April 29, 1993Dear Commissioner Harvey:
City of Okeechobee
Charles Harvey
Chairman
Okeechobee Board of County Commissioners
304 N.W. 2nd St.
Okeechobee, Florida 34972
Re: OBWA Franchise agreement
55 S.E. Third Avenue Okeechobee, Florida 34974 -2932 813/763-3372
IC
(4/01 817 tt1)
April 29, 1993
Please accept this letter as notice on behalf of the City
of Okeechobee of the objections of the City to the intended action
of April 29, 1993, by the Board of County Commissioners concerning
the adoption, and award, of a franchise from Okeechobee County, to
Okeechobee Beachwater Association, for the provision of water and
wastewater service to the area as delineated in Exhibit A attached
to the franchise agreement.
Let me preface this letter by referring back to what I
consider the initiation of, and continuing basis for, this
objection; that being the filing of the action by the City with the
Department cf Administrative Hearings (DOAH), objecting to the
comprehensive plan submitted by the County on April 2, 1992.
You will recall that our primary objections to the County
comprehensive plan was that the plan did not address goals,
policies or objectives necessary for intergovernmental coordination
and cooperation between the County and the City regarding the
future of, and provision for, utility service in the unincorporated
area of the County. In fact, the plan as submitted seemingly by-
passes any coordination with the City. The other primary objection
to the plan is the failure of the County to appropriately refer to
the one and only water and wastewater utility system, and service
area, in existence, that of course the system of the City. Due to
this omission, and specifically the plan's failure to accurately
identify the City's wastewater and potable water geographic service
area, including that portion of the City's service area which
extends into the unincorporated area of the County, and to which
the City has sought tc provide service to on a uniform and
nondiscriminatory manner, the City felt it imperative to protect
our interest by initiating the DOAH action.
Since September, 1992, despite our best efforts, little
progress has been made towards negotiating a settlement of these
Pace 2
concerns of the City. Our intent was, and is. as being in the best
interest of all Citizens in the County, was to arrive at a
mechanism to facilitate intergovernmental co- operation in
developing County -wide utility service, and avoid territorial
disputes over service areas to prevent, or limit duplicative or
competitive water and wastewater utility service areas.
Historically of course, since at least 1970, the ability of
Beachwater to provide water service to the area it serves has been
negotiated with, and permitted by, the City of Okeechobee, and as
we all know, this agreement is due to expire in October, 1994.
Despite our efforts to resolve these problems, we are now
confronted with the specter of the County of Okeechobee stepping in
and assuming control over the service area granted to Beachwater by
the City, and entering into a franchise agreement with Beachwater.
This franchise not only permits water service within the present
area in which Beachwater has its infrastructure, but permits
expansion of service, and purports to grant the right to provide
wastewater service as well throughout the area granted as well.
Thus, the City now must address the very problem we sought to
avoid by initiating the DOAH action; unilateral action in the area
of utility service by the County without any intent, or attempt by
the County to co- operate with the City, and encroachment within the
service area we have claimed for many years.
While we all have endeavored to some degree to work towards a
unified utility system, each of you must understand that the City
must proceed also with an assumption that such a system may never
come to be. Therefore, the protection of the existing 201 utility
service area is a priority concern for the City of Okeechobee. If
we must continue providing utility service without joinder by the
County or other entity, and regardless of the existence of this
franchise agreement or subsequent formation of a utility authority
by the County, we cannot, and will not, permit intrusion by others
seeking to provide utility services into cur service area. Everyone
is clearly aware of the City's system expansion plans on the table
at this time; the letting of the contract to construct our well
water facility to provide an additional one million g.p.d. to our
customers, and the impending design contract to double cur
wastewater capacity, from .6 million g.p.d to 1.2 million g.p.d.
Although the City does not yet actually have pipe in the ground
throughout our service area, we do possess the prior legal right to
serve the area. The City has also been conducting planninc.
engineering, and design studies to expand our system and customer
Page 3
base, in conjunction with the above described plant expansions. In
summary, the City remains ready, willing and able to render
efficient and effective service to those within our service area
who seek to be served.
The objections that we raise to the franchise include that
there exist questionable grounds to support the granting of this
franchise by the County; the County is acting inconsistently with
the adopted goals, policies and objectives of the Okeechobee County
comprehensive plan by granting this franchise; and the County has
failed to obtain the consent of the City to this encroachment into
our service area, as required by Florida Statutes 180.06, which
deals with the construction of, and operation of, a competing
utility service in a previously established service area.
The adoption of this franchise ordinance at this time will not
promote the formation of a utility authority; to the contrary, it
may force the City to protect its substantive and procedural
remedies by the immediate filing of appropriate legal challenges.
While this notice may not serve to cause each of you to reconsider
this ill- advised approach to the provision of water and wastewater
service to the North shore of Lake Okeechobee, you proceed at your
peril, and to that of the Citizens of the County and City of
Okeechobee. The City must reserve the right, and so places you cn
notice, to initiate any and all appropriate legal challenge to this
franchise and intrusion into our service area.
Kindest Regards,
f
L am^ z)--
`ohn R. Cock
City Attorney
City of Okeechobee
JRC /1fy
cc: Jack Coker
Okeechobee Beachwater Association, Inc.
South Florida Water Management District
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