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HomeMy WebLinkAboutA033 - Maple Grove Mobile Home Park - Request for Sanitary Sewer ConnectionITEM #:37 DATE:08-12-25 DEPT:PW SUBJECT:MAPLE GROVE MOBILE HOME PARK REQUEST FOR SANITARY SEWER CONNECTION COUNCIL ACTION FORM BACKGROUND: On July 8, 2025, City Council received a memo from staff regarding a request from Horizon Land Management, on behalf of Maple Grove MHC, LLC, to connect the Maple Grove Mobile Home Park (6100 W. Lincoln Way) to the City of Ames sanitary sewer system (the request from Horizon Land Management and staff memo are attached). The Council directed staff to place the memo on a future agenda for the City Council's consideration. A history of complaints and investigations by the Iowa DNR has documented ongoing concerns about the mobile home park’s existing septic system, including citations for illicit discharges that pose environmental risks. To comply with Iowa DNR requirements while exploring alternatives, the park currently pumps wastewater from its private collection system and hauls it offsite for treatment. If the system becomes overloaded between pumping intervals, excess sewage would be discharged into a Boone County drainage district tile that empties directly into College Creek. Under current City policy, properties located outside the City limits are not eligible for sanitary sewer service, regardless of their land use designation. While drought conditions in recent years have complicated water quality sampling, new data reinforces prior concerns. On June 18, 2025, Prairie Rivers of Iowa collected water samples from College Creek at Wilder Boulevard as part of its regular monthly monitoring. The sample was analyzed for microbial source tracking and confirmed the presence of human- source fecal contamination upstream of Wilder. Although the exact point source of contamination could not be determined, Prairie Rivers, acting as the City’s water quality consultant, attributes these elevated E. coli levels in part to failing septic systems and lagoon overflows in the area. These systems are discharging into Boone County Drainage District 93B and Story County Drainage District 4 tile lines, which flow directly into College Creek. SEWER INFRASTRUCTURE: The City’s FY 2023/24 Ames Plan 2040 Sanitary Sewer Extension project, now complete, extended a public sanitary sewer main from the west end of Norris Street to approximately 500 feet south of Lincoln Way, along the west edge of the S. 500th Avenue right-of-way (see attached map). This sewer main was constructed to support future annexation and development contemplated by Ames Plan 2040. The main lies entirely outside the current City limits, within Story and Boone Counties. During and after construction of the sewer main, staff received multiple inquiries from the Iowa DNR and three nearby property owners located outside the City limits 1 (including Maple Grove) regarding abandoning their existing septic systems and connecting to the new public sewer. These properties are identified in Table 1, below. Sewer flowline elevations have been reviewed and can adequately serve this area with the City's new sanitary sewer main. Within City limits, sanitary sewer charges are based on metered water usage and are billed monthly through the customer ’s water bill. For properties outside the City that are not served by City water, an alternative method of determining usage would be required. This could involve coordination with Xenia Rural Water, the area’s primary rural water provider, or the establishment of a standard usage assumption for properties on private wells. Either approach would require creation of a new “rural” sewer rate, similar to the rural water rate outlined in Municipal Code Section 28.201(5). Although the City has not historically provided sewer service outside of the corporate limits, there are a few examples of the City providing water service outside of Ames. There are eight properties located outside the City limits where the City has agreed to provide water service, either because the rural water provider was unable to do so or because the City intended to eventually annex into that area. These customers paid for the costs of extending the water infrastructure, and their accounts are metered and billed at a higher rate than those within the corporate limits. However, none of these out-of-city properties are connected to the City’s sanitary sewer system and, therefore, do not pay sewer charges. Area Properties: Table 1 reflects the properties that have been identified as likely beneficiaries of a public sanitary sewer connection in this area. Among these, the properties marked with an asterisk are those that have inquired with staff about a connection. Table 1. Property Address Owner