HomeMy WebLinkAboutDocumentation_Miscellaneous_Tab 4_4/26/1994 rsh. VILLAGE OF TEQUESTA
DEPARTMENT OF COMMUNITY DEVELOPMENT
- ft;• Post Office Box 3273 • 357 Tequesta Drive
;
�'�� , I Tcquesta,Florida 33469-0273 • (407) 575-6220
sa; ,,° Fax: (407) 575-6203
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MEMORANDUM :
TO: Thomas G. Bradford, Village. Manager
FROM: Scott D. Ladd, Building Official
DATE: April 21, 1994
SUBJECT: Current Status Regarding Condition of Eastwinds. Circle
Concrete Roadway.
Tom, please find attached the following documents pertaining to the
above referenced subject:
1. Status report/Chronological record dated September 7, 1993.
2. Letter from W. Richard Staudinger, P. E. to Gary Preston dated
September 7, 1993.
3. Letter from the Village Manager to the Village Attorney dated
September 13, 1993.
4. Letter from the Village Attorney to Scott Ladd dated January 25,
1994. •
5. Letter from the Village Attorney to Scott Ladd dated March 15,
1994.
6. Letter from the Village Attorney to H. David Kelley, Jr. , P. E.
dated march 15. 1994.
The matter is currently in the hands of the Village Attorney who is
researching and examining this issue and who will eventually give us a
recommendation on how to proceed to address the failing concrete
roadway.
Recycled Paper
VILLAGE OF TEQUESTA FILE COPY
DEPARTMENT OF COMMUNITY DEVELOPMENT
t '11 ' Post.(IIIice Box 1271 • 357 Tequesta Drive
y + Tequesta. Florida 334(9.0273 • (407) 575-6220
s Fax. (407, 575-620.;
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CH row.,
MEMORANDUM :
•
TO: Thomas G. Bradford, Villaae Manager
,
FROM: Scott D. Ladd, Building Official /"/�04
DATE: September 7, 1993
SUBJECT: Status Report Regarding Condition of Eastwinds Circle
Concrete Roadway.
Tom, as you are aware, the concrete roadway at Eastwinds Circle has
been deteriorating for some time now. Per your request, I have
researched the' Eastwinds Landing Subdivision files in order to set
forth a chronological record of certain events concerning the
approval, permitting, inspection and final acceptance of the
infrastructure at Eastwinds Landing.
Chronological Record:
1. September, October & November, 1988: Review of proposed design
plans and record plat by one of the Village' s Consulting
Engineers, H. David Kelley, Jr. , P. E. , P. L. S. , of Executive
Management & Engineering Consultants, Inc. ( Developers Engineer
of Record was Peter Aquart, P. E. , of Lindahl, Browning, Ferrari &
Hellstrom, Inc. , of Jupiter, FL) .
See' Exhibits "A", "B" & "C".
2. December 20, 1988: Village Council grants approval of the
preliminary and final plat for Eastwinds Landing.
See Exhibit "D".
•
3. February 14, 1989: Developers engineers submit engineered
drawings for a concrete paving alternate for Eastwinds Circle.
See Exhibit "E".
4. February 17, 1989: Building Department sends the engineered
drawings for the concrete paving . alternate to H. David Kelley,
P. E. , P. L. S. , for review on behalf of the Village.
See Exhibit "F".
5. March 6, 1989: H. David Kelley, P. E. , P. L. S. , sends results of
his review of the concrete paving alternate to Scott D. Ladd,
Building Official, identifying three areas of concern, including a
concern regarding the design criteria for the concrete roadway.
See Exhibit "G".
•
•
•
Rec'cled Paper
6. March 27, 1989: Response letter from Peter Aquart, F. E. ,
Developers Engineer of Record, wherein Mr. Aquart disagrees with
Mr. Kelley' s concern regarding the design for the proposed
concrete roadway.
See Exhibit "H".
NOTE: The proposed concrete roadway design met the "minimum" FDOT
specs as called for by the Village. Mr. Kelley offered what now
appears to be • an appropriate upgrading for ' the design of the
concrete roadway but the Engineer of Record . stoo.d by his minimum
FDOT design. The suggested upgrading by Mr. Kelley was a .
recommendation and not mandatory or binding upon the Engineer of
Record. In retrospect, it may well be that this difference of
opinion with regard to the concrete paving design was the starting
point of what ultimately followed with the deterioration of the
concrete roadway.
