Item 10 Sanitary SewerMonroe County Comprehensive Plan Update
SANITARY SEWER
Table of Contents
Item
10.0 SANITARY SEWER....................................................................................................................................1
10.1
Introduction..................................................................................................................................1
3
10.2
Regulatory Framework............................................................................................................
3
10.2.1 Federal Regulation.......................................................................................................
10.2.2 State Regulation
............................................................................................................4
10.2.3 Local Regulation............................................................................................................
8
10.3
Existing Facilities - General Description.........................................................................10
10.3.1 OSTDS Systems............................................................................................................11
10.3.2 On -Site Management Systems...............................................................................11
10.3.3 Central Sanitary Sewer Treatment Facilities...................................................12
10.4
Existing Facilities - Detailed Description........................................................................13
10.4.1 Current Level of Service Requirements.............................................................14
10.4.2 Wastewater Facilities................................................................................................14
10.5
Capacity Analysis......................................................................................................................21
10.5.1 Operational Responsibility and Proportional Capacity...............................21
10.5.2 Service Areas and Predominant Land Use........................................................21
10.5.3 Design Capacities of Wastewater Treatment Facilities
...............................22
10.5.4 Level of Service (2010)............................................................................................23
10.5.5 Performance, Problems, and Opportunities.....................................................24
10.6
Policy and Regulations............................................................................................................25
Bibliography 26
List of Tables
Table P gZe
Table 10.1:
Monroe County Comprehensive Plan Wastewater Policies ...................................... 9
Table 10.2:
Service Area per Sanitary Service Provider...................................................................13
Table10.3:
BAT and AWT Standards.......................................................................................................14
Table 10.4:
EDU Allocations per Wastewater Project.......................................................................15
Table 10.5:
Capacity of Unincorporated Monroe County Sanitary Sewer Services Area ....22
Table 10.6:
2010 Demand vs Capacity....................................................................................................23
Table10.7:
2030 Demand vs Capacity....................................................................................................24
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TABLE OF CONTENTS
Monroe County Comprehensive Plan Update
10.0 SANITARY SEWER ELEMENT
[Rule 9J-5.011, F.A.C.]
The Sanitary Sewer Element of the Monroe County (County) Comprehensive Plan
addresses the data inventory requirements of Rule 9J-5.005(2) and Rule 9J-5.011 of the
Florida Administrative Code (F.A.C.) The Sanitary Sewer Element is a required
comprehensive plan element under Florida's Local Government Comprehensive Planning
and Land Development Regulation Act (Chapter 163.3177.6(c), F.S.)
The purpose of the element is to address the issues and needs of sanitary sewer facilities
that will be provided concurrently with the demand for services; to identify safe disposal
methods for treated waste; and to establish the level of service for sanitary sewer.
The Sanitary Sewer Element provides a description of the existing and projected sewage
treatment and disposal methods in use in the County.
10.1 Introduction
The sustainability of the marine ecosystem of the Florida Keys (the "Keys") is dependent
upon clear water with low nutrient loading. Treatment of sewage and the disposal of
wastewater within the County historically have been accomplished through septic tanks, on -
site treatment and disposal systems (OSTDS), and small to intermediate sized privately -
owned wastewater treatment package plants. With expansion and growth, regional systems
consisting of treatment plants and centralized sewer have been built providing a greater
level of collection and treatment. Several sewer districts, both private and municipal, have
been formed to service more densely populated areas.
Notwithstanding the above accomplishments, the Keys face the challenge of obtaining
adequate funding sources to implement the extent of regional systems required to meet
guidelines established by State and federal mandates. To further complicate the issue, in
more sparsely populated areas, advanced methods of treatment are not generally
economically feasible. Regulatory pressure and the implementation of numeric nutrient
criteria increase the complexity of providing proper treatment of sewage. Current
wastewater treatment practices, combined with severely limited soils and high land use
densities result in increased potential for ground and surface water contamination.
Over the last 20 years, aerobic treatment units (ATU) for more advanced onsite treatment
and secondary treatment plants have been introduced. Although they provide better
treatment than septic tanks, including effluent disinfection, ATUs are not an efficient means
of removal of phosphorus and nitrogen.
With the adoption of the Monroe County Sanitary Wastewater Master Plan (the "Master Plan")
in June of 2000, the County has implemented a program to address these issues. The Master
Plan addresses planned facilities, improvements, and expansion of regional facilities as well
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Monroe County Comprehensive Plan Update
as programs working with the Department of Health (DOH) to administer code enforcement
for septic tanks. The plan focuses on utilizing regional systems for treatment in hot spots
(areas of high density) and alternative Best Available Technology (BAT) in cold spots (areas
of low density). Although originally planned to provide compliance by July of 2010, the
Master Plan has fallen short mainly due to a gap in funding. This section will compare the
existing service capacity against the level of service required for compliance with regulatory
standards for both existing and projected demands.
The 2000 Master Plan identified 23,000 private onsite systems within unincorporated
Monroe County, made up of septic tanks, ATUs, and unknown connections servicing a total
of 4.88 million gallons per day (MGD). In addition, 246 small wastewater treatment plants
(WWTP) were identified servicing another 2.40 MGD. The Master Plan called for several
measures including the following:
• Replacement or upgrade of onsite systems to Onsite Wastewater Nutrient Reduction
Systems (OWNRS);
• Creation of 12 community collection systems, five of which are to be phased into
regional systems;
• Address hot spots with community systems by 2010; and
• Upgrade 17 facilities to BAT/Advanced Wastewater Treatment (AWT) by 2010.
In addition, facilities were to be upgraded to accommodate water reuse programs and the
distribution system was to be installed. The major drawbacks to reuse cited in the Master
Plan include the lack of large users and economic feasibility.
In the County's Annual Assessment Report Evaluating the Work Program Year 10 (May
2008), the Department of Community Affairs (DCA) noted the following conclusions from
the Department of Environmental Protection (FDEP) report to DCA:
• While progress had been made, there is a long way to go toward compliance in
terms of completion schedules and meeting the July 1, 2010 deadline.
• Dozens of small facilities relying on connection to central systems will be out of
compliance on that date.
• The same will likely be true of a number of homeowners served by septic tanks and
OSTDS.
• FDEP would do whatever it could within its power to promote compliance assuming
that the DOH would do the same to resolve the OSTDS requirements.
