Appendix A is bound in this document at the pages listed above. Appendices B to G are existing documents in the program record and are referenced rather than reproduced, so that this report stays at a length a Commission member will read.

On 26 May 2026 the Florida Department of Environmental Protection confirmed in writing that all eight items due within thirty days under its Stipulated Penalty Assessment of 21 April 2026 were complete. The administrative penalty of $62,852.92 had already been paid and receipt confirmed on the coordination call of 11 May 2026. That correspondence marks the end of the corrective action phase that had run since the Consent Order was executed on 12 August 2025.

This is a real achievement and it should be recorded as one. In roughly five weeks the department answered eight open items, filed eight supporting appendices, and closed a penalty assessment. Very few departments of this size move that quickly under that kind of pressure.

Closing the corrective actions did not reduce the work. It changed its nature. The eleven Standard Operating Procedures the City submitted to the Department commit the department to 135 recurring actionable items. Together with the two progress reporting obligations in the Consent Order, that is 658 separate actions in the first 180 day operating period and 1,326 in a full year, or about twenty six every week. The department currently fields a fraction of the staff that volume implies.

This plan does not ask the City to do more than it agreed to do. It sets out what the City already agreed to, counts it honestly, and identifies where continuity of service is at risk.

1. One compliance item remains open. The erosion and sedimentation control ordinance under paragraph 6(c) viii was due 1 August 2026. It is the last item standing between the City and a formal closure letter from the Department.
2. Four asset counts are unsettled and they gate everything. The City documents state outfalls as zero, four or five, and storm drain inlets as 403, 450 or 773. Until those are fixed the field workload cannot be sized, staffed or budgeted with confidence.
3. Two reporting obligations have never been filed. The bi-monthly report under paragraph 6(e) and the quarterly report under paragraph 7. The Department has not assessed a penalty against either, but both remain owed and both are the first thing a reviewer looks for.
4. The workforce position is the central risk. A single position carries most of the program. If that person leaves, the record stops. This is addressed at Appendix A.
5. A funded pathway exists and is time limited. A phased Drinking Water State Revolving Fund program of approximately $17.2 million has been identified, of which roughly $8.43 million is potentially forgivable. The City qualifies on disadvantaged community criteria.

The plan makes three recommendations, in descending order of urgency and ascending order of cost.

Lenders and grant reviewers ask a single question before they ask anything else: is this project part of a plan. A city that answers yes is funded on the strength of the plan. A city that answers no is asked to justify each request from first principles, every time, and is usually funded last.

The City currently has an executed Consent Order, a scored funding application and eleven procedures. What it does not have is the document that connects them, prices them across five years and shows the revenue that carries the debt service. That document is the difference between reacting to regulators and programming the work.

Compliance programs do not usually fail because someone made a wrong decision. They fail because a person left, a report was not sent, a calendar entry was never made, and eight months later a letter arrives. That is precisely the sequence this City experienced between October 2025 and April 2026.

Appendix A sets out the current organization as far as it can be reconstructed from the record, a proposed organization, and the training and succession arrangements that would allow the program to survive the loss of any single person.

It reaches beyond Public Works. The obligations in the order and the permit touch the Building Department for permit and construction data, the City Attorney for the ordinance, Finance for the funding applications and the rate position, Information Technology for the systems that hold the record, and the Office of the City Manager for the reporting the Department receives. This plan is addressed to the Public Works and Utilities Department because that is where the obligation sits, but it cannot be delivered there alone.

Most municipal strategic plans take six to nine months and cover every function of a department. This one was produced in weeks and covers one thing. That was a deliberate choice made with the Director.

The reason is the clock. The City is operating under an executed Consent Order with enumerated obligations, fixed dates and stipulated penalties. A plan that arrives after those dates have passed is an academic exercise. The department needed a working instrument, not a study.

This plan does not cover the sanitary sewer consent order with Miami-Dade DERM, the water treatment and distribution capital program beyond lead service lines, solid waste, roads outside the stormwater context, or the department's general administration. Each of those deserves its own plan. Folding them in here would have delayed a document the City needed immediately.

