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HomeMy WebLinkAboutZ-5664 Application 3r r r r r � � � � rr �r r■r r rr � 292 ORDINANCE NO. 16,949 AN ORDINANCE APPROVING A CONTRACT BETWEEN THE CITY OF LITTLE ROCK AND THE CITY OF SHANNON HILLS FOR THE TREATMENT OF SEWAGE; REPEALING ORDINANCE NO. 15,614, APPROVED DECEMBER 20, 1988 AND ,DECLARING AN EMERGENCY. WHEREAS, the City of Little Rock, Arkansas owns a i i sewage disposal works and operates said work through the # Little Rock Sanitary Sewer Committee ("the Sewer Committee") and the Little Rock Wastewater Utility (the "Utility") and the City of Little Rock is authorized to contract with another city or political subdivision to provide sewage treatment for that entity to the extent of the capacity of I the sewage disposal works without impairing the usefulness of said works to the owners upon such terms and conditions I as may be fixed by the Sewer Committee and approved by ordinance of the respecting contracting parties; and I WHEREAS, the City of Shannon Hills owns a certain F ' sewage collection system within its municipal boundary which the City of Shannon Hills operates, and this system is not adequate or satisfactory to treat the sewage; and WHEREAS, it is in the best interest of the City of Shannon Hills ("Shannon Hills") in lieu of a prior contract dated June 6, 1989, for the extension of sewer service by i Little Rock to Shannon Hills which was never performed and i the parties mutually desire now to enter into another i contract to enter into an agreement with the City of Little Rock for the treatment of sewage upon such terms and conditions as may be fixed by the Sewer Committee and r approved by ordinance of the respective contracting parties; and WHEREAS, the City of Little Rock and Shannon Hills desire to enter into a certain contract pursuant to law for a period not to exceed 15 years and said contract is attached hereto on different terms and conditions, releasing each other from any obligations in conjunction with the prior contract dated June 6, 1989, and the prior Ordinance No. 15,614 approved December 20, 1988, shall be repealed; I and I WHEREAS, the treatment of' sewage in accordance with said contract will not impair the usefulness of the sewage disposal works owned by the City of Little Rock, and the City of Little Rock, by its City Board of Directors, desires i to enter into said contract and authorize the Mayor, City Clerk, Sewer Committee and the Manager of the Utility to I execute said contract; and j WHEREAS, the provisions of A.C.A. §14-235-212 require approval by ordinance of the respective contracting parties and the Sewer Committee has recommended approval of the contract for treatment of the sewage in accordance with the provisions of said contract; NOW, THEREFORE, BE IT ORDAINED by the Board of Directors of the City of Little Rock, Arkansas: SECTION 1. That the contract between the City of Little Rock and Shannon Hills to extend sewer service by the City of Little Rock to and for the treatment of sewage from 2 � ■r �■ �■ rr r� � � � r r■ M M M M 294 Shannon Hills provided, however, that the City of Shannon Hills shall remain totally responsible for the maintenance of its existing sewer system and any additions thereto, the use of which shall at all times be subject to the charges, collections and all provisions contained in the applicable Little Rock sewer ordinances in effect, and as amended or changed in the future during the term of this contract, or any extensions thereof by the City of Little Rock is hereby approved. A copy of the contract is attached hereto. The Mayor, the City Clerk, the Chairman of the Sewer Committee and the Manager of the Little Rock Wastewater Utility are authorized to execute the contract. SECTION 2. That all Resolutions and Ordinances and parts thereof in conflict with any parts of this Ordinance, including Ordinance No. 15,614 approved December 20, 1988 are hereby repealed. SECTION 3. That since the contract approved by this Ordinance is of great importance to the health and welfare of the citizens of the City of Little Rock, an emergency is hereby declared to exist and this ordinance shall be in full force and effect from and after its passage and approval. PASSED: August 1 , 1995. ATTEST: APP LVED: ` < a-A.'e ��2- ��M 41ULU�j ' MZ9�CA City Clerk Robbie Hancock May r Jim D i ey 3 I M M r M M Exhibit to' Ord.- '#'1-6-,9-49 CONTRACT THIS CONTRACT made on this day of 11 1995 by and between the City of Little Rock, Arkansas, the Sanitary Sewer Committee (both hereinafter collectively referred to as "Little Rock"), and the City of Shannon Hills (hereinafter referred to as "Shannon Hills"); WHEREAS, on June 6, 1989, the City of Little Rock, the Little Rock Sanitary Sewer Committee (both referred to as "Little Rock") entered into an agreement (the "1989 Agreement") with the City of Shannon Hills ("Shannon Hills") and Shannon Hills Water, Sewer and Fire Protection Improvement District No. 3 ("SID No. 311) for the extension of sewer service by Little Rock to Shannon Hills and SID No. 3 and sewer service was never extended to Shannon Hills and 295 SID No. 3; and, WHEREAS, since the execution of the 1989 Agreement, the City of Shannon Hills has acquired all rights, title and ownership of the sewer system previously owned and operated by SID No. 3 situated within the city limits of Shannon Hills; and, residents of the City of Little Rock previously receiving sewer service by SID No. 3 in the subdivision known as Rolling Pines have been connected to the sewer system of Little Rock and are currently being served by Little Rock; and, WHEREAS, Little Rock and Shannon Hills desire to enter into a new contract in substitution of all terms of the 1989 Agreement discharging and extinguishing all rights, duties 296 or obligations of either party under the 1989 Agreement, and in lieu thereof enter into the new contract subject to the provisions hereinafter set forth whereby*Shannon Hills shall abandon its--existing-sewage treatment plant and connect with the Little Rock sewer system, it being agreed that Shannon Hills shall remain totally responsible for the maintenance of its existing sewer system and any additions thereto, the use of all of which shall at all times be subject to the charges, collections, and all provisions contained in the applicable provisions set forth hereinafter, as well as Little -Rock sewer ordinances in effect and as amended, or changed in the future, during the term of this contract or any extension thereof. NOW THEREFORE, in consideration of the mutual benefits to be derived herefrom by all parties hereto, it is hereby agreed by and between the parties: 1. Connection b Shannon Hills to the Sewer system of the City of Little_ Rock. Little Rock, as Owner, hereby agrees to permit Shannon Hills, as Lessee, to connect to the sewer system of Little Rock under the terms of this Contract as soon as practical after the necessary ordinances are adopted as referred to. herein, including those approving this agreement pursuant to A.C.A §14-235-212 by the governing authorities of the City of Little Rock.and Shannon Hills; and Shannon Hills hereby agrees at its expense to make such connection in a manner and at a location as approved by the Manager of the Little Rock Wastewater 2 f' � `♦ f' f♦ f♦ i 297 Utility (the "Manager"), and in accordance with the terms I and provisions of this Contract and all applicable laws and regulations. As soon as this connection is completed and approved- by -the - Manager•,. the treatment plant currently operated by Shannon Hills shall be abandoned and no longer used in the sewer system of Shannon Hills. Shannon Hills shall pay to the Sewer Committee an initial connection fee of $8,000.00 for the present users (approximately 550 users); and, thereafter, $100.00 per home user for future tie -ons, and such other connection fees as published in the Sewer Committees connection fee schedule, effective February 6, 1987, and any amendments made thereto. 2. Wastewater Discharge Flow Measuring^ Meter. The connection to the Little Rock facilities shall include the furnishing and installation of a wastewater discharge flow meter by Shannon Hills and all expenses in connection therewith shall be borne by Shannon Hills. The meter shall be of a type and installation as approved by the Manager. The function of the meter shall be to measure and record accurately all flows discharged into the Little Rock sewer facilities by Shannon Hills. Little Rock by the Utility further agrees to maintain this meter to insure its reliability and accuracy. 3. Sewer Services +Char es and Collections. (a) Shannon Hills agrees to pay the Utility a monthly sewer service charge and said charge shall be promptly billed after the first day of each month for the services 3 1 29$ provided by this agreement. The monthly sewer service charge shall be computed from the total flow registered by the Wastewater Discharge Flow Measuring Meter, excluding 30% infiltration and-••inflow,-at.the rates set by the.Little Rock Board of Directors for sewer service inside the city limits of Little Rock, Arkansas, currently in effect and as may be adjusted in the future, it being expressly understood by the parties that rate adjustments may occur in the future during the term and the rates to be charged hereunder shall at all times be in accordance with those rates for sewer service inside the city limits of Little Rock, Arkansas, as adjusted in the future. The monthly statement for the charge shall be based upon flow meter readings conducted by the Utility; however, in the event of flow meter malfunction, the Utility may estimate the reading based upon a comparable preceding period. All charges for sewer service provided to Shannon Hills shall be billed to Shannon Hills and it shall be the responsibility of Shannon Hills to make timely payment of these charges on or before the twentieth (20th) day following the month for which the service is billed. Shannon Hills shall collect from its users all sums which may be due in connection with the service extended. The Sewer Committee for the use and benefit of the City of Little Rock shall have all rights to effect such collection of all sums owed to Little Rock pursuant to Arkansas law, including but not limited to those provisions contained in A.C.A. §14-235-223; and Shannon Hills agrees to hold 4 harmless the Sewer Committee for all losses, costs and expenses as may be sustained by Little Rock in connection with the payment of such sewer service. If Shannon Hills does not remit payment on'or before the twentieth (20th) day of the month following the month for which the service is billed, a penalty equal to ten percent (10%) of the total payment amount due shall be added to such payment, and if not paid on or before the twentieth (20th) day of the month in which the statement is submitted, Little Rock may terminate this agreement in accordance with the terms herein. 4. Applicatiori of City of Little Rock Sewer Ordinances. The provisions of all existing and future ordinances enacted by the City of Little Rock relating to the regulation of the construction, operation and maintenance of sewers shall apply to the sewer facilities owned and operated by Shannon Hills and connected to the sewer facilities owned and operated by the City of Little Rock. The provisions of these ordinances shall be binding on the parties hereto, including the rates as may be from time to time specified; and Shannon Hills covenants that it will at all times comply with said ordinances and further agrees to hold harmless the Sewer Committee from all losses, damages, expenses or liabilities of any nature incurred by the Sewer Committee as a consequence of any acts, omissions or any conduct by any authorized representative or employee of Shannon Hills, its customers or citizens arising out of 299 300 any violations of said ordinance or any Provision of this Contract or relating to the sewer service furnished as a consequence thereof. 5'. - Future - Connections • with -- the -Sewer System of Shannon Hills. Shannon Hills agrees not to extend any sewer services to any area outside the incorporated area of Shannon Hills as the boundaries exist on the date when this Contract is executed, unless the governing body of the City of Little Rock has given its prior written approval to do SO. Shannon Hills further agrees to limit any future sewer main extensions and sewer connections in any portion of Pulaski County not currently served unless Shannon Hills obtains the prior approval in writing by the Sewer Committee; and then only for so long as service is not w available from the Sewer Committee for all users now located in the City of Little Rock, situated in Pulaski County, Arkansas. A map of the City of Shannon Hills showing the current boundaries is attached hereto as Exhibit "A". 6'. Future Extensions of__5ervice. The Sewer Committee shall not be obligated for and assumes no liability for any future extension of service not specifically set forth herein, and no such extension shall be made without the prior.written approval of the governing body of the City of I , r Little -Rock and the Sewer Committee. This Contract r anticipates up to 1,000 Shannon Hills users. In any event, anyone desiring such an extension of service beyond the existing facilities hereby served shall bear the full cost 6 • • Sol thereof, including all costs of any nature whatsoever involved in effecting such extension or making available such service and any connection fees set -by the Sewer Committee;- and SID -No.- 142 and Shannon -Hills. The further extension of service shall be in accordance with the rules and regulations of the Sewer Committee and subject to its approval at the time of the extension of service. 7. Shannon Hills Com rehensive Devela vent Plan Zpninq Ordinance and Pre -Treatment Ordinance. Prior to the connection of the sewer system of Shannon Hills with the City of Little -Rock, Shannon Hills shall furnish proof of the adoption of a comprehensive development plan and zoning ordinance and a sewage pretreatment ordinance; and said plan and zoning ordinance shall have been submitted to the Director of Comprehensive Planning for the City of Little Rock for his written approval before the sewer connection specified in this Contract with the pretreatment ordinance to be approved by the Manager before said connection is made; and Shannon Hills covenants to maintain and enforce at all times said comprehensive development plan, zoning ordinance and sewage pretreatment ordinance. 8. Title and Maintenance Responsibility_ for Sewer Facilities Owned and Operated by Shannon Hills. Title to and maintenance responsibility for any and all sewer facilities of any nature whatsoever located within the incorporated city limits of Shannon Hills, including but not limited to each customer's public facilities to the public 7 E 0 sewer line, shall remain with Shannon Hills or its citizens; and Little Rock shall have no liability or responsibility for the operating or maintenance of said sewer system located within -the -incorporated city limits of Shannon Hills or any future connections as may from time to time be permitted. 302 g. rerm of Contract. Unless terminaueu edrxjGL, L -1+G term of this Contract shall be for a period of fifteen (15) years from the date hereof at which time it will expire; provided, however, this Contract may be extended by the agreement of the parties hereto upon notice given by either party prior to the end of the term and adoption, thereafter, of approving ordinances by Shannon Hills and the City of Little Rock, Arkansas. 10. Assignment or Transfer. This Contract and the rights hereunder shall not be assigned or transferred by O Shannon Hills, and shall be binding upon the successors of either party. 11. Taxes. Shannon Hills covenants and agrees to pay any and all taxes levied by the United States and the State of Arkansas for the services provided and treatment of sewage pursuant to this contract, and shall comply with all federal, state, county and municipal laws, ordinances, rules and regulations pertaining to the treatment of sewage; and Shannon Hills further agrees to indemnify and hold harmless Little Rock for any loss or damage of nature whatsoever sustained by Little Rock occasioned by the failure to comply 8 M with said laws, ordinances, rules and regulations by the I f employees or authorized representatives of Shannon Hills. i i 12. Termination. This Contract may be terminated by Little•Rock if Shannon--Hills-fails to comply fully with any of the terms and provisions of this Contract. Termination of this Contract may occur only after actual written notice is given of the nature of the breach. In the event of the termination of this Contract, all obligations of Little Rock to treat the sewage under the agreement shall cease and Shannon Hills shall immediately remove the sewer connection provided herein, it being the intention of the parties F hereto that Shannon Hills shall be solely responsible for i the treatment of its sewage upon termination of this I Contract, failing which Little Rock shall be entitled to recover from Shannon Hills all damages sustained by Little Rock of any nature whatsoever proximately caused by Shannon Hills' violation of any provision(s) of this Contract, including but not limited to Shannon Hills' failure to remove said sewer connection and treat said sewage in the event it fails to do so. 13. Notices. All notices hereunder shall be in writing and shall be deemed to have been duly given when sent by certified mail, postage prepaid, as follows: If to Little Rock: Little Rock Wastewater Utility AND City of Little Rock 221 East Capitol Avenue City Hall, 500 W. Markham Little Rock, Arkansas 72201 Little Rock, Arkansas 72201 Attn: Manager Attn: City Manager and Mayor If to Shannon Hills: 9 303 • 304 1 city of Shannon Hills City Hall Shannon Hills, Arkansas 72103 Attention: Mayor 14. update- o Re ulations..- Shannon Hills agrees to abide by the rules and regulations published from time to time concerning the treatment of sewage by Little Rock; and all applicable federal, state, county and municipal regulations concerning construction, operating, maintenance, and protection of treatment of sewage pursuant to this Contract. Little Rock shall have the right,, if it deems 1 necessary or appropriate, to inspect all individual tie -ons r s to the Shannon Hills sewage system. i 15. Governmental Function. The parties recognize that f treatment of sewage pursuant to this agreement is a i governmental function and this.Agreement shall be performed by the parties hereto in their respective governmental capacities. 