Item C1
BOARD OF COUNlY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: December 3.2008
Division: County Attorney
Bulk Item: Yes
No ---1L
Staff Contact: Bob Shillinlfer x3470
AGENDA ITEM WORDING:
A public hearing to approve a compliance agreement to resolve the outstanding issues associated with
Comprehensive Plan Amendment package 08-01 (working waterfront amendments).
ITEM BACKGROUND: The working waterfronts Comprehensive Plan amendment was adopted by
the BOCC (Ordinance 008-2008) and rendered to the Florida Department of Community Affairs (DCA)
on February 4, 2008. Upon completion of its review, in a letter dated March 31, 2008, the DCA issued
its notice of intent to find the amendment not in compliance. That finding by DCA triggered a
statutorily required administrative challenge. The County, DCA, and several interveners have been
engaged in settlement discussions in attempt to amicably resolve that challenge. Those discussions
resulted in a tentative settlement agreement also known as a compliance agreement. Under F.S.
163.3184(16)(c), before the County can approve the compliance agreement, it must hold a public
hearing on that agreement. If the compliance agreement is approved, the County would then hold an
adoption hearing to consider an ordinance implementing the negotiated amendments to the
comprehensive plan.
PREVIOUS RELEVANT BOCC ACTION: June 2008 - BOCC directed staff to negotiate a
settlement of the administrative challenge to the comprehensive plan amendments.
February 2008 - Final adoption of the Comprehensive Plan amendment for working waterfronts.
September 2007 - Approved transtnittal of a Comprehensive Plan amendment fur working waterfronts.
September 2006 - Directed staff to enter into an inter-local agreement with South Florida Regional
Planning Council to develop a Comprehensive Plan amendment for working waterfronts.
CONTRACT/AGREEMENT CHANGES: nla
STAFF RECOMMENDATIONS: Approval
TOTAL COST:
N/A
BUDGETED: Yes ---1L No
COST TO COUNlY:
N/A
SOURCE OF FUNDS:
REVENUE PRODUCING: Yes
No
AMOUNT PER MONTH_ Year
APPROVED BY: County Atty ~ OMB/Purchasing _ Risk Management_
DOCUMENTATION:
Included
Not Required_
DIsPosmON:
AGENDA ITEM # c... \
STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
DEPARTMENT OF COMlVIUNITY
AFFAIRS,
Petitioner,
v.
DCA Docket No. 08-l-NOI-440l-(A)-(N)
DOAH CASE NO. 08-2035GM
MONROE COUNTY, FLORIDA,
Respondent,
and
ROBBIE'S SAFE HARBOR MARINE
ENTERPRISES, INC.; SAFE HARBOUR
PROPERTIES, LLC; KW RESORT
UTILITIES CORP.; PROTECT KEY WEST
AND TIIE FLORIDA KEYS, INC., d/b/a
LAST STAND; and NEW STOCK ISLAND
PROPERTIES, LLC.,
IntelVenors.
STIPULATED SETTLEMENT AGREEMENT
THIS STIPULATED SETTLEMENT AGREEMENT is entered into by and between the
State of Florida, Department of Community Affairs, Monroe County, and IntelVenors New Stock
Island Properties, LLC, Robbie's Safe Harbor Marine Enterprises, Inc., Safe Harbour Properties,
LLC, KW Resort Utilities Corp., and Protect Key West and the Florida Keys, Inc., d/b/a Last
Stand, as a complete and final settlement of all claims raised in the above-styled proceeding.
