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DOAH Case No. 94-2560DRIti- it STATE OF FLORIDA FLORIDA LAND AND WATER ADJUDICATORY COMMISSION DEPARTMENT OF COMMUNITY AFFAIRS Petitioner, vs. ALDO R. FAGA' and JEANNE FAGA', owners, GRILL CONSTRUCTION, INC, General Contractor; and MONROE COUNTY, FLORIDA, Respondents. AGREEMENT FLWAC Case No. APP-93-091 DOAH Case No. 94-2560DRI THIS AGREEMENT is entered into between The ESTATE OF ALDO FAGA and JEANNE FAGA, property owner (hereinafter "FAGA"); GRILL CONSTRUCTION, INC., general contractor (hereinafter "GRILL"); the FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS, an agency of the State of Florida (hereinafter the "DCA"); and MONROE COUNTY, apolitical su> divisien of the State of Florida (hereinafter "COUNTY'). WITNESSETH: - WHEREAS, FAGA is the owner of real property known as: Lots 23-32, Block 21, COCO PLUM BEACH SUBDIVISION, Fat Deer Key, in unincorporated Monroe County, Florida. (hereinafter the "Subject Property"); and WHEREAS on September 23,1993, the COUNTY issued to FAGA building permit number 92-2-3617 (including 92-2-3615) and public works permit number 0764 (collectively "Building 1 t r Permits") for construction of a single-family residence on Parcel A of the Subject Property; and WHEREAS, the COUNTY issued permit numbers 92-2-3618, 92-2-3619, and 92-2-3623, for Parcels B, C, and D on the subject property; and WHEREAS, the Florida Department of Health and Rehabilitative Services has issued Permit numbers M3995, M4095, M4195, and M4295, for Parcels A-D, respectively; and WHEREAS, on November 8,1993, the DCA timely appealed the Building Permits for Parcel A to the Florida Land and Water Adjudicatory Commission alleging that the Building Permits were inconsistent with the applicable provisions of the Monroe County comprehensive plan and land development regulations and the provisions of Chapters 163 and 380, Florida Statutes; and WHEREAS, most of Monroe County, including the Subject Property, is located within the Florida Keys Area of Critical State Concern, as designated under §§380.05 and 380.0552, Florida Statutes; and WHEREAS, the DCA is the state land planning agency with the duty and responsibility of administering and enforcing the provisions of Chapter 380, Florida Statutes, the Florida Environmental Land and Water Management Act of 1972 (the "Act"), and the rules and regulations promulgated thereunder which include the Monroe County comprehensive plan and land development regulations; and WHEREAS, the parties recognize the binding effect of Florida Statute § 163.3227 and Monroe County Code §9.5-101 and 9.5-102, as to the form and content of this Agreement; and WHEREAS, pursuant to §§380.032(3), Florida Statutes, the DCA is authorized to enter into agreements with any landowner, developer, or governmental agency as may be necessary to effectuate the provisions and purposes of the Act or any rules promulgated thereunder; and WHEREAS, FAGA has submitted to the DCA and the COUNTY a site plan in an effort to 2 address the issues raised by the DCA in its appeal, which documents are acceptable to the DCA and the COUNTY with certain conditions described herein; and WHEREAS, the permits on appeal and the Subject Property are governed by the 1986 adopted comprehensive plan and implementing land development regulations and policies as of the date of permit application submittal; and WHEREAS, the parties wish to avoid the expense and delay of lengthy litigation and resolve the pending appeal under terms set forth herein, which said terms effectuate the provisions and purposes of the Act, and it is in their best interests to do so; and WHEREAS, the parties are resolving disputed issues of fact and law as to this appeal and in addition, any issues associated with the proposed residences for Parcels B, C and D; and WHEREAS, the DCA and the COUNTY find that this Agreement is in the best interests of the state and county and is necessary to effectuate the provisions and purposes of Chapter 380, Florida Statutes; and WHEREAS, the COUNTY joins in this Agreement for the purpose of implementing and enforcing the same; and WHEREAS, this Agreement incorporates by reference all other regulatory approvals not modified by this Agreement. NOW, THEREFORE, in consideration of the mutual covenants and undertakings herein, and in consideration of the benefits to accrue to each of the parties, the receipt and sufficiency of which are hereby acknowledged the parties hereby agree as follows: 1. Representations. The above recitations and representations are true and correct and by this reference are incorporated herein and are essential elements hereof. 3 4 A 2. Site Plan. FAGA has submitted to the COUNTY and the DCA, and the COUNTY and the DCA have approved, a revised site plan dated September 11, 1996. A copy of the revised site plan is attached hereto as Exhibit "A". The revised site plan is acceptable to and is hereby approved by the DCA and the COUNTY with the following conditions: A. All elements of the revised site plan shall be requirements of development and shall be mandatory, unless otherwise modified in this Agreement. All conditions for development specified in this agreement shall be mandatory. All use of the term "should" shall be deemed to be mandatory. B. The bridge depicted on Exhibit "A" shall be technically reviewed for modification to concrete construction as may be elected by FAGA. It is recognized that modifications to the existing ramp and fill therewith may be required if concrete construction is elected for the access bridge as may be authorized by the Florida Department of Environmental Protection ("FDEP"). If concrete construction is not elected by FAGA, a wooden bridge shall be built as depicted on the site plan, as approved by the FDEP. C. The DCA and the COUNTY acknowledge that FAGA may exercise transfer of development rights or sale of development rights assigned to the property in accordance with the 1986 adopted comprehensive plan provisions and land development regulations. D. It is not the intention of the COUNTY and the DCA to require acceleration of development of the Subject Property, but rather to maximize best land use management practices, including conservation values consistent with FAGA's rights and commitments herein. FAGA may elect to commence building pursuant to each building permit approval for each parcel independent of any other parcel to sequence construction of one residence at a time. However, once building 11 a has commenced, all other time limitations set forth in the Monroe County Code apply. Sequencing of construction may occur for a maximum period of ten years from the effective date of this Agreement by which construction must be completed. The ten year buildout period may be extended after ten years only upon written agreement among the parties. Due to the permit conditions required by this Agreement and Exhibit A hereto, the construction schedule set forth in the Monroe County Code applicable to Parcel A (permit numbers 92-2-3617, 92-2-3615 and public works permit number 0764) is tolled for a period of one (1) year from the effective date of this Agreement. E. The subject site plan shall include no drainage swales for the ocean side of the residences for Parcels A, B, C and D, and no concrete slab for the residence for Parcel A. Any swales otherwise required pursuant to the approved stormwater plan shall not discharge to the saltwater slough. F. No fill or excavation shall occur within the existing mangrove habitat as depicted on the site plan and as verified in the field prior to construction as per the FDEP permit. G. The access bridge reflected on the site plan rendered with the building permit application shall be of a length so as to clear the mangroves and salt water slough on site such that either end of the access bridge will terminate beyond the mangrove lines and the boundaries of the slough. H. The guest suite shall be connected to the main structure (single family residence, or "SFR") so as to form a single habitable unit by connecting the dripline on the north and south side of the former main residence and former guest suite which will increase the habitable square footage for each residence due to the reconfigured dripline. However, any increase in the 5 habitable square footage shall be limited to the square footage of the dripline connection only. In addition, FAGA will execute a restrictive covenant with the land which prohibits rental, sale or lease of the