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Agenda 10/26/2021 Item #16A 8 (Budget Amendment from Fund 327 to Project 60142)16.A.8 10/26/2021 EXECUTIVE SUMMARY Recommendation to authorize a budget amendment in the amount of $1,333,776 to transfer funds within the Stormwater Bond Fund (327) from Reserves to the West Goodlette-Frank Joint Stormwater-Sewer Project - Phase 2 (Project 60142). OBJECTIVE: To provide funding for the County's portion of design costs for the West Goodlette- Frank Joint Stormwater-Sewer Project - Phase 2 in conformance with the Interlocal Agreement with the City of Naples. CONSIDERATIONS: On February 22, 2020 (Agenda Item 16.A.2) the Board of County Commissioners (Board) approved an Interlocal Agreement titled "West Goodlette-Frank Road Area Joint Stormwater and Sanitary Sewer Improvements" with the City of Naples for the design and construction of sanitary sewer and stormwater capital improvements for a project commonly called West Goodlette-Frank - Phase 2. In accordance with the Interlocal Agreement, the City is responsible for procurement of both the design and construction services, with the County providing reimbursement funding for its portions of the design and construction costs. On March 17, 2021 the City of Naples approved a contract with the design consultant firm of Q. Grady Minor and Associates, P.A., a Florida corporation (Grady Minor) for the design of the West Goodlette- Frank - Phase 2 project. The total value of the contract was $2,747,120.00 with the County's portion being $1,303,776.10. On April 15, 2021 the City of Naples issued their Notice to Proceed letter to Grady Minor to begin the design process. As the design progresses through the various levels of completion, the City of Naples will be invoicing Collier County for reimbursement of the County's portion of the design costs, as identified in the City's contract with Grady Minor. This budget amendment is to provide funding for the pending Purchase Order with the City of Naples as well as providing funding for additional costs anticipated for property and easement research/acquisition by Growth Management Department staff as the design progresses to completion. FISCAL IMPACT: A budget amendment in the amount of $1,333,776 is required to transfer funds within the Stormwater Bond Fund (327) from Reserves to the West Goodlette-Frank - Phase 2 Project 60142. There is no incremental maintenance cost associated with this design action. Incremental maintenance costs will be addressed at the time of award of the planned construction contract. GROWTH MANAGEMENT IMPACT: This item has no impact on the Growth Management Plan. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, raises no legal issues and requires majority vote for approval. -JAK RECOMMENDATION: To authorize a budget amendment in the amount of $1,333,776.00 to transfer funds within the Stormwater Bond Fund (327) from Reserves to the West Goodlette-Frank - Phase 2 (Project 60142). Packet Pg. 726 10/26/2021 16.A.8 Prepared By: Robert Wiley, Principal Project Manager, Stormwater Management Section, Capital Project Planning, Impact Fees and Program Management Division ATTACHMENT(S) 1. Recorded Interlocal Agreement w City of Naples (PDF) Packet Pg. 727 16.A.8 10/26/2021 COLLIER COUNTY Board of County Commissioners Item Number: 16.A.8 Doe ID: 20154 Item Summary: Recommendation to authorize a budget amendment in the amount of $1,333,776 to transfer funds within the Stormwater Bond Fund (327) from Reserves to the West Goodlette-Frank Joint Stormwater- Sewer Project — Phase 2 (Project 60142). Meeting Date: 10/26/2021 Prepared by: Title: Project Manager, Principal — Capital Project Planning, Impact Fees, and Program Management Name: Robert Wiley 09/29/2021 10:43 AM Submitted by: Title: Director — Capital Project Planning, Impact Fees, and Program Management Name: Matthew McLean 09/29/2021 10:43 AM Approved By: Review: Growth Management Department Lissett DeLaRosa Growth Management Department Procurement Services Ana Reynoso Level 1 Purchasing Gatekeeper Growth Management Department Lisa Taylor Additional Reviewer Procurement Services Sandra Herrera Additional Reviewer Capital Project Planning, Impact Fees, and Program Management Ian Barnwell Capital Project Planning, Impact Fees, and Program Management Matthew McLean Growth Management Department Robert Wiley Growth Management Growth Management Department Trinity Scott Transportation Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Office of Management and Budget Susan Usher Additional Reviewer County Manager's Office Amy Patterson Level 4 County Manager Review Board of County Commissioners Geoffrey Willig Meeting Pending Completed 09/29/2021 11:28 AM Completed 09/29/2021 11:58 AM Completed 09/29/2021 3:18 PM Completed 09/29/2021 3:58 PM Additional Reviewer Completed Additional Reviewer Completed Skipped 09/21/2021 11:49 AM Completed 09/30/2021 11:32 