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Productivity Committee Agenda 03/14/2019March 14, 2019 10:00 AM Productivity Committee Meeting 3299 Tamiami Trl E Naples FL, 34112 Fifth Floor Training Room 1. Call to Order 2. Pledge of Allegiance 3. Roll Call 4. Adoption of the Agenda 5. Public Comment 6. Adoption of Minutes from Previous Meeting 6.1. February 7, 2018 7. Staff Reports 8. New Business 8.1. Landscape Maintenance 9. Old Business 9.1. BMAP Cost 10. Announcements (no action) 11. Committee Member Discussion 12. Next Meeting Time, Date and Location 12.1. Thursday, April 11, 2019 @ 10AM 13. Adjournment Good Morning (afternoon) Commissioners. At your request the County Productivity Committee, of which I serve as chairman has examined the Storm Water status in the county. We reviewed previous efforts, held our regular meetings and called a special meeting in the evening to allow for more public input. I know that I speak for all members of the committee in thanking you for submitting an issue to the Productivity Committee for our review. At several of our meetings the committee members suggested and requested an assignment to utilize the committee cumulative talents and experience. Although the deputy county manager and staff adequately presented information that was of interest, we didn’t have an “assignment” until this was undertaken. The other opinion shared by the committee is that this issue was very complex and has several moving parts. In hindsight I think we would have preferred something simpler to “cut our teeth on”. The storm water system in Collier County is, as you know, extensive and contains multiple pieces and parts to deal with collection and movement of water, prevention of flooding, and final elimination while minimizing the impact on water quality. The committee reviewed the system, the most recent resources applied to operation and maintenance and the need for additional priority and action(s). Multiple possibilities exist for applying the proper resources in improving the storm water system. Recent efforts have been inadequate and the Productivity Committee is unanimous in recommending that the Commission approve a long-range plan to address the shortfalls that exist. The current year effort expends ~$8M on a system that requires some $21M/year for the next 5 years to recover and approach industry standards. The options presented to the committee were 1) a storm water utility fee, 2) ad Valorem tax, 3) Bonding, 4) a franchise fee, 5) or some combination of these. After significant deliberation and hearing from each of the members individually the committee voted to recommend a dedicated 0.15 mils of the ad Valorem tax to fund storm water Operations, Maintenance and capital needs in the next budget year. Although not meeting the total needs of the system this level of effort yields approximately a 50% increase in funding. It also provides the time necessary to create the long-range plan recommended, assess the impacts of tax base growth, and the opportunities and options to improve the system without simply going to the population for additional revenue as suggested last September. Revised 9/15/2015 version 15.1 EXECUTIVE SUMMARY Recommendation to approve staff’s recommendation to continue moving forward with implementing a Limited Stormwater Utility Fee to fund operations and maintenance of the County’s Stormwater Management System, for future consideration by the Board of County Commissioners. OBJECTIVE: Provide staff with direction in order to proceeded with budgeting and funding the Operations, Maintenance and Capital needs of the County Stormwater Management System. CONSIDERATIONS: On September 6, 2018, the Board of County Commissioners (Board) directed that the Stormwater Utility Fee adoption be continued for one year to allow greater public input and evaluate potential adjusts to the parameters of the fee. Two subsequent presentations were made to the Board (October 23, 2018, Item 11G and November 13, 2018, Item 11B) on the status of the Stormwater Utility, further information related to public input/comments, funding levels and potential Stormwater Utility Fee options. These presentations outlined the requirements and timeframes to implement a Stormwater Utility in FY 20. Arising from the November 13, 2018 presentation, the Board directed that the matter of Stormwater funding, including the Stormwater Utility concept, be assigned to the Productivity Committee for their review and development of options to address the ongoing funding needs of the County Stormwater Management System. To that end, staff has been working with key stakeholders, outside counsel, and the Productivity Committee to develop a suite of potential options. Through this review, staff has developed a recommendation that provides necessary funding for the critical operations and maintenance of the Stormwater Management System that is less impactful and generally more acceptable than the original Stormwater Utility proposal, and still provides a stable, dedicated funding source for these activities. Staff is recommending continuing to move forward with implementing a Limited Stormwater Utility Fee for Operations and Maintenance activities. Staff has been working with outside counsel to develop a preliminary fee structure within specified legal parameters. Upon receiving further Board direction, staff will finalize the calculations in order to move forward through the adoption process required by Florida Statutes. Several additional public hearings are required before the fee can be adopted and implemented. In addition, staff will continue to work with the public and stakeholders to discuss and identify potential concerns and issues. While all parties do not agree on what is the best mechanism to fund Stormwater Management functions, all parties that have been a part of the discussion agree that there is a significant need to properly fund Stormwater Management activities. Preliminary details of the Limited Stormwater Utility Fee are as follows: • Unincorporated Area • Single fee for condo units • Single fee for residential parcels • Commercial parcels: ERU based, tiered, with maximum cap number of ERUs • Revenues generated applied to Operations & Maintenance • Capital Projects would require continued funding from Property Taxes • Continues to rely on impervious area calculations as a starting basis for the fee to preserve legal defensibility • Provides simplified structure, without complicated credit programs Estimated fee ranges are as follows: Revised 9/15/2015 version 15.1 Parcel Type Annual Fee Monthly Fee Residential (parcel) $60 - $75 $5.00 - $6.25 Condominium (unit) $39 - $51 $3.25 - $4.25 Commercial (parcel) $60 - $1,200 $5 - $100 Based on the preliminary fee ranges above, revenue projections provide estimated funding of approximately $8.4 - $8.6 million to be dedicated and restricted to Stormwater activities to move towards achieving the Industry Standard Level of Service that was supported by the Board. Therefore, staff’s recommendation, as detailed above, is to move forward with implementing a Limited Stormwater Utility Fees for Stormwater Management Operations and Maintenance, not to exceed the maximum of the ranges above. If the Board accepts staff’s recommendation, the next steps in the process include continued public outreach and finalization of the fee structure to present a final recommendation and the required Preliminary Rate Resolution to the Board in April or early May. The remaining steps of the Statutory process follow the decision of the