HomeMy WebLinkAboutHDR Engineering, Inc. 2026-03-05COU No. 2526-154
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AGREEMENT FOR
PROFESSIONAL CONSULTING SERVICES
This Agreement, made and entered into this 5th day of March, 2026 (“Effective Date”),
by and between CITY OF UKIAH, CALIFORNIA, hereinafter referred to as "City" and HDR
Engineering, Inc, a corporation organized and in good standing under the laws of the state of
Nebraska, hereinafter referred to as "Consultant".
RECITALS
This Agreement is predicated on the following facts:
a. City requires consulting services related to Lake Mendocino Hydroelectric Relicensing.
b. Consultant represents that it has the qualifications, skills, experience and properly
licensed to provide these services, and is willing to provide them according to the terms
of this Agreement.
c. City and Consultant agree upon the Scope-of-Work and Work Schedule attached hereto
as Attachment "A", describing contract provisions for the project and setting forth the
completion dates for the various services to be provided pursuant to this Agreement.
TERMS OF AGREEMENT
1.0 DESCRIPTION OF PROJECT
1.1 The Project is described in detail in the attached Scope-of-Work (Attachment "A").
2.0 SCOPE OF SERVICES
2.1 As set forth in Attachment "A".
2.2. Additional Services. Additional services, if any, shall only proceed upon written
agreement between City and Consultant. The written Agreement shall be in the form of
an Amendment to this Agreement.
3.0 CONDUCT OF WORK
3.1 Time of Completion. Consultant shall commence performance of services as required
by the Scope-of-Work upon receipt of a Notice to Proceed from City and shall complete
such services within six years from receipt of the Notice to Proceed. Consultant shall
complete the work in accordance with the requirements of the Agreement, even if
contract disputes arise or Consultant contends it is entitled to further compensation.
3.2 Standard of Care. Consultant shall perform all services with the care and skill ordinarily
used by members of Consultant's profession practicing under the same or similar
circumstances at the same time and in the same locality.
4.0 COMPENSATION FOR SERVICES
4.1 Basis for Compensation. For the performance of the professional services of this
Agreement, Consultant shall be compensated on a time and expense basis not to
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exceed a guaranteed maximum dollar amount of $664,000. Labor charges shall be
based upon hourly billing rates for the various classifications of personnel employed by
Consultant to perform the Scope of Work as set forth in the attached Attachment A,
which shall include all indirect costs and expenses of every kind or nature, except direct
expenses. The direct expenses and the fees to be charged for same shall be as set
forth in Attachment A. Consultant shall complete the Scope of Work for the not-to-
exceed guaranteed maximum, even if actual time and expenses exceed that amount.
4.2 Changes. Should changes in compensation be required because of changes to the
Scope-of-Work of this Agreement, the parties shall agree in writing to any changes in
compensation. "Changes to the Scope-of-Work" means different activities than those
described in Attachment "A" and not additional time to complete those activities than the
parties anticipated on the date they entered this Agreement.
4.3 Sub-contractor Payment. The use of sub-consultants or other services to perform a
portion of the work of this Agreement shall be approved by City prior to commencement
of work. The cost of sub-consultants shall be included within guaranteed not-to-exceed
amount set forth in Section 4.1.
4.4 Terms of Payment. Payment to Consultant for services rendered in accordance with this
contract shall be based upon submission of monthly invoices for the work satisfactorily
performed prior to the date of the invoice less any amount already paid to Consultant,
which amounts shall be due and payable thirty (30) days after receipt by City. The
invoices shall provide a description of each item of work performed, the time expended
to perform each task, the fees charged for that task, and the direct expenses incurred
and billed for. Invoices shall be accompanied by documentation sufficient to enable City
to determine progress made and to support the expenses claimed.
5.0 ASSURANCES OF CONSULTANT
5.1 Independent Contractor. Consultant is an independent contractor and is solely
responsible for its acts or omissions. Consultant (including its agents, servants, and
employees) is not the City's agent, employee, or representative for any purpose.
It is the express intention of the parties hereto that Consultant is an independent
contractor and not an employee, joint venturer, or partner of City for any purpose
whatsoever. City shall have no right to, and shall not control the manner or prescribe the
method of accomplishing those services contracted to and performed by Consultant
under this Agreement, and the general public and all governmental agencies regulating
such activity shall be so informed.
Those provisions of this Agreement that reserve ultimate authority in City have been
inserted solely to achieve compliance with federal and state laws, rules, regulations, and
interpretations thereof. No such provisions and no other provisions of this Agreement
shall be interpreted or construed as creating or establishing the relationship of employer
and employee between Consultant and City.
Consultant shall pay all estimated and actual federal and state income and self-
employment taxes that are due the state and federal government and shall furnish and
pay worker's compensation insurance, unemployment insurance and any other benefits
required by law for himself and his employees, if any. Consultant agrees to indemnify
and hold City and its officers, agents and employees harmless from and against any
claims or demands by federal, state or local government agencies for any such taxes or
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benefits due but not paid by Consultant, including the legal costs associated with
defending against any audit, claim, demand or law suit.
Consultant warrants and represents that it is a properly licensed professional or
professional organization with a substantial investment in its business and that it
maintains its own offices and staff which it will use in performing under this Agreement.
5.2 Conflict of Interest. Consultant understands that its professional responsibility is solely
to City. Consultant has no interest and will not acquire any direct or indirect interest that
would conflict with its performance of the Agreement. Consultant shall not in the
performance of this Agreement employ a person having such an interest. If the City
Manager determines that the Consultant has a disclosure obligation under the City’s
local conflict of interest code, the Consultant shall file the required disclosure form with
the City Clerk within 10 days of being notified of the City Manager’s determination.
6.0 INDEMNIFICATION
6.1 Insurance Liability. Without limiting Consultant's obligations arising under Paragraph 6.2
Consultant shall not begin work under this Agreement until it procures and maintains for
the full period of time allowed by law, surviving the termination of this Agreement
insurance against claims for injuries to persons or damages to property, which may arise
from or in connection with its performance under this Agreement.
A. Minimum Scope of Insurance
Coverage shall be at least as broad as:
1. Insurance Services Office ("ISO) Commercial General Liability Coverage
Form No. CG 20 10 10 01 and Commercial General Liability Coverage –
Completed Operations Form No. CG 20 37 10 01.
2. ISO Form No. CA 0001 (Ed. 1/87) covering Automobile Liability, Code 1
"any auto" or Code 8, 9 if no owned autos and endorsement CA 0025.
3. Worker's Compensation Insurance as required by the Labor Code of the
State of California and Employers Liability Insurance.
4. Errors and Omissions liability insurance appropriate to the consultant’s
profession.
B. Minimum Policy Limits
Consultant shall maintain limits no less than:
1. General Liability: $1,000,000 combined single limit per occurrence for
bodily injury, personal injury and property damage including operations,
products and completed operations. If Commercial General Liability
Insurance or other form with a general aggregate limit is used, the
general aggregate limit shall apply separately to the work performed
under this Agreement, or the aggregate limit shall be twice the prescribed
per occurrence limit.
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2. Automobile Liability: $1,000,000 combined single limit per accident for
bodily injury and property damage.
3. Worker's Compensation and Employers Liability: Worker's compensation
limits as required by the Labor Code of the State of California and
Employers Liability limits of $1,000,000 per accident.
4. Errors and Omissions liability: $1,000,000 per claim.
C. Deductibles and Self-Insured Retentions
Any deductibles or self-insured retentions must be declared to and approved by
the City.
D. Other Insurance Provisions
The policies are to contain, or be endorsed to contain, the following provisions:
1. General Liability and Automobile Liability Coverages
a. The City, it officers, officials, employees and volunteers are to be
covered as additional insureds as respects; liability arising out of
activities performed by or on behalf of the Consultant, products
and completed operations of the Consultant, premises owned,
occupied or used by the Consultant, or automobiles owned, hired
or borrowed by the Consultant for the full period of time allowed by
law, surviving the termination of this Agreement. The coverage
shall contain no special limitations on the scope-of-protection
afforded to the City, its officers, officials, employees or volunteers.
b. The Consultant's insurance coverage shall be primary insurance
as respects to the City, its officers, officials, employees and
volunteers. Any insurance or self-insurance maintained by the
City, its officers, officials, employees or volunteers shall be in
excess of the Consultant's insurance and shall not contribute with
it.
c. Any Consultant failure to comply with reporting provisions of the
policies shall not affect coverage provided to the City, its officers,
officials, employees or volunteers as additional insureds.
d. The Consultant's insurance shall apply separately to each insured
against whom claim is made or suit is brought, except with respect
to the limits of the insurer's liability.
2. Worker's Compensation and Employers Liability Coverage
The insurer shall agree to waive all rights of subrogation against the City,
its officers, officials, employees and volunteers for losses arising from
Consultant's performance of the work, pursuant to this Agreement.
3. Professional Liability Coverage
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If written on a claims-made basis, the retroactivity date shall be the
effective date of this Agreement. The policy period shall extend one (1)
year from the date of final approved invoice.
4. All Coverages
Each Insurance policy required by this clause shall be endorsed to state
that coverage shall not be canceled or materially changed in limits except
after thirty (30) days prior written notice by certified mail, return receipt
requested, has been given to the City.
E. Acceptability of Insurers
Insurance is to be placed with admitted California insurers with an A.M. Best's
rating of no less than A- for financial strength, AA for long-term credit rating and
AMB-1 for short-term credit rating.
F. Verification of Coverage
The City reserves the right to require complete, certified copies of all required
insurance policies, at any time, subject to redactions of HDR’s proprietary and
confidential information. Subject to maintaining the confidentiality of proprietary
or confidential information disclosed to City, Consultant shall not redact such
information upon a showing by the City that it is relevant to a coverage dispute
between the City and Consultant’s insurance company.
G. Subcontractors
Consultant shall furnish separate certificates and endorsements for each sub-
contractor or sub-consultant. All coverage for sub-contractors or sub-consultants
shall be subject to all insurance requirements set forth in this Paragraph 6.1.
6.2 Indemnification. Notwithstanding the foregoing insurance requirements, and in addition
thereto, Consultant agrees, for the full period of time allowed by law, surviving the
termination of this Agreement, to indemnify the City for any claim, cost or liability that
arises out of, or pertains to, or relates to any negligent act or omission or the willful
misconduct of Consultant in the performance of services under this contract by
Consultant, but this indemnity does not apply to liability for damages for death or bodily
injury to persons, injury to property, or other loss, arising from the sole negligence, willful
misconduct or defects in design by the City, or arising from the active negligence of the
City.
