02/17/2000
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MEMORANDUM OF UNDERSTANDING z )> C
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Coordinated Permit Review Process for Wastewater Disposal R;ffliiis -
And Development Permits for New Residential Developm~~~Fz: UI
In Unincorporated Monroe County ~~~ ~
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This Memorandum of Understanding ('MOU") is entered into between ~De ~or.
Department of Community Affairs ("DCA"), Florida Department of Hecftffi
("DOH"), including the Monroe County Health Department ("MCHD"), Florida
Department of Environmental Protection ("DEP") and Monroe County ("County").
Background
The purpose of this MOU is to document the individual and collective
responsibilities of the above parties to implement a coordinated permit review
process regarding wastewater disposal permits and development permits for new
residential development in unincorporated Monroe County as required under
Administration Commission Rule 28-20.100, Comprehensive Plan - Part II (35)
Policy 101.2.13 and as directed in Executive Orders 96-108 and 98-309. This
MOU replaces the original MOU entered into between the parties in July 1997.
Rule 28-20.100 directs that no state agency shall issue a wastewater disposal
permit that would allow development in excess of the number of permits that
Monroe County may issue under Policy 101.2.13 for new residential
development, and that Monroe County shall not issue development permits in
excess of wastewater disposal permits that DOH or wastewater treatment plant
construction permits that DEP may issue.
Monroe County adopted Ordinance No. 16-1992, as amended, establishing a
dwelling unit allocation system, also referred to as the Rate of Growth Ordinance
("ROGO"), to facilitate implementation of the Florida Keys Comprehensive Plan
and Development regulations and to regulate the rate of growth.
Monroe County more recently adopted Ordinance No. 31-1999 regarding an
inspection and compliance program for on-site sewage treatment and disposal
systems ("OSTDS"), requiring the replacement of unknown, unpermitted and
inadequate OSTDS within areas identified as "Cold Spots" in the County's master
wastewater planning process.
Purpose and Scope
This MOU and the above cited ordinances, as amended by Administration
Commission Rule No. 28-20.100, are intended to serve as the interim Permit
Allocation System, the coordinated permit review process, and the tracking
system for monitoring nutrient reduction credits required by Administration
Commission Rule 28-20.100.
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Authority
General authority for the parties to enter into this MOU is provided by
Administration Commission Rule No. 28-20.100(35), Florida Administrative Code.
Additionally, DCA is authorized by Section 380.032, Florida Statutes (F.S.), to
enter into an agreement with any landowner, developer or other governmental
agency as may be necessary to effectuate the provisions and purposes of
Chapter 380, F.S., or any related rule. DEP is authorized to enter into this
agreement under Section 403.61 (21), F.S., and Monroe County is authorized
under Chapters 125 and 380, F.S.
Nutrient Reduction Credits
Nutrient reduction credit(s) are generated for the replacement or upgrading of a
cesspool or non-compliant OSTDS with a DOH/MCHD approved OSTDS or
connection to a DEP approved wastewater treatment system. Nutrient reduction
credits ("nutrient credit") are generated in accordance with the Nutrient Reduction
Credit Schedule, which is included as Addendum One to this Agreement. These
credits may be accumulated and may be applied to ROGO allocation awards in
future ROGO years. Except as expressly provided for in this Agreement, nutrient
credits may only be applied to a ROGO allocation award within the same ROGO
planning area in which they were generated.
DOH Tracking System for Nutrient Credits
DOH/MCHD, hereinafter referred to collectively as "MCHD," agrees to maintain a
tracking system that monitors nutrient reduction credits in each of the County's
ROGO areas. MCHD agrees to track the number of nutrient credits generated.
Each full (1.0) nutrient credit will be assigned a unique identifier number. Each
half (0.5) credit will be given a unique identifier with an "A" or "B" suffix, that must
be linked to its corresponding half credit to generate a full nutrient credit.
Prior to each Monroe County Planning Commission meeting to approve the
allocation of ROGO awards, MCHD agrees to notify the Monroe County Planning
Department of the number of full nutrient credits available in each ROGO area
along with their unique identifier numbers.
No OSTDS permit may be issued for a new residential dwelling unit unless a full
unused nutrient credit exists for that ROGO area. When the OSTDS permit is
issued, a nutrient credit is then considered used and the record for that nutrient
credit will include a unique identifier provided by Monroe County for the ROGO
allocation award linked to that nutrient credit. The nutrient credit identifier and
ROGO allocation award identifier will both be included on the issued OSTDS
permit.
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The MCHD with assistance from Monroe County will keep a cumulative list of
individual used and unused nutrient credits, unique identifiers for each nutrient
credit, dates issued, ROGO area of each nutrient credit, the corresponding
OSTDS permits issued, and corresponding ROGO award identifiers. MCHD
agrees to provide a semi-annual report showing totals-to-date, annual, and semi-
annual figures to all parties to this Agreement and to the Executive Office of the
Governor.