The Keys Wastewater Plan - November 2007 Report, prepared by Monroe County
Engineering Division at the request of the Florida House of Representatives Environmental
and Natural Resources Council, identified progress of the individual projects along with
local government responsibilities for specific facilities. The report included a summary of
nine local governments and utility service areas providing centralized systems within
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unincorporated Monroe County. The executive summary of the report cited a funding gap
of approximately $336 million in meeting the July 2010 date for compliance.
In April 2010, the Florida Senate and House approved SB 2018 extending the deadline for
compliance to the end of 2015, and postponing fines and potential liens against property
owners. In addition, the bill authorized $200 million of State funding for improvements;
however, the source of funding remains unresolved.
Meeting the 2015 extension requires a detailed financial plan to implement necessary plant
and infrastructure improvements. The funding gap of $330 million, which has already
stretched the County's capacity for debt service, continues to broaden due to a delayed
revenue stream resulting from delays in design and construction of new systems.
Subsidizing costs is consistent with County's policy.
The County is reluctant to impose assessments on residents for un-funded mandates that
could result in home forfeitures and financial hardship. The varying costs among projects
pose additional problems. For example, areas such as Cudjoe Regional System, projected at
$20,000 per EDU, costs up to four times as much as other systems ranging from $5,000 to
$10,000 per EDU. Improvements to Cudjoe Regional System could require supplemental
funding to bring costs in -line with other systems to avoid an unreasonable burden to the
residents.
The County looks to State and Federal assistance to make up the difference. Because of
uncertainties, all alternative avenues for funding need to be explored and implemented.
Without a detailed financial plan and diligent pursuit of funding sources, there is concern
that the 2015 extension may not be met.
10.2 Regulatory Framework
[Rule 9]-S.011 (2), F.A.C]
10.2.1 Federal Regulation
Pursuant to the Clean Water Act, 33 U.S.C. §1251 et seq. (1972), the Environmental
Protection Agency (EPA) has authority to promulgate and administer regulations for
sewage disposal and treatment. Implementation is delegated to the State of Florida
through the FDEP. Once a wastewater management plan is approved, EPA may enter into
agreement with the local government to implement.
EPA is currently working through the details for implementation of Numeric Nutrient
Reduction Standards. The specific criteria of this program are not yet identified; however,
the intent of the program is to restrict, in measurable quantities, the discharge of pollutant
loads to surface waters and ultimately coastal and subterranean waters.
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10.2.2 State Regulation
10.2.2.1 Area of Critical State Concern:
In 1975, due to concerns of the degradation of the marine ecosystem and continued
pressures for expanded development, the DCA designated the Keys as an Area of Critical
State Concern. Among other issues, this designation focused on programs including
implementation of a comprehensive plan to address untreated sewage discharge into
waters of the Keys. The County has since implemented a comprehensive planning process
resulting in the Rate of Growth Ordinance (ROGO) and other efforts to manage impacts
associated with development.
10.2.2.2 Five Year Work Program the "Work Pro ram" and the Florida Ke s
CarrviU Capacity Study (FKCCS�
In December 12, 1995, the Administration Commission found the 2010 Monroe County
Comprehensive Plan not in compliance and ordered facilitated rulemaking/mediation to
address outstanding issues. In July 1997, the Administration Commission proposed Rule
28-20.100, F.A.C., which introduced the concept of the Work Program requiring the
following activities as it relates to wastewater:
• Continued construction of wastewater facilities in hot spots begun in previous year.
• Design and construction of additional wastewater treatment facilities in accordance
with the schedule of a wastewater master plan.
• Implementation of the FKCCS to establish development standards ensuring that all new
development not exceed the capacity the ecosystem's ability to sustain impacts.
• Complete elimination of cesspits.
The FKCCS was tasked with providing specific recommendations, including adequate
capital funding, protection of the environment, ensuring private property rights, providing
for adequate affordable work force housing and meeting the goal of reducing the State's
role in regulatory oversight. With respect to wastewater, the FKCCS used benchmarks to
correlate impacts of nutrient loading on marine ecosystems and the level of sustainable
development.
The four key topics of discussion within the FKCCS include Terrestrial Habitat Protection,
Allocation and Distribution of Growth, Affordable Housing, and Funding. Of the four topics,
Allocation and Distribution of Growth, and Funding addressed recommendations related to
wastewater. The Allocation and Distribution of Growth is addressed through ROGO with
the establishment of 2,548 additional residential units within the County to be built over a
ten-year period. The distribution of the residential units involves many factors and various
stakeholders, but the principles of focusing new development and infill within partially
developed areas and guiding future growth towards areas with existing or planned/funded
wastewater systems are consistent with the goals of the FKCCS.
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Finding adequate funding for the environmental and socioeconomic needs of the Keys is a
difficult issue. The County has a relatively small population and a high number of tourists.
The burden of playing catch-up with years of inadequate treatment facilities combined with
the increase in housing costs associated with the tourist -based economy adds to the issue
of affordable housing and economically feasible solutions; however, all current
infrastructure requirements and waste disposal standards are to be upheld. Many
potential sources for additional funding were presented for discussion including
establishing tolls, residential impact fees, bed tax, Ad Valorem Tax, State and federal
matching funds, and tourist -based sales tax.
Although many tasks identified in the Master Plan remain incomplete, all are being
addressed. The remaining tasks consist mainly of costly capital improvement projects for
which funding remains the key issue to implementation.
In November of 2010, under section 28-20.130, the requirements for the Work Program
were updated by DCA. Under the revised Work Program, specific tasks and timelines are
established to bring deficient systems into compliance.
Among the rules are requirements for the County Comprehensive Plan to restrict permits
for new development or redevelopment unless served by a central sewer system with
committed funding; permitted by DEP and physically under construction or with an onsite
sewage treatment facility shown to be in compliance with requirements of s.381.0065(4),
F.S. Furthermore, the County must direct new and redevelopment to areas with committed
funding, permit, and physically under construction.
Rules specific to Wastewater Implementation include the following:
• By July 1, 2011, the County shall evaluate annually and allocate funding for wastewater
implementation with such funding identified in annual update to the Capital
Improvements Element of the Comprehensive Plan.
• By July 1, 2011, the County shall determine cold spots and unfounded service areas and
provide a map delineating those areas.
• By August 1, 2013, the County shall work with the owners of wastewater facilities, DEP,
and DOH to fulfill requirements for compliance and coordinate notice and actions
against owners that will not meet advanced wastewater requirements.
