Item F6
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: February 17,2000
Bulk Item: Yes No X
Division: Growth Management
Department: N/ A
AGENDA ITEM WORDING:
Approval of exemption from the nonresidential Permit Allocation System based on status as a federally tax-exempt
non-profit religious organization.
ITEM BACKGROUND:
The Jenetopulos Group is proposing the construction of a 3,217 square foot church with an open courtyard.
The proposed church will be servicing the needs of current Monroe County residents and will not have any impact
on hurricane evacuation time.
The item was heard at the January 26, 2000 Planning Commission and was passed unanimously on a 5 - 0 vote.
PREVIOUS RELEVANT BOARD ACTION:
None
STAFF RECOMMENDATION:
Approval
TOTAL COST:
N/A
BUDGETED: Yes N/ A
No
.
COST TO COUNTY: N/A
AMOUNT PER MONTH
N/A
PER YEAR N/A
APPROVED BY: County Attorney X
OMB/Purchasing N/ A
Risk Management N/ A
DEP AR TMENT DIRECTOR APPROVAL:
lanning
DIVISION DIRECTOR APPROVAL:
Timoth
DOCUMENTATION: Included
x
To follow ~ Not required
Agenda Item #: ~
DISPOSITION:
~ ~~
RESOLUTION NO. -2000
A RESOLUTION BY THE MONROE COUNTY BOARD OF COUNTY
COMMISSIONERS APPROVING AN EXEMPTION FROM THE NON-
RESIDENTIAL PERMIT ALLOCATION SYSTEM PURSUANT TO
POLICY 101.3.4 OF THE MONROE COUNTY YEAR 2010
COMPREHENSNE PLAN FOR ST. NICHOLAS GREEK ORTHODOX
CHURCH. THE PROPERTY IS LOCATED AT MILE MARKER 98.1 AND
IS FURTHER DESCRIBED AS PART OF TRACT "A" , CARIBBEAN
HEIGHTS SUBDIVISION, ISLAND OF KEY LARGO, MONROE
COUNTY, FLORIDA. THE LAND USE DESIGNATION IS SUBURBAN
RESIDENTIAL AND THE REAL EST A TE NUMBER IS 04592970-000000.
WHEREAS, Policy 101.3.4 of the Year 2010 Comprehensive Plan allows the Board of
County Commissioners to exempt federally tax-exempt non-profit organizations from the
nonresidential permit allocation system after a finding by the Planning Commission that such
activity will not adversely affect the hurricane evacuation objectives of the Comprehensive Plan;
and
WHEREAS, St. Nicholas Greek Orthodox Church has requested an exemption from the
non-residential permit allocation system; and
WHEREAS, during a regular meeting held January 26, 2000, the Monroe County
Planning Commission conducted a public hearing on the request by St. Nicholas Greek Orthodox
Church, for an exemption to the non-residential permit allocation system for a church and
recommended approval of the request to the Board of County Commissioners based on the
following findings of fact and conclusions of law:
1. The St. Nicholas Greek Orthodox Church and the Orthodox Christian Community of the
Florida Keys, Inc., is a Federally tax-exempt non-profit organization; and
2. An exemption to Monroe County Year 2010 Comprehensive Plan Policy 101.3.4 IS
required to construct the 3,217 Sq. Ft. building as an Institutional use; and
3. Churches are considered institutional uses and are allowed as Minor Conditional uses in
the Suburban Residential (SR) land use district; and
4. The proposed 3,217 square foot church will be serving the needs of current Monroe
County residents and will not have any impact on hurricane evacuation times; and
5. The use as a church complies with County level of service standards; and
C:\TEMP\St. Nicholas Bacc Resolution.doc
Page 1 of2
Initial
.1)
6. The proposed church is in compliance with all applicable land development regulations
and the Monroe County Year 2010 Comprehensive Plan; and
Therefore, we conclude that based on numbers 1-6 above, that the church will not adversely
affect the hurricane evacuation objectives of the Year 2010 Comprehensive plan; and
WHEREAS, the Board of County Commissioners has duly considered the
recommendations and findings of fact an conclusions of law of the Planning Commission adopts
them as their own; NOW THEREFORE,
BE IT RESOLVED BY THE MONROE COUNTY BOARD OF COUNTY
COMMISSIONERS, that the preceding Findings of Fact and Conclusions of Law, support their
decision to APPROVE the request filed by St. Nicholas Greek Orthodox Church and the
Orthodox Christian Community of the Florida Keys, Inc., as a federally tax-exempt, non-profit
organization, for an exemption to the non-residential permit allocation system pursuant to Policy
101.3.4 of the Monroe County Year 2010 Comprehensive Plan.
