Item P2BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: March 20, 2013 Division: Growth Management
Bulk Item: Yes NoX Department: Plam'na & Environmental resources
Staff Contact Person/Phone ##: Christine Hurley — 289-2500
AGENDA ITEM WORDING: A public hearing to consider an Ordinance to amend Section 138- ) of the Monroe
County Code to clarify that, in addition to hotels, lawful transient Residential Rate of Growth Ordinance (ROGO)
exemptions (TRE's) may be transferred to recreational vehicle (RV) parrs.
ITEM BACKGROUND. Comprehensive Plan Policy 101.5.8 establishes the parameters of a THE program. The
policy allows for the transfer off -site of dwelling units, mobile homes, hotel rooms, motel rooms, RV spaces, and
campground spaces, provided that the units to be transferred are lawfully established. The Comprehensive Plan does not
prohibit the off` -site twsfer of TEE's associated with transient residential units to ITV park developments. However,
currently, the Land Development Code only allows the transfer of TRE's to hotel developments and as such, indirectly
prohibits the transfer of Tl 's to RV park developments.
Allowing transient residential units to be transferred off -site to hotel developments, but not RV parry developments, is in
conflict with the definition of transient residential unit, which includes a hotel/motel room and a space for parking a
recreational vehicle or travel trailer. Further, the impacts of a hotel and RV park are similar and staff could not find any
purpose in limiting the transfer of TRE's to hotel developments.
1n addition to other existing criteria related to tier and flood zone, the transfer of TIDE' s would be limited to the same
LOGO subarea, with the exception that ROGO exemptions associated with transient residential units may be transferred
from the Big pine and No Name Key ROGO subarea to the Rawer Keys ROGO subarea (however not from the Lower
Keys ROGO subarea to the he Big pine and No Name Key ROGO subarea). The County has adapted numerous
Comprehensive Plan policies, the Big pine Key and No Name Key Habitat Conservation Plan and the Big pine Key and
No Name Key Livable CommuniKeys Community Master plan to address the special environmental issues associated
with Big Pine and No Name Keys, including those related to protection of federally -protected species, the prioritization of
acquiring habitat areas and the prevention of further encroachment on natural resources. Allowing the transfer of transient
residential units from Big Pine Key and No Dame Key to other locations within the Lower Keys sub -area (which Big Pine
and No Dame Key were originally part with the adoption of ROGO in 1992, but later separated into an independent
ROGO subarea) will facilitate the County's goal of implementing the adopted regulatory documents - by reducing the
number (and impact) of transient residential units.
During a regularly scheduled meeting held on December 18, 2012, the Monroe County Development Review Committee
reviewed the ordinance and recommended approval to the BOCC. During a regularly scheduled meeting held on
February 27, 2013, the Planning Commission reviewed the ordinance and recommended approval to the BOCC.,
PREVIOUS RELEVANT BOCC ACTION :None.
CONTRACT/AGREEMENT CHANGES: n/a
STAFF RECOMMENDATIONS: Staff recommends approval. ..
TOTAL COST: INDIRECT COST: BUDGETED: Yes No
DIFFERENTIAL OF LOCAL PREFERENCE.
COST TOCOUNTY:
REVENUE PRODUCING: Yes No
LYRE OF FUNDS* _.
4 AMOUNT PER MONTH Year
APPROVED BY: County Atty x OMB/Purchasing _ Risk Management
DOCUMENTATION: Included x Not required
DISPOSITION: AGENDA ITEM ##
MEMORANDUM
ONROE COUNTY PLANNING & ENVIRONMENTAL REsouRCEs DEPARTMENT
To: Monroe County Board of County Commissioners
Through: Christine Hurley, AI P, Director of Growth Management
Townsley Schwab, Senior Director of Planning & Environmental resources
From: Joseph Haberman, AI P, Planning & Development Review Manager
Date: February 28, 2013
Sub *e t: AN ORDINANCE BY THE MONROE COUNT BOARD OF COUNTY
COMMISSIONERS AMENDING MONROF COUN77 CODE SECTION 1 8-
( )} CLARIFYING THAT LA WF L TRANSIENT RESIDENTIAL RATE OF
GROWTH ORDINANCE (ROGO) EXEMPTIONS 1UY BE TRANSFERRED TO
RECREATIONAL VEHICLE (RV) PARKS, ', AS WELL AS A HOTELS;
PROVIDING FOR E FR BILIIT; PROVIDING FOR REPEAL OF
CONFLICTING PROVISIONS; PROVIDING FOR TRANSMITTAL TO THE
STATE LAND PLANNTNG AGENCYAND THE SECRETARY OF STATE;
PROVIDING FOR CODIFICA TI N; PR O VIDIN FOR AN EFFECTIVE DATE.