• By August 1, 2011, the County shall adopt an ordinance establishing the upgrade
program with implementation dates and enforcement procedures for on -site package
plants.
• By July 1, 2011, the County shall annually draft a resolution requesting $50 million of
the $200 million of bonds authorized under Section 215.619, F.S. and appropriate
sufficient dept service for the construction of wastewater projects within the Florida
Keys.
• By July 1, 2011, the County shall evaluate State and federal funding opportunities and
apply annually to at least one State or federal grant program for wastewater projects.
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• By July 1, 2011, the County shall develop and implement local funding programs
necessary for construction, operation, maintenance, and replacement of facilities.
• By July 1, 2011, the County shall by resolution identify and delineate on a map areas
served by central sewage facilities and those that will not be served by central facilities.
• By July 1, 2011, in coordination with DEP, the County shall execute an interlocal
agreement addressing non -service and unfunded service areas. The agreement shall
address mechanisms for FKAA, DOH or DEP to provide upgrades and central
management of onsite facilities located in non -service and unfounded areas.
Furthermore, DOH and DEP will report to DCA with an assessment and magnitude of
non-compliance and identify enforcement mechanisms needed to ensure upgrades.
• By July 1, 2013, the County shall provide a report including addresses and parcel
numbers of property owners that fail or refuse to connect to central sewer facilities
within timeline required. This report will be submitted to DCA and shall describe status
of enforcement actions and circumstances under which enforcement has or has not
been initiated.
Wastewater Projects and their associated timelines included in the rule amendment are as
follows:
• Key Largo Wastewater Treatment Facility. Key Largo Wastewater Treatment District is
responsible for wastewater treatment in its service area and the completion of the Key
Largo Wastewater Treatment Facility.
- By July 1, 2011, Monroe County shall complete construction of the South
Transmission Line; and
- By July 1, 2011, Monroe County shall complete design of Collection basin C, E, F, G, H,
I, J, and K; and
By July 1, 2011, Monroe County shall complete construction of Collection basins E-
H; and
By July 1, 2011, Monroe County shall schedule construction of Collection basins I-K
and ;
By July 1, 2011, Monroe County shall complete construction of Collection basins I-K;
and
- By July 1, 2011, Monroe County shall complete 50 percent of hook-ups to Key Largo
Regional WWTP; and
By July 1, 2012, Monroe County shall complete 75 percent of hook-ups to Key Largo
Regional WWTP; and.
By July 1, 2013, Monroe County shall complete all remaining connections to Key
Largo Regional WWTP.
• Hawk's Cay, Duck Key and Conch Key Wastewater Treatment Facility.
By March 1, 2012, Monroe County shall complete construction of Hawk's Cay WWTP
upgrade/expansion, transmission, and collection system; and
By July 1, 2013, Monroe County shall complete construction of Duck Key collection
system; and
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By March 1, 2012, Monroe County shall initiate property connections to Hawk's Cay
WWTP; and
By December 31, 2012, Monroe County shall complete 50 percent of hook-ups to
Hawk's Cay WWTP; and
• South Lower Keys Wastewater Treatment Facility (Big Coppitt Regional System).
- By July 1, 2012, Monroe County shall complete 75 percent hookups to South Lower
Keys WWTP; and
- By July 1, 2013, Monroe County shall complete all remaining connections to the
South Lower Keys WWTP.
• Cudjoe Regional Wastewater Treatment Facility.
- By July 1, 2011, Monroe County shall complete planning and design documents for
the Cudjoe Regional Wastewater Treatment Facility, the Central Area (Cudjoe,
Summerland and Upper Sugarloaf) Collection System and the Central Area
Transmission Main. (Plant is not being designed and/or constructed in phases.);
and
- By January 2012 Monroe County shall complete design and planning for Outer Area
(Lower Sugarloaf, Torches, Ramrod, Big Pine Key) Collection System and
Transmission Main; and
- By October 1, 2011, Monroe County shall initiate construction of the wastewater
treatment plant, the Central Area Collection System and Central Area Transmission
Main); and
- By July 1, 2014, Monroe County shall complete construction of Wastewater
Treatment, Central Area Collection System and Central Area Transmission Main; and
- By February 2012 Monroe County shall initiate construction of the Outer Area
Collection System and Transmission Main; and
- By February 2015 Monroe County shall complete construction of the Outer Area
Collection System and Transmission Main; and
- By July 1, 2014, Monroe County shall initiate property connections - complete 25
percent of hook-ups to Cudjoe Regional WWTP; and
- By July 1, 2015, Monroe County shall complete 50 percent of hook-ups to Cudjoe
Regional WWTP; and
- By December 2015, Monroe County shall complete remaining hook-ups to Cudjoe
Regional WWTP.
10.2.2.3 Department of Health Program for Compliance
The DOH administers code enforcement for septic tanks within the Keys. The DOH regulates
permits and establishes criteria for construction and certification of these facilities.
10.2.2.4 Chapter 163.3177, F.S.
This statute encourages local governments to develop a "community vision" which provides
for sustainable growth, recognizes fiscal constraints, and protects its natural resources. In
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addition, it calls for development of "urban service boundaries" which ensure the area is
served (or will be served) with adequate public facilities and services.
10.2.2.5 91-5011 FAC
This section of F.A.C. requires local governments to analyze the jurisdictional needs and
capabilities or deficiencies of facilities in meeting the requirements established through
this section. Local governments are required to provide information in the comprehensive
plans to show compliance or plans for compliance including specific information for
facilities identified; entity responsible for operation; service areas and service capacity;
current and projected demands; and level of service provided.
Among other requirements, local governments are to report on condition and performance
of existing facilities and as well as problems and opportunities for improvement.
10.2.3 Local Regulation
10.2.3.1 Monroe County Sanitary Wastewater Master Plan
The Monroe County Sanitary Wastewater Master Plan, adopted in June 2000, addresses the
requirements addressed in 9J-5.011, F.A.C. The Master Plan identifies programs
established to meet the demands and level of treatment necessary for compliance.
10.2.3.2 Monroe County Comprehensive Plan
In accordance with 9J-5.011, F.A.C., local governments are required to address the
following policy objectives in their comprehensive plans related to wastewater
management in guiding development:
• Protection and improvement of water quality by providing for the construction,
operation, maintenance, and replacement of central sewage collection, treatment and
disposal, and installation and proper operation and maintenance of onsite sewage
treatment systems.
• Establishment of construction schedules and capital financing plans for wastewater
management improvements and standards for the construction of wastewater
treatment facilities or collection systems.