Board on the adoption of the Preliminary Rate Resolution. PRODUCTIVITY COMMITTEE REVIEW: In accordance with Board direction, the Productivity Committee met and discussed the Stormwater Utility Fee at 4 meetings: • December 13, 2018 • January 10, 2019 • January 29, 2019 • February 7, 2019 The Committee discussed the Stormwater Utility Fee as it was presented to the Board at the September 6, 2018 Board meeting, a limited fee to address maintenance, Ad Valorem funding, and a Franchise Fee option. Staff shared the Operations and Maintenance and Capital needs to achieve the industry standard as adopted by the Board. At the last meeting the Productivity Committee arrived at their recommendation to the Board. The Committee felt that it was necessary to allocate the appropriate level of funding to at least address the maintenance of the stormwater system. The Committee showed a preference for a dedicated funding source and felt that a Stormwater Utility Fee was the most effective method but felt that more analysis should be done over the next year. With the implementation of the Infrastructure Sales Surtax the Committee felt that it was too early to tell what the impacts would be upon commercial establishments. The Committee was also hesitant to recommend any long-term funding plan that did not result in dedicated funding concerned that there would be nothing preventing future Boards from reallocating funding to other projects. The Committee agreed that they would like to see the County dedicate a .15 mils equivalent (approximately $12M/yr.) for Fiscal Year 2020 to fund the Stormwater Maintenance as well as a portion of the Stormwater Capital program. During the upcoming year, allow the Productivity Committee and staff to continue to work toward developing/refining a Stormwater Utility Fee. Staff should consider the impacts of the Infrastructure Sales Surtax on local businesses. Other Considerations are to implement a Franchise Fee at approximately 5.9% specifically for stormwater maintenance. Capital projects would require funding from property taxes/other sources. FISCAL IMPACT: The current level of funding from the General Fund (001) and Unincorporated Area General Fund (111) is not sufficient to achieve an expanded level of Stormwater Capital and Maintenance funding consistent with industry standards. Without implementing a dedicated Stormwater Assessment, some level of capital financing, in conjunction with increasing General Fund (001) and Unincorporated Area General Fund (111) maintenance dollars, will be required to advance the program beyond the current, limited “pay go” standard. Revised 9/15/2015 version 15.1 If a Stormwater Utility Fee is implemented under the parameters above, the dedicated funds would be used for the Operations and Maintenance of the Stormwater Management System, thereby providing adequate funding to ultimately achieve and maintain industry standards. The Stormwater Capital program would continue to be funded by the General Fund (001) and Unincorporated Area General Fund (111) with the possibility to utilize some level of capital financing to augment the funding and move needed projects forward. GROWTH MANAGEMENT IMPACT: The proposed recommendation, as well as other options considered, would provide additional Stormwater funding to further the goals, objectives and policies of the Stormwater Management Sub-Element of the Collier County Growth Management Plan. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney and requires majority vote for approval. Legal review of the fee will need to await staff’s ultimate proposal. -JAK RECOMMENDATION: To approve staff’s recommendation to move forward with implementing a Limited Stormwater Utility Fee, with fee ranges not to exceed those detailed above, to fund Operations and Maintenance of the County’s Stormwater Management System, for future consideration by the Board of County Commissioners. Prepared by: Geoff Willig, Operations Analyst for the County Manager's Office Amy Patterson, Director, GMD Capital Projects Planning Page 1 of 6 February 20, 2019 Basin Action Management Plan (BMAP) Costs White Paper Purpose The purpose of this whitepaper is to provide a general understanding of a Basin Action Management Plan (BMAP) and the potential costs of development and implementation. This paper will attempt to quantify the cost associated with BMAPs and focus on three waterbodies within Collier County (Gordon River Extension, Naples Bay, and Lake Trafford). Background The Florida Department of Environmental Protection (FDEP) developed a five-year cycle that divides Florida into five groups of surface water basins in which different activities take place each year; the cycle is reiterated continuously to evaluate the success of clean-up efforts, refine water quality protection strategies, and account for the changes brought about by Florida’s rapid growth and development. Collier County is located in the Everglades West Coast Basin (EWC) in Group 1. Each group undergoes a cycle of five phases on a rotating schedule. Collier County entered this rotating cycle in 2000 and is currently in Phase 2 of Cycle 4. Phase 2 of Cycle 4 was delayed by the FDEP due to the development and implementation of new dissolved oxygen and numeric nutrient criteria Statewide. Phase 1: Preliminary Evaluation Close coordination with local stakeholders to conduct a preliminary basin wide water quality assessment; inventory existing and proposed management activities; identify management objectives and issues of concern; develop a strategic monitoring plan; and produce a preliminary Status Report that includes a Planning List of potentially impaired waters. Phase 2: Strategic Monitoring and Assessment Cooperative efforts between the FDEP and local stakeholders to collect additional data; get data into STORET or WIN (regulatory databases); complete water quality assessment; produce a final Assessment Report that includes a Verified List of impaired waters for Secretarial adoption; and provide an opportunity for stakeholders to document reasonable assurance (for FDEP review) that existing management plans and projects are adequate to restore water quality without the establishment of a Total Maximum Daily Load (TMDL). Phase 3: Development and Adoption of TMDLs Coordination with stakeholders to discuss TMDL model framework, including model requirements, parameters to be modeled, model endpoints, design run scenarios and preliminary allocations; communication of science used in the process; and public workshops for rule adoption of TMDLs. Phase 4: Development of Basin Management Action Plan (BMAP) Broad stakeholder participation in developing a Basin Management Action Plan (including detailed allocations and implementation strategies), incorporating it into existing management plans where feasible; public meetings during the planning process. Page 2 of 6 February 20, 2019 Phase 5: Implementation of Basin Management Action Plan Emphasis on implementing the BMAP, other voluntary stakeholder actions, and local watershed management structures; FDEP will continue to provide technical assistance, fulfill oversight responsibilities, and administer National Pollutant Discharge Elimination System (NPDES) point and nonpoint source permits. Impaired Waters Rules Assessment - Phases 1 and 2 involve the collection and assessment of surface water quality data. Collier County Pollution Control monitors 77 surface water sites and uploads the data to the FDEP’s database. The FDEP utilizes this database to determine if the waterbodies are meeting State water