Item J3BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: June 15, 2011 Division: Growth Management
Bulk Item: Yes _ No X Department: Building
Staff Contact Person/Phone #: Joseph Paskalik
289-2574
AGENDA ITEM WORDING: Discussion and direction related to amendment of the County's flood
plain ordinance in light of House Bill 407.
ITEM BACKGROUND: The Florida Legislature passed House Bill 407, which pre-empts Section 6-
10E the County Code. That section requires a home owner to submit to an inspection of their
downstairs enclosure when applying for a permit on a portion of the property unrelated to the
downstairs enclosure. HB 407 will become effective on July 1, 2012 (see attached).
The County has three primary regulatory programs under their flood plain ordinance:
1. FEMA Pilot Inspection Program (inspection upon insurance renewal)
2. Required inspection of any suspected living area within downstairs enclosures (below base
flood elevation) on Building Permit (MC Code Section 6-107)
3. Required inspection of any suspected living area within downstairs enclosures (below base
flood elevation) on transfer (sale) (MC Code Section 122-6).
HB407 impacts number 2, the Inspection on Building Permit ordinance. Staff discussed this bill with
FEMA representative, Brad Loar CFM, Director of Mitigation Division, Region IV prior to the bill's
adoption. . Staff also discussed a proposed alternative to inspection on building permit with FEMA
representatives in Washington D.C. on May 24, 2011. FEMA indicated their willingness to work with
Monroe County to develop an alternative, should the bill pass. Now that the bill has passed, staff
needs to begin development of an alternative program, working with FEMA, to assure MC future
eligibility in the National Flood Insurance Program (NFIP). Attached is a summary of a proposed
alternative.
PREVIOUS RELEVANT BOCC ACTION: BOCC adopted a floodplain ordinance in 1975, which as
been modified and amended several times during the intervening years.
CONTRACT/AGREEMENT CHANGES: n/a
STAFF RECOMMENDATIONS: Direct staff to develop an alternative process for flood plain
compliance and correspond with FEMA officials in Atlanta to review proposed alternatives.
TOTAL COST: N/A INDIRECT COST: N/A
DIFFERENTIAL OF LOCAL PREFERENCE:
BUDGETED: Yes _No _
COST TO COUNTY: SOURCE OF FUNDS: N/A
REVENUE PRODUCING: N/A AMOUNT PER MONTH Year _
APPROVED BY: County Atty x OMB/Purchasing Risk Management
DOCUMENTATION: Included x Not Required
DISPOSITION: AGENDA ITEM #
F L 0 R I D A H O U S E O F R E P R E S E N T A T I V E S
ENROLLED
CSIHB 407
2011 Legislature
1 A bill to be entitled
2 An act relating to residential building permits; amending
3 s. 553.79, F.S.; prohibiting local enforcing agencies and
4 building code officials or entities from requiring certain
5 inspections of buildings, structures, or real property as
6 a condition of issuance of certain residential building
7 permits; providing for application; providing for
8 conditional repeal; providing an effective date.
9
10 Be It Enacted by the Legislature of the State of Florida:
11
12 Section 1. Subsection (17) is added to section 553.79,
13 Florida Statutes, to read:
14 553.79 Permits; applications; issuance; inspections.-
15 (17)(a) A local enforcing agency, and any local building
16 code administrator, inspector, or other official or entity, may
17 not require as a condition of issuance of a one- or two-family
18 residential building permit the inspection of any portion of a
19 building, structure, or real property that is not directly
20 impacted by the construction, erection, alteration,
21 modification, repair, or demolition of the building, structure,
22 or real property for which the permit is sought.
23 (b) This subsection does not apply to a building permit
24 sought for:
25 1. A substantial improvement as defined in s. 161.54 or as
26 defined in the Florida Building Code.
27 2. A change of occupancy as defined in the Florida
28 Building Code.
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
ENROLLED
CSIHB 407
2011 Legislature
29 3. A conversion from residential to nonresidential or,
30 mixed use pursuant to s. 553.507(2)(a) or as defined in the
31 Florida Building Code.
32 4. An historic building as defined in the Florida Building
33 Code.
34 (c) This subsection does not prohibit a local enforcing
35 agency, or any local building code administrator, inspector, or
36 other official or entity, from:
37 1. Citing any violation inadvertently observed in plain
38 view during the ordinary course of an inspection conducted in
39 accordance with the prohibition in paragraph (a).
40 2. Inspecting a physically nonadjacent portion of a
41 building, structure, or real property that is directly impacted
42 by the construction, erection, alteration, modification, repair,
43 or demolition of the building, structure, or real property for
44 which the permit is sought in accordance with the prohibition in
45 paragraph (a) .
46 3. Inspecting any portion of a building, structure, or
47 real property for which the owner or other person having control
48 of the building, structure, or real property has voluntarily
49 consented to the inspection of that portion of the building,
50 structure, or real property in accordance with the prohibition
51 in paragraph (a).
