Resolution 187-2002
RESOLUTION 18 7 -2002
A RESOLUTION AMENDING RESOLUTION NO. 115-2002 OF mE
BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY
APPROVING A REVISED IMPLEMENTATION PLAN FOR THE
FLOOD INSURANCE INSPECTION AND COMPLIANCE PROGRAM
FOR SUBMITTAL TO THE FEDERAL EMERGENCY MANAGEMENT
AGENCY
WHEREAS, the Board of County Commissioners ("BOCC") adopted Resolution No.
115-2002 on March 20, 2002, approving a remedial plan for submittal to the Federal Emergency
Management Administration (FEMA), called the "Implementation Plan for Monroe County Flood
Insurance Inspection and Compliance Program" to meet one of the requirements identified in a
letter from FEMA's Region IV Director, dated January 14,2002; and,
WHEREAS, FEMA Region IV office has responded to the remedial plan approved by
the BOCC in a letter dated April 2, 2002, which requests that the County revise the plan to
provide more detail on how the County will address structures more than four-years old in the
inspection program;
WHEREAS, the Growth Management Division staff, in consultation with FEMA Region
IV staff, has prepared a revised remedial plan that addresses the need for further clarification and
detail requested by FEMA; and,
BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF
MONROE COUNTY, FLORIDA that:
Section ]. The BOCC hereby amends Resolution No. ] 15-2002, by replacing Exhibit ],
"Implementation Plan for Monroe County Flood Insurance and Inspection and Compliance
Program", with a new Exhibit 1 which is hereby attached.
Section 2. The County Administrator is directed to expeditiously transmit this Resolution
and attached exhibit to the Region IV office of FEMA.
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("') UJ It\.SSED AND ADOPTED Board of County Commissioners of Monroe County at a
':':'re~ ..ieeting of said Board held on the 17th day of April, A.D., 2002.
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.iloi5 ~o~ Mayor Charles 'S~y' McCoy yes
~ --j~8 O~ ~..1.,.Of1o, Mayor Pro Tern DIXIe Spehar yes
a::: >-:5w ~ 18.2 <'J, Commissioner George Neugent yes
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ex: 'I: a:: _ '-.;,\\ ommlSSlOner ora 1 lams a sent
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~ C:l ~ ~\' '" 1.1'<;1 Commissioner Murray Nelson yes
(SEAL) BOARD OF COUNTY COMMISSIONERS OF
ATTEST: MONROE COUNTY, FLORIDA
ByJ),r;:d::JJ ~ By: MaYor!Chai~
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EXHIBIT 1
IMPLEMENTATION PLAN FOR
MONROE COUNTY
FLOOD INSURANCE INSPECTION AND
COMPLIANCE PROGRAM
Flood Insurance Inspection Program
o Prior to March 14, 2002, the Growth Management Division staff submitted a
complete list of the names and addresses of owners (policy holders provided by
FEMA) of all structures less than four years old that may contain possible
violations of the County's floodplain regulations to the Federal Emergency Flood
Insurance and Mitigation Division (FEMA/NFIP).
o Starting in June, 2002, the County Growth Management Division staff will submit
monthly to FEMA/NFIP, the names and addresses of approximately -1-50 owners
(policy holders) of structures with possible violations of the County's floodplain
regulations. The lists to be compiled and sent to FEMA will start with the newest
structures working back through to the oldest structures.
o As the first requests for inspections from property owners come forward after
notification by their insurance companies, the County's Building and Code
Enforcement staff will begin inspections and implement the downstairs enclosure
compliance program as outlined in the Federal Register. [It is anticipated that
actual inspections will not begin until October, 2002, which would mean that
under the inspection program, the first group of unpermitted enclosures and
improvements would not be brought into compliance until mid-2003.]
o During the inspection program, the County staff will collect and record the
amount and number of flood insurance claims submitted for each inspected
structure to provide a data base for calibrating and updating any flood damage
model.
Florida Keys Flood Damage Model
To assist Monroe County in its efforts to bring non-compliant buildings into
compliance with its floodplain regulations, the Monroe County Commission is requesting
that FEMA create or cause to create a Florida Keys flood damage model based on Florida
Keys topography, historical records, and actual flood damage sustained, post-FIRM, by
Florida Keys structures. It is anticipated that such a study could be completed in 2003,
which would allow the County's floodplain compliance program to be modified, if
approved by FEMA, based on the results of the damage model.
