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Item P1 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: October 18,2000 Division: County Attorney AGENDA ITEM WORDING: Public Hearing of an Ordinance declaring that an emergency exists and waiving notice by a 4/5's vote; designating Higgs Beach Park, Bernstein_ Park, Watson Field, Marathon Community Park, Marathon Marina, Key Largo Community Park and Harry Harris Park as Monroe County Regional Parks and authorizing the use of general fund revenue for maintenance, operation and capital improvement of such parks. ITEM BACKGROUND: PREVIOUS RELEVANT BOCC ACTION: STAFF RECOMMENDATION: Approval. TOTAL COST: BUDGETED: Yes_ No Cost to County: APPROVED BY: County Attorney _~ OM8/Purchasing Risk Management DIVISION DIRECTOR~~ DOCUMENTATION: . Inc uded _~ To Follow Not required AGENDA ITEM # I~P' Mayor Shirley Freeman ORDINANCE NO - 2000 AN ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA, DECLARING THAT AN EMERGENCY EXISTS AND WAIVING NOTICE BY A FOUR-FIFTH'S. VOTE; DESIGNATING HIGGS BEACH PARK, BERNSTEIN PARK, WATSON FIELD, MARATHON COMMUNITY _PARK, MARATHON MARINA AND BAY BOTTOM, KEY LARGO COMMUNITY PARK AND HARRY HARRIS PARK AS MONROE COUNTY REGIONAL PARKS AND AUTHORIZING THE USE OF GENERAL FUND REVENUE FOR THE MAINTENANCE, UPKEEP, OPERATION AND THE CAPITAL IMPROVEMENT OF SUCH PARKS; PROVIDING FOR SEVERABILITY; PROVIDING FOR THE REPEAL OF ALL ORDINANCES INCONSISTENT HEREWITH; PROVIDING FOR INCORPORATION INTO THE MONROE COUNTY CODE OF ORDINANCES: AND PROVIDING AN EFFECTIVE DATE WHEREAS, it is desired to create a system of County regional parks whose attractions are such that the parks draw visitors form an area beyond the park's immediate neighborhood; WHEREAS, the only equitable way to fund such regional parks is through the general fund so that all residents who desire to use such parks pay for their upkeep rather than just the . residents in the immediate area; WHEREAS, the City of Marathon's refusal to accept County parks located within the City makes it imperative to immediately establish a regional park system and provide a funding mechanism for that system in order that County recreational facilities can be kept open for the citizens with a minimum of disruption; now, therefore, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA: Section 1. An emergency is hereby declared and notice waived by a four-fIfth's vote. The following County parks are hereby designated Monroe County Regional Parks: a) Higgs Beach Park (Key West); b) Bernstein Park (Stock Island): c) Watson Field (Big Pine Key); d) Marathon Community Park (Marathon); e) Marathon Marina and bay bottom (Marathon); f) Key Largo Community Park (Key Largo); and g) Harry Harris Park (Tavernier). Section 2. Revenue from the Monroe County general fund is hereby authorized to be expended on the regional parks designated in Section 1 of this Ordinance for maintenance, operating expenses, upkeep and capital improvements. Section 3. If any section, subsection, sentence, clause or provision of this ordinance is held invalid, the remainder of this ordinance shall not be affected by such invalidify. Section 4. All ordinances or parts of ordinances in conflict with this ordinance are hereby repealed to the extent of said conflict. Section 5. The provisions of this ordinance shall be included and incorporated in the Code of Ordinances of the County of Monroe, Florida, as an addition or amendment thereto, and shall be appropriately renumbered to conform to the uniform numbering system of the Code. Section 6. This ordinance shall take effect when a certified copy of this ordinance has been accepted by the postal authorities of the United States for special delivery by registered mail to the Secretary Of State of the State of Florida in accordance with the provisions of Florida Statute 125.66(3). PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting of said Board held on the 18th day of October, 2000. 