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Item T5 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: April 20, 2005 Division: Growth Management Bulk Item: Yes_ No~ Department: Planning Staff Contact Person: K. Marlene Conaway AGENDA ITEM WORDING: A pubic hearing to consider an Interim Development Ordinance (IDO) deferring the acceptance of applications for redevelopment and conversion of marine facilities including commercial marinas and working waterfront within 365 days of the effective date of the Ordinance or when the comprehensive plan and land development regulations become effective, whichever comes first. (First of two public hearings) ITEM BACKGROUND: Monroe County is experiencing the loss of and redevelopment of marine facilities including commercial marinas and the working waterfront including boat yards, wet and dry storage, fish houses and commercial fishing vessel dockage at an unprecedented rate. The County finds that it is necessary to enact an Interim Development Ordinance deferring the acceptance of development applications that seek development approval for the redevelopment and conversion of marine facilities and working waterfront properties. The proposed IDO is supported by Goals and Objectives of the 2010 Comprehensive Plan. Goal 212 directs the County to prioritize shoreline land uses and establish criteria for shoreline development in order to preserve and enhance coastal resources and to ensure the continued economic viability of the County. Goal 213 directs the County to ensure adequate public access to the beach or shoreline. Objective 502.1 directs the County to promote the preservation and enhancement of the existing ports and port related activities. The Florida State Senate is hearing legislation (SBP 7040) which will, among other elements, include requirements that local comprehensive plans for coastal counties include criteria to encourage the preservation of recreational and commercial working waterfronts. The County has contracted with South Florida Regional Planning Council to prepare a public water access and marine facilities plan and develop implementation measures including Comprehensive Plan and Land Development Regulations. At the March 10, 2005 public meeting of the Development Review Committee, the Committee voted to recommend approval of the proposed IDO to the Planning Commission. At the March 23, 2005 public meeting of the Planning Commission, the Commission continued the item to the April 13, 2005 Planning Commission in Marathon. At the April 13, 2005 Planning Commission meeting, it is anticipated that the Commission will recommend action to the Board of County Commissioners. PREVIOUS REVELANT BOCC ACTION: The Board of County Commissioners at a regular meeting on January 19, 2005, directed staff to prepare an interim development ordinance to prevent further redevelopment and conversion of marine facilities including commercial marinas and the working waterfront, and to implement a policy of "No-Net-Loss" of public access to marine facilities while County legislation is being prepared. CONTRACT/AGREEMENT CHANGES: NI A STAFF RECOMMENDATIONS: Approval TOTAL COST: N/ A BUDGETED: Yes _No N/A COST TO COUNTY: N/A SOURCE OF FUNDS: N/A REVEl'.T{JE PRODUCING: Yes N/A No Year APPROVED BY: County Attorney DIVISION DIRECTOR APPROVAL: DOCUMENT A TION: Included X DISPOSITION: AGENDA ITEM # INTERIM DEVELOPMENT ORDINANCE DEFERMENT OF DEVELOPMENT APPLICATIONS FOR THE REDEVELOPMENT AND CONVERSION OF MARINE FACILITIES AND THE WORKING WATERFRONT BOARD OF COUNTY COMMISSIONERS KEY WEST APRIL 20, 2005 SGCC-IDG - Workhlg Walecfront Page I of /4 April 4, 2005 INTERIM DEVELOPMENT ORDINANCE A REQUEST BY MONROE COUNTY DEPARTMENT OF PLANNING AND ENVIRONMENTAL RESOURCES TO ADOPT AN INTERIM DEVELOPMENT ORDINANCE (IDO) DEFERRING THE ACCEPTANCE OF APPLICATIONS FOR REDEVELOPMENT AND CONVERSION OF MARINE FACILITIES INCLUDING COMMERCIAL MARINAS AND THE WORKING WATERFRONT WITHIN 365 DAYS OF THE EFFECTIVE DATE OF THE ORDINANCE OR WHEN THE COMPREHENSIVE PLAN AND LAND DEVELOPMENT REGULA TIONS BECOME EFFECTIVE. RECOMMENDA TIONS Staff: Approval DRC: Approval PC: Approval March 10, 2005 March 10, 2005 April 13, 2005 Staff Report Resolution #D -05 Resolution #P -05 SOCC-IDO - Working Wateifront Page 2 of 14 April 4, 2005 BOCC-IDO - Working Watnfronl DRAFT BOCC ORDINANCE Page 3 of 14 April 4, 2005 ORDINANCE NO. 2005 AN ORDINANCE BY THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS ADOPTING AN INTERIM DEVELOPMENT ORDINANCE DEFERRING THE ACCEPT ANCE OF DEVELOPMENT APPLICATIONS FOR THE REDEVELOPMENT AND CONVERSION OF MARINE FACILITIES INCLUDING COMMERCIAL MARINAS AND THE WORKING WATERFRONT UNTIL LAND DEVELOPMENT REGULATIONS AND COMPREHENSIVE PLAN AMENDMENTS ARE DRAFTED; PROVIDING FOR EXEMPTIONS; PROVIDING FOR TRANSMITTAL TO FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS (DCA); AND PROVIDING FOR EXPIRATION WITHIN 365 DAYS OF THE EFFECTIVE DATE OF THE ORDINANCE OR WHEN THE AMENDMENTS BECOME EFFECTIVE, WHICHEVER COMES FIRST. WHEREAS, the Board of County Commissioners at their meeting of August 18, 2004, directed staff to have a public water access and marine facilities plan prepared for Monroe County; and \VHEREAS, the Board of County Commissioners discussed a policy of "No Net Loss" of working waterfront or public access to the waterfront policy at their December 16, 2004 meeting; and WHEREAS, Monroe County is experiencing the loss of afIfl-working waterfront and the loss of public access to the water due to the redevelopment of marine facilities, including commercial marinas, and the working waterfront, including boat yards, wet and dry storage, fish houses and commercial fishing vessel dockage, at an unprecedented rate; and WHEREAS, the continued loss of working waterfront and public access in the County is and will be detrimental to the economic and social wellbeing and the health, safety, and welfare of the citizens of the County; and WHEREAS, there is a great concern that if nothing is done if the Comprehensive Plan and land development rcgulations are not amended to control certain conversions and #tis redevelopments, future losses of waterfront facilities working waterfront and public access will negatively affect the economy and bring an end to critical marine services (e.g. boat yards), commercial marinas that are available to the public, and traditional trades associated with commercial fishing; and WHEREAS, it is necessary to undertake a comprehensive and deliberate analysis of the economic, social, and quality of life implications of continued conversions and redevelopments and the impact of same on the public access and working waterfront; and WHEREAS. preserving the status quo while undertaking said analysis will ensure that BOCC-lDO -Working Waterfi'ont Page I 0(7 April 12, 2005 the County's problems related to diminished public access and loss of working waterfront will not be exacerbated during the time it takes to prepare a wcll-reasoned and equitable planning and regulatory program; and WHEREAS, preserving the status quo for a temporary period of time will prevent development that could be inconsistent with the Comprehensive Plan and/or with pending changes to the Comprehensive Plan or land development regulations: and WHEREAS, a number of waterfront owners are exploring the possible change of use of their property to private residential uses and private exclusive use of dockage which will further decrease the public access and/or working waterfront; and WHEREAS, Goal 212 of the 2010 Comprehensive Plan directs the County to prioritize shoreline land uses and establish criteria for shoreline development in order to preserve and enhance coastal resources and to ensure the continued economic viability of the County; and WHEREAS, Goal 213 of the 2010 Comprehensive Plan directs the County to ensure adequate public access to the beach or shoreline; and \VHEREAS, Objective 502.1 of the 2010 Comprehensive Plan directs the County to promote the preservation and enhancement of the existing ports and port related activities; and WHEREAS, the County does not have an acctifate needs to update and augment its inventory of public access points, pertinent waterfront facility locations and specific waterfront uses in order to have ami a thorough and accurate understanding of the socio-economic data on existing waterfront marine facilities; and WHEREAS, the acceptance or processing of development applications during the term of this ordinance would result in confusion for property owners, inefficiencies in governmental services, and potentially redundant review processes and may unreasonably affect the expectations of property owners; and WHEREAS, the approval of development applications for conversions and redevelopment, as described herein, will result in the continued and irreversible loss of public access and working waterfront; and WHEREAS, the exemption of certain uses and development actIVItIes, as provided herein, advances the intent of this Ordinance and will not diminish public access or further the loss of working waterfront; and WHEREAS, the County recognizes the need to develop comprehensive plan and land development regulations and programs to preserve marine facilities including commercial BOCC~1DO eWorking Walelfront Page 2 of7 April J 2. 2005 marinas that offer public access and provide for working waterfront that offer public access; and WHEREAS, the Board of County Commissioners at their meeting of January 19,2005, voted to contract with the South Florida Regional Planning Council to prepare the public water access and marine facilities plan and implementation measures including Comprehensive Plan and Land Development Regulations; and WHEREAS, the County has committed necessary staff and resources to the development of these policies and regulations; and WHEREAS, this interim Ordinance and the planned amendments to the Plan and land development regulations are necessary to protect the health, safety, and general welfare and to advance the policies set forth in the Comprehensive Plan~ and \VHEREAS, the utilization of the moratorium device as a temporary measure to facilitate government decision making, study and adoption of comprehensive plan and land development regulations is a legitimate governmental tool to facilitate logical and considered growth and as a means of avoiding inefficient and ill-conceived development; and WHEREAS, the County finds that it is necessary to enact an Interim Development Ordinance deferring the acceptance of development applications that seek development approval for the redevelopment of waterfront properties; and WHEREAS, the County finds that a 365-day deferment of development applications and approvals as provided herein is reasonable and is the minimum necessary to protect the health, safety, and general welfare of the citizens of the County and to implement the Comprehensive Plan; and WHEREAS, the temporary deferral of development applications and approvals, as provided herein, are not intended nor shall it be construed to inhibit the existing lawful use of properties in accordance with the Comprehensive Plan and land development regulations; and WHEREAS, Chapter 125, F.S. authorizes the Board of County Commissioners to adopt ordinances to provide standards protecting against imminent and immediate threat to the health, safety and welfare of the citizens of Monroe County; and \VHEREAS, this Interim Development Ordinance constitutes a valid exercise of the County's police power and is otherwise consistent with Section 163.316, et seq., F.S., which, inter alia, encourages the use of innovative land development regulations including provisions like moratoria to implement the adopted comprehensive plan; and WHEREAS, the Board of County Connnissioners at a regular meeting on January 19, BOCC-IDO ~Working Walerfront Page 3 of7 April! 2, 2005 2005, directed staff to prepare an ordinance deferring acceptance of applications for redevelopment of marine facilities including commercial marinas and the working waterfront (boat yards, wet and dry storage, tlsh houses and commercial fishing vessel dockage) that would diminish public access or result in the loss of working front, while staff prepares amendments to the 20 I 0 Comprehensive Plan and Land Development Regulations; and WHEREAS, following direction of the Board of County Commissioners, the Growth Management staff immediately undertook the development of this Interim Development Ordinance and preparation of a contract for the development of a public water access and marine facilities plan and implementation measures including Comprehensive Plan and Land Development Regulations; and WHEREAS, the Planning Commission has reviewed the draft Interim Development Ordinance and considered rooommended approval to the Board of County Commissioners; and WHEREAS, the Board of County Commissioners has reviewed and considered the draft Interim Development Ordinance recommended by the Planning Commission and Planning staff; and NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA: Section 1. The purpose and intent of this Interim Development Ordinance is to implement the Board of County Commissioners' directive of January 19, 2005, to prepare an interim development ordinance to prevent further redevelopment and conversion of marine facilities including commercial marinas and the working waterfront, that result in the loss of working waterfront and diminish public access a:aa in order to implement a policy of "No-Net-Loss" of working waterfront and public access to marine facilities while legislation is being prepared. Section 2. Except as provided tor in Section 5 of this ordinance, R:redevelopment and conversion of existing uses and structures, as used in this ordinance, includes the following: . Any change of use from a water dependent use to a water enhanced or a non-water dependent use of a commercial marina. . Any division of uplands and/or bay bottom of existing marine facilities into individual parcels regardless of type of ownership. . Any modification, improvements or expansions of existing marine facilities, resulting in the loss of public access from both land and water to the v.'aterfront and '.vater body. . Any change of use of the working waterfront to a commercial marina or a non-water dependent use. Section 3. The following definitions apply in this ordinance: B()CC~fDO ..Working WateJjiYHlI Page 40f7 April!l. l005 . Existing uses and structures means those