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HomeMy WebLinkAbout05-21-2024 Supporting DocumentsSenior Meeting Attendance Volunteer Items of Note Scholarship Award Attendance Ratio Hours $500 Kennedy Whitley 9/12 75% 49 Any absences were for testing or school activities; currently Years of membership: serves as Chair Years of membership: Robert Davidson 11/12 92% 35.5 2024 2023-2024 'Missed meetings were for medical reasons; volunteered to $250 Bayleigh Castle 10/12 83% 32.5 author the essay for the volunteer project competition Years of membership: 2023-2024 All students mentioned above have met the current requirements provided inthe scholarship guidelines, OYC Coordinato/""14 A ),6*- CITY OF OCEE } 1 N. Bluford Avenue Ocoee, Florida 34761 ocoee f,o,;da 407-905-3100 SPEAKING RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspec#ion by all persons. DATE r� -' NAME PHONE # OCOEE RESIDENT YES ENO ❑ ' f'4 � /( f t/� (OPTIONAL) ADDRESS ZIP CODE E-MAIL ` WO V �d �� I want to address the Board about (Please provide Item # and/or topic): Do you have a prepared statement, or other document(s) from which you will address the Board? 04 Yes if yes, please attach copy of same to this Reservation Form. All proceedings before the Commission -shall be governedthe Civility The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CITY OF OCOEE V 1 N. Bluford Avenue ocoe(? Ocoee, Florida 34761 flodda 407-905-3100 SPEAKING RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE �—k g�a� NAME JCL(, PHONE PHONE# OCOEE RESIDENT YES NO El (OPTIONAL) ADDRESS CITY ZIP CODE E-MAIL I want to address the Board about (Please provide Item # and/or topic): C(X-�("cy4s -gxves�ign C -r- soshti pared state �entr o lherLdoN"eCnt'—(s)Yr9 w%ch(WI'T address Do you have a prepa No V Yes if yes, please attach copy of same to this Reservation Form !'e' cymk)n (�6x� The following time limits to speak are in effect: :public _UpArings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CITY OF OCOEE CIVILITY CODE - adopted July 1, 2003. 7,ursuant to Resolution No. 2003-16 adopted on July 1, 2003, the following Civility Code shall govern all -.troceedings before the City of Ocoee City Commission and Boards - I . All electronic devices, including cell phones and pagers, shall be either turned off or otherwise silenced. 2. Prolonged conversations shall be conducted outside Commission Chambers. 3. Clapping, whistling, heckling, gesturing, loud conversations, or other disruptive behavior is prohibited. 4. Only those individuals who have submitted speaker forms and who have been recognized by the Mayor (or Chair) may address comments to the Commission (or Board). 5. Comments at public hearings shall be limited to the subject being considered by the Commission. 6. Comments at Citizens Comments shall be directed to City issues. 7. All public comments shall avoid personal attacks, abusive language, and redundancy. 8. No person attending a Commission or Board meeting is to harass, annoy or otherwise disturb any other person in the room. Vv- CITY OF OCOEE 1 N. Bluford Avenue ocoee Ocoee, Florida 34761 407-905-3100 SPEAKING RESE 'i'R'VATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspe t" by all persons. DATE, 77- V. NAME PHONE# OCOEE RESIDENT YES 1!5NO 7 (OPTIONAL) ADDRESS CITY ZIP CODE E-MAIL I want to address the Board about (Please provide Item # and/or topic): -e -���DL C" 6-'' Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes if yes, please attach copy of same to this Reservation Form. All proceedings before the Commission shall be governed by the Civility Code — see back The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. '40 a_�e CITY OF OCOEE X, C rV\ 44 _'ggr 1 N. Bluford Avenue 0;t, C1 . C> Ocoee, Florida 34761 ocoe. ri�'(C'Jr f I ori'la 1 3 4105-3) SPEAKING RESERVATION FORM , NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE J NAME PHONE# OCOEE RESIDENT YES NO El (OPTIONAL) ADDRESS —CITY. enree_ I want to address the Board about (Pease proyide Item # and/or topic): ZIP CODE3L( Do you have a prepared statement, or other document(s) from which you will address the Board? No X Yes if yes, please attach copy of same to this Reservation Form. lg� gjgppqyi��1�11 ji 0 11; 1 V! 9! V MTV" 10 TV � W'', "KIFFU11112 The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CITY OF OCOEE law 1 N. Bluford Avenue ocoee Ocoee, Florida 34761 llorida 407-905-3100 Rall SPEAKING RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE NAME PHONE# OCOEE RESIDENT YES ZK"NO ■ (OPTIONAL) ADDRESS Eq0Cu�2n LtaA s2o�—uTy ZIP COD E-MAIL I want to address the Board about (Please provide Item # and/or topic): 2)A e x! L,) Dekla-&LL,!t ctyd 71 Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes if yes, please attach copy of same to this Reservation Form. The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes, Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CITY OF OCOEE 1 N.,Bluford Avenue l Ocoee, Florida 34761 o CCU ee 407-905-3100 flortdc SPEAKING RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspections by all persons. DATE J NAME 4 OCOEE RESIDENT YES NO ❑ (OPTIONAL) ADDRESS 0 7 1 a 7t r CS k�CITY z(P CODE l r� E—MAIL I want to address the Board about (Please provide Item # and/or topic): oc'Dee 4/1 Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes rX` if yes, please attach copy of same to this Reservation Form. All proceedings before the Commission shalt be governed by the Civility Code — see Lack The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments- 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CITY OF OCOEE 6) 440 1 N. Bluford Avenue Ocoee, Florida 34761 ocoee 407-905-3100 I I 0'I'd. SPEAKIMr. RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE NAME /* PHONE OCOEE RESIDENT YES NO D CITY ZIP CODE_ (OPTIONAL) ADDRESS E-MAIL I want to address the Board aoyt (Please ,provide Item # andfor topic): Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes if yes, please attach copy of same to this Reservation Form. All proceedings before the Commission shall be governed by the Civility Code — see back The following time limits to speak are in effect: Public Hearings. petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. CI TY OF OCOEE 1 N. Bluford Avenue Ocoee, Florida 34761 O CCU e e 407-905-3100 florida SPEAKING RESERVATION FORM eakin reservation forms are public records under Chapter 119, Florida Statutes, and are NOTE: All submitted sp g open to inspection by all persons. DATE PHONE # NAME r1 OCOEE RESIDENT YES NO p CITY __ ZIP CODE (OPTIONAL) ADDRESS _W I want to address the Board about (Please provide Item # and/or topic): 1i ich you will address the Board? Do you have a prepared statement, or other document(s) from wh No Lsz� Yes if yes, please attach copy of same to this Reservation Form. ed by the Civility e 11 proceedings before the Commission shall be govern The following time limits to speak are in effect: �u blic Hearin s: petitioner presentation 15 minutes; citizen c mer ents - 5gminutes per speaker; petitioner rebuttal - 5 minutes. Onen to Publ►c — Citizens Comments - 3 minutes per speaker, CITY OF OCOEE I N. Bluford Avenue Ocoee, Florida 34761 ocoee 407-905-3100 florlde qD=At<1Wr. RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE a,4 PHONE # NAME OCOEE RESIDENT YES NO FD j Zip CODE (OPTIONAL) ADDRESS CITY--V E-MAIL I want to address the Board about (Please provide Item # and/or topic): 041 t C�� V 1A-1t1G61Tc%11V16`-- Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes_ if yes, please attach copy of same to this Reservation Form. A . 11 proceedings before the Commission shall be governed by the Civility Code — see back The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments- 3 minutes per speaker, per meeting. CITY OF OCOEE 1 N. Bluford Avenue Ocoee, Florida 34761 o CCU e e 407-905-3100 f[ot[do mr`S (7 rC.SEIZ Tl NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE fir: .. . Z . 0 J � � PHONE # NAME OCOEE RESIDENT YES NO ❑ CITY ZIP CODE (OPTIONAL) ADDRESS E-MAI L 1 want to a dress the Board about (Please p vide It m # and/or topic): Do You have a prepared s afiemenfi, or other document(s) from which you will address the Board? No Yes if yes; please attach copy of same to this Reservation Form. kafnrp the Commission shall be governed by the Civility Code — see hack The following time limits to speak are in effect: etitioner rebuttal - 5 Public Hearings: petitioner presentation -15 minutes; citizen comments - 5 minutes per speaker; p minutes. per speaker, p meeting. O en to Public — Citizens Comments - 3 minutes p, per g. NOTE: All submitted speaking reservation forms are public records under Chapter 119` Florida Statutes, and are open bzinspection byall persons. con OCOEE RESIDENT YES VI/ )NO F� L (OPTIONAL) ADDRESS xA2,2 OmiePCODE": 3?/ all ` I want toaddress the Board obouA(Pleaqe provide Item ppand/or : Do e a prepared statement, orother dnournantka from which you will address the Board? No Yes_____ ifyes, please attach copy ofsame tnthis Reservation Form. All proceedings before the Commission shall be governed by the Civility Code — see back The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. Sibbitt, Melanie From: noreply@civicpIus.com Sent: Tuesday, May 21, 2024 11:42 AM To: Citizens; City Clerk DL Subject: Online Form Submittal: Speaking Reservation Form If you are having problems viewing this HTML email, click to view a Text version. NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. We also have a printable PQF Form. Date:* OCOEE RESIDENT: 05/2112024 (X) Yes O No NAME:* PHONE# Andrea Jones 407 579 1315 (OPTIONAL) Address: (Please, Not a P.O. Box) City: Switch Grass Circle Ocoee State: Zip: FIL 34761 Email Address: andreagjones13@gmaii.com I want to address the Board about (Please provide Item # and/or topic): A4 A Rarnnel Pandinn of Ordinnnea ftir (ItArrianin Pninf a Pa7nninn Any member of the public whose behavior is disruptive and violates the City of Ocoee Civility Code is subject to removal from the Commission (or Board) meeting by an officer and such other action as may be appropriate, CITY OF OCOEE 1 N. Bluford Avenue ocoee Ocoee, Florida 34761 407-905-3100 SPEAKING RESERVATION FORM NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection by all persons. DATE NAME PHONE' # OCOEE RESIDENT YES Xt NO El (OPTIONAL) ADDRESS CITYJ ZIP CODE, E-MAIL I want to address the Board about (Please provide Item # ad/or topic): Do you have a prepared statement, or other document(s) from which you will address the Board? No Yes if yes, please attach copy of same to this Reservation Form. All proceedings before the Commission shall be governed by the Civility Code — see back The following time limits to speak are in effect: Public Hearings: petitioner presentation - 15 minutes; citizen comments - 5 minutes per speaker; petitioner rebuttal - 5 minutes. Open to Public — Citizens Comments - 3 minutes per speaker, per meeting. From: noreply@civicplus.com Sent: Tuesday, K4ey21, 2024 5:47 PM To: Citizens; City Clerk DL if you are having problems viewing this HTML email, click toview aText version. Speaking Reservation Form �/�� H��� �� NOTE: All submitted speaking reservation forms are public records under Chapter 119, Florida Statutes, and are open to inspection byall persons, VVCalso have o printable PDF Form. Date:* OCCJEERES|DENT: 6/21/24 () Yea () No PHONE# Christopher Webster (OPTIONAL) Address: (Please, Not aP]]. Box) City: Ocoee Stab*: Zip: FL 34761 Email Address: I want to address the Board about (Please provide Item # and/or topic): Traffic by Prairie, Lake You may send questions and comments to citizans@ocoee.org. Do you have a prepared statement, or other document(s) from File Upload which you will address the Board? I I (if yes, please attach copy of same to this Reservation Form.)* Convert to PDF?[ Seaver, Sherry From: Kennedy, Scott Sent Tuesday May 21,2U245:S2PK4 To; Seaver, Sherry Subject: FVV: Gardenia Pointe - Request for Meeting From: Laurie M.Perez <Lauhe.Perez@graymbimsonzVmP Sent: Monday, May 13,202 10:42AM To: Kennedy, Scott <SKennedy@wcoeaorg> Cc: Jason VV.Sea[|/Jason.Sear|@gray-robinson.00nn> Subject: Gardenia Pointe ' Request for Meeting Good morning, Commissioner Kennedy — Can you please let me know if you would be available for a meeting to discuss Gardenia Pointe with Mr. Seadprior to the next City Council Meeting scheduled for the Z1s"7 Heisalready going fobeover there for ameeting with the Mayor nnThursday, May 16matI2:OO. If you are not available that afternoon, please let me know what other day and time would work for you and I can confirm Mr. Searl's availability. Laurie M. Perez Legal Assistant T 407.843,8880 F 407.244.5690 � � '�—` GmyRobinson,P.A.~301 East Pine Street, Suite 1400,Orlando, Florida32801 PAY �����~���K �� v���� ���_�����a~aSON ATTORNEYS xADVISORS »CONSULTANTS This e-mail is intended only for theindividua|(s) orenUty($ named within the meesage. This e-mail might contain legally privileged L911mus 1. Which Standard of Review to Use for a Rezoning? 0 There are 2 types, depending on whether the request is a comprehensive plan amendment or a rezoning. Here ... since no comprehensive plan amendment - because project's proposed density is less than max city allows and, as such, already complies with city's adopted comprehensive plan - this is only a site specific rezoning, the standard is, "quasi judicial" in nature, and is subject to a "competent substantial evidence" standard aUnder Florida law, an applicant has initial burden of demonstrating through competent substantial evidence the rezoning request complies with the local government's adopted code criteria. Once an applicant satisfies its initial burden of demonstrating compliance with applicable code requirements the application must be granted, unless the opposition carries its burden, which is to demonstrate [by competent substantial evidence] that the applicant's requests do not meet the standards." See Jesus Fellowship (752 So.2d 708, Fla. 3rd DCA 2000) 2, What is Competent Substantial Evidence? 