HomeMy WebLinkAboutRESPONSE - RFP - 7177 FORT COLLINS GHG TECHNICAL ASSISTANCEW——
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Proposal to Provide Services fior
7177 Fort Collins GHG Technical Assistance
S'�`bmitt d to
City of Fort Collins Purchasing Division
215 North Mason Street, 2nd Floor
Fort Collins, Colorado 80534
Submitted by
SWCA Environment -al Consultanfis
295 Interlocken Boulevard, Suite 300
Broomfield, Colorado 80021
Phone: 303.487.1183
October 5, 2010
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions
City moves forward in developing an integrated approach to GHG and sustainability
best management practices.
> Management consultation
> Ecological footprint assessments
➢ Environmental footprint baseline assessments
> Energy baselines and reduction strategies
> Carbon and energy reduction strategies
> Sustainability program development
> Environmental and financial analysis/Return-on-Investment (ROI)
> Public outreach and engagement
> Sustainability plan development
> Energy and carbon data management
> Sustainability training
SWCA's passion for preserving our planet starts at home. We have
assessed our own impacts and developed an internal sustainability team
with aggressive goals for reduction of our own impacts. We are a Founding
Reporter to The Climate Registry, have tracked our GHG inventory for the
past three years, and have completed third -party verification of our
inventory per The Registry's protocol, earning us the recognition of being a
"Climate Registered" organization. In addition to GHG reporting, we have
developed a corporate sustainability plan, and our offices have
implemented a wide range of sustainability initiatives.
We propose to complete the proposed services for a lump sum price of $25,731.
Our estimated time and budget for each task is summarized below.
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Task I — Kickoff and evaluate process (38 hours)
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$5,016
Task II — Develop data repository and process (72 hours)
$8,833
Task Illa — Develop reporting tool (56 hours)
$7,020
Task IIIb — Emissions reporting review (40 hours)
$4,862
Total estimated cost
$25,731
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010 1 7
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions
SWCA has a long and successful record of working with public and private
organizations on complex and technically complicated environmental projects. We have
completed GHG inventories using a wide variety of inventory protocols, including The
Climate Registry's General Reporting Protocol and sector -specific protocols, the EPA
Climate Leaders Protocol, the ICLEI International Local Government GHG Emissions
Analysis Protocol, WRI/WBCSD's GHG Protocol, the IPCC's Guidelines for National
Greenhouse Gas Inventories, the EPA's Climate Leaders GHG Inventory Protocol, and
ISO 14064-1.
We have selected the following projects to highlight our extensive experience. In each
case we worked with the client to complete large data -collection efforts from multiple
locations and departments; to complete a GHG inventory using specific analysis and
reporting protocols; and to create a data management system that facilitates future data
collection, management, and reporting.
Project Experience: Salt Lake County; Salt Lake City, Utah; 2009
Project summary: SWCA worked with Salt Lake County to
develop the County's baseline GHG emissions inventory for its
first year reporting to The Climate Registry. This project included
collecting data from numerous departments, more than 200
facility locations, the County -operated landfill, and 1,400
vehicles. It also included the development of an Access -based
energy and GHG database system, giving the County a
centralized system in which to store and manage its GHG
reporting activity data.
Services provided: GHG inventory; help identifying an
appropriate baseline year; boundary setting; development of a
customized data questionnaire; collection of data with county
personnel; data verification; identification of appropriate
conversion factors; inventory analysis using The Climate Registry
protocol; development of energy use and GHG database; and
preparation of GHG inventory report.
➢ Other information: The project was completed successfully, on _
schedule, and within budget.
Contact: Teresa Young, Planning Manager Facilities Management; 801-
468-2250
Project Experience: Balfour Beatty Construction; Atlanta, Georgia;
2010
➢ Project summary: SWCA worked with Balfour Beatty Construction to
develop the company's baseline GHG emissions inventory under the EPA
Climate Leaders protocol. This included data collection from the company's
11 offices and 88 construction sites scattered across the Eastern United
States. To facilitate reporting, SWCA developed a customized questionnaire
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions 10
and GHG calculation tool for instantaneous calculation of_'�_
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construction -site GHG emissions, landfill diversion rates, and
water consumption.
