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Item U4 BOARD OF COUNTY COMMISSIONERS AGENDAITEMSU~ARY Meeting Date: 19 February 2003 Division: Growth Management Bulk Item: Yes No -1L. Department" Marine Resources AGENDA ITEM WORDING: Discussion of issues and potential resolutions to concerns involving the connection cost for residential and commercial properties to Key West Resort Utility. ITEM BACKGROUND: At its January meeting the Board heard from commercial and residential property owners on Stock Island concerning the cost of certain requirements for connection to Key West Resort Utility. The discussion started during a hearing on an ordinance to amend the connection requirements in the County's "Mandatory Connection" Ordinance and new provisions for providing a longer timeframe to pay connection fees. Staff has had an opportunity to meet internally and with Key West Resort Utility and has some suggestions about ways to resolve some, but not all, of the property owners concerns. PREVIOUS RELEVANT BOCC ACTION: January 2003 - Review and Table of an Ordinance providing the means to extend connection fees payments CONTRACT/AGREEMENT CHANGES: NA STAFF RECOMMENDATIONS; Board discussion TOTAL COST: None BUDGETED: Yes No COST TO COUNTY: None SOURCE OF FUNDS: REVENUE PRODUCING: Yes No -1L. AMOUNT PerMonth Year APPROVED BY: County Atty -1L. DIVISION DIRECTOR APPROVAL: DOCUMENTATION: Included DISPOSITION: AGENDA ITEM NO.: OJ/ BC0302120 02/03/032:37 PM AGENDA ITEM WITH LATE DOCUMENTATION DIVISION DEPARTMENT SUBJECT AGENDA ITEM NUMBER Memorandum DeD.rtment ofM.riDe Resources 2798 Overseas Highway, Suite 420 Marathon, Florida 33050 Voice: (305) 289 2507 FAX: (305) 289 2536 Email: earren-!!eon!e:i1monroecountv-tl.com Board OfCouDtv Commissioners Mayor Dixie Spehar, Dist. I Mayor Pro Tem Murray Nelson, Dist. 5 Commissioner George Neugent, Dist. 2 Commissioner Chlrles "Sonny" McCoy, DisL 3 Commissioner Nora Williams, Dist. 4 DATE: 19 February, 2003 TO: Board of County Commissioners FROM: George Garrett, Director of Marine Resources SUBJECT: Update on Key West Resort Utility Matters Introduction Staff has made a preliminary review of issues raised by numerous property owners concerning connection requirements to Key West Resort Utility. Based on that review staff offers the following information and suggests that an additional month to two months be utilized to work with the Utility on a property by property basis to consider connection options. A recommendation on policy and specific solutions will be provided to the Commission at either its March or April regular meeting. Backeround --".... In late July 2002 at a special meeting of the Board, the Commission approved a Contract with Key West Resort Utilities (Utility) to expand wastewater service to the remainder of south Stock Island not currently served by the Utility. Construction on the expanded wastewater project area began in October 2002 and has progressed rapidly. At the January Commission meeting, the Commission heard from a number of individuals, homeowners associations, and private commercial property owners concerning connection to Key West Resort Utility. Most concerns revolved around technical requirements (engineering related) for connection to the utility and around the Utility and Service Agreements required by the Utility. ~ BC0302121 02119/038:00 AM -It .L.t Since the January Commission meeting, staff has met internally, with Key West Resort Utility, with a number of property owners, with the Florida Keys Aqueduct Authority, and has participated in a teleconference with the Public Service Commission. Staff has also talked with a number of individuals in telephone conversations about the project. The most recent meetings occurred as late as Monday and Tuesday of this week. Actions Since BOCC Meetine Meetings 1. 23 January 2003 - Internal staff meeting . George Garrett . Dave Koppel . Ken Williams 2. January 2003 - Meeting withBoyd's Campground . George Garrett . Ken Williams . Danny Hamilton 3. 10 February 2003 -Meeting withKWRU . George Garrett . Dave Koppel . Ken Williams . Doug Carter . John Johnson . Chris Johnson . Ed Castle 4. 17 February 2003 - Teleconference with Public Service Commission staff . Ralph Jeager - PSC staff . Other PSC staff . Tim Keonig - Coral Hammock . Danny Hamilton - Boyd's Campground . Representative ??? - Hurricane Hole Marina . Representative ??? - Carlisle Group . Representative ??? - PropertylProject ???M. Commissioner Nelson . George Garrett . Ken Williams .... 2 5. 