0 Now, the staff report of a local government's professional planning staff constitutes competent substantial evidence where they "contain relevant valid evidence which supports the Commission's decision." See Jesus Fellowship (cite above), As you've already heard from city's own professional planning staff in the comprehensive presentation to you, our requested rezoning complies with city's adopted code criteria and is supported by competent substantial evidence (which includes the staff report together with staff's presentation, and the applicant's and its expert witness testimony), so the applicant has met its burden here 3. What is Not Competent Substantial Evidence? Going back to our April 16 th commission meeting continued discussion, there was a focus regarding perceived traffic impacts. Florida courts, in the case of traffic impacts, since it is an area where technical expertise is required, have generally held that lay opinion testimony does NOT constitute valid evidence upon which a local government decision may be based in whole or in part, See Jesus Fellowship (cite above). Further, in a local case involving the City of Deland, the court found that generalized statements in opposition to a project do NOT constitute competent substantial evidence upon which local government can base a quasi-judicial zoning decision. See City of Deland (577 So.2d 593, Fla. 5th DCA 1991). "Lay witnesses" speculation about "potential traffic problems, light and noise pollution" and general unfavorable impacts of a proposed land use are NOT considered competent substantial evidence, See Katherine's Bay (52 So.3d 19, Fla. Dist. Ct. App. 2010). Generalized fears of an increase in traffic are insufficient to justify the denial of a rezoning application. See Debes (690 So.2d 700, Fla. Dist. Ct. App. 1997) 0 the local government must evaluate a development application based solely upon the "definite, objective" criteria adopted .in its enacted regulations (i.e. comprehensive plan and city code). Adding to such published criteria during the hearing process or basing its decision on anything but such criteria is not permitted. See Omni Point Holdings (811 So.2d 767, Fla. 3d DCA 2002) Nequested Action to Approve Ordinance Rezoning Gardenia Pointe to PUD /22605/9960521698 vI Jesus Fellowship, Inc. v. Miami -Dade County, 752 So-2d 708 (2000) 25 Fla. L. Weekly D481, 25 Fla. L. Weekly D1179 KeyCite Yellow Flag - Negative Treatment Distinguished by Miami -Dade County v. Publix Supermarkets, Inc.. Fla.App. 3 Dist., May 6, 2020 752 So.2d 708 District Court of Appeal of Florida, Third District. JESUS FELLOWSHIP, INC., Petitioner, V. MIAMI-DADE COUNTY, Florida, Respondent. No. 3D99-1073. I Feb. 23,2000, Synopsis After the county commission denied a portion of church's zoning application to allow private school, church petitioned for writ of certiorari and the Circuit Court, Appellate Division, Dade County, Frechicka Smith, Arthur Rothenburg, and Thomas Wilson Jr., JJ., affirmed commission's denial. Church petitioned for writ of certiorari. The District Court of Appeal, Fletcher, J,, held that church was entitled to approval of zoning application for special exceptions and unusual use to permit private school with grades K-12 and 524 students. Circuit Court order quashed . and case remanded with instructions. West Headnotes (4) III Zoning and Planning Scope and Extent of Review District Court of Appeal's review of the Circuit Court's decision on appeal of decision by Zoning Appeals Board is limited to determining whether the Circuit Court afforded due process and correctly applied the correct law. Zoning and Planning Public interest or 6 welfare Applicant seeking special exceptions and unusual uses need only demonstrate to decision - making body that its proposal is consistent with county's land use plan, that uses are specifically authorized as special exceptions and unusual uses in applicable zoning district, and that requests meet with applicable zoning code standards of review; if this is accomplished, then application must be granted unless opposition carries its burden, which is to demonstrate that applicant's requests do not meet standards and are in fact adverse to the public interest. 4 Cases that cite this headnote [3] Zoning and Planning t Schools and education Church was entitled to approval of zoning application for special exceptions and unusual use to permit private school with grades K-12 and 524 students, and should not have been limited to grades K-6 and 150 students, as evidence before county commission, including county zoning maps, professional staff recommendations, aerial photographs, and testimony in objection, were either irrelevant or supported church's position. 3 Cases that cite this headnote 141 Zoning and Planning t-= Grounds for -I-ant or denial in general Past violations are not a basis to deny a present pending application that meets the code standards. 2 Cases that cite this headnote Attorneys and Law Firms 5 Cases that cite this hcadnOtc *708 Mathew D. Staver and Erick W. Stanley, Liberty Counsel (Orlando); DiBartolomeo & DiBartolomeo and Dean nberg Dunn Price & [2] Zoning and Planning o- Grounds for grant or D. DiBartolomeo, Miami; Bilzin Sui i; denial in gencral Axelrod and Michael W. Larkin and Jerry B. Proctor, Miami; for petitioner. 'J �,i Jesus Fellowship, Inc. v. Miami -Dade County, 752 So.2d 708 (2000) 25 Fla,'L Weekly D481, 25 Fla. L. Weekly D1 179 Robert A. Ginsberg, County Attorney, Augusto Maxwell, Assistant County Attorney; Kathryn Knicricin Estevez, Miami; Adorno & Zeder, Fort Lauderdale, and George I-,. Knox, Miami, for respondent. Before JORGENSON, COPE, and FLETCHER, JJ. Opinion FLETCHER, Judge. Jesus Fellowship, Inc. [Church] petitions this court for a writ of certiorari asking that we vacate an order entered by the circuit court, acting in its appellate capacity, which order affirmed the decision of the Miami -Dade County Commission [Commission] denying a portion of the Church's zoning application. We grant the petition and quash the circuit court's decision. The Church owns 12.2 acres in a residential area zoned for one -acre estate *709 homes.' In 1997, the Church filed a zoning application for special exceptions and an unusual use to permit the expansion of the Church's religious facilities and to permit a private school and a day care center. After reviewing the application the county's professional staff recommended denial of the requests. At the public hearing before the Zoning Appeals Board 2 [ZAB] the Church agreed to several changes which satisfied the professional staff, bringing about its recommendation of approval. Among the Church's concessions was a limitation to an enrollment of 524 students. The ZAB approved the application with the changes. The ZAB decision was appealed to the Commission by a number of objectors'. The county's professional staff continued to recommend approval with the ZAB-authorized 524 students, The Commission approved the Church's application generally but denied it in part, limiting the school to grades K-6 and 150 students. The Church petitioned the circuit court for a writ of certiorari alleging, inter alia, that the Commission's decision reducing the number of students and grades was not supported by substantial competent evidence. The circuit court upheld the Commission's partial denial. [11 This court's review of the circuit court's decision is limited to determining whether the circuit court afforded due process and correctly applied the correct law. 1111alitro v. City qfCoral Gables. 619 So.2d 455 (Fla. 3d DCA 1993); see also Herrera v. (.`itv ql'Aliami, 600 So.2(1561 (Fla, 3d DCA), review denied, 613 So.2d 2 (Fla. 1992). Our review of the record indicates that the circuit court missed its mark. It failed to correctly apply the correct law as its decision allows the use of incompetent evidence to support the Commission's decision and fails to apply the principles applicable to special exceptions and unusual uses. [21 An applicant seeking special exceptions and unusual uses need only demonstrate to the decision -making body that its proposal is consistent with the county's land use plan; that the uses are specifically authorized as special exceptions and unusual uses in the applicable zoning district; and that the requests meet with the applicable zoning code standards of review. If this is accomplished, then the application must be granted unless the opposition carries its burden, which is to demonstrate that the applicant's requests do not meet the standards and are in fact adverse to the public interest.3 See lri,ine i,. Duval Couqy Planning Comm., 495 So.2d 167 (Fla.1986); illelropolitan Dade County i�. Faller; 497 So.2d 1322 (Fla. 3d DCA 1986). [31 The basis for the circuit court's errors here was its conclusion that the simple fact that the Commission had before it the county zoning maps, the professional staff recommendations, aerial photographs, and testimony in objection was a sufficient basis for the Commission's denial. The mere presence in the record of these items is not, however, sufficient. They must be or contain relevant valid evidence which supports the Commission's decision. In reaching its conclusion the circuit court relied on Meiropolitan Dade CounfY v, Blumenthal, 675 So.2d 598 (Fla. 3d DCA 1995), review dismissed, 680 So.2d 421 (Fla. 1996). Therein the zoning maps and testimony contained evidence of the surrounding densities in the area, in a case involving a rezoning, i.e., a change of residential density, and not, as here, special exceptions or unusual uses, which do not involve a district boundary change (rezoning). In Blumenthal the maps were *710 relevant evidence necessary for the Commission to view in order to compare the existing surrounding districts' densities to assure consistency therewith (either a like density or a consistent step up -or down -in density). In the Church's case the maps of the surrounding zoning districts are not evidence which support the Commission's decision, The only zoning district inquiry here was whether the subject property is in a zoning district which permits the requested uses. This was not an issue as the land use plan and the zoning district permit the Church's request for the special exceptions and unusual.use. Jesus Fellowship, Inc. v. Miami -Dade County, 752 So.2d 708 (2000) 25 Fla'. L. -Weekly D481, 25 Fla. L Weekly D 1179 Further, the circuit court concluded that the professional staffs report was evidence supporting the Commission's denial. This clearly is not the case as the staffs report to the Commission was for approval, the staff unequivocally stating that all of the applicable standards were met by the requests. This is not evidence supporting the denial, Additionally, the testimony offered by the objectors does not qu alify as supportive evidence (or evidence at all in most cases) as a thorough review of the objectors' case demonstrates: The first witness, an engineer, complained that there would be more traffic on the neighborhood streets, 4 but quickly announced that he was not testifying as an expert. Where technical expertise is required lay opinion testimony is not valid evidence upon which a special exception determination can be based in whole or in part. See Pollard i� Palm Beach Comav, 560 So.2d 1358 (Fla. 4th DCA 1.990); City of .4popka v Orallae colmm,, 299 So.2d 657 (Fla. 4th DCA 1974). el The objectors' second witness testified that he wished to preserve the residential -character of his neighborhood and was concerned about the loss of what he described as "green space," However, churches and schools are part of the residential neighborhood character per the land use plan and the applicable zoning. As to his concerns regarding green space, the Church did not seek a variance thereof. The amount of green space to be provided meets the county's code standard. The testimony of this witness does not support the denial. Irihie, 495 So.2d 167; Fidlei; 497 So.2d 1322. 141 The third- objecting witness submitted numerous letters of protest and complained of past violations on the property. The letters are not evidence. City ol'Apopko, 299 So.2d 657. Past violations are not a basis to deny a present pending application that meets the code standards.') The next witness called by the objectors was the Church's reverend. The transcript 6 reveals an examination that meandered through the operation of the Church; how the expansion is to be financed; and the make-up of the congregation. This line of questioning prompted Commission members to inquire as to its relevancy to land use issues. The answer to their inquiry, of course, is that it does not bear on the special exception/unusual use standards, thus is not relevant. Irvine, 495 So.2d 167; Fuller, 497 So.2d 1322, The objectors' final witness was Guillermo Olmedillo, the director of planning. Olmedillo's testimony reveals only that it fortified his written opinion that the Church's application met all code standards.? Nowhere in the hearing record does there appear any evidence relating to the restriction to grades K-6 and to 150 students. After the evidentiary hearing closed, the restriction appeared, without a *711 warning of its impending arrival, as a "suggestion" by the objectors' attorney, T.150. It was promptly pounced upon by the Coininission, put into the forrn of the denial motion, and passed. In summary, the Church presented sufficient evidence to carry its burden; the objectors presented only testimony and documents that support the Church's application or which the courts have held not to be evidence. When the circuit court decided there was evidence (substantial, competent) to support the Commission's denial of the application, it failed to apply the correct law as to the granting or denial of special exceptions and unusual uses, and failed to apply the correct law as to what constitutes competent evidence in such cases. As a result we quash the circuit court's order and remand the case with instructions to the circuit court to direct the Commission to remove the limitation to K-6 and 150 students and to grant the application with grades K-12 and 524 students. 8 All Citations 752 So.2d 708, 25 Fla, L. Weekly D481, 25 Fla, L. Weekly D1179 Footnotes Churches and schools are permitted uses in residential areas under the county's land use plan. See Machado v Musgrove, 519 So.2d 629 (Fla. 3d DCA 1987), cert. denied, 529 So.2d 693 (Fla. 1988). 2 As it was then constituted. . , Jesus Fellowship, Inc, xMiami-Dade County, 752So.2d7Vg(2oVu) ' 3 Of course, if the opposition demonstrates that a request is inconsistent with the zoning authority's land use plan, then denial ininorder. Such iunot the case here aaweobserved infootnote 1. 4 However, the only ingress and egress proposed for the site is8TthAvenue, not "neighborhood" street; rather Uis a state minor arterial road. 5 8does, however, show lax enforcement hythe county inthe past. 6 Twenty-six (20pages of transcript. 7 For example: ^Q. So therefore is it not fair to say that the application pursuant to mouvdy|nable standards is compatible and completely consistent with the standards delineated inthe Dade County Zoning Code? A. It is consistent with the Dade County Zoning Code, yes," 8 Wedonot reach the other issues and express no opinion one way or another unthem. End of 6ocument 0 2024 Thomson Reuters. No claim to original US, Government Works. xv��7|�� ���0�4ThomsunRe,&'rs�u�uh,�muh�naiU�� Gu*own�,8VV�/ks* Colonial Apartments, L.P. v. City of Deland, 577 So.2d 593 (1991) 16 Fla. L Weekly 505 577 So.2d 593 District Court of Appeal of Florida, Fifth District. COLONIAL APARTMENTS, L.P., etc., Petitioner, I - V. CITY OF eLAND, etc., Respondent. No. 90-1377. Feb. 14,1991, I Rehearing Denied April 8, 1991. Synopsis Limited partnership sought to construct apartment project and sought approval of site plan. City denied approval. Partnership petitioned for writ of certiorari, The Circuit Court denied the petition. Partnership petitioned for writ of certiorari to review Circuit Court's denial, The District Court of Appeal, Peterson, 1, held that city could not approve site plan for construction of apartment complex which would have density of 13 units per acre on condition that density not exceed 6 units per acre, in that ordinance specifically allowed for density of 16 units per acre in district in which complex was sought to be built. Writ granted, order quashed, remanded with directions. West Headnotes (5) 111 Zoning and Planning - Grounds for grant or denial in general Opinions of neighbors, by themselves, are insufficient to support denial of proposed development, I Case that cites this headnote 121 Zoning and Planning Other particular conditions or agreements City could not approve site plan for construction of apartment project which would have density of 13 units per acre on condition that density not exceed 6 units per acre; 16 units per acre was within term "low density" used in statement of intent portion of zoning ordinance, and nothing in ordinance would leave one who examined it to suspect that term "compatibility" as used in statement of intent was meant to allow adjustment of cap of 16 units per acre. 2 Cases that cite this headnote [31 Zoning and Planning ..- One -family, two- family, or multiple dwellings While project density is legitimate concern and is most important concern, it is concern that must be addressed and expressed in appropriate ordinances. [4] Zoning and Planning �,= One -family, two- family, or multiple dwellings When law establishes specific allowable density, its clear terms cannot be varied by forced interpretation of intent. [51 Zoning and Planning Permits, certificates, and approvals in general Review by District Court of Appeal of circuit court's decision denying petitioner's challenge to city's denial of approval of site plan was limited to determination of whether circuit court afforded procedural due process and applied correct law. US.C.A. Const.Amends. 