7. May 10, 1989: Approval letter from Paul F. Brienza, P. E. ,
Director of Engineering Services, Loxahatchee River Environmental
Control District ( ENCON) , approving the design of the sanitary •
sewer system under the proposed concrete roadway at Eastwinds
Landing.
See Exhibit "I". •
8. June 14, 1989: Permit issued to Dickerson Florida, Inc. for the
installation of the concrete road and the underground utilities.
See Exhibit "J".
9. July 10 - September 7, 1989: . Building Department files indicate
that a field representative of the Engineer of Record' s firm
performed 15 field inspections at Eastwinds Landing while the
underground utilities were being installed.
10. January 9, 1990: A letter of transmittal to Building Inspector
George Silvers from Mary C. Dwan of Lindahl, Browning, Ferrari &
Hellstrom, Inc. , included five concrete pavement test reports.
See Exhibit "K".
•
•
11. May 25, 1990: Letter from Peter Aquart, P. E. , Engineer of Record,
certifying that the paving, grading, drainage, water distribution
and sewer collection system have been completed in substantial
compliance with the approved plans and specs for Eastwinds
Landing.
See Exhibit "L".
12. June 25, 1990: Interoffice memo from Don Zimmerman to Richard
Staudinger, P. E. , of Gee & Jenson, indicating that a semi-final
review ( field inspection) has been..perf ormed at Eastwinds Landing
and listing 14 discrepancies that needed to be corrected.
See Exhibit "M".
•
NOTE: Gee & Jenson was requested by the Village to perform the
semi-final and final reviews . for compliance with Village
requirements as H. David Kelley, •P. E. , P. L. S. , had moved to
California due to his father becoming seriously ill.
- 2 -
13. June 26, 1990: Memo from Steven A. Kennedy, Deputy Building •
Official , to Scott D. Ladd, Building Official , indicating an
amended list of discrepancies as a result of the semi-final
inspection performed June 21, 1990. Mr. Kennedy' s list is
slightly different from Don Zimmerman' s because they looked for
different items for compliance.
See Exhibit "N".
14. July 9, 1990: Received a letter from Mary C. Dwan of Lindahl ,
Browning. Ferrari - & Hellstrom, Inc. , acknowledging the results of
the June 9, 1990 semi-final inspection and indicating that
compliance with the list of discrepancies would be forthcoming.
See Exhibit "0".
15. August 7, 1990: Letter to the Developer of Eastwinds Landing from
Scott D. Ladd asking for payment of the invoice from Gee & Jenson
for their semi-final review.
See Exhibit "P".
16. August 24, 1990: Letter to Steven Kennedy, Deputy Building
Official, from Richard Staudinger, P. E. , of Gee & Jenson,
indicating that a final field inspection was conducted at
Eastwinds Landing and that all items from the semi-final
discrepancy list dated June 21. 1990 were reviewed. This letter
serves as the Village engineers final approval of the protect.
See Exhibit "Q".
17. October 29. . 1990: Letter, from Scott D. Ladd to Developers
representative requesting payment for Gee & Jenson' s invoice for
the final inspection of Eastwinds Landing.
See Exhibit "R".
18. October 31, 1990: Letter to Scott D. Ladd, Building Official.
from Robert A. . Schaeffer. Developers representative, requesting
that the Village of -Tequesta formally accept Eastwinds Landing
Subdivision.
See Exhibit "S".
19. November 2, 1990: Letter from Thomas G. Bradford, Village
Manager. to Robert A. Schaeffer, Developers representative,
accepting the publicly . dedicated road right-of-way within '
Eastwinds Landing known as Eastwinds Circle.
See Exhibit "T".
20. November 21, 1990: First permit issued for the construction of a
single-family dwelling unit in Eastwinds Landing. At this time
the concrete roadway was in satisfactory condition.
21. November 2, 1991: One year warranty on the infrastructure at
Eastwinds Landing Subdivision expires. It seems apparent that due
to a lack of . use the concrete roadway is still in satisfactory
condition, keeping in mind that only one house has been built with
only one family actually living in the Subdivision.
- 3 - •
22. July, 1, 1992: Second permit issued for the construction of a
single-family dwelling unit . A period of 19 months elapses before
the second home receives a building permit in the Subdivision.
