Resolution 176-2020 I County Attorney
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5 RESOLUTION NO. 176 -2020
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7 A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF
8 MONROE COUNTY, FORMALIZING THE PRIOR APPROVAL OF THE
9 SPECIAL MAGISTRATE'S RECOMMENDED ORDER REGARDING THE
10 BENEFICIAL USE DETERMINATION APPLICATION OF PATRICIA J.
11 EDWARDS AND HENRY A. OLYNGER JR., AND DENIAL OF THE
12 RELIEF SOUGHT BY APPLICANTS.
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15 WHEREAS, Patricia J. Edwards and Henry A. Olynger, Jr. ("Applicants") filed an
16 amended application for a Determination of Beneficial Use("BUD") on June 12,2017; and
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18 WHEREAS, the BUD application was referred to a Special Magistrate as provided in
19 Sections 102-105 and 102-106 of the Monroe County Code; and
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21 WHEREAS, the duly appointed Special Magistrate, Francine M. Ffolkes, held an
22 evidentiary hearing on January 16, 2018; and
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24 WHEREAS, the Special Magistrate issued a Recommended Order with recommended
25 Findings of Fact and Conclusions of Law on March 27, 2018, and a copy of the Recommended
26 Order is hereby appended to, and made a part of, this Resolution; and
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28 WHEREAS, the Board of County Commissioners must approve, modify, reverse, or
29 approve with conditions a Recommended Order from a Special Magistrate during a public
30 hearing as provided in Monroe County Code, Section 102-108; and
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32 WHEREAS, a public hearing was held before the Board of County Commissioners on
33 July 18, 2018; and
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35 WHEREAS, the Board of County Commissioners unanimously voted at the July 18,
36 2018, hearing to approve without conditions the March 27, 2018, Recommended Order and deny
37 beneficial use relief; and
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39 WHEREAS, following the July 18, 2018, hearing, the Board of County Commissioners
40 did not formalize its decision to approve without conditions the March 27, 2018, Recommended
41 Order and deny beneficial use relief pursuant to a written resolution; and
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43 WHEREAS, on October 9, 2019, the Florida Division of Administrative Hearing
44 requested that the County provide it with a written final decision on the Recommended Order in
45 order to close out its case file; and
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1 WHEREAS, the Board wishes to formalize its acceptance of the recommendation of the
2 Special Magistrate as proposed in his Recommended Order; now therefore:
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4 BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF
5 MONROE COUNTY,FLORIDA,as follows:
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7 That the Board of County Commissioners hereby approves the Recommended Order
8 dated March 27, 2018,made by the Special Magistrate and adopts it as the final decision of the
9 Board. The final decision is denial of the relief sought by Applicants in their application for a
10 BUD.
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12 PASSED AND ADOPTED by the Board of County Commissioners of Monroe County,
13 Florida,at a regular meeting of the Board held on the 17"day of June 2020.
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15 Mayor Carruthers Yes
16 Mayor Pro Tem Coldiron
17 Commissioner Cates Yea
18 Commissioner Rice Yya
19 Commissioner Murphy Yes
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22 (SEAL) BOARD OF COUNTY COMMISSIONERS
23 ` Attest:KEVIN MADOK,Clerk OF MONROE COUNTY,FLORIDA
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26 By Uf """ . By
27 As Deputy Clerk Mayor eath them
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MONROE COUNTY ATTORNEY'S OFFICE
MAC AS70
PAUNECE SCULL
ASSIST
DATE:
STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
PATRICIA J. EDWARDS AND HENRY A.
OLYNGER, JR. /TIC,
Petitioners,
VS . Case No. 17-6177GM
MONROE COUNTY PLANNING
COMMISSION,
Respondent .
RECOMMENDED ORDER
This matter was heard before the Division of Administrative
Hearings (DOAH) by its assigned Administrative Law Judge,
Francine M. Ffolkes, on January 16, 2018, at video
teleconferencing sites in Tallahassee and Key West, Florida.
APPEARANCES
For Petitioners : Van D. Fischer, Esquire
VDF Law, PLLC
Post Office Box 420526
Summerland Key, Florida 33042
For Respondent : Derek V. Howard, Esquire
Monroe County Attorney' s Office
1111 12th Street, Suite 408
Post Office Box 1026
Key West, Florida 33041-1026
STATEMENT OF THE ISSUE
The issue is whether to approve the Petitioners'
application for a beneficial use determination (BUD) regarding
their property on Ramrod Key, Florida, and if approved, to
determine the type of relief that is appropriate .
PRELIMINARY STATEMENT
In 2016, the Petitioners filed a BUD application under
section 102-102, et . seq. , Monroe County Code . In 2017, the
Petitioners filed an Amended BUD Application. The Petitioners
asserted that a December 4, 2015, denial of their single-family
residential building permit application constituted an
as-applied taking of their property. The denial stated that the
property did not constitute a "lot" for purposes of density. As
relief, the Petitioners seek to have the property awarded a
density allocation for development of one dwelling unit and a
building permit issued.