DEP Assistance in Nutrient Tracking
The Department will assist Monroe County in its nutrient tracking efforts to
ensure that construction permits for domestic wastewater facilities do not allow
development in excess of the number of building permits that the County may
issue. To do this, the DEP will provide the County with a copy of the permit
application within 15 days of its receipt by the DEP.
The DEP will notify the County of its intent to draft (or deny) a permit. If the
County objects, for any reason, to issuing the permit, it may request an
administrative hearing in accordance with Rule 62-620.510, FAC.
County Tracking of 88 "Future" Nutrient Credits
In accordance with Florida Administration Commission Rule 28-20.100, Monroe
County is permitted to receive 88 "future" nutrient credits that are to be
generated by the County's assistance program, funded by the State and County,
for the replacement of cesspools for low and low-moderate income households.
The County has applied a portion of these nutrient credits to eliminate the
backlog of applicants eligible for a ROGO allocation award at the end of ROGO
Year 8. The remainder of the nutrient credits are to be applied anywhere in the
County at the policy discretion of the Board of County Commissioners.
The County agrees to maintain a tracking system for these "future" nutrient
credits. Each nutrient credit will be assigned a unique identifier number by the
County.
The County will provide MCHD with the unique identifier for the nutrient credit at
the same time that the unique ROGO allocation award identifier is provided. This
nutrient credit identifier and ROGO allocation award identifier will both be
included on the issued OSTD permit.
For the 88 "future" credits, the County will keep a cumulative list of individual
used and unused nutrient credits, unique identifiers for each nutrient credit, dates
issued, the corresponding OSTDS permits issued, and corresponding ROGO
award identifiers. The County agrees to provide a semi-annual report showing
totals-to-date to the parties to this Agreement and to the Executive Office of the
Governor.
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ROGO Allocation Tracking System
The County agrees to maintain a tracking system that monitors ROGO allocation
awards in each of the separate ROGO areas, with separate tracking for market-
rate residential and affordable residential awards. The County agrees to track
the number of residential ROGO allocation awards generated and used.
When a building permit application for a new residential dwelling unit is submitted
to the County Building Department, the County will assign a unique identifier to
that application which shall also serve as its unique ROGO award identification
number for tracking purposes. When a ROGO allocation award is made, the
County will notify applicants receiving the ROGO award and MCHD.
In determining ROGO allocation awards, the County will use the information
provided by MCHD and its own nutrient tracking records regarding the number of
nutrient credits available in each ROGO area. No building permit for a new
residential dwelling unit may be issued unless the applicant has received a
ROGO allocation award with a unique identifier; and, if appropriate, an OSTDS
permit with a corresponding nutrient credit and unique identifier from MCHD.
Assignment of Nutrient Credits
Nutrient credits will be divided between affordable residential and market-rate
residential awards in a minimum of 20:80 proportion, unless the County's
Planning Commission approves an increase in the proportion of affordable
housing allocations as provided for in the Monroe County Land Development
Regulations. If such an increase is authorized, this proportion will be adjusted
accordingly and the County will notify MCHD. No nutrient credits associated with
affordable residential ROGO allocation awards may be switched to market-rate
residential allocations.
Any nutrient credits which the County obtains through agreements with private
and public entities under the provisions of Chapters 163 and 380, F.S., will be
available for assignment by the County within the same ROGO planning area.
The County will coordinate the assignment of these nutrient credits with MCHD.
A ROGO allocation awardee with an available nutrient credit has sixty (60) days
to pick up his OSTDS and building permit after notification by the County. After
sixty (60) days, the ROGO allocation award expires and the nutrient credit is
available to be assigned to the eligible ROGO awardee highest on the nutrient
credit list.
The County will maintain a cumulative list of individual used and unused ROGO
allocation awards, corresponding unique award identifiers, dates issued, ROGO
area of each award including whether it was categorized as either market-rate
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residential or affordable residential, and the corresponding nutrient credit
identifiers. The County agrees to provide a quarterly summary report showing
totals to date, annual, and quarterly figures to all parties to this Agreement and
the Executive Office of the Governor.
Adjustment of ROGO Awards
Applicants with ROGO scores sufficient to receive an allocation in a ROGO
quarter, but unable to be awarded a ROGO allocation in order to receive their
OSTDS and building permits because of a shortage of nutrient credits, will retain
their ROGO ranking and nutrient credit priority rank for future nutrient credits that
may become available, ahead of ROGO applicants who receive a sufficient
ranking to receive a ROGO allocation in subsequent ROGO quarters.
At the end of each ROGO year, the number of ROGO allocation awards in the
next ROGO year will be reduced by the number of ROGO applications with
sufficient scores to receive a ROGO allocation award, but which are still awaiting
a nutrient credit.