One way the County has responded to these requirements is by establishing the Master
Plan and adoption of the following policies in the Sanitary Sewer element, which are
summarized in Table 10.1.
In addition, the County participated in research projects through the Florida Department of
Environmental Protection, and published the document Reasonable Assurance
Documentation (FKRAD -May 2008), which "provides reasonable assurance that the
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stakeholders in the Keys have provided or will implement sufficient control mechanisms to
return the area's near shore waters to the water quality targets". The following elements
were implemented to provide the reasonable assurance: Description of the Impaired
Water, Description of the Water Quality and Aquatic Ecological Goals, Description of the
Proposed Management Actions to Be Undertaken, Description of Procedures for Monitoring
and Reporting Results, and Description of Proposed Corrective Actions. The FKRAD rules
related to Wastewater Management have been incorporated into the County's master plan
and policy decisions.
Table 10.1- Monroe County Comprehensive Plan Wastewater Policies
Policy No.
Summary
901.16
Established January 4, 1998, as the deadline for adoption of permanent level of service
standards for package treatment plants and on -site disposal systems (OSTDS) based on
the findings of the Wastewater Master Plan and correlated amendments to the Land
Development Regulations.
901.4.2
Amendment to the Building Code requiring notification to property owners issued
building permits to complete hook-up to the central sewer facilities, pending availability
within one year of becoming available, or as required as part of changes in State law or in
level of service.
901.4.4
County agreement with EPA, FDEP, South Florida Water Management District (SFWMD),
and National Oceanic and Atmospheric Administration (NOAA) regarding the scope of
studies required to document pollutant loads from OSTDS, cesspits, package treatment
plants, and other point and non -point sources on the Florida Keys into surrounding
waters. These studies shall be executed according to the terms of the agreement, in
coordination with the Water Quality Protection Program for the Florida Keys National
Marine Sanctuary. Upon execution of this agreement, the scope of the Sanitary
Wastewater Master Plan shall be adjusted accordingly.
901.5.18
As part of the Sanitary Wastewater Master Plan, an inventory of all wastewater treatment
plants and OSTDS areas shall be completed identifying:
the entity having operation responsibility;
current rated plant capacity;
existing treatment status (number and type of hookups);
- all future committed capacity (number and type of hookups);
all facilities which fall below level of service standards identified in the Master Plan;
costs associated with improving those facilities to meet minimum level of service
standards;
funding sources and construction schedules for those improvements; and
average and peak flow design capacity for sanitary sewer facilities.
901.4.9
In the event Central Sewer Service becomes available (as defined by Chapter 10D-6) to
areas served by OSTDS, owners of OSTDS within such areas shall have 365 days to
connect to the centrals stem
901.5.8
County shall ensure that wastewater treatment facilities are designed and constructed in
accordance with the adopted levels of service, so as to limit the discharge or introduction
of pollutants
901.5.18
All existing development shall connect to public treatment plants where available within
one year of the date of plant start-up.
Source: Monroe County 2010 Compretiensrve Flan
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10.3 Existing Facilities - General Description
[Rule 9J-5.011 (1) (f), F.A.C.]
Sanitary sewer treatment within the County is provided through a combination of regional
systems, OSTDS, package plants, and septic tanks. Approximately 30 percent of the land
mass is within the boundaries of incorporated areas of the County. The majority of the hot
spots are located within the incorporated areas, accounting for roughly 75 percent of the
total wastewater generated within the Keys.
The Master Plan includes four major principles to improve wastewater management
throughout the Keys:
• Upgrade or replace existing onsite systems with onsite wastewater nutrient reduction
systems (OWNRS) in cold spots;
• Implement central community wastewater collection and treatment systems in hot
spots;
• When community treatment systems increase to the point where no longer
economically feasible to operate as community systems, consolidate them into regional
systems; and
• Phase implementation of small regional systems and construct regional treatment
plants so that interim community treatment systems are not necessary.
With the implementation of the Master Plan, regional service areas have been delineated
and total demands within each service area have been identified. The basic unit of
measurement used in evaluation is an Equivalent Dwelling Unit (EDU). One EDU is
equivalent to approximately 167 gallons per day (gpd) of wastewater.
In accordance with Chapter 64E-6, F.A.C., the DOH has authority for issuing permits for
onsite disposal systems. Chapter 64E-6, F.A.C. stipulates that the owner of a properly
functioning onsite sewage treatment and disposal system must connect to an available
publicly owned or investor -owned sewerage system within 365 days after the system is
available for connection. The owner of the onsite system in need of repair of modification
must connect to an available sewerage system within 90 days. Due to the designation as an
Area of Critical State Concern, variances for compliance shall not be granted under any
circumstances.
In areas where injection wells are approved for use, the DOH is the permitting agent for ATUs
where the daily domestic sewage flow will not exceed 2,000 gpd. For establishments with
greater than 2,000 gpd, but less than 10,000 gpd, the DOH is the permitting authority for the
ATUs, and the FDEP is the permitting agent for the injection wells.
Owners of onsite systems must comply with the general maintenance and operational
requirements of Chapter 64E-6, F.A.C., and any additional operation and maintenance
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requirements specified by the system design engineer. Onsite systems must be inspected by
an approved maintenance entity at least two times each year.
When site conditions are favorable and septic tank systems are properly designed,
constructed, and maintained, they can be efficient and economical alternatives to centralized
wastewater treatment systems. Under unfavorable site conditions, such as high septic tank
density, high seasonal rainfall, shallow ground water, or highly permeable soils, OSTDS can
be a significant source of nutrient and bacterial ground water contamination. Anderson et al.
(1988), in their report regarding the impact of individual and small community sewage
systems, indicated that virtually 100 percent of the soils in Monroe County are severely
limited for conventional OSTDS practices.
10.3.1 OSTDS Systems
Though alternative OSTDS systems have been shown generally to provide improved
treatment of sewage relative to conventional septic tanks, further monitoring and evaluation
of these systems by DOH is essential to ensure the protection of public health and water
quality in the Keys. Nitrogen and phosphorous concentrations in wastewater may be
reduced through specifically designed systems. Such systems may be utilized for OSTDS and
package treatment plants. They must be carefully designed, constructed, operated and
maintained to achieve the desired results.
