BCC Minutes 01/16/2001 W (County Attorney's Office Informational Update)January 16, 2001
TRANSCRIPT OF THE WORKSHOP OF THE
BOARD OF COUNTY COMMISSIONERS
Naples, Florida, January 16, 2001
LET IT BE REMEMBERED, that the Board of County
as the Board of Zoning Appeals and as the governing board(s) of
such special districts as have been created according to law and
having conducted business herein, met on this date at 9:00 a.m. I
in SPECIAL SESSION in Building "F" of the Government Complex,
East Naples, Florida, with the following members present:
CHAIRMAN:
James D. Carter, Ph.D.
Jim Coletta
Donna Fiala
Tom Henning
Pamela Mac'Kie
ALSO PRESENT: Tom Olliff, County Manager
David Weigel, County Attorney
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COUNTY ATTORNEY'S OFFICE
INFORMATIONAL WORKSHOP
January 16, 2001
Sunshine Law
1
Public Records
2
Ethics
3
Ex Parte Communications
4
Tourist Development Tax
5
Emergency Management
6
Board Meetings / Reconsideration
7
January 16, 2001
CHAIRMAN CARTER: Call this workshop to order. It is one
that's going to be presented by the county attorney.
And Mr. Weigel, and Mr. Ramiro, it is all yours. Mr. Weigel is
not here, so Mr. Ramiro Manalich, it is all yours.
MR. MANALICH: Well, I can start with the third topic on the
CHAIRMAN CARTER: The third topic on the agenda. Okay.
MR. MOUNTFORD: You want me to take my aspect of the
first topic?
MR. MANALICH: Sure, if you're volunteering -- oh, here we
go. Here we go.
CHAIRMAN CARTER: Are you going to talk about the
Sunshine this morning, Mr. Weigel?
MR. WEIGEL: Among other things, thank you.
Good morning, Mr. Chairman, fellow commissioners. I want
to tell you that the county attorney office is very pleased to have
the opportunity to speak with you all today. And I also want to
thank Tom Olliff, our county manager, for assisting us to become
to the top of the order in regard to the workshops that we
presented to the commission as a whole over the weeks ahead.
And also want to mention that you have with you two books:
One is the county attorney office informational workshop book,
divided into seven topics.
Additionally, we provided a copy of the civil emergencies
workbook that we had provided the commission in August of this
past year, but not all the members have them at this time. So
we're working that into our workshop today. And Mr. Ken Pineau
of the emergency operations will loin us at that point a little later
on in the discussion.
I wanted to provide you all a donut to get your morning
started, but Ramiro told me that with our current gift and ethics
laws, I can't do that.
COMMISSIONER COLETTA: You can give us the hole in the
donut, though.
MR. WEIGEL: But at any rate, there's a lot of can-dos that
you'll be hearing about also.
Most of the topics that we're going to discuss today are kind
of a how-to type of instruction. Some of the advice will be how
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January 16, 2001
not to do something.
Now, the county attorney office doesn't like to be the how
not to and tell its client what it can't do, how it can't get there,
how it cannot achieve its very worthy goals. However,
specifically we have to inform you, as well as all who may watch
this program today or the video in the future, that the Florida
Government in the Sunshine Law, the Public Records Law,
Chapter 119, Florida Statutes, and the ex parte communications
requirements are not what the county attorney tells you because
we don't want you to accomplish your ends, your very worthy
goals. We do tell you these things, however, because we want
you to accomplish these goals, these ends, these projects, and
we want to make sure that you achieve these ends in a
defensible and worthy way.
It's precisely because we absolutely desire for your projects
to come to fruition that we take the opportunity whenever we
can to advise you as to the procedures that are not created by
you, but are imposed by the state on local government.
As you are aware, the county attorney has provided this
information various times in the past. I've had the privilege of
speaking with board members individually one-on-one from time
to time for five years now. But it's always an ongoing process.
There are small permutations and changes that occur in the law
from time to time, and we always want to make you aware of
those things, too.
However, this is the first time that this office has had the
opportunity to have a workshop before the Board of County
Commissioners. Thank you, Tom. And of course, it's the first
time that we've had the opportunity to address this board
collectively in this fashion. Thank you, board.
At the outset, I'd like to make two or three observations.
One, you the board at this workshop today will receive what we
consider workaday information and knowledge on the Sunshine
Law, the public records, requirements and ex parte
communications. And you'll see that the Florida legislature has
made the local government process a very open process. It
requires you as elected officers to act in a meeting process; that
is, essentially open to observation by the public in nearly all
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January 16, 2001
aspects. Parenthetically I state, this does not provide for
efficiency in a business sense.