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Community Park, Harry Harris Park, Key Largo Community Park - FY 2001 Now Maintenance Capital- Total General Fund $46,853 $0 $46,853 Unincorporated Parks & Beaches $440,832 $0 $440,832 Tourist Development Council $284,438 $110,520 $394,958 One Cent Infrastructure Sales Tax $0 $56,480 $56,480 Marathon Community Park-Not Funded $143,069 $44,500 $187,569 Total $915,192 $211,500 $1,126,692 With Regional Parks General Fund* Unincorporated Parks & Beaches Tourist Development Council One Cent Infrastructure Sales Tax Marathon Community Park-Not Funded Total Maintenance $630,754 $0 $284,438 $0 $0 $915,192 Capital $44,500 $0 $110,520 $56,480 $0 $211,500 Total $675,254 $0 $394,958 $56,480 $0 $1,126,692 Ad Valorem Breakdown*** Now Taxes per $100,000 Millage of Taxable Value Cities Maintenance Capital Total 0.0047 0.0000 0.0047 $0.47 $0.00 $0.47 Unicorporated Monroe County Maintenance Capital Total 0.1024 0.0000 0.1024 $10.24 $0.00 $10.24 With Regional Parks Taxes per $100,000 Millage of Taxable Value Countywide Maintenance Capital Total 0.0632 0.0045 0.0677 $6.32 $0.45 $6.77 .f .;;a - * Would require using $628,401 of Reserves in the General Fund to fund Fiscal Year 2001 expenses out of Countywide ad valorem taxes. - Capital expenses will vary widely from year to year. *** This shows the difference in ad valorem taxes if this had been implemented in the Fiscal Year 2001 adopted budget. Office of Management & Budget 10/5/2000 BEFORE THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA INRE: Millus and Lori Skidmore Beneficial Use Application / MONROE COUNTY'S PROPOSED DENIAL/REJECTION OF BENEFICIAL USE DETERMINATION In accordance with ~9.5-174, MCC, the Monroe County Division of Growth Management proposes the BOCC reject the Special Master's Proposed Beneficial Use Determination and as grounds states: 1. Pursuant to ~9.5-174, Monroe County Code, the Board of County Commissioners ("BOCC") has final authority to grant or deny beneficial use determinations and may approve, reject, or modify an order from the Special Master proposing to grant beneficial use. 2. In this case, the beneficial use application was submitted to determine whether the applicant will be denied all reasonable economic use of his property by application of Policy 204.2.6 of the Year 20 10 Comprehensive Plan, and whether the applicant is entitled to relief under Policies contained in Objective 101.18 ofthe Year 2010 Comprehensive Plan (as administered and implemented in the "Agreement Between the Department of Community Affairs and Monroe County" dated February 23, 1998), the approved portions of Ordinance 052- 1997 and the Monroe County Code. 3. A beneficial use determination is available to provide relief when an applicant has been deprived of all reasonable economic use of his property. This form of administrative relief allows property owners to seek relief or be compensated when it is found that certain regulations result in a "taking" of the Applicant's property. In this case, while the Applicant's current ROGO score has been reduced by six (6) points, this certainly has not resulted in a denial of all reasonable economic use for the following reasons: I-?~ A. The Monroe County Year 2010 Comprehensive Plan, adopted January 4, 1996, included Coastal High Hazard Areas as one of the weighted categories to be used in the Permit Allocation System. The Applicant purchased the property in June, 1997 - more than one year after the plan was adopted. Therefore, the Applicant was on notice that the Code could be modified at any point in time to include Coastal High Hazard Areas as a weighted category in the ROGO point allocation system. B. The change to ~9.5-127, while lowering the Applicant's ROGO score by six (6) points, has not taken away the Applicant's ability to obtain additional points available under the ROGO point allocation system. Additional point may be obtained by raising the structure, or by purchasing and transferring development rights from an eligible sender site. The applicant will also continue to receive additional perserverance points which will increase his ROGO score. C. More than 100 applicants were reevaluated after the May 22, 1998 revisions ofthe ROGO criteria in the Monroe County Code. The allocation system is designed to allocate the limited number of dwelling units available annually in a logical systematic manner. Those parcels that best meet and further the goals, objectives and policies ofthe Comprehensive Plan are permitted first. The reduction in the Applicant's point score was a direct result of revisions made to further the goals, objectives and policies ofthe Comprehensive Plan. D. Section 9.5-129, MCC, provides for administrative relief for those applicants tha. thave been denied an allocation