Item B1
* BOCC SPECIAL MEETING *
* CLOSED SESSION 9:00 A.M. *
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: 2/26/13 MAR Division: County Attorney
Bulk Item: Yes No XX Staff Contact Person: Bob Shillinger, 292-3470
AGENDA ITEM WORDING:
An Attorney-Client Closed Session in the matters of:
1) Monroe County v. Utility Board of the City of Key West, dba Keys Energy Services, Case No.
CA-K-12-549;
2) Alicia Roemmele-Putney, et al. v. Robt. D. Reynolds, et al., Case No.: 3D12-333(formerly
styled as Roemmele-Putney, et al. v. Monroe County, et al., Case No. 3D12-333, Lower
Tribunal Case No. CA-K-11-342);
3) Reynolds v. Utility Bd. of the City of KW, dba Keys Energy Services, PSC Docket No.120054-EM;
4) James B. Newton, Ruth L. Newton, Robert D. Reynolds and Julianne C. Reynolds v. Monroe
County, Case No. 2013-CA-86-K; and
5) An administrative appeal by James D. Newton, re: Property at 2047 Bahia Shores Road, No
Name Key, Planning Department File No. 2012-096 also styled as James B. Newton & Ruth
Newton, Appellants, v. Monroe Co. Planning Commission, Appellee, DOAH Case No.13-
000083.
ITEM BACKGROUND:
Per F.S. 286.011(8), the subject matter of the meeting shall be confined to settlement negotiations or
strategy sessions related to litigation expenditures.
Present at the meeting will be the County Commissioners, County Administrator Roman Gastesi,
County Attorney Bob Shillinger, Assistant County Derek Howard, Assistant County Attorney Susan
Grimsley, Assistant County Attorney Steve Williams, special litigation counsel Mike Burke and a
certified court reporter.
PREVIOUS RELEVANT BOCC ACTION:
2/20/13 BOCC approved a Closed Session to be held at the BOCC Special meeting on 2/26/13 at 9:00
a.m. in Marathon, FL
CONTRACT/AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATIONS:
N/A
TOTAL COST: INDIRECT COST:_____BUDGETED:
Court Reporter costs Yes X No _____
DIFFERENTIAL OF LOCAL PREFERENCE: _______________________________________
COST TO COUNTY: SOURCE OF FUNDS:
Court Reporter costsGeneral Funds
REVENUE PRODUCING:AMOUNT PER MONTHYear ____
Yes No X
APPROVED BY:
County Atty X OMB/Purchasing Risk Management ____
DOCUMENTATION:
Included Not Required X
DISPOSITION:AGENDA ITEM #
Revised 2/05
The Solar Community of No Name Key
1 934 No Name Drive
No Name Key, Florida 33043
Monroe County Board of County Commission Special Meeting
February 26, 2013 — Marathon, Florida
Agenda Item B -1 and C -1 and D -3
Dear Mayor Neugent and Fellow Commissioners:
We have reviewed the materials in the binder that was recently distributed by Commissioners
Rice's office. Important information is not included in this binder. We have also reviewed the
back -up materials for today's agenda. Important information is also missing from the back-
up materials.
As an aside, there were over 135 pages of information in the back -up materials for today's
agenda. This information was made available to the public this past Friday, February 22,
2013. We do not feel this is enough time for us, or for this Board, to review and digest all of
the information provided for today's agenda items.
We ask they you please consider the additional information we will be providing today prior
to making up your minds on these important issues.
For the record, we would like to call your attention to Section 102- 185(d) Appeals, which
states:
"Section 1o2- 185(d) Effect of filing an appeal.
The filing of a notice of appeal shall stay all permit activity and any proceedings in furtherance
of the action appealed from unless the administrative official rendering such decision,
determination or interpretation certifies in writing to the commission and the applicant that a
stay poses an imminent peril to life or property, in which case the appeal shall not stay further
permit activity and any proceedings. The commission shall review such certification and grant
or deny a stay of the proceedings."
Recently the adjacent property owners were notified of an Appeal to the Planning Department
by Robert and Julianne Reynolds regarding a permit to connect their house to the power
poles recently installed on No Name Key by Keys Energy Services. (KES) (File Number 2013-
024.) This Appeal may have the effect of staying any action that would allow the connection of
the 22 homes on No Name Key to the KES power poles. Not being sure of its affect on today's
proceedings, we decided to be cautious and make it part of the record.
B -1: It is a Poor Idea to Ignore the Public Service Commission (PSC) Hearings
The County could decide not to participate in all of the matters currently before the PSC.
This would be a very risky decision. It would mean that Monroe County is willing to hand
over their Home Rule to an appointed Board in Tallahassee. It would also mean the County
would not have the authority to enter into agreements with utility providers without in put
from the PSC. The County needs to present its solid legal arguments to the PSC. None of the
pending suits should be ignored. This issue is reaches far beyond the scope of No Name Key.
C -1: A Settlement Agreement in Conflict with the CBRS Overlay District Ordinance is Illegal
The County could conceivably decide to enter into a Settlement Agreement to end the ongoing
litigation by allowing the 22 homes to hook into the power lines on No Name Key, but that
would be against the law.
It is clearly an illegal act for a local government to enter into a Settlement Agreement if the
agreement is in violation of the local Code. Any agreement that would allow the hook -up of
the 22 houses to the newly placed infrastructure on No Name Key would be considered
contract zoning which is highly illegal.
We wrote Attorney Robert Hartsell yesterday for confirmation that the County cannot legally
enter into a Settlement Agreement that would be in conflict with the CBRS Overlay District
ordinance.