“Indemnify,” as used herein includes the expenses of defending against a claim and the
payment of any settlement or judgment arising out of the claim. Defense costs include
all costs associated with defending the claim, including, but not limited to, the fees of
attorneys, investigators, consultants, experts and expert witnesses, and litigation
expenses.
References in this paragraph to City or Consultant, include their officers, employees,
agents, and subcontractors.
7.0 CONTRACT PROVISIONS
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7.1 Ownership of Work. All documents furnished to Consultant by City and all documents or
reports and supportive data prepared by Consultant under this Agreement are owned
and become the property of the City upon their creation and shall be given to City
immediately upon demand and at the completion of Consultant's services at no
additional cost to City. Deliverables are identified in the Scope-of-Work, Attachment "A".
All documents produced by Consultant shall be furnished to City in digital format and
hardcopy. Consultant shall produce the digital format, using software and media
approved by City. Any modifications or reuse of the documents by City for purposes
other than those intended by the Agreement shall be at the City's sole risk and without
liability to Consultant.
7.2 Governing Law. Consultant shall comply with the laws and regulations of the United
States, the State of California, and all local governments having jurisdiction over this
Agreement. The interpretation and enforcement of this Agreement shall be governed by
California law and any action arising under or in connection with this Agreement must be
filed in a Court of competent jurisdiction in Mendocino County.
7.3 Entire Agreement. This Agreement plus its Attachment(s) and executed Amendments
set forth the entire understanding between the parties.
7.4 Severability. If any term of this Agreement is held invalid by a court of competent
jurisdiction, the remainder of this Agreement shall remain in effect.
7.5 Modification. No modification of this Agreement is valid unless made with the agreement
of both parties in writing.
7.6 Assignment. Consultant's services are considered unique and personal. Consultant
shall not assign, transfer, or sub-contract its interest or obligation under all or any portion
of this Agreement without City's prior written consent.
7.7 Waiver. No waiver of a breach of any covenant, term, or condition of this Agreement
shall be a waiver of any other or subsequent breach of the same or any other covenant,
term or condition or a waiver of the covenant, term or condition itself.
7.8 Termination. This Agreement may only be terminated by either party: 1) for breach of
the Agreement; 2) because funds are no longer available to pay Consultant for services
provided under this Agreement; or 3) City has abandoned and does not wish to complete
the project for which Consultant was retained. A party shall notify the other party of any
alleged breach of the Agreement and of the action required to cure the breach. If the
breaching party fails to cure the breach within the time specified in the notice, the
contract shall be terminated as of that time. If terminated for lack of funds or
abandonment of the project, the contract shall terminate on the date notice of
termination is given to Consultant. City shall pay the Consultant only for services
performed and expenses incurred as of the effective termination date. In such event, as
a condition to payment, Consultant shall provide to City all finished or unfinished
documents, data, studies, surveys, drawings, maps, models, photographs and reports
prepared by the Consultant under this Agreement. Consultant shall be entitled to
receive just and equitable compensation for any work completed hereunder in
accordance with the requirements of this Agreement, subject to off-set for any direct
damages City may incur as a result of Consultant's breach of contract.
7.9 Execution of Agreement. This Agreement may be executed in duplicate originals, each
bearing the original signature of the parties. Alternatively, this Agreement may be
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executed and delivered by facsimile or other electronic transmission, and in more than
one counterpart, each of which shall be deemed an original, and all of which together
shall constitute one and the same instrument. When executed using either alternative,
the executed agreement shall be deemed an original admissible as evidence in any
administrative or judicial proceeding to prove the terms and content of this Agreement.
8.0 NOTICES
Any notice given under this Agreement shall be in writing and deemed given when
personally delivered or deposited in the mail (certified or registered) addressed to the
parties as follows:
CITY OF UKIAH HDR ENGINEERING, INC.
DEPT. OF ELECTRIC UTILITY ATTN: CHRISTINA M. KEITHLY
1350 HASTINGS RD 1 CAPITOL MALL, SUITE 500
UKIAH, CALIFORNIA 95482 SACRAMENTO, CA 95814
9.0 SIGNATURES
IN WITNESS WHEREOF, the parties have executed this Agreement the Effective Date:
CONSULTANT
____________________
Date
____________________
Date
BY: __________________________
PRINT NAME: _________________
47-0680568
IRS IDN Number
CITY OF UKIAH
BY:
CITY MANAGER
ATTEST
____________________
CITY CLERK Date
Elizabeth Mesbah, Vice President
March 6, 2026
03/11/2026
03/11/2026
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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HDR developed its proposed team with the Lake Mendocino PP
relicensing in mind. Our proposed Project Manager, Chuck
Vertucci, is experienced in leading relicensings with smaller Project
footprints and less anticipated environmental impacts, where the
focus can be on completing the relicensing process in an efficient
and cost-effective manner. Working closely with Chuck is our
Senior FERC Advisor, Devin Malkin, and Assistant Project
Manager, Ian Cain, who bring additional experience in navigating
the relicensing process. Our proposed Principal-in-Charge,
Elizabeth Dawson, brings an owner’s perspective to our project
team and will support the City and the HDR team in this advisory
role. Finally, HDR’s key technical leads have held these roles on
numerous previous relicensings while working closely with Chuck.
The assigned personnel will not be substituted without the
City’s approval.
HDR has intentionally limited the key personnel proposed for Lake
Mendocino PP relicensing to control cost and maintain efficiencies
and has confirmed that this Project fits within each key personnel’s
overall workload. In addition, our broader team of FERC regulatory
specialists and subject matter experts are available to assist, should
the relicensing require additional resources. These staff will include
junior, mid-level, and senior:
•FERC Regulatory Specialists
•Aquatic and Terrestrial Biologists
•Cultural Resource Specialists
•Environmental Planners
•Global Information Systems (GIS)/Data
Solutions Specialists
•Project Administrators and Accountants
HDR’s key personnel are introduced in staff biographies on the
following page. Full resumes for each are provided in
Appendix A.
C. Staffing Plan
Elizabeth Dawson, PE
Key Personnel
PRINCIPAL-IN-CHARGE
PROJECT MANAGER
Chuck Vertucci
SENIOR FERC ADVISOR
Devin Malkin
TECHNICAL RESOURCES
Aquatic/Water Resources
Norm Ponferrada
Anna Clabaugh
Terrestrial Resources
Ian Cain
Eliza Schlein
Recreation, Aesthetics, and
Land Use Resources
Matt Paquette
Kaden Emerson
Cultural Resources
Danielle Risse, RPA
Kamil Rochon
GIS/Data Solutions
Keir Keightley, GISP
Angela Tang
Administration/Accounting
Jacare Palmer
Tyler Miller
Jordyn Texley
Figure 2 - HDR Organizational Chart
ASSISTANT PROJECT MANAGER
Ian Cain
Attachment A
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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E. Project Understanding and Approach
Key Project Strategies
Based on HDR’s 30 years of experience performing FERC
hydropower relicensings in California and a preliminary review of
available documents and sensitive resources in and around Lake
Mendocino PP, HDR has identified four key project strategies for
relicensing. Our proposed project approach looks to address each of
those issues to support the overall relicensing.
1.Emphasize Project Operations and Constraints
The City cannot control or request water from Coyote Valley
Dam and Lake Mendocino, but operates Lake Mendocino PP only
when USACE releases from Coyote Valley Dam provide enough
flow. This lack of control removes or reduces two of the most
high-profile issues related to FERC relicensing of hydropower
projects—downstream flows and anadromous fish. This is
particularly important for Lake Mendocino PP, since Endangered
Species Act (ESA) listed fish, steelhead - Central California Coast
Distinct Population Segment (DPS) (Oncorhynchus mykiss)
and Chinook salmon (Oncorhynchus tshawytscha)—California
Coastal Evolutionary Significant Unit (ESU), occur in the East
Fork Russian River below Lake Mendocino. This section of
the East Fork Russian River is also considered Essential Fish
Habitat (EFH) for Chinook salmon, while the mainstem Russian
River is also considered Designated Critical Habitat (DCH) for
Chinook salmon. Section 7 consultation with NOAA’s National
Marine Fisheries Service (NMFS) will be required; however,
the potential of Lake Mendocino PP to affect the species, EFH,
and DCH will be limited to water quality directly below the
powerhouse. Requests for larger studies—including operations
modeling, water quantity, water quality/temperature, channel
morphology, macroinvertebrates, riparian habitat and other
biological resources downstream of the Coyote Valley Dam—can
be strongly countered as having no nexus to Lake Mendocino
PP. Information on potential Lake Mendocino PP operations that
might affect ESA-listed fish can be gathered during data gap
surveys, described in Key Project Issue #3. Lake Mendocino PP’s
lack of control over the flows also supports the use of the TLP,
since it substantively limits the complexities of the relicensing,
reduces the need for relicensing meetings (particularly for
developing study plans), and improves the likelihood of approval
of the TLP by the FERC, as discussed in Key Project Issue #2.
2.TLP is the Right Choice for the Lake Mendocino PP
HDR commends the City for its intent to request the TLP and
believes this approach presents the best combination of cost
savings and process control for the City. Given the details of Lake
Mendocino PP, HDR’s recent experience with TLP requests, and
FERC’s recent approvals of the TLP, HDR believes the TLP request
is likely to be granted by FERC. As the City is aware, the TLP is
advantageous to licensees because it puts FERC’s NEPA process
after the Final license Application (FLA) is filed, giving the City
more opportunities to fully describe its project and potential
environmental impacts (or lack thereof) to FERC. Additionally,
TLP gives the City more control over a key aspect of relicensing
study plans, which are further discussed in Key Issue #3. Finally,
the TLP requires fewer meetings and formal deliverables, which
represents cost savings for the City compared to the Integrated
Licensing Process (ILP). However, HDR does recommend the City
hold directed agency meetings beyond the minimum required by
the TLP, a strategy we have successfully used on multiple other
projects to achieve positive outcomes for the licensees.
3.Development and Implementation of Study Plans
HDR and the City both understand that the development and
implementation of study plans is one of the major cost drivers for
most California relicensing processes. HDR proposes to minimize
the need for costly and time-consuming study plan development
and implementation during relicensing by conducting data gap
surveys for the resource areas that typically require data gathering
in relicensings – cultural resources, terrestrial biology, and water
resources – as part of the development of the PAD. This will
reduce (or eliminate) study plan development and implementation
for those resource areas by allowing the City to drive the
process. This will also reduce the likelihood of study requests
from relicensing participants and increase the City’s chances of
successfully disputing any requests that are made. This approach
is further outlined below.
