intensive construction activity in a rural residential area; therefore, extensive noise site measurements and 3D noise modeling is proposed. Rincon will conduct up to six short-term (15-minute) and three long-term (24-hour) ambient sound level measurements on the project site to characterize ambient noise levels.
Construction noise levels for the project will be analyzed using the SoundPLAN noise model, based on equipment types and operations provided by the City. Vibration levels will be calculated in terms of peak particle velocity for structural evaluations. If significant impacts are identified, appropriate mitigation measures will be identified (e.g., necessary barrier heights or other mitigation options to reduce noise levels to applicable standards).
Transportation
This section of the EIR will rely on a transportation study prepared by Fehr & Peers. This will include a VMT analysis; assessment of geometric design hazards; and assessment of inadequate emergency access. Fehr & Peers’s specific proposed scope of work is provided as Task 4.4. This report will be incorporated into the transportation section of the EIR.
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Tribal Cultural Resources
The area, including the city and nearby coastline, is considered sensitive for tribal cultural resources by the Pomo.
This section will summarize the results of AB 52 consultation (Task 5). Rincon will summarize AB 52 efforts and include identified mitigation in the EIR, as applicable. Mitigation measures will be included, if warranted, based on the results of consultation.
Utilities and Service Systems
This section will discuss potential impacts to water supply and service systems, wastewater conveyance and treatment systems, wastewater and solid waste generation, and solid waste collection and disposal systems.
Water and wastewater services are provided by the City of Fort Bragg, and solid waste services are provided by C&S Waste Solutions. Impacts to the storm drain system will be addressed in the hydrology and water quality section. Rincon will document the existing water supply conditions based upon review of published data. In addition, impacts relating to wastewater and solid waste generation will be discussed. Project-specific mitigation will be identified as needed.
Deliverables
• ADEIR (Microsoft Word)
Task 7 Screen Check Draft EIR
Rincon will address one round of City comments on the ADEIR and prepare a Screen Check Draft EIR. It is assumed that all comments from the City, including City’s legal counsel, will be provided as a consolidated set of comments in editable electronic format (i.e., as tracked changes in Microsoft Word). City staff will be responsible for reconciling conflicting comments prior to being sent to Rincon. For the purpose of cost estimating, it is assumed that addressing City and legal comments on the ADEIR will require no more than 60 professional staff hours, including meeting and coordination regarding the approach to addressing comments. If additional effort is needed, a scope amendment may be required. The Screen Check Draft EIR will be submitted to the City in Microsoft Word with track changes retained.
Deliverables
• Screen Check Draft EIR (Microsoft Word with track changes retained) Task 8 Public Draft EIR
Once the City approves the Screen Check Draft EIR, Rincon will prepare the Draft EIR for public circulation. To maintain momentum in the project schedule and provide cost efficiency, we assume City comments will be minimal at this stage and will focus on any new content in the Screen Check Draft EIR (i.e., track changes).
Rincon will prepare required noticing forms, including the Notice of Completion (NOC), Notice of Availability (NOA), and OPR’s Summary Form for Electronic Document Submittal, for City review. Rincon will address one round of comments on the forms. It is assumed that City staff will be responsible for filing the NOP with the State Clearinghouse/OPR and Mendocino County Clerk. It is assumed the City will be responsible for required newspaper ads and other public noticing of the document’s availability, such as radius label mailing or on-site posting. As required by State law, the Public Draft EIR will require at least a 45-day public review period. Rincon will provide two hard copies of the Public Draft EIR for posting at the City offices and Fort Bragg Library and will provide a digital version in Adobe PDF for posting to the City’s website. Accessibility remediation of the Draft EIR is not included in this scope of work but can be completed upon request for an additional fee.
Rincon staff will also be available to attend a public hearing during the Draft EIR comment period. Attendance at this hearing is described under Task 14.
Deliverables
• Public Draft EIR (two hard copies, one Adobe PDF copy with user-friendly cross-reference hyperlinks) • Draft and Final CEQA Notices, including the NOC, NOA, and OPR’s Summary Form (Microsoft Word and/or Adobe PDF)
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
44 Task 9 Response to Comments and Administrative Final EIR Upon receipt of public comments on the Draft EIR, Rincon will prepare a draft response to comments and an Administrative Final EIR for review by the City. This scope of work assumes up to 10 comment letters containing comments on the content of the CEQA document will be received, including three lengthy (over five pages) and/or substantive letters, all of which can be adequately responded to in a maximum of 90 professional staff hours.
