Item J3BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Bate: January 19, 2012 Division: Growth Management
Bulk Item: Yes No X Department: Planning. & Environmental Resource
Staff Contact Person: Michael Roberts
(305 289- 2502 . .. ,..
AGENDA ITEM WORDING: Discussion and direction regarding the request by the South Florida Water
Management District and the Florida Department of Environmental Protection for Monroe County to Sponsor a
Regional Offsite Mitigation Area (ROMA) to provide compensatory mitigation for wetland impacts in the
Keys.
ITEM BACKGROUND: In the Keys, mitigation for impacts to aquatic resources (including wetlands)
associated with single family residential development, including boat docks, seawalls, etc., has most often been
provided through an environmental mitigation Trust Fund that was established as a result of a Federal case
involving wetland impacts. This Fund is known as the Keys Environmental Restoration Fund (KERF) and
payment to KERF by permit applicants has been accepted by the ACOE and the Florida Department of
Environmental Protection (DEP) as mitigation for wetland impacts associated with single family residential
construction, including docks and seawalls. However, as detailed in the attached backup information, KERF
does not currently meet Federal or State requirements for off -site mitigation. As a result, KERF cannot provide
mitigation for wetland impacts for projects that require a permit from the South Florida Water Management
District (SFWMD), such as commercial projects and those impacting more than 1 acre of wetlands.
Due to changes in State and Federal regulations related to offsite mitigation since KERF began operations, there
is concern regarding KERF's future ability to provide a mitigation option to the residents of Monroe County.
The ACOE has requested the County to pursue an In -Lieu Fee (ILF) program that meets Federal mitigation
requirements, or to assist KERF in gaining compliance with the Federal Rule. In addition to this request, FDEP
and the SFWMD have asked. the County to evaluate the possibility of acting as a sponsor for a ROMA in
accordance with State statutes governing off -site mitigation programs. AROMA or a mitigation bank are the
only mitigation options available under State regulations that allow a permittee to pay a fee rather than provide
the mitigation directly through on -site wetland.
For Monroe County property owners to continue to have an option to provide off -site mitigation by paying a fee,
Monroe County may need to take action. Potential actions are grouped into 5 basic alternatives: (1) Establish a
federal ILF agreement to create and manage our own mitigation program to provide mitigation for only SFR
projects that do not require State mitigation (2) Establish a federal ILF agreement and enter into a
Memorandum of Agreement with the state to create and manage our own In -Lieu Fee and ROMA program to
provide mitigation for all SFR projects; (3 Establish a federal ILF agreement and enter into a Memorandum of
Agreement with the state to create and manage our own In -Lieu Fee and ROMA program to provide mitigation
for all projects; (4) Enter into a Memorandum of Agreement with the state to create a ROMA and contract with
KERF (or possibly another mitigation provider TBD) to accomplish the approved mitigation projects and
provide support in the establishment of a Corps permitted In -Lieu Fee program; or (5) Do nothing.
PREVIOUS RELEVANT COMMISSION ACTION:
CONTRACT/AGREEMENT CHANGES: NIA
STAFF RECOMMENDATION: Direct staff to prepare RFP/SOQ for Consultant to prepare permit documents and
provide mitigation services for wetland restoration and/or enhancement
TOTAL COST: $170,000 INDIRECT COST: $20,000 BUDGETED: Yes No NIA
COST TO COUNTY: NIA SOURCE OF FUNDS: NIA
REVENUE PRODUCING: Yes No NIA AMOUNT PER MONTH: NIA Year
APPROVED BY: County Attorney I OMB / Purchasing I Risk Management
DOCUMENTATION: Included X Not Required
DISPOSITION: AGENDA ITEM #
County of Monroe
Growth Management Division
Planning & Environmental Resources
Deuartment
2798 Overseas Highway, Suite 410
Marathon, FL 33050
Voice: (305) 289-2500
FAX: (305) 289-2535
December 21, 2011
Board of County_Commissioners
Mayor Heather Caruthers, Dist. 3
Mayor Pro Tem David Rice, Dist. 4
Kim Wigington, Dist. 1
George Neugent, Dist. 2
Sylvia J. Murphy, Dist. 5
We strive to he caring, professional and fair
Wtanml
TO: Board of County Commissioners
Roman Gastesi, County Administrator
THROUGH: Christine Hurley; Growth Management Division Director
FROM: Michael Roberts, Sr. Administrator/Environmental Resources
RE: SUN94ARY OF MONROE COUNTY ALTERNATIVES FOR
COMPENSATORY MITIGATION OPTIONS IN THE FLORIDA KEYS
Development activities that result in impacts to wetlands and other surface waters require
permits from State and Federal agencies as well as approval from Monroe County. In both the
State and Federal permit review process, the applicant must first demonstrate that the proposed
wetland impact is unavoidable, and that the impacts proposed have been reduced or minimized to
the greatest extent practicable. Once the applicant has demonstrated that the proposed project
meets these criteria, then they must compensate for any functional loss of wetland habitat value.