Meeting: March 20, 2013
1
I REQ ET
3
4 The Planning & Environmental resources Department is proposing amendments to the text
5 of 138- () of the Monroe County Code. The purpose of the proposed amendment is to
6 clarify that lawful transient residential late of Growth Ordinance (ROGO) exemptions may
7 he transferred to recreational vehicle parks, as well as hotels. In addition, the proposed
amendment would clarify other existing processes and improve the readability of the
9 subsection.
10
1 I II RELEVANT PRIOR COUNTY ACTIONS:
1
13 In part to provide regulations Outlining the Transfer of RO O Exemption (TRE) program,
14 the County established MCC § 13 - (formerly . -1 0).
15
16 During a regularly scheduled meeting held on December 18, 2012, the Monroe County
17 Development Review Committee reviewed the ordinance and reconu ended approval to the
18 BO.
1
0 ]wring a regularly scheduled meeting held on February 27, 2013, the Planning Commission
1 reviewed the ordinance and recommended approval to the BOCC.
22
23
Page I of 5 (File N20 1 2-1 65)
I IIl REVIEW
2
3 Comprehensive Plan Policy 101.5.8 establishes the parameters of a Transfer of RO O
4 Exemption (TRE) program. The policy allows for the transfer off -site of dwelling units,
mobile hones, hotel roams, motel rooms, recreational vehicle spaces, and campground
6 spaces, provided that the units to be transferred are lawfully established. The Comprehensive
7 Plan does not prohibit the off -site transfer of TRE's associated with transient residential units
to RV park developments. However, currently, the Land Development Code only allows the
transfer of TRE's to hotel developments and as such, indirectly prohibits the transfer of `
10 TRE's to RV park developments.
11
12 Allowing transient residential units to be transferred off -site to hotel developments, but not
13 RV park developments, is in conflict with the definition of tramient residential unit, which
14 includes a hotel/motel room and a space for parking a recreational vehicle or travel trailer.
15 Further, the impacts of a hotel and RV park are similar and staff could not find any purpose
16 in limiting the transfer of TRE's to hotel developments.
17
18 The transfer off -site of lawfully existing transient residential units would not conflict with
19 Comprehensive Plan Policy 101.2.6, as such a transfer does not create additional, new
0 transient units, but simply allows the transfer to another location. Further, for a pending
1 major hurricane (category -5), Monroe County implements a staged/phased evacuation
22 procedure to achieve and maintain an overall 4-hour hurricane evacuation clearance time for
23 the resident population, pursuant to Comprehensive Plan Policy 216.1.8. The evacuation
4 procedure for visitors staying at a hotel or motel room or a RV are mandated to evacuate 4
5 hours in advance of tropical storm winds (evacuate within the same phase).
2
7 In addition to other existing criteria related to tier and flood zone, the transfer of TRE's
28 would be limited to the same RD O subarea, with the exception that RD D exemptions
9 associated with transient residential units may be transferred from the Big Pine and No Name
30 Key ROGO subarea to the Lower Keys ROO subarea (however not from the Lower Keys
31 RDO subarea to the he Big Pine and No Name Key ROO subarea). The County has
32 adopted numerous Comprehensive Plan policies, the Big Pine Ivey and No Dame Key
33 Habitat Conservation Plan and the Big Pine Key and No Name Ivey Livable CommuniKeys
34 Community Master Plan to address the special enviromnental issues associated with Big Pine
35 and No Name Keys, including those related to protection of federally -protected species, the
36 prioritization of acquiring habitat areas and the prevention of further encroachment on natural
37 resources. Allowing the transfer of transient residential units from Big Pine Key and No
38 Dame Key to other locations within the Lower Keys sub -area (which Big Pine and No Name
39 Key were originally part with the adoption of RDGO in 1992, but later separated into an
40 independent ROD subarea) will facilitate the ounty's goal of implementing the adopted
41 regulatory documents - by reducing the number (and impact) of transient residential units.