Acres % of Total Area Water Source 5820 Lincoln Way*LDR Iowa I LLC 12.38 47.3%City of Ames 5910 W Lincoln Way*West End Apartment L C 3.55 13.6%Xenia 6008 W Lincoln Way Watkins, Graham 1.14 4.4%Well 6014 W Lincoln Way Sporrer, Jeff & Stacey 0.38 1.4%Xenia 6018 W Lincoln Way Joan Pfeffer 0.42 1.6%Xenia 6100 W Lincoln Way*Maple Grove MHC LLC 8.30 31.7%Xenia Total - 26.17 100.0% - * Properties inquiring about sanitary sewer service connection to the City’s system. The City Council is not obligated to authorize the extension of sanitary sewer service to properties outside city limits. However, Council may determine that there is a benefit to considering the request. Three options are available, and the advantages, challenges, 2 and additional considerations related to each are detailed below: 1. "Rural Sewer" Service Agreement This option would allow sanitary sewer service to be provided without annexation. Maple Grove Mobile Home Park would still be responsible for extending the public sewer main to its property and constructing a service connection per City standards. A formal agreement would be required with each property owner that requests to connect. Such agreements would include: 1) conditions addressing future annexation timing, 2) use restrictions, 3) modification of their internal sewer system without City consent, and 4) rates for a new "rural sewer" service class. Advantages: Allows for the removal of non-compliant septic systems from the College Creek watershed. Allows for faster implementation compared to annexation, particularly for Maple Grove, which faces urgent environmental compliance issues. May be more acceptable to property owners not ready or willing to annex at this time, but would establish annexation agreements for the future. Limits City obligations strictly to sanitary sewer (and excludes intersection improvements, road maintenance, police, fire, etc. that would be required of the City with annexation). Challenges: A method would need to be established by the City to determine sewer usage to allow for billing for those properties that use unmetered well water. Adds administrative complexity for managing custom agreements and enforcement. This approach creates a mechanism for properties to receive both City water and sewer utilities without annexing. Historically, access to these utilities has been tied to annexation, facilitating the growth of the City. Additionally, these properties will remain exempt from City land use, zoning, and code enforcement jurisdiction. 2. Annexation of All Six Properties Under this option, the property owners would need to initiate a voluntary annexation of the six parcels listed in Table 1 and petition the City for approval. As part of annexation, the property owners would enter into a development agreement requiring them to extend the sanitary sewer main west to their properties, in accordance with City specifications and easement requirements, and to install individual service connections at their own expense. In this option, unless all six properties agree to be annexed, it will not be possible to develop a contiguous annexation area including Maple Grove. Advantages: Allows for the removal of non-compliant septic systems with high risk of environmental contamination in the College Creek watershed. Ensures that future re-development of the affected properties will be consistent with City zoning, land use regulation, and development standards. Enables sanitary sewer billing through the City’s existing water utility system for properties served by City or Xenia water. Annexation is consistent with the Ames Plan 2040 vision for growth in this area. 3 Challenges: The existing land uses in the subject area do not fully align with the City’s adopted Future Land Use Map, which envisions higher-density residential along Lincoln Way. Some existing properties may encounter challenges complying with the City's standards (e.g., rental housing regulations). Requires cooperation from multiple property owners to create a voluntary annexation. Commits the City to providing other municipal services (e.g., street maintenance, police, fire). The time necessary to organize the annexation may delay the correction of immediate septic problems. Additional Considerations: With annexation, the City would not automatically assume jurisdictional responsibility for maintenance and repair of W. Lincoln Way between S. 500th Street and X Avenue in Boone County. However, the City would assume responsibility for the Boone and Story County right-of-way adjacent to the annexed area on S. 500th Street. Additionally, the annexed area contains some drainage district infrastructure. The City would become a party to the maintenance of that infrastructure if annexed. 