This compensation is referred to as wetland mitigation. Wetland mitigation can be provided by
the applicant through (1) the restoration or creation of wetlands on the same site as the impact
(on -site mitigation), (2) the restoration or creation of wetlands at a location other than the impact
site (off -site mitigation), or (3) through the purchase of credits through a permitted wetland
mitigation bank, Regional Offsite Mitigation Area (BONA) or In -Lieu Fee program.
In the Keys, mitigation for impacts to aquatic resources (including wetlands) associated with
single family residential development, including boat docks, seawalls, etc., has most often been
provided through a slightly different approach than those listed above. In 1981 an
environmental mitigation Trust Fund was established as a result of a Federal case involving
wetland impacts. The Fund is administered by the Audubon Society and overseen by the U.S.
Army Corps of Engineers (ACOE). This Fund eventually became known as the Keys
Environmental Restoration Fund (KERF) and payment to KERF by permit applicants has been
accepted by the ACOE and the Florida Department of Environmental Protection (DEP) as
mitigation for wetland impacts associated with single family residential construction, including
docks and seawalls (like an In -Lieu Fee program). Due to a wide array of issues associated with
on -site mitigation, most property owners in the Keys opt to pay into the Fund as mitigation for
impacts to wetlands and other surface waters.
It is important to note that the South Florida Water Management District does NOT accept
payment into the fund as mitigation. However, SFWMD regulates commercial and multi -family
development —not single family homes. While commercial and other non-residential
development projects may also use KERF to mitigate for Federally regulated impacts, if the
project requires permitting through SFWMD the applicants must provide permittee responsible
mitigation. Permittee responsible mitigation means mitigation that is provided directly by the
permittee through wetland restoration, enhancement or creation.
Due to a lack of success in the small scale mitigation projects generally undertaken for on -site
mitigation, the U.S. Army Corps of Engineers and the Environmental Protection Agency issued
regulations governing compensatory mitigation in 2008 (Federal Mitigation Rule) that
established a preference for mitigation banks and provided performance standards for all types of
mitigation. The Federal rule required that mitigation banks and In -Lieu Fee programs meet a
specific set of performance criteria in order to continue to sell credits. KERF was informed by
the ACOE that they do not meet the rrLnimum criteria contained in the Rule and they must meet
the standards provided in the rule by June of 2013 in order to continue to provide mitigation for
single family residential development and other development in conjunction with ACOE dredge
and fill permits. FDEP and the SFWNID have also stated that KERF must come into compliance
with State requirements regulating a ROMA in order to continue to provide mitigation.
At this time County staff does not have a clear picture of exactly how far along KERF is in being
able to comply with the Federal ILF rule or the State of Florida ROMA regulations.
Correspondence provided by the Florida Department of Environmental Protection states in part:
"The current agreement between Florida Audubon Society and the COE does not meet the
requirements of 373.4135, F.S. The proposed "Responsibility for Mitigation Funded Restoration
Projects "provides additional information, but is not sufficient to proceed with securing a
sponsor. In particular, the proposal does not include an overall plan of proposed mitigation sites
with ecological characterization, description, assessments of current and proposed conditions
using Uniform Mitigation Assessment Method (UAMM)., quantification of ecological
improvement, success criteria and timeframe in which they would be met, along with
management plans for each of those mitigation sites. Once this information is clear, then the
issues of obtaining permits and other authorizations, full cost accounting, acquisition and
preservation, monitoring, responsible entity, and other requirements will need to be addressed
for each of the mitigation sites or the overall plan (if the mitigation projects are relatively
homogeneous in nature)',,
Due to the uncertainty of KERF's future ability to provide a mitigation option to the residents of
Monroe County, the U.S. Army Corps of Engineers has requested the County to pursue an In -
Lieu Fee program of their own, or to assist KERF in gaining compliance with the Federal Rule.