quality standards provided in Florida Administrative Code 62-302. If the surface waters are not meeting State standards, the FDEP verifies them as “impaired” and prioritizes them for Total Maximum Daily Load (TMDL) development. On November 14, 2018, the FDEP released their draft list of verified impaired waters for Phase 2 of Cycle 4. Total Maximum Daily Load (TMDL) - Phase 3 begins the development of a TMDL. A TMDL is a scientific determination of the maximum amount of a given pollutant that a surface water can absorb and still meet the water quality standards that protect human health and aquatic life. Water bodies that do not meet water quality standards are identified as "impaired" for the particular pollutants of concern (e.g. nutrients, bacteria, mercury, etc.). Upon this determination TMDLs must be developed, adopted and implemented to reduce those pollutants and clean up the water body. Once TMDLs are adopted under Secretarial Order, they are then considered the new water quality criteria for that waterbody and are incorporated into Florida Administrative Code 62-304. Discharges into a waterbody with an adopted TMDL must meet the water quality criteria set forth in the TMDL. Collier County currently has three TMDLs (Gordon River Extension, Lake Trafford, and Cocohatchee River). Basin Management Action Plans - A BMAP is the "blueprint" for restoring impaired waters by reducing pollutant loading to meet the allowable criteria established in a TMDL. BMAPs include a set of strategies including but not limited to, permit limits on wastewater facilities, urban and agricultural best management practices, conservation programs, and financial assistance and revenue generating activities designed to reduce pollutants established by the TMDL. These broad-based plans are developed by the FDEP with input from local stakeholders. They rely on local input and local commitment, and they are adopted by Secretarial Order to be enforceable. A BMAP typically includes language requiring load reductions for any National Pollutant Discharge Elimination System (NPDES) permit holders that discharge into the waterbody with the TMDL. Currently there are no BMAPs for the 3 waterbodies with adopted TMDLs in Collier County. Lee County has 3 adopted BMAPs that were developed to address almost identical TMDLs as those we have in Collier County. Language has been written into their NPDES permit and they are required to meet the TMDL limits in their county’s stormwater system. Lee County has spent approximately $27.1 million in 5 years on projects to improve water quality in an attempt to meet their TMDLs and comply with their BMAPs. Currently, the FDEP has no plans to implement a BMAP for existing TMDLs within Collier County for Assessment Cycle 4. Staff believes this is due to proactive pollution prevention activities and coordination with FDEP. That doesn’t mean that there won’t be BMAPs in the future for future TMDLs, especially if water quality improvements are not made. Page 3 of 6 February 20, 2019 Costs associated with BMAPs Determining the cost of a BMAP is problematic due to the specific nature of each water body and the watersheds which feed them. Additionally, the impairments and or TMDLs which can result in issuance of a BMAP are contaminant specific as are the assessments, corrective actions, educational outreach, and best management practice required to restore water quality. The following section will attempt to establish some general costs associated with BMAPs. Source Tracking – One of the first steps of a BMAP is to determine all potential contributing sources within a watershed. This requires extensive research including reviews of aerial photography, regulated facilities, current and former land uses, and stormwater management systems within each watershed. Upon completion of the research, extensive ground truthing is required to confirm the location of regulated facilities, actual land uses, and the outfalls of each stormwater management system within the watershed. Contaminant specific sampling within each watershed will be necessary to determine sources that are degrading water quality within a watershed. Costs associated with source tracking can vary greatly depending on the specific waterbody and the impairments within. Septic to Sewer Conversion – Depending on the specific impairment, septic systems may be a significant contributor to water quality degradation. Nutrient impacts associated with onsite septic systems generally result from dense urban development, specifically residential development on small lots in locations with elevated water tables. These conditions exist in several areas of Collier County. Based on this general understanding the costs associated with septic to sewer conversion should be factored into quantifying a BMAP associated with nutrient impairments. Capital Improvement Stormwater Projects – Proper stormwater management is an integral component of water quality. Maintenance and or replacement of ageing infrastructure to improve functionality in addition to the installation of new stormwater management systems, can improve water quality throughout the county. Based on this understanding stormwater improvement projects and ongoing maintenance may be require to comply with a BMAP. Collier County stormwater staff provided costs for maintenance and new infrastructure projects within the Lake Trafford, Gordon River Extension, and Naples Bay (Golden Gate City) watersheds. Best Management Practices – Once the sources of a specific contaminant have been determined, best management practices can be implemented within those source areas to reduce pollutant loads within a waterbody. Best management practices can include altering landscape maintenance practices, lake management, providing secondary containment at regulated facilities, properly maintaining stormwater management systems, establishing new littoral shelf planting, etc. As with source tracking, costs associated with the implementation of best management practices can vary greatly. Education and Outreach – Education and outreach plays an integral part of addressing and rectifying any BMAP. Educating stakeholders and the general public requires the development of educational materials (brochures, posters, presentation and other informative handouts), in addition to attending public meetings, workshops, and events. The costs associated with education and outreach can vary depending type of impairment, the size of the watershed, and the number of stakeholders. Page 4 of 6 February 20, 2019 Site Specific Examples Lake Trafford – This watershed is impaired for nutrients, unionized ammonia and dissolved oxygen. TMDLs have been established for total nitrogen (TN) and total phosphorus (TP), as the FDEP is anticipating that by reducing TN and TP loading, ammonia and dissolved oxygen concentrations will respond favorably. Internal nutrient cycling within Lake Trafford has been a major ongoing nutrient source. In response, South Florida Water Management District dredged the lake in 2007-2010 to remove nutrient laden sediment. Additionally, a Lake Trafford Management Team was formed to bring stakeholders and managers together to develop a comprehensive plan to provide guidance on the long-term management of the lake to reach water quality goals. As part of an inclusive Everglades West Coast (EWC) BMAP, established to address dissolved oxygen impairments in the entire EWC, the FDEP wanted to gather more data regionally on land uses and their influence on groundwater and impairment of surface waters. This included