RECITALS
WHEREAS, the State of Florida, Department of Community Affairs (DCA or
Department), is the state land planning agency and has the authority to administer and enforce
the Local Government Comprehensive Planning and Land Development Regulation Act, Chapter
163, Part n, Florida Statutes; and
WHEREAS, Monroe County (Local Government) is a local government with the duty to
adopt comprehensive plan amendments that are "in compliance;" and
WHEREAS, Intervenors New Stock Island Properties, LLC, Robbie's Safe Harbor
Marine Enterprises, Inc., Safe Harbour Properties, LLC, KW Resort Utilities Corp., and Protect
Key West and the Florida Keys, Inc., d/b/a Last Stand, intervened in this case and have been
granted party status; and
WHEREAS, on February 4, 2008, the Local Government adopted Ordinance No. 008-
2008 adopting amendments to the Monroe County 2010 Comprehensive Plan (plan
Amendments); and
WHEREAS, the Plan Amendments propose to amend the Future Land Use Element and
Conservation and Coastal Management Element of the Monroe County 2010 Comprehensive
Plan related to preservation of recreational and commercial working waterfronts, including
development criteria for the Maritime Industries Land Use District within the Industrial future
land use category; and
WHEREAS, the Department issued its Notice ofIntent and Statement of Intent regarding
the Plan Amendments on March 31,2008; and
WHEREAS, as set forth in the Statement of Intent, the Department contends that the Plan
Amendments are not "in compliance"; and
WHEREAS, pursuant to Section 163.3184(10), Florida Statutes, DCA has initiated the
above-styled formal administrative proceeding challenging the Plan Amendments; and
WHEREAS, the parties executing this Stipulated Settlement Agreement wish to avoid the
expense, delay, and uncertainty of lengthy litigation and to resolve this proceeding under the
terms set forth herein, and agree it is in their respective mutual best interests to do so;
NOW, TIffiREFORE, in consideration of the mutual covenants and promises herein
below set forth, 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 represent and agree as
follows:
GENERAL PROVISIONS
I. Definitions. As used in this agreement, the following words and phrases shall
have the following meanings:
a. Act: The Local Government Comprehensive Planning and Land
Development Regulation Act, as codified in Part n, Chapter 163, Florida Statutes.
b. Al!reement: This stipulated settlement agreement.
c. Comnrehensive Plan Amendment or Plan Amendment: Comprehensive
plan amendment adopted by the Local Government on February 4, 2008, as Ordinance No. 008-
2008.
d. DOAH: The Florida Division of Administrative Hearings.
e. In comnliance or into comnliance: The meaning set forth in Section
163.3184(1)(b), Florida Statutes.
f Notice: The notice of intent issued by the Department to which was
attached its statement of intent to find the Plan Amendments not in compliance.
g. Petition: The petition for administrative hearing and relief filed by the
Department in this case.
h. Remedial Action: A remedial plan amendment, submission of support
document or other action described in the statement of intent or this Agreement as an action
which must be completed to bring the Plan Amendments into compliance.
i. Remedial Plan Amendment: An amendment to the plan or support
document, the need for which is identified in this Agreement, including its exhibits, and which
the Local Government must adopt to complete all remedial actions. Remedial plan amendments
adopted pursuant to this Agreement must, in the opinion of the Department, be consistent with
and substantially similar in concept and content to the ones identified in this Agreement or be
otherwise acceptable to the Department.
j. Statement of Intent: The statement of intent to find the Plan Amendment
not in compliance issued by the Department in this case.
k. SQPport DOCllment: The stQdies, inventory maps, SQrveys, data,
inventories, listings or analyses Qsed to develop and SQPport the Plan Amendments or Remedial
Plan Amendment.
2. Department Powers. The Department is the state land planning agency and has
the power and dQty to administer and enforce the Act and to determine whether the Plan
Amendments are in compliance.
3. Nel1:otiation of Alireement. The Department issued its Notice and Statement of
Intent to find the Plan Amendments not in compliance, and filed the Petition in this case to that
effect. Subsequent to the filing of the Petition the parties conferred and agreed to resolve the
issues in the Petition, Notice and Statement of Intent through this Agreement. It is the intent of
this Agreement to resolve fully all issues between the parties in this proceeding.
4. Dismissal. If the Local Government completes the Remedial Actions required by
this Agreement, the Department will issue a cumulative Notice of Intent addressing both the
Remedial Plan Amendment and the initial Plan Amendments subject to these proceedings. The
Department will file the ClImulative Notice of Intent with DOAH. The Department will also file
a request to relinquish jurisdiction to the Department for dismissal of this proceeding or for
realignment of the parties, as appropriate under Section 163.3184(16)(f), Florida Statutes.