award for four consecutive years. This Applicant has been in the system for two years and may apply for administrative relief directly under ROGO ifhe does not obtain an award within four years from the date of application. E. In Burnham v. Monroe County, 738 So.2d 471 (Fla. 3d DCA 1999), the Third District Court of Appeals held upheld Monroe County's ROGO point allocation system as a constitutional means of allocating the County's limited number of building permits. The court held that the requirement that applicants obtain points by including certain design features or purchasing development rights from other buildable properties is a constitutional and effective means of managing growth. In upholding the ROGO system, the Court specifically held that the point system does not constitute a taking where additional points are available which the applicant has not availed himself. To wit: It is clear from the record that no taking has occurred; all that the owners had to do in order to obtain the necessary points for their building permit was to make a few minor changes to their plans. To establish a taking by inverse condemnation, a plaintiff must show that the challenged regulation denies all economically beneficial or productive use of land. Burnham, 738 So.2d at 472. 4. As in Burnham, the Applicant here has the ability to obtain additional ROGO points of which he has not availed himself. Accordingly, the complained-of regulation does not constitute a taking and has not resulted in a denial of all reasonable beneficial use of the Applicant's property. WHEREFORE, the Monroe County Division of Growth Management respectfully requests the BOCC reject the proposed beneficial use determination of Special Master Overby and DENY the application for beneficial use. Respectfully submitted, ~c~ Florida Bar No. 136964 MORGAN & HENDRICK Counsel for Monroe County Growth Management 317 Whitehead Street Key West, Florida 33040 305-296-5676 305-296-4331 (fax) KCabanas@f1akeysol.com CUNNINGHAM, MILLER, HEFFERNAN & WOLFE, L.L.P. 2975 OVERSEAS HIGHWAY POST OFFICE Box 500938 MARATHON, FLORIDA 33050-0938 RALPH E. CUNNINGHAM, ..JR., RETIRED ROBERT K. MILLER* WILLIAM ..J. HEFFERNAN, ..JR. ..JOHN ..J. WOLFE** HALFORD G. SCHUHMACHER*** EUGENE G. KYLE, III RICHARD A. MALAFY CHERYL L. HASTINGS ..JAMES F. NOLAN TI::i..EA-lCl'lE: (305) 743-9427 FAX: (305) 743-8800 REAL ESTATE FAX: (305) 743-7489 WWW.FLORIDAKEYSLAW.COM *ALSO ADMllTED IN NEW YORK **ALSO ADMllTED IN TEXAS ***ALSO ADMllTED IN MICHIGAN October 13,2000 Via Facsimile and Federal Express Overnight Karen K. Cabanas 317 Whitehead Street Key West, Florida 33040 Re: In Re: Mil/us and Lori Skidmore Beneficial Use Application Dear Karen: Enclosed please find a copy of our response in the above referenced matter. By a copy of this letter we have transmitted a copy of our response to Marlene Conaway. Should you have any questions please do not hesitate to contact us. BEFORE THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA IN RE: Milus and Lori Skidmore Beneficial Use Application / APPLICANTS' PROPOSED APPROVAL OR MODIFICATION OF BENEFICIAL USE DETERMINATION In accordance with Sec. 9.5-174, Monroe County Code, Milus and Lori Skidmore ("Applicants"), propose that the Board of County Commissioners approve or approve with modifications the Special Master's Proposed Beneficial Use Determination and as grounds state: 1. Pursuant to Section 9.5-174, Monroe County Code, the Board of County Commissioners ("BOCC") has final authority to grant or deny vested rights and beneficial use determinations and may approve, reject, or modify an order from the Special Master proposing to grant vested rights and beneficial use. 2. Applicants purchased a lot in the Sugarloaf Shores Subdivision in Monroe County with plans to build a home thereon, in reliance on the provisions of the Monroe County Year 20 1 0 Comprehensive Plan (the "Plan") and the Land Development Regulations then in effect, including the Regulations relating to Dwelling Unit Allocation System (the "ROGO Regulations"). At the time applicants purchased the property, there were no "imminent" or "pending" changes in the ROGO Regulations. After the purchase was completed, Applicants expeditiously obtained their OSDS Construction Permit, had building plans prepared and approved by the County Building Department, and submitted a ROGO application. Applicants