HomeMy Public PortalAbout2004-14 Agreement with Post Buckley Schuh & Jernigan, IncRESOLUTION NO. 2004-14
A RESOLUTION OF THE VILLAGE OF KEY BISCAYNE,
FLORIDA; AUTHORIZING THE VILLAGE MANAGER TO
EXECUTE THE ATTACHED AGREEMENT ON BEHALF OF
THE VILLAGE WITH POST BUCKLEY SCHUH &
JERNIGAN, INC. FOR THE PREPARATION OF AN
ENVIRONMENTAL INFORMATION DOCUMENT FOR THE
VILLAGE OF KEY BISCAYNE SANITARY SEWER
PROJECT, PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, the Village of Key Biscayne was placed on the Federal Omnibus Bill which
allocates $1,000,000 in federal funds for the Village of Key Biscayne Sanitary Sewer Project; and
WHEREAS, the Village of Key Biscayne must provide an Environmental Information
Document (EID) to the Environmental Protection Agency in order to receive the $1,000,000
allocation.
NOW, THEREFORE, IT IS HEREBY RESOLVED BY THE VILLAGE COUNCIL
OF THE VILLAGE OF KEY BISCAYNE AS FOLLOWS:
Section 1. That the Village Manager is hereby authorized to execute the attached
Agreement, on behalf of the Village, with Post Buckley Schuh & Jernigan, Inc.
Section 2. Post Buckley Schuh & Jernigan will provide professional services for the
preparation of an Environmental Information Document (EID) for the Village of Key Biscayne
Sanitary Sewer Project in accordance with the Environmental Protection Agency's (EPA)
requirements.
Section 3. This resolution shall take effect immediately upon adoption.
PASSED AND ADOPTED this 23rd day of March , 2004.
4,0 6b/tie4 .,-:__
MAYOR ROBERT OLDAKOWSKI
AT
ic/lee,J61
CONCHITA H. ALVAREZ, CMC, VILLAGE CL
APPROVED AS TO FORM AND LEGAL SUFFI
VILLAGE ATTORNEY
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VILLAGE OF KEY BISCAYNE
AGREEMENT FOR
SERVICES
THIS AGREEMENT, made and entered into on the 2 day of frirch , 2004 by and
between the Village of Key Biscayne, Dade County, Florida, party of the first (hereinafter called
"Village"), and Post Buckley Schuh & Jernigan, Inc. , party of the second part (Hereinafter called
"Contractor");
RECITALS
The VILLAGE wants to engage the CONTRACTOR to perform certain services as described
in accordance with paragraph 1, scope of services to this Agreement ("Specified Services'). The
CONTRACTOR wants to provide such Specified Services in connection with professional services
for the preparation of an Environmental Information Document (EID) for the Village's sanitary
sewer project in accordance with the Environmental Protection Agency's (EPA) requirements.
In consideration of the mutual covenants in this Agreement, the parties agree as follows:
1. SCOPE OF SERVICES
A. The CONTRACTOR agrees, as directed by the Village Manager, to perform the following
services: Post Buckley Schuh & Jernigan will provide the following services for the Village of Key
Biscayne as described in "Exhibit A" attached hereto.
2. FEES FOR SERVICES
The CONTRACTOR agrees to charge the VILLAGE for performance of the Specified
Services provided in accordance in "Exhibit A" in an amount not to exceed $14,500.
3. TERM
The term of this agreement is = year unless terminated pursuant to paragraph 7 or
extended pursuant to paragraph 9.
4. GENERAL TERMS AND CONDITIONS
The VILLAGE reserves theright to amend the scope of services with appropriate adjustments
to the contract price.
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5 . A S S I G N M E N T
T h i s A g r e e m e n t s h a l l n o t b e a s s i g n a b l e b y t h e C O N T R A C T O R .