16. Invalid Provision Shal,l Nat Invalidate Contract. The parties agree that in the event any paragraph, sentence, clause or word(s) of this Contract shall be held to be invalid, illegal or unenforceable,• all other terms and provisions of this Contract shall remain in full force and effect, and this Contract shall be construed as if not containing the particular provision or provisions held'to be invalid. 18. Contract -Legally Binding, All parties to the Contract agree to the terms contained herein and represent 10 �r■.::.::.�■..�:..:� ....r. �. r .��. r�...:�.:r � r■r rr �r rr r� rr it 305 to each other that the terms of this Contract have been duly accepted and approved by the authorized representatives of the parties hereto; and all parties covenant to each other that ,a1:1 action •required by -law -has been -taken to make this Contract legally binding and enforceable and that the parties hereto shall have all of the rights and remedies under the law of Arkansas to enforce the terms of this Contract. DATED this day of , 1995. ATTEST: Attest: ATTEST: CITY OF SHANNON HILLS, ARKANSAS By: Mayor CITY OF LITTLE ROCK, ARKANSAS By: Mayor LITTLE ROCK SANITARY SEWER COMMITTEE By: Chairtan 11 306 Manager Little Rock Wastewater Utility 12 r � _ _ � r r � r � r r r� r r ■■� � JUN-06-95 THU 13:51 SHANNON HILLS 1 591 455 '5103 P.01 3b; th�76:0 % � • 1 � � 1 � y +l •. a 11� poocrtia�la o ;�• � ,. K is Ci C"" r rR �` rs:: CA•��i?��re �, ti= x X. 711 • -� • 114i i T. r AM, H DM = C% AT opt orr'r: .'• � f•1^IC � r j � �. :sti: nj: 'fir _���1. •4 Rq^P.,JL_, :;i;:.: SA a :.►'.:: Exhibit "A" to Shannon n; w•■rru��±�r��{ Hills/Little Rock Z Contract .,. .r 615 ORDINANCE NO. 15,614 AN ORDINANCE APPROVING A CONTRACT BETWEEN THE CITY OF LITTLE ROCK AND THE CITY OF SHANNON HILLS AND SHANNON HILLS WATER, SEWER AND FIRE PROTECTION IMPROVEMENT DISTRICT NO. 3 FOR THE TREATMENT OF SEWAGE WHEREAS, the City of Little Rock, Arkansas owns a sewage disposal works and operates said work through the Little Rock Sanitary Sewer Committee ("the Sewer Committee") and the Little Rock Wastewater Utility (the "Utility") and the City of Little Rock is authorized to contract with another city or political subdivision to provide sewage treatment for that entity to the extent of the capacity of the sewage disposal works without impairing the usefulness of said works to the owners upon such terms and conditions as may be fixed by the Sewer Committee and approved by ordinance of the respecting contracting parties; and WHEREAS, the Shannon Hills Water, Sewer and Fire Protection Improvement District No. 3 ("S.I.D. No. 3") owns and operates a certain sewage collection system within the City of Shannon Hills and this system is not adequate or satisfactory to treat the sewage; and WHEREAS, the City of Shannon Hills is the holder of a conditional assignment of S.T.D. No. 3 ,to transfer all of the property of the improvement district to the City of Shannon Hills after the re -payment of all capital indebtedness of S.I.D. No. 3; and 620 WHEREAS, it is in the best interest of the City of Shannon Hills and S.I.D. No. 3 (both referred to hereafter as "Shannon Hills") to enter into an agreement with the City of Little Rock for the treatment of sewage upon such terms and conditions as may be fixed by the Sewer Committee and approved by ordinance of the respective contracting parties; and WHEREAS, the City of Little Rock and Shannon Hills desire to enter into a certain contract pursuant to law for a period not to exceed 15 years and said contract is attached hereto; and WHEREAS, the treatment of sewage in accordance with said contract will not impair the usefulness of the sewage disposal works owned by the City of Little Rock, and the City of Little Rock, by its City Board of Directors, desires to enter into said contract and authorize the Mayor, City Clerk, Sewer Committee and the Manager of the Utility to execute said contract; and WHEREAS, the provisions of A.C.A. §14-235-212 require approval by ordinance of the respective contracting parties and the Sewer Committee has recommended approval of the contract for treatment of the sewage in accordance with the provisions of said contract; NOW, THEREFORE, BE IT ORDAINED by the Board of Directors of the City of Little Rock, Arkansas: SECTION 1. That the contract between the City of Little Rock and Shannon Hills for the treatment of the sewage from 0736H -2- 621 Shannon Hills by the sewage disposal works owned by the City of Little Rock is hereby approved, subject to the terms of the contract, a copy of which is attached hereto. The Mayor, the City Clerk, the Chairman of the Sewer Committee and the Manager of the Little Rock Wastewater Utility are authorized to execute the contract. SECTION 2. That since the contract approved by this ordinance is of great importance to the health and welfare of the citizens of the City of Little Rock, an emergency is hereby declared to exist and this ordinance shall be in full force and effect from and after its passage and approval. PASSED: December 20 1988. Mayor Lot ie Shackelford ATTEST: C y Clerk zech 0736H -3- mom i r m m m A Agreement m = m r THIS AGREEMENT made on this day of —, 1988, by and between the City of Little Rock, Arkansas, the Sanitary Sewer Committee (both hereinafter collectively referred to as "Little Rock"), and the City of Shannon Hills and Shannon Hills Water, Sewer and Fire Protection Improvement District No. 3 (both hereinafter collectively referred to as "Shannon Hills"); WHEREAS, the City of Shannon Hills is the holder of a conditional assignment of the aforesaid improvement district to transfer all of the property of the improvement district to the City of Shannon Hills after the re -payment of all capital indebtedness of the improvement district; and the improvement district may acquire, through improvement loans or bonds, the funds to perform the construction work intended by this agreement and will perform all operational and maintenance duties provided for in this contract until the plant, equipment, lines and other improvements can be transferred capital debt free to the City of Shannon Hills, and both political entities agree, as Shannon Hills, to comply with all of the terms and conditions of this agreement and perform the responsibilities applicable to each under this agreement; and WHEREAS, Shannon Hills desires to connect into the existing sewer system owned by the City of Little Rock, and operated by the City of Little Rock through the Sanitary Sewer Committee and the Little Rock Wastewater Utility (the "Utility"), and also to abandon its existing treatment plant located within the corporate limits of Shannon Hills, as well as to regulate further connections to the Shannon Hills system; and to transfer the service of all of the Shannon Hills sewer system users residing within the corporate limits of the City of Little Rock to the Sewer Committee's system; and, WHEREAS, Little Rock desires to enter into an agreement permitting Shannon Hills to connect with the sewer system of Little Rock, upon certain terms and conditions as herein specifically set forth, and to provide for service for all 622 0736H -2- 623 residents of the City of Little Rock who are presently connected to the Shannon Hills sewer system, and to provide for control of all future temporary service for Little Rock residents; and, when permanent service to the Sewer Committee's system can be provided for the Little Rock resident users, to terminate Shan- non Hills sewer service to the Little Rock residents; and to further limit the extension of sewer services to unincorporated areas of Saline County; NOW, THEREFORE, in consideration of the mutual benefits to be derived herefrom by all parties hereto, it is hereby agreed by and between the parties: 1. Connection by Shannon Hills to the Sewer System of the City of Little Rock. Little Rock, as Owner, hereby agrees to permit Shannon Hills, as Lessee, to connect to the sewer system of Little Rock under the terms of this agreement as soon as practical after the necessary ordinances are adopted as referred to herein, including those approving this agreement pursuant to A.C.A. §14-235-212 by the governing authorities of the City of Little Rock and Shannon Hills; and Shannon Hills hereby agrees at its expense to make such connection in a manner and at a location as approved by the Manager of the Little Rock Wastewater Utility (the "Manager"), and in accordance with the terms and provisions of this agreement and all applicable laws and regulations. As soon as this connection is completed and approved by the Manager, the treatment plant currently operated by Shannon Hills shall be abandoned and no longer used in the sewer system of Shannon Hills. Shannon Hills shall pay to the Sewer Committee an initial connection fee of $8,000.00 for the present users (approximately 550 users); and, thereafter, $100.00 per home user for future tie -ons, and such other connection fees as published in the Sewer Committee's connection fee schedule, effective February 6, 1987, and any amendments made thereto. 2. Wastewater Discharge Flow Pleasuring Meter. The connec- tion to the Little Rock facilities shall include the furnishing 0736H -2- and installation of a wastewater discharge flow meter by Shannon Hills and all expenses in connection therewith shall be borne by Shannon Hills. The meter shall be of a type and installation as approved by the Manager. The function of the meter shall be to measure and record accurately all flows discharged into the Little Rock sewer facilities by Shannon Hills. Little Rock by the Utility further agrees to maintain this meter to insure its reliability and accuracy. 3. Sewer Services, Charges and Collections. (a) Shannon Hills agrees to pay the Utility a monthly sewer service charge and said charge shall be promptly billed after the first day of each month for the services provided by this agreement. The monthly sewer service charge shall be computed from the total flow registered by the Wastewater Discharge Flow Measuring Meter, including all infiltration and inflow, at the rates set by the Little Rock Hoard of Directors for sewer ser- vice outside the city limits of Little Rock, Arkansas. The monthly statement for the charge shall be based upon flow meter readings conducted by the Utility; however, in the event of flow meter malfunction, the Utility may estimate the reading based upon a comparable preceding period. All charges for sewer service provided to Shannon Hills shall be billed to Shannon Hills and it shall be the responsibility of Shannon Hills to make timely payment of these charges on or before the twentieth (20th) day following the month for which the service is billed. Shannon Hills shall collect from its users all sums which may be due in connection with the service extended. The Sewer Commit- tee for the use and benefit of the City of Little Rock shall have all rights to effect such collection of all sums owed to Little Rock pursuant to Arkansas law, including but not limited tb those provisions contained in A.C.A. §14-235-223; and Shannon Hills agrees to hold harmless the Sewer Committee for all los- ses, costs and expenses as may be sustained by Little Rock in connection with the payment of such sewer service. If Shannon Hills does not remit payment on or before the twentieth (20th) 0736H -3- 624 0736H ..q_ day of the month following the month for which the service is billed, a penalty equal to ten percent (10%) of the total pay- ment amount due shall be added to such payment, and if not paid on or before the twentieth (20th) day of the month in which the statement is submitted, Little Rock may terminate this agreement in accordance with the terms herein. (b) All customers of Shannon Hills who reside within the city limits of Little Rock shall be billed for sewage treatment by Shannon Hills at inside city limits rates as provided in the applicable ordinances of the City of Little Rock, as currently set forth in City of Little Rock Ordinance No. 15,242, amending Ordinance No. 13,982, adopted on February 3, 1987, and as may be amended or adopted in the future. However, Shannon Hills may make any uniform reasonable charge to all of its customers to provide funds to amortize fees charged it by Mabelvale-Alexander Sewer Improvement District 142 ("S.I.D. No. 142"), capital debt amortization, infiltration costs, sewer maintenance and opera- tional costs; and as long as the Little Rock customers are charged no more than inside city rates for ,sewer treatment, the uniform charges will not be deemed to contravene this agree- ment. Shannon Hills shall receive a credit each month for service to customers residing inside the city limits of Little Rock. The credit shall be an amount equal to the difference between the amount owed by those customers residing in the city limits of Little Rock as reflected by their individual water y meters based on the inside city limit rate, and that portion of the actual charge by the Sewer Committee (as computed from the total flow registered by the discharge flow measuring meter) which is attributable to the service provided by Shannon Hills to those customers inside the city limits of Little Rock. 4. Aeplication of Cit of Little Rock Sewer Ordinances. The provisions of all existing and future ordinances enacted by the City of Little Rock relating to the regulation of the construc- tion, operation and maintenance of sewers shall apply to the sewer facilities owned and operated by Shannon Hills and con - 0736H ..q_ I nected to the sewer facilities owned and operated by the City of Little Rock. The provisions of these ordinances shall be binding on the parties hereto, including the rates as may be from time to time specified; and Shannon Hills covenants that it will at all times comply with said ordinances and further agrees to hold harmless the Sewer Committee from all losses, damages, expenses or liabilities of any nature incurred by the Sewer Committee as a consequence of any acts, omissions or any conduct by any authorized representative or employee of Shannon Hills, its customers or citizens arising out of any violations of said ordinance or any provision of this agreement or relating to the sewer service furnished as a consequence thereof. 5. Future Connections with the Sewer System of Shannon Hills. Shannon Hills agrees not to extend any sewer services to any area outside the incorporated area of Shannon Hills as the boundaries exist on the date when this agreement is executed, unless the governing body of the City of Little Rock has given its prior written approval to do so. Shannon Hills further agrees to limit any future sewer main extensions and sewer connections in any portion of Pulaski County not currently served unless Shannon Hills obtains the prior approval in writing by the Sewer Committee; and then only for so long as service is not available from the Sewer Committee for all users now located in the City of Little Rock, including but not limited to Rolling Hills Subdivision, situated in Pulaski County, Arkansas. A map of the City of Shannon Hills showing the current boundaries is attached hereto as Exhibit "A". 6. Future Extensions of Service. The Sewer Committee shall not be obligated for and assumes no liability for any future extension of service not specifically set forth herein, and no such extension shall be made without the prior written approval of the governing body of the City of Little Rock and the Sewer Committee. This agreement anticipates up to 1,000 Shannon Hills users. In any event, anyone desiring such an extension of ser- vice beyond the existing facilities hereby served shall bear the 0736H 1--M r r r 626 full cost thereof, including all costs of any nature whatsoever 621 involved in effecting such extension or making available such service and any connection fees set by the Sewer Committee, and S.I.D. No. 142 and Shannon Hills. The further extension of service shall be in accordance with the rules and regulations• of the Sewer Committee and subject to its approval at the time of the extension of service. 7. Shannon Hills, Comprehensive Development_ Plan, Zoning Or- dinance and Fre-Treatment Ordinance. Prior to the connection of the sewer system of Shannon Hills with the City of Little Rock, Shannon Hills shall furnish proof of the adoption of a comprehensive development plan and zoning ordinance and a sewage pretreatment ordinance; and said plan and zoning ordinance shall have been submitted to the Director of Comprehensive Planning for the City of• Little Rock for his written approval before the sewer connection specified in this agreement with the pretreat- ment ordinance to be approved by the Manager before said con- nection is made. B. Title and Maintenance Responsibility for Sewer Facilities Owned and O erated b Shannon Hills. Title to and maintenance responsibility for any and all sewer facilities of any nature whatsoever located within the incorporated city limits of Shannon Hills, including but not limited to each customer's public facilities to the public sewer line, shall remain with Shannon Hills or its citizens; and Little Rock shall have no liability or responsibility for the operating or maintenance of said sewer system located within the incorporated city limits of Shannon Hills or any future connections as may from time to time be permitted. 9. Term of Agreement. Unless terminated earlier, the term of this agreement shall be for a period of fifteen (15) years from the date hereof at which time it will expire; provided, however, this agreement may be extended by the agreement of the parties hereto upon notice given by either party prior to the end of the term and adoption, thereafter, of approving ordinances 0736H -6- � r� r � �■■ � r r r ■■r �■ �■ r� r by the contracting parties hereto. 10. Assignment or Transler. This agreement and the rights hereunder shall not be assigned or transferred by Shannon Hills, but shall be binding upon the successors of either party. 