5, 14. Attorneys and Law Firms *594 Jason G. Reynolds of Coble, Barkin, Gordon, Morris & Reynolds, RA., Daytona Beach, for petitioner. Astrid de Parry, City Atty., Deland, for respondent. Opinion PETERSON, Judge. Colonial Apartments, L.P. v. City of Deland, 577 S0.2d 593 (1991) 16 Fla: L. Weekly 505 Colonial Apartments, L.P., petitions for a writ of certiorari to review the circuit court's denial of a petition for a writ of certiorari filed in that court. The petition in the circuit court asked for relief from an administrative action by the City of Deland in denying approval of a site plan submitted by petitioner. We grant the writ. Petitioner sought to construct an apartment project on an approximately twenty -acre site in the City of Deland: The site had been rezoned R-4 under section 33-8.1 of the Deland Code of Ordinances at the time of its annexation into the city in 1972. The ordinance has remained substantially unchanged since the annexation, Pertinent portions of the ordinance provide: (A) Statement of intent. The intent of the R-4 dwelling district is to: (1) Permit the construction of totally planned single- family cluster developments or duplexes, triplexes and low -density low-rise garden type apartments on relatively large tracts of land in single or common ownership; (2) Require the preparation and approval of detailed site, landscape, traffic, parking and other plans deemed necessary as part of an overall development concept; (3) Require a greater amount of open space and recreation area to building area; and (4) Achieve an esthetic and compatible relationship between buildings, yards, patios, parking areas, common open space, recreation areas, and adjacent properties. (E) Dimensional requirements. The following requirements shall apply in the R-4 District: (1) Minfinuiri project site. A two-family or multi -family dwelling project site should be approximately one acre or more in area in order to accoirimodate at least two (2) or three (3) buildin gs, and in any case be sufficient in size to meet the requirements set out herein. (2) Project density, The maximum allowable number of dwelling units shall not exceed sixteen (16) units per acre. (F) Building height. In order to encourage variety in the appearance of building roof lines and more usable or landscaped area, developers are permitted to design a portion of the iriulti-family dwelling project to a maximum height of three (3) stories or forty-five (45) feet provided the following conditions are met: (3) No three-story structures shall be located adjacent to a single-family residential area as shown on the zoning map or land use plan. (H) Screening. A minimum five-foot high screen shall be provided along side and rear lot lines that abut upon a single-family residential area as shown on the zoning map or land use plan but shall not be required in any front yard or along side lot lines abutting a street, park, stream, lake or golf course... (N) Architecture and environmental quality guidelines. In order to promote architectural and environmental quality within the project, the developer is encouraged to utilize the following guidelines in designing the project: (2) The architectural design of buildings should be developed with consideration *595 given to the relationship of existing adjacent development in terms of building height, mass, texture, line, and pattern. Additionally, the ordinance provided in rather specific tern -is for setback requirements, spacing between buildings, number of stories and height requirements, minimum livable floor area in square feet, screening, parking requirements and design, vehicle access lanes, sidewalks, open space requirements, landscaping, signs, and architectural and environmental quality guidelines. Petitioner attempted to comply with the requirements of the ordinance and submitted for approval a site plan that provided for a density of thirteen units per acre. The city's planning authorities recommended to the city commission that the plan be approved with certain changes not involving density; the Colonial Apartments, L.P. v. City of DeLand, 577 So.2d 593 (1991) 16 Fla. L.-W-66-k-ly 5-0-5, petitioner agreed in writing to make the suggested changes. The city commission tabled action on the plan at the first consideration when adjoining landowners voiced opposition. Then, at a contiriission meeting on December 18, 1989, final action was taken that approved the plan with the single condition that the density not exceed six units per acre. The city directed a letter to petitioner on December 21, 1989, stating the reason for its action: 1. Based upon Section 33-8,1(A)(1), the proposed development did not meet the criteria of being "low -density low-rise garden type apartments on relatively large tracts of land"; and 2. Based upon Section 33-81(A)(4), the proposed development did not achieve an aesthetic and compatible relationship with the adjacent properties. Petitioner then requested that the circuit court grant review of the action of the city commission and argued that the action had the practical effect of illegally down -zoning the site from sixteen to six units per acre. The city responded by arguing that the site had never been properly zoned R-4 when annexed because of non-compliance by the applicant and the city with notice and hearing requirements and/or a required sketch development plan. The city further argued that a planned development in the RA zoning district was more analogous to a special exception use than a rezoning, and that density was a proper consideration tinder the "statement of intent" portion of the ordinance that required an "aesthetic and compatible relationship" with adjacent properties. The circuit court denied the petition in a sixteen -page opinion and order in which it discussed: (1) the illegality of the initial rezoning (noting that it was not necessary to rule upon this issue since "all parties agreed that the R-4 zoning designation should be presumed valid"); (2) the inadequate level of city services and increase in traffic; (3) the fact that the site is surrounded on three sides by low density, single-family, residential and agricultural use and the fact that the closest existing multi -family development has a density of 4.25 to 4.5 units per acre; and (4) the generally accepted planning standard for low-dcnsity, multi -family developments of five to eight units per acre. The order concluded by holding that the city had discretion to condition site plan approval for a multi- family development in the R-4 zoning district on a reduction of project density, and that the city's determination was supported by substantial, competent evidence that six dwelling units per acre would be more compatible with surrounding properties. The circuit court also commented that "[p]roject density is of legitimate concern to the City Commission in determining whether or not to approve a site plan for a multifamily development in the R-4 zoning district." The appendices provided by the parties included copies of the legislative history of the annexation, including 1972 minutes and ordinances. That history reflected that the primary purpose of the city in annexing the site in 1972 was to promote the joint efforts of 'developers of lands in the general location of the site to construct a master sewer lift station and discourage installation of four to six individual small package treatment plants. Nothing in the 1972 records provides the slightest hint that density was a consideration except the statement *596 in ordinance number 72-34 that "the building of R-4 multiple family dwellings on the subject property would be consistent with the City's Comprehensive Use Plan, which plan has been approved by the Planning Board of the City of DeLand as well as the technical assistance of the Volusia Council of Goverrintents...." The appendices contain neither copies of pertinent portions of the comprehensive plans nor minutes of the 1989 city commission meetings that would allow any insight into the substantial down -zoning of the site. We view the issue that was presented to the circuit court as one of construction of the R-4 ordinance. While there may have been an additional issue initially on the validity of ordinance 72-34 that zoned the site R-4 and annexed it into the city limits of DeLand, that issue was removed from consideration by the circuit court through the stipulation of the parties. [1] The elected and appointed officials charged with the administration of city and county government are subjected to increasing pressures. On one hand, they are pressed to allow growth only if it is commensurate with available roads and services. On the other hand is the pressure from landowners who wish to develop their vacant properties in a manner that results in the largest return of capital or pleasure. Still another pressure is the desire of neighbors who do not wish their present enjoyment of their lands disrupted in the slightest by the use of adjoining vacant property. Opposition of surrounding property owners must be considered by the city in the instant case since the statement of intent of the RA ordinance includes the desire to achieve aesthetic and compatible relationships between adjacent properties. But the opinions of neighbors by themselves are insufficient to support a denial of a proposed development, BML In ivsunews v. Qji qfCasselberi-Y', 476 So.2-d 713 (Fla. 5th DCA 1985), V", Colonial Apartiflents, L.R v. City of DeLand, 577 So.2d 593 (1991) UW66kly'5O5 rev. denied, 486 So.2d 595 (F1a.1986); Conefla is City of Sarasolu, 400 So.2d 1051 (Fla. 2d DCA 1981). General rules of statutory construction in zoning matters have evolved in past judicial attempts at interpretation and are appropriate in our review of the DeLand ordinance. Some of the basic rules were set forth in Rinker lVetterials Coq)orotion v. City a ,f'Morth illfianti, 286 So.2d 552 (Fla.] 973): (a) In statutory construction, statutes must be given their plain and obvious meaning and it must be assumed that the legislative body knew the plain and ordinary meanings of the words. (c) Since zoning regulations are in derogation of private rights of ownership, words used in a zoning ordinance should be given their broadest meaning when there is no definition or clear intent to the contrary and the ordinance should be interpreted in favor of the property owner. Id. at 553 (footnotes omitted). In Rinker, the supreme court also cited Rose v. Torun of ffillsboro Beach, 216 So.2d 258 (Fla, 4th DCA 1968), for the rule that courts generally may not insert words or phrases in municipal ordinances in order to express intentions which do not appear, unless it is clear that the omission was inadvertent, and must give to an ordinance the plain and ordinary meaning of the words employed by the legislative body. -1d. at 553. [21 This court followed another basic rule in ON ol"Ormond Beach i,, State ex rel. Del Marco, 426 So.2d 1029 (Fla. 5th DCA 1983), when we stated that the primary guide to statutory interpretation is the determination of legislative intent. it is only the interpretation of the statement of intent of the DeLand ordinance that causes the problem in the instant case, since the other portions of. the ordinance are rather precise in directing the manner in which a parcel of land designated R-4 may be used. This statement of intent was used by the city to vary the rather straightforward pronouncement of the ordinance that limited the project density to sixteen units per acre. The record shows there was no evidence of intent before the trial court other than the language of the ordinance and the history of the annexation. The history seems to indicate that the city *597 induced the then - landowner to seek annexation in return for the R-4 zoning and availability of sewer facilities. As to the language of the ordinance, we note the following: 1. The ordinance does not define the terms "low density" and "large tracts of land" as stated in section 33-8.1(A) (1), Some assistance in interpreting the term "low -density" can be gleaned, however, from several sections of the ordinance: (a) Subsection (E)(1) provides that a imilti-family dwelling project site ("multiple -family dwelling"), which includes a "garden apartment" pursuant to subsection (13)(3), should be approximately one acre or more in size to accommodate at least two or three buildings, Subsection (13)(2) describes a garden apartment as a group of two to eight owner- or renter - occupied dwelling units, but this number may be increased to twelve if approved by the planning board. This implies that each building can have eight units without the approval of the planning board. If eight units are allowed and at least two buildings are to be accommodated on approximately one acre, a simple calculation allows us to arrive at the maximum project density of sixteen units per acre. Whether sixteen units per acre are considered low, medium, or high density in other legislation is not clear or even material to this case, but in this ordinance, this number of units appears to fit the definition of a low -density, garden -type apartment, (b) The ordinance contemplates that the R-4 zoning use would be placed adjacent to a single-family residential area indicating compatibility, Subsection (17)(3) prohibits three-story structures adjacent to a single-family residential area, and subsection (H) requires screening through the use of hedges and wood or masomy construction along side and rear lot lines abutting a single-family residential area. This recognition in the ordinance that R-4 and single-family districts can abut in the city's scheme of zoning undercuts the city's argument that the instant petitioner's attempt to gain approval of a site -plan showing thirteen units per acre is absurd when considering the surrounding properties. The city's own professional planning board did not seem to consider the site -plan absurd when it endorsed it with suggested changes not involving a density change. The operative portions of the ordinance reviewed indicate that, for purposes of this ordinance, sixteen units per acre is within the term "low density" used in the statement of intent portion of the ordinance. Furthermore, nothing in the ordinance would lead one who examines the ordinance to Colonial Apartments, L.P. v. City of Deland, 577 So.2d 593 (1991) suspect that the term "compatibility" as used in the statement today in determining land value. When a law establishes a of intent was meant to allow adjustment of the cap of sixteen specific allowable density, its clear terms cannot be varied by units per acre prescribed in subsection (E). a forced interpretation of intent. Such an ordinance should be interpreted in accordance with its plain meaning. The city relies in part on Life Concepts, Inc. v. flarelen, 562 So.2d 726 (Fla, 5th DCA 1990), for its contention that the allowable density can be adjusted because the statement of intent requires that a project have a "compatible relationship" with adjacent properties. The City of Apopka ordinance under review in Lift Concepts required that a use be "compatible with the surrounding residential uses." However, that ordinance is unlike the one in the instant case in that the phrase used in Apopka constituted a density restriction. The operative portion of the Apopka ordinance specifically provided that "[t]he maxiinum number of occupants to reside in the facility shall be compatible with the surrounding residential uses ...... Id. at 727. Moreover, unlike DeLand's ordinance, Apopka's ordinance never specified density at a certain number. We find most significant the comment in Life Concepts: "Had the ordinance provided a specific numerical cap on the occupancy of the home, the zoning board would have been prohibited from considering the actual impact of the proposed use." Life Concepts, at 728. [31 141 We agree with the city that project density is a legitimate concern and go further in stating that it t is a most important concern. But it is a concern that must be addressed and expressed in appropriate ordinances. A community should be developed in