uses and structures in existence prior to and including February 28, 2005. . Commercial marina means a facility with three or more slips for the mooring, berthing, storing or securing of watercraft and may include accessory retail and service uses, but not including docks accessory to land based dwelling units or individual berths under private ownership. . Marine facility means commercial marinas, the working waterfront, and any other public access point including boat ramps that provide public access to the navigable waters of the state. . Public access means the ability of members of the public to physically reach, enter, or use a water-body by either land or water. . Working waterfront means a parcel or parcels of real property that provide access for water dependent boat yards, wet and dry storage, fish houses (fish landings, processing and packaging) and commercial fishing vessel dockage; it does not mean commercial marinas for the dockage of pleasure craft. . Water dependent use means a use or portions of a use that can only be carried out on, in or adjacent to water areas because the use requires access to the water body. . Water enhanced use means a use that is not a water dependent use but benefits economically or aesthetically by its location on the waterfront; examples include restaurants, hotels and residential uses. Section 4. During the time this ordinance is in effect as specified herein, there shall be a moratorium upon the issuance of building permits, acceptance of development applications or issuance of development orders and development permits within unincorporated Monroe County concerning the redevelopment or conversion of existing uses and structures related to marine facilities, including commercial mminas and the working waterfront, that result in diminished public access or loss of working waterfront, except as provided herein. Section 5. Exempt from this ordinance is are the following: . Development under an approved Conditional Use Permit, general maintenance, repair and/or safety improvements~ and, . Any modification, improvements, or expansion to existing marine facility that does not diminish public access and does not result in the loss of working waterfront. Section 6. Pursuant to its lawful authority and the pending legislation doctrine as set forth in Smith v. Citv of Clearwater, 383 So.2d 681 (Fla. 2d DCA, 1980) the Board of County Commissioners hereby establishes the interim development regulations set forth in this Ordinance, which shall remain in full force and effect until the expiration of this legislation within one year of its effective date or whenever the plan and land development regulations Boce.IDO -Working Waterfront Page 5 of7 April!2, 2005 become effective, whichever comes first. Section 7: Until expiration of this Interim Development Ordinance no application for a building permit or development approval for any development or redevelopment, that meets the criteria for review identified in Section 2 hereof, shall be granted pursuant to an application or request with a submittal date of March 1,2005, or later. Section 8: Any application for a building permit or development approval ~ith a submittal date of February 28,2005, or earlier shall be exempt from this Interim Development Ordinance. Section 9: As of the effective date of this Ordinance no application for a building permit or development approval, meeting the criteria for review identified in Section 2 hereof, shall be accepted or processed by the Growth Management Division, except applications exempt hereunder and development awarded a vested rights determination pursuant to Section 11 hereof. Section 10: This Ordinance shall not be construed to prohibit the application for or issuance of a building permit or development approval for any development or redevelopment that does not meet the criteria for review identified in Section 2 hereof, or that does not result in diminished public access or the loss of working waterfront, that is allowed pursuant to the Monroe County Land Development Regulations and the 201 0 Comprehensive Plan. Section 11: Any property owner adversely affected by the provlSlons of this Interim Development Ordinance may seek a determination that the owner's proposed development or redevelopment is vested against the provisions of this Interim Development Ordinance, by filing with the Director of Growth Management, together with an administrative fee in the amount of $400, a vested rights application setting forth facts establishing the applicant met, prior to the date that this Ordinance is adopted by the Board of Monroe County Commissioners, the vested rights standards set forth in Section 9,5-181, Monroe County code. Such application must be filed no later than sixty (60) days after the effective date of this ordinance. Section 12: The County Administrator is directed to have the Growth Management Division begin immediately preparing the draft text amendments and other supporting studies in cooperation with the Planning Commission in order to address the issue of redevelopment and conversion of marine facilities that result in diminished public access or the loss of working waterfront. Section 13. If any section, subsection, sentence, clause, item, charge or prOVISIon of this ordinance is held invalid, the remainder shall not be affected by such invalidity. Section 14. All ordinances or parts of ordinances in conflict with this ordinance are hereby repealed to the extent of said conflict. Section 15. The ordinance is hereby transmitted to the Florida Department of Community Affairs pursuant to Chapter 380, Florida Statutes and the DCA is requested to review and approve it by Immediate Final Order in accordance with F.S.120.569(2)(n), in recognition of the public importance of retaining the working waterfront, marine facilities, and public access to the waterfront, and to prevent the threat of further loss thereof as "an immediate danger to the public health, safety, or welfare". BOCC-IDO -Working WaterfroM Page 60f7 Aprill2. 2005 Section 16. This ordinance shall be filed in the Office of the Secretary of State of the State of Florida, but shall not become effective until a notice is issued by the Department of Community Affairs or Administration Commission approving ordinance pursuant to Florida Statutes, Chapter 380. Section 17. This ordinance shall stand repealed as of 11 :59 p.m. on the 365th day after the effective date of the Ordinance, unless repealed sooner by the Board of County Commissioners or upon the adoption of amendments to the comprehensive plan and land development regulations addressing public access and marine facilities. PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida at a regular meeting held on the _ day of , 2005. Mayor Dixie Spehar Mayor Pro Tem Charles "Sonny" McCoy Commissioner Murray NelsOIi Commissioner George Neugent Commissioner David Rice BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA BY Mayor Dixie Spehar (SEAL) ATTEST: DANNY L KOLHAGE, CLERK MONROE COUNTY ATTORNEY APPR9V~P A~ TO FORM ~ // t~;'r:;~~/} Ioi .j .~s ,{C)i"{C Deputy Clerk Oil : BOCC~[f)O -Working Waierfi-orrl Page 70f7 April J 2, 2005 Baec Staff Reporl~IDa~ Working Water:!i"Onl BOCC STAFF REPORT Page 10 of 14 April 4, 2005 Monroe County Department of Planning and Environmental Resources 2798 Overseas Highway Marathon Florida 33050 ~ April 1, 2005 TO: Board of County Commissioner FROM: K. Marlene Conaway, Director of Planning and Environmental Resources RE: Interim Development Ordinance-Marine Facilities and Working Waterfronts fvfEETING DATE: April 20, 2005 Summary The Board of County Commissioners (BOCC) at a regular meeting on January 19, 2005, directed Growth Management staff to prepare an Interim Development Ordinance (IDO) defening the acceptance of applications for redevelopment and conversion of marine facilities including commercial marinas and the working waterfront (boat yards, wet and dry storage, fish houses and commercial fishing vessel dockage) while staff prepares amendments to the 2010 Comprehensive Plan and Land Development Regulations (LDR). Concurrently, following direction of the BOCC at the same regular meeting on January 19, 2005, Growth Management staff immediately undertook the development of this Interim Development Ordinance and preparation of a contract for the development of a public water access and marine facilities plan and implementation measures including 2010 Comprehensive Plan and Land Development Regulations. This rDO provides for specific exemptions and clarifying definitions. The IDO is to expire within 365 days from the effective date of the Ordinance, or when the 2010 Comprehensive Plan and LDR amendments become effective, whichever comes first. Background Monroe County is experiencing the loss of and redevelopment of marine facilities and the working waterfront including commercial marinas, boat yards, wet and dry storage, fish houses and commercial fishing vessel dockage, at an unprecedented rate. A number of waterfront owners are exploring the possible change of use of their property, to private residential uses and private exclusive use of dockage which will further decrease the public access and working waterfront usages. There is great concern that if nothing is done to control this redevelopment that future losses of waterfront facilities will negatively affect the economy and bring an end to critical marine services (e.g. boat yards), commercial marinas that are available to the public and traditional trades associated with commercial fishing and other water-dependent uses. The pressure to redevelop waterfront properties to non-water related or non-water dependent type uses is such that unless acceptance of such applications is deferred, there is not time to write land development regulations or Comprehensive Plan amendments to adequately address the probable negative impacts of the rapid rate of change. The County does not have an accurate inventory of pertinent waterfront facility locations and specific waterfront uses and a thorough understanding of the socio-economic data on existing BOCC Stqff Report-IDO- Working Waterfront Page 11 of /4 April 4, 2005 waterfront marine facilities. However, the County recognizes the need to develop comprehensive plan and land development regulations and programs to preserve marine facilities including commercial marinas and the working waterfront. A "no net loss" of public access to the waterfront policy was discussed by the BOCC at their December 16, 2004, meeting. To meet these needs, the Board of County Commissioners, at their meeting of August 18, 2004, directed staff to have a public water access and marine facilities plan prepared for Monroe County. At their meeting of January 19,2005, the BOCC voted to contract with the South Florida Regional Planning Council to prepare the public water access and marine facilities plan and implementation measures including Comprehensive Plan and Land Development Regulation amendments. The contract to prepare the plan and implementation measures is further substantiated by Goal 212 of the 2010 Comprehensive Plan which directs the County to prioritize shoreline land uses and establish criteria for shoreline development in order to preserve and enhance coastal resources and to ensure the continued economic viability of the County; Goal 213 of the 2010 Comprehensive Plan which directs the County to ensure adequate public access to the beach or shoreline; and Objective 502.1 of the 2010 Comprehensive Plan which direct the County to promote the preservation and enhancement of the existing ports and port related activities. Furthermore, the Florida State Senate is reviewing a proposed committee bill, SPB 7040, which will include enunciating the State's interest in maintaining recreational and commercial working waterfronts and public access to waterfront property, and require the future land use plan element of local comprehensive plans for coastal counties to include criteria to encourage the preservation of recreational and commercial working waterfronts. Provision of tax incentives and deferrals are also included in SPB 7040. The confidence level of this legislation passing is high. The purpose of the proposed deference of accepting applications is to provide time for the preparation of the public water access and marine facilities plan and implementation measures by the South Florida Regional Planning Council. This IDO will also provide time for staff to draft the necessary Land Development Regulations and 2010 Comprehensive Plan amendments, the Planning Commission to review the proposed changes and the public time to consider, understand and comment on the amendments. Monroe County is acting expeditiously by proposing this Interim Development Ordinance so that Comprehensive Plan and LDR amendments can be developed which will be in coordination with the pending State legislation. Redevelopment and conversion of existing uses and structures, as used in this Ordinance, includes the following: . Any change of use from a water dependent use to a water enhanced or a non-water dependent use of a commercial marina. . Any division of uplands and/or bay bottom of existing marine facilities into individual parcels regardless of type of ownership. . Any modification, improvements or expansions of existing marine facilities resulting in loss of public access from both land and water to the waterfront and water body. . Any change of use of the working waterfront to a commercial marina or a non-water dependent use. BOCC Staff Report-IDO- Working Waterfront Page 12 of14 April 4. 