5. Description of Provisions not in Compliance and Remedial Actions: Lel1:al Effect
of Agreement. Exhibit A to this Agreement is a copy of the Department's Statement of Intent,
which identifies the provisions the Department contends are not in compliance. Exhibit B
contains Remedial Actions needed for compliance. Exhibits A and B are incorporated into this
Agreement by this reference. This Agreement constitutes a stipulation that if the Remedial
Actions are accomplished, the Plan Amendments will be in compliance.
6. Remedial Actions to be Considered for Adoption. The Local Government agrees
to consider for adoption by formal action of its governing body all Remedial Actions described
in Exhibit B no later than the time period provided for in this Agreement.
7. Adoption or ADproval of Remedial Plan Amendments. Within 60 days after
execution of this Agreement by the parties, the Local Government shall consider for adoption all
Remedial Actions or Plan Amendments and amendments to the Support Documents. This may
be done at a single adoption hearing. Within \0 working days after adoption of the Remedial
Plan Amendment, the Local Government shall transmit 3 copies of the Remedial Plan
Amendment to the Department as provided in Rule 9J-l1.011(5), Florida Administrative Code.
The Local Government also shall submit one copy of the Remedial Plan Amendment to the
regional planning agency and to any other unit of local or state government that has filed a
written request with the governing body for a copy of the Remedial Plan Amendment, and shall
provide a copy to any party granted Intervenor status in this proceeding. The Remedial Plan
Amendment shall be transmitted to the Department along with a letter which describes the
remedial action adopted fur each part of the comprehensive plan amended, including references
to specific portions and pages.
8. Acknowledgment. All parties to this Agreement acknowledge that the "based
upon" provisions in Section 163.3184(8), Florida Statutes, do not apply to the Remedial Plan
Amendment.
9. Review of Remedial Plan Amendment and Notice ofIntent. Within 30 days after
receipt of the adopted Remedial Plan Amendment and any necessary Support Documents, the
Department shall issue a Notice of Intent pursuant to Section 163.3184, Florida Statutes, fur the
adopted Amendments in accordance with this Agreement.
a. In Compliance: If the adopted Remedial Actions satisfY this Agreement,
the Department shall issue a cumulative Notice of Intent addressing both the Plan Amendments
and the Remedial Plan Amendment as being in compliance. The Department shall file this
cumulative notice with DOAH and shall move to realign the parties or to have this proceeding
dismissed, as may be appropriate.
b. Not in Comoliance: If the Remedial Actions do not satisfY this
Agreement, the Department shall issue a Notice ofIntent to find the Remedial Plan Amendment
not in compliance and shall forward the notice to DOAH for consolidation with the pending
proceeding.
10. Effect of Amendment. Adoption of any Remedial Plan Amendment shall not be
counted toward the frequency restrictions imposed upon plan amendments pursuant to Section
163.3187(1), Florida Statutes.
11. Pur:pose of this Al!reement Not Establishing Precedent. The parties enter into
this Agreement in a spirit of cooperation for the purpose of avoiding costly, lengthy and
unnecessary litigation and in recognition of the desire for the speedy and reasonable resolution of
disputes arising out of or related to the Plan Amendments. The acceptance of proposals for
purposes of this Agreement is part of a negotiated agreement affecting many factual and legal
issues and is not an endorsement of, and does not establish precedent for, the use of these
proposals in any other circumstances or by any other local government.
12. AJ;lDroval bv Governinll Body. This Agreement has been approved by the Local
Government's governing body at a public hearing advertised at least 10 days prior to the hearing
in a newspaper of general circulation in the manner prescribed for advertisements in Section
163 .3 I 84(16X c), Florida Statutes. This Agreement has been executed by the appropriate officer
as provided in the Local Government's charter or other regulations.
13. Chanl!es in Law. Nothing in this Agreement shall be construed to relieve any
party from adhering to the law, and in the event of a change in any statute or administrative
regulation inconsistent with this Agreement, the statute or regulation shall take precedence and
shall be deemed incorporated in this Agreement by reference.
14. Other Persons Unaffected. Nothing in this Agreement shall be deemed to affect
the rights of any person not a party to this Agreement. This Agreement is not intended to benefit
any third party.
15. Attornev Fees and Costs. Each party shall bear its own costs, including attorneys
fees, incurred in connection with the above-captioned case and this Agreement.
16. Effective Date. This Agreement shall become effective immediately upon
execution by the Department and the Local Government.