6 . F R O H I B i T I O N A G A I N S T C O N T I N G E N T F E E S
T h e C O N T R A C T O R , w a r r a n t s t h a t i t h a s n o t e m p l o y e d o r r e t a i n e d a n y c o m p a n y o r p e r s o n ,
o t h e r t h a n a b o n a f i d e e m p l o y e e w o r k i n g s o l e l y f o r t h e C O N T R A C T O R , t o s o l i c i t o r s e c u r e t h i s
A g r e e m e n t , a n d t h a t i t h a s n o t p a i d o r a g r e e d t o p a y a n y p e r s o n ( s ) , c o m p a n y , c o r p o r a t i o n , i n d i v i d u a l
o r f i r m , o t h e r t h a n a b o n a f i d e e m p l o y e e w o r k i n g s o l e l y f o r t h e C O N T R A C T O R a n y f e e ,
c o m m i s s i o n , p e r c e n t a g e , g i f t , o r a n y o t h e r c o n s i d e r a t i o n , c o n t i n g e n t u p o n o r r e s u l t i n g f r o m t h e
a w a r d o r m a l t i n g o f t h i s A g r e e m e n t .
T . ' T E R M I N A T I O N
T h i s A g r e e m e n t m a y b e t e r m i n a t e d b y t h e V I L L A G E u p o n t e n d a y s ' w r i t t e n n o t i c e w i t h o r
w i t h o u t c a u s e a n d m a y b e t e r m i n a t e d b y t h e C O N T R A C T O R u p o n 4 5 d a y s ' w r i t t e n n o t i c e w i t h o r
w i t h o u t c a u s e . I f t h i s A g r e e m e n t i s t e r m i n a t e d , t h e C O N T R A C T O R s h a l l b e p a i d i n a c c o r d a n c e
w i t h t h e p r o v i s i o n s o f P a r a g r a p h 2 o f t h i s c o n t r a c t f o r a l l a c c e p t a b l e w o r k p e r f o r m e d u p t o t h e d a t e
o f t e r m i n a t i o n .
8 . N Q N E X C W S I V E A G R E E M E N T
T h e s e r v i c e s t o b e p r o v i d e d b y t h e C O N T R A C T O R p u r s u a n t t o t h i s A g r e e m e n t n t s h a l l b e
n o n e x c l u s i v e a n d n o t h i n g h e r e i n s h a l l p r e c l u d e t h e V I L L A G E e n g a g i n g o t h e r f i r m s t o p e r i b r a l l s e
s a m e o r s i m i l a r s e r v i c e s f o r t h e b e n e f i t o f t h e V I L L A G E w i t h i n t h e V I L L A G E ' S s o l e a n d & W a t t l e
d i s c r e t i o n .
9 . E N T I R E A G R E E M E N T
T h e p a r t i e s h e r e b y a g r e e t h a t t h i s i s t h e e n t i r e A g r e e m e n t b e t w e e n t h e p a r t i e s . T h i s
A g r e e m e n t c a n n o t b e a m e n d e d o r m o d i f i e d w i t h o u t t h e e x p r e s s w r i t t e n c o n s e n t o f t h e p a r t i e s .
1 0 . W A R R A N T I E S O F C O N T R A C T O R
T h e C O N T R A C T O R h e r e b y w a r r a n t s a n d r e p r e s e n t s t h a t a l l t i m e s d u r i n g t h e t e r m o f t h i s
A g r e e m e n t i t s h a l l m a i n t a i n i n g o o d s t a n d i n g a l l r e q u i r e d l i c e n s e s , c e r t i f i c a t i o n s a n d p e r m i t s
r e q u i r e d u n d e r F e d e r a l , S t a t e a n d l o c a l l a w s n e c e s s a r y t o p e r f o r m t h e S p e c i f i e d S e r v i c e s .
T h e C O N T R A C T O R s h a l l f u r n i s h p r o o f t h a t i t h a s W o r k e r ' s C o m p e n s a t i o n I n s u r a n c e a s
r e q u i r e d b y C h a p t e r 4 4 0 , F l o r i d a S t a t u t e s a n d l i a b i l i t y i n s u n u i c e i n t h e a m o u n t o f o n e m i l l i o n d o l l a r s ,
s i n g l e l i m i t , f o r b o d i l y i n j u r y a n d p r o p e r t y d a m a g e , i n a f o r m r e q u i r e d b y t h e V i l l a g e ' s R i s k
M a n a g e m e n t o f f i c e , w i t h t h e V i l l a g e n a m e d a s a d d i t i o n a l i n s u r e d o n s u c h l i a b i l i t y i n s u r a n c e p o l i c y .
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11. ATTORNEY'S FEES
In connection with any litigation arising out of this Ageentent, the prevailing party shall be
entitled to recover reasonable attorney's fees and costs. This provision shall exclude all litigation
resolved by agreement of the parties.