received a summary ROGO Score of 18 points. At this point, absent the ROGO allocation system, Applicants would have been issued a building permit. On October 30, 1997 after accomplishing all of this, the first public notice of the proposed changes were published in the Keynoter. On May 22, 1998, just when Applicants neared the top of the ROGO line and had purchased a cesspool credit, the new ROGO Regulations became effective and modified the scoring of points under the permit allocation system. As a result of the new ROGO Regulations, Applicants were deprived of six points, which put them considerably lower down the ROGO line, and which effectively knocked them out of contention for obtaining a permit any time in the near future. 3. Applicants challenged the County's retroactive application of the new ROGO allocation system and filed their Application For Determination of Vested Rights on March 25,1999, seeking to restore the six points which had been taken away from them. The County contended that the provisions of the Plan concerning the ROGO system put Applicants on notice ofthe County's intentto implement the changes. Applicants pointed out that the Plan contains numerous goals and objectives to accomplish certain items, and if they were all treated as constituting notice, there would be so little certainly that it would be impossible to undertake any type of planned activity. Applicants further argued thatthey had conducted themselves in compliance with all applicable codes and regulations, relied upon agency requirements and approvals, and spent substantial sums of money in reliance on the then existing ROGO Regulations and that therefore the County was equitably estopped from CUNNINGHAM. MILLER, HEFFERNAN & WOLFE, L.L.P. 2975 Overseas Highway, Marathon, Florida 33050-0938 - TEL. (305) 743-9427 Page 2 of 3 attempting to retroactively apply the new ROGO Regulations to them. Lastly, Applicants countered that the County was also precluded from applying the ROGO Regulations to them because nb changes to said regulations were pending at the time the ROGO application was submitted. After hearing argument of counsel and receiving the relevant evidence, the Special Master recommended that a Final Beneficial Use Determination be adopted and approved by the Board of County Commissioners awarding the addition of six ROGO points to the Applicants, due to the applicants' having met the criteria for eligibility set forth at 9.5-172, Monroe County Code. 4. Applicants submit that the Special Master's recommendation that a Final Beneficial Use Determination be adopted should be approved by the Board of County Commissioners. As the Special Master found "[I]t would be unfair and unreasonable, and an inequitable financial burden on the applicants to require them to bear the additional costs and delays of waiting four years for an administrative hearing or then requiring the applicants to enter the County's Commercial ROGO system with the 'negative six points'. The Special Master continued that "[T]o subtract six points from the applicant's ROGO score after they had substantially completed the entire permitting process would be unjust and inequitable given the circumstances of this case." As a result, the Special Master concluded that the Applicants had been unjustly deprived of the beneficial use of the subject property. 5. In the alternative, Applicants submit that the Special Masters recommendation for approval should be affirmed as it reaches the right result, even if the Board finds itself in disagreement with the theory upon which it was based. It is well within the power of the Board to affirm his ruling based upon a different theory. (see, Dade County School Bd. v. Radio Station WQBA, 731 so.2d 638, 644- 645 (Fla. 1999) holding that "[I]f a trial court reaches the right result, but for the wrong reasons, it will be upheld if there is any basis which would support the judgment on the record."; see also, Direct Oil Corp. v. Brown, 178 So.2d 13, 15 (Fla. 1965) holding that "[T]he findings of the lower court are not necessarily binding and controHing on appeal, and if these findings are grounded on an erroneous theory, the judgment may yet be affirmed where appellate review discloses other theories to support it."). The special Master's recommendations are also supported by the theory of Vested Rights. As noted, the Special Master