In addition to this request, FDEP and the SFWNID have asked the County to evaluate the
possibility of acting as a sponsor for a ROMA in accordance with State statutes governing off -
site mitigation programs. AROMA or a mitigation bank are the only mitigation options
available under State regulations that allow a permittee to pay a fee rather than provide the
mitigation independently.
Monroe County staff has met with the USACOE, FDEP and SFWMD to discuss the possibility
of acting as sponsor for the State permit (BONA) and assisting KERF in pursuit of Federal
approval. In addition, the County has met with representatives of KERF to initiate conversation
on how the County and KERF might work together to assure that our property owners have
options available for wetland mitigation.
For Monroe County County property owners to continue to have an option to provide off -site
mitigation by paying a fee, Monroe County may need to take action. Potential actions are
grouped into 5 basic alternatives: (1) Establish a federal ILF agreement to create and manage our
own mitigation program to provide mitigation for only SFR projects that do not require State
mitigation (2) Establish a federal ILF agreement and enter into a Memorandum of Agreement
with the state to create and manage our own In -Lieu Fee and ROMA program to provide
mitigation for all SFR projects; (3 Establish a federal ILF agreement and enter into a
Memorandum of Agreement with the state to create and manage our own In -Lieu Fee and
ROMA program to provide mitigation for all projects; (4) Enter into a Memorandum of
Agreement with the state to create a ROMA and contract with KERF (or possibly another
mitigation provider TBD) to accomplish the approved mitigation projects and provide support in
the establishment of a Corps permitted In -Lieu Fee program; or (5) Do nothing.
Alternative 1—County as Mitisation Provider for Single Family Residential proiects for
which the ACOE requires mitigation, but that are exempt from State mitigation
requirements
• File prospectus with U.S. Army Corps of Engineers and the Interagency Review Team
(IRT) to create and operate an In -Lieu Fee (ILF) program in accordance with the Federal
mitigation rule.
Requirements for Mitigation Bank and In -Lieu Fee Program Instruments
Mitigation bank and in -lieu fee program instruments must include the following
information:
1. Description of the proposed service area(s) in this case the Florida Keys
2. Accounting procedures
3. Provision stating that legal responsibility for providing mitigation lies with the
sponsor once a permittee secures credits from the sponsor
4. Default and closure provisions
5 . Reporting protocols
6. Any other information deemed necessary by the district engineer
For an in -lieu fee pro am, a complete instrument must also include the following
information:
1. Compensation planning framework (33 CFR 332.8(c)/40 CFR 230.98(c));
2. Specification of the amount of advance credits (33 CFR 332.8(n)/40 CFR
230.98(n)) and the fee schedule for these credits;
3. Methodology for determining future project -specific credits and fees;
4. Description of the in -lieu fee program account (33 CFR 332.8(i)/40 CFR
230.98(i)).
Costs for Alternative 1 are estimated at $35,150
A brief summary of the advantages and disadvantages of this alternative is provided below:
Advanta es
• Allows Monroe County to control the mitigation program and not rely on the
performance (either technical or financial) of a 3rd party provider (such as KERF or other
mitigation contractor)
• Eliminates the potential for having to advertise for a mitigation provider
• Monroe County could contract with a qualified 3`1 party provider as mitigation contractor
to implement some or all of the approved mitigation activities and monitoring
requirements at any time during the life of the ILF program.
• Eliminates the need to Sponsor a ROMA but still provides a mitigation option for those
property owners that only require ACOE permits (typically docks/seawalls on canals and
IS lots that contain wetlands that are regulated by the ACOE but not by the State).
Disadvantages
• Will require significant Monroe County staff resources to complete the Prospectus and
In -Lieu Fee Instrument
• Requires the County to be responsible for the implementation and long term (in
perpetuity) success of the mitigation areas
s Requires staff resources to locate, design and permit the appropriate mitigation areas
Alternative 2 — County as Mtigation Provider for Single Family Residential nroiects that
require mitigation from ALOE and FDEPI
File application with the State to create & operate a Regional Off -site Mitigation Area
(BONA) and prepare a MOA in accordance with State statutes (373.4135, F.S.). At a
minimum, the memorandum of agreement must address the following for each project
authorized:
1. A description of the work that will be conducted on the site and a timeline for
completion of such work.
2. A timeline for obtaining any required environmental resource permit.
3. The environmental success criteria that the project must achieve.
4. The monitoring and long-term management requirements that must be undertaken for
the project.
5. An assessment of the project in accordance with s. 373.4136(4)(a)-(i), until the
adoption of the uniform wetland mitigation assessment method pursuant to s.
373.414(18).
6. A designation of the entity responsible for the successful completion of the mitigation
work.
7. A definition of the geographic area where the project may be used as mitigation
established using the criteria of s. 373.4136(6).
8. Provision and a timetable for the acquisition of any lands necessary for the project.
9. Provision for preservation of the site.
10. Provision for application of all moneys received solely to the project for which they
were collected.
11. Provision for termination of the agreement and cessation of use of the project as
mitigation if any material contingency of the agreement has failed to occur.
12. Provision in the agreement for additional projects to be added and evaluated as they
are identified.
File prospectus with U.S. Army Corps of Engineers and the Interagency Review Team
(IP,T) to create and operate an In -Lieu Fee (ILF) program in accordance with the Federal
mitigation rule.
Requirements for Mitigation Bank and In -Lieu Fee Program Instruments
Mitigation bank and in -lieu fee program instruments must include the following
information:
1. Description of the proposed service area(s) in this case the Florida Keys
2. Accounting procedures
3. Provision stating that legal responsibility for providing mitigation lies with the
sponsor once a permittee secures credits from the sponsor
4. Default and closure provisions
' ROMA instruments must ensure that mitigation costs provide for the full cost accounting of the project,
including the project activities, land costs, and administration. However, ROMAs designated for
mitigation use by private, single-family residential construction (not incorporated residential
development) only, the full cost accounting provision is not required. In either case, moneys received
for a ROMA project may only be used for that project, and no other purpose.
S. Reporting protocols
6. Any other information deemed necessary by the district engineer
For an in -lieu fee program, a complete instrument must also include the following
information:
1. Compensation planning framework (33 CFR 332.8(c)/40 CFR 230.98(c));
2. Specification of the amount of advance credits (33 CFR 332.8(n)/40 CFR 230.98(n))
and the fee schedule for these credits;
3. Methodology for determining future project -specific credits and fees;
4. Description of the in -lieu fee program account (33 CFR 332.8(i)/40 CFR 230.98(i)).
Costs for Alternative 2 are estimated at $45,527
A brief summary of the advantages and disadvantages of this alternative is provided below:
Advanta es
• Allows Monroe County to control the mitigation program and not rely on the
performance (either technical or financial) of a 3rd party provider (such as KERF or other
mitigation contractor)
• Eliminates the potential for having to advertise for a mitigation provider
• Monroe County could contract with a qualified 3rd party provider as mitigation contractor
to implement some or all of the approved mitigation activities and monitoring
requirements at any time during the life of the MOA
• Monroe County could exercise the option in 373.4135(7) and limit the mitigation to
single family residences. This would limit the potential for the mitigation program to be
perceived by the public as a service to the development community rather than a needed
alternative for our community
Disadvantages
• will require substantial Monroe County staff resources to complete the MOA, Prospectus
and applicable Environmental Resource Permits, may require additional staffing
• Requires the County to be responsible for the implementation and long term ('in
perpetuity) success of the mitigation areas
• Requires staff resources to locate, design and permit the appropriate mitigation areas
Alternative 3 — County as Mitigation Provider for SFR &Commercial proiects that
require mitigation from ALOE, FDEP and/or SFWMD
• File application with the State to create & operate a Regional Off -site Mitigation Area
(BONA) and prepare a MOA in accordance with State statutes (373.4135, F.S.). At a
minimum, the memorandum of agreement must address the following for each project
authorized:
1. A description of the work that will be conducted on the site and a timeline for
completion of such work.
2. A timeline for obtaining any required environmental resource permit.
3. The environmental success criteria that the project must achieve.
4. The monitoring and long-term management requirements that must be undertaken for
the project.
5. An assessment of the project in accordance with s. 373.4136(4)(a)-(i), until the
adoption of the uniform wetland mitigation assessment method pursuant to s.
373.414(18).
6. A designation of the entity responsible for the successful completion of the mitigation
work.
7. A definition of the geographic area where the project maybe used as mitigation
established using the criteria of s. 373.4136(6).
8. Full cost accounting of the project, including annual review and adjustment.
9. Provision and a timetable for the acquisition of any lands necessary for the project.
10. Provision for preservation of the site.
11. Provision for application of all moneys received solely to the project for which they
were collected.
12. Provision for termination of the agreement and cessation of use of the project as
mitigation if any material contingency of the agreement has failed to occur.
13. Provision in the agreement for additional projects to be added and evaluated as they
are identified.
File prospectus with U.S. Army Corps of Engineers and the Interagency Review Team
ORT) to create and operate an In -Lieu Fee (ILF) program in accordance with the Federal
mitigation rule.
Requirements for Mitigation Bank and In -Lieu Fee Program Instruments
Mitigation bank and in -lieu fee program instruments must include the following
information:
1. Description of the proposed service area(s) in this case the Florida Keys
2. Accounting procedures
3. Provision stating that legal responsibility for providing mitigation lies with the
sponsor once a permittee secures credits from the sponsor
4. Default and closure provisions
5. Reporting protocols
6. Any other information deemed necessary by the district engineer
For an in -lieu fee progam, a complete instrument must also include the following
information:
1. Compensation planning framework (33 CFR 332.8(c)/40 CFR 230.98(c));
2. Specification of the amount of advance credits (33 CFR 332.8(n)/40 CFR 230.98(n))
and the fee schedule for these credits;
3. Methodology for determining future project -specific credits and fees;
4. Description of the in -lieu fee program account (33 CFR 332.8(i)/40 CFR 230.98(1)).
Costs for Alternative 3 are estimated at $511,155
A brief summary of the advantages and disadvantages of this alternative is provided below:
Advanta es
• Allows Monroe County to control the mitigation program and not rely on the
performance (either technical or financial) of a 3'' party provider (such as KERF or other
mitigation contractor)
• Eliminates the potential for having to advertise for a mitigation provider
• Monroe County could contract with a qualified 3rd party provider as mitigation contractor
to implement some or all of the approved mitigation activities and monitoring
requirements at any time during the life of the MOA
• Monroe County could exercise the option in 373.4135(7) and limit the mitigation to
single family residences. This would limit the potential for the ROMA to be perceived by
the public as a service to the development community rather than a needed alternative for
our community
Disadvantas
• Will require substantial Monroe County staff resources to complete the MOA, Prospectus
and applicable Environmental Resource Permits, possibly requiring additional staffing
• Requires the County to be responsible for the implementation and long term (in
perpetuity) success of the mitigation areas
• Requires staff resources to locate, design and permit the appropriate mitigation areas
Alternative 4 — County's MOA and ELF includes a 3rd Party Mitigation Provider CURF or
other TBD}
The county would file an application with the State to create & operate a Regional Off -site
Mitigation Area (BONA) and prepare a MOA in accordance with State statutes (373.4135,
F.S.), specifying in that application that Keys Environmental Restoration Fund (KERF) would
be establishing, implementing, and monitoring the mitigation areas, and would be responsible for
meeting both the state and federal requirements of full cost accounting and other technical
documentation requirements
This alternative will require the development of a detailed memorandum of understanding (or
contract) between Monroe County and the ultimate 3xd party provider (with KERF as the
mitigation contractor) that stipulates the performance criteria that we will require of the provider
as well as the criteria spelled out in the rules referred to above.