10.3.2 On -Site Management Systems
Various alternatives for on -site treatment and disposal of wastewater are available for use in
the County. It is important, however, when choosing an alternative that each component
combined to make a total system should meet the following basic criteria:
• Produce an effluent of adequate quality for safe disposal;
• Be simple (few mechanical parts; easy to maintain);
• Be reliable (maintain consistent treatment);
• Protect the aesthetic qualities of an area; and
• Be acceptable to the homeowner or to the owner of another type of establishment (easy
to use; creates no nuisance).
In areas of low density, cold spots, where centralized systems are not economically feasible,
the plan for treatment focuses on Best Available Technology (BAT). The term BAT refers to a
practice that is determined to be the most effective, practical means of preventing or
reducing the amount of pollution generated by nonpoint sources to a level compatible with
water quality goals. The selection of an appropriate BAT will depend greatly upon site
conditions such as land use, topography, slope, water table elevation, and geology. BAT
selection must be very site specific so as to assure proper operation and prevent undesirable
results such contamination of surface waters.
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10.3.3 Central Sanitary Sewer Treatment Facilities
The treatment plant component of the central sanitary sewer facility functions to remove
l
solid and organic materials from the sewage. Depending on the proportion of materias
removed, processes which accomplish treatment are generally grouped into one of th
following four categories: e
• Primary Treatment
Primary treatment removes between 30 and 35 percent of the organic materials and up
to 50 percent of the solids from the sewage, and is the least expensive treatment. This
level of treatment is also commonly referred to as physical treatment because screens
and settling tanks are the most common methods used to remove the solids.
• Secondary Treatment
Secondary treatment removes approximately 90 percent of total organic materials and
suspended solids from sewage, and is the most common level of treatment provided by
centralized facilities. This level of treatment generally requires multiple steps involving
one biological process and one or more processes for removal of suspended solids, and is
more expensive than primary treatment.
• Tertiary Treatment
Sewage may also contain large quantities of synthetic organic compounds or inorganic
chemicals which may create pollution problems if not removed. Tertiary treatment is any
treatment process beyond secondary treatment. The most common tertiary processes
remove compounds of phosphorous and nitrogen. One method of tertiary treatment is
spray irrigation, such as the irrigation of the golf course at Key Colony Beach. Because of
the extra processes required, tertiary treatment is more expensive than secondary
treatment.
• Advanced Wastewater Treatment (AWT)
This term refers to tertiary treatment within the wastewater treatment plant itself to
levels of water purity generally acceptable for discharge directly into surface waters.
AWT standards are set by law (Section 403.086, F.S.) in Florida. Very few wastewater
treatment facilities in the State of Florida meet the AWT treatment standards. Advanced
waste treatment is the most expensive method of treatment due to the additional plant
and operations costs.
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10.4 Existing Facilities - Detailed Description
[Rule 9J-5.011 (1) (e), F.A.C.]
There are currently nine sanitary service providers within the County consisting of four
municipalities, four private entities, and the Florida Keys Aqueduct Authority (FKAA). A
summary of EDUs treated by each service provider is shown in Table 10.2.
Table 10.2 - Service Area per Sanitary Service Provider
Service Area
Ocean Reef
Agency/ Total EDUs Total Dernand
1'r _ ovider Within Service Within Service
Area r rCapacity
NKL Utility 1,800 0.30
Corp.
Total Excess
Treatryient I'lanned
0.47 0.17
Key Largo
KLWTD
13,707
2.29
2.30
0.01
Village of Islamorada
City
8,895
1.49
1.92
0.43
City of Layton
FKAA
350
0.06
0.07
0.01
Duck Key/Conch Key
FKAA
1,454
0.24
0.28
0.03
City of Marathon
city
8,203
1.37
1.39
0.02
City of Marathon
city
8,203
1.37
1.39
0.02
Cudjoe Regional *
FKAA
7,987
1.33
1.18
-.15
Baypoint WWTS
FKAA
430
0.07
0.07
0.045
Big Coppitt
FKAA
1,711
0.29
0.32
0.04
Boca Chica
US Navy
2,600
0.43
0.44
0.01
Key Haven
FKAA
450
0.06
0.20
0.14
Stock Island
KW Resort
Util. Corp
2,672
0.45
0.45
0.00
City of Key West
city
24,075
4.02
4.00
Totals
75,736
12.65
13.04
0.54
Source: Keys Wastewater Plan - 2007, Report to Environmental and Natural Resources Council, h HH
* Includes North Lower Keys, Big Pine Key, Ramrod, Middle Lower keys, Summerland, Upper and Lower
Sugarloaf.
This table inventories the number of EDUs within each service area to be treated through
existing or planned wastewater projects. The table uses a conversion factor of 167 gpd per
EDU to convert demand to MGD for comparison against capacity created in treatment
facilities.
This section provides a summary of the wastewater systems for each service provider and
identifies the treatment capacities provided by individual facilities within their respective
service area.
Sanitary Sewer 13 Technical Document: May 2011
Monroe County Com rehensive Plan U date
10.4.1 Current Level of Service Requirements
In 1999, the Florida Legislature established binding treatment and disposal requirements
for wastewater management including central treatment facilities regulated by FDEP and
OSTDS regulated by the DOH. A standard of treatment was established for OSTDS and
sewage treatment plants with a deadline for compliance of July 1, 2010. Facilities with less
than 100,000 gpd were to apply Best Available Technology (BAT) standards, while facilities
producing greater than 100,000 gpd apply AWT standards. Table 10.3 indicates the
standards applied to each.
Table 10.3 - BAT and AWT Standards
BAT standards apply to facilities with design capacities less than
100,000 gpd (generally, OSTDS and "package plants") 10 10 10 1
AWT standards apply to facilities with design capacities equal
to or greater than 100,000 gpd (community and central
wastewater treatment systems) 5 5 3 1
Source: FDEP Report to DCA, 10 yr Work Program April 2008
10.4.2 Wastewater Facilities
The most common type of centralized sanitary sewer system is the localized small sewage
treatment facility, or "package plant" as they are commonly known. Large scale municipal
sanitary sewer systems which generally provide services to densely populated areas are
another type of centralized facility. These centralized facilities are comprised of three
components which perform the basic functions of collection, treatment and disposal of
sewage.