Pursuant to a contract, the BUD Application was referred by
the Respondent, Monroe County Planning Commission (County) , to
DOAH for a hearing before a special magistrate (administrative
law judge) . See § 102-105, Monroe Cnty. Code . The parties
filed their Joint Pre-hearing Stipulation on January 2, 2018, in
which the parties separately listed their exhibits and the
Petitioners indicated that they were not calling any witnesses .
At the start of the hearing, the County lodged hearsay
objections to two appraisals that were identified as Attachments
10 and 11 to the Amended BUD Application in the Petitioners'
list of exhibits . The County followed up with objecting to the
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entire Amended BUD Application as hearsay since the Petitioners
were not presenting any direct evidence that would be
corroborated by the Amended BUD Application. The undersigned
ruled that the Amended BUD Application was not admitted into
evidence for the truth of the matters asserted therein, but only
admitted to show that an Amended BUD Application was submitted
to the County. '/
Despite not being listed as a witness in the Joint Pre-
hearing Stipulation, the undersigned allowed Henry A.
Olynger, Jr. , to testify on behalf of the Petitioners . The
County presented the testimony of Kevin Bond, Monroe County
Planning and Development Review Manager, who was accepted as an
expert in land planning. A November 9, 2017, memorandum to the
Special Magistrate was accepted into evidence .
Neither party hired a court reporter to preserve the record
of the hearing. Therefore, there is no transcript of the
proceeding. The Petitioners filed a written Closing Argument
and the County filed a motion to strike the Petitioners' Closing
Argument . The County' s motion to strike is denied.
Proposed Recommended Orders were filed by the parties, and
they were considered in the preparation of this Recommended
Order.
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FINDINGS OF FACT
The following findings of fact are taken from the parties'
joint pre-hearing stipulation, and the direct evidence adduced
at the hearing.
The Property
1 . The Petitioners' property is located at 475 Brown
Drive, Ramrod Key, in Monroe County. According to the
Monroe County Property Appraiser, the size of the site is
0 . 95 acres . The property is vacant and contains disturbed and
undisturbed wetland habitat . The property' s immediate vicinity
is described as residential development of single-family units
to the west and south, environmentally sensitive lands to the
south and east, and open water to the north.
2 . The property is legally described as "being a portion
of Tract `A' , Ramrod Shores Third Addition, according to the
plat thereof, as recorded in Plat Book 6, Page 108 of the Public
Records of Monroe County, Florida" having real estate number
00209971-004600 . The property' s current Land Use Map Zoning
Districts are Improved Subdivision (IS) and Native Area (NA) .
The property' s Future Land Use Map (FLUM) designations are
Residential Medium (RM) and Residential Conservation (RC) . The
Tier Designation is Tier III Infill Area.
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Relevant Prior County Actions
3 . On December 19, 1972, the Monroe County Board of County
Commissioners (BOCC) passed Resolution No. 146-1972 approving
the Plat of Ramrod Shores Third Addition and filed for record in
Plat Book 6 at Page 108 of the Public Records of Monroe County.
The landowner was James M. Brown, as Trustee . The subject
property is within Tract A of this plat .
4 . In 1986, Monroe County adopted a revised set of zoning
regulations via Ordinance No. 33-1986 . Ordinance No. 33-1986
also approved a revised series of zoning maps (also known as the
Pattison Maps) for all areas of the unincorporated county by
reference . With the adoption of the 1986 Land Development
Regulations and zoning maps, most of the Petitioners' property
was designated as IS zoning with a small portion as NA.
5 . In 1992, a revised series of zoning maps were approved
(also known as the Craig Maps) for all areas of the
unincorporated county. With the adoption of the revised (Craig)
zoning maps, the Petitioners' property remained designated as IS
with a small portion as NA.
6 . In 1993, the County adopted a set of FLUM maps pursuant
to a joint stipulated settlement agreement and section 163 . 3184,
Florida Statutes . BOCC Ordinance No. 016-1993 memorialized the
approval . The FLUM maps took effect in 1997 after approval from
the state land planning agency. With the adoption of the FLUM
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maps, the Petitioners' property was designated as RM and a small
portion as RC.
7 . On March 23, 2015, the Petitioners were provided a
Letter of Current Site Conditions for the subject property. The
letter summarized the environmental habitats on the property and
the applicable portions of the Comprehensive Plan and Land
Development Code . The letter stated the KEYWEP score for
disturbed portions of the wetland was 4 . 45 . The score of 4 . 45
means the property was buildable, disturbed wetlands . The
undisturbed wetlands consist of tidal mangroves and were by
definition "red flag" wetlands . Disturbed wetlands may be
developed under section 118-10, Monroe County Code . Development
is not permitted in undisturbed wetlands where 100 percent open
space is required.