2005 The following definitions apply in this ordinance: . Existing uses and structures means those uses and structures In existence prior to and including February 28, 2005. . Commercial marina means a facility with three or more slips for the mooring, berthing, storing or securing of watercraft and may include accessory retail and service uses, but not including docks accessory to land based dwelling units or individual berths under private ownership. . Marine facility means commercial marinas, the working waterlront, and any other public access point including boat ramps that provide public access to the navigable waters of the state. . Public access means the ability of members of the public to physically reach, enter or use a water-body by either land or water. . Working waterlront means a parcel or parcels of real property that provide access for water dependent boat yards, wet and dry storage, fish houses (fish landings, processing and packaging) and commercial fishing vessel dockage, it does not mean commercial marinas for the dockage of pleasure craft. . Water dependent use means a use or portions of a use that can only be carried out on, in or adjacent to water areas because the use requires access to the water body. . Water enhanced use means a use that is not a water dependent use but benefits economically or aesthetically by its location on the waterlront, examples include restaurants, hotels and residential uses. The following exemptions are provided in this Ordinance: . Exempt from this ordinance is development under an approved Conditional Use Permit, general maintenance, repair and/or safety improvements. . Any application for a building permit or development approval with a submittal date of February 28, 2005 or earlier shall be exempt from this Interim Development Ordinance. Until expiration of this Interim Development Ordinance, no building permit application or planning approval for any development or redevelopment that meets the criteria as used in this ordinance, shall be granted pursuant to an application or request with a submittal date of March 1, 2005, or later. This ordinance shall not be construed to prohibit the issuance of a building permit or planning approval for any development or redevelopment that does not meet the criteria for review identified as "redevelopment" or "conversion" as used in this ordinance that is allowed pursuant to the Monroe County Land Development Regulations and the 2010 Comprehensive Plan. soee StaffReport.lDO.Workillg Waterfront Page 13 (~f 14 April 4, 2005 As of the effective date of the ordinance, no building permit application or development approval meeting the criteria for review identified as "redevelopment" or "conversion" as used in this ordinance, shall be accepted or processed by the Growth Management Division, except applications exempt hereunder and development awarded a vested rights determination pursuant to the following: Any property owner adversely affected by the provIsIons of this Interim Development Ordinance may seek a determination that the owner's proposed development or redevelopment is vested against the provisions of this Interim Development Ordinance, by filing with the Director of Growth Management, together with an administrative fee in the amount of $400, a vested rights application setting forth facts establishing the applicant met, prior to the date that this ordinance is adopted by the Board of Monroe County Commissioners, the vested rights standards set forth in Section 9.5-181, Monroe County code. Such application must be filed no later than sixty (60) days after the effective date of this ordinance. Staff Recommendation The Planning Staff recommends the Monroe County Board of County Commissioners APPROVE the attached Interim Development Ordinance deferring development applications for the redevelopment and conversion of marine facilities and the working waterfront. Boce StaffReporUDO~Workillg Waterfront Page 14 (if 14 April 4, 2005 Session :Bills : : flsenate.gov Page 1 of 28 Senate Bill s b7040pb CODING: Words ;,trie:kcFI are deletions; words qnd.~IUned are additions. Florida Senate - 2005 (PROPOSED COMMITTEE BILL) SPB 7040 FOR CONSIDERATION By the Committee on Community Affairs 578-957A-05 1 2 3 4 5 6 7 8 9 A bill to be entitled 10 11 12 13 14 15 16 17 18 19 20 21 22 23 An act relating to waterfront property; amending s. 163.31 ZZ / F. S .; requiring the future land use plan element of a local comprehensive plan for a coastal county to include criteria to encourage the preservation of recreational and commercial working waterfronts; including public access to waterways within those items indicated in a recreation and open space element; amending s. 163.31Z~/ F.S.; providing requirements for the shoreline use component of a coastal management element with respect to recreational and commercial working waterfronts; amending s. Z53.~3, F.S.; requiring the Board of Trustees of the Internal Improvement Trust Fund to encourage certain uses for sovereign submerged lands; establishing the WaLerfronts Florida Program within the Department of Community Affairs; providing definitions; requiring that the program implement the Waterfronts Florida Partnership Program in coordination with the Department of Environmental Protection; http://199.44.254.194/cgi-bin/view -page.pl?File=sb 7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page L 01 L~ 24 requiring the Department of Environmental 25 Protection, in coordination with the Fish and 26 Wildlife Conservation Commission, to study the 27 use of state parks for recreational boating; 28 requiring that the department make 29 recommendations to the Governor and the 30 Legislature; amending s. 3ZZ,41, F. S. ; 31 providing for funding certain boating grant 1 CODING: Words f::t:':"i'~lnJn are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 programs administered by the Fish and Wildlife 2 Conservation Commission; amending 5. 328~Z2, 3 F.S.; increasing vessel registration fees; 4 providing for a portion of the fees to be 5 designated for boating grant programs; amending 6 s. J2~,76, F.S.; clarifying the use of funds 7 designated for boating grant programs; creating 8 s. 324.07, F.S.; enunciating the state's 9 interest in maintaining recreational and 10 commercial working waterfronts; defining the 11 term "recreational and commercial working 12 waterfront"; creating 5S. 197.304-197.3047, 13 F.S.; providing a tax deferral for ad valorem 14 taxes and non-ad valorem assessments covered by http://199.44.254.194/cgi-bin/viewyage.pl?File=sb7040pb.html&Directory=session/2005/. .. 4/112005 Session :Bills : : flsenate.gov Page 3 of 28 15 a tax certificate and levied on recreational 16 and commercial working waterfronts; providing 17 certain exceptions; specifying the rate of the 18 deferral; providing that the taxes, 19 assessments, and interest deferred constitute a 20 prior lien on the property; providing an 21 application process; providing notice 22 requirements; providing for a decision of the 23 tax collector to be appealed to the value 24 adjustment board; providing for calculating the 25 deferral; providing requirements for deferred 26 payment tax certificates; providing for the 27 deferral to cease if there is a change in the 28 use of the property; requiring notice to the 29 tax collector; requiring payment of deferred 30 taxes, assessments, and interest under certain 31 circumstances; authorizing specified parties to 2 CODING: Words "tci"hHl are deletions; words are additions. Flor~da Senate - 2005 578-957A-OS (PROPOSED COMMITTEE BILL) SPB 7040 1 make a prepayment of deferred taxes; providing 2 for distribution of payments; providing for 3 construction of provisions authorizing the 4 deferments; providing penalties; providing for 5 a penalty to be appealed to the value 6 adjustment board; providing an effective date. http://199.44.254.194/cgi-bin/view-page.pl?File=sb 7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 4 of 2S 7 8 Be It Enacted by the Legislature of the State of Florida: 9 10 Section 1. Paragraphs (a) and (e) of subsection (6) of 11 section 16:1,117.Z, Florida Statutes, are amended to read: 12 1.f13.31ZZ Required and optional elements of 13 comprehensive plan; studies and surveys.-- 14 (6) In addition to the requirements of subsections 15 (1)-(5), the comprehensive plan shall include the following 16 elements: 17 (a) A future land use plan element designating 18 proposed future general distribution, location, and extent of 19 the uses of land for residential uses, commercial uses, 20 industry, agriculture, recreation, conservation, education, 21 public buildings and grounds, other public facilities, and 22 other categories of the public and private uses of land. 23 Counties are encouraged to designate rural land stewardship 24 areas, pursuant to the provisions of paragraph (11) (d), as 25 overlays on the future land use map. Each future land use 26 category must be defined in terms of uses included, and must 27 include standards to be followed in the control and 28 distribution of population densities and building and 29 structure intensities. The proposed distribution, location, 30 and extent of the various categories of land use shall be 31 shown on a land use map or map series which shall be 3 CODING: Words f'~ri"]'~n are deletions; words are additions. http://199.44.254.194!cgi-binlview -page. pI ?File=sb7040pb.html&Directory=session/2005/... 4/112005 Session :Bills : : flsenate.gov Page 5 of 28 Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 supplemented by goals, policies, and measurable objectives. 2 The future land use plan shall be based upon surveys, studies, 3 and data regarding the area, including the amount of land 4 required to accommodate anticipated growth; the projected 5 population of the area; the character of undeveloped land; the 6 availability of public services; the need for redevelopment, 7 including the renewal of blighted areas and the elimination of 8 nonconforming uses which are inconsistent with the character 9 of the community; the compatibility of uses on lands adjacent 10 to or closely proximate to military installations; and, in 11 rural communities, the need for job creation, capital 12 investment, and economic development that will strengthen and 13 diversify the community's economy. The future land use plan 14 may designate areas for future planned development use 15 involving combinations of types of uses for which special 16 regulations may be necessary to ensure development in accord 17 with the principles and standards of the comprehensive plan 18 and this act. The future land use plan element shall include 19 criteria to be used to achieve the compatibility of adjacent 20 or closely proximate lands with military installations. In 21 addition, for rural communities, the amount of land designated 22 for future planned industrial use shall be based upon surveys 23 and studies that reflect the need for job creation, capital 24 investment, and the necessity to strengthen and diversify the 25 local economies, and shall not be limited solely by the 26 projected population of the rural community. The future land 27 use plan of a county may also designate areas for possible http://199.44.254.194/cgi-binlview -page.pl?File=sb7040pb.html&Directory=sessionl2005/... 4/112005 Session :Bills : : flsenate.gov ~age 0 or L.O 28 future municipal incorporation. The land use maps or map 29 series shall generally identify and depict historic district 30 boundaries and shall designate historically significant 31 properties meriting protection. 4 CODING: Words~'tr.~ "k'~n are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 3 'r!'Lt~,(;rf1>:;nt::;,~~defincd~.~~_}:' 2", :rL-,-- The future land use 4 element must clearly identify the land use categories in which 5 public schools are an allowable use. When delineating the 6 land use categories in which public schools are an allowable 7 use, a local government shall include in the categories 8 sufficient land proximate to residential development to meet 9 the projected needs for schools in coordination with public 10 school boards and may establish differing criteria for schools 11 of different type or size. Each local government shall 12 include lands contiguous to existing school sites, to the 13 maximum extent possible, within the land use categories in 14 which public schools are an allowable use. All comprehensive 15 plans must comply with the school siting requirements of this 16 paragraph no later than October 1, 1999. The failure by a 17 local government to comply with these school siting 18 requirements by October 1, 1999, will result in the 19 prohibition of the local government's ability to amend the http://199.44.254.194/cgi-binlview--page.pl ?File=sb7040pb.html&Directory=sessionl2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 7 of28 20 local comprehensive plan, except for plan amendments described 21 in s. 163~J187(1) (b), until the school siting requirements are 22 met. Amendments proposed by a local government for purposes of 23 identifying the land use categories in which public schools 24 are an allowable use or for adopting or amending the 25 school-siting maps pursuant to s. 163.31776(3) are exempt from 26 the limitation on the frequency of plan amendments contained 27 in s. 1QJ.31~Z. The future land use element shall include 28 criteria that encourage the location of schools proximate to 29 urban residential areas to the extent possible and shall 30 require that the local government seek to collocate public 31 facilities, such as parks, libraries, and cowmunity centers, 5 CODING: Words R+:::-:; c"]r;] are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 with schools to the extent possible and to encourage the use 2 of elementary schools as focal points for neighborhoods. For 3 schools serving predominantly rural counties, defined as a 4 county with a population of 100,000 or fewer, an agricultural 5 land use category shall be eligible for the location of public 6 school facilities if the local comprehensive plan contains 7 school si~ing criteria and the location is consistent with 8 such criteria. Local governments required to update or amend 9 their comprehensive plan to include criteria and address 10 compatibility of adjacent or closely proximate lands with http://199.44.254.194/cgi-bin/viewyage.pl ?File=sb7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 8 of 28 11 existing military installations in their future land use plan 12 element shall transmit the update or amendment to the 13 department by June 30, 2006. 14 (e) A recreation and open space element indicating a 15 comprehensive system of public and private sites for 16 recreation, including, but not limited to, natural 17 reservations, parks and playgrounds, parkways, beaches and 18 public access to beaches, open spaces, and other 19 recreational facilities. 20 Section 2. Paragraph (g) of subsection (2) of section 21 1Q_3...l1Z.8, Florida Statutes, is amended to read: 22 163~178 Coastal management.-- 23 (2) Each coastal management element required by s. 24 1~:h3J77(6) (g) shall be based on studies, surveys, and data; 25 be consistent with coastal resource plans prepared and adopted 26 pursuant to general or special law; and contain: 27 (g) A shoreline use component u ~ identifies 28 public access to beach and shoreline areas and addresses the 29 need for water-dependent and water-related facilities, 30 including marinas, along shoreline areas. 