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➢ Services provided: GHG inventory; assistance on boundary
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setting; development of customized data questionnaire; data
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collection support; data verification; identification of
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appropriate conversion factors; inventory analysis using EPA
Climate Leaders protocol; development of energy use and
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carbon database; and preparation of GHG inventory report.
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This project included the collection of data from multiple
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office locations in cities across the United States and
approximately 90 project sites.
Other information: The project was completed successfully,
on schedule, and within budget.
➢ Contact: Tracy Browne, Director of Integrated Project Delivery; 954-585-
4316
Project Experience: Riverside Company; New York, New
York; 2009
> Project summary: Riverside Company (Riverside) is one of the largest
private equity firms in the United States and owns more than 60 portfolio
companies. With its large portfolio of companies in a wide range of sectors,
Riverside needed to understand and prepare to mitigate risks to its portfolio
posed by climate change. Riverside asked SWCA to develop a triple bottom
line reporting process for its portfolio companies that encompassed social,
environmental, and financial reporting. Riverside also requested that SWCA
develop an Energy and Carbon Management System, allowing its portfolio
companies to quickly assess and report their major energy uses and GHG
emissions sources. The system has been rolled out to all Riverside portfolio
companies, and is being used by Riverside to track and manage the carbon
risk associated with its portfolio.
➢ Services provided: GHG inventory and Sustainability Program
Development; management consultation; Green Team alignment; triple
bottom line assessment including a GHG inventory, ecological footprint,
water analysis, waste analysis, current green practices analysis, social and
financial sustainability analysis, and recommendations for impact reductions.
Developed a customized energy and carbon management system.
> Other information: The project was completed successfully, on schedule,
and within budget.
> Contact: Paul Farrow, Corporate Sustainability Director, 207-557-4856
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010 9
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* _Denver Office
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Broomfield, CO 60021
Tel 303.487.1183 Fox 303.487.1245
_ENVIRONMENTAL CONSULTANTS r
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October 5, 2010
The City of Fort Collins
Purchasing Division
215 North Mason Street, 2nd floor
Fort Collins, Colorado 80524
Subject: Request for Proposal — 7177 Fort Collins GHG Technical Assistance
Dear Proposal Review Team:
SWCA Environmental Consultants (SWCA) is pleased to present this proposal in responses to the
above subject Request for Proposal (RFP). As longtime members of the Front Range community with a
passion for sustainability, we are excited by the opportunity to partner with your staff on this project
and help you meet your greenhouse gas (GHG) reduction goals.
SWCA puts client needs at the forefront of every project. This includes technical considerations and
budgetary and scheduling needs. Our client dedication has earned us a top Engineering News -Record
environmental firm designation, and we have been among the top 20 firms in environmental science
revenue. Such rankings are the result of client satisfaction, recurring partnerships, and positive
reputation among clients.
Our specialized project team will provide the City of Fort Collins (the City) with the following
significant benefits:
➢ GHG Inventory Experience — SWCA's expertise in this field comes from having
completed dozens of GHG inventories, including assistance to clients with large and
complex GHG reporting needs. We recently completed a very detailed energy use and
GHG emissions baseline for Salt Lake County, which included a data -collection program,
a data -management system, and a GHG inventory. This municipality included numerous
departments, 200 individual facilities, and 1,400 fleet vehicles. We have helped our
clients manage a wide range of climate change and sustainability issues, including waste
and recycling, materials conservation, fleet impacts, water conservation, business travel
and commuting impacts, sustainability education, and organizational engagement.
> Energy and GHG Data Management System Expertise — SWCA's combination of
GHG expertise and database development capability allows us to offer the City a
customized GHG data management system. This will greatly facilitate baseline and future
GHG inventory data collection, analysis, and reporting by providing a centralized
repository for all GHG data and analysis needs; tracking data -collection progress for each
reporting entity; automatically flagging potential data -entry errors; calculating GHG
emissions; and providing a high degree of insight to the City regarding its GHG emissions
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innventory by enabling emissions reporting by entity, source, scope, and other useful
factors.