11. Taxes. Shannon Hills covenants and agrees to pay any and all taxes levied by the United States and the State of Arkansas for the services provided and treatment of sewage pursuant to this contract, and shall comply with all federal, state, county and municipal laws, ordinances, rules and regulations pertaining to the treatment of sewage; and Shannon Hills further agrees to indemnify and hold harmless Little Rock for any loss or damage of nature whatsoever sustained by Little Rock occasioned by the failure to comply with said laws, ordinances, rules and regulations by the employees or authorized representatives of Shannon Hills. 12, Termination. This agreement may be terminated by Little Rock if Shannon Hills fails to comply fully with any of the terms and provisions of this agreement. Termination of this agreement may occur only after actual written notice is given of the nature of the breach. In the event of the termination of this agreement, all obligations of Little Rock to treat the sewage under the agreement shall cease and Shannon Hills shall immediately remove the sewer connection provided herein, it being the intention of the parties hereto that Shannon Hills shall be solely responsible for the treatment of its sewage upon termination of this agreement, failing which Little Rock shall be entitled to recover from Shannon Hills all damages sustained by Little Rock of any nature whatsoever proximately caused by Shannon Hills' violation of any provision(s) of this agreement, including but not limited to Shannon Hills' failure to remove said sewer connection and treat said sewage in the event it fails to do so. 13. Notices. All notices hereunder shall be in writing and shall be deemed to have been duly given when sent by registered or certified mail, postage prepaid, as follows: 0736H M 62('35 M = M M If to Little Rock: Little Rock Wastewater Utility AND City of Little Rock 221 East Capitol Avenue City Hall, 500 W. Markham Little Rock, AR 72202 Little Rock, AR 72201 Attention: Manager Attention: City Manager If to,Shannon Hills: Shannon Hills Water, Sewer AND City of Shannon Hills & Eire Protection District City Hall 10000 High Road Shannon Hills, AR 72103 Shannon Hills, AR 72103 Attention: Mayor Attention: Manager 14. Update of Regulations. Shannon Hills agrees to abide by the rules and regulations published from time to time concerning the treatment of sewage by Little Rock; and all applicable federal, state, county and municipal regulations concerning construction, operating, maintenance, and protection of treatment of sewage pursuant to this agreement. Little Rock shall have the right. if it deems necessary or appropriate, to inspect all individual tie -ons to the Shannon Hills sewage system. 15. Governmental function. The parties recognize that treatment of sewage pursuant to this agreement is a governmental function and this Agreement shall be performed by the parties hereto in their respective governmental capacities. 16. Invalid Provision Shall Not Invalidate Agreement. The parties agree that in the event any paragraph, sentence, clause or word(s) of this agreement shall be held to be invalid, il- legal or unenforceable, all other terms and provisions of this agreement shall remain in full force and effect, and this agree- ment shall be construed as if not containing the particular provision or provisions held to be invalid. 17. Agreement ;eNallY Binding. All parties to the agree- ment agree to the terms contained herein and represent to each other that the terms of this agreement have been duly accepted and approved by the authorized representatives of the 'parties hereto; and all parties covenant to each other that all action required by law has been taken to make this agreement legally binding and enforceable and that the parties hereto shall have 0736H -8- Mi r '� r r� r r r �r r� r r ■r r� r all of the rights and remedies under the law of Arkansas to 630 enforce the terms of this agreement. DATED this day of 1988. ATTEST: CITY OF SHANNON HILLS, ARKANSAS By: Mayor SHANNON HILLS WATER, SEWER AND FIRE PROTECTION IMPROVEMENT DISTRICT NO. 3 BY: _ Chairman Secretary Comptroller CITY OF LITTLE ROCK, ARKANSAS BY: Mayor ATTEST: Clerk LITTLE ROCK SANITARY SEWER COMMITTEE BY: Chairman ATTEST: Manager Little Rock Wastewater Utility 0736H -9- I t u.jj�II c ki •� '•-rt ei`ifLL]li--iVw 0.. •� . • z �L ` �,i .1 IY N rII •� 'S i� � Yl nr [� :;• �. 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O i•i \\ i\ i b\i i\ b « 00 00 _ ] l Y O O L') 2 4 II � W a O O O O h t y t b w IIO W '•+ y 4 b 1 W O v 0 2 k1 2 V 3 V 4 W� 4 0 4 � W, O O ; V7 v D W V p W W v t O uCC O rc Li 61 t'j tt O W 11.1 ? q � >1lu i 41Q ? -j ^ O: O O Q LI q 2 ? • O O -Il m J W O V o O 4: Q 1C Q J Q q O U O x T It z q J u Q 2 ? •• •I U L!m 111 FC I 4 l O V) 'i 1•/ Ol m > J O I u J K W m O O m w R w W w m zt U J u O u O u Il' ti Ci 0 W Q 1 J JIM GUY TUCKER GOVERNOR DEPARTMENT OF HEALTH 4815 WEST MARKHAM STREET • LITTLE ROCK, ARKANSAS 72205.3867 TELEPHONE AC 501 661.2000 Mr. Tim Lemons, P.E. Bond Consulting Engineers, Inc. 1010 S. Redmond.Road Jacksonville, AR 72075 Dear Mr. Lemons: M. JOYCELYN ELDERS, M.D. DIRECTOR April 1, 1993 te,It C.. - (2L,& _ D F -W RE: Sewage Treatment Plant Shannon Hills Water & Sewer Improvement Shannon Hills, AR 93 E 720-2 The plans and specifications for the captioned project, dated December, 1992, prepared by Bond Consulting Engineers, and submitted to the Division of Engineering on January 27, 1993 have been reviewed and are hereby approved with the following conditions. 1. The Division of Engineering relied upon the statements and representations made in the engineer's report, plans, and specifications. In case any statement or representation in the aforementioned documents is found to be incorrect, this Approval may be revoked. 2. There shall be no deviation from the plans and specifications unless revised plans and specifications have been first sub— mitted for review and written consent given. 3. The review and approval of the plans and specifications were for functional and sanitary features and in no way constitute an analysis of the structural design. 4. If construction on this project is not started within one year of the date affixed hereto, this Letter of Approval is void. Mr. Tim Lemons, P.E. April 1, 1993 Page 2 5. As you are aware, this office has strongly recommended for several years that Shannon Hills wastewater.be treated by Little Rock. The collection lines of S.I.D. 142 were built with this purpose in mind as were certain capital improvements in Shannon Hills. Although the treatment plant is approved from a technical standpoint, as proposed, it is our opinion that it is in the best interest of both Shannon Hills and the City of Little Rock to reach an agreement in principle and price on the treatment of Shannon Hills wastewater by Little Rock. From Shannon Hill's standpoint, not having a treatment facility will free up people, equipment, and utility costs associated with operation and maintenance. Although the cost analysis showed a slight advantage to Shannon Hills operating its own facility, unforeseen and higher than anticipated cost related to a treatment facility are a real possibility, particularly as the facility ages. From Little Rock's standpoint, connection of Shannon Hills will eradicate the discharge of treated sewage into a stream that traverses a large part of the city. All treated sewage, regardless of the level of treatment, contains viable pathogenic organisms. These organisms remain viable until time and environmental factors result in their die—off. Elimination of the effluent from a stream that travels through a population center makes only good sense. We understand that Shannon Hills and the City of Little rock are still negotiating over the provisions of providing service. We strongly encourage Shannon Hills and Little Rock to diligently pursue a service agreement. Such an agreement is in the best interest of the citizens of both cities. The plans and specifications are being retained for our files. Mr. Tim Lemons, P.E. April 1, 1993 Page 3 When submitting correspondence pertaining to this project, please include our reference number 93 E 720-2. Sincerely, Robert Hart, P.E. Chief Engineer Division of Engineering RH:JS:MF:pmc cc: Pulaski County Sanitarian Plan Review, Plumbing Section Jim Ort, Shannon Hills WSFPID #3 Jim Dailey, Mayor, City of Little Rock Charles Nickerson, Acting CityM ager, City of Little Rock Little Rock Wastewater Utilii ID#86/41-43 cc,, Gi o f I SNA,vn./v.l MAP 1q1 L LS Conditional Use Permit (CUP) TRS 1S,13W,16 PD CT Z-5664 SHANNON HILLS WASTEWATER TREATMENT PLANT C.U.P. ITEM NO. r� B 3/93 TRS 1S,13 W,16 PD CT SHANNON HILLS Area Zoning Z-5664 ITEM NO. SHANNON HILLS WASTEWATER B TREATMENT PLANT N C.U.P. 3/93 'Oy-GrircAouxa PLANT i i Y- s: i E Ccs. Gi�✓E 20, 91.46Xi C4W7-' 5,4L;rc/ar G- PAJNIG DR. VIC 1'V/7Y Al MR•Q H/ L LS Conditional Use Permit (CUP) TRS 1S,13W,16 Z-$664 ITEM NO. PD SHANNON HILLS WASTEWATER TREATMENT PLANT CT C.U.P. 3/93 COUNTY LINE RD SHANNON HILLS Area Zoning ----------------- T R S ,_.. --.---- - TRS 1S -13W,16 Z-$664 -- -- - - - - - - ITEM NO. PD SHANNON HILLS WASTEWATER N CT TREATMENT PLANT C.U.P. 3/93 RESOLUTION NO. A RESOLUTION RESCINDING THE LITTLE ROCK PLANNING COMMISSION'S ACTION IN DENYING A CONDITIONAL USE PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WASTEWATER TREATMENT FACILITY BY THE SHANNON HILLS WATER, SEWER AND FIRE PROTECTION DISTRICT NO. 3 WHEREAS, an application was filed with the Little Rock Planning Commission for a conditional use permit to allow for the construction and operation of a wastewater treatment facility on the R-2 zoned property described as the SW 1/4, SE 1/4 and the West 330 feet of the North 1/2, SE 1/4, SE 1/4, Section 16, T -1-S, R -13-W, Little Rock, Arkansas; and WHEREAS, the Little Rock Planning Commission determined that the proposed use was an inappropriate land use and denied the application at its April 20, 1993 meeting; and WHEREAS, the Little Rock Board of Directors has determined that action to be incorrect. NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF DIRECTORS OF THE CITY OF LITTLE ROCK ARKANSAS. SECTION 1. The action of the Little Rock Planning Commission in denying an application for a conditional use permit to allow for the construction and operation of a wastewater treatment facility on the R-2 zoned property described as the SW 1/4, SE 1/4 and the West 330 feet of the North 1/2, SE 1/4, SE 1/4, Section 16, T -1-S, R -13-W, Little Rock, Arkansas is hereby rescinded. SECTION 2. Said Conditional Use Permit is hereby approved. SECTION 3. This resolution shall be in full force and effect from and after its adoption. ADOPTED: ATTEST: City Clerk APPROVED AS TO FORM: City Attorney APPROVED: Mayor RESOLUTION NO. A RESOLUTION SUSTAINING THE LITTLE ROCK PLANNING COMMISSION'S ACTION IN DENYING A CONDITIONAL USE PERMIT FOR THE CONSTRUCTION AND OPERATION OF A WASTEWATER TREATMENT FACILITY BY THE SHANNON HILLS WATER, SEWER AND FIRE PROTECTION DISTRICT NO. 3 WHEREAS, an application was filed with the Little Rock Planning Commission for a conditional use permit to allow for the construction and operation of a wastewater treatment facility on the R-2 zoned property described as the SW 1/4, SE 1/4 and the West 330 feet of the North 1/2, SE 1/4, SE 1/4, Section 16, T -1-S, R -13-W, Little Rock, Arkansas; and WHEREAS, the Little Rock Planning Commission determined that the proposed use was an inappropriate land use and denied the application at its April 20, 1993 meeting; and WHEREAS, the Little Rock Board of Directors has determined that action to be correct. NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF DIRECTORS OF THE CITY OF LITTLE ROCK ARKANSAS. SECTION 1. The action of the Little Rock Planning Commission in denying an application for a conditional use permit to allow for the construction and operation of a wastewater treatment facility on the R-2 zoned property described as the SW 1/4, SE 1/4 and the West 330 feet of the North 1/2, SE 1/4, SE 1/4, Section 16, T -1-S, R -13-W, Little Rock, Arkansas is hereby sustained. SECTION 2. This resolution shall be in full force and effect from and after its adoption. ADOPTED: ATTEST: City Clerk APPROVED AS TO FORM: City Attorney APPROVED: Mayor Little Rock221 E. Capitol Wastewater ® Little Rock, Arkansas 72202 Utility February 19, 1993 Mr. Stephen Giles Assistant City Attorney City of Little Rock City Hall Markham and Broadway Little Rock, Arkansas 72201 Re: City of Little Rock Planning Commission Meeting on March 9, 1993, at 1:00 p.m. Regarding Shannon Hills Wastewater Plant Proposal and Request for Conditional Use Permit Dear Steve: This is to confirm our telephone conversation this morning in which you advised me that the Subdivision Committee met yesterday in connection with the captioned matter and that the Planning Commission meeting is scheduled to be held on Tuesday, March 9, 1993 at 1:00 p.m. to formally consider the Shannon Hills Wastewater Plant proposal and request for a conditional use permit. Enclosed is a copy of my letter dated February 18, 1993, to Jerry Gardner with copies of the letters mentioned in my letter to Jerry. You are welcome to review the Utility's rather voluminous files on this matter and please feel free to call me at 688-1403 for further information or copies of any additional documents. Since Rick Barger and I will not be available for the Planning Commission meeting on March 9, 1993, Reggie A. Corbitt, Manager, will be present to answer any questions from the Planning Commission. In the meantime, please telephone Rick Barger if you have any questions which are technical in nature. Rick has thoroughly reviewed this matter and is very familiar with the wastewater treatment issues involved in the proposed constructed wetlands treatment plant to be located on the property involved in the captioned matter. Best regards. Yours truly, D n F. Hamilton Staff Attorney DFH/jbm Over Little Rock221 E. Capitol Wastewater Little Rock, Arkansas 72202 Utility" 501/376-2903 February 18, 1993 Mr. Jerry Gardner Civil Engineering Manager City of Little Rock. Department of Public Works 700 West Markham Little Rock, Arkansas 72201 Re: City of Little Rock Subdivision Committee Meeting on March 9, 1993, at 12:30 p.m. Regarding Shannon -Hills Wastewater Plant Proposal and Zoning Request Dear Jerry: . Jim Boyd, Little Rock Wastewater Utility Supervisor Construction Administration New Mains, has requested that I send you copies of pertinent documents from the Utility file pertaining to the captioned matter and that a Utility representative should attend the Subdivision Committee meeting on March 9, 1993 at 12:30 p.m. in order to answer possible questions. Since the Utility file on this matter is voluminous and covers a period of time over many years, I have selected the following documents in response to your request and you are certainly welcome to review the file in its entirety at your convenience: 1. Letter dated September 10, 1992, from Reggie Corbitt to Mike Chandler, Mike Hood, and Paul Acre, all of the Arkansas Department of Pollution Control and Ecology, expressing comments and objections to the Shannon Hills 201 Facility Plan dated April, 1992, as prepared by Bond Consulting Engineers, Inc. 2. Article titled Water Plant violating Permit published in the Arkansas Democrat -Gazette February 23, 1992,issue. 3. Four pages of drawings and graphs pertaining to the proposed Shannon Hills Wastewater Treatment Plant to be located within the city limits of Little Rock, Arkansas, as given to Tom Dalton in the conference held on October 22, 1992. 4. Letter dated December. 18, 1992, from Paul Acre of the Arkansas Department of Pollution Control and Ecology to Reggie A. Corbitt in response to Reggie Corbitt's letter dated September 10, 1992, with copies of the following: Mr. Jerry Gardner February 18, 1993 Page 2 (a) October 1, 1992, letter to Paul Acre of ADPC&E from Tim Lemons with enclosures consisting of Addendum No. 1 to facility plan; letter dated September 21, 1992, from Charles A. Brown to Tim Lemons; letter dated September 24, 1992, to Paul Acre from Charles A. Brown with additional enclosures consisting of treatment plant expenses dated January 8, 1990 and a warranty deed from Teddy Andrew Meyer and Mary Sue Meyer, husband and. wife, to Shannon Hills Water, Sewer, and Fire Improvement District No. 31 and a trustee deed from the same grantee, both dated August 17, 1992. (b) September 30, 1992 letter from Paul Acre to Reggie A. Corbitt. A Utility representative will attend the Subdivision Committee meeting on March 9, 1993, at 12:30 p.m. in order to answer any questions which are technical in nature which should be directed to Rick Barger in the meantime. Unfortunately, I will be out of town on that date and, therefore, I will be unable to attend the Subdivision Committee meeting. Please feel free to call me at 688- 1403, or Reggie Corbitt, or Rick Barger if you need any further additional information. If you do need to review any of the other documents in our voluminous files, please telephone me and I will be glad to make them available at your convenience. Best regards. Yo truly, on F. Hamilton Staff Attorney DFH/jbm cc: Reggie A. Corbitt Rick Barger Sewer Committee Members Little Rock Wastewater0 Utility/ September 10, 1992 221 E. Capitol Little Rock, Arkansas 72202 501/376-2903 Mr. Mike Chandler Arkansas Department of Pollution Control and Ecology 8101 Interstate 30 Post Office Box 8913 Little Rock, AR 72219-8913 Mr. Mike Hood Arkansas Department of Pollution Control and Ecology 8101 Interstate 30 Post Office Box 8913 Little Rock, Arkansas 72219-8913 Mr. Paul Acre Arkansas Department of Pollution Control and Ecology 8101 Interstate 30 Post Office Box 8913 Little Rock, AR 72219-8913 Re: City of Shannon Hills/Shannon Hills Water, Sewer, and Fire Protection Improvement District No. 3/ Sewer Improvement District No. 142/City of Little Rock and Sewer Committee Contracts Your File No.: CS -050730-03, Little Rock, Arkansas CS -050709-03, Shannon Hills, Arkansas Gentlemen: This letter is to express to you comments and objections to the Shannon Hills 201 Facility Plan, dated April, 1992, revised August, 1992, prepared by Bond Consulting Engineers, Inc. in connection with the captioned matter and filed in your office on August 31, 1992. Our comments and objections are as follows: 1. Proposed Permit Limitations are too Lenient The "preliminary" permit limits that ADPC&E has proposed for the Shannon Hills Wastewater Plant effluent appear _ very__,lenient_considering the stream they will discharge - into. The proposed