4
43 Therefore, staff recommends the following changes (Deletions are { t r c k eT E 4�and
44 additions are underlined. Text to remain the same is in black):
4
46 See. 138-2 * Type of development not affected.
Page 2 of 5 (Rile ##2012-165)
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The residential ROGO shall not apply to the development described below:
(2) Transfer of, -site. Transfer off site shall consist of either the demolition of a dwelling unit
on s rter a change of use i rem rig ii E ttn oEt l€]
OR 1' < -r -' f the floor area of dwelling unit on a sender site to another permitted use in
the applicable land use zoning) district that does not require the ROGO exemption and the
development of a new transient residential unit or affordable housin unit on a receiver site
as follows }
a. Eligibility of sender unit or space. In order to be an eligible sender unit or space, the
unit or space shall be a A hotel room, motel room, camj2ground space, recreational
vehicle space, mobile home, or dwelling unitFcnnpp
t rat is found to have been lawfully established pursuant to subsection .
b. Criteria for redevelopment of -site. i �e a - I V er S}
j+ r
4 r 1° u a f: iZ 9 ■ +' 1. ri'-3 T7 Z':.
1. Transfer to a hotel, motel, or recreational vehicle park+ lawfull
established hotel room, motel room, cannparound space, or recreational vehicle
space ma be ,�e eEe transferred off -site to another hotel} motel or recreational
yeWc le park if the:
(i) The sender S unit is an eligible _c cm tic and .%wr%rk tL
. 'was
used as a transient residential unit in accordance with section 101-1;
and
(ii) The receiver Reel ver site/unit meets all of the following criteria:
(AA) 4s The receiver site is located in the same ROGO o subarea as the sender
site, with the exception that ROGO exemptions associated with transient
residential dwelling _units Emav be transferred from the Big Pine and No
Name Kerr ROGO subarea to the Dower lees Roo subarea}
(BB) -w4h-k-P T receiver unit _shall onlye con tt-ucted within a) a tier III
designated area or ' ' a tier III -A (special protection area) designated
area _ where the development does not involve the
clearing of any pkeFtwn -&I . [in- Ups native habitat patch el - ooe ifttaj Lrea r .
Ise L �$ and
� e � raa zfr r. S
CC) The receiver unit shall not be constructed within a velocity (V) zone.
. Transfer to affordable housing. A_ia fully established d eliing unit_may be
transferred off -site 1 t e all itb:e h us kii� revel i t f Ily
4L jJ
TI�3'LLTL. �j % . _�. T a
i The sender uni( is an eligible ROGO exemption and provided that it was used
as a permanent residential _ unit_i n_accordance with section 101 - 1_3 and
(iij The receiver site meets all of the followin criteria:
(AA) The receiver pfepesed unit is shall be an affordablelousing unit
pursuant to sections 1014 and 130-1 1;
(BB) The receiver site is located in the same ROGO subarea as the
sender site;
Page 3 of 5 (File #2012-16 )
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�Cc�,in The receI.
iver unit shall only be constructed within aka
tier III designated area or within a tier 111-A (special protection area)
designated area fly _ where i p t does_not
involve the clearing of any portion native habitatsof en k!
(l�l��receiver unit shall not be constructed within q�, , f f, hli a velocity
(V) zone,
Procedresor transfer off -site.
1, A � - 12re-ap�l iatio conference and, a nYinor
conditional use pennit approval shall be required for both the sender site and the
receiver site. The minor conditional use for the transfer shall be reviewed pursuant
to = ntt standards in this �n subsection and not _ f4N." the standards
provided in section 110-6 7. R e � %e . - P
• �m�, . s dart of the
minor conditional use Nrmit ap roval process, mailing of notice shall be required
to owners of real propegy located within 300 feet of the receiver site and owners of
real pro grty. jocated within 300 feet of the sender site. The receiver shall he Pwed
in accordance with sections 11 0-5(h) and 110-6 . posting of notice, as required. to
section 11 0-5(f) shall be required for the receiver site, but not the sender site.
2. A sender unit shall be assigned a unique identifier number that shall be used for
tracking and monitoring by the planning department. Multiple units to be
transferred from a sender site to a sinal a receiver site may be authorized under a
single minor conditional use permit approval. The unique identifier number shall be
itemized to the minor - conditional use permit develoment orders and _ buildi j �
permits required for both the sender and receiver sites.