PASSED AND ADOPTED by the Board of County Commissioners of Monroe County,
Florida, at a regular meeting held on the 17th day of February, 2000.
Mayor Freeman
Mayor Pro Tem Neugent
Commissioner Harvey
Commissioner Reich
Commissioner Williams
BOARD OF COUNTY COMMISSIONERS
OF MONROE COUNTY, FLORIDA
BY:
(MA YOR/CHAIRMAN)
ATTEST
DANNY L. KOLHAGE, CLERK
BY
(SEAL)
BY:
DEPUTY CLERK
Resolution #
C:\TEMP\St. Nicholas BOCC Resolution.doc
Page 2 of2
Initial
MEMORANDUM
TO:
The Board of County Commissioners
K. Marleoe Conaway, Director of Pl~~
February 7, 2000
FROM:
DATE:
RE:
ST. NICHOLAS GREEK ORTHODOX CHURCH REQUEST FOR
EXEMPTION FROM THE NONRESIDENTIAL PERMIT ALLOCATION
SYSTEM PURSUANT TO POLICY 101.3.4, MONROE COUNTY YEAR 2010
COMPREHENSIVE PLAN.
MEETING DATE: February 17,2000
I. REQUEST:
St. Nicholas Greek Orthodox Church and the Orthodox Christian Community of the Florida Keys,
Inc. is requesting an exemption from the nonresidential permit allocation system based on their status
as a federally tax exempt religious organization.
Policy 101.3.4 states that:
Development activity by federally tax-exempt non-profit educational, scientific, religious,
social service, cultural and recreational organizations may be exempted from the permit
allocation system by the Board of County Commissioners after review by the Planning
Commission upon a finding that such activity will not adversely affect the hurricane
evacuation objectives of the Comprehensive Plan. . . All other provision of the
Comprehensive Plan shall apply to development exempted from the Permit Allocation
System, including compliance with the adopted levels of service for the provision of adequate
public facilities.
The Jenetopulos Group, agent for St. Nicholas Greek Orthodox Church, is proposing the construction
of a 3,217 square foot domed church with an open courtyard on property described as Tract A,
Caribbean Heights, in Key Largo (RE# 0492970-000000) The proposed building is located in the
Suburban Residential (SR) Land Use District, adjacent to U. S. #1 at MM 98.1.
II. PREVIOUS RELEVANT PLANNING COMMISSION ACTION:
On January 26, 2000, by Resolution P4-00, the Planning Commission recommended approval to the
Board of County Commissioners of the request filed by St. Nicholas Greek Orthodox Church for an
exemption to the non-residential permit allocation system pursuant to Monroe County Year 2010
Comprehensive Plan Policy 101.3.4.
Page 1 of2
C:\TEMP\St. Nicholas BOCC Exemption.doc
III. ANALYSIS:
The proposed church is a 3,217 square foot domed church and social hall, adjoined by an open
courtyard and a 24 space parking lot. The St. Nicholas parishioners have been using the St. James the
Fisherman Episcopal Church on Saturday mornings for the past seven years and now wish to build
their own church. The St. Nicholas Greek Orthodox Church will be serving the needs of current
Monroe County residents, and will not have any impact on hurricane evacuation time.
The proposed church will require Minor Conditional use approval. The project has been reviewed and
found to be in compliance with Objective 101.1 which states, "Monroe County shall ensure that at the
time a development permit is issued, adequate public facilities are available to serve the development
at the adopted level of service standards concurrent with the impacts of such development."