Costs for Alternative 4 are estimated at $170,198
Advanta es
• If we are able to Sponsor KERF and reach agreement on performance criteria, this
alternative has the best chance meeting the Federal deadline of June 2013 and not leaving
a window of time when off site mitigation is not available in Monroe County
• KERF has a proven track record in providing the required services as well as the
relationships with land managers throughout the Keys to identify potential mitigation
projects
• Limits the amount of Monroe County staff resources required to oversight and
management rather than the technical involvement required in other alternatives.
Disadvan taffies
• Leaves Monroe County vulnerable to lack of performance by the selected Contractor and
the subsequent liability of the permit conditions
• Potential liability for long term maintenance of mitigation areas which may not have
adequate maintenance funding
• If we do not advertise, potential repercussions from other mitigation providers
NOTE: Purchasing procedures need to be evaluated to determine whether an RFP/RFQ is
required for 3rd party contractor of it the County can sole -source with KERF as the mitigation
provider.
Alternative 5 -- Take no C oW& Action
This alternative is simply the County not getting involved in the provision of wetland mitigation.
KERF would need to meet the Federal requirements for an ILF by June 2013 or cease to provide
mitigation for Federally regulated impacts.
In addition, KERF would need to find another governmental entity to serve as Sponsor and
would need meet State's requirements for a ROMA without the assistance or input of Monroe
County.
Advantages
• No requirement for staff resources
• Monroe County assumes no liability for any mitigation project or oversight
Disadvantages
■ If KERF does not find a sponsor and is not able to achieve compliance with Federal
regulations, residents of Monroe County will not have an off -site mitigation alternative
available after June 2013
■ Without off -site mitigation, most homeowners will not be able to meet mitigation
requirements for docks or single family residences that impact wetlands
Department of Environmental Resources
Suite #420
2798 Overseas Highway
Marathon FL 33050
Voice: (305) 289-2500
FAX: (305) 289-2536
Table 2. Comparison of Mitigation Alternatives Services & Costs
Alternative
1 County Operation of In lieu Fee (ILF) Program Only
2 County Operation of a ROMA & ILF for SFR Only
3 County Operation of full scale ROMA/ILF
4 County Contract w 3rd Party for ROMA/ILF
5 No Action * *
County of Monroe
Growth Management Division
Board of County Commissioners
Mayor David Rice, Dist., 4
Mayor Pro Tern Kim Wigington, Dist. 1
Heather Carruthers, Dist. 3
George Neugent, Dist. 2
Sylvia J. Murphy, Dist. 5
We strive to be caring, professional and fair
/
W
GOD O
WCVW
GODO
o
�
�o CV ,�
Q
o-1
�
�
O
Yes
No
No
$ 35J50.00
$ 9800.00
$ 133,750.00
$ 9800.00
Yes
Yes
No
$ 45,527.00
$ 9800.00
$ 144J27.00
$ 9800.00
Yes
Yes
Yes
$ 51J55.00
$ 9800.00
$ 149,755.00
$ 9800.00
Yes
Yes
Yes
$ 170J 98.00
$ 1000.00
$ 180J 98.00
$ 1000.00
No
No
No
$ -
$ -
$ -
$ -
* Either with Keys Environmental Restoration Fund (KERF) or through RFQ
* * Presumes that KERF is unable to achieve compliance with Federal Mitigation Rule & there is no Sponsor for a ROMA
* * * Administration Costs are recoverable through mitigation fees
Alternative 1— County as Mitigation Provider for Single Family Residential projects for which the ALOE requires mitigation, but that
are exempt from State mitigation requirements
Description of the proposed service area(s) in this
case the Florida Keys
Accounting procedures
Provision stating that legal responsibility for
providing mitigation lies with the sponsor once a
permittee secures credits from the sponsor
Default and closure provisions
Reporting protocols
Any other information deemed necessary by the
district engineer
Compensation planning framework
Specification of the amount of advance credits and
the fee schedule for these credits;
Methodology for determining future project --specific
credits and fees;
Description of the in -lieu fee program account
IRTIACDE Coordination & Revisions
Administrative Review, QA/QC
Uqj
� � � m ❑ z m
20
80
12
4
8
2
80
20
15
OZIJI
8
80
10 40
14 306 80
$ 1,108.97 $ 13,745.21 $ 2,810.64 $
120 16
40
40
20
zoo
zo
476 52 928
16,043.58 $ 1,450.72 $ 35,159.12
Alternative 2 — County as Mitigation Provider for Single Family Residential projects that require mitigation from ACOE and FDEP mitigation
requirements
Jz
s
o m LIJ �► a
a: �o Ica �Q
Description of the proposed service area(s) in this
case the Florida Keys
20
80
40
8
Accounting procedures
12
4
Provision stating that legal responsibility for
providing mitigation lies with the sponsor once a
permittee secures credits from the sponsor
2
2
Default and closure provisions
8
8
2
Reporting protocols
2
8
Any other information deemed necessary by the
district engineer
20
40
16
Compensation planning framework
4
12
Specification of the amount of advance credits and
the fee schedule for these credits;
4
12
Methodology for determining future project -specific
credits and fees;
8
40
Description of the in -lieu fee program account
8
A description of the work that will be conducted on
the site and a timeline for completion of such work.