4.Focus on Relicensing Outcomes
Although costs during relicensing are a substantive concern, HDR
also advises careful attention to the environmental or cultural
resource measures that may be imposed by agencies and included
by FERC in the City’s new license. HDR’s goal is not only for the
City to obtain a new license in a cost-effective manner, but to
minimize these Protection, Mitigation and Enhancement (PM&E)
costs and avoid operational constraints and loss of generation
following license issuance. Our thorough understanding of the
relicensing process, experience with key resource issues such
as ESA-listed fish, and experience negotiating with federal and
California state agencies provides the City with a team that is
poised to deliver advantageous relicensing outcomes. To support
this, HDR proposes several meetings with the resource agencies
throughout the relicensing—with the goal of reaching consensus
on PM&E measures while keeping the City’s overall relicensing
and operational objectives at the forefront, as also described in
Key Project Issue #2.
Project Management and City
Coordination
Throughout the course of the relicensing, HDR will coordinate
closely with the City using monthly meetings and summaries.
Following HDR’s recommended initial Kick-off Meeting, described
on the following page, HDR will schedule a series of hour-long
virtual meetings with City staff, with an agenda provided in advance.
During the development of major relicensing documents, meetings
will be scheduled monthly. HDR’s PM and APM will attend all
meetings, with the Strategic FERC Advisor attending up to half of
the meetings. As the relicensing proceeds, some meetings may be
shorter in length or may be replaced by written updates, at the City’s
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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discretion. Action items from each meeting will be tracked on the
project SharePoint site. HDR’s PM will also be available to attend
the City’s bi-monthly Council meetings and present updates to the
City Council Members upon request by City staff. HDR will also be
available to help prepare presentations and updates that City staff
may present directly. HDR assumes attendance at City Council
meetings will mostly be tied to major relicensing milestones, such
as the development and filing of the PAD, DLA, FLA, and post-FLA
processes. HDR will use an internal SharePoint website for document
production, review, and storage. HDR’s SharePoint lead will develop,
manage, and provide website access to City staff throughout
the project.
Project Schedule
HDR has provided a draft Project Schedule (see Tables 1 and 2 in
Section F), including our current recommendations and assuming
use of the TLP. No later than one month after contract execution,
HDR will refine this schedule based on input from the City, including
the Kick-off Meeting, review of existing project documents, and
other required and relevant milestones. In addition, HDR will provide
a draft schedule for distributing PAD sections to the City for review,
along with the timeframe for second review of the full document.
HDR will develop a similar schedule for the DLA and FLA.
Invoices and Progress Reports
HDR will submit monthly invoices and monthly progress reports
covering the work under the contract to the City’s PM no later than
the first two weeks of each month. The progress report shall include
the following, at a minimum:
•A brief description of the work completed in the previous month
•A brief description of the work projected to be completed by the
end of the current month
•Summary level information regarding scope, schedule,
and budget
•Contractual items that may need to be addressed
•HDR will discuss the content and format of the progress reports
at the Kick-off Meeting and bring a proposed template
Project Approach
Project Initiation
The Lake Mendocino PP relicensing will begin with HDR and the City
working together to develop a relicensing strategy that will guide the
process throughout.
KICK-OFF MEETING
HDR will work with the City to prepare for and conduct a Kick-off
Meeting with City staff. HDR’s PM, APM, and the Water/Aquatic
Resources Lead will attend the meeting, which will be held at the
City of Ukiah offices. The Kick-off Meeting will take place over the
course of two to three hours, and HDR will provide a draft agenda
for the City’s comment and approval prior to the meeting. HDR will
also bring the proposed schedule for PAD development (described
in Deliverables), the draft Project description and operations, and
a template outline for one PAD section to review with the City.
Additional items to discuss will include general administrative items,
communication protocols, existing and available City and FERC
information, anticipated relicensing participants and their contact
information, and monthly progress reporting format and content.
HDR will also preview the internal SharePoint site, which will be
used to house and share relicensing documents and references and
will also allow for collaborative development of documents. To take
advantage of HDR staff traveling to the City, we also recommend a
brief site visit with City staff to help answer any immediate questions
and support development of the PAD and data gathering efforts.
REVIEW EXISTING CITY AND FERC DATA
HDR will review City, FERC, and other reasonably available existing
documentation for the Project, including the Project’s current
FERC exhibits, to identify the Project’s current FERC boundary and
facilities according to the license. HDR will inform the City’s PM by
email no later than six weeks after the Kick-off Meeting if missing
documentation or information shortcomings are identified. Some
documents generally required from the Licensee to complete a
PAD include:
•As-built drawings (especially if there have been changes not
filed with the FERC)
•Power Purchase Agreements and other agreements/contracts
that relate to the licensed project
•Monthly Flow Exceedance Curves
•Flow through the powerhouse for a 10-year period of record
•Capacity versus head rating
•Tailwater rating curves
•Monthly and annual gross generation in kilowatt-hours over a
10-year period
•Facility maintenance records
•FERC inspection records (if not posted to the eLibrary)
•Water temperature and dissolved oxygen (DO) data, other water
quality data
•Records for any other monitoring that may have been done by
the licensee in the area of Lake Mendocino PP (fish surveys,
benthic macroinvertebrates, etc.).
As part of the early outreach to interested parties, HDR will also ask
those parties to provide information they possess that is relevant
to the Lake Mendocino PP relicensing. HDR will post existing
information to the internal SharePoint so both HDR and City staff can
access the existing available data during relicensing.
RELICENSING PARTICIPANTS CONTACT
INFORMATION
HDR will work with City staff to identify interested parties and their
applicable contact information (e.g., phone numbers, emails, and
physical addresses) and provide a comprehensive list to the City. An
initial list of potential relicensing participants will be developed for
the Kick-off Meeting using FERC’s Service List, the Native American
Heritage Commission for Tribal Contacts, and HDR’s understanding
of resource agency contacts for FERC relicensings. At the outset,
the California Department of Fish and Wildlife (CDFW), National
Marine Fisheries Service (NMFS), State Water Resources Control
Board (SWRCB), State Historic Preservation Officer (SHPO), United
States Fish and Wildlife Service (USFWS), USACE, and potentially,
the National Park Service are most likely to be active relicensing
participants. Regional and local non-governmental organizations like
Trout Unlimited, American Rivers, and potentially others may also
participate in relicensing and will be part of HDR’s initial list. This list
will be updated as the relicensing progresses and additional parties
are identified.
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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F. Scope of Services (Major Milestones and Deliverables)
This section details the major milestones and deliverables as
detailed in the City’s RFP.
Prepare and File a Notice of Intent
HDR will work with City staff to prepare and file the Notice of Intent
(NOI) (along with the PAD) declaring that the City intends to seek
a new license (relicense) for Lake Mendocino PP. As part of the
NOI, the City will request to be FERC’s non-federal representative
for informal consultation under Section 106 of the National Historic
Preservation Act (NHPA) and Section 7 of the ESA. This will allow
the City to consult with Native American Tribes, the SHPO and the
USFWS, as needed during relicensing. The NOI (18 C.F.R. § 5.5) will
also be used as the basis of the DLA’s Initial Statement.
Prepare and File a Pre-Application
Document
The PAD (18.C.F.R. § 5.6) provides not only a summary of existing,
relevant, and reasonably available information, but the story of the
Project and the set-up for the license application. The pillars of Lake
Mendocino PP’s story include the small footprint of the FERC Project
Boundary, the lack of Project impacts to environmental resources,
and the fact that the City does not control flow.
Another part of the relicensing strategy and PAD development is to
determine active relicensing participants and their interests early in
the process. To confirm interested relicensing participants, possible
resources issues, and study requests, HDR recommends that the
City hold a pre-PAD meeting. The initial list of potential relicensing
participants, as described above, will be invited. This approximately
one-hour virtual meeting will describe the Project, proposed
changes, and relicensing milestones and will also allow participants
to request information relevant to the Project—including any issues
they feel should be discussed during relicensing. The invitation will
include a written request for that information, which will also serve
as the PAD questionnaire.
The PAD will be tailored as closely as possible to the license
application to simplify later development. This will include
providing drafts of Exhibit A (Project Description), Exhibit B
(Project Operations), Exhibit F (Project Drawings), and Exhibit G
(Project Maps) as attachments to the PAD and structuring the
PAD’s environmental resource sections to meet the requirements of
Exhibit E of the license application to the extent possible. PAD-
specific information not included as part of the draft Exhibits will be
incorporated as required.
Per the schedule developed during the initial internal meetings,
HDR will provide the City with individual sections of the PAD for the
first round of review and comment—generally three at a time and
starting with the Project Description and Operations—spread over
the first half of 2026. HDR will provide a minimum of two weeks
for City staff to review the documents and provide comments. The
entire PAD, with all comments addressed, will be provided to the
City for a second round of review and comment approximately two
months prior to the PAD filing so there is ample time for the City
to review and HDR to address the comments. All documents will
be placed on the internal SharePoint, developed and maintained
by HDR, and City staff will be provided with access to perform
their reviews.
Filing of the PAD will occur no later than March 31, 2027 (five
years prior to license expiration), though HDR’s proposed schedule
includes filing by December 31, 2026, per the City’s RFP. A separate
request to use the TLP (18 C.F.R. § 5.3) will be drafted and filed with
the FERC, on the same day as the PAD and NOI are filed. A notice
of these filing requests will be published in a local newspaper. The
City of Ukiah’s website will host the public relicensing documents
(or links to the FERC eLibrary) to provide access to relicensing
participants. HDR will also provide a copy of the PAD and NOI to
local libraries.
Consultation with Regulatory Agencies
and Other Interested Parties
Informal consultation under Section 7 of the ESA and Section 106
of the NHPA is anticipated to require consultation and meetings
with the NMFS, USFWS, Native American Tribes, and SHPO. HDR
notes that, ultimately, consultation under Section 7 and Section 106
is FERC’s responsibility as the lead agency; once FERC delegates
the City as FERC’s non-federal representative, it can engage
these parties directly. HDR has had recent success working with
these parties early in the process to try to reach consensus and
conclude consultation.