31 6 CODING: Words jc"r.::_'~kQM are deletions; words ined are additions. Florida Senate - 2005 578-957A-OS (PROPOSED COMMITTEE BILL) SPB 7040 1 2 http://199.44.254.194/cgi-binlview--page.pl ?File=sb7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 9 of 28 3 Section 3. Present subsection (15) of section Z5~.03, 4 Florida Statutes, is redesignated as subsection (16), and a 5 new subsection (15) is added to that section, to read: 6 b~J.03 Board of trustees to administer state lands; 7 lands enumerated.-- 8 9 10 11 12 13 Section 4. 14 ~;..~~ch.0~~ca.l ~~~,~~~~ i~;;!7~!~~,ncc' ariC s'.lr)L'?(-?~~_'l~ tr:i C~'),~~~~rrLurl,~~~}<::~"3 in 15 16 17 18 19 .J.._:r~~~~~a.l,__ q()"]'C~[~ l~~~~~.:::;rl t (':!:!!~~;~Tl::~; i V(~ D_~_dL , 20 21 22 23 24 25 26 27 28 29 ~ 30 31 ~", "~ 7 'j", ~~~ http://199A4.254.194/cgi-bin/viewyage.pl?File=sb7040pb.html&Directory=session/2005/... 4/112005 Session :Bills : : flsenate.gov Page 1001'28 CODING: Words J;:~r' g'~gw. are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 3 4 ~~"'~:.~ c:r"~Lli ca 1_ a ~~i~~! i s t Zt[l c~e r ~L~}~or)(J':;:- t~_, -t r .2;~~~Ejj- n(Lc~~ ;,:i nil , ,'C I Tn,:;~nc.: .l.{:t_L CT"~_.~~~__ 5 i3.~~~?~~i s t ax:{:;e ~J~ c V-l(~_'r-:: er f:t~~~:lt C?~Llun:i.J.:.i<:~ 5 '--:";,~~~~: o~_~'_;~,: 'j::: f J:m~ ~ ::~ 6 7 ~;) ~ 8 9 L.~2L__m~:~.l (~'~m pub 1. j::~:_ ;'~-i C ~-;c~":::-':3 ~~) ; 10 ..( C) _,~~ 1'/_ :i" t i~ q ;j,t-:- in(-J [~~~.i za r'ds ; __~ ;.:lnd 11 12 13 14 15 ct 16 17 18 19 20 21 22 23 { ciJ~_----.E!~t"l d n c i. r~' t h ~;~ -~J .i. a l~J. e t~~r~::~'~?i cJ -L t~'~).r~;3, .1. w~~~~:~~.~ Section 5. http://199.44.254.194/cgi-bin/view yage. pi ?File=sb 7040pb.html&Directory=session/2005/,.. 4/112005 Session :Bills : : flsenate.gov Page 11 of28 24 25 26 27 ."t'~:'~'!':c,~?IfLn\c::Xldat~c~i{)rJ.~~ w;~Jl .~~L_ ::::<<'-~.. _~~~~~~~~~~(0 .1:..S:-~~(,:j, '.c..'-- ~_~.':? tc!". 28 29 30 31 8 CODING: Words ctr"~k",rxl are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 Srl.d" sut)rnit ~~} :r:'~?~)():rt:: s~urnrna.,rj :~::i~n_::li_!~::: f_:Lr~j.i..n'-J.:~~~~ 3 4 5 "', ,', (', .,~ ',..I ',': 6 Section 6. Section 327AZ, Florida Statutes, is 7 amended to read: 8 327.4Z Competitive grant programs.--The commission 9 shall develop and administer competitive grant programs funded 10 with moneys transferred pursuant to ....... 2.QQ,Jl06 ( 1) (d) 11 3J.S..72,J J;'. Grants may be awarded for the construction and 12 maintenance of publicly owned boat ramps, piers, and docks; 13 boater education; deployment of manatee technical avoidance 14 technology; and economic development initiatives that promote 15 boating in the state. The commission may adopt rules pursuant http://199.44.254.194/cgi-bin/viewyage.pl?File=sb 7040pb.html&Directory=session/2005/... 411/2005 Session :Bills : : flsenate.gov Page 12 of28 16 to chapter 120 to implement this section. 17 Section 7. Subsections (1) and (15) of section 1?8.72, 18 Florida Statutes, are amended to read: 19 J?8.72 Classification; registration; fees and charges; 20 surcharge; disposition of fees; fines; marine turtle 21 stickers.-- 22 (1) VESSEL REGISTRATION FEE.--Vesse1s that are 23 required to be registered shall be classified for registration 24 purposes according to the following schedule, and the 25 registration certificate fee shall be in the following 26 amounts: 27 Class A-1--Less than 12 feet in length, and all canoes 28 to which propulsion motors have been attached, regardless of 29 length... . ~ . ~ . 'It . .. . ~ . . . . . . . . . ... . . . .. . . .. .. . . .. . .. . .. .. . . . .. . .. .. . .. .. .. . .... " 30 ~ 31 ..CI..s2.aw~~:; c rJ -~:)_ n. q (:r~.:~~~n t p ~c ::; SL~:iJ rn ~:.;) .. ~ _~:~T~~~~~_:.~.~~_:..C:CT~~~:~m~m,:...~--.:iLm 9 CODING: Words c::r~.C'<'<Qn are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 Class A-2--12 feet or more and less than 16 feet in 2 length............................................. ~ 3 (To county) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2.85 4 ...~ T () J;?S'; ~~~ t~ tJj3~~~:-_I?I~~,~~~JN":._~-_:'_.:~c. ~ _~ . . ~ .. ~ ._~_~ .. ~ . ~ ~ ~_.,,:@:,~:--':~~- \ -, . 5 Class 1--16 feet or more and less than 26 feet in 6 length............................................ .?..~.'.;C ~ http://199.44.254.194/cgi-bin/view-page.pl?File=sb7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 13 of28 7 (To county)............................................... 8.85 8 9 Class 2--26 feet or more and less than 40 feet in 10 length............................................. (<3~) c.!" r:n 11 (To county)............................................ - .32.85 12 1\ rn ~ ~_lLo 3. t =- :":,~ r",... ~J r_,:~;~. x r --~ ~'J ~. ~ :~_:?' .. ~ ~ . .. .. ~ . ~ _ to ~ . . .. . . ~ .. .. ~ .. ~ ~ . ~ ~ .. .. ~ . .~_'.-)~~~ ,-_ ':.- 13 Class 3--40 feet or more and less than 65 feet in 14 length............................................ ~ 15 (To county) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .56.85 16 . (..:L () L~,~~.~~~i~- ~L n. ~:) q -r b n .~:~~_ 'p r D <:r:c ,j.,m~~: ) . . ~ . ~ ~ ~ + ~ . .. . . .. .. . ~ . ~ .. ~ . ~ ~ .. .. . .. ~ ~ ,.' 17 Class 4--65 feet or more and less than 110 feet in 18 length................... _ . . . . . . . . . . . . . . . . . . _ . . . . . } /. 3 ~ 1 9 ( Toe 0 un t y) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 . 85 20 (~L~2_..~r2..odtinq~uwSL~'2n,t Q2~g~g.:r.a:rcl:3) .. ~ .. '_" . ~ .. . . 4 .. 4_~_:'_..~~m~~m=~'~"':_~~': " .. " . ~2.s A CJ 21 Class 5--110 feet or more in length.............. 22 122 :5Q 23 (To county).............................................. 86. 85 24 .(To ~!;)(Jd1:~,:L:r;.q .:J~!~.j!nt p:["oq!~,~~rns) .. . . . 4,~~ M ~ . . ~ . .... _'_~.~:~:.~.: .. .. . . ~ .. ~~~~:'..~. . . 3J., CO 25 Dealer registration certificate ...... ..... .2U.5Q l~ en 26 .. ( 'T' qc~ b i=' a. t 5!'i. ()" <JI.';j.n'l::. p:c :2~J}.:~;iIa,-::' .....~~.... ~~.~ ~.. .>.~ ."~ ~~~... ~ ~'.i' ~ ,,,: l_' 27 28 The county portion of the vessel registration fee is derived 29 from recreational vessels only. 30 (15) DISTRIBUTION OF FEES.--Except for the first $1, 31 which shall be remitted to the state for deposit into the Save 10 CODING: Words ~~t r' c"r4~ are deletions; words are additions. Florida Senate - 2005 (PROPOSED COMMITTEE BILL) SPB 7040 http://199.44.254.194/cgi-binlview.....rage.pl?File=sb 7040pb.html&Directory=session/2005/... 4/112005 Session :Bills : : flsenate.gov Page 140f28 578-957A-05 1 the Manatee Trust Fund created within the Fish and Wildlife 2 Conservation Commission, moneys designated for the use of the 3 counties, as specified in subsection (1), shall be distributed 4 by the tax collector to the board of county commissioners for 5 use as provided in this section. Such moneys to be returned to 6 the counties are for the sole purposes of providing 7 recreational channel marking and public launching facilities 8 and other boating-related activities, for removal of vessels 9 and floating structures deemed a hazard to public safety and 10 health for failure to comply with s. 3ZI.53, and for manatee 11 and marine mammal protection and recovery. 12 13 14 15 (~~.>~~:\ p~.~c,t :i~~~~, .i TJ (~:c_"__~:_i:~P t: ~~,~'~~~'"O r (>~{ _L d,.{~~:,';G-_~:~~~~~ 3 2~. 4 7 ~~~ 16 Section 8. Subsection (1) of section 32~J6, Florida 17 Statutes, is amended to read: 18 32&,76 Marine Resources Conservation Trust Fund; 19 vessel registration funds; appropriation and distribution.-- 20 (1) Except as otherwise specified in this subsection 21 and less $1.4 million for any administrative costs which shall 22 be deposited in the Highway Safety Operating Trust Fund, in 23 each fiscal year beginning on or after July 1, 2001, all funds 24 collected from the registration of vessels through the 25 Department of Highway Safety and Motor Vehicles and the tax 26 collectors of the state, except for those funds designated as 27 the county portion http://199.44.254.194/cgi-binlview-page.pl?File=sb7040pb.html&Directory=sessionl2005/... 4/112005 Session :Bills : : flsenate.gov Page 15 of28 28JJ::,n!:s pOIt:ic[; pursuant ~o s. JZ8]1{1), shall be deposited in 29 the Marine Resources Conservation Trust Fund for recreational 30 channel marking; public launching facilities; law enforcement 31 and quality control programs; aquatic weed control; manatee 11 CODING: Words [''''r; -:,l."?n are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 protection, recovery, rescue, rehabilitation, and release; and 2 marine mammal protection and recovery. The funds collected 3 pursuant to s. ~28.12(1) shall be transferred as follows: 4 (a) In each fiscal year, an amount equal to $1.50 for 5 each commercial and recreational vessel registered in this 6 state shall be transferred by the Department of Highway Safety 7 and Motor Vehicles to the Save the Manatee Trust Fund and 8 shall be used only for the purposes specified in s. T!Q;.1.f. (4) . 9 (b) An amount equal to $2 from each recreational 10 vessel registration fee, except that for class A-I vessels, 11 shall be transferred by the Department of Highway Safety and 12 Motor Vehicles to the Invasive Plant Control Trust Fund in the 13 Department of Environmental Protection for aquatic weed 14 research and control. 15 (c) An amount equal to 40 percent of the registration 16 fees from commercial vessels shall be transferred by the 17 Department of Highway Safety and Motor Vehicles to the 18 Invasive Plant Control Trust Fund in the Department of 19 Environmental Protection for aquatic plant research and http://199.44.254.194/cgi-bin/view-.rage.pI ?File=sb7040pb.html&Directory=session/2005/... 4/112005 Session :Bills : : flsenate.gov Page 16 of28 21 20 control. (d) An amount equal to 40 percent of the registration 22 fees from commercial vessels shall be transferred by the 23 Department of Highway Safety and Motor Vehicles, on a monthly 24 basis, to the General Inspection Trust Fund of the Department 25 of Agriculture and Consumer Services. These funds shall be 26 used for shellfish and aquaculture law enforcement and quality 28 27 control programs. Section 9. Section 342.07, Florida Statutes, is 29 created to read: 30 31 12 CODING: Words f:tri<:.:':9f,l are deletions; words are additions. F10rida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 'I t"~ 3 4 5 6 ,c; -:- 7 8 9 10 http://199.44.254,194/cgi_binJview-page.pl?File=sb7040pb.htm1&Directory=sessionJ2005/... 4/112005 Session :Bills : : flsenate.gov Page 17 of28 11 12 " 13 14 ,:'.~, y- \ ~J ~; 15 16 '- t ~ ; (j ;" ~- i--, ;:::-. '~"i 2:1. ., (;: "-~r-,~ te2t5 L.r)~l.C 17 18 19 20 21 (~/ f r(~~a..1 p ~~S;:I.:(:- r"r~ \;" t ha t: nr:'j;/ .J_ -ct(:: ;j c; (::(;'S E, f'o r \,.;jrJ t (:.~ :t"::::.E:~~~~':.PiX~'lcJ~=::n t 22 23 24 l.\r c:.r: t~,.L n q 1,1.{ <;1 't <:-:~:C E _r <--.' n t >:: =~'~~;,~~:I~:~.:i. :r.' ~,: _ d ' 1";: C t cl(=<:~~~;_' t:() or' ~ L()(~2t:~Lon '-'/;;.L 25 ,"' .~:~ 1:. T~ L c t~ >::: rT~ 26 27 28 ~7~ t~ d, t ~:; G I:"" t h ;~l'~:: f,~ ( 1.L~.~~~~~ ()r recr~~~i:'LOJ1,31" 2i T' ~;~_~~.~~~~ r>!:) c :c -(, 29 n ,( .::j J "\''' (~;:::~ 30 ",;}C u;.~.....; 31 rX)d 13 CODING: Words ,tCtC'-:gj(l are deletions; words are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 http://199.44.254.194/cgi-bin/view-page.pl?File=sb7040pb.html&Directory=session/2005/. .. 4/1/2005 Session :Bills : : flsenate.gov Page 18 of28 3 "ve3~:E~_:l"~ia3 t=hf? S,~,ITle ^ > .! n~~1ZLQ2 r 3:' ."'"h,c t;:;::C.f[ -m.~:!d n ni'~~ 4 5 Section 10. Sections 197.304, 197.3041, 197.3042, 6 197.3043, 197.3044, 197.3045, 197.3046, and 197.3047, Florida 7 Statutes, are created to read: 8 9 ',<0 r k.:; r'. Y'(" ~", .!..;~ -'r+ ~ 10 11 12 13 14 s.J~J.5~.s~ i,-} (~l~ .0 (~ ~~2.2 v E; r {~ d b V. a. t. (;[ x c (~ "C t ~L f i ~~; ~~~~!~5:;'; ~~: c .~~~~_~""u n d (~ :t: -c:: n 1. S 15 ';;~L~,:~.:i-n-t.x}~l: li;j';Ji.~~.d_ on tl}dt p.rC!l?~:~~rt v b'/ ~~~,~"~l:~E!~m..;~rlfJ.;,l~;;J,l 1 6 ~:~.PP J. :h:~.:c:! tic) n ~m~:L.::c -(~ (j x d (:~:L err,'. d .~'" v~' i. -t ~ ~ -t:~ Ii (; C 0";3 n"t Ym..~ t d /: C ~~:' 1 (:-; c t 2I~_,..:.;~ 17 18 '-;:iI-~=: 19 i~~,.0rd(~r~_ t (J a tK.irrna t i :~:91 v dc.rno.ris -;-~..:cat>::~ CCInr>.l. J_ anc:e \~Ji t h t.t}(~ 20 ~:'~~~ r (::rnf~: !l~~ S c: 1: _~~.tl is ~C~(;c:t~L::)n " 21 ,L~ ) /if~E r (... ';/ a.1 of an ap'p~J.caz~0rl i~0r tax d.;~.~f~:~r_r;~l nil .L 22 23 24 t~2X (:ertj.ficat:e sold -"~~--~-- u. n ""~_:=;~~_~~T_ t r ~:L ~L~,.:~; n a r.:: :~ c: T (>tn~~_:::cv;:L.::~;~:;~' ci'j.J.(.~ d,rld __~__c'cc~~ ~~~w,.~,~.____._.~'c. 25 2 6 ~:~ r l ~~~L}::' E;'~ 1~c \/ ~ 27 28 C-'("e 29 is 30 31 14 http://199.44.254.194/cgi-binlview-page.pl?File=sb7040pb.html&Directory=session/2005/.. . 4/112005 Session :Bills : : flsenate.gov Page 19 of28 CODING: Words E +, r ,; S:"~ 2~ are del et ions; words lned are additions. Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 ::~.,[ '<>u. r-i. ';.. Lh,~:i. ;,. e x I:~: ;:::~ e c ::~ 'I l)(-:,r<:(: ~ t <of ':;':~~;3eQ V.~j.j,~~ I' ~Di~~ 3 4 (4) I'he aITlOurlt of ~axe~;, ['l()Fl--ad Vi:i.L0Y'Crf\ 2SS0SSffi8DZS,. 5 ana i,nterest deferre~i stta[.'L accrue i.oter-sst at a rat:e 0qtla:l 6 7 Lbr-, a~'/r:::-:ca.CF:~ .'/,:[,.~::':Ld 'Hi,) rna_tu.:C.:Lt~~/ '......;." >.' ""'j,,'-i.(J-'t.:~: y'ry' :f'.i..x;::~d- j..r ceIL'-::: 8 ~.~ '.1_ " r OI l~_hi::: ~H"." ,'.l,eJ.a i~,::::-t::.i.rZ:~~~.~:!.~.L_~_,..~'~.J<.:tc'rr, .Lnv::~.::~t:rn.'.::~rtt.~'3 (':L~) (" 9 ('" no (';:- 10 ~0 11 12 13 14 15 ana be col~lect,~ed a~~ 01=11E~r 18r15 L c r 'h.m~~_:'{~:0_~~ S f .'.:j ::,~ 0 J:-' () "/ i lj ~~~? d. t C.1: 16 ::~.ucL elf; 1 7 ;:::J:L~? I~'~S sm<':;L '!~ ~:-: I }.n Ci Ln t (; :ce,':.-: t:: ~:~ h ,.::! :' ',.i~.l .;.. '-i r,)e <1 U ,_::~ I pa 'Ii ,_:)D .L~;iI___.,_~:lt!~~~ 18 19 20 21 22 pr',':.ocr:i.bcj Lv tt-lC (:iC'Dd:C r,[T;_,c-::-ri.t Ci.i -J C l~ .:i. ~:; h c'-~J~~:;2J~_!J~Q <,:c-un.t:: .'.-: _w~__~.~_~~__~--'- t. r' ,":;; 23 http://199.44.254.194Icgi-bin/view -page. pi ?File=sb7040pb.htrnl&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 20 of28 24 i'z(;cl l_i 25 26 27 28 f",.-;on ,,-,.;., 29 30 31 15 CODING: Words o;:+<rj glon are deletionSi words Ln00 are additions. 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Florida Senate - 2005 578-957A-05 (PROPOSED COMMITTEE BILL) SPB 7040 1 2 . -c .] http://199.44.254.194/cgi-bin/view-page.pl?File=sb7040pb.htm1&Directory=sessionl2 005/... 4/112005 Session :Bills : : flsenate.gov Page 27 of 28 3 4 {'} :f" 5 ~rlV ~)erS0n aqalrlst ~~] (~S:~E~~_~~~~ili-~_l:::_~_L:_~_~_ :,-". ~::~ ~:) f-; r (: ~:.: C~ r 1 i~),:~(j ~'~_cm 6 7 L '~/ <: ,1- 8 9 Section 11. This act shall take effect July 1, 2005. 