accordance with planned action. Development decisions should not be *598 made in reaction to an application that relies on an ordinance establishing a density no longer acceptable to the majority of the current members of a governing body. Owners are entitled to fair play; the lands which may represent their life fortunes should notbe subjected to ad hoc legislation. Density is one of the most important elements in the marketplace End of DOGLIMPtIt [5] Our review of the circuit court's decision is limited to a determination of whether that court afforded procedural due process and applied the correct law. City ofDeerfield Beach v. Naillant, 419 So.2d 624 (Fla.] 9821). The correct law applicable in this case is that the ordinance should be given its plain meaning and that any doubts should be construed in favor of a property owner. The circuit court's reliance upon the undefined and uncertain standards contained in the statement of intent when clear and specific numbers of units are expressed in that same ordinance is not an interpretation that recognizes the plain meaning of the ordinance. It is not fair to the governed that the simple issue of how many dwelling units are allowed under this city ordinance requires a sixteen -page trial court opinion interpreting the ordinance against a clearly expressed number. We grant the writ of certiorari, quash the order of the circuit court, and remand to the circuit court with directions to quash the administrative decision by the City of Deland to impose a condition that the density of petitioner's development not exceed six dwelling units per acre. Writ GRANTED; order QUASHED; REMANDED with directions. W. SHARP and GOSIIORN, JJ., concur. All Citations 577 So.2d 593, 16 Fla. L. Weekly 505 Oc 2024 Thomson heaters, No claim to original U.S. Government Works, .... . . ...... .,.it. "Ah Katherine's Bay, LLC v. Fagan, 52 So,3d 19 (2010) 3 Fia-'.'LWeekly ­b275b' 52 So.3d 19 District Court of Appeal of Florida, First District, KATHERINE'S BAY, LLC, Intervenor, Appellant, V. Ronald J. FAGAN and Citrus County, Appellees. No. 1DI0-939 I Dec. 14, 2010, Synopsis Background: Developer sought review of Department of Administration decision approving ALJ's ruling that rezoning of its property from low intensity coastal lakes (CL) to Recreational Vehicle Park/Carripground (RVP) was invalid because it rendered the county's comprehensive plan internally inconsistent. Neighboring landowner intervened, Holdings: The District Court of Appeal, Lewis, J., held that: [ I ] assertion that recommendation of the county staff was not given sufficient weight was unreviewable; West Headnotes (12) M In [2] ALYs finding that property had severe environmental [3] limitations was thoroughly supported by the county staffs report; [3] ALYs finding of severe environmental limitations was insufficient to justify overriding county's determination that amendment to plan was proper; [4] ALJ erred by relying on neighboring landowner's testimony concerning impact of rezoning; and [5] reliance by ALJ on definitions provided in Administrative Code was proper. Reversed and remanded. U Zoning and Planning .— Preservation before board or officer of _grounds of review Argument that the ALJ applied the wrong standard was not properly before District Court of Appeal, where appellant stood silent when appellee argued that the fairly debatable standard did not apply and when the ALJ invited appellant to provide contrary authority. Zoning and Planning ,- Modification or amendment; rezoning Assertion that recommendation of the county staff was not given sufficient weight by Department of Administration was unreviewable on appeal from decision approving ALYs ruling that rezoning of developer's property from low intensity coastal lakes (CL) to Recreational Vehicle Park/Campground (RVP) was invalid because it rendered the county's comprehensive plan internally inconsistent; it was not the role of the District Court of Appeal to reweigh evidence anew. Zoning and -Planning .:— Particular Uses or Restrictions ALYs finding that property, which was rezoned from low intensity coastal lakes (CL) to Recreational Vehicle Park/Campground (RVP), had severe environmental limitations was thoroughly supported by the county staffs report, although ALJ did not agree with staff s ultimate conclusion; ALJ recited report heavily and relied on its concrete findings which showed the environmental limitations of the subject property. Zoning and Planning --- Particular Uses or Restrictions Zoning and Planning Cl- Do novo review in general Katherine's Bay, LLC v. Fagan, 52 So.3d 19 (2010) 35 Fla. L. Weekly D2759 Whether ALJ erred in relying on a general When all the pertinent provisions of county's policy in county's comprehensive plan when comprehensive plan were considered in more specific policies existed was an pari materia, mere fact that area had issue of law to be reviewed de novo environmental limitations was not basis to in review of Department of Administration prohibit development, as long as it was decision that rezoning of developer's property carried out in accordance with limitations from low intensity coastal lakes (CL) to provided by plan and county's land development Recreational Vehicle Park/Carripground (RVP) code, and, thus, ALYs finding of severe was invalid because it rendered the county's environmental limitations was insufficient to comprehensive plan internally inconsistent; but, justify overriding county's determination that Department of Administration was correct amendment to comprehensive plan changing that ALJ was required to presume that zoning from low intensity coastal lakes (CL) to county's determination that the amendment Recreational Vehicle Park/Campground (RVP) to comprehensive plan complied with Local was proper, where, under plan, entire coastal area Government Comprehensive Planning and Land was considered environmentally sensitive, with Development Regulation Act and, thus, was future development expected, West's F.S.A. consistent with the plan. West's F.S.A, § 163,3187(3)(a). 1 b3.31 g7(3)(a). 191 Zoning and Planning F Particular Uses or 151 Zoning and Planning - Coin pi-chen sive or Restrictions general plan ALJ erred by relying on neighboring landowner's Rules of statutory construction are applicable to testimony concerning impact of rezoning of the interpretation of comprehensive plans. developer's land from low intensity coastal lakes (CL) to Recreational Vehicle Park/Campground I Case that cites this headnote (RVP) on potential light pollution, increased traffic, and negative impacts on value of homes 16] Statutes General and specific terms and in the area; there were no facts to support his provisions; ejusdern gencris concerns, county staffs report indicated that traffic issue was studied by an expert who Specific provisions of statutes control over determined that increased traffic would not general -icral ones, unduly burden the area, and ALJ gave undue emphasis to landowner's preference not to have an RV park as a neighbor, but preference in itself [7] Statutes Construing together; harmony I-- was insufficient to override developer's desire to Statutes =LL Superfluousness build an RV park on its land. Statutes In pari materia I Case that cites this headnote One provision of statute should not be read in such a way that it renders another provision meaningless; all statutory provisions on related [10] Zoning and Planning Particular Uses or subjects are read in pari materia and harmonized Res(rictions, so that each is given effect. Reliance by ALJ, who was considering whether rezoning of developer's property I Case that cites this headnote from low intensity coastal lakes (CL) to Recreational Vehicle Park/Campground (RVP) 181 Zoning and Planning Particular Uses or was invalid because it rendered the county's Restrictions comprehensive plan internally inconsistent, on definitions provided in Administrative Code P Katherine's Bay, LI-C v. Fagan, 52 So.3d 19 (2010) 35'Fla. L VVe'ek­l'y'D2759 was proper where county's comprehensive plan did not define term "compatible," and because statute governing process for adoption of comprehensive plan defined in "compliance" as consistent with requirements of state comprehensive plan, appropriate strategic regional policy plan, and with chapter of Administrative Code governing criteria for review of local government comprehensive plans and plan amendments. 'West's F,S,A. §§ 163.3171, 163,3178, 163.3180, 163.3184(1)(b), 163,3191, 163.3245; Fla.Admin.Code Ann. r. 9J-5.003(23). I Case that cites this headnote III] Zoning and Planning (;= Change to plan itself, in general To show that amendment to county's comprehensive plan provided for an incompatible land use, landowner was required to prove that, because of new future land use category assigned to neighboring developer's property, the land uses or conditions in the area could not coexist in a stable fashion over time such that no use or condition was unduly negatively impacted directly or indirectly by another use or condition. 1121 Zoning and Planning ,=- Evidence Lay witnesses may offer their views in land use cases about matters not requiring expert testimony; lay witnesses may testify about the natural beauty of an area because this is not an issue requiring expertise, but their speculation about potential traffic problems, light and noise pollution, and general unfavorable impacts of a proposed land use are not considered competent, substantial evidence. Attorneys and Law Firms *21 Clark A. Stillwell, Inverness, for Appellant. Shaw P. Stiller, General Counsel, Department of Community Affairs, Tallahassee, and Denise A. Lyn, Inverness, for Appellees. Opinion LEWIS, J. Katherine's Bay, LLC, Appellant, seeks review of a final order issued by the Administration Commission ("the Commission"), which adopted an administrative law judge's ("ALF') holding that a small-scale development amendment ("the Amendment") to Citrus County's Comprehensive Plan ("the Plan") was invalid because it rendered the Plan internally inconsistent. The ALJ and the Commission recognized two grounds for finding the Amendment inconsistent with the Plan: first, that it violated a policy in the Plan's Future Land Use Element ("FLUE") requiring compatibility of land uses; and second, that it violated a policy in the Plan's FLUE requiring the County to guide future development to areas with minimal environmental limitations. Appellant challenges both grounds. As to the first ground, Appellant argues that there was a lack of competent, substantial evidence to support the ALYs finding that the Amendment approved a future land use designation that was incompatible with the surrounding uses. We agree. As to the second ground, Appellant argues both that there was a lack of competent, substantial evidence to support the ALJ's factual findings and that the ALYs ultimate conclusion resulted from an erroneous construction of the Plan. While we do find competent, substantial evidence of the findings the ALI made in relation to the second ground, we hold that the findings did not support the conclusion that the Amendment rendered the Plan internally inconsistent. Because the ALYs conclusion that the Amendment rendered the Plan internally inconsistent is not supported by either of the FLUE policies at issue, we reverse and remand to the Commission for reinstatement of the ordinance, *22 I. Facts and Procedural History On May 26, 2009, the Citrus County Board of County Commissioners adopted an ordinance that amended the Plan's Generalized Future Land Use Map ("GFLUM"), which is a part of the FLUE. The Amendment changed the future land use designation of a 9.9—acre parcel of land owned by Appellant, based on Appellant's application for such a change. wj,! Katherine's Bay, LLC v. Fagan, 52 So.3d 19 (2010) 25 Fla. L,Weekly D-27-5-9, The subject property is located in a geographic region defined by Citrus County as the "Coastal Area." According to the Plan, "[t]he Coastal Area parallels the Gulf of Mexico, and the boundary may be described as following the west side of US- 19 north from the Hernando County line to the Withlacoochee River." The Plan notes that "[t]his boundary is the basis for an environmentally sensitive overlay zone to be used for land use regulatory purposes." Before the Amendment, the subject property was designated Low Intensity Coastal and Lakes ("CL"), which the Plan defines in pertinent part as follows: Low Intensity Coastal and Lakes (CL) This land use category designates those areas having environmental characteristics that are sensitive to development and therefore should be protected. Residential development in this district is limited to a maximum of one dwelling -unit per 20 acres... In addition to single family residential development, the following land uses may be allowed provided the permitted use is compatible with the surrounding area, and standards for development are met as specified in the Citrus County Land Development Code (LDC)[:] • Multifamily residences (in existing platted areas only or in lieu of clustering single family units at a density of one unit per lot of record and requiring the recombination of said lots. For example, a duplex requires two lots to be recombined into a single parcel, a quadruplex four lots, etc.) • Recreational uses • Agricultural and Silviculture uses • Public/Semi—Public, Institutional facilities • Home occupations • Now railroad right-of-way, storage facilities, or related Structures • Cornirmnication towers • Utilities • Commercial fishing and marina related uses • Commercial uses that are water related, water dependent, or necessary for the support of the immediate population[.] The Amendment changed the subject property's future land use category from CL to Recreational Vehicle Park/ Campground ("RVP"), which the Plan defines in pertinent part as follows: Recreational Vehicle Park/Campground (RVP) This category is intended to recognize existing Recreational Vehicle (RV) Parks and Campgrounds, as well as to provide for the location and development of new parks for recreational vehicles. Such parks are intended specifically to allow temporary living accommodation for recreation, camping, or travel use. New RV parks shall be required to preserve thirty percent (30%) of the gross site area as permanent open space, consistent with Policy 17.15,11 of this Plan. *23 In addition to RV/campsite development, the following land uses as detailed in the Land Development Code, shall be allowed provided the permitted use is compatible with the surrounding area, and standards for development are met as specified in the County Land Development Code: • Recreational Uses • Agricultural and Silvicultural Uses • Public/Seirii—Public, Institutional Facilities • Convenience retail and personal services to serve park visitors and guests up to one percent of the gross site area, not to exceed 5,000 square feet, located within the development and not accessible from any external road[.] After the Amendment changing the subject property's future land use category from CL to RVP was adopted, Appellee, the owner of neighboring property, challenged the Amendment under the procedure set forth in section 163.3187(3)(a), Florida Statutes (2008). Appellee argued that the Amendment was not "in compliance" with the Local Government Comprehensive Planning and Land Development Regulation Act ("the Act") because it rendered the Plan internally inconsistent. Appellee identified two policies in the FLUE, Katherine's Bay, LLC v. Fagan, 52 So.3d 19 (2010) among others, that he claimed were inconsistent with the Amendment. Those policies are 17.2.7 and 17.2.8, and they provide as follows: Policy 17.2.7 The County shall guide future development to the most appropriate areas, as depicted on the GFLUM, specifically those with minimal environinental limitations and the availability of necessary services. Policy 17.2.8 The County shall utilize land use techniques and development standards to achieve a functional and compatible land use framework which reduces