18 February 2003 - FKAA Meeting . George Garrett . Ken Williams . Jim Reynolds . Jack Teague . Ray Shimokubo Telephone Communications Doug Carter - Key West Resort Utility Danny Hamilton - Boyd's Campground Diana Moore - Harbor Shores Condominium Jeff Weiler - Weiler Engineering Kim Wigington - Harbor Shores Condominium Issues Engineering Design · Options - buffer tanks versus vacuum pits and other considerations Questions raised by property owners at January's Commission meeting are mirrored in documents provided by CH2MHill in July 2002 (Exhibits 1 and 2). The concerns revolve mostly around the responsibility of parties for potential expenses, as they would be incurred by the Utility in providing a Utility connection or by the property owner in preparing to acquire a connection. Questions are raised about the issues of "connection equity" or whether one property owner, in relatively similar physical circumstances to another property owner, would pay similar amounts to acquire a Utility connection over and above the Utility connection fees ($2,700 per Equivalent Dwelling Unit). In other words is there relative equity in the costs that would be incurred for on-site improvements in preparation to make a connection to the Utility? · Weiler quote and explanation of quote Weiler Engineering was asked for and has provided a quote for additional services (primarily the provision of 74 additional vacuum valve pits), principally for the mobile home parks and campgrounds located alongMaloney Avenue (Exhibit 3). .... 3 ~L/~~"~V~ ~~.UU ~U~-,O~-L~~O r-LHNNJ.NI..l Vl:..t'J t-'Abl:. l::l~ In subsequent discussion with the Utility, staff requested and received an explanation from Weiler Engineering concerning the proposed location of each new vacuum valve pit suggested in the quote noted above (Exhibit 4). Utility and Service Aereements. · PSC issues - Questions of Contract content Staff was made aware of six complaints raised to the Public Service Commission (PSC) against Key West Resort Utility as late as 5:00 PM Friday afternoon February 14) 2003. On February 17,2003, staff participated in a teleconference with the Public Service Commission to hear and discuss issues raised by the complainants. Though there appear to be substantive issues concerning the content of contracts required by the Utility, they appear to be contractual legal issues that can best be resolved between PSC staff and the Utility or between the complainants and the Utility. Complaints and issues, as raised to thePSC are provided as Exhibit 5. Recommendations Staff feels that additional review of the issues is required, particularly including · a thorough review of engineering options, on a property by property basis, with Key West Resort Utility and Weiler Engineering. · a thorough review of the Weiler Engineering quote for additional engineering services in light of a review of current engineering plans. . Staff feels that the issues surroWlding the Utility and Service Agreement requires some additional review, including · a review of example contract documents by the County Attorney's Office · coordination with the Public Service Commission in their deliberation over complaints from various potential Utility clients Based on additional review: · staff will provide policy recommendations concerning the individual property connection options where not currently resolved. · Any additional potential costs will be considered and a specific and detailed recommendation concerning those costs will be provided. · Staff will also provide additional recommendations as they would apply to future projects. 4 CH2:MHill Documentation (2) Weiler quote Weiler Explanation of quote PSC document I ,..,......L. V.,J Documents 5 EXIDBIT 1 ...._-~._. .,. 6 '~ CH2MHILL: .. .~ /~ July 5,2002 Mr. Tim McGarry, D#ector Division of Growth Management Monroe County 2798 Overseas Highw~y, Suite 420 Marathon, Florida 33(1)50 Subject: KW Resort Utilities Wastewater Collection System Expansion CH2M HILL 64 10 51h Street SUil&2A Key Wesl, FL 33040.5835 ,., 305.284.1145 f'lx 3ClI.2N....,3 I I Dear Tim: .' I We have made a general review of the drawings for the proposed vacuum sEtwer system expansion. Out observations are summarized below. , i 1. It appears that all existing systems that are currently connected to package plants are proposed to belconnected to the new vacuum sewer system by mearuf of buffer tanks, a common type of connection to a vacuum system for larger c:once~trated flows. It would be lJeneficial if I<W Resort Utilities would confirm this anclf. identify the buffer tanks where these connections are to be made. 2. Are the proposed buffer tanks always immediately adjacent to the wastewater treatment plants (WWTPs) or pumping stations to be abandoned? 3. How aTe the bufferitanks to be paid for? We did not see a unit price for buffer tanks identified in the Bid Proposal. . 4. It is indicated that there are currently 1,775 existing equivalent dwelling ~nits (EDUs) (KW Resort Utilities refers to these as equivalent residential conn~ons CERCs]) that are not served by central sewers. I 5. It is also projected that approximately 1,000 EDUs will connect within one year, with the balance to connect over the next five years (155 connections per ~ear). Where are these 775 EOUs that will connect over the next five years? ' 6. There are four area~ within the limits of the proposed sewer system exp+ion with the note, " Area Required to Install Internal Vacuum Tanks". Exactly rhat is reqiured, who is re~ponsible for both insta1Iing the internal vacuum tanks[and the the associated costs; when will this work be done, and how many EDDs are in these areas? i 7. Review of the drawings indicates there are other smaller trailer