guest suite, or of anything less than the entire single family residence. FAGA agrees that each stairway shall provide reasonable uniform access to all portions of each residence, and the site plan shall include no additional independent access to the guest suite. I. Minimal excavation will be allowed for transplantation on the beach berm, i.e., the absolute minimum amount necessary to transplant the native species in accordance with the COUNTY approved transplantation plan. J. The parties agree that the Subject Property, including the access bridge and proposed residences for Parcels A, B, C, and D, as approved by regulatory agencies, are vested in accordance with the 1986 Monroe County Comprehensive Plan and implementing regulations including project sequencing imposed by this Agreement and said vesting shall not be subject to appeal by the DCA or COUNTY. Project modifications and time schedule waivers shall remain vested under the 1986 Comprehensive Plan, but shall be subject to applicable provisions of the Monroe County Code at the time the modification or waiver is approved. The COUNTY reserves its right to allow variance or waiver of any such provisions as allowed by law. K. In the event that all or a portion of the existing or authorized development subject to this Agreement should be destroyed by a storm, fire or other common disaster, FAGA, all heirs, grantees, successors or assigns shall have the right to rebuild or repair so long as such work is in compliance with this Agreement and applicable provisions of the COUNTY's 1986 Comprehensive Plan and implementing land development regulations L. FAGA may elect to sequence issuance of each building permits for Parcels C.1 A- D to allow one (1) residence to be completed before issuance of a second residence building permit within the time schedule of Paragraph 2.1). FAGA may elect to request issuance of more than one (1) building permit at a time or request issuance of one (1) or more building permits while one (1) or more residence(s) are under construction within the time schedule of Paragraph 2.D. 3. Post -Development Survey. Inspection and Restoration. Within two (2) weeks following commencement of construction of each single-family residence authorized under the subject permits, FAGA shall provide to the DCA and the COUNTY actual written or verbal notice that construction has commenced. The DCA and COUNTY staff shall be allowed reasonable access to the site, with prior appointment by at least 48 hours notice, for site inspection and verification of adherence to the revised site plan and this Agreement. The DCA and COUNTY agree to indemnify FAGA, all heirs, grantees, successors or assigns, from all claims for damages resultant from the gross negligence or misconduct of DCA and /or County representatives performing a site inspection pursuant to this Agreement. Such inspections shall occur no sooner than two (2) weeks after receipt of notice from FAGA that construction has commenced, and may take place on a random basis. The final site inspection shall be performed no later than two (2) weeks after completion of construction. Pursuant to the site inspections, the DCA shall notify the COUNTY and FAGA whether violation of either the COUNTY land development regulations or this Agreement has occurred. Said violation, if any, shall constitute a material breach of this Agreement. 4. Recommended Order. The Recommended Order entered in this case on November 1, 1995, (attached hereto as Exhibit B) shall have full force and legal erect. In consideration of the equities involved in this case, the revised site plan (Exhibit A), and the stipulations and conditions of this Agreement, the parties agree to jointly request the entry of a final order by the Florida Land 7 and Water Adjudicatory Commission adopting the findings of fact and conclusions of law in the Recommended Order and allowing FAGA to develop the subject property in accordance with the permit conditions and site plan revisions described herein and attached hereto as Exhibit A. 5. Further Proceedim. By their signature hereon, the parties to this Agreement join in a request to place this matter in abeyance pending issuance of a final order consistent with this Agreement. 6. Breach of Agreement and Cure Provisions. a. Upon FAGA's material breach of the terms and conditions of this Agreement, the COUNTY or the DCA may serve written notice on FAGA and shall provide FAGA the opportunity, within 60 days, to respond to or cure the breach, and/or to propose a method of fulfilling the Agreement's terms and conditions within a reasonable period of time. The COUNTY or the DCA, in their discretion, may jointly allow FAGA an opportunity to cure the breach or to negotiate an amendment to this Agreement within a reasonable time, not to exceed six(6) months after FAGA's response or proposal, absent exigent circumstances. The six month time frame may be extended by the parties, in writing, as long as curing of the breach or negotiation of an amendment to this Agreement is continuing in good faith. b. The following events, unless caused by fire, storms, floods or other acts of God or events beyond the control of FAGA, are to be considered a material breach of this Agreement: (1) The failure to comply with or violation of any or all terms of this Agreement; (2) The failure to maintain the conservation area provisions of this Agreement; (3) The failure to maintain conditions placed on permits or approvals contained in this Agreement; and (4) The failure to comply with applicable permitting requirements of the COUNTY after notice and opportunity withing sixty (60) days to comply with such permitting requirements or, if applicable, to commence compliance with such requirements if compliance requires more than sixty (60) days. C. If the DCA or the COUNTY finds that FAGA or a successor is in material breach of this Agreement and, after notice is given as provided herein to respond to or cure said breach, FAGA fails within a reasonable time to respond, cure or secure an amendment resolving the breach, then FAGA's rights hereunder are terminated and FAGA is subject to judicial action pursuant to Section 380.11, Florida Statutes, or to any cause of action for breach of Agreement available to DCA or the COUNTY. Any cause of action for breach of Agreement shall also be available to FAGA for any material breach of this Agreement by DCA or the COUNTY. However, in the event FAGA has sold a parcel or parcels, a material breach by FAGA shall not prevent an individual parcel owner from developing that parcel or parcels if such development is not in material breach of this Agreement. 7. Amendment. Termination or Revocation. The parties hereto shall at all times adhere to the terms and conditions of this Agreement. Amendment, termination or revocation of this Agreement shall be in a written document approved and executed by the parties to this Agreement or their heirs, grantees, successors or assigns, if applicable. 8. Procedures Governing Revocation DCA. Upon breach of Paragraph 6a. hereof, the DCA may revoke this Agreement by written notice of revocation to FAGA and the COUNTY. The Department's revocation shall be subject to the procedural requirements of Chapter 120, Florida Statutes. 9. Retention of Right to Request Entry of Final Order. If any party fails to implement this Agreement within the time periods prescribed hereunder, or if this Agreement is based upon 7 f materially false or inaccurate information, any party shall be entitled to withdraw from this Agreement and seek a final order in this case by motion filed with the Florida Land and Water Adjudicatory Commission. 10. State and Federal Law. If state or federal laws enacted after the effective date of this Agreement preclude any party's compliance with the terms of this Agreement, this Agreement shall be modified or revoked as is necessary to comply with the relevant state or federal laws, if applicable. However, this Agreement shall not be construed to waive or supersede any contention under law that FAGA has acquired vested rights under prior law. 1 1. Compliance with Other Laws. The failure of this Agreement to address a particular permit, condition, term, or restriction shall not relieve FAGA or the parcel owners of the necessity of complying with the laws governing said permitting requirements, conditions, terms or restrictions. 