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of that existing mobile home park is on the County's water and <br />sewage system. The second issue for discussion has to do with the <br />simple fact that mobile homes use less water and generate less <br />sewage than the standard residential user. Last, but not least, he <br />wanted to address a provision in the proposed ordinance which <br />involves a look back, 24 months after connecting to the system, to <br />see if, in fact, the use that is being generated by that project is <br />the volume of use on a peak -load capacity that was estimated when <br />the project originally connected. Mr. Radell informed the Board <br />that Heritage Village Mobile Home Park has 430 units, has been in <br />existence for approximately 17 years and has had its own on-site <br />water and sewer system during that time; so, with regard to the <br />historical data approach, the records for more than ten years are <br />available. He felt this is not a situation where you have to use <br />a crystal ball as you would with a new development. Staff has used <br />the argument that when a family of two leaves a mobile home and is <br />replaced by a family of six, water use and sewage generation <br />increases three -fold. The historical information from Heritage <br />Village shows that the impact has been even and consistent over the <br />years. Mr. Radell made another point in connection with capacity <br />used by mobile home owners. He said there are two times when <br />capacity for water and sewer use is allocated. First, is when it <br />is charged to the mobile home park owner, and in the case of <br />Heritage Village it is for 250 gallons per day per ERU for water <br />and sewer per unit. The other time is in the agency reporting <br />process when Indian River County reports the commitment of capacity <br />for a mobile home to DER as 200 gallons per day, which is 80% of <br />allocated capacity. There is a discrepancy and it seems capacity <br />is being sold twice and the County realizes that mobile homes, in <br />fact, do use less than an average single family residential unit. <br />We recommend the Board do the following to correct what we perceive <br />to be a gross inequity and an unfair situation: under Section 7, <br />Paragraph 27 of your proposed ordinance, in the case of large <br />mobile home communities, look at the historical records, evaluate <br />the historical records on the basis of peak demands of that park <br />and base capacity commitments on that peak demand. <br />Chairman Bird asked if his point is the data would indicate <br />the proper allocation may be less than one ERU per mobile home. <br />Mr. Radell said, absolutely, that was his point, and would <br />pertain to large parks with recorded historical data. In fact, he <br />quoted from Section 27, indicating the County can make exceptions <br />to correct inequities by adjusting the impact fee. He also would <br />recommend the County recognize that, in fact, mobile homes use <br />water and generate sewage in the amounts that the County currently <br />41 <br />Poor <br />` IAR 12 19N� <br />