10 11 ***************************************** 12 SENATE SUMMARY 13 Defines the term "recreational and corrunercial working waterfronts" for purposes of land use planning and a 14 newly created tax and assessment deferral. Requires that the land use plan element of a comprehensive plan for a 15 coastal county and the shoreline use component of a coastal management element include criteria to encourage 16 the preservation of recreational and corrunercial working waterfronts. Creates the Waterfronts Florida Program 17 within the Department of Community Affairs. Requires that the Department of Environmental Protection, in 18 coordination with the Fish and Wildlife Conservation Commission, study the use of state parks for recreational 19 boating and report to the Governor and the Legislature. Increases vessel registration fees for the purpose of 20 funding boating grant programs. Authorizes a property owner to claim a tax deferral for ad valorem taxes and 21 non-ad valorem assessments covered by a tax certificate and levied on recreational and commercial working 22 waterfronts. Provides procedures for administering the deferral of taxes and assessments. (See bill for 23 details. ) 24 25 26 27 28 29 30 31 21 http://199A4.254.194/cgi-binlviewj)age.pl?File=sb7040pb.html&Directory=session/2005/... 4/1/2005 Session :Bills : : flsenate.gov Page 28 of 28 CODING: Words lO:~r~.s;::k ~N are deletions; words are additions. Disclaimer: The information on this system is unverified. The journals or printed bills of the respective chambers should be consulted for official purposes. Copyright ~ 2000-2004 State of Florida. http://199.44.254.194/cgi-binlview--page.pl?File=sb7040pb.html&Directory=session/2005/... 411/2005 County of Monroe Growth Management Division 2798 Overseas Highway Suite 410 Marathon, Florida 33050 Voice; 305.289. 2500 FAX; 305.289. 2536 Board of County Commissioners Mayor Dixie Spehar, District 1 Mayor Pro Tern Charles "Sonny" McCoy, District 3 George Neugent, District 2 David Rice, District 4 Murray E. Nelson, District 5 MEMORANDUM TO: Board of County Commissioners FROM: Timothy 1. McGarry, Al~W Director of Growth Mapg7~t . I Apnl 6, 2005 DATE: SUBJECT: Public Hearing on Comprehensive Package of Amendments to the Comprehensive Plan and Land Development Regulations for Implementation of Goal 105 - Tier System INTRODUCTION Overview At its March 17, 2005, public hearing and workshop, the Board agreed that each individual Commissioner would send comments and suggestions on the Tier System to the Growth Management Division for review and analysis. Based on these comments and suggestions and Board and staff dialogue at the March public hearing, the staff was directed to prepare recommended options for further revisions to the proposed Tier System for consideration by the Board at its April 20, 2005, public hearing. Purpose The purpose of this memorandum is to provide a framework for conducting the public hearing(s) on the proposed ordinances by providing specific recommendations and options for further revisions to the draft ordinances in a structured manner that will facilitate the Board's decision making on this complex set of ordinances. As addenda to this memorandum, the staffs responses to Commissioner's comments and suggestions and a staff evaluation of Mr. Ed Swift's requested changes to the Tier System are present in Attachment A and B respectively. Page 1 of 12 Public Hearing Procedures and Outcome Similar to the March public hearing, the staff is requesting that all seven ordinances, including the two transmittal resolutions be heard concurrently. However, the staff is requesting that the public be allowed to speak before the staff presentation to the Board. The staff will then proceed to go over each set ofrecommendations and options with the Board. It is the staffs intention for the Board to make a decision on each of these remaining policy issues at the April 17, 2005, public hearing. Based on the Board's direction, the staff will make necessary changes to the draft ordinances amending the Comprehensive Plan and Land Development Regulations. The staff intends to come back to the Board at a May 18, 2005, public hearing with the final draft ordinances. At the May public hearing, the Board will be asked to give its approval of the two resolutions for transmittal of the two ordinances amending the Comprehensive Plan to DCA for review and comment. None of the ordinances amending either the Comprehensive Plan or the Land Development Regulations, including the Tier Overlay District Map, will be adopted until after DCA has reviewed and commented upon the draft amendments to the Comprehensive Plan. TIER SYSTEM RECOMMENDATIONS, OPTIONS AND DECISIONS This section has been structured to facilitate the key decisions that the Board has to make on the remaining outstanding issues regarding the finalization of the proposed amendments to the Comprehensive Plan and Land Development Regulations. To that end, the staff has grouped the key decisions needed to be made by issue area based on the Board's discussion at the March 17 meeting and written comments provided to the Growth Management Division subsequent to that meeting. Additionally, the staff has added two new issues with recommendations that have come to the staff's attention since the March meeting. Not included in this memorandum are any issues or provisions in the ordinances on which the Board has not voiced disagreement, such as the proposed limitation on the number of administrative relief awards. However, should any Board member believe that further discussion is necessary, the Commissioner needs to bring the issue to the Board's attention at the April meeting. Issues from March Meetin2 Increasing Federal and State Legal and Financial Involvement Background: At the March 17, 2005, public hearing, the Board raised concerns about the mandates being placed on the County by the Federal and State governments without sufficient funding. More importantly, the Board voiced its unanimous concern with the general unwillingness of the Federal and State government to fully participate in the legal defense in the "taking claims" and sharing in the cost of this defense resulting from the Page 2 of 12 County implementing these mandates. The Board directed staff to prepare an amendment to the Comprehensive Plan that memorializes the Board's position on this significant issue. Proposed Revision: Amend the Comprehensive Plan by creating Policy 6 that states the policy of Monroe County to use its full powers and resources through its Federal and State representatives and courts of competent jurisdiction to bring the Federal and State governments in as a "third party" and full participant in any litigation arising from County actions to implement the mandates of the Florida Keys Carrying Capacity as set forth by the Florida Administration Commission in this Comprehensive Plan and Federal Endangered Species Act. Staff Recommendation: The staffrecommends approval ofthe proposed revision. Board Decision: Tier I Points Background: At the March 17, 2005, public hearing, the Growth Management Division's Special Legal Counsel indicated his concerns about the point differential between Tier I and III properties. He stated that the point differential of 30 points may be too excessive as applicants could claim that without significant investment it would be fruitless to enter into ROGO, which they may argue is a de facto "taking". The current ROGO scoring system where applicants can receive significant negative points has given the County Special Legal Counsel's concerns. The issue in addressing points is directly related to balancing property rights with public objectives for environmental and habitat protection. Therefore, any increase in points to address property rights issues ("takings claims"), must be carefully weighed against the ramifications for undermining the protection of environmentally sensitive habitat and protected species and public policies to direct development to infill areas. A directly related issue has to do with the Tier System's stated objectives in simplifying the current regulatory system and making it more transparent for property owners. However, if layer upon layer of scoring modifications are needed to be applied to correct problems with the classification of properties into three tiers, the system becomes more complex and less transparent. Options: 1. Retain the exiting assignment of 0 points to Tier I under ROGa. Pro- Retaining the existing assignment of "0" points makes it more difficult for development in Tier I and ensures significant mitigation in the form of land dedication. In addition, it addresses the issues of "buffers" and "secondary impacts", which are not addressed in the current system, but Page 3 of 12 need to be addressed as recommended in the Florida Keys Carrying Capacity Study. In many cases, properties that currently receive a significant number of negative points due to the presence of several protected species will be more competitive, further reducing potential "takings claims". Con- Although some Tier I properties may benefit from the new point system, compared to the existing system, other properties which have less existing upland native habitat and/or lack the presence of endangered species would be more adversely affected. Concerns have been raised that retaining the significant point differential may be considered a de facto "taking" for these properties as they would make prohibitive to be developed. 2. Assign + 1 0 points to Tier I under ROGO Pro- The increase in points assigned to Tier I would make it less difficult to be awarded an allocation to receive a permit for development, which reduces the County's liability to potential takings claims; however, it will still require the property owner to dedicate at least 5 lots to be on par with Tier ill properties. [Note: For Big Pine Key and No Name Key only a 20 point differential exists between Tier I and ill designations.} Con- The application of + 10 points increases the likelihood for development in Tier I of many properties that are now heavily penalized by the presence of protected species and upland native habitat. This impact on the proposed system makes it a less satisfactory than the currently proposed assignment of "0" points in meeting the minimization and mitigation (dedication of lots) requirements of the Tier System. A question that is still difficult to answer is whether or not the need to dedicate five lots to be on par with Tier III properties (estimated to cost at least $150,000) is cost prohibitive, excluding many property owners from getting a permit. 3. Assign +10 points to Tier I under ROGO, but place a cap on the number of allocations that can be awarded in Tier I to 6 (3 in Upper Keys and 3 in Lower Keys. Pro- This option has the same advantages as those for Option 2, but the cap placed on the number of allocations would more satisfactorily achieve the minimization and mitigation requirements than Option 2. A similar cap exists on the number of allocations in Tier I for Big Pine Key and No Name Key. Con- The disadvantages of this option are the same to those for Option 2, but are further minimized by the caps placed on the number of allocation awards in Tier 1. Page 4 of 12 4. Assign -] 0 points to any application in Tier I under ROGO that proposes development within a habitat of a protected species (i.e., endangered/threatened and State protected)as depicted on the County's Endangered and Threatened Plant and Animal Maps and Florida Keys Carrying Capacity Maps. Pro- The assignment of -10 points to any application proposing development within a habitat of a protected species addresses the problem that results from increasing the points for all Tier I properties to + 10. Under the current system, these properties are heavily penalized as negative points are cumulatively assigned based on the number of endangered/threatened species and quality of native upland habitat. Even with the assigning of + 10 points these properties will still be more competitive than under the current ROGO system; however these negative points ensure that such properties will provide more mitigation than required for other Tier I properties that lack these indicators. It will further erode the case for making claims that may be made under the current ROGO system, which assigns a significant number of negative points to these properties. It should be further noted that the presence of protected species is a very good surrogate for the presence of the native habitat that needs to be protected. Con- This option does not penalize properties enough and makes it still too easy to obtain a permit. Staff Recommendation: The staff recommends a combination of Option 2 and Option 4: . assign +10 points to applications in Tier I; and, . assign -10 points to any application in Tier I that proposes development within a habitat of a protected species. Board Decision: Tier II Points Background: At the March 1 ih public hearing, a significant amount of discussion concerned the scoring of Tier II properties in ROGO. The consensus of the Board was that the proposed scoring differential of 10 points was too severe; therefore, retaining this point differential is not an option under consideration. The scoring for Tier II needs to appropriately support the objectives and policies of Comprehensive Plan Goal 105 and more equitably and fairly reflect the real environmental and policy differences between Tier II and III designated properties. Page 5 of 12 Options: 1. Assign +30 points to both Tier I and II under ROGO Pro- The elimination of the point difference between the two designations will reduce much of the opposition to the Tier II designations. Con- The elimination of the point differential would be inconsistent with Goal 105, as it would further encourage development outside of infill subdivisions. In addition it would benefit many properties that would receive negative points under the current system due to habitat; therefore, it does not appropriately support the mitigation and minimization requirements of the Tier system. It will require revisions to the current HEI and its application in at least Tier II areas. This option is not likely to be supported by DCA. 2. Assign +20 points to Tier II under ROGO, but expand vesting by awarding current applications in Tier II that have received a +1 point for habitat +30 points. [Note this option may be combined with other ones.] Pro- This option provides an equitable solution for those property owners that made their investment decisions based on the existing system rules. Con- The option doesn't comprehensively address the policy issue concerning the point differential between Tier II and III designated properties that have been cited by Commissioners and staff. 