Sustainability and GHG Reduction Program Experience — We believe our experience
with other related services (e.g., sustainability planning, GHG reduction strategies, cost
and impact reduction analysis, community outreach, training, and more) will greatly
benefit the City as you move forward in developing and implementing a comprehensive
GHG data management, and sustainability program.
➢ Expert Third -Party Review — SWCA will provide an expert, independent, third -party
review of your inventory process and reduction program for this project. This is essentially
a fresh set of eyes to help the City identify areas of process and/or reporting improvement.
➢ Proven Track Record — SWCA has been serving clients for almost 30 years, and we are
known for excellent work for a wide range of federal, state, and local government
organizations as well as other leading groups across the Front Range and the Western
United States.
➢ Fast Project Completion — SWCA understands that time is of the essence. Our project
team is ready to fast -track the completion of this project to meet your proposed schedule.
➢ Carbon Neutral Services — SWCA will calculate the GHG emissions that result from our
services to you and purchase offsets to effectively provide carbon neutral services on this
project. We will provide you with a complete analysis as well as offset certificates.
SWCA offers the City our depth of experience with highly complex GHG inventories and database
development —providing the tools you need to effectively and efficiently manage your GHG
emissions.
It is in the spirit of teamwork and professionalism that we offer our services to the City of Fort Collins.
We look forward to being a part of your project team —and helping you shape a cleaner, a more
efficient, and more sustainable future.
Respectfully,
Chris Haas, MS
Natural Resources Program Director
SWCA Environmental Consultants, Denver Office
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions.®
SWCA Environmental Consultants (SWCA) understands that the City of Fort Collins
has made a made a significant commitment towards reducing its GHG emissions. We
know that the City tracks its GHG emissions and reports progress on its community and
municipal emissions reduction efforts. Although the methodology for tracking and
reporting progress has evolved and improved over time, there are still areas where the
process can be even further improved.
This project would include a review of the City's program and data collection processes,
development of a new and more efficient data -collection repository (database),
development of an inventory calculation and reporting tool, and a review of the City's
2010 and 2011 community emissions inventories.
SWCA proposes to complete each of the tasks outlined by the City within the prescribed
budget and schedule. The scope of work we propose to complete under this project is
described below.
Project Kickoff
SWCA will hold a project kickoff meeting with the City and the
SWCA project team within a week of project award. The purpose of
this meeting will be to jointly review the scope of work, discuss the
City's overall vision/goals and critical project -success factors,
assign roles and responsibilities, establish a communications %rye 1 i
protocol, and develop a final schedule.
We will also conduct regular internal SWCA team coordination
meetings to address issues, monitor schedules and budgets, and
discuss upcoming tasks. In addition, we will coordinate regular
conference calls and in -person meetings during project execution•
with City staff.
Task I: Evaluate Process
SWCA project team members include staff experienced in the development of complex
process maps. We will work with key City personnel involved with the City's GHG data
collection and reporting to develop a process map of the City's GHG data collection,
analysis, and reporting process. The process map will include the following:
All City of Fort Collins GHG-related reporting activities across the
organization.
What tasks are completed and what is required for each step of the data
collection and reporting process.
The party responsible for each step.
> The timeframe surrounding each step.
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010
SWCA project team members
include staff experienced in
the development of complex
process maps.
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions.°'
➢ Existing standards against which reporting is completed and considerations
of future reporting requirements including:
• The impact of reporting standards on data collection (records
sourcing and quality assurance),
• The impact of reporting standards on data analysis (calculation
methodologies and conversion factors), and
• The impact of reporting standards on the reporting of results (format
of the emissions profile by scope, gas, etc.; potential for third party
verification; and formatting of data for bulk data transfer
applications).