Informal Section 7 Consultation
Informal Section 7 Consultation with NMFS is assumed to be
required due to the presence of steelhead—Central California Coast
DPS and Chinook salmon—California Coastal ESU as well as DCH
and EFH for Chinook salmon in the East Fork Russian River below
Lake Mendocino PP. HDR anticipates up to two virtual meetings for
informal consultation with the NMFS during the relicensing. Meeting
goals include:
1.Educate NMFS on Project operations and the limited ability (if
any) to alter stream conditions
2.Resolve any differences that are identified to avoid
complications during formal consultation related to impacts
and mitigation
3.If necessary, reach agreement on potential conservation
measures to be included in the new license that will allow
NMFS to conclude Section 7 consultation
Based on the current understanding of Lake Mendocino PP
operations, HDR has not proposed the development of an Applicant
Prepared Biological Assessment (APBA) or EFH document, given
the lack of impacts to ESA-listed fish. If new information comes to
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
22
light during relicensing regarding impacts to ESA-listed fish, HDR will
work with the City to decide if a different strategic approach to ESA
consultation is needed, including development of an APBA and EFH.
Informal Section 7 consultation with the USFWS may be required
for terrestrial species, but the Project’s footprint and operations
limit possible effects on endangered terrestrial species. Information
gathered for the PAD, including through data gap surveys, will be
used to determine if consultation and PM&E measures are needed
or likely to be required for terrestrial endangered species. Up to two
virtual meetings with USFWS are anticipated for informal Section
7 consultation. The goal of the meetings is to reach agreement on
potential conservation measures and (if necessary) to mitigate for
potential impacts that we would include in the new license that will
allow USFWS to conclude Section 7 consultation.
A preliminary search of USFWS’ iPAC database resulted in eight ESA-
listed species with the potential to occur near the Lake Mendocino
PP. Of these species, three are listed as Endangered: Burke’s
Goldfields (Lasthenia burkei), Contra Costa Goldfields (Lasthenia
conjugens), and Showy Indian Clover (Trifolium amoenum); three
are listed as Threatened: Northern Spotted Owl (Strix occidentalis
caurina), Western Snowy Plover (Charadrius nivosus nivosus),
Yellow-billed Cuckoo (Coccyzus americanus); and two are listed as
Proposed Threatened: Northwestern Pond Turtle (Actinemys
marmorata) and Monarch Butterfly (Danaus plexippus). Terrestrial
surveys, described below, will confirm the presence or absence of
habitat for these species and document whether any are observed.
Potential Project effects (or lack thereof) to these species will be
addressed in the PAD.
Informal Section 106 Consultation
HDR will complete consultation with SHPO and Native American
Tribes, as needed, during the development of the license application.
A separate cultural resources report, based on data collected during
development of the PAD, will be written for use during consultation
with Native American Tribes and SHPO. To successfully conclude
Section 106 consultation, concurrence from SHPO is needed on:
1.The definition of the Area of Potential Effect
2.Concurrence on the effort to identify resources
3.Concurrence on any National Register
eligibility recommendations
4.Agreement on ‘no effect’ or ‘no adverse effect’ on
historical properties
5.Verifying that Native American Tribes were consulted
(information from Section 106 consultation will be provided in
the DLA, if consultation is completed prior to distribution, or
in the FLA)
Meetings with Regulatory Agencies
and Other Interested Parties
The Joint Meeting and Site Visit, described below, are the only
meetings required by TLP during relicensing. HDR also proposes that
the City meet with resource agencies to discuss proposed measures
and management plans, if needed. These meetings are in addition to
the meetings described above in the PAD and Consultation sections.
While these meetings are not required under the TLP, HDR has found
that targeted discussions with relicensing participants throughout
the process can support better relicensing outcomes, regardless of
the FERC process used. The TLP allows the City to have more control
over the timing, quantity, and direction of these meetings compared
to the more rigid—and expensive—requirements of the ILP.
Joint Meeting and Site Visit
Within 120 days of the filing of the NOI and PAD, the Joint Meeting
(18 C.F.R.§16.8(b)(4)) will be held. As part of planning, the proposed
Joint Meeting date and site visit will be published in the PAD, though
relicensing participants will need to be consulted with regarding the
date. Those relicensing participants who express interest in the Joint
Meeting will be offered a site visit. An option for an in-person Joint
Meeting will be offered, but it is likely most relicensing participants
will attend the virtual meeting. HDR will record the virtual meeting in
order to maintain compliance with FERC requirements.
The Joint Meeting offers another opportunity to learn which
relicensing participants intend to be part of the process, in addition
to which elements each participant intends to focus on. This
discussion will foreshadow upcoming PAD comments and study
requests so the City can prepare to respond to them before they are
filed (no later than 60 days after the Joint Meeting).
Recommended Meetings
Based on extensive experience, HDR recommends that the City work
proactively with CDFW, USFWA, and other agencies during DLA
development, rather than wait for the agencies to provide comments
on the DLA and propose license measures. HDR and the City will
draft proposed measures to discuss at virtual meetings, basing them
on Project information, agency interest, and likelihood of FERC to
add a similar (but likely more complicated) measure to the license if
requested by an agency. If agreement on measures can be reached,
they will be included in the DLA. By utilizing this approach, the
City keeps a measure of control on potential measures by leading
consultation with the agencies and reduces the risk of unexpected
agency recommendations of license measures after the filing of
the FLA and any substantive disagreements that lead to a required
Meeting to Resolve Differences (18 C.F.R. § 16.8 c(6)(i)&(iii)).
Based on HDR’s current understanding of Lake Mendocino PP, no
disagreements on measures are expected, and thus, the Meeting to
Resolve Differences is not specifically scheduled or budgeted for, but
if needed, HDR’s included budget for agency meetings will be used
for this meeting. If the Meeting to Resolve Differences is required,
HDR will prepare the required agenda, notifications, and meeting
materials and will lead the meeting on behalf of the City. The results
of the meeting will be documented in the FLA.
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23
Develop Study Plans and Conduct
Studies
Based on HDR’s current understanding of the Project, potential
resources where data gaps may be identified include three topics:
•Cultural Resources
•Terrestrial Biological Resources
•Water Quality, including temperature and DO in the East Fork
Russian River downstream of Lake Mendocino PP.
Therefore, to fill in anticipated data gaps and to curtail formal study
requests later in relicensing, HDR recommends performing data
collection for those three resources and including the data in the
applicable resource sections of the PAD. This early data collection
effort should fill most, if not all, of the data gaps for Lake Mendocino
PP and address many of the anticipated resource agencies’ interests.
More details on the proposed data gap surveys are provided below.
HDR has successfully used this approach on prior relicensing
projects, including two of our reference projects. Completing these
surveys and completing a robust data gap analysis will help the City
avoid potentially costly and time-consuming study plan development
and implementation.
Cultural and Tribal Resources
Per the requirements of Section 106 of the NHPA and FERC,
HDR will conduct a cultural re-sources data gap survey to identify
any potential historic properties, including Tribal resources, which
may be affected by continued operations and maintenance of the
Project. To accomplish this, HDR will request a records search
from the Northwest Information Center of the California Historical
Resources Information System at Sonoma State University, which
maintains the records for Mendocino County. The records search will
identify any previously recorded archaeological or built environment
resources, within or adjacent to, the FERC Project Boundary. The
search will also provide details on previously conducted cultural
resource studies. HDR will also contact the Native American
Heritage Commission to request a search of the Sacred Lands File
and a current Tribal representative contact list to assist with Tribal
consultation. Concurrent to the records search request, HDR will
complete and submit an archaeological survey permit request to
appropriate federal agencies who have jurisdiction over land within
the Project Boundary (e.g., USACE). HDR anticipates that the permit
will be issued to HDR under the authority of the Archaeological
Resources Protection Act.
Following a review of the records’ search data and receipt of any
necessary permits, HDR will conduct a pedestrian survey of the
defined FERC Project Boundary to update any previously recorded
cultural resources and to fully document any newly encountered
resources on the State of California, Department of Parks and
Recreation 532 Series forms. HDR understands that the Lake
Mendocino Hydroelectric Power Plant was completed in 1986
and, as such, will not meet the standard 50-year-old threshold for
documentation or National Register of Historic Places eligibility
consideration until 2036. HDR assumes that any appurtenant facility
included under the FERC license dates to the same period and, as
such, does not propose to conduct a built environment survey of
the power plant. However, HDR does note that consideration of
the facility for National Register of Historic Places eligibility will
be a condition of the new license when it reaches the 50-year-
old threshold. The results of the cultural resources survey will be
compiled into a technical report that will be used for Section 106
compliance requirements, as described above, and for associated
consultation with Native American Tribes, USACE, FERC, and the
SHPO. The compiled data in the report will also assist and inform the
development of the cultural and Tribal resource sections in the PAD,
DLA, and FLA.
Terrestrial Resources
Surveys will consist of a general habitat assessment and vegetation
mapping to describe the ecology of the Project area and provide
information about the potential for special-status wildlife species to
occur in the Project area. Concurrently with these activities, there
will be a focused special-status plant survey and noxious weed
survey, generally following the CDFW’s Protocols for Surveying and
Evaluating Impacts to Special Status Native Plant Populations and
Sensitive Natural Communities (CDFW 2018) , consisting of two full
passes of the Project area. Any special-status species occurrences
will be mapped and data on the occurrences collected. A general
assessment of aquatic features in the Project area will also occur
during these surveys. A formal aquatic resources delineation,
following USACE guidelines, is not proposed for terrestrial studies
as it is not needed unless the City is proposing new construction
activities that may impact an aquatic feature. Biological assessments
will include an evaluation of habitat potential for listed or proposed
species under the federal and state ESA.
Water Resources
HDR will monitor water temperature, DO, and water quality
parameters downstream of Lake Mendocino PP on the East Fork
Russian River if current data are not available. Data collection will
include installing continuous water temperature and DO loggers at
up to two accessible sites on the East Fork Russian River, including
one site downstream of the Lake Mendocino PP discharge and a
potential second site further downstream if determined necessary.
Each site will include duplicate loggers to avoid data losses due
to equipment malfunctions or other issues. The loggers will be
deployed in spring and maintained until fall to capture seasonal
warming and cooling trends. An additional site visit will occur
after equipment installation for data downloads and equipment
checks in the summer. This continuous monitoring will allow for
evaluation of temperature and DO during periods when the power
plant is operating and when it is offline. In addition to continuous
temperature and DO monitoring, during each site visit (i.e., spring
logger installs, summer data download, and fall equipment removal),
HDR will measure instantaneous water quality parameters with
a multiparameter water quality meter downstream of the Lake
Mendocino PP to provide water quality information. If possible,
some attempt will be made to include water quality measurements
both when the power plant is operating and when it is offline. HDR
will coordinate closely to identify safe access points, schedule
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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installations, and determine optimal timing for sampling. Data
collected will be compiled into accessible files that could be used to
develop a report to characterize downstream temperature, DO, and
water quality conditions.