3. Decline the request to provide sanitary sewer service outside the City limits for the subject properties Advantages: The environmental impacts posed by the existing septic infrastructure will continue to be managed by the County Sanitarian and Iowa DNR. City staff time remains reserved for established Council priorities. Challenges: The properties may have to resolve their septic issues in a piece-meal approach rather than at one time in a comprehensive manner. ALTERNATIVES: 1. Direct staff to develop a “rural sewer” service agreement that would allow Maple Grove Mobile Home Park and other nearby properties to connect to the City’s sanitary sewer system without annexation. 2. Require annexation into the City of Ames as a condition of connecting to the sanitary sewer system. 3. Decline the request for sanitary sewer service to Maple Grove Mobile Home Park and maintain the current policy of not extending sewer service outside the City limits. CITY MANAGER'S RECOMMENDED ACTION: Extension of a public sanitary sewer main to serve Maple Grove and adjacent properties appears to be the best path to ensure septic issues do not continue to threaten the quality of water in College Creek. The key question to resolve is whether connection should be made contingent on either: 4 1. Execution of a detailed "Rural Sewer" agreement addressing billing, maintenance, and future annexation conditions; or 2. Annexation of the properties into the City of Ames. Staff believes a Rural Sewer agreement, with future annexation conditions, would be the best approach in this situation. It provides for the affected properties to eventually become part of the City while resolving environmental issues as quickly as possible. The challenge with this approach is the staff time that will be necessary to prepare the agreements for annexation and sewer service. Although this area is within a future growth area, it is not an immediate priority. Therefore, it is the recommendation of the City Manager that the City Council adopt Alternative No. 1, as described above. ATTACHMENT(S): 25-07-08 Maple Grove Sewer Memo.pdf Map - West Ames Sanitary Sewer Connection.pdf N._Flippen_-_Connection_to_COA_Sewer_LIne.pdf 5 Caring People  Quality Programs  Exceptional Service 515.239.5160 main 515.239.5404 fax 515 Clark Ave. Ames, IA 50010 www.CityofAmes.org Public Works - Engineering MEMO To: Mayor and Ames City Council From: Mindy Bryngelson, PE, Municipal Engineer Date: July 8, 2025 Subject: Maple Grove Mobile Home Park – Request for Sanitary Sewer Connection Background: On April 22, 2025, City Council directed staff to prepare a memo regarding a formal request from Horizon Land Management, on behalf of Maple Grove MHC, LLC, to connect the Maple Grove Mobile Home Park (6100 W. Lincoln Way) to the City of Ames sanitary sewer system. This 8.3-acre property lies outside City limits in Boone County but is located within a designated Priority Growth Area under Ames Plan 2040. A history of complaints and investigations by the Iowa DNR has documented ongoing concerns about the mobile home park’s existing septic system, including citations for illicit discharges that pose environmental risks. To comply with Iowa DNR requirements while exploring alternatives, the park currently pumps wastewater from its private collection system and hauls it offsite for treatment. If the system becomes overloaded between pumping intervals, excess sewage would be discharged into a Boone County drainage district tile that empties directly into College Creek. Under current City policy, properties located outside the City limits are not eligible for sanitary sewer service, regardless of their land use designation. The City’s FY 2023/24 Ames Plan 2040 Sanitary Sewer Extension project, now complete, extended a public sanitary sewer main from the west end of Norris Street to approximately 500 feet south of Lincoln Way, along the west edge of the S. 500th Avenue right-of-way (see attached map). This sewer main was constructed to support future annexation and development contemplated by Ames Plan 2040. The main lies entirely outside the current City limits, within Story and Boone Counties. During and after construction of the sewer main, staff received inquiries from the Iowa DNR and three nearby property owners located outside the City limits (including Maple Grove) regarding abandoning their existing septic systems and connecting to the new public sewer. These properties are identified in Table 1, below. Sewer flowline elevations have been reviewed and can adequately serve this area with the City's new sanitary sewer main. 6 Page 2 of 5 Within City limits, sanitary sewer charges are based on metered water usage and are billed monthly through the customer’s water bill. For properties outside the City that are not served by City water, an