3. Assign +30 points Tier II under ROGO, but apply a -5 points to those Tier II applications that proposed to clear 2,500 square feet or more of upland native habitat. Pro- This option addresses the concerns raised about encouraging development in upland native habitat inconsistent with the mitigation and minimization requirements of the Tier System that has led to appeals of permits by DCA and a Notice of Violation. [The assignment of -5 points is the deduction made under the current regulations for a moderate quality habitat.] Con- The downside to this option is that it treats the majority of Tier II lots similar to Tier III which is inconsistent with Comprehensive Plan Goal 105 in that it encourages development outside of infill (Tier III) subdivisions. 4. Assign +26 points to Tier II under ROGa.. Pro- This option may more appropriately and equitably recognizes the differences between Tier II and Tier III properties than the current point Page 6 of 12 differential, but at the same time makes Tier III properties more desirable for development, consistent with Comprehensive Plan Goal 105. Con- The only downside is that all Tier II properties are treated equally even those with upland native habitat that must be cleared, which works against mitigation and minimization requirements of the Tier System. 5. Assign +26 points to Tier II under ROGOs, but apply -5 points to applications proposing to clear 2,500 square feet or more of upland native habitat. [Revision of option presented to Board at the March 1 ih public hearing.) Pro- This option improves on Option 4 by not treating all Tier II properties equally in that only properties with upland native habitat that propose significant clearing are penalized, which is more consistent with the mitigation and minimization requirements of the Tier System than Option 2. Con- This option makes administration of the Tier System slightly more complicated. It automatically assumes that a "moderate quality" upland native habitat exists on any property requiring clearing of more than 2,500 square feet, which may not a fair and equitable for all situations. Staff Recommendation: The staff recommends Option 5 as the preferred option: assign + 26 points to Tier II, but apply a -5 points to applications proposing to clear 2,500 square feet or more of upland native habitat. As its second choice, the staff recommends Option 4: assign +26 points to Tier II. [Note: After further analysis conducted since the March public hearing, the staff is no longer in a position to support Option 3, as it assigns the same ROGO point value to both Tier II and Tier IlL] Board Decision: Lottery Background: At the March 1 ih meeting, the staff received no clear direction from the Board concerning the lottery, although subsequently it did receive written comments from one Commissioner opposing the lottery. The County Special Legal Counsel did point out that a lottery may serve a valuable legal purpose in defense of "takings claims" by providing an additional avenue for applicants to obtain a permit. The proposed amendments to the Comprehensive Plan would authorize, but not require the Board to establish both a lottery and competitive system. As proposed, the lottery would only be available for market rate applicants and not for allocations in Big Pine Key and No Name Key. To be eligible, the application must meet the minimum number of points assigned to Tier III properties (i.e., +30); and must be the only application entered into ROGO by an individual, entity or organization. Under the Page 7 of 12 proposed system, a mlmmum of 20 percent of the market rate allocations would be available; this share can be annually adjusted up or down by the Board. The decisions that the Commission must make regarding the lottery include 1) whether or not to make a lottery available; 2) eligibility and conditions for Tier I properties in the lottery system; 3) and limits and share of the market rate allocations to be made available to the lottery system. Retain the lottery as proposed. Pro- The lottery alternative provides an avenue for households that lack the financial resources to compete in the market system, but are not eligible for an affordable housing allocation or not in a position to accept the conditions placed on affordable housing allocations. The system is not intended for developers or individuals who need certainty in the planning of their future residences. It provides an additional legal defense in countering "takings claims". Con- A lottery creates some uncertainty in the development process for individuals, where certainty is desired. It creates additional administrative burden and cost by requiring the County to maintain two separate allocation systems. The lottery may be subject to abuse in that developers and contractors may employ individuals to "front" for their applications. Staff Recommendation: The staff recommends that the Board support a dual lottery and competitive system. Board Decision: Keep Tier I properties eligible for lottery as proposed. Pro- The eligibility for Tier I applications in the lottery system provides an additional protection for the County against "takings claims", as applicants have the opportunity to secure an allocation award with less points than under the competitive system, if the cost to enter the lottery system are not cost prohibitive, which is an issue -see cons. (The staff believes it may well take at least two additional lot dedications above the +30 point threshold for applications to be successful in the competitive system.) Con- Being eligible for the lottery may make property owners less likely to seel their properties to the public increasing the potential development of environmentally sensitive lands and helping to increase the acquisition costs of these properties. If the applicant is required to meet a minimum number of points, it is questionable that applicants with the necessary financial resources would really make use of the lottery option rather than the competitive system based on the marginal difference in costs involved and relatively small impact on the overall development costs of the property. More importantly, even if the point differential Page 8 of 12 between Tier I and ill were reduced as proposed under the Tier I issue, applicants with less financial resources may make the claim that the requirement to add 20 additional points (i.e., dedicating at least 5 lots to the County) to be eligible for the lottery at additional cost of $150,000 is prohibitive and effectively excludes them from developing their property. Of course whether or not these costs are actually prohibitive in terms of the high price Keys market can not be known until tested in court. To address this issue, if the minimum point threshold were lowered to allow less costly entry into the lottery system, it may open Tier I to more development, reduce the mitigation requirements for these properties (in form of lot dedications) and increase the numbers of property owners unwilling to dedicate or sell their property to the State or County. Staff Recommendation: The staff recommends that Tier I properties be made eligible for entry into the lottery with the following conditions: . The application shall be a legally platted URM/IS lot that is within 300 feet of FKAA water service and abuts a paved County or State road; . The applicant must meet a minimum threshold of +22 points; . The application shall not propose development in a protected species habitat (endangered/threatened and State protected species) depicted on the Threatened and Endangered Plant and Animal Species Maps and Florida Keys Carrying Capacity Study; and, . As a condition of its issuance, any permit authorized under a lottery allocation award in Tier I, shall be required to meet the mitigation and minimization recommendations identified by the U.S. Fish and Wildlife Service in its technical coordination review. Board Decision: Retain the fJrovlslOns establishing the number and limits on lottery allocations as {JrofJosed in the draft ordinances. Pro- The proposed initial share of 20 percent (24 allocations) per year for the lottery system is considered a reasonable, but conservative first step in establishing the system. The system provides flexibility in that the Board may annually raise or lower the share of permits to the lottery system, but any increase is limited to 50 percent of the previous year's total and any decrease can be no lower than 20 percent of the total market rate allocations. Additionally, authorizing language in the Comprehensive Plan does not require the County to establish a lottery; therefore, if the lottery proves to unsatisfactory, the Board can amend its Land Page 9 of 12 Development regulations to eliminate its prOVISIOns without amending the Comprehensive Plan. Con- The language provides no maximum cap on the number of lottery allocations that may be eventually made available and for potentially significant increases in the annual number of allocations, which may create further uncertainty in the construction/development community. Staff Recommendation: The staff recommends that a maximum cap of 50% be placed on the number of allocations under a lottery system and the number of allocations in the system can only be increased by 20% annually rather than 50%. Board Decision: Payment for Points under ROGOINROGO Retain the provision for applicants in ROGOINROGO be purchase ROGO points as proposed. Background: The proposed ordinances allow for applicants to purchase up to 3 ROGO points. The fees collected will be placed into a fund for purchase of conservation lands. The basis of the cost for each ROGO point is to be set annually by the Board based on the average assessed value of all privately-owned vacant ISIURM lots divided by four (number of points awarded for dedicated ROGO lot). Pro- The ability to purchase ROGO points is intended to help dampen the rising market value of eligible lots for dedication under ROGO caused by the numbers of lots being dedicated and speculation by real estate investors. As more lots are acquired by the State and County, fewer lots will be available further increasing the market value of these lots. This provision recognizes that even with the number of additional lots eligible for dedication for 1 point, it may be difficult for many individuals to obtain those extra points to make their application competitive enough to receive an allocation award. Additionally, this option will provide the County with an another funding source for its land acquisition efforts. Con- The most significant disadvantage of the payment for points provision is that it requires the County through the Land Authority to expend its resources on identifying and purchasing. With land dedication for points, the private market does this reducing the acquisition costs for the County. Staff Recommendation: The staff recommends that the payment for points provision be retained. Board Decision: Page 10 of12 New Issues Existing Non-residential Uses and Tier System Background: In its further review of the Tier System, the staff recognized that many existing non-residential uses were located in Tier I or II. Unlike residential properties, in order to expand existing non-residential development must go through NROGO to obtain authorization for any additional floor area, which may place an unintended hardship on existing properties. A similar exception is made for existing non-residential development on Big Pine Key. Proposed Revision: Revise the language in NROGO ordinance to permit all eXlstmg lawfully established non-residential uses to be assigned +20 points under NROGO; if the existing use is located within a Tier I area, the assignment of the +20 points will be contingent upon no further clearing of upland native habitat and no addition and/or expansion of the existing lot or parcel upon the use is situated. Staff Recommendation: The staff recommends approval of the proposed revision. Board Decision: Additional Points for Market Rate Housing as Part of an Affordable Housing Project Increase the number points awarded in ROGO from +3 to +5 or +6 for market rate units that are part of an affordable housing proiect. Background: One of requested revisions to the Tier System that Mr. Ed Swift's presented in his letter (Attachment B) to the Board is to increase under ROGO the number of points that can be awarded to market rate housing as part of an affordable housing project. He is requesting that the number of points be increased from +3 to +5 or +6. Under the County's regulations in projects of five units or more, 20 percent ofthe units may be market rate. In reviewing his request, the staff found that the proposed amendments to ROGO calls for +3 points, which is inconsistent with existing regulations in Section 9.5-266. Retaining the +5 points bonus is preferable to only awarding +3 points as the higher point value (higher than a dedicate ROGO lot) more clearly reflects the priorities of the Board to enact measures to promote affordable housing. Staff Recommendation: The staff recommends revising the award from +3 points to +5 points for market rate units that are part of an affordable housing project. Board Decision: CONCLUSION Page 11 of 12 Once the Board has provided direction to the staff on revisions to the proposed ordinances, the staff will prepare revised ordinances to be presented to the Board at the May 18, 2005, public hearing. The County's Special Legal Counsel will be asked to provide a legal memorandum on the defensibility of the final draft ordinances, which will be available prior to the May meeting. At the May meeting, if the Board is amenable, the staff will request that the two resolutions be approved by the Board to transmit the draft ordinances amending the Comprehensive Plan to DCA for review and comment. Attachment A- Board Comments and Suggestions Attachment B- Staff Evaluation ofMr. Ed Swift's Requested Changes to the Tier System Page 12 of 12 ATTACHMENT A BOARD COMMENTS AND SUGGESTIONS Written and oral comments and suggestions concerning the proposed ordinances and Tier System