incompatible land uses. Appellant intervened in the proceedings, and the matter proceeded to a section 120.57 hearing. The parties stipulated that the subject property is located across the road from Appellee's property, which is on the Homosassa River, and that the subject property is bordered in all directions by property designated as either CL or Coastal and Lakes Residential ("CLR"). They also stipulated that there exists on Appellant's property a parcel designated Coastal/Lakes—Commercial ("CLC") I and that this property is being used as an RV park because this use of the property is vested. Further, they stipulated that Appellee's property was in the Coastal High Hazard Area ("CHHA"). At the hearing, Appellee supported his argument that the Amendment rendered the subject property incompatible with the surrounding uses primarily by presenting his own testimony and that of his neighbor. Appellee described the beauty and peacefulness of the area and opined that the introduction of another RV park into the area would lead to increased traffic, litter, noise, and light pollution. He testified that the vested RV park currently existing on Appellant's property is an "eyesore" that "looks like a bunch of junk stored on the front lawn." Appellee also testified that, in 1993, there was a major flood in the area around his home, which was so severe that he had to tie boats to his mailbox to keep them from floating down *24 the road. He was concerned that the RV park Appellant planned to develop on the subject property would require him to manage even more debris in the event of a natural disaster. Appellee also expressed concern that the RV park would decrease his property value. A neighbor expressed the same concerns about the potential for increased traffic and decreased property values in the area. The evidence concerning the subject property's environmental limitations came in the form of the County Staffs report and the testimony of Dr. Timothy Pitts and Sue Farnsworth, both of whom were employed by the County as planners. The report was prepared by Dr. Pitts, who was the County's Senior Planner of Community Development at the time. According to the County Staffs report, the subject property was studied by officials in the fire prevention, engineering, -Litilities,,and environmental divisions. The fire prevention. and engineering representatives recommended approval of the application with conditions, and the utilities representative recommended approval. The environmental planner did not recommend approval or denial but noted that the subject property was within a "Karst Sensitive Arca."2 Additionally, the report indicated that a "traffic analysis" had revealed that "adequate capacity exists on Halls River Road for anticipated traffic at the maximum development potential of the site." The report also noted that the subject property was within the CHHA and that it contained "significant wetland areas." According to the report, if the application was granted, Appellant would still need to "design a Master Plan of Development that minimizes wetland alterations." One of the policies of the Plan that the report indicated may be cause for concern was Policy 3.18.11, which provides as follows: The County shall protect springs by prohibiting increases in allowed land use intensity at the Generalized Future Land Use level within a Karst Sensitive Area without a hydrogeological analysis that addresses impacts to groundwater resources. The analysis shall be performed by a professional geologist or professional engineer licensed in Florida. Karst Sensitive Area shall be defined as an area in which limestone lies within five (5) feet of depth from natural grade. In relation to this policy, the report stated that Appellant had "provided a letter from a professional engineer that adequately meets the intent of this policy" and that Appellant intended "to develop the site using methods that will meet the intent of the Comprehensive Plan," The report also contained the following observations: This site has some severe environmental restrictions — extensive wetlands, proximity to an Outstanding Florida Waterbody, Karst sensitive landscape —and it will be difficult to design a site that meets the standards of the Comprehensive Plan and the Land Development Code, The following policy would potentially restrict development if this application were to be approved: Policy 3,16.3 Development shall not be allowed at the maximum densities and intensities of the underlying Katherine's Bay, LLC v. Fagan, 52 So.3d 19 (2010) 35 Fla'aL. Weekly D2759 land use district if those densities would be harmful to natural resources. So, the applicant should be cautioned that given the environmental sensitivity of the property, development may be limited on this site to less than the allowable maximum intensity. If this *25 application is approved, an appropriately designed master plan of development will be required which meets all standards of theComprehensive Plan and the Land Developnient Code and is approved by the Board of County Commissioners. Ultimately, despite the environmental limitations, the County Staff concluded that the site was "appropriate for some type of RV Park development subject to an appropriately designed master plan," In making this recommendation, the County Staff emphasized that, "based on the enviromuental limitations of the area, the applicant is cautioned that the site may not be able to be designed at the maximum intensity for this land use district." Dr. Pitts testified consistently with the County Staffs report. He noted that neither the Plan nor the Land Development Code ("LDC") prohibits RV parks in either karst sensitive areas or the CHHA. He explained, however, that the County has regulations limiting the density or intensity of RV parks in such areas and indicated that the professional studies he had received on the subject property represented that the site could be developed to meet those standards. Dr. Pitts testified that, in his opinion, "just about anything west of [U.S. Highway 19] is — karst sensitive." Dr. Pitts acknowledged that the subject property had 1.64 acres of wetlands and that there were wetlands in the surrounding areas. He explained that the Plan requires "setbacks" to mitigate wetland impacts and ' that the LDC required one - hundred percent protection of the wetlands. Additionally, he explained that the regulations required fifty percent open space in the Coastal Area. Based on, these regulations, Dr. Pitts testified that it was highly unlikely that Appellant would be permitted to develop the space at the maximum build - out potential theoretically allowed under the new designation, which would be five units per acre. He emphasized that, no matter what the number of approved units proved to be, complete protection of the wetlands would be required. Finally, Dr. Pitts testified that there were several vested uses in the surrounding area, including a 300—to 400—unit RV park, that did not conform to the land use designations identified for those properties in the Plan. Farnsworth, an environmental planner for the County, testified that the wetlands were located around the perimeter of the property and that they extended into the part of the property beyond the perimeter. She explained, however, that permitting standards for an RV park prohibited the filling of wetlands and that the subject property could be developed as an RV park without the need to fill in the wetlands. After the hearing, the ALJ issued a Recommended Order concluding that the Amendment was inconsistent with FLUE Policy 17.2.7's requirement that future development be directed to "the most appropriate areas, as depicted on the GFLUM, specifically those with minimal environmental limitations." in support of this conclusion, the ALJ noted the County Staffs finding that the land had "severe environmental limitations." In particular, the ALJ noted that the area in which the subject property was located had extensive wetlands, a karst sensitive landscape, and a CHHA designation. The ALJ acknowledged that the Plan did not expressly prohibit RV parks in CHHA areas and that there were regulations in the Plan and the LDC that would limit the intensity of development on this land even under the RVP designation, The ALJ concluded, however, that "[n]otwithstanding the other provisions within the Plan and LDRs that place limitations on RV park development *26 in an effort to satisfy environmental constraints, — the subject property is clearly not 'the most appropriate area, as depicted on the GFLUM' for new development, nor is it an area with 'minimal environmental limitations,' " The ALJ also concluded that the Amendment was inconsistent with FLUE Policy 17.2.8's requirement that development be accomplished in a "functional and compatible land use framework which reduces incompatible land uses." Because "compatible" is not defined in the Plan, the ALJ relied on the definition of "compatibility" in Florida Adjuinistrativc Code Rule 9J-5.003(23). That definition is as follows: "Compatibility" means a condition in which land uses or conditions can coexist in relative proximity to each other in a stable fashion over time such that no use or condition is unduly negatively impacted directly or indirectly by another use or condition. In support of the conclusion that the new designation approved a land use incompatible with the surrounding uses, the ALJ noted Appellee's testimony concerning the characteristics of the area. He also noted Appellee's concerns about noise, lighting, litter, traffic, and property value, The ALJ further noted that there were only six nonconforming land -uses and that each was permitted to exist due to vested rights, The ALJ then stated, "It is fair to infer that the insertion Katherine's Bay, LLG v. Fagan, 52 So.3d 19 (2010) 35 Fla. L. Weekly D2759 of an RV park in the middle of a large tract of vacant CL land would logically lead to further requests for reclassifying CL land to expand the new RV park or to allow other non- residential uses." The ALJ further found the following: The commercial RV park, with a yet -to -be determined number of spaces for temporary RVs, tenants, and associated commercial development, will be in close proximity to a predominately [sic] residential neighborhood. A reasonable inference from the evidence is that these commercial uses will have a direct or indirect negative impact on the nearby residential properties and should not coexist in close proximity to one another. Based on these findings and the determination that the Amendment was inconsistent with FLUE Policy 17.2.7, the ALJ recommended that the Commission conclude that the Amendment was not in compliance with the Act. The Commission adopted the ALYs findings and conclusions, except that it modified the finding that the Amendment would "logically lead to further requests for reclassifying CL land to expand the new RV park or to allow other non-residential uses." The Commission concluded that this finding was mere conjecture, unsupported by competent, substantial evidence. It modified the finding to read, "Unlike the presence of ... pre-existing, non -conforming -uses, permitting the addition of an RV park in the middle of a large tract of vacant CL land now would set a precedent that an RV park, a Commercial Land Use, I is compatible with the Low Intensity Coastal and Lakes Land Use designation in this vicinity." Based on the adoption of the ALYs findings and conclusions, as modified, the Commission held that the Amendment had no legal effect. 11. Analysis A. Standard of Review The amendment at issue in this case was adopted under the authority of section 1633 187( 1 )(c). Florida Statutes (2008). Section 161,3187(3)(a) provides for review of amendments adopted under section 163.3187(l)(0) under the following terms: The state land planning agency shall not review or issue a notice of intent for small scale development amendments which satisfy the requirements of paragraph *27 (1)(c). Any affected person may file a petition with the Division of Administrative Hearings pursuant to ss. 120,569 and 120.57 to request a bearing to challenge the compliance of a small scale development amendment with this act within 30 days following the local government's adoption of the amendment, shall serve a copy of the petition on the local government, and shall furnish a copy to the state land planning agency. An administrative law judge shall hold a hearing in the affected jurisdiction not less than 30 days nor more than 60 days following the filing of a petition and the assignment of an administrative law judge. The parties to a hearing held pursuant to this subsection shall be the petitioner, the local government, and any intervenor. In the proceeding, the local government's determination that the small scale development amendment is in compliance is presumed to be correct. The local government's determination shall be sustained unless it is shown by a preponderance of the evidence that the amendment is not in compliance with the requirements of this act. In any proceeding initiated pursuant to this subsection, the state land planning agency may intervene. § 163.3187(3)(a), Because Appellant is challenging the Administration Commission's final agency action in this appeal, see id., this Court's standard of review is governed by section 120.68(7), Florida Statutes (2010). That section provides inpertinentpart as follows: The court shall remand a case to the agency for further proceedings consistent with the court's decision or set aside agency action, as appropriate, when it finds that: (b) The agency's action depends on any finding of fact that is not supported by competent, substantial evidence in the record of a hearing conducted pursuant to ss. 120.569 and 120.57,- however, the court shall not substitute its judgment for that of the agency as to the weight of the evidence on any disputed finding of fact; [or] (d) The agency has erroneously interpreted a provision of law and a correct interpretation compels a particular action.... § 120.68(7). [11 In this Court, Appellant challenges the sufficiency of the evidence supporting the findings of inconsistency with both policies.3 In addition, Appellant challenges the Katherine's Bay, LLC v, Fagan, 52 So.3d 19 (2010) 35 FIa. L. Weekly 'ff7tb­ ALJ's interpretation of the policy requiring that future development be directed toward areas of the County with minimal environmental limitations. The separate arguments concerning each policy will be addressed in turn, B. FLUE Policy 17.2.7 With regard to FLUE Policy 17.2,7, Appellant raises two arguments: first, that *28 the ALJ erred in relying on the County Staffs finding of "severe environmental limitations" because the County Staff recommended approval of the application; and second, that the ALJ erred in failing to apply the FLUE policies that are more specific to RV parks in the Coastal Area in lieu of FLUE Policy 17.2.7, which is a general planning policy applicable to all land use decisions countywide. We agree with the second point. i, The County Staff's Report 121 [3] Appellant insists that the ALJ was required to give the County Staffs recommendation great weight. Even assuming that the County Staffs report was entitled to great weight in this case, there is no basis in the record for believing that the ALJ did not give it due consideration, To the contrary, the ALJ recited it heavily and relied on the concrete findings within it that showed the environmental limitations of the subject property, even though the ALJ disagreed with the ultimate conclusion. If an ALJ were not entitled to disagree, then the ALYs review would serve no purpose. To the extent Appellant argues that the recommendation of the County Staff was not given sufficient weight, this assertion is unreviewable because "[i]t is not the role of the appellate court to reweigh evidence anew," )`bwig,i� D(,])t of Editc- Dii, o0locational Rehab., 943 So.2d 901,902 (Fla. I st DCA 2006). The ALJ's finding that the subject property had severe environmental limitations was thoroughly supported by the County Staffs report. Whether those limitations required a finding that the Amendment was inconsistent with FLUE Policy 17.2.7 is, however, a separate matter. this issue de novo, however, we bear in mind that the ALJ was required tinder section 163,3187(3)(a) to presume that the County's determination that the Amendment complied with the Act (and, thus, was consistent with the Plan) was correct. 