Case Nos. APP-94-106 & APP-95-001STATE OF FLORIDA
FLORIDA LAND AND WATER ADJUDICATORY DIVISION
DEPARTMENT OF COMMUNITY AFFAIRS,
Petitioners,
VS.
BRIAN SULLIVAN, Owner, and SEAMARK
CONSTRUCTION COMPANY, INC., General
Contractor; and MONROE COUNTY, a
political subdivision of the State
of Florida,
Respondent.
CASE NO. APP-94-106
APP-95-001
SETTLEMENT AGREEMENT
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This Agreement is entered into by and between BRIAN SULLIVAN,
Owner/Developer; MONROE COUNTY, Florida, a political subdivision of
the State of Florida; and the DEPARTMENT OF COMMUNITY AFFAIRS ("the
Department" or "DCA").
W I T N E S S E T H:
WHEREAS, BRIAN SULLIVAN is the owner of real property known as
lots 8, 9, 45, 46, 47 and 48, Block 4, Cutthroat Harbour Estates,
Cudj oe Key ( "the subject property") within the Florida Keys Area of
Critical State Concern; and
WHEREAS, on October 5 and November 22, 1994, respectively,
Monroe County issued building permits nos. 9410000776, 9410000775,
9410000777 authorizing development of single family residences on
the subject properties; and
agreement/sullivan.agm 10/20/95 1
WHEREAS, on December 27, 1994 and January 6, 1995, the
Department timely appealed the permits to the Florida Land and
Water Adjudicatory Commission; and
WHEREAS, the Department 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, including the
Monroe County comprehensive plan and land development regulations
in the Florida Keys Area of Critical State Concern; and
WHEREAS, pursuant to Section 380.032(3), Florida Statutes, the
Department 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, BRIAN SULLIVAN will acquire certain real property
that is not the subject of this appeal, located in the Lower Keys
of Monroe County, Florida, which is less environmentally sensitive
and more suitable for single family residential development than
the subject property, and
WHEREAS, BRIAN SULLIVAN received an award under the County's
Dwelling Unit Allocation Ordinance ("ROGO") authorizing
construction of three (3) single family homes, which received
positive points for lot aggregation, low volume plumbing, exceeding
the base flood elevation by one foot, and ability to sustain a wind
load of greater than 130 mph, and
agreement/sullivan.agm 10/20/95 2
WHEREAS, Monroe County has applied for and received funding
from State of Florida, Department of Community Affairs, Florida
Communities Trust, to assist the County in acquisition efforts to
purchase environmentally sensitive lands unsuitable for
development, and
WHEREAS, Monroe County, in coordination with the Monroe County
Land Authority, has elected to purchase the lots that are the
subject of this appeal for conservation purposes, at a purchase
price of $18,393.00 which represents the actual investment by the
owner, and
WHEREAS, the parties wish to avoid the expense, delay and
uncertainty of litigation and resolve the above -styled development
order appeal and related issues under the terms and conditions set
forth herein, and it is in their best interests to do so; and
WHEREAS, the Department finds that this agreement is in the
best interests of the state and is necessary to effectuate the
provisions and purposes of Chapter 380, Florida Statutes.
NOW, THEREFORE, in consideration of the mutual promises and
undertakings contained herein, the receipt and sufficiency of which
are hereby acknowledged, the parties agree as follows:
1. Recitals. The above recitals are incorporated herein and
form a material part of this agreement.
2. The parties agree that the subject properties include
environmentally sensitive lands that are not desireable for
development of single family homes.
agreement/sullivan.agm 12/19/95 3
3. Pursuant to this Settlement Agreement, the parties agree
that the subject single family homes shall and must be permitted in
the Lower Keys at other sites owned by Mr. Sullivan that are
comprised of disturbed uplands that are less environmentally
sensitive and more suitable for single family development, are each
served by paved roads, electric lines and FKAA water lines (all
existing on the effective date of this agreement) and are in a
recorded, platted subdivision designated "IS" on the County's Land
Use District Map, not to include any sites on Big Pine Key.
4. Under the unique circumstances of this case, Mr. Sullivan
shall be allowed to transfer his "ROGO Award" received under the
County's Dwelling Unit Allocation Ordinance (permitting development
of the subject single family houses) from the subject property to
the less environmentally sensitive site, identified in paragraph 3,
above, within two (2) years of the effective date of this
agreement. Mr. Sullivan will not be required to submit a new
application for a new ROGO award in order to build the same houses
at the new site. The County will process a refund request for all
application, permitting and impact fees previously paid and
applicable fees will be assessed at the new locations when permits
are issued.
5. Mr. Sullivan may revise the subject site plans as
necessary to accommodate construction of the single family homes at
the new sites, but in no event shall the subject site plans be
revised or altered with respect to the structural design components
(excluding lot aggregation) that contributed to or caused
assignment of positive ROGO points. Mr. Sullivan shall obtain
agreement/sullivan.agm 12/19/95 4
a building permit for single family development on the new site
within two (2) years of the effective date of this Agreement.
6. The County shall utilize funds received from State of
Florida, Department of Community Affairs, Florida Communities Trust
for the purpose of acquiring land in Monroe County rendered
undesirable for development by operation of the Dwelling Unit
Allocation Ordinance, to purchase the subject property. Said
purchase shall occur no later than six (6) months from the
effective date of this Agreement.
7. Further Proceedings. Within five (5) working days after
an amended development order consistent with this agreement is
rendered to the Department, the Department shall file a notice of
voluntary dismissal of this appeal and seek a final order from the
Florida Land and Water Adjudicatory Commission concluding this
appeal proceeding. By their signatures hereon, the parties to this
agreement join in any request to place this matter in abeyance
pending issuance of an amended development order and the filing of
a notice of voluntary dismissal, and join in any request for entry
of a final order consistent with this agreement.
8. 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 settlement 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
agreement/sullivan.agm 10/24/95 5
with regard to the proper interpretation and implementation of
statutory and regulatory provisions relating to areas of critical
state concern. This agreement shall not be given precedential
effect with regard to any other development orders for other
projects in an area of critical state concern.
9. Retention of Right to Final Hearing. Should any party
fail to implement this agreement within the time periods prescribed
hereunder, or if this agreement is based upon materially false or
inaccurate information, any party shall be entitled to withdraw
from this agreement and seek.a final hearing in this case by motion
filed with the Florida Land and Water Adjudicatory Commission.
10. Certification of Understanding and Voluntary Execution;
Release; Costs and Attorney's Fees. The parties and/or their
authorized representatives each certify that they have read and
understand 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, disputes or otherwise, which
could have been asserted against the other party as a result of the
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 building permit nos.
9410000776, 9410000775, 9410000777. Each party shall bear its own
costs and attorney's fees incurred in this proceeding.
11. 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
agreement/sullivan.agm 10/20/95 6
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.
12. Scope of Authority_. This Agreement affects the rights
and obligations of the parties under the provisions of 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.
13. 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.
14. Binding Effect; Recordation of Agreement. This Agreement
shall be binding on the parties, their heirs, successors and
assigns. Within ten (10) days after entry of a final order by the
Florida Land and Water Adjudicatory Commission concluding this
appeal, the Owner shall record this Agreement in the Public Records
of Monroe County, Florida, and shall promptly provide proof of
recordation to Monroe County find the Department, including the
official records book and page where this Agreement is recorded.
Proof of recordation shall be furnished by hand delivery or U.S.
Mail, postage prepaid to the County by directing same to Antonia
Gerli, Acting Planning Director, 2798 Overseas Highway, Marathon,
agreement/sullivan.agm 10/20/95 7
Florida 33050, and to the Department by directing same to Mike
McDaniel, Growth Management Administrator, Region 2, Division of
Resource Planning and Management, Department of Community Affairs,
2740 Centerview Drive, Tallahassee, FL 32399-2100, or to such other
person or address as the County or Department may hereafter direct
in writing. Communications to the Owner/Developer regarding this
agreement and the development authorized thereby shall be directed
to Mr. Brian Sullivan, Post Office Box 421063, Summerland Key,
Florida 33042.
15. Entirety of Agreement/Amendment. This Agreement
constitutes the entire agreement of the parties. This Agreement
may be modified or amended only by a separate writing signed by all
parties hereto.
16. Effective Date of Agreement. The effective date of this
Agreement is the date the last party signs this agreement.
IN WITNESS WHEREOF, the parties, by their duly authorized
undersigned representatives, have executed this Agreement on the
dates and year below written.
agreement/sullivan.agm 10/20/95 8
v 13AJ5�
Date
STATE OF FLORIDA
COUNTY OF LEON
DEPARTMENT OF COMMUNITY AFFAIRS,
An Agency of the State of Florida
'C
.�:(/l, by ; G�tPa.�') Opt
Charles G. Pattison
Director, Division of Resource
Planning and Management
This instrument was acknowledged before me this /37'A- day of
✓ r , 199k, by Charles Pattison, as Director, Division of
Resource P10anning and Management, Department of Community Affairs,
who is personally known to me and who did not take an oath.
"t&ry Public
Name (typed, printed or stamped)
c� 36 16 /S
Commission Number
My commission expires:
agreement/sullivan.agm 10/20/95 9
- cL•i/� CSX f
W ess r
Witness
STATE OF FLORIDA
COUNTY OF MONROE
BRIAN SULLIVAN, Owner
Date:
The fore in instrument was acknowledged before me this
day of r , 1995, by BRIAN SULLIVAN, who is
ersonal y m r has produced
as i en 1 on and did (did not) take an oath.
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NofAIre ! ' _ tR. �)M
,Ptl�l Gr n{� �Q
`:BiV,CB
G�UJSJV
agreement/sullivan.agm 10/20/95 10
Notary ublicic /
Name (typ#d, printed or stamped)
Commission Number
My Commission Expires:
6
MONROE COUNTY
APPNO 'DAS : J FM By:Ma
LWALSU =P"'. Monroe Coun Board of
nCounty Commissioners
Date:
STATE OF FLORIDA
COUNTY OF MONROE
A The fore o'nc in was acknowlpd ed_befoxe me t$is
day of , 199N4 by
who is e 1 kn wn o or who has producey _
as identification, and who did (did not) take an oath.
dw
Notary Pu is
agreement/sullivan.agm 10/20/95 11
RuWh -An n ?av ri me n
Name (typed, printed or stamped)
CC 50(n 3,a5
Commission Number
My commission expires: 1430199
C
f pL Rl_iTHANN JANTZ�N
°�� My Corrun Exp. 12/30/99
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No. CC506335
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