the Lake Trafford watershed which is impaired for nutrients. As part of this BMAP, the FDEP installed and monitored wells in areas with various land uses throughout the EWC including, golf courses, residential areas (with septic systems), and areas using reclaimed water for irrigation. The monitored wells installed within the Lake Trafford watershed assisted with assessing what land uses may be contributing to the nutrient loading of the Lake. The FDEP and Collier County collected and analyzed samples in this watershed for two years (2014-2016). The FDEP has not concluded this monitoring effort, but reprioritized staff and resources elsewhere in the State. Pollution Control continues to assist FDEP with sample collection of extra bottles for FDEP’s nutrient source tracking in this WBID. Potential Cost of a Lake Trafford BMAP Source Tracking Routine monitoring $26,000, annually Groundwater assessment including new well installation, and DNA tracking $26,000 Subtotal $52,000 Septic Sewer Conversion – approximately $30,000 per system N/A Stormwater Projects – Planned within the next 10 years $22.6 million BMPs – Costs can vary dramatically ($100 - $100,000) ($100-$100,000) Education and Outreach – approximately $7,200 per WIBD $7,200 Total BMAP costs estimates (excludes any septic to sewer) $22,709,200 Page 5 of 6 February 20, 2019 Gordon River Extension – The Gordon River Extension is currently impaired for dissolved oxygen. The FDEP has attributed the dissolved oxygen impairment to elevated nutrients. Therefore, the TMDL requires total nitrogen reductions. The Gordon River Extension watershed is heavily developed with commercial and residential land uses. The FDEP installed and monitored wells within and outside of the Gordon River Extension Basin to see if groundwater and land uses are contributing to the nutrient load. Pollution Control assisted with monitoring of existing wells and locating sites for new wells that were representative of existing land uses. Samples were collected by FDEP from 2014-2016 until FDEP staff were reprioritized to other projects. Actions conducted to reduce nitrogen within this watershed include the Freedom Park wetland treatment system, which was designed and built to treat stormwater and remove nutrients from the surface water. Due to the relatively shallow groundwater table and dense residential development utilizing septic systems, Collier County and the City of Naples are conducted a joint project including septic to sewer conversion and stormwater improvements within this WBID. Pollution Control continues to assist FDEP with sample collection of extra bottles for FDEP’s nutrient and bacteria source tracking in this WBID. Potential Cost of a Gordon River Extension BMAP Source Tracking Routine monitoring $26,000, annually Groundwater assessment including new well installation, and DNA tracking $26,000 Subtotal $52,000 Septic Sewer Conversion – approximately $30,000 x 980 $29.4 million Stormwater Projects – Planned within the next 10 years (8-Projects) $33 million BMPs – Costs can vary dramatically ($100 - $100,000) ($100-$100,000) Education and Outreach – approximately $7,200 per WIBD $7,200 Total BMAP costs estimates $62,509200 Page 6 of 6 February 20, 2019 Naples Bay Costal Segment (Golden Gate City) – The Naples Bay Costal Segment watershed does not currently have TMDLs established, however iron and copper impairments have been identified, and data trends indicates that nutrients and bacteria may be added to the list this year. A significant upstream contributor to the Naples Bay watershed is Golden Gate City, which is heavily developed with commercial and residential land uses. A majority of the residential development is single family, constructed on small lots with septic systems. Due to the relatively shallow water table within this watershed it is suspected that these land uses may be a significant contributor of nutrients. Golden Gate City also contains an extensive County maintained stormwater management system. Collier County Pollution Control conducted additional monitoring and source tracking to determine the sources of copper and iron within this watershed. The source tracking research and sampling data, indicated that the use of copper-based herbicides being directly applied to the stormwater management system is a significant source of copper to the watershed. Pollution Control then conducted targeted education and outreach to pond owners, including County owned/maintained ponds, on adaptive pond management; discontinued use of copper-based herbicides and nutrient runoff reductions. Additionally, this source tracking research and sampling data indicated that the source of iron is naturally occurring from groundwater flows into the canals. Due to the location of this watershed several municipalities have jurisdictional interests, therefore BMAP costs may be spread out among several stakeholders. However, the potential savings may be negated by the additional costs associated with project coordination and cost share agreements. Potential Cost of a Naples Bay BMAP Source Tracking Routine monitoring $53,000, annually Groundwater assessment including new well installation, and DNA tracking $53,500 Subtotal $106,000 x 4 WBIDs that discharge to Naples Bay $424,000 Septic Sewer Conversion – approximately $30,000 x 1,500 $45 million Stormwater Projects – Planned within the next 10 years (8-Projects) $33 million BMPs – Costs can vary dramatically ($100 - $100,000) ($100-$100,000) Education and Outreach – approximately $7,200 per WIBD $7,200 Total BMAP costs estimates $78,481,200 Conclusions As discussed throughout this paper quantifying the costs associated with the assignment of a Basin Management Action Plan is difficult and estimates can vary. The individual characteristics of each watershed/waterbody and the impairments and or TMDLs which can result in issuance of a BMAP are contaminant specific as are the assessments, corrective actions, educational outreach, and best management practices required to restore water quality. Additional consideration should be made for multiple agency and municipality coordination and the costs shares that may be required depending on the watersheds boundaries and contributing sources. POLLUTION CONTROL & PREVENTION ORDINANCE Danette Kinaszczuk & Rhonda Watkins Planning Commission-March 7, 2019 •Delegates authority to State •Permits and presumptive criteria Clean Water Act Impaired Waters Rule F.A.C. 62-303 •CWA mandates that states assess their water quality and report to EPA •Implemented in Florida via the Impaired Waters Rule •Data collected by Pollution Control is used for the assessment •The state determines impairments, TMDLs, and BMAPs, not Pollution Control •33% of waterbodies are impaired •3 have Total Maximum Daily Loads assigned •0 Basin Management Action Plans Status •Classifications •Sampling Sites WBIDs Based on fecal coliform criteria Bacteria Impairments •FDEP has previously tied to nutrient impairments •Likely caused by groundwater inputs •No new impairments until numeric nutrient criteria are developed Dissolved Oxygen Impairments •Based on chlorophyll levels •New numeric nutrient criteria for estuaries •No current numeric nutrient criteria for canals Nutrient Impairments Caused by use of copper-based herbicides in freshwater systems and anti-fouling paint in estuaries Copper Impairments Naturally occurring coming from groundwater Iron Impairments Herbicide Application Can homeowners apply herbicides to ponds? RECOMMENDATION Live Green.Save Blue. Thank You Report Pollution. Section