alternative method of determining usage would be required. This could involve coordination with Xenia Rural Water, the area’s primary rural water provider, or the establishment of a standard usage assumption for properties on private wells. Either approach would require creation of a new “rural” sewer rate, similar to the rural water rate outlined in Municipal Code Section 28.201(5). Although the City has not historically provided sewer service outside of the corporate limits, there are a few examples of the City providing water service outside of Ames. There are eight properties located outside the City limits where the City has agreed to provide water service, either because the rural water provider was unable to do so or because the City intended to eventually annex into that area. These customers paid for the costs of extending the water infrastructure, and their accounts are metered and billed at a higher rate than those within the corporate limits. However, none of these out-of-city properties are connected to the City’s sanitary sewer system and, therefore, do not pay sewer charges. 5820 Lincoln Way is one of the properties outside of Ames that receives water and is now requesting to connect to the City's sewer service. Area Properties: Table 1 reflects the properties that have been identified as likely beneficiaries of a public sanitary sewer connection in this area. Among these, the properties marked with an asterisk are those that have inquired with staff about a connection. Table 1. Property Address Owner Acres % of Total Area Water Source 5820 Lincoln Way * LDR Iowa I LLC 12.38 47.3% City of Ames 5910 W Lincoln Way * West End Apartment L C 3.55 13.6% Xenia 6008 W Lincoln Way Watkins, Graham 1.14 4.4% Well 6014 W Lincoln Way Sporrer, Jeff & Stacey 0.38 1.4% Xenia 6018 W Lincoln Way Joan Pfeffer 0.42 1.6% Xenia 6100 W Lincoln Way* Maple Grove MHC LLC 8.30 31.7% Xenia Total - 26.17 100.0% - * Properties inquiring about sanitary sewer service connection to the city’s system. Options: The City Council is not obligated to authorize the extension of sanitary sewer service to properties outside city limits. However, Council may determine that there is a benefit to considering the request. Three options are available. Option 1: Annexation of All Six Properties Under this option, the property owners would initiate annexation of the six parcels listed in Table 1 and petition the City for approval. As part of annexation, the property owners would enter into a development agreement requiring them to extend the sanitary sewer 7 Page 3 of 5 main west to their properties, in accordance with City specifications and easement requirements, and to install individual service connections at their own expense. In this option, unless all six properties agree to be annexed, it will not be possible to develop a contiguous annexation area including Maple Grove. Advantages: · Removes non-compliant septic systems with high risk of environmental contamination in the College Creek watershed. · Ensures that future re-development of the affected properties will be consistent with City zoning, land use regulation, and development standards. · Enables sanitary sewer billing through the City’s existing water utility system for properties served by City or Xenia water. · Annexation is consistent with the Ames Plan 2040 vision for growth in this area. Challenges: · The existing land uses in the subject area do not fully align with the City’s adopted Future Land Use Map, which envisions higher-density residential along Lincoln Way. · Some existing properties may encounter challenges complying with the City's standards (e.g., rental housing regulations). · Requires cooperation from multiple property owners to create a voluntary annexation. · Commits the City to providing other municipal services (e.g., street maintenance, police, fire). · The time necessary to organize the annexation may delay the correction of immediate septic problems. Additional Consideration: With annexation, the City would not automatically assume jurisdictional responsibility for maintenance and repair of W. Lincoln Way between S. 500th Street and X Avenue in Boone County. However, the City would assume responsibility for the Boone and Story County right-of-way adjacent to the annexed area on S. 500th Street. Additionally, the annexed area contains some drainage district infrastructure. The City would become a party to the maintenance of that infrastructure if annexed. Option 2: “Rural Sewer” Service Agreement This option would allow sanitary sewer service to be provided without annexation. Maple Grove Mobile Home Park would still be responsible for extending the public sewer main to its property and constructing a service connection per City standards. A formal agreement would be required with each participating property owner. Such agreements would include: 1) Conditions addressing future annexation timing, 2) use restrictions, 3) modification limitations without City consent, and 4) rates for a new "rural sewer" service class. Advantages: · Removes non-compliant septic systems from the College Creek watershed. · Allows for faster implementation compared to annexation, particularly for Maple Grove, which faces urgent environmental compliance issues. 