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HomeMy WebLinkAboutZ-9042 Application 5SO ORDERED THIS DAY OF 2015. a BECKYW. KEOGH, APPROVED AS TO FORM AND CONTENT: Flushing Meadows Water Treatment, Inc. Fan (Typed br printed name) TITLE:_ DATE: 4_ Is Q01 S Page 10 of 10 Flushing Meadows Water Treatment, Inc. CAO MITCHELL WILLIAMS About Usl Attorneys) Practices) Diversityl Newsroom) Careers) Contact Environmental, Energy, and Water Bldg WASTEWATER ENFORCEMENT: ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY ISSUES EMERGENCY ORDER, TO'WASHINGTON COUNTY PROPERTY OWNERS IMPROVEMENT DISTRICT NO.5 Posted April 15, 2015 Author: Walter G. Wright The Arkansas Department of Environmental Quality ("ADEQ") has issued an Emergency Order ("EO") to the Washington County Property Owners Improvement District No. 5 ("District") based on its determination that emergency conditions exist as a result of an unpermitted discharge of raw sewage at a facility that the District operates. The EO states that the District is located in Farmington, Arkansas. Permit No. 464-WR-3 ("Permit") was granted to the District in 2011. The facility operated by the District is allegedly located 100 feet from an unnamed tributary of the Illinois River in Stream Segment 3J. It further alleges that an ADEQ inspector conducted an inspection at the District facility and noted an unpermitted discharge of untreated wastewater as a result of an overflow of the aeration cell. The inspector allegedly noted the facility's waste disposal was not operational. The EO states that as a result of the failure of the waste disposal system, untreated wastewater was being discharged out of the aeration pond onto Valley View Golf Course. ADEQ personnel allegedly took samples at the site of unpermitted discharge which are stated to be above Fecal Coliform Bacteria and E. coli permitted levels. The EO orders that the facility: o Immediately cease and desist from any and all unpermitted discharges o Immediately remediate the area impacted by the unpermitted charges o Provide evidence to the ADEQ including documentation and pictures within 5 calendar days indicating that the two items above were promptly completed A copy of the April 1 st EO can be downloaded below. Download File nf 9 7/7/2015 8:27 AN BACK Email Updates To sign up to receive posts from our Environmental, Energy and Water blog in your Inbox, fill in the following fields and hit submit. Thanks, and welcome! * First name * Email * Last name * required Submit Clear Other Mitchell Williams Blogs ® Bank Regulatory Blog . Bankruptcy/D-C Rights Blog * Corporate & Securities Blog 9 ERISA Blog e Immigration Law Blog Insurance Regulatory Blog • Labor & Employment Blog • Physician/Healthcare Blog ■ Tax Blog T ATTORNEY LOGIN 02015 Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C. All rights reserved. Attorney - Client Relationship. Use of the Mitchell Williams web site does not create an attorney -client relationship between you and Mitchell Williams . If you send us an e-mail and we do not already represent you, your e-mail will not create an attorney -client relationship and will not necessarily be treated as privileged or confidential. 2 of 2 7/7n.015 8.27 AN ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY IN THE MATTER OF Flushing Meadows Water Treatment, Inc. LIS No. 14-174 3555 Homestead Drive Permit No. AR0048879 Conway, AR 72032 AFIN 23-00461 CONSENT ADMINISTRATIVE ORDER This Consent Administrative Order (hereinafter "Order") is issued pursuant to the authority of the Arkansas Water and Air Pollution Control Act, Ark. Code Ann. § 8-4-101 et seq. (hereinafter "the Act'), the Federal Water Pollution Control Act, 33 U.S.C. § 1311 et seq., and the regulations issued thereunder by Arkansas Pollution Control and Ecology Commission (hereinafter "APC&EC"). The issues herein having been settled by the agreement of the Flushing Meadows Water Treatment, Inc. (hereinafter "Respondent") and the Arkansas Department of Environmental Quality (hereinafter "ADEQ" or "Department"), it is hereby agreed and stipulated that the following FINDINGS OF FACT and ORDER AND AGREEMENT be entered. FINDINGS OF FACT 1. Respondent operates a wastewater treatment facility and associated collection system (hereinafter "facility") located in 77 Brewer Road, Conway, Faulkner County, Arkansas. 2. Respondent is regulated pursuant to the National Pollutant Discharge Elimination System (hereinafter "NPDES"). Page 1 of 10 Flushing Meadows Water Treatment, Inc. CAO 3. Respondent's facility discharges treated wastewater to an unnamed tributary of Gold Creek thence to Lake Conway. 4. Pursuant to the federal Clean Water Act (hereinafter "CWA"), 33 U.S.C. § 1311(a) et seq., the NPDES program prohibits the discharge of pollutants except as in compliance vAth a permit issued under the NPDES program in accord vAth 33 §1342(a). 5. ADEQ is authorized under' the Arkansas Water and Air Pollution Control Act to issue NPDES permits in the state of Arkansas and to initiate an enforcement action for any violation of an NPDES permit. 6, NPDES Permit Number AR0048879 (hereinafter "Perrnir) was issued to the Respondent on May 31, 2010. The Permit became effective on June 1, 2010, and expires on May 31, 2015. Can September 15, 2014, a complete Permit renewal application was received by the Department. 7. Ark. Code Ann. § 8-4-217(a) provides: (a) It shall be unlawful for any person to: (1) Cause pollution... of any waters of the state. (3) Violate any provisions of this chapter or of any rule, regulation, or order adopted by the [APC&EC] under this chapter or of a permit issued under this chapter by the [ADEQ]. 8. Ark. Code Ann. § 8-4-103 authorizes ADEQ to assess an administrative civil penalty not to exceed ten thousand dollars ($10,000) per violation for any violation of any provision of the Act and any regulation or permit issued pursuant to the Act. 9. Pursuant to Ark. Code Ann. § 8-4-103(c)(1)(B), "Each day of a continuing violation may be deemed a separate violation for purposes of penalty assessment." 10. The Department conducted a review of certified Discharge Monitoring Reports submitted by the facility in accordance with the Permit from December 31, 2011, Page 2 of 10 Flushing Meadows Water Treatment, Inc. CAO through November 30, 2014. The review revealed violations of the permitted effluent discharge limits detailed in Part I,, Section A of the Permit. Respondent reported fifty- one (51) violations of the permitted effluent limits of five (5) pollutants from December 31, 2011, through November 30, 2014. Respondent reported twenty-two (22) exceedances of the limit for Ammonia Nitrogen, fifteen (15) exceedances of the limit for Carbonaceous Biochemical Oxygen Demand, ten (10) exceedances of the limit for Totaf Suspended Solids, two (2) exceedances of the limit for pH, and two (2) exceedances of the limit for Fecal Coliform. Each of the fifty-one (51) discharge limitation violations listed above constitutes a separate Permit violation and therefore reflects fifty-one (51) separate violations of Ark. Code Ann. § 8-4-217(a)(3). 11. Pursuant to Ariz. Code Ann. § 8-4-203(b)(1)(A) and Part Il, Section 5 of the Permit, Respondent must maintain continuous financial assurance on file with the Department. 12. On August 1, 2011, the Department received an Irrevocable Letter of Credit (hereinafter "LOC # 2000686") in the amount of Fifteen Thousand Dollars ($15,000.00) from Metropolitan National Bank. On August 1, 2012, LOC # 2000686 expired. The failure to maintain continuous financial assurance violates Part II. Paragraph 5 of the Permit and therefore violates Ark. Code Ann_ § 8-4-217(a)(3). 13. ADEQ attempted to contact Respondent by certified letter on May 20, 2013, and on February 25, 2014. 14. On May 16, 2014, the Department received a financial assurance instrument in the form of an Irrevocable Letter of Credit (LOC # 86039757) in the amount of Fifteen Thousand Dollars ($15,000.00). LOC # 86039757 expires on May 6, 2015. Page 3of10 Flushing Meadows Water Treatment, Inc. CAO 15. On May 4, 2015, the Department received a financial assurance instrument in the form of an Irrevocable Letter of Credit (LOG # 86039757) in the amount of Fifteen Thousand Dollars ($15,000,00). LOC # 86039757 expires on May 6, 2016. 16. On March 5, 6, 13, 17, and 18, 2014, the Department conducted inspections of the facility's west lift station at Shiloh Creek Estates. The inspections revealed the following violations: a. On March 5, 6, and 13, 2014, raw sewage from the lift station located west of the intersection of Shiloh Drive and Homestead Road was pumped through a pipe into a storm drain that discharged to an unnamed tributary of Gold Creek. This unpermitted discharge violated Ark. Code Ann_ § 8-4 217(b)(1)(D). b. Backup pumps for the lift station were not available to replace primary pumps. These conditions violated Part III, Section B. 1. A of the Permit and therefore violated Ark. Code Ann. § 8-4-217(a)(3). c. Solids were observed on the ground near the lift station. These conditions violated Part III, Section B.6 of the Permit and therefore violated Ark. Code Ann. § 8-4-217(a)(3). 16. On March 17, 2014, an ADEQ inspector visited the site and observed that the pipe has been removed, ceasing the unpermitted discharge. 17. On July 1, 2014, a proposed Consent Administrative Order was mailed to Respondent. 18. On July 15, 2014, Respondent met with ADEQ staff to discuss the proposed Consent Administrative Order. At that meeting, Respondent stated they would submit a Page 4 of 10 Flushing Meadows Water Treatment, Inc. CAO Corrective Action Plan (hereinafter "CAP") to the Department in regard to the effluent violations. However, to date, no CAP has been received by the Department. 19. On July 23, 2014, Respondent submitted photographic documentation of the removal of the previously observed solids at the lift station. 20. On September 26, 2014, the Department conducted an inspection of the facility. The inspection revealed four (4) unpermitted discharges at four locations: a. 3440 Bentonville Drive, Conway, Arkansas 72032; b. 3336 Antietam Drive, Conway, Arkansas 72032; c. 3465 Perryville Drive, Conway, Arkansas 72032; and d. Southeast corner of Crowley Ridge and Appomattox Drives, Conway, Arkansas 72032. These unpermitted discharges violated Ark. Code Ann. §8-4-217(b)(1)(D)_ 21. On December 17, 2014, the Department issued a Notice of Violation, LIS 14-174. 22. On January 2, 2015, Lorene Wyatt filed a Request for Hearing on behalf of Respondent. The APC&EC assigned Docket No. 15-001-NOV to the hearing request. ORDER AND AGREEMENT WHEREFORE, the parties stipulate and agree as follows: 1. Within thirty (30) days of the effective date of the Order, Respondent shall hire an Arkansas -licensed Professional Engineer (hereinafter "P.E.") to perform a complete treatment system evaluation. Within ten (10) days of the completion of the treatment system evaluation, a copy of that evaluation shall be submitted to ADEQ. If the treatment system evaluation determines that further corrective actions are needed, a complete Corrective Action Plan (hereinafter "CAP") shall be submitted to ADEQ within twenty (20) days of the completion of the complete treatment system evaluation. The Page 5 of 10 Flushing Meadows Water Treatment, Inc. CAO CAP must be certified by an Arkansas -licensed Professional Engineer, using the best available technology to comply with Permit effluent limit violations. The CAP shall include a milestone schedule and detail the methods and technologies Respondent shall utilize to achieve compliance with the terms of the Permit and to prevent future violations_ The CAP shall be signed in accordance with Part III, Section D, Paragraph 11 of the Permit. Upon approval by ADEQ, the CAP and milestone schedule shall be fully enforceable as a term of this Order. 2. On or before the effective date of the Order, Respondent must obtain backup pumps for the lift station. A copy of the receipt showing the purchase of the pumps must be submitted to ADEQ within five (5) days of the effective date of the Order. 3. On or before the effective date of the Order, Respondent must provide a certification from a P.E. and photo documentation showing the four (4) unpermitted discharges identified in paragraph 20 of the Findings of Fact have ceased and have been fully remediated. 4. All submittals referenced above must be sent to: Arkansas Department of Environmental Quality Water Division 5301 Northshore Drive North tittle Rock, AR 72118-5317 5. In compromise and full settlement of the violations specified in the Findings of Fact, Respondent agrees to pay a civil penalty of Six Thousand Five Hundred Fifty Dollars ($6,550.00) payable in twelve (12) monthly payments. The first payment of Five Hundred Fifty Dollars ($550.00) is due within 15 days of the effective date of this Order. Each subsequent monthly payment of Five Hundred Dollars ($500.00) is due on 1st day of each month until the civil penalty is paid in full. In the event Respondent fails to Page 6 of 10 Flushing Meadows Water Treatment, Inc. CAO comply with this Order or make timely monthly penalty payments, the civil penalty amount will revert back to the assessed amount of Thirteen Thousand One Hundred Dollars ($13,100.00) and the full outstanding balance will be due and payable immediately to the Arkansas Department of Environmental Quality. Such payments of the penalty shall be made payable to the Arkansas Department of Environmental Quality, and mailed to the attention of: Arkansas Department of Environmental Quality Fiscal Division 5301 Northshore Drive North Little Rock, AR 72118 In the event that Respondent fails to pay the civil penalty within the prescribed time, ADEQ shall be entitled to attorneys' fees and costs of collection. 6, Failure to meet any requirement or deadline of this Order constitutes a violation of said Order. If the Respondent should fail to meet any such requirements or deadlines, the Respondent consents and agrees to pay on demand to ADEQ stipulated penalties according to the following schedule: a. First day through fourteenth day: $100.00 per day b. Fifteenth day through the thirtieth day: $500.00 per day c. Each day beyond the thirtieth day: $1000.00 per day These stipulated penalties for delay in performance shall be in addition to any other remedies or sanctions which may be available to ADEQ by reason of failure by the Respondent to comply with the requirements of this Order. 7. If any event, including but not limited to an act of nature, occurs which causes or may cause a delay in the achievement of compliance by the Respondent with the requirements or deadlines of this Order, the Respondent shall so notify ADEQ, in Page 7 of 10 Flushing Meadows Water Treatment, Inc. CAO writing, as soon as reasonably possible after it is apparent that a delay wifl result, but in no case after the due dates specified in this Order. The notification shall describe in detail the anticipated length of the delay, the precise cause of the delay, the measures being taken and to be taken to minimize the delay, and the timetable by which those measures Will be implemented. 8, ADEQ may grant an extension of any provision of this Order, provided that the Respondent requests such an extension in writing and provided that the delay or anticipated delay has or will be caused by circumstances beyond the control of and without the fault of the Respondent. The time for performance may be extended for a reasonable period but in no event longer than the period of delay resulting from such circumstances. 'The burden of proving that any delay is caused by circumstances beyond the control of and without the fault of the Respondent and the length of the delay attributable to such circumstances shall rest with the Respondent. Failure to notify the ADEQ promptly, as provided in the preceding paragraph of this Section, shall be grounds for a denial of an extension. 9. All submittals required by the Order and Agreement are subject to approval by ADEQ. Unless otherwise specified herein, in the event of any deficiencies, Respondent shall, within the timeframe specified by ADEQ, submit any additional information or changes requested, or take additional actions specified by ADEQ to correct any such deficiencies. Failure to adequately respond to such Notice of Deficiency (NOD) within the timeframe specified in writing by ADEQ constitutes a failure to meet the requirements established by this Order. 10. This Order is subject to public review and comment in accordance with Ark. Code Page 8 of 10 Flushing Meadows Water Treatment, Inc. CAO Ann. § 8-4-103(d) and APC&EC Regulation No. 8 and shall not be effective until thirty (30) calendar days after public notice is given. ADEQ retains the right to rescind this Order based upon the comments received within the thirty -day public comment period. Notwithstanding the public notice requirements, the corrective actions necessary to achieve compliance shall be taken immediately. The publication of this Order shall occur on or about the 10th or 25th day of the month following the date this Order is executed. As provided by APC&EC Regulation No. 8, this matter is subject to being reopened upon Commission initiative or in the event a petition to set aside this Order is granted by the Commission. 11. Nothing in this Order shall be construed as a waiver by ADEQ of its enforcement authority over alleged violations not specifically addressed herein. Also, this Order does not exonerate the Respondent from any past, present, or future conduct which is not expressly addressed herein, nor does it relieve the Respondent of its responsibilities for obtaining any necessary permits. 12. As provided by APC&EC Reg.8.615, the Request for Hearing in this matter is hereby withdrawn and the filing of this Order shall close APC&EC Docket No. 15-001- NOV without further Commission action_ 13. By virtue of the signature appearing below, the individual represents that he or she is an Officer of Respondent, being duly authorized to execute and bind Respondent to the terms contained herein. Execution of this Order by an individual other than an Officer of Respondent shall be accompanied by a resolution granting signature authority to said individual as duly ratified by the governing body of the entity. Page 9 of 10 Flushing Meadows Water Treatment, Inc. CAO SO ORDERED THIS BECKY W. KEOGH, DAY OF . 2015. RECTOR APPROVED AS TO FORM AND CONTENT: .Flushing Meadows Water Treatment, Inc. (S (Typed br printed name) TITLE: Orc S l `L DATE: oZd l S Page 10 of 10 Flushing Meadows Water Treatment, Inc. CAO A-DE_Q A R K A N S A S Department of Environmental Quality MEMORANDUM To: Commission Members From.: Tammie J. Hynum, Chief, Hazardous Waste Division1�a Date: May 29, 2015 Subject: Permit Modifications Issued for the Month of May 2015 Three (3) permit modifications were issued during the month of May 2015: • Aero'et Rocketd ne 8H-RN1 : Class 2 hermit modification (allows for the plugging and abandonment of three (3) existing groundwater monitoring wells); Received 1/15/2015; Approved 5/4/2015 41 Clean Harbors El Dorado 0OH-RNI): Class l permit modification (updating ADEQ Notification Tree); Received 5/14/2015; Approved 5/20/2015 • Weyerhaeuser NR Company C5H-RN1): Class 1 permit modification (updating type of financial assurance mechanism); Received 4/22/2015; Approved 5/7/2015 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880 vnvw. a d eq. state . o r. u s WEST FORK WASTEWATER TREATMENT PLANT CITY OF WEST FORK, ARKANSAS The West Fork wastewater treatment plant consists of two lagoons that were built in 1970 and a mechanical plant that was put in service in 1973. The first lagoon cell is used for flow equalization of the raw wastewater. The second lagoon cell is used for dechlorination of the treated wastewater. A mechanical plant located on the east side of the lagoon cells is used for biological treatment of the City's wastewater, This plant was designed for a flow of 100,000 gallons per day and it is now treating approximately 140,000 gallons per day. Between the age of this plant (36 years) and the fact that it is operating at a rate in excess of its design capacity, it is reaching its useful life, As indicated in the attached maps, the two lagoons were built immediately on the east side of the West Fork of the White River. The entire plant site for both the lagoons and the mechanical plant beside the lagoons are included in the Zone AE of the applicable Flood Insurance Rate Map. This is the case for the FIRM map published in 1991 (Panel 170 for Washington County) and the updated Preliminary FIRM map dated August 7, 2006 (Panel 360 of Washington County, Map No. 05143C0360F). A copy of the 1991 FIRM map is attached. It is unknown what flood information was utilized when the plant was designed in 1970 to 1972. However, the plant has flooded twice since 2004 and has been subject to flood damage in prior years. During these flood periods, the lagoons are submerged in the river, and the plant is inaccessible for operation and maintenance. Damage to the plant facilities and the security fence has occurred. Since this plant was constructed, the City of West Fork has expanded to the north, along Highway 71. Most of this expansion area does not have a sewage collection system because it would require pump stations to route the sewage back to the wastewater treatment plant. There is one preschool facility that has installed its own pump station. Otherwise, residential growth in this area is relying on septic tanks. Consequently, the existing treatment plant has multiple issues, as follows: 1. It is old (36 years) for a welded steel package treatment plant. 2. Its design capacity is being exceeded with flows of around 140,000 gallons per day and a design capacity of 100,000 gallons per day. 3. Its location is in the wrong place due to the flood damage it has been sustaining. 