AM Completed 09/30/2021 12:31 PM Completed 10/01/2021 10:30 AM Completed 10/03/2021 3:18 PM Completed 10/18/2021 9:34 AM 10/26/2021 9:00 AM Packet Pg. 728 16.A.8.a INTERLOCAL AGREEMENT PROJECT: West Goodlette-Frank Road Area Joint Stormwater and Sanitary Sewer Improvements THIS INTERLOCAL AGREEMENT is made and entered into this day of t 20�y and between the City of Naples, Florida, a Florida municipal corporation (the "CITY") and Co�County a political subdivision of the State of Florida, (the "COUNTY") and (collectively, the "Parties"). WITNESSETH WHEREAS, the CITY has identified a need to undertake the design and construction of a sanitary sewer collection system to eliminate failing septic tanks on various streets located south of Pine Ridge Road between Goodlette-Frank Road and US41, and WHEREAS, the CITY in 2006 developed a "Master Sewer Plan for the City's Unsewered Service Areas", hereinafter referred to as "MSP", and WHEREAS, the COUNTY has identified the need to make roadside improvements to the stormwater system along various streets within the boundaries of the CITY's MSP, and WHEREAS, the CITY owns certain potable water and wastewater utility systems (Utility) within, adjacent to, and in the vicinity of the road easements and/or rights -of -way of the streets identified as needing stormwater improvements, and WHEREAS, the CITY and COUNTY are both aware of septic system problems experienced by local residents during periods of intense or extended rainfall that resulted in temporary street and yard flooding within the MSP, and WHEREAS, the CITY and COUNTY have determined and mutually agree that it is economically advantageous and in the best interest of the public to enter into this Agreement to undertake a joint project (PROJECT) to construct roadside stormwater improvements and a sanitary sewer collection system, and WHEREAS, the CITY and COUNTY are both in agreement that the CITY will manage the Project's design, permitting and construction phases, subject to the COUNTY's participation as set forth herein, and WHEREAS, the CITY and COUNTY are both in agreement that the CITY will be responsible for funding the utility cost portions of the Project and the COUNTY will be responsible for funding the stormwater improvement cost portions of the Project. NOW, THEREFORE, in consideration of the above premises, and the mutual covenants, terms, and provisions contained herein, the CITY and COUNTY agree as follows: "Remainder of this page left blank intentionally" INSTR 5838538 OR 5735 PG 3100 RECORDED 3/5/2020 2:21 PM PAGES 12 CLERK OF THE CIRCUIT COURT AND COMPTROLLER COLLIER COUNTY FLORIDA REC $103.50 Packet Pg. 729 16.A.8.a Article 1: SECTION I: CITY's RESPONSIBILITIES 1.0 The CITY will serve as project manager for the design, permitting and construction phases of the PROJECT. The CITY's assigned staff project manager shall be under the supervision of the CITY's contract manager as identified in Section 3.4 below. 1.1 The CITY shall maintain open communication with the COUNTY's assigned project manager and provide periodic progress reports and documentation about the PROJECT as requested by the COUNTY. 1.2 The CITY shall procure comprehensive Stormwater and roadway -related design, construction and construction administrative services for the COUNTY's Stormwater and roadway portions of the PROJECT, which work shall be jointly and concurrently performed with the CITY's design, construction and construction administrative services for its Utility portion of the PROJECT. 1.3 The following specific services, duties and responsibilities will be the obligation of the CITY regarding the design coordination, construction, and contract administration of the Stormwater and roadway work on behalf of the COUNTY. A. The CITY's and COUNTY's assigned project managers shall maintain open communication with each other and provide periodic progress reports and documentation about the PROJECT as requested by the CITY and COUNTY. Throughout the design, permitting and construction phases of the PROJECT, both project managers shall mutually schedule periodic progress meetings as deemed necessary. B. The CITY shall prepare and release a Request for Proposal (RFP) for design engineering services, in accordance with the CITY purchasing policies, that complies with the Consultant's Competitive Negotiation Act (CCNA) as required by Section 287.055, Florida Statutes. Preparation of the scope of work for the RFP will be a j oint effort between CITY and COUNTY wherein the main focus of the CITY's contribution will address the Utility design issues, and the main focus of the COUNTY's contribution will address the Stormwater and roadway design issues. The RFP Selection Committee (described in Section 3.5 below) will rank the Consultant's proposals and hold interviews with the top three (3) ranked firms. Upon successful contract scope and cost negotiation with an engineering