parks. some housing areas, and other areas that do not have vacuum sewer facilities (vacuum valve pits) adjacent: to the properties for easy connection to the new vaCU1.Jm sewer system. How will these areas be connected to the new vacuum collection system expansion? ' ... Mr. Tim McGarry ~, July 5, 2002 Page 2 B. There are only 87 ~acuum valve pits included in the Bid Proposal for aU ithree phases. Considering the buffer tanks used for connecting the approximately 410 BOlls currently mil package plants (the contributing flow from buffer tarlks is limited in a vacuup1 sewer system), the 87 vacuum valve pits appear to ~ low. There certainly is . good design reason for the low number of vacuum v~ve pits, but the reason is ~t apparent to us. : i It is my understandin$ that three of the bids received on June 27 were just s,ghtly above the $4,600,000 E1Stimate, and that I<W Resort Utilities expects to have~gotiated a contract price of $4,600,000 with one of the three lowest bidders by the Jul 17 BOCC meeting. In our opinion, the $4,600,000 is a reasonable price for the work in lved. The fact that the threeilowest bidders were within about five percent of each lother also confirms that the $4,600,000 is a reasonable price. . . ' i , Please let me know haw you want to proceed from here. Except for July 8 ~ 9, I am ,~, available to meet with I the County, and KW Resort Utilities, if you desire, at 1Y0ur convience. In the meantime, f~l free to call me with any questions or comments. I I ~ce~, I ~H2M ~LL 7. . <<',#/ I) , .~~ '(At. eth F. Williams, RE. ...4'~' c: George Garrett ~ ..'" .... EXHIBIT 2 to ..jiI..' ... 7 CHaM HILL 6410 5th Street Suite 2A ~y West, Fl 33040-5835 _1305.2M.1M5 Pax 305.284.4913 r~'.. CH2MHILLi .~ ~ / ~ July 11, 2002 Mr. Tim McGarry, drector Division of Growth Management Monroe County 2798 Overseas Highway, Suite 420 Marathon, FL 33050 Subject: Estimated Number of EDUs Currently Connected to Existing Paclkage WWTPs that are Proposed to Connect to the KW Resort Utilities Sewer Sy~tem Expansion Dear Tim: I One of the tasks of 00/ Work Order No.1 authorization is to estimate the n+ber of EDUs currently connected to package wastewater treatment plants (WWTPs) withijn the KW Resort Utilities Service Area. All these connections are proposed to connect tb the sewer system expansion. This letter provides the EDU estimate and the approach t4.ken to arrive at this estimate. I To estimate the EDUs associated with existing package plants, the Consul~t requested and obtained from FKAA lall their Stock Island water accounts and water use dat~ for the ll-month period May 200l-March 2002. The Consultant then sorted these water accounts to estimate the number of accounts that currently discharge to existing package I WWTPs and that are proposed to connect to the KW Resort Utilities expanded wastewate1l' collection system. Two agencies, the Flotida Department of Health (DOH) and th. .e Florida De~fhnent of Environmental Protedtion (DEP), permit and regulate WWTPs within the K~ Resort Utilities Service Area.iThese WWTPs are summarized below. The phase of th~ collection system expansion where these systems would connect is shown in parentheses, I DOH is responsible far: I · Spottswood comntercial strip mall along McDonald Avenue, which connected to the inactive Pearl Trailer Park Secondary WWTP (Phase I). I · Burger King Restaurant Secondary WWTP (Phase I) I DEP is responsible for: · Waters Edge Colony Secondary WWTP (Phase I) · Roy's Trailer Park Secondary WWTP (Phase I) ~ . Boyd's Campgroumd Secondary WWTP (Phase I) Harbor Shores Mo~ile Home Park Secondary WWTP (Phase III) . ~ , Mr. Tim McGarry, Director I Page 2 July 11, 2002 137483.AP.SI · Coconut Grove Mobile Home Park Secondary WWTP (Phase III) · Peninsular Marine Enterprises Secondary WWTP (Phase III) · Oceanside BAT WWTP (Phase III) , Exhibit 1 provides a summary, by phase, of the estimated EDUs currently on package plants that are proposed to connect to the expanded wastewater collection system. IEDUs are shown for both the I4W Resort Utilities EDU definition and the FKAA EDU definition. Both entities define residential EDUs in the same manner-individually metered ~ving units, whether they be single family homes, a mobile home, an apartment unit, a c~ndo unit, or a unit of a duplex, triplex, or quadraplex-are defined as one EDU. Commerc,al EDUs are defined differently. J{w Resort Utilities defines a commercial EDU to be eq~valent to a water use of 205 gallons per day (gpd), with a minimum of one EDU, where~ FKAA defines a commercial) EDU to be equivalent to a water use of 167 gpd, with alminimum. of ~~ I I ! ~'. EXHIBIT 1 Estimated EDUs of Systems Currently Served by Package WWTPSl KW Resort Utilities System EDU Definition FKAA EDU D8flnltlon Phase I Spottswood Commercial Strip Mall Burger King Waters Edge Colony Roys Trailer park Boyd's Campground Subtotal Phase I Phase III Harbor Shores 1M0bile Home Park Coconut Grove! Mobile Home Park Peninsular Marine Enterprises 2 Oceanside Marina Subtotal Phase III 13.8 5.4 65.0 108.0 44.3 236.5 i I I ! 1412 6.~ 6811 108.0 54;5 70 34 9.8 3 60.6 3 174.4 251.4 I ! ~~ 12Jo 14 69.5 4 185J5 _r: GRA'ND TOTAL 3 410.9 . 