HDR will also collect water quality samples at one location
downstream of the Lake Mendocino PP and, if needed, a second
location further downstream. Samples will be collected once when
the project is operating and once when it is offline. A California-
certified laboratory will be used to analyze and provide results on
the samples. HDR will work with the City on the best timing for grab
sampling and logger installations, as well as areas for safe access.
Data will be included in the water resources and biological sections
of the PAD.
Conducting Studies Safely
A Site-Specific Safety Plan for the Lake Mendocino PP relicensing
will be developed by the PM and one or more experienced field
staff as part of the initial set-up of the Project. This will include, at
a minimum, information on the Project scope, location and specific
sites, schedule for field work, details on how field work will be
implemented, key staff safety roles, information on reporting unsafe
conditions and/or incidents, an emergency action plan, information
on potential safety risks and how to minimize/mitigate them,
details on trainings field staff are required to have, requirements
for personal protective and other safety equipment, check-in/
check-out procedures, and any other relevant Project-specific safety
information. Given the location of the Project, we will also include a
section about fire safety and smoke inhalation. Nearby hospitals and
other resources will be listed, as will emergency contact information
for all crew members. Field staff are required to read, be familiar
with and, acknowledge through signature the Safety Plan before
going into the field. A copy of the Safety Plan is also carried into
the field by each team performing work. Additionally, a Job Hazard
Analysis (JHA) will be completed for each specific field task on
the Project by the team performing that task. This analysis takes
a deeper look at the actions that will be necessary to complete
the fieldwork, starting with any anticipated travel requirements.
Each step is evaluated for potential hazards and control measures
to be implemented to eliminate or minimize each hazard. The JHA
form also lists the necessary equipment and training required
to perform the task safely. Field team members are responsible
for being actively involved in the hazard analysis. JHAs are living
documents that are required to be updated as field conditions and
activities change.
Respond to Comments and Engage in
Dispute Resolution
HDR anticipates some comments from resource agencies on the
PAD and DLA. Comments on the PAD not related to studies will be
addressed in the DLA. Comments on the DLA will be addressed in
the FLA. A comment tracker, in the form of a table, will be included
as part of the Consultation Log for the Project, which will be included
in all major relicensing documents.
While not required under the TLP, HDR recommends that if any
study requests are filed with FERC in response to the PAD and Joint
Meeting, a response be drafted and filed with the FERC as part of
closing out the First Stage Consultation. For the purposes of this
proposal, HDR assumes that only the three data collection efforts
described above will be needed. Additional data collection efforts
or study development and implementation are not included in
this scope of work. HDR also assumes that there will be no formal
study disputes requested by any resource agencies given the lack of
anticipated issues, the City’s lack of control of flow in the East Fork
Russian River, and experience with other TLP relicensings (where
no formal study disputes have occurred). HDR does not anticipate
that there will be a need for formal dispute resolution, but as
described above, one of the proposed meetings could be repurposed
for a required second Joint Meeting to address disagreements
on measures.
License Application
Per the TLP, the City must provide a DLA to relicensing participants
for review and comment; therefore, this section is broken into DLA
and FLA development.
Draft License Application
With the expectation of no relicensing studies, HDR recommends
starting the development of the DLA (18 C.F.R.§ 4.51 and 16.8(c))
in 2028, giving the City ample time to review and finalize the DLA
before the target distribution date to the relicensing participants of
May 2029. Providing the DLA early to relicensing participants allows
more time to respond to comments and assemble the FLA ahead of
the target date to file no later than December 18, 2029.
The new exhibits that will be developed for the DLA consist of
Exhibit C (Construction History), Exhibit D (Cost and Financing), and
Exhibit H (Miscellaneous Filing Information). Confidential, Privileged,
and Critical Energy Infrastructure Information (CEII) contained in
those exhibits will be excluded from the public version of the DLA
but will be filed with FERC. The other sections will be updated and
reformatted from the PAD, as needed, for use in the DLA. Comments
and questions from relicensing participants on the PAD will be
addressed in the DLA. The DLA will also include the City’s proposed
PM&E measures, if any, that will be included in the new license.
The review process for the DLA will flow similarly to the PAD, with
HDR providing the City three to four sections at a time for initial
review (minimum of 2 weeks), spread over the development period,
addressing all comments. The complete DLA will then undergo a
second review several months prior to distribution to relicensing
participants for 90-day review. All documents will be placed on the
internal SharePoint, developed and maintained by HDR, and City
staff will be provided with access to perform their reviews.
Final License Application
Relicensing Participants have 90 days to review and provide written
comments on the DLA. Once the comments are received, HDR will
review and organize the comments for the City’s review, including
a recommended response approach for each comment. HDR will
update the FLA based on comments received on the DLA, new
information that may be available, and additional changes agreed
to by the City. To make the City’s review of the FLA more efficient,
it will only provide individual sections for review (minimum of two
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
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weeks) if the section has substantial updates from the DLA. The
complete FLA will be provided to the City for final review and sign
off no less than two weeks prior to filing with FERC. All documents
will be placed on the internal SharePoint, developed and maintained
by HDR, and City staff will be provided with access to perform their
reviews. The Notice of Filing (18 C.F.R.§ 4.32(b)(6)) will be submitted
so that it is published twice within 14 days of filing the FLA, in a local
newspaper. The City of Ukiah’s website will host the FLA (or links
to the FERC eLibrary), providing access to relicensing participants.
While the RFP calls for filing the FLA by December 31, 2029, HDR
recommends a target date of December 18, 2029 to avoid potential
holiday schedule conflicts at the end of December. The latest the
City can file the FLA is March 31, 2030, two years prior to license
expiration, so the proposed schedule provides for some flexibility
if needed.
Post-FLA Activities
Once the City files the FLA, the relicensing transitions into the
post-FLA phase, which is less constrained by specific schedules
and somewhat out of the control of the City, although it remains
important to review and respond to items as they occur. Initially,
while FERC prepares to deem the license application ‘Ready for
Environmental Analysis’ (REA), it may issue Additional Information
Requests (AIR), or clarifications to the City. If FERC issues AIRs,
HDR will work with the City on the required response, including a
schedule. Considering the lack of complexity of Lake Mendocino PP,
HDR anticipates minimal AIRs.
NEPA Process
FERC’s NEPA process includes participation in site visits, public
meetings, and review of FERC’s scoping documents. HDR will
participate in the site visits and public meeting, advise the City
if HDR suggests responding to comments made during these
activities, and review and comment on FERC’s Scoping Documents 1
and 2, if necessary. Based on recent TLP relicensings, HDR assumes
minimal comments will be prepared or filed with FERC by the City.
This task also includes preparing a response to comments on the
City’s FLA that will be filed with FERC. HDR will compile comments
into a format that readily shows the commenter, comment, overlap
among comments, initial suggestions to FERC, and rationale for
suggestion. HDR assumes the City will only respond to comments
with which the City does not agree. This will not include comments
regarding editorial or other non-PM&E-related comments. HDR will
meet with the City to finalize the responses. HDR will then prepare a
draft filing with FERC for the City’s review and approval ,and will file
the response within 60 days of the deadline for comments.
This task also includes preparing and filing comments on FERC’s
draft Environmental Assessment (EA) or Environmental Impact
Statement (EIS). HDR assumes that FERC will issue a draft EA/
EIS, hold a Federal Power Act Section 10(j) meeting, and allow for
comments. HDR will review the draft EA/EIS, focusing primarily on
PM&E measures, and develop initial suggestions regarding whether
the City should comment on the PM&E measure, including the
alternative the City might file. HDR will provide the draft comments
to the City for review and approval and file the comments with
FERC. As part of this task, HDR will also prepare for, participate
in, and follow-up on FERC’s Section 10(j) meeting. For reference, a
FERC 10(j) meeting is a formal discussion between FERC and federal
and state fish and wildlife agencies meant to resolve conflicts or
inconsistencies in recommendations to protect and enhance fish
and wildlife resources during relicensing. Finally, although FERC’s
regulations do not specifically provide a period for comments on the
final EA/EIS, HDR recommends that the City review the document
for omissions and errors, and file comments with FERC if any
are found.
Water Quality Certification and CEQA
HDR will prepare a draft letter from the City to the SWRCB filing
a Section 401 Water Quality Certification (WQC) application,
participate in a pre-filing meeting with the SWRCB, and file proof of
the application with FERC. This will occur within 60 days of FERC’s
REA notice. HDR will support the City with a single virtual meeting
with the SWRCB prior to submitting the application.
HDR will review the draft WQC, if released by the SWRCB, focusing
primarily on the conditions, and will also develop initial suggestions
regarding whether the City should comment on the draft WQC,
including the alternative the City might propose. HDR will provide
the draft comments to the City for review and approval and provide
them to the SWRCB. If other interested parties provide comments on
the draft WQC, HDR will review and provide any recommendations
on those comments to the City as well. The final WQC will be issued
by the SWRCB no later than one year after the WQC application
is filed.
As part of the WQC process, the City must complete a California
Environmental Quality Act (CEQA) review process. Based on HDR’s
current understanding of the project, HDR assumes a Categorical
Exemption will be the appropriate level of CEQA review. HDR will
prepare the Notice of Exemption (NOE) form and supplemental
information. Supplemental information will be pulled from the FLA
and updated as needed with other publicly available information
at the time of filing the NOE. HDR will submit the NOE and
supplemental information electronically to the City for review. Upon
receipt of the City’s comments, HDR will revise the package to
incorporate comments and prepare a final NOE and supplemental
information package for approval. HDR will assist the City in
submitting the NOE and supplemental information package to the
State Clearinghouse through CEQAnet. HDR assumes that the City
will be responsible for filing the NOE and supplemental information
package with the County Clerk-Recorder’s office as well as paying
any applicable fees.
License Issuance
Once FERC completes its NEPA process, consultation under Section
7 (Endangered Species) and Section 106 (Cultural Resources) is
complete, and the City provides a valid water quality certification
(or proof of waiver); FERC will have received all the necessary
information to issue the City a new license.