were received from three Commissioners. The comments and suggestions and staff response to each are grouped by issue or policy area. Lack of Adequate Public Funding for Land Acquisition Comment: The Tier I designation makes such lands unbuildable or totally unusable by the property owners. The U.S Constitution requires that the County compensate these property owners for the loss of their properties. Therefore, unless the County has sufficient funds to purchase these properties, the Tier I designation should only be for those lands with highest quality upland native habitat for which the County has the funds to purchase. Response: The Tier I designation does not make these lands unbuildable or totally unusable. Existing developed properties are not affected except if they require an allocation award under ROGO or NROGO. Many of these properties have value for ROGOINROGO dedication purposes or sale ofTDRs. Most of the proposed Tier I designated parcels already have little or no development potential under the present regulations and the Tier System does not make the overwhelming majority of these properties less competitive under the proposed system. Many of these properties contain wetlands and mangroves that were unbuildable prior to the enactment of the 1986 Land Development Regulations. Furthermore, nothing precludes these property owners from competing in ROGO, recognizing that they will most likely have to dedicate at least 8 lots to the County to be competitive. As long as these property owners have some recourse for obtaining development approval, the imposition of the Tier designation does not automatically deprive property owners of their rights or give them a right to a takings claim. Property owners must try to exercise their property rights before their case is considered "ripe" for a takings claim. Under the proposed Tier System and ROGO, if the property owners are not successful after four years in ROGO they may seek administrative relief. The Board has the discretion to either offer to purchase their property or give them a permit and therefore, if sufficient funding is not available to purchase lands, the Board has the option to issue a permit. Page 1 of8 ATTACHMENT A The boundaries of the Forever Florida Program include almost every Tier I designated parcel, except those properties which have asked to be removed from the program. Although the assessed value of privately-owned vacant lands within Tier I is $42 million (Property Tax Appraiser records) less than the $93 million made available under the Forever Florida program, the actual purchase of the price of properties will be higher, especially the longer it takes to acquire these properties for public ownership. Therefore, the County must aggressively move forward to secure more funding for land acquisition as stated in the staff s December memorandum to the Board. However, the actual purchase prices of these properties can not be known until they are purchased. Nothing requires a property owner to sell to the State or County. If the property owner is unwilling to sell or is unwilling to sell the property at its fair market value, then the value of the property will be established through the court system after the property owner has exhausted his administrative remedies to receive development approval for his property. Therefore, it is the staffs opinion that the County does not need to have sufficient funds up front to purchase all designated properties, for the following reasons: (1) development is not automatically prohibited in Tier I and properties in Tier I are not made unusable by the designation; (2) property owners generally must try to exercise their development rights and exhaust administrative remedies before they can support a valid "takings" claim, which will spread out over many years the number of properties that the County will have to purchase due to such claims; (3) many property owners will not exercise their property rights for many reasons, which will allow the County to purchase or acquire these properties over time; and, (4) the administrative relief system allows the issuance of a permit, which provides an escape mechanism should the County have insufficient funds to purchase property due to a potential "takings claim". Page2of8 ATTACHMENT A It is essential that all properties eligible for Tier I designation be so designated so development is discouraged from these environmentally sensitive areas to preclude further fragmentation of habitat and direct/secondary impacts on endangered and threatened species. It is also necessary to clearly communicate to property owners the County's policies concerning the development of their properties in these environmentally sensitive areas and the need for public acquisition to preserve and restore these lands. Encouraging scattered development on these lands that need preservation will only further drive up the cost of acquisition on the remaining lands and generate false expectations for property owners. Tier Designation Issues Comment: Response: The Tier I boundaries contain parcels that have few or no quality native upland habitat. Some of these properties are scarified and have little habitat value. These properties should not be included in the Tier I boundaries. The boundaries of Tier I are intended to include more than just patches of high quality habitat. The criteria for Tier I designation are specifically described under proposed Section 9.5-256 (b)(I) with the primary result of designating all lands necessary to implement the recommendations of the Florida Keys Carrying Capacity regarding minimizing further fragmentation and degradation of habitat and the restoration and enhancement of habitat. Therefore, even though a property may have or appear to have little or no habitat or endangered and threatened species, they are integral to the restoration and protection of wetlands and upland native habitat. These lands are intended to be restored to allow for regrowth and connection of isolated patches and provide buffer areas for both habitat and protected species from developed areas. All of this is essential to the long-term viability of native habitat and wildlife in the Florida Keys. To encourage development on these properties will not only remove these opportunities, but result in further primary and secondary impacts on existing habitat and protected species. A lot- by-lot piecemeal approach to conservation and resource protection that does not comprehensively address loss of habitat and the cumulative impacts on the Florida Keys' endangered and threatened species, which is the problem with the current system. Page 3 of 8 Comment: Response: ATTACHMENT A The following criteria should be included m establishing the Tiers: Tier I · Contain Conservation and Natural Area (CNA) and contiguous lands over two (2) acres; · Dedicated paved roads, scarified lots and existing homes shall be considered breaks in land parcels; · Branches or limbs of existing trees over paved roads do not constitute contiguous; . Two (2) acre parcels or more and CNA lands; · Lands are separated from Tier II and III areas by a paved road. Tier II · Contain parcels of one (1) acre to 1.999 acres that are contiguousc · Subdivisions are less than 50% built out. Tier III . Subdivisions more than 50 % built out. In responding to the suggested criteria, the staff believes that the terms "parcel" and "contiguous lands" referred to in the comments actually means the patch size of upland native habitat, rather than to the real division of property. The lands designated as CNA and Tier I are based on the same criteria; therefore, the inclusion of CNA as part of the criteria only further confuses the matter, as specific criteria were followed to designated the boundaries ofthe CNA, which the Tier I boundaries follow. The Commissioner's proposed criteria for considering "breaks" in habitat patch continuity by using the presence of paved roads and the need for a paved road to be located between Tier I and Tier II/Tier III properties will further reduce the boundaries of Tier I. The reduction of these boundaries will lead to further habitat degradation and fragmentation and adverse impacts on protected species. The criteria in proposed Section 9.5-256(b) presents the specific criteria upon which the CNA, and the Tier I boundaries were drawn. The initial boundaries for Tier I (aka CNA) was based on the FMRl Maps for the Florida Keys. All habitat patches of four or more acres in size and, freshwater and transitional wetlands were Page 4 of8 Comment: ATTACHMENT A included in Tier 1. The endangered and threatened species maps were reviewed and identified areas were added. Existing properties zoned Conservation and Native Area, areas with little or no development or public infrastructure, and lands designated by state and federal agencies for conservation and natural resource protection were also considered in the drafting the maps. In addition, a undeveloped buffer, of up to 500 feet in width was added where appropriate as called for in the Comprehensive Plan and special studies between natural areas and developed areas to reduce secondary impacts. This buffer was reduced where canals or major roadways that served existing residences exist; properties on the other side of these man-made barriers generally received a Tier II designation. Through site visits and review of the most recent aerial photographs, vacant smaller upland habitat patches of less than four acres that can be connected as well as vacant lands that can be restored to connect these habitat patches were identified and included. Where site visits or aerial photographs revealed new development, this was taken into account, mostly in reducing the Tier I boundaries and assigning another designation to these properties. The designation criteria used for Tier II and III are also clearly spelled out in proposed Section 9.5-256(b). The proposed subdivision build out threshold numbers for Tier II and III areas presented by the Commissioner are consistent with this proposed criteria. The proposed changes in threshold patch size for designation conflicts with the criteria used to originally establish the CNA, now Tier I, and Tiers II and III. Except for a couple of isolated patches of habitat almost every habitat patch of two acres of more is contained in proposed Tier I. Tier II contains all remaining habitat patches down to one-half acre or smaller in size. To reduce the threshold to allow one-acre upland habitat patches in Tier III, as suggested, would conflict with the recommendations of the Florida Keys Carrying Capacity Study. These patches should be protected through minimization and mitigation measures required for Tier II properties. All subdivisions should be surveyed by an independent agency to show existing houses, scarified lots, and contiguous parcels ("patches?") over one (1) acre in Tier II and two (2) acres in Tier 1. Page 5 of8 Response: A IT ACHMENT A To ensure public confidence and acceptance of land use data used to prepare the Tier Overlay District Maps, the staff believes it would be worthwhile to contract with another organization or agency to survey and gather information on buildings and land uses that can be entered into the County's Geographic Information System. This project will be completed prior to the final Tier Overlay District Map being considered by the Board. ROGO Scoring for Tier II Designated Properties Comment: Response: Prefers Option #2 (26 points for Tier II and 30 points for Tier III as an equitable spread; does not favor Option # 4, which grandfathers Tier II applicants in the existing system that have a + 1 habitat score - increasing Tier II to 26 points from 20 points addresses fairness issue; and, finds Option #3 acceptable (30 points for either Tier II or III. but deducts 4 points for any application in Tier II clearing more than 1,000 square feet of habitat), but it does not help accomplish planning goal of encouraging development on infilllots. No response is required. Donation of ROGO Lots Comment: Response: Comment: Response: Donated lots in Tier II that are not part of one (1) acre or contiguous parcel ("patch? 'J may be used for affordable housing. The proposed ordinance already allows for Tier II and Tier III lots dedicated under ROGO to be eligible for affordable housing Affordable housing in Tier II is limited to clearing of no more than 5,000 square feet of upland native habitat or the clearing requirements of proposed Section 9.5-347, whichever is greater. Allow Tier 1, II, and III lots to be dedicated for ROGO points. The proposed regulations allow for dedication of lots in all three Tiers; except that in Tier III the lots are for affordable housing only, as no significant upland habitat patches remain in these areas. Payment for ROGOPoints Comment: Response: Let the market determine the price of ROGO lots; the County receives them for free for prese1iiation or affordable housing. The staff is uncertain what this comment is intended to mean. ROGO lots are sold and purchased on the free market. Even if the Page6of8 Comment: Response: Comment: Response: ATTACHMENT A Board opts to allow applicants to purchase up to three points, the value of these points will be based on the average assessed value of all vacant, privately-owned URM/IS lots according to the Property Tax records. The Property Appraiser establishes the assessed value of residential property based on comparable sales data. Sixty-three (63) allocations will be available for market rate permits; this will provide for a higher number donated ROGO lots due to competition. The number of market allocations that will be available will be 126. The 63 number is the minimum number of allocations, if 50 percent are required to be assigned to awards granted under administrative relief. The staff is unsure whether this comment is merely a statement or an indirect way of stating opposition to the purchase of points. However, as the dedication of lots is the primary option under the new ROGO system for applications to add points to be more competitive, the number of lots dedicated for ROGO will increase, particularly as the number of lots and parcels eligible for donation will increase significantly. Supports payment for points. No response is required. Limitation on Administrative Relief Allocation Awards Comment: Response: Lottery Option Comment: Response: Not more than 50% of ROGO allocations shall be used for administrative