23. July. 1, 1992 - August 10, 1993: Seven permits are issued for new
single-family dwelling units within Eastwinds Landing Subdivision
and, most likely due to the daily trafficking of heavy
construction related vehicles and equipment on Eastwinds Landing,
the concrete roadway begins to rapidly deteriorate.
24. March 31, 1993: Meeting at Eastwinds Landing with Richard
Staudinger, P. E. , Gary Preston, Public Works Director and Scott D.
Ladd, Building Official, to inspect the degradation of the
concrete pavement at Eastwinds Circle and to have Mr. Staudinger
report back to Gary Preston on his professional opinion as to what
might be going wrong with the roadway and his recommendations as
to how to properly repair the road. As of this date, Mr.
Staudinger has not responded back to the Village. One of the
suggestions that came out of this field inspection was to ask
ENCON to investigate their sewer system to determine if possible
leakage and/or line breaks in the sewer system might be causing
the concrete road breakup. A subsequent phone call from Paul
Br ienza., P. E. , of ENCON, stated that a thorough investigation of
their sewer system showed no leaks present and no sand entering
the sewer lines thereby concluding that ENCON' s sewer system was
not the cause of the concrete roadway deterioration.
Tom, this brings us up to date on the historical chronology regarding
Eastwinds Landing. If Gary Preston or myself can be of further
assistance with regard to this matter, please let us know. Also, per
your request, we will videotape Eastwinds Landing for use at an
upcoming Public Works Committee meeting.
SDL: 7 mm
Attch. .
cc: Gary Preston
FILE COPY ��,
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Mr. Gary Preston, Director � r1..
Public Works & Recreation .:- ti •a `
Village of Tequesta
357 Tequesta Drive �,�,� ��; _
P.O. Box 3273 'A DT; ) $' M.4r F ,
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Tequesta, FL 33469 *y�}3 �. :,, � ' f .
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Re: Eastwind Landings
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Dear Gary,
This letter is sent as a follow up to several field trips and conversations we have had with Scott
Ladd and yourself concerning the condition of the cracked concrete roads at the Eastwind
Landing subdivision. This is a subdivision which was constructed between 1988 and 1990.
Gee & Jenson did not review the developers design plans nor did they inspect the construction
of the roadways for the Village. The sanitary sewer system is owned and was inspected by
Encon (Loxahatchee River Environmental Control District). Subsequent to the sign off and
certification of the subdivision improvements by the developer's engineer, and a final inspection
of the roadways and drainage, by Gee & Jenson and the Village, Encon found problems with the
sanitary sewer lines and connections to manholes which required the contractor to come in and
do repairs during the one (1)-year warranty period. Subsequent to that there were additional
concerns by Encon. None of the follow up repairs including those during the warranty period
were inspected by the Village or Gee & Jenson.
Earlier this year I contacted, Paul Williams, the inspector at Encon and requested that he verify
whether or not additional problems are occurring with the sanitary sewer system at Eastwind
Landings. He indicated that at the present time there appear to be no problems, as no sand or
debris is being picked up in the sanitary sewer lines indicating any leakage. From our field
observation it appears that the primary problems with the roadways cracking at this point is due
to heavy overloading of the subdivision streets by trucks delivering construction equipment
including roof tile, concrete and sod, during the construction of homes. This can be evidenced
by the location of the problems adjacent to homes under construction or recently completed and
the lack of problems in the culdesac area where heavy construction equipment and trucks are not
parked or loaded and unloaded.
•
I will be happy to discuss this matter with you or.with the Public Works Committee, should
additional questions or details be necessary concerning the condition of the roadways in Eastwind
Landings.
Ve t rs,
�Cl
. Ri d St udinger, P.E.
WRS:jer .
93004.40/110
c: Scott Ladd Tom Bradford
(..-7f:�,J'' - VILLAGE OF TEQUESTA FILE COPY
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Sep ember 13 , 1993 � ?
John C. Randolph, Esq.
Jones , Foster, Johnston & Stubbs, P .A.
P .O. Box 3475
West Palm Beach, Florida 33402-3475
RE: Eastwinds Circle; Status Report
Dear Skip:
By now, I am sure you know that the Building Official has been
reviewing the condition of Eastwinds Circle, a concrete road within
the public right-of-way serving the subdivision known as Eastwinds
Landing. After passage of the warranty period and upon the
commencement of home construction, the road began to deteriorate
rapidly. There are severe cracks throughout this roadway. The
Building Official has videotaped the same and can accompany you to
the site for first hand inspection, if needed.