consulting firm, the Naples City Council will vote whether to enter into design contract for the PROJECT. Before such vote, the COUNTY may determine whether it wishes to proceed further with the PROJECT. If not, the COUNTY shall notify the CITY in which case the COUNTY will be responsible only for its portion of "shared expenses" to that point. Shared expenses are as defined in section 3.8, below. C. During the design portion of the PROJECT, the CITY is responsible for providing requested information to the consultant and timely reviews of draft plan sets. The CITY's review will focus on the design of the Utility portions of the PROJECT, with only cursory review (primarily dealing with conflicts) provided for the stormwater and roadway portions of the PROJECT. The CITY will rely upon the COUNTY to provide the CITY with timely detailed reviews and comments for the stormwater and roadway portions of the PROJECT. D. The CITY will be responsible for preparing an ITB (with input from the COUNTY), conducting the public bid and award of the construction contract, culminating with the Packet Pg. 730 16.A.8.a COUNTY and CITY entering into a three -party agreement with the selected contractor. The contractor selected shall be based upon the overall lowest (for both stormwater and utility work in the aggregate), responsive and responsible bid received. Before such vote to approve the award of the three -party agreement to the contractor, the COUNTY may determine whether it wishes to proceed with the PROJECT. If not, the COUNTY shall notify the CITY, in which case the COUNTY will be responsible for its portion of shared expenses to that point. E. Funding for the construction of the Utility and shared expense portions of the designed and permitted PROJECT will be provided by the CITY. The CITY is responsible for paying the contractor selected for the PROJECT for that portion of the work pertaining to its Utility improvements. F. The CITY shall obtain all necessary land rights (road rights -of -way and utility easements) needed to successfully construct the utility portions of the PROJECT. These land rights shall be obtained prior to issuance of a Notice to Proceed letter to the construction contractor(s). G. The CITY shall conduct a formal preconstruction conference prior to commencing with the PROJECT. The CITY will provide the notice of the preconstruction conference at least five (5) working days prior to the conference. The COUNTY's assigned project manager will attend this conference, and other COUNTY representatives may attend at the COUNTY's discretion. A copy of the minutes of said conference shall be submitted to the COUNTY's project manager. H. The stormwater and road work shall be coordinated with the COUNTY's project manager with respect to keeping the COUNTY advised of technical, cost, and schedule impacts upon the stormwater and roadway improvements. I. The CITY shall confer with the COUNTY's project manager as deemed necessary by the COUNTY in order to coordinate work stages between the Utility, stormwater, and roadway improvements from a public interest view point. J. The CITY shall administer design changes, clarifications, supplements and other contract amendments that may be necessary during the design and construction of the stormwater and roadway improvements. These contract directives to the consultant and contractor may be in the form of plans, memoranda, reports, change orders, and supplemental agreements and shall be subject to written approval by the COUNTY's project manager and/or contract authority, which approval shall not be unreasonably withheld. The above notwithstanding, upon notification to COUNTY, the COUNTY herein authorizes the CITY to prepare, execute, and implement minor change orders (defined as not exceeding 5% ofhe contract amount) for "field directives" necessitated by actual field conditions related to the shared expenses related to roadway improvements so as not to delay the contractor's performance and so as to meet the intent of the approved design for the stormwater and roadway improvements. Said change orders shall be issued either using existing contract unit prices or negotiated unit prices for work adjustments within the physical limit of the stormwater and roadway work as shown in the construction plans. In no event shall the value of the total change orders exceed the stormwater and roadway allowance to be included in the BID approved by both the CITY and COUNTY. Additional or extra work which exceeds the above change order authority by CITY shall be submitted for prior review, approval and execution by the COUNTY. ,A,,.1 Packet Pg. 731 16.A.8.a K. CITY shall submit a final Certificate of Completion letter to the COUNTY along with an appropriate number of plans detailing the stormwater and roadway improvements as constructed by the Parties' contractor ("As -built record drawings"). A one-year warranty for work