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MEMORANDUM <br /> Date: April 14, 1995 <br /> To: Bob Hammitt, Maintenance Director <br /> From: Fred McVey, Maintenance Planning Manager <br /> Subject: Sewer Connection Compliance Program Status <br /> This memo provides information related to the status of the sewer connection compliance <br /> program, supplemental to that provided in the 1994 Maintenance Planning & Technical Support <br /> Annual Report. While the compliance rate achieved by the program is considered successful, <br /> for the first time in the history of the River Road /Santa Clara sewer project the City did not meet <br /> connection goals specified in the project's EPA grant conditions. To understand how !he <br /> connection compliance program can achieve a connection rate of 95% for those properties <br /> served by sewers prior to 1994 and still not meet EPA grant conditions, the relationship of the <br /> grant construction and connection schedules to compliance program policies and procedures <br /> was examined in detail. <br /> Several inherent discrepancies exists between the timing of connections to the public sewer <br /> required by EPA grant conditions and the timing required in the policies and procedures, based <br /> on Eugene Code provisions, of the connection compliance program. First, the Eugene code <br /> requires that all structures within 160 feet of a public sewer connect to the public sewer; EPA <br /> grant conditions require all developed properties "served" by sewers, irrespective of distance <br /> from the public sewer, to connect. Current code provisions do not allow enforcement of the <br /> connection requirement for those properties where the structure is more than 160 feet from the <br /> public sewer or right -of -way containing the public sewer. To date, 11 property owners have <br /> asked for and been granted an extension of the connection requirement based on the distance <br /> criteria. <br /> A second contradiction between the connection compliance program and the EPA grant <br /> conditions is the time allowed for property owners to complete connection. The connection <br /> compliance program normally allows an 18 -month grace period to connect and provides for <br /> extension of this time in some situations. The EPA grant conditions appear to assume.that <br /> 100% of properties served by sewers connect within twelve months of construction. The <br /> construction and connection schedules specified in the grant call for 60 percent of the <br /> developed properties in the grant area be served by sewers by December 31, 1993 and for 60 <br /> percent of the developed properties to be connected to the public sewer by December 31, <br /> 1994. This expected 12 -month connection period contradicts the City's policy of allowing an 18- <br /> month grace period to connect. <br /> The connection compliance program recognizes that certain conditions of financial hardship, or <br /> other legal or physical conditions may justify extending the time allowed to a property owner to <br /> complete connection to the public sewer. Two general categories of extension are allowed in <br /> our connection compliance program, financial hardship and administrative. Financial hardship <br /> extensions are allowed based on the same criteria used to determine eligibility for a sewer <br />