Comment letters that solely express support or opposition to the project would not count against the 10-letter estimate. The actual level of effort required to respond will depend on the length, detail, and sophistication of the comments, in addition to the number of letters received. We reserve the right to reevaluate the effort level and request a scope amendment upon the closing of the public comment period. If the number of comment letters and the effort to prepare responses is greater than anticipated, Rincon will notify City staff immediately and discuss options to amend our scope of work and budget as necessary.
Rincon will address one round of consolidated City and legal comments, to be provided in editable format, on the draft Responses to Comments and prepare a Screen Check Responses to Comments, in Microsoft Word with edits shown in track changes. Upon City review and approval of the Screen Check, Rincon will submit the Final EIR for hearing in Adobe PDF format.
Deliverables
• Draft and Final Response to Comments (Microsoft Word and Adobe PDF) Task 10 Mitigation Monitoring and Reporting Program
Concurrent with Task 9, Rincon will prepare a Mitigation Monitoring and Reporting Plan (MMRP), which will be bound separately from the Final EIR. The MMRP will be provided in a format designed for use by planners, environmental monitors, or code enforcement officers. Essentially, this plan will take the form of a detailed table that describes:
• Persons/agencies responsible for monitoring compliance with each condition • Timing when monitoring must occur
• Frequency of monitoring
• Criteria to be used to determine compliance with conditions The final version of the MMRP will be incorporated as an appendix to the Final EIR.
Deliverables
• Draft and Final MMRP (Microsoft Word and Adobe PDF)
Task 11 Final EIR
After receipt of City comments on the Administrative Final EIR (Task 9) and MMRP (Task 10), Rincon will prepare a Screen Check Final EIR for City staff review and confirmation followed by a Final EIR after incorporating comments from City staff. Rincon will prepare a draft Notice of Determination (NOD) for City approval. It is assumed that City staff will file with the County Clerk and State Clearinghouse within 5 working days of project approval. It is assumed that the City will pay all applicable fees associated with filing the NOD at the County Clerk, including payment of the CDFW CEQA filing fee.
Deliverables
• Screen Check Final EIR (Microsoft Word with track changes retained) • Final Program EIR (Adobe PDF copy with user-friendly cross-reference hyperlinks) • NOD (Adobe PDF)
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Task 12 CEQA Findings, Statement of Overriding Considerations, and Resolution Rincon will prepare the CEQA Findings and Statement of Overriding Considerations (if a significant and unavoidable impact is identified) for the project based on the impact conclusions of the EIR, based on a template provided by the City. The Draft CEQA Findings will be submitted alongside the Final EIR, and will contain a discussion of alternatives, including the rationale for rejecting any of the analyzed alternatives, using in part the project objectives. This scope of work assumes if alternatives are determined to be infeasible due to financial considerations, or that the Statement of Overriding Considerations relies on specific economic or financial factors, any available corresponding financial data to support these conclusions will be provided by the City. This task will comply with State CEQA Guidelines Sections 15091 and 15093 and will be submitted in a City-approved electronic format. Rincon will prepare an administrative draft version of the CEQA Findings for City and legal review, will address one round of consolidated comments, and submit a final document version digitally.
Rincon will also prepare the draft CEQA Resolution for City and legal review and comment. The CEQA Resolution will be prepared in accordance with the City’s required format. The CEQA Resolution will incorporate the CEQA Findings and, if applicable, the Statement of Overriding Considerations. Rincon will address one round of consolidated comments and submit a final document version digitally.
Deliverables
• Draft and Final CEQA Findings and Statement of Overriding Considerations (Microsoft Word and Adobe PDF)
Task 13 Administrative Record
Rincon will maintain the Administrative Record for this project. Maintenance of an accurate and comprehensive Administrative Record is important for the defensibility of the EIR, should it be challenged. Rincon will develop a work plan at the outset that instructs internal staff on the way in which the Administrative Record will be developed and maintained. As sources are referenced in each section of the report, they are logged in an index containing a hyper-linked cross-reference to the individual source files, copies of which are maintained on company servers. These include, for example, guidance documents, websites, correspondence, and technical memoranda. The index and source files will be supplied digitally alongside the Final EIR.