Development of this process map will enable SWCA to pinpoint ---.
inefficiencies and gaps in the City's current reporting process,
and identify potential future reporting requirements and
associated new reporting needs for which the City may want to
p re pa re.
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Based on the outcome of the process mapping exercise, SWCA ,ate
will develop a set of recommended process improvements that
will enable the City to report GHGs more quickly and efficiently,
with reduced redundancy, and in a way that anticipates
reasonably foreseeable future reporting needs. SWCA will provide a report with the
process map and our process recommendations to the City.
Task 11: Develop Data Repository and Process
SWCA will develop a user-friendly data repository and reporting system to store all
activity data that feeds into community and municipal GHG inventory and reduction
reporting. The system will be based on a relational database and will be designed as a
"one -stop" data repository for the City's GHG data, including summary data from Utility
Manager, community -level GHG inventory activity data, and any other data the City
may wish to track. For example, the City may want to track municipal GHG activity data
or key metrics and indicators such as city population, the number of municipal
employees, etc., for use in its GHG emissions performance reporting.
SWCA recommends a design meeting with City staff to document the City's data
storage and GHG reporting needs. During this meeting, we will review the findings of
Task I; discuss various design and capability options for the system; evaluate the
hardware, software, and licensing requirements, restrictions, and standards; and finalize
the list of desired data input and reporting capability parameters. This meeting, and
follow-up conservations with City staff, will help ensure the development of a reliable
system that fully integrates the functionality requirements of the City.
Once the database and reporting requirements have been established, SWCA will
develop a database for City use on its network resources. We propose two options for
the database system platform, both of which use Microsoft Access 2003 or 2007 as the
user interface to the database management system. Option 1 employs Access as the
underlying database, with options to allow multiple users to enter and extract data.
SWCA will develop a user-
friendly data repository and
reporting system to store all
activity data that feeds into
community and municipal
GHG inventory and reduction
reporting. The system will be
based on a relational
database and will be
designed as a "one -stop" data
repository for the City's GHG
data.
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010 1 2
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions.®
Option 2 provides a more stable and robust relational -database management system,
using open -source database platforms of PostgreSQL or MySQL, with an Access
interface for multiple -user editing and data extraction. The City's network resources and
IT standards and requirements on data entry, reporting, and user access will determine
which option is appropriate. The cost of services will not change regardless of which
option is selected.
The final database will allow for the reliable storage and retrieval of the City's data. The
database will include a user-friendly data input interface. This data input interface will
clearly delineate all data elements and input requirements, provide for automated data
quality checks to identify and flag potential data entry or other errors, allow for the
tracking of document/data-control information, and include separate customized data
input modules for the primary data input sources identified in the Task I process map.
SWCA will provide a pilot of the database interface for the City to review, but assumes
the review process will not exceed one week to ensure that the project timeline is
maintained. Development of the final database will be done while the interface and
data entry tools are being reviewed. Once the database development process is
finished, SWCA will provide documentation on the database, including table and
relationship structures, data -entry tools, and a user manual on how City staff can
update and maintain the database with a recommended process (format/timeline) for
City departments to provide data.
Task Ilia: Develop Reporting Tool
Once the database has been developed, SWCA will create a
simple, automated reporting tool interface within it. This tool will
calculate the City's various GHG emissions inventories (with
municipal, community, and sub -inventories as needed); allow for
reporting by.scope, gas, source, and date; and enable reporting
of GHG emissions metrics (e.g., metric tons carbon dioxide
equivalent [Mt COA per person) identified during the design
meeting. This tool can be formatted to conform to other reporting
requirements such as the environmental and GHG portions of the
Global Reporting Initiative (GRI) or the Department of Energy's
Energy Efficiency and Conservation Block Grant (EECBG)
reporting.
After the reporting tool has been created, SWCA will provide documentation describing
its functionality and embedded calculations (including conversion factors with complete
references), methodologies, and assumptions. SWCA will also develop a user manual
on how to generate the reports.