of PC Ordinance Summary Reasoning Article 2, Section 3 Requires best management practices be implemented While the actual language in Article 2 Section 3 is more stringent because FAC 62-780 FAC does not specifically state best management practices (BMPs) must be implemented, FDEP typically requires BMPs as a permit requirement or in the event of a spill, FDEP does site specific recommendations that typically include implementation of BMPs. FDEP often waives fines for BMP implementation. Article 3, Section 1 (A)Second sentence of A more is restrictive than FAC 62-624.200 (11) If there are impairments or Total Maximum Daily Loads assigned, Collier County is responsible for reducing pollutant loads into the receiving waterbody. Collier County may need to limit the polluant load of a discharger beyond the allowed downstream amount so the cumulative effect does not exceed the allowable pollutant load criteria downstream. Article 4, Section 4 (A) (7) A timeline is now given for changes to TL application packet which is more restrictive than existing ordinance 87-79 which has no timeline. This puts a time requirement on haulers to notify us about changes to the information that was supplied in the hauler's application, such as the addition of a new truck. We have trouble with haulers only licensing some of their trucks, then we catch them switching to an unlicensed (uninspected) truck which causes problems, for example, you may recall in January a 1200 gallons spill on Immokalee Road that also went into the canal. The time requirement will eliminate any ambiguity. Article 4, Section 4 (A) (8)Gives the ability to revoke license up to a year which is more restrictive than current ordinance 87-79. Right now we have no enforcement authority so there is no incentive to comply with the licensing requirement. The aformentioned hauler was unresponsive to compliance requests for 4 months and insisted the truck that discharged on Immokalee Road wasn't used in Collier County. The potential to not be able to operate in Collier County for up to one year will provide incentive to comply. Article 5, Section 2 (C)Requires a lock for lift stations, as opposed to FAC 62-604.400 (2) (d) which just requires a fence. Wet wells in lift stations are deep pits filled with raw sewage located in most residential areas. Left unlocked, children can access them causing serious injury or death. We want the wet wells or the fence surrounding the entire station to be locked so childen are unable to access them. Article 5, Section 2 (D)FAC 62-604.500 (2) states that system must be operated/ maintained so as to provide uninterrupted service, so requiring a maintenance contractor to ensure it functions all of the time is more restrictive. Article 5 Section 2 requires private lift stations owners must have a lift station maintenance agreement with a contractor that will respond 24/7/365 which is typical of lift station maintenance companies. State law says the collection system including the private lift station has to work all the time but we beleive that isn't feasible so we want an on call maintenance company to respond, for example, when there is raw sewage coming out of a manhole during the 4th of July block party. Article 5, Section 2 (E)62-604 (2)(d) deals with signage same as written in Ordinance, but reporting change in contractor is more restrictive. Article 5 Section 2 (E) requires the lift station owner to notify Collier County with any changes to the lift station maintenance contractor so we can get ahold of someone to come out and pump down the lift station and make repairs, for examples, when we get the call at 3 am that there is raw sewage flowing into Haldeman Creek. Article 6, Section 2 Requires monitoring of private stormater managements system Source tracking, the discharger may have to show they are not discharging contaminants if permit requirements are not being met or reasonable BMPs are not being implemented. Section of PC Ordinance Summary Reasoning Article 8, Section 1 {C) (1)Requires testing and maintenance of source tracking records Maintnence of source tracking data/records, the discharger may have to show they are not discharging contaminants if permit requirements are not being met or reasonable BMPs are not being implemented. Article 8, Section 2 (A,B)FAC 62-780 requires reporting to state, this is more restrictive in that they need to report to Pollution Control as well. Allows for faster response time, also allows oversight for spills FDEP determines to be de minimus. Article 8, Section 2 (C)Requires installation of BMPs. Same as Article 2 Section 3. While the actual language in Article 2 Section 3 is more stringent because FAC 62-780 FAC does not specifically state best management practices (BMPs) must be implemented, FDEP typically requires BMPs as a permit requirement or in the event of a spill, FDEP does site specific recommendations that typically include implementation of BMPs. FDEP often waives fines for BMP implementation. Article 8, Section 2 (D)Requires remediation for cumulative pollution, but under one-time pollution amounts. Individual spills may not impact water quality beyond allowable criteria, therefore no remedation criteria exists, however, ongoing discharges do impact beyond allowable criteria and this will allow for remediating cumulative discharges if needed. Article 8, Section 2 (E)County may hire contractor to clean up and bill PRSR. This would be done when the responsible party or property owner can not be found in a timely manner and it is in the best interest of Collier County to stop a discharge or remediate a site, such as a spill in a wellfield protection zone. Proposed Pollution Control & Prevention Ordinance 02/26/2019 STAFF REPORT TO: COLLIER COUNTY PLANNING COMMISSION FROM: POLLUTION CONTROL GROWTH MANAGEMENT DEPARTMENT HEARING DATE: March 7, 2019 SUBJECT: PROPOSED POLLUTION CONTROL & PREVENTION ORDINANCE ______________________________________________________________________________ UPDATE FROM FEBRUARY 7, 2019 MEETING All requested changes were made to the ordinance. Additionally, “Section One Collier County adopts an ordinance that reads as follows:” was added. Here is a link to an interactive map that illustrates the watersheds (WBIDs); classifications; water quality monitoring sites; and if applicable, impairments or total maximum daily loads. Attachments:  Attachment 2 – updated ordinance  Attachment 3 – snapshot of one sampling site water quality monitoring data  Attachment 4 – more restrictive rule summary and reasoning  Attachment 5 –CCPC read ahead TMDL and BMAP plan process  Attachment 6 – staff presentation REQUESTED ACTION: Pollution Control staff requests that the Planning Commission sitting as the Environmental Advisory Council provide a recommendation of approval to the Board of County Commissioners for the proposed Pollution Control and Prevention Ordinance, consolidating, repealing and replacing Ordinance No. 87-79, regarding the Transportation and Disposal of Sludge and repealing Resolution No. 88-311 regarding fees for sludge transportation and disposal permits. This proposed ordinance will be in addition to Ordinance No. 89-20, the existing Collier County Water Pollution Control Ordinance. Collier County has a Phase II National Pollution Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit. Element Three of Collier County’s NPDES MS4 permit requires a “regulatory mechanism for the detection a nd elimination of non- stormwater discharges.” The January 2015 audit report of Collier County’s NPDES MS4 program by the