relief No response is required. Does not support including Tier [lots in the lottery unless there is an over-riding reason to include them in the lottery; if Tier [ is included the number of awards should be limited in anyone year; concerned that the inclusion of Tier I would encourage more applications in Tier 1, decreasing the number of property owners willing to sell in Tier 1. At the March 16th public hearing, the Growth Management Division's Special Legal Counsel favored including Tier I lots in the lottery, which is reflected in his basic concern about the large Page7of8 Comment: Response: Comment: Response: ATTACHMENT A point differential between Tier I and Tiers IIIIlI. In his opinion, the lottery would provide a possibility for a Tier I application to obtain a permit and help temper arguments concerning the large point differential between Tier I and Tier WIll making such app licati on. In any situation, the number of such permits that can be awarded should be limited and mitigation required, such as requiring the application to meet the minimum point threshold. The concern about decreasing the number of property willing to sell in Tier I is a valid concern, especially if entry into the lottery is too easy and no maximum limits are placed on the number of awards. Is the initial 20% allocation for the number of market allocations to be available in the lottery too much or too little? The staff deliberately set the lottery aside to only 20 percent to ensure that the majority of market rate allocations remain in the competitive system resulting in more land dedications to the County. This allocation can be adjusted annually by the BOCC by increasing or decreasing the number by 50%, except that the minimum may never go below 20%. No maximum limit was set Does not support lottery system, as people need to be able to plan on when they can build. One of the cons against the lottery is that it does not provide certainty to applicants, which is why both a competitive and lottery system are proposed in the draft Tier System package. Page 8 of8 ATTACHMENT B MEMORANDUM TO: Board of County Commissioners FROM: Timothy J. McGarry, AICP /J1;1 Director of Growth ManagemetrV I f DATE: April 1, 2005 SUBJECT: Staff Evaluation of Proposed Changes to Tier System Requested by Mr. Ed Swift At the March 16, 2005, Commission meeting, the Board directed staff to evaluate the attached letter from Mr. Ed Swift requesting specific changes to the proposed Tier System. This memorandum provides staff analysis and recommendations on each proposal. I. Proposal: Give greater density bonuses for building affordable homes on commercially zoned property. Analysis: The existing density bonus for affordable housing in the Mixed Use (MU) district is an effective maximum gross density of 14.4 units per acre (18 units per maximum net density) and in the Suburban Commercial (SC) district is an effective maximum gross density of 12 units per acre (15 units per maximum net density). Changes in this density would require amendments to the Comprehensive Plan and Land Development Regulations. Any change in density for affordable housing in the commercial districts needs to be carefully reviewed as it has implications for increased off-site impacts and raises potential for community opposition to needed housing. Another option would be rezoning of specific properties to allow for higher density. This proposal calling for an increase in the density bonus to provide greater incentives for construction of affordable housing should to be considered as part of the comprehensive review of the County's affordable housing policies, regulations and programs that will be started shortly in conjunction with the imposition of the Interim Development Ordinance on conversion and redevelopment of mobile home parks. Recommendation: No action should be taken at this time, but the increased density bonus issue should be thoroughly investigated as part of the comprehensive review of the County's affordable housing policies, regulations and programs. II. Proposal: Do not apply the 20 percent open space requirement to affordable housing. Analysis: The Comprehensive Plan and Land Development Regulations require that all development has at least 20 percent open space, which includes setbacks and required Page 1 of 4 ATTACHMENT B landscaping buffers. The argument presented by Mr. Swift is that applying this standard to affordable housing, the same as market rate housing, reduces the incentives (i.e., density) for developers to build this type of housing. The elimination of the open space requirement would make such affordable housing incompatible with other development in the county. Without open space limits, every inch of property could be covered by impervious surfaces and structures except for areas required to be left open for setbacks or required landscaped buffers. Therefore, such an exemption would not further good land use planning principles and would only work to increase potential neighborhood opposition to these projects. Rather than decreasing open space requirements, the more appropriate option would be to increase the density bonus for affordable housing, as requested in I above. This option would meet Mr. Swift's concerns, but retain the benefits that accrue to the community and tenants/owners from having open space requirements in the County's regulations. Recommendation: The proposal to exempt affordable housing projects from open space requirements should not be pursued any further, but an increase in the density bonus should be considered as part of the comprehensive review of the County's affordable housing policies, regulations, and programs. III. (a) Proposal: Increase the number of ROGO points from 3 to 5 or 6 awarded to market rate housing as part of an affordable housing project. Analysis: The existing regulations allow for 20 percent of an employee and affordable housing project to be market rate. Market rate units in these projects receive the density bonus allowed for affordable housing, are not required to apply TDRs, and receive +5 points under ROGO. These market rate units are deed restricted to households earning 70% of their income from Monroe County. The proposed amendments call for only +3 points, which is inconsistent with existing regulations in Section 9.5-266. This inconsistency was an oversight in the drafting of the proposed amendments. Retaining the +5 points bonus is preferable to only awarding +3 points as the higher point value more clearly defines the priorities placed by the County in promoting affordable housing. Recommendation: The proposed ordinances amending the Comprehensive Plan and Land Development Regulations should be revised to award +5 points to market rate units in affordable housing projects. III (b) Proposal: Award +1 ROGO point for each affordable unit constructed, which the developer may apply to other off-site projects.' Analysis: It is unclear whether these points would be awarded for affordable housing constructed in a mixed market rate-affordable housing project and/or a solely affordable housing project. This concept may have some merit, but needs further investigation during Page 2 of 4 ATTACHMENT B the preparation of the comprehensive review of the County's affordable housing policies, regulations, and programs. Recommendation: No action should be taken at this time, but the proposal awarding property owner or developer one ROGO point for each affordable housing unit constructed should be examined as part of the comprehensive review of the County's affordable housing policies, regulations and programs. IV. Proposal: Provide direct notice of the Tier System to all property owners of proposed Tier I and II designated properties by certified mail or tax bills. Analysis: The staff believes that the use of certified mail would be cost prohibitive with over 6,500 separate vacant privately-owned parcels, excluding Big Pine Key and No Name Key. The TRlM notices will not be sent until this summer, therefore, sending a notice with the tax bills is not a viable option, unless the Board wants to further delay implementation of the system into next year. The public is being made aware of proposed Tier System and Tier maps through: newspaper ads; County website; press releases; and presentations before public interest and citizen groups. Planners in both the Marathon and Plantation offices have been specifically assigned to answer citizen's questions on the Tier System. In addition, any property owner may access the County's website to find out to which proposed Tier their property has been assigned or they may go to any County library or the Growth Management offices in Marathon or Plantation Key. The County has held four Planning Commission public hearings and will have had held at least five public hearings before the Board of County Commissioners on the Tier System before any final action is taken this summer. The path being followed by the staff for public notification is far more than required under either Chapters 125 and 163, Florida Statutes, or the County's own regulations and provides ample opportunity for interested property owners to learn about the system or provide input in the development of the Tier System. The staff is not in agreement with the assertion made by Mr. Swift that the Tier System is a major across the board change in land use. Other than new clearing limits, the Tier System only directly affects development requiring an allocation award under ROGO or NROGO. It does not change or modify the list of permitted uses in any zoning district. The staff further disagrees that the Tier System will result in a "dramatic change in the value of land", as the real development value of the overwhelming number of properties will not change in the long run due to the system. The proposed Tier System is far more transparent to both sellers and buyers in the real estate market, as it provides fuller disclosure to property owners on the development potential of their property than under the current system. Page 3 of 4 ATTACHMENT B As discussed in a previous memorandum to the Board, the potential of most properties to successfully compete in ROGO or NROGO will not change under the new system. The preponderance of properties proposed for a Tier I designation are not competitive under the current system and will not be competitive under the proposed system. It should be further noted that almost every owner of vacant property in Tier I has been contacted by the State concerning inclusion of their property in the Florida Forever boundaries for future public acquisition for conservation purposes. This action alone should have put most property owners on notice about the development expectations regarding their property. The competitiveness of Tier II properties under the proposed system as compared to the existing one will greatly hinge upon the final determination by the Board of the point differential between Tier III and Tier II; however, it should be noted that even under the current system 40% of applications in proposed Tier II areas already receive negative points for environmental impacts. This number would even be higher if existing vegetation conditions were taken into consideration. Finally, if the unusual and extraordinary effort were made to send individual notices to all property owners, it may only raise undue concerns from property owners about the ramifications of the system on their property. Unduly raising the level of concern over an issue, that materially affects only a small percentage of property owners, may only result in increasing the anxiety and fears of property owners and overwhelm the staff with numerous questions. Recommendation: This proposal on requiring individual notices to be sent to property owners in proposed Tier I and II areas should not be pursued any further as the County is providing sufficient access and opportunities for interested property owners to become informed about the Tier System. Attachment Page 4 of 4 March 17,2005 Dear Commissioners: Below is a summary of my request for changes in the Tier System propo$al noW before you: I. If landowners, can be enticed or incentivized to build affordable housing on commercial properties that would result in the elimination of potential commercial growth while helping to solve our housing problem. Request: Give greater density bonuses for building affordable homes on commercially zoned property. II. Because affordable housing creates, by its nature, smaller unit sizes the need to set aside 20% of the land for open space is not necessary. Applying the same standard to affordable projects sites as we do to bigger market rate sites is not realistic and unnecessarily reduces the number of units we can build on any given site. Land is precious and we need to use it conservatively. Request: In determining buildable area on M.D. or S.c. or any other commercial land used for affordable housing allow 100% rather than the 80% now used to determine the net buildable area. III. The allowing of mixed income affordable housing developments of 80% affordable and 20% deed restricted market rate is currently in our code. This was included as a way to encourage owners of very valuable property to build affordable housing however the incentive now being requested by the planning board of 3 ROGO points for these deed restricted market rate units is not sufficient to accomplish the goal and entice the owners of this land to use it for affordable projects. Request: Please consider 5 or 6 ROGO points as the incentive for the 20% deed restricted market rate units now allowed in affordable mixed income properties. Might I also suggest that one ROGO point be awarded fro each affordable unit built thus a developer could amass ROGO points toward off-site permitting, This would be a major incentive to build affordable housing. 1 . ~ IV. The method of notice of the Tier System hearings and implementation is now advertisements in the newspaper. Because of the dramatic change in the value of lal}d represented in the Tier System the result is a major across the board land use change or in effect a comprehensive re-zoning of property. Request: Direct notice of all Tier I and Tier II property owners by certified mail or tax bills or in some more direct way than by newspaper ads are in order. This notice should include a description of what the change is and how it will affect their property. Sincerely yours, Edwin O. Swift, III EOS/mhc 2