permit limits are noted below: Shannon Hills Proposed Discharge_ Limits (As per 3/31/92 ADPC&E Letter from Bob Singleton) Parameter Limitation Summer Winter CBOD5 15 mg/L 20 mg/L TSS 20 mg/L 20 mg/L NH3-N 6 mg/L 12 mg/L 3. Mr. Mike chandler Mr. Paul Acre Mr. Mike Hood September 10, 1992 Page 2 The lack of more stringent standards is highly unusual considering the fact that the discharge stream is Otter Creek, which feeds into Fourche Creek, which flows 20 miles through Little Rock. Further, Fourche Creek flows through Hindman Park, which has many diverse public uses including fishing, picnicking, softball, and a public golf course. With Shannon Hills discharge flowing through the most heavily populated area of the State, more stringent values for CBOD5, TSS, and NH3-N are certainly appropriate. Also, numerous additional parameters, routinely included for discharges into small tributaries such as Otter Creek, would be a D.O. limit of 6.0 mg/L, heavy metals limits, dechlorination, and biomonitoring. The "desk top model" that ADPC&E refers to in their letter of March 31, 1992, should be reevaluated in determining appropriate discharge limits for the proposed new Shannon Hills Wastewater Treatment Plant. S.Y.D. 142 Connection Fee A fee of $100,000 up front and $181,000 paid out at $36,000 per year is proposed to SID 142 for Alternatives B (constructed wetlands) and D (sand filter system), which would not even use the oversized line constructed by SID 142 for the purpose of serving Shannon Hills. This payment is discussed on pages 131 and 131a of the Facility Plan. LRWU Proposed Compromise service Charges are Less than the Original Contract Rate In 1989, Shannon Hills signed a contract with LRWU for treating Shannon -Hills wastewater -at "the treatment rate for the District $1.10/100 cf" (see Page 6). On Page 146, the Facility Plan notes our current proposed rate for Shannon Hills is $1.06/100 cf, which is less than our 1989 proposed fee. 4. Constructed Wetlands Annual Cost Unrealistically Low On page 129, Table 2, "Annual Wastewater Treatment O & M" includes some unrealistically low annual O&M values for Alt. B, the Constructed Wetlands. The laboratory costs are shown as $720.00 per year. Assuming there is a sample once per week for CBOD5, NH3-N, TSS, and fecal Mr. Mike Chandler Mr. Paul Acre Mr. Mike Hood September 10, 1992 Page 3 coliform, the monthly cost would be in the $500 range with an annual cost of $6,000.00. Secondly, the "Site Main" (meaning site maintenance), annual fee of $360.00 is the same for "Alt. All, connection to Little Rock as it is for Alt. B., the Constructed Wetlands alternative. The connection to Little Rock would have no maintenance other than reading a meter, versus the Facultative Lagoon/ Wetlands which would need multiple visits each week, checking disinfection, etc. The Constructed Wetlands alternative would cost far more than $360 per year for "Site Main". 5. Unreliable Data Collected for Design The cost effectiveness of connection to Little Rock, determination of the collection system's need for rehabilitation, and the sizing of the constructed wetlands all depend on the collection of accurate flow measurements. on the collection system and accurate wastewater analysis. Neither accurate flow or wastewater data is presented in the Facility Plan. A. Wastewater Characteristics Data uestionable On Page 40, the Facility Plan states "The engineer recommends that the above documentation should not be used for design," referring to the inaccuracy of plant influent testing. Bond Consulting Engineers then decide on Page 40 to use a BOD value of 194 mg/L "calculated in the Future Planning Analysis of this report." B. Unreliable Data Collected During I/I Analysis On Page 21, the field data collection for the I/I Analysis is discussed. It is noted that, during the field data collection period, the total system flow meter "has not performed consistently throughout the two month period mandated by ADPC&E for the analysis of I/I." Another six months has passed since the I/I Analysis, and the records of wastewater flow rates pumped since completion of the I/I field data collection should be evaluated. Mr. Mike Chandler Mr. Paul Acre Mr. Mike Hood September 10, 1992 Page 3 6. Constructed Wetlands Unproven Technolo An internal memo from the Department of Health and Hospitals, State of Louisiana, dated 10/17/92, states: "Effective immediately, all regional district engineering staff are NOT to approve any more Rock Reed Filters/ Constructed Wetlands until they are further evaluated." ADPL&E personnel should follow up with Louisiana personnel concerning the status of constructed wetlands prior to approving any additional constructed wetlands in Arkansas. ADPC&E, in conjunction with USEPA, is scheduling to study the current constructed wetlands now in operation in Arkansas and some in surrounding states to determine their performance. With serious questions concerning constructed wetlands existing in an adjacent state, and Arkansas preparing to study the system's effectiveness at several existing facilities, prudent engineering practice would dictate that this technology should not be used at this time for a plant that can affect the 185,000 citizens of Little Rock. 7. Public Health Issues A. Public Contact Issues Shannon Hills is proposing to build a facultative lagoon, followed by constructed wetlands, on Otter Creek which then flows twenty miles through the most densely populated- part of the State of Arkansas, risking contact with the population of 185,000. As noted in Item #3, the effluent from Shannon Hills would flow through Otter Creek which empties into Fourche Creek, where citizens of Little Rock fish. Fourche Creek also flows through Hindman Park where numerous recreational activities take place including softball, golf, and general outdoor activities. Mr. Mike Chandler Mr. Paul Acre Mr. Mike Hood September 10, 1992 Page 5 B. Mosquito and Other Insect Infestation The proposed facultative lagoon and wetlands will become a breeding ground for mosquitos and other insects. An elementary school and major food distribution center are located within one mile of the site, as are several residential areas, including the City of Shannon Hills. C. Solution to Protection of Public Health The most prudent way to protect the public from the threat to public health originating from wastewater from Shannon Hills is without question the connection of Shannon Hills to the Little Rock Wastewater Collection System. Shannon Hills' wastewater would then be treated at the Fourche Creek Treatment Plant which has one of the best compliance records in the State of Arkansas over the past four years. 8. Alt. A - Connection to Little Rock AllegedlV Resulting in Construction Cost Being too Hi h On page 137, the total cost to connect to Little Rock with two feet of pipe is shown at $90,000. Some questionable items in the table include $10,000 for legal fees, $4,500 for the I/I Study, and $3,000 for an Operations Manual. An I/I Study was completed for the 201 Facility Plan and Little Rock funded the $10,000 cost in 1989 to draft a connection contract with Shannon Hills. The need for an Operations Manual seems questionable. 9. Non --Compliance With ADPL&# Redundancy Design Guidelines The "Configuration" section of the ADPC&E Wetlands Design Guidelines state that "Total Cell Volume and/or area should be based on one cell out of service." The Bond Engineers' preliminary design calculations for wetlands do not comply with the design guidelines for redundancy. Four wetland cells are proposed with all four constantly in operation. The Tennessee Valley Authority (TVA) design considerations referred to in the ADPC&E Design Guidelines recommend on Page 5 "draining each cell on rotating intervals" to enhance mosquito control. Rotating cells for draining would reinforce the,need for a fifth redundant wetland cell for Shannon Hills. I Mr. Mike Chandler Mr. Paul Acre Mr. Mike Hood September 10, 1992 Page 6 In addition to the comments contained in this letter, we share the same concerns expressed in the letter dated May 28, 1992 to John Griffin, Chairman of Shannon Hills Water, Sewer, and Fire Protection Improvement District No. 3 from Paul Acre, P.E., Project Engineer, Construction Assistance Division of the Arkansas Department of Pollution Control and Ecology. The comments by Mr. Acre should be adequately addressed before proceeding further and we respectfully request the opportunity to review any responses to the matters raised in Mr. Acre's letter, as well as the right to comment further. Please make this letter a part of the permanent file in connection with the captioned matter, and I would welcome the opportunity to discuss our comments and objections at your earliest convenience in order to expedite a resolution of this matter as quickly as possible. These comments and objections have been prepared on the basis of the analysis of Rick L. Barger, Director of Operations, and approved by me for submission to you. Yours truly, IR re' A. Corbitt Manager RAC/ jbm cc: Harold MacIntire Charles Brown Sam Jones Tom Dalton Tom Carpenter Rick Barger Don F. Hamilton Sewer Committee Members _-__ -- The Arkansas Democrat -Gazette, Sunday, February 23, 1992 - 6 - BrJdt S_W1 PE` si mmD=116=et( Slaff wrtv� A` Fvr at :TealIour Sha6tion t( Hills' ;,WaW_ .. L 6 e treatY-b e e n'.- vione'., t"I: hik, Otter-,Cri statt!,r lot iabtieb'2 --penalties Qntrbl ;i o Sion •• ate thA.%wteIkpOHtItiI , s w A6 Z d e Improyem s-' Blrio uaup on a .ae called. him.: last w -16: jk-� tfiitj,,­:.-who- ab eg Rialw- _bnt outiothe c6m** issiqlt: -1bld'441 &W loll u in9 !. t.W -w- fenn- th ;... Ij _0 _Ing 4io g; no- sewage. "The whole thing depends on how much more can'people in. Shannon bills pay for utility 'service than people in Little ..Rock," Brown said. ing sewagb,i6 Shannon Hills Sa11ne pp��� r p .- .trnpravem t'; -:district had �al-' Cae►riiy ready use . a $150,ODI shanndV from the Farmers -Home 'Ad-� i wasm+++raWf HIIJs_ ayContinued from Arkansas' minis#:ratiivi� to build r .con- Wasment plant •evidence 'the plant is harming nectiuig line:;« It lacl�s::about two.,+�eet of .:; �: , - i]istr�et: 142 11 'led to be- .the creek PC" offiMals :cit- ''connected,",:,;Charles . lieve, among other thiizgs, iuig.;a shortage -of'manpower,:' :1taXe ' taever_;ordei'ed :#esta:;,:of .being Brown,..the:'disirict s, a#torney, ""M _that the Shannon Hills tie=on would water. qualiityxn thejcreel v� ,; But a Decerrmber' 4087 test.of said: The rate. change by.,the.,Lit be facilitated by its customers not being required to pay more effluent 'from the -plant -- the tle Rock utility wouiil�"raise Shannon Hills' �monthly.--biU, , than -retail rates .that would. y Rock) dity "e d - is -would gay ear"lie'st; such record availible"' -aBthe �PC&E - showed =it -con- shared .by . about _550 -'house- off:: the :ver real +prospect ri :a #airied eight times as rrtany,sus- state::per- holds; from $7,500 to • ,about 17,000, Brown ra>d �.t e $ _• xiholesee' rate which would,b6 e;' ri bettertfox:Pub f," lawyer ;lpeiuded solids -as its allows- :Similar'violations Rock charges 150 percenf; o -its ? - '" Sappuel Joties� _wrgte"il:o_,the ziit bf'.ihe permit have -continued in -city rate to'treat out -of -city PR morsthiy since then. ; : �., sewage.- _ ; "�_:: The other option is for :.� �Lttle ,Rock utility officials �% -. The tributary :: joins - Otter Creek the; :discharge , Shannon Hills-'to�build s new lii�spntg3ones;aceduizt'- :.near: :p;oint. Otter- creeek,-i: =plant;or improve the existing one. The PC&E`'has given the :.g{j&E. records raise ques- about 'the, improvement through gindrnan Park -in --Lit Rock, runs into: Fourche improvement district prelimi- ,distzict's alility;,to `operate a .119 r Creek -and finally ]Mins the AxL ' nary approval for a $800,000 loan from the: Agency's revolve -.waste water. treatment" plant eff`xciently. Workers-:• at the kansas River... % "� : ; :.:.:. ".That's contrary.. to .t -the , ing loan fund: The mdnthly sewer charges -Shannon Hills .treatment plant + have told inspectors iti�ras nc ' .Health and.welfare_of the.city h of L'ttle Rack,'.-'.. eggier.C,o hitt r ' 1 �" , needed to ,pay }pack tie -loan -$10;0 less wkl maintained by past opera - - A inspection in i - • tr manager: of'Lit d, ock,s wa;;te :4 I '-� � :wou'Id''be-'about than -the: Dost ot'tying:onto the .PC&E «. Zde 1989 found the plant .in Water utility,0,�id:3-- ��2 �:� There •app¢ar-Wo Ile -,two -.al- I�ittl¢ =Rock:? systems; .:Brown P lete disrepair," much of '. - ternatives, but .nether pis t5re.L =, said.But ]Viabelvale-Alezaader _cots 'fie ' machinery for treating waste water inoperable: ; of drawbacks..: ; One is;foitthe`Sltsaitak�iHills;�' . Seer 7rnpQvem1S.Distr'rgt;.. 1`A:'wouid object #o a#� :. "Sometimes we have not m rovement. disfct�ka'send p.. :`tts:sewage'to Littl x--11 ie .any. tempt by. Shannon Hills to - . had the -best operators," Grif- �� "But build or improve its own plant-, lin said. at this time we �tiseated bypas$ing„on r�laat i�itd' tying: into Y sewer According, to its” lawyer, the Mabelvale-P�lexander- district have a highly: qualified per- son." •iirfc. owned. -by theoMabelvale- spent "sevalhundrethf i Alexander sewer o- 'district. That wad t plan sand dollars" to expand its sys- Aemin Representatives -of , the Sewer systems and therPC&E 'ilritil last spring,.,,. ,`Little Rack raised its rates for,treat�;; antici.pation.ofShannon... , Hills tying on:: _ -Fare to meet next month, and theHills commission- ;. ,Shannon ers will -ask Little Rock to lower its price for treating sewage. "The whole thing depends on how much more can'people in. Shannon bills pay for utility 'service than people in Little ..Rock," Brown said. '• � 1320= B EX/ST. " V. L�� TIE w/B" I S ! r 12 LEVEE TOP � lti 13 ac.,POND 5' DE PTH) ti POND DISCHARGE WIER 753' x � •3 IFy DISTRIBUTION BOX :L xp •::: I i MANHOLE (TYPICAL j Ex15T B" LINE 7, CHLORINATOR : TIE �v/8" T.S. 8 V. RECYCLE LINE RECYCLE VALVES-�11�- RECYCLE PUMP r r• "`_� n w r —r 13201 Lir dC A NOTES: RECYCLE PUMP C LINE TO BE USED _ CNS DURING EMERGENCY LOW --FLOW PERIOD TO PROTECT PLANTS 1N FILTERS. TENATIVE LAYOUT SHOWN, SHALL BE SHA( MODIFIED TO MEET TOPOGRAPHIC SEW1 FEATURES OF PROPERTY. MPF lm T $4 a 44 O m Q) S O N N O O a) J L N b N A b N O 14 41 W 4J td W 4J 14 4J n4 1W T' [,d T O O A� W m ,V v a 4J .,4 4J U .A cd 1� b A �i 0) 34 0% -a k, N 30.00 20.00 10.00-- ALT. 'A' ALT.'S' ALT.'D' CONNECT. TO CONSTRUCTED SAND L.R.W.W. (I.32) WETLANDS 'FILTER ` SYSTEM ESTIMATED MONTHLY SEWER BILL - 6000 GALLONS 1- 2 IrW m � O (D N OOD d' NN T- I -- (1/!DW) U N 00 N N 0) Cfl N C\1 LO d' N N C\J 0 T C T ' T � S � o w T TT T �1J T T V J "I"t ■N STATE OF ARKANSAS rte`: r`� DEPARTMENT OF POLLUTION CONTROL AN '4• CONSTRUCTION ASSISTANCE DIVISION ¢8101 INTERSTATE 30, P.O. BOX 8913 ar LITTLE ROCK, AR 5 72219-8913 PI : (501) S74:2RX AX: (501) 562-1541 December 18, 1992 Reggie A. Corbitt, Manbqer Little Rock Wastewater 221 E. Capitol Little Rock, Arkansas 72202 Re: CS -050709-03 Shannon Hills W., S. & F. Improvement District #3 Dear Mr. Corbitt: This letter is in follow-up to our September 30, 1992 correspondence regarding the Shannon Hills Facility Plan. We have Evaluated the information in the facilities plan, as well as, the additional data from the consulting engineer for Shannon Hills, Mr. Tim Lemons, PE, of Bond Consulting Engineers, Inc. (hereon referred to as "The Consultant"). By this letter -we will attempt to address the questions in your letter of September 10, 1992 and explain our position. The following is a response by item number: 1. The discharge limits for Shannon Hills have been adopted by the Arkansas Department of Pollution Control and Ecology (ADPL&E) Water Quality Management Plan (WQMP). The Construction Assistance Division (CAD) is guided by the water quality limits determined by the Planning Section of the Department's Water Division. Requests for reevaluation of the limits imposed by the Water Quality Management Plan should be addressed directly to the Chief of the Department's Water Division, however, a response to your comments is provided below. Based on information provided by the Water Division, the discharge limits proposed for Shannon Hills will meet all water quality regulations. These limits will maintain a 5 mg/l dissolved oxygen level in the receiving stream for winter months. Because the water shed area above the point of discharge of the receiving stream is less than 10 square miles, a 2 mg/l dissolved oxygen standard was used for summer months. As to heavy metals limits, there is no State standard.for heavy metals. Any required limitations are based on the results of biomonitoring and local pre-treatment standards. Because Shannon Hills is classed as a minor discharger and there is no known or suspected industrial discharge, dechlorination and biomonitoring will not be a permit requirement. r -2- In summary, the discharge limits developed for Shannon Hills are in compliance with all State Water Quality Standards and the limits are not presently under consideration for change. 2. We are not a party to the contractual arrangement between Shannon Hills and Sewer Improvement District #142; however, it appears that the direct and indirect costs are appropriately addressed in the economic comparison of alternatives in the facility planning document. Shannon Hills has apparently entered into a settlement with District #142 for $100,000. 3. Again, it appears that the direct and indirect costs are appropriately addressed in the economic comparison of alternatives in the facility planning document. 4. The explanation from Bond Consulting Engineers indicates that reference was made to a Benton, Louisiana facility for estimates on cost of operation. Although these costs may appear to be low, the overall sewer budget appears adequate to operate the system. By our analysis, a projected increase of three (3) times the engineers estimate for cost of operation only results in an increase of the total Present Worth (PW) by only $97,000 for a total.PW of $2,237,321.00. Therefore, this issue alone does not change the selected alternative. In a review of the capital and annual costs associated with the two primary alternatives, it was determined that.annual costs for the wetlands alternative would have to increase by $25,861.00 per year before the connection to Little Rock became the most cost effective alternative. A summary of the review is enclosed. 