8 . On November 24, 2015, the Petitioners applied for a
building permit to construct a single-family detached
residential dwelling unit . On December 4, 2015, the County' s
Planning and Environmental Resources Department (the Department)
sent the Petitioners a notice that the Department denied their
building permit application number 15106233 . The notice
informed the Petitioners that the Department' s decision may be
appealed within 30 calendar days . No appeal was filed to
challenge the propriety of the Department' s decision.
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9 . The Department' s December 4, 2015, notice stated that
the Ramrod Shores Third Addition Plat shows that the
Petitioners' property is located within Tract A. Although
Tract A was subdivided into seven parcels, this was never shown
as lots on an approved and duly recorded plat . The Department
determined that the property did not meet the definition of
"lot" in section 101-1, Monroe County Code, and did not meet the
residential density requirements of the IS Land Use District in
order to allow the proposed development of a dwelling unit . See
§ 130-157, Monroe Cnty. Code .
10 . On December 7, 2016, the Department received the
agent' s BUD Application, File No. 2016-202 . On December 22,
2016, the Department sent the agent a Notice of Deficiencies
pursuant to section 102-105, Monroe County Code, after the
application was reviewed by staff to determine if the
application was complete and included the materials and
information listed in section 102-105 (b) . On January 6, 2017,
the Department received additional materials and information
from the agent . On January 27, 2017, the Department notified
the agent that the application was determined to be sufficient .
11 . On March 28, 2017, the Department forwarded the BUD
application to DOAH for adjudication. After the Petitioners
sought to amend their application with a new basis for relief,
DOAH relinquished its jurisdiction.
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12 . On June 12, 2017, the Petitioners submitted an Amended
BUD Application to the Department . After sending a second
Notice of Deficiencies and receiving additional materials and
information from the agent, the Department determined that the
application was sufficient .
13 . The Amended BUD Application was suspended for 60 days,
pursuant to BOCC Resolution No. 214-2017, as a temporary
emergency measure after Hurricane Irma made landfall in the
Florida Keys on September 10, 2017 . On November 9, 2017, the
Department forwarded the BUD Application to DOAH for
adjudication.
Petitioners' Actions
14 . The Petitioners purchased the subject property on
April 23, 1990 . Between 1990 and 1991, the Petitioners
submitted an application to the Department of Health and
Rehabilitative Services (HRS) for an on-site aerobic septic
system. At first, the HRS denied the application based on lot
size issues . The HRS Variance Review Board recommended
disapproval of the septic system application on June 7, 1991, on
the grounds of insufficient lot size and an illegal canal .
15 . After the Petitioners failed to obtain HRS approval in
1991, they took no further steps to develop the property until
they submitted an application for a Letter of Current Site
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Conditions on January 30, 2015, and an application for a single-
family residence on November 24, 2015 .
16 . Mr. Olynger testified that the Petitioners purchased
the property because of the ocean view and expected to build a
house on the property. He testified that after the HRS denials
in the early 1990s, he started the process of trying to develop
the property again in 2014 because central sewer was now
available .
IS Land Use District
17 . Due to the density requirements for the IS Land Use
District of one dwelling unit per lot, the Petitioners are
unable to construct a single-family home, which is an as-of-
right use in the IS Land Use District .
18 . The IS Land Use District permits other as-of-right and
conditional uses . While Mr. Olynger disputed the economic
productivity of some of these uses, it was not disputed that the
property could potentially be used for (a) recreational
purposes; (b) a community park; (c) beekeeping; (d) wastewater
system; (e) Rate of Growth Ordinance (ROGO) points or
transferable development rights (TDRs) ; or (f) sold to a
neighbor for open space, yard expansion or an accessory use,
such as a pool .
19 . Mr. Bond testified that that the County' s
Comprehensive Plan and Code allow landowners competing for the
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limited number of building allocations in the point-based ROGO
to buy and donate vacant parcels such as the subject property to
increase their ROGO scores . The subject property qualifies as a
ROGO Lot and there is an active secondary market of people
buying and trading ROGO Lots in Monroe County.
20 . Mr. Bond also testified that the Petitioners could
apply for Future Land Use Map and Land Use (Zoning) District Map
amendments to a category that would allow for the construction
of a single-family dwelling based upon an adopted acreage
density standard. The Petitioners have not made any such
applications .