There are nine sanitary sewer service providers serving 15 associated service areas located
throughout the County. For the most part, service areas within incorporated areas coincide
with the limits of incorporation. The four service areas served by regional service providers
within incorporated areas include the Village of Islamorada, Key Colony Beach, City of
Marathon, and the City of Key West; the City of Layton is served by FKAA. Within
unincorporated Monroe County, there are five regional service providers: North Key Largo
Utility Corp., Key Largo Wastewater Treatment District, Key West Resort Utilities Corp., Stock
Island, and FKAA. FKAA provides service to seven of the 15 service areas previously
identified. A graphical representation of both the incorporated and unincorporated Regional
Service Areas is provided in Map Series 10.1. This map also shows the total treatment
capacity within each service and estimated demands (number of EDUs).
Sanitary Sewer 14 Technical Document: May 2011
Monroe County Comprehensive Plan Update
Regional systems are regulated through FDEP, and as such, are subject to the same State and
Federal regulations. Because each regional service provider is accountable for compliance,
responsibility for service areas within incorporated areas typically falls with the municipality
they serve. With the exception of the City of Layton that is served through FKAA, each
municipal and private provider is independent of one another.
The total EDUs for each service area is summarized in Table 10.4. The table shows
progress made toward accounting for EDUs in implementing the various wastewater
projects.
Table 10.4 - EDU Allocations per Wastewater Project
Wastewater
Project
Ocean Reef
Total
EDUs
1,800
Planning
EDUs
Design
EDIJs
Construction
EDtJs
20
Connections
Completed
1,780
Remaining
0
Key Largo
13,707
5,483
3,617
3,618
789
989
Village of Islamorada
8,895
7,695
1,200
0
City of Layton
350
317
33
Duck Key/Conch Key
1,4541
1,021
433
City of Marathon
8,203
137
0
7121
945
0
City of Key Colony
1,502
1,502
0
Cudjoe Regional *
7,987
922
7065
0
0
Baypoint WWTS
430
281
149
0
Big Coppitt
1,711
818
893
0
Boca Chica
2,6001
2,600
0
Key Haven
450
450
0
Stock Island
2,672
2,672
0
City of Key West
2,4075
24,075
0
Total
75,736
13,596
4539
18,642
38,393
1,455
Source: Keys Wastewater Plan - 2007, Report to Environmental and Natural Resources Council, MR
* Includes North Lower Keys, Big Pine Key, Ramrod, Middle Lower keys, Summerland, Upper and Lower
Sugarloaf.
Hook-up of individual services does not correlate directly with construction of collection
system or plant improvements. "Remaining EDU's" reflect those not yet connected, in some
state of design, or under construction.
10.4.2.1 Village of Islamorada
The Village of Islamorada is sub -divided into five separate collection and treatment basins
in varying states of completion. Total 8,895 EDUs; capacity 2.06 MGD.
Sanitary Sewer 15 Technical Document: May 2011
North Plantation Key
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
South -Plan - Kev
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Windlev Key
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Upper Matecumbe
EDUs to be treated:
Treatment Capacity
Type of treatment:
Status:
Lower Matecumbe
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Monroe County Comprehensive Plan U date
1,400 EDUs (.17 MGD)
1,800 EDUs (.30 MGD)
AWT
Plant construction completed.
Collection system serving 1,200 EDUs.
1,796 EDUs (.30 MGD)
1,800 EDUs (.30 MGD)
AWT
Status unknown.
804 EDUs (.13 MGD)
804 EDUs (.13 MGD)
AWT
Status unknown.
3,628 EDUs (.60 MGD)
3,590 EDUs (.60 MGD)
AWT
Status unknown.
3,063 EDUs (.51 MGD)
3,532 EDUs (.59 MGD)
AWT
Status unknown.
10.4.2.2 Key Colony Beach
The Key Colony Beach central collection system was constructed in 1960. Despite ongoing
repairs to infiltration and inflow, this project is compliant with 2010 effluent standards.
KeY CoIQDy Beach
EDUs to be treated: 1,500 EDUs (.25 MGD)
Treatment Capacity: 1,500 EDUs (.25 MGD)
Type of treatment: AWT
Status: Plant construction completed. Basin is compliant.
10.4.2.3 Marathon
The City of Marathon is sub -divided into seven separate collection and treatment basins in
varying states of completion. Total 8,203 EDUs; capacity 1.38 MGD
Sanitary Sewer 16 Technical Document: May 2011
Monroe County Comprehensive Plan Update
Service Area 1. Knight's Kev
EDUs to be treated: 138 EDUs (.023 MGD)
Treatment Capacity: 138 EDUs (.023 MGD)
Type of treatment: BAT
Status: In process of redevelopment; the City is partnering with a
private developer to provide BAT plant. City will design and
construct collection system to convey wastewater to new plant.
Service Area 2. Boot Kev
EDUs to be treated: 4 EDUs (.0006 MGD)
Treatment Capacity: 4 EDUs (.0006 MGD)
Type of treatment: BAT
Status: Under construction.
Service Area 3. Vaca Key (westl
EDUs to be treated: 1,479 EDUs (.247 MGD)
Treatment Capacity: 1,500 EDUs (.25 MGD)
Type of treatment: Nutrient Removal
Status: Under construction.
Service Area 4. Vaca Key
(centrall
EDUs to be treated:
2,389 EDUs (.399 MGD)
Treatment Capacity:
2,395 EDUs (.40 MGD)
Type of treatment:
Nutrient Removal with
Club.
Status:
Under construction.
effluent re -use to Sombrero County
Service Area 5, Vaca Key (eastl
EDUs to be treated: 2,935 EDUs (.490 MGD)
Treatment Capacity: 2,988 EDUs (.499 MGD)
Type of treatment: AWT
Status: Served through expansion of existing Little Venice Plant. Under
construction.
Service Area 6. Fat Deer Key (west1
EDUs to be treated: 928 EDUs (.155 MGD)
Treatment Capacity: 928 EDUs (.155 MGD)
Type of treatment: Package Plant
Status: Served through vacuum collection and upgrade to existing
package plant. Under construction.
Sanitary Sewer 17 Technical Document: May 2011
Monroe County Comprehensive Plan Update
Service Area 7 Grassy Kev
EDUs to be treated: 1,500 EDUs (.063 MGD)
Treatment Capacity: 1,500 EDUs (.063 MGD)
Type of treatment: BAT
Status: Large densely populated are served by relocation of two BAT
plants. Under construction.
10.4.2.4 CitY of Key West
The City of Key West operates a wastewater treatment facility constructed in 1989. The
system encountered Infiltration and Inflow (I&I) problems approximately ten years ago
releasing extensive fecal coliform into nearshore waters. The City has implemented
corrective measures since then including I&I testing and repairs to sewer systems;
accelerated Capital Improvement Programs (CIP) related to sewer repair/replacement;
constructed a Class 1 deep injection well to eliminate ocean outfall; accelerated retrofit of
the WWTP to meet AWT standards; and other pro -active measures.