Florida Department of Environmental Protection (FDEP) indicated that the existing ordinances used to regulate discharges are insufficient and requires Collier County to “review Proposed Pollution Control & Prevention Ordinance 02/26/2019 existing ordinance and/or develop a new ordinance which defines and prohibits illicit discharge to the MS4.” Ordinance No. 87-79, Transportation and Disposal of Sludge was adopted to regulate the transportation and disposal of sludge to ensure that such activities do not endanger public health or the quality of the waters of the County. In the 31 years since Ordinance No. 87-79 was adopted; definitions, standards, and federal and state regulations have changed making the current ordinance outdated and redundant in some aspects. The proposed new ordinance will update, clarify, and add environmental protections which reflect current regulations, practices, and the goals of the Pollution Control Program; and protect Collier County’s natural resources. Ordinance No. 89-20, the Collier County Water Pollution Control Ordinance was adopted to establish and fund a County water pollution control program which focused on sewage as the primary pollutant. This Ordinance was adopted with a county-wide referendum and allows the County to levy county-wide up to one-tenth of a mil for a water pollution control program. Because of the funding authority, this Ordinance is not proposed for repeal and will be in addition to the proposed ordinance. In the 29 years since Ordinance 89-20 was adopted; definitions, standards, and federal and state regulations have changed making the existing ordinance outdated and ineffective. The proposed new ordinance will reflect current regulations and practices, the goals of the Pollution Control Program, and protect Collier County’s natural resources. The proposed ordinance includes: Additional and updated definitions; Updated laws and regulations; Specific language prohibiting illicit discharges; Requirements for reporting and remediating discharges of pollutants; Emphasis on pollution prevention through public outreach/education and best management practices; and Provisions for enforcement. Resolution 88-311 addressing fees associated with sludge transportation licenses and disposal permits will be repealed. GROWTH MANAGEMENT PLAN (GMP) CONSISTENCY: This proposed ordinance is consistent with the goals and objectives of Collier County’s Growth Management Plan Conservation and Coastal Management Element and the Natural Groundwater Aquifer Recharge Sub-Element. Additionally, the County’s Watershed Management Plan and the Floodplain Management Plan support the proposed ordinance. NEIGHBORHOOD INFORMATION MEETING (NIM): Although a NIM is not required for adoption of this ordinance, considerable effort was put into soliciting input from the various stakeholders. Those stakeholders include the regulated community such as business owners that handle hazardous materials in wellfield protection zones, Proposed Pollution Control & Prevention Ordinance 02/26/2019 biosolids haulers, wastewater treatment plant operators and the members of the Property Owner Association Presidents, area utilities, Development Services Advisory Committee, as well as the Florida Department of Health, Florida Department of Environmental Protection, Conservancy of Southwest Florida, and Big Cypress Basin. DEVELOPMENT SERVICES ADVISORY COMMITTEE RECOMMENDAITON: The proposed ordinance was unanimously approved by the Development Services Advisory Committee (DSAC) on May 2, 2018 with a recommendation that the following language be added to Article VI, Section 2: “Pre-existing residential permitted properties shall not be required to implement structural BMPs to existing drainage structures.” Keeping in mind that this section only applies if permit requirements are not being met or reasonable best management practices (BMPs) are not being implemented, it is staff’s recommendation to leave the language as written. If DSAC’s proposed language was included in the ordinance, all existing residential developments would be exempt from any potential requirements to implement any structural pollution prevention BMPs. This will prevent Collier County from being able to address point source pollution flowing into our stormwater system while still being required to meet state mandated water quality standards associated with a Basin Management Action Plan. ENVIRONMENTAL ADVISORY COUNCIL (EAC) REVIEW: This Ordinance is presented to the EAC in accordance with Sections 2-1193(a), (c) and (j), which read as follows: The powers and duties of the EAC are as follows: (a) Identify, study, evaluate, and provide technical recommendations to the BCC on programs necessary for the conservation, management, and protection of air, land, and water resources and environmental quality in the County; (c) Advise the BCC in developing and revising, as appropriate, local rules, ordinances, regulations, programs, and other initiatives addressing the use, conservation, and preservation of the County's natural resources; (j) Assist in the implementation of any new programs, ordinances, and/or policies adopted by the BCC which deal with the conservation, management, and protection of air, land, water, and natural resources and environmental quality in the County; COUNTY ATTORNEY OFFICE REVIEW: The County Attorney’s Office reviewed this staff report on August 15, 2018. RECOMMENDATION: Proposed Pollution Control & Prevention Ordinance 02/26/2019 Recommendation that the Planning Commission sitting as the EAC provide a recommendation of approval to the Board of County Commissioner of the proposed Pollution Control and Prevention Ordinance, consolidating, repealing and replacing Ordinance No. 87-79, regarding the Transportation and Disposal of Sludge and repealing Resolution No. 88-311 regarding fees for sludge transportation and disposal permits. PLANNING COMMISSION READ AHEAD-TOTAL MAXIMUM DAILY LOAD & BASIN MANAGEMENT ACTION PLAN PROCESS The Florida Department of Environmental Protection (FDEP) developed a five-year cycle that divides Florida into five groups of surface water basins (Figure 1) in which different activities take place each year; the cycle is reiterated continuously to evaluate the success of clean-up efforts, refine water quality protection strategies, and account for the changes brought about by Florida’s rapid growth and development. Collier County is located in the Everglades West Coast Basin (EWC) in Group 1. Each group undergoes a cycle of five phases on a rotating schedule (Table 1). Collier County entered this rotating cycle in 2000 is currently in Phase 2 of Cycle 4. Phase 2 of Cycle 4 was delayed BY FDEP due to the development and implementation of new dissolved oxygen and numeric nutrient criteria in the Statewide. Table 1. Schedule for TMDL Development in the Everglades West Coast Basin Cycle One YEAR 2000 2001 2001 2002 2002 2003 2003 2004 2004 2005 Group 1 *PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 Cycle Two YEAR 2005 2006 2006 2007 2007 2008 2008 2009 2009 2010 Group 1 PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 Cycle Three YEAR 2010 2011 2011 2012 2012 2013 2013 2014 2014 2015 Group 1 PHASE 1 PHASE 2 PHASE 3 PHASE 4 PHASE 5 Cycle Four YEAR 2015 2016 2016 2017 2017 2018 2018 2019 2019 2020 Group 1 PHASE 1 PHASE 2 PHASE 2 cont’d PHASE 2 cont’d PHASE 3 Cycle Five—etc. YEAR 2020 2021 2021 2022 2022 2023 2023 2024 2024 2025 Group 1 PHASE 4 PHASE 5 PHASE 1 PHASE 2 PHASE 3 Phase 1: Preliminary Evaluation Close coordination with local stakeholders to conduct