It also does not restate the Consent Order. The order is attached at Appendix D and it speaks for itself. This plan is about what the City has to do next.

It is written for the Director of Public Works and Utilities, to be carried into the City Manager's office and the Assistant City Manager's office. It is written in plain language so that a reader who is not an engineer can follow the argument and act on it.

This plan did not begin with a document review. It began with the Director and the department in a room, two blank whiteboards, and one question: why are we here.

The first board captured the diagnosis. Everything the department knew was wrong, written down in no particular order and then connected. The second board captured the response. Both are reproduced below as they were drawn, with nothing added and nothing removed.

Starting from the department's own words rather than a consultant template produced two things a template would have missed. First, the single word the department kept returning to was documentation, not funding and not staffing. Second, the response the department reached on its own was a process, not a request. Access the data, analyze it, transmit it. That is a workflow the City can own.

The Department has said a formal closure letter will follow once the remaining item is complete. That letter is worth having. It is the document the City can put in front of the Commission, a lender or a grant reviewer.

The strengths are real and recent. A department that closes eight regulatory items in five weeks is a department that can execute when it is pointed at something specific.

The weaknesses share one root. They are all about the record rather than the work. The City is doing more than it can currently prove, and proof is what the Consent Order asks for.

The single most important line in this figure is in the threats quadrant: loss of the position that holds the program. Every other threat has a mitigation that money or time can buy. That one does not.

It counts actions the City has already committed to in writing. It is not an estimate of effort produced by a consultant and it does not assume any new program.

It is also a floor rather than a ceiling. Four asset counts remain unsettled. Quarterly outfall inspections resolve to zero, sixteen or twenty a year depending on which City document is correct. Semi-annual inlet surveys resolve to 806, 900 or 1,546. Settling four numbers converts this from a range into a figure the City can budget against.

The pattern is consistent. The department has written good procedure. What it lacks is the capacity and the continuity to run that procedure through a shock without the record stopping.

A Consent Order sets out the minimum a City must do to return to compliance. It does not describe a functioning program. The twelve projects below are what the department needs to satisfy the intent of the order and to stay satisfied once the order closes.

Each project is tied to an obligation, given a category and placed in sequence. Nothing here is speculative and nothing here is outside the scope of the order or the permit.

Seven of the twelve are already in progress in some form. The value of listing them together is not novelty. It is that a Commission or a lender can see one program rather than twelve unrelated requests.

The order lists documents. Read as a whole it asks for something larger: a City that can inspect what it owns, record what it inspects, report what it records, and fund what the record shows it needs.

Projects P-01 through P-05 make the City compliant. Projects P-06 through P-10 make it capable. Projects P-11 and P-12 make it fundable. A department that completes only the first group will be back in front of the regulator when the next permit cycle begins.

Shovel ready is not a description of intent. It is a description of paperwork. A project is shovel ready when the scope is defined, the design is sufficiently advanced, the cost is defensible and the authorising resolution is in place. Until then it cannot be funded no matter how urgent it is.

The lead service line program is the closest the City has to shovel ready. The Request for Inclusion was signed on 15 May 2025 and scored in the highest acute public health risk category. The planning and design loan converts that into design, and design is what construction money attaches to.

Both routes benefit from the same preparation the rest of this plan calls for. A County letter of support and a WIFIA letter of interest both ask what the City has, what it plans and what it can repay, and all three of those answers come from the work in Sections 5 to 9.

Everything in this plan points at the same conclusion. The department is managing a five year problem with one year instruments. A five year master plan is the instrument that matches the problem.

At present each request is judged on its own merits and against every other request the City makes. With a master plan in place the question changes from whether this particular project is worth funding to whether the City is executing a plan it has already published. That is a materially easier question for a reviewer to answer yes to.

It also protects the department internally. A project inside an adopted plan is difficult to defer without an explicit decision to depart from the plan. A project outside one is deferred without a decision being recorded.