completed by the contractor shall be included in the Parties' construction agreement. The final Certification of Completion shall be submitted by the engineer of record to the FDEP and other local and state agencies that govern the Utility improvements. L. All contracts entered into by the Parties' for the design and/or construction of the PROJECT shall require the party contracting with the Parties' to hold harmless, indemnify and defend the CITY and COUNTY and its consultants, agents, officers and employees from any and all claims, losses, penalties, fees, or any expense, damage, or liability incurred by any of them, whether for personal injury, property damage, direct or consequential damages, or economic loss arising directly or indirectly on account of or in connection with the work done by the Parties' consultant or contractor pertaining to the design and construction of the Utility, stormwater and/or roadway or by any person, firm or corporation to whom any portion of the Utility, stormwater or roadway work is subcontracted by the Parties' consultant or contractor. M. Monthly utility field measurements and quantity calculations shall be made by the engineer of record of utility work accomplished for processing of monthly progress payments to the Parties' contractor. The CITY's project manager shall verify and approve these measurements and calculations in writing prior to the CITY's issuance of monthly progress payments to the contractor. N. The CITY shall open a Purchase Order to the selected construction contractor so that it can make payment for the utility and shared expense work performed and provided under the terms of the Parties' construction agreement with the contractor, including the CITY's portion of shared expenses. Article 2: SECTION II: COUNTY's RESPONSIBILITIES 2.0 The COUNTY and CITY staff shall cooperate and agree on the complete contents of the final ITB prior to issuance and will thereafter enter into a three -party agreement with the contractor resulting from that ITB, as provided herein. The COUNTY shall provide and perform project support duties as defined below to ensure that the design, construction and contract administration services meet the mutual satisfaction of the COUNTY and CITY, and other governing agencies that have jurisdictional control over the stormwater and roadway improvements. 2.1 The specific project support duties and responsibilities enumerated below shall be the obligation of the COUNTY. A. The COUNTY's Capital Project, Impact Fees and Program Management Division Director will serve as the COUNTY's assigned contract authority and point of contact for the CITY's contract manager as identified in Section 3.4 below. The CITY's Utility Department Director shall designate in writing an assigned CITY project manager to work with the COUNTY's assigned project manager in typical day to day coordination of PROJECT design, permitting and construction. The CITY's Utility Department Director shall assign in writing a Utility project coordinator (if that person is someone different from the assigned project manager) for the purpose of coordinating, resolving, and communicating construction issues at the field level with COUNTY's project manager. The CITY's project manager and/or project coordinator 4 Packet Pg. 732 16.A.8.a shall attend periodic construction progress meetings with the COUNTY and their contractor(s), subcontractors and utility companies with direct or indirect interest in the provisions of the Interlocal Agreement. B. The Parties' assigned project managers shall maintain open communication with each other and provide periodic progress reports and documentation about the PROJECT to one another upon request. Throughout the design, permitting and construction phases of the PROJECT, both project managers shall mutually schedule periodic progress meetings as deemed necessary. The Parties shall provide each other written notice of all regularly scheduled progress meetings at least five (5) working days prior to the meeting. C. The COUNTY shall provide CITY with the specific stormwater and roadway -related detailed information needed for inclusion in preparation of the scope of services for the Request for Proposals (RFP) for the PROJECT design phase consultant selection process as identified in Section 3.5 below. D. The COUNTY shall obtain all necessary land rights (rights -of -way, drainage easements, temporary construction easements, etc.) required for the construction, operation and maintenance of the stormwater facilities portion of the PROJECT. The land rights shall be obtained, recorded, and made available to the CITY prior to the CITY's issuance of a jointly signed Notice to Proceed letter to the construction contractor(s). E. Funding for the design and permitting of the stormwater and shared expense portions of the PROJECT shall be provided by the COUNTY to the CITY. Reimbursement of COUNTY - incurred