26
HDR’s proposed schedule (see Table 1) includes early completion of documents to meet FERC regulatory deadlines without stress and allows ample time for the City’s review of all documents. This schedule assumes a November 3, 2025 notice to proceed from the City, a December 2026 PAD filing,
and December 2029 FLA filing per the RFP. The schedule will be further refined based on discussions with the City and the FERC relicensing process. HDR notes that the schedule through the filing of the FLA is well defined by several key FERC milestones and that post-FLA activities rely more
heavily on actions by FERC, because others and can be difficult to predict. HDR’s proposed schedule is based on our recent experience on other projects combined with our optimism that the City’s relicensing will not generate much controversy that could cause delays. Yellow shading on the
schedule below indicates that the task is estimated to be in progress and green indicates the month the task is estimated to be completed.
Project Schedule
Major Topic Milestone/Deliverable 2026 2027
Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec
Develop and
File NOI/PAD”
Meet with Agencies and Request Information
Develop Draft NOI/PAD for City Review
Develop Draft TLP Request for City Review
Finalize and File NOI/PAD
Finalize and File TLP Request
Complete Early Studies (Results in PAD)
Post PAD Activities
Plan and Hold Joint Meeting / Site Visit
Review Comments and Study Requests
Major Topic Milestone/Deliverable 2028 2029
Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec
Develop and Distribute DLA Develop Draft DLA for City Review
Finalize and Distribute DLA
Develop and File FLA
Review Comments on DLA
Plan and Hold Meeting to Resolve Differences
Finalize and File FLA
Table 1: Overview Relicensing Schedule for the City of Ukiah’s Lake Mendocino Hydroelectric Project
27
NOTES:
•While not shown on this schedule, HDR assumes monthly check-in calls with the City, attendance City Council meetings (if requested), and monthly invoices.
•Activities in 2025 will include project start up and working with the City on relicensing strategy. Pre-PAD development will also begin.•Specific due dates will be established while working with the City and based on FERC requirements.•Yellow shading indicates that the task is estimated to be in progress and green indicates the month the task is estimated to be completed.•HDR will provide interim sections of the PAD, DLA, and FLA for City review to spread out City’s time commitments.•HDR assumes there are no formal study disputes and that the City does not perform additional studies. If the City agrees to additional studies, they would occur in 2027 and/or 2028.•The latest the City can file its PAD is March 31, 2027, five years prior to the license expiration. HDR assumes PAD filing in December 2026.•The latest the City can file its FLA is March 31, 2030, two years prior to the license expiration. HDR assumes FLA filing in December 2029.•Post-FLA activities in 2030 and 2031 are a best estimate of when they could occur but the actual schedule will be set by FERC as its NEPA process progresses.
•HDR assumes activities for relicensing will be completed in 2031 however, FERC will likely not issue the license until April 1, 2032 even if it is ready earlier.
Project Schedule (continued)
Table 1.A: Overview Relicensing Schedule for the City of Ukiah’s Lake Mendocino Hydroelectric Project
Major Topic Milestone/Deliverable 2030 2031
Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec
Post-FLA Activities
Additional Information Requests
Scoping Document 1 and 2
REA and Comment Responses
Apply for WQC Application
CEQA Notice of Exemption
Draft WQC Review and Comments
Final WQC Review and Comment
Draft EA/EIR Review and Comment
Section 7 Consultation
10(j) Process including Meeting
Final EA/EIR Review and Comments
28
HDR also provides a detailed TLP relicensing schedule assuming a PAD filing date of December 18, 2026 and FLA filing date of December 18, 2029 (to limit impacts from the holidays later in December). The schedule also shows the FERC requirement and who is responsible for the item (i.e., the
City, FERC, or relicensing participants).
Project Schedule
Subsection(s)Lead Activity 1
Lake Mendocino PP
Timeframe 2,3
(Start & Finish)
18 C.F.R. § 5.3.
(b)City File request to use TLP 12/18/2026 (Friday)
18 C.F.R. § 5.5. NOTIFICATION OF INTENT
(a)-(g)City File Notice of Intent (NOI) to file an application for a new license and request for non-federal representative status under § 7 of the Endangered Species Act
(ESA) and § 106 of the National Historic Preservation Act (NHPA) (no earlier than 5.5 years and no later than 5 years prior to expiration of the current license)12/18/2026 (Friday)
18 C.F.R. § 5.6. PRE-APPLICATION DOCUMENT
(a)-(e)City File Pre-Application Document (PAD) (no earlier than 5.5 years and no later than 5 years prior to expiration of the current license)12/18/2026 (Friday)
18 C.F.R. § 5.7. TRIBAL CONSULTATION
--FERC Hold meeting with potentially affected Native American tribes (NLT 30 days of date NOI and PAD filed)12/19/2026 (Saturday)1/18/2027 (Monday)
18 C.F.R. § 5.8. NOTICE OF COMMENCEMENT OF PROCEEDING, DECISION ON USE OF TLP, AND INITIATION OF ESA AND NHPA INFORMAL CONSULTATION
(a)FERC Issue Notice of Commencement of Proceeding (NCP) and decision regarding City’s request to use TLP (NLT 60 days of date NOI and PAD filed)12/19/2026 (Saturday)2/16/2027 (Tuesday)
(b)FERC Request initiation of informal consultation under § 7 of the ESA and/or § 106 of the NHPA, if appropriate (NLT 60 days of date NOI and PAD filed)12/19/2026 (Saturday)2/16/2027 (Tuesday)
18 C.F.R. § 16.8. FIRST STAGE CONSULTATION – HOLD JOINT MEETING AND SITE VISIT
(b)(3)(i)(B)City Consult with the resource agencies, Native American tribes, and members of the public on the scheduling of a joint meeting (NLT 15 days in advance of the joint
meeting)2/17/2027 (Wednesday)4/1/2027 (Thursday)
(b)(3)(i)(B) [and 18
CFR § 16.8(h)(i)]City Post notice of joint meeting in local newspapers, including purpose, location, time, and agenda (NLT 14 days in advance of the joint meeting)2/17/2027 (Wednesday)4/2/2027 (Friday)
(b)(3)(i)(B City Provide to resource agencies, Native American tribes, and FERC a written notice of the time and place of the joint meeting and an agenda of the issues to be
discussed at the joint meeting (NLT 15 days in advance of the joint meeting)2/17/2027 (Wednesday)4/1/2027 (Thursday)
(b)(3)(ii)(B City Hold the joint meeting and provide an opportunity for a site visit to review the information and discuss the data and studies to be provided by City as part of the
consultation process (No earlier than (NET) 30 days but NLT 60 days of date NCP is issued)3/18/2027 (Thursday)4/16/2027 (Friday)
(b)(4)Relicensing Participants Resource agencies, Native American tribes and members of the public may attend the joint meeting to express their views regarding resource issues that should
be addressed in the application. Attendance of the public at the site visit is at the discretion of City (NET 30 days but NLT 60 days of date NCP is issued)3/18/2027 (Thursday)4/16/2027 (Friday)
(b)(4)City Make either an audio recording or written transcripts of the joint meeting, and promptly provide copies of these recordings, upon request (Promptly provide to
FERC, agencies, and Indian tribes, upon request)Promptly provide following the joint meeting
Table 2: Detailed schedule for City of ukiah’s Lake Mendocino PP Relicensing, assuming the City files the NOI and PAD on Dember 18, 2026. The schedule also assumes the City files its Final License Applications on December 18, 2029. Orange shaded row indicates a required City filing, and a pink shaded row indicates a required City-sponsored meeting.
29
Project Schedule
Subsection(s)Lead Activity 1
Lake Mendocino PP
Timeframe 2,3
(Start & Finish)
18 C.F.R. § 16.8. FIRST STAGE CONSULTATION - STUDY REQUESTS AND DISPUTE RESOLUTION
(b)(5)Relicensing Participants Provide to City written comments identifying Relicensing Participant’s determination of necessary studies to be performed or the information to be provided by
City (NLT 60 days after joint meeting unless deadline is extended to 120 days by FERC)4/17/2027 (Saturday)6/16/2027 (Wednesday)
(b)(6)(i)City & Relicensing Participants
During first stage consultation, if City and Relicensing Participant disagree regarding any matter or regarding the need to conduct a study or gather information,
City or the Relicensing Participant may refer the dispute in writing to FERC for resolution, providing a copy to other affected parties (any time during first stage
consultation).
4/17/2027 (Saturday)Until First Stage Ends
(b)(6)(ii)Disagreeing Party If a dispute is filed with FERC, the disagreeing party may file a response (NLT 15 days from the date the dispute is filed with FERC)NLT 15 days from the date the dispute is filed with
FERC
(b)(6)(iv)FERC FERC resolves dispute ----
18 C.F.R. § 16.8. SECOND STAGE CONSULTATION – CONDUCT STUDIES
(c)(1)City Conduct studies (if necessary)6/17/2027 (Thursday)Until Second Stage Ends
(c)(2)Relicensing Participants During Second Stage Consultation, a Relicensing Participant may request City conduct a study or gather information not previously identified. City must
promptly initiate the study or gather the information unless it refers the request to FERC for resolution (during second stage consultation).
When Second Stage
Begins Until Second Stage Ends
(c)(2)City City may refer the request to FERC for dispute resolution, copying affected parties.----
(b)(6)(ii)City If City files the dispute with FERC, other affected parties may file a response (NLT 15 days from the date the dispute is filed with FERC)NLT 15 days from the date City files the dispute
with FERC
(b)(6)(iv)FERC FERC resolves dispute ----
18 C.F.R. § 16.8. SECOND STAGE CONSULTATION – DRAFT LICENSE APPLICATION
c(4)City Provide to agencies and Native American tribes a copy of the DLA, including full documentation of consultation.
