AMD_2_-_ATT_1__Q_and_A_in_Response_to_Sol_Incorporated_into_the_Solicitation_0002.pdf
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- Attached to
- D-B North Fume Replacement, Sacramento NWR
- Solicitation number
- 140FGA26R0001
About this file
This document is a Questions and Answers (Q&A) response to Solicitation No. 140FGA26R0001, Amendment #2 for Design-Build Services for North Flume Replacement at Sacramento National Wildlife Refuge. The project involves designing and constructing a replacement flume pipe crossing Logan Creek with a minimum conveyance capacity of 30 cubic feet per second (cfs). The overall period of performance is 24 months, with the design and permitting phase (35% completion) due within 12 months from Notice to Proceed, and the construction phase to be completed within 12 months from design completion and acceptance. The estimated project magnitude is $500,000 to $1,000,000 for the entire design-build effort, covering design, permitting, and construction. The new flume structure must be designed for a minimal 50-year service life using fire-resistant corrugated metal pipe (CMP) or equivalent materials meeting design performance requirements.
The contractor bears full responsibility for determining and acquiring all necessary permits, including Section 404, Section 401, and Streambed Alteration Agreements, and must provide proof of permit applications or contact attempts with regulatory agencies. Excavation and ground-breaking activities are restricted to May 1 through October 31. The Government will provide a Categorical Exclusion (Cat Ex) and Section 7 Biological Opinion but will not provide geotechnical data, subsurface investigations, survey control points, or as-built drawings; contractors must conduct independent investigations and clearly state assumptions in proposals. Schedule delays caused by regulatory agency review timelines may qualify for period of performance adjustments at no additional cost to the Government upon documented request to the Contracting Officer. Contractors are responsible for site dewatering, temporary conveyance methods, equipment removal and off-site disposal of excavated materials, and establishing project control. FAR 52.236-2 applies for differing site conditions, and maintenance of contractor pricing is required even if permit timelines are delayed due to factors outside their control.
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Design-Build Services North Flume Replacement Questions in Response to the Solicitation
Solicitation NO. 140FGA26R0001 Amendment #2
Question 1: Can you please confirm what form should be used for sending the PPQ to clients for past project experience?
Answer: No standardized form. You may use whatever form/template you have. Ensure it covers all the required information that is typically asked for within the PPQ. Attached is a PPQ template if needed.
Question 2: Section L of the solicitation includes directions for phase 1 and phase 2 of the solicitation process. Please confirm that the key personnel and price portions are not to be included in the contractor’s submission.
Answer: Only submit phase 1 information/documentation. As outlined on page 48 of the solicitation, do not submit phase 2 information with phase 1 submission. Phase 2 includes evaluation factor 3-key personnel and evaluation factor 4-price, and executed bid guarantee.
Only firms selected to continue to phase 2 shall submit phase 2 information/documentation.
Question 3: The performance period that is included in the Statement of Work states that Design and permitting phase shall be completed and approved within six (6) months from NTP. Because the work would be within Waters of the U.S./State, a Nationwide Permit from the Army Corps of Engineers and a Water Quality Certification from the regional Water Board would be required. The Water Quality Certification turnaround time is a minimum of 120 days when factoring in the pre-application notification period, review periods, etc. The 35% plans and a stable project description will be required to be completed by the selected A-E before submitting these applications because we need to nail down the impact footprint to Waters of the U.S./State.
Answer: Refer to updated SOW Section 1.1 Period of Performance. “The overall period of performance is 24 months. 35% Design and permitting phase (Task 1-3) shall be completed and approved within twelve (12) months from NTP. Construction/build phase shall be completed within twelve (12) months from completion and acceptance of Task 1-3…”
Delays associated with regulatory agency review timelines may be considered for period of performance adjustment, the contractor may submit a documented request to CO for consideration.
Question 4: Could the Sacramento National Wildlife Refuge provide a copy of the SNWR Biological Opinion?
Answer: We would be able to provide a BO.
Question 5: Has a cultural resources survey of the North Flume area been completed? The Nationwide Permit typically requires a cultural resources survey of the project area.
Answer: Technically, on refuge ground, we are covered under our programmatic documents in our CCP. All we would need for NEPA should be a Cat Ex, which USFWS can complete.
Solicitation NO. 140FGA26R0001 Amendment #2
Question 6: Will permits be completed prior to the completion of the Categorial Exclusion document?
Answer: To be determined.
Question 7: The SOW indicates that USFWS will conduct preconstruction surveys for Giant Garter Snake (GGS). Please confirm whether the contractor will be required to provide a qualified biological monitor during ground-disturbing activities, or if monitoring services will be provided by USFWS.
Answer: Biological monitoring is not required as part of this contract, monitoring will not be provided by USFWS. The Sacramento NWR reserves the right to provide monitor for construction activities if deemed necessary. The Refuge staff can conduct a pre-construction survey as added precaution.
Question 8: The SOW notes that excavation must occur between May 1 and October 31. Please confirm whether this restriction applies to all earthwork activities or only work occurring within aquatic habitat or wetted areas.
Answer: All ground-breaking activities.
Question 9: Please provide the design flow rate (CFS) or other hydraulic design criteria that must be met by the replacement flume to ensure adequate conveyance capacity.
Answer: The flume pipe requires a minimum conveyance of 30 cfs.
Question 10: Are as-built dimensions, hydraulic capacity data, or additional drawings available for the existing flume to assist with design development and capacity verification?
Answer: There are no other as-builts, data, or additional drawings other than what was attached to the solicitation.
Question 11: Is any geotechnical or subsurface investigation data available for the project site (e.g., soil borings, groundwater conditions, soil resistivity)? If so, please provide.
Answer: There is no subsurface investigation data available for the project site, unforeseen requirements should be reported to CO in a timely manner. State assumption clearly in proposal.
Question 12: During construction, will USFWS shut down or dewater the canal, or will the contractor be required to provide a temporary method of conveyance to maintain water deliveries past the work area (such as bypass pumping, temporary diversion piping, or other conveyance method)?
Solicitation NO. 140FGA26R0001 Amendment #2
Answer: Reference SOW Sec 1.2.3 “Areas that require dewatering and can be dewatered will remain dry for a minimum of two (2) weeks prior to construction. Any dewatered habitat will remain dry for at least 15 consecutive days prior to excavating or filling of the dewatered habitat.”
Question 13: The SOW indicates that the contractor is responsible for permitting support. Please confirm which permits are anticipated (e.g., USACE Section 404, RWQCB Section 401, CDFW Streambed Alteration Agreement).
Answer: It is the contractor's responsibility to determine and acquire all necessary permits.
Contractor must also provide permits or proof of attempt to contact regulatory agency.
Question 14: Has Section 106 cultural resource review already been completed for the project area, or should the contractor assume that cultural resource surveys may be required during the design phase?
Answer: Assume “No Potential to Cause Effects (NPTCE) finding” and Cultural Resource review complete. USFWS to provide written confirmation, unforeseen requirements should be reported to CO in a timely manner. State assumption clearly in proposal.
Question 15: Please confirm whether nesting birds or other protected avian species within the refuge may impose seasonal construction restrictions. Specifically, are nesting bird surveys required, what are the limits of those surveys, and will the known nesting pair of bald eagles within the refuge impose any work restrictions or buffer zones affecting this project?
Answer: This location would not require a nest survey and the project is also not with a disturbance buffer zone of current eagle nests.
Question 16: Will the Government provide survey control points or existing survey data for the project area, or should the contractor assume responsibility for establishing project control?
Answer: Contractor shall assume responsibility for establishing project control, assume no existing survey data. Reference SOW Task 1.
Question 17: The contractor understands that environmental permitting timelines can vary significantly and may be subject to agency review periods outside the contractor’s control. If required permits are delayed beyond the planned construction period of performance despite timely submission and coordination by the contractor, please confirm whether liquidated damages would apply under those circumstances, or whether schedule adjustments would be granted for delays attributable to regulatory agency review.
Answer: Refer to updated SOW Section 1.1 Period of Performance. “The overall period of performance is 24 months. 35% Design and permitting phase (Task 1-3) shall be completed and
Solicitation NO. 140FGA26R0001 Amendment #2 approved within twelve (12) months from NTP. Construction/build phase shall be completed within twelve (12) months from completion and acceptance of Task 1-3…”
Delays associated with regulatory agency review timelines may be considered for period of performance adjustment, the contractor may submit a documented request to CO for consideration.
Question 18: The RFP requires completion of design and environmental permitting within approximately six (6) months of NTP. If the Contractor demonstrates due diligence but agency reviews, interagency coordination, signature routing, or third-party approvals extend beyond this period, how will schedule impacts be addressed?
Answer: Refer to updated SOW Section 1.1 Period of Performance. “The overall period of performance is 24 months. 35% Design and permitting phase (Task 1-3) shall be completed and approved within twelve (12) months from NTP. Construction/build phase shall be completed within twelve (12) months from completion and acceptance of Task 1-3…”
Delays associated with regulatory agency review timelines may be considered for period of performance adjustment, the contractor may submit a documented request to CO for consideration.
Question 19: Will delays associated with regulatory agency review timelines (e.g., USACE, CDFW, RWQCB, SHPO, USFWS internal reviews) qualify for schedule extensions without liquidated damages or default risk?
Answer: Yes, as long as the delay is not due to the contractor. Delays associated with regulatory agency review timelines may be considered for period of performance adjustment, the contractor may submit a documented request to CO for consideration.
Question 20: Is there a defined review duration for Government submittal reviews (35%, 65%, 100%)? If review periods exceed anticipated durations, will the schedule be equitably adjusted?
Answer: Yes, as long as the delay is not due to the contractor, a no-cost extension will be considered by the CO. 14 day maximum, for government review period on major submittals.
Question 21: Does the Government anticipate any known permitting constraints or coordination challenges that could impact the 6-month milestone (whether positively or negatively)?
Answer: No, but the USFWS will consider such delays for period of performance adjustment, if the contractor is not causing the delay.
Solicitation NO. 140FGA26R0001 Amendment #2
Question 22: The project is located on Federal property. Please confirm whether CEQA compliance is not required and whether NEPA coverage has already been completed or will be provided by the Government.
Answer: Refer to answer on question 5. NEPA Cat Ex. To be completed by USFWS. It is the contractor's responsibility to verify and acquire other necessary permits. CEQA compliance check is the contractor’s responsibility, contractor must also provide permits or, at a minimum, proof of attempt to contact regulatory agency.
Question 23: If additional environmental studies (e.g., biological assessments, cultural surveys, jurisdictional delineations, wetland mitigation plans, groundwater investigations) are required beyond what is reasonably inferable from the RFP, how will compensation and schedule be addressed?
Answer: Handled via a change order if the CO approves. The CO will issue a RFP to the contractor for the change order. If the proposal for the change is determined to be fair and reasonable, the CO may issue a change order modification. State your assumptions clearly in your proposal.
Question 24: The creek is described as jurisdictional waters of the State, while the canal is not.
Please clarify the anticipated permitting pathway (e.g., Section 404/401, Streambed Alteration Agreement) and whether any programmatic permits apply.
Answer: It is the contractor's responsibility to determine and acquire necessary permits.
Contractor must also provide permits or proof of attempt to contact regulatory agency.
Question 25: During the pre-bid meeting, a programmatic document covering maintenance activities was referenced. How does this programmatic document apply to this design-build replacement project, and may it be relied upon for environmental coverage?
Answer: Our programmatic CCP and BO covers maintenance activities and construction on existing refuge infrastructure.
Biological Opinion Implementation: “Projects and activities covered under this opinion are those that involve day-today management of the Sacramento NWRC. Such activities include habitat manipulation and restoration, modifications to existing structures, repair and maintenance of levees, roads, trails, unities, etc.”
Question 26: What is the anticipated groundwater elevation during the typical construction window? Are any geotechnical or hydrogeologic reports available for the area?
Answer: Unknown, all information currently available for the site has been provided in solicitation attachments.
Solicitation NO. 140FGA26R0001
Question 27: What are the specific periods during which the canal will be dewatered or dry?
Answer: Canal will be as dry as possible during the summer field / construction period. That said, there is subbing that occurs from neighboring agricultural activities that are outside of Refuge control. Canal will be dry May 1 and the canal would need to be re-charged approximately in September.
Question 28: What is the maximum allowable duration for canal shutdown prior to and during construction to allow site drying and safe access?
Answer: Refer to answer on question 12.
Question 29: Will the Government provide written confirmation of allowable flow constraints (up to 30 cfs noted during site visit)?
Answer: See answer to question 9.
Question 30: Is temporary bypass pumping or flow diversion (creek and/or canal) anticipated to be Contractor responsibility? If so, are performance criteria available?