12. NOTICES
All notices and communications to the VILLAGE or CONTRACTOR shall be in writing and
shall be deemed to have properly given if transmitted by registered or certified mail or hand delivery.
All notices and communications shall be effective upon receipt Notices shall be addressed as
follows:
Village:
Jacqueline R Menendez
Village Manager
88 West McIntyre Street
Key Biscayne, Florida 33149
With a copy to: Village Attorney
Weiss Scrota & Helfinan
Pastoriza & Cruedes, P.A.
2665 South Bayshore Drive
Suite 420
Miami, Florida 33133
Contractor:
Conchita H. Alvarez
Village Clerk
88 West McIntyre Street
Key Biscayne, Florida 33149
Post Buckley Schuh & Jernigan, Inc.
2001 N.W. 107x' Avenue
Miami, FL 33172
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13. GOVERNNG LAW
This Agreement shall be construed in accordance with the laws of the State of Florida.
IN WITNESS WHEREOF, the parties hereto have accepted, made and executed this
Agreement upon the tams and conditions above stated on the day and year first above written.
CONTRACTOR:
Post Buckley Schuh & Jernigan, Inc.
2001 N.W. 107th Avenue
Miami, FL 33172
4
VILLAGE:
Village of Key Biscayne
88 West McIntyre Street
Key Biscayne, Florida 33149
uelinc R. Me dez
Manag
age Clerk
al6,C'�'
Exhibit A
Scope of Services
PBSI
An employee -owned company
Transmitted Via: U.S. Mail/Facsimile
March 12, 2004
Ms. Jacqueline Menendez
Village Manager
Village of Key Biscayne
85 West McIntyre Street, Suite 201
Key Biscayne, FL 33149
RE: Key Biscayne Sanitary Sewer System Environmental Information Document Proposal
File: 01-0640.00 #1
Dear Ms. Menendez:
As per your request we are submitting our scope and fee proposal to provide Professional Services
for the preparation of an Environmental Information Document (EID) for the Village's sanitary
sewer system project in accordance with the Environmental Protection Agency's (EPA)
requirements.
The EID will in general and as applicable, follow the attached outline. It should be noted that some
of the information will need to be supplied to PBS&J by the Village. Specifically for example,
funding status and public participation activities as described in Sections A and G of the attached
outline, respectively.
Deliverables
Draft EID
Final EID
Schedule and Budget
Schedule
5 Copies
15 Copies
PBS&J is proposing the following schedule for this project:
2001 Northwest 107th Avenue, Miami, Florida 33172-2507 • Telephone (305) 592-7275 • www.pbsj.com
Ms.. Jacqueline Menendez
Village of Key Biscayne
Page 2
March 12, 2004
Task Description Approximate Duration -
Draft EID 4 weeks
Final EID 2 weeks
Total (Not including City and Agency Review time) 6 weeks
Budget
PBS&J is proposing a lump sum fee of $14,500 to complete the work as described herein.
Exceptions
• PBS&J anticipates holding three meetings with the Village and/or permitting agencies through
the duration of the project. Meetings called by the Village and/or permitting agencies in excess
of the number specified above are not included in this proposal
• Any application or review fees associated with the EID and/or permits
• Public Hearings
• Copies of deliverables in excess of the number specified above
We appreciate the opportunity to submit this proposal, and look forward to once again working with
the Village on this project. If you have any questions, please call me at (305) 514-3218.
Sincerely,
PBS&J
4---------.2<
Patricia A. Carney, P.E.
Program Manager
Water/ Wastewater Program
PAC/jrg
K:1EnvlWmtKEYBISC eidlproposal.doc
Environmental Information Document Instructions
For Wastewater and Drinking Water Projects
The NationalEnvironmentaLPolicyAct.(NEPA) applies tc► the sped 1 ppprnpriations
projects (SPAPs). The NEPA regulations that apply to the SPAPs are the Council of
Environmental Quality's implementing regulations at 40 CFR Parts 1500-1508 and EPA's
NEPA regulations at 40 CRF Part 6, Subparts A through D. In January 1995, EPA issued
two memorandums describing how the NEPA requirements and the intergovernmental
review regulations at 40 CFR Part 29 apply to special appropriations projects that were
authorized in fiscal year (FY) 1995. The requirements found in those memorandums also
apply to the SPAPs authorized by the EPA Appropriations Acts for FY 1996 through FY
2002.