Given Mr. Shillinger's advice at the BOCC meeting on December 12, 2012, when the issue of a
settlement agreement was first raised, we would imagine he would agree with the case law in
the attached letter from Mr. Hartsell dated February 24, 2013. (See attached Letter to Alicia
Roemmele- Putney from Attorney Hartsell dated February 24, 2013 regarding Contract
Zoning.)
D -3: A Legislative Interpretation Based on Erroneous Fact is Not Allowed Under the Law
As described in Option C of Agenda Item D-3, Staff is including the option of making a
legislative finding that a conflict exists between the language in the Year 2010 Comprehensive
Land Use Plan and the Monroe County Code. It is further explained by Staff that such a
Finding could be use to initiate an amendment to the Code to eliminate Section 130 -122 MCC,
the CBRS Overlay District ordinance. This would allow the immediate hook-up of the 22
houses to the commercially supplied power on No Name Key.
Option C is a poor idea for a multitude of reasons. First, this Board would be misapplying
Section 163.3194 FS, which exists as an interim solution where a newly adopted
Comprehensive Plan is more restrictive than the not -yet updated Land Development
Regulations, or visa versa.
More importantly, this Board would be making a Finding that is not supported by Facts.
A conflict between the language in the Year 2010 Comprehensive Plan and the MCC Section
130 -122 clearly does NOT exist for the following reasons.
1.) In plain English "discourage" and "prohibit" are not opposing, they are gradations of the
negative. "Encourage" and "prohibit" or "discourage" and "allow" are opposing and therefore
would be in conflict.
2.) Comprehensive Land Use Plans are policy documents and are by definition more general
in nature than the Land Development Code, which implements the policies of the Plan and
are more specific in nature.
3.) The Year 2010 Comprehensive Land Use Plan includes Policy 1301.7.12, which includes
both the words "discourage" and "prohibit." This alone clearly demonstrates there is no
conflict between the Year 2010 Comprehensive Land Use Plan and the Monroe County Code.
Policy 1301.7.12 states:
"By January 4, 1998, Monroe County shall initiate discussions with the FKAA and
providers of electricity and telephone service to assess the measures, which could be
taken to discourage or prohibit extension of facilities and services to Coastal
Barrier Resources Systems (CBRS) units." (Year 2010 Comprehensive Plan, Adopted
on January 4, 1996.)' Note: the highlighting was added for emphasis.
4.) On December 19, 2001 the original CBRS Overlay District ordinance 043 -2001 was
unanimously adopted by the BOCC.
After adoption it was sent to the Department of Community Affairs (DCA) for review. The
DCA found the original ordinance to be consistent with the Year 2010 Comprehensive Plan.
The DCA Final Order No.: DCA02- OR -o32 includes Finding of Fact number 3 that states:
"Ord. 043 -2001 is consistent with the County 2010 Comprehensive Plan." (See
attached DCA Final Order No.: DCA02- OR -o32.)
5.) On September 17, 2008, the BOCC (3 -2) amended the CBRS Overlay District ordinance by
creating Ordinance No. 020 -2008. which lifted the prohibition against the extension of a new
infrastructure to or through CBRS units.
On December 12, 2008. the DCA REJECTED the amended ordinance because lifting the
prohibition would made the ordinance inconsistent with the Year 2010 Comprehensive Land
Use Plan's policies to discourage both private and public investments in CBRS units for new
or expanded facilities.
The DCA Final Order No.: DCA08 -OR -352 includes Finding of Fact number 7 that states:
"Section 163.3202, Florida Statutes, however, requires that land development
regulations contain specific and detailed provisions necessary to implement the
adopted comprehensive plan which discourages the extension of facilities and utility
services to CBRS units and prohibits public expenditures for new or expanded facilities
areas designated as unites of CBRS except for expenditures necessary for public health
' In fact, Acting Planning Director Antonia Gerli took this action on January 31, 1996 in a Letter to Mr. Dale Finigan listing
the CBRS policies. And, Monroe County Administrator James Roberts also took this action on August 2, 1996 when he
wrote the Utility Board of the City of Key West stating that: "Also, you should know that the Monroe County
Comprehensive Plan as adopted has policies that are clearly not in support of such an extension of electric service. Please
see attachments. Therefore, I must suggest to you that the County does not support extension of electric service to No Name
Key."
and safety. While the County's Comprehensive Plan does not prohibit the extension of
facilities and services into CBRS units, Ordinance 020 -2008 conflicts with the County's
policies discouraging both private and public investments in CBRS units for new or
expanded facilities." (See attached DCA Final Order No.: DCA08 -OR -352.)
On February 18, 2009, the BOCC (5 -0) RESCINDED Ordinance No. 020 -2008. This means
that the original wording of Ordinance 043 -2001 remains in place and still stands as
consistent with the Year 2010 Comprehensive Land Use Plan.
In closing, please see the attached 02/25/2008 letter from Attorney Hartsell to Attorney
Shillinger regarding Agenda Item D -3 and which cites the applicable law to substantiate the
above statements as to why Option 3 is not available to this Commission.
Thank you for you interest in this matter.
Sincerely,
Alicia Roemmele- Putney, Presiden
The Solar Community of No Name Key
872 -8888
Attachments:
•Letter to Alicia Roemmele- Putney from Attorney Hartsell dated February 24, 2013 regarding
Contract Zoning, 2 pages.
.Department of Community Affairs Final Order No.: DCA02- OR -o3, 6 pages.
•Department of Community Affairs Final Order No.: DCA08 -OR -352, 7 pages.
•Letter to Attorney Shillinger from Attorney Hartsell dated February 24, 2013 regarding
Agenda Item's D -3 "Option C ", 2 pages.