Secondly, I mention that it makes local governments more
formal in their activities, with many requirements, before you can
get anything done. It's not that you don't have the tasks and the
goals and the plans and the vision, but there is a fame work
imposed by the state. And it's up to us as your advisor, friend,
colleague, to let you know, inform you, what those processes
are, so you can get there quicker and once you're there, defend
the process, make them stand the test of any challenge that may
come.
Secondly, I'm so pleased to say that this workshop plays to
several audiences, and not just you. The general public, the
newspaper, the electronic media, citizens groups, homeowners
associations, development and business interests all should
better understand that the rules for local government are largely
established by the Florida legislature, and you have to follow
those procedures.
They will know, or should come to better know, that when
they act with you in the formal meeting session or interact with
you individually, providing information, making requests, that at
the end of the day, as it's popular to say now, there are certain
requirements that come into play, and that you know those
requirements and you will see that you adhere to them and that
they do, too.
Thirdly, I just mention that the workshop is televised. And
these topics are going to be presented to all of the county
manager divisions and departments. Now, they may not need to
know all seven topics at once clearly, but the ones that affect
them, we're going to be out on the circuit to promote and inform,
and we also will be talking to all of the 40 plus citizens advisory
boards and committees. And we do this anyway.
I just reinforce this to you, that part of our plan for this year
is to more formally see to it that by the end of the year we will
have talked with them all and answered the questions that they
have in their own special experience. The productivity
committee may have a different experience than the hospital
healthcare committee. And the same goes with the groups that
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January 16, 2001
are involved with land use, land planning, they may have various
side issues that are based upon these solid topics. We're going
to make sure that they have not only the opportunity but in fact
the forced opportunity to spend some time with us in that regard.
The books that we have here are published well beyond to
pass out to you. And they're going to be available to all who
wish them, within some limits. And the fact is that we can also
break out individual parts of the booklet for individual groups.
The City of Naples, other municipalities, are invited to take
advantage of these things, or these materials. I've already
spoken with the City of Naples in that regard and look forward to
speak to the other municipalities. What we have is open,
sharable (sic) and we think absolutely correct.
As we go forward here, again, approaching the Sunshine
topic, the first one, the questions on the topic may be answered
at the end of the -- in the process of the presentation. And we
have in fact reserved time at the end of each presentation for
questions that you may create along the way. But besides that,
feel free to interrupt, to ask a question at any time. Because it
may be more cogent to ask the question in a particular part of
the presentation than wait until some later moment.
And now to talk about the Sunshine Law. In the book that
you have, first topic, Sunshine Law, you'll find an outline and
you'll -- that I prepared. And what it uses in large part is
information that comes from the Government in the Sunshine
Manual, which is published annually by the Attorney General
office. Very good book. Covers Sunshine Law and public
records. You all have these. And if you can't find them, please
get one, make it part of your library. I think you'll find it handy
reference. And the good part about the Sunshine Law is it's not
really that long. It's only about 25, 27 pages. The rest of it's
mainly public records, and that gets pretty lengthy.
Also included in the outline under Sunshine Law is a 1993
Attorney General synopsis of various important parts of the
Sunshine Law. And although it's dated, what's there is still
accurate. And we think that it's of some use and handy
reference.
My approach to Sunshine Law over the years has been one,
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let's get through the basics of the law, but two, how does it apply
to the everyday life of an individual commissioner, a collective
board or committee, and the delegation of functions that
sometimes occur to committee members.
First, what is the Sunshine Law? Well, it's -- Florida's
Government in Sunshine Law does provide a right of access to
governmental proceedings at both the state and local levels. It's
an offshoot of the 1972, '74 Watergate proceedings, no question
about it. The Florida Sunshine Law is one of the most
far-reaching Sunshine laws that any state has in the union. I
guess that's all of them.
What is it? It's three things: The meetings of public boards
or commissions must be open to the public; reasonable notice of
each meeting must be given; and minutes of the meeting must be
taken. It's as simple as that and as complex as the details
therein.
The Florida constitution has been amended to provide for
the Sunshine Law to be recognized in it also. Relatively recently.
The legislature, the state government has a strong affinity to the
Sunshine Law.
