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DocuSign Envelope Its: BE74E31 B-F73A-4A43-A �IBD4E6CBC6F5 FIRSTCARBON Proposal Quality Control FCS's system of quality control is much more than document review prior to submittal. It involves every step in the preparation of technical studies and environmental documents. Upon project initiation, all team members are provided with a copy of the agreed -upon scope of work, allowing every individual involved with the project to have the same understanding of the required work products, the content of the work products, and the prevailing schedule/budget constraints. One of our in-house attorneys, Megan Starr, JD, oversees the environmental services publications team and the overall Quality Assurance/Quality Control (QA/QC) process for the environmental documents that FCS prepares. FCS's QA/QC Manager, Project Directors, and Project Managers coordinate all activities related to QA/QC— including multiple reviews of project documents —to ensure legal defensibility, technical accuracy, and objectivity. In addition, FCS's management team commits to not only reviewing the "final product" but also to conducting a thorough review of all technical data and studies used to support our documents' findings and conclusions. This ensures that all of FCS's findings are accurate and properly incorporated. Knowledge of Local, State, and Federal Regulations FC5 regularly works with regulatory agencies through the CEQA process to identify, discuss, and resolve key environmental issues, as well as during the regulatory permitting phases of projects. We have good relationships with local, state, and federal agency staff and can facilitate discussions and meetings as needed to raise issues for discussion and resolution. Our management and technical staff have excellent working relationships with the State Historic Preservation Office (SHPO), California Department of Transportation (Caltrans), California Department of Fish and Wildlife (CDFW), California's Regional Water Quality Control Boards (RWQCBs), and the US Army Corps of Engineers (USACE). We have in-depth experience in Section 106 compliance and reports for cultural resources, obtaining 404 permits from the USACE, preparing water quality certificate applications for the RWQCBs, and obtaining Streambed Alteration Agreements from the CDFW. Compliance with Processing and Legal Requirements FCS has established an excellent record of legal defensibility for environmental documents with our clients. We exercise particular care to ensure that our environmental documents contain thorough environmental analyses and explicit documentation of all data sources and research contacts. This approach reduces the potential for successful legal challenge. FCS's staff is experienced in conducting environmental documentation for controversial projects; we have developed research and documentation techniques, and we use agency -accepted environmental assessment techniques that minimize avenues for legal challenge. FCS's in-house attorneys regularly monitor CEQA court decisions and CEQA Amendments to keep FCS Managers abreast of legal precedents and compliance issues. FCS's environmental technical staff attends annual updates regarding CEQA compliance to maintain a current approach to legal compliance. All FCS Project Managers have years of experience preparing and managing project administrative records according to the requirements of CEQA and are well versed in the various processing requirements that apply to specific types of environmental documentation, including minimum circulation periods, distribution and noticing requirements, and processing timelines. mWMf WERICA I EdRGK 1AM1CA 1 AU5TRA IA IA FIRSTCARBONSOLUTIONS.COM 5