Site plans have been submitted and have been found to be in compliance with all applicable Land
Development Regulations and the Year 2010 Comprehensive Plan.
St. Nicholas Greek Orthodox Church has submitted documentation from the Internal Revenue Service
(IRS) District Director dated March 26, 1992 stating that the organization is exempt from Federal
Income Tax under section 501 (a) of the IRS code as an organization described in Section 501 (c)(3).
CONCLUSION AND RECOMMENDATION:
Based on the fact that the church will not have any impact on hurricane evacuation objectives and that
preliminary plans have been found to be in compliance with the Monroe County 2010 Comprehensive
Plan, Staff recommends to the Board of County Commissioners that an exemption be granted frompthe nonresidential permit allocation system for St. Nicholas Greek Orthodox Church.
Page 2 of2
C:\TEMP\St. Nicholas HaeC Exemption.doc
RESOLUTION NO. P04-00
A RESOLUTION BY THE MONROE COUNTY PLANNING
COMMISSION RECOMMENDING APPROVAL OF AN EXEMPTION
FROM THE NON-RESIDENTIAL PERMIT ALLOCATION SYSTEM
PURSUANT TO POLICY 101.3.4 OF THE MONROE COUNTY YEAR
2010 COMPREHENSIVE PLAN FOR ST. NICHOLAS GREEK
ORTHODOX CHURCH. THE PROPERTY IS LOCATED AT MILE
MARKER 98.1 AND IS FURTHER DESCRIBED AS TRACT "A" ,
CARIBBEAN HEIGHTS SUBDIVISION, ISLAND OF KEY LARGO,
MONROE COUNTY, FLORIDA. THE LAND USE DESIGNATION IS
SUBURBAN RESIDENTIAL AND THE REAL ESTATE NUMBER IS
0492970-000000.
WHEREAS, during a regular meeting held January 26, 2000, the Monroe County
Planning Commission conducted a public hearing on the request filed by the St. Nicholas Greek
Orthodox Church, for an exemption to the non-residential permit allocation system for a new
church; and
WHEREAS, the proposed development is located on property legally described as Tract
"A", Caribbean Heights Subdivision Addition, Island of Key Largo; and
WHEREAS, the above-described property is located in the Suburban Residential (SR)
land use district; and
WHEREAS, the Planning Commission was presented with the following evidence,
which by reference is hereby incorporated as a part of the record of said hearing:
1. The request from St. Nicholas Greek Orthodox Church; and
2. The staff report from Donny Lang, Senior Planner, dated November 24, 1999; and
3. The sworn testimony of Monroe County Planning staff; and
4. Comments by Garth Coller Esquire, Planning Commission Counsel; and
WHEREAS, the Planning Commission has made the following Findings of Fact and
Conclusions of Law based on the sworn testimony of the Monroe County Planning Department
staff, and the record:
C:\TEMP\St Nicholas Resolution P04-00.doc
Page 1 of2
Initial
1. The Orthodox Christian Community of the Florida Keys, operating as St. Nicholas Greek
Orthodox Church is a Federally tax-exempt non-profit organization; and
2. An exemption to Monroe County Year 2010 Comprehensive Plan Policy 101.3.4 IS
required to construct the 3,217 Sq. Ft. church building as an Institutional use; and
3. Churches are considered institutional uses and are allowed as Minor Conditional uses in
the Suburban Residential (SR) land use district; and
4. The proposed 3,217 square foot church will be serving the needs of current Monroe
County residents and will not have any impact on hurricane evacuation times; and
5. The use as a church complies with County level of service standards; and
6. The proposed church is in compliance with all applicable land development regulations
and the Monroe County Year 2010 Comprehensive Plan; NOW THEREFORE,
BE IT RESOLVED BY THE PLANNING COMMISSION OF MONROE COUNTY,
FLORIDA, that the preceding Findings of Fact and Conclusions of Law, support their
decision to recommend APPROVAL to the Board of County Commissioners of the request filed
by the Orthodox Christian Community of the Florida Keys and the St. Nicholas Greek Orthodox
Church for an exemption to the non-residential permit allocation system pursuant to Policy
101.3.4 of the Monroe County Year 2010 Comprehensive Plan.