(No less than 150 days prior to deadline for filing license application)
c(5)Relicensing Participants Provide written comments on DLA to City (NLT 90 days of date DLA is distributed)6/1/2029 (Friday)7/23/2029 (Monday)2
c(6)(i)&(iii)City, Relicensing Participants
If comments indicate that a resource agency or Native American tribe has a substantive disagreement with City’s conclusions regarding resource impacts or
proposed PM&E measures, City holds at least one joint meeting with the disagreeing resource agency or Native American tribe and other agencies with similar
or related areas of interest, expertise, or responsibility to discuss and to attempt to reach agreement. City and the disagreeing resource agency or Native
American tribe may conclude the joint meeting with a document embodying any agreement and any issues that are unresolved. (NLT 60 days from the date of
the written comments of the disagreeing agency or Indian tribe)
NLT 60 days from the date of the written
comments
c(6)(ii)City Consult with disagreeing party and others about scheduling of joint meeting, and provide FERC, disagreeing party and others with written notice of the time and
place of the joint meeting and a written agenda of the issues to be discussed at the joint meeting (NLT 15 days in advance of the joint meeting)NLT 15 days in advance of the Joint Meeting
c(7)City & Disagreeing Party City and the disagreeing resource agency or Native American tribe may conclude the joint meeting with a document embodying any agreement and any issues
that are unresolved.----
30
Project Schedule
Subsection(s)Lead Activity 1
Lake Mendocino PP
Timeframe 2,3
(Start & Finish)
c(8)City City describe all disagreements with a resource agency or Native American tribe on technical or PM&E measures in its application, including an explanation of
the basis for City’s disagreement with the resource agency or Native American tribe.----
18 C.F.R. § 16.8. THIRD STAGE CONSULTATION – FINAL LICENSE APPLICATION
(d)(1)City File a Final License Application (FLA) and provide a copy of the FLA to agencies, Native American tribes, governmental offices and consulted members of the
public (NLT 2 years prior to expiration of the current license)December 18, 2029 (Tuesday)
(f)City Include in Exhibit E documentation of all consultation regarding comments, recommendation and proposed terms and conditions and studies. If the comments,
recommendation and proposed terms and conditions and studies were not accepted by City, describe why. (unspecified)Include in FLA
18 C.F.R. § 5.19. TENDERING NOTICE AND SCHEDULE (Tendering Notice)
(a)-(c)FERC Issue Tendering Notice and schedule and post in Federal Register and contact agencies and tribes directly (NLT 14 days after FLA filed)December 19, 2029
(Wednesday)1/2/2030 (Wednesday)2
(d)FERC Resolve requests for additional information gathering or studies made in comments on DLA or PLP (NLT 30 days after FLA filed)December 19, 2029
(Wednesday)1/17/2030 (Thursday)
18 C.F.R. § 5.20. DEFICIENT APPLICATIONS
(a)-(b)FERC HDR considers this section not applicable to City’s relicensing. The application will not be deficient.N/A N/A
18 C.F.R. § 5.21. ADDITIONAL INFORMATION
N/A FERC May issue additional information requests (AIR) (no specific timeline in regulation)Timeframe and AIRs determined by FERC
N/A City File additional information if directed by FERC (no specific timeline in regulation; FERC’s AIR sets filing due date)Timeframe and AIRs determined by FERC
18 C.F.R. § 5.22. NOTICE OF ACCEPTACE AND READY FOR ENVIRONMENTAL ANALYSIS (REA Notice)
(a)-(c)FERC
Issue notice that application is ready for environmental analysis, and requesting comments, protests and interventions, recommendation, preliminary terms
and conditions, and preliminary fishway prescriptions, and establishing date for final amendments to application, and updated schedule (no specific timeline in
regulation)
When FERC deems application is complete;
timeframe determined by FERC.
18 C.F.R. § 5.23. RESPONSE TO REA NOTICE
(a)Relicensing Participants File comments, protests and interventions, recommendation, preliminary terms and conditions, and preliminary fishway prescriptions NLT 60 days after REA Notice issued
As provided in 50 C.F.R., Part 221 (for NMFS) and other regulations for DOA or DOI land agencies, within 30 days of when mandatory conditioning agencies file preliminary terms and conditions and preliminary fishway prescriptions, the licensee and interested parties
may file with the mandatory conditioning agency a request for an evidentiary hearing on disputed material facts and/or alternative conditions. The Department’s regulations establish the procedures and timeframe.
(a)City & Relicensing Participants File reply comments NLT 105 days after REA Notice issued
(c)City File a Clean Water Act (CWA) § 401 water quality certification (WQC), or copy of request for WQC, or evidence of waiver of WQC (NLT 60 days after REA
Notice issued)NLT 60 days after REA Notice issued
WQC is covered under the CWA, not the FPA. In HDR’s experience, the State Water Resources Control Board (SWRCB) rarely waives the WQC and requires the Lead Agency, City in this case, comply with the California Environmental Quality Act (CEQA) before the SWRCB
issues the WQC, although if the SWRCB considers the 1-year statutory deadline for issuing a WQC to be in jeopardy, the SWRCB will issue WQC without CEQA compliance being complete. For this proposal, HDR assumes a Notice of Exemption (NOE) will be sufficient to
comply with CEQA.
31
Project Schedule
Subsection(s)Lead Activity 1
Lake Mendocino PP
Timeframe 2,3
(Start & Finish)
18 C.F.R. § 5.25. APPLICATIONS REQUIRING A DRAFT NEPA DOCUMENT
(a)-(b)FERC Issue draft environmental assessment (DEA) or draft environmental impact statement (DEIS) NLT 180 days after comments on REA Notice due
(c)City & Relicensing Participants File comments on DEA/DEIS NLT 30 or 60 days, as determined by FERC, after
FERC issues DEA/DEIS
(d)Mandatory Conditioning
Agencies File modified final terms and conditions, and final fishway prescriptions NLT 60 days after comments on DEA/DEIS due
Endangered Species Act (ESA) §7 consultation and National Historic Preservation Act (NHPS) §106 consultation are governed by the ESA and NHPA, as compared to the FPA. In HDR’s experience, FERC usually consults directly with NMFS and USFWS under ESA and with
SHPO and the Advisory Council under NHPA after FERC issues its DEA/DEIS. ESA consultation usually involves correspondence from FERC to NMFS and/or USFWS seeking concurrence on FERC’s conclusions regarding effects of the action on ESA-listed species. NMFS and/
or USFWS will issue a biological opinion if FERC concludes that the action is likely to adversely affect or result in Jeopardy for a species. In historic resources are associated with the action, FERC will develop and issue a programmatic agreement for execution between,
FERC, SHPO, and the Advisory Council. Given the lack of complexity and smaller footprints of City's projects, HDR assumes Section 7 and Section 106 Consultation will be minimal.
(e)FERC Issue final environmental assessment (FEA) or final environmental impact statement (FEIS)NLT 90 days after final terms and conditions and
final fishway prescriptions due
18 C.F.R § 5.26. SECTION 10(j) PROCESS
(a)Fish and Wildlife Agencies File section 10((j) fish and wildlife recommendations NLT 30 or 60 days, as determined by FERC, after
DEA/DEIS
(b)FERC May request written clarification of recommended fish and wildlife recommendation No specific timeline in regulation
(b)City & Relicensing Participants May file response to FERC’s request for clarification Ttimeframe as specified by FERC in request for
clarification
(b)FERC FERC include in DEA/DEIS preliminary determination of inconsistency (when FERC issues DEA/DEIS)NLT 180 days after comments on REA Notice due
(c)Fish and Wildlife Agencies May request meeting to resolve differences No timeframe in FERC regulations
(d)FERC If FERC decides to hold Section 10(j) meeting, provide notice to interested parties of Section 10(j) meeting NLT 15 days prior to Section 10(j) meeting
(d)FERC, City & Relicensing
Participants FERC hold Section 10(j) meeting NLT 90 days after FERC issues preliminary
determination of inconsistency
(d)FERC FERC issues summary of Section 19(j) meeting No timeframe in FERC regulations
(e)FERC FERC posts in Federal Register findings and statements required in FPA Section 19(j)(2)When FERC issues order granting or denying
license
ORDER ISSUING LICENSE
N/A FERC FERC Issues License March 2032
1 The activity description is a good faith effort to summarize the pertinent regulation. The reader is encouraged to read the specific regulation.
2 18 C.F.R. § 385.2007(a)(2) provides that if a filing date falls on a Saturday, Sunday or federal legal public holiday, the deadline for filing becomes the next business day.
3 When an activity is contingent on completion of a previous activity, the schedule assumes the previous activity is completed the latest date possible for that previous activity.
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
47
HDR has worked on over thirty (30) relicensings in California (see Figure 1), including those with many similarities to Lake
Mendocino PP, which allows us to accurately estimate the level of effort required to successfully deliver the project and also
identify the major tasks and milestones that need to be completed. HDR has outlined our approach to completing the project,
detailed several strategic approaches for how to do so more efficiently and cost effectively, and a provided a schedule based on
the City’s target filing dates, FERC deadlines, and HDR’s experience with these processes. HDR’s proposed hours and budget by
task are provided in Table A-1 with task specific budget assumptions following. As directed in the RFP, HDR’s single page Rate
Sheet is provided as Table A-2.
H. Fee Proposal (Including Rate Sheet and Assumptions)
TASK DESCRIPTION ESTIMATED HOURS BUDGET
1 Project Management and Coordination with City 684 $169,000
2 NOI, PAD, and TLP Request 813 $148,000
3 Consultation and Meetings (non-Section 106) 108 $27,000
4 Develop and Conduct Studies 260 $58,500
5 Respond to Comments and Dispute Resolution 97 $22,500
6 Section 106 Consultation 170 $32,000
7 Draft License Application 438 $82,000
8 Final License Application 281 $53,000
9 FERC’s NEPA Process 211 $46,500
10 Water Quality Certification including CEQA NOE 102 $25,500
TOTAL 3,164 $664,000
11 Optional Project Contingency (~20%)N/A $130,000
TOTAL WITH CONTIGENCY TBD $794,000
Table 3: Budget Estimate
Task Contingency Budget
HDR’s proposal provides a detailed scope, schedule, and budget (including
assumptions) for the City’s consideration. We feel many of the tasks can
be budgeted with decent clarity based on FERC’s requirements and HDR’s
extensive experience. However, HDR also recognizes that parts of FERC
relicensing can be somewhat unpredictable with the potential to significantly
impact overall costs. For the Lake Mendocino PP relicensing, HDR sees two
major areas where additional costs could be incurred if certain assumptions are
incorrect: field studies and post-FLA activities. Regarding field studies,
HDR has proposed targeted studies to fill data gaps and mitigate the need for
additional (and often more expensive) studies. However, resource agencies
may request additional studies and engage in formal study dispute (even if
unlikely), which could lead FERC to directing the City to complete additional
studies. In addition, the City may identify additional studies it chooses to
complete as it prepares the PAD and other relicensing documents if the data
may benefit the City’s relicensing strategy. Post-FLA activities can be difficult
to budget since the complexity and schedule of those activities may be driven
by the outcomes in relicensing leading up to the FLA filing over four years.