Key West WWTP
EDUs to be treated: 24,075 EDUs (4.02 MGD)
Treatment Capacity: 23,952 EDUs (4.0 MGD)
Type of treatment: AWT
Status: System functioning under routine maintenance; compliant
with 2010 wastewater Standards.
10.4.2.5 City of Layton
Through partnership with FKAA, the City of Layton wastewater system serves the entire
city. No future projects are currently planned for this system.
Layton BAT
EDUs to be treated: 350 EDUs (.06 MGD)
Treatment Capacity: 385 EDUs (.066 MGD)
Type of treatment: BAT
Status: System compliant with 2010 wastewater standards.
10.4.2.E Ocean Reef
Ocean Reef is a privately operated system with a secondary treatment facility to
accommodate reuse.
Sanitary Sewer 18 Technical Document: May 2011
Monroe County Comprehensive Plan Update
Ocean Reef
EDUs to be treated: 1,800 EDUs (.30 MGD)
Treatment Capacity: 2,814 EDUs (.47 MGD)
Type of treatment: AWT
Status: Re -use distribution system in place. System compliant with
2010 wastewater standards.
10.4.2.7 Key Largo
Key Largo wastewater treatment is provided through a WWTP and collection sub -divided
among 11 basins identified as A through K. Improvements are in varying states of
completion. Total EDUs 13,707; total capacity 2.30 MGD.
Key Largo WWTP
EDUs to be treated: 13,707 EDUs (2.29 MGD)
Treatment Capacity: 13,772 EDUs (2.3 MGD)
Type of treatment: AWT
Status: Treatment plant is active, but connections are minimal. System
in various stages of completion.
10.4.2.8 Stock Island
Stock Island is a privately operated system operated by Key West Resort Utility
Corporation. An upgrade was completed to bring the secondary treatment plant to AWT.
Stock Island
EDUs to be treated: 2,672 EDUs (.45 MGD)
Treatment Capacity: 2,695 EDUs (.45 MGD)
Type of treatment: AWT
Status: System compliant with 2010 wastewater standards.
10.4.2.9 Unincorporated Monroe/FKAA
FKAA operates a total of six wastewater systems within unincorporated Monroe County
(does not include Layton). Total EDUs 10,281; total capacity 2.30 MGD.
North Lower Keys (Big Pine)
EDUs to be treated: 4,478 EDUs (.75 MGD)
Treatment Capacity: 4,790 EDUs (.80 MGD)
Type of treatment: AWT
Status: Under design, construction on hold pending funding.
(Incorporated into Cudjoe Regional System)
Sanitary Sewer 19 Technical Document: May 2011
Monroe County Comprehensive Plan Update
Middle Lower Ke�(Cudjoel
EDUs to be treated: 2,852 EDUs (.47 MGD)
Treatment Capacity: 13,372 EDUs (.3 MGD)
Type of treatment: AWT
Status: Under design, construction on hold pending funding.
(Incorporated into Cudjoe Regional System)
South Lower Kev�Big Coppitt)
EDUs to be treated: 1,711 EDUs (.29 MGD)
Treatment Capacity: 1,916 EDUs (.32 MGD)
Type of treatment: AWT
Status: Treatment plant is active.
Bavpoint
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Duck and Conch Keys
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Lower Sugarloaf
EDUs to be treated:
Treatment Capacity:
Type of treatment:
Status:
Sanitary Sewer
System Complete.
429 EDUs (.07 MGD)
430 EDUs (.07 MGD)
BAT
Treatment plant is active. System complete.
1,454 EDUs (.24 MGD)
1,677 EDUs (.28 MGD)
Secondary WWTP
Facility Constructed, updated to AWT standards.
657 EDUs (.11 MGD)
480 EDUs (.08 MGD)
BAT
Under design, construction on hold pending funding.
(Incorporated into Cudjoe Regional System)
The Remainder of This Page Intentionally Left Blank
20 Technical Document: May 2011
Monroe County Comprehensive Plan Update
10.5 Capacity Analysis
Although unincorporated Monroe County includes approximately 70 percent of the County
landmass, it accounts for only 25 percent of the total sanitary sewer demand; the majority
of demand is treated by municipal service providers. Service within unincorporated
Monroe County is provided through both private and public facilities. This section
references facilities within unincorporated Monroe County only.
10.5.1 Operational Responsibility and Proportional Capacity
[Rule 9J-5.011(1)(d) and (e), F.A.C.]
Through the Wastewater Master Plan, many regional improvements including facilities and
collection systems have been identified. Both demand and treatment capacities for each
service area have been accounted for and tabulated. The summary of capacities for
unincorporated Monroe is presented here by region; Upper, Middle, and Lower Keys. A
baseline was established using the planned EDU's for each service area and converting to a
population. This number was compared against the projected unincorporated functional
population distribution by sub -area. In comparing the 2010 population report to the
population served within the service areas, the numbers deviate slightly but are within 10
percent. The explanation for this is the exacting nature of delineating service areas vs. the
general approach to population on a regional basis. In addition, capacities for service areas
do not incorporate those systems to remain on septic through DOH. It should be noted that
this comparison is based on planned improvements. The level of completion of
improvements within each service area varies.
10.5.2 Service Areas and Predominant Land Use
[Rule 9J-5.011(1)(e)2., F.A.C.]
The service areas for unincorporated Monroe County have been separated into Upper,
Middle, and Lower Keys to align with the 2010-2030 population projections. These service
areas are made up of a combination of public and private systems as follows:
• Upper Keys: Key Largo Wastewater Treatment District
Ocean Reef (private system)
• Middle Keys: Duck Key Service Area (servicing Duck and Conch Keys)
• Lower Keys: Cudjoe Regional Service Area
Big Coppitt Service Area
Baypoint Service Area (institutional)
Boca Chica Key/NAS (institutional)
Key Haven Service Area (private)
Stock Island (private)
Other miscellaneous private service areas
Sanitary Sewer 21 Technical Document: May 2011
Monroe County Comprehensive Plan Update
The limits and location of these service areas are identified on Map Series 10.1. Additional
development and expansion of service is not expected to occur due to the restricted land
use. However, the shift from permanent to seasonal occupation of units results in an
increase of the functional population and associated increase in the number of persons per
household. This increase translates to approximately a 3.6 percent increase in demand for
the Upper, Middle, and Lower Keys.