What's included -- what boards are included within the
Sunshine Law? Well, all committees, all boards, all groups of
elected or non-elected officials appointed by elected officials are
in fact subject to the Sunshine Law, which means they again
have to meet the three prerequisites: Their meetings must be
open to the public, reasonable notice must be given, and minutes
always must be taken.
Does the Sunshine Law apply to members of public boards
who also serve as administrative officers or employees? What
does that mean? It means that if you as a commissioner or
someone as a committee member, if they also serve as an
employee, or have an administrative office related to the work
that they're doing as an appointed or elected official, they may
have an issue with the Sunshine Law. And what the Attorney
General's opinions tell us is that you can occupy both places and
be on the committee, but in your normal workaday life, if you talk
with someone else in the business sector about matters that will
come before that board or committee, or have been acted upon
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January 16, 2001
within that board or committee within a recent time, that you're
subject to the Sunshine Law and/or you may have a conflict and
you've got to be very careful.
What is a meeting that's subject to the Sunshine Law? It's
any coming together of two or more persons. They can come
together physically in a meeting, they could come together at a
trolley, they could come together at a social gathering, at a
homeowners situation -- meeting, they could come together in a
social event or in a restaurant.
So what does that tell us? It tell us that it's very easy to
have a meeting. And if you have a meeting, you've got to have
three requirements: Notice, minutes and the fact that it's got to
be public, open to the public. That's why we strongly
recommend the commissioners be very careful when they find
themselves coming together outside of the board room. Yes?
COMMISSIONER FIALA: So then when somebody comes in
to lobby us, for instance, or explain an issue that they have
particular concern with, or if we attend a civic association
meeting where the people there give their opinions or feelings
about a certain subject, but obviously there's no minutes to that
or anything, is that why we have disclosure when we come up
here, addressing a certain subject?
MR. WEIGEL: Good question. And it's not absolutely related
to the Sunshine meeting per se, but it has -- but it is related to
Sunshine and the meeting requirements generally. And that is
two or more commissioners in this case find themselves together
at a meeting or homeowners association --
COMMISSIONER FIALA: Oh, I see --
MR. WEIGEL: -- then you have a Sunshine Law requirement,
potentially, if the commissioners interact in any way
informationally.
COMMISSIONER FIALA: But if you're just alone --
MR. WEIGEL: If you're alone and you receive information
and it happens to be in a land use type of topic, something that
will come up in the quasi judicial area, which is conditional use,
rezones, variances, things like that, neighborhood kind of things,
land things, then yes, you can be there as a single commissioner.
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No problem. But you need to take good note, be able to have
the recall so that on the record later on at that formal board
meeting when that issue comes up, you can say oh, yes, I met
with the XYZ homeowners' association and they provided me
letters. And even to some degree tell who talked to you. The
more you have to bring back makes it more defensible if the case
was ever challenged.
COMMISSIONER FIALA: Thank you.
MR. WEIGEL: But in a pure meeting context, what we are
talking about here is that it's very easy to find yourself in a
situation, a setting with other commissioners present, and if you
cross the line and it can be challenged as a Sunshine Law
meeting, that is, a meeting of commissioners, if you don't have
those prerequisites of notice, minutes, adequate public notice,
and in a forum where there's public access, you can run into
problems later on.
COMMISSIONER HENNING: Mr. Weigel?
MR. WEIGEL: Yes.
COMMISSIONER HENNING: An advisory board member
comes to a commission member to discuss a topic that they
approved or disapproved and that has come before the Board of
Commissioners, is there -- where does the Sunshine Law fit in in
that issue?
MR. WEIGEL: Okay, another good question. I'll probably say
that about every question, obviously. But the fact is, is that it's
only you coming into a meeting with your four colleagues here
that creates a Sunshine Law question for you. And if you meet
with individuals from other boards or committees, that's not a
problem as far as the Sunshine Law requirements go.
However, if you have two members of a committee coming
to meet you, you might, you know, say be careful, gentlemen,
have you met the Sunshine Law requirement? Because they may
be putting themselves into a position of risk as they come to
meet you.
But even if they should put themselves in a position of risk,
and that is -- we're not talking about homeowners' associations
or civic groups, but we're talking about committees created by
this board. If members -- multiple members of the same
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committee should meet with an individual commissioner,
ultimately they're the ones that put themselves at individual
personal risk or liability, and not you for having had the meeting.
You're just one person and you're not meeting with your
colleagues and so you're okay, as far as that goes.
But from time to time it does come up that other
committees, in their zeal and desire to accomplish something in
a timely way, may in fact themselves put themselves in a
potentially compromising Sunshine Law situation.