L
Conditions for issuance of ` permit. No building permit shall be issued for the new
transient residential unit or affordable housing unit on the receiver site until one of the
following conditions is met:
1. The dwelling unit to be transferred is demolished as per an issued demolition permit
and a final inspection of the demolished or removed dwelling unit or space has been
completed by all necessary county staff n e ` .
. The structure in which the dwel l ins unit to be transferred is located is converted to
another permitted use as per an issued building permit and a final certificate of
occupancy for the conversion has been issued Ee fie
- I ,
_
e
�,a. n, ' _ .. r- ' ��. _ ._ �bz st rati n of a sender site eonsxstent with an approved
restoration/re-vegetation plan.
Page 4 of 5 (File #2012-165)
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IV RECOMMENDATION
Staff has found that the proposed text amendment would be consistent with the Principles for
Guiding Development in the Florida Keys Area of Critical State Concern, the Monroe
County Comprehensive Flan and the Monroe County Code.
Further, staff` has found that the proposed text amendment would be 1n compliance With the
provisions of § 10 -1 d)(5)(b)t 1 a Changed projections (e.g., regarding public service
needs) from those on which the text or boundary was based; 2. Changed assumptions (e.g.,
regarding demographic trends); 3. Data errors, including errors in mapping, vegetative types
and natural features described in volume I of the plan; 4. New issues- 5. Recognition of a
need for additional detail or comprehensiveness; or 6. Data updates. Specifically, staff has
found that the proposed text amendments are necessary due to a recognition of a need for
additional detail or comprehensiveness.
Staff recommends that the Board of County Commissioners amend the Monroe County Code
as stated in the text of this staff report.
Page 5 of 5 (File # 01 -165)
MONR E COUNTY, FLORIDA
IHNR E COUNTY BOARD OF COUNTY COMMISSIONERS
ORDINANCE NO.
AN ORDINANCE BY THE M NROE COUNTY BOARD OF
COUNTY COMMISSIONERS AMENDING MONROE COUNTY
CODE SECTION I38- 2( )-* CLARIFYING THAT LAWFUL
TRANSIENT RESIDENTIAL RATE OF GROWTH ORDINANCE
(ROGO) EXEMPTIONS MAY BE TRANSFERRED TO
RECREATIONAL VEHICLE (RV) PARKS, AS WELL AS A
MOTELS* PROVIDING FOR EVERABILITY-o PROVIDING FOR
REPEAL OF CONFLICTING PROVISIONS; PROVIDING FOR
TRANSMITTAL TO THE STATE LAND PLANNING AGENCY
AND THE SECRETARY OF STATE; PROVIDING FOR
ODIFI ATION-o PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, Monroe County Comprehensive Plan Policy 101.5.8 establishes the parameters of
a Transfer of ROO Exemption (TRE) program, which allows for the transfer off -site of hotel
rooms,, campground spaces and/or recreational vehicle (RV) spaces to another site provided that
the units to be transferred were lawfully -established-, and
WHEREAS, the Monroe County Comprehensive Plan does not prohibit the off -site transfer of
lawfully -established ROOO exemptions associated with transient residential units to RV park
developments-- and
WHEREAS, allowing transient residential units to be only transferred off -site to hotel
development, but not RV park developments, conflicts with the definition of transient residential
t nk, as set forth in Section 101-1 of the Monroe County Code, which includes both a hotel/motel
room and a space for parking a RV or travel trailer, and
WHEREAS, the transfer off -site of lawfully -established transient residential units does not
conflict with Monroe County Comprehensive Plan Policy 101.2.6, as the transfer does not create
additional, new transient units} but simply allows the transfer to another location; and
WHEREAS, for a pending major hurricane (category - ), Monroe County implements a
staged/phased evacuation procedure to achieve and maintain an overall 4-hour hurricane
evacuation clearance time for the resident population, pursuant to Monroe County
Comprehensive Plan Policy 1 .1. 8 ; and
Page 1 of 5
WHEREAS, the evacuation procedure for visitors staying at a hotel/motel room or within a
RV/travel trailer are mandated to evacuate 48 hours in advance of tropical storm winds (evacuate
within the same phase); and