21 . There was no direct evidence on the fair market value
of the property, as encumbered by the regulation.2
CONCLUSIONS OF LAW
22 . Pursuant to a contract with DOAH, after a BUD
application is determined to be complete, it is transmitted to a
special magistrate (administrative law judge) to set a hearing
date . See § 102-105 (d) (2) , Monroe Cnty. Code . The hearing
process is governed by the following broad guidelines set forth
in subsection 102-106 (b) :
At the hearing, the landowner or landowner' s
representative shall present the landowner' s
case and the Planning Director or his or her
representative shall represent the county' s
case . The special magistrate may accept
briefs, evidence, reports, or proposed
recommendations from the parties .
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23 . Section 102-109 (a) provides :
[R] elief . . . may be granted where a court
of competent jurisdiction likely would
determine that a final action by the county
has caused a taking of property and a
judicial finding of liability would not be
precluded by a cognizable defense, including
lack of investment-backed expectations,
statutes of limitation, laches, or other
preclusions to relief.
24 . The Petitioners have the burden of showing that relief
is appropriate . See § 102-109 (b) , Monroe Cnty. Code . The
Petitioners have alleged an as-applied regulatory taking.
25 . Section 101-104, Monroe County Code, defines when a
landowner can apply for BUD relief:
Relief under this division cannot be
established until the landowner has received
a final decision on development approval
applications from the county, including
building permit allocation system
applications, appeals, administrative relief
pursuant to sections 138-27 [ROGO] and 138-
54 [NROGO] , and other available relief,
exceptions, or variances, unless the
applicant asserts that a land development
regulation or comprehensive plan policy, on
its face, meets the standards for relief in
section 102-109 .
26 . The BUD process requires the Petitioners to receive a
final decision on various forms of relief listed in section 102-
104 before applying for relief under the BUD process . The
evidence established that the Petitioners did not appeal the
denial of their building permit, did not apply for
administrative relief under the ROGO provisions, and did not
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apply for any zoning district map or future land use map
amendments to a category that would allow for the construction
of a single-family dwelling based upon an adopted acreage
density standard. See § 102-104, Monroe Cnty. Code .
27 . For an as-applied takings claim to be considered ripe,
a property owner must have taken reasonable and necessary steps
to allow the County to exercise its judgment regarding
development plans, including the opportunity to grant waivers
and variances or other relief. See Collins v. Monroe Cnty. , 999
So. 2d 709, 716 (Fla. 3d DCA 2008) ; § 102-104, Monroe Cnty.
Code .
28 . Under the provisions of the Monroe County Code, this
Amended BUD Application fails to comply with the exhaustion
requirement of section 102-104 and applicable case law.
Therefore, the Petitioners' as-applied claim is not ripe and
should be denied.
29 . A court of competent jurisdiction likely would
determine that the Petitioners' as-applied claim is not ripe,
which is a cognizable defense precluding a judicial finding of
liability. See § 102-109, Monroe Cnty. Code .
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RECOMMENDATION
Based on the foregoing Findings of Fact and Conclusions of
Law, it is
RECOMMENDED that the Board of County Commissioners deny the
Petitioners' application for relief under section 102-104,
Monroe County Code .
DONE AND ENTERED this 27th day of March, 2018, in
Tallahassee, Leon County, Florida.
FRANCINE M. FFOLKES
Administrative Law Judge
Division of Administrative Hearings
The Desoto Building
1230 Apalachee Parkway
Tallahassee, Florida 32399-3060
(850) 488-9675
Fax Filing (850) 921-6847
www.doah. state . fl .us
Filed with the Clerk of the
Division of Administrative Hearings
this 27th day of March, 2018 .
ENDNOTES
l Hearsay alone cannot form the basis for a finding of fact .
See § 120 . 57 (1) (c) , Fla. Stat . (2017) ("Hearsay evidence may be
used for the purpose of supplementing or explaining other
evidence, but it shall not be sufficient in itself to support a
finding unless it would be admissible over objection in civil
actions . ") .
21 Appraisals were specifically objected to by the County as
hearsay documents . The appraisals were attachments to the BUD
application, which was not admitted into evidence for the truth
of the matters asserted therein. Since direct evidence
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regarding appraised values was not presented by the Petitioners,
no finding of fact can be made using only hearsay as the basis .
Id.
COPIES FURNISHED:
Ilze Aguila, Senior Coordinator
County of Monroe
Board of County Commissioners
Suite 410
2798 Overseas Highway
Marathon, Florida 33050
(eServed)
Derek V. Howard, Esquire
Monroe County Attorney' s Office
1111 12th Street, Suite 408
Post Office Box 1026
Key West, Florida 33041-1026
(eServed)
Van D. Fischer, Esquire
VDF Law, PLLC
Post Office Box 420526
Summerland Key, Florida 33042
(eServed)
NOTICE OF FURTHER RIGHTS
This Recommended Order will be considered by the Board of County
Commissioners at a public hearing. See § 102-108, Monroe Cnty.
Code . The time and place of such hearing will be noticed by the
County.
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