5A. The approach used by "the consultant" appears to be a conservative and logical approach. The engineer used a typical textbook design parameter instead of the unusually low analysis from an influent grab sample. 5B. True, I/I data appeared to be flawed, however after further examination we estimated that reducing waste water flows to as low as 42,000,000 gallons per year (which is the amount of water used by Shannon Hills last year) only results in reducing the PW total for Alt. A to $2,435,309.00. The consultant reported that they contacted the manufacturer of their wastewater flow meter and had determined that the meter was working properly. After making allowances for a time period during which a line across otter Creek broke allowing a large inflow, they found that the measured average flow data was consistent with the design flow they had chosen. The explanation and data appears to be acceptable. 6. Arkansas did investigate the apparent problems that Louisiana was having with constructed wetlands and it was determined that the design criteria that Louisiana was using differed significantly from that used in Arkansas. The Arkansas design used a much larger area and a lower cross sectional loading. Louisiana has since adopted design criteria more in line with that used in Arkansas. -3 - As you know, Pollution Control and Ecology has an ongoing program for evaluating the effectiveness of the constructed wetlands treatment process. The latest, preliminary findings from the program have been shared with the consultant. These findings indicate that shallower beds should be considered. Although "Constructed Wetlands' (CW) are relatively new, it is a proven treatment concept. As with any new process, mechanical or otherwise, the design parameters are being refined as experience dictates. As always, the system requires appropriate operation and maintenance. ADPC&E through the support of EPA Region 6, has funded several CW projects in Arkansas. In addition, our Construction Assistance Division and Water Division engineers have worked closely in an effort to refine minimum construction guidelines for CW in an effort to avoid some of the design and operational problems encountered in Louisiana. We believe our minimum design guidelines are acceptable and presently have no basis upon which we could justify the dismissal of CW technology from consideration. 7A. Public health is of utmost concern; however the proposed CW for Shannon Hills meets Department design guidelines for disinfection facilities and Water Quality Standards for secondary contact recreation.. Water Quality Standards for primary and secondary contact recreation are considered adequate by the Department of Health for the protection of the public health. However, in response to your comments, the Construction Assistance Division will recommend to the Water Division that disinfection requirements be included in the modified permit to meet primary contact standards, rather than the secondary standard that Shannon Hills would otherwise be subject to. 7B. Any waterbody (freshwater or wastewater) has the potential to provide habitat for mosquitoes or other vectors. NPDES permits do not directly address the regulation of vectors at wastewater treatment facilities, however adherence to State standards and guidelines in the design and operation of the facilities will minimize potential adverse impacts. it is our opinion that the project should not be turned down based on the possibility of problems with mosquitoes and other vectors. 7C. We agree that the elimination of point source pollution is desirable. However as long as Shannon Hills, in working with an approved consultant, can reasonably design and construct a facility that can meet state water quality standards, the present rules & regulations under which we operate do not allow us the flexibility to deny Shannon Hills a loan on this issue alone. 8. To participate in the RLF program, an I/I Study, Facility Plan and Environmental Information Document as well as legal services are required. The consultant considered the legal costs for the negotiation with S.I.D. #142, the development of the Facility Plan and the review of contract documents for connection to -4 - Little Rock. Construction costs were attributed to the abandonment of the existing wastewater treatment facility. The estimated costs for these and other items noted in the Facility Plan for connection to Little Rock may appear to be high, however, it is my opinion that the costs provided in the Facility Plan appear to be reasonable for participation in the RLF program. 9. I agree that the preliminary design did not account for BOD loading with one cell out of service. Although the preliminary design did not incorporate our latest guideline criteria, the consultant for Shannon Hills used conservative assumptions for his design and this issue can be easily remedied with minor design changes. The total wetland area proposed by the consultant will meet the minimum criteria for redundancy. Therefore, I conclude that the "preliminary design" can reasonably meet our guidelines for redundancy. Also enclosed is a copy of the response to us by the consultant pertaining to your questions. Other issues concerning this project may result in further delays or penalties to Shannon Hills from the RLF program or enforcement. However, the issues pertaining to your correspondence of September 10, 1992 do not in our opinion provide sufficient evidence for project dismissal. To update you on the current project status, the environmental review of the Shannon Hills project has not been completed and is now not scheduled to be completed until possibly June or July 1993. Shannon Hills plans to obtain a special use zoning permit from Little Rock and would have until June 14, 1992 to obtain the permit and still meet the present Memorandum of Agreement schedule. Sinc ly, Paul Acre, P.E. Project Engineer PA/MH/paa Enclosure cc: Charles Brown; Brown and Associates Attorneys Don F. Hamilton; LRWWU, Staff Attorney October 1, 1992 B Mr. Paul Acre, PE Arkansas Department of Pollution Control and Ecology 8108 Interstate 30 Post Office Box 8913 Little Rock, AR 72219-8913 RE: Shannon Hills Water, Sewer & Fire Protection Improvement District 1#3 Dear Mr. Acre: This letter is in response to a letter of comments and objection sent to your office from Little Rock Wastewater Utility, dated September 10, 1992, as pertaining to the Facility Plan submitted for the Shannon Hills Water, Sewer and Fire Protection Improvement-bistrict #3. Enclosed with this letter is an Addendum to the Facility Plan for the above said entity. In this addendum the fol- lowing items are discussed: S.I.D. #142 -connection fee; rebuttal to LRWW comments as pertaining to proposed com- promise service charges; rebuttal to NLR comments as per- taining to statement concerning constructed wetlands cost unrealistically low; rebuttal to LRWW comments as pertaining to unreliable data collected for design; rebuttal to LRWW comments as pertaining to opinion that constructed wetlands an unproven technology; comments related to public health issues; comments as pertaining to statement by LRWW as per- taining to connection to LRWW allegedly resulting in con- struction cost being too high; and comments to LRWW opinion of non-compliance with ADPCE and Redundancy Design Guide- lines., as pertaining to Alternative B, Constructed Wetlands. Please include this addendum in your files. Upon your review_, the -addendum will become part of the Facility Plan previously submitted. Sincerely, Tim ,me ons, PE Enc. cc: Mike Chandler, ADPCE; Mike Hood, ADPCE; Charles Brown, Attorney; Jim Ort, SHWSFPID#3; Hugh Christophel, SHWSFPID#3; John Griffin, SHWSFPID#3; Don Hightower, SHWSFPID#3 .n1/ Bond Consulting Engineers, Inc. ff ADDENDUM #1 FACILITY PLAN (Dated April, 1992; Revised August, 1992) SHANNON HILLS WATER, SEWER & FIRE PROTECTION IMPROVEMENT DISTRICT #3 October 1, 1992 This addendum shall be included with, and become part of, the Facility Plan document presently on file with CS -050709-03, at the Arkansas Department of Pollution Control and Ecology. Item 1. S.I.D.#142 Connection Fee Attention is called to pages 131 thru 132 of the Facility Plan. for discussion on this topic. At the time of preparation of this document, S.I.D. #142 and the Shannon Hills Water, Sewer and Fire Protection Improvement District #3 (SHWSFPID#3) were negotiating a settlement on the said connec- tion fee. Enclosed you will find a letter ad- dressed to the design engineer from Charles Brown, attorney for SHWSFPID#3, dated September 21, 1992, addressing the proposed settlement. Simply put, SHWSFPID#3 will pay a one time, lump sum fee of $100,000.00 to S.I.D. #142 for full satisfaction of the agreement. If SHWSFPID#3 decides at a future date to connect to S.I.D. #142, the remain- ing $181,000.00 would be paid as discussed. To substantiate this claim, attention is called to an approved and signed agreement, between these parties included with this addendum. Item 2. LRWW Proposed Compromise-Servi-ce—Charge Attention is once again called to the letter from Charles Brown, dated September 21, 1992, for an indepth discussion on this topic. It should be pointed out that the $1.06 per 100 cubic feet sewer treatment charge proposed by LRWW, as discussed in the Facility Plan,-is'tentative and has not approved by the Little Rock -Board of Directors. jQ� �I r, 1992 Item 3. Constructed Wetlands Cost The LRWW letter is critical of the estimated amount budgeted annually for treatment 0 & M for Alterna- tives A and B. First, the laboratory cost estimated for Alternative B are based on the requirements associated with the existing permit, taken once a month. The present cost per month for testing is $60.00. However, if additional testing is required, the added cost can be covered under Miscellaneous items of the annual estimated collection 0 & M (Page 128, Facility Plan). Second, LRWW questions the Site Maintenance item of the 0 & M Estimate for Al- ternatives A and B. From inspecting Table 2, Page 129,.one will discover that site maintenance is the same for all three alternatives. Although the Con- structed Wetlands and Sand Filter systems will require more "site maintenance", in which items are given in said table for mowing of levees, harvesting of plants and filter grubbing, with the connection to LRWW, -SHWSFPID#3 would be forced to do monthly inspection and maintenance of the 1 mile force main between the entities and air relief valves. Attention is called to the enclosed "Treatment Plant Expenses" as per- taining to the Town of Benton, Louisiana.�;constru4ed wetlands treatment plant. This plant continues to discharge effluent well below the preliminary limits set for SHWSFPID#3 but has a contributing population of 2,950 individuals. However, the estimated treat- ment 0 & M costs should be similar. The actual total costs for the Benton plant is $4,357.25, or $1.48 per individual. This cost includes phone, electric, gasoline, the repair of PH meter, regulator repair, film, slides, and ball bearing replacement for motor, none of which is stated in the Alternative B 0 & M estimate for SHWSFPID#3. It -should also be noted that Benton includes pumping cost in their treatment -costs. All pumping cost.associated with each altern- ative for SHWSFPID#3, is included in the estimated collection OM & R. However, these costs are included in the estimates for collection O,M & R for SHWSFPID#3. Still, the estimated treatment 0 & M for Alternative --B is approximately $2.00 per individual, well above that actual cost for the Benton plant. In short, the cost for mowing levees and plant harvest- ing, for SHWSFPID#3, could be added to the cost esti- mated for site maintenance, providing a budget of $1,640.00 for "SITE MAINTENANCE". Item 4. Data Collected for Design (a) Wastewater Characteristics. In the letter of September 10, 1992, LRWW discusses the statements of the design engineer presented on page 40 of the Facility Plan. According to LRWW, these results are questionable. LRWW may possibly be correct in that if one averages the collected influent sample data, from tests performed prior -to the development of the Facility Plan, the results are as follows: BOD (mg/1) 53.20 TSS (mg/1) 73.50 pH 6.80 Fecal (per 100 ml) 11933.30 As stated in the Facility Plan, this information is substituted with a much more conservative criteria for the simple reason of logic. Although the influent test data was collected over a period of days and remains somewhat consistent, this use of this laboratory data would be ludicrous. Therefore, the conservative criteria is developed and used as demonstrated in the Future Planning Analysis of the Facility Plan. The. use of more lenient data would not serve in the best in- terest of SHWSFPID#3. (b) I/I Analysis. As per the request of ADPCE, the design engineer has further investigated the flow from the SHWSFPID#3 as pertaining to the amount of wastewater originating from the collection system. According to the manufac- turer, the metering station has and is operating in a satisfactory manner. From November 15, 1992, to August 30, 1992, 55,068,700 gallons has flowed through the meter. This period represents 289 days, with a per person flow of 116.5 gallons per day (based on 1635 people). However, a major sewer line break occured at the Otter Creek -crossing in December, 1991. During this month, 9,314,600 gallons flowed thru.the meter. Since this number is not representative of the remaining month, we must deduct its numbers from the analysis. With this in mind, 45,754,100 gallons were sent thru the meter in 258 days, making the average 108.5 gallons per person per day. Therefore the design flow of 111.7 gallons per person per day is consistent with the actual flow. Item 5. Constructed Wetlands Unproven Technology In the LRWW letter; attention is called to a letter from the Department of Health and Hospitals, State of Louisiana which states: "Effective immediately, all Item 6. district engineering staff are NOT to approve any more Rock Reed Filters/Constructed Wetlands until they are further evaluated." It seems apparent that LRWW may be attempting to discredit the Con- structed Wetlands systems based on this remark. Upon further investigation, the concern expressed in Louisiana was not to question the ability of the constructed wetlands system, but to assist the Louisiana Department in the implementation of stan- dard design guidelines for this source of treatment. Unlike Arkansas which has previously established strice guidelines for design, Louisiana was allow- ing the construction o these systems in almost any form submitted. In essence, there were a number of variations of the constructed wetlands following little to no design guidelines. On the other hand, ADPCE has cautiously developed the existing design criteria for constructed wet- lands prior to -the construction of the first system. According to ADPCE, Louisiana's new, tenative design guidelines almost completely mirror.those adopted by ADPCE sometime ago. Public Health Issues (a) Public Contact Issues. The comment expressed by LRWW, as pertaining to the health risk with the installation of a Constructed Wetlands, must be unaware of the present condition of the existing wastewater treatment facility operated by SHWSFPID#3. The facility presently in use has existed since approximately 1968. This plant is com- prised of a samll primary clarifier, settling pond, and a small source of aeration with an aerator placed in the pond. It cannot meet the NPDES discharge limits as presently imposed, the basic reason that SHWSFPID#3 is pursuing the selection of a treatment alternative. From examining monthly DMR data for discharge effluent, as listed in the Facility Plan, the average for BOD is 35.3mg l , and for TSS is 77.7mg/l, for -the existing treatment facility. Past records indicate that the aerator has only been in a consistent, full operating mode for only a short time. Although not included in the Facility Plan, the effluent BOD and TSS test results have been much higher in recent years. The present operator has performed minor adjustments to the treatment facility and has substantially lowered the effluent perimeters. Ironic to the stat"ements made by the author of the LRWW letter, the discharge point for the existing treatment facility is Otter Creek. Therefore, the residents in question have been receiving the effluent from a now "out dated" treatment plant for 24 years. To our knowledge, there are no significant health problems associated with the discharge as it exists. Since the proposed Con- structed Wetlands will be designed to meet the impending NPDES permit limitations, which are much more stringent than the quality of existing 'discharge into Otter Creek, the concerns expressed in the LRWW letter deserve little merit. (b) Mosquito and Other Pest Infestation. Concern is expressed in the LRWW letter as pertain- ing to the location of the proposed Constructed Wetalnds in respect to schools and major food distribution center, and the residential areas including Shannon Hills. Included in this addendum is a warranty deed which describes the proposed treatment plant location if Alternative B is selected. The facility would exist within a mile of the areas discussed above, however, the existing treatment facility, which has been in existence for 24 years, presently exists within 250 feet of the largest residential area in Shannon Hills. The proposed facility is planned to exist at a distance further than the existing facility. To out knowledge, there has not existed an abnormal mosquito or related pest infestation problem even with the existing system, which includes a faculative pond. Item 7. Cost for Connection to LRWW In the letter from LRWW, questions have arised as to the expense for each item. In this letter, it is assumed that by its content, the analysist which reviewed the Facility Plan does not realize that con- nection to LRWW would still require the abandonment of the existing treatment facility, as well as the two feet of pipe•to complete the connection. The legal fees listed for this alternative inlcude the negotiating with S.I.D. #142 as pertaining to the connection fee, legal resources necessary for the development of the Facility Plan, and legal services required for the review of the contract docuemnts associated with the construction of Alternative A, to name a few. The I/I study, Facility Plan and Environmental Information Document are all included in the $45,000.00 fee for this alternative. Irregardless of the alternative selected, these items are required for participation in the RLF program., as well as the requirement of a operations manual. BOND CONSULTING ENGINEERS, INC. JOB N0. 