4. Its location is in the wrong place to allow gravity flow service to West Fork's growth area along Highway 71, north of the plant. These issues can all be addressed by relocating the plant to the north, at a location outside and/or above the flood plane area. Alternatively, this situation could be addressed by routing the City's wastewater flow further north, past the City of Greenland, to Fayetteville's wastewater collection and treatment system. Currently, Fayetteville accepts the wastewater generated in Greenland and treats it at its east wastewater treatment plant, Greenland's sewer mains and pump station are near capacity, so routing West Fork's flow through Greenland would require increased capability in Greenland's mains and pump stations, or separate mains and a pump station for West Fork's flow. Greenland's system needs to be upgraded, so a cooperative effort may be possible. Fayetteville has just completed a new wastewater treatment plant on the west side of Fayetteville and has substantially reduced its load on the east plant, Consequently, it is anticipated that Fayetteville would be capable of treating West Fork's flows, and that Fayetteville would be interested in this concept to accomplish more regionalization of the area's wastewater treatment. Depending upon the actual connection point to the Fayetteville system, this concept of routing West Fork's flow to Fayetteville could require 29,000 to 34,000 feet of sewer main, as well as a pump station. Previous economic evaluations have indicated that it is more cost effective to expand the plant at its existing location, than to route the flows to Fayetteville. However, these evaluations did not include the considerations of a new plant site out of the flood plane and further north to receive gravity flow from the north end of West Fork. If the plant is to be moved north, then part of the pipeline required f to reach Fayetteville must be built. At some point, it becomes more economical to route the pipeline all the way to Fayetteville, depending on how far the plant would be moved to the north. West Fork 'waste 'water Treatment Pleat Leaking Wastewater Into White bluer Posted 4:52 pm, April 7, 2014, by Curt Lanning, Updated at 04:55pm, April 7, 2014 Facebook 170 Twittez•7 o Goog•lele Pint.erest p Linlcedli.l • Emai 1 The Arkansas Department of Environmental Quality confirmed Monday (April 7) that they had visited the West Fork Waste Water Treatment Plant multiple times and observed sewage overflow leaking into the White River. A complaint was reportedly made via email that when it rains, raw sewage overflows from, a manhole on the south side of the treatment facility and flows into the White River, according to the ADEQ. ADEQ inspectors visited the facility twice on April 2 and April 3. They observed sewage overflow was occurring and that wastewater was entering the White River. On the second visit (April 3), inspectors observed a second overflow occurring at a splitter box located on the facility. On Monday (April 7), inspectors returned to the facility once more and saw the overflows were still occurring, according to the ADEQ. ADEQ notified the city that they need to fix the situation, and they'll continue to monitor the overflows and stay in contact with city officials to ensure the problems are addressed. Filed in: News 4 comments Froud Arka/ san And to think that we put a man on the moon over 50 years ago, yet we can't stop human waste from flowing into our streams. This is sad Arkansans. ,Please do mention this story to your friends and colleagues tomorrow and the days ahead. We are the natural state. Let's act like it. A ril 7 2014 at S :42 m Former Citizen The West Fork Administrator has know for over a decade the sewage plant is past obsolete. That office has done nothing but sweep the problem under the rug and drink coffee with the good of boys out there. ADEQ gave them an extension years ago to either bring the plant up to code or work out an agreement with Fayetteville. Someone needs to FOI the records from that office and the ADEQ. It's all there, no one is holding anyone accountable. April 7, 2014 at 10:35 pm 8420yatslClee Oh, Arkansas. That bastion of intelligence. This shows us "We don't need no stinkin' regulations". Who needs clean water? The GOP says we don't. Don't want to drink E. Coli? Then vote democrat. April 9 2014 at 6:35 am Jo/rts Another instance where someone tries to turn a community problem into a political problem and play the blame game. The community most impacted by this environmental affront should take the stand and make the effort to remedy this problem -- not a bunch of politicians or individuals so blinded by their demagoguery. April 11, 2014 at 8.30 pm Sewage runoff in White River near West Fork KFSM 10:41 p.m. CDT April 9, 2014 CONNECT 1 TWEETLINK:EDTNCOMMENTEMAILMORE WEST FOLK, Ark. (KFSM) - A report from the Arkansas Department of Environmental Quality confirmed a sewage runoff into the White River on Wednesday. It's now causing concern among some in the West .Fork community about the safety of their local water supplies. City officials said there's no need for anyone to be alarmed, and there are no problems with the drinking water. Officials found two sewage leaks at the West Fork waste water treatment facility last week. The city said it has received a state grant to fix the 40-year-old system, and will continue conducting safety tests. Still, some people say they're being cautious until things are worked out. "It's more than just drinking water, but certainly drinking water is probably the greatest concern right away to the most people. Then in the water quality and the health for the river, for the people that want to fish in it, the people that want to swim in it, those are concerns that also need to be addressed," said John Pennington of the Beaver Watershed Alliance. The city said there is no set date for when the treatment facility will be repaired. For the full story from KFSM, click here. CONNECT 1 TWEETLINKEDINCOMMENTEMAILMORE WEST FORK WASTEWATER TREATMENT PLANT CITY OF WEST FORK, ARKANSAS The West Fork wastewater treatment plant consists of two lagoons that were built in 1970 and a mechanical plant that was put in service in 1973. The first lagoon cell is used for flow equalization of the raw wastewater. The second lagoon cell is used for dechlorination of the treated wastewater. A mechanical plant located on the east side of the lagoon cells is used for biological treatment of the City's wastewater. This plant was designed for a flow of 100,000 gallons per day and it is now treating approximately 140,000 gallons per day. Between the age of this plant (36 years) and the fact that it is operating at a rate in excess of its design capacity, it is reaching its useful life. As indicated in the attached maps, the two lagoons were built immediately on the east side of the West Fork of the White River. The entire plant site for both the lagoons and the mechanical plant beside the lagoons are included in the Zone AE of the applicable Flood Insurance Rate Map. This is the case for the FIRM map published in 1991 (Panel 170 for Washington County) and the updated Preliminary FIRM map dated August 7, 2006 (Panel 360 of Washington County, Map No. 05143C0360F). A copy of the 1991 FIRM map is attached. It is unknown what flood information was utilized when the plant was designed in 1970 to 1972. However, the plant has flooded twice since 2004 and has been subject to flood damage in prior years. During these flood periods, the lagoons are submerged in the river, and the plant is inaccessible for operation and maintenance. Damage to the plant facilities and the security fence has occurred. Since this plant was constructed, the City of West Fork has expanded to the north, along Highway 71. Most of this expansion area does not have a sewage collection system because it would require pump stations to route the sewage back to the wastewater treatment plant. There is one preschool facility that has installed its own pump station. Otherwise, residential growth in this area is relying on septic tanks. Consequently, the existing treatment plant has multiple issues, as follows: 1. It is old (36 years) for a welded steel package treatment plant. 2. Its design capacity is being exceeded with flows of around 140,000 gallons per day and a design capacity of 100,000 gallons per day. 3. Its location is in the wrong place due to the flood damage it has been sustaining. 4. Its location is in the wrong place to allow gravity flow service to West Fork's growth area along Highway 71, north of the plant. These issues can all be addressed by relocating the plant to the north, at a location outside and/or above the flood plane area. Alternatively, this situation could be addressed by routing the City's wastewater flow further north, past the City of Greenland, to Fayetteville's wastewater collection and treatment system. Currently, Fayetteville accepts the wastewater generated in Greenland and treats it at its east wastewater treatment plant. Greenland's sewer mains and pump station are near capacity, so routing West Fork's flow through Greenland would require increased capability in Greenland's mains and pump stations, or separate mains and a pump station for West Fork's flow. Greenland's system needs to be upgraded, so a cooperative effort may be possible. Fayetteville has just completed a new wastewater treatment plant on the west side of Fayetteville and has substantially reduced its load on the east plant. Consequently, it is anticipated that Fayetteville would be capable of treating West Fork's flows, and that Fayetteville would be interested in this concept to accomplish more regionalization of the area's wastewater treatment. Depending upon the actual connection point to the Fayetteville system, this concept of routing West Fork's flow to Fayetteville could require 29,000 to 34,000 feet of sewer main, as well as a pump station. Previous economic evaluations have indicated that it is more cost effective to expand the plant at its existing location, than to route the flows to Fayetteville. However, these evaluations did not include the considerations of a new plant site out of the flood plane and further north to receive gravity flow from the north end of West Fork. If the plant is to be moved north, then part of the pipeline required to reach Fayetteville must be built. At some point, it becomes more economical to route the pipeline all the way to Fayetteville, depending on how far the plant would be moved to the north. West Fork Waste Water Tr eatmeat Plant Leaking Wastewater Into White River Posted 4:52 pm, April 7, 2014, by Curt F,anniq , Updated at 04:55pm, April 7, 2014 • Facebook170 ■ Twitter? ■ Googje ■ Pinterest ■ Linkedin 1 ■ :Email W. st The Arkansas Department of Environmental Quality confirmed Monday (April 7) that they had visited the West Fork Waste Water Treatment Plant multiple times and observed sewage overflow leaking into the White River. A complaint was reportedly made via email that when it rains, raw sewage overflows from a manhole on the south side of the treatment facility and flows into the White River, according to the ADEQ. ADEQ inspectors visited the facility twice on April 2 and April 3. They observed sewage overflow was occurring and that wastewater was entering the White River. On the second visit (April 3), inspectors observed a second overflow occurring at a splitter box located on the facility. On Monday (April 7), inspectors returned to the facility once more and saw the overflows were still occurring, according to the ADEQ. ADEQ notified the city that they need to fix the situation, and they'll continue to monitor the overflows and stay in contact with city officials to ensure the problems are addressed. Filed in: News Prowl Arkansan And to think that we put a man on the moon over 50 years ago, yet we can't stop human waste from rowing into our streams. This is sad Arkansans. Please do mention this story to your friends and colleagues tomorrow and the days ahead. We are the natural state. Let's act like it. April 7 2014 at 8:42 pm Former Citizen The West Fork Administrator has know for over a decade the sewage plant is past obsolete. That office has done nothing but sweep the problem under the rug and drink coffee with the good of boys out there. ADEQ gave them an extension years ago to either bring the plant up to code or work out an agreement with Fayetteville. Someone needs to FOI the records from that office and the ADEQ. It's all there, no one is holding anyone accountable. April 7, 2014 at 10:3 5 pni K!] Rhy �er Oh, Arkansas. That bastion of intelligence. This shows us "We don't need no stinkin' regulations". Who needs clean water? The GOP says we don't. Don't want to drink E. Coli? Then vote democrat. April 9, 2014 at 6:35 am John Another instance where someone tries to turn a community problem into a political problem and play the blame game. The community most impacted by this environmental affront should take the stand and make the effort to remedy this problem — not a bunch of politicians or individuals so blinded by their demagoguery. April 11, 2014 at 8:'0 pm Sewage runoff in White River near West Fork KFSM 10:41 p.m. CDT April 9, 2014 CONNECT 1 TWEETLINKEDINCOMMENTEMAILMORE WEST FORK, Ark. (KFSM) - A report from the Arkansas Department of Environmental Quality confirmed a sewage runoff into the White River on Wednesday. It's now causing concern among some in the West Fork community about the safety of their local water supplies. City officials said there's no need for anyone to be alarmed; and there are no problems with the drinking water. Officials found two sewage leaks at the West Fork waste water treatment facility .last week. The city said it has received a state grant to fix the 40-year-old system, and will continue conducting safety tests. Still, some people say they're being cautious until things are worked out. "It's more than just drinking water, but certainly drinking water is probably the greatest concern right away to the most people. Then in the water quality and the health for the river, for the people that want to fish in it, the people that want to swim in it, those are concerns that also need to be addressed," said John Pennington of the Beaver Watershed Alliance. The city said there is no set date for when the treatment facility will be repaired. For the full story from KFSM, click here. CONNECT 1 TWEETLINKEDINCOMMENTEMAILMORE ARKA14SAS POLLUTION CONTROL AND ECOLOGY COMMISSION REGULATIONS COMMITTEE MEETING Thursday, May 21, 2015 8:30 a.m. ARKANSAS DEPAR2MONT OF EN"VITRONWNTAL QUALITY 5301 NORTHSHOPX DRIVEf NORTH LITTLE ROCK, ARK"SAS 72118 AGENDA (item #01) I. Call Meeting to Order - 8:30 a.m. II. Roll Call III. Approval of December 5, 2014 Committee Minutes (Item #02) IV. Regulation No. 23, Hazardous Waste Management APPENDIX I - Docket No. 15-001-R (item #05-12) - Tammie J. Hynum for Arkansas Department of Environmental Quality - Minute Order (Initiate) V. Adjourn APdi�-ANSAS POLLUTION CONTROL AND ECOLOGY C011v"-ISSION REGULAR COMISSION FETING Thursday, May 21, 2015 9:00 a.m. ARK"SAS DEPARTMENT OF R'RVIRON7ENVAL QUALITY 5301 NORTHSHORE DRxvg NORTH LITTLE ROC-K, ARKANSAS 72118 AGENDA (Item #03) I. Call Meeting to Order - 9:00 a.m. II. Roll Call III. Approval of April 24, 2015, Commission Meeting Minutes Department Reports A. Director's Report B. Status of Regulations Monthly Report C. Division Permit Reports IV. Public Comments V. Commission Reports A. Chair Ann Henry 1. Presentation of Plaque to Commissioner Mike Armstrong 2. Presentation of Plaque to Commissioner Darwin Hendrix 3. Presentation of Plaque to Commissioner John Simpson 4. Presentation of Plague to Commissioner William Thompson B. Regulations Committee - Randy Young 1. Regulation No. 23, Hazardous Waste Management - Docket No. 15-001-R - Tammie J. Hynum for Arkansas Department of Environmental Quality - Minute Order (Initiate) (Item #042 zteffi #182 hams 19-23 APPENDIX I (Items #05-12 VI. Request to Expend More than $2,000,000.00 from the Landfill Post -Closure Trust Fund - Benjamin T. Jones for Arkansas Department Of Envirorff-,ental Quality - Minute Order (Adopt) VII. dininistrative Law Judge - Charles Moulton A. Reco_mraended Decision 1. In the Matter of Chicot Sewer Systems, LLC Docket No. 15-003-NOV Minute order (Adopt) APPENDIX II Ir �eaz_ #13) APPENDIX III frtem-- ,14--15) 2. In the Tatter of Decision of Interim APPENDIX ITT Director J. Ryan Benefield and Pulaski County (Ytems Solid Waste Management District Board -- Docket No. 15-001-MISC - Minute Order (Adopt) VIII. Adjourn. ARKANSAS POLLUTION CONTROL AND ECOLOGY C0141ISSION IN THE INTER OF CHICOT 1 DOCKET NO, 15-003--NDV SEWER SYSTM4S, LIC ] ORDER NO, 2 RECO3M1ZNDZD DECISION Appearances: Mr. Ken Harper for Chicot Sewer Systems, LLC; Mr. Michael McAlister for Arkansas :Department of Environmental Quality. I. IN TR0IDUCTION Chicot Sewer System, L;,C ("Css") operates a wastewater treatment facility located at 14124 Chicot Road, Mabelvale, Saline County, .Arkansas. On February 5, 2015, the Arkansas Department of Lnvironmental Quality ("ADEQ") issued a Notice of Violation ("NOy"), LIS '15-020, to CSS for alleged violations of the Arkansas Water and Air Pollution Control Act, Ark. Code Ann, §§ 8-4-101 et seq.; the Federal Water Pollution Control Act, 33 U,S.C, §§ 1311 et seq.; Regulation No. 2 and Regulation No. 6, On March 12, 2015, Mr. Ken Harper faxed a Request for Hearing to the Arkansas Pollution Control and Ecology Commission ("Commission") office and on March 13, 2015, JADEQ filed a Motion to Dismiss CSS's Request for Hearing. ADEQ alleges the CSS Request for Hearing has been filed too late; that the Request for Hearing did not include a complete and detailed statement identifying the legal issues and factual objections being appealed and did not comport with Reg. 8,603(C)(1)(c); and that CSS's Request For Hearing was filed by a non -attorney and Reg. 8,602 requires a corporation in an adjudicative proceeding to be represented by an Docket !10, 15-003-NOV Order No. 2 Page Uo. 2 attorney. II. JURISDICTION The Commission has jurisdiction; over this matter pursuant to Arkansas Code Annotated § 8-1-203(b)(5), which authorizes the appeal of an enforcement action. III. STANDARD OF REVIEW under .Rule 12(b)(6) the Commission's administrative law judge ("ALJ") must review the facts alleged in AJOEQ's motion in a light most ,Favorable to CSS, the non-moving party. Neal v. Wilson, 316 Ark. 588, 595-96, 873 S.W.2d 552 (1994). iV. FINDINGS Or FACTS 1. CSS operates a wastewater treatment facility which is regulated pursuant to the National Pollutant Discharge Elimination Program ("NPDES") and CSS was issued Permit No. AR0047261 ("the Permit"). 2. On August 7, 2013, an ADEQ water inspector conducted an inspection of the CSS facility in response to a complaint. 3. On August 22, 2013, ADEQ conducted a follow-up inspection and took water samples from CSS's permitted discharge. The results of those water samples demonstrated elevated levels of fecal coliform, bacteria and decreased levels of dissolved oxygen in violation of Part 1, Section A, of the Permit. 4. On August 28, 2013 the Department notified CSS of the results of the August 22, 2013 inspection; on September 11, 2013 and September 23, 2013, the Department received CSS's responses; on Dacket No. 15-003-140V Order No. 2 Page 11o. 3 October 16, 2013, the Department notified CSS that its responses were inadequate; and on October 30, 2014, CSS responded to the Department's October 16, 2013, letter. 5. On February 25, 2014, an ADF.Q water division inspector conducted a compliance inspection of the CSS facility and found that an unpermitted discharge was taking place into a tributary of Fourche Creek. 6. Water samples taken from this unpermitted discharge demonstrated elevated levels of E. coli, fecal coliform bacteria, and ammonium nitrogen. Water samples taken from CSS's ,permitted discharge demonstrated elevated levels of ammonium nitrogen above the permitted level and levels of dissolved oxygen below the permitted level. 7. The ADEQ inspector notified CSS on February 25, 2014, by telephone that an unpermitted discharge was occurring from the CSS facility. S. A follow-up inspection conducted on February 27, 2014, revealed the unpermitted discharge was continuing. 9. On March 5, 2014, the Director issued Emergency Order LIS 14-021 ("EO") against CSS and on March 6, 2014, representatives of CSS met with the Director to discuss the EO. 10, On March 10, 2014, CSS submitted photos that showed the unpermitted discharge had ceased. 11. ADEQ served a cover letter, a copy of the NOV, and a copy of Commission Regulation No. 8 upon CSS via certified mail on Docket No. 15-003-NOV Order No. 2 Page No. i February 11, 2015. The NOV required CSS to eubmi.t a corrective action plan and assessed a civil penalty in the total amount of. $33,000. 12, The certified mail receipt number 7006 3450 0003 4067 7349, as well as the returned certificate and LISPS tracking information, confirmed delivery of the NOV to CSS or, February 11, 2.015 . 13. A separate set of identical documents was also sent February 6, 2015, to CSS's registered agent for service of process, Janet Harper, via certified mail, restricted delivery. A copy of that letter reflecting the certified .mail, receipt number 7006 3450 0003 4067 7493, as well as USPS tracking information indicated that notice was left but "No Authorized Recipient Available." 14. ADEQ's NOV states that if CSS wishes to dispute the Allegations and Proposed Findings of Fact or the Proposed Civil Penalty Assessment and Order, then CSS must file a written request for hearing with the Commission in compliance with Regulation No. 8 within twenty (20) calendar days of receipt of the NOV. 15. The cover letter served on CSS on February 11, 2015, re- states that a written request for hearing must be filed with the Commission within twenty (20) calendar days of receipt of the NOV. 16. Twenty (20) calendar days from February 11, 2015 was Tuesday, March 3, 2015. 17. CSS's Request for Hearing was filed with the Commission by facsimile on March 12, 2015. Docket No, 15-003-NOV Orden' No. 7 119e Ito. 5 18. CSS's Request for Hearing was filed by Mr. Ker Harper and CSS is a limited liability corporation. 19. CSS's Request for. Hearing consists of one (1) paragraph which states, in its entirety: Please be advised that I just received your notice of violation. i have called and spoke to Pat C,off and I an, writing this to request a hearing. Chicot Sewer systems, LLC will take immediate actions to come within compliance with all discharges that are currently out of compliance. Pat Goff advised me +Go ask for a telephone hearing. At your convince (sic) please call me at 501-837-7690. Your help in correcting this matter is appreciated. Thank you very much. 20. Commission Reg. 8.602 requires a corporation in an adjudicative proceeding to be represented by an attorney. 21, On April 2, 2015, the Commission's ALJ held a preliminary hearing via telephone conference call with counsel for PLDEQ and Mr. Ken Harper for CSS. During this telephone conference call Mr. Harper confirmed to the ALJ that he is not a licensed attorney in good standing in the state of Arkansas, and CSS had no plans to retain counsel. V. DISCUSSION AND CONCLUSIONS OF LAW Commission Reg.8.602 requires corporations to be represented by an attorney in all Commission adjudicatory proceedings, and it has been settled by the Arkansas Supreme Court that the practice of law is not confined to services rendered by an attorney in court of justice, but includes any service of a legal nature rendered outside of courts and unrelated to matters pending in the courts. Nisha LLC v, Tribuilt Construction Group, LLC, 2012 Ark, 130 (Ark. Docket No. 15-003-140V Order No. 2 P&9e ::o. 6 2012). The Commission's adjudicatory hearings are conducted in a manner that mirrors the standard practice of law. Typical pre - hearing practice consists of pleadings and motions being filed, discovery being propounded, and depositions being taken. The adjudicatory hearings are characterized by opening and closing statements, direct and cross examination of witnesses, and the occasional voiz d1re of expert witnesses. In short, appearing before the Commission on behalf of a corporate client is, without a doubt, the practice of law. That is why Commission. Reg.8,602 requires corporations to be represented by an attorney in all Commission adjudicatory proceedings, and why the At,J dismisses this appeal pursuant to Reg.8.602. Because this appeal is being dismissed pursuant to Reg.8.602, the ALJ is not reaching the merits of ADEQ's two other points in support of dismissal - that CSS's Request for Hearing was filed too late in violation of Reg.8.403 and CSS's Request for Hearing did not comport with Reg. 8.603(C)(1)(c). IT IS THEREFORE ORDERED: 1. Under the provisions of Regulation No. 8.602 the ALJ grants ADEQ's Motion to Dismiss with prejudice. RECOMMENDATION It is the recommendation of the administrative law judge that the Arkansas Pollution Control and Ecology Commission adopt and affirm, without modification, the findings of fact and conclusions Docke[ Uo. 15.003,HOV order 140. 2 Page Vo- 7 of law set out in the above Recorimended Decision. IT IS SO ORDERED This 2i3 day of April 2015 Ch es Moulton Administrative Lax Judge 'Docket NO. :5-003-NOV Order Ho. 2 Page No. 9 CERTIFICATE OF SERVICE I, Patricia Goff, Commission Secretary, hereby certify that a copy of the foregoing Order No. 2, In the Matter of Chicot Sewer Systems, LLC; Docket Va. 15-003-Nov has been mailed by certified mail or by first class mail, postage prepaid to the following parties of record, this 2"a clay of April 2015. CERTIFIED MAIL 7013 0600 0001 8188 2188 Ken harper Chicot Sewer Systems, LLC PO Box 942 Bryant, AR 72089 (501) a37-7690 Michael McAlister Arkansas Department of Environmental Quality 5301 Northshore Dr. North Little Rock, AR 72118 (501) 662-0918 (501) 682-0091 111 Patricia Goff Cv-� Commission Secretary Arkansas Pollution Control and Ecology Commission_ 101 East Capitol, Suite 205 Little Rock, Arkansas 72201 (501) 682-7890 FAX: 682-7891 ARICANSAS POLLUTION CONTROL Chicot Sewer Systems, AND ECOLOGY COMMISSION LLC Docket No. 15-003-NOV MINUTE ORDER NO. 15 - PAGE 1 OF 1 On April 2, 2015, Charles Moulton, Administrative Law Judge ("ALJ"), issued Order No. 2 (Recommended Decision) in Docket No. 15-003-NOV, which is a case styled: In the Matter of Chicot Sewer Systems, LLC. Order No. 2 grants ADEQ's Motion to Dismiss with prejudice. The record compiled in this docket by the Administrative Law Judge and Order No. 2 came before the Commission at its May 21, 2015 meeting. After considering the matter, the Commission adopts and affirms, without modification, Order No. 2 (Recommended Decision) entered on April 2, 2015, and closes this docket. COMMISSIONERS J. Bates NI. Goggans L. Bengal R. Moss J. Chamberlin Et. Reynolds It. Chastain W. Stites J. Fox B. White C. Gardner R. Young SUBMITTED BY: Charles Moulton PASSED: 5/21/15 A. Henry - Chair UPDATED STATUS REPORT AND PROPOSED ACTION PLAN FOR WA STE WA TER COLLECTION AND TREA. TMENT SYSTEMS PREPARED FOR MARBLE FALLS SENDER .IMPROVEMENT DISTRICT NUMBER ONE MARBLE FALLS, ARRANSAS AUGUST 2010 ENGINF.F-RING SFRVICFS, INC. 1207 SOUCII OLD MISSOURI ROAD • P. O. Box 282 • SPRINGDALE, ARKANSAS 72765-0282 479-751-8733 •479-751-8746 (Fr1X) • w %vw.EVGINLl.RI.\IOSERVICES.CONI 13 TABLE OF CONTENTS I. GENFRA.L OVERVIEW.......... 1-1 2. PROGRESS TO DATE & UPDATED SYSTEM STATUS .......................................... 2-1 3. PROPOSED ACTION PLAN TO COMPLETE SYSTEM WPROVEMENTS Phase I Improvements .............................. ........................................ ............ ..................... 3-1 Phase 11 Improvements .............................................. I....... .. ......... ? ............................. 3-6 Phase III Improvements ........... ........................ 11 ...... m— ............................................ 3-1.0 4. SUMMARY ............................ ......................................................................................... 4-1 APPENDICES Appendix A - Preliminary Injunction Consent Decree Appendix B - August 12, 2010 Effluent Sample Test Results Appendix C - C112M Hill OMI Lift Station Assessment LIST OF FIGURES Figure 3,1 Diagram of Phase I Improvements ............. 3-4 Figure 3.2 Cost .Estimate - Phase I Improvements............................................................. 3-5 Figure 3.3 Diagram of Phase 11 Improvements.................................................................. 3-8 Figure 3.4 Cost Estimate - Phase II Improvements............................................................ 3-9 Figure 3.5 Diagram of Phase III Improvements .......... ..............................................3-11 Figure 3.6 Cost Estimate - Phase .III Improvements....................................................3.12 it 1. GENERAL OVERVIEW The existing collection and treatment systems serving Marble balls were designed in the late 1960's. In recent decades, the system has fallen into disrepair and has been found to be in violation of Arkansas Department of Environmentai Quality ("ADEQ") and Arkansas Department of health ("ADH") regulations numerous times. Most recently, the District experienced a major failure of their primary lift station. The failure occurred during the ice storm in early 2009, and raw sewage discharged into a nearby stream which flows into a tributary of the Buffalo National Diver. For several months, the District hauled sewage from the lift station to a manhole on the gravity line upstream of the treatment facility, However, the vehicle used by the District to haul the wastewater was vandalized, rendering the .District unable to haul the sewage any longer, resulting in the sewer discharge. In response to the lift station failure and ensuing sewage discharge, ADEQ filed a lawsuit (Case No. CV 2010-10-1) to force the Marble Falls Water, Sewer and Solid Waste Disposal Suburban Improvement District ("the District") to bring their wastewater system into compliance with permit requirements and state and federal regulations, At a hearing on March 2, 2010, the District was placed under a Preliminary Injunction Consent Decree (included in the Appendix) requiring the District to take specific steps to address the sewer system deficiencies. Since that time, the District has worked to ensure that all provisions of the court order were satisfied. The District retained Engineering Services, Inc. to prepare evaluations of the system and a Preliminary Engineering Report, hired licensed wastewater operators to maintain and operate the system, and has made repairs to various components of the existing system to reduce the potential for adverse impacts resulting from its operation. At the direction of the District, this report has been prepared to document the District's efforts to date to meet the requirements set forth in the court order, provide an updated status of the existing system, and provide a proposal outlining measures for the District to take to complete the remaining items of work and bring the system into full compliance with NPDES permit requirements, regulations and the court order. 2. PROGRESS TO DATE & UPDATED SYSTEM STATUS At a Circuit Court of Newton County, Arkansas hearing on March 2, 2010, the District was placed under a Preliminary Injunction Consent Decree (included in the Appendix) requiring the District to take specific steps to address the sewer system deficiencies: A) Complete installation of the new lift station, and continue operation of the temporary pump until the new lift station is complete. 13) Retain a Class 1.1 licensed operator for the wastewater treatment system. C) .Retain a professional engineer to evaluate the existing wastewater treatment system and recommend a plan of action to address the long terra wastewater treatment needs of Marble Falls, with evaluation to be submitted by April 6, 2010. D) Secure funding for wastewater treatment System rehabilitation/replacetnent. E) Retain a professional engineer to evaluate the existing wastewater collection system and recommend a plan of action to upgrade and/or rehabilitate the system, with the evaluation to be submitted by a date established during a telephone conference hearing on April 9, 2010. F) Take all reasonable measures to prevent further discharges of untreated effluent and comply with the District's NPDES permit. Since the issuance of the Preliminary Injunction Consent Decree, below is a summary of the activities the District has taken per the Injunctive Terms of the decree: A) The District submitted the lift station plans prepared by Nelson Engineering on January 21, 2010 to the Arkansas Department of Health. The plans were approved by the Department of Health on April 13, 2010. Funding for the new lift station will be pursued and the lift station will be installed pursuant to the proposal in Section 3, if the proposal is approved by ADEQ. With assistance from the Arkansas Rural Water Association, a temporary pump was placed into operation in February of 2010 at the failed lift station. The District continues to operate this temporary pump system, which is still in place. Since the installment of 2-1 PROGRESS TO DATE & UPDATED SYSTEM SrA T'US the temporary pump station, there has been no unauthorized discharge from the failed lift station site, B) On June 1, 2010, the District retained the RK Water Operations, LLC as the licensed wastewater treatment operator for the District. RK Water Operations, LLC has two (2) Class 3 licensed wastewater operators. The operators have repaired the clarifier skimmer arm and resumed normal operations of the District's Wastewater 'Treatment Plant. The results of a sample taken from the wastewater treatment plant's clarifier on August 12, 2010 are included in the Appendix; C) On March 9, 2010, the District retained the professional engineering services of Engineering Services, :Inc. ("ESI") to perform a diagnostics of the wastewater treatment plant system and wastewater collection system to determine the condition of the system and provide recommendations to rehabilitate the system. The wastewater treatment plant evaluation and plan of action was completed by EST and delivered to the Arkansas Department of Environmental Quality on April 6, 2010. The District requested and received assistance from Arkansas Rural Water Association in .March of 2010 to conduct a smoke test of the integrity of the District's collection system lines. The results of the smoke test were utilized by ESI in the development of the wastewater collection system evaluation. The wastewater collection system evaluation and plan of action was completed by ESI and delivered to the Arkansas Department of Environmental Quality on April 29, 2010. Based upon the findings of the wastewater treatment plant system diagnostics study and the wastewater collection system diagnostics study. ESI prepared and submitted a Preliminary Engineering Report for the District to the Arkansas Department of Environmental Quality on May 20, 2010. The Preliminary Engineering Report recommended improvements to the wastewater collection and treatment systems to improve the collection system and provide a reliable means of wastewater treatment. D) Since the completion of the Preliminary Engineering Report, the District has pursued financing to make the improvements recommended in the report. On July 7, 2010, the District received a letter of recommendation for the project from the Arkansas Water and Wastewater Advisory Committee ("WWAC"). WWAC approval is 2.2 PROGRESS TO DATE & UPDA TED SYSTEV STATUS required prior to receiving public funding for any water or wastewater improvement project in the State of Arkansas. On August 5, 2010, the District received notification from the Arkansas State Highway and Transportation Department ("AHTD") that AHTD would reimburse the District for the relocation of collection lines to be impacted by the widening of State Highway 7 in the amount not to exceed $292,307.00. Applications for funding for the remaining improvements have been made to the Arkansas Natural resources Commission ("ANRC") and the United .States Department of Agriculture -Rural Development ("USDA-rD"), which provide loan and grant funding for water and wastewater projects in Arkansas. The District also has prepared an application for funding through the Ike 2 Community Development Block Grant Fund Disaster Recovery Assistance funding program administered by the Arkansas Economic Development Commission ("AEDC"). Because applications for funding .from the Ike 2 program are limited to cities and counties, the District's Ike 2 application must be approved and signed by Newton County Judge John Griffith. Judge Griffith has expressed support for the project and has placed consideration of the application on the agenda for the September 7, 2010 Newton County Quorum Court meeting. If approved by the Quorum Court, the application will be signed and submitted to AFDC for funding. The District will continue to pursue funding for the additional needed improvements in accordance with the proposal in Section 3 of this document, if approved by ADE;Q. E) As noted previously, the evaluation and plan of action for the wastewater collection system was prepared by EST and submitted to ADEQ on April 29, 2010. Due to collection system concerns raised by the Arkansas Department of Environmental Quality at a court teleconference on June 30, 2010, Arkansas Rural Water Association conducted an evaluation of the District's collection lines and lift stations on July 1-2, 2010 per a request from the District. This evaluation consisted primarily of dye testing, and the results of the study showed that effluent from both lift stations was reaching the wastewater treatment plant. 2-3 !'RO(� RESS TO DATE & UPDATED SYSTEM STATUS F) Since the issuance of the Preliminary Injunction Consent Decree, the District has made great strides in improving the operation of the existing systems. In conjunction with Cii2M Hill UIvII and a representative from the Community Resource Group, the District's licensed operators conducted an evaluation of the District's small lift station and wastewater treatment plant on July 15, 2010 to provide an updated assessment of the operational treatment plant. This assessment is included in the Appendix to this document. The District and the operators from RK Water Operations, LLC have made several improvements to the treatment unit since the Preliminary Engineering Report ("PER.") was submitted, and many of the deficiencies noted in the PER have been corrected. Some of the most notable improvements are: • The skimmer arm in the clarifier has been repaired and now functions correctly. • The aeration system has been repaired and also now function correctly, although only one two blower units is functional, providing no redundancy in the system. • The tablet chlorination unit located at the out -fall from the treatment unit into the pond is now operational. Since the improvements to the treatment plant have been completed, the treatment unit is operating at a much higher level of performance than during the initial evaluation by ESI. A sample of water from the clarifier unit of the treatment plant was taken on August 12, 2010 and tested. The test results from the sample are included in the Appendix. Since January 2010, the District has replaced two (2) line segments and cleared seven (7) plugs in the gravity collection lines to improve the operation of the collection system. As indicated above, the District has satisfied several requirements of the Injunctive Terms of the court order, and has made substantial progress towards the satisfaction of all items. Work is currently underway to bring the system into full compliance with the Injunctive Terms as well as with the NPDES permit requirements and state and federal regulations regarding wastewater systems. The following section provides a proposal for completing the items or work necessary to successfully complete this process. 2-4 3. PROPOSED ACTION PLAN As discussed in Section 2, the District has made substantial progress toward satisfying all terms of the Preliminary Injunction Consent Decree. However, several steps still remain to completely bring the Marble Falls wastewater system into ,full compliance with all Injunctive Terms, NPDES permit requirements, and state and federal regulations. This section provides the District's proposal for completion of these remaining steps, which are divided into three phases. 3.1 - Iffi%SE II Phase I includes the items of work which are necessary to complete as quickly as possible to address issues which pm-ent an imminent threat to the residents and environment in the vicinity of Marble Falls or which are necessary to responsibly and safely operate the wastewater system. These items include: A) AHTD Sewer Line Relocation B) Lift Station 2 (Small Lift Station) Pump Replacement C) Installation of New Lift Station to Replace Temporary Pump D) WWTP Laboratoryffesting Equipment and Supplies E) Emergency Repairs to Existing Treatment Plant F) Monthly Testing at Chlorination Vault (Outfall into Pond) A) AHTD is in the process of modifying Highway 7, which serves as the western boundary of the District's service area. As part of this process, AHTD has expanded the Highway 7 right-of-way. The new right-of-way encompasses several hundred feet of existing sewer main, which therefore must be relocated. AHTD has agreed to provide up to $292,307 in funding to construct a new sewer main which will divert all of the wastewater which currently flows to Lift Station 2 to Lift Station 1 instead. This will allow the District to temporarily discontinue use of much of the existing collection system, as well as Lift Station 2 and Force Main 2. By reducing the amount of infrastructure they must maintain and operate, the District will reduce monthly operating and maintenance costs, but still provide wastewater service to all but two current customers. The two customers which will no longer be served by the system will be provided with septic systems as part of this project. Construction plans and specifications for these improvements have been submitted to the Arkansas Department of Health for approval. B) There are two existing pumps in Lift Station 2 (small lift station located in amusement park) which are designed to operate alternately and provide redundancy for one another. 3-1 PROPOSED ACTION PLAN One of the two pumps has failed, and the tuber pump, due to its age, could potentially fail at any time. Use of this lift station will be temporarily discontinued following completion of the AHTD sewer main relocation. However. the permit, bid, and construction process for the sewer fine relocation could potentially tal'ce several months. The risk posed by relying on a single operational pump :n the interim is too high to allow, and immediate pump replacement is recommended. Because any new pumps would only be in service for a short period before use of the lift station is discontinued, it would be more advantageous to repair the existing failed }pump, if possible. This would provide the lift station with two aged but operationaiwri'mps, which will likely be sufficient until the AHTD relocation is complete. If repair i6-hot possible, it is likely that the funding agency for Phase I will only provide funding for new pumps with the condition that they be returned to the funding agency once t Wj)f the lift station is discontinued. C) plans for a new lift station to replace Lift Station l (the large lift station, which failed during the ice storm of 2009) were developed by Vern Nelson. P.E. and have been approved by the Arkansas Depart.meni-of Health. The new lift station will be located cast of Highway 7 along the south side of Highway 7 Spur. A new two inch diameter force main will be installed within the existing force main. Once the new lift station is constructed and operational, the ternpv+ yy pump at the failed lift station will no longer be required. -= D) The District has retained the serviccUf RK Water Operations, LLC to operate and maintain the treatment system. RK Water Operations, LLC has two Class 3 licensed wastewater operators, and is well qualified perform this task. However, in order to properly operate and monitor the system, the operators need laboratory and testing equipment and supplies. These are standard items which should be present at any 4 permitted treatment facility, and on -site' laboratory and testing capability is required by ADEQ regulations. E) The Preliminary Engineering Report and the evaluation compiled by CH2M Hill OMI noted many deficiencies at the existing treatment plant. Although progress has been made and the plant is operating at a much higher level than during initial assessments, many problems are still present which pose imminent threats to the ability to continue operating the plant until a new plant is constructed. These items include replacement of wiring and a control box, installation of a small blower unit to provide redundant aeration capability, installation of an alarm system, and providing water service to the treatment plant site. 3-2 s�t0 PROPOSED ACTION PLAN F) Phase I includes implementation of a monthly testing program. The program will consist of testing a sample from the outfall into the pond once a month, which will be tested by a certified laboratory to determine effluent characteristics. This testing is not required under the current NPDES permit, but is being undertaken voluntarily in order to establish the quality of effluent being produced by the treatment unit and discharged into the polishing pored. The test results will also give the District an objective statistic that can be used to monitor the performance of the operators. The NPDES permit does require a monthly monitoring report, but the official testing location established by the permit is the outfall from the pond to the receiving stream. There has been no recorded discharge from this location in recent history, and the required official monthly report therefore will simply .note "No discharge". In order to provide regular data to monitor the treatment system's performance, institution of this alternate testing program is proposed. Phase I also includes payment for initial professional engineering services already provided to the District, which included preparation of the evaluation of the treatment system, the evaluation of the collection system, and the Preliminary Engineering Report, which were required by the Preliminary Injunction Consent Decree. Figure 3.1 is a diagram of the improvements included in Phase 'I of this proposal. The anticipated total cost of Phase I is approximately $168,177.50, and a preliminary cost estimate is included as Figure 3.2. Because funding for the AHTD sewer line relocation has already been secured, the sewer line relocation is not included in the total estimated cost for Phase I. The sewer line relocation has been submitted to the Arkansas Department of Health for approval of construction plans, and construction is anticipated to be complete in eight months. The remainder of Phase I is dependent upon obtaining funding for the proposed improvements. Once funding has been secured, Phase I is anticipated to be completed in eight months. 3-3 Por6on of Gravity Main Within New Highway Right -of --way PROPOSED ACTION PLAN Figure 3.1 Diagram of Phase I Improvements Lift Station I (To Be Abandoned) PMPOsed Lift Station - (By Vem Nelson, F.E.) ,0 Proposed jC'CP1­_ SopticSystwnN �t \./- (TO M Proposed • Septic systarn false) Use of This Podion of Lateral 6 To Be Discontinued Lateral 4 (Use to Be Discontinued) Lateral 4 (Use to be Disconflnued) Lateran (To Remain in Use) • Station 2 Replace Pumps ( Use to be \Dismntiflued) 1 Latem] 7 (Use to be Discontinued) ........... Force Main 2 (Use to be Discontinued) Treatment Plant Lat (Use 1. Emergency Repairs 2. Lab Equip. & Supplies Portion of Lateral 2 and I" Main i to Be Abandoned Portion of Lateral 2 and Force Main I to Remain In Use -Proposed Gravity Main Extenslon Portion of Lateral 6 To Remain In Use '0 Lateral I (To Remain In Use) LEGEND E_NWng Grwlky Main ID Rwnaln In Use ..... . ..... ExWng GMM MaIn use b be DisaDnInued •..... Propuliad Grzvlty Main DdwWon ExImIN Farm Main to RwrmM In Use EA9*V FQrw Main Use to be DWconInued L— — Roads ng PROPOSED ACTION PLAN Figure 3.2 Cost Estimate - Phase I Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COST A®EQ PROPOSAL - PHASE I MARBLE FALLS SEWER IMPROVEMENT DISTRICT #1 AUGUST 2010 DESCRIPTION OF ITEM ESTIMATED _ AMOUNT JT5,000.00 Small Lift Station Pump Replacement $ Treatment Plant Water Corinect'an. Lab Equlpment, Control Box, Wiring; s, Alarm System $ 35,000.00 New Treatment Plant Electrical System $ 151000.00 TOTAL, ESTIMATED CONSTRUCTION COST ; 651000100 Conlingercy (100/.) $ 5,50000 Design Engineering (11?'a) $ 6,05000 050 Construction Inspection (5 2590) $ 2 50 Administrative Engineering for Diagnostics Studies f1equired by Consent Order $ $ 2.500 00 7 Engineering for peas llhy StudylPrellminary Engineering neport required by Consent Order $ ,500.()0 12,5W.00 ESTIMATED COST - PHASE I SUBTOTAL $ 91,937.50 New Litt Station to Replace Failed Lift Station I by Vern Nelson, P.E. (Cost provided by Vern Nelson, P-E.) $ 41 41,740.00 Increase Capacity of New Lilt Station to Accommodate Diverted Flow Irom Lift Station 2 $ Seplic Systems for 2 Customers ($7,500 Feach) $ ,740.00 15,000 00 TOTAL ESTIMATED COST - PHASE 1 $ 168,177.50 Note: Phase I Includes construction at a new section of sanitary sewer main to divert wastewater from Litt Station 2 (small Ilh station) to the new tiff station. AHTD has obli ated funds for this Portion of Phase 1, $ 292,307,00 3-5 PROPOY D AMON PLAN 3.2 - !PHASE till Phase II includes items which are important for system operation and maintenance, but which do not represent as urgent a need as those items in Phase I. The items in Phase 11 will enhance the operation or maintenance of the system, but their immediate installation are not absolutely essential. Phase 11 includes: A) Sewer Line and Manhole Rehabilitation B) Existing Treatment Plant I:mproverrients (Also Utilized by New Treatment Plant) C) Installation of Security Fencing A) Several deficiencies in the gravity collection system which is to remain in use were noted during the smoke testing and described in the Preliminary Engineering Report. These items include replacement of sections gravity sewer lines and replacement and repair of damaged manholes. Completing these items of work will reduce the potential for inflow and infiltration, reduce frequency of clogs which can result in sewage overflows, and reduce the operation and maintenance expenses incurred by the District. The manholes and sections of pipe which will be rehabilitated in Phase 11 are indicated in Figure 3.3. B) Phase II includes several improvements to the wastewater treatment unit which will be used by the existing system, and will also be utilized by the new treatment system once it is placed into operation. This item includes include modification of the headworks box to include a bar screen, which will prevent large solids from entering the treatment unit. This item includes installation of a new chlorination system and chlorine contact tank, construction of a step aeration system and modifications to the plant outfall piping and discharge location to acco.nunodate the new components. Flow monitoring capability will also be installed. These items will be constructed in such a manner and location that they will be able to remain in place once the new treatment plant is constructed and will be utilized as part of the new plant's treatment process. These improvements are intended to allow continued operation of the existing treattent plant until funding and permits are obtained for the new treatment plant. C) Currently there is no fencing to restrict access to the treatment plant or equipment building. Current security measures include a locked barrier on the stairs up the side of the treatment unit, a lock on the door to the equipment building, and a locked gate accessing the chlorination vault at the outfall to the polishing pond. A diagram of the proposed improvements under Phasc I1 of this proposal is included as Figure 3-6 PROPOSED ACTION PLAN 3.3. The cost to complete Phase II is estimated to be approximately $168,850, as indicated in the Phase 11 Preliminary Cost .Est►mate included as Figure 3.4. Once funding for Phase Il is secured, it is anticipated that construction will be complete in approximately eight months. 