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56 <br />sewer system more closely reflect BOCC values in the near term by simply modifying the <br />system's rules of operation.. For example, the Board might create a rule of operation that forbids <br />the extension of the system in ways (wastewater pumping stations) or to areas not envisioned in <br />the system master plan except to serve an affordable housing complex or a public facility or to <br />address a public health/environmental concern. Other rules could outline requirements relative <br />to stream crossings, establishing perpetual maintenance funds, providing standby power <br />generation, alarm systems, etc. Any precedent that might conceivably be established by any <br />decision on the Richmond Hills project could be either eliminated by or incorporated within the <br />rules of operation. <br />Conclusion <br />The County administration and staff have certainly taken the central pumping station precedent <br />issue into account in the recommendation that a STEP system be used to provide sewer service <br />to Richmond Hills. However, the precedent setting potential is a secondary concern. The <br />primary concern is that the current lack of a utility maintenance capability impedes the County's <br />ability to ensure immediate response to pump station emergencies and to prevent or reduce <br />wastewater spills. Under current operating practice, OWASA provides a very high level of <br />service to the County in its contractual agreement to maintain the existing Efland sewer pump <br />station. However, in the event of regional disaster such as Hurricane Fran, OWASA will <br />understandably respond to its own needs first. County administration and staff acknowledge that <br />these concerns will become moot if and when the Efland sewer system expands to its ultimate <br />capacity (as defined by the existing master plan) and the County develops its own utility <br />maintenance and emergency response capacity. Furthermore, County administration and staff <br />acknowledge that the use of STEP system may not drastically reduce the County's cost in <br />providing sewer service to Richmond Hills. That is, County staff may have to take on some sort <br />of administrative role in financing and coordinating the necessary maintenance of a STEP <br />collector system. <br />The listing of system advantages and disadvantages applicable to gravity collection/central <br />pumping station system and the STEP system earlier in this memorandum provide clear <br />indication that concerns applicable to the Richmond Hills project move well beyond the <br />boundary of typical utility concerns: The larger issues of how the County will: 1) impact the <br />development of the Efland corridor by the manner in which it develops the service capacity of <br />the Efland sewer system; 2) meet the expanding operational demands of an expanding Efland <br />sewer system; and 3) address its affordable housing goals in light of budgetary constraints, <br />providing utility services and land use/planning concerns, will consume much time and energy <br />before they are finally resolved. However, the BOCC is faced with the necessity of making a <br />decision has to how to address the interplay between the larger issues and the Richmond Hills <br />project now. The BOCC can follow the administration/staff recommendation and require that <br />individual residents of Richmond Hills take responsibility for the operation of their STEP <br />systems. Or the Board can direct staff to develop a plan to help finance and manage those <br />systems. The Board can also choose to allow the development of a gravity collector/central <br />R <br />