PASSED AND ADOPTED by the Planning Commission of Monroe County, Florida, at a
regular meeting held on the 26th day of January, 2000.
Chair Mapes yes
Vice-Chair Gorsuch yes
Commissioner Stuart yes
Commissioner Hill yes
Commissioner Marr yes
PLANNING COMMISSION OF
MONROE COUNTY, FLORIDA
BY
Lynn Mapes, Chair
day of
,2000.
C:\TEMP\St Nicholas Resolution P04-00.doc
Page 2 of2
Initial
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RESOLUTION NO.
00-73
A RESOLUTION OF THE CITY COMMISSION OF THE
CITY OF KEY WEST, FLORIDA, IN SUPPORT OF THE
PROPOSED ACTION BY THE BOARD OF COUNTY
COMMISSIONERS OF MONROE COUNTY TO PROCEED WITH
THE SELECTION OF THE TOP-RANKED FIRM TO
DESIGN, BUILD AND OPERATE A KEY LARGO
WASTEWATER TREATMENT SYSTEM; PROVIDING FOR AN
EFFECTIVE DATE
WHEREAS, the City of Key West continues actively and
comprehensively to address the need to improve its
wastewater treatment and collection system; and
WHEREAS, the City of Key West has recently adopted
a comprehensive solution to treating wastewater that
includes advance wastewater treatment (AWT) to improve
water quality and public health for all residents; and
WHEREAS, the City of Key West remains supportive of
efforts to improve water quality throughout the Florida
Keys.
NOW THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF KEY WEST, FLORIDA, AS FOLLOWS:
Section 1:
That the Board of County Commissioners'
proposed action to select the top-ranked firm who will be most
cost-effecti ve and who will meet the wastewater needs of the
greater Key Largo area is hereby supported.
/
.... ,.
Section 2:
That the Board of County Commissioners'
continued efforts in addressing countywide existing wastewater
concerns for the health and safety of all county residents is
~
hereby supported.
Section 3:
That this Resolution shall go into effect
immediately upon its passage and adoption and authentication by the
signature of the presiding officer and the Clerk of the Commission.
Passed and adopted by the City Commission at a meeting held
this
15TH
day of
FEBRUARY
, 2000.
Authenticated by the presiding officer and Clerk of the
Commission on
FEBRUARY 16
, 2000.
Filed with
, 2000.
c=ReEf ~fiEf.
February 17, 2000
a non'prafit membership or!3anization dedicated to
Pre5erve and Protect Livin!3 Coral Reef Ecosystems
throu!3h local. re!3ional and !3lobal efforts
Monroe County Board of County Comnllsswners
Dear Mayor and Commissioners.
Reef Relief supports the efforts of the Monroe County Commission to provide advanced
\vastewater treatment or A \\-'T to an residents of Key Largo. The proposal presented by Ogden
Water to be considered today deserves the support of everyone who values our marine
,...-....:-...--..-..... .._.1 _.~LI':.. L......f4.-L '\'171-:1.. ....... ..__.1.__...4.-...._.1 ...L....-4.- _.__.. _...._L...._.. ....L...c..L.... 1)..-.... r .._._....
t::'11VI1Ul1111t""i1l LUlU tJUUllL llCdltlL ';'V HIlt:' rye Ul1UC;l~lallU Uli.1l11htllY 111CI11UCl,:'} VI LIlt; l'\..t::'y Li.t1t;v
community are unGllndiar with this proposal, your decision to begHl negotiations \-vtth thls firm
should go forv'iard even while additional community workshops are held by Ogden so that
everyone can learn more about this innovaUve proposal and so that they can then provide
constructive input into the negotiation process. The recent me survey reinforced that water
quality is of paramount concern to aU Keys residents. The time for delays is over. i-Ve must take
action to deal ii'ith our wasteiiiater problems.