12. Caveat. The parties acknowledge their disagreement over whether the subject development order is consistent with the provisions of Chapter 380, Florida Statutes, relating to Areas of Critical State Concern and the administrative rules promulgated thereunder and have entered into this Agreement solely in the spirit of compromise. By their signatures hereon, no party shall be deemed to have acquiesced in the position of another party with regard to the proper interpretation and implementation of statutory and regulatory provisions relating to Areas of Critical State Concern. The Agreement shall not be given precedential effect with regard to other development orders excluding the Subject Property for other projects in an Area of Critical State Concern. 13. Certification of Understanding and Voluntary Execution: Costs and Attorney's Fees. The parties and/or their authorized representatives each certify that they have read and understand 10 the terms and conditions of this Agreement and that it is voluntarily executed for the purposes of making a full and final settlement of any and all claims or disputes of any nature, which could have been asserted against the other party as a result of this appeal of the subject development order. The parties hereto release each other party from any and all claims of whatever nature which arise or may arise out of the appeal of the Building Permits that was the subject of DOAH Case No. 94-2560DRI. Each party shall bear its own costs and attorney's fees incurred in this proceeding. 14. Drafting of Agreement. The parties shall be deemed to have participated generally in the drafting of this Agreement. Accordingly, this Agreement shall be construed neutrally without regard to the party or parties responsible for its preparation, and any terms, conditions, uncertainty, or ambiguity shall not be construed against any of the parties as a result of the drafting of this Agreement. 15. Entry of Final Order. Within five (5) days after this Agreement is executed by all parties, the DCA shall submit the Agreement to the Florida Land and Water Adjudicatory Commission with a recommendation to the Florida Land and Water Adjudicatory Commission that it accept this Agreement and enter an order approving the Agreement, as provided in Paragraph 4 herein, thereby concluding the subject appeal. The DCA shall endeavor to expeditiously conclude this matter to avoid unnecessary delay to FAGA. 16. Effective Date of Agreement, The effective date of this Agreement is the date on which the Florida Land and Water Adjudicatory Commission enters its Final Order. IT Duplicate Originals, This Agreement may be executed in any number of originals, all of which evidence one Agreement, and only one of which need be produced for any purpose. 18. Recordation of Agreement This Agreement is intended to and shall create a binding 11 covenant running with the land. FAGA shall provide the COUNTY with an executed Agreement within sixty (60) days of the Monroe County Commission and the DCAs approval of this Agreement, whichever date is later. The COUNTY shall record this Agreement with the Clerk of the Circuit Court of Monroe County within fourteen (14) days upon receipt from FAGA. Recording fees shall be paid by FAGA. Proof of recordation shall be provided by FAGA to the DCA within fourteen (14) days after the Agreement is recorded. If this Agreement is subsequently amended, canceled, modified, extended or revoked, the Clerk shall have notice of such action, the same shall be recorded, and notice provided to the DCA in the same manner as the original Agreement. 19. Scope of Authoritv This Agreement affects the rights and obligations of the parties under Chapter 380, Florida Statutes, relating to Areas of Critical State Concern. It is not intended to influence or determine the authority or decisions of any other state or local government or agency in issuance of any other permits or approvals that might be required by state law or local ordinance for any development authorized by this Agreement. 20. Entirety of Agreement This Agreement incorporates and includes all prior negotiations, correspondence, conversations, agreements or understandings applicable to the matters contained herein and the parties agree that there are no commitments, agreements or understandings concerning the subject matter of this Agreement that are not contained in or incorporated into this document. Accordingly, it is agreed that no deviation from the terms hereof shall be predicated upon any pnor representations or agreements, whether oral or written. 21. Seve_ ra�vs If a court of competent jurisdiction determines that any part of this Agreement is contrary to, prohibited by, or deemed invalid under any applicable law or regulation, such provisions shall be inapplicable and deemed omitted to the extent so contrary, prohibited or 12 invalid; however, the remainder hereof shall not be invalidated thereby and shall be given full force and effect. 22. Jurisdiction and GoverningLaw The parties hereto agree that initial venue for any and all suits or actions at law regarding this Agreement shall be Monroe County, Florida, and no other jurisdiction. This Agreement shall be construed and interpreted under the laws of the State of Florida. 23. Successors and Assigns This Agreement shall be binding upon the parties hereto, their successors in interest, heirs, grantees, assigns and personal representatives. Any entity purchasing one or more of the parcels, or portions thereof, shall take subject to the terms and provisions or this Agreement. Purchasers of one or more parcels after the date of this Agreement may independently elect to amend the development approvals for the parcel(s), however, those purchasers shall not be deemed the heirs, grantees, successors or assigns of FAGA for completion of the obligations of this Agreement. 24. Notices. All notices, demands, requests, or replies provided for or permitted by this Agreement shall be in writing and may be delivered by any one of the following methods: (a) By personal delivery; (b) By deposit with the United States Postal Service as certified or registered mail, return receipt requested, postage prepaid, to the address stated below; (c) By facsimile; or (d) By deposit with an overnight express delivery service. Notice deposited with the United States Postal Service in the manner described above shall be deemed effective three (3) business days after deposit with the Postal Service. Notice by facsimile or overnight express delivery service shall be deemed effective one (1) business day after transmission by facsimile or after deposit with the express delivery service. 13 For purposes of notice, demand, request or replies, the address of the COUNTY shall be: BOB HERMAN Director, Growth Management Division Monroe County 2798 Overseas Highway, Suite 400 Marathon, FL, 33050-2227 With a copy to: JAMES T. HENDRICK, ESQUIRE Monroe County Attorney 310 Fleming Street Key West, FL 33040 The address of FAGA shall be: JEANNE FAGA 88 Kings Cross Scarsdale, NY 10583 With a copy to: J.A. JURGENS ESQUIRE J.A. Jurgens, PA. 1964 Howell Branch Road, Suite 206 Winter Park, FL 32792 The address of the DCA shall be: MICHAEL McDANIEL Growth Management Administrator Department of Community Affairs 2555 Shumard Oak Boulevard Tallahassee, FL 32399-2100 14 4 Eli IN WITNESS WHEREOF, the parties have executed this Agreement on the date and year below written. Date STATE OF NEW YORK COUNTY OFc� THE ESTATE OF ALDO FAGA AND JEANNE' FAGA By; ANNE' �FAGA The foregoing instrument wa- a;;knowledged before me this _A� day o CANINE' FAGA, who is personally known to me or who has produced.96, by as identification and who did not take an oath. NOTARY PUBLIC My Commission Expires: i 1 6 5 5 00 DAVID JACOBS Notary Public, State of New York No. 01 JA5004190 Qualified In Westchester Cou Commission Expires 11/09/9— l Date STATE OF FLORIDA COUNTY OF LEON DEPARTMENT OF COMMUNITY AFFAIRS, an agenc a State of Florida By:CL& yzld� CHARLES PATTISON The foregoing instrument was acknowledged before me this 15 day of January, 1997, by CHARLES PATTISON, as mow;-si,,,. b%ccc�„ - of the DEPARTMENT OF COMMUNITY AFFAIRS, who is personally known to me or who has produced as identification and who did not take an oath. NOTARY PUBLIC ;.. My Commission expires: 'r bvhuw rFIrW TROY FAIN INSURANCE, INC. : ,t"jj�r rrr l? RONa M. Frazier 7 MY COMMISSION N CC5M70 EXPIRES October 6, 2000 80NOEo TNRU TROY FAAY INSURANCE, INC. 16 a December 18. 