Ultimately, the public is going to look to the Village to repair
this road. Obviously, we do not feel that this road was
constructed or designed to meet Village standards. We need your
advice and guidance as to the appropriate action necessary to
recoup all or a portion of the costs of properly fixing or
rebuilding this road, whichever is appropriate. Mr. Ladd and/or
the applicable consulting engineers can provide you with all the
information that you may need to properly investigate this matter.
Attached is a chronological report prepared by the Building
Official for your review in this matter. Please review the matter
with the Building Official and provide him with the necessary
instructions to properly proceed in this manner. Please keep me
periodically apprised on this issue.
•
FILE
COPY
JONES, FOSTER, JOHNSTON & STUBBS, P. A.
ATTORNEYS AND COUNSELORS
FLAMER CENTER TOWER
505 SOUTH FLAGLER DRIVE
- ELEVENTH FLOOR r.t'•
LARRY B.ALEXANDER JOHN BLAIR McCRACKEN P.O. BOX 3475 , HENRY F.LILIENTHAL
STEPHEN J.AUCAMP SCOTT L.McMULLEN WEST PALM BEACH,FLORIDA 33402-3475 1902-1982
TRACEY BIAGIOTTI • JOHN C.RANDOLPH JOYCE A.CONWAY JOHN C.RAU (407) W E50-3000 HARRY ABON JOHNSTON
1895.1983
MARGARET L COOPER ANDREW ROSS FAX:(407)832-1454 �QI
EDWARD DIAZ STEVEN J.ROTHMAN 1.0 R.BRUCE JONES
REBECCA G.DOANE PETER A.SACHS A 1'a 2 1904•19843
CHRISTOPHER S.DUKE 0.CULVER SMITH M 66V
SCOTT G.HAWKINS SIDNEY A.STUBBS.JR. 'VILLAGE'-' o� PAUL C.WOLFE
LAG
THORNTON M.HENRY ALLEN R.TOMLINSON c� 1933-1991
PETERS. .EINFE JOHNS. P.MPER
WALS i-cntESTA RETIRED
MICHAEL B.KLEINFELD MICHAEL P.WAVER WRITER'S DIRECT UNE: >�C1 LJ 1!1 WIUJAM A.FOSTER
T.KRANZ H.ADAMS WEAVER G.
•
•
•
��D V- �E� OF
COUNSEL COU
V L MOR C UNSEL
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January 25, 1994
•
Scott D. Ladd, C.B.O.
Village of Tequesta
Post Office Box 3273
Tequesta, Florida 33469
RE: Village of Tequesta
Eastwinds Circle
Our File No. 13153.1 •
•
Dear Scott:
We have reviewed all of the materials that you and Tom Bradford
have provided us regarding the conditions of the Eastwinds Circle
concrete roadway. As you know, the one year warranty on the
infrastructure at Eastwinds Landing subdivision expired in
November, 1991. At that time the concrete ' roadway appeared to be
in satisfactory condition as only one house had been built with
only one family actually living in the - subdivision. - It was not.
until July 1992 that seven permits were issued for single family
homes within Eastwinds Landing subdivision and the roadway then
began to deteriorate.
Although the one year :warranty on the infrastructure has .expired,:-:.-
the Village may be able to recoup all or a portion of the -cost of
properly fixing or rebuilding the road. The contractor/developer
can be liable to non-privity owners based on negligence and/or
breach of implied warranty. A contractor/developer owes a general
duty to those who could foreseeably. be harmed to use reasonable
care in the performance of the. work. - Further, ,.an .implied warranty._
of fitness and 'merchantabi'lity'_exists independent,:of:' a statute :or ' .
any intention on the part of the;.developer orcontractor to create.
it. The=-implied warranty 'extends to�subistantal compliance`with -
plans and specifications,_ ,,compliance with applicable building,
codas=,=arid=fitness and merchantability. Major:_defects may entitle
the non-privity owner to damages to remedy or repair the defects.
Scott D. Ladd, C.B.O.
January 25, 1994.
Page 2
We note from the materials provided that the developer's design
plan for the roadway was questioned by the Village's consulting
engineer, David Kelley, of Sheremeta Associates, in March 1989
before the road was constructed. The developer's engineer,
Lindahl, Browning, called for 6" - 3,000 .psi unreinforced concrete
pavement. The Village's consulting engineer, David Kelley, _
recommended the use of Class II, 3,400 psi concrete. Mr. Kelley
recommended an upgrade from the "minimum" FDOT specs. The engineer
of record stood by his minimum FDOT design.