Last November, Key West voters approved a comprehensive sewage solution that includes
advanced wastewater treatment to eliminate harmful nutrients, phasing out the ocean outfall
with a state-mandated deep injection well, and replumbing all city sewer lines within a two-year
period. His refreshing to see that Key Largo, the next largest Keys community, may
follow suit witb a sewage system tbat wiH improve water quality througb advanced
wastewater treatment.
The Ogden Water proposal is cost etIective, achieves a higb standard of waste treatment,
and eliminates the lengthy, expensive, and p-;:,liticalprocess of paying consultants lots of
money to bid out eacb phase because it is a design-build-operate system. Although many of
us believe that t:r~e fIorida Keys has already reached its enviroIl1lientaI call ying capacity arid that
further development should be discouraged, we cannot continue to let pollution from illegal
cesspits, leaky septic systems arid shallow injection wells discharge nutrients into nearshore
waters because we fear that dealing with our sewage will encourage more development.
Scientific studies have documented t:r~at such effluent reaches nearshore waters in 3 I I hours.
which our economy and quaEty ofEfe depends. for years, Reef Relief has encouraged t:r~e state
We must upgrade existing facilities as soon as possible if we value the coral reef ecosystem on
that reqUIres less physical space for the plant than traditional plants and ecOnOlntes of scale
onsite s):stems. Noyv the oppoftU:iity exists to achieve j\ \-VT th:rough a central selvage syste!!l
the Keys based on their opinion that advanced treatment technologIes were unavailable tor such
systems. Instead, Ioca! plant operators and others lobbied to reduce water quaEty standards for
regulators and the operators of existing sewage package plants to upgrade on-site treatment
tr-lTough the ap.~)lication of irUlovative technulogies.
R~cf R~licf Environm~nt.al C~nt.~r & Store
201 William St.r~"t.. PD. Box 430, r.."y W"st., FI 33041
(305) 294-3100 fax (305) 293-9515
www_r~cfr"licf.or!3 ..mail: r..eflrJlb..lIsout.hn~
Pagel\vo, Kl::J::J; KELlbt
Investing lH advanced sewage treatment, or A WT, is the only reasonable approach if we want a
treated sewage contribute to the marked decline m water quality of our coral reef ecosystem.
future ..vith dean ..vater. Nutrients in the form of nitrates and phosphates from inadequate1y-
This ecosystem includes nearshore waters, mangroves, seajo;Tasses and coral reefs that require
clear, clean, nutrient-free tropical ocean waters to thnve. Each contributing source of nutrients
insisting that those upstream of us do their part as weil.
brings us closer to enviroIl!uenta! decEm; and we must do all we can on a !oca! Ie'leI while sti!!
pnc'nnr~10.p ,\lnTitn hP,('li1 np.~.ntl;.:rt~nn, t,~;-ith ni_T;-lp.n 1T!"'iD"!r.::d';;-1tplv
.....................-....-.:::i- _i......-.......... .---0.........60- .......-c."'.......-..."'................... ................ .........0--....... ..."'...---..........--...-...........J.
county commission on this pro-actIve approach to our sewage inirastructure needs and
experienced in ..vaste'Nater treatrnent pIant construction and operation. ~Ve congratulate the
Ogden's proposal is economical and meets advanced wastewater standards. The company is
Very truly yours,
1tJN~L
DeeVon Quirolo
Exe.cuti"\le Director
The ....
Nature'
conservancYg;
Florida Keys
February 17, 2000
Dear Monroe County Commissioners,
This letter is to recommend that the Board of County Commissioners adopt the
wastewater treatment proposal before you today.
The ability to achieve maximum water quality benefits and to adequately monitor
wastewater systems is a primary objective in resolving the water quality problem in the
Keys. A central system and an on-site system were ranked the top two proposals by the
technical review committee. Both achieve the standards we believe are necessary to
protect marine habitat in the Florida Keys. Given that central and on-site systems can
meet A WT standards and that both could potentially contribute to future growth, we
support selecting the more cost-effective option.
Concerns about growth in the Keys and subsequent impact on the ecosystem are
well- founded and we are among those worried about potential negative impacts.
However, this concern should not create an obstacle to appropriate water quality
improvements. It's time for the County to move forward with wastewater improvements
in the Keys.