a preliminary basin water quality assessment; inventory existing and proposed management activities; identify management objectives and issues of concern; develop a strategic monitoring plan; and produce a preliminary Status Report that includes a Planning List of potentially impaired waters. Phase 2: Strategic Monitoring and Assessment Figure 1. TMDL Basins Cooperative efforts between FDEP and local stakeholders to collect additional data; get data into STORET or WIN; complete water quality assessment; produce a final Assessment Report that includes a Verified List of impaired waters for Secretarial adoption; and provide an opportunity for stakeholders to document reasonable assurance (for FDEP review) that existing management plans and projects are adequate to restore water quality without the establishment of a Total Maximum Daily Load (TMDL). Phase 3: Development and Adoption of TMDLs Coordination with stakeholders to discuss TMDL model framework, including model requirements, parameters to be modeled, model endpoints, design run scenarios and preliminary allocations; communication of science used in the process; and public workshops for rule adoption of TMDLs. Phase 4: Development of Basin Management Action Plan (BMAP) Broad stakeholder participation in developing a Basin Management Action Plan (including detailed allocations and implementation strategies), incorporating it into existing management plans where feasible; public meetings during the planning process. Phase 5: Implementation of Basin Management Action Plan Emphasis on implementing the BMAP, other voluntary stakeholder actions, and local watershed management structures; FDEP will continue to provide technical assistance, fulfill oversight responsibilities, and administer National Pollutant Discharge Elimination System (NPDES) point and nonpoint source permits. Impaired Waters Rules Assessment Phases 1 and 2 involve the collection and assessment of surface water quality data. Collier County Pollution Control monitors 77 surface water sites for Collier County and uploads the data to FDEP’s database. Using this database, FDEP performs an assessment to determine if the waterbodies are meeting State water quality standards provided in Florida Administrative Code 62-302. If the waters are not meeting standards, FDEP verifies them as “impaired” and prioritizes them for TMDL development. On November 14, 2018, FDEP released their draft list of verified impaired waters for Phase 2 of Cycle 4 which includes all of Collier County. Total Maximum Daily Load (TMDL) Phase 3 begins the development of a TMDL. A TMDL is a scientific determination of the maximum amount of a given pollutant that a surface water can absorb and still meet the water quality standards that protect human health and aquatic life. Water bodies that do not meet water quality standards are identified as "impaired" for the particular pollutants of concern - nutrients, bacteria, mercury, etc. - and TMDLs must be developed, adopted and implemented to reduce those pollutants and clean up the water body. Once TMDLs are adopted under Secretarial Order, they are then considered the new water quality criteria for that waterbody and are incorporated into the Florida Administrative Code 62-304. Discharges into a waterbody with an adopted TMDL must meet the water quality criteria set forth in the TMDL. Collier County currently has 3 TMDLs. Basin Management Action Plans A BMAP is the "blueprint" for restoring impaired waters by reducing pollutant loadings to meet the allowable criteria established in a TMDL. It represents a comprehensive set of strategies--permit limits on wastewater facilities, urban and agricultural best management practices, conservation programs, financial assistance and revenue generating activities, etc.--designed to implement the pollutant reductions established by the TMDL. These broad-based plans are developed by FDEP with input from local stakeholders--they rely on local input and local commitment--and they are adopted by Secretarial Order to be enforceable. As part of the BMAP, language requiring load reductions is typically included in any National Pollutant Discharge Elimination System (NPDES) permits that discharge into the waterbody with the TMDL. Currently there are no BMAPs for the 3 waterbodies with adopted TMDLs in Collier County. Lee County has 3 adopted BMAPs that were developed to address almost identical TMDLs as those we have in Collier County. Language has been written into their NPDES permit and they are required to meet the TMDL limits in their county’s stormwater system. Lee County has spent approximately $27.1 million in 5 years to implement projects to improve water quality to meet their TMDLs and comply with their BMAPs. FDEP has no plans to implement a BMAP for existing TMDLs in Collier County for Assessment Cycle 4. Staff believes this is due to proactive pollution prevention activities and coordination with FDEP. That doesn’t mean that there won’t be BMAPs in the future for future TMDLs, especially if water quality improvements are not made. EXAMPLES OF ACTIONS TAKEN TO ADDRESS TMDLS AND WATER QUALITY IMPAIRMENTS TO PREVENT BMAPS IN COLLIER COUNTY. Lake Trafford is impaired for nutrients, unionized ammonia and dissolved oxygen. The TMDL is established for total nitrogen (TN) and total phosphorus (TP). FDEP is making the assumption that by reducing TN and TP loading that ammonia and dissolved oxygen will respond favorably.  Actions taken to address TMDL o Internal nutrient cycling was the biggest source of nutrients in the lake. Dredging of the lake to remove nutrient heavy sediments completed in 2010. o Lake Trafford Management Team was formed to bring stakeholders and managers together to develop a comprehensive plan to provide guidance on the long-term management of the lake to reach water quality goals. o FDEP installed and monitored wells within the Lake Trafford watershed to see if groundwater and what land uses are contributing to the nutrient load. Pollution Control assisted with monitoring of existing wells and locating locations for new wells. Samples were collected from 2014-2016 until FDEP staff were reprioritized to other projects. o As part of an inclusive Everglades West Coast BMAP to address dissolved oxygen impairments in the entire EWC, FDEP wanted to gather more data regionally on land uses and their influence on groundwater and impairment of surface waters. This included two watersheds (Lake Trafford & Gordon River Extension) in Collier County that are impaired due to nutrients. As part of this BMAP, FDEP installed and monitored wells in these watersheds for two years (2014-2016) in various land uses that included septic tanks, golf courses, residential, and areas using reuse irrigation. FDEP has not concluded this monitoring effort, but were reprioritized elsewhere in the State. o Stormwater Inlet Marking o Pollution Control continues to assist FDEP with sample collection of extra bottles for FDEP’s nutrient source tracking in this WBID. Gordon River Extension is impaired for dissolved oxygen. FDEP tied the dissolved oxygen impairment to elevated nutrients. Therefore, the TMDL requires total nitrogen reductions.  