Coordinated Permit Review Process
The Coordinated Permit Review Process for On-site Wastewater Disposal
Permits and Development Permits for unincorporated Monroe County from the
applicant's perspective will be as follows:
1. The applicant for an OSTDS permit for new development applies for
and receives a preliminary OSTDS letter of review from MCHD if all conditions
are met except the possession of a nutrient credit. The applicant signs a
disclaimer acknowledging that the OSTDS permit will not be issued until and
unless a nutrient credit is available, and that the County cannot issue a building
permit until the applicant receives a ROGO allocation award and verification of
nutrient credit availability.
2. The applicant provides the County with a coordinating letter from
MCHD and goes through the building permit application and ROGO process and
receives a ROGO allocation ranking. The ROGO ranking also determines the
priority for a nutrient credit.
3. If the applicant's ranking is sufficiently high to receive a ROGO
allocation award and if a nutrient credit is available, the applicant is notified by
Monroe County that he is eligible to receive an OSTDS permit and then a
building permit. The County notifies the MCHD. The notification includes a
unique identifier for the applicant's ROGO award. The notification also states
that the awardee has sixty (60) days to pick up the OSTDS permit from the
MCHD and the building permit from the County; otherwise the applicant's
building permit and ROGO award expire. The County also compiles a ranking of
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all applicants considered for the quarterly ROGO allocation award. Applicants
may consult this list to determine their ranking. In some ROGO quarters, the
number of available nutrient credits may be less than the number of available
ROGO allocation awards. Those ROGO applicants with sufficient ranking to be
eligible for a ROGO award, but are unable to receive an award due to a shortage
of nutrient credits, will retain their ROGO ranking and nutrient credit priority rank
for future nutrient credits that may become available, ahead of applicants who
have sufficient ranking to receive a ROGO award in future quarters.
4. The applicant brings the ROGO award notification with its unique
identifier to the MCHD to receive an OSTDS permit. MCHD issues the applicant
an OSTDS permit showing both the nutrient credit unique identifier and the
ROGO award unique identifier. MCHD notifies the County after the applicant
receives the OSTDS permit.
5. The applicant brings the OSTDS permit to the County and picks up his
building permit. The building permit shows both the nutrient credit unique
identifier and ROGO award unique identifier.
6. At any stage in the permitting process an applicant has the option of
earning a nutrient credit in accordance with the schedule in Addendum One by
replacing or upgrading a wastewater system in the ROGO area within which the
applicant wishes to build. After final inspection and approval by MCHD of the
new OSTDS replacing or upgrading a wastewater system, MCHD will reserve the
resulting nutrient credit and unique identifier in the applicant's name and will
issue a preliminary OSTDS letter of review if all other conditions are met.
However under no circumstances will the applicant be able to reserve a nutrient
credit that is generated under the County's Homeowners Wastewater Assistance
Program or without providing the MCHD with a building permit application
number.
Effective Date
This MOU shall take effect upon the date the last party signs this MOU and shall
remain in effect for the period prescribed within Administration Commission Rule
28-20.100.
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THE PARTIES, by their duly authorized undersigned representatives have
executed this Memorandum of Understanding on the dates and year below
written.
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Mayor, Board of ounty Commissioners,
Monroe County, Florida
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Administrator, Monroe County Haith Department
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ADDENDUM ONE
NUTRIENT REDUCTION CREDIT SCHEDULE
On-site Sewage Treatment and Disposal System Upgrades
The upgrade or replacement of the following wastewater treatment systems to a
DOH/MCHD approved OSTDS:
Cesspit
Substandard OSTDS
Approved OSTDS
Secondary Treatment
1.0 Nutrient Credit
0.5 Nutrient Credit
0.5 Nutrient Credit
Not Applicable
Centralized: Secondary Wastewater Treatment System Upgrades
The upgrade or replacement of the following wastewater treatment systems to a
DEP approved centralized system with secondary treatment:
Cesspit
Substandard OSTDS
Approved OSTDS
Secondary Treatment
1.0 Nutrient Credit
0.5 Nutrient Credit
0.0 Nutrient Credit
Not Applicable
Centralized: Best Available Treatment (BAT)
The upgrade or replacement of the following wastewater treatment systems to a
DEP approved centralized SAT system:
Cesspit
Substandard OSTDS
Approved OSTDS
Secondary Treatment
1.0 Nutrient Credit
1.0 Nutrient Credit
1.0 Nutrient Credit
1.0 Nutrient Credit
Centralized: Advanced Wastewater Treatment (A WT)
The upgrade or replacement of the following wastewater treatment systems to a
DEP approved centralized AWT system:
Cesspit
Substandard OSTDS
Approved OSTDS
Secondary
1.5 Nutrient Credit
1.5 Nutrient Credit
1.5 Nutrient Credit
1.5 Nutrient Credit
Note: 1.0 nutrient credit equals 1.0 equivalent residential unit (ERU).
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