3-7 PROPOSED ACTION -PLAN Figure 3.3 Diagram of Phase 11 Improvements Instag Manhole Replace 58.06 L.F. of Existing Sewer Main Replace 194.56 L.F. of EAsting Sewer Main Rehabilitate Manhole LEGEND Rehabilitate----- 4 Manhole Rehabilitate Manhole Remove Concrete Stubout / Repair Una Replace 285.26 L.F. of Exlsbng Sewer Main rs Remove concrete - • stubouts/repair lines Replace 234.64 L.F. of ....... Existing Sewer Main Treatment Plant 1. Headymrks Vault 2. Chlorination System N 3. Stop Aeration 4. Modify Outfall Piping 5. Flow Monitoring 6, Security Fencing Pond Fidadna GwIty Main to Rarnign In Use ...... ExftV ahm* M& Use to be Dawod E)ftdn Face Mah b Remain In Use Eidadng Fom Main Um to be Dlowntinum! Roads PROPOSED ACTION PLAN Figure 3,4 Cosy Estimate - Phaase II Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COS ADEQ PROPOSAL — PHASE 11 MARBLE FALLS SEINER IMPROVEMENT DISTRICT #1 AUGUST 2010 DESCRIPTION OF ITEM ESTIMATED A_ MOUNT Sewer M31n Replacement $ 38,860,00 Manhole Rehabilitation $ 7,.500,00 Remove Existing Stubouts and Repair Sewer Main $ 7,500,00 Proposed Manhole at and of Lateral 2 $ 3,500,00 Modification of Existing Headworks Vaud and Installation of Bar Screon $ 5,000,00 Instaliatlon of Now Chlorination system with Contact Tank S 12,50R00 Construction of Step Aeration and Aeration Tank $ 25,000,00 Reconfigure Outfail Piping / Modi;y Discharge Location / Flow Monitoring Equipment $ 10,000.00 Construction of Security Fencing and Cates $ 16,WO 00 TOTAL ESTIMATED CONSTRUCTION COST S 125,880,00 Contingency (100/.) $ 12,SH 00 Design Engineering (IM) $ 12,588 00 Construction Inspection (50/6) $ 6,294.00 LegaVEond Counsel $ 10,000.00 Administrative/Permitting $ 1 504 00 TOTAL ESTIMATED COST - PHASE II $ 168,850.00 3-9 PROPOSED ACTION PLAN 3.3-En,sEIII Phase III of the proposal includes installation of a new wastewater treatment facility as detailed in the Preliminary Engineering Report, ether than items which will have already been installed in Phase I or Phase II of this proposal. All parties are in agreement that continued operation of the existing treatment plant is not a viable long tertt option for the District, and that a new treatment plant is a priority. However, due to the low revenue levels of the District relative to the cost of the new treatment facility, funding for the new treatment system will have to consist primarily of grant funding, The amount of time necessary to secure sufficient grant funding is difficult to anticipate. For this reason, it is important that the District improve the existing infrastructure sufficiently through Phase I and Phase .11 of this proposal to allow continued .operation of the existing facilities until funding for the stew plant can be secured through Phase fit. A diagram of the proposed treatment facility is included as Figure 3.5, and a preliminary cost estimate of the new treatment facility is included as Figure 3.6. The treatment facility is anticipated to cost approximately $419,375, Once funding for Phase ill is obtained, it is anticipated that construction of the proposed improvements will be complete in approximately sixteen months. 3- l0 PROPOSF.O AC]ION PLAN Figure 3.5 Diagram of Phase III Improvements *T — ,z _ — � � y' � OAie11T►MW j 4 f�C R.e�W WSJ IaSiLF.�l�P1 F?i�i C{T1Da l0 WfaY•Td 1�i 1 .�,y}yq py 5 aomLrETaa6 (.a1 wMHMM5CiH7! � *IAM �, a+R►uao..wweq h�i l Un i Farm TiEA% nW 1 ' � 1 � 'I � ' I 11 TICATEZ7B9R1fiff MAW To SAaC( f 41 MET= e 1l 5 0� •, � . h 11 r.�T—.� 00RN0 ANl)rE•- TRIn vatm i EIMIIO7Tiai b fmURSOM TOY roaiBeynwr crM ilk ��T� �, � TtThflYT1�/ITYvrfwr '� :5 LOUNM co HOW OIYN�OiIil /tip � - . =aut�.wwau� � � ♦ -- UE rkm — — _ — TrEAlbriMTJi( law do-ok ! 10 CgAnxiawyAlm 018rNO MAlb Oran 'NIOMWA'It AOCAW Y N `!L� W TAW M I 1A&aMff ITA M f araTT7�amra>,cTT�va o+«R 6 WW nQ K/MTd aroMnoK •niu GgmIrhm* 3-ll PROPOSED WTION PLAN Figure 3.6 Cost Estimate - Phase III Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COST A®EO PROPOSAL - PHASE III MARBLE FALLS SEWER IMPROVEMENT DISTRICT #1 AUGUST 2010 DESCRIPTIONDESCRIPTIONOFITEM ESTIMATED AMOUNT Yard Piping tp NGW 20,OW Gabon Ser ling Tank $ 20,0W 00 Installation of 20,004 gallon Settling Tank $ 60,000.00 fnslalration of 20.000 gallon Recirculaslon Tank $ 60,000 00 Yard Plpfng for NitraiE FlecircuWior7 Feature $ 12,5W 00 System Component Pumps $ 5,0w00 Installation of Filter Pods $ 1 I0,0w 00 Inulali-3lion of 5,000 gallon Porishing Tank $ 25,000 00 Construction of Seoudly �encing and Galas $ 16,000.00 Pumping and Disposal of WW from Existing Aeration Basin and Cbrifier (38,000 gal) $ 2,5W,00 Rehabilitation of Exlsfing Building S 6,500.00 TOTAL ESTIMATED CONSTRUCTION COST $ 317,SM,00 Contingency (100/.) $ 31,750,00 Design Engineering (10%) $ 31,750.00 Construction Inspeclion (50%) $ 15,87500 Legal / Hand Counsel $ 20400 00 Adminlslrative ! Permitting $ 2,500 00 TOTAL ESTIMATED COST - PHASE III $ 419,375.00 3.12 4. SUMMARY If the proposal is approved by ADEQ and implemented by the District, it is the opinion of the engineer that the required improvements to the existing wastewater collection and treatment systems can be completed in a mariner which will provide a long term solution to the needs of the residents of Marble Falls while also protecting the public health and environment in the area. The proposal allows the District to address the most immediate needs of the system first, and also provides a process whereby the remaining needs can be met without danger of health or environmental damage occurring in the interim. The three phases of proposed improvements to the wastewater system are summarized below: Phase I - Estimated Completion Date: Eight Months from Funding Obii atlon Funding has been secured from AHTD for diversion of wastewater from Lift Station 2 to the new lift station. $292,307.00 a Request grant funding from ANRC for emergency improvements to existing wastewater treatment plant, replacement of Lift Station 2 pumps, and construction of new lift station. $168,177.50 Phase II - Estimated Completion Date: Eizht Months from Funding Obliiation • Request funding for improvements to existing wastewater treatment plant which will also be utilized by the new treatment plant and rehabilitation of the gravity collection mains. Potential funding sources include ANRC, USDA Rural Development, and the Ike 2 CDBG program. $168,850.00 Phase III - Estimated Completion Date: Sixteen Mouths from Fundln g Obligation ■ Request funding for construction of new wastewater treatment plant. Potential funding sources include ANRC, USDA Rural Development, and the Ike 2 CDBG program. $419,375.00 4-1 I � 1 kr i if Ill Y — E e, r O �. c l01 R O 1 RL I SITE - AG Ladd Use Plan RL P Case: Z-9042 n( Location: S. of Kanis RD, Between Chenal Downs Subdivision & Walnut Grove RD Ward: N/A 0 220440 880 Feet PD- 21 CT: 42.02 TRS- T2N R14W33 Z-9042 0 IWALNUT GROVE ROADOWNS 0 CUPCil )- I AND City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 January 8, 2016 Phillip Lewis Engineering 2701 Kavanaugh Blvd Suite 200 Little Rock, AR 72205 Re: Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Sirs: This is to advise you that in connection with your request concerning the above referenced file number the following action was taken by the Planning Commission at its meeting on January 7, 2016: Approved with conditions. Recommended approval with conditions. Recommended approval as submitted. Denied your request as submitted. Deferred to the Meeting. X Other: _ Withdrew your request. If you have any questions please do not hesitate to contact me at 371-6821. Respectfully, Donna James, AICP Subdivision Administrator AF C i r THIS SITE AF R2 Area Zoning Case: Z-9042 jV Location: S. of Kanis RD, Between Chenal Downs Subdivision & Walnut Grove RD Ward: N/A PD: 21 0 220440 880 Feet CT: 42.02 TRS- T2N R14W33 MITCHELL 11 WILLIAMS J. Scott Schallhorn Direct Dial: 501.688-8854 Fax:501-918-7654 E-mail: sschallhorn@mwlaw.wm September 30, 2015 City of Little Rock Planning Commission c/o Ms. Donna James Subdivision Administrator City of Little Rock 723 Markham Street Little Rock, Arkansas 72201 425 West Capitol Avenue, Suite 1800 Little Rock, Arkansas 72201-3525 Telephone:501-688-8800 Fax:501-088.8807 Re: The Trails, Subdivision and Conditional Use Permit; File No. Z-9042 Ladies and Gentlemen: This firm represents Wayne Richie and Unleashed Innovations, Inc., developer of The Trails. The 154 acres proposed for subdivision lies outside the City limits but within the City's Extraterritorial Planning Jurisdiction, and is presently zoned R-2. The developer initially proposed a PD-R with smaller lots for cottage -style homes, intending to offer an alternative to individuals seeking housing in a natural setting but without the upkeep of a multi -acre lot and large house, After receiving negative responses from surrounding property owners, Mr. Richie amended his approach and elected to plat the subdivision to satisfy the requirements of R-2 zoning. The final, preliminary plat proposed by Unleashed Innovations will satisfy all subdivision requirements of the R-2 designation. No variances are requested. The neighborhood will retain its natural character, with wooded buffers encircling the subdivision and multiple natural green spaces interspersed among the homes. While somewhat larger than originally planned, the homes in the neighborhood still offer an alternative to those desiring a natural setting and the amenities of the nearby commercial districts. Architectural controls will be enforced to insure quality design and construction appropriate for homes in a neighborhood like this. The areas west of Little Rock are being developed rapidly. Quality, smaller scale homes will diversify the available housing inventory and enhance property values. It is good planning for an area that will soon be developed like the Chenal neighborhoods were years ago. A Conditional Use Permit is sought to permit the installation and operation of a wastewater treatment plant for the subdivision. The treatment system planned for The Trails must meet stringent Arkansas Department of Environmental Quality ("ADEQ") rules to receive a discharge permit, and must continue to meet ongoing testing and inspection requirements to retain the permit. The planned system will meet the preliminary discharge limits proposed by ADEQ and provided to the Planning Department staff. Provisions for the assessment of the property owners to fund the ongoing maintenance and permitting of the system are included in 4201463.2 Mitchell, Williams, Selig, Gates & Woodyard, P.L,L.C, I Atrorneys at Law Mi tchellW illiamsLaw.com September 30, 2015 Page 2 restrictive covenants that will encumber the property. Granting the Conditional Use Permit allows the construction of the treatment system. No homes will be sold unless the treatment system is properly designed and constructed, and after satisfying the requirements of the ADEQ for a discharge permit. The neighborhood will also provide jobs for the community, increase tax, fee and permit revenue from enhanced property values, stamp taxes, building permits and sales taxes, and increase sales in nearby businesses. Development of The Trails will benefit the community at large. Wayne Richie and Unleased Innovations, Inc. request that the subdivision plat and the conditional use permit be approved. Yours very truly, MITCHELL, WILLIAMS, SELIG, GATES & WOODY RD, P.L.L.C. By J. Scott Schallhorn JSS:tbs 42014632 ta City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Ruth Bell 7611 Briarwood Little Rock, AR 72204 Planning Zoning and Subdivision Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock CcDepartment of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Jerry Strooessle 21405 Walnut Grove Trail Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal: Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Laura L Robinson 32114 Kanis Road Paron, AR 72122 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Troy Laha 6602 Baseline Road Little Rock, AR 72209 Planning Zoning and Subdivision Re. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission ta City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Marcus & Rebecca Kilburn 2221 Dixie Road Little Rock, AR 72223 Planning Zoning and Subdivision Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Johnny & Joyce Taylor 32000 Kanis Road Paron, AR 72122 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission ta City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Van McClendon PUCO Planning and Development 3200 Brown Street Little Rock, AR 72206 Planning Zoning and Subdivision Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Stephen Wilson 410 Stewart Road Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Plannin.g Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Gail Wilson 410 Stewart Road Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Alan and Dianna New 17925 Burlingame Road Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Paulette Richie 12 Valletta Circle Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments —Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development Planning 723 West Markham Street Zoning and Little Rock, Arkansas 72201-1334 Subdivision Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Earnie Peters 5507 Ranch Drive Little Rock, AR 72223 Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock l�7 Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Richard & Coustanse 3200 Roberts Road Little Rock, AR 72223 Planning Zoning and Subdivision Re: S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission Et City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Drew Kelso 4 Dressage Lane Little Rock, AR 72223 Planning Zoning and Subdivision Re. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission City of Little Rock Department of Planning and Development 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 or 371-6863 October 19, 2015 Walter Smiley 1920 Walnut Grove Road Little Rock, AR 72223 Planning Zoning and Subdivision Re S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road Dear Citizen: On behalf of the Little Rock Planning Commission, I would like to thank you for your participation in the October 8, 2015, Commission meeting. It is very important to the City staff and the Planning Commission to have citizen input in the planning decision - making process. S-1758 - The Trails Subdivision Preliminary Plat, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road & Z-9042 - The Trails Conditional Use Permit, located on the Southside of Kanis Road between the Chenal Downs Subdivision and Walnut Grove Road was deferred to the January 7, 2016 public hearing. For additional information, you can contact staff at 371-4790. Staff responsibilities are as follows: Conditional and Tower Use Permits — Dana Carney - Planning Future Land Use Plan Amendments — Walter Malone - Planning Rezoning and Zoning Variance — Monte Moore - Planning Subdivision and Planned Unit Developments — Donna James - Planning Land Alteration Variance Request — Vince Floriani — Public Works Thank you again for your input. Sincerely, Tony Bozynski Secretary to Little Rock Planning Commission James, Donna From: mandy duff <vigor47mm@yahoo.com> Sent: Wednesday, July 1, 2015 8:04 AM To: James, Donna Subject: future of west Pulake Co. I oppose the project development to be built between Walnut Grove and Chenal Downs on Kanis Rd. The magnitude of homes could and would cause congestion on a winding, two lane road. The proposal of how to handle the sewage is incompetent at best. I am a "Concerned Citizen of W.Puliaski Co., and resident. mandy moore, property own James, Donna From: Paul Gregory <pgregory77@gmail.com> Sent: Tuesday, June 30, 2015 9:04 AM To: James, Donna Subject: Objections to Proposed Trails Subdivision Ms. James, The purpose of this email is to convey my objections to the proposed Trails subdivision on Kanis Road in Pulaski County. They are listed below: 1. This development is not in keeping with the City of Little Rock Land Use Plan for the Burlingame Valley which specifically states that "Residential Low Density (RL) is the only recommended development in the area, with the exception of a single small area of Residential Medium Density (RM) off Kanis Road near Ferndale Cutoff. With the steep slope and lack of sewer in the area the development pattern is expected to remain at densities of less than 5 units per acre." The proposed development seeks to change the zoning to UNLIMITED residential density. Would apartment complexes be next? 2. The steep slopes and heavily wooded terrain would have to be all but eliminated in order to accommodate acceptably level streets, driveways and home lots. Needless to say this would destroy the natural beauty of the area. 3. This area is not served by the Little Rock sewer system nor is it likely to be in the near future because of the steep terrain. The developer is proposing a community owned treatment plant. The effluent from this plant will discharge into Fletcher Creek which is a tributary of the Little Maumelle River. Are there any precedents for community owned sewer plants upstream of Lake Maumelle? Who is actually responsible for a community owned sewer system? The smell and the possibility of a system failure are serious concerns. 4. The addition of 299 homes along Kanis Road will exacerbate problems residents of this area are already having with traffic. The lack of a turning lane at the Chenal Downs entry is one example. My wife, Cathy, and I chose this area to live because of its rural character and wooded terrain. We have invested a significant portion of our lives and a considerable amount of money to build a home and a life here. We believe the original land use plan is correct and should be protected. I urge you to communicate our objections to the Planning Commission. Thank you for your time and attention to this issue! Sincerely, Paul Gregory 19507 Burlingame Road Little Rock, AR 72223 James, Donna From: Johnny Taylor <jtsg44@sbcglobal.net> Sent: Tuesday, June 30, 2015 11:30 AM To: James, Donna Subject: FW: proposed development The Trails From: Johnny Taylor [mailto:jtsg44@sbcgloba1.net] Sent: Tuesday, June 30, 2015 10:53 AM To: 'djames@littlrrock.org' Subject: proposed development The Trails I am a member of the West Pulaski County Neighbor hood association and have great concerns about the proposed development called The Trails on Kanis road. First part of the project would have ten units per acre this is far to great a density for this county setting. They would have to build a sewage treatment plant which would put the watershed at risk. This is a pristine and beautiful area of our city and the developer is putting it all at risk with his proposed development. Also if developed as proposed the traffic on that part of Kanis would be unbearable. Please deny this proposed development it is not in the best interest of our city or county. James, Donna From: lolly@lollyhonea.com Sent: Saturday, June 27, 2015 5:17 PM To: James, Donna Subject: Trails development Hi Donna,We are opposed to the Trails development because of the very real threat to our invironment.With the proposed septic system and such a high density of homes it seems very possible that Fletcher Creek and then The Little Maumelle River could be at risk. The infrastructure and ingress egress off Kanis Road would be a nightmare with our existing narrow road with very little shoulder. We are approximately 1 mile from Walnut Grove and are very aware of the dangerous traffic patterns. We have had 2 people killed in our front yard in the twenty eight years we have lived here. I have been hit three times when stopped and trying to turn into my drive way.Even though we are west of Walnut Grove,the traffic headed west of there would be greatly affected. I feel strongly that development in this corridor should be thoughtfully and carefully planned with regard to safety and respect to the current zoning and plans already put in place for this area. Thank you so much, Ross an Lolly Honea 501-960-4277 James, Donna From: Jon Adams <tazlon@aol.com> Sent: Friday, June 26, 2015 9:09 AM To: James, Donna Subject: Trails Subdivision I would like to voice my concern that about the above mentioned proposed subdivision. This subdivision is poorly thought out as it will put too many houses on to small of lots. I would like to encourage that this be redone with larger lots. Regards, Jon Adams 2325 Live Oaks Drive Little Rock, AR. 72223 Sent from my Wad James, Donna From: Joy Wheeler <joyfrank821 @sbcglobal.net> Sent: Thursday, June 25, 2015 4:44 PM To: James, Donna Cc: ccwPulaskiCo@gmail.com Subject: OPPOSITION TO THE PROPOSED TRAIL SUBDIVISION Mr. James, As a 47 year resident on Burlingame Rd. in Burlingame Valley my husband and I would like to express our opposition to having the Trail Subdivision proposed by Wayne Ritchie on Kanis Rd between Chenal Downs and Walnut Grove. The impact on this area will be extreme. The first is to the beauty of a pristine area. If you drive Kanis Rd toward Ferndale and reach this area on any hot day in the summer you will notice the temperature drop. Adding driveways cutting down trees and adding roads hot asphalt roofs will increase the temperature. The run off on both sides of the mountain of rain water will increase. During a heavy rain it already runs across the road and imagine if there were no trees and undergrowth to stop it. The traffic from this number of homes will also be a problem on the narrow but loved strip of Kanis. But the biggest thing that we oppose is the sewer system that will eventually empty into Fletcher Creek which runs into Little Maumelle River and eventually into Maumelle Lake. As you well know Little Rocks water system. Please take all of this into consideration and vote no on this proposal. Frank and Joy Wheeler 18611 Burlingame Rd. Little Rock, Ar. 72223 501-821-7118 I James, Donna From: Laura Edwards <lauraemomof3@comcast.net> Sent: Wednesday, June 24, 2015 11:27 AM To: James, Donna Subject: Kanis Rd development I strongly disapprove/ oppose of the Kanis/Fletcher Creek area development. Laura Edwards James, Donna From: Jerry Straessle <JLS@jlsemail.com> Sent: Tuesday, June 23, 2015 3:06 PM To: James, Donna Subject: Proposed Trails Subdivision on Kanis Road Ms. James, I own 25 acres immediately West and South of this proposed subdivision. Unfortunately, my home is located on the extreme Eastern edge of my acreage and as such will be less than 100 yards from what we understand to be the 5th phase of this project to construct numerous Patio and Cottage style homes. In addition, we will be within half a block of the proposed solid waste treatment structure and settlement ponds. We are very concerned about the dollar value impact this structure will have on a future sale of our property, not to mention the distinct possibility of unpleasant orders. We are also concerned about the plan to discharge the waste water in Fletcher Creek and the negative impact on what is currently a pristine stream. We have further concerns about the overall impact to the watershed and the inevitable runoff from the construction (destruction of the existing forest). We obtain our drinking water from a well and have grave concerns this construction will not only disrupt our current water supply but also ruin its perfect taste. In addition to our well, there are numerous wet weather creeks/brooks that possibly will become torrents of water cascading down the mountain during heavy rains. We already have drainage problems during heavy rain periods. I cannot imagine how much more water will run off the mountain after the forest is cleared. We acknowledge the Developer's offer to provide connections to the Central Arkansas Water System, but if the 51h Phase of this development is 5 years away, we will be negatively impacted for a long time period. We are particularly concerned about the impact 300+ new homes will have on the Kanis road infrastructure. Kanis is a narrow and winding road with a fairly heavy traffic load in our present environment. The addition of potentially 600 more cars per day will just make things worse. The proposed density of Patio and Cottage homes on the back side of the development could change the entire neighborhood, as most of the existing home owners have multiple acreage, like we do. This problem could be resolved by reducing the number of plots for Patio and Cottage homes. Reducing the number of these house sites would also help alleviate the anticipated traffic problems on Kanis Road. We would very much appreciate a negative recommendation to the Planning Commission on the project in its current form. Or, at the least, to address the concerns listed above with the Developer, if you allow the project to move forward. Please feel free to contact me if you have any questions. �T �it2 �a"ij Woad S 57- r Sdr 312- 2422 6#'w 50125Y- 6196 'l1PaZtP.e 501225- 0164 57ax James, Donna From: Carney, Dana Sent: Thursday, June 4, 2015 8:58 AM To: James, Donna Subject: FW: File No. Z-7500-E, Development at 14600 Cantrell Road, Little Rock From: Michael Schwartz [mailto:michdan2@comcast.net] Sent: Wednesday, June 3, 2015 6:08 PM To: Carney, Dana Cc: Harris, Venita Subject: File No. Z-7500-E, Development at 14600 Cantrell Road, Little Rock I object to the development plan for the development behind my house at the above address. The planning has been done in 2 parcels rather than as one development. When my residence was built, Fred and Sally Berg subdivided their ] ] + acre property; my lot was designated as Lot A. When she subdivided, the planning commission required dedication of ROW for Ison Creek, not easement but dedication. There is no mention of this on these planning documents. I also object to a two story building in my back yard. If it is approved, the part of the building that faces my house - the north side of the building - should have no windows and there should be no roof access. The drawings submitted with the proposal were poorly done and slap dash and they do not identify the buildings to be built in accordance with the proposal and they do not identify the dedicated ROW on the creek. The developer should be required to remove immediately the fill from dedicated city ROW along the creek whether or not any development is ever approved. Please submit my comments as a part of objections to this item on the agenda for the June 4, 2015 meeting. Daniel Clanton 5550 Pinnacle Valley Road Little Rock, AR 72223-4285 1 James, Donna From: Paige Gorman <paige.gorman@me.com> Sent: Thursday, June 4, 2015 9:15 AM To: James, Donna Subject: Opposition Fletcher creek I am writing to oppose the Fletcher Creek Neighborhood on Kanis road in west Little Rock. I am concerned about traffic, environmental impact, property values (most lots in this area are a minimum of 5 acre plots and small lots with this quantity of houses will lower property values) and aesthetic of the Kanis Road. Thank you for this consideration. Paige Gorman 19525 Burlingame Rd Little Rock, AR 72223 Paige.gorman@me.com James, Donna From: Chris & Andee Pitcock <chrisandee@yahoo.com> Sent: Wednesday, June 3, 2015 4:54 PM To: James, Donna Subject: Deny the Trails Subdivision, Developer, Wayne Richie - I am opposed Mrs. James, will add my voice to those that think that this proposed zoning change and CUP is a bad idea. I thank you for your support of the community and its residents. Something that I did not read clearly in the Staff comments is any reference to Pulaski County Master Road Plan that designates Kanis Rd, from Denny to Saline County, a Scenic and Heritage Corridor, htt ://Dulaskicount . netlpdf/p ulcomasterroad plan. pdf: Scenic and Heritage Corridors Pulaski County has identified corridors which have unique scenic appeal or historical significance within the county. To preserve the character and uniqueness of these roadways, alternative design standards have been adopted for each of these roadways. In addition to reduced standards for right-of-way and cross-section width, the county may initiate other efforts to maintain the integrity of the following corridors as scenic and heritage corridors. Kanis Road — Denny Road to Saline Coup Kanis Road has long been a major roadway leading west from Little Rock. West of Denny Road this corridor travels between two ridges and follows the Little Maumelle River from Ferndale to Saline County. In addition to providing views of the mountain stream and adjacent ridges, Kanis Road provides access to recreational areas (Camp Okotoma, Ferncliff Camp, Arkansas 4-H Center) and large -lot residential developments. This corridor is on the Pulaski County Master Trails Plan with bike lanes from Burlingame Road to Saline County. A separate multi -use path will connect Ferndale with the existing Rock Creek Trail in Little Rock. And in that spirit, I ask that you include in your consideration the serious impact of such a dense development, water treatment facility and increase in traffic to the environment and aesthetics of our area. Thank you, Andreae Pitcock 21001 Burlingame Rd Little Rock, AR 72223 chrisandee@yahoo.com James, Donna From: Len's on SBC <len.griffin@sbcglobal.net> Sent: Wednesday, June 3, 2015 10:39 PM To: James, Donna Cc: ccwpulaskico@gmail.com Subject: Proposed Development along Kanis Rd. I would like to speak in opposition to the application for planned zoning development on the property along Kanis Road, west of Chenal Downs and east of Walnut Grove. The houses in this area are all located on large tracts of property, and while the houses vary in size they are all located on large pieces of property, each several acres in size. This gives the area that distinct feel and is what attracts people to this area. The proposal for up to 300 structures located in less than 1.1 miles along Kanis means each will be built on small divisions of land. This does not fit with the feel of the surrounding area. In addition, the added traffic from the concentration of such a subdivision will negatively impact an already busy Kanis Rd. Mr. Richie in his May 18 letter re: Notice of Public Hearing, listed what he calls four benefits for the area. In my opinion, none of the things listed are benefits. They and, in fact, all detriments to the houses and development already in the area. The area specified along Kanis is not suitable for the development proposed. I speak in opposition to the proposed development, "The Trails" Len & Bev Griffin 40 Cliffdale Dr. Little Rock, 72223 501 821-6855 1 James, Donna From: tim boehm <endodoctimbo@me.com> Sent: Wednesday, June 3, 2015 5:12 PM To: James, Donna Subject: Kanis/chenal development We oppose the development of higher density housing on kanis road as opposed to acreage parcels as is already established on the Kanis corridor. The traffic on Kanis has already significantly increased and would become unbearable which would lead to road widening. Maintenance of tree canopy simply means keeping a close canopy over the outer two lanes of a 3 or 4 lane road. Double talk at its best. Such congestion would destroy the bucolic presence and life style of Kanis rd. Not to mention congestion impact & image destruction on the historical Methodist church on Walnut Grove rd Property values would actually decrease due to denser population , reduction of natural beauty, & overcrowding of schools & facilities Why, we may as well move to the Heights or downtown Little Rock Sincerely. Residents of Iron Horse Rd Sent from my iPhone James, Donna From: Richard Brown <dick.millie@yahoo.com> Sent: Wednesday, June 3, 2015 12:30 PM To: James, Donna Subject: Fletcher Creek Neighborhood We would like to add our objections to those of our neighbors in the Ferndale area. We feel that many houses would add too much of a burden the roads in our area Also the sewer issues would foul our creeks Thank you for your time Richard and Mildred Brown James, Donna From: Sent: To: Subject: Dear Ms. James, Jan Greenway <jangreenway@me.com> Wednesday, May 27, 2015 10:05 PM James, Donna Proposed development: The Trails We recently learned of the proposed subdivision ("The Trails" ) along Kanis Road. With almost 300 lots offered for development along both Kanis and Burlingame Roads, this massive endeavor would cause immeasurable harm to the overall scenic, peaceful area that now exists in this part of Pulaski county. As you know, Kanis is one of few remaining roadways with lush canopies and void of utility poles and lines. A development of this size and scope would jeopardize the major appeal for living in this area, for to accommodate that many home sites, Kanis Road would need to be widened with power lines added. That would totally destroy the uniqueness of this lovely country road and traffic along this corridor would increase exponentially. In addition, this development is proposing providing its own treatment plant since lot sizes are too small to support individual septic systems. This is a huge concern, especially because discharge and runoff would primarily be into Fletcher Creek, eventually working its way to Pinnacle Mountain Park. We have personally had issues with another of Mr. Richie's developments, Ferncrest Estates, along Burlingame Road. In this instance, runoff from drainage directly entered our property and totally infiltrated our pond with mud and silt, and damaged our rocked waterfall & outflow. We have had to reconstruct that spillway/outflow three times to accommodate the enormous amount of water that now flows from Ferncrest development through the small creeks, and into our pond. I can't begin to imagine what runoff will be generated with "The Trails" development. We have so loved living in "the country" for the past 17 years and certainly hope to be able to enjoy many more years of peaceful, quite living in this beautiful part of Arkansas. We totally, unreservedly oppose the proposed "Trails" subdivision and ask that you please deny approval for this development at the hearing June 4. Respectfully, Jan Greenway 7 Tuscany Cove Little Rock, AR 72223 James, Donna From: Amy Bailey <amybailey456@icloud.com> Sent: Wednesday, May 27, 2015 10:24 PM To: James, Donna Subject: NO developing "The Trails" My husband and I live at 3 Chenal Downs Blvd and are very against the proposed development of "The Trails." This would only increase the traffic problem which already exists, and affect the already under manned police & fire services. Besides above, the natural beauty of the canopy on Kanis will likely be affected. What about discharge of water waste, etc. Please do not allow The Trails to develop. That would affect this area in a negative way. Thank you for hearing our concern - Amy & Mike Bailey Sent from my iPhone James, Donna From: Bartter, Thaddeus <TBartter@uams.edu> Sent: Friday, May 29, 2015 7:40 AM To: James, Donna Subject: Proposed "TRAILS" development on Kanis Road I would like to express my opposition to the Trails development proposed for Kanis Road from Chenal Downs to Walnut Grove Road. I have reviewed the proposal and the proposed site plan. This proposed re -zoning would violate the nature of the area and would create problems with traffic, sewage, and run-off. Please help me and my neighbors to block this proposal. Sincerely, Thaddeus Bartter 15 Livree Lane Chenal Downs Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Borynski, Tony From: 1T Meister <jtmeister@lbdgconsultants.com> Sent: Tuesday, June 02, 2015 9:19 AM To: board; City Manager; Borynski, Tony Subject: The Trails Subdivision I am writing to express my concern and opposition to the proposed subdivision along kanis road near the intersection of Walnut Grove Road just outside of Little Rock. We live on a very quiet street called Walnut Grove Road and the addition of 300 new homes basically in our back yard would not be anything like the use that is currently in place. Most of the residences in this area are single family homes on acreage. Walnut Grove is a very quiet street and at times only wide enough for a single vehicle to pass safely. To add this much traffic and to this area would be unsafe and unsightly. We are also very concerned over the treatment facility that is being proposed and that would eventually run into Fletcher Creek, a beautiful piece of nature that should be left undisturbed. Kanis Road in this area is a fairly heavily traveled street and adding not one but two new intersections along this two lane street with ditches on each side cannot possibly be a safe thing to do. We are opposed to this proposal. I believe this agenda item has been moved to the July 16th meeting and we very much encourage you to vote "no" to this proposal. Regards, J.T. Meister, Jr 2002 Walnut Grove Road Little Rock, Arkansas 72223 501-313-8477 James, Donna From: duong nguyen <duongangelajoshua@yahoo.com> Sent: Friday, May 29, 2015 5:11 PM To: lames, Donna Subject: Trails Neighborhood Dear Mr. James, We are residents in the Chenal Downs neighborhood. We are vehemently opposed to the new Trails subdivision which is being considered. This will place an undue burden on the area here. This area of Pulaski county includes residences mainly with large lots/acreage. This area is too small for the number of lots/residents that would be added. Adding a sewer system will deface this area and be problematic. Sincerely, Angela and Duong Nguyen James, Donna From: SUE KEATHLEY <skeathleymd@sbcglobal.net> Sent: Tuesday, June 2, 2015 7:41 AM To: James, Donna Subject: Trails We are opposed to to the new area called Trails. It is inconsistent with the development pattern of this area. It will undermine the quality of life and property values in this area. Sue and Gary Keathley -2218 Walnut Grove Rd. James, Donna From: cliff peck <peckdvm@yahoo.com> Sent: Tuesday, June 2, 2015 7:33 AM To: James, Donna Subject: Proposed neighborhood on Kanis To Whom This May Concern: Please let this letter serve as my personal vote AGAINST the proposed neighborhood on Kanis rd west of Chenal Downs. Besides defacing the beauty of Fletcher hollow, the sewage treatment facility planned with in it would be an ecological nightmare that I, or my neighbors of 35 years, want to experience. Please confirm that this has reached the right office. Sincerely, Cliff Peck DVM 1 James, Donna From: Gail Clayton <ga5ran@sbcglobal.net> Sent: Monday, June 1, 2015 9:01 PM To: James, Donna Subject: The Trails development We are against this for thats too many homes in one area. That would bring an additional 500 cars onto Kanis at rush hour on roads that are not that safe already... Also the water runoff from heavy rains would cause Kanis rd. to flood even more... Fewer homes on larger sites would be better. Raymond Clayton Burlingame rd. James, Donna From: C. Darby <CWDarby@mobilehearingsolutions.com> Sent: Monday, June 1, 2015 4:17 PM To: James, Donna Subject: Fletcher Creek/Trails Subdivision I will be unable to attend the June 4th Planning Commission meeting but do want to voice my objection to such a proposed development. I purchased property in the Walnut Grove Rd/Burlingame Road area specifically to get away from the "City" and the many issues of city life. I object to this development specifically for the following reasons: • The area primarily consists of homes built on larger acreage, not zero lot line type residences (which appears to be what is proposed). This would have negative impact on property values for the majority of current property owners in the area. • An additional 300 homes concentrated on 154 acres would create unacceptable traffic logistics, most likely requiring additional tax burden and the City's expense of widening Kanis Road (and probably Walnut Grove Road as well). Without widening the roads, there would be the creation of an abundance of vehicles, bottle -necked, twice daily at a minimum. An added 500- 600 cars during morning and afternoon drive times is just not conducive to effective or efficient traffic control with the existing 2 lane roadway. Maintaining the tree canopy of the "holler" as proposed, is not feasible for such a staggering increase in traffic demand. • The proposed addition of fire hydrants and public utilities leads me to believe annexation into the City of Little Rock would be required. Seems logical as more people in the area would require more police and fire protection. It is doubtful that the West Pulaski Volunteer Fire Department or the Pulaski County Sheriff's Department could currently take on another 300 residents. As stated previously, I moved out of the city purposely and have no need for additional utilities, services, or the associated costs and tax burdens. • A high density subdivision, as proposed, would require a sewer system/pumping station/treatment plant to be constructed. This alone has high impact on the serene nature of the area and certain to be an eyesore for the community. In addition to the cost for taxpayers of the connecting infrastructure, a sewage plant in our community is yet another property devaluing aspect for existing property owners. You do hereby have my proxy to speak against this proposed development. Thank You, C.W. "(Dar6y„ MA, HIS/D 501-821-1234 Mo b it eH earin gSo l utio n s www.mobilehearin solutions.rom James, Donna From: Gordon Gondek <ggondek@aristotle.net> Sent: Monday, June 1, 2015 2:43 PM To: James, Donna Cc: Lisa Subject: The Trails Dear Ms. James; I am writing to voice my opposition to the development, The Trails, on Kanis Road. We built out house out west over 20 years ago and have seen the city moving west to encroach on what we viewed as living out in the country. Those days are gone. The thought of large construction vehicles and potentially another several hundred cars a day on an already busy, two lane Kanis Road is not a very appealing idea to me. We will be at the meeting on Thursday. Gordon Gondek James, Donna From: Alan New <New@taggarch.com> Sent: Monday, June 1, 2015 8:25 AM To: Alan New; James, Donna Cc: diananew Subject: RE: Proposed Kanis Development D. James, please note that I put my address as North Little Rock that is where our Architectural practice is. Our residence is on Burlingame in Little Rock. ALAN NEW, ALA PRINCIPAL SENIOR DESIGNER 4500 Burrow Dr_, North Little Rock, AR 72116 501,758,7443 Office 901.825.0904 Cell www.taggarch.com this transmission is (or its intended recipient(s) only; all others are hereby notified that any use of its content is prohibited. From: Alan New Sent: Monday, June 01, 2015 7:34 AM To: 'DJames@littlerock.org' Cc: 'diananew' Subject: Proposed Kanis Development Yes I support stopping the proposed 300 home development that will be running parallel to Kanis . This development will obliterate the entrance to the Ferndale community and is impractical due to numerous reasons, size of lots, size of homes, the necessary clear cutting of the ridge, the on going maintenance of the sewage treatment facility, the introduction of an additional 600 cars (2 per house hold) to Kanis,( this may require the city to widen Kanis to create turn lanes into the development), and the downstream impact of such a development on Fletcher Creek to name a few. Please count me in and I am planning on attending the Thursday hearing. I would also suggest a pre meeting one night this week to strategize a concerted logical approach that addresses this issue on its merits rater than just an approach that attacks its destruction of the beauty that we purchased or property to enjoy. Alan and Diana New 17925 Burlingame Road North Little Rock, Arkansas 72223 Alan cell 901 825 0904 Diana cell 901 488 7111 James, Donna From: Alan New <New@taggarch.com> Sent: Monday, June 1, 2015 7:34 AM To: James, Donna Cc: diananew Subject: Proposed Kanis Development Yes I support stopping the proposed 300 home development that will be running parallel to Kanis. This development will obliterate the entrance to the Ferndale community and is impractical due to numerous reasons, size of lots, size of homes, the necessary clear cutting of the ridge, the on going maintenance of the sewage treatment facility, the introduction of an additional 600 cars (2 per house hold) to Kanis,( this may require the city to widen Kanis to create turn lanes into the development), and the downstream impact of such a development on Fletcher Creek to name a few. Please count me in and I am planning on attending the Thursday hearing. I would also suggest a pre meeting one night this week to strategize a concerted logical approach that addresses this issue on its merits rater than just an approach that attacks its destruction of the beauty that we purchased or property to enjoy. Alan and Diana New 17925 Burlingame Road North Little Rock, Arkansas 72223 Alan cell 901 825 0904 Diana cell 901 488 7111 AIAN NEW, AIA, PRINCIPAL. SENIOR DESIGNER 4500 Burrow Dr., North Little Rock, AR 72116 501.758 7443 Office 901.825,0904 Cell www.taggarch.com I h!s transmission is for its intended recipient(s) only, all others are hereby notified that any use cf its content is prohibited James, Donna From: Nancy Watkins <rhw23600@sbcglobal.net> Sent: Sunday, May 31, 2015 1:26 PM To: James, Donna Subject: fletcher Creek Neighborhood I am opposed to any development along Kanis Rd that would violate current zoning. I have about 80 acres and I will use all my ability to stop anyone from such a project. Thanks Robert Watkins 23600 Foxridge R.D Little Rock, AR 72223 501-821-6611 1 James, Donna From: JT Meister <jtmeister@lbdgconsultants.com> Sent: Sunday, May 31, 2015 9:15 AM To: James, Donna Subject: The Trails proposed subdivision We live at 2002 Walnut Grove Road and are very much opposed to the proposal of a 300 home subdivision on kanis road. This is a rural area with homes on large lots and Kanis is not built to handle that much extra traffic. This would be very inconsistent with any land use near this area and have major impact on traffic flow and home values. We are opposed to this application filed by Wayne Richie. Regards JT Meister, Jr. 2002 Walnut Grove Road Little Rock, AR 72223 501-313-8477 jtmeister@lbdgconsultants.com James, Donna From: Gresham Barnes <gmanbarnes@sbcglobal.net> Sent: Saturday, May 30, 2015 5:41 PM To: James, Donna Cc: angelspjb@sbc.global.net Subject: Proposed Long -Form Planned Zoning Development Kanis Rd. As an interested party, and since the area in question is directly in view of my home, I oppose this request. 299 houses stacked on top of the ridge will be unsightly and will without doubt destroy one of the last beauties left in Pulaski County. The site would be better suited for 10-15 Upscale homes built with the beauty of the mountain in mind. How can the board even consider a treatment plant in this area, when the only place for the runoff to go is Fletcher Creek. No matter how you plan it, it goes in the creek. Who will pay for maintenance, and cleanup 20 years from now when the whole thing fails and destroys the water from here to Lake Maumelle? Mr. Richie was until recently a resident of the Burlingame Valley. I doubt he would have approved of that sort of view from his 10,000 sq. ft home 2 mailboxes down from mine either. Gresham Barnes 17607 Burlingame Rd Little Rock AR 72223 501-821-8023 James, Donna From: Bobby Harper <bharper9@gmail.com> Sent: Wednesday, June 3, 2015 6:28 AM To: James, Donna Subject: Kanis rd fletcher creek Please note that I formally oppose the rezoning request for the development of The Trails subdivision on Kanis Rd. I think because of the proposed lot size and number of homes sites this development is not compatible with the other developments in the area. Bobby Harper 14625 Burlingame Rd. Little Rock, AR 72223 Sent from my iPad James, Donna From: Mark Johnson <mjohnlit@swbell.net> Sent: Tuesday, June 2, 2015 5:00 PM To: James, Donna Cc: ccwpulaskico@gmail.com Subject: Kanis Road Development West of Chenal Downs Sir / Madam - I am very much opposed to the proposed rezoning to allow high -density development in our area. Some of these proposed lots would be smaller than a basketball court. I intend to be in attendance at the Hearing on June 4th. Respectfully yours, Mark Johnson 23616 Kanis Road Little Rock, AR 72223 (501) 347-5337 (cell) James, Donna From: ladybug82336@aol.com Sent: Tuesday, June 2, 2015 8:46 PM To: James, Donna Cc: ccwpulaskico@gmail.com Subject: Oppose Fletcher Creek Neighborhood To Whom it may concern: I am writing to oppose the development of property in the wooded area called the holler. This is a beautiful area of woods that shows beauty all year round. It also keeps a place for our wildlife. Go develop property off Rahling or Chenal Parkway. We love the beauty of our trees out here & it also gives oxygen to our ozone. Again, my family & I oppose any development on Kanis Rd west of Chenal Downs & east of Walnut Grove Rd. My husband has lived on our land almost all of his life along with his grandparents/parents. Also, there is a cemetary off Walnut Grove road that we have family buried in. Please do not destruct those grave sites. Build your single family houses elsewhere. We would like to keep the trees for our wildlife that is zoned for hunting in this area. Sincerely, Glenda Miller 25725 Kanis Rd Little Rock, AR 72223 501-551-6915 James, Donna From: Ted Grimmett <ted.grimmett@gmail.com> Sent: Thursday, June 11, 2015 10:50 AM To: James, Donna; Rhetta Bennett; Pat Grimmett; Sally Anderson Subject: Opposed to Trails development We are Ted & Rhetta Grimmett and we live about 1 mile east from the western boundary of the proposed Trails development along Kanis Road. We are not opposed to development that is compatible with the existing properties and the environment, but what Mr Ritchie proposes is a densely populated subdivision with 300 homes on a 154 acre subdivision with its own sewage treatment plant. His proposal is wrong headed because it is culturally and environmentally incompatible with the area immediately surrounding his proposed development. He needs to maintain the Trails development in a way that is compatible with the existing properties in the area - homes on large lots or acreage, not a house every 1 /2 acre, which is what the math works out to be. It is also my understanding the Trails development is in a flood plain that drains into the Little Maumelle River. That is the reason for the current zoning restrictions. The Trails development proposal allowing for a house on a half acre lot flies in the face of that zoning restriction. Again, we have no problem with Mr. Ritchie developing his property, but he should develop The Trails under the current zoning restrictions and be denied any changes in zoning classification in regard to The Trails development. Sincerely, Ted & Rhetta Grimmett James, Donna From: Karen <kperry724@gmail.com> Sent: Thursday, June 11, 2015 10:38 AM To: James, Donna Subject: Opposition for the Kanis Rd/Fletcher Creek I am writing this email to say I am opposed to the Kanis Road/Fletcher Creek development. Please let me know if I can provide additional information or assist in any way. Thanks, Karen Perry (501) 680-3603 Sent from my Whone James, Donna From: dick torti <dicktorti@hotmail.com> Sent: Thursday, June 4, 2015 12:02 PM To: James, Donna Subject: RE: Emailing: SCAN0029 I am opposed to the Kanis Road/Fletcher Creek proposal by Wayne Ritchie. From: DJames@littlerock.org To: dicktorti@hotmail.com Subject: RE: Emailing: SCAN0029 Date: Thu, 4 Jun 2015 16:10:01 +0000 There is not an attachment or a reference to the project you are requesting to not be allowed. From: dick torti [mailto:dicktorti@hotmail.com] Sent: Wednesday, June 3, 2015 8:27 PM To: blanzengineering@sbcglobal.net; James, Donna Subject: RE: Emailing: SCAN0029 I oppose this request to be allowed, > From: blanzen ineerin sbc loba1.net > To: wl.dean@vahoo.com; elaine thetitleco.net; route003 hotmail.com; dicktorti@hotmail.com; imspradlev@spradleyphillips.com > Subject: Emailing: SCAN0029 > Date: Wed, 3 Jun 2015 10:32:48 -0500 > Bill" please forward to John Kapp. > Your message is ready to be sent with the following file or link > attachments: > SCAN0029 > Note: To protect against computer viruses, e-mail programs may prevent > sending or receiving certain types of file attachments. Check your e-mail > security settings to determine how attachments are handled. 1 James, Donna From: Mary <baskinmc@yahoo.com> Sent: Wednesday, June 24, 2015 10:47 PM To: James, Donna Subject: Objection for City Planning The purpose of this email is to file an objection to the development planned on Kanis Rd called The Trails. We are residents of Ferndale and own 8 acres of land. As you know, most of the parcels out here are fairly large and rural. This proposed development is totally out of sinc with this part of the county. High density development is unacceptable in that location. The increased traffic is inappropriate for our roads. The sewer situation would be a nightmare for our creeks. We would appreciate your consideration of those of us who have made this our home because of it's nature. This type of development should be reserved for urban settings. Thank you. Mary and Tery Baskin 2 Live Oaks Ct. Little Rock, AR 72223 501-821-4601 1 James, Donna From: Thaddeus Bartter <bartter.thad@gmail.com> Sent: Monday, July 6, 2015 10:30 PM To: James, Donna Subject: Kanis Road - Please say no To the City Planning Board: As property owners of the lovely neighborhood of Chenal Downs we were horrified to hear of a proposed development that would drastically change the nature of our area. A high -density city -like settlement set on a quiet country road makes no sense to us, and would, in our opinion, be destructive. We are concerned about traffic. We are concerned about sewage. We are concerned about runoff. The proposed settlement violates in every sense the nature of the area and the community in which it is proposed. We strongly oppose it. Please communicate this opinion. Thank you. Thaddeus Bartter 1 James, Donna From: Teka Bartter <tekabartter@hotmail.com> Sent: Monday, July 6, 2015 10:27 PM To: James, Donna Subject: Objection to Kanis Road Proposal am a member of the Concerned Citizens of Pulaski County and own a property at Chenal Downs. I have heard about the proposed development on Kanis Road, and wanted to respond. I oppose the development as proposed. I am very concerned. The urbanization of a country road carries with it several problems. First is the traffic. The road is small and windy, and would need to be widened to accept a marked increase in traffic. The area is not built for this density. If a builder were to change the character of the area completely, I would suggest that he would have to be responsible for all improvements that made access reasonable. Another issue is that of sewage. A large high -density development would require a sewage plant. The plant would discharge into the creek system, itself unattractive. Any failure or overflow would pollute from Fletcher Creek through Pinnacle State Park and to the Little Maumelle. I would suggest that a private sewage facility should not be allowed, that any management of that magnitude needs to be handled by the government. The change in watershed caused by high -density housing would increase the volume of runoff and the chance of overflow failure. In summary, I think that the proposed building project is inappropriate for its proposed location. Please count my voice and vote against this idea. Sincerely, Teka Bartter 1 James, Donna From: Terry Davis <terry6793@att.net> Sent: Monday, July 6, 2015 7:50 PM To: James, Donna Subject: Trails Development on Kanis Road We are Roger & Terry Davis. We live on Burlingame Road, in west Pulaski County, adjacent to the property up for approval for the Trails Subdivision Development on Kanis Road. We would ask that you give careful consideration to disapproving this development. Our concerns are that the number of proposed residences and the proposed lot sizes would be inappropriate for the area, and that the sewage plant which is planned would pollute Fletcher Creek, which flows into the Little Maumelle River, which is part of the Maumelle Watershed. We would appreciate your careful consideration of this proposal. Thank you, Roger & Terry Davis Members, West Pulaski Property Owners Association. James, Donna From: Nancy Watkins <rhw23600@sbcglobal.net> Sent: Sunday, July 5, 2015 3:52 PM To: James, Donna Subject: Trails subdivision Attn: Donna James We want to communicate to you our complete opposition to the planned Trails subdivision on Kanis Road. The reason for this disapproval is that the proposed subdivision is completely opposite from our current zoning for this area. We have lived at 23600 Foxridge Road for more than 35 years and the reason why we spent money on this acreage was because of the pristine nature of this area. We specifically chose Ferndale because of the minimum 5-acre, single family zoning ordinance. We vehemently oppose this variance to current the zoning law. We currently own approximately 80 acres and because of our large investment in this area, we 1 are willing to spend large sums to protect our real estate investment. Thank you for your attention on this matter. Nancy and Bob Watkins 23600 Foxridge Road Little Rock, Ar 72223 501 821 6611 z James, Donna From: carol pait <cbpait1971 @sbcglobal.net> Sent: Monday, July 6, 2015 12:34 PM To: James, Donna Subject: Objection to Proposed "Trails" Subdivision Dear Ms. James: I am a homeowner and resident of Chenal Downs, and I am writing you to express my objection to the proposed "Trails" subdivision. I am particularly concerned with the housing/lot density proposed. Large lots and acreage are the norm in this part of the County, and I understand the developer has requested a variance to the current R2 zoning to allow for the smaller lots. I strongly oppose the variance change. The high -density proposed development will place undue strain and congestion on Kanis and Walnut Roads. The "Trails" developer has asked for waivers so that he does not have to follow the Master Street Plan to protect these two roads. I object to the requested waivers. Additionally, I am very concerned with the developer's plan to construct a wastewater treatment plant on the property. This poses great risks, including possible contamination of well water and damage to the watershed, Fletcher Creek, and the Little Maumelle. I strongly object to his request for a Conditional Use Permit for this treatment facility. Development of the proposed "Trails" subdivision will be disastrous for this portion of Pulaski County. Please respect the concerns of the current residents/landowners as you consider the developer's intentions and vote NO to the proposal. Sincerely, Carol Pait 48 Trotter Ln Little Rock, AR 72223 James, Donna From: Jerry Wilson <jwilson@efsolutionsinc.com> Sent: Friday, May 15, 2015 12:56 PM To: James, Donna Cc: Grant Bray (12bbray@aol.com); Richard Bornemeier; drewkelso@sbcglobal.net; kent_rector@steris.com; sharilyn.gasaway@gmail.com Subject: The Trails" Subdivision Proposal Good Afternoon, Ms. James! Thank you for your assistance in properly representing ourselves to the planning commission. This is in reference to "The Trails" subdivision represented by Unleashed Innovations, 1700 Chenal Parkway. We are opposed to the proposed subdivision for the following reasons. Foremost we are a neighboring subdivision that would be directly impacted in multiple ways. ➢ The density of houses on the topography and acreage of land is not safely supported in a variety of areas. ➢ There is not sufficient waste water facilities in place to support it. ➢ The rezoning of the location doesn't match the surrounding areas usage. ➢ Approval should include a plan to support the water runoff created by building the subdivision. ➢ There is not sufficient roads to support the additional traffic on Kanis Road. ➢ Kanis is currently used extensively by bicyclers & there is not a bicycle lane. Additional traffic would endanger lives. ➢ No approval until it is signed off by the Ark. Dept. of Health, ADEQ and whoever is in charge of traffic planning for the City. ➢ No approval without assurance of the financial stability of completion and Maintenance of waste water facility. ➢ The change of zoning will cause the loss of the wooded canopy along Kanis Road, which is one of the most scenic drives in Arkansas. Thank you for your consideration to the facts related to this proposal Drew Kelso — Grant Bray — Richard Bornemeier — Sharilyn Gassaway — Kent Rector - Jerry Wilson Chenal Downs Property Owners Association May 20, 2015 Donna James City Planning Office 723 West Markham St. Little Rock, AR 72201 Dear Ms. James, Our names are Richard and Renee Bornemeier. We are residents of Chenal Downs which is located in West Pulaski County. Chenal Downs is a subdivision adjacent to Wayne Ritchie's proposed development called "The Trails". We are very concerned and have objections to this development. 1. This project will obviously take a great deal of capital to develop. In addition to land preparation, there will be streets, curbs, gutters, drainage and utilities. Along with these, a very expensive sewage treatment plant has also been proposed. The financial profile of a project of this scale will be quite large. In the not too distant past, there has been tremendous fluctuation in the sale of real estate. If this project were to be started but not completed due to insufficient capital or a loss of interest from the developer, a half -finished development of this size will permanently scar the environment here. We assume "The Trails" intends to use water supplied by Central Arkansas Water. The water pressure supplied to fire hydrants in the area have recently proved to be inadequate for fighting a house fire. A house, on the same topographical ridge as "The Trails", within Chenal Downs at #12 Sellette Court, just burned to the ground a couple of weeks ago. One of the reasons cited was poor water pressure on the fire hydrants. A development of this size would only further strain to an already difficult situation. The West Pulaski Volunteer Fire Department should also sign off on their ability to protect "The Trails" in case of residential fire. This proposed development includes a large number of houses. The amount of traffic alone will make navigating 2- lane Kanis Road even more challenging. There is also a large amount of wildlife in the area. Deer, fox, wild turkey, to name a few, can all be seen. The massive excavation will destroy one of the nicest parts of `The Natural State" in central Arkansas. If you haven't had the opportunity recently, you should drive out Kanis Road some Sunday afternoon and you will see what we are talking about. 4. Many homeowners in the area are dependent on well water. By clearing this land, there will be unknown amounts of storm runoff and damage to the lower areas below the development and will certainly have an effect on the water aquafers that serve the area. Many of these West Pulaski County residents will have no alternative water supply. The storm water runoff and any discharge from the sewage treatment plant, whether intentional or accidental will wind up in Fletcher Creek that winds through the valley along the entire development. Fletcher Creek runs into the Little Maumelle River just a few miles away. The Little Maumelle runs through the Pinnacle Mountain State Park and then to Two Rivers Park. Sediments and contamination of this watershed could have serious consequences. Neighboring Chenal Downs has a series of 5 catch basin lakes just to control the storm water runoff and sediment. We know and trust that you have a desire to make sure that housing developments have positive effects on the community and are not detrimental. We would respectfully ask you to consider the above points and not allow the development of "The Trails". Respectfully, Richard and Renee Bornemeier 11 Chenal Downs Blvd. Little Rock, AR 72223 James, Donna From: Sent: To: Subject: Good Day, Mr. James: LEE KINNEBREW <Ikinnebrew@sbcglobal.net> Thursday, May 21, 2015 12:07 PM James, Donna PLANNED SUBDIVISION "THE TRAILS" As residents of Chenal Downs, Lee & Myra Kinnebrew would like to go on record as OPPOSED to "The Trails" subdivision for the following reasons: • The lack of sufficient waste water facilities to support such a high density subdivision • A high density subdivision does NOT fit with the area usage Kanis Road is not currently designed for high density traffic especially entry & exit from Kanis Road • There should be no approval until all traffic studies and waste water treatment studies are complete There needs to be input from the local school systems as to their ability to handle additional students that come from a high density subdivision Thank you for consideration of the above concerns • Lee & Myra Kinnebrew Page 1 of 2 Drew Kelso From: "Drew Kelso" <drewkelso@sbcglobal.net> Date: Tuesday, May 19, 2015 8:21 AM To: <DJames@littlerock.org> Subject: The Trails Subdivision proposal to City Planning Donna James, Please make sure the staff working on the proposed subdivision, The Trails, out in West Pulaski County gets the following information. Also that the Planning Committee has my comments as follows: 1. The proposed Trails subdivision is a high density development which is not manageable in the Western Pulaski County. Everything is geared to 5 acre or larger tracts. If the Trails were proposed as 5 acre tracts most objections would be neutralized. 2. Because of this proposed high density development, there is planned a sewage treatment facility. These developer/subdivision sewage treatment facilities are problematic and should be avoided. Many small incorporated cites and towns have problems managing and maintaining them as well, especially over long periods of time. Recent examples of such problems are: The sewage treatment plant at Marble Falls which dumps affluent into the Buffalo River; The West Fork community sewage treatment facility, dumping affluent in to the White River, and lastly and more recently the Chicot sewage treatment plant in Southwest Little Rock. All of these are public record and have been before the ADEQ and the Arkansas Dept. of Health. lam sending paper documentation on each in the mail so make sure the staff and committee have this information as well. 3. Fire protection in the area is by the West Pulaski Volunteer Fire Dept. While they do the best they can, but they are not equipped to handle the additional coverage of a high density development like the Trails. The Fire Chief should be contacted and his concerns about how they can handle development of this sort should be noted. 4. The Pulaski County Sheriffs Dept. provides emergency help to the area. They do this from a modestly staffed substation. Large increases in population density can only make this situation worse. The Pulaski County Sheriff should sign off on his ability to handle the increased population. 5. There should be no further clearing or site preparation work done on this development without further approval. We don't want a scalped mountain and ridge left if the development does not proceed. 6. Pulaski County is in no position to handle the improvements that would be needed to Kanis Road to handle the increased residential traffic much less the amount of traffic during the construction phases. For these reasons, and several others already submitted the Trails subdivision should not be approved as proposed. My home is in Chenal Downs which is adjacent to the proposed development. Thanks for your help. 5/19/2015 Page 2 of 2 Drew Kelso #4 Dressage Lane Little Rock, AR 72223 501-680-4828 5/19/2015 ARKANSAS POLLUTION CONTROL AND ECOLOGY COMMISSION REGULATIONS COMMITTEE MEETING Thursday,,May 21, 2015 8:30 a.m. ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE NORTH LITTLE ROCK, ARKANSAS 72118 AGENDA 'Item #01) I. Call Meeting to Order - 8:30 a.m. II. Roll Call III. Approval of December 5, 2014 Committee Minutes (Item #02) IV. Regulation No. 23, Hazardous Waste Management APPENDIX I - Docket No. 15-001-R (Item #05-12) - Tammie J. Hynum for Arkansas Department of Environmental Quality - Minute Order (Initiate) V. Adjourn ARKANSAS POLLUTION CONTROL AND ECOLOGY COMMISSION REGULAR COMMISSION MEETING Thursday, May 21, 2015 9:00 a.m. A.RKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE NORTH LITTLE ROCK, A.RKANSAS 72118 AGENDA (Item #03) I. Call Meeting to Order - 9:00 a.m. II. Roll Call III. Approval of April 24, 2015, Commission Meeting Minutes Department Reports A. Director's Report B. Status of Regulations Monthly Report C. Division Permit Reports IV. Public Comments V. Commission Reports A. Chair Ann Henry 1. Presentation of Plaque to Commissioner Mike Armstrong 2. Presentation of Plaque to Commissioner Darwin Hendrix 3. Presentation of Plaque to Commissioner John Simpson 4. Presentation of Plaque to Commissioner William Thompson B. Regulations Committee - Randy Young 1. Regulation No. 23, Hazardous Waste Management - Docket No. 15-001-R - Tammie J. Hynum for Arkansas Department of Environmental Quality - Minute Order (Initiate) (Item #04) (Item #1� (Items #19-231 APPENDIX I (Items #05-12) VI. Request to Expend More than $2,000,000.00 from the Landfill Post -Closure Trust Fund - Benjamin T. Jones for Arkansas Department Of Environmental Quality - Minute Order (Adopt) VII. Administrative Law Judge - Charles Moulton A. Recommended Decision 1. In the Matter of Chicot Sewer Systems, LLC - Docket No. 15-003-NOV - Minute Order (Adopt) APPENDIX II (Items #13) APPENDIX III (Items #14-15) 2. In the Matter of Decision of Interim APPENDIX IV Director J. Ryan Benefield and Pulaski County (Items #16-17) Solid Waste Management District Board - Docket No. 15-001-MISC - Minute Order (Adopt) VIII. Adjourn. ARKANSAS POLLUTION CONTROL AND ECOLOGY COMMISSION IN THE MATTER OF CHICOT ) DOCKET NO. 15-003-NOV SEWER SYSTEMS, LLC ) ORDER NO. 2 RECOMMENDED DECISION Appearances: Mr. Ken Harper for Chicot Sewer Systems, LLC; Mr. Michael McAlister for Arkansas Department of Environmental Quality. I. INTRODUCTION Chicot Sewer System, LLC ("CSS") operates a wastewater treatment facility located at 14124 Chicot Road, Mabelvale, Saline County, Arkansas. On February 5, 2015, the Arkansas Department of Environmental Quality ("ADEQ") issued a Notice of Violation ("NOVI'), LIS 15-020, to CSS for alleged violations of the Arkansas Water and Air Pollution Control Act, Ark. Code Ann. §§ 8-4-101 et seq.; the Federal Water Pollution Control Act, 33 U.S.C. §§ 1311 et seq.; Regulation No. 2 and Regulation No. 6. On March 12, 2015, Mr. Ken Harper faxed a Request for Hearing to the Arkansas Pollution Control and Ecology Commission ("Commission") office and on March 13, 2015, ADEQ filed a Motion to Dismiss CSS's Request for Hearing. ADEQ alleges the CSS Request for Hearing has been filed too late; that the Request for Hearing did not include a complete and detailed statement identifying the legal issues and factual objections being appealed and did not comport with Reg. 8.603 (C) (1) (c) ; and that CSS's Request for Hearing was filed by a non -attorney and Reg. 8.602 requires a corporation in an adjudicative proceeding to be represented by an Docket No. 15-003-NOV Order No. 2 Page No. 2 attorney. II. JURISDICTION The Commission has jurisdiction over this matter pursuant to Arkansas Code Annotated 5 e-1-203(b)(5), which authorizes the appeal of an enforcement action. III. STANDARD OF REVIEW Under Rule 12(b)(6) the Commission's administrative law judge ("ALJ") must review the facts alleged in ADEQ's motion in a light most favorable to CSS, the non-moving party. Neal v. Wilson, 316 Ark. 588, 595-96, 873 S.W.2d 552 (1994). IV. FINDINGS OF FACTS 1. CSS operates a wastewater treatment facility which is regulated pursuant to the National Pollutant Discharge Elimination Program ("NPDES") and CSS was issued Permit No. AR0047261 ("the Permit"). 2. On August 7, 2013, an ADEQ water inspector conducted an inspection of the CSS facility in response to a complaint. 3. On August 22, 2013, ADEQ conducted a follow-up inspection and took water samples from CSS's permitted discharge. The results of those water samples demonstrated elevated levels of fecal coliform bacteria and decreased levels of dissolved oxygen in violation of Part 1, Section A, of the Permit. 4. On August 28, 2013 the Department notified CSS of the results of the August 22, 2013 inspection; on September 11, 2013 and September 23, 2013, the Department received CSS's responses; on Docket No. 15-003-NOV Order No. 2 Page No. 3 October 16, 2013, the Department notified CSS that its responses were inadequate; and on October 30, 2014, CSS responded to the Department's October 16, 2013, letter. 5. On February 25, 2014, an ADEQ water division inspector conducted a compliance inspection of the CSS facility and found that an unpermitted discharge was taking place into a tributary of Fourche Creek. 6. Water samples taken from this unpermitted discharge demonstrated elevated levels of E. coli, fecal coliform bacteria, and ammonium nitrogen. Water samples taken from CSS's permitted discharge demonstrated elevated levels of ammonium nitrogen above the permitted level and levels of dissolved oxygen below the permitted level. 7. The ADEQ inspector notified CSS on February 25, 2014, by telephone that an unpermitted discharge was occurring from the CSS facility. B. A follow-up inspection conducted on February 27, 2014, revealed the unpermitted discharge was continuing. 9. On March 5, 2014, the Director issued Emergency Order LIS 14-021 ("EO") against CSS and on March 6, 2014, representatives of CSS met with the Director to discuss the EO. 10. On March 10, 2014, CSS submitted photos that showed the unpermitted discharge had ceased. 11. ADEQ served a cover letter, a copy of the NOV, and a copy of Commission Regulation No. B upon CSS via certified mail on Docket No. IS-003-NOV Order No. 2 Page No. 4 February 11, 2015. The NOV required CSS to submit a corrective action plan and assessed a civil penalty in the total amount of $33,000. 12. The certified mail receipt number 7006 3450 0003 4067 7349, as well as the returned certificate and USPS tracking information, confirmed delivery of the NOV to CSS on February 11, 2015. 13. A separate set of identical documents was also sent February 6, 2015, to CSS's registered agent for service of process, Janet Harper, via certified mail, restricted delivery. A copy of that letter reflecting the certified mail receipt number 7006 3450 0003 4067 7493, as well as USPS tracking information indicated that notice was left but "No Authorized Recipient Available." 14. ADEQ's NOV states that if CSS wishes to dispute the Allegations and Proposed Findings of Fact or the Proposed Civil Penalty Assessment and Order, then CSS must file a written request for hearing with the Commission in compliance with Regulation No. 8 within twenty (20) calendar days of receipt of the NOV. 15. The cover letter served on CSS on February 11, 2015, re- states that a written request for hearing must be filed with the Commission within twenty (20) calendar days of receipt of the NOV. 16. Twenty (20) calendar days from February 11, 2015 was Tuesday, March 3, 2015. 17. CSS's Request for Hearing was filed with the Commission by facsimile on March 12, 2015. Docket No. 15-003-NOV Order No. 2 Page No. 5 18. CSS's Request for Hearing was filed by Mr. Ken Harper and CSS is a limited liability corporation. 19. CSS's Request for Hearing consists of one (1) paragraph which states, in its entirety: Please be advised that I just received your notice of violation. I have called and spoke to Pat Goff and I am writing this to request a hearing. Chicot Sewer Systems, LLC will take immediate actions to come within compliance with all discharges that are currently out of compliance. Pat Goff advised me to ask for a telephone hearing. At your convince (sic) please call me at 501-837-7690. Your help in correcting this matter is appreciated. Thank you very much. 20. Commission Reg. 8.602 requires a corporation in an adjudicative proceeding to be represented by an attorney. 21. On April 2, 2015, the Commission's ALJ held a preliminary hearing via telephone conference call with counsel for ADEQ and Mr. Ken Harper for CSS. During this telephone conference call Mr. Harper confirmed to the ALJ that he is not a licensed attorney in good standing in the state of Arkansas, and CSS had no plans to retain counsel. V. DISCUSSION AND CONCLUSIONS OF LAW Commission Reg.8.602 requires corporations to be represented by an attorney in all Commission adjudicatory proceedings, and it has been settled by the Arkansas Supreme Court that the practice of law is not confined to services rendered by an attorney in court of justice, but includes any service of a legal nature rendered outside of courts and unrelated to matters pending in the courts. Nisha LLC v. Tribuilt Construction Group, LLC, 2012 Ark. 130 (Ark. Docket No. 15-003-NOV Order No. 2 Page No. 6 2012) . The Commission's adjudicatory hearings are conducted in a manner that mirrors the standard practice of law. Typical pre - hearing practice consists of pleadings and motions being filed, discovery being propounded, and depositions being taken. The adjudicatory hearings are characterized by opening and closing statements, direct and cross examination of witnesses, and the occasional voir dire of expert witnesses. In short, appearing before the Commission on behalf of a corporate client is, without a doubt, the practice of law. That is why Commission Reg.8.602 requires corporations to be represented by an attorney in all Commission adjudicatory proceedings, and why the ALJ dismisses this appeal pursuant to Reg.8.602. Because this appeal is being dismissed pursuant to Reg.8.602, the ALJ is not reaching the merits of ADEQ's two other points in support of dismissal - that CSS's Request for Hearing was filed too late in violation of Reg.8.403 and CSS's Request for Hearing did not comport with Reg. 8.603(C)(1)(c). IT IS THEREFORE ORDERED: 1. Under the provisions of Regulation No. 8.602 the ALJ grants ADEQ's Motion to Dismiss with prejudice. RECOMMENDATION It is the recommendation of the administrative law judge that the Arkansas Pollution Control and Ecology Commission adopt and affirm, without modification, the findings of fact and conclusions Docket No. 15-003-NOV Order No. 2 Page No. 7 of law set out in the above Recommended Decision. IT IS SO ORDERED This 2nd day of April 2015 CMes Moulton Administrative Lary Judge Docket No. 15-003-NOV Order No. 2 Page No. B CERTIFICATE OF SERVICE I, Patricia Goff, Commission Secretary, hereby certify that a copy of the foregoing Order No. 2, In the Matter of Chicot Sewer Systems, LLC; Docket No. 15-003-NOV has been mailed by certified mail or by first class mail, postage prepaid to the following parties of record, this 2"d day of April 2015. CERTIFIED MAIL 7013 0600 0001 8188 2188 Ken Harper Chicot Sewer Systems, LLC PO Box 942 Bryant, AR 72089 (501) 837-7690 Michael McAlister Arkansas Department of Environmental Quality 5301 Northshore Dr. North Little Rock, AR 72118 (501) 682-0918 (501) 682-0891 11 Patricia Goff Commission Secretary Arkansas Pollution Control and Ecology Commission 101 East Capitol, Suite 205 Little Rock, Arkansas 72201 (501) 682-7890 FAX: 682-7891 ARKANSAS POLLUTION CONTROL AND ECOLOGY COMMISSION Chicot Sewer Systems, LLC MINUTE ORDER NO. 15 - Docket No. 15-003-NOV PAGE 1 OF 1 On April 2, 2015, Charles Moulton, Administrative Law Judge ("ALJ"), issued Order No. 2 (Recommended Decision) in Docket No. 15-003-NOV, which is a case styled: In the Matter of Chicot Sewer Systems, LLC. Order No. 2 grants ADEQ's Motion to Dismiss with prejudice. The record compiled in this docket by the Administrative Law Judge and Order No. 2 came before the Commission at its May 21, 2015 meeting. After considering the matter, the Commission adopts and affirms, without modification, Order No. 2 (Recommended Decision) entered on April 2, 2015, and closes this docket. COMMISSIONERS .1. Bates L. Bengal .1. Chamberlin R. Chastain J. Fox C. Gardner M. Goggans R. Moss R. Reynolds W. Stites B. White R. Young SUBMITTED BY: Charles Moulton PASSED: 5/21/15 A. Henry - Chair ARKANSAS POLLUTION CONTROL AND ECOLOGY COMMISSION IN THE MATTER OF DECISION ] DOCKET NO. 15-001-MISC OF INTERIM DIRECTOR ] ORDER NO. 4 J. RYAN BENEFIELD AND } PULASKI COUNTY SOLID WASTE j MANAGEMENT DISTRICT BOARD ) RECOMMENDED DECISION Appearances: Mr. Richard C. Downing for L&W Environmental, LLC; Beth Blevins Carpenter and LaTonya Austin for Pulaski County Solid Waste Management District Board; Ms. Tracy R. Rothermel and Mr. William K. Montgomery for the Director of the Arkansas Department of Environmental Quality. 1. INTRODUCTION L&W Environmental, LLC ("L&W") owns and operates a Class 4 landfill and recycling facility in Pulaski County, Arkansas. Pulaski County Regional Solid Waste Management District Board ("District Board" or "Board") is the governing body of the Pulaski County Regional Solid Waste Management District. On June 2, 2014, L&W submitted an application to the District Board requesting the District Board issue it a Certificate of Need ("CON") for a transfer station at its Pulaski County, facility. After the public comment period ended on July 11, 2014, and with no comments being received, the District Board took up L&W's CON application at its August 12, 2014, meeting. After hearing from L&W and discussion by the District Board members, the Board denied L&W's CON application. On September 10, 2014 - pursuant to Ark. Code Ann. § 8-6- 706(d) and Commission Reg.22.205 - L&W submitted a Notice of Appeal and Supporting Documents of the District Board's denial decision to WEST FORK WASTEWATER TREATMENT PLANT CITY OF WEST FORK, ARKANSAS The West Fork wastewater treatment plant consists of two lagoons that were built in 1970 and a mechanical plant that was put in senlice in 1973. The first lagoon cell is used for flow equalization of the raw wastewater. The second lagoon cell is used for dechlorination of the treated wastewater. A mechanical plant located on the east side of the lagoon cells is used for biological treatment of the City's wastewater. This plant was designed for a flow of 100,000 gallons per day and it is now treating approximately 140,0D0 gallons per day. Between the age of this plant (36 years) and the fact that it is operating at a rate in excess of its design capacity, it is reaching its useful life. As indicated in the attached maps, the two lagoons were built immediately on the east side of the West Fork of the White River. The entire plant site for both the lagoons and the mechanical plant beside the lagoons are included in the Zone AE of the applicable Flood Insurance Rate Map. This is the case for the FIRM map published in 1991 (Panel 170 for Washington County) and the updated Preliminary FIRM map dated August 7, 2006 (Panel 360 of Washington County, Map No. 05143C0360F). A copy of the 1991 FIRM map is attached. It is unknown what flood information was utilized when the plant was designed in 1970 to 1972. However, the plant has flooded twice since 2004 and has been subject to flood damage in prior years. During these flood periods, the lagoons are submerged in the river, and the plant is inaccessible for operation and maintenance. Damage to the plant facilities and the security fence has occurred. Since this plant was constructed, the City of West Fork has expanded to the north, along Highway 71. Most of this expansion area does not have a sewage collection system because it would require pump stations to route the sewage back to the wastewater treatment plant. There is one preschool facility that has installed its own pump station. Otherwise, residential growth in this area is relying on septic tanks. Consequently, the existing treatment plant has multiple issues, as follows: 1. It is old (36 years) for a welded steel package treatment plant. 2. Its design capacity is being exceeded with flows of around 140,D00 gallons per day and a design capacity of 100,000 gallons per day. 3. Its location is in the wrong place due to the flood damage it has been sustaining. 4. Its location is in the wrong place to allow gravity flow service to West Fork's growth area along Highway 71, north of the plant. These issues can all be addressed by relocating the plant to the north, at a location outside and/or above the flood plane area. Alternatively, this situation could be addressed by routing the City's wastewater flow further north, past the City of Greenland, to Fayetteville's wastewater collection and treatment system. Currently, Fayetteville accepts the wastewater generated in Greenland and treats it at its east wastewater treatment plant. Greenland's sewer mains and pump station are near capacity, so routing West Fork's flow through Greenland would require increased capability in Greenland's mains and pump stations, or separate mains and a pump station for West Fork's flow. Greenland's system needs to be upgraded, so a cooperative effort may be possible. Fayetteville has just completed a new wastewater treatment plant on the west side of Fayetteville and has substantially reduced its load on the east plant. Consequently, it is anticipated that Fayetteville would be capable of treating West Fork's flows, and that Fayetteville would be interested in this concept to accomplish more regionalization of the area's wastewater treatment. Depending upon the actual connection point to the Fayetteville system, this concept of routing West Fork's flow to Fayetteville could require 29,D00 to 34,000 feet of sewer main, as well as a pump station. Previous economic evaluations have indicated that it is more cost effective to expand the plant at its existing location, than to route the flows to Fayetteville. However, these evaluations did not include the considerations of a new plant site out of the flood plane and further north to receive gravity flow from the north end of West Fork. If the plant is to be moved north, then part of the pipeline required to reach Fayetteville must be built. At some point, it becomes more economical to route the pipeline all the way to Fayetteville, depending on how far the plant would be moved to the north. Nest Fork Waste Water Treatment Plant Leaking Wastewater Into White River Posted 4:52 pm, April 7, 2014, by Curt Lanning, Updated at 04:55pm, April 7, 2014 Facebookl70 ■ Twitter7 • Goggle ■ Pinterest LinkedInl ■ Email The Arkansas Department of Environmental Quality confirmed Monday (April 7) that they had visited the West Fork Waste Water Treatment Plant multiple times and observed sewage overflow leaking into the White River. A complaint was reportedly made via email that when it rains, raw sewage overflows from a manhole on the south side of the treatment facility and flows into the White River, according to the ADEQ. ADEQ inspectors visited the facility twice on April 2 and April 3. They observed sewage overflow was occurring and that wastewater was entering the White River. On the second visit (April 3), inspectors observed a second overflow occurring at a splitter box located on the facility. On Monday (April 7), inspectors returned to the facility once more and saw the overflows were still occurring, according to the ADEQ. ADEQ notified the city that they need to fix the situation, and they'll continue to monitor the overflows and stay in contact with city officials to ensure the problems are addressed. Filed in: News 4 comments Proud Arkansan And to think that we put a man on the moon over 50 years ago, yet we can't stop human waste from flowing into our streams. This is sad Arkansans. Please do mention this story to your friends and colleagues tomorrow and the days ahead. We are the natural state. Let's act like it. April 7. 2014 at 8.42 pm Former Citizen The West Fork Administrator has know for over a decade the sewage plant is past obsolete. That office has done nothing but sweep the problem under the rug and drink coffee with the good of boys out there. ADEQ gave them an extension years ago to either bring the plant up to code or work out an agreement with Fayetteville. Someone needs to FOI the records from that office and the ADEQ. It's all there, no one is holding anyone accountable. Mril 7,2014 at_1-0.35 }gym Rina VanKleef Oh, Arkansas. That bastion of intelligence. This shows us "We don't need no stinkin' regulations". Who needs clean water? The GOP says we don't. Don't want to drink E. Coli? Then vote democrat. April 9, 2014 at 6:35 am John Another instance where someone tries to turn a community problem into a political problem and play the blame game. The community most impacted by this environmental affront should take the stand and make the effort to remedy this problem — not a bunch of politicians or individuals so blinded by their demagoguery. April 11,2014aE8.30pin Sewage runoff in White River near West Fork KFSM 10:41 p.m. CDT April 9, 2014 CONNECT 1 TWEETLINKEDINCOMMENTEMAILMORE WEST FORK, Ark. (KFSM) - A report from the Arkansas Department of Environmental Quality confirmed a sewage runoff into the White River on Wednesday. It's now causing concern among some in the West Fork community about the safety of their local water supplies. City officials said there's no need for anyone to be alarmed, and there are no problems with the drinking water. Officials found two sewage leaks at the West Fork waste water treatment facility last week. The city said it has received a state grant to fix the 40-year-old system, and will continue conducting safety tests. Still, some people say they're being cautious until things are worked out. "It's more than just drinking water, but certainly drinking water is probably the greatest concern right away to the most people. Then in the water quality and the health for the river, for the people that want to fish in it, the people that want to swim in it, those are concerns that also need to be addressed," said John Pennington of the Beaver Watershed Alliance. The city said there is no set date for when the treatment facility will be repaired. For the full story from KFSM, click here. CONNECT 1 TWEETLINKEDINCOMMENTEMAILMORE UPDATED STATUS REPORT AND PROPOSED ACTION PLAN FOR WASTE WA TER COLLECTION AND TREATMENT SYSTEMS PREPARED FOR MARBLE FALLS SEWER IMPROVEMENT DISTRICT NUMBER ONE MARBLE .,FALLS, ARKANSAS AUGUST 2010 ENGINEERING SERVICES, INC. 1207 SOUTIi OLD MISSOURI ROAD • P. O. BOX 282 • SPRINGDALE, ARKANSAS 72765-0282 479-751-8733.479-751-8746 (FAX) • www.ENG]Nri:RIVOSERVICES.COM TABLE OF CONTENTS 1. GENERAL OVERVIEW................................................................................................ 1-1 2. PROGRESS TO DATE & UPDATED SYSTEM STATUS .......................................... 2-1 3. PROPOSED ACTION PLAN TO COMPLETE SYSTEM IMPROVEMENTS PhaseI Improvements....................................................................................................... 3-1 Phase II Improvements...................................................................................................... 3-6 Phase III Improvements ............. ....................................................................................... 3-10 4. SUMMARY .................................... APPENDICES Appendix A - Preliminary Injunction Consent Decree Appendix B - August 12, 2010 Effluent Sample Test Results Appendix C - CH2M Hill OMI Lift Station Assessment ..... 4-1 i LIST OF FIGURES Figure 3.1 Diagram of Phase I Improvements................................................................... 3-4 Figure 3.2 Cost Estimate - Phase I Improvements............................................................. 3-5 Figure 3.3 Diagram of Phase II Improvements.................................................................. 3-8 Figure 3.4 Cost Estimate - Phase II Improvements............................................................ 3-9 Figure 3.5 Diagram of Phase III Improvements.......................................................... ......3-1 1 Figure 3.6 Cost Estimate - Phase III Improvements..........................................................3-12 LIJ 1. GENERAL OVERVIEW The existing collection and treatment systems serving Marble Falls were designed in the late 1960's. In recent decades, the system has fallen into disrepair and has been found to be in violation of Arkansas Department of Environmental Quality ("ADEQ") and Arkansas Department of Health ("ADH") regulations numerous times. Most recently, the District experienced a major failure of their primary lift station. The failure occurred during the ice storm in early 2009, and raw sewage discharged into a nearby stream which flows into a tributary of the Buffalo National River. For several months, the District hauled sewage from the lift station to a manhole on the gravity line upstream of the treatment facility. However, the vehicle used by the District to haul the wastewater was vandalized, rendering the District unable to haul the sewage any longer, resulting in the sewer discharge. In response to the lift station failure and ensuing sewage discharge, ADEQ filed a lawsuit (Case No. CV 2010-10-1) to force the Marble Falls Water, Sewer and Solid Waste Disposal Suburban Improvement District ("the District") to bring their wastewater system into compliance with permit requirements and state and federal regulations. At a hearing on March 2, 2010, the District was placed under a Preliminary Injunction Consent Decree (included in the Appendix) requiring the District to take specific steps to address the sewer system deficiencies. Since that time, the District has worked to ensure that all provisions of the court order were satisfied. The District retained Engineering Services, Inc. to prepare evaluations of the system and a Preliminary Engineering Report, hired licensed wastewater operators to maintain and operate the system, and has made repairs to various components of the existing system to reduce the potential for adverse impacts resulting from its operation. At the direction of the District, this report has been prepared to document the District's efforts to date to meet the requirements set forth in the court order, provide an updated status of the existing system, and provide a proposal outlining measures for the District to take to complete the remaining items of work and bring the system into full compliance with NPDES permit requirements, regulations and the court order. 2. PROGRESS TO DATE & UPDATED SYSTEM STATUS At a Circuit Court of Newton County, Arkansas hearing on March 2, 2010, the District was placed under a Preliminary Injunction Consent Decree (included in the Appendix) requiring the District to take specific steps to address the sewer system deficiencies: A) Complete installation of the new lift station, and continue operation of the temporary pump until the new lift station is complete. B) Retain a Class II licensed operator for the wastewater treatment system. C) Retain a professional engineer to evaluate the existing wastewater treatment system and recommend a plan of action to address the long term wastewater treatment needs of Marble Falls, with evaluation to be submitted by April 6, 2010. D) Secure funding for wastewater treatment system rehabilitation/replacement. E) Retain a professional engineer to evaluate the existing wastewater collection system and recommend a plan of action to upgrade and/or rehabilitate the system, with the evaluation to be submitted by a date established during a telephone conference hearing on April 9, 2010. F) Take all reasonable measures to prevent further discharges of untreated effluent and comply with the District's NPDES permit. Since the issuance of the Preliminary Injunction Consent Decree, below is a summary of the activities the District has taken per the Injunctive Terms of the decree: A) The District submitted the lift station plans prepared by Nelson Engineering on January 21, 2010 to the Arkansas Department of Health. The plans were approved by the Department of Health on April 13, 2010. Funding for the new lift station will be pursued and the lift station will be installed pursuant to the proposal in Section 3, if the proposal is approved by ADEQ. With assistance from the Arkansas Rural Water Association, a temporary pump was placed into operation in February of 2010 at the failed lift station. The District continues to operate this temporary pump system, which is still in place. Since the installment of 2-1 PROGRESS TO DATE & UPDATED SYSTEM STATUS the temporary pump station, there has been no unauthorized discharge from the failed lift station site. B) On June 1, 2010, the District retained the RK Water Operations, LLC as the licensed wastewater treatment operator for the District. RK Water Operations, LLC has two (2) Class 3 licensed wastewater operators. The operators have repaired the clarifier skimmer arm and resumed normal operations of the District's Wastewater Treatment Plant. The results of a sample taken from the wastewater treatment plant's clarifier on August 12, 2010 are included in the Appendix. C) On March 9, 2010, the District retained the professional engineering services of Engineering Services, Inc. ("ESI") to perform a diagnostics of the wastewater treatment plant system and wastewater collection system to determine the condition of the system and provide recommendations to rehabilitate the system. The wastewater treatment plant evaluation and plan of action was completed by ESI and delivered to the Arkansas Department of Environmental Quality on April 6, 2010. The District requested and received assistance from Arkansas Rural Water Association in March of 2010 to conduct a smoke test of the integrity of the District's collection system lines. The results of the smoke test were utilized by ESI in the development of the wastewater collection system evaluation. The wastewater collection system evaluation and plan of action was completed by ESI and delivered to the Arkansas Department of Environmental Quality on April 29, 2010. Based upon the findings of the wastewater treatment plant system diagnostics study and the wastewater collection system diagnostics study, ESI prepared and submitted a Preliminary Engineering Report for the District to the Arkansas Department of Environmental Quality on May 20, 2010. The Preliminary Engineering Report recommended improvements to the wastewater collection and treatment systems to improve the collection system and provide a reliable means of wastewater treatment. D) Since the completion of the Preliminary Engineering Report, the District has pursued financing to make the improvements recommended in the report. On July 7, 2010, the District received a letter of recommendation for the project from the Arkansas Water and Wastewater Advisory Committee ("WWAC"). WWAC approval is 2-2 PROGRESS TO DATE & UPDATED SYSTEM STATUS required prior to receiving public funding for any water or wastewater improvement project in the State of Arkansas. On August 5, 2010, the District received notification from the Arkansas State Highway and Transportation Department ("AHTD") that AHTD would reimburse the District for the relocation of collection lines to be impacted by the widening of State Highway 7 in the amount not to exceed $292,307.00. Applications for funding for the remaining improvements have been made to the Arkansas Natural Resources Commission ("ANRC") and the United States Department of Agriculture -Rural Development ("USDA-RD"), which provide loan and grant funding for water and wastewater projects in Arkansas. The District also has prepared an application for funding through the Ike 2 Community Development Block Grant Fund Disaster Recovery Assistance funding program administered by the Arkansas Economic Development Commission ("AEDC"). Because applications for funding from the Ike 2 program are limited to cities and counties, the District's Ike 2 application must be approved and signed by Newton County Judge John Griffith. Judge Griffith has expressed support for the project and has placed consideration of the application on the agenda for the September 7, 2010 Newton County Quorum Court meeting. If approved by the Quorum Court, the application will be signed and submitted to AEDC for funding. The District will continue to pursue funding for the additional needed improvements in accordance with the proposal in Section 3 of this document, if approved by ADEQ. E) As noted previously, the evaluation and plan of action for the wastewater collection System was prepared by ESI and submitted to ADEQ on April 29, 2010. Due to collection system concerns raised by the Arkansas Department of Environmental Quality at a court teleconference on June 30, 2010, Arkansas Rural Water Association conducted an evaluation of the District's collection lines and lift stations on July 1-2, 2010 per a request from the District. This evaluation consisted primarily of dye testing, and the results of the study showed that effluent from both lift stations was reaching the wastewater treatment plant. 