WHEREAS, the transfer of lawf ally-establi shed transient residential units would be limited to
the same ROGO subarea, with the exception that ROGO exemptions associated with transient
residential units may be transferred from the Big Pine and No Name Key ROO subarea to the
Lower Keys 1 O O subarea (however not from the Leger Keys 1 O O subarea to the he Big
Pine and No Name Key ROGO subarea). The County has adopted numerous Comprehensive
Plan policies, the Big Pine Key and No Name Key Habitat Conservation Plan and the Big Pine
Key and No Name Key Livable CommuniKeys Community Master Plan to address the special
environmental issues associated with Big Pine and No Name Keys, including those related to
protection of federally -protected species, the prioritization of acquiring habitat areas and the
prevention of further encroachment on natural resources. Allowing the transfer of transient
residential units from Big Pine Key and No Name Key to other locations within the Lower Keys
subarea (which Big Pine and No Name Key were ongrnally part with the adoption of ROGO in
1992, but later separated into an independent 1OO subarea) will facilitate the ounty's goal of
implementing the adopted regulatory documents - by reducing the number (and impact) of
transient residential units; and
WHEREAS, based upon the information and documentation submitted, the Commission makes
the following Conclusions of Law: 1 ) the text amendment is consistent with the Principles for
Guiding Development in the Florida Keys Area of Critical State Concern-- ) the text amendment
is consistent with the provisions and intent of the Monroe County Comprehensive Plan; and )
the text amendment is consistent with the provisions and intent of the Monroe County Code; and
WHEREAS, during a regularly scheduled meeting held on December 18, 2012, the Monroe
County Development Review Committee reviewed the ordinance and recommended approval to
the Board of County Commissioners; and
WHEREAS, during a regularly scheduled public hearing held on February 27, 2013, the Monroe
County Planning Commission reviewed the ordinance and recommended approval to the Board
of County Commissioners-,
NOW,, THEREFORE, BE IT ORDAINED ED BY THE MONROE COUNTY BOARD of
COUNTY COMMISSIONERS-.
Section 1. Section 1 -() of the Monroe County Code shall be amended as follows (deletions
are and additions are underlined):
See. 13 - 2. Type of development not affected.
The residential ROGO shall not apply to the development described below:
Page 2 of 5
(2) Transfer off -site. Transfer off -site shall consist of either the demolition of a dwelling
on a sender site or a change of use
a - site -of the floor area of dwelling unit on a sender site to another t)enmtted use in
the applicable land use zonin district that does not r� r uie the RGO eem Lion and
.__ � ..,. .._ � ,.� the
development of a new transient residential unit or affordable housing unit on a receiver site
as follows ' F
at Eligibility of sender unit or space. In order to be an eligible sender wit or she, the
unit or sj2ace shall be a hotel morn, motel room c=pgound Mace, recreational
vehicle s a mobile home, or dwelling unit. .anapa
found to have been lawfully establishedyursuant to subsection 1.
b. Criteriafor redevelopment of site. site
M
1. Transfer to a hotel motel or recreational vehicle park. A hetWO, lawfull
established hotel room m2tel morn cam ound space, or recreational vehicle
Vace may be tr"ferrd off --site to another hotel .,.Motel or recreational
vehiclear if the:
(i) The sender unit is an eligible RO O exemption and was
used as a transient residential unit in accordance with section 10 1-1
}
and
(fi) The receiver site/unit meets all of the fallovnng criteria:
(AA)49 The receiver site is located in the sane ROGO subarea as the sender
site with the exceDtion that RO O e em tions associated with transient
residential dwelling units mu be transferred from the Biz Pine and No
Name Kev ROGO subarea to the Dower Keys ROGO subarea;
(BB) ` The receiver unit shall only be constructed within a a tier III
designated area or IZ) a tier III --A (special protection area) designated
area where the development does not involve the
clearing of any ' native habitat
. and
(CC) The receiver unit shall not be constructed within a veloci zone.