The Nature Conservancy has spent considerable time over the past year and a half
seeking federal financial assistance for water quality improvements in the Keys. We
believe the national significance of our ecological resources warrants a federal share in
the cost of wastewater and stormwater upgrades. However, we have repeatedly heard
from Members of Congress that Monroe County must show it can make progress on this
problem before federal investments will be made. The project before you can provide that
milestone.
Sincerely,
~~~.
....-........-. -
lffiF
Director
po. Box 4958 . Key West, FL 33041-4958 . 305296-3880 . FAX 305 292-1763
rt'lwkJ fltlJ1l'1
TO:
Mayor Shirley Freeman, Commissioner Wilhelmina Harvey,
Commissioner George Neugent, Commissioner Mary Kay Reich,
Commissioner Nora Williams
FROM:
John Loftis
24 Center Lane, Key Largo, Florida 33037
SUBJECT:
Sewer System for Key Largo
DATE:
16 February 2000
Since I will be out of the country and not able to attend the BOCC meeting on 17 February 2000, I
am writing you my opinion about the sewer system for Key Largo. We have been told, by Commissioner
Williams, that all the Keys have to be on sewer by the year 2009, which is not far off.
The fact that the Daniels proposed, 90 ft. injection well, (higher cost) will not provide a cost of
operation" .. . until they are awarded the contract" is unacceptable. The fact that a third party would be
operating the Daniels constructed facility creates the very serious and costly potential for disclaimer-of-
responsibility by the builder by virtue of the third party's control of the plant. Since the contracts for
operation of the sewer plant would be between the county and the operator, the county and the property
owners affected would assume most of the risk and liability for relief from responsibility by the operators, if
the plant operation is not satisfactory. There are way too many unanswered questions regarding the Daniels
proposal to "sign oft" on any facet of this project at this time.
Still wright Point is included in the Daniels - Lake Surprise proposal to "minimize the financial
impact" to the Lake Surprise/Sexton Cove property owners. In other words, we were included to help foot
the bill for this project even though we were not part of the "Hot Spot" problem. If the Daniels proposal
goes through, we will be unfairly paying a lot of money for a problem that we are not a part of. I think we
are being blackmailed and are being treated like pawns in the issue of addressing the "Hot Spot" Lake
Surprise wastewater issue.
The Ogden (all of Key Largo) proposal is a guaranteed cost, minimum risk, builder run plant with
2000 ft. + deep injection wells. The Ogden proposal is the fairest and most equitable to the property owners
in Key Largo and would potentially reduce the financial hardship imposed upon many of the "Cold Spot"
areas that could be included in the project.
As indicated by the vote that I asked for at the meeting on January 31 st, and at the meeting on
February 15th, it was (except for two dissenting votes) a unanimous vote that the Ogden Water Systems
proposal is the most preferred and suitable system of the two that were discussed. The people of Key Largo
have spoken - please vote with us, not against us.
Your participation in steering this project to a suitable location satisfactory to the majority of the
inhabitants of Key Largo is of utmost importance to us all. The citizens of Key Largo must be included in
the site selection process. In addition, I demand that you hold in Key Largo all public forums or meetings in
regard to the sewer system. You can count on my support only if consideration of these constraints are
seriously considered. The support that I have garnered for the sewer project will remain only if the scope of
the initial project encompasses all of Key Largo (Ogden Initiative -least cost), and is not so short-sighted as
to be one of three plants to be located on this island (as proposed by the Daniels Company). The tide of
positive support will turn against the project if the smaller scope (Daniels - high cost) project is pursued.
My opinion is if you do not support the Ogden Proposal, then I U~YoU take NO action on this issue until
further studies can be made.
o ftis
File: John, Commissioners letter
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eNVIRONMeNTAL DeFeNse
finding the ways that work
February 11,2000
Ms. Shirley Freeman, County Mayor
Monroe County Commission
5100 College Road, Public Service Building II
Stock Island, Key West Florida 33040
RE: Key Largo Central Sewer System
Dear Ms. Freeman:
Please enter into the public record for the above referenced matter these comments of
Environmental Defense. On behalf of our over 300,000 members, including more than
17,000 in Florida, we urge you to reject the proposal before you to design and construct a
central sewer system for Key Largo. We recommend as an alternative smaller-scale
wastewater treatment systems coupled with a policy to limit growth so as to avoid
reaching the carrying capacity of Key Largo and its waters.