4 436J9 1See Attachment A for more detail on EDU determination 20nly BAT facility, all others are secondary facilities. 321.6 are current EDUs; 39 are future ED Us for condos and restaurant. 426.5 are current EDUs; 43 are future EDUs for condos and restaurant. ,...,.r-___, I ! For Oceanside Marina, 39 EDUs (43 FKAA EDUs) (condo units and restaurant) do not exist today, but construction of the condo units has started. It is therefore assumed I that the condo I units and restaurant will exist by the time the sewer system expansion is operational. Therefore, the estimated number of ED Us connected to package plants per the KW Resort Utilities definition is 410.9, and the estimated number of EDUs connected to packctge plants per the FKAA definition is 436.9, a difference of 26 EDUs, which is only abou~6 percent difference between thel two definitions. I :~ Mr. Tim McGarry, ~ector Page 3 ' July 11, 2002 137483.AP.SI Only Oceanside M~a has a BAT facility, all the other eight WWTPs are secondary facilities. : Sincerely, c George Garrett DFB31003696181.doc/b21900001 --------... ~.. .... r--, ATTACHMENT A Detailed EDU Determination Process for Systems Curren6y Served by Package WWTPs Spottswood Commercl*1 Strip Mall Note: This is a new facility, so long term water use data generally is not available. . FKAA accounts, 54501 McDonaid Avenue, all <167 gpd, or 205 gpd FKAA account First State Bank Average daily water u~e, 360 gpd I Burger King FKAA account, average daily water use 1,107 gpd Waters Edge Colony I FKAA individual acc04nts, per lot FKAA account, ITNOR Corp. Average daily water use, 2,860 gpd .r---....... Roy's Trailer Park FKAA individual accounts, per lot Boyd's Campground 4 FKAA accounts Total average daily water use, 9,080 gpd Harbor Shores Mobile Home Park FKAA individual accounts, per lot FKAA account, Harbor:Shores, Inc. Total average daily water use, 110 gpd Coconut Grove Mobile Home Park FKAA individual accou~ts, per lot Peninsular Marine Enterprises No FKAA account foun41 ED Us Estimated from WWTP flow Average daily flow, 2,OQO gpd Oceanside Marina Note: Per Monroe Courity Planning Department, 22 Condo Units and a . . 2,500 sq ft expansion to restaurant are proposed 22 condo units Expanded restaurant1 78 seats @ 40 gpC!l = 3,120 gpd 20 bar @ 20 gpd = 400 gpd Total estimated average daily water use, 3,520 gpd FKAA water account Average daily water usel 8,850 gpd Assumed that 50% of water use goes to boat washing, etc. Net average daily water use, 4,425 gpd lNo recent water use history available as restaurant has been closed DFB31003696181.00ClO21900001 N,. eous KW Resort. FKAA 12 12 1.8 2.2 13.8 14.2 5.4 6.6 51 51 14.0 17.1 65.0 68.1 108 108 44.3 54.5 69 69 1 70 1 70 44 44 9.8 12.0 _.~. ; 22 22 17 21 21.6 60.6 26.5 69.5 .... EXHIBIT 3 'Ol 8 ~~/~~/L~~~ ~~:~~ ~~~tl~"'/.LtI'" ...< ...,,~=:;;2.~~d;2iCj,;~;;~;;1~t;;;~~:,1i.iZ. ..-i.... Weiler Engineering Memo To: FftHn: ce: DMe: CCIIl.!cnr Ne,sorv117 l<7 Ft JI1f'Weil8l', P.E. V 7.{v/lJ!A BlU Smith, Ed Cari., ~.E.., Jot1nJOhnson, F.E. 2J2aI20Q3 Stock J!Jand Sewer :cpsrlCigr'I/WEC No, 02013 ReI COrnrn/$$ianer. We hav. evalulted the ~ddmonal C:OS~ to prgvide valve oito Witnln tne County right-of-way to servQ the traIler par" and C8mpgrouna aniilS on South Stock Island. Ol:r ear/mate of sao9.. is tQ PrcvIde one varve pit per I~ ~OU's per t~e manufacture's design CliterJa. The estimate might be reduCl!d by as rnud'l as $153,000 to iJcc"Ol:imatel~ SS,5e,S9S if the exl9Mg cn-!IIle collection and distribtmon systems can be utU~ :0 buffer the discharge rate to lese; than three gallons per r"invte pit val"'l! pit pr10r 10 dlscharging to the COJnty rtght--of~y, It appears that utJ1iz1ticr't af some cf the exisUng, on. systems is feasible fer at least so,'. d the pro~,1ies. others, ~ may be more eco"omj~l to eltnet' provide new services to tMe I\ght4-NBY er ;onst1iels YIlQ./um coll~" sysmam on;ile. ~l_e understb lQ tnat rnj~ estimatfl has b~ co"'I)Ieted withOI.l: , detailed design and may vary. As aIY.iays, please feel free to Sive me ;J caU at (941) 764-64.4; if yeL: have any Questicns or wish to diseus; mat1ers further. ... ~2/~4IL~~~ ~~:~~ ~l:lOt:l~~(lb:': I."UMM NELSON PAGE B4 ,- . ..... .:' '::'?~:l~~f:;'~:~~~':;)i ::;:::t{:;'?~i',;\,:;~;.: ". .. ',' :'. ",'. .... .'. ,". .. '. '.-, : .~ . . . .. . . ,'..... .." .,......... ..' - " , "J. '" '. ......, -_;:--;: ::-2~.3 1e: 23 The L..allJ Offices of SHB&B 13129397765 P.El2 srOCK ISLAND V ACUtJM SEWER PROJECT COST ESTIMAtE 'OR ADDmONAL WORK TO SERVICE TR..l n I:R PARKS rttM , UI\'lT NO. Dl.5CIUPTIOS Q~. tINtT Rille! AMOl.1NT (S) (S) l. MArNnNANCE OF TMmC J LS 10.000 10,000 z. COXST. STAn OUT" ASaaUf'_TS 1 LS 10,000 10,000 ), 6~ PVc. SDItJ J v ACtTtlM SEVtlJl. ~.'SO L1' 4& ao.soo 4 3" PVC. SDIU! VACUUM SiV.T.1. 1,000 LF 410 :to,lXlO s. 6" pvc. StiR. z' GRA VrlY UvnR. J,ooO U' 1 45 4:f,OOO 6. 6~ DIVIS!ON VAlVES 15 U "6 9."Q ,. VACUUM m nn ',e' COMPlm" 74 EA 4.810 3%.000 I, ASPIW. "f' R.ESTOltAnoN 200 SY 2S 5,'00 9, CONO!n SIDEWALK W:'AC!MENT 500 sy 30 I $,000 iO. CONCR.!TE ~A y ImPIJR. !OO sv 30 1$.000 11. SHELL DlUVEWAY ~PAI\K:'NC:WAlP. 500 sy 7 ~oo 12- SERVICE CL~OUTS 100 EA J4~ 14.900 13. CONC:RETE ENCASEMENT 100 LF' 26 2.600 ,;I stm-tl;)r AL ~$TIMAu Uil,()90 iNGlM"EiRING I: ~SPECnON @ ''fa S49,d4 ., "'OMlNlS'I'R.'