52 4. Inspecting any portion of a building, structure, or
53 real property pursuant to an inspection warrant issued in
54 accordance with ss. 933.20-933.30.
55 (d) This subsection is repealed upon receipt by the
56 Secretary of State of the written certification by the chair of
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F L O R I D A H O U S E O F R E P R E S E N T A T I V E S
ENROLLED
CS/HB 407
2011 Legislature
57 the Florida Building Commission that the commission has adopted
58 an amendment to the Florida Building Code which substantially
59 incorporates this subsection, including the prohibition in
60 paragraph (a), as part of the code and such amendment has taken
61 effect.
62 Section 2. This act shall take effect July 1, 2012.
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MEMORANDUM
MONROE COUNTY GROWTH MANAGEMENT DIVISION
BUILDING DEPARTMENT
We strive to be caring, professional and fair
DATE: May 26, 2011
TO: Christine Hurley, Growth Management Director
FROM: Joe Paskalik, Sr. Director/Building Official
Mary Wingate, Sr. Floodplain Coordinator
SUBJECT: SUMMARY OF CURRENT PROCESS FOR ILLEGAL
DOWNSTAIRS ENCLOSURES / ALTERNATIVES AFTER
PASSAGE OF STATE OF FLORIDA HOUSE BILL 407
Currently, Monroe County requires an inspection of downstairs enclosures
Under Section 6-107 of the Monroe County Code. The process is as follows:
1. Homeowner asks for building permit and must submit property record card with
application.
2. Staff reviews property record card to determine if living area exists in
downstairs, then writes letter to property owner notifying them of need for
inspection.
3. Property owner calls for inspection.
4. Perform inspection.
5. If not in compliance with floodplain management ordinances, owners are
notified of required remedies.
6. If permit that was applied for originally was for something irrelevant to the
downstairs enclosures (e.g. roof, fence, etc.), permit is issued after inspection of
downstairs area.
7. If not in compliance, and no remedy is made for downstairs enclosure in time
period given (3-6 months depending upon severity of violation
[plumbing/electric requires permitting so longer time period given), violation is
referred to Code Enforcement.
8. Code Enforcement sends NOV (explaining violation, suggested solutions, and
who to contact to remedy) and sets hearing before Special Magistrate.
9. Special Magistrate hears case
a. If finds that property is not in compliance:
i. Gives new compliance date
ii. Sets fines starting day after compliance date
iii. Property owner has 30 days to initiate appeal process
b. If finds that property is in compliance case is dismissed.
The above process will be unenforceable due to Florida House Bill 407/ Senate Bill 580.
Monroe County has until July 1, 2012 to adopt an ordinance that will provide for an
alternative to 6-107. This must be approved by FEMA. The following proposal to
modify 6-107 which includes the Implementation Plan, per FEMA's requirements, for
continuing participation in the NFIP, is offered:
The County is seeking to obtain definitive data from the Monroe County Property
Appraiser which will identify all single family residences which contain enclosures
that are identified as living area on the ground floor. Once this data is captured, our
technical staff will deduct all the parcels that have already received inspections via
the pilot program or other programs, and been made compliant.
The remaining property owners will be notified that an inspection will be required
in order to verify compliance with the Monroe County Floodplain Ordinance.
Failure to obtain the inspection will result in a Code Compliance referral or
possibly a 1316 declaration, providing the parcel is insured through the NFIP.
Once the owners obtain this inspection, and are compliant, they will receive a
Certificate of Compliance. This is a proactive opportunity for property owners to
receive evidence that they have a compliant structure which will create a positive
market condition. If an owner has a non -compliant structure, they will be notified
of all the required corrections to the enclosure to become compliant with the permit
authorizing the construction, OR the violation will be forwarded to the Code
Compliance Department for prosecution. Finally, once a property is compliant,
the County will provide a non -conversion agreement to be signed by the property
owner and recorded by the county.
This non -conversion agreement will provide protection to future buyers through
title work. Every two years an updated potential ground floor enclosure list will
be reviewed, and any changes to the Property Record that indicate illegal
construction below base flood elevation will go through the inspection process.
The County may also consider obtaining a list of all properties that have transferred
ownership and any such property that failed to obtain the required inspection will be
contacted for inspection.
In addition, all new construction that contains any type of below base flood elevation
enclosure, will be required to record a "Notice of Non -Conversion" to the property, which
should alleviate this problem in the future.
NONCONVERSION AGREEMENT
FOR CERTAIN STRUCTURES IN THE COASTAL FLOODPLAIN
Application has been made for a Permit from [community name], Louisiana.
Permit #
Property Owner
Address
Deed dated . Recorded
Tax map . block . parcel
Base Flood Elevation at the site is feet (NGVD).
Map Panel Number . effective date
In consideration for the granting of a Permit for the above structure, the Property Owner agrees to the
following:
1. That the enclosed area below the base Rood elevation shall be used solely for parking of vehicles,
limited storage, or access to the building and will never be used for human habitation without first
becoming fully compliant with.the Flood damage prevention ordinance in effect at the time of
conversion.
2. That the wags shall not be reinforced or altered to negate their ability to break away during a storm
and all Interior walls, ceilings, and floors below the Base Flood Elevation shall be unfinished or
constructed of flood resistant materials.
3. That mechanical, electrical, or plumbing devices shall not be installed below the Base Flood
Elevation.
4. That any variation in construction beyond what is permitted shall constitute a violation of this
agreement and Section of Ordinance #
5. That this Nonconversion Agreement becomes part of Permit #
Signature of Property Owner Witness Date
At a minimum, the following has been recorded on the deed to the above property: 'This stricture has
received special permission to be constructed in the Special Flood Hazard Area. The lowest floor shall
not be finished or converted to a habitable space unless the enclosed area below the Base Flood
Elevation becomes fully compliant with Ordinance # in effect at the time of conversion. At this site,
the Base Flood Elevation is feet, National Geodetic Vertical Datum"
Signature, Recorder of Deeds Date
P, -7-0 i\j P-'s
NONCONVERSION AGREEMENT
FOR CERTAIN STRUCTURES IN THE FLOODPI.AIN
Application has been made for a Permit from (community name), Louisiana.
Permit*
Property Owner
Address
Deed dated . Recorded
Tax map . block . panel
Base Flood Elevation at the site is feet (NGVD).
Map Panel Number . effective data
In consideration for the granting of a Permit for the above structure, the Property Owner agrees to the
following:
1. That the enclosed area below the base flood elevation shall be used solely for parldng of vehicles,
limited storage, or access to the building and will never be used for human habitation without first
becoming fully compliant with the Flood damage prevention ordinance in effect at the time of
conversion.
2 That all interior walls, ceilings, and floors below the Base Flood Elevation shall be unfinished or
constructed of flood resistant materials.
3. That mechanical, electrical, or plumbing devices shall not be installed below the Base Flood
Elevation.
4. The walls of the enclosed areas below the Base Flood Elevation shall be equipped with at least two
vents which permit the automatic entry and exit of floodwater with total openings of at least one
square inch for every square foot of enclosed area below flood level. The vents shall be on at least
two different walls and the bottoms of the vents shall be no more than one foot above grade.
5. That any variation in construction tion beyond what Is permitted shall constitute a violation of this
agreement and Section of Ordinance #
6. That this Nonoonversion Agreement becomes part of Permit #
Signature of Property Owner Witness Date
At a minimum, the following has been recorded on the deed to the above property: 'This structure has
received special permission to be constructed in the Special Flood Hazard Area. The lowest floor shall
not be finished or converted to a habitable space unless the enclosed area below the Base Flood
Elevation becomes fully compliant with Ordinance # in effect at the time of conversion. At this site,
the Base Flood Elevation is feet, National Geodetic Vertical Datum."
Signature, Recorder of Deeds Date
CORRECTED PAGE
Item J-3
9. Special Magistrate hears case
a. If finds that property is not in compliance:
i. Gives new compliance date
ii. Sets fines starting day after compliance date
iii. Property owner has 30 days to initiate appeal process
b. If finds that property is in compliance case is dismissed.
The above process will be unenforceable due to Florida House Bill 407/ Senate Bill
580. Monroe County has until July 1, 2012 to adopt an ordinance that will provide
for an alternative to 6-107. This must be approved by FEMA. The following
proposal to modify 6-107 which includes the Implementation Plan, per FEMA's
requirements, for continuing participation in the NFIP, is offered:
The County is seeking to obtain definitive data from the Monroe County Property
Appraiser which will identify all single family residences which contain enclosures
that are identified as living area on the ground floor. Once this data is captured, our
technical staff will deduct all the parcels that have already received inspections via
the pilot program or other programs, and been made compliant.
The remaining property owners will be notified that an inspection will be required
in order to verify compliance with the Monroe County Floodplain Ordinance.
.
Once the owners obtain this inspection, and are compliant, they will receive a
Certificate of Compliance. This is a proactive opportunity for property owners to
receive evidence that they have a compliant structure which will create a positive
market condition. If an owner has a non -compliant structure, they will be notified
of all the required corrections to the enclosure to become compliant with the permit
authorizing the construction, OR the violation will be forwarded to the Code
Compliance Department for prosecution. Finally, once a property is compliant,
the County will provide a non -conversion agreement to be signed by the property
owner and recorded by the county.
This non -conversion agreement will provide protection to future buyers through
title work. Every two years an updated potential ground floor enclosure list will
be reviewed, and any changes to the Property Record that indicate illegal
construction below base flood elevation will go through the inspection process.