Answer: Canal will be dry, Logan Creek will have some flow. Any groundwater pumping (excavation water table) or diversion would be the responsibility of the contractor.
Question 31: Please confirm that the CMP crossing and bypass gate with stoplogs may occupy the same geographic location and orientation as observed in the field.
Answer: Confirmed.
Question 32: Are there specific hydraulic performance criteria (beyond matching existing 30 cfs capacity) that must be met in the final design?
Answer: Structure shall be designed to provide a minimal service life of 50 years, resist forces from variable flows, prevent deterioration and decrease maintenance.
Question 33: Who is responsible for regulatory agency application fees, permit fees, mitigation fees, and utility company review fees? Should these be included in the lump sum proposal?
Answer: Contractor is responsible for determining and acquiring required permits, state assumptions in proposal. Contractor must also provide permits or proof of attempt to contact regulatory agency. Contractor may provide permitting costs as Lump Sum Task No. 3 on Bid Schedule.
Solicitation NO. 140FGA26R0001 Amendment #2
Question 34: If required environmental mitigation (e.g., credits, restoration planting, off-site mitigation) is identified after award, how will that cost be handled?
Answer: Handled via a change order if the CO approves. The CO will issue a RFP to the contractor for the change order. If the proposal for the change is determined to be fair and reasonable, the CO may issue a change order modification. State your assumptions clearly in your proposal.
Question 35: Given that this is a lump sum design-build contract, how should proposers account for unknown environmental study requirements that cannot reasonably be defined pre-award?
Answer: Refer to answer on question 34.
Question 36: Is the Project Engineer (Designer of Record) required to attend bi-weekly project status meetings throughout construction, or may attendance be virtual or limited to specific milestones?
Answer: Not required to attend bi-weekly meetings but may attend as needed.
Question 37: What level of Government participation is anticipated during design development (e.g., recurring coordination meetings, site visits, stakeholder meetings)?
Answer: As needed or requested by contractor. “The Contractor will hold bi-weekly project status update meetings during design and permitting following the project kick-off meeting. The Contractor is responsible for the preparation and distribution of the agenda, meeting minutes, and action item list.” Reference SOW Sec 2.1
Question 38: Are any geotechnical borings, subsurface utility investigations, or hazardous materials assessments available to proposers? We understand this is a design-build, but we also need to know the expectations of project-specific level of effort being requested.
Answer: No
Question 39: If differing site conditions are encountered (e.g., undocumented utilities, high groundwater, unsuitable soils), will FAR 52.236-2 apply in the standard manner for equitable adjustment?
Answer: Yes, FAR 52.236-2 will apply.
Question 40: Are there known contaminated soils, asbestos-containing materials, or hazardous constituents associated with the existing flume structure?
Solicitation NO. 140FGA26R0001 Amendment #2
Answer: No, please report any unforeseen safety hazards to CO immediately upon discovery, state assumption clearly on proposal.
Question 41: Section H.3.1 states no additional monetary compensation will be provided for environmental suspension of work. Please clarify whether schedule extensions will be granted for such suspensions.
Answer: Yes, schedule extensions may be considered with documented proof of unforeseen delay, also refer to answer on question 3.
Question 42: During fire danger season, endangered species restrictions, or weather delays, will contract time be equitably adjusted?
Answer: If delays occur due to reasons outside the contractor’s control, a no-cost extension may be considered by the CO and possibly granted.
Question 43: Has any additional design development or design intent been completed since the project was last advertised in April 2025?
Answer: No.
Question 44: Has a design team been selected through any other procurement method or advertisement?
Answer: This is a design-build project. The awarded contractor must have their own design team.
Question 45: Can USFWS provide the assumed or desired elevations for the proposed structure(s)?
Answer: To be determined/calculated by contractor during design.
Question 46: Please provide the required material type for the new flume pipe (e.g., aluminum, steel, corrugated metal, etc.). Currently we are assuming Fire resistant coated CMP.
Answer: Correct, fire-resistant corrugated metal pipe (CMP) minimum, but contractor may propose materials of similar performance meeting design requirements on SOW.
Question 47: Please provide the expected diameter of the new flume pipe crossing Logan Creek.
Solicitation NO. 140FGA26R0001 Amendment #2
Answer: Contractor shall calculate and determine size for design and construction.