1996 MONROE of the Sta By: (SEAL) Attest: , a political subdivision DOUGE-4*S, Mayor Clerk Deputy Clerk DAWYLMN STATE OF FLORIDA DEPl9�fYCLEFIK COUNTY OF MONROE The foregoing was acknowledged before me this 18th day of December, 1996, by KEITH DOUGLASS, as Mayor of MONROE COUNTY, wh_o is _personally known to me or who has produced as identification and who did not take an oath. NOTARY P LIC My Commission expires: PjUC RIM ANN JANTZEN My Comm Exp. 12130/'99 Bonded B Service Ins No. CC506335 BY �,X.% [larrin � D AS TO FO1�M AND ICVENCY 17 (Ao � II �0 Q `a o m rna # o_ s eza a � 'C1II\1Y, I w o ` x a � of o-� cep N �~ 150' L, a 3 n o N kQ oa I CD 32 a O a m D l D 0 n m N n O O ? D p �o o� 50' 1� � kD 4 Im t p a 150' a m bcli `° o O CD DI z m oa cn Cb s° — \... `° (D N o v -Ti 0 3° sz"s�ti O ��F p o00 rn o O D' L is / �. in t • PROJECT OVERALL SITEPLAN QUADRANGLE MARATHON /7i7 LATITUDE LAND INFORMATION SERVICES APPLICANT J. FA CA LONGITUDE 2440 S.E. Federal Hwy., Ste. Z P.O. Box 1500, Stuart, FL 34995 LOCATION MARATHON, FL FDER # (407) 288-4880 Fox 288-0128 TITLE OVERALL SITEPLAN ACOE # Eric B. Holly, Agent FDNR # : SHEET I OF 1 STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS DEPARTMENT OF COMMUNITY AFFAIRS, Petitioner, CASE NO. 94-2560DRI vs. ) ALDO R. FAGA and JEANNE FAGA, ) Owners; GRILL CONSTRUCTION, INC., ) General Contractor; and MONROE j COUNTY, FLORIDA, Respondents. RECOMMENDED ORDER Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, Claude B. Arrington, held a formal hearing in the above -styled case on June 7-9, 1995, in Key West, Florida. APPEARANCES For Petitioner: Stephanie M. Gehres, Esquire Assistant General Counsel Department of Community Affairs 2796 Overseas Highway, Suite 212 Marathon, Florida 33050 For the Fagas: Michael L. Gore, Esquire Michael J. Grindstaff, Esquire Shutts & Bowen 20 North Orange Avenue, Suite 1000 Orlando, Florida 32801 For Grill No appearance. Construction, Inc.: For Monroe No appearance. County: STATEMENT OF THE ISSUES Whether Permit Number 9220003617 issued by Monroe County, Florida, to Jeanne and Aldo Faga is inconsistent with the Monroe Exhibit B County Comprehensive Plan and Monroe County Land Development Regulations. Three areas of dispute were involved in this proceeding: Whether the permitted development (as modified by stipulation) is inconsistent with provisions requiring development to be clustered on the least environmentally sensitive portion of the site; Whether the permitted development (as modified by stipulation) is inconsistent with provisions pertaining to construction in mangroves and submerged lands; and Whether the permitted development (as modified by stipulation) is inconsistent with provisions establishing setback requirements from beach berms that are known turtle nesting areas. PRELIMINARY STATEMENT Petitioner timely appealed a development order issued by Monroe County, Florida, to Aldo R. Faga and Jeanne Faga, as owners, and to Grill Construction, Inc., as general contractor. Mr. Faga died after the issuance of the permit, and the Estate of Aldo R. Faga, deceased, was substituted as the party in interest. The dispute was referred to the Division of Administrative Hearings, and this proceeding followed. The Fagas own ten (10) contiguous acres of property, originally platted as 10 separate lots. The property was reconfigured, and the lots combined to form four (4) lots, referred to as Parcels A through D. The development order appealed here is a building permit issued by Monroe County for construction on Parcel A only. To resolve the clustering issue, it is necessary to determine the habitat types that exist on Parcel A. That 2 determination will resolve whether the permitted development is "clustered" on the property such that the development impacts the least sensitive portion of the parcel. The determination of the habitat seaward of the slough and the landward extent of the beach berm is necessary to resolve whether the development as permitted by Monroe County complies with mandated setbacks from known or potential turtle nesting areas. Finally, it will be necessary to resolve whether the bridge/access structure as permitted by the Department of Environmental Protection and approved by Monroe County is allowable under the pertinent land development regulations. Prior to the formal hearing, the parties entered into certain stipulations that form the basis of findings of fact in this Recommended Order. At the formal hearing Petitioner presented the testimony of four (4) witnesses: Kenneth Metcalf, Community Program Administrator for the Florida Keys Area of Critical State Concern; Kathleen Edgerton, a Planner IV, Biologist employed by the Department; Patricia McNeese, an ecologist with Lewis Environmental Services and Director of Monroe County's' Environmental Resources Department; and Pat Wells, a manager with the Florida Park Service. Mr. Metcalf was tendered and accepted as an expert in the fields of urban regional planning and in the implementation of the Critical Area Plan in the Florida Keys. Ms. Edgerton was tendered and accepted as an expert in the fields of biology, marine biology and Florida Keys ecology. Ms. McNeese was tendered and accepted as an expert in the fields of biology, marine biology and Florida Keys ecology. Mr. Wells was tendered and accepted as an expert in the field of marine turtle nesting in the Florida Keys. The Respondents presented the testimony of four (4) witnesses: Brian Winchester, President of Winchester Environmental Associates, Inc.; Lorenzo Aghemo, Planning Director for Monroe County; Jennifer Faga, the daughter and representative of Respondent Jeanne Faga; and Kenneth Metcalf. Mr. Winchester was tendered and accepted as an expert in biology and Florida Keys biological ecosystems, including plant identification and habitat analysis. Respondents also called as a witness Faye Buchanan, a licensed real estate broker specializing in property sales in the Middle Keys area of Florida. Her proffered testimony was found to be irrelevant and was, consequently, excluded. The Petitioner offered the following exhibits that were admitted into evidence: 1, 2, 3, 3 (a) , 4, 7 (a) , 7(b), 7 (c) , 7(d), 7(e), 7(f), 7(g), 8(a), 8(b), 8(c), 8(d), 8(e), 9(a), 9(b), 10, 11, 14(a), and 14(b). There were no Petitioner exhibits marked 5, 6, 12 or 13. Petitioner's Exhibit 15 was marked for identification purposes only. Petitioner's exhibits.16 (5 bags of soil) and 17 (a bag of seagrass) were accepted for demonstrative purposes only. The Fagas offered 37 exhibits, identified as Fagas' Exhibits 1 - 37, all of which were admitted into evidence except Exhibit number 30. A transcript of the proceedings has been filed. At the request of the parties, the time for filing post -hearing submissions was set for more than ten days following the filing 4 T � � of the transcript. Consequently, the parties waived the requirement that a recommended order be rendered within thirty days after the transcript is filed. Rule 60Q-2.031, Florida Administrative Code. Rulings on the parties' proposed findings of fact may be found in the Appendix to this Recommended Order. FINDINGS OF FACT THE PARTIES 1. Petitioner is the state land planning agency charged with the responsibility to administer the provisions of Chapter 380, Florida Statutes, and the regulations promulgated thereunder. Petitioner has the authority to appeal to the Florida Land and Water Adjudicatory Commission any development order issued in an area of critical state concern. 2. Jeanne Faga and the Estate of Aldo Faga, deceased, hereafter referred to collectively as the "Fagas," are the owners of approximately ten acres of real property known as Lots 23 through 32, Block 21, Coco Plum Beach subdivision, Fat Deer Key, in unincorporated Monroe County, Florida. This property, acquired by the Fagas in 1971, has been subdivided by the Fagas into four parcels. Lots 23-24 have been consolidated and will be referred to as Parcel A. The remaining lots have been divided into Parcels B, C, and D. 3. Grill Construction, Inc., is a Florida corporation and is the general contractor for Respondent for the building permit at issue. 4. Monroe County, Florida; is a political subdivision of the State of Florida. Monroe County did not actively participate in this proceeding. 5 THE DEVELOPMENT ORDER AND ITS HISTORY 5. Most of Monroe County, including the subject property, is within the Florida Keys Area of Critical State Concern, as designated under Sections 380.05 and 380.0552, Florida Statutes. These statutory provisions require that Monroe County adopt and implement a comprehensive plan and land development regulations consistent with the Principles for Guiding Development found at Section 380.0552(7), Florida Statutes. 