In retrospect, it may be that the concrete paving design is the
reason for the deterioration of the roadway. The Village hired Gee
&Jenson to perform the semi-final reviews for compliance with
Village requirements as David Kelley had moved to California. Gee
& Jenson prepared a list of discrepancies as a result of the semi-
final inspection and the final inspection, but none of the items
included the concrete roadway. Ultimately, Gee & Jenson found
everything to be in order.
Richard Staudinger, P.E. , of Gee & Jenson, addressed a memo to Gary
Preston dated September 7, 1993, wherein he concludes that the
primary problem with the roadway's cracking is due to heavy
overloading of the subdivision streets by trucks delivering
construction equipment including roof tile, concrete and sod,
during the construction of homes. Mr. Staudinger said that this is
evidenced by the location of the problems adjacent to homes under
construction or recently completed and the lack of problems in the
cul de sac area where heavy construction equipment and trucks are
not parked, loaded or unloaded. Gee & Jenson points out that they
did not review the developer's design plans, nor did they inspect
construction of the roadways during the construction process. Mr.
Staudinger concludes that the problem with the roadway is not due
to any leakage from the sanitary sewer lines.
In order to provide further advice in regard to how to proceed with
this matter, we need to have more information regarding the
contracts and discussions as related to the design specifications ..
for the roadway. John Trimper from this office will be contacting
you to discuss this matter in more detail.
Sincere ,
C. rRandolph
JCR/ssm
JONES . FOSTER , JOHNSTON & STUBBS . P . A .
2(
FILE COPY P.
JONES, FOSTER, JOHNSTON & STUBBS, P. A.
ATTORNEYS AND COUNSELORS
FLAGLER CENTER TOWER
505 SOUTH FLAGLER DRIVE
ELEVENTH FLOOR T
P.O. BOX 3475 },p l 1 HENRI% LILIENTHAL
'_ARRY B.ALEXANDER JOHN BLAIR MCCRACKEN ' ` 3 •'� , ,17.2 I992
.�
STEPHEN J.AUCAMP SCOTT L.MCMULLEN WEST PALM BEACH,FLORIDA 33402-3475 /. }u ...'..'t-'
•
TRACEY BIAGIOTTI JOHN C.RANDOLPH / HARRY ALLSON JOHNSTON
JOYCE A.CONWAY JOHN C.RAU (407)850-3000 I//
MARGARET L.COOPER ANDREW ROSS FAX (407)832-1454 Iegsl9e3
EDWARD DIAZ STEVEN J.ROTHMAN R.BRUCE JONES
REBECCA G.DOANE •PETER A.SACHS I L' ]a I37d-1see
CHRISTOPHER S.DUKE D.CULVER SMITH III I , `AA. n j LJ a+0 � I
SCOTT G.HAWKINS SIDNEY A.STUBBS,JR. PAULC.WOLFE
THORNTON M.HENRY ALLEN R.TOMLINSON - _ 3-I991
PETER S.HOLTON JOHN S.TRIMPER ` •. .- .. 1�1- TIRED
MARK B.KLEINFELD MICHAEL P.WALSH WRITER'S DIRECT LINE: ^ - WIL A.FOSTER
MICHAEL T.KRANZ H.ADAMS WEAVER _ ''•I J �T�
. -_' 1 F COUNSEL
FT. L. AMIN FLANAGAN
•
March ' 15, 1994
•
Mr. Scott D. Ladd, C.B.O.
Building Official
Village of Tequesta
P.O. Box 3273
Tequesta, Fla. 33469-0273
Re: Eastwinds Circle
Our File No. : 13153.1
Dear Mr. Ladd: .
I apologize for not responding to you in written form sooner
than this. However, please don't take my silence as a sign of
inactivity.
We discussed the fact that I would attempt to locate H. David
Kelley, P.E. , who prepared a design criteria for the concrete
roadway in 1989 on behalf of • the Village. The developer's
engineer, Lindahl, Browning, called for 6" - 3,000 psi unreinforced
concrete pavement. Mr. Kelly recommended an upgrade from the
"minimum" FDO specs and the use of Class II, 3,400 psi. Lindahl,
Browning stood by the minimum DOT design. •
I have been able to locate David Kelley at his current
employment with CCO Consultants in Ft. Lauderdale, Florida. I have
furnished Mr. Kelley with a copy of your status report regarding
the condition of Eastwinds Circle. Once David Kelley has had an
opportunity to review this document, he will get back to me and we
will discuss..-whether or not the specifications are the reason for
the current...problems_w4th the roadway. - f
• " s
Mr. Scott D. Ladd, C.B.O.