17. Filing and Continuance. This Agreement shall be filed with DOAH by the
Department after execution by the parties; Upon the filing of this Agreement, the administrative
proceeding in this matter shall be stayed by the Administrative Law Judge in accordance with
Section 163.3184(16)(b), Florida Statutes.
18. Retention of Right to Final Hearing. The parties to this Agreement hereby retain
the right to have a final hearing in this proceeding in the event of a breach of this Agreement, and
nothing in this Agreement shall be deemed a waiver of such right. Any party to this Agreement
may move to have this matter set for hearing if it becomes apparent that any other party whose
action is required by this Agreement is not proceeding in good faith to take that action.
19. Construction of Alrreement. All parties to this Agreement are deemed to have
participated in its drafting. In the event of any ambiguity in the terms of this Agreement, the
parties agree that such ambiguity shall be construed without regard to which of the parties
drafted the provision in question.
20. Entire Agreement. This is the entire agreement between the parties and no verbal
or written assurance or promise is effective or binding unless included in this document.
21. Governmental Discretion Unaffected. This Agreement is not intended to bind the
Local Government in the exercise of governmental discretion which is exercisable in accordance
with law only upon the giving of appropriate public notice and required public hearings.
22. Multiple 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.
23 . Captions. The captions inserted in this Agreement are for the purpose of
convenience only and shall not be utilized to construe or interpret any provision of this
Agreement.
In witness whereof, the parties hereto have caused this Agreement to be executed by their
undersigned officials as duly authorized.
FLORIDA DEPARTMENT
OF COMMUNITY AFFAIRS
Approved as to form and legality:
Charles Gauthier, AICP, Director
Division of Community Planning
Richard E. Shine
Assistant General Counsel
Date
.2008
Date
,2008
STATE OF FLORIDA
COUNTY OF LEON
The foregoing instrument was acknowledged before me this _ day of
, 2008, by CHARLES GAUTHIER, who is personally known to me or who
has produced
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stamped)
My commission expires:
MONROE COUNTY, FLORIDA
Date
,2008
By:
George Neugent, Mayor
ATTEST:
DANNY L. KOLHAGE, CLERK
MONROE COUNTY ATTORNEY
APPA" V"D RM:
By
R RT 8. SHILLINGER, JR.
CHIEF A$SfJ'T!'5 C~~'tTTORNEY
Dala:
STATE OF FLORIDA
COUNTY OF MONROE
The foregoing instrument was acknowledged before me this _ day of
. 2008, by George Neugent, who is personally known to me or who has
produced
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stamped)
My commission expires:
NEW STOCK ISLAND PROPERTIES, LLC
By
.2008
STATE OF
COUNTY OF
The foregoing instrument was acknowledged before me this _ day of
. 2008, by
. who is personally known to me or who has
produced _
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stf!Illped)
My commission expires:
ROBBIE'S SAFE HARBOR MARINE
ENTERPRISES, INC.
By
,2008
STATE OF FLORIDA
COUNTY OF MONROE
The foregoing instrument was acknowledged before me this _ day of
, 2008, by
, who is personally known to me or who has
produced
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stamped)
My commission expires:
SAFE HARBOUR PROPERTIES, LLC
By
,2008
STATE OF FLORIDA
COUNTY OF MONROE
The foregoing instrument was acknowledged before me this _ day of
, 2008, by
, who is personally known to me or who has
produced
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stamped)
My commission expires:
KW RESORT UTILITIES CORP.
By
,2008
STATE OF FLORIDA
COUNTY OF MONROE
The foregoing instrument was acknowledged before me this _ day of
. 2008, by
. who is personally known to me or who has
produced _
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stamped)
My commission expires:
PROTECT KEY WEST AND THE FLORIDA
KEYS, INC., d/b/a LAST STAND
By
AI Sullivan, President
.2008
STATE OF FLORIDA
COUNTY OF MONROE
The foregoing instrument was acknowledged before me this _ day of
. 2008, by AI Sullivan, who is personally known to me or who has produced
as identification and who did/did not take an oath.
(SEAL)
NOTARY PUBLIC
Name (typed, printed or stl!ffiped)
My commission expires: