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Item P1BOARD OF COUNTY COMMISSIONERS AGENDA ITS SUMMARY Meeting Date: MaL2 1. 2014 Bulk Item: Yes No X Division: Growth Mannorement Staff Contact Person/Phone #: Christine Hi irlev 9 RQ-?'s 17 AGENDA ITEM WORDING: A public hearing to consider an ordinance by the Monroe County Board of County Commissioners deleting Monroe County Code §130-158, Improved subdivision and commercial fishing village district densities as duplicative; removing court invalidated provisions regarding combining of contiguous lots in common ownership; deleting §130-159, Urban residential -mobile home district density as duplicative; removing invalid provisions regarding combining of contiguous lots in common ownership. (Legislative Proceeding) ITEM BACKGROUND: Residential density is regulated by Policy 101.4-21 of the Comprehensive Plan (CPS and §130-157 of the Monroe County Code (MCC). Consistent with CP Policy 101.4.3 and 101.4.22, MCC §130-157 states that the residential allocated density for the Improved Subdivision (IS) and Urban Residential -Mobile Home (URNR land use (zoning) districts is I dwelling unit per lot. There is not a density for the Commercial Fishing Village (CFV) zoning district assigned in MCC §130-157; however controlling CP Policy 101.4.22 specifies that the allocated density for the CFV district is I dwelling unit per lot. In addition to the density regulations cited above, MCC §130-158(a) and §130-159(a) state that "...the owner of a lot in an improved subdivision (IS) district or commercial fishing village (CFV) district shall be entitled to develop a single- family detached dwelling on the lot..." and "...the owner of a lot in an urban residential mobile home district shall be entitled to develop a dwelling on the lot..." These statements are duplicative of the relevant density tables in MCC § 13 0- 15 7 and CP Policy 10 1.4.22. Further, MCC § I 30-158(b) and § 130-159(b) state, "in the event contiguous lots are owned in common ownership on or after [September 15, 1986], the owner thereof shall be entitled to one unit per two lots or 12,500 [8,000 for URM] square feet of land area, exclusive of rights -of -way, whichever area is less." These provisions were found to be unconstitutional and invalid on April 6, 1989. The Court ruled against Monroe County and the Florida Department of Community Affairs in W. A. Perkins v. Monroe County, No. 88-706 (Fla. Cir. Ct. Apr. 6, 1989) on the constitutional and statutory validity of Sections 9.5-263 and 9.5-264 of the Monroe County Code (formerly Sections 9-303 and 9-304 of the Florida Keys Comprehensive Plan), also known as the "Contiguous Lot Provisions," and pennanently enjoined the County and State from enforcing the subject provisions on the basis of their violations of the Due Process and Equal Protection Clauses of the United States and Florida Constitutions, and their violations of Chapters 163 and 380, Florida Statutes, and Sections 718.507 and 719.507, Florida Statutes. While these provisions were found to be unconstitutional and invalid on April 6, 1989, they were not removed from the code. As these sections of the code are duplicative, and portions have been found unconstitutional and invalid, and the County is permanently enjoined from enforcing them, they a be removed from the land development regulations. PREVIOUS RELEVANT BOCC ACTION: On February 28,1986, the Board of County Commissioners (BOCC) adopted Resolution 049-1986, approving and submitting to the State Land Planning Authority (the Florida Department of Community Affairs —"DCA") the Monroe County Comprehensive Plan, which included the subject regulations (at that time, §9-303 and §9-304) in Volume III — Land Development Regulations. On October 3, 1986, the BOCC adopted Ordinance 033-1986, confirming the adoption of the Monroe County Comprehensive Plan and Land Development Regulations on February 28, 1986, and confirming their effective date of September 15, 1986, according to Florida Administrative Code Rule W-I 4.003 and W14.004. CONTRACTIAGREEMENT CHANGES: N/A STAFF RECOMMENDATIONS: Approval TOTAL COST: INDIRECT COST: BUDGETED: Yes No DIFFERENTIAL OF LOCAL PREFERENCE: COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes No AMOUNT PER MONTH Year APPROVED BY: County Atty 301 OMB/Purchasing Risk Management DOCUMENTATION: Included X Not Required DISPOSITION- AGENDA ITEM # Mr. 2 3 4 6 ORDINANCE NO. 2014 7 8 AN ORDINANCE BY THE ICI COUNTY BOARD OF 9 COUNTY COMMISSIONERS DELETING MONROE 10 COUNTY CODE SECTION 130-158, IMPROVED 11 SUBDIVISION AND COMMERCIAL FISHING VILLAGE 12 DISTRICT DENSITIES AS DUPLICATIVE; REMOVING 13 INVALID PROVISIONS REGARDING COMBINING OF 14 CONTIGUOUS LOTS IN COMMON OWNERSHIP; 15 DELETING SECTION 130-159, URBAN REST DENTIAL- 16 MOBILE HOME DISTRICT DENSITY AS DUPLICATIVE; 17 REMOVING INVALID PROVISIONS REGARDING 18 COMBINING OF CONTIGUOUS LOTS IN COMMON 19 OWNERSHIP; PROVIDING FOR SEVERABILITY; 20 PROVIDING FOR REPEAL OF CONFLICTING 21 PROVISIONS; PROVIDING FOR TRANSMITTAL TO THE 22 STATE LAND PLANNING AGENCY AND THE 23 SECRETARY OF STATE; PROVIDING FOR 24 CODIFICATION; PROVIDING FOR AN EFFECTIVE 25 DATE. 26 27 28 WHEREAS, the current regulations reduce the density associated with a platted lot by 29 simple act of a property owner purchasing two contiguous IS, URM, or CFV lots on any date 30 after September 15, 1986; and 31 32 WHEREAS, density is regulated by the adopted Comprehensive Plan and the adopted 33 Monroe County Code, which assign an allocated density of I dwelling unit per lot to the 34 Residential Medium (RM) future land use category and the Improved Subdivision (IS), 35 Commercial Fishing Village (CFV), and Urban Residential Mobile Home (URM) land use 36 districts; and 37 38 WHEREAS, the provisions of MCC §130-158(a) which state "...the owner of a lot in an 39 improved subdivision district or commercial fishing village district shall be entitled to develop a 40 single-family detached dwelling on the lot..." are duplicative with the relevant density tables in 41 MCC § 13 0 -15 7 and CP Policy 10 1.4.22; and 42 43 WHEREAS, the provisions of MCC § 130-159(a), which state ;;...the owner of a lot in an 44 urban residential mobile home district shall be entitled to develop a dwelling on the lot..." are 45 duplicative with the relevant density tables in MCC § 130-157 and CP Policy 10 1.4.22; and 46 I WHEREAS, the provisions of MCC §130-158(b) and §130-159(b) were found to be 2 unconstitutional and invalid on April 6, 1989 when the Court ruled against Monroe County and 3 the Florida Department of Community Affairs in W. A. Perkins v. Monroe County, No. 88-706 4 (Fla. Cir. Ct. Apr. 6, 1989) on the constitutional and statutory validity of Sections 9.5-263 and 5 9.5-264 of the Monroe County Code (formerly Sections 9-303 and 9-304 of the Florida Keys 6 Comprehensive Plan), also known as the "'Contiguous Lot Provisions," and permanently 7 enjoined the County and State from enforcing the subject Provisions on the basis of their 8 violations of the Due Process and Equal Protection Clauses of the United States and Florida 9 Constitutions, and their violations of Chapters 163 and 380, Florida Statutes, and Sections 10 718.507 and 719.507, Florida Statutes; and 11 12 WHEREAS, the Monroe County Development Review Committee considered the 13 proposed amendment at a regularly scheduled meeting held on the 25th day of June, 2013; and 14 15 WHEREAS, at a regularly scheduled meeting held on the 28th day of August, 2013, the 16 Monroe County Planning Commission held a public hearing to consider, review and receive 17 public comment for a proposed amendment to the Monroe County Code and recommended 18 approval of the amendment; and 19 20 WHEREAS, at a regularly scheduled meeting held on the 21" day of May, 2014, the 21 BOCC held a public hearing to consider, review and receive public comment for a proposed 22 amendment to the Mon -roe County Code; and 23 24 WHEREAS, the proposed amendment is consistent with the provisions and intent of the 25 Monroe County Comprehensive Plan; and 26 27 WHEREAS, the proposed amendment is necessary due to new issues as required by 28 §102-158 of the Monroe County Code, in that the subject provisions have been found 29 unconstitutional and invalid and the County has been enjoined from enforcing them; and 30 31 WHEREAS, the proposed amendment is consistent with the Principles for Guiding 32 Development for the Florida Keys Area of Critical State Concern, Section 380.0552(7), Florida 33 Statutes; 34 35 NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY 36 COMMISSIONERS OF MONROE COUNTY, FLORIDA: 37 38 Section 1. The Monroe County Code is amended as follows- (Deletions are and 39 additions are underlined,) 40 41 See. 130-158. Reserved. 42 densfties-. 43 44 45 1 2 3 4 5 6 — — — -- 7 8 9 10 11 12 13 anus t-. 14 15 Sec. 130-159. Reserved. 16 17 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Section 2. Severabili!L. If any section, paragraph, subdivision, clause, sentence or provision of 34 this ordinance shall be adjudged by any court of competent jurisdiction to be invalid, such 35 judgment shall not affect, impair, invalidate, or nullify the remainder of this ordinance, but the 36 etTect thereof shall be confined to the section, paragraph, subdivision, clause, sentence, or 37 provision immediately involved in the controversy in which such judgment or decree shall be 38 rendered. 39 40 Section 3. Conflicti m _Pr visions. In the case of direct conflict between any provision of this 41 ordinance and a portion or provision of any appropriate federal, state, or County law, rule code 42 or regulation, the more restrictive shall apply, 43 44 Section 4. Transmittal. This ordinance shall be transmitted to the Florida State Land planning 45 Agency as required by F.S. 380.05(l 1) and F.S. 3W0552(9). 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Section 5.Film - This ordinance shall be filed in the Office of the Secretary of the State of Florida but shall not become effective until a notice of Final Order is issued by the Florida State Land Planning Agency or Administration Commission approving the ordinance and any challenge to the order is resolved. Section 6. Inclusion in the Monroe County (-'- The provisions of this Ordinance shall be included and incorporated in the Code of Ordinances of the County of Monroe, Florida, as an addition to amendment thereto, and shall be appropriately renumbered to conform to the uniform marking 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 permit, and or other development approval application submitted after the effective date. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting held on the day of , 2014. Mayor Sylvia Murphy Mayorpro to Danny L. Kolhage Commissioner Heather Carruthers Commissioner David Rice Commissioner George Neugent MONROE COUNTY BOARD OF COUNTY COMMISSIONERS Attest: AM Y HEAVILW, CLERK Im Im Mayor Sylvia Murphy MEMORANDUM MONROE COUNTY PLANNING & ENVIRONMENTAL REsoURCEs DEPARTMENT Top Monroe o ty Board of County Commissioners Through: Christine Hurley, aI P, Director of Growth Management Townsley Schwab, Senior Director of Planning Environmental Resources From: Mayte Sant a, Assistant Director of Planning Environmental Resources Emily Schernpr, Principal Planner Bate: April 22, 2014 Subject: AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY NTY COMMISSIONERS DELETING MOOR E COUNTY BODE SECTION 130-158, IMPROVED SUBDIVISION AND COMMERCIAL FISHING VILLAGE DISTRICT .i ENSITIES AS DUPLICATIVE, REMOVING INVALID PROVISIONS" REGARDING COMBINING BININ F CONTIGUOUS LOTS IY COMMON OWNERSHIP,- DELETING SECTION 130-159, URBAN RESIDENTIAL —MOBILE HOME DISTRICT DENSITY 11S DUPLICATIVE REMOVING INVALID PROVISIONS REGARDING COMBINING OF CONTIGUOUS UOUS LOTS IN COMMON OWNERSHIP; PROVIDING FOR SEVERABILITY PROVIDING FOR REPEAL OF CONFLICTING PROVISIONS; PROVIDING FOR TRANSMITTAL TO THE STATE LAND PLANNING AGENCY AND THE SECRETARY OF STATE,- PROVIDING FOR CODIFICAIION; PROVIDING FOR AN EFFECTIVE DATE, Meeting: May 21, 2014 Ia REQUEST This is a request from the Planning & Environmental Resources Department to delete §130-158 d §130-159 of the Monroe County Cod (MCC) as duplicative and to remove provisions which eliminate the density associated with a platted lot, in the event that two contiguous Improved Subdivision (IS), Urban Residential Mobile Home (II ), or Courmercial Fishing Village (CEO`) lots are owned in commono ership. These provisions were found invalid n unconstitutional by the 1 tips Circuit Court of ` Monroe o County in 1989, and the County was permanently errjoinedfr m enforcing therm; however, they have not been removedfrom the code. IIe BACKGROUND / RELEVANT PRIOR O T ACTIONS n February 28, 1986, the Board of County Commissioners (1 O) adopted Resolution 049- 1986, approving and submitting to the State Land