costs for the design and permitting of stormwater and shared expense portions of the PROJECT will be made by the COUNTY to the CITY within thirty (30) days of the Notice to Proceed letter to the construction contractor. If for some reason the PROJECT is terminated and does not proceed through completion of design, or permitting, or does not enter into construction, the COUNTY will provide the reimbursement to the CITY within ninety (90) days of the date of termination. F. At the time of construction contract bid preparation, those stormwater and shared expense items identified for which the COUNTY is financially responsible shall be subject to the COUNTY's review and approval by the COUNTY's assigned project manager. The CITY will include the stormwater and shared expense work in the PROJECT bid to receive the bid price for the COUNTY's construction stormwater and shared expense work. Prior to the CITY's issuance of the jointly signed Notice to Proceed letter to the construction contractor, the COUNTY shall provide a Purchase Order to the successful contractor for the COUNTY's portion of the construction of the stormwater and shared expense improvements. Funding for additional approved cost increases for stormwater and shared expense construction work (e.g. quantity changes, change orders, etc.) will be provided by the COUNTY. G. The COUNTY shall review the design documents, approve the stormwater and roadway design, inspect the work as necessary, and review and approve the "As -built record drawings," which will represent and depict the stormwater and roadway as constructed by the Parties' contractor. H. During the design portion of the PROJECT, the COUNTY is responsible for providing requested information to the consultant and timely reviews of draft plan sets. The COUNTY's review will focus on the design of the stormwater and roadway portions of the PROJECT, with only cursory review (primarily dealing with conflicts) provided for the utility portions of the CA O, Packet Pg. 733 16.A.8.a PROJECT. The COUNTY will provide the CITY with timely detailed reviews and comments for the stormwater and roadway portions of the PROJECT, so that the CITY can submit the COUNTY's comments to the design consultant. I. Monthly stormwater and roadway field measurements and quantity calculations shall be made by the engineer of record of stormwater and roadway work accomplished for processing of monthly progress payments to the Parties' contractor. The COUNTY's project manager shall verify and approve these measurements and calculations in writing prior to the COUNTY's issuance of monthly progress payments to the contractor. J. The COUNTY shall open a Purchase Order to the selected construction contractor so that it can make payment for the stormwater and shared expense work performed and provided under the terms of the Parties' construction agreement with the contractor. Article 3: SECTION III: MUTUAL COVENANTS 3.0 The location of the PROJECT is within Area 1, Area 2, Area 3 and Area 6 of the "City of Naples Master Sewer Plan for the City's Unsewered Service Areas" prepared by Johnson Engineering in September 2006. The specific streets under consideration for the PROJECT may include some or all of the streets as shown in the attached Exhibit A Area Map. 3.1 The Parties' shall not be responsible for construction means, methods, techniques, skills, sequences or procedures of construction relating to the PROJECT's improvements. The above responsibilities during construction shall remain with the Parties' contractor and/or the contractor's subcontractors subject to the conditions and responsibilities set forth in this Interlocal Agreement and the construction contract. 3.2 The COUNTY shall be responsible for providing review services and guidance to ensure that design and construction of the stormwater and roadway components of the PROJECT comply with or exceed the COUNTY's stormwater and roadway design and construction minimum standards. 3.3 Neither Party shall be responsible to the other should their contractor fail to comply with the Occupational Safety and Health Administration (OSHA) Safety and Health Standards (29 C.F.R. 1926) as authorized by the U.S. Department of Labor, OSHA; said responsibilities to be that of the Parties' contractor(s) and/or their contractor's subcontractor. 3.4 The CITY's Utilities Department Director, either directly with the COUNTY's Capital Project, Impact Fees and Program Management Division Director or through a duly authorized project manager assigned to the PROJECT, shall act as the CITY's contract manager under this Interlocal Agreement. 