The post-FLA schedule is also less defined and driven by FERC staff workloads
and other agency actions. Finally, as part of the required WQC, the City will
complete CEQA, which HDR assumes may be satisfied with a NOE, based
on the current understanding of the project and today’s CEQA guidelines. If
the project or regulatory landscape changes prior to initiating CEQA, a more
expensive CEQA process may be needed (e.g. Mitigated Negative Declaration
or Environmental Impact Report).
To assist the City in planning for these uncertainties, HDR recommends the
City consider a contingency task with a budget of 15 to 20 percent of the
total estimated relicensing cost. This budget could be included as part of
the initial contract award or held by the City until a change in the project
warrants a contract change order. Regardless, the City has planned for some
additional expenditures should they arise. The contingency budget would not
be utilized without prior approval by the City and tracked using a “change log”
or moving the contingency budget into existing tasks where needed. HDR has
successfully used this approach with several relicensing clients and finds it
strikes a balance between firm budget planning and the flexibility often needed
during relicensing.
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
48
TASK DESCRIPTION FY26
(07/01/25)
FY27
(07/01/26)
FY28
(07/01/27)
FY29
(07/01/28)
FY30
(07/01/29)
FY31
(07/01/30)
FY232
(07/01/31)TOTAL
1 Project Management and Coordination w/ City $ 13,520.00 $ 28,730.00 $ 28,730.00 $ 28,730.00 $ 28,730.00 $ 28,730.00 $ 11,830.00 $ 169,000.00
2 NOI, PAD, and TLP Request $ 51,800.00 $ 96,200.00 $ -$ -$ -$ -$ - $ 148,000.00
3 Consultation and Meetings (non-Section 106)$ - $ 6,750.00 $ - $ 13,500.00 $ 6,750.00 $ -$ - $ 27,000.00
4 Develop and Conduct Studies $ 20,475.00 $ 38,025.00 $ -$ -$ -$ -$ - $ 58,500.00
5 Respond to Comments and Dispute Mtgs.$ - $ 11,250.00 $ -$ - $ 11,250.00 $ -$ - $ 22,500.00
6 Section 106 Consultation $ - $ 8,000.00 $ 8,000.00 $ - $ 8,000.00 $ 8,000.00 $ - $ 32,000.00
7 Draft License Application $ - $ - $ 24,600.00 $ 57,400.00 $ -$ -$ - $ 82,000.00
8 Final License Application $ - $ -$ - $ 13,250.00 $ 39,750.00 $ -$ - $ 53,000.00
9 FERC’s NEPA Process $ - $ -$ -$ - $ 11,625.00 $ 23,250.00 $ 11,625.00 $ 46,500.00
10 Water Quality Certification incl. CEQA NOE $ - $ -$ -$ -$ - $ 19,125.00 $ 6,375.00 $ 25,500.00
TOTAL $ 85,800.00 $ 189,000.00 $ 61,300.00 $ 112,900.00 $ 106,100.00 $ 79,100.00 $ 29,800.00 $ 664,000.00
Table 4 provides HDR’s estimated annual fiscal year cashflow for the project duration based on the assumptions and schedule provided in the proposal.
Table 4: Estimated Annual Fiscal Year Cashflow
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
49
Budget Assumptions
HDR made two major assumptions for its cost proposal:
1.FERC will approve the request to use the TLP.
2.The contract is issued in November 2025 and goes through
December 2031, when post-FLA activities will be concluded.
Task 1 - Project Management and Meetings
1.Except for the initial kickoff meeting, PM check-in meetings
will be held virtually via Microsoft Teams.
2.Up to 60 1-hr PM check-in meetings will be held throughout
the Project, with an additional 1-hr per meeting for the APM
to prepare the agenda and meeting minutes, at the timing
described under Project Management.
3.The PM and APM will attend each 60 check-in meetings.
4.One City Council meeting will be attended virtually by the PM
and APM.
5.HDR will maintain an internal SharePoint site accessible to
HDR and City staff.
6.The City will design, update, troubleshoot, and upload all
necessary documents to its own website, which will be used to
host required public information.
Task 2 - Prepare and File NOI, PAD, and TLP
request
1.Draft NOI and TLP request will be provided to the City on the
HDR-hosted SharePoint site.
2.The City will provide one consolidated round of review in Track
Changes to NOI and TLP request on the SharePoint site.
3.The City will provide one consolidated round of review
in Track Changes to the final NOI and TLP request on the
SharePoint site.
4.The City will reimburse HDR for the costs of
newspaper notices.
5.Draft PAD sections will be provided to the City on the
HDR-hosted SharePoint site.
6.The City will provide one consolidated round of review in Track
Changes to PAD sections on the SharePoint site.
7.A complete PAD will be provided for City review
on SharePoint.
8.The City will provide one consolidated round of review in Track
Changes to the final PAD on the SharePoint site.
9.Final NOI, PAD, and TLP request will be posted on the
City’s website.
10.No paper copies of the PAD will be required, and the City will
reimburse HDR for the cost of materials and postage should
copies of the document on DVD be required.
Task 3 - Mandatory Consultation and
Meetings (non-Section 106)
1.Up to two virtual, 1-hour informal Section 7 consultation
meetings will be held with USFWS.
2.Up to two virtual, 1-hour informal Section 7 consultation
meetings will be held with NMFS.
3.Section 106 Consultation meetings are covered in Task 6.
4.A joint Agency Meeting and site visit will be held.
5.The City will support access for the site visit.
6.HDR PM and APM will attend site visit and Joint Meeting, and
the Senior FERC Advisor will attend the Joint Meeting virtually.
7.Up to two virtual, 1-hour Relicensing Participant meetings will
be held to develop PM&E measures for inclusion in the DLA.
Task 4 - Develop and Conduct Studies
1.FERC will not direct the City to conduct additional studies.
2.The City will provide access to the project site.
3.No research trips to archival repositories will be necessary.
4.No cultural resource permits other than Archaeological
Resource Protection Act permit issued by the USACE will
be required.
5.No more than one previously unrecorded archaeological
resource will be identified during the field survey at each
project site.
6.The City will reimburse HDR for field equipment costs
for studies and laboratory fees associated with water
quality analysis.
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
50
Task 5 - Respond to Comments and Dispute
Resolution
1. Up to five PAD comment letters will be received for
the project.
2. There will be no formal study dispute requests.
3. The meeting to resolve differences (if required) is included in
Task 3.
Task 6 - Section 106 Consultation
1. No additional records search from the California Historical
Resources Information System will be necessary for the
cultural or Tribal resources analysis as part of the development
of the DLA.
2. Up to two consultation meetings with Native American Tribes
will be necessary.
3. Consultation with Native American Tribes will not identify
Traditional Cultural Properties, Traditional Cultural
Landscapes, or Tribal Cultural Resources requiring further
analysis, assessment, or evaluation.
4. No adverse effects on historic properties are anticipated, so
additional steps will not be needed.
5. No Historic Properties Management Plan will be necessary.
Task 7 - Draft License Application
1. Draft DLA sections will be provided to the City on the HDR-
hosted SharePoint site.
2. The City will provide one consolidated round of review in track
changes to DLA sections on the SharePoint site.
3. A complete DLA will be provided for City review
on SharePoint.
4. The City will provide one consolidated round of review in track
changes to the final DLA on the SharePoint site.
5. Final DLA will be posted on the City’s website and posted to
the FERC eLibrary.
6. No paper copies of the DLA will be required, and the City will
reimburse HDR for the cost of materials and postage should
copies of the document on DVD be required.
7. A Supporting Design Report will not be necessary for the DLA.
8. The City will provide known updated information for resources
covered in the PAD that should be included in the DLA.
9. No additional field work is anticipated for the development of
the DLA.
Task 8 - Final License Application
1. Draft FLA sections will be provided to the City on the
HDR-hosted SharePoint site.
2. The City will provide one consolidated round of review in track
changes to FLA sections on the SharePoint site.
3. A complete FLA will be provided for the City’s review on
the SharePoint.
4. The City will provide one consolidated round of review in Track
Changes to the final DLA on the SharePoint site.
5. Final FLA will be posted on the City’s website and posted to
the FERC eLibrary.
6. No paper copies of the FLA will be required, and the City will
reimburse HDR for the cost of materials and postage should
copies of the document on DVD be required.
7. The City will reimburse HDR for costs of newspaper notices.
Task 9 - FERC’s NEPA process and
Additional Information Requests
1. FERC AIR’s will not include additional fieldwork or modeling,
but will be clarifying in nature.
2. FERC will not hold an in-person NEPA scoping meeting or Site
Visit (consistent with recent TLP proceedings).
3. FERC will not order the City to conduct additional studies.
4. FERC’s 10(j) meeting will be virtual.
5. Draft NEPA responses, including REA comments and draft EA
comments, will be provided to the City on the HDR-hosted
SharePoint site.
6. The City will provide one consolidated round of review in Track
Changes to NEPA responses on the SharePoint site.
Task 10 - Water Quality Certification and
CEQA
1. The pre-application meeting with the SWRCB will be virtual.
2. A CEQA NOE will be the appropriate level of environmental
review for the proposed projects, and the City will be the Lead
Agency for the CEQA NOE.
3. The City will be responsible for filing the NOE and
supplemental information package and paying all applicable
CEQA filing fees with the County Clerk-Recorder’s office.
4. Draft WQC application and CEQA NOE will be provided to the
City on the HDR-hosted SharePoint site.
5. The City will provide one consolidated round of review in
Track Changes to draft CEQA NOE and WQC application on the
SharePoint site.
City of Ukiah | Lake Mendocino Hydroelectric Relicensing
51
Rate Sheet
CATEGORY 1 2025 - 2029 2
FERC PM / Advisors $300.00 - $450.00
Chuck Vertucci*$372.06
Devin Malkin*$313.63
Elizabeth Dawson*$428.55
Sr. Technical Staff $230.00 - $340.00
Ian Cain*$235.29
Matt Paquette*$268.04
Norm Ponferrada*$332.07
Danielle Risse*$276.63
Kelly MacVane $234.40
Technical Staff $130.00 - $230.00
Kaden Emerson $130.71
Anna Claubaugh $206.43
Eliza Schlein $198.26
Kamil Rochon $144.68
Michelle Sandmann $165.62
GIS / Data Solutions $120.00 - $215.00
Kier Keightley*$202.44
Angela Tang $131.54
Admin / Accounting $100.00 - $180.00
Jacare Palmer $178.65
Jordyn Texley $161.59
Tyler Miller $112.91
Table 5: Rate Sheet
LEGEND
1 Additional staff will be added within rate categories as needed
2 Rates will be escalated after 2029 through discussions with the City
*Indicates key personnel