Question 48: Is there a Geotechnical report/borings, or will a new Geotechnical report/borings be needed?
Answer: No geotechnical reports available or needed.
Question 49: Is there intent that the Hydraulic model provided in the Master Plan be relied upon for design or is a new hydraulic model needed?
Answer: Independent hydraulic model for the North Flume will be needed. The existing model can be referred to but designer needs to verify and update as needed.
Question 50: The SOW requires the contractor to design the flume but does not provide: Base Flow, Peak Flow, Seasonal Variability, Groundwater elevations, or possible Subbing from adjacent farming. Can USFWS provide this hydrologic data?
Answer: To be determined/calculated by contractor during design.
Question 51: Please provide a copy of the sign-in sheet from the 3/3/2026 site visit.
Answer: The sign-in sheet will not be released. This is an internal document.
Question 52: Please clarify the quantity and limits of concrete structure removal required under this contract.
Answer: As needed to meet requirements on SOW, assume all concrete spoils must be hauled and properly disposed.
Question 53: Can USFWS provide a marked-up or highlighted drawing showing the intended demolition limits?
Answer: Demolition limits are to be determined during design by contractor.
Question 54: What is the anticipated depth of the new barrier wall below the existing structure, should this approach be used to address leakage issues?
Answer: To be determined/calculated by contractor during design.
Solicitation NO. 140FGA26R0001 Amendment #2
Question 55: Backfill, CLSM, and Embankment Protection-
a) Will Controlled Low-Strength Material (CLSM) be required to mitigate future piping or undermining beneath the new structure(s)? If so, please provide the assumed elevations for CLSM placement.
b) Will riprap be required for embankment stabilization adjacent to the new concrete structure(s)? If so, please specify the required vertical and horizontal extents.
Answer: a) & b) To be determined/calculated by contractor during design.
Question 56: Will cofferdams be required at Logan Creek and/or the existing east–west water ditch? If cofferdams are required, can USFWS identify each cofferdam location.
Answer: To be determined/calculated by contractor during design, state assumptions clearly in proposal.
Question 57: Please confirm that all cofferdams are to be furnished and installed by the Contractor.
Answer: Yes, but the need is be determined/calculated by contractor during design.
Question 58: Please confirm whether cleared and grubbed material may be stockpiled onsite and remain onsite. If allowed, please provide a map showing the designated stockpile area.
Answer: Excavated and grubbed material should be hauled off-site, which includes smooth rounded, river cobble stone.
Question 59: Please identify Staging areas for contractor use.
Answer: This will depend on project timing. The refuge has many potential staging areas in close proximity to the construction location.
Question 60: Please identify all permitting agencies and permit types expected for this project (e.g., Section 404, CEQA, WOTUS etc.).
Answer: It is the contractor's responsibility to determine and acquire necessary permits based on developed design. Contractor must also provide permits or proof of attempt to contact regulatory agency.
Solicitation NO. 140FGA26R0001
Question 61: How will any schedule delays concerning permitting. Permit timelines are not under contractors control.
Answer: Delays associated with regulatory agency review timelines may be considered for period of performance adjustment at no additional cost to the Government, the contractor may submit a documented request to CO for consideration. Refer to updated SOW Section 1.1 Period of Performance. “The overall period of performance is 24 months. 35% Design and permitting phase (Task 1-3) shall be completed and approved within twelve (12) months from NTP.
Construction/build phase shall be completed within twelve (12) months from completion and acceptance of Task 1-3…”
Question 62: How long is the work stoppage for any GGS encounters within the work zone?
Answer: This is laid out in the SOW. Any GGS encountered within the work zone requires that refuge staff be notified. If a snake is killed, this will be documented. If it is alive. Refuge staff will just need to check the area and confirm that the snake has left the area.
Question 63: CEQA, if required, can take up to 18 months from start to finish if there is not public objection. Public objections could make this process take years. How will extended delays such as this be handled?
Answer: Due to delays outside the contractor’s control, the CO may extend the period of performance at no additional cost to the Government. State assumptions clearly on the proposal.
Question 64: Is the contractor expected to maintain their pricing if the permit timelines are delayed and outside of their control?
Answer: Yes.
Question 65: Is there a USFWS biological survey available?
Answer: Not sure what type of biological survey this would be referring to.
Question 66: Will USFWS provide separate estimated costs (EE) for the following:
(1) Architectural & Engineering (A&E) efforts,
(2) Construction cost magnitude (currently stated as $500,000–$1,000,000), and
(3) Permitting efforts not currently listed as a line item?
Solicitation NO. 140FGA26R0001 Amendment #2
Answer: The magnitude of the project outlined in the solicitation, between $500,000 and $1,000,000.00, is for the entire design-build project, not just the construction portion.
Question 67: Please provide a copy of the site visit sign in sheet from 3/3/2026 site visit.
Answer: The sign-in sheet will not be released. This is an internal document.
Question 68: How much of the various concrete structure(s) is to be removed?
Answer: To be determined/calculated by contractor during design.
Question 69: Can a highlighted drawing be provided by USFW showing the extent of the intended Demo area?
Answer: Refer to answer on question 52. Demolition limits are dependent on site investigation and data collection.
Question 70: How deep is the expected new barrier wall going to be underneath the existing depth of the existing structure? (if this route is to be taken to fix the leaking happening with the structure)
Answer: Refer to answer on question 54.
Question 71: Can the USFW provide assumed/desired elevations of the intended structure(s)?
Answer: To be determined/calculated by contractor during design.
Question 72: Will CLSM be required to mitigate and future piping / undermining of the new structure(s)? If so, please provide assumed elevations of such.
Answer: Yes, replacements needs to correct deficiencies. Elevations to be determined/calculated by contractor during design.
Question 73: Will coffer dams be necessary at either Logan Creek or the existing water ditch running East to West?
Solicitation NO. 140FGA26R0001 Amendment #2
Question 74: If cofferdam(s) are necessary, can the USFW itemize each cofferdam and provide expected flows at each cofferdam location?
Answer: To be determined/calculated by contractor during design.
Question 75: Please confirm cofferdam(s) will be provided by the selected Contractor and not the USFW.
Answer: If needed, contractor must provide and install required coffer dams. The government doesn’t expect area to be wet, but contractor must investigate water table influence.
Question 76: Has any additional design work or design intent been completed since the last time this project bid in April of 2025?
Answer: No.
Question 77: Has a design team been selected through any other methods or advertisements?
Answer: No. A design team is the responsibility of the awarded contractor.
Question 78: Will rip rap be necessary for embankment stability once Concrete structure(s) are in place to mitigate future erosion of NEW Flume pipe? If so, how far up the embankment and how far back from the structure(s)?
Answer: Structure shall be designed to provide a minimal service life of 50 years, resist forces from variable flows, prevent deterioration and decrease maintenance. Material type and size to be determined during design, state your assumptions in proposal.
Question 79: Please provide direction of expected material for New Flume pipe (IE, aluminum, steel, corrugated, etc.).
Answer: Structure shall be designed to provide a minimal service life of 50 years, resist forces from variable flows, prevent deterioration and decrease maintenance. Refence SOW Sec. 2 Scope.
Question 80: Please provide expected diameter of expected Flume pipe to cross Logan Creek.
Solicitation NO. 140FGA26R0001 Amendment #2
Question 81: Please confirm clear & grub material from the intended work area can be stockpiled onsite and remain onsite. If so, please provide a map indicating stockpile location.
Answer: All excavated or grubbed material should be moved off-site, which includes smooth, rounded river cobbles.
Question 82: Please provide which permitting agencies and requirements will be expected by Contractor (IE, 404 permitting, CEQA permitting, etc.).
Answer: All which are required based on developed design, it is the contractor's responsibility to determine and acquire necessary permits. Contractor must also provide permits or, at a minimum, proof of attempt to contact regulatory agency.
Question 83: Will USFW provide an estimated cost of (1). A&E efforts separate from the estimated (2). Construction cost magnitude of $500,000.00 - $1,000,000.00 & (3). Permitting efforts which are currently not identified as a line item. Three separate expected costs/line items?
Answer: No. The magnitude of the project outlined in the solicitation, between $500,000 and $1,000,000.00, is for the entire design-build project, not just the construction portion.
Question 84: Disposal of construction waste and vegetation on-site or haul off?
Answer: All excavated or grubbed material should be moved off-site.
Question 85: What permits that the refuge already has as a part of our programmatic CCP cover this project?
Answer: They should be covered under our Section 7 with a CatEx, I did the Section 106 previously for this project and should have some other coverage too.
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