Environmental Defense (formerly known as the Environmental Defense Fund, or EDF) is
a leading, national environmental group. Environmental Defense worked for many years
in Monroe County, helping to establish the Florida Keys National Marine Sanctuary and
serving on the Sanctuary's technical advisory committee. We also served on a committee
convened by the Florida Department of Health on Onsite Sewage Disposal Systems, and
currently work closely with the State of Florida and the South Atlantic Fisheries
Management Council to protect essential habitats of the reef fishes of Florida.
We are marine ecologists with expertise in the effects of nutrients on marine ecosystems,
and in marine environmental policy. The goal of improving water quality in the Keys is
very laudable, and perhaps the most important environmental goal in the County. It is
also a critical goal for all Americans who treasure the mangroves, seagrasses, and coral
reefs of the Keys. We are concerned, however, that the construction of a central sewer
system on Key Largo may subvert that goal, despite the best of intentions.
Even the best, most cost-effective sewer system typically struggles to keep up with
increases in the number of people depending upon it. Experience and re earch have
shown that added infrastructure such as central sewer systems can direc ly induc:RECEIV
additional growth. There are numerous studies showing how adding ro d ca' ED
increases the amount of traffic (e.g., Hansen, M. and Y. Huang. Road I in
California. Transportation Research A, Vol. 31, No.3, 1997, pp. 205- 18. r N6~d~~. 2000
North Carolina Office' 2500 Blue Ridge Road. Raleigh, NC 27607. Tel919 881 2601 . Fax 91988126 COUNTY AD ,WJSIRATOR
New York, NY . Washington, DC . Oakland, CA . Boulder, CO . Austin, TX Project Offices. Boston. MA . Los Angeles, CA
Totally chlOrine free 100Ck. post-consumer recycled paper
c;J- F7a
Mayor Shirley Freeman
February 11,2000
Page 2
Relationships Between Highway Capacity and Induced Vehicle Travel. TRB 78th Annual
Meeting Preprint CD-ROM, TRB, National Research Council, Washington D.C., January
1999. )
This additional growth can be costly. Studies routinely show that the costs associated
with induced growth often exceed revenues resulting from that growth (documentation
available upon request).
More to the point, additional growth can overwhelm the sewer system, necessitating
additional capacity. Furthermore, more people mean more wastewater discharge. Even if
the discharge is quite clean, the incremental effects of added loadings can jeopardize
water quality just as surely as a lower volume, but dirtier, discharge can. Cumulative
impacts often result in overall environmental degradation, in spite of environmental
regulation or technological improvements. For example, individual fishermen comply
with a plethora of regulations, yet 42% of the nation's fish stocks (that have been
assessed) have been overfished.
In addition, the presence of greater numbers of people inevitably increases other pollution
sources, and induces expansion of impervious surfaces, soil compaction and other effects
which generate increased levels of stormwater runoff into adjacent waters. Elevated use
of fertilizers and other home and yard chemicals, deposition of airborne pollutants from
vehicle exhausts, and other effects generate incremental loads of nonpoint-source
pollutants to surrounding waters and aquifers. Delivery of pathogens and metals and
other toxicants are also typically elevated, unless coordinated steps are taken to prevent
such effects.
In fact, at least one southeastern state has specifically blocked the development of a
centralized sewer system for an analogous coastal resort region for exactly this reason.
North Carolina has refused to issue either an ocean discharge permit or a non-discharge
permit for land application for a central sewer system for Carteret County (Beaufort,
Atlantic Beach and the barrier island beaches of Bogue Banks) specifically because of the
pollution threats associated with induced growth and development that would be
expected. Another new sewer system in coastal North Carolina was allowed to be built at
a reduced scale from that originally proposed (mostly to remediate pollution form failing
septic tanks), but was capped in volume to prevent induction of growth, and accompanied
by a comprehensive growth and nonpoint source management program. Montgomery
County in Maryland has also limited growth on the basis of sewer, water, road, and
school capacity.