Planning authority (the Florida. Department of Community affairs — "DCA) the Monroe County Comprehensive Plan, which included the subject regulations (at that time, Sections 9-303 and 9-304) in Volume III — Land Development Regulations. Florida Administrative Code Rule M-14.004 approved portions of the Monroe County Land Development Regulations, including Sec. 9-303 and 9-304, with an effective date of September 15,1986. On October 3, 1986, the BOCC adopted Ordinance 033-1986, confirming the adoption of the Monroe County Comprehensive Plan and Land Development Regulations on February 28, 1986, and confirming their effective date of September 15, 1986, according to Florida Administrative Code Rule 9J- 14.003 and 9J 14.004. On April 6, 1989, the Court ruled against Monroe County and the Florida Department of Community Affairs in W, A. Perkins v. Monroe County, No. 88-706 (Fla. it. to Apr. 6,1989). It held that Sections 9.5-263 and 9.5-264 of the Monroe County Code (formerly Sections 9-303 and 9-304 of the Florida Keys Comprehensive Plan), also known as the "Contiguous Lot Provisions" were unconstitutional and invalid. The Court permanently enjoined the County and State from enforcing the subject provisions on the is of their violations of the Due Process and Equal Protection Clauses of the United States and Florida Constitutions, and their violations of Chapters 163 and 380, Florida Statutes, and Sections 718.507 and 719,507, Florida Statutes (judgment attached as Exhibit 1). During a regularly scheduled meeting held on June 25, 2013, the Monroe County Development Review Committee considered the proposed amendment and recommended approval with several adjustments made at the meeting. During a regularly scheduled meeting held on August 28, 2013, the Monroe County Planning Commission held a public hearing to consider, review and receive public comment for the proposed amendment and recommended approval of the amendment to the BOCC (Resolution P24-13, see Exhibit 2). 111. REVIEW The current sections of MCC under review read as follows: Sec. 130-158. Improved subdivision and commercial fishing village district densities. (a) Notwithstanding the density limitations of section 130-157, the owner of a lot in an improved subdivision district or commercial fishing village district shall be entitled to develop a single-family detached dwelling on the lot, provided that: (1) The lot has sufficient land area and dimensions to meet the requirements for the installation of on -site wastewater treatment systems; (2) The lot was a la buildable lot eligible for a building permit on the effective date of the ordinance from which this chapter is derived; and (3) The development of a single-family detached dwelling on the lot conforms to each and every other requirement of the plan. (b) In the event contiguous lots are owned in common ownership on or after the effective date of the ordinance from which this chapter is derived, the owner thereof shall be entitled to one unit per two lots or 12,500 square feet of land area, exclusive of rights -of -way, whichever area is less, provided that in no event shall a landowner be entitled to more dwelling its than buildable lots were provided for in the plat as originally approved by the county and filed with the clerk of the court. Sec. 130-159. Urban residentiat--mobile home district density. (a) Notwithstanding the density limitations of section 130-157, the owner of a lot in an urban residential mobile home district shall be entitled to develop a dwelling on the lot, provided that: (1) The loth sufficient land area and dimensions to meet the requirements of F.A.C. ch. 64E-6 for the installations of on -site wastewater treatment systems; (2) The lot was a lawful buildable lot eligible for a building permit on the effective date of the ordinance from which this chapter is derived; and (3) The development of a single-family detached dwelling on the lot conforms to each and every other requirement of the plan. (b) In the event contiguous lots are owned in common ownership on or after the effective date of the ordinance from which this chapter is derived, the owner thereof shall be entitled to one it per two lots or 8,000 square feet of land area, exclusive of rights -of -way, whichever area is less; provided that in no event shall a landowner be entitled to more dwelling its than buildable lots were provided for in the plat as originally approved by the county and filed with the clerk of the court. MCC §130-158(a) and §130-159(a) Density is regulated by the adopted Comprehensive Plan (CM and the adopted Monroe County Code (MCC). Consistent with CP Policy 101.4.3 and 101.4.22 (Exhibit 3), MCC §130-157 (Exhibit 4) states that the residential allocated density for the IS and URM land use districts is 1 dwelling it per lot (with no maximum net density assigned). There is not a density for CFV assigned in MCC §130-157; however, controlling CP Policy 101.4.22 specifies that the allocated density for the CFV district is I dwelling it per lot (with no maximum net density available). Therefore, the provisions of MCC §130-158(a) and §130-159(a), which state that "...the owner of a lot in an improved subdivision district or commercial fishing village district shall be entitled to develop a single-family detached dwelling on the lot. . . " and "...the owner of a lot in an urban residential —mobile home district shall be entitled to develop a dwelling on the lot.. are duplicative of the relevant density tables in MCC §130-157 and CP Policy 101.4.22. Further, the qualifying provisions for developing a dwelling on a lot stated in MCC §130- 158(a)(1-3) and §130-159(a)(1-3), are also unnecessary: (1) The lot has sufficient land area and dimensions to meet the requirements for the installation of on -site wastewater treatment systems. [URM: The lot has sufficient land area and dimensions to meet the requirements of FA. C ch. 64E-6 for the installations of on -site wastewater treatment systems] — Building permits for any dwelling unit must already meet the State of Florida Department of Health requirements for on -site wastewater treatment systems or wastewater collection systems, as governed by Florida Administrative Code. (2) The lot was a lawful buildable lot eligible for a building permit on the effective date of the ordinance from which this chapter is derived; — It is not practical or necessary for planning staff to look into the history of a parcel and the applicable land development regulations at the time of this ordinance. Current density requirements and all other applicable regulations control whether or not a parcel is eligible for a building permit. (3) The development of a single-family detached dwelling on the lot conforms to each and every other requirement of the plan. — Development of any type within any land use district is already required to conform to every applicable requirement of Monroe County Code and the Comprehensive Plan. MCC §130-158(b) and §130-159(b) MCC §130-158(b) and §130-159(b) state, "in the event contiguous lots are owned in common ownership on or after [September 15, 1986], the owner thereof shall be entitled to one it per two lots or 12,500 [8,000 for UEM] square feet of land area, exclusive of rights -of -way, whichever area is less." These provisions were fibond to be unconstitutional and invalid on April 6, 1989, The Court ruled against Monroe County and the Florida Department of Community Affairs in W .4, Perkins v. Monroe Coumy, No. 88-706 (Fla. Cir. CY, ,lpr6, 1989) on the constitutional and statutory validity of Sections 9.5-263 and 9,5-264 of the Monroe County Code (formerly Sections 9-303 and 9-304 of the Florida Keys Comprehensive Plan), also known as the "Contiguous of Provisions, " and permanently enjoined the County and State ftom enforcing the subject Provisions on the basis of their violations of the Due Process and Equal Protection Clauses of the United States and Florida Constitutions, and their violations of'Chapters 163 and 380, Florida Statutes, and Sections 718,507 and 719,507, Florida Statutes judgment attached as Exhibit 1). As these sections of the code have been found unconstitutional and invalid, and the County is peammently enjoined from enforcing them, they should be removed from the land development regulations. IV. PROPOSED AMENDMENT Therefore, staff recommends the following changes (Deletions are strielam—Shen„ gh—and additions are underlined See. 130-158. Reserved. See. 130-159. Reserved. V. STAFF RECOMMENDATION Staff has found that the proposed text amendment would be consistent with one or more of the required provisions of § 102-158(d)(5)(b): I. 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 new issues, in that the subject provisions have been found unconstitutional and invalid and the County has been enjoined from enforcing them. Staff has found that the proposed text amendments (deletions) would be consistent with the Monroe County Year 2010 Comprehensive Plan, the Florida Keys Principles for Guiding Development, and Sections 163.3194, 163.3201 and 163.3202, Florida Statute. Staff recommends that the Board of County Commissioners amend the Monroe County Code as stated in the text of this staff report. VI. EXHIBITS 1. W. A. Perkins v. Monroe County, No. 88-706 (Fla, Cit. Ct. Apr. 6,1989). 2. Planning Commission Resolution P24-13. 3. Comprehensive Plan Policies 10 1 .4.3 and 10 1.4.22 4. Monroe County Code § 13 0-157. Maximum residential density and district open space. 5. Consistency with the Florida Keys Principles for Guiding Development, Comprehensive Plan and Florida Statutes. 9 5 5 FF� WV UIT COUP, OF sent SI)tFTII ordeljUDIs' CIAt* CIRCUIT Its Tire CISCe HDRCOO?EZHK"" IS AND rCM UON Us A., pausing, JR.# W. A. FORM$ III, 02mis "01THAN I dAnotsy 9 CA RA dos 68-706-CA-19 Vs. clams offoresentations Poulos CO UM I at ale RUSS ORA AINTIFY80 NOTI RA IS CAUBg Coding an to be board an Class Plaintiffs' Nation partial summary judgment and the CCU ft haying reviewed the for morandOf low filed by to* Parties and having Meum leadingand ps heard the argument *I counsel, the Court finds as Follows$ summa is plaintiffs have filed a Motion for eare'al ry . judgment 110 ding Montag County Code, emotions 0-30) and 9304 as I - -264 be codified to read Sections 9.5, 263 and 9.5to older Iminaturyp arbitrary and unreasonable and that aide* javalid and unenforceable. The above Cited regulations read an follows$ 1:7 Section 9.5-2631 Mtn d in common I the agent contiguous lots are owns chapter, date of this I? ownership on or altar the oftcOtiyt hereof, shall be entitled' to one (1) unit For two this owner t hundred (12$5UN) square V., (2) Iota or twelve thousand give naive of L,ht.-cf-way, whicheVOT be ages, of land arcs, Orel a landowner is loop# provided that in no Ovant shall lots veto area than buildable more dwalliAg Uglisa entitled to as originally approved by Hantca provided for in the plat County and filed with the clack Of the Cenci" Session 9.5-2641 min the avant Contiguous lots are, owned in Common dote Of this chaPterP the effective ownership On Of Affecl be entitled to USA (1) unit Far two thereof Dh*l left of land area the owner (2) lots at eight thousand (OM01 BqUACO whichever SO@* is con, provided exclusive of rights-Cf-WAYO landowner be entitled to Mora in Ile event shall a for in the that 3 were pxgvtdod 1! dwelling unite than buildable Ict� approved by dengod County and filed with rigically plat as W 0 the clerk of the courts. the in 3, The teclft Overman ownership, as stated -cited regulations is defined in MOnCOG County Code' Section above C.13, as codified to toga, Section 9.5.4, and which 3- Item as101, id Section dada as I Pechich M-4 533955 ET-1 03 1 fill 90 0 hummed ownership means a shared interest in real .prop6rty by the same person or any persons related by marriage at blood within an immediate family locluding parents# moouses# siblings and childrah.4 4. Under the contiguous lot pravLaians of the Monroe County Code an set forth above# the fight of a ltroperty owner toe ,build upon his lot In an improved subdivision to determined by! whether or not 'be or, one of his immediate EaMilyp by blood or; marriagot,conar an adjacent lot. Thus if a brother and sister and' adjacent lots in an. improved subdivision falling within the! I I contiguous lot definitions# only one may build on his at hurl I lot, Howeverp if two unrolated.parrionG owned the identical locr$, !both would be able to build. I 5. The contiguous lot Provisions thOCIRCOTO create 4 cl*881, of • property, owners within the improved subdivisions in Monroe 1Cdun'ty# plarida that have difE0ydflt and logo rights to build umbel their lots than other similarly situated property *masts in the ,oavai subdivisions owning identical late. 6. in order to be valid# a zoning ordinance which `restricts the use of private property must be necessary ROT the 111 publ-La welfare. This necessity lion been defined by the yLocidal icourts an roqtLLring a substantial need for the restrictions in the interest at the public Coultas safetYp Wglf&tG Or metals. (Police power)" 7 A zoning ordinance enacted under a government'O iodercLso of police power may not be adopted or enforced in,such al, manner an to work a discrimination. 0. in determining the validity of zoning -legislation, both the form and substance of the enactment at*. subject to judicial J ; f�tingufry. 9. It is the duty of this Court to declare a Boning i!-Oidinanco unconstitutional it the ordinance does not beat 4 eE j�adbabawtlal relation to the public welfare or if the p;Acti,dal' I o' discrimination. operation and effect of the ordinance reauits in lee The contiguous lot provisions an adopted do not beat a substantial relationship to the publLo'healthe safety, Welfare or metals, The regulation of use Of property under the quisO Of a r 583965 01CP087 W0991 police power based Upon who Owns tho PCQPBCtY rather than the nature or quality of the property advances no recognized benefit to the public, 11, The contiguous lot provisions an adopted are .diswfifnic4bwrY in substance add Cllffltsticn- The regulations ragUir& identification Of family members Audi derialLion of their relationships for equitable onfoiCeRWitt&t l $t This identificati*4 and dopf i OIL tion is impossible for the liwailoingp losing and talipq officials As there is A* way to determine Who are Piediate Easily members- for relatives With It is clear that theme provisions fail to Idiffetant last names. enforcement could be establish Any means by which their reasonably' of impartially accomplishedv The Provision$ Can Only itbe enforced in an arbitrary and capricious Vdk"allt- Crew if the government. aftial.818 could identify immcdiatO Ia family mom here Owning adjacent lotus the prievi Card fail provide a procedure for determining, W iCh Qf two family' fe"Obvie owns the 'buildable lot and which the non -buildablo' 10A - .T`hust 'Ila brother and sister own two adjacent lots. subject' to. the 11 contiguous lot r9gtoictlace, the. county must d4acrLIALWAtO Against 110"S by prohibiting building while rawarding''thO other with building rights. The Contiguous lot provisions fail to 'provide procedures for asking this discriminatory doter inactions 22. The contiou . Quo lot provisoes ate ultimately 11digerimins tcry because there is no just basis for the classifications created by the PtOviGiOAG- The wi4tsaLfications are arbitrary and capricicuse In a society that recognized family as its foundAtieflIF it era manifeatlY Absurd to adopt zoning ordinances which prohibit me family members from owning and building ha s on 10tc sae to mean other while complete greengage could build 00 rho identical late. 13. Counsel fag defendant Monroe County OdwitB to this Court that the county has twice tried to- amend Its 0040 to reveal the contiguous lot Pres"'Ons' Monroe. CcUwtY informs this Court johat the granting of this nation in consistent with the countyle a 9 own efforts to remove the contiguous last provisions. 14. Defendant Florida Department of community Affairs offers no evidence at argument to suggest that the contiguous lot pfcvisiods are valid or conatitutionsl. No reasonable basis for the classification created by the ordinances is Argued.- I I Defendant Department of Community Affairs 'does admit that it also! tried to remove the contiguous let provisions from the Monroe' County Code by its rule taking authority under Chapter 380, lorids statutes, Its efforts to strike the Contiguous letl i 1 Ii provisions by rule have not been successful as of this dated 156 The contiguous lot provisions of hOnrea COURAY's I Comprehensive Land Use plan violate the due process and squat `iseteetin clauses of the United states and Florida +Constitutions. i6� The contiguous lot proviaiarta of the Mont county comprehensive Land use Flan violate Florida laws specifically :;CRAptinis 163 and 300p Florida statutea. and Section 710-307 and 119 0507o Florida Statutes 1988. PP IS TgBRBFORS ORDERED AND AWUDGNDS l.. plaintiff Close, Motion For partial summary judgment is grenades 1, section 9o5 263 and 965 264 of the Monroe County Coder'' lormarly sections 9-303 and -304 of the Florida Keys ItCamprahansiva lan, volute 111, are hereby declared to be invalid and snconatitutional, ' 3. Defendants Monroe C*UntY'r Florida and the Florida DapartNant of Community Affairs are hereby par neatly onJeinsd from enforcing Sections 9.5 263 and 9. 264 against the plaintiff class. DIANa AND ORDERED at Key West# Monroe County, Florida .er this Arday of April, 1969. iIL. Kathryn FUnohesa$ RDE, , moor a ouldnells gaq. I Michael f#alrnr F-h- ,I Imogene RyUcn r one. h tcsmll�ls Circut 'Judge a.:ra area � I, i SOUNHANNE UUMLS THE E ORDER wilt y Ls C9ar1t MAILEDTO ATTORNEYS Of RE ON TI�?OFENC RY ExhilW+z a 3 4 5 E COUNTY, FLORIDA S PLANNING SSI RESOLUTION 4-13 10 A RESOLUTIONE MONROE COUNTY PLANNING I COMMISSION RECOMMENDING APPROVALE AN 12 ORDINANCE BY THE MONROE COUNTY BOARD OF 13 COUNTY COMMISSIONERSDELETING E 14 COUNTY CODE SECTION 130-158, IMPROVED 15 SUBDIVISION t L FISHING VILLAGE 16 DISTRICT DENSITIES AS DUPLICATIVE 17 REMOVING OUTDATED PROVISIONS REGARDING 18 COMBININGE CONTIGUOUS LOTS IN COMMON 19 OWNERSHIP; DELETING SECTION130-159, URBAN 0 E TIAL—MOBILE HOME DISTRICT DENSITY AS 21 DUPLICATIVE AND REMOVINGOUTDATED 22 PROVISIONS REGARDING COMBINING OF 23 CONTIGUOUS LOTS IN COMMON OWNERSHIP; 24 PROVIDING FOR SE I ; PROVIDING FOR 25 REPEAL OF CONFLICTING PROVISIONS; PROVIDING 26 FOR S TTO THE STATE LAND PLANNING 27 AGENCY THE SECRETARY F° STATE; 28 PROVIDING FOR I A."TI ; PROVIDING 29 EFFECTIVEDATE. 30 31 WHEREAS, the Planning Environmental Resources Department is proposing amendment32 to the Monroe County Code deleting Monroe County Code Section 130-15 , 33 Improved subdivision and commercial fishing village district densities, deleting Monroe 34 County Cade Section 130-15, Urban residential — mobile home district density, and 5 36 WHEREAS, the Monroe County Development Review Committee considered the 37 proposed amendment at a regularly scheduled meeting held on the 25th day of June, 2013 d 3 39 WHEREAS, at a regularly scheduled meeting held on the 28th day of August, 2013, the 40 Monroe County Planning Commission held a public hearing to consider, review and receive 1 public comment for a proposed amendment to the Monroe County Cade and to make its 42 recommendation to the Board of CountyCommissioners; and 43 44 WHEREAS, the Monroe County Planning Commission makes the following findings of 45 fact and conclusions of 1 ; 1 1. The current regulations reduce the density associated with a platted lot by simple act of a 2 property owner purchasing two contiguous IS, URM, or CFV lots on any date after 3 September 15, 1986; and 4 2. Density is regulated by the adopted Comprehensive Plan and the adopted Monroe County 5 Code, which assign an allocated density of I dwelling it per lot to the Residential 6 Medium (RM) future land use category and the Improved Subdivision (IS), Commercial 7 Fishing Village (CFV), and Urban Residential Mobile Home (URM) land use districts; 8 and 9 1 The provisions of MCC § I 30-158(a) which state the owner of a lot in an improved to subdivision district or commercial fishing village district shall be entitled to develop a 11 single-family detached dwelling on the lot..." are duplicative with the relevant density 12 tables in MCC § 13 0-157 and CP Policy 10 1 .4.2 1; and 13 4. The provisions of MCC §130-159(a), which state "...the owner of a lot in an urban 14 residential —mobile home district shall be entitled to develop a dwelling on the lot..." are 15 duplicative with the relevant density tables in MCC §130-157 and CP Policy 101.4.21; 16 and 17 5. It is an unreasonable expectation for the County to assurne that potential property owners 18 are aware of the regulation and it is impractical, and/or impossible for County staff to 19 research necessary ownership information to for such regulations; and 20 6. MCC § I 30-158(b) and § 130-159(b) were adopted by the County on September 15, 1986. 21 With the subsequent adoption and refinement of the 2010 Monroe County 22 Comprehensive Plan and implementing Land Development Code, including the specific 23 density tables (requirements), these provisions are no longer necessary, and 24 74 The proposed amendment is consistent with the provisions and intent of the Monroe 25 County Comprehensive Plan; and 26 8. The proposed amendment is necessary due to new issues and recognition of a need for 27 additional detail or comprehensiveness as required by Section 102-158 of the Monroe 28 County Code; and 29 9. The proposed amendment is consistent with the Principles for Guiding Development for 30 the Florida Keys Area of Critical State Concern, Section 380.0552(7), Florida Statutes. 31 32 NOW, THEREFORE, BE IT RESOLVED BY THE PLANNING COMMISSION OF 33 MONROE COUNTY, FLORIDA: 34 35 Section 1. The following amendment to the Monroe County Code is recommended for 36 transmittal to the State Land Planning Agency and adoption by the Board of County 37 Commissioners as follows (deletions are strielsea-4firmildr and additions are 38 underlined): 39 40 See. 130-158. Reserved., ja%ved—sulidovissimammi K 41 densidesw 1 2 3 4 5 6 7 8 9 to 11 12 13 14 I 17 18 Sec. 130-159. Reserved. 22 23 24 25 26 27 28 29 I 35 36 PASSED AND RECOMMENDED FOR ADOPTION by the Monroe County Planning 37 Commission at a regular meeting held on the 28th day of August, 2013. 38 39 William What, Chair 40 Denise Wetting, Commissioner 41 Jeb Hale, Commissioner 42 Elizabeth Lustburg, Cornmissioner 43 Ron Miller, Commissioner Page 3 of 4 Resolution P24-13 2 OM PLANNING C B�r M OF 0 FLOREDA 4 William Wiatt, Chair 5 _—q 6 Signed this —LT day of—!--�,:-. 7 8 Monroe County Planning Commission Attorney 9 10 Approved As To Form FILED wDN THg 12 13 Date: 14 S�EP 10 2013 AGENCYCLERK Exhibit 3 to Staff Report Monroe County Year 2010 Comprehensive Plan — Relevant Adopted Policies Policy 101.4-3 The principal purpose of the Residential Medium land use category is to recognize those portions of subdivisions that were lawfully established and improved prior to the adoption of this plan and to define improved subdivisions as those lots served by a dedicated and accepted existing roadway, have an approved potable water supply, and have sufficient uplands to accommodate the residential uses. Development on vacant land within this land use category shall be limited to one residential dwelling unit for each such platted lot or parcel which existed at the time of plan adoption. However, Monroe County shall adopt Land Development Regulations which allow nonresidential uses that were listed as a perinitted use in the Land Development Regulations that were in effect immediately prior to the institution of the 2010 Comprehensive Plan (pre-2010 LDR's), and that lawfully existed on such lands on January 4, 1996 to develop, redevelop, reestablish and/or substantially improve provided that the uses are limited in intensity, floor area, density and to the type of use that existed on January 4, 1996 or limited to what the pre-2010 LDR's allowed, whichever is more restricted. Lands within this land use category shall not be further subdivided. [W-5.006(3)(c) I and 7] Policy 101.412 Monme County hereby adopts the following density and intensity standards for the future land use cixegcries, which am she on the Future Land Use Map and described in Policies 101.4.1 - 101.4.l7:[9J-5.006(3Xc)7]. Future Land Use Densities and latencies Fairre Land Use Category Allocated Density Maximuni Net Density Maximum lnensity And Comoponding Zoning (per Wre) (per bail le aae) (floor am race) Agriculture (A) 0 do VA 020-0.25 (no direetty car ndin zonin ol N/A 7Aa­Wrt i A : D 0 do N/A 0.10 (AD soning) 0 romix/ carox N/A Conworcial(COMM) 0 do N/A 0. 15-0,50 (C I 2and C2 0 rooms/s aces rooms a aces ILIA Comeavation (C) 0 do N/A U5 run, (CD z:) ' g) 0 roci N/A "—aimn (E) 0 do NIA 030 (no &ectly 22!!222diug �mrin 0 22nLspaces N/A Industrial (1) 1 do 2 do (I and NU zoning) 0 2Ln��apaces N/A EEO,25-0.60 Institutional (INS) 0 do N /A 025-0E.40 _j (no irecip, fing zoning) 3i, mic 4 rou're i 6-24 roo:ms/spaces -Tia-7in-b—nd N;w 0,01 do N/A 0.10 QVIN zonimb 0 Car 0 roo N/A Military (M) 6 do 12 do 030-050 pol' zoning) 10 roams/spaces 20 Mixed Usd/Cormwinercial 0,1 O-OA5 (SC, UC, DR, RV, MU and 1-6 do 2 -18 do (SC, UC, DR, RV, mid MU MI zoning) 5-15 morns/icaces 10-25 moneopsco zoning) I do (MI zoning) 2 do (MI sunine 0.30-0,60 M zoning) -K��UW�Commercjaffjsmng Fishing Approx. 3-8 do 12 do 02MA0 (CIA, CW), CFSD zoning) 0 rooms/spaces 0 2��nwzpaces ZicFacitifies (P 9 �( I —0 d u N/A 0, 10-030 (no d�y co�rmsponaimgzonio�g). 0 rooms/spaces N/A Exhibit 3 - Page 1 of 2 Public Buildings/Grounds (PB) 0 N/A (r 10-0.30 b1c, 0 morns/spaces NIA Recreation (R) 0.25 du NIA 020 (PR MtQ 2 22nLT2ces N/A _ Residential Conservation (RC) 0-0.25 do 1,VA 0-0.10 (OR 0 NIA Residential Low (RL) 025-050 du 5 do 0,20-025 (SSI� RE, and SR-Lzorn � n 0 roog�V NA _g) Residential Medium (RM) approx 0 5-8 du I N/A 0 (IS Zonium (I dMot) N(A 0 22E!�S��i Residential 1-figh (RIFE approx 3-16 du 12 do 0 (IS -do, URM(� and URIO ennead (1-2 dudob 20 rosims/spaces lorosims/spaces Notes: (a) 'N/A!' means that maximum net density bonuses, shall not be available. (b) The allocated densities for submerged lands, salt ponds, fieshroner ponds, and mangroves shelf be 0 mid the mazimum not densities bonuses "I not be available. (c) The allossited density for CFV zoning shag be I dweftg unit per lot and the maximum net density bonuses shag not be available. (d) Maximurn net density bras shelf not be available to the SS district (e) The allocated density for IS-D and URM zoning shag be 2 and I dwelling units per lot, resisectively and the maximum net density bonuses shag not be avaflalxh-� The maximum net density for the UR disnict shag be 25 for its where all rate am designated as affordable housin& (g) For molester consisting ofocks, pinelands or disaidard vantands within the Mixed Usel Commercial and Mixed Usc/ Commercial Fishing land me categories, the floor am ratio shall, be 0. 10 and the maximum net residential density bonuses not apply, (h) Uses under the categories ofARriculture, Education, Insfitirtional, Public Facilities, and Public Buildings mid Uses, which have no directly corresporamig zoning, may be an Ind him new or existing zoning districa; as appropmee. I -be Maximinn Net Density is the maximum, density allowable with the use ofTDRs. {jiA mixture of uses shag be maintained for parcels designated as MI zoning district that are within the RIC fitaire land use category. Working waterfront and water dependent uses, such as manna, fish house/market, boat raper, boat building, boat storage, or other similar uses, shelf comprise a an' nimurn of'35% ofthe upland am of the properto pursuant to Policy 10 1 A5. Exhibit 3 - Page 2 of 2 Exhibit 4 to Staff Report Monroe County Code — Section 130-157. Maximum residential density and district open space. The maximum residential density and district open space shall be in accordance with the following table: an Use District Allocated Density Maximum Net Density Open Space DUIAcre DUBuildablearea Ratio Urban commercial 6.0 12.0 0.2 Urban residential 6,0 110 0.2 (Affordable housing) 6,0 25 °O 0.2 (Employee housing) 6.0 25.0 0.2 Urban residential mobile home Blot 0 0.2 (URM) Mobile home parks per section 10 1 - 1 5.0 TO 0.2 URM-limited 1/lot 0 0.2 Suburban commercial 10 6.0 0.2 (Employee housing) 3.0 15,0 0.2 Suburban residential 0.5 5.0 0.5 Suburban residential LTD OJ 3.0 0.5 Sparsely settled 0.5 0 0.8 Native 0.25 0 Mainland native 0.01 0 0.99 OfTshore island 0.1 0 0.95 Improved subdivision 1/lot 0 0.2 Exhibit 4 - Page 1 of 2 Commercial fishing" 3.0 12.0 0.2 Destination resort Lo 18.0 0.2 Industrial 1.0 2.0 02 Maritime industry 1.0 2.0 U Mixed use 1.0 1240 0.2 (Affordable housing) LO 18.0 0.2 (Employee housing) 1.0 18.0 0.2 Military facility 6.0 12.0 01 Park and refuge 0.25 0 0.9 *See additional open space ratios in chapter 118; in accordance with section 101-2(l), the most restrictive of these ratios applies. "The allocated and maximum net densities listed in this table do not apply to CFSD-20 (Little Torch). See section 130-79(14)c. for residential densities. Exhibit 4 - Page 2 of 2 Exhibit 5 to Staff Report Consistency Review 1. The proposed amendment to delete §130-158 and §130-159 of the Monroe County Code as duplicative and which provisions have been ruled invalid and unconstitutional, is consistent with the Principles for Guiding Development for the Florida Keys Area, Section 380.0552(7), Florida Statute. For the purposes of reviewing consistency of the adopted plan or any amendments to that plan with the principles for guiding development and any amendments to the principles, the principles shall be construed as a whole and no specific provision shall be construed or applied in isolation from the other provisions. (a) Strengthening local government capabilities for managing land use and development so that local government is able to achieve these objectives without continuing the area of critical state concern designation. (b) Protecting shoreline and marine resources, including mangroves, coral reef formations, seagrass, beds, wetlands, fish and wildlife, and their habitat. (c) Protecting upland resources, tropical biological communities, freshwater wetlands, native tropical vegetation (for example, hardwood hammocks and pinelands), dune ridges and beaches, wildlife, and their habitat. (d) Ensuring the maximum well-being of the Florida Keys and its citizens through sound economic development. (e) Limiting the adverse impacts of development on the quality of water throughout the Florida Keys. (f) Enhancing natural scenic resources, promoting the aesthetic benefits of the natural environment, and ensuring that development is compatible with the unique historic character of the Florida Keys. (g) Protecting the historical heritage of the Florida Keys. (h) Protecting the value, efficiency, cost-effectiveness, and amortized life of existing and proposed major public investments, including- 6. The Florida Keys Aqueduct and water supply facilities; 7. Sewage collection, treatment, and disposal facilities; & Solid waste treatment, collection, and disposal facilities; 9. Key West Naval Air Station and other military facilities; 10. Transportation facilities; 11. Federal parks, wildlife refuges, and marine sanctuaries; 12. State parks, recreation facilities, aquatic preserves, and other publicly owned properties; 13v City electric service and the Florida Keys Electric Co-op; and 14. Other utilities, as appropriate. (i) Protecting and improving water quality by providing for the construction, operation, maintenance, and replacement of stornuvater management facilities; central sewage collection; treatment and disposal facilities; and the installation and proper operation and maintenance of onsite sewage treatment and disposal systems. Exhibit 5 — Page I of 3 Ensunng: the improvement of nearshore water quality by requiring the construction and operation of wastewater management facilities that meet the requirements of as. 381.0065(4)(1) and 403.086(10), as applicable, and by directing growth to areas served by central wastewater treatment facilities through permit allocation systems, (M Limiting the adverse impacts of public investments on the environmental resources of the Florida Keys. (1) Making available adequate affordable housing for all sectors of the population of the Florida Keys. (m)Providing adequate alternatives for the protection of public safety and welfare in the event of a natural or marimade disaster and for a postdisaster reconstruction plan. (n) Protecting the public health, safety, and welfare of the citizens of the Florida Keys and maintaining the Florida Keys as a unique Florida resource. Pursuant to Section 380-0552(7) Florida Statutes, the proposed amendment is consistent with the Principles for Guiding Development as a whole and is not inconsistent with any Principle. 