8 Page 4 of 5 · May be more acceptable to property owners not ready or willing to annex at this time but would establish annexation agreements for the future. · Limits City obligations strictly to sanitary sewer (and excludes intersection improvements, road maintenance, police, fire, etc.). Challenges: · A method would need to be established by the City to determine sewer usage to allow for billing for those properties that use unmetered well water. · Adds administrative complexity for managing custom agreements and enforcement. · This approach creates a mechanism for properties to receive both City water and sewer utilities without annexing. Historically, access to these utilities has been tied to annexation, facilitating the growth of the City. Additionally, these properties will remain exempt from City land use, zoning, and code enforcement jurisdiction Option 3: Decline the request to provide sanitary sewer service outside the City limits for the subject properties Advantages: · The environmental impacts posed by the existing septic infrastructure will continue to be managed by the County Sanitarian and Iowa DNR. · City staff time remains reserved for established Council priorities. Challenges: · The properties may have to resolve their septic issues in a piece-meal approach rather than at one time in a comprehensive manner. Staff Comments: While drought conditions in recent years have complicated water quality testing, sampling at College Creek near Wilder Boulevard has consistently shown elevated levels of E. coli bacteria. Prairie Rivers of Iowa, the City’s water quality consultant, attributes these levels in part to failing septic systems and lagoon overflows discharging into the Boone County Drainage District 93B and Story County Drainage District 4 tile, which empty directly into College Creek. However, more testing may be necessary to identify the specific cause. Extension of a public sanitary sewer main to serve Maple Grove and adjacent properties appears to be the best path to ensure septic issues do not continue to threaten the quality of water in College Creek. The key question to resolve is whether connection should be made contingent on either: 1. Annexation of the properties into the City of Ames; or 2. Execution of a detailed "Rural Sewer" agreement addressing billing, maintenance, and future annexation conditions. Staff believes a Rural Sewer agreement, with future annexation conditions, would be the best approach in this situation. It provides for the affected properties to eventually become part of the City while resolving environmental issues as quickly as possible. The challenge with this approach is the staff time that will 9 Page 5 of 5 be necessary to prepare the agreements for annexation and sewer service. Although this area is within a future growth area, it is not an immediate priority. Attachments: Map - West Ames Sanitary Sewer Connection.pdf N. Flippen – Connection to COA Sewer Line.pdf 10 M© City of Ames, Iowa makes no warranties, expressed or implied, including without limitation, any warranties of merchantability or fitness for a particular purpose. In no event shall the City of Ames be liable for lost profits or any consequential or incidental damages caused by the use of this map. 1:4,514 ArcGIS Web Map NEW 15" S A N I T A R Y S E W E R MAPLE GROVE MOBILE HOME PARK ADDITIONAL PROPERTIES WHO HAVE INQUIRED ABOUT CONNECTION TO THE CITY'S SANITARY SEWER ADDITIONAL PROPERTIES WHO MAY BENEFIT FROM SANITARY SEWER CONNECTION 550859106008 6014 6018 6100 CITY OF AMES WATER XENIA WATER WELL WATER 5820 AMES CORPORATE LIMITS DRAINAGE DISTRICT TILE 11 1 Hall, Renee From:Nichole Flippen <nflippen@horizonlandco.com> Sent:Wednesday, April 16, 2025 3:18 PM To:City Council and Mayor Cc:Kate Costello; Sara Strenk; David Hoyle; Tammy Joseph; Emmet Conneely Subject:PROPOSED CONNECTION TO CITY OF AMES PUBLIC SEWER LINE EXTENSION - 6100 W. LINCOLN WAY, AMES, IA 50014 Attachments:CES-PP2501 Maple Grove MHP Preliminary Sanitary Sewer Plan 3-17-2025.pdf; Maple Grove MHC_WW LTR_02-25-25.pdf; REQUEST FOR SEWER CONNECTION (MAPLE GROVE)(04-2025).pdf [External Email] Good aŌernoon Mayor Haila & Council Members: Please see the aƩached correspondence requesƟng submiƩed on behalf of Maple Grove MHC, LLC. Should you have any quesƟons or