Task Ilib: Independent Review
In addition, SWCA will complete an independent, informal, third -party review of the
City's community emissions reporting for 2010 and 2011 data, to affirm acceptable
data .quality for this emissions reporting effort. Having generated dozens of GHG
inventories for a wide range of clients, SWCA is very experienced in GHG emissions
reporting, and our review of the City's reporting can serve to enhance the public
credibility of the City's efforts. Upon completion of our review, we will provide the City
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010 1 3
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative. Solutions
with a letter stating our opinion regarding the quality of the inventory for each of the
2010 and 2011 inventory years.
Project Deliverables
The scope of work outlined above will include the following corresponding deliverables.
➢ A process map of the City's current GHG reporting processes
Written recommendations for efficiency improvements in GHG-related data
collection
➢ A database for City GHG activity data and metric storage and retrieval
.� Database documentation, including a user manual on data entry and
maintenance
➢ A reporting tool linked to the database enabling the efficient generation of
City reporting metrics
➢ A reporting tool user manual that describes tool functionality and the
calculation methodologies embedded within it
➢ A summary of our review of the City's 2011 and 2012 inventory reports
SWCA's proposed project team includes the following members:
Richard Young; PE — Project Oversight, Senior Engineer, and QA/QC
Richard Young is SWCA's Sustainability and Climate Change Practice Group leader
as well as a licensed professional engineer (PE). He has more than 25 years of
environmental engineering, consulting, and management experience with municipal,
private, and federal clients on a broad range of environmental projects. For the last
four years, Mr. Young has focused exclusively on climate change and sustainability
services, managing more than 20 GHG inventory baselines and sustainability
planning projects —including GHG inventories, ecological footprinting, water -use
assessments, waste stream analysis, and energy -use and impact -reduction planning.
His environmental and business management background brings a unique perspective
to GHG and energy reduction strategies and sustainability planning. He specializes in
GHG inventories, sustainability planning, and eco-business strategies, as well as
program development, stakeholder communication, and employee engagement. Mr.
Young has presented on sustainability and carbon management issues at a number of
conferences across the United States.
As senior engineer, Mr. Young will be responsible for all technical oversight and
QA/QC for the project.
Andrew Hultgren; CE — Project Manager and Technical Lead
Andrew Hultgren holds a chemical engineering degree from Princeton University and
has acted as project manager and lead technical analyst on more than two dozen GHG
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010
For the last four years, Mr.
Young has focused
exclusively on climate change
and sustainability services,
managing more than 20
GHG inventory baselines and
sustainability planning
projects —including GHG
inventories, ecological
footprinting, water -use
assessments, waste stream
analysis, and energy -use and
impact -reduction planning.
4
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions
inventories. Mr. Hultgren has extensive experience in climate change analysis and GHG
inventory development and management, and has served on The Climate Registry's
Technical Expert Panel.
Mr. Hultgren is an expert in GHG inventories, ecological footprinting, and
environmental baseline assessments. He has developed a custom database of local
GHG conversion factors, and is experienced with many GHG reporting protocols
(including EPA Climate Leaders, The Climate Registry General Reporting Protocol, The
Climate Registry Local Government Operations Protocol, the ICLEI International Local
Government GHG Emissions Analysis Protocol, the WRI/WBCSD GHG Protocol, the
IPCC's Guidelines for National Greenhouse Gas Inventories, and ISO 14064-1). Mr.
Hultgren has been the lead project manager and technical analyst on GHG inventories
for several large municipal clients, government agencies, and private sector businesses.
His recent clients include Park City Municipal Corporation, Salt Lake County, Salt Lake
City Corporation, Deer Valley Ski Resort, Banco Popular de Puerto Rico, Questar Gas
Company, Kennecott Land Company (Rio Tinto), Bureau of Land Management, U.S.
Forest Service, and many others. He has a broad range of experience in data
collection, data management, emissions calculation tools, and environmental
sustainability opportunities assessments and planning.
In addition, Mr. Hultgren has several years experience in process engineering as a
Process Research Engineer, developing process maps for complex processes with
multiple inputs and intermediate phases in the specialty chemicals industry.