2. The proposed amendment to delete §130-158 and §130-159 as duplicative and twhich provisions have been ruled invalid and unconstitutional, is consistent with the adopted Comprehensive Plan as described in the staff report. 3. The proposed amendment to delete §130-158 and §130-159 as duplicative and t which provision have been ruled invalid and unconstitutional, is consistent with Part 11 of Chapter 163, Florida Statute (F.S.). Specifically, the amendment furthers: 1633161(6), F.S. - It is the intent of this act that adopted comprehensive plans shall have the legal status set out in this act and that no public or private development shall be permitted except in conformity with comprehensive plans, or elements or portions thereof, prepared and adopted in conformity with this act. 163.3161(10), E& - It is the intent of the Legislature that all governmental entities in this state recognize and respect judicially acknowledged or constitutionally protected private property rights. It is the intent of the Legislature that all rules, ordinances, regulations, comprehensive plans and amendments thereto, and programs adopted under the authority of this act must be developed, promulgated, implemented, and applied with sensitivity for private property rights and not be unduly restrictive, and property owners must be free from actions by others which would hann their property or which would constitute an inordinate burden on property rights as those terms are defined in s. 70.001(3)(e) and (f). Full and just compensation or other appropriate relief must be provided to any property owner for a governmental action that is determined to be an invalid exercise of the police power which constitutes a taking, as provided by law. Any such relief must ultimately be determined in ajudicial action. 163.3194(1)(b), E& — All land development regulations enacted or amended shall be consistent with the adopted comprehensive plan, or element or portion thereof, and any land development regulations existing at the time of adoption which are not consistent with the adopted comprehensive plan, or element or portion thereof, shall be amended so as to be consistent. If a local government allows an existing land development regulation which is inconsistent with the most recently adopted comprehensive plan, or element or portion thereof, to remain in effect, the local government shall adopt a schedule for bringing the land development regulation into conformity with the provisions of the most recently adopted Exhibit 5 — Page 2 of 3 comprehensive plan, or element or portion thereof, During the interim period when the provisions of the most recently adopted comprehensive plan, or element or portion thereof, and the land development regulations are inconsistent, the provisions of the most recently adopted comprehensive plan, or element or portion thereof, shall govern any action taken in regard to an application for a development order. 163,3194(3)(a), F.S. — A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspects of development permitted by such order or regulation are compatible with and birther the objectives, policies, land uses, and densities or intensities in the comprehensive plan and if it meets all other criteria enumerated by the local government. 163.3201, F.S. — It is the intent of this act that adopted comprehensive plans or elements thereof shall be implemented, in part, by the adoption and enforcement of appropriate local regulations on the development of lands and waters within an area. It is the intent of this act that the adoption and enforcement by a governing body of regulations for the development of land or the adoption and enforcement by a governing body of a land development code for an area shall be based on, be related to, and be a means of implementation for an adopted comprehensive plan as required by this act 163.3202(2), IF. - Local land development regulations shall contain specific and detailed provisions necessary or desirable to implement the adopted comprehensive plan and shall at a minimum: (a) Regulate the subdivision of land. (b) Regulate the use of land and water for those land use categories included in the land use element and ensure the compatibility of adjacent uses and provide for open space. (c) Provide for protection of potable water welifields. (d) Regulate areas subject to seasonal and periodic flooding and provide for drainage and storinwater management. (a) Ensure the protection of environmentally sensitive lands designated in the comprehensive plan. (f) Regulate signage. (g) Provide that public facilities and services meet or exceed the standards established in the capital improvements element required by s. 163.3177 and are available when needed for the development, or that development orders and permits are conditioned on the availability of these public facilities and services necessary to serve the proposed development. A local government may not issue a development order or permit that results in a reduction in the level of services for the affected public facilities below the level of services provided in the local government's comprehensive plan. (h) Ensure safe and convenient onsite traffic flow, considering needed vehicle parking. (i) Maintain the existing density of residential properties or recreational vehicle parks if the properties are intended for residential use and are located in the unincorporated areas that have sufficient infrastructure, as determined by a local governing authority, and are not located within a coastal high -hazard area under s. 163.3178. Exhibit 5 — Page 3 of 3