COMMISSIONER COLETTA: Mr. Weigel?
MR. WEIGEL: Yes.
COMMISSIONER COLETTA'- I've got a question. How about
where the commissioner, sitting commissioner, takes a part on a
committee? Now you really have a situation that mires down in
the mud as trying to -- explain to me how that would work. In
other words, if you were a member of this sitting commission and
you also were of the committee. I know in the past we have had
commissioners that headed up different committees.
MR. WEIGEL: Right. Well, the one thing of course we keep
in mind is that those committees themselves are also operating
under the Sunshine. Fully noticed, things of that -- public access,
minutes are taken. So there's no problem with that aspect right
there.
Now, if the commissioner who is a member of the committee
or subcommittee is coming back to the Board of County
Commissioners, has no delegated authority from the board other
than to attend there and participate in dialogue, things of that
nature, we probably will not have a problem.
But I will say that that gets us into the area that I spoke
about initially of administrative offices and things of that nature.
It gets us so close to that that any time that that comes up,
whether it's at a board meeting or separate from a board
meeting, I would ask that we fine tune that question and that
situation with the county attorney office. Because there is a
potential for a problem. It probably won't occur if we kind of tidy
all the things and make sure that the directire of that
commissioner from the -- from its board doesn't overstep the
boundaries. But that's one where we need to be very careful
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about.
And that's where I was saying at the very beginning that the
Sunshine Law makes it more complicated and more difficult to
achieve very important and realistic local government goals. But
because it's there, we want to see to it that it gets done properly
and defensibly.
COMMISSIONER COLETTA: Let me clarify that question just
one more time, and I won't delay you any longer.
If you belong to one of these committees, the individual
members of the committee can't come to the commission office
to talk to you, it would have to just be at the committee meeting
or at the -- at a commission meeting when that particular item
came up and they're making their presentations. You wouldn't
be able to meet with the committee members in your office,
that's correct, isn't it, if you're a member of that committee?
MR. WEIGEL: That's correct.
COMMISSIONER COLETTA: Okay, thank you. That's what I
wanted to know.
MR. WEIGEL: Okay, that's fine.
CHAIRMAN CARTER: Well, let me pursue that a little further.
What if you're the liaison to the board to the committee, and I'll
use the productivity committee, and I sit there and I'm not a
voting member of that committee, I am there to sometimes
answer questions, et cetera. Does that say that the chairman of
that committee or any member of that committee then in the
future could not come and meet with me one-on-one?
MR. WEIGEL: No, absolutely not. And that's a good
distinction. Particularly if you're not a full-blooded member of the
committee but there as a liaison or informational person to
report back to the board, I don't think that you run into that kind
of problem.
At the same time, the other committee members always
need to be careful that if they come and talk with a
commissioner, they should only do it singly. And again, I -- this is
the one area that I think we would approach and based on our
discussions with the Attorney General, that we have to look at
these very closely on a case-by-case basis so that if there's an
area of risk, we can tackle it ahead of time. But there is a slight
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distinction.
COMMISSIONER MAC'KIE: But productivity committee, for
example, I think I am a voting member. I think I'm a -- am I not?
I wouldn't think of meeting one-on-one with a -- MR. WEIGEL: Right.
COMMISSIONER MAC'KIE: -- committee member in
productivity.
MR. WEIGEL: That's right. And you should not, and you do
not.
COMMISSIONER MAC'KIE: Yeah. And frankly, I'm always
going to err on the side of not having one-on-ones with people on
which I sit on the same committees even, because I'm not ever
sure if I'm a liaison or a committee member or whatever I am.
It's just safer not to -- now, you can meet with people all day
long. If I'm on a productivity committee and they want to -- a
member of productivity committee. wants to come in and talk to
me about, you know, their weekend at the beach or something
that isn't ever on the agenda or conceivably to be on the agenda
of the productivity committee -- I'm trying to think of an example,
you know.
MR. WEIGEL: Well, those general examples you give are
absolutely appropriate.
COMMISSIONER MAC'KIE: Do that all day.
MR. WEIGEL: And you see, even two commissioners in this
1995 memo that I included in your backup materials here, I tried
to respond to some of the common kinds of what ifs that come
up,
And, in fact, yes, commissioners can find themselves at a
social event or at a civic event, or it could be the City of Naples
something or some other event of a more social nature. The fact
is, if they don't dialogue amongst themselves on something