10.5.3 Design Capacities of Wastewater Treatment Facilities
[Rule 9J-5.011 (1)(e)3., F.A.C.]
Table 10.5 identifies the capacity for treatment through various planned improvements.
The table depicts capacity in MGD, EDU's, and Population for each service area within
unincorporated Monroe County. A conversion factor of 2.27 persons per EDU was used to
determine Population Capacity.
Table 10.5 - Capacity of Unincorporated Monroe County Sanitary Sewer
Services Area
UPPER KEYS
Key Largo
Ocean Reef
KLWTD
2.30 13,772
! 31,263
NKU UTIL.
0.47
2,814
6,389
SUBTOTAL =
2.77
16,587
37,652
i
MIDDLE KEYS
Duck Key/Conch Key
' FKAA
0.28
1,677
Not Applicable
3,806
Lon Key
(N.A
N/A
N/A
N/A
SUBTOTAL =
�O28
1,677
3,806
I
LOWER KEYS
Cudjoe
FKAA
1.33 1
7,964
18,078
Big Co it
Baypoint
FKAA
FKAA
0.32
1,916
4,350
Boca Chica
US NAVY
0.07 1
0.44
419
' 680
KeyHaven
FKAA
0.2 01
2,635
1,198
5,981
i KW RESORT
2,714
Stock Island
UTIL.
0.45 !
2,695
6,117
SUBTOTAL--
2.81
16,907
37,924
*Pnniiinfinn + 7 77
Sanitary Sewer 22 Technical Document: May 2011
Monroe County Comprehensive Plan Update
The total capacity by population aligns with the projections for functional population.
Table 10.6 shows a more detailed comparison of population within each service area
against capacity.
10.5.4 Level of Service (2010)
[Rule 9J-5.011(1)(e)4. and 5., and (f)1.a.,F.A.C.]
Expanding upon Table 10.5, Table 10.6 shows the relationship between the 2010
demands and capacity of planned improvements to accommodate such demands and a
percent utilized as an indication of surplus capacity for each service area. Assuming service
area capacities properly account for peak flows, a utilization rate of 100 percent indicates
..that no additional EDU's can be treated without further plant expansion.
Table 10.6 - 2010 Demand vs. Capacity
Capacity Capacity Demand NUrpJJS/-*CIIUIL r CI LCIIL
Service Area 1
UPPER KEY
Key Largo 2.30 13,772 113,707 65 100%
Ocean Reef 0.47
2,814
1,800
1,014
64%
MIDDLE
Duck Key/Conch 0.28
1,677
1,454
223
87%
Key
Long Key NA
NA
NA
NA
LOWER KEYS
Cudjoe 1.33
1 7,964
7,987
23
>100 0
Big Co it
0.32
1,916
1,711
205
89%
Baypoint
0.07
419
430
(11)
>100%
Boca Chica
0.44
2,635
2,600
35
99%
Key Haven
0.20
1,198
450
748
38%
Stock Island
0.45
2,695
2,672
23
99%
Following projected growth rates of 3.6 percent for the Upper, Middle, and Lower Keys,
Table 10.7 expands upon Table 10.6 showing additional demands against capacity of
planned improvements.
Sanitary Sewer 23 Technical Document: may zutl
Monroe County Comprehensive Plan Update
Table 10.7 - 2030 Demand vs. Capacity
10.5.5 Performance, Problems, and Opportunities
[Rule 95-5. 011 (1)(f)2. and 3., FAC]
The capacities and demands for the previous tables are for planned improvements in
various states of completion. A more detailed analysis of existing connections and level of
service are identified in the analysis of existing conditions. The primary obstruction
hindering implementation has been funding.
All proposed improvements at or above 100 percent utilization should be further analyzed
to ensure conformance with future demands. In addition, the reallocation of demands from
Permanent to Functional Population and the migration from Upper to Lower Keys may
result in the need to confirm plant capacities.
One uncertainty is the impact that the pending EPA Water Quality Standards for the State of
Florida's Lakes and Flowing Waters and Marine Systems, 40 CFR, part 131, may have on
both existing and proposed facilities. The mandates associated with this program may
introduce additional requirements for treatment and result in further improvements to
both regional and small private facilities.
Sanitary Sewer 24 Technical Document: May 2011
Monroe County Comprehensive Plan Update
10.6 Policy and Regulations
[Rule 9J-5.011 (2) (c), FAQ
The most significant issue in implementing the proposed wastewater plan is the lack of
funding and construction of proposed improvements. Of the total number of EDUs treated
through the ongoing programs, only 45 percent have resulted in hook-ups being made.
Some of the recommendations to overcome fiscal impacts suggested in the Master Plan are
as follows:
• FKAA and County to pursue uniform fee structure to enable implementation to less
dense areas to level out impact and connection fees.
• Pursue State and federal grants with FKAA to supplement costs.
• A Memorandum of Understanding between FKAA and County was established
identifying FKAA as the service provider, except for municipal areas.
• Acquire necessary land to accommodate future facilities and expansion.
• Develop standards and hook-up requirements for hot spots in coordination with DOH.
The Remainder of This Page Intentionally Left Blank
Sanitary Sewer 25 Technical Document: May 2011
Monroe County Com rehensive Plan Update
Bibliography
Anderson, D.L., J.M. Rice, M.L. Voohees, R.A. Kirner, and K.M. Sherman, 1987, In On -Site
Wastewater Treatment.
Department of Community Affairs, "Annual Assessment Report, Florida Keys Area of Critical
State Concern", July 2007.
Department of Environmental Protection, "Report to Department Community Affairs, 10-
year Work Program for Monroe, Florida Keys Wastewater Improvements", April
2008.
Florida Keys Aqueduct Authority, "Lower Keys Wastewater Master Plan Update' November
2008 Workshop.
FDEP, "Florida Keys Area Reasonable Assurance Documentation - North, Central, South-
Centera and Southern", May 2008.
Monroe County Comprehensive Plan, Technical Document, Element 10.0, 2000.
Monroe County, "Keys Wastewater Plan" - November 2007, Report to Environmental and
Natural Resources Council, Florida House of Representatives.
Monroe County, "Monroe County Sanitary Wastewater Master Plan", June 2000.
Sanitary Sewer 26
Technical Document: May 2011
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