1010 S. REDMOND ROAD DATE E JACKSONVILLE, ARKANSAS 72076 PROJECT -- ,e YllCr, pori { Cf CSI F -17 I i ! t ! t - I I ! - Fr H- HFI 4 - LAO -7- X dF7. id - t "-. 4i-, 4-F -- _ _y '-�--_= =� c?_ra - V-weE+'DSS • -----�-----•- --•- - �--+ - ice- - - - . � 1 .. , ^. i � ~ - B BOND CONSULTING ENGINEERS, INC. JOB N0. 1010 S. REDMOND ROAD DATE JACKSONVILLE, ARKANSAS 72076 PROJECT LL I = r I LL c kk 77 +117 p _ k i 5 I I 14 I.'���?7. � #�r�-� �°57�r�7�•.--:-�r�i''�vZ�SdaZs�._r'i�o�i�.( mv I3'vD Acre, ar�*-f � ! � �-ccs � art �'I� �dlC �Vr� ��ie►ss. � �+D _ _�CaC —PQ.W Off c.t ' Of Charles A. Brown, P.A. Sandra L. Sherrod September 21, 1992 �24a&l (LA 13zo�n, ./ C -7q. Brown & Associates, Attorneys 3UIrC'$TO U191011 11ATI01VA1. rLAZA 12.1 WEST CAPITOL AVENUE LITTLE ROCK, ARKANSAS 72201 TELEPHONLr 501.37,4.7582 PAX 301.374-7504 Mr. Tim Lemons Bond Consulting Engineers 1010 So. Redmond Road Jacksonville, -AR 72076 RE: Application of Shannon Hills Water, Sealer & Fire Protection Improvement District No. 3 for Constructed Wetlands Treatment Facility with Arkansas Dept, of Pollution & Control Dear Tim: S recently faxed to you a copy of the Little Rock wastewater Utility's objections, which they have filed with the Department of Pollution Control. & Ecology. S asked the manager of the Waterworks Sewer Department at Shannon Halls to contact you to get your comments upon matters dealing with the engineering portions of their complaints I have also informed you I would write you a ,letter regarding Items No. 2 and No. 3 on the second page of their comments, insofar ap I am the principal person who has knowledge about those two points. As to paragraph 2: As I previously informed you, an agreement has been reached between the counsel for Shannon- Hills Water, Sewer & Fire Protection Improvement I?istrrict No. 3, and Mabelvale-Alexander Sewer IRIProvement District Na, 142, For the settlement of claims between the two Districts. You will recall that -historically, Mr. Tommy Bond, who was then the engineer for the District, was contacted by the engineers for District 142 and, Mr. off.ic?al Hoard action, r, Band requested that the engineers for District; 142 enlarge the size of the pipes being placed under Interstate 40 to accommodate the anticipated 'sewage from tje Shanno-i'Hills and the south Otter Creek drainage area in anticipation of'a future tip -on by Shannon Hills to the outfall lines. No formc-1 acceptance of Mr. Hondas request was ever made by the Sharron H -FIs Bo&rd, but the Board W -2- FOR and in `'fact, became knowledgeable and did kdino re pOnse toect the the sizing, emphasis from the during 1985 through o r did negotiate 9 Department of pollution Control & Ecolo9Yr our response to District 142 and the Little Rock Waspts mentioned, cility to tie into Dof 1991, their lines ainfra, during ll of 1990 and the spring paragraph 3, durin ically thwarted. this effort was econom However, Shannon Hills No. 3 has recognized some responsibility elinesi under for the H° of the size of District the increasing were requested to pay approximately a Interstate. We originally sizin but negotiated an half a million dollars for the up- g' to pay agreement, in anticipationthe he 07.676% ontheunpaid $281,000, plus interestcommE,ncing when District 3 tied balance, payable $36,000 per year, onto District 142's lines. The Little Rocward k Wastewater Utility's comments o reach a mi directed g eementowith the efforts of Districtutwo tont contingencies. District 142 based up (a) in event that the Constructed Wetlands are approved; or The Constructed Wetlands are disapproved and we have to (b) tie into the City's treatment facility and use District 142's lines. Attached Exhibit "A" is an unsigried copy of the agreement that has been approved by the attorneys and should be executed by both oct ber 28, parties soon. Essentially, what it states is that by QO° of the from deposits on hen riding the District line in�t:he ll origi al $100,000 onstruction increased costs of expa g ations that No. 3 has to District in full satisfaction of an oblig & EcolocY� and, Distract 3 142. In the event the Constructed Wetlands Treatment Facility is sat�.sfactory to pollution Control concedes satisfactorily 'with construction, the $100,040 ends all payments to No. 142 rove the in the event that pollution Control & Bed Wetlands nthen ot pparagraph Shannon Hills application for Constructed Wetlands,the nal $261,000 be reinstated and even 5 provides that the orifi• and a credit of $100,000 be g. contract terms reinstated, and over a period of District No. 3 on the $281,000 obliq'jtionr aid. together with eight (8) years the remaining $181.000 will be paid, $30,4n 7.676% interest, in annual installments enc is my inevent that we do have per year. This latter conti�ng Y expanded lines for to tie into Dttleict Rock42's lines WastewateraUtilityd use tTreatment plant. service to La. -3 - As to comment No. 2, there will be no operational costs payable to District No. 142 if the Constructed Wetlands Treatment Facility is approved by PC&E. Contrary to Little Rock Wastewater Utility's comment, there will then be no continuing obligation for the balance of the $181,000. As to Objection No. 3: This has been responded to previously, but probably to another division or department of the Department of Pollution Control & Ecology. To put it in perspective, on November 19, 1985, when negotiations were in process with the Little Rock Wastewater Utility to reach a contract for the treatment of Shannon'Hills sewage, which negotia- tions were prompted by the requirements of the Department of pollution -Control. & Ecology, a request was made to reduce Little Rock Wastewater Utility's sewer treatment charge from the "150% of the in -city rate" for out -of -city sewer service connections. On that date, the Little Rock Wastewater Utility stated by letter that it was necessary for the Little Rock Wastewater Utility to receive 150% of the "in -city" rate for treatment of out -of -city sewage. A copy of that letter is attached as Exhibit "B". As a result of the requirement to tie into the City of Little Rock Sewer Treatment Plant, negotiations continued with both District 142 and the Little Rock Wastewater Facility, and on June 60 1989, District No. 3 entered into a contract with the City Board of Directors and the Wastewater Committee based upon that representa- tion and based upon Ordinance No. 15242 of the City of Little Rack, which provided that the in -city rate would be 73¢ per 100 cubic feet, and the out -of -city rate would be $1.10 per 100 cubic feet. See attached Exhibit "C". , This contract for the treatment of Shannon -Hills sewage was to take effect when Shannon Hills tied into District 142's line and the Little Rock Wastewater Utility began treating the sewage. It is inherent in the contract that such event had to occur to trigger the payment of any sums. After Shannon Hills commenced work in reliance upon the $1.10 per 100 cubic feet rate to be paid to the City of Little Rack, District No. 3 established its budgets accordingly with various regulatory institutions. The Little Rock Wastewater utility and the City of Little Rock undertook a rate study by Alvord, Berdick & Howson in April, 1990. That study included in the cost of the various outfall lines and treatment plants all of the funds paid for the trunk lines and treatment plant, although in excess of $25,000,000 had been paid for such improvements by a direct grant through the Department of Pollution Control & Ecology. The Wastewater Utility's expert included that cost in its amortization to justify an increase in the out -of -city rates for a projected rate of $2.20 per 100 cubic feet. see page X/4 and X/7 to arrive at the $2.20 -4 - per 100 cubic feet, plus $2.80 per 5/8" metered customer monthly fixed charge. Even with this study and in spite of it being based upon the grant as being part of the cost of the system for which Little Rock Wastewater Utility expected a return, the City of Little Rock amended its ordinance previously relied upon by District No. 3, on March 51 1991, to even exceed the study's recommended charge for out -of -city customers and adopted the rate of $2.48 per 100 cubic feet. See the Exhibit of Ordinance 16018, attached as Exhibit "D". It was at this time that Shannon Hills realized that the City of Little Rock, regardless of what Little Rock Wastewater Utility had stated was taking the position that it could raise rates without relation to any prior agreements on the percentage to be paid by out -of --city customers, and that Little Rock could charge rates based on anybody's contributions, and without regard to the economic condition of the area served, and without regard for its own previous contracts and representations. If District No. 3 tied into the sewer system of the City of Little Rock, then the City of Little Rock's Board of Directors could set rates at their whim and pleasure, and the Shannon Hills users would be unrepresented on the City Board. It was at this time that the decision was made to seek ay feasible alternative to subjecting the Shannon Hills sewer users to such economic stress by the City of Little Rock's Board of Directors. The application for the constructed Wetlands Treatment Facility was commenced. Sometime in June or July, 1991, culminating in an Ordinance No. 16080, dated August 6, 1991, the City Board of Directors decreased the out -of --city rates to 150% of the in --city rate of $1.06. The out -of -city rate is $1.59 per 140 cubic feet. See attached Exhibit "E", Ordinance No. 16080. District No. 3 is not aware if such action was taken by the City Board of Directors because of the pending. Wetlands application; or for other reasons, but it certainly fits the time frame. Shortly after the August 5, 1991 Ordinance, the Little Rock Wastewater Utility inquired why District No. 3 had not tied on for sewage treatment with the Little Rock Wastewater Utility, and District 3's objections were voiced. Multiple negotiations have been undertaken and although the City of Little Rock rate is $1.59 per 100 cubic feet at the present time, the Wastewater Committee of the Little Rock Wastewater Utility has indicated that they would recommend a rate comparable to the in - city rate. The Sewer Committee would ask the Little Rock Board of Directors .to make an exception._ because Shannon Hills will also have the cost of collecting and maintaining its collection system above the cost charged by the Little Rock Wastewater Utility for merely treating the sewage. A condition of such settlement was that the Shannon Hills users would be required to acknowledge that they would have to pay any rate that may be ultimately set within the next 2 or 3 years, and thereafter, by the Board of Directors of the -5 - City of Little Rock. No assurance can be afforded No. 3 that the City Board of Directors would not raise the rates "willie-nillie" and for the sole interest of the City -of Little Rock. District No. 3 prefers to proceed with the Constructed Wetlands application and be subject to the regulation of the Department of Pollution Control & Ecology rather than to subject itself to the possibility of economic strangulation by the Board of Directors of the City of Little Rock. It is no secret that the City of Little Rock's Board of Directors are refusing to grant service to out -of - city, and out -of -county customers for water, and now sewage treatment, unless the applicants consent to annexation to the City of Little Rock, regardless of the state of the law permitting annexation across County lines. Therefore, we feel that paragraphs 2 and 3 of Little Rock Wastewater utility's,gomments and objections dated September 10, 1992, are: First, erroneous in its descriptions of the.District's obligations; and, Secondly, somewhat misleading and an omission of the City of Little Rock's Ordinance that is in effect at the present time, and omits any reference to the condition for a possibly short temporary "in -city" rate, that the City of Little Rock's Board of Directors will have ultimate unfettered authority over Shannon Hills rate making, and that No. 3 can expect such an increase in 2 or 3 years. I trust that you can use whatever portion, or all, of this letter that is necessary to respond to the comments and objections promulgated by the Little Rock Wastewater Utility's letter. Yours very truly, az, �, /" !� . /, g -, - — Charles A. Brown CAB:rr Encl. cc: Secretary Shannon Hills Water, Sewer & Fire Protection Improvement District #3 -Q.W OffLcel of i Charles A. Brown. P.A. Sandra L. Sherrod September 24, 1992 Cga7-f� bq. Dzocvn, (I -D . c7T. Mr. Paul Acre, P.E. Arkansas Department of Pollution, Control & Ecology 8101'Interstate 30 P. 0. Box 8913 Little Rock, AR 72219-8913 Brown & Associates, Attorneys SUITE 1970 UNION NATIONAL PLAZA 124 WEST CAPITOL AVENUE LITTLE ROCK. ARKANSAS 72201 TELEPHONE 501.374-7582 FAX 501.374.7584 RE: Application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for Constructed Wetlands Approval - Response to Rumor that the City of Little Rock May Sue the District Dear Paul: Mr. Lemons indicated that he had heard that a rumor was being bandied about by the objector, City of Little Rock, that the City of Little Rock would sue Shannon Hills dater, Sewer & Fire Protection Improvement District No. 3, and would tie-up its revenues. Since the attorney for Little Rock Wastewater has previously alluded such to me, and I've alluded that we might sue them, I think. it ought to be placed in proper prospective. Your department has been furnished a copy of the contract dated June 6, 1989, which has -a self determination date unless renewed at the end of 15 years from June 6,'1989. A copy of the contract is also attached. Attached to this letter is a November 19, 1985, letter from Little Rock Wastewater that was the basis for the agreement of June 6, 1989, for Shannon Hills to pay 1 1/2 times the in -city rate for service. You will note on page 2 of the June 6, 1989 Contract in paragraph 1, it is permissive for Shannon Halls to connect to the Little Rock system. The first full sentence shows the permission; and on page 3, paragraph 3{a}, the first sentence provides that the monthly sewer service charges will be for service provided by the Little Rock Wastewater. If there is no service provided, there can be no monthly charges, obviously. -2 - Shannon Hills entered into the contract, as above mentioned, based on the City of Little Rock's assurance that 150% of the in -city sewer rate would be the maximum charge. You will note that paragraph 3(b), of the attached Little Rock Ordinance No. 15,242 sets forth the in -city rate of 73¢/100 cubic feet, and, it also sets forth the out -of -city rate of $1.10/100 cubic feet. At the time the contract was entered into, that was the applicable Ordinance and Shannon Hills understood that when necessary the in - city rate of the City of Little Rock would be increased and that future rates to Shannon Hills would be 1 1/2 times that in -city rate as changed. During our construction, preparatory to tieing into the City of Little Rock's lines, the Little Rock City Board of Directors unilaterally breached the implied and essential term, that out -of -city customers would pay 150% of the in -city rate. Attached is Ordinance No. 16,018, wherein you will note that on March 5,. 1991, the in -city rate was set at $1.06 per 100 cubic feet, and the out -of -city rate was set at $2.48, or 233% of the in - city rate. It was then that the Board of Commissioners of Shannon Hills realized that the City of Little Rock had breached the basic premise upon which its contract with them was bottomed, and that the City of Little Rock claimed power to set out -of -city rates without regard to previous commitments, contracts, and fair dealing. In reliance upon this breach, Shannon Hills Board proceeded with the Constructed Wetlands application knowing that the citizens of Shannon Hills could at most only pay the estimated $7,000-$7,500 per month, based on an estimated infiltration rate of 20%. The March 5, 1991 Ordinance would have required the monthly payment of from $15,750 to $17,000 per month, even assuming a minimum 20% infiltration rate. We began having indications that a 20% infiltration rate might not be adequate. Obviously, the citizens of Shannon Hills cannot pay the sums that would be required by the City of Little. They had just gone from an average bill of about $20.00 per user to an average bill in excess of $4x.00 per user, just to meet the requirements of the June 6, 1989 agreement. Some alternative has to be available. It is true that on August 6, 1991, the City reduced the out -of -city rates back to 150% or $1.59 per 100 cubic feet. See .attached Ordinance No. 16080, which would have increased Shannon Hills' monthly payment, assuming the minimum infiltration rate, to more than $10,100 per month. This additional increase in itself is a sizable bill when added to the previous increase. Therefore, as you can see, Shannon Hills has relied upon the breach by 'Little Rock When they raised the rates to 233% of the in -city rate, that they expended money and were prepared to file suit to cancel the contract and believe they would be successful. 