~TION.t 1.ECW. @ l06A $61.109 CONTINGENCY i 10% S61.IOP nmNGi3~ IJa,S4J 't"OT,\L ESTiMATE $109,'9' . " Based upon apP%'OXJmate1y : tmlc pE:r 6 \1r1its or existing fow data with an additional 5 contingency raab. ... EXHIBIT 4 _",Co. ~ 9 _,. ,..1M I LL .".. ....... "" ..... V' ...... U".I. I". v U.L u PHONE NO. : 305 294 4913 "O:.L.LOCJ ....Ub.LUocel.LU. Feb. 18 2003 09:53AM P3 lIIJUU":/UU", "Excellenu In Engineen'1g"' ~0020 Vmlilm Blvd.. St:irc '7.9 PMt Ch:\dotl:c FL 33954 (5" 1) i6';.6447 ph (9!'\) ;64-8915 €a.\: -;.. : WEILER ENGINEERING CORPORATION DOClClli656 Februmy 12. 2003 Mr. Georae Gmrett, Director Divi!;ion of Marine Resources Monroe COunty Regional Service ':emet 2798 O\'erseas Highway Marathon. FL 33050 RE: K W Resort Utilities - SWf;.k bland Expansion- Design Criteria Dear Mr. Garrett: The purpose of this letter is to provide requested information cona:ming additional resources !eQUired to provide vacuum Pits at County CXpCDJC for the larier mobile home parks on Stock Island. Following are peniJ3ent poiats from the meeting; 1, The following are the affeeted propertie$ that have been provided a VICUWIl sewer stub rather than vacuum pits _VOt butter tanks: o Leo's Campground o Stock Island Trailet o !2 Mobile; on Lawel Ave o Coral Isle o WaterE Edge Colony o OQe8D Spray o E1 Senor Roughy o Rolphs o Woodso:1S o Boyds c Coconut ("!'Ow o Oceanside o StyroDs o 19 Apanmems on Maloney 2. The above propcniC5 were ~rovided a StUb only because based upon our analysis and AirVsc's COJ1ClDTe:DCe this '>.'as the preferred approach for the following r~ns: o The ~'eriDg configuration for optimal system reliance was for the aOOve properties to iDstall and or convert their eximne; sysr.ems to a vacmnn system ~;th Stock IslaDd Sewer Project - Rnpoll9! Letter Page ] ~ ... ....~ :~~HILL F~NE NO. : 305 294 4913 ---.. -----..--~ Feb. 18 2003 09:53AM P4 'C:.I """'"" vv't SWQk lsllJld Sewer Project - Response Leiter individual vacuum pits on their property. AirVae insisted upon this type of configuration at the time of project bidding. o Requirlni the aOOVI: properties to instaII vacuum pits ort their property was in accordance with M.)nrDl: Caumy Orrl~ ()4..2000 Section 1 and Chapter 381, F.A.C. Secticn381 .0065 (2)(a) since their flows exeeed 1000 gpd. o Given that all pfopl:rties must expend resources to hook up to the vacuum system, (or a gravity, low p:~sure, or force main system) it did not appear to be an unreasonable expec:tation that residentiel propcni~ with more than 6 ttailers be req uired to install the '\"KUUnl pitA at their expense. o Given that the best ::onfiguration for 1be phs was to be located on priv~ property, our SC4lpc of service and aad1ori't}. did not exten4 to include installation . on their property, 3. The properties that receivel buffer tanks are mta.u~,. apttt'tment buildm8s and 1rUlI'inas. ~ properties ,~ given tlIr1ks even though their flows exc:eed 1000 gpd because the most feasible CJ.eaI1S for them to hook up is for a buffer taDk to be placed in the R/W. 4. We recently provided an estimate to provide tanks for the properties listed in Item l above. 'The estimate was iJ'lXOximatcly $600.000 to $800.000 to provide ww in the R/W fer the referenced properties. While this option is ~chnical1y &!sible. the additional County expendi':ure will net equal the reduction in ~sts to the private properties. For the vast majority oftb.e a1Iecte;j properties, the overall (public and private) lo'West cost alternative will be far the vacuum pits to he installed on private property. S. The question was presented &3 to why these tanks were not provided in the original desigD, as if a mimke has heen made on our part. This could not be further from the trUth.. We desipd the system ror maocim.um :eliability, lowest cost and within the provisions of county ami state ordinauces. We could not be expected to foresee that the County may wish to a.c:commodate the Mobile Home Parks: beyond that stipulated by relevant mtu1es. 6. Mr. Williams persistently hdicat.ed that perhaps a vacuum system is not the preferred approach and that a force a1&ic c.xteDSion would be preferable. This analysis is flawed from the o~ since a force: main system would DOt provide "Available" seJ'\.ice to properties with less than 1 {IOO gpd tom! :tl.;>w 3IId most properties will prefer the vacuum system once they have analyzed the long term expenses associated with pumping stations. We have complet!d an a-tensive analysis of available technology and concluded that a "QCuum ~:'Stem is the best al.terDat:i.ve for a safe, reliable and affordable sewer 5yStem for &'tock !slane. CH2Mhill in the Master Plan for Monroe Cou."1ty also shared this conclusion and this is not significantly deeted by ih~ pos:5ibility of Smck !s1aJ:ld S~ Project - R..'"SpODSC Letter Page 2 .... :;..:;:MH I LL .- .....,"" ..' "'v ...&a.u. ",...,. .... ""..., PI-GE NO. : 305 294 4913 It\J..L~1 ~.u,",,,,.& .1.&.