concerns regarding this correspondence, please feel free to contact me directly. Nichole D. Flippen, Esq. General Counsel Horizon Land Co., LLC 2151 Priest Bridge Drive, Suite 7 Crofton, MD 21114 Ofϐice: (410)721-3374 x23 || Fax: (443)332-0055 nϐlippen@horizonlandco.com || www.horizonlandco.com 12 Nichole D. Flippen General Counsel nflippen@horizonlandco.com Horizon Land Management, LLC 2151 Priest Bridge Drive, Suite 7 Crofton, MD 21114 Direct: (410)721.3374 ext. 23 April 16, 2025 VIA E-MAIL ONLY TO: mayorcouncil@amescitycouncil.org RE: PROPOSED CONNECTION TO CITY OF AMES PUBLIC SEWER LINE EXTENSION 6100 W. LINCOLN WAY, AMES, IA 50014 Dear Mayor Haila & Council Members: Horizon Land Management, LLC serves as the management agent for an 8.3 acre parcel located at 6100 W. Lincoln Way, Ames, IA 50014, which is commonly known as the Maple Grove Mobile Home Park (“Park”). The Park, which is just beyond the City of Ames’s (“City”) limits, operates on a private wastewater treatment system (“System”), but with the expansion of the City’s public sewer line, the Park’s owner, Maple Grove MHC, LLC (“Maple Grove”), would like to look into alternative options, including the potential to connect to the City’s public sewer system. As you may be aware, the Park’s System, which serves fifty-nine (59) mobile home lots, has suffered significant wastewater treatment issues since 2014. The System was rehabilitated after a 2018 notice from the Iowa Department of Natural Resources (“IDNR”), but in 2021 the System was found to be inadequate in treatment capacity; therefore, a new treatment facility was designed in 2023 which, due to enlargement of the System beyond its existing location, required waivers from the owners of two nearby properties. Notwithstanding several attempts to contact these owners to obtain the requisite waivers to enlarge the System, our efforts have been unsuccessful. So, our ability to move forward with the enlargement of the Park’s System has been in a holding pattern. Based on current development plans, it appears that the City is in the process of extending its public sanitary sewer collection system (“Public Sewer Line Extension”) to an area near the Park. It is our understanding that the Public Sewer Line Extension will cross S. 500th Avenue (Y Ave.) and will then head north in the west right-of-way (“ROW”) of 500th Ave. This extension will create an opportunity for the Park to connect to the Public Sewer Line, which would eliminate the need for the Park’s System to be enlarged, provide for more efficient wastewater treatment and resolve the concerns raised by IDNR. In fact, a letter from Brenda L. Smith of the IDNR to Mindy Bryngelson of the City of Ames specifically noted that “The IDNR fully supports the City of 13 Nichole D. Flippen General Counsel nflippen@horizonlandco.com Horizon Land Management, LLC 2151 Priest Bridge Drive, Suite 7 Crofton, MD 21114 Direct: (410)721.3374 ext. 23 Ames providing wastewater collection and conveyance of wastewater from the Maple Grove MHP to the City’s publicly owned treatment works.” As such, we feel that this solution would be beneficial to all. While the current plans for the Public Sewer Line Extension would be near the Park, it would not extend far enough north to allow sensible connection and extension to the Park itself; therefore, modifications to the existing Public Sewer Line Extension plans would be required. Specifically, the proposed Public Sewer Line Extension would need to be modified (i) to extended 92’ further north along the west ROW and (ii) to install a manhole at that location. This slight modification would only add 80’ of sanitary sewer, since there is a 12’ stub being proposed north of the manhole; and the relocation of the manhole would not cause the plan to exceed the maximum manhole spacing requirement of 400 feet. For ease of reference, I have attached a plan showing the desired extension of the sanitary sewer to the Park. Per discussions with our engineer, reasons and benefits for the relocation of the proposed manhole and additional 92’ of sewer include the following:  Sanitary sewer is designed to minimize the total number of manholes to reduce infiltration and inflow of stormwater and ground water into the treatment system, thereby reducing treatment costs.  The proposed design modification for the sewer manhole placement would allow a connection and extension to run parallel and 15’ south of the south line of the properties lying west of 500th Ave.  