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NPDES Permit Negotiations
RBI is a leader in the area of NPDES permitting for municipal wastewater treatment plants. We assist clients throughout the state in negotiating both new and renewed NPDES permits. RBI brings current science into the NPDES permitting process, and identifies opportunities to update and refine water quality standards for specific water bodies as a means of cost-effectively resolving significant permit compliance issues. We also specialize in assisting clients with resolving self-monitoring data problems and trace metal compliance issues, which includes conducting site-specific water-effect ratio studies. RBI is uniquely qualified to prepare water quality and aquatic biological resources chapters for environmental impact reports prepared for new or expanded wastewater treatment plants. |
CEQA/NEPA Environmental Documentation
RBI has extensive expertise and experience in preparing CEQA and NEPA chapters addressing potential project impacts to terrestrial and aquatic biological resources, water quality, and hydrology/water supply. RBI staff’s combination of high-level technical knowledge and CEQA/NEPA understanding and experience make them uniquely qualified to address project impacts to these resource categories. As such, RBI is called upon by other CEQA/NEPA consulting firms to prepare chapters for these resource categories. In addition, RBI is experienced is preparing initial studies and mitigated declarations to meet clients’ CEQA needs for smaller projects. |
FERC Hydroelectric Licensing
The FERC (Federal Energy Regulatory Commission) relicensing process is complex, with environmental, engineering, and economic elements. Relicensing is a public process that usually takes about five years from planning to granting of the license. It requires a comprehensive evaluation of a wide variety of issues and involves as many as 20 regulatory agencies. Successfully completing the relicensing process involves identifying and resolving project issues in consultation with the many federal and state resource agencies, as well as stakeholders—local and national non-governmental organizations, home and boat owner associations, and individuals who have an interest in the project. RBI worked with clients to develop a scope of environmental studies that satisfied agency requirements. RBI directed interaction with large agency and public stakeholder groups for multiple biological issue areas. We managed development and implementation of study plans, including vegetation communities, riparian, invasive/exotic plant species, special-status plant and wildlife species, as well as amphibians and reptiles, raptors, and other game.
California’s estuaries, rivers, and streams provide habitat for a variety of endangered and threatened fish species, including spring- winter-run chinook salmon, steelhead, coho salmon, green sturgeon, and Delta smelt. Many projects have the potential to adversely affect these species and their habitat, requiring consultation with NOAA Fisheries and USFWS to determine and minimize the potential impacts. RBI’s biologists have extensive experience in conducting informal and formal consultation with these agencies, including the preparation of biological assessments and evaluations. RBI has earned a reputation of providing high-quality work amongst its clients and agency biologists by maintaining an objective approach that relies on the current scientific understanding of special-status fish species. |
State and Federal ESA Consultations
California’s estuaries, rivers, streams, and creeks provide habitat for a variety of endangered and threatened fish species, including spring-run and winter-run chinook salmon, steelhead, coho salmon, green sturgeon, and Delta smelt. Many projects have the potential to adversely affect these species and their habitat, and require consultation with NOAA Fisheries and USFWS to determine and minimize the potential direct and indirect impacts. RBI’s biologists have extensive experience in conducting informal and formal consultation with these agencies, including the preparation of biological assessments and evaluations to ensure that the project does not jeopardize the existence of a listed species.
RBI’s biologists conduct reconnaissance surveys to characterize the biological resources onsite and habitat use to ensure that potential impacts are fully described. Special attention is given to survey areas that could support special-status habitats and species. Based on review of existing documentation, and field reconnaissance and analysis, RBI biologists prepare detailed impact analyses and develop appropriate mitigation measures to avoid, minimize, or eliminate the potential adverse impacts on listed species. RBI has earned a reputation of providing high-quality work amongst clients and agency biologists by maintaining an objective approach that relies on a sound scientific understanding of special-status species, their habitats, and how the proposed project could affect them. |
Wetland and Jurisdictional Waters Permitting
RBI’s regulatory specialists strive to streamline the permitting process for projects involving work in jurisdictional water bodies and wetlands as the permit processes can involve multiple agencies and complex state and federal resource protection regulations. Construction activity that results in fill of Waters of the United States requires a Section 404 permit from the USACE. In California, a condition of the Section 404 permit is the acquisition of a Section 401 CWA Water Quality Certification from the RWQCB. A Fish and Game Code Section 1600 Streambed Alteration Agreement is typically required from CDFG. In addition, dredging and construction within a navigable Water of the U.S. requires a Section 10 permit from USACE. Construction activities in water bodies also may require authorization from one or more state and local agencies such as the State Lands Commission, Reclamation Board, local Reclamation District, or other special districts.
RBI staff have long-term productive relationships with the agencies that implement the permitting processes. The major permit compliance procedures that RBI can lead include:
Wetlland Delineations: A Wetland Delineation is an ecological field study that locates the wetland-upland boundaries and requires a detailed analysis of the soil, vegetation, and water, using methodology proscribed in the U.S. Army Corps of Engineers 1987 Wetland Delineation Manual. A jurisdictional wetland delineation report is typically submitted to USACE to begin the Section 404/10 permit process. A jurisdictional delineation report summarizes the methodology, existing conditions, and findings. RBI often coordinates and attends field verification meetings with USACE representatives.
Section 404 and Section 10 CWA Permits: RBI is experienced preparing applications for Nationwide and individual Section 404 permits. RBI recommends early coordination with the regulatory agencies through initial planning meetings where multiple agencies are invited to discuss project effects on sensitive resources, identify regulatory issues, develop the permit strategy and schedule, and determine mitigation/enhancement requirements. RBI is experienced at developing compensatory mitigation proposals to offset permanent loss of the functions and values of Waters of the U.S. RBI also closely coordinates with the USACE to ensure that the permit application materials are complete and technically accurate, and tracks the progress of the permit application to meet client schedules.
Section 404 Wetlands Mitigation Monitoring Plan (MMP). RBI can prepare formal MMPs in conformance to the USACE guidelines. An MMP includes a characterization of the types, functions, and values provided by habitats at the site and the mitigation goals. The MMP also includes descriptions of proposed restoration activities, including site preparation and protection measures, a plant palette and detailed planting plan, proposed maintenance activities, and a monitoring plan outlining the final success criteria for the restored areas, target jurisdictional acreage to be created, performance criteria and monitoring methods, and any contingency remedial actions. The MMP is submitted to the USACE as part of the Section 404 application.
Section 401 Water Quality Certification. Federal law requires submittal of an application to the RWQCB for Water Quality Certification for projects involving the discharge of dredged or fill material into Waters of the U.S. The purpose of these certifications is to ensure that the project will not violate state and federal water quality standards. For a typical project, RBI can efficiently develop a request letter and permit application for the RWQCB based on the clients project description, identified construction techniques, and methods to minimize or avoid excessive erosion, turbidity, and other adverse water quality effects.
Section 1600 Streambed Alteration Agreement. DFG has jurisdiction over the plant, fish, and wildlife resources of the state. Projects that involve diversion or obstruction to the natural channel flow or substantial changes to the bed, channel, or bank of any river, stream, or lake designated by DFG, or use of any material from a lakebed must first notify DFG and request a Streambed Alteration Agreement. This requirement typically applies to all activities undertaken within the 100-year floodplain and within the ordinary high water mark of water bodies that contain or once contained fish and wildlife, or supports or once supported riparian vegetation. RBI is experienced at preparing the application for Section 1600 SAA. RBI closely coordinates with DFG to track permit progress and ensure that the permit application materials are complete. |
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