151 161 [71 Rules of statutory construction are applicable to the interpretation of comprehensive plans. See Greut Outdoors Trading, Inc. v. City oJ'High Springs, 550 So.2d 483, 485 (Fla. Ist DCA 1989) (noting that the rules of statutory construction apply to municipal ordinances and city charters); ff'ilfls, 41 So3d at279 (noting that a comprehensive plan is like a "constitution for all future development within the governmental boundary") (citation omitted). Appellant argues that this case implicates the rules of construction that specific provisions control over general ones and that one provision should not be read in such a way that it renders another provision meaningless. Both rules are well - established, See Murra ' i,� i� Mariner Health, 994 So.2d 1051, 1061 (Fla.2008). Another rule of construction relevant to this issue is that all provisions on related subjects be read in pari materia and harmonized so that each is given effect. Cone v. Stale, Dol)'l ofHeallh. 886 So.2d 1007. 1010 (Fla. 1st DCA 2004). [81 Here, the ALJ concluded that the Amendment conflicted with FLUE Policy 17.2.7, which provides, "The County shall guide future development to the most appropriate areas, as depicted on the GFLUM, specifically those with minimal environmental limitations and the availability of necessary services." (CP 10-155). Appellant contends that FLUE Policies 17.6.5 and 17.6.12, which are more specific to RV parks in the Coastal Area, indicate *29 that the Amendment was consistent with the Plan. Those policies provide as follows: Policy 17.6.5 Specialized commercial needs, such as water -dependent and water -related uses, temporary accommodations for tourists and campers, as well as neighborhood commercial uses and services serving residential communities within the general Coastal, Lakes, and Rivers Areas shall be provided for within the Future Land Use Plan and standards for development provided within the County LDC. ii. Interpretation of the Plan Policy 17.6.12 Recreational vehicle (RV) parks and 141 Appellant's argument that the ALJ erred in relying on a campgrounds shall be designed according to a detailed general policy in the Plan where more specific policies existed master plan, shall preserve a minimum of 30 percent of is an issue of law to be reviewed de novo. See Nassau County the property in open space, shall provide a minimum of TfVlis, 41 So.3(1270, 278 (Fla. 1 st DCA 2010). In reviewing an additional 10 percent of the property as recreation Katherine's Bay, LLC v. Fagan, 52 So.3d 19 (2010) 35 Fla. L'.' W,,e--e"k-lyD, 2,7 5-9, areas, and generally shall conform to the commercial development standards in the Land Development Code.... In order to minimize the adverse impact of development on the resources and natural features of the Coastal, Lakes, and Rivers Region, the LDC shall be amended to include additional review criteria for all new RVP projects located in this region. Such criteria may include: • Restrictions on density • Enhanced open space requirements • Weiland protection • Upland preservation • Clustering • Connection to regional central water and sewer service Appellant is correct in noting that the development of new RV parks in Coastal Areas was specifically anticipated by FLUE Policy 17.6,12, This observation does not, however, mandate approval of an RVP designation for the particular parcel at issue. Thus, it was appropriate for the ALJ to resort to other portions of the Plan to determine whether approval of the RVP designation for the subject property was proper. The policy that-1-nost directly relates to this inquiry is FLUE Policy 17.2.7, which articulates the County's general preference for guiding future development to the "most appropriate areas," which are areas "with minimal environmental limitations." Two additional provisions of the Plan provide more context for the policies at issue. First, the Plan describes the "Coastal Area" as follows: The Coastal. Area parallels the Gulf of Mexico, and the boundary may be described as following the west side of US-19 north from the Hernando County line to the Withlacoochee River. This boundary is the basis for an environmentally sensitive overlay zone to be used for land use regulatory purposes.... Second, under the heading "Development in Weiland and Coastal Areas," the Plan notes the following: Future development in the Coastal, Lake, and River Areas will require careful management in order to reduce potential problems and impacts on the environment. Development within these areas will be limited to low, [sic] intensity uses. In addition, all development will be required to nicet standards for development and obtain necessary permits from appropriate regulatory agencies. These two provisions show that, under the Plan, the entire Coastal Area is considered environmentally sensitive, and yet "[fluture development" of this envirourrientally sensitive area is expected. Thus, when all the pertinent provisions of the Plan are considered in pari materia, the mere fact *30 that an area has environmental limitations is not a basis to prohibit development as long as the development is carried out in accordance with the limitations provided by the Plan and the LDC. Therefore, the ALYs finding of "severe environmental limitations" was insufficient to justify overriding the County's determination that the Amendment was proper, particularly in light of the presumption required by section 163.31 87(3)(a), The ALJ properly found the existence of wetlands and karst sensitivity in the area, but there was no competent, substantial evidence that these limitations were so severe as to require a prohibition on the development of an RV park under the restrictions that would be imposed by the LDC, In sum, when FLUE Policy 17.2.7 and the evidence related to that policy are viewed in the context of all relevant provisions of the Plan, the conclusion that the Amendment is inconsistent with that policy is unsupported. C. FLUE Policy 17.2.8 t91 With regard to FLUE Policy 17.2.8, Appellant argues that the ALJ erred in relying on the testimony of Appellee and his neighbor as a basis for finding incompatibility of the subject property's new future land use designation with the surrounding uses. In particular, he argues that this testimony was "unacceptable lay testimony" and that no competent, substantial evidence showed a lack of compatibility, as that term is defined by Florida Administrative Code Rule 9J- 5,003(23). We agree, [101 1111 Initially, we note that the reliance on the definitions provided in Florida Adi-ninistrative Code Rule 9J- 5,003 was proper because the Plan does not define the term "compatible," and because section 163.3184(1)(b) defines "in compliance" in pertinent part as "consistent with the requirements of ss. 163,3177, 163.3178, 1633 180, 163319 1, and 163,3245, with the state comprehensive plan, with the appropriate strategic regional policy plan, and with chapter 9J-5, Florida Administrative Code." Therefore, to show that the Amendment provided for an incompatible land use, Appellee was required to prove that, because of the new future land use category assigned to Appellant's property, the land Katherine's Bay, LLC v. Fagan, 52 5o.3d 19 (2010) 3'6Fla. _L. Weekly D2759 uses or conditions in the area could not "coexist ... in a stable fashion over time such that no use or condition is unduly negatively impacted directly or indirectly by another use or condition." See Fla. R. Admin. Code 9J-5.003(23). 1121 Lay witnesses may offer their views in land use cases about matters not requiring expert testimony. jIllefro. Dade Ce)11171), v. Blumenthal. 675 So.2d 598., 601 (Fla. 3d DCA 1995). For example, lay witnesses may testify about the natural beauty of an area because this is not an issue requiring expertise. Blumenthal, 675 So.2d at 601. Lay witnesses' speculation about potential "traffic problems, light and noise pollution," and general unfavorable impacts of a proposed land use are not however, considered competent, substantial evidence. Pollard v. Pahn Beach Connty, 560 So.2d 1358, 1359-60 (Fla. 4th DCA 1990). Similarly, lay witnesses' opinions that a proposed land use will devalue homes in the area are insufficient to support a finding that such devaluation will. occur. See 01,11 of.4po].)ka v, Orange Cowa.V, 299 So.2d 657, 659-60 (Fla. 4th DCA 1974) (citation emitted). There must be evidence other than the lay witnesses' opinions to support such claims, See MIL hivs. r,. City ot"Casselben)�, 476 So.2d 713, 715 (Fla.. 5th DCA 1985); City(fApoj)ka, 299 So.2d at 660. Based on these standards, it was error for the ALJ to rely on Appellee's testimony concerning potential light pollution, increased traffic, and negative impacts on *31 the value of the homes in the area. There were no facts to support his concerns, and in fact, the County Staffs report indicates that the traffic issue was studied by an expert and determined that increased traffic would not unduly burden the area. Although it was proper for the ALJ to consider Appellee's observations that, with the exception of the vested non- conforming uses, the area is predominantly residential and that it is peaceful, Appellee presented no competent, substantial evidence to support his claim that the new RV park would unduly interfere with those characteristics of the area. The mere fact that Appellee's property has a different future land use designation than Appellant's re-classified property is insufficient. See I-fillsboroit.-h Counl), v. Mesishore Realtv, Inc., 444 So.2d 25, 27 (Fla, 2d DCA 1983) (holding that the mere fact that property is in close proximity to another property with a less restrictive classification does not require reclassification). Additionally, while it may have been noteworthy that Appellant presently fails to maintain its vested one -acre RV park in an attractive manner, the concern that the yet -to -be -developed RV park would be maintained in the same way is speculative and does not establish long- term negative impacts stemming from the reclassification of the subject property. In sum, based on the applicable definition of "compatibility," Appellant's argument that there was insufficient evidence to support a finding that the RV park was incompatible is well -taken. It appears that, in finding the proposed use incompatible with the surrounding uses, the ALJ gave undue emphasis to Appellee's preference not to have an RV park as a neighbor. However, this preference in itself is insufficient to override Appellant's desire to build an RV park on its land. See Cone fla v: Citf' ' 1, oSarasota, 400 So.2d 1051, 1053 (Fla. 2d DCA 1981) (suggesting that a land -use decision should not be "based primarily on the sentiments of other residents"). As a result, we bold that the ALJ erred in concluding that the Amendment was inconsistent with FLUE Policy 17.2.8. 111. Conclusion For the reasons explained above, both of the ALYs ultimate conclusions as to inconsistency of the Amendment with the remaining portions of the Plan were erroneous. As a result, we reverse and remand to the Commission for reinstatement of the ordinance approving the Amendment. REVERSED and REMANDED. WEBSTER and MARSTILLER, JJ., Concur. All Citations 52 So3d 19, 35 Fla, L. Weekly D2759 Footnotes As provided in the Plan, the CLC category allows commercial uses that are "water related, water dependent, or necessary for the support of the immediate population," i.e. "neighborhood commercial uses, personal services, or professional services." This category is intended "for a single business entity on a single parcel of property." ' Katherine's Bay, LLCxFagan, 52So.34i8(2V1V) 35 Fla 2 According to Dr. P0a, hanst is "limestone underground sort ofrock structure that is very porous" and through which "pollutants can very easily travel." 3 In challenging the sufficiency of the evidence, Appellant argues that the AU did not view the evidence with aneye toward the proper standard. He contends the AU should have considered whether the County's determination that the Amendment was proper was ^ha|dy debatable," based on the standard recognized in Coastal Development of North Florida,Inc.v� City of Beach. 788 8o2d 204 (F\a,2001). The argument that the AU applied the wrong ' standard is not properly before us Appellant stood silent when Appellee argued to the ALthat the "fairly . dnbatob|e''standard did not apply and when the ALJinvited 8ppe||ar�tnprovide cnr�neryauthohty.See DepYn/Bus, &FYo[l Regulation, Cunxtr Indus, LicanxkV7Bd. x Ka/ -den. iO Go.3d 047. 648 (Fla. 1st DCA2O0A) (recognizing the preservation rule inadministrative pmceedinAa). End ofDocument OG2024Thomson Reuters, Noclaim hooriginal U.S. Government Works. -----'----------�------'---�--------- tVVudo 11 Debes v. City of Key West, 690 So.2d 700 (1997) 22 Fla. 'L.'Weekly b827' general on ground that commercial zoning 690 So.2d 700 of parcel would create more traffic than District Court of Appeal of Florida, noncommercial Use. Third District. 2 Cases that cite this headnote Cheryl L. DEBES, as Trustee, Petitioner, V. The CITY OF KEY WEST, Respondent. No. 96-245 1. I April 2,1997. Synopsis Landowner filed petition for certiorari review of decision by the Circuit Court, Monroe County, Sandra Taylor, J., which upheld city commission's denial of application to rezone parcel of owner's property from medium density residential to commercial general. The District Court of Appeal, Schwartz, C.J., held that refusal to rezone property was arbitrary, discriminatory, and unreasonable. Certiorari granted. West Beadnotes (3) [11 Zoning and Planning .gym Change fi,om residential Use to business, commercial, or industrial Use City commission's refusal to rezone owner's property from medium density residential to commercial general so as to permit construction of shopping center was arbitrary, discriminatory, and unreasonable, where parcel was surrounded in all directions and on both sides of street by property which was both zoned and used for commercial purposes, 4 Cases that cite this headnote 121 Zoning and Planning Change from residential Use to business, commercial, or industrial Use City commission could not justify denial of application to rezone owner's property from medium density residential to commercial [31 Zoning and Planning Change from residential use to business, commercial., or industrial use City commission could not justify denial of application to rezone owner's property from residential to commercial general on ground that denial promoted creation of adequate housing; promotion of affordable housing, while it may represent desirable public policy, may not be promoted on back of private landowner by depriving him of constitutionally protected use of his property. 2 Cases that cite this headnote Attorneys and Law Firms *700 Mattson & Tobin and Andrew M. 