EPA reviews all SPAPs to assure compliance with NEPA and other environmental laws and
regulations, such as the Endangered Species Act. For all projects that are not eligible for a
Categorical Exclusion (CE), each grantee must complete an Environmental Information
Document (EID). A suggested outline with descriptions is provided below. An EID
describes and evaluates the environmental impacts of the feasible alternatives, including the
'No Action' alternative. The scope of the EID should be commensurate with the size and
significance of the proposed project.
Prior to preparation of the EID, the applicant should obtain concurrence for the proposed
project from the crosscutters, such as the State's Historical Commission, the US Fish and
Wildlife Service, the US Army Corps of Engineers (wetlands, Section 404 permits, dredge
and fill, structures placed in navigable waterways).
The EPA reviews the EID and makes a determination as to the environmental affects of the
proposed project. If the project is found to have no significant effect, then EPA documents
their findings with the preparation of an Environmental Assessment (EA) and issues a
Finding of No Significant Impact (FNSI) for a 30 -day comment period. Completion of the
30 -day comment period without significant adverse opposition will complete the
environmental review process. If the EPA cannot support a FNSI, the applicant will be
required to take part in an Environmental Impact Statement.
Public participation should be included in the project planning process culminating in a
public meeting or hearing that presents the proposed project to the public and includes
discussion of both environmental and financial impacts. A record of the public
meeting/hearing and proof of advertising should be included in the EID.
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Environmental Information Document (EID) Outline
for Wastewater and Drinking Water Projects
A. Proposed Project and Funding Status
This section should include a description of the project, the need for the project, and the cost
of the project.
The project description should include the project name, owner and operator of the facilities,
location of the facilities, and the planning area description. List all facilities and actions
proposed by the facilities plan/engineering report. Functionally separate major components
should be listed as separate items. For example, a treatment plant is an item, an interceptor
line is an item, a new pump station is an item, etc. Sewer rehabilitation is an example of an
"action."
The need for the facility should be briefly stated, such as: to solve a water quality or water
quantity problem; to solve a public health concern; to correct inadequate systems or system
components; to increase treatment due to more stringent effluent limits; or for some other
reason. If the effluent limits have changed, include the existing effluent limits and the
proposed limits More information for the need for the project will be presented in section D.
Relevant design parameters should include a description of major unit processes, flow
diagram, sewer/water pipe lengths, sizes, and locations, and basic design criteria.
Include maps and figures no larger than 8.5 X 11 inches. Include a copy of a United States
Geological Survey (USGS) 7.5" topographical map showing the existing and proposed
facilities associated with the project and the overall project area. The location of major
project components should be clearly identified, such as treatment works, sewers, water lines,
pump station, storage facilities, etc.
Project costs should include proposed total project costs and all funding sources for the entire
project.
B. Existing Environment
This section should describe aspects of the natural environment of the planning area that
affected the alternative selection process or could be affected by implementing the plan. For
example, for surface water discharge, it is not necessary to describe soil conditions in detail;
however, any selected alternative using soil for treatment (septic tanks, spray irrigation,
overland flow), should include a thorough description of soil conditions.
A description of surface waters and their quality is needed in every case, along with any
Revised 10/017/02 2 of 7 EPA Region 4
public health problems due to water quality. The classification of the surface waters should
be stated, and a statement made to indicate if the waters are meeting the required water
quality standards for that classification. Water quality sampling data can be presented, if
available. There should be a qualitative statement at a minimum. _
If the project impacts groundwater quality or quantity, a discussion of the existing
groundwater quality should be included. For example, if ground water quality is being
degraded by existing wastewater disposal methods and the proposed project will reduce or
eliminate that impairment, a discussion of that issue should be included. The basis of
establishing the groundwater impairment should also be discussed, including ground water
sampling or other data sources. This information may also be given in Section D, Need for
Proposed Facilities.
Describe briefly any special or sensitive environmental areas such as wetlands; air quality
non -attainment areas; endangered or threatened species; prime or unique agricultural lands;
areas of recognized scenic, recreational, archeological or historic value; valuable floral or
faunal communities; wild or scenic rivers; drinking water (surface or groundwater) sources;
floodplains; recreational or commercial uses of potential receiving streams; and parkland or
other public lands.
