Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-01 · Rev H · 16 Aug 2026

OP-01 · INSPECTION AND COMPLIANCE

Outsource the function. Connect the workflow.

Eleven SOPs are in. The inventory is in. The record that proves the program runs is not.

✓

Procedures

11 SOPs submitted January 2026

✓

Facility inventory

13 high risk named from 495 permitted

Inspection records

First summary in. The rest not compiled.

Construction records

Log format built. No records in it.

Progress reports

Data exists. None filed since Aug 2025.

One connected chain

iWorQ holds records. Nothing carries them to FDEP.

In placePartialNot in placeNot started

1Where it stands

11 SOPs submitted January 2026. Frequencies set: monthly, quarterly, semi-annual by tier.
13 high-risk facilities named, from an inventory of 495 permitted.
Inspection records since 12 Aug 2025: first summary complete. Balance pending Building Department data access.
Progress reports: none filed. First one was due 11 Oct 2025.
Capacity: 0.25 FTEs on documented counts, 6.27 once every asset is counted. The City fields 0.50.

2What this costs the City

TurnoverOne person holds the function. They leave, the program stops.
Constant trainingThe order requires training SOPs at III.A.7.c, III.A.7.d and III.A.9.c. Keeping staff current against them is a critical gap.
AccountabilityNo target, no metric, no number anyone owns.
Meeting the metricsMilestones close on evidence delivered to a schedule.
CostSalary, benefits, vehicle, supervision and training, all carried on one position.

3Recommendation

Outsource the inspection function to an entity that carries the obligation, not just the staff time. Fixed scope. Fixed fee. Defined metric. Monthly evidence in a form FDEP accepts.

The City keeps the authority and the record. It stops carrying turnover, training, supervision and vehicle cost.

What the City buys is a number it can report, not a position to keep refilling.

4The technology gap

iWorQ is the system of record in every SOP. It stops at the record. Reports to FDEP are rebuilt by hand from it, alongside forms, spreadsheets and email.

INSPECT→PROACTIVE→REGULATORY→REPORT

One system, one chain. The tailgate inspection becomes the compliance record, then the regulatory file, then the report. FDEP gets a login.

5Cost comparison

In-house today, one position, fully loaded see page 2$77,855 / yr

Program at the level the SOPs require estimate$487,881 / yr

Same program, documented counts only floor$19,347 / yr

Outsourced inspection, fixed fee

Project management fee, one time$55,000

Connected system, annual

Stipulated penalty ¶10 $200 day$6,000 month$73,000 year

Demandable any time after the day is missed. On top of the $62,852.92 already assessed, and of up to $15,000 per day per violation under paragraph 17.

Decision items six decisions, four of them cost nothing

Outsource the inspection function. Fixed scope, fixed fee, defined metric, monthly evidence.
Approve the connected compliance system. One tool from inspection to report. Scope and budget on request.
Release Building Department permit data to Public Works. This builds the target list.
Close the two gaps in the SOP set. Post-construction review SOP 02-01, and a structural control SOP with a frequency.
Name the funding source. Stormwater fund or the consultant services line.
Confirm the four asset counts. Outfalls, inlets, structural controls, active construction sites.

Director, Public Works City Manager Date

Prepared for the City of Opa-locka by APAS · Obligations and penalties cited to Consent Order OGC No. 24-3045. OP-01 · Page 1 of 3

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-01 · Rev H · 16 Aug 2026

OP-01 · PAGE 2 · COST AND LEVEL OF SERVICE

What the function costs. What it has to produce.

Built from published Florida rates. An APAS estimate the City can correct in an afternoon.

AFully loaded cost of one inspector

Personnel

Base salary44,811

FRS employer contribution, 14.03%6,287

FICA, 7.65%3,428

Health insurance, employer share7,833

Workers compensation, 2.0%896

Subtotal63,255

Operating

Vehicle, 8,000 mi at 72.5¢5,800

Devices, tablet and GPS1,200

PPE and sampling supplies600

Supervision, 5% of a loaded supervisor5,500

Training and certification1,500

Subtotal14,600

Fully loaded annual costone position, one year

$77,855

Cost per productive inspection hour

$53.12

Paid hours are not inspection hours. Only 70.5% of a paid year reaches the field.