'robin, Key Largo, for petitioner. *701 Mark Graham Hanson, for respondent. Before SCHIAIAIZTZ, C.J., and COPE and FLETC1-1ER, JJ. Opinion SCHWARTZ, Chief Judge. [1] The petitioner is the owner of undeveloped land on North Roosevelt Boulevard in Key West. The parcel is in the center of what is specifically designated in the city's Comprehensive Plan as a primary commercial area and is, in fact, surrounded in all directions and on both sides of the street by property which is both zoned and used for commercial purposes. Notwithstanding, the Key West City Commission three times denied I an application initiated by its own City Planner,` and approved by the Planning Board, to amend the designation of the property on the Future Land Use Map (FLUM) from Medium Density Residential (MDR) to Commercial General (CG) I so as to permit the construction of a shopping center. On this petition for certiorari review of a circuit court decision which upheld the last denial, we Debes v. City of Key West, 690 So.2d 700 (1997) conclude that, as a matter of law, "the refusal to rezone the property [was] arbitrary, discriminatory [and] unreasonable." Board of Counl.i,, Connnrs it Snyder, 627 So.2d 469., 476 (Fla, 1993). Almost without more, this brief recitation of the characteristics of the area and of the petitioner's particular situation clearly establishes that singling out her property alone for disparate treatment represents a wholly impermissible instance of discriminatory spot zoning -or, in this context, spot planning -in reverse. Tollius a CilY of'!Viond, 96 So.2d 122 (Fla. 1957); City* Connnission v ffoodlaioi Park Cemetery Co., 553 So.2d 1227 (Fla. 3d DCA 1989), review denied, 563 So.2d 631 (F1aJ990); City ol'Coral Gables i� 111"lepinan, 418 So.2d 339 (Fla. 3d DCA 1982), review denied, 424 So.2d 760 (Fla.] 982); 014v i� OtY of Jacksonville, 328 So.2d 854 (Fla. Ist DCA 1976); Q), oj'South Miand i,. Hillbaiter, 312 So.2d 241 (Fla. 3d DCA 1975); City of. 1flunii i,. Sehittle, 262 So.2d 14 (Fla. 3d DCA 1972); see Parkin- Facilities, Inc. 1,. City qfiVftand Beach, 88 So,2d 141 (Fla. I 956)(spot zoning); County ql'Brewird 1,. ffbot'llialn, 223 So.2d 344 (Fla, 4th DCA 1969)(same), cert. denied, 229 So.2d 872 (Fla. 1969); 7 Fla.Jur.2d Building, Zoning, & Land Controls § 110, at 512 (1978), The city contends, however, that its action is justified by (a) "substantial, competent evidence," Snyder, 627 So.2d at 475,4 before the Commission that commercial zoning of the petitioner's parcel would result in increased traffic and (b) a desire to encourage the building of "affordable housing" in the city -a result which would in effect be mandated by the MDR designation because it excludes commercial or office use. Neither position has a semblance of merit. [2] I. Trqflic Increase No Justification, Because it is virtually self-evident that, by its very nature, all commercial uses create "more traffic" than non-commercial ones, it is equally obvious that local government cannot *702 justify a denial of a particular commercial use on this ground. To bold otherwise would mean, as it apparently did in the proceedings before the Commission, that the protectable rights of any owner may be arbitrarily destroyed. This is not, and we will not let it be, the law. Tollius, 96 So,2d at 122 (change in neighborhood to commercial use requires restrictions to residential use to be relaxed). Indeed, the Commission's actions in this case involve almost every one of the several bases upon which courts both here and elsewhere have rejected the contention that a potential traffic increase may support the denial of otherwise required commercial zoning, 5 Rathkopf s The Law of Zoning & Planning § 59.03 (4tb ed. 1996), and cases collected at § 59,03[3] (denial of commercial use -unjustified by showing merely of a "generalized increase in traffic due to an increase in intensity of use"); § 59.03[4]("a desire to prevent an undesirable increase in traffic congestion is not sufficient justification for the retention of an unsuitable or unreasonable zoning classification"); § 59,03[5] ("[z]oning classifications and permit decisions based on a desire to avoid increased traffic congestion may be held invalid where such action involves unreasonable discrimination between neighboring tracts or similar uses"; citing Florida Mining & jlfalerials Coq). r. Port Orange, 518 So.2d 311 (Fla. 5th DCA 1987) (reversing denial of special permit to construct cement plant based on fact that cement trucks would pass through residential area, when trucks from other, similar businesses were pern-iitted to do so), review denied, 528 So.2d 1181 (F1a,1988)); § 59.03[6] ("[z]oning classification or restrictions based on traffic conditions may be held invalid ... where land is uniquely burdened to extract a public benefit as a substitute for proper traffic management and control"). As the petitioner correctly argues, the traffic problems which may or may not be presented by her proposed commercial development of the property are properly considered in the administrative process which the city has itself established. See 5 Rathkopf s The Law of Zoning & Planning § 59.03[l ], [3]. Generalized fears of an increase in traffic are wholly inappropriate, however., to deny any one landowner the rights to which he is entitled. [3] 2. Promotion of t4ffordable I-Jollsiiig No Justification The claim that the city's action may be justified as promoting the creation of adequate housing is, if anything, even more obviously deficient. While this aim may represent a desirable public policy -which might support, for example, the condemnation of property for that use, see State v, Miami Beach Redei,,elopinent Agen(l' y, 392 So.2d 875 (Fla.] 980)-it emphatically may not be promoted on the back of a private landowner by depriving him of the constitutionally protected use of his property. As the estimable Judge Cowart correctly and succinctly stated: A property owner is entitled to have his property properly zoned based on proper zoning concepts without regard to the one particular use which the owner might then intend to make of the various uses permitted under a proper zoning classification. A zoning authority's insistence on considering the owner's specific use of a parcel of land J Debes v. City of Key West, 690 So.2d 700 (1997) 22 Fla, L.'Weekly b827 constitutes not zoning but direct governmental control of the actual use of each parcel of land which is inconsistent with constitutionally guaranteed private property rights. p017)oi.Fe Point Partnership v. St. Johns CounlY, 470 So.2d 850, 851 (Fla. 5th DCA 1985); accord ABG Real Eslate Dei: Co. v. St, Johns Courify, 608 So.2d 59, 63 (Fla. 5th DCA 1992), cause dismissed; 613 So.2d 8 (Fla. 1993). In sum, the record reflects that the only reason for the denial of the proposed rezoning was that the opposition -of the city's existing merchants to the competition represented by the prospective commercial use of the property and of those who wanted more housing -had the votes. We reiterate, however, what was said in the reverse situation presented by a city's approval of an unjustified zoning change in Allopaliah Coinniunil),Ass'n r. 01 v q1'.)APami, 379 So.2d 387, 394 (Fla. 3d DCA 1990), cert. denied, 386 So.2d 635 (Fla. 1980): The [courts] ... will not and cannot approve a zoning regulation -or any governmental action adversely affecting the *703 rights of others-NArhicb is based on no more than the fact that those who support it have the power to work their will. Accord, e.g., T)wn of Ponce Inlet v. Rancourt, 627 So.2d 586, 588 n, I (Fla. 5th DCA 1993); 01Y ol'Apopka 1, Orange Counly, 299 So.2d 657 (Fla. 4th DCA 1974). For these reasons, we conclude that the circuit court decision so fundamentally and seriously departs from the controlling law that a miscarriage of justice has resulted and that review on certiorari is therefore both justified and required. Haines City Coninninio, Dev v. fleggg, 658 So.2d 523 (F1a,1995); Snyder, 627 So.2d at 469; Alletropolitan Dade County v. Blumenthal, 675 So.2d 598 (Fla. 3d DCA 1995), review dismissed, 680 So.2d 421 (F1a,1996); ABQ 608 So.2d at 59. Upon that review, the decision is quashed and the cause remanded with directions to require the City Commission to grant the application in question. Certiorari granted. All Citations 690 So.2d 700, 22 Fla. L. Weekly D827 Footnotes The two previous denials were both quashed on review by the circuit court. Our disposition of the present case makes it unnecessary directly to consider the petitioner's very substantial contention that at least the first of these rulings entitles her to relief under the doctrine of res judicata, 2 The application stemmed from the professionals' desire to correct what they characterized as their own "mistake" in their designating the parcel as MDR because, at that time, a plan had been submitted to build a residential development on the parcel. In the event, the proposal proved financially unworkable and failed entirely. 3 CG permits commercial, office and residential use. MDR permits residential use. 4 While we agree that Snyder provides the appropriate standard of review, see Snyder 627 So.2d at 469; City of Ft. Lauderdale v, Multidyne Medical Waste Management, h7c., 567 So.2d 955 (Fla. 4th DCA 1990), review denied, 581 So.2d 165 (Fla. 1991), the issue is not determinative or even important in our consideration of the case. As we suspect is very often the case, the application of any possible formulation of the showing necessary either to support or to overturn a local government's decision of the present kind, including the "fairly debatable" standard deemed appropriate in Martin County v. Yusem, 690 So.2d 1288 (Fla. Case No. 87,078, opinion filed, March 27, 1997)[22 FLW S 1561; e.g., Allapattah Community Assn v. City of Miami, 379 So.2d 387 (Fla. 3d DCA 1980), cert. denied, 386 So.2d 635 (Fla.1 980), would yield the same result, See Metropolitan Dade County v. Fuller, 515 So.2d 1312, 1314 n. 4 (Fla. 3d DCA 1987). Etid of Document Oc 2024 Thomson Reuters, No claim to original US. Government Works. Miami -Dade County v. Omnipoint Floldings, Inc., 811 So.2d 767 (2002) 27 Fla. L. Weekly D516 P0 KeyCite Red Flag - Severe Negative Treatment Decision Quashed by Miami -Dade County v. Onimpoint Holdings, Inc., Fla., September 25, 2003 811 So.2d 767 District Court of Appeal of Florida, Third District, MIAMI—DADE COUNTY, Petitioner, V. OMNIPOINT HOLDINGS, INC., Respondent. No. 3D0I-2347. I March 6, 2002. Synopsis County sought petition for writ of certiorari to quash decision of the Circuit Court, Dade County, Amy Steele Donner, Gisela Cardonne, Manuel A. Crespo, JJ., directing county's community zoning appeals board to grant applicant permission to erect telecommunications monopole. The District Court of Appeal, Fletcher, I, held that: (1) county code section setting forth criteria which must be met for approval of application of unusual uses was unconstitutional, and (2) petition for writ of certiorari was denied. Petition denied. West Headnotes (3) [1] Zoning and 0 Planning "y- Telecommunications towers and facilities Zonin,g, and Planning Variances and exceptions County zoning code section setting forth criteria for grant or denial of application of unusual uses, non-use variances, and modifications of conditions, including telecommunications monopole, was unconstitutional; section which contained list of uses which conditioned on approval after public hearing did not provide definite, objective criteria to guide county's zoning boards in making decisions to grant or deny applications, and thus, board could arbitrarily deny provision of wireless services. 2 Cases that cite this headnote t2l Zoning and Planning k Permits, Certificates, and Approvals Zoning and Planning (4,"= Variances and exceptions Ordinarily when zoning code standards for special exceptions, unusual uses, new vises, and conditional uses are declared invalid, the opportunity to obtain exception or other use is lost. [3] Zoning and Planning I,- Tel ecomirtuni cations uses Zoning and Planning Telecommunications towers and facilities County's petition for writ of certiorari to quash decision of trial court directing county's community zoning appeals board to grant applicant permission to erect telecommunications monopole was denied; board's denial of applicant's request for unusual use was in zoning district in which use was permitted after public hearing, and county's unconstitutional hearing criteria had effect of prohibiting provision of personal wire services in violation of the Telecommunications Act. Communications Act of 1934, § 332(c)(7)(13)(i) (11), as amended, 47 U.S.C.A. § 332(c)(7)(13)(i) (11). I Case that cites this headnote Attorneys and Law Firms *767 Robert A. Ginsburg, County Attorney, Jay W. Williams, Assistant County Attorney, for petitioner. Hayes & Martolvive and Deborah L. Martolvive (St.Petersburg), for respondent. Before JORGENSON, GODERICH, and FLETCH-ER, JJ. J\Wi Miami -Dade County v. Omnipoint Holdings, Inc., 811 So.2d 767 (2002) 27 Fla'. C'Weekly D516 Opinion FLETCHER, Judge. Miami —Dade County seeks a writ of certiorari quashing a circuit court decision which directs the County's Community Zoning Appeals Board 12 [Board] to grant the application of Omnipoint Holdings, Inc. [Omnipoint] for an unusual use, a non-use variance, and a modification of a condition attached to an earlier resolution. This grant would result in permission for Omnipoint to erect a telecommunications monopole with a height of 148 feet. The circuit court's decision ordering the Board to approve Omnipoint's application has two separate bases: (1) that the record before the Board reflects a lack of substantial competent evidence supporting the Board's denial of the application, and (2) that the Board's decision is in violation of *768 section 332(c)(7)(13)(i)(1) of the Federal Telecommunications Act, 47 U.S.C. § 332 (1996) [Fed, Act]. Our decision turns only on section 332(c)(7)(B)(i)(11) rather than (1). 1 11] The Fed. Act states in pertinent part: "(i) The regulation of the placement, construction, and modification of personal wireless service facilities by any state or local government or instrumentality thereof. (1) shall not unreasonably discriminate among providers of functionally equivalent services; and (11) shall not prohibit or have the effect of prohibiting the provision of personal wireless services." Our first concern is what we conclude to be the ability of the Board to deny arbitrarily the provision of wireless services, 2 which ability stems from the County's zoning code sections which contain the criteria for the grant or denial of unusual uses, non-use variances, and modifications of conditions. Our discussion starts with unusual uses, which are established by section 33-13(e), Miami —Dade County Code. This section contains a lengthy list of uses which are conditioned on approval after public hearing. Among those uses is the requested monopole. The code section which purports to create the criteria which must be met for approval of unusual uses is section 33-311(A)(3), which provides in pertinent part: "Special exceptions, unusual and new uses, [The county zoning boards have authority to] [h]ear application for and grant or deny special exceptions; that is, those exceptions permitted by the regulations only upon approval after public hearing, new uses and unusual uses which by the regulations are only permitted -upon approval after public hearing, provided the applied for exception or use, including exception for site or plot plan approval, in the opinion of the Community Zoning Appeals Board, would not have an unfavorable effect on the economy of Miami Dade County, Florida, would not generate or result in excessive noise or traffic, cause undue or excessive burden on public facilities, including water, sewer, solid waste disposal, recreation, transportation, streets, roads, highways or other such facilities which have been constructed or which are planned and budgeted for construction, are accessible by private or public roads, streets or highways, tend to create a fire or other equally or greater dangerous hazards, or provoke excessive overcrowding or concentration of people or population, when considering the necessity for and reasonableness of such applied for exception or use in relation to the present and future development of the area concerned and the compatibility of the applied for exception or use with such area and its development." This language is legally deficient because it lacks objective criteria for the County's zoning boards to use in their decision making process. As stated in Universitly Books & Videos, Inc, iz Miami —Dade Counrv, Fla., 13 )2 F.Supp.2d 1008, 1017 (S.D.Fla,2001), in relation to this exact code section: "First, the public hearing requirement grants too much discretion to the CZAB. The procedure for public hearings ... allows the CZAB to accept or reject an *769 application based on vague and subjective criteria._ The standards for granting or denying an application are not precise or objective. Indeed, they are almost entirely subjective. This is improper. See Lady J Lingerie, 176 F.3d I at 1362.