&0 Feb. 18 2003 l1l9: 54AM PS llWUU'f.' \,I\,/'t ~mck IsJud Stwer Project - RMpcmsIlar traDSfening $600,000 to SSOO.OOO of total costs ii"om private property owners to the County . 7. Determinine the best altmtative for each facility noted in Item 1 above will :require a d~cd anaJ.ysis of t.beir ~'ltem. Such an aua1ysis was DOt iDcluded in our O:riginal or CWTel1t scope ~f &erVices. S. We desi&ned the ~ to be capable of providing sewer service in accordance with COlmty and stGte stItUtt4I. Ow- design ~ the best sewer alternative b Stock Island and we are confident tho d.::sign will withstaad an>" crcch'ble critical analysis, If I can be of any further assislancI: with this issue, please do not besitate to contact me at 941- 764-6447. Sincen:ly, ~ Joh11 Johnson PE Weiler EDlinecriJJg Corporation CC: Dave Koppel, Monroe County Ken Williams, CH2Mbil1 Bill Smith., KW Resort TJtiities Doug Carter, KW Resort ltilities Jeff Weiler. Weiler Etlsine:ring f/ Stock [sland Sewer Project - RespODSe Letter Pato 3 .... EXHIBIT 5 _.._"If' . ..... 10 ,>.-- ~_:~ ~_:___~_ ~.~1_;_<_ , ,.,. i7/~E103 11:58 185134137180 FPSC PAGE 02 ;.::::: , .- ,j : < ..' { ...,;. -.."... summary of complaints an~ Commission concerns regarding service availability agreements of KW Resort Utilities Corp. (The opinions contained ~Ln this document are those of Commission ';_3.== and do not bind tbe commission's decision on any future vote on this matter.) CCMPLAlNANTS CC'ral Hammock, LLC new development, has signed developer c~~eement noting objections to certain sections and provisions of a~reement - System Construction, Property Rights, Indemnification, aLd Insurance provisions. In prooess of ;f1ling formal complaint ""if:.b. Commission. Hclrbor Shores Condomin.ium Owners Associatioin Inc. delvelopment, has not YE!t signed developer agreement. ,::c':lcerns about overall tc-ne of agreement language. New General Boyd's Campground - Existing development, has not signed developer =~~reement due to concern:3 over Property Rights, Indemnification, :r:s'...:rance, and sees no nef!d for bill of sale, etc. if not conveying ::.nes to KW. -'. =2isle Group - New development in early stages of permitting. .:::y concerns related to e.greement, payment of service availability charges, tariff availability, and graVity/vacuum system 1"equirements and readinee:s. Sd.fe Harbour Marina - Existing marina already connected to KW 'ste~, service availability charges established in early 2002. KW c.. aims a change in type,' amount of service and wishes to charge additional capacity. Chc~nge in service centers around additional restaurant seating capacity and concerns over existence/installation of commercial grease trap. -,.~:,'. j{ilrricane Hole Marina - :~xisting marina, trying to connect to KW 'C:Tstem. Main dispute is with ERe calculation. Hurricane Hole under :'l~~W ownership and expanding/planning to expand. Requesting sllpporting information justifying ERe estimates. ~::-ILITY AGREEMENT .....~!"Icerns over the Utility Agreement center around the following -1- ....... .. ,,~-- ;..,. 3:5:'- -i> S<f-:< '.. ...-.....> ~. ~W~ _ ,- i ~ 2103 11 : 58 18504137180 FPSC PAGE 03 areas: ~SSUE 1} Section 2, System Conatruction, subsection {all "Prior to the construction and installation of the system, Developer shall, at its sole cost ana expense, cause to be prepared and provide to service company plana and specifications of the system ("Plans ana specifications"), which Plans and Specifications shall be prepared by 8ZJgJ.ueers acceptable tc> Serv:Lce campeu2Y, :l.u :its sole jUJd absolute disaret.iol1, in accordance with all policies and practices of Service Company and all applicakle lawa and regulations and standards adopted by the Department ot Envircnmental Protection and Monroe County." =-"velopers have expressed concern that this clause may constitute a conflict of interest. ':::;~~ission Staff Preliminary Concerns: Standards related only to ::ertification and licensing should provide sufficient safeguards to - :.~ 'utility with regardi3 to any engineer's qualifications and ~.;.'"aiity of service. Su::h approval should not be withheld for :)t.herwise qualified engineers absent specific justific;ation by the utility. ~"ference: Rules 25-30.540 Administrc.ti ve Code ( 7) , 25-30.545, Florida ::::nstJE 2} Section 3, 'Syst.em Records I subsections (a) through (j): 2~reral1, this section SElems to be inconsistent with regards to \'lhether or not KW is to take possession of the collection system. Many of the subsection!3 ( (d) through (h)) appear applicable =E"3ardless of whether or not KW takes possession of lines. S'4bsections (a) through (c) and subsection (j) appear to only be l ~y~r:t in the eve::lt thclt KW is to take possession of the lines. - ~ .'. CmDlnission Staff Prelimirlary Concerns: This area of the agreement !"-,~eds to be clarified and/or should be divided into separate ~'~ctions. It is staff's opinion that for upkeep, repair, (':):J.nection, and disconnec!tion concerns, it is in KW's interest to _ _q~ire that all lines be conveyed to the utility. However, KW is entitled to establish r'3asonable standards that the collection s:{stem must meet prior tc such conveyance. If there are to remain c~rcumstances where KW is not conveyed the collection system, then -::::e record keeping requirements should be separated accordingly. -2- ....... ~......... .......... . ,- ~ .,' ,'4-. i. '-r..;;- -. .