Deliverables
• Administrative Record (Adobe PDF)
Task 14 Public Hearings (Three)
This task provides a budgeted allowance for the Rincon team to assist staff in preparing for and attending public hearings for the EIR. If desired, Rincon can prepare presentation materials and assist City staff with the EIR portion of presentations. For purposes of this proposal, we have assumed that Rincon’s Principal-in-Charge will attend up to two hearings virtually, and Rincon’s Project Manager will attend up to two hearings in person.
In addition, we have assumed that the City will coordinate a third public hearing during the public comment period on the Draft EIR. Rincon’s Project Manager will attend this hearing virtually.
Deliverables
• Draft and Final presentation materials (Microsoft PowerPoint) • Attendance at three hearings (two in-person hearings and one virtually hearing with up to two Rincon staff members in attendance)
Optional Task 15 Legal Review
Rincon has on staff a qualified legal team with more than 45 years combined experience in land use, long-range planning, CEQA review, and CEQA litigation. Such experience allows Rincon to provide trusted, substantive review of key documents, including the Public Draft EIR and Final EIR, to provide legal adequacy and a sound basis for a defense during legal challenge. Rincon’s legal team also provides strong support for responding to comments City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
46 on the environmental and land use documents and in addressing identified concerns raised in late correspondence prior to the public hearings.
With careful consideration as to how each step of the process may ultimately affect the outcome and impact on the community perception, Rincon can provide thoughtful analysis on the best approach to take for any unique or potentially controversial issue, with the legal team participating on an as needed basis for planning calls and internal discussion and review. This scope includes legal review of the Draft EIR and Final EIR, to be conducted prior to City review of the Administrative Draft version of the documents.
A total of 20 staff hours is included in this task for legal review. Additional legal review can be provided on a time-and-materials basis to provide a more thorough review of specific topic areas as requested by the City.
Deliverables
• Legal review of the Administrative Draft EIR and Administrative Final EIR, prior to draft submittals to the City
Optional Task 16 Fish Passage Assessment – Raw Water Line Replacement Rincon will coordinate with the Engineering Design team to ensure that construction and development of culverts prevent or minimize impacts to hydraulic conditions and effects to aquatic habitats that can block fish from migrating to upstream habitats. We will describe general culvert design and criteria for the identification of conceptual-level passage components that would provide upstream and downstream volitional passage for California Coastal Chinook salmon (Oncorhynchus tshawytscha), Northern California steelhead (Oncorhynchus mykiss), and California Coast coho salmon. The description will be used to support the culvert replacements for Segment 2 of the Raw Water Line Replacement Project as part of the feasibility of fish passage assessment.
Deliverables
• Draft and final descriptions of general culvert design and criteria • Attendance at up to three 1-hour meetings with the design engineers • Attendance at up to three 1-hour meetings with agency staff Optional Task 17 Permitting Assistance – Raw Water Line Replacement Rincon is available to provide permitting support and assistance, once the necessary permits are identified. Our approach to securing permits and/or authorizations from the regulatory/resource agencies includes early engagement with the City and/or project engineering team to develop a permitting strategy and then confirm this approach and associated requirements with the respective agencies.
We assume one or more of the stream crossings associated with Segment 2 of the Raw Water Line Replacement Project (i.e., the culvert replacements) will require permits from the USACE, RWQCB, and CDFW as well as a supporting Aquatic Resources Delineation or Jurisdictional Delineation report. To comply with the federal Endangered Species Act and potential Section 7 consultation between the USACE and NMFS, Rincon would incorporate the results of Task 16, Fish Passage Assessment, into the permitting strategy and, if necessary, a Biological Assessment. Depending on the design for each culvert, impacts to wetlands and/or riparian habitat may occur and therefore, would require preparation of a Habitat Mitigation and Monitoring Plan. Rincon has routinely conducted effects analyses for federally listed species and prepared mitigation plans and would do so, as needed, on behalf of the City.