Include environmental justice information. In preparing the EID, the grantee must identify
any minority populations and low-income populations which exist within the overall
planning area or which may otherwise be impacted by the project (e.g. downstream or
downwind communities). Native American communities, including their traditional resource
areas are included. If these areas would be affected by an alternative under consideration,
more detail should be provided.
For those special environments not found in the planning area, make a statement such as "No
wetlands, wildlife preserves, prime agricultural lands, or other environments of special
interest are located where they could be impacted by implementation of the recommended
facilities."
C. Existing Wastewater Facilities/Drinking Water System
This section should begin with a general description of the wastewater collection and
treatment system for the planning area for both wastewater and drinking water projects.
Describe existing collection, transport, treatment and sludge facilities. The service area(s) of
these facilities should be described briefly and shown on an attached figure. Mention the
condition of the facilities, especially as it affects alternative selection. For existing treatment
plants, state: 1) original design capacity and effluent limits; 2) existing permit limits; and 3)
actual performance over a recent period.
For wastewater projects, include wastewater flows (average, peak, and wet weather), influent
characteristics, major industrial users, and infiltration and inflow. Sewered and unsewered
Revised 10/017/02 3 of 7 EPA Region 4
areas should be mentioned and shown on the figure.
Where septic tanks are prevalent in all or part of the service planning area, their performance
should be described. Explain any problems. It is not sufficient merely to state that
malfunctioning septic tanks are causing aproblem_ Some documentationof the problem
should be cited, and details given about the location and severity of the problems.
For drinking water projects, include a description of the existing treatment and distribution
system, water demand (average and peak), surface water sources including intake locations
and permitted and actual withdrawal, groundwater sources, location of wells and well fields,
water storage, raw water characteristics, residual and backwash disposal and the service area.
Include existing system performance for all facilities.
D. Need for Proposed Facilities and Actions
This section should provide a summary of the need for wastewater or water facilities or
actions, emphasizing existing public health or water quality problems. These problems
typically include water quality violations or problems, documented public health hazards,
National Pollutant Discharge Elimination System (NPDES) permit non-compliance, existing
facility overload, insufficient capacity for projected demand, failing on -site systems,
insufficient pressure, etc.
For wastewater projects effluent limits are to be stated, and their derivation explained.
Describe different limits for different potential receiving streams.
If sewer rehabilitation is a proposed action, it should be justified by a brief quantitative
summary of the inflow/infiltration (I/I) problem. Location of the severe I/I areas should be
stated and shown on a figure if needed to identify significant project tasks.
Other special situations may justify proposed facilities.
Include the planning period for the project. The planning period should justify the capacity
of the system with its projected population. Population projections should be based on U.S.
Census projections or some recognized source of demographic data. Existing and projected
flows should be presented. Include land use projections, and the future environment without
the project.
E. Alternative Analysis
All alternatives analyzed should be described. The development of alternatives should
include the no -action alternative (the environment without the project), optimum utilization
of existing facilities including flow reduction and water conservation, and new construction
alternatives.
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An explanation should be given for rejecting or selecting alternatives. The explanation
should include present worth or equivalent annual cost comparisons; reliability of the
alternatives; complexity of the alternatives;.significant environmental effects;_andlegator_
institutional constraints.
F. Environmental Consequences; Mitigative Measures
Identify which reasonable alternative has been selected, and state the reasons why this
alternative has been chosen.
Describe and document the environmental effects of the selected alternative on each of the
different environmental aspects listed in this section. Address the direct, indirect, and
cumulative effects for each aspect.
Direct effects are changes directly related to the project activity. Indirect effects are changes
that occur later in time or are removed in distance which are reasonable foreseeable, such as
community growth, population density, land use, and natural environment. Cumulative
effects are the total changes to the environment resulting from the effect of the selected
alternative when added to the effect of other past, present, or reasonable foreseeable future
actions. Discuss any mitigation measures necessary to avoid or minimize any adverse
impact.
One important secondary impact of a project could be the development/growth that would be
encouraged or enabled by the construction of the project. The impact of that growth must be
addressed, including potable water demands, wastewater produced, land use changes, impact
on natural areas or wildlife, and other such concerns
This section should describe anticipated impacts on the environment and measures proposed
to mitigate those adverse impacts. Discuss recommendations from the crosscutting agencies
that implement environmental laws and include agency approval/sign-off letters in an
appendix to the EID. For each of the laws that is not applicable, provide a comment stating
that the law is not applicable.