3.5 The CITY and COUNTY agree that this is a joint project that will follow the Request for Proposal (RFP) process for selecting the design consultant, and the public bidding process for selecting the construction contractor(s). As such, the City Manager shall approve the CITY's members of the RFP selection committee. The CITY will provide two (2) staff members with utility design/construction experience and one (1) staff member with stormwater and/or roadway design/construction experience to serve on an RFP selection committee and a bid review committee. The COUNTY shall provide two (2) staff members with stormwater and/or roadway design/construction experience and one (1) CAQ Packet Pg. 734 16.A.8.a staff member with utility design/construction experience to serve on an RFP selection committee and a bid review committee. 3.6 During the construction phase of the PROJECT, construction engineering inspection services will be provided by CITY staff, COUNTY staff, consultant firm, and/or any combination thereof. Periodic on -site inspections and construction reviews will be conducted by the CITY (or its designee) and the COUNTY (or its designee) to assess the contractor's compliance with the construction plans and contract documents. 3.7 Upon completion of any portion of the PROJECT, either the Utility or stormwater portions, including work authorized under change orders and supplemental agreements, the CITY and COUNTY shall conduct a joint final inspection of the work with the CITY's and COUNTY's project managers and/or inspectors and/or engineer of record prior to the Parties' issuing final payment to the contractor. 3.8 Payments to contracted firms for completed and accepted work, including design, permitting, and construction will follow the procedures identified in the Parties' relevant contract documents. The PROJECT expenses, which shall be shared equally by the Parties (the "shared expenses"), specifically include: 1. CITY: That portion of the expenses required for the funding for the design, permitting and construction of the Utility portions of the PROJECT; 2. COUNTY: That portion required of the expenses required for the funding for the design, permitting and construction of the stormwater portions of the PROJECT; and 3. Those portions identified as shared expenses (e.g. roadway, mobilization, maintenance of traffic, landscaping, etc.) on the ITB Bid Schedule to be agreed upon by the Parties or as later added to this Agreement through a written amendment by the Parties. 3.9 The CITY is responsible for the development and implementation of a public relations program for the PROJECT to address needed public support for the PROJECT. The CITY will schedule any public meetings, workshops, information distribution, etc. deemed viable and necessary to inform the affected public about the planned water and sewer facilities and the expectations they can have regarding fiscal, physical, and timing impacts related to the Utility portion of the PROJECT. The COUNTY will participate in the public meetings and provide the CITY with information related to the stormwater and roadway regarding fiscal, physical, and timing impacts related to the PROJECT. The CITY will provide the COUNTY written notice of all public relations public meetings, workshops and information distribution efforts at least five (5) working days prior to the meetings, workshops or information distribution. Article 4: SECTION IV: AGREEMENT TERMS 4.0 This Interlocal Agreement shall remain in full force and effect from the date first above written and shall terminate upon the completion of all services and responsibilities mutually performed by the CITY and by the COUNTY to the written satisfaction of each to the other. It is understood that the actual termination date herein may occur on or about the date of final approval and acceptance of all Utility, Stormwater and Roadway improvements by the Parties and subject to construction contract warranty provisions. This date is contemplated to be subsequent to the actual date of final approval and acceptance of the stormwater and roadway improvements by the COUNTY and following any outstanding payment(s) owed by the COUNTY to the CITY. Packet Pg. 735 16.A.8.a IN WITNESS WHEREOF, the parties hereto have caused this Interlocal Agreement to be executed by their appropriate officials, as of the date first above written. By: Patricia -Ur.% mbosic, City Clerk Approved as to Form and Legal Sufficiency: James Fox City Attorney ATTES'��+ ry DW1614T E. 13?,,QQt%C4fdkK sign CW Ap vo Form Leg -, i— Scott R. Teach Deputy County Attorney AS TO THE CITY OF NAPLES: CITY OF NAPLES, FLORIDA �By: ,!// Bill Barnett, Mayor AS TO THE COUNTY: COLLIER C UNTY, FLORIDA By: Burt L. Saunders Chairman Packet Pg. 736 1 16.A.8.a EX�HIB-I—T A-1 4, Existlng Bower Service U"ewered Area 1 CM OFl D ,FL.MIDA 9 Packet Pg. 737 EXHIBIT A-2 r; 141f- Lt IF) t 7 C ExWUng Sewer Semite Un-Sawated Area 2 C� OF kWL FLOAIDA 10 Packet Pg. 738 16.A.8.a EXHIBIT A-3 im.. ExWng Sewer Service �..... Un-Sewered Area 3 a:.:]•..,ro... ,irrYDI' Itk ES. FLORIDA 0 Packet Pg. 739 16.A.8.a EXHIBIT A-4 - µ 4 - _t 40: IFI r '.F-(" ExftUng Sewer Service ..,w UnSewered Area 6 " FLDMDA 12 Packet Pg. 740