6. Monroe County has adopted a comprehensive plan, effective September 15, 1986, which complies with the Principles for Guiding Development and which has been approved by the Petitioner and by the Administration Commission. The Monroe County comprehensive plan is implemented by and through its adopted land development regulations, codified primarily in Chapter 9.5, Monroe County Code (M.C.C.). 7. While Respondent originally applied for a development permit for one residence on each of the four parcels and for an access bridge on Parcel A, the subject of this permit appeal proceeding is the development order for Parcel A only. If the project is permitted, it -is contemplated that the access bridge at issue in this proceeding will provide access to the residences the Fagas hope to build on Parcels B, C, and D. B. The initial permit application for a residence on each of the four (4) parcels and an access bridge on Parcel A capable of use by motor vehicles was denied by Monroe County staff. The Fagas thereafter appealed the staff denial to the Planning Commission. The Planning Commission reviewed the project and 6 affirmed the denial by staff. The Fagas thereafter appealed the denial by the Planning Commission to the Monroe Cou-ity Commission. 9. On July 28, 1993, the Monroe County Board of County Commissioners adopted Resolution No. 299-1993, which reversed the denial of the appeal by the Planning Commission, and authorized the Fagas to go forward with the building permit applications. On September 23, 1993, Monroe County issued to the Fagas and Grill Construction Co. building permit number 9220003617, the development order that is the subject of this proceeding. This development order includes public works permit number 0764 and building permit number 9220003615, which address the proposed access bridge on the subject site. The development order approves the permit for the access bridge that was issued by the Department of Environmental Protection. This development order authorizes the construction of a 4,501 square foot single family home with 2,426 square feet of porches, a 813 square foot enclosure for parking and storage, fill for a driveway, a separate guest house and an elevated bridge approximately 12 feet wide and 160 feet long. The building permit issued by Monroe County at issue in this proceeding did not include construction on Parcels B, C and D. 10. The Department timely filed its challenge to the subject development order pursuant to Section 380.07, Florida Statutes. 7 t , t STIPULATED PERMIT CONDITIONS 11. The parties stipulated that the following modifications to the development order would be made if the project is permitted:2 A. The subject development permit conditions shall be amended to state that the subject site plan shall include no drainage swales and no concrete slabs. B. The subject development permit conditions shall be amended such that the site plan shall include no fill or excavation between the proposed structures and the salt water slough, for a driveway or for any other purpose, except for minimal fill necessary for the ramp at each end of the proposed bridge. No fill or excavation shall occur within the existing mangrove habitat as depicted on the site plan and as verified in the field prior to construction. C. The subject development permit conditions shall be amended to reflect that the access bridge reflected on the site plan rendered with the building permit application shall be of a length so as to clear the mangroves and salt water slough on site such that either end of the access bridge will terminate beyond the end of the mangrove lines and the boundaries of the slough. D. The subject development permit conditions shall be amended to reflect the guest suite be connected to the main structure (single family residence, or "SFR") by an enclosed interior hallway, atrium or the like, so as to form a single habitable unit. In addition, the Fagas will execute a restrictive covenant to run with the land which prohibits rental, sale or lease of the guest suite,.or anything less than the entire single family residence. Each stairwell to the SFR will access a deck which provides uniform access to each room in the SFR, and the site plan shall include no additional independent access to the guest suite.. E. Only minimal excavation will be allowed for transplantation on the beach berm, i.e., the absolute minimum amount necessary to 8 transplant the native species identified in the County -approved transplantation plan. The transplantation shall occur in a manner which preserves the contour of the beach berm and ground cover resources on site and restores the area cleared for development to natural conditions which include native plant species transplanted on site. GENERAL DESCRIPTION OF PARCEL A 12. Most of the land constituting the four Faga parcels was "created" in the late 1950s, by depositing seaward (south) of the then existing shoreline spoil material from offshore dredging. The original "beach" in this area of Fat Deer Key (prior to the dredge and fill activities) existed just south of Coco Plum Drive, which now serves as the northern border of the Faga parcel. As a result of this dredge and fill activity, most of the dry land that presently exists on Parcels A-D was created from lands that were submerged. Additionally, the saltwater slough that exists on Parcels A-D was created as a result of this dredge and fill activity. 13.' The subject site, Parcel A, is bordered on the north by Coco Plum Drive, on the West by a multistory condominium development, on the South by the Atlantic Ocean, and on the East by Parcel B. Parcel A is rectangular, with the East - West. measurement being approximately 215 feet and the North - South measurement being approximately 375 feet. The Eastern third of V the central portion of the Faga parcel contains a shallow, manmade water body (the "saltwater slough"), which is fringed with mangroves. 14. Because the saltwater slough was created by the dredge and fill activity, it is appropriate to classify the saltwater 9 t � . slough as a manmade water body pursuant to Section 9.5-4 9(M-4), M.C.C., which defines the term "manmade water body" as follows: (M-4) Manmade water body means a water body that was created by excavation by mechanical means under human control and shall include a canal, cut basin or channel where its edges or margins have subsequently been modified by natural forces. 15. All of Parcel A, meets the following definition of "disturbed land" found at Section 9.5-4(D-14), M.C.C.: (D-14) "Disturbed Land": Disturbed land means land that manifested signs of environmental disturbance which has had an observable effect on the structure and function of the natural community which existed on the site prior to the disturbance. 16. The remainder of the property, including the sandy beach area and beach berm, will be discussed in detail below. CLUSTERING REGULATIONS 17. Section 9.5-345(a), M.C.C., requires clustering of development as follows: "Clustering": When a parcel proposed for development contains more than one (1) habitat type, all development shall be clustered on the least sensitive portions of the parcel subject to the maximum net densities of Section 9.5-262, the open space requirements of Sections 9.5-262 and 9.5-269 and the performance standards of this section. For the purposes of this subsection, the sensitivity of habitat types shall be as listed with subsection (1) being the most sensitive and subsection (18) being the least sensitive. The least sensitive part of the parcel shall be fully utilized prior to the distribution of density to the next least sensitive habitat type. 1) High hammock (high -quality) ; 2) Palm hammock; 3) Cactus hammock; 4) Beach/berm; 5) Pinelands (high -quality); 6) Salt marsh and buttonwood 10 associations; 7) High hammock (moderate -quality); 8) Low hammock (low -quality); (moderate -qu Y)� 9) (10) Low hammock Pinelands (low -quality); (11) High hammock ( low -quality) ; (12) Low hammock (low -quality); (13) (14) Disturbed with hammock; Disturbed with salt marsh and buttonwood; (15) Disturbed beach/berm; (16) Disturbed with exotics; (17) Disturbed with slash pines; (18) Disturbed. 