Actions taken to address TMDL o Freedom Park, a wetland treatment system, was designed and built to treat stormwater within this watershed and remove nutrients from the surface water. o Partner project with City of Naples for conversion of septic tanks to sewer conversion and stormwater improvements within this WBID. o Collier County Pollution Control has assisted FDEP with further monitoring  FDEP installed and monitored wells within the Gordon River Extension Basin and outside the basin to see if groundwater and what land uses are contributing to the nutrient load. Pollution Control assisted with monitoring of existing wells and locating sites for new wells that were representative of existing land uses. Samples were collected by FDEP from 2014-2016 until FDEP staff were reprioritized to other projects.  Pollution Control was involved in downloading the data from the flow meter every 2-3 weeks and sending the data to FDEP. The flow meter was removed by FDEP in 2012 due to equipment failure.  Pollution Control continues to assist FDEP with sample collection of extra bottles for FDEP’s nutrient and bacteria source tracking in this WBID. Cocohatchee River is impaired for fecal coliform. The TMDL requires reduction of bacteria in stormwater runoff to the estuary.  Actions taken to address TMDL o 2008--Pollution Control did an intensive study to locate any point sources for fecal coliform. None were found. Collier County Utilities tightness tested all their systems and no leaks were found. FDOH inspected all the septic tanks in the area and found no issues. At that point, FDEP assumed sampling responsibilities and sampled for one year. They were unable to locate a source. o 2015—FDEP and Pollution Control did a more formal “walk the WBID” using biomarkers to target human sources of bacteria. Pollution Control assisted with sample locations, sampling and analysis. No specific sources were found. o Pollution Control added new water quality stations to their network to further delineate sources. o In Naples Park and Vanderbilt area, the County is currently replacing aging sewage pipes and retrofitting existing stormwater infrastructure to include water quality treatment systems. o Pollution Control did door to door outreach to 1,159 houses in the watershed in 2017 to encourage residents to reduce personal pollution in their own backyards. o Pollution Control proactively implemented analysis of more representative bacteria species before new regulations were implemented. Copper Impairments Pollution Control did further monitoring to determine the source of copper was from the use of copper - based herbicides being directly applied to the stormwater system. Pollution Control then targeted education and outreach to pond owners, including County owned/maintained ponds, on adaptive pond management; discontinued use of copper-based herbicides and nutrient runoff reductions. Iron Impairments Pollution Control did further monitoring to determine the source of iron and found source to be naturally occurring from groundwater flows into the canals. Pollution Control prepared a White Paper with the study results and sent it to FDEP. Pollution Control is working with FDEP to have the impairments classified as naturally occurring. Illicit Discharge training Road and bridge personnel, engineering inspectors, building Inspectors, and code enforcement inspectors have been trained to recognize and report pollution discharges to Pollution Control. Erosion Control LCD amendment now requires erosion control measures on all residential home sites in addition to commercial construction. Many pollutants enter the waterways attached to soil particles. Keeping soils out of the water also keeps pollutants out of the water. Landscape Beautification Program at a Crossroads February 26, 2019 L-1 2016 BCC approves the Collier County Landscape Beautification Master Plan. The Master Plan restarts landscape program. Dedicated funding for five years. Addition of 50 miles of new landscaped medians. L-2 L-3 Landscape Beautification Master Plan Ranking Installation of 18 New Miles. Upon completion – 122 Maintenance Miles. Restoring damage from Hurricane Irma. Comprehensive maintenance services. L-4 Completed Projects L-5 L-6 Completed 2017 L-7 Completed 2018 Completed 2018L-8 Completed 2019L-9 8 Miles of median landscaping have been completed. 2019 : 122 Miles of Median Landscaping L-10 L-11 L-12 L-13 L-14 L-15 10 Miles of Median Landscaping is under construction. 2019 : 122 Miles of Median Landscaping 112 miles of landscaping currently under maintenance contracts. 10 miles of landscape currently under construction. •Completion dates 2019. 2017 average maintenance cost per mile was $44,430. 2018/2019 increased to $63,285 cost per mile. •41% increase. •Contracts prices will increase in year two by 2.9%. Landscape Maintenance Budget •$4.2 M is the current budget for maintenance contractual services (Cost center 163801). Landscape Maintenance Cost •$7.1 M is current costs for landscape maintenance contracts. •$259 K for new landscape maintenance contracts in CY 2019. Landscape Maintenance Deficit $3.1 M Capital Budget •$3.5M is the current budget for capital projects (see attached list of deferred landscape projects on next slide). L-16 Account Current Budget Amended Budget Operating*$4,223,622 $7,310,731 Capital**$3,524,115 $437,006 L-17 * Contractual Services Budget ** Available Budget Design Projects: Oil Well Road (Immokalee to Everglades) Radio Road (2 medians) Oil Well Road (Everglades to Arthrex) Oil Well Road (Arthrex to Ave Maria) Collier Boulevard (17th to 5th) US 41/ 951 Improvements FDOT* US 41 East (951-Greenway) FDOT* Collier Boulevard (US 41 to Fiddlers) Davis Boulevard (Santa Barbara to Cedar Hammock) Davis Boulevard (Cedar Hammock to 951) *FDOT projects will continue Construction Projects: Oil Well Road (Immokalee to Everglades) Radio Road (2 medians remaining) Collier Boulevard (Marino to Business Circle) Santa Barbara Boulevard (I-75 to Copper Leaf) L-18 Suspend Capital funded projects. Maintain $7M maintenance contracts. Fund purchase orders deficit with $3.1M Capital budget. Use remaining funds for major irrigation repairs. Perform incidental services such as mulch, irrigation repair, fertilizer, pruning, etc. Future: investigate hiring in-house crews for partial maintenance services. L-19 Pros for Contracted Maintenance Minimal hiring requirements Ability to pay more Ability to generate workers quicker Trained personnel Cons for Contracted Maintenance Unknown and Higher costs (until contracts awarded) Limited competition (resulting in higher costs and non-performance issues). Subject to failure (inexperienced landscape maintenance firms). Reduced control over services Accounting issues (invoicing) Pros for In-house Maintenance Controlled costs Accountability Decreased accounting issues Potentially lower overall costs (high contracted rates that increase yearly). Better performance Cons for In-house Maintenance Equipment expenses/start-up costs Challenges in hiring personnel Employability –Meeting County standards Training Personnel safety Daily operating costs Timing L-20 Landscape Capital Projects: Complete existing construction projects (cost estimate: $200k) Suspend new capital projects except for grant-funded projects and current sculpture project (cost estimate: $315k FDOT, $150k sculpture) Conduct public outreach to educate stakeholders on the status of the Landscape Beautification Master Plan Develop options for Board consideration during the budget workshop Landscape Maintenance: Transfer capital funds into the maintenance budget Maintain current maintenance contracts Consult with current maintenance contractors for further cost reductions to fund landscape maintenance services such as: •Fertilization, pesticide, and herbicide treatments •Plant replacements (limited) •Tree pruning •Irrigation repairs Seek Grant funding for existing State and County roadways L-21