Assumptions
This scope of work incorporates the following assumptions:
• Site plans will be provided in portable document format (PDF) or AutoCAD (DWG or DXF) format. • The City or Design Consultant will provide the requested information including construction methods, equipment and timing, and export and import of soils and materials.
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Rincon Consultants, Inc. 47
• All data needs are reviewed and approved prior to modeling. Any major changes to the modeling inputs after beginning modeling may necessitate remodeling which will be charged on a time and materials basis. • The City or Design Consultant will provide estimates of daily worker, vendor, and haul truck trips during project construction.
• It is assumed that rock blasting will not be needed during construction. • Project management will be required over a 20-month period, starting at Notice to Proceed. • Rincon’s project manager will attend monthly project status meetings for the duration of the contract, assumed to be 20 months. Status meetings will be virtual and will not exceed 1 hour in length with no more than 30 minutes of time for meeting preparation and writing/circulating notes from the status meeting. • The City will be responsible for payment of newspaper filing fees. • The City will be responsible for filing all CEQA notices, including the NOP, NOA, and NOD, with the Mendocino County Clerk and the State Clearinghouse and for payment of all filing fees, including the CDFW filing fee. • Once approved by the City, the EIR project description will be stable for the duration of the work scope. • Rincon will prepare the AB 52 letters, and the City will send them. • All comments from the City will be provided as a consolidated set of comments in editable electronic format (i.e., as tracked changes in Microsoft Word). All comments will clearly indicate the requested changes. If there are multiple reviewers, the City will be responsible for reconciling conflicting comments prior to sending to Rincon.
• Rincon will address one round of consolidated comments from the City on each deliverable, to be provided as tracked changes in Word. Any additional revisions will be completed on a time and materials basis in accordance with our standard fee schedule.
• Responses of up to 10 substantive public comment letters and emails related to the Community Forest Plan. • Addressing City comments on each deliverable will not require additional, new analysis or field investigation. • To maintain momentum in the project schedule and provide cost efficiency, we assume City comments will focus on any new content in the previous version of the deliverable, and new comments on previously submitted content will be minimal.
• The City will coordinate any site access needed to conduct ambient noise monitoring. • No field work will be necessary to assess paleontological resource impacts. • In addition to the No Project Alternative, up to two build alternatives will be presented to reduce potential impacts.
• Rincon will provide two hard copies of the Draft EIR. • Up to 10 comment letters containing comments on the content of the EIR will be received, including three lengthy (over five pages) and/or substantive letters, all of which can be adequately responded to in a maximum of 90 professional staff hours. Comment letters that solely express support or opposition to the project would not count against the 10-letter estimate. The actual level of effort required to respond will depend on the length, detail, and sophistication of the comments, in addition to the number of letters received. We reserve the right to reevaluate the effort level and request a scope amendment upon the closing of the public comment period. If the number of comment letters and the effort to prepare responses is greater than anticipated, Rincon will notify City staff immediately and discuss options to amend our scope of work and budget as necessary.
• This scope of work assumes that if alternatives are determined to be infeasible due to financial considerations, or that the Statement of Overriding Considerations relies on specific economic or financial factors, corresponding financial data to support these conclusions will be provided by the City. • Public hearings will not exceed 3 hours in length.
• We assume hearings (including the Scoping Meeting and two Public Hearings) may be held virtually but have budgeted to attend hearings in person if required.
• Fish passage analyses will be conducted by qualified fish biologists and will be based on regulatory fish passage criteria. These analyses should only be used as a planning tool.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
48 • Documents will not be formatted for Americans with Disabilities Act accessibility. However, accessible documents can be provided for an additional fee.
• Costs have been allocated to tasks based upon Rincon’s proposed approach. Rincon may re-allocate costs among tasks and/or direct costs as circumstances warrant so long as the adjustments maintain the total price within its authorized amount.
• Standard rates are subject to a 3.5 percent annual escalation The future years reflect a 3.5 percent annual escalation.
City of Fort Bragg
Preparation of an Environmental Impact Report for Construction of Reservoirs and Community Forest – Fort Bragg Reservoir Project for Water Storage Resilience
56 J. Consultant Agreement
Rincon has reviewed the City’s standard consultant services agreement, and we do not have any issues or require amendments to the language in the agreement.