18. Landowners are required to cluster development on the least sensitive portions of their property, subject to open space requirements for the respective classifications and subject to the maximum density for a parcel. An area classified as "disturbed" has a twenty percent open space requirement. Parcel A has a maximum density limit of 2.5 units per acre. HABITAT DETERMINATION -- GENERALLY 19. To determine whether it is necessary to cluster this development, it is necessary to determine the habitat classification for Parcel A. Monroe County has adopted an existing conditions map that purports to show the existing habitat classifications on Parcel A. The existing conditions map reflects two habitat classifications for Parcel A: open water (the area of the saltwater slough) and disturbed with buttonwood and salt marsh. on the Aslan survey3 as the 20. The area designated saltwater slough is properly designated as open water. 21. The parties agree that the classification on the existing conditions map for the remainder of Parcel A as 11 "disturbed with buttonwood and salt marsh" is incorrect. The parties disagree as to the appropriate habitat classification for the portions of Parcel A landward and seaward of the saltwater slough. 22. Brian Winchester, on behalf of the Fagas, spent in excess of 8o hours on the four Faga parcels, conducting visual observations and taking core samples. He conducted field surveys of the four parcels during July 9-11, September 23- 24, October. 20-22, and November 11-12, 1992. Staff of the Monroe County Environmental Resources Department conducted a joint site visit to the parcels with Mr. Winchester on September 23 and October 21, 1992. 23. Mr. Winchester identified each small area of the parcel that he believed justified a distinct habitat classification and, based on a qualitative and quantitative analysis (which included counting individual stems in some areas), determined whether there was a dominate species for each area. 24. In October and November, 1992, Mr. Winchester staked the edges of each portion of Parcel A that he believed constituted a distinct habitat. Those. staked areas reflecting a plant community were then measured by Asian, Inc. and depicted on the Asian survey. The Asian survey also marks the mean high water line on the property and measures the topography of all four parcels. 25. Kathleen Edgerton and Patricia McNeese, the biologists who testified for the Petitioner, disagreed with Mr. Winchester's habitat evaluation. They conducted separate on -site inspections 12 of the property, each with the benefit of the Aslan survey, and each determined what she considered to be the appropriate habitat classifications on Parcel A. Ms. Edgerton and Ms. McNeese were in agreement as to how the habitats of Parcel A should be classified. 26. Petitioner's experts determined the extent of the saltwater slough and the mangrove fringe surrounding it. They determined the extent of the beach berm (which they consider to extend to the mangrove fringe on the seaward side of the slough) and determined the habitat of Parcel A seaward of the mangrove fringe. They then determined the habitat classification for the portion of Parcel A lying landward of the mangrove fringe. Based on their on -site evaluations of the property, Petitioner's experts did not believe that the portion of Parcel A lying landward or seaward of the mangrove fringe justified more than one habitat classification. 27. in resolving the conflicting testimony between Respondents' expert and Petitioner's experts, more weight is given to the opinions expressed by Ms. Edgerton and Ms. McNeese because they have had extensive experience in conducting habitat classifications for lands in the Florida Keys as a part of their official responsibilities. While Mr. Winchester is an accomplished biologist, his experience in making habitat determinations in the Florida Keys is limited. The undersigned is persuaded by the testimony from Petitioner's experts that observations of species on site for making habitat determinations involve the subject parcel in larger perspective than that used 13 r� , by Mr. Winchester. HABITAT DETERMINATION LANDWARD OF THE SLOUGH 28. Mr. Winchester expressed the opinion that the following habitat classifications exist on the portion of Parcel A lying landward of the mangrove fringe: a small strip of land adjacent to the road that should be classified as "disturbed"; a larger strip of land that should be classified as "disturbed with exotics"; and a third strip of land that should be classified as "disturbed with salt marsh and buttonwood". Petitioner's experts testified that the entire portion of Parcel A landward of the mangrove -fringe should be classified as "disturbed". This dispute is resolved by finding that the greater weight of the evidence establishes that the portion of Parcel A landward of the mangrove fringe should be classified as "disturbed". While exotics, including Australian Pines and Brazilian peppers, exist in different areas of this part of the property, Petitioner's experts established that other vegetation exists and that exotics do not dominate the portions of the property classified by Mr. Winchester as "disturbed with exotics". Likewise, it is concluded that the portion of the property classified by Mr. Winchester as "disturbed with salt marsh and buttonwood" should be classified as "disturbed" since there is little salt marsh and buttonwood does not dominate. Further, there exists in this area trees and vegetation that are not typically found in an area designated as "salt marsh and buttonwood". 14 GRQ H INGE AND 'F O SALTWATER SLOUCH 29. The Department of Environmental Protection (DEP) has claimed jurisdiction of the saltwater slough, an assertion that is not challenged in this proceeding. 30. The parties disagree an to whether the saltwater slough is tidally influenced and whether the mangrove fringe around the saltwater slough meets the definition of a "mangrove community". 31. The salt water slough Consists of shallow, landlocked water over mud, sand and marl bottoms. The water level increases with heavy rains and infrequent storm tides, and decreases during periods of drought. The slough has been observed to be dry during time of drought, negating any inference of regular tidal influence. Based primarily on Mr. Winchester's observations and quantitative measurements, it is concluded that there is no regular tidal influence on the slough. 32. That the saltwater slough is ecologically significant and provides a valuable resource for birds, especially during storms, was not seriously disputed at the formal hearing. The birds that normally use the beach will come into the slough, where they can stay within the protection of the mangroves. They feed there, and are not subjected to wave .force and wind that they would receive if they were on the outside. 33. The salt water slough is encircled by a fringe of mangroves. Mr. Winchester classified the mangrove fringe as ,,disturbed with mangroves". This classification is consistent with similar classifications on Monroe County's existing conditions maps, but the classification is not separately listed Dat-ir Fax Note 7671 We � �' 0Ipages� O From 'o.:'Dept• Co. 'horse 4 Phone # Fax # is Feb iY '9'6 10 3� F' in the County's land development regulations pertaining to clustering because specific regulations limit development in mangroves.4 Whether the areas delineated by the Asian survey as being the mangrove fringe is classified as "mangroves" or as "disturbed with mangroves" is irrelevant for determining the issues presented by this proceeding. HABITAT DETERMINATION - WATEMAR.D OF THE SLOWH 34. Section 9.5-4(B-3), defines the term "beach berm" as follows: Beach berm means a bake, sandy shoreline with a mound or ridge of unconsolidated sand that is immediately landward of, and usually parallel to, the shoreline and beach. The sand is calcareous material that is the remains of marine organisms such as corals, algae and molluscs. The berm may include forested, coastal ridges and may be colonized by hammock vegetation. 