'Obviously, the reduction in price must have been an effort to correct their previous abuse of the contract, at least an effort to return to a good faith understanding with other parties. We have -3 - been informed that if a reduced amount were temporarily agreed upon, that Shannon Hills would have to acknowledge the authority of the City of Little Rock to set the out -of -city rates at any price they want to at any future date decided upon. obviously, to abdicate rate making to the Board of the City of Little Rock would be contrary to the Board's Statutory duty to act in best interest of the District's users in Shannon Hills and such should be permitted to occur only if forced to do so by the Department of Pollution Control & Ecology. It is Shannon Hills' position that the City of Little Rock first breached the agreement and has estopped itself from relying thereon. Secondly, no monthly charges could be recovered even if a suit for damages occurred. Thusly, if by chance they sued for damages, the only monetary damages to which they would have been entitled was a tie -on fee of $8,000, as mentioned in paragraph 2. Since no one is connecting, it is our position that nothing is due for a tie -on fee. It was a permissive tie -on to begin with. The City of Little Rock has suffered no monetary damages by our failure to tie on. . We, therefore, believe that their rumor is merely an effort to disrupt this application. we have advised the engineer that if something needs to be placed in the application as an estimate of damages, that $8,000 is the only stated damages that could possibly be awarded. We have proposed to cancel the agreement with the City of Little Rock by ceding to them that part of the collection system that is located within the City limits of Little Rock, Pulaski County, Arkansas. This may be a valuable consideration to them. They are just not able to handle the collection and sewage treatment of the area at the present time. They seem to want that service area. I hope this adequately meets your concern, if any, as to the possibility of any suit by the City of Little Rock based on the June 6, 1989 contract. We look forward to continued progress in the Constructed Wetlands Treatment Application. Yours very truly, A L ",;;; /�, � //" - , Charles A. Brown Attorney for Shannon Hills Water, Sewer & Fire Improvement Dist. No. 3 CAB:rr -4 - cc: Mr. Tim Lemons Bond Engineering 1010 So. Redmond Road Jacksonville, AR 72076 Mr. Jimmy Ort Shannon Hills Water, Sewer & Fire Improvement Dist. No. 3 10,000 High Road East Shannon Hills, AR 72103 .1 V V TOWN OF BENTON P. O. BOX 336 BENTON, LOUISIANA 71006 1318! 965-9589 Orme Or THc M•vc4t JANUARY B. 1990 TREATMENT PLANT EXPENSES JANUARY 1989 TO DECEMBER 1989 r $ 607.74 PHONE' 1�C ELECTRI 617.04 498.15 GASOLINE CHEMICALS 1.318.71 , DMR LAB REPORTS 1.002.00 REPAIR PH METER 51.46 REGULATOR REPAIR 38.92 13.48 FILM SLIDES 189.51 BALL BEARING FOR MOTOR 20-24 - TOTAL EXPENSES $ 4.357.25 Item 8. ADPCE & Redunancy De I appreicate the con to the PRELIMINARY desi constructed wetlands ADPCE guidelines. W ines, one will note that u ion", the following statem should consist of mu volume and/or areas 1 out of service. This wi en out of service as ne out causing an overload other words, ADPCE require o be included in the tota , when a cell is drained, a ter, the plants and bacte are probable to parish. e must include proper e scenerio as with the owever, rotation of cell use, of bed, is impractical. Enclosed you will fin s sup- porting the Prelimina in the Facility Plan. As wi , con- tengencies are added s case, two exist: first, th 30 lbs. BOD/acre/day, as oppo /day; and second, we -assume the pond at 75%, when act ed. The first contengency of the pond, while the secon filter size. This is demons on. Three of the four pro suffi- cient to treat the wa uide- lines. In conclusion, the Facility Pladdress the concerns expressed in a le ated May 28, 1992. These revisions aft dated August 31, 1992. Sincerely, Tim Lemons, PE Bond Consulting Engineers, Inc. Item 8. ADPCE & Redunancy Design Guidelines I appreicate the concern of LRWW as perating to the PRELIMINARY design, however, the proposed constructed wetlands will be designed to meet ADPCE guidelines. When inspecting the guidelines, one will note that under subtitle "Configuration", the following statement exists: "The system should consist of multiple cells. Total cell volume and/or area should be based bn one cell out of service. This will allow a cell to be taken out of service as needed for maintenance without causing an overload to the other cells." In other words, ADPCE requires the additional volume to be included in the total design volume, however, when a cell is drained, as implied in the LRWW letter, the plants and bacteria existing in the cell are probable to parish. The wetlands total volume must include proper contengency for worst case scenerio as with the isolation of a cell. However, rotation of cell use, with perodic drainage of bed, is impractical. Enclosed you will find computation worksheets sup- porting the Preliminary Design demonstrated in the Facility Plan. As with any engineering firm, con- tengencies are added to a design, and in this case, two exist: first, the pond loading rate is 30 lbs. BOD/acre/day, as opposed to 50 lbs. BOD/acre/day; and second, we assumed a BOD removal rate in the pond at 75%, when actually 85% may be expected. The first contengency causes the overdesign of the pond, while the second adds a contengency to filter size. This is demonstrated in the computation. Three of the four proposed filters should be suffi- cient to treat the wastewater as per ADPCE guide- lines. In conclusion, the Facility Plan has been revised to address the concerns expressed in a letter from your office dated May 28, 1992. These revisions appear in the Final Draft dated August 31, 1992. Sincerely, Tim Lemons, PE Bond Consulting Engineers, Inc. �` STATE OF ARKANSAS DEPARTNP —ST OF POLLUTION CONTROL AND ECOLOGY CONSTRUCTION ASSISTANCE DIVISION 8101 INTERSTATE 30, P.O. BOX 8913 r, LITTLE PHONE: ARKANSAS 6219-8913 FAX: (S01) 562-2541 U CT 2 JAB September 30, 1992 Mr. Reggie A. Corbitt, ManagerY Little Rock Wastewater Utility COPY 221 E. Capitol FILE Little Rock, Arkansas 72202 A RETURN Dear Mr. Corbitt: This letter is to acknowledge receipt of your letter dated September 10, 1992, regarding the Shannon Hills Facilities Plan. We appreciate your interest and concerns. We are continuing to evaluate,' the information in the facilities plan, as well as awaiting additional data from the consulting engineer. Faul 'erely, Acre, P.E. Project Engineer PA/la cc: Charles Brown Don F. Hamilton WORK ORDER FORM (for establishing priorities) SUBMITTED i DATE:kn I + DATE: 3 u ,2 TIME: I. ' > 0 TIME: DO FOR �-- AUTHO 1 � PROJECT/ITEM - (e-) K AA / AA t- 4 u �T-- I - � CC,-. � CL-�Cw��j � "\� ( e, r TYPE OF PAPER MQ NO. OF C 1 FORMATD ES _ w�� ,da,c-t AA,0 PAul u--� yecrj� d - :• PC -6 Revised 8-2-89 1. Meeting Date: lfiil� �0!l�1CJ3 2. Case No.: -5667 3. Request : ���%6� ��oj'� If� �`fI!'� ...... o f fJ �.4srfWh 77,e 77M r/771/7 I- ��t�1�tj 017 fn.s fr'-� �d�af d� .y�s'•�crr fi 2 4. Location: -rkt SW'14)5E •Iq Arab 4-L9 VJ01 335 R& q� �'1.• lN�� �1• ���,SE yf� SE Vq SSG+ren Ib , "f -I -S, 9. 13-W� Lirr Ie r'7Ur-1Cj F�f�ks�risrt3 ; Gen'-r�-iii 9(A l.bGw-rem fly mss zr, oi= -#�a Interye_L M of VIIAui �Ibtrt. 3 "d Cwn L�►.� 'pA� 5. DwnerApplicant- 5A �mnan �i�f f7 1�� .e,S��rer A-nd r +r"e I,r.� �fade�i��rt-t h"1 krc r 6. Existing Status: No.3r(,hA-rle,5 3rDWrJj A(rCAt ys.SAcreI VAde ytlo Ped sl �e'wAtc� h,ts been r-Ie�� Crr 7. Proposed WAs�J A4 A�tALAI FA r-, AIA VfOr 41 C� a�ShAAA0� � Is 8. Staff Recommendation:bwdjAS 8Ur,UPrrt IAtIPPfoPf'r rs: L&LAWe _... .. . 11or in ji v &)f In kc1ts+5 uF IVU CL+11_CAS Dr 9. Planning Commission Recommendation:'bB%Al,A-%1pjr�Anl� f?rovr��rE I_AAb v s t 10. Conditions o r I ssues Rema i n i ng t o be Reso I ved • *MA_)V f til ArIA Wl- 6501 . U � �r]A44ta pit�� aA�s� �� d'Ilt:y �tlapast� 1 v]t 15 I{UA 1 1 . Right -o f -Way 1 ssues : 1�i��-o�r'WIt`] d��C7�tGA �G,►• Pt,t' i�S r �t� �fr�, tri [oy •14 r�[ CVUj\N i -k" (1, as wln[Ll• k5 �4 Etrntr �r�kh (�est,rnt f, F .« _f IC 12. Recommendation Forwarded With: P - n -1 L - P l,r�n t,n G- ►m� 5 1 �► V OT V Az nin 13 . �V 0� ors: AZA'5 In4llC��lfm W �1 1��1�� r o f14� f l p4St%j 3. 1 A-6 Ak A-V' CW�1Vj; a Am at mw bNjtb o �On ►`n >r,�nit Rnc�. and Sh+�n� Malt 14. Neighborhood P l z n: 10 (A� -, U \(-U �O(r A "kA w �ait �,� S kA-NAC Wt�t 15 - 6 -Vit -IM Vv LL r it QOCV 5 W&,SVVJkW 121-5 �f-i-A WORK ORDER FORM (for establishing priorities) SU M HED QN DI JF Qbl DATE: �-3 �i DATE: I TIME: r 13 TIME DO FOR NA C,_c a PROJECTIITEM TYPE OF PAPER NO. 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Brown, P.A. Sandra L. Sherrod April 21, 1993 Mayor Jim Dailey, and Board of Directors of Little Rock City Hall Building Little Rock, AR 72201 Brown & Associates, Attorneys SUITE 1970 UNION NATIONAL PLAZA 124 WEST CAPITOL AVENUE LITTLE ROCK ARKANSAS 72201 TELEPHONE 501-374-7582 FAX 501.374-7584 Re: Appeal of Denial of Conditional Use Permit Application of Shannon Hills Water, Sewer and Fire Protection Improvement District No. 3 of Saline County, Planning Commission No. Z- 5664 Dear Mr. Mayor and Directors, Please accept this letter as the appeal of the action of the Little Rock Planning Commission of the application for a Conditional Use Permit for the construction of a "Constructed Wetlands" Wastewater Treatment Facility. Attached is the required copy of the planning commission application indicating the denial action and the application is properly executed by a member of its staff. Yours very truly, Charles A. Brown. ��- Attorney and Agent for Applicant, Shannon Hills Water, Sewer and Fire Protection Improvement District No. 3 of Saline County, AR. CAB/cb cc: Mr. Dana Carney Mr. Hugh Christophel, Chr. APPLICATION FOR CONDITIONAL USE PERMIT Zoning Case File No. Z-� Planning Commission Meeting docketed for. ALU -1, 19S 3 at - ix. 30 P.M. Application Is hereby made to the Little Rock Planning Commission pvrsuanl la the provisions of Act 186 of 1957, Acts of Arkansas, as amended, and Cha pler 36 of Liltle Rock, Ark. Rev, Code (1988), as amended, requesting a Conditional Use Permit on the following property: Address: No address available - undeveloped General Location: At the North end of Forest Trail, Shannon Hills, Ark. Legal Description The SWi , SEi and the West 330 feet of the NJ, SEi, SEi , Section 16, T -1-S, R -13-W, Little Rock, Pulaski County, Arkansas Title to (his properly is vested in: Shannon Hills Water Sewer & Fire Protection 10,000 High Road East (Name) Imp. Aist.$3 Mablevale, AR 72103 455-3195 (Address) (Telephone) Subject property Is presently zoned; R-2 A Conditional Use Permit Is roquesled Io allow use of the properly for:_ Wastewater treatment There (are) (are not) private restrictions pertaining to the proposed usE. utilik It is hereby agreed that lite required filing fee will be paid Inimedialal and IIIe posling of the sign furnished will be accomplished as required. Applicant (owner or authorized agent): Charles Br n, Attorney 124 West Capitol:, Suite 1970 Address; Little Rock, AR. 72201 Telephone: 374-7582 Planning Commission_ 19 3-a -f (3t5nJitiens-of Appy: Board of Directors Approved: 9 Ordinance Number: ' Conditions of Approval: April 19, 1993 13401 Meyer Road Mabelvale, AR 72103 Little Rock Board of Directors Little Rock, Arkansas Gentlemen= We are writing to express our opposition to the proposed Shannon Hills sewer treatment facility located just west of Meyer Road and Sheila Lane. As we understand the proposal, the sewer plant will be located in Pulaski County, yet service Saline County, thus yielding no benefit for us. We feel the facility will be a detriment to our neighborhood and property values. A perfect example is the lost sale of Ed and Christy Rachel's home at the end of Meyer Road. Mr. Rachel's business is forcing the family to move to Mississippi. Their perspective buyer backed out of the deal when it was learned that sewer ponds would be built in his backyard. Who wants to pay over $100,000 for home located next to a sewer treatment plant? We strongly urge you to deny the application. Sincerely, CAU4 Chuck Turley �, Sherry Tuff ley To the Little Rock Planning Commissioner: My name is Jake L. Johnson. I live at 13318 Meyer Lane, Mabelvale, Arkansas. I bought my home July 1992, and have done some remodeling, including a new lawn and a new driveway that cost me more than $8,000. My home is valued at over $180,000. If this system is installed, I feel that the value of my home would reduce dramatically. If I had heard about something like this before I purchased this house I would not have purchased it. I am strongly against this water treatment plant. Thank you. 15 Sheila Mabelvale, Ar. 72103 April 19, 1993 Little Rock Board of Directors City Hall Little Rock, Ar. Re: Shannon Hills Sewer Treatment Plant Gentlemen, I oppose building the Shannon Hills sewer treatment plant. My reasons are as follows: 1. The plant will be built approximately 1200 feet from my house and will greatly de -value our property. 2. The potential health problems it can create are a major concern. 3. I dread the problems caused when Otter Creek floods the ponds. I have lived in this neighborhood since 1976 and I know that it doesn't take a great deal of rain to cause this creek to overflow about a half a block area of Alexander Rd. When this happens raw sewage would be flowing over Alexander Rd. Your vote against this proposed project will be greatly appreciated. Sincerely, Kaye Wood Bill Falkner Little Rock Planning Commission: As a resident of the Chambers subdivision in the city of Little Rock, I would like to take this opportunity to register my opposition to the sewer treatment facility proposal by the city of Shannon Hills on property adjacent to our neighborhood. I am opposed to locating this facility as proposed for the following reasons: 1. An adequate sewer line is currently available to Shannon Hills, making a treatment facility redundant and a potential health and environmental hazard. 2. Locating a sewer facility adjacent to an established residential area would adversely impact property values and quality of life for our neighborhood. 3. Introduction of waste water into Otter Creek poses a threat to health and the environment. I urge the members of the Planning Commission to deny the conditional use permit request and urge the cities of Shannon Hill and Little Rock to agree to use the existing sewer line as originally planned. Your refusal of this permit request will help protect our families and property. Thank you, #20 Sheila Lane Mabelvale, Arkansas 72103 Bill Falkner H - (501) 455-0243 W - (501) 376-4791 April 14, 1993 Little Rock Board of Directors City Hall Little Rock, AR Gentlemen: Regarding the proposed sewer plant to be built west of Shelia and Meyer Lane in Pulaski County, my wife and I wish to go on record as opposing this sewer plant. We strongly feel this will be a detriment to our neighborhood and will certainly devalue our property. A. Robeson Carolyn Robeson daews T � Wa P I CC9,*7 )�l I S'.5 0/7 Ca vF�) 4z ,p yy �W4v .�.� .c5 r e s t dl� ,21 93 E 720-2 April 18, 1993 The Little Rock Planning Commission: Re: Preposed Sewer Treatment Plant for Shannon Hills; To Whom It May Concern: We, together, Jim & Anita Romine of 12711 Meyer Lane, Mabelvale, ArkansAs do strongly object to the idea of a sewage plant being built in our neighborhood. We feel that this is inappropriate for this property due to the discharge that might come from this project. We also feel that it might be dangerous to health. Other things which might be caused by this action is a fowl smell. The value of property owners would probably depreciate with a sewer treatment facility being built. Shannon Hills has been given the opportunity to tie on to the city sewer treatment plant. Let them do so. How can Saline County obtain the rights to our Pulaski County Property? If this is allowed, why not let our property be returned to Saline County and let our kids attend the Bryant School District. We wish to make this statement as part of record that we are strongly opposed to this action now or anytime in the near future. Yours truly, .1 1 - oal�� d774� k i & Anita Romine April 18, 1993 Little Rock Planning Commission To Whom It May Concern: This is in regard to the proposed Shannon Hills Wastewater Treatment Facility. We have listed a few of the major concerns we have about the Shannon Hills Wastewater Treatment Facility: 1. We live directly east of the proposed site at 17 Sheila Lane & Meyer Lane. The closest residential house in this area is only about 800 feet to the east. These homes are nice and we take pride in our neighborhood. We feel the value of these homes will be severely damaged by this treatment plant. 2. We are also concerned about the odor from the sewer and the noise from the pump. 3. The discharge from the plant into Otter Creek could be very detrimental to the property for miles downstream. 4. We would strongly encourage Shannon Hills to try to work out service with Little Rock. Sincerely, t�yce Grab e Peggy Grable 12724 Meyer Lane Mabelvale, AR 72103 A;Dril 19, 1993 Little Rock Planning Commission City Hall 500 West Martiu'zam Street Little Rock, AR 72201 RE: Zoning Case File No. Z--5664 Proposed Shannon Hills Wastewater Treatment Facility Please be advised that the undersigned Little Rock residential pro erty owners near the proposed site are opposed to the establishment of any wastewater treatment facility nearby. We are against the issuance of a conditional use permit for that purpose. W` agree with the Planning Commission Staff Committee that this would be an inappropriate use of this property and would not be in the best interest of the City of Little Rock. There would be both air and iter pollution from the facility and its presence would be a continuing nuisance to the nearby neiqhborhooc's and would degrade the czaality of living, the residential property nearby and the proposed Lark area. We recommend the conditional use permit be denied and that no further consideration be given to a imstewater treatment facility in this area. SHELTON R. NELSON =ELLE D. N 9 Sunrise Lane Mabelvale, AR 72103 April 19, 1993 City of Little Rock Department of Neighborhood and Planning 723 West Markahm Little Rock, AR 72201 Dear Committee: I am strongly opposed to the building of the Shannon Hills Wastewater Treatment Facility at the following location: The SW 1/4, SE 1/4 and the West 330 feet of the North 1/2, SE 1/4, SE 1/4, Section 16, T -1-S, R -13-W, Little Rock, Arkansas As you are aware the Staff recommends denial of this application as being an inappropriate use of this property, and not in the best interest of the citizens of the City of Little Rock. As a resident for 21 years in this area, I am concerned with the following: 1. Property val-ues would decrease because people don't want to live close to a sewer treatment plant. 2. Fear of neighborhood deteriorating. 