~.. . - ;Je3 11:58 1851341371813 FP:il,; PAGE 134 Referenoe: Rule 25-30.530 (3), Florida Administrative Code ISSUE 3) Section 4, Property Rights: T:,is section also ~~.: ~ership of the expressed concern appeal:S to be inconsistent with regards to collec':ion system. Several developers have over qranting these property rights to the -_.~~:.:.ty . CcDad..ion Staff Preliminary CODoerns: This area of the agreement also needs to be clarifiE!d as to whether or not ownership of the c~llection system has boen conveyed to KW. If the developer maintains ownership of thE~ collection system, then why would it not .Co: -che developer who is responsible for upkeep, maintenance, and repair of the collection :3ystem? In this case, staff is concerned tr..at such property right~:, easements, etc. should relate only to tJ:..ose instances where thE! collection system has been conveyed to ~.. Similar to Issue 2, if there are to be instances where the cc.llection system is to be owned by the developer and instances wt.ere KW owns the collection system, the agreement should address eccch of these circumstances separately. n:st7B 4) Section 5, Existing System, subsection (e): "In the event that Dl:!veloper's syseem after connection to service companies system needs; repair (other than non-emergency repairs) then Developer agrees to make said repairs within 30 days of notice by Service :~~any. In the event of failure by Developer to make repairs eo its system within saicj time periocj t:btm !Jer'VJ.ce Campill.1Y sball be permitted (but DOC obligated) to Jllak. [laid repairs. Any costs expended by Servi.ce CampiU2Y .:in ..J::iDg repa:l.r:. to Developarl s system sllall upon presentation of a b:i.ll to Developer be immediately due IIDd payable. In the eveDt of t:be Dc,,~d for emergency repa:i.rs to Developer's sys tem I Service Company shall be autbor.1J:8d to make sai.d rePairs (but .,ball not: be obligated) and upon pre.ll1enf:ation of a bill eo .Developer for said repairs sai.d bill s.hall be .:imm8d:i.aeely due iIl.1d payable." Commission Staff Preliminary Concerns: Through review of past, commission approved developer agreements, the language above has only been utilized during the conveyance of collection or d:_stribution systems. In the event that the developer owns the collection system and dCles not make timely repairs, why is the :::'(~medy of discontinuance of service at the point of connection not n.. ::::icient? -3- "II'- ...1.........,. " ..( J _ ',/~ ae3. 11: 58 185B413718B FPSC PAGE ElS :=.~ r erence I Rules 25-30.231, 25-30.225(6), 25-30.320 (2) (b), Florida A~ninistrative Code iSSUE 5) Section 6, Rates, Pees, Charges, sub.ection (b)z ~In the event that Develcper and Service Company shall not agree as to the number of Connectionlil rec;:uired by Developer for the Property, the deed.ion of the Service C~y "hall control, and Developer shall pay for, ana Service Company will reserve for Developer, the number of Connections specified by Service company. ':'.;.:nmissi.oD. Staff Preliminary Concerns: Pursuant to Rule 25- 30.560(1), Florida Administrative Code, such disagreements may be directed to the Public Service Commission for disposition by filing a written complaint in compliance with Rule 25-22, Florida Administrative Code. R~ferenc.: Rule 25-30.560, Florida Administrative Code ~SSUB 6) Secti.on 14, indemnification: ::~velopers, along with Commission staff, :y~~ the circumstances flnd extent that utility is prudent and reasonable. have expressed concerns indemnification of the :.: :=:-.i.ssion Staff Prelimin.!1ry Concerns f Should this indemnification .c~ clarified regarding circumstances in which it applies? For i::.stance; \\..... for damagHs resulting from providing wastewater s€~rvice which occur at or beyond the Customer's side of the Service Connection". ~~~. I~:StJE 7) Seeti.on 15 - Insurance: Ccmcern has been expressed by developers over how much, and to what ey.tent liability can be avoided by the utility, and whether or not it is the developer's responsibility to insure against ~uch :!OJ,abilities of the utility. ~clmmiBBion Staff Preliminary Concerns: Staff is UDsure of the rElasonableness of requi:r'ing the developer, at its expense, to :':,s~,=e the utility againut liability. Also, how long should the _.