35. Parcel A contains a sandy beach, including a seaweed wrack and some low vegetation which is typical of beach berm vegetation as defined in the Monroe County Code. Behind.the low vegetation, lies an area of Australian Pine trees that extends to the seaward extent of the mangrove fringe. Petitioner asserts that the beach berm on Parcel A extends to the mangrove fringe and that the proper classification for all of Parcel A seaward from the mangrove fringe is "disturbed beach berm". Respondents assert that seaward from the mangrove fringe on the east side of the parcel there is a small section that should be classified as disturbed with salt marsh and buttonwood, that the area with the Australian Panes should be classified as disturbed with exotics, and that the remaining portion should be classified'as disturbed beach berm. 16 36. The accepted characteristics of beach berm soil, as defined in the LDRs and Comprehensive plan, are "calcareous" and "unconsolidated". Reference to the soil as calcareous refers to its origin, while the consolidation of the soil refers to its compression and its cohesiveness. 37. The soil from the mean high water line to the mangrove fringe seaward of the slough is unconsolidated, calcareous sand. The only area that appears to exhibit consolidated soils is that which has been compacted by vehicular use in the property. Vegetation typical of beach berms is scattered throughout the parcel between the mean high water mark and the mangrove fringe. 38. The area of Parcel A that lies between the mean high water mark and the mangrove fringe seaward of the saltwater slough, is beach berm. This portion of Parcel A is properly classified as "disturbed beach berm" as opposed to "beach berm" because the entire parcel is disturbed lands and because Australian Pines have encroached on a portion of the beach berm. CLUSTERING ANALYSIS 39. Petitioner established that development on Parcel A (with the exception of the access structure to be discussed below) should be limited to the area landward of the slough that should be classified as "disturbed". The Petitioner established that this area of Parcel A is large enough to accommodate a reconfigured version of the development. TURTLE NESTING SETBACK 40. Section 9.5-345 (3) (f) , M.C.C., provides for a setback of construction from turtle nesting areas in areas designated as disturbed beach berm as follows: 17 S f. No structure shall be located within fifty (50) feet of any portion of any beach - berm complex which is known to serve as an active nesting or resting area of marine turtles, terns, gulls or other birds . . . 41. While no specific sites on Parcel A were identified as active nesting sites, the beach on which Parcel A is located is a known turtle nesting area. The expert testimony from Patrick Wells established that marine turtles most frequently nest within 50 feet of the mean high water line. The expert testimony of Mr. Metcalf established that the setback of fifty feet required in Section 9.5-345(o)(3)f, M.C.C., should be typically measured from the backslope of any beach berm crest. If there is no beach berm crest on a parcel or if the beach berm crest is more than fifty feet from the mean high water line, the setback should be measured from a line that is parallel to and fifty feet landward of the mean high water line.5 42. Mr. Winchester identified the existence of a beach berm "crest" within the area of Parcel A that is designated on the Aslan survey as disturbed beach berm. Mr. Winchester testified that he observed a three or four inch drop behind the crest and was of the opinion that the beach berm crest was formed by wind and wave action. The crest, as identified by Mr. Winchester, is marked on the Aslan survey and is just a few feet from the mean high water line. 43. Petitioner's experts testified that there was no crest and that there was a gradual rise in the beach berm elevation from the mean high water mark to the beginning of the mangrove fringe. is 44. This conflict in the evidence is resolved by finding that there is no discernible beach berm crest until it reaches the mangrove fringe. This finding is consistent with the expert testimony presented by the Petitioner, the photographic evidence, and the topographical markings on the Aslan survey. Further, this finding is consistent with the manner in which this property was created by the depositing of fill. 45. Based on the foregoing findings, it determined that the beginning of the setback line should be from a line parallel to and fifty feet landward of the mean high water line. The distance of the setback itself should be fifty feet as required by Section 9.5-345(o)(3)f, M.C.C. The development order at issue in this proceeding does not comply with the turtle nesting setback requirement. THE ACCESS STRUCTURE 46. Section 9.5-345(m), M.C.C., authorizes construction of piers, docks, utility pilings and walkways on areas with mangroves and submerged lands. All structures on any submerged lands and mangroves are required to be designed, located, and constructed on pilings or other supports. 47. DEP has issued a permit for the access structure that, if constructed, will be on pilings that are set in areas of the mangrove fringe and in areas of the slough. As permitted by DEP, the access structure would be 12 feet wide and 160 feet long. As noted above, the parties have stipulated that the subject development permit conditions shall be amended to reflect that the access bridge reflected on the site plan rendered with the 19 I ♦ l building permit application shall be of a length so as to clear the mangroves and salt water slough on site such that either end of the access bridge will terminate beyond the end of the mangrove lines and the boundaries of the slough. The DEP permit contains appropriate special and general conditions to assure that the access structure will be constructed consistent with pertinent permitting criteria. 48. The primary objection to the access structure raised by the Petitioner is to the width of the structure. Mr. Metcalf testified, without contradiction, that the acceptable standard in the planning profession for the maximum width for a walkway is six feet. Based on that testimony, it is found that the access structure should be authorized with the conditions imposed by DEP and as modified by the parties's stipulation, but with the additional condition that the width of the structure be changed from twelve feet to six feet. CONCLUSIONS OF LAW 49. The Division of Administrative Hearings has jurisdiction over the parties to, and the subject matter of, this proceeding. Sections 120.57(1) and 380.07(3), Florida Statutes. 50. The Petitioner timely appealed, pursuant to Section 380.07, Florida Statutes, the development order that is described in the findings of fact portion of this Recommended Order. The activity authorized by the building permit is "development" as defined in the Monroe County land development regulations and Chapter 380, Florida Statutes. The building permit is a "development order" within the meaning of Chapter 380, Florida 20 Statutes. See Section 9.5-4(D-8), Monroe County Code, and Section 380.04, Florida Statutes. 51. Although designated an appeal, this proceeding is properly considered to be a "de novo" proceeding pursuant to the provisions of Section 120.57(1), Florida Statutes. The initial burden of going forward with the evidence that the development order is not in accordance with Chapter 380, Florida Statutes, the Monroe County Comprehensive Plan, and the Monroe County land development regulations, and the ultimate burden of persuasion, is on the Petitioner. Young v Department of Community Affairs, 625 So.2d 831 (Fla. 1993); Transcmlf Pipeline Co. v. Board of County Commissioners, 438 So.2d 876 (Fla. 1st DCA 1983). 52. In Young v Department of Community Affairs, supra, at 834, the Court observed that the Legislature has statutorily determined that development in the Florida Keys Area of Critical State Concern will have an adverse impact if not in accordance with chapter 380, the local development regulations and the local comprehensive plan." 53. In conformity with and in furtherance of the purposes of Chapter 380, Florida Statutes, the Local Government Comprehensive Planning and Land Development Regulation Act requires that Monroe County permit only that development which is consistent with the Monroe County comprehensive plan. See, Sections 163.3161(2) and 163.3194(1), Florida Statutes. See also, Sections 163.3201, 163.3215(1), and 163.3213(1), Florida Statutes. 54. The Petitioner's burden is to establish by competent, substantial evidence that the permitted development authorized by 21 building permit number 9220003617 does not comply with the Monroe County comprehensive plan and land development regulations, and that the development is, consequently, not in accordance with the provisions of Chapter 380, Florida Statutes. Petitioner has met I its burden in this proceeding. 