Environmental laws that must be considered include:
Archeological and Historic Preservation Act of 1974, Pub. L. 86-523, as amended;
Coordinate with the State Historic Preservation Officer.
Clean Air Act, Pub. L. 84-159, as amended;
Address any impacts on air quality. If construction activities will generate dust
emissions that need to be controlled, indicate what methods will be used to
minimum these emissions. Address any potential sources of odor emissions that
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may be generated or eliminated through the implementation of the project.
Coastal Barrier Resources Act, Pub. L. 97-348;
Determine if the project is located on a coastal barrier island. If so, coordinate
with. the_ State C4mtal_Zone_..Management Agency.
Coastal Zone Management Act, Pub. L 92-583, as amended;
Determine whether the project is located in a coastal zone management area. If
so, obtain comments from the Coastal Zone Management Program.
Endangered Species Act, Pub. L. 93-205, as amended;
Identify any federally endangered and/or federally protected species within the
project area through coordination with the U.S. Fish and Wildlife Service
Environmental Justice, Executive Order 12898;
See Environmental Justice information in Section 19 of the SPAPs workbook.
Floodplain Management, Executive Order (EO) 11988 as amended by EO 12148;
Coordinate with Federal Emergency Management Agency (FEMA) if any part of
the project is located in a floodplain.
Protection of Wetlands, Executive Order 11990;
Coordinate with United States Army Corps of Engineers if wetlands will be
impacted by the project.
Farmland Protection Policy Act, Pub. L. 97-98;
Coordinate with the Natural Resource Conservation Service (NRCS) to protect
significant/important agricultural land from irreversible conversion to uses which
result in its loss as an environmental or essential food production resource.
National Historic Preservation Act of 1966, PL 89-665, as amended;
Coordinate with the State Historic Preservation Officer.
Fish and Wildlife Coordination Act, Pub. L. 85-665, as amended;
Coordinate with the US Fish and Wildlife Service
Safe Drinking Water Act, Pub. L 93-523, as amended;
Identify if the project will affect sole source aquifers. If so, contact your Region
4 project officer.
Wild and Scenic Rivers Act, Pub. L. 90-542, as amended;
Determine whether the project will have any effects on any river in the National
Wild and Scenic Rivers system, the "Nationwide Rivers Inventory," or an
American Heritage River. If the project is located within one mile of one of
these designated streams, contact the National Park Service and the department
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of Conservation and National Resources for comments.
Most environmental impacts to be considered are the features described in Section B,
Existing Environment (above). There may also be direct or indirect impacts on land use
practices, neighborhood stability, air quality_and_ noise_. fevels.__Ani_y_suchimp tsshould_ be
described.
It is not necessary to discuss special environmental areas (wetlands, etc.) that have been
identified in Section B, Existing Environment, as not found in the project area. On the other
hand, if any special environments are mentioned in Section B and are located in the project
area, something must be said in this section about impacts of the project(s) on them.
All structural and nonstructural mitigative measures should be described. If the usual
minimizing of erosion during construction is the only expected mitigative measure, this can
be mentioned in one short sentence. Detailed description is needed only for more unusual
mitigative measures that respond to some public or regulatory agency concern over a
perceived threat to the environment or public health.
Include a discussion of necessary permits (NPDES, 404, etc.) issued or needed, as well as
necessary inter -municipal agreements executed or pending.
G. Public -Participation; Sources Consulted
Summarize all public participation, including meetings and public hearings, noting any
public objections. EPA Region 4 has identified minimum requirements for the public
participation process in SPAPs grants. A description of these requirements can be found in
Section 20 of the SPAPs Grant Procedures Workbook. For complex or controversial
projects, a public hearing may be required. In addition, if there has been significant public
objection based on an environmental concern, an Environmental Impact Statement may be
necessary. Include documentation of the necessary public meeting, including the public
meeting date, public meeting transcripts, audiotape or video, and proof of publication of the
notice of the meeting in the local newspaper.
Although not required, we recommend presenting to the public the typical residential user
charge estimated to result from implementation of the plan.
List all sources consulted for information and/or concurrence. The State Clearinghouse, for
those states that have clearinghouses, should always be one of the entities consulted. If any
comments have been offered opposing any aspect of the plan, explain how those comments
have been resolved.
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