2-3 PROGRESS TO DATE & UPDATED SYSTEM STATUS F) Since the issuance of the Preliminary Injunction Consent Decree, the District has made great strides in improving the operation of the existing systems. In conjunction with CH2M Hill OMI and a representative from the Community Resource Group, the District's licensed operators conducted an evaluation of the District's small lift station and wastewater treatment plant on July 15, 2010 to provide an updated assessment of the operational treatment plant. This assessment is included in the Appendix to this document. The District and the operators from RK Water Operations, LLC have made several improvements to the treatment unit since the Preliminary Engineering Report ("PER") was submitted, and many of the deficiencies noted in the PER have been corrected. Some of the most notable improvements are: • The skimmer arm in the clarifier has been repaired and now functions correctly. • The aeration system has been repaired and also now function correctly, although only one two blower units is functional, providing no redundancy in the system. • The tablet chlorination unit located at the outfall from the treatment unit into the pond is now operational. Since the improvements to the treatment plant have been completed, the treatment unit is operating at a much higher level of performance than during the initial evaluation by ESI. A sample of water from the clarifier unit of the treatment plant was taken on August 12, 2010 and tested. The test results from the sample are included in the Appendix. Since January 2010, the District has replaced two (2) line segments and cleared seven (7) plugs in the gravity collection lines to improve the operation of the collection system. As indicated above, the District has satisfied several requirements of the Injunctive Terms of the court order, and has made substantial progress towards the satisfaction of all items. Work is currently underway to bring the system into full compliance with the Injunctive Terms as well as with the NPDES permit requirements and state and federal regulations regarding wastewater systems. The following section provides a proposal for completing the items or work necessary to successfully complete this process. 24 3. PROPOSED ACTION PLAN As discussed in Section 2, the District has made substantial progress toward satisfying all terms of the Preliminary Injunction Consent Decree. However, several steps still remain to completely bring the Marble Falls wastewater system into full compliance with all Injunctive Terms, NPDES permit requirements, and state and federal regulations. This section provides the District's proposal for completion of these remaining steps, which are divided into three phases. 3.1- PHASE 1 Phase I includes the items of work which are necessary to complete as quickly as possible to address issues which present an imminent threat to the residents and environment in the vicinity of Marble Falls or which are necessary to responsibly and safely operate the wastewater system. These items include: A) AHTD Sewer Line Relocation B) Lift Station 2 (Small Lift Station) Pump Replacement C) Installation of New Lift Station to Replace Temporary Pump D) WWTP Laboratory/Testing Equipment and Supplies E) Emergency Repairs to Existing Treatment Plant F) Monthly Testing at Chlorination Vault (Outfall into Pond) A) AHTD is in the process of modifying Highway 7, which serves as the western boundary of the District's service area. As part of this process, AHTD has expanded the Highway 7 right-of-way. The new right-of-way encompasses several hundred feet of existing sewer main, which therefore must be relocated. AHTD has agreed to provide up to $292,307 in funding to construct a new sewer main which will divert all of the wastewater which currently flows to Lift Station 2 to Lift Station 1 instead. This will allow the District to temporarily discontinue use of much of the existing collection system, as well as Lift Station 2 and Force Main 2. By reducing the amount of infrastructure they must maintain and operate, the District will reduce monthly operating and maintenance costs, but still provide wastewater service to all but two current customers. The two customers which will no longer be served by the system will be provided with septic systems as part of this project. Construction plans and specifications for these improvements have been submitted to the Arkansas Department of Health for approval. B) There are two existing pumps in Lift Station 2 (small lift station located in amusement park) which are designed to operate alternately and provide redundancy for one another. 3-1 PROPOSED ACTION PLAN One of the two pumps has failed, and the other pump, due to its age, could potentially fail at any time. Use of this lift station will be temporarily discontinued following completion of the AHTD sewer main relocation. However, the permit, bid, and construction process for the sewer line relocation could potentially take several months. The risk posed by relying on a single operational pump in the interim is too high to allow, and immediate pump replacement is recommended. Because any new pumps would only be in service for a short period before use of the lift station is discontinued, it would be more advantageous to repair the existing failed pump, if possible. This would provide the lift station with two aged but operational pumps, which will likely be sufficient until the AHTD relocation is complete. If repair is not possible, it is likely that the funding agency for Phase I will only provide funding for new pumps with the condition that they be returned to the funding agency once use of the lift station is discontinued. C) Plans for a new lift station to replace Lift Station 1 (the large lift station, which failed during the ice storm of 2009) were developed by Vern Nelson, P.E. and have been approved by the Arkansas Department of Health. The new lift station will be located east of Highway 7 along the south side of Highway 7 Spur. A new two inch diameter force main will be installed within the existing force main. Once the new lift station is constructed and operational, the temporary pump at the failed lift station will no longer be required. D) The District has retained the services of RK Water Operations, LLC to operate and maintain the treatment system. RK Water Operations, LLC has two Class 3 licensed wastewater operators, and is well qualified perform this task. However, in order to properly operate and monitor the system, the operators need laboratory and testing equipment and supplies. These are standard items which should be present at any permitted treatment facility, and on-sitc laboratory and testing capability is required by ADEQ regulations. E) The Preliminary Engineering Report and the evaluation compiled by C142M Hill OMI noted many deficiencies at the existing treatment plant. Although progress has been made and the plant is operating at a much higher level than during initial assessments, many problems are still present which pose imminent threats to the ability to continue operating the plant until a new plant is constructed. These items include replacement of wiring and a control box, installation of a small blower unit to provide redundant aeration capability, installation of an alarm system, and providing water service to the treatment plant site. 3-2 PROPOSED ACTION PLAN F) Phase I includes implementation of a monthly testing program. The program will consist of testing a sample from the outfall into the pond once a month, which will be tested by a certified laboratory to determine effluent characteristics. This testing is not required under the current NPDES permit, but is being undertaken voluntarily in order to establish the quality of effluent being produced by the treatment unit and discharged into the polishing pond. The test results will also give the District an objective statistic that can be used to monitor the performance of the operators. The NPDES permit does require a monthly monitoring report, but the official testing location established by the permit is the outfall from the pond to the receiving stream. There has been no recorded discharge from this location in recent history, and the required official monthly report therefore will simply note "No discharge". In order to provide regular data to monitor the treatment system's performance, institution of this alternate testing program is proposed. Phase I also includes payment for initial professional engineering services already provided to the District, which included preparation of the evaluation of the treatment system, the evaluation of the collection system, and the Preliminary Engineering Report, which were required by the Preliminary Injunction Consent Decree. Figure 3.1 is a diagram of the improvements included in Phase I of this proposal. The anticipated total cost of Phase I is approximately $168,177.50, and a preliminary cost estimate is included as Figure 3.2. Because funding for the AHTD sewer line relocation has already been secured, the sewer line relocation is not included in the total estimated cost for Phase I. The sewer line relocation has been submitted to the Arkansas Department of Health for approval of construction plans, and construction is anticipated to be complete in eight months. The remainder of Phase I is dependent upon obtaining funding for the proposed improvements. Once funding has been secured, Phase I is anticipated to be completed in eight months. 3-3 Portion of Gravity Main Wlthln New Highway Right-of-way PROPOSED ACTION PLAN Figure 3.1 Diagram of Phase I Improvements Lift Station 1 Portion of Lateral 2 and (To Be Abandoned) Fore Main 1 to Be Proposed Uft Station 'rf Abandoned (By Vern Nelson. r"r 7 ' `I Portion of Lateral 2 Proposed AT Lateww3 y and Force Main 1 to Septic System (To Re n 7 Remain In Use r•. �^ n Use) Proposed Gravity I Main Extension Proposed ` Use of This Portion Septic System., of Lateral 6 To Be Discontinued O Lateral (tie to Be Discontinued) . Lateral 4 (Use to be Discontinued) Lateral 1 ' (To Remain in Use) . •' ift Station 2 • Replace Pumps +' ' (Use to be I:]iscontinued) yf ■ Lateral ■ (Use to be Discontinued) :-•----•--•. {i arce Main 2 (Use to be Discontinued) 1 Treatment Plant 1. Emergency Repalm 2. Lab Equip. S Supplies f .. J� Portion of Lateral 6 •� To Remain In Use '4p'fb as ��Lateral 1 (To Remain In Use) LEGEND Existing Gravity Main to Remain In Use --_ -•- Existing Gravity Main - Use to be DismAnued -----...... Proposed G-Aly Msin Erdenelon Es nft Force Main to Remetn In Um Exdettnp Faroe Main Use to be DW=dnued — -- Roads Pond 3 PROPOSED ACTION PLAN Figure 3.2 Cost Estimate - Phase I Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COST ADEQ PROPOSAL - PHASE I MARBLE FALLS SEWER IMPROVEMENT DISTRICT #1 AUGUST 2010 ESTIMATED DESCRIPTION OF ITEM AMOUNT Small Lift Station Pump Replacement $ 5,000.00 Treatment Plant Water Connectan, Lab Equipment, Control BoM Wiring: & Alarm System $ 35,000.00 New Treatment Plant Electrical System $ 15,000.00 TOTAL ESTIMATED CONSTRUCTION COST $ 55,000•00 Contingency (10%) $ 5,50000 Design Engineering (11%) $ 6,05000 Construction Inspection (5 25%) $ 2,88750 Administrative $ 2,500.00 Engineering for Diagnostics Studies Required by Consent Order $ 7,500.00 Engineering for Feasibllity Siudy/Prellminary Engineering nepcit Required by Consent Order $ 12,500.00 ESTIMATED COST - PHASE I SUBTOTAL $ 91,937.50 New Lift Station to Replace Failed Lift Station t by Vern Nelson, P.E. (Cost provided by Vern Nelson, P.E.) $ 41,740.00 Increase Capacity of New Lift Station to Accommodate Diverted Flow from Lift Station 2 $ 19,500 00 Septic Systems for 2 Customers ($7,500 Feach) $ 15,000 00 TOTAL ESTIMATED COST - PHASE 1 $ 168,177.50 Note: Phase I Includes conslrutxlon of a new section of sanitary sewer main to divert wastewater from Litt Station 2 (small Ilft station) to the new lift station. AHTD has obligated funds for this portion of Phase I. S 292.207 00 3-5 PROPOSED ACTION PLAN 3.2 - PHASE H Phase 11 includes items which are important for system operation and maintenance, but which do not represent as urgent a need as those items in Phase I. The items in Phase 11 will enhance the operation or maintenance of the system, but their immediate installation are not absolutely essential. Phase 11 includes: A) Sewer Line and Manhole Rehabilitation B) Existing Treatment Plant Improvements (Also Utilized by New Treatment Plant) C) Installation of Security Fencing A) Several deficiencies in the gravity collection system which is to remain in use were noted during the smoke testing and described in the Preliminary Engineering Report. These items include replacement of sections gravity sewer lines and replacement and repair of damaged manholes. Completing these items of work will reduce the potential for inflow and infiltration, reduce frequency of clogs which can result in sewage overflows, and reduce the operation and maintenance expenses incurred by the District. The manholes and sections of pipe which will be rehabilitated in Phase 11 are indicated in Figure 3.3. B) Phase II includes several improvements to the wastewater treatment unit which will be used by the existing system, and will also be utilized by the new treatment system once it is placed into operation. This item includes include modification of the headworks box to include a bar screen, which will prevent large solids from entering the treatment unit. This item includes installation of a new chlorination system and chlorine contact tank, construction of a step aeration system and modifications to the plant outfall piping and discharge location to accommodate the new components. Flow monitoring capability will also be installed. These items will be constructed in such a manner and location that they will be able to remain in place once the new treatment plant is constructed and will be utilized as part of the new plant's treatment process. These improvements are intended to allow continued operation of the existing treatment plant until funding and permits are obtained for the new treatment plant. C) Currently there is no fencing to restrict access to the treatment plant or equipment building. Current security measures include a locked barrier on the stairs up the side of the treatment unit, a lock on the door to the equipment building, and a locked gate accessing the chlorination vault at the outfall to the polishing pond. A diagram of the proposed improvements under Phase II of this proposal is included as Figure 3-6 PROPOSED AC77ON PLAN 3.3. The cost to complete Phase H is estimated to be approximately $168,850, as indicated in the Phase II Preliminary Cost Estimate included as Figure 3.4. Once funding for Phase II is secured, it is anticipated that construction will be complete in approximately eight months. 3-7 PROPOSED ACTION PLAN Figure 3.3 Diagram of Phase H Improvements Install Manhole Replace 58.06 L.F. Of E)deting Sewer Main Replace 194.56 L.F. of Existing Sewer Main Rehabilitate Manhole LEGEND Rehabilitate Manhole Rehabilitate --------- Manhole Remove Concrete �' Stuboul I Repair Line ti Replace 285-26 L. F. of Ex isUng Sewer Main Remove oommte Go stubouts/repair lines I Replace 234.64 L.F. of .......... Existing Sower Main Treatment Plant 1. Headvmfics Vault 2. Chlorination System 3. Stop Aeration 4. Modify Outran Piping S. Flow Monkoting 6. Security Fencing ...... Existing Grrifty Main to ft. n In Use •----- ExIbIng Grudy MWn Uw to be Dkoon6vied ExIs" Face Maki IID Rarnaln In Use Exieft Face Main Wo to be Dleconlinued Roads Pond kr _--7D a2 PROPOSED ACTION P/AN Figure 3.4 Cost Estimate - Phase II Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COST ADEQ PROPOSAL - PHASE II MARBLE FALLS SEWER IMPROVEMENT DISTRICT #1 AUGUST 2010 ESTIMATED DESCRIPTION OF ITEM AMOUNT Sewer Main Replacement $ 38,880.00 Manhole Rehabilitation $ 7,500.00 Remove Existing Stubouts and Repair Sewer Main $ 7,500.00 Proposed Manhole at end of Lateral 2 $ 3,500.00 Modification of Existing Headworks Vault and Installation of Bar Screen $ 5,000.00 Installation of New Chlorination System with Contact Tank $ 12,500.00 Construction of Step Aeration and Aeration Tank $ 25,000.00 Reconfigure Outfall Piping / Modify Discharge Location / Flow Monitoring Equipment $ 10,000.00 Construction of Security Fencing and Gates 16 000.00 TOTAL ESTIMATED CONSTRUCTION COST $ 125,880•00 Contingency (10%) $ 12,58800 Design Engineering (100%) $ 12,588 00 Construction Inspection (So/.) $ 6,29400 Legal/Bond Counsel $ 10,000.00 Administrative/Permitting $ 1,500.00 TOTAL ESTIMATED COST - PHASE II $ 168,850.00 3-9 PROPOSED ACTION PLAN 3.3 - PHASE III Phase III of the proposal includes installation of a new wastewater treatment facility as detailed in the Preliminary Engineering Report, other than items which will have already been installed in Phase I or Phase II of this proposal. All parties are in agreement that continued operation of the existing treatment plant is not a viable long term option for the District, and that a new treatment plant is a priority. However, due to the low revenue levels of the District relative to the cost of the new treatment facility, funding for the new treatment system will have to consist primarily of grant funding. The amount of time necessary to secure sufficient grant funding is difficult to anticipate. For this reason, it is important that the District improve the existing infrastructure sufficiently through Phase I and Phase II of this proposal to allow continued operation of the existing facilities until funding for the new plant can be secured through Phase III. A diagram of the proposed treatment facility is included as Figure 3.5, and a preliminary cost estimate of the new treatment facility is included as Figure 3.6. The treatment facility is anticipated to cost approximately $419,375. Once funding for Phase III is obtained, it is anticipated that construction of the proposed improvements will be complete in approximately sixteen months. 001 PROPOSED ACTION PLAN Figure 3.5 Diagram of Phase III Improvements - PDOIT ss — IEAWIfJDM Bf9{ RDfi1MM M1E) FCWAMNTFRM crTfwro TJTWATM@02 (JK TOE C&%00HfNiDM K# wmo"OOf %WHWAWFEEN 0WA "OMiMr10 44 PHAU 0 1 R TIlAMr AMP �r 1 �} FXWI7O safsC 5 l ll 0"M� rTETw �1 coM�r ' aTanMD 0 WRMaVLM2T0 �s TfafmawA.Msro � TMtATMLNT TM ! _ R YOOfED WfI/I.Lf776 � TOfEWTWATMP fIMf ow^mum 4 J/ a OTAwoa llL l+01 a =aur�EHreu�wo f a� CONYil[TAM \ IxErM¢ ODNr/16T! HaDMD TANK 11 NMGMIOEMT10 t T11y7}?IAODMfAC7TRK pow • MMSTTYAT:MTOI Ovem /HAE D 01104FAM ►I[TD GRM PTMK 0 E 1 7MAT®OiMEW YiTwl �PETT 1 /NYT M TAKU 11 QIAUMTOT 11 1 ll 1l U 11 11 tl caow.TU+ [fo RE !C_M77C] 11� /.VJ[T LIEfl116 rOLaN�1G�pO LGCAF OM O MW I"l bR/fr W l !D M OONffTMA T®YMMNi mfMO AOWND Pew AFEAM P M4 ■ 3-11 PROPOSED ACTION PLAN Figure 3.6 Cost Estimate - Phase III Improvements ENGINEER'S PRELIMINARY OPINION OF PROBABLE COST ADEQ PROPOSAL - PHASE III MARBLE FALLS SEWER IMPROVEMENT DISTRICT #1 AUGUST 2010 ESTIMATED DESCRIPTION OF ITEM AMOUNT Yard Piping to New 20,000 Gallon Settling Tank $ 20,000 00 Installation of 20,000 gallon Settling Tank $ 60,000.00 Installation of 20,000 gallon Recirculation Tank $ 60,000.00 Yard Piping for Nitrate Recirculation Feature $ 12,500.00 System Component Pumps $ 5,000.00 Installation of Filter Pods $ 110.000.00 Installation of 5,000 gallon Polishing Tank $ 25,000.00 Construction o1 Security Fencing and Gates $ 16,000.00 Purring and Disposal of WW from Existing Aeration Basin and Clarifier (38,000 gaq $ 2,500,00 Rehabilitation of Existing Building $ 6,500.00 TOTAL ESTIMATED CONSTRUCTION COST $ 317,500.00 Contingency (100/.) $ 31,760.00 Design Engineering (10%) $ 31,750.00 Construction Inspection (511/6) $ 15.875 00 Legal / Bond Counsel $ 20,000.00 Administrative / Permitting $ 2,500.00 TOTAL ESTIMATED COST - PHASE III $ 419,375.00 3-12 4. SUMMARY If the proposal is approved by ADEQ and implemented by the District, it is the opinion of the engineer that the required improvements to the existing wastewater collection and treatment systems can be completed in a manner which will provide a long term solution to the needs of the residents of Marble Falls while also protecting the public health and environment in the area. The proposal allows the District to address the most immediate needs of the system first, and also provides a process whereby the remaining needs can be met without danger of health or environmental damage occurring in the interim. The three phases of proposed improvements to the wastewater system are summarized below: Phase I - Estimated Completion Date: Eiaht Months from Fundina Obligation • Funding has been secured from AHTD for diversion of wastewater from Lift Station 2 to the new lift station. $292,307.00 + Request grant funding from ANRC for emergency improvements to existing wastewater treatment plant, replacement of Lift Station 2 pumps, and construction of new lift station. $168,177.50 Phase II - Estimated Completion Date: Ei ht Months from Funding Obligation • Request funding for improvements to existing wastewater treatment plant which will also be utilized by the new treatment plant and rehabilitation of the gravity collection mains. Potential funding sources include ANRC, USDA Rural Development, and the Ike 2 CDBG program. $168,850.00 Phase Ill - Estimated Completion Date: Sixteen Months from Funding Obli ation + Request funding for construction of new wastewater treatment plant. Potential funding sources include ANRC, USDA Rural Development, and the Ike 2 CDBG program. $419,375.00 4-1 James, Donna From: duong nguyen <duongangelajoshua@yahoo.com> Sent: Tuesday, July 7, 2015 9:53 PM To: James, Donna Subject: opposed to Trails Subdivision Dear Ms. lames, My husband and I are writing to express our opposition to the Trails Subdivision planned for Kanis. Road. 1. The small lots are not appropriate and are inconsistent with this area of Pulaski county where large lots\ and acreage are the norm. Please oppose the R2 zoning. 2. We are opposed to the waivers requested for Kanis and Walnut Road. We need to protect these roads. 3. We are definitely opposed to the construction of a waste eater treatment facility. This will damage our watershed of Fletcher Creek and the Little Maumelle. 4. We object to variances requested on the maximum grade allowable. We are homeowners in Chenal Downs and are voicing our objection to this project. We would like to hear a response from you. Respectfully yours, Duong and Angela Nguyen 20 Livree Lane Little Rock, AR 72223 James, Donna From: Jason Payne <Jason.Payne@chrobinson.com> Sent: Tuesday, July 7, 2015 4:40 PM To: James, Donna Subject: objection to the Trails Subdivision Good afternoon Donna, Please take into consideration my family's objection to the Trails Subdivision. We oppose due to the following: a) to the housing/lot density proposed in the application. The small lots are inappropriate and inconsistent with the area of the County where large lots and acreage are the norm. The developer has asked for a variance to the current R2 zoning to allow the small lots. Oppose the variance from R2 zoning. b) to the waivers requested on Kanis Road and Walnut Road. The Master Street Plan and the County require certain guidelines/rules to protect these two roads. The developer has asked for waivers so they do not have to follow these guidelines. They have asked for additional dedication of right of way on Kanis Rd. and a waiver to release them from making some improvements required on Walnut Grove Road. c) to the request for a Conditional Use permit to allow the construction of a waste water treatment facility on the property. The risk of damage to the watershed, Fletcher Creek and the Little Maumelle makes the facility unacceptable. Possible contamination of well water is also a concern. d) to variances requested on the maximum grade allowable. The maximum allowable grade permitted now is 15% on internal streets and the fire codes allow only 10% for emergency access. They have requested a variance to exceed these maximums. Thank you, Jason Payne , 5 ,nmr Sales Exe_ ,utive North America Surfar_e Transportation C.H R,,,binson l 1 C ente:v(e:,v Dr I Suitt: 301 ! t,ittle Rock, AR 7221 : C..,r, 2(1(j cell FG 1 551 2732 , ;ax rG1 7.5 3040 ���.px�,,p -_';t; .roh.inso, coin w_vw ch>chinson com (aL A r u D eN la t m e r%w! ****************************************************************************************** ******************************* This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of C.H. Robinson. C.H. 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