March 15, 1994
Page 2
I will keep you apprised of any new development or
information.
Very truly yours,
JONES OSTE , J NSTON
& S ► BB' , P. .
JOHN TRIMPER
JST: lh\ladd.le
JONES , FOSTER . JOHNSTON & STUBBS . P . A .
FILE
• JONES, FOSTER, JOHNSTON & Ttiftivi , P. A. •
ATTORNEYS AND COUNSELORS
FLAGLER CENTER TOWER V"`yr-
505 SOUTH FLAGLER DRIVE
ELEVENTH FLOOR
LARRY B ALE%ANGER JOHN GLAIR MCCRACKCN P.O. BOX 3475 •
;HENRY F.LILIENTHAL
STEPHEN J AUCAMP SCOTT L.McMULLEN WEST PALM BEACH,FLORIDA 33402-3475 '"1 ,1 1902.1982
TRACEY BIAGIOTTI JOHN C.RANDOLPH H RRY ALLISON JOHNSTOH
C FAX
JOYCE A CONWAY JOHN C.RAU (407)859-3000
MARGARET L.COOPER ANDREW ROSS 18951983
:(407)832-1454 -r
EDWARD OIAZ STEVEN J.ROTHMAN - �. � - �c'.'-� R.BRUCE JONES
REBECCA G.DOANE PETER A.SACHS 1904.1988
CHRISTOPHER S.DUKE D CULVER SMITH M
SCOTT G.HAWKINS SIDNEY A.STUBBS,JR. •� PAUL C.WOLFE
THORNTON M.HENRY ALLEN R.TOMLINSON '- ,ff 1933.1991
PETER S.HOLTON JOHN S.TAMPER
MARK B.KLEINFELD MICHAEL P.WALSH WRITER'S DIRECT LINE: RED
wIwAE RETIA.RED
FOSTER
MICHAEL T.KRANZ H.ADAMS WEAVER
OF COUNSEL
L MARTIN FLANAGAN
March 15, 1994
WORK PRODUCT PRIVILEGED
H. David Kelley, Jr. , P.E.
7310 West Lake Drive •
West Palm Beach, Florida 33406-6722
Re: Eastwinds Circle Concrete Roadway
Tequesta, Florida
' Dear Mr. Kelley:
This follows our telephone conversation of last week, wherein
I talked to you regarding the concrete roadway at Eastwinds Circle
in Tequesta, Florida. Back in 1989 the Village of. Tequesta
retained you to prepare a design criteria for the concrete roadway.
I am enclosing a package of documents relative to this matter that
will presumably refresh your recollection regarding your prior
involvement.
. Eastwinds Circle is experiencing significant cracking.
Richard Staudinger, P.E. of Gee and Jensen, has written a memo
dated September 7, 1993, wherein he concludes that the primary
problem with the roadway's cracking is due to heavy overloading of
the streets by trucks delivering construction equipment including
roof tile, concrete and sod. However, the memo does not indicate •
why the construction equipment and vehicles has actually caused an
overloading.
I note with interest that you recommended the use of Class II,
3,400 psi concrete in 1989 before the road was constructed. The
developer's engineer, Lindahl, Browning, called for 6"- - 3,000 psi
unreinforced concrete pavement. The engineer stood by his
recommendation for the minimum FDOT design. In retrospect, it
certainly appears that perhaps the specification is the reason for.
the current deterioration of the roadway.
H. David Kelley, Jr. , P.E.
March 15, 1994
Page 2
The Village of Tequesta has asked me to look at this matter to
determine what rights and responsibilities may apply. It is my
feeling that we should first examine whether the developer's design
criteria is the culprit.
•
Please feel free to contact me so that we can determine where
we can go from here. I look forward to consulting with you on
this matter.
Very truly yours,
JONES, FO TER JOHNSTON
& BBS,
-
S N S. TRIMPER
/
JST:lh\kelley. le
✓
cc: Scott Ladd (privileged work product)
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JONES , FOSTER , JOHNSTON & S T U B B S , P . A .