As project manager, Mr. Hultgren will be responsible for overseeing development of the
GHG data management system and reporting tool.
Darcee Killpack; MS — Data Management System Support
Darcee Killpack has worked in government agencies and private companies to develop
information management programs and tools. She is experienced with website design,
data management, training development, geographic information systems (GIS), and
technical programs.
Through previous experience, she shaped the development of a large database
program at the U.S. National Oceanic and Atmospheric Administration (NOAA) Pacific
Services Center in Honolulu, Hawaii. She currently serves as SWCA's database lead on
the design, development, and implementation of a multiagency, web -enabled database
management system. Her expertise includes database management systems design to
support data collection and organization; web services and visualization tools to support
decision processes and planning, and analysis tools and modeling to support planning
and suitability analysis.
Ms. Killpack is also experienced with the development of online searchable databases,
and has provided QA/QC procedures for in -field database data -collection systems. She
leads the programmatic development of database management systems for SWCA,
using SQL Server, MySQL, and PostgreSQL database systems.
Ms. Killpack will support Mr. Hultgren in developing the data management system and
reporting tool.
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010
Mr. Hultgren is an expert in
GHG inventories, ecological
footprinting, and
environmental baseline
assessments. He has has been
the lead project manager and
technical analyst on GHG
inventories for several large
municipal clients, government
agencies, and private sector
businesses.
Ms. Killpack's expertise
includes database
management systems design
to support data collection and
organization; web services
and visualization tools to
support decision processes
and planning; and analysis
tools and modeling to support
planning and suitability
analysis.
SWCA
ENVIRONMENTAL CONSULTANTS
Sound Science. Creative Solutions.®
SWCA understands that the City would like to complete the requested scope of work by
December 2010. We anticipate no problems whatsoever with your proposed December
2010 completion date. If the project award date is much later than anticipated, a slight
change in the schedule provided below may be needed, but any such modification
would be discussed and approved at the kickoff meeting.
Task
setup and kickoff meeting
Weeks
0-1
Document and process review
0-2
Database development
1-3
Reporting tool
1-3
Database and reporting testing
3-4
Final and transfer to City of Fort Collins
5-6
Contingency
1
Total estimated project duration
6-7 weeks
To ensure the timely completion of this project, the SWCA project manager, Mr.
Hultgren, will prepare a detailed project schedule plan two days after the project kickoff
meeting. The schedule will include a list of key milestones, deliverables, and responsible
parties. The schedule will be implemented through regular team coordination meetings
to address issues; monitor schedules and budgets, and discuss upcoming tasks,
deliverables, and staffing needs. Similar meetings will be held between the SWCA
project manager and the City's project team.
Climate change is the great issue of our time. With its global reach and potential
consequences spanning decades to millennia, climate change is a challenge that is at a
critical tipping point. The City of Fort Collins has an established history of leadership in
addressing this extremely important issue, and SWCA is excited at the prospect of
partnering with the City as it continues to show how municipalities can effectively
respond to the threat of climate change. We are committed to and have a long history
of sustainability best management practices. Our dedicated team of experts focuses
exclusively on sustainability and climate change services —and we are ready to help the
City meet its GHG reduction goals and demonstrate an even greater level of leadership
in climate change practices.
SWCA's internal sustainability services group specializes in climate change and
sustainability services. In addition to our extensive GHG inventory experience, we have
provided the following sustainability services to a wide range of public and private
clients, helping clients throughout the United States take proactive steps toward a more
sustainable future. We believe our expertise in these areas will be of great benefit as the
PROPOSAL TO PROVIDE SERVICES FOR 7177 FORT COLLINS GHG TECHNICAL
ASSISTANCE; OCTOBER 5, 2010
Our dedicated team of experts
focuses exclusively on
sustainability and climate
change services —and we are
ready to help the City meet its
GHG reduction goals and
demonstrate an even greater
level of leadership in climate
change practices.
N.