Mayor Shirley Freeman
February 11,2000
Page 3
For these reasons, we recommend the development of a truly comprehensive
environmental quality policy for Monroe County that would integrate appropriate
wastewater treatment technology with growth control and carrying capacity concepts.
According to such a policy, the financial costs and performance of a particular sewage
treatment proposal would not be the sole considerations in deciding the proper course of
action. A comprehensive policy would recognize the important potential secondary
impacts of the choice of wastewater treatment technology, including induced population
growth, the need for increased capacity later, incremental impacts on water quality of
larger loadings oftreated wastewater and nonpoint source pollution due to increased
population, potential increased congestion, and increased need for other types of
infrastructure and services for a larger population.
Given these considerations, smaller-scale treatment technologies - coupled with growth
management - may be more appropriate for Key Largo than an economically and
environmentally expensive central sewer system.
Thank you for considering our comments. Please do not hesitate to call on us if we can
be of assistance.
Sincerely,
~Uj~~
Senior Scientist
C4r(l12L
Douglas N. Rader, Ph.D.
Senior Scientist
111, c..hJ.w A:. 7) lLVoJ..
Michelle A. Duval, Ph.D.
Staff Scientist
02/17/2000 16:44 FAX 305+296+4313
LAST STAND
flJ02
LAST STAND
P.O. Box 146. Key W t, A 33041 (305) 296-3335
.Protecting the Keys"
February 16. 2000
Mayor Shirley Freeman and Counc:y Commissioners
Board of Monroe County Commissioners
Key Largo Public Library
Dear Mayor Freeman and Members of the Commission:
At our meeting of February 14. 2000 the Board of Directors of Last Stand passed a resolution in support
of centralized Key Largo wastewater treatment.
The Ogden Wastewater System proposal appears to meet technical and perfonnance criteria and eco-
nomic feasibility. While we acknowledge that the proposal has received top ranking by the an E.P.A.
technical advisory panel, we encourage compliance with the requirements of the Monroe County Com-
prehensive Plan that technical assistance be provided by the Water Quality Steering Committee of the
Florida Keys National Marine Sanctuary.
Last Srand therefore recommends that the Board of County Commissioners condition approval upon the
favorable review and recommendation of the Water Quality Steering Conunirtee.
Furthermore. we share concerns that centralized wastewater treatment not become a vehicle to promote
growth and therefore recommend that any determination of present and future system capacity be consis-
tent with the Rate of Growth Ordinance.
\~)
V-
02/17/2000 16:44 FAX 305+296+4313
LAST STAND
~01
LAST STAND
P.o. Box 146. Key W .' R 33041 (305) 296-3335
.Protecting the Keys.
FACSIMILE COVER SHEET
TO: Monroe County Public Library, Key Largo
FACSIMILE NUMBER: (305) 853-7311
FROM:
Joseph X. DiNovo, Esquire; Executive Director
FACSIMILE NUMBER: (305) 296-4313
DATE: 2-16-00
PAGES: 1 OF 2
MESSAGE: Attached is a letter to the Monroe County Board of Commissioners which
reflects the resolution of the Board of Directors of Last Stand at itli February 14,2000
meeting relative to centralized wastewater treatment in Key Largo. Please deliver the
letter to the County Clerk tor inclusion in the record of the meeting of the Monroe
County Commission on February 16,2000.
ATTENTION
This message is intended for the use of the individual or entity to which it is addressed
and may contain information that is privileged, confidential and exempt from disclosure
under applicable law. If the reader of this message is not the intended recipient or the
employee or agent responsible for delivering the message to the intended recipient, you
are hereby notified that any dissemination, distribution or copying of this communication
is strictly prohibited. If you have this communication in error, please notifY us
immediately by telephone and return the original message to us at the above address via
the United States Postal Service. lbank You.