If the manhole were not relocated, the connection would run diagonally across the undeveloped property lying to the south, which would reduce the development potential. Design relocation of the proposed manhole would allow said vacant property to be developed economically and productively. Considering the foregoing, we are curious to know whether the City would consider permitting the Park to connect to the City’s sewer lines by agreement. If the City of Ames is willing to make this modification to its Public Sewer Line Extension plans to benefit the Park, Maple Grove would be willing to pay for all costs associated with the proposed design modification and installation of the additional sanitary sewer main, as a sign of good faith and Maple Grove’s appreciation for the City’s accommodation. 14 Nichole D. Flippen General Counsel nflippen@horizonlandco.com Horizon Land Management, LLC 2151 Priest Bridge Drive, Suite 7 Crofton, MD 21114 Direct: (410)721.3374 ext. 23 Might the City be willing to consider this accommodation? If so, please contact me at your earliest convenience. I may be reached by telephone at (410)721-3374 ext. 23 or via e-mail to nflippen@horizonlandco.com. On behalf of Maple Grove, we appreciate your time and consideration and look forward to your prompt response. Best regards, Nichole D. Flippen General Counsel Enclosure Cc: Kate Costello Sara Strenk David Hoyle Tammy Joseph Emmett Conneely 15 FIELD OFFICE 5, 6200 PARK AVE STE 200, DES MOINES IA 50321 Phone: 515-725-0268 www.IowaDNR.gov Fax: 515-725-8201 Sent Via Electronic Mail Receipt Confirmation Requested February 25, 2025 MINDY BRYNGELSON CITY OF AMES 515 CLARK AVE. AMES IA 50010 mindy.bryngelson@cityofames.org SUBJECT: Maple Grove MHC LLC The Iowa DNR fully supports the City of Ames providing wastewater collection and conveyance of wastewater from the Maple Grove MHP to the City’s publicly owned treatment works. Providing such a connection and service is expected to alleviate the wastewater treatment disposal challenges experienced at the mobile home park. A history of complaints and investigations by the Iowa DNR demonstrates ongoing concerns about the wastewater facility. The existing wastewater treatment system at Maple Grove MHP has endured persistent problems, including hydraulic overloading and mound failures (2011/2014/2018). These failures led to the necessity of pumping and hauling wastewater offsite, which is not a sustainable long- term solution. The system is designed as a non-discharging system, but there have been instances of illicit discharges, posing environmental risks. The most recent operational concerns were detailed in the last two inspection reports for the Maple Grove MHC. In 2017, the site maintenance manager was reported to be unsure of the wastewater flow direction and endpoint. The same inspection noted a lack of familiarity with the operation and maintenance of the pumps and flow meter. A 2012 inspection noted that the telemetry system for remote monitoring was not functional, hindering timely detection of problems. These operational issues raise concerns about the consistent and effective management of the wastewater treatment process. In late 2023, Maple Grove MHC did attempt to address the Iowa DNR’s concerns by requesting approval to remove the old mounds and construct new mounds. However, due to separation distance requirements they were required to obtain waivers of separation from the two commercial building owner(s) and file with the county recorder. Maple Grove MHC has been unable to obtain these waivers which has put their project at a standstill. As the City of Ames is well aware of the Iowa DNR’s role ensuring environmental and regulatory compliance, it’s important to raise awareness of the facility’s past illicit discharges and the risk of continued environmental contamination they pose. Connecting to the City's wastewater collection system would eliminate the potential for such incidents, ensure regulatory compliance, and provide a reliable, long-term solution for wastewater treatment at Maple Grove MHC. It would also eliminate the need for the mobile home park to manage and maintain its own complex wastewater treatment system, assist in the reduction or elimination of potential environmental hazards related to the current system, and protect human health by providing consistent and reliable wastewater treatment. 16 FIELD OFFICE 5, 6200 PARK AVE STE 200, DES MOINES IA 50321 Phone: 515-725-0268 www.IowaDNR.gov Fax: 515-725-8201 I’m confident that the City of Ames will continue to be an invaluable asset to its residents and partner in environmental stewardship. If the City has any questions or would like to discuss this matter further, please feel free to give me a call at 515-250-4094 or you can email me directly at brenda.smith@dnr.iowa.gov . Sincerely, Brenda Smith, Environmental Specialist Field Services and Compliance Bureau Field Office# 5, 515-725-0628 c: Emmett Conneely, econneely@horizonlm.com Brenda L. Smith Digitally signed by Brenda L. 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