3. Proposed 70 acre tract north of this property which has been donated to the City of Little Rock for future park development will be jeopardized. Also, the Wastewater Treatment Facility would violate this plan. I feel your decision not to allow this plant to be constructed at this location would be the correct thing to do. Sincerely, Oo c m &V&PY-" Don Runyan �/,� �_az g - ia-4, t_�_ �. CC�/� AV/ ia-4, t_�_ �. April 20, 1993 LITTLE ROCK PLANNING COMMISSION As residents of southwest Little Rock and Mabelvale for 33 years, we would like to protest the proposed Sewage Treatment Facility for Shannon Hills. We feel very strongly that a Saline County community should not be using land in Pulaski County for such a purpose. We own three acres on Meyer Road. Otter Creek crosses the southwest corner of our property, then flows on through several populated areas. We are greatly concerned for the health and safety of our families and our neighborhood, along with the nuisance factors of odor, noise, etc. This land lies in the 100 year flood plain, and this poses a serious threat as well. In addition to the environmental damage such a facility would cause, the residents of this area stand to suffer financially through loss of property values. Since Shannon Hills has access to the Little Rock Sewer Improvement District which is already in place, this would seem to be the best and most logical solution to this problem. We hope you will take our concerns into consideration and vote against allowing this facility to be built on this property. Sinc0reely G� .-Joe R. Sul an Dot W. Sullivan 13302 Meyer Road Mabelvale, Arkansas 72103 455-3329 April 19, 1993 Board of Directors City of Little Rock Second Floor City Hall Little Rock, AR I own the property at 13403 Meyer Road, Little Rock, AR. Recently I was informed that the community of Shannon Hills has submitted to the City of Little Rock, an application for conditional use in order to build a sewer treatment plant West of Shelia & Meyer Road in Pulaski County. The property being considered for this treatment plant is adjacent to the residential area in which I reside. I purchased this property at 13403 Meyer Road eight years ago. It is a beautiful country setting, all of the houses are well kept, each on at least two acres. We felt that this property would be an ideal place to raise our three children and a good investment as well. We had the advantages of city fire and police protection, and the comfort of rural living. I am adamantly opposed to this proposed treatment plant. I am convinced that the resulting odor and potential health hazard will not only make our lives unpleasant, but will greatly de -value my property. My understanding is that this treatment plant is designed for use by Saline County residents. Why then, is the treat- ment plant to be built in Pulaski County? I am certainly not an engineer, but since the proposed treatment plant would be in the flood plain, what will happen when the facility overflows? Where would the untreated waste go, Otter Creek? The environmental impact of this will be disastrous! I respectfully request that this application be denied. Re ards, Alan M. Long 13403 Meyer Road Mabelvale, AR 72103 NOTICE WAIVER AND CONSENT TO SHANNON HILLS WASTEWATER TREATMENT UTILITY KNOW ALL MEN BY THESE PRESENTS: That the undersigned, hereby acknowledges Notice of the Public Hearing to be held before the Little Rock Planning Commission on March 9, 1993, at 12:30 p.m. o'clock, upon the application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for the approval of a Conditional Use Permit to permit construction of a Wastewater Treatment Utility on the property described as: Southwest 1/4, Southeast 1/4, and the West 330' of the North 1/2 of the Southeast 1/4 of the Southeast 1/4 of Section 16, Township 1 South, Range 13 West, in Little Rock, Pulaski County, Arkansas. The undersigned further acknowledges having the opportunity to examine and question the applicant about the plans, specification, and engineering design of the Wastewater Treatment Utility, which is to be placed upon property, within 200' of the undersigned's property. The undersigned hereby waives any and all objections that the undersigned may have to the location and construction of the improvements upon the above-described property and agree that the Conditional Use Permit may be issued under Sections 36-104(3) and 36-253(4)(c) of the Little Rock Zoning Ordinance. DATED thi f day of7__�/o J6,trL,(,f, 1993. ®rr- f� upt I'._. , Ralph D. Schla man 13716 Joan Drive Mabelvale, AR 72103 NOTICE, WAIVER AND CONSENT TO SHANNON HILLS WASTEWATER TREATMENT UTILITY KNOW ALL MEN BY THESE PRESENTS: That the undersigned, hereby acknowledges Notice of the Public Hearing to be held before the Little Rock Planning Commission on March 9, 1993, at 12:30 p.m. o'clock, upon the application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for the approval of a Conditional Use Permit to permit construction of a Wastewater Treatment Utility on the property described as: Southwest 1/4, Southeast 1/4, and the West 330' of the North 1/2 of the Southeast 1/4 of the Southeast 1/4 of Section 16, Township 1 South, Range 13 West, in Little Rock, Pulaski County, Arkansas. The undersigned further acknowledges having the opportunity to examine and question the applicant about the plans, specification, and engineering design of the Wastewater Treatment Utility, which is to be placed upon property, within 200' of the undersigned's property. The undersigned hereby waives any and all objections that the undersigned may have to the location and construction of the improvements upon the above-described property and agree that the Conditional Use Permit may be issued under Sections 36-104(3) and 36-253(4)(c) of the Little Rock Zoning Ordinance. DATED this i zk day of1993. e .CS David G. or La ra R. Meador 11408 Donnie Drive Mabelvale, AR 72103 NOTICE WAIVER AND CONSENT TO SHANNON HILLS WASTEWATER TREATMENT UTILITY KNOW ALL MEN BY THESE PRESENTS: That the undersigned, hereby acknowledges Notice of the Public Hearing to be held before the Little Rock Planning Commission on March 9, 1993, at 12:30 p.m. o'clock, upon the application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for the approval of a Conditional Use Permit to permit construction of a Wastewater Treatment Utility on the property described as: Southwest 1/4, Southeast 1/4, and the West 330' of the North 1/2 of the Southeast 1/4 of the Southeast 1/4 of Section 16, Township 1 South, Range 13 West, in Little Rock, Pulaski County, Arkansas. The undersigned further acknowledges having the opportunity to examine and question the applicant about the plans, specification, and engineering design of the Wastewater Treatment Utility, which is to be placed upon property, within 200' of the undersigned's property. The undersigned hereby waives any and all objections that the undersigned may have to the location and construction of the improvements upon the above-described property and agree that the Conditional Use Permit may be issued under Sections 36-104(3) and 36-253(4)(c) of the Little Rock Zoning Ordinance. DATED this ` day of 1993. �,2 &_z4a4ine � Clarence M. or Susan K. Woods 11324 Donnie Drive Mabelvale, AR 72103 REASONS FOR DENIAL Z-5664 1. In conflict with the development standards and review guidelines - Section 36-107: (1) The proposed use is so designed, located and proposed to be operated that the public health, safety and welfare will be protected. (2) The proposed land use is compatible with and will not adversely effect other property in the area where it is proposed to be located. (7) Safeguards proposed to limit noxious or offensive emissions including lighting, noise, glare, dust and odor are addressed. 2. An unproven design for this application. 3. Could adversely affect the City's Storm Water Management responsibility. Shannon Hills' current facility is not properly operated and is under an EPA mandate. 4. Located in a single family area next to a school. 5. Located adjacent to a 70 acre City park. 6. An agreement had been made in 1984 to tie -on to Little Rock wastewater system. The Fourche Plant System when designed, included the Shannon Hills service area. 7. Little Rock sewer main within 5 feet of Shannon Hills' line with an in -city use rate. 8. Many citizens of Shannon Hills are opposed to the treatment facility. 9. State Health Department recommends connecting to Little Rock sewer. l.au-T Df fLCEA Of ofka&i 44. Jgzown, (J -D. og. Charles A. Brown, P.A. Sandra L. Sherrod April 20, 1993 Board of Commissioners Little Rock Planning Commission 723 West Markham Street Little Rock, AR 72203 Brown & Associates, Attorneys SUITE 1970 UNION NATIONAL PLAZA 124 WEST CAPITOL AVENUE LITTLE ROCK. ARKANSAS 72201 TELEPHONE 501-374-7582 FAX 501-374-7584 RE: Application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for Conditional Use Permit for a Constructed Wetlands Treatment Facility Dear Commissioners: Please find attached to this letter comments, and exhibits to comments, addressing the ten staff comments listed in the Subdivision Committee Meeting Agenda of April 1, 1993. You will note that I have approached them in reverse order. We trust you will take these matters into consideration as you make your final determination concerning the application. Yours very truly, Charles A. Brown Attorney and Agent for the Applicant CAB:rr Encl. 1Pau, doffLCF-1 Of i. } Charles A. Brown, P.A. Sandra L. Sherrod April 20, 1993 efia,&s e• ot0tun., . c4. Mr. Brad Walker 1500 Riverfront Drive, Suite 118 P. O. Box 250242 Little Rock, AR 72225 Brown & Associates, Attorneys SUITE 1970 UNION NATIONAL PLAZA 124 WEST CAPITOL AVENUE LITTLE ROCK. ARKANSAS 72201 TELEPHONE 501-374-7582 FAX 501-374-7584 RE: Application of Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3 for Conditional Use Permit for a Constructed Wetlands Treatment Facility Dear Mr. Walker: Please find attached to this letter comments, and exhibits to comments, addressing the ten staff comments listed in the Subdivision Committee Meeting Agenda of April 1, 1993. You will note that I have approached them in reverse order. We trust you will take these matters into consideration as you make you- final determination concerning the application. Yours very truly, 46gr'14 04011, Charles A. Brown Attorney and Agent for the Applicant CAB:rr Encl. EXHIBIT COMMISSION MEMBER LETTER Items 9 & 10 on the Subdivision Committee Comments refer to the buffers and 6' screening fence along the South perimeter. The 6' screening fence should be shown on the plans on the plans of the engineer and it will be chain link with barbs, and there will be plantings inside the fence to -provide for the buffer between the actual facility and the surrounding property owners. In addition to the fence, there will be tree plantings to provide a screen. Additionally, to the South of the tract being developed will be a 50' strip, 45' of which will be an easement as required by Item 1 on the Committee Comment. Five additional feet is provided for an additional buffer between the chain link fence and any arterial street to be constructed in accordance with the Master Street Plan. We are informed that the buffer along the West boundary will not be required in that it abuts the right-of-way for the Arkansas Power & Light Co.'s transmission lines, and there should be adequate buffers therefrom. As to Item 8, which may be in fact the most serious comment from the staff for the Subcommittee meeting, please find attached the following: (a) November 19, 1985 letter from the Little Rock Wastewater Utility indicating that 1 1/2 times the in -city rate will be required for out -of -city service. This letter was preliminary to the negotiated contract which was contingent upon Shannon Hills Water, Sewer & Fire Protection Improvement District tieing into City service for wastewater to be treated by the City of Little Rock. The contract was bottomed upon the provision that 150% of the in -city rate would be required to serve the Shannon Hills area. (b) A copy of Little Rock Ordinance No. 15,242, which was in effect at the time of the execution of the contingent contract showing the out -of -city volumetric charge to be $1.10 per 100 cubic feet. From Exhibit A, it was deter- mined that Cammack Village, which we are informed do not maintain their own system, was paying the out -of -city rate. (c) Please find attached Ordinance No. 16,018, which stated that commencing April 5, 1991, the volumetric charge for in -city rate per 100 cubic feet would be $1.06, and for out -of -city rate would be $2.48, a 225% or more charge for out -of -city treatment than for in -city treatment. (d) A copy of Ordinance No. 16,080, showing that commencing September 1, 1991, the volumetric charge for the in -city rate would be $1.06, and the out -of -city rate $1,59; or, a 150% rate charge. -2 - It is significant that upon the passage of the Ordinance referred to in Paragraph (b), supra, included a charge of over 20¢ per 100 cubic feet above the consultant's report what should be a fair charge for out -of -city rates, assuming that the City of Little Rock provided the full amount of the cost for the Fourche Creek Treatment Plant and outfall line to the Otter Creek area. Obviously, with the Federal Government making in excess of $25 million grant to the line, and Improvement District No. 142 paying a portion of the line, and bonds being issued for the balance of the construction cost, which bonds are payable from the regular sewer rate, and since Shannon Hills under the contract was to maintain their own collection system, pumping stations, and pay for infiltration, the action of the City Board on March 5, 1991, not only breached the 150% agreement, but brought home to the Board of Commissioners of the Shannon Hills Water, Sewer & Fire Protection Improvement District No. 3, that the City Board of Little Rock could and did pass rate increases at its will and pleasure without regard or input from the affected areas, and without regard to the fundamental agreement that the rate would not exceed 150%. Obviously, this applicant would violate their sworn duty to represent their constituency if they collaborated with the excessive charges imposed by Ordinance No. 16,018 and thereby destroyed the viability of their consumers to pay the bills. The Constructed Wetlands Treatment Facility was fostered by necessitated survival instinct as a result of the March 5, 1991 action of the Board of Directors of the City of Little Rock. We would suggest that Item 8 not be an item of consideration by the City Planning Commission in passing upon the appropriateness of the Constructed Wetlands Conditional use Application. Items 6 and 7 appear to be mere comments and describe the park or open space designation of adjacent property, or the flood plain property of Otter Creek. No construction by the applicant in the Otter Creek Flood Plain is anticipated or shown upon the plan. See the comments as to Paragraph 5, infra. As to Paragraph 5 relative to the existing water main on the North perimeter of the tract and the proximity of the discharge of the treated wastewater upstream from the water main, we would suggest that this is a matter to be considered in setting the limits of the discharge from the wastewater treatment facility, and the approval of the Health Department. There has been previously furnished the Planning Commission a copy of the April 1, 1993, Arkansas Department of Health review and approval letter, with appropriate disclaimers. (Exhibit 5) Item 5 does make a policy comment which probably can be agreed with gener- ally by all parties involved in the wastewater treatment facility; however, all parties recognize the economic factor relating to the ability of the user to pay for exorbitant treatment charges. -3 - We would assume that the comments of Item 5 have been answered by the approval of the Health Department of the plans which showed the existing water main and showed the discharge upstream therefrom, and recognition that the wastewater discharge would not permeate through the steel -encased water main, which would have a higher inside water pressure than the outside Otter Creek flow. As to Item 4, Bond Consulting Engineers have been requested to provide their review as the wastewater specialists. As to Item 3, please find attached a copy of the Arkansas Depart- ment of Pollution Control & Ecology letter granting the construction permit, which of course is contingent upon the approval of the site now under consideration. (Exhibit 6) As to Items 1 and 2, the applicant has removed from the application the South 50' of the 40 acre tract from its construction area. The applicant has agreed, and will continue to agree, that upon the approval of the site, that a proper right-of-way designation for the South 45, of the 40 acre tract will be granted to the City of Little Rock for use as an arterial street. It would appropriate for the easement to contain some language that in event the street is not built within a reasonable period of time, 15 to 20 years, that the easement, like a vacated alley easement, revert to the owner. The request is made to waive any deposit or contributions required of the applicant for the 50, not included in the Constructed Wetlands facility treatment area, and which street would be an arterial street with no improvement to the facility under consideration, and the arterial street is designated on the Master Street Plan as being 45' in Saline County, which crosses a series of lots. The probability of the right-of-way for the series of lots being acquired by the Saline County Court by voluntary dedication or by eminent domain, and the building of the South half of the arterial street, appears to be so remote and highly unlikely, that a waiver of this contribution in lieu of construc- tion of the Countyline Road, is requested. However, if this is the only objection to the Little Rock Planning Commission and the Board of Directors of the City of Little Rock approval. This application, for the negotiation would be appropriate. One further point may be raised at this Commission meeting. It may be the compatibility of the Constructed Wetlands Treatment Facility with the One Family Residential zoning for this area. The area was annexed as a part of an overall annexation "volunteered" through the efforts of Mr. Leon Sneed, a former city of the City of Little Rock Planning Staff. This area alone would not qualify under the Arkansas Statutes as being suitable farm land for residential development at the time of annexation, and, as all other property annexed, came into the City as residentially zoned.