<vsloper be required to maintain in,surance, and when would the :'wmeowner's association become responsible? As in Issues 3 and 4 -4- .. l 1 j i' t f h ' .' : ~03 11 : 58 18504137180 FPSC PAGE 06 above, why wouldn' t thE~ remedy of discontinuing service be sufficient in instances wh~re the collection system remains in the possession of the developer? ISSUE 8} Section 18 - MiscellaneouB ProviB~ons. subsection (j): Ccnce,rn has been expressed by developers, as well as staff, about ~te requirement to waive the right to a jury trial. Ce,mmdssion Staff Preli~nary Concerns: Where the developer must request service from the utility, is the requirement to waive the right to a jury trial appropriate or enforceable? :::~STJE 9) General Concerns Cc~ssion Staff Preli~nary Concerns: Similar to concerns :::':?:ressed in Issues 2 and 3 above, staff reconunends that KW review ::..ts :billing and disconnect:ion practices pursuant to which entity is o\O'Iler of the collection system. For example, if a developer is to mE.intain ownership of the collection system after connecting to ~"s treatment facilities, the final point of connection for which '::':~ utility is responsible is where the developer's collection system meets the utility line. In this circumstance, staff b~dieves the entire development is normally treated as one single customer. Any service interruptions, billing, etc. should only be handled at this single c\:.stomer, developer level. (i.e., failure to pay by one individual landowner could result in KW having to c.~.sconnect the entire development.) This single customer issue is also important in that KW would only be responsible for billing the developer, providing one bill which would then be the responsibility of the developer to pay I<W and :.;:en divide and collect from each individual property owner within -:.be development. -:.~:~. =::: KW wishes to bill, connect, and disconnect each property owner ?i: ,'.:'1 individual cuetorner, why is it not necessary that the utility t(~ke possession of the lines and collection system at the time the d(~veloper agreement is entered? -5- -. : 7/~'a03 11: 58 18504137180 FPSC PAGE 07 SERVICE AGREBMBNT Upon review by staff, it a~pear6 the following areas of the service 2.::!reement do not comply with Commission rules and/or Florida Statutes. ~~s~m 1) RATES, FEES, CH~GES. & TARIFF (c') The actual costo! collecting c!lny delinquent bill shall be assessed to the customer. Commission Staff Prel~nary ConcernB: It appears that KW has no s1.:,ch provision for any la-:e charge contained in its tariff on file -,..'i -=h this Commission. Reference: Section 367.091(4), Florida Statutes ISSUE 2} (i i) CaDaci ty R.eservation Fee Ccmmi8sion Staff prelimiIl.ary Concerns: Staff is unclear as to why !\.v1 would need to re-eva,luate service availability charges for changes in type of service for residential customers. Under what s:.!:"cumstances might this apply? ::!lSUE 3) BILLING FOR SEF:VICES PROVIDED Bills for service provided are due when rendered and considered d(~linquent if not paid wi thin 10 days of the billing date. Past due accounts accrue a penalty of lot of the delinquent amount after a p(~riod of 30 days from tiIe bill date. -....., Commission Staff Prelimil:1ary Concerns: It appears that bills are being treated delinquent sooner than allowed by Commission Rule. Kli has no such provision for any late charge contained in its tariff on file with this Commission. Reference: Rule 25-30.335(4), Florida Administrative Code Section 367.091(4), Florida Sta~utes -6- .... 1 j I i: t J i -::-,':383 11:58 18504137180 FPSC PAGE 08 :3SUE 4) IUSCONNECTION F:>R NONPAYMENT Ct:stomer agrees to allow access on customer's property for all disconnections of service. ~cmmdBBion Staff PreliDd~ary CODcerns: While this topic may be a~propriate in instances where the developer wishes to have the utility handle disconnect:ions and developer is the owner of the collection system, staff believes that it should not be included in a service agreement. ?"E!ference: . Rule 25-30.320(2) (g), Florida Administrative Code ZSSUE 5) REQUESTED DISCONTINUANCE OF SERVICE -:':-pc..r.: termination of service and settlement of all outstanding ~70unts, any existing apjjlication/agreement will, become void and :-."curity deposit will be refunded. . Commission Staff PrelimirLary Concerns: KW should take note that a:'l customer deposits hElld for security are to accrue interest while held by the u~ilit).. In addition, these deposits are to be returned to the customer. with said interest, after 23 months of satisfactory payment. R(!ference: Rules 25-'30.225(6), 25-30.311, Florida Administrative Code :25-30.320 (:2) (b) , ISStJ'E 6) SERVICE C~MP~;' S RIGHTS RESERVED _.J', I'; is agreed that the Service Company resery-es the right to 't.-:ansgress on the described property for the purpose of installing, m~intaining, repairing, or removing lines in the event of an emergency or otherwise. :::: :>1tImission Staff Prelimin.ary Concerns: Similar to Issues 1 and 2 of -:. 1e Utility Agreement, noted above, staff believes that these rights are a product of ownership of the lines and collection system of the development. While a separate agreement may be p::>ssible where the developer maintains ownership of the collection system, should it be at 1:he discretion of the developer to either allow ingress to its lines for the purpose of individual -7- - .-;:~e:;; 1:':58 185134137180 FPSC PAGE 09 -...~ 1 ;';." I ,; ," I :ii9connection? And if thE: developer wishes to decline, should the ::u,c.-off be limited to the point where the developer's lines interconnect with the utility's? P.sference: Rule 25-30.231, Florida Administrative Code _..4~. -8- -