40
40
A timeline for obtaining any required environmental
resource permit.
10
20
The environmental success criteria that the project
must achieve.
8
20
The monitoring and long-term management
requirements that must be undertaken for the
project.
UMAM assessment
A designation of the entity responsible for the
successful completion of the mitigation work.
Provision and a timetable for the acquisition of any
lands necessary for the project.
Provision for preservation of the site.
Provision for application of all moneys received
solely to the project for which they were collected.
Provision for termination of the agreement and
cessation of use of the project as mitigation if any
material contingency of the agreement has failed to
occur.
Provision in the agreement for additional projects to
be added and evaluated as they are identified.
SFWMD/IRT Coordination & Revisions
Administrative Review, QA/QC
8 20
40 1 120
21 81 1 8
41 1 24
2 1 8 1 1 12
20 120 200
10 40
46 362 80 604
$ 3,643.75 $ 16,260.68 $ 2,810.64 $ 20,357.82 $
15
20
88 1180
21#455.07 $ 45,527.96
JAIternative 3 --- County as Mitigation Provider for SFR & Commercial Projects that require mitigation from ALOE, FDEP and/or SFWMD
•, o �.
❑ CO Q
Description of the proposed service area(s) in this
case the Florida Keys
30
80
40
8
Accounting procedures
16
4
Provision stating that legal responsibility for
providing mitigation lies with the sponsor once a
permittee secures credits from the sponsor
2
8
2
Default and closure provisions
8
8
2
Reporting protocols
2
8
Any other information deemed necessary by the
district engineer
40
60
16
Compensation planning framework
4
12
Specification of the amount of advance credits and
the fee schedule for these credits;
4
12
Methodology for determining future project -specific
credits and fees;
8
40
Description of the in -lieu fee program account
8
A description of the work that will be conducted on
the site and a timeline for completion of such work.
40
40
A timeline for obtaining any required environmental
1
resource hermit.
10
20
The environmental success criteria that the project
must achieve.
The monitoring and long-term management
requirements that must be undertaken for the
project.
UMAM assessment
A designation of the entity responsible for the
successful completion of the mitigation work.
Provision and a timetable for the acquisition of any
lands necessary for the project.
Provision for preservation of the site.
Provision for application of all moneys received
solely to the project for which they were collected.
Provision for termination of the agreement and
cessation of use of the project as mitigation if any
material contingency of the agreement has failed to
occur.
Provision in the agreement for additional projects to
be added and evaluated as they are identified.
S FwMDIIRT Coordination & Revisions
Administrative Review, QA/QC
s 1 1 20
8 20
60 1 160
121 1 40
20 120 200
10 40
46 424 88 680
$ 3,643.75 $ 19,045.66 $ 3,091.70 $ 22,919.40 $
15
20
88 1326
2,455.07 $ 51,155.58
Alternative 4 — County's MOA and ILF includes a 3rd Party Mitigation Provider (KERF or other TBD)
a�
Prepare RFPISOQ 2 24 6
Coordinate draft MOA with Consultant 20 80 10
Coordinate Consultant activities 8 120
Quarterly report review 8 2
Project Management (annually post permit) 12 120 20
42 352 38 432
$ 3,326.90 $ 15,811.49 $ 1,060.14 $ 20,198.54
Consultant Permitting Costs estimated at $ 150,000.00
$ 170,198.54