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Remediation of Non-compliant Structures Including Those Older than Four Years
o The Board of County Commissioners will request its delegation to the Florida
Legislature to address the four-year statute of limitations on code enforcement
prosecution of violations of the County's floodplain regulations.
o The County's inspection program will include of all post-FIRM structures,
including those more than four-years old identified as having a potential violation.
The County Commission and its Growth Management Division staff believe that
a significant percentage of structures more than four years old with unpermitted,
non-compliant below base flood elevation improvements will voluntarily come
into compliance through theis multi-year flood insurance inspection program. As
these structures are identified by the County staff through the flood insurance
inspection program, the County will provide a list to FEMA of those structures
that may have a potential violation, and which will require an inspection. If the
owners of these structures refuse the inspection, their insurance will not be
renewed by their insurer. The property owner of any structure inspected by the
County that is determined to have a violation will have six months, if the violation
is more than four years old, or two months, if the violation is less than four years
old, to obtain a demolition permit to bring the structure into compliance. If the
owner of a property with an identified violation chooses not to obtain the
demolition permit by the deadline established above, or obtains the demolition
permit but no approved final inspection occurs within 60 days after issuance of
the demolition permit, the County will pursue one of the following actions as
applicable:
I) If the violation is less than four-years old, the County will expeditiously
pursue code enforcement action and will formally submit a declaration for
denial of the property owner's insurance to FEMA pursuant to Section
1316 of the National Flood Insurance if the structure is not brought into
compliance.
2) If the violation is beyond the four-year statute of limitations, the County
will submit a declaration for denial of the property owner's insurance to
FEMA pursuant to Section 1316 of the National Flood Insurance Act.
Actions to Ensure No New Additional Non-compliant Structures
o Although the County is currently limited by the four-year statute of limitations as
to code enforcement action, the County through its County Growth Management
Division will implement the following actions to ensure that any new violations
are brought into timely compliance and do not become subject to the four-year
statute of limitations barring code enforcement prosecution:
1) Amend the existing floodplain regulations to require as a condition of its
building permit that any new dwelling with an opaque below base flood
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enclosure have a restrictive covenant allowing the County to inspect the
structure on a periodic basis to ensure compliance with County floodplain
regulations. [Amendments to the floodplain regulations will be in effect
by no later than July, 2002.]
2) Require any structure found to be non-compliant during the flood
insurance inspection program or code enforcement action have a
restrictive covenant similar as that required for new construction proposed
in 1) above, if an opaque below base flood enclosure is to be retained as a
permit condition to bring the structure into compliance. [This requirement
will be implemented through the above amendments to the floodplain
regulations. ]
3) Conduct inspections of dwellings with restrictive covenants to ensure
compliance with the County's floodplain regulations, upon receipt of
evidence establishing probable cause of a violation, or a minimum of once
every four years~
4) Continue to vigorously pursue code enforcement action for violation of the
County floodplain regulations through code enforcement and the normal
permitting process, including prosecution of owners of structures more
than four years old, where property tax records and/or evidence from site
visits provide probable cause of a violation that is less than four years old.
5) Request that FEMA provide the County with a "Submit to Rate" for any
applications for new flood insurance policies on previously uninsured
properties with a possible violation , so that the County may pursue
compliance under code enforcement proceedings, if the violation is less
than four years old, or if older than four years, through a Section 1316
declaration.
6) Prepare for FEMA's approval by no later than September 30, 2002, a plan
and administrative procedures, as part of the County flood insurance
inspection program, for providing additional time to come into compliance
for those non-compliant structures with below base flood enclosures
occupied by very low to moderate income households, as defined under
the Monroe County Code. [This proposal recognizes the difficulty in
finding suitable replacement housing for the County's most at-risk
population and would help mitigate the adverse impacts on these
households and the County's affordable housing stock.]
7) Identify and compile for Monroe County's flood insurance inspection and
compliance program a list of all structures that fail to come into
compliance and submit a quarterly progress report to FEMA beginning
July, 2003.
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8) Evaluate Monroe County's flood insurance inspection and compliance
program by June 2004, and if necessary, develop and implement further
remedial actions with FEMA's approval, to ensure enforcement of the
County's floodplain regulations.
The County Growth Management Division staff has the sufficient resources to implement
the above program over a six year period.
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