55. Deference has been given to the Petitioner's interpretation of the land development regulations pertaining to classification of habitat. An agency's interpretation of its own rules and regulations will not be overturned even if such interpretation is not the sole possible interpretation, the most logical interpretation, or the most desirable interpretation. An agency's interpretation of its rules and governing statutes will not be overturned unless the interpretation is clearly erroneous. Health Ouest Co oration et al. v. Department of Health and Rehabilitative Services and Arbor Health Care Co. et al., 11 FALR 5427 (1989), ABC Li ors Inc. v. Department of Business Regulation, 397 So.2d 696 (Fla. 1st DCA 1981); Department of Insurance v Southeast Volusia Hospital District, 438 So.2d 815 (Fla. 1983). 56. As reflected by the Findings of Fact, the Petitioner has established by competent, substantial evidence that the development of a single-family residence, guest suite and access bridge, as authorized by Monroe County under building permit number 9220003617, does not comply with the Monroe County comprehensive plan and land development regulations, and consequently is not in accordance with the provisions of Chapter 380, Florida Statutes. The stipulation as to modifications that 22 would be made by the Fagas if the development is permitted does not bring the development into compliance. 57. The development would meet all permitting criteria, including the 50 foot turtle nesting setback, if the development is clustered on the least sensitive portion of the parcel (the area landward of the saltwater slough classified as disturbed), if the stipulated modifications are incorporated, and if the access bridge is reduced in width from twelve feet to six feet. RECDATION Based on the foregoing Findings of Fact and Conclusions of Law, it is RECOMMENDED that the Florida Land and Water Adjudicatory Commission enter a final order that adopts the findings of fact and conclusions of law contained herein and denies the subject development order number 9220003617. The permit can be approved if the Fagas choose to modify its application to conform to the findings and conclusions contained herein. DONE AND ENTERED this 1st day of November, 1995, in Tallahassee, Leon County, Florida. C ZjDE B . ARRINGTON Hearing Officer Division of Administrative Hearings The Desoto Building 1230 Apalachee Parkway Tallahassee, Florida 32399-1550 (904) 488-9675 Filed with the Clerk of the Division of Administrative Hearings this 1st day of November 1995. 23 ENDNOTES 1 These exhibits were pre -marked by the Petitioner using its own marking system. 2 The site plan referred to in the stipulation is dated July 9, 1993, and was submitted to the Petitioner by the County as part of the permitting file. 3 The Aslan survey was prepared on behalf of the Fagas by Aslan,.Inc., a professional land surveying corporation. 4 See, Section 9.5-345(m), M.C.C., discussed above. Respondents established that the mangrove fringe is not subject to tidal influence and that, consequently, the mangrove fringe does not meet the following definition of "mangrove community" found at Section 9.5-4 (m-3), M.C.C.: Mangrove community means a wetland plant association subject to tidal influence where the vegetation is dominated by one (1) or more of the following three (3) species of mangroves . . . 5 The provisions of Section 9.5-286, M.C.C., do not Petitioner did not introduce a apply nesting to this proceeding because inventory approved by the Monroe County planning director or by the Florida Freshwater Fish and Game Division. Section 9.5-286, M.C.C. provides, in pertinent part, as follows: (c) No structure other than docks shall be located within fifty ( 5 0 ) feet of any shoreline area which is known to serve as an active turtle nesting or resting area for marine turtles. Active nesting area" is defined as one that has appeared on (a competently prepared) nesting inventory (approved by the planning director and Florida Freshwater Fish and Game Division) at least once within the previous three (3) years prior to the development application. . APPENDIX TO RECOMMENDED ORDER,.CASE NO. 94-2560DRI The following rulings are made as to the proposed findings of fact submitted by the Petitioner. 1. The proposed findings of fact in paragraphs 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 17, 20, 22, 23, 30, 33, 43, 46, 47, 24 Feb C.gr 10:35 F. 03 48, 55, S6, 57, 65, 66, 67, 69, 77, 81, 84, 86, and 88 are adopted in material part by the Recommended Order. 2. The proposed findings of fact in paragraph 13 are adopted in part by the Recommended Order, but are rejected to the extent they are unnecessary to the conclusions reached. 3. The proposed findings of fact in. paragraphs 14, 16, 21, 25, 26, 27, 28, 29, 31, 32, 34, 35, 36, 37,38, 39, 41, 42, 44, 45, 491 50, 51, 52, 53, 54, 58, 59, 60, 61, 62, 63, 64, 68, 70, 71, 721 75, 76, 78, 79, 80, 82, 85, 87, 89, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99, 101, and 102 are subordinate to the findings made. 4. The proposed findings of fact in paragraphs 15 and 18 are rejected as being contrary to the findings made. 5. The proposed findings of fact in paragraph 19 are adopted in part by the Recommended Order, but are rejected to the extent they are contrary to the findings made. G. The proposed findings of fact in paragraphs 24, 40, 73, 74, 83, 103, and 104 are rejected as being unnecessary to the conclusions reached. 7. The proposed findings of fact in paragraph 100 are rejected as being unsubstantiated by the evidence. The following rulings are made as to the proposed findings of fact submitted by the Fagas. 1. The. proposed findings of fact in paragraphs 1, 2, 3, 41 5, 6, 7, 8, 91 10, 11, 17, 181 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 32, 39, 40, 42, 60, and 62 are adopted in material part by the Recommended order. 25 Feb 15 1CI: --S6 F..-Ja 2. The proposed findings of fact in par -graph 12 are adopted in part by the Recommended Order and rejected in part as being unnecessary to the Conclusions reached. 3. The proposed findings of fact in paragraphs 13, 14, 15, and 16 are rejected as being unnecessary to the conclusions reached. These proposed findings attempt to establish a bias on the part of the Petitioner in an attempt to impugn its motive and impeach its main witnesses. This argument pertaining to bias lacks credibility and is, consequently, rejected. 4. The proposed findings of fact in paragraphs 29, 30, 33, 34, 351 36, 37, 38, 46, 47, 48, 54, 57, 59, and 64 are rejected as being contrary to the findings made. S. The proposed findings of fact in paragraphs 31, 41, 49, So, 51, 52, 56, and 63 are subordinate to the findings made. 6. The proposed findings of fact in paragraph 43 are adopted in material part by the Recommended Order or are subordinate to the findings made. 7. The proposed findings of fact in paragraphs 44, 4.5, 55, and 58 are rejected as being unnecessary to the conclusions reached. 8. The proposed findings of fact in paragraph 53 are rejected as being unnecessary to the conclusions reached or as being contrary to the greater weight of the evidence. 9 The proposed findings of fact in paragraph 61 are adopted in part by the Recommended Order. The proposed findings pertaining to the pilings ignores the differences in width and load capacity between the access bridge and a walkway and are, consequently, rejected as being unsubstantiated by' the evidence. 26 V e , s COPIES FURNISHED: Stephanie M. Gehres, Esquire Department of Community Affairs 2796 Overseas Highway, Suite 212 Marathon, Florida 33050 Terrell Arline, Esquire Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 J.A. Jurgens, Esquire Post Office Box 1178 Winter Park, Florida 32790 Michael L. Gore, Esquire Michael J. Grindstaff, Esquire Shutts & Bowen 20 North Orange Avenue, Suite 1000 Orlando, Florida 32801 James T. Hendrick, Esquire 317 Whitehead Street Key West, Florida 33040 Grill Construction, Inc. 784 Duck Key Drive Duck Key, Florida 33050 Carolyn Dekle Director Council South Florida Regional Planning 3400 Hollywood Boulevard, Suite 140 Hollywood, Florida 33021 Bob Bradley, Secretary Florida Land & Water Adjudicatory Commission 2105 The Capitol Tallahassee, Florida 32399-0001 Gregory C. Smith, Esquire Governor's Legal Office 209 The Capitol Tallahassee, Florida 32399-0001 James F. Murley, Secretary Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Dan Stengle, General Counsel Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 27