The Consent Order runs to 2030 for the structural control obligations. The lead service line program runs to 2036. Neither fits inside an annual budget cycle. A five year plan is the shortest horizon that can hold both, and it is the horizon the funding agencies work to.

Two entries on this table are shown as owed rather than late. The Department did not cite the progress reports in its April assessment, so no penalty has been assessed against them. They remain obligations under the order and they are the first thing a reviewer looks for.

A standing reporting cadence with a named owner. Not a new system and not a new position. A calendar entry, a template, and one person accountable for pressing send. Every date in the table above is protected by that single discipline, and the absence of it is what produced the April assessment.

Stipulated penalties under paragraph 10 run at $200 per day and are demandable at any time after a requirement is missed. That is $6,000 a month and $73,000 a year. Paragraph 17 allows judicial penalties of up to $15,000 per day per violation. Paragraph 14 waives the Department's right to pursue pre-order violations only for as long as the City remains in complete compliance.

The first three actions in the table above cost nothing and remove most of that exposure. That is an unusual position to be in and it will not last indefinitely.

1. Confirm the ordinance is adopted. Paragraph 6(c) viii. It was due 1 August 2026 and it is the only item standing between the City and a formal closure letter from the Department. If it has been adopted, the confirmation needs to reach FDEP. If it has not, it needs a date.
2. Establish the reporting cadence. Bi-monthly and quarterly, on a calendar, with one named person accountable. This is the discipline whose absence produced the April assessment.
3. Settle the four asset counts. Outfalls, storm drain inlets, structural controls and typical active construction sites. Four numbers that make every other figure in this plan exact.
4. File the planning and design loan. The scope is written and the project is scored. This is the nearest available money and the window moves on a federal cycle.
5. Close the three procedural gaps. One certified procedure does not exist, one is referenced by five others and is missing, and the structural control procedure sits outside the submitted set.
6. Document how the work continues without the person doing it. Written procedure, a training record and a delivery model that survives a resignation.

Five of the six actions above are already in progress in some form. The department has procedures written, an application scoped, and a regulator relationship that is working. What is at risk is not the starting of this work. It is the continuing of it.

Compliance programs do not usually fail because someone made a wrong decision. They fail because a person left, a report was not sent, a calendar entry was never made, and eight months later a letter arrives. That is precisely the sequence this City experienced between October 2025 and April 2026, and it is the sequence this plan is designed to prevent from repeating.

The department can answer any question a regulator asks from a system rather than from memory. The capital program is funded from a plan rather than from crisis. Lead service lines are being replaced on a schedule that finishes ahead of the federal deadline. Structural controls have a complete inventory and an inspection record. And the program continues when any individual leaves.

None of that requires a new department. It requires the six actions in Section 10, taken in the next ninety days, and then sustained.

The City of Opa-locka has been described in its regulatory correspondence in terms of what it has failed to submit. That is a fair description of the file and an unfair description of the department. In the five weeks between 21 April and 26 May 2026 this department closed eight regulatory items and a penalty assessment. The capability is present. What has been missing is the connective work between the capability and the record, and that is a solvable problem.

Prepared at the direction of the Assistant City Manager. Submitted to the Office of the City Manager for review. Signature indicates receipt and acknowledgment of the findings, not approval of any expenditure.

The single largest threat identified in Section 4 is the loss of the position that carries the compliance program. This appendix sets out why that risk exists structurally, and what structure would remove it.

The Consent Order requires training under Permit Parts III.A.7.c, III.A.7.d and III.A.9.c. The department currently satisfies this through occasional sessions. That meets the letter of the requirement and does very little for continuity.

The training obligation is currently the weakest link in the procedure set. One procedure that five others depend on for their training frequency is not present in the submitted set at all.

The structure in Figure 9 should be judged against one question. If the person who currently holds the compliance program resigned tomorrow, how long before the Department noticed. Under the current structure the honest answer is one reporting cycle, which is sixty days. Under the proposed structure it is no time at all, because the record continues without them.