-"' The court also noted that: "Considerations of the public interest or incompatibility with surrounding land area are precisely the subjective and vague criteria that were rejected in Lady J. Lingerie." The referenced Lady J, Lingerie court dealt with provisions of the Jacksonville Zoning Code, 4 which provisions are similar Miarni-Dade County v. Omnipoint Holdings, Inc., 811 So.2d 767 (2002) 27 Fla. L.'We6ldy D516 to those of section 33-311 (A)(3), Miami —Dade County Code. As to the similar Jacksonville code language the Lad), J. Lingerie court stated (at 1361): "None of the nine criteria is precise and objective. All of them —individually and collectively —empower the zoning board to covertly discriminate against adult entertainment establishments tinder the guise of general 'compatibility' or 'environmental' considerations." We recognize, of course, that Lad), J. Lingerie and UniversityBooks & Videos dealt with First Amendment issues surrounding adult bookstores and entertainment centers. The Lady J. Lingerie court,- concentrating on such rights, stated en possant that Jacksonville was free to use its vague zoning criteria for other types of applications. As the federal court did not have that issue before it, the comment was gratuitous. It is also out of sync with Florida law. Consistently Florida courts have declared unconstitutional ordinances that lack objective standards to guide zoning and other quasi-judicial boards in making their decisions.' See North Buy Village it Blackwell, 88 So.2d 524 (Fla. 1956); Drexel a Cilia qfjViand Beach, 64 So.2d 317 (Fla. 1953); City of Miami i,. Save Brickell At,enite, 426 So.2d 1100 (Fla. 3d DCA 1983); Pinellas County i,,. Jasmille Pla--a, Inc., 334 Sold 639 (Fla, 2d DCA 1976). Thus as section 33-311 (A)(3) of the county code does not provide definite, objective criteria to guide the County's zoning boards in making their decisions, it is unconstitutional,(' In relation to Omnipoint's request for modification of a condition contained in an earlier zoning resolution, it is section 33-311(A)(7), Miaini—Dade County Code that governs.? It reads: "[The county zoning boards have authority to] [h]car applications to modify or eliminate any condition or part thereof which has been imposed by any final decision adopted by resolution, and to modify or eliminate any provisions of restrictive covenants, or parts thereof, accepted at public hearing, except as otherwise provided in Section 33— *770 314(C)(3); provided, that the appropriate board finds after public bearing that the modification or elimination, in the opinion of the Community Zoning Appeals Board, would not generate excessive noise or traffic, tend to create a fire or other equally or greater dangerous hazard, or provoke excessive overcrowding of people, or would not tend to provoke a nuisance, or would not be incompatible with the area concerned, when considering the necessity and reasonableness of the modification or elimination in relation to the present and future development of the area concerned." As can readily be observed this section also lacks constitutionally required objective criteria and is therefore invalid.8 [21 [3] We are thus left with the question of what effect the invalidity of the criteria has on Omnipoint's application in light of the Fed. Act, which precludes local governments from prohibiting the provision of wireless services. Ordinarily when the code standards for special exceptions, unusual uses, new uses, and conditional uses are declared invalid, the opportunity to obtain the exception or other use is lost. See Citl,, of St. Petersburg v. Schiveitzei; 297 So.2d 74 (Fla, 2d DCA 1974), cert. denied, 308 So.2d 114 (F1a.1975). Here, however, unlike Schweitzer; we are dealing with the intent behind the Fed, Act, Keeping in mind that the Board denied Onimpoint an unusual use in a zoning district in which that use is permitted after public hearing the County's unconstitutional hearing criteria have the effect of prohibiting the provision of personal wire services in violation of the Federal Telecommunications Act, 47 U.S.C. § 332(c)(7)(B) (i)(11). As the circuit court reached the right result (although on a different basis) we deny the County's petition for writ of certiorari and leave intact the circuit court's remand to the Board for the purpose of the Board's granting approval of Omnipoint's application for the monopole, All Citations 811 So.2d 767, 27 Fla. L. Weekly D516 Footnotes I We do not reach the various questions as to substantial competent evidence. There is no doubt that wireless services —at least under present technology —require a series of poles of substantial height in order to function. ' . Miami -Dade County x0mnipoirdHoldings, hnc,O11Sn.2d7O7(20V2) �f��.T. 3 LadyJ, LucyJ,Liny*rioxCity o/Jacksonville, 176F,3d1358(11VxCic1099. 4 The Jacksonville code language may befound at pp. 1369-70.Lady 1Lingerie. � Sufficient guidelines are required aothat: 1.persons are able todetermine their rights and duties; 2. the decisions recognizing such rights will not be left to arbitrary administrative determination; 3. all applicants will betreated equally; and 4, meaningful judicial review is available. 6 Arguably Omnipoint did not preserve the constitutional question. However, sections 33-311 (A)(3)and 83-311(A)(7)are We proceed See Po0orkxDopo�non<ofHea0�Q h/ndumentaUyu��|randu�uot� therefore pm � 7 The earlier condition required development of OmnipnnCo property in accordance with a specific site plan, The modification would amend the site plan so asNallow the monopole, 8 AatoOmni[oint'arequest for anon-use variance, the language of section 33-311(A)(4)(b) ofthe code (governing non- use variances) is also unconstitutional. See the discussion thereof in the concurring opinion in Miami —Dade County u G/mxaq 802So.2d 1154(F|a. 5d DCA20O1). End of DoCurnOnt Ku2024ThommmReuters. Noclaim tooriginal U.S. Government Works. -----------------'-------- i |UC GmvmnmmniYVurks 4 VV�ST|�V ���02�Thur�yonR�u�/a No�*omioor�ma � Experience 29 Years Experience with Current Firm 5 Years Education B.S.C.E. University of Central Florida, 1995 M.S.C.E. University of Central Florida, 1997 Certifications Registered Professional Engineer, Florida PE #56849 02115/2001 — 0212812025 Advanced Maintenance of Traffic, AMOT #59060 Key Expertise Project Management Design, Traffic for PD&E Studies Transportation Analyses Developments of Regional Impact Transportation Corridor Studies Training Active Traffic Management & Managed Lanes Certification Course, 2010 PTV America — VISSIM & VISUM Training, 2009 ITS Evaluation Using CUBE CUBE Comprehensive Modeling Training, 2008 Advanced Transit and Freight Modeling Training, 2006 AYMAN H. AS-SAIDII, PE Mr, As-Saidi is a well -qualified Civil Engineer with a master's degree in Transportation Engineering from the University of Central Florida. He has over 29 years of experience in the field of traffic engineering, transportation planning and infrastructure in a career that has embraced studies on traffic impact forecasting and demand modeling, traffic and parking operations, rail and transit schemes plus Intelligent Transportation and Geographic Information Systems. Mr. As-Saidi has worked with major clients on high profile projects in the public and private sectors in Abu Dhabi, Qatar and Oman as well as having extensive experience in the United States on sophisticated urban development and transportation plans. Mr. As-Saidi is an acknowledged expert in managing transportation and infrastructure projects of all magnitudes and complexities for both public agencies and private sector clients and has presented papers at international venues in the areas of traffic safety and GIS. He is an efficient, organized team I eader and motivatorwith a successful record in the effective coordination of both external and internal teams in meeting engineering objectives and doing so within agreed budgetary and time constraints. He demonstrates significant skills in the identification and resolution of technical and management difficulties. Mr. As-Saidi has developed a particular expertise which harmonizes sophisticated technical knowledge in operating to the highest engineering standards with the ability to manage individual projects to commercially successful conclusions. Relevant Project Experience Orange County Transportation Planning Continuing Services 2021 — Present Orange County, Florida Engineer of Record / Project Manager As a prime consultant for a 3-year contract, TMGs role is to provide all aspects of transportation planning services for Orange County including, but not limited to, Comprehensive Plan and Development Review, Transportation Systems Management and Operations Studies (TSM&O)/Modeling, Mulfirnodal Planning, Public Involvement and Administration Services. City of Apopka Continuing Services 2020 — Present City of Apopka, Florida Engineer of Record I Project Manager As subconsultant to Newkirk Engineering Inc., responsible for the transportation and traffic design elements relating to this continuing set -vices contract (CSC). TIVIC's role is to provide all aspects of traffic engineering and planning, design, and safety projects for the City, and to perform QA/QG reviews for signalization design plans and traffic studies. Recent projects include signal warrant analysis for the Han -non Road extension, conducted in accordance with the requirements of City of Apopka, Orange County, and FDOT standards, utilizing the methods and requirements of the Manual on Uniform Traffic Control Devices (MUTCD). Preparation of the subsequent signalization design plans for the intersection of Harmon Road and Ocoee Apopka Road are in progress. City of Sanford Continuing Services City of Sanford, Florida Engineer of Record I Project Manager Managed the transportation and traffic engineering tasks under this CSC. Prepared analyses in accordance with City of Sanford, Seminole County and FDOT requirements. The scope of work included data collection, including held reviews and various traffic Counts, crash analysis, turn lane warrants, signal warrants, traffic projections, and safety studies. Recent projects include golf cart crossing wan -ant studies, conducted in accordance with the criteria of the FDOT Traffic Engineering Manual (TEM), which include existing conditions analyses, TEM criterion analysis, recommendations, and required signage. These analyses were prepared in support of the City's initiative for multi -modal transportation between neighborhoods and within Historic Downtown Sanford, AYMAN H. AS.-SAIDI, PE . . . . . . . . . . . . . . OCPS Continuing Services Orange County, Florida Engineer of Record / Project Manager As a subconsultant to Hanlex Civil LLC, co -managed team of engineers in the preparation of traffic, access, and pedestrian studies for various existing and new schools throughout Orange County. Evaluations involved considering the multi -modal transportation network, including roadway, bicycle routes, pedestrian routes, multi -use paths within the walk shed. Additionally, traffic operations at the connection points and at the vehicular and bus access points were considered. A qualitative review of pedestrian routes and facilities was completed to document_ observed or projected network continuity deficiencies, safety hazards to the pedestrian, and significant ADA compliance deficiencies. Recommendations ecommendations were developed for continuous pedestrian and bicycle connectivitywithin the walk shed, as well as improvements to address mobility deficiencies in the area- Internal circulation and access points were evaluated to ensure that adequate flow patterns were established, sufficient on -site queue storage was provided, and adequate operations were supported with appropriate traffic control, auxiliary lanes, and sufficient throughput capacity at the intersections. Vineland Avenue Widening Design Traffic for PDS orange County, Florida Engineer of Record / Project Manager As a subconsultant to Harris Ciivil Engineers, LLC, managed the transportation elements relating to the Preliminary Design Study (PDS) for Vineland Avenue, from SR 535 to International Drive, in Orange County. The scope of work included the development of future traffic projections, future traffic cha'racteristics, operational level of service analyses and the recommended roadway geometry to accommodate the design year conditions., The technical memorandum documenting design traffic for this project adhered to specifications and procedures outlined in the FDOT Project Traffic Forecasting Handbook. CR 455 Design Traffic for PUE Study Lake County, Florida Engineer of Record / Project Manager As a subconsultant to METRO Consulting Group, LLC, managed the transportation elements relating to the preliminary engineering and environmental analysis services forthe extension of CR 455 new alignment from Hartwood Marsh Road toWellnessWay in Lake County. The scope of work included preparing transportation dernand models for opening, interim and design years, determining growth rates, turning movement projections, daily and peak hour traffic projections, and future conditions analysis. The study tested multiple roadway alignments and the effect of each alignment on the surrounding roadway network. Mr- As-Saidi was responsible for the preparation of the Design Traffic Technical Memorandum (DTTM), and presenting all traffic related results to government agencies and in community meetings. Ministry of Transportation (Oman) Technical Support Services Sultanate of Oman Engineer of Record Project Manager Managed a 3-Year Continuing Service Contract with the Ministry to provide technical support for all transportation engineering projects. The scope included services Linder transportation planning, traffic engineering, highway design and supervision, traffic data collection, bicycle and pedestrian plans, traffic safety and preparation of tender packages for government projects, Traffic & Mobility Consultants LI-C w 3101 Maguire Boulevard, Suite 265, Orlando, Florida 32803 Phone: (407) 531-5332 x209 u Email: alla@trafficmol)ility.com EVENT ANALYSIS Search Crashes cERC 11 Crashes In Custom Rrca From 111/2018 - 3/14/2024 Charting r^ 0 Yes 0 No r C.J Atr Day or Night > or3 y Day Pr VcoLe V\< istaPkvq Night E Crash Severity vs Crash Type a f Angle ... -... Antra{.. Injury Summary, Common Attributes FOOT Attrbutes ttiCyCle Head On Total Fata' Crashes Serious Injury Crashes injury Crashes Property Damage Only Cras... tee Turn Crashes I 0 1 5 s 5 Or, Rvaa s Other x� Fatalities (within 30 Days) 0 0 0 0 0 v Padest an incapacitating injuries r u 1 v u Roar End Non -Incapacitating injuries 2 0 0 2 0 ., might Turn ' Rollover Possible Injuries 3 0 0 3 0 sidesvAPe NO Injtries 18 0 0:. 4. 14 linznaern Non-Tmffic Fatalities 0 0 0 '.... 0 0 Ilk +iizr tTt+'t' R Fatal tnr o"ilatino rrnn•InranarMia g P—hte Injury Un rnfirry Nnn-Traina Fatal Inury Injury Crash Severity AMARMIUMMM I RM OAR Crashes in Cu_,torn Area Frorn 1/1/2023 - 3/14/2024 Charting Angle Animal Bicycle Head On ray Left'rum OffRoad J­ Other pedeawan Rear End RI)bf Turn Rollover sidesvdpe Fare Sun Injury Summary.. Cominnn Attrihul,-MOT 4ttriNil-, PAan Total Fatal Crashes Serious In ury Crashes In ury Crashes Property Damacle Only Cr3s... Tue Crashes 1 0 0 0 1 Fablities ivvithin 30 Days) 0 0 0 0 0 Wed Incapacitating In.uries 0 0 0 0 0 Thu Non -incapacitating injuries 0 0 0 0 0 Possible Injuries 0 0 0 0 0 Fri No injuries 2 0 0 0 2 Sai Sanl2p. mcapacdafing, Non-Inc3pac4ating Possible Injury NO Injury Injury Irjury Crash Severity Crash Calendar t1on-Traffic, Fatal l2p-4pm 4pm-Orm .P"-12.m 12-4— torn..U. Tima,)f Day