BLevel of service, from the frequencies the SOPs fix

2,080

Paid hours
40 x 52 weeks

−

1,832

Working hours
less leave and 11 holidays

−

1,466

Productive hours
less 20% admin

3.0

Hours per inspection
drive, visit, form, upload

489

Inspections one FTE delivers
in a full year

0.25

FTEs required, documented counts onlyThe floor. 121 inspections a year, every count sourced to an SOP.

6.27

FTEs required, once every asset is countedAPAS estimate. 3,061 inspections a year.

0.50

FTEs the City fields todayOne position, not full time on this function.

Of the estimated program covered2,817 inspections will not happen this year.

Eleven of fourteen asset counts are APAS placeholders and carry 96% of the estimate. Outfalls, storm drain inlets, structural controls and active construction sites are the four counts that move the answer. Supply those four and the estimate becomes a number the City owns.

Sources. Salary: Florida code enforcement officer average, ZipRecruiter Aug 2026. FRS Regular Class employer rate 14.03%, 1 Jul 2025. Health: KFF 2025 survey. Vehicle: IRS 2026 rate. Mileage, workers compensation, devices, supervision and training are APAS assumptions.

CHow a KPI becomes a closed milestone

Prepared for the City of Opa-locka by APAS · Cost figures are an APAS estimate from published rates and are offered for the City to correct. OP-01 · Page 2 of 3

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-01 · Rev H · 16 Aug 2026

OP-01 · PAGE 3 · THE SOP REGISTER

What the City told FDEP it would do, and how often.

Every frequency below is quoted from the SOP that sets it. The City wrote these numbers, not APAS.

BThe clock, from the day the order was executed

Obligation	Where it comes from	Applies to	Due	Status
Bi-monthly and quarterly progress reports	Order 6(e) and 7 · 60 days	Every open corrective action	11 Oct 2025	308 days, none filed
Proactive inspection records since execution	Order 6(b).v · SOP 07-01 · Appendix A	Every priority tier of the MS4	10 Nov 2025	278 days, first summary only
Construction inspection records since execution	Order 6(b).xv · SOP 09-02 · Appendix D	Every active permitted site	10 Nov 2025	278 days, log format only
Inspect every structural control and roadway structure	Order 6(d)(ii) · Permit III.A.1	All of them, city-wide	12 Aug 2030	no SOP in the set

The order fixes the dates. The SOPs fix the frequency. Every date runs from 12 August 2025, the day the order became effective. The register below maps each frequency to its SOP.

CEvery measure, its SOP, its scope, its frequency

Measure	SOP that sets it	Applies to	Frequency the SOP fixes	Record since 12 Aug 2025
Proactive inspections by priority tier	SOP 07-01 §6.1 III.A.7.c	Six tiers: TMDL basins, aging sewer, industrial, repeat violators, septic, sensitive waters	Monthly tiers 1–2 · Quarterly tiers 3–4 · Semi-annual tiers 5–6	First summary only
Outfall inspections	SOP 07-01 §6.2	Every City outfall	Quarterly minimum	Not produced
Dry weather screening	SOP 07-01 §6.2	Priority 1 and 2 areas	Monthly	Not produced
Storm drain inlet survey	SOP 07-01 §6.2	All inlets	Semi-annual	Not produced
High-risk facility inspections	SOP 08-01 §6.2.1 III.A.8.a	13 named facilities from 495 permitted	Annual IW-5 and SW, by DERM · Once per 5-yr cycle all others, by the City	DERM reports not pulled into iWorQ
Construction site inspections	SOP 09-02 §6.1.1 III.A.9.b	Every active site, graded by acreage and receiving water	Weekly to bi-weekly high · Bi-weekly medium · Monthly low	Log format only, no records
Street sweeping and litter	SOP 03-01 §6.2 III.A.3	All zones on the sweeping map	Weekly by zone	Volumes not compiled
Manholes and lift stations	SOP 07-07 §6.9	All manholes and lift stations	Twice per year	Not tracked
Structural control inspections	No SOP in the set III.A.1	All structural controls and roadway collection structures	Once per 5 years Order 6(d)(ii)	Not started
Progress reporting	Order 6(e) and 7	Every open corrective action	Bi-monthly and quarterly	None filed

Two holes in the set. The compliance matrix lists SOP 02-01 for post-construction review, item 6(b).i, but no SOP 02-01 is in the document. And nothing carries a frequency for structural controls under Permit III.A.1, the 5-year obligation at Order 6(d)(ii).

Prepared for the City of Opa-locka by APAS · Every frequency is quoted from the City SOP set submitted January 2026.OP-01 · Page 3 of 3