recommended that Applicants should be awarded the additional six ROGO points based upon a denial of Applicants' beneficial use of the subject property by the County's retroactive application of the new ROGO point system. While Applicant agrees with the findings of the Special Master, approval of the Special Masters recommendation is also warranted on the basis of the theory of Vested Rights, which is what Applicants applied for. The case of Smith v. Clearwater clearly supports the recognition of Vested Rights. In that case, owners of parcels of land who intended to construct high-rise units with parking below, brought an action challenging the city's zoning ordinance amendments. 383 So. 2d 681 (Fla. App. 2nd Dist. 1980). After a lengthy and informative discussion of Florida law concerning equitable estoppel and the effect of pending zoning changes, the court enunciated the rule that "even if he has not made the substantial expenditures in reliance upon the city's position necessary to create an estoppel, he is still entitled to obtain a building permit which is within the provisions of existing zoning so long as the rezoning ordinance which would preclude the intended use is not pending at the time when a proper application is made". (emphasis added) Id., at 689. Here, much like in Smith. the Plan CUNNINGHAM. MILLER, HEFFERNAN & WOLFE, L.L.P. 2975 Overseas Highway, Marathon, Florida 33050-0938 - TEL. (305) 743-9427 Page 3 of 3 contemplates a change to the ROGO Regulations, but the County had not made the changes to reflect this when the ROGO application was filed and was still awarding points based on the system in place. In Smith, the existence of the Plan did not even seem to be a factor. The court was aware of the city's comprehensive plan and apparently did not believe that this constituted notice to the owners of pending zoning changes as the court held the zoning changes were "pending" only when the appropriate administrative department was actively pursuing the zoning change. Id., at 689. "Active pursuit" as that term is used here means that there must be active and documented efforts on the part of those authorized to do the work which, in the nonnal course of municipal action, culminate in the requisite zoning change. Id., at 689. The mere existence of language in a comprehensive plan is not the requisite active pursuit as espoused in Smith. The "purpose of a comprehensive plan is to set general guidelines for future development, and not necessarily to accomplish immediate land use changes." Southwest Ranches, 502 So. 2d 936, as cited in Lee Countv v. Sunbelt Eauities II. Ltd.. Partnership. 619 So. 2d 996, 1004 (Fla. 2nd DCA 1993). The mere existence of the language in the Plan is not enough to put Applicants on notice of a pending change in regulations as the Plan does not have an immediate effect and without more cannot be considered an active pursuit of the proposed changes. As such, Applicants' are entitled to the six points lost due to the changes imposed by the County as their rights had vested in the six points. 6. In conclusion, as the Special Master in his recommendation aptly seemed to have applied the principle recognized under Florida law that equity regards that as done which ought to have been done. As such, it is clear that the County should be equitably estopped from applying the revised ROGO Regulations due to the substantial sums expended by the Applicants and the granting of permits (OSDS) and approvals (Building Department). Additionally, the new ROGO Regulations should not be applied retroactively, because the Applicants had already filed the ROGO application (and fulfilled all the necessary prerequisites prior to the filing) prior to the first notice of the proposed changes to the ROGO Regulations. Thus, the proposed changes were not pending at the time of filing. Accordingly, the six points lost due to the changes should be restored to the Owners. WHEREFORE, Applicants respectfully request the BOCC accept and/or modify and accept the proposed beneficial use detennination and GRANT the application for beneficial use. Dated: October 13,2000 By: JOHN 1. W Florida B Cunning , Miller, Heffernan & Wolfe, LLP 2975 Overseas Highway Marathon, FL 33050 305-743-9427 305-743-7489 (fax) CUNNINGHAM. MILLER, HEFFERNAN & WOLFE. L.L.P. 2975 Overseas Highway, Marathon, Florida 33050-0938 - TEL. (305) 743-9427