. Transfer to affordable housing. An A lawfully established dwellm" unit mgy be
transferred off -site if the icth
t ,
111M
(i) The sender unit is an eligible ROGO e em tion and.provided that it was used
as a Dennanent residential unit in accordance with section 101-1. and
(ii)The receiver site meets all of the following criteria:
(AA The receiver unit ie shall be an affordabl housing ut
pursuant to sections 10 1-1 and 1 30-1 1;
LB�s The receiver site is located in the sar ne ROGO subarea as the
sender site;
(CC) ... The receiver unit shall only be constructed within al a
tier III designated area or b within a tier III -A (special protection area
designated area where the devel ment does not
involve the clearing of any portion native habitat
--maLand
Page 3 of
IDI The receiver unit shall not be constructed within Ar. yAL.J QJ Aian#lad i velocity
(V) zone.
e. Procedures for transfer off -site.
-site.
l ■ pre-apl2lieation conference and, at �� .. a mm" Or
conditional use permit gpnroval shall be required for both the sender site and the
receiver site. The minor conditional use for the transfer shall be reviewed pursuant
to standards in this subsection and not + the standards
provided in section 110, 7, . As art of the
minor conditional use vermit a roval roeess mmflffig of notice shall be re uired
to owners of real locatediwthin 300 feet of the receiver site and owners of
real mopgrty located within Soo feet of the sender site. The receiver shall be Dosted
in accordance with sections 110-5ffiLand 110-6 ■ Posting -of notice as required in
section 110- shall be M uired for the receiver site but not the sender site,
. A sender unit shall be assigned a unique identifier number that shall be used for
tracking and monitoring by the planning department. Multiple units to be
transferred from a sender site to a sin le receiver site may be authorized under a
single nu'nor conditional use permit approval, The un.igue identifier number shall be
itemized in the minor conditional use permit develo ment orders and buildin
rmits r w' ed for both the sender and receiver sites.
.
ts
d. Conditions for issuance of permit. No building permit shall be issued for the new
transient residential unit or fordable housing L unlit on the receiver site until one of the
following conditions is net:
1. The dwellxn� unit to be transferred is demolished as per an issued demolition permit
and a final inspection of the demolished or removed dwelling unit or space has been
completed by all necessary cognly staff - ...
. The structure in which. the dwelling unit to be transferred is located is converted to
another Dermitted use as ner an issued building. pennit and a final certificate of
occLapancy for the conversion has been issued
a ■ ■
,r
3. Restoration of the sender site consistent with an approved
restoration/re-vegetation plan.
Section 2. Severabili,
If any section, paragraph, subdivision, clause, sentence or provision of this ordinance shall be
adjudged by any court of competent jurisdiction to be invalid, such judgment shall not affect,
impair, invalidate, or nullify the remainder of this ordinance, but the effect thereof shall be
confined to the section, paragraph, subdivision, clause, sentence, or provision immediately
involved in the controversy in which such judgment or decree shall be rendered.
Page 4 of 5
Seadon 3. Confilcgng Provisions.
In the case of direct conflict between any provision of this ordinance and a portion or provision
appropriate of any federal, state, or County law, rule code or regulation, the more restrictive shall
apply,
wdon 4. Trans�itt .
This ordinance sha11 he transmitted to the Florida State Land Planning Agency as required by F. S.
380.0 (11) and RS, 380.05 ().
Seen 5. F In *
This ordinance shall he filed in the Office of the Secretary of the State of Florida but shall not
become effective until a notice is issued by the Florida State Land Planning Agency or
Administration Commission approving the ordinance,,
Sections 6* Inclusion in the Monroe Cauuty Code*
The provisions of this Ordinance shall he included and incorporated in the Code of Ordinances
of the County of Monroe, Florida, as an addition to amendment thereto, and shall he
appropriately renumbered to conform to the uniform marlKing system of the Code.
Section 7. Effective Date.
This ordinance shall become effective as provided by law and stated above. This ordinance
applies to any applicable application submitted after the effective date.
PASSE! AND ADOPTED by the Board of County Commissioners of Monroe County, Florida
at a regular meeting held on the day of _.�2013.
Mayor George Neugent
Mayor Pro Tem Heather Carruthers
Commissioner Danny Kolhage
Commissioner Sylvia Murphy
Commissioner David lice
MONROE COUNTY BOAR'S of COUNTY CONMUSSIONERS
Attest: Array Heavilin, Clerk
Deputy Clerk
By
Mayor George Neugent
O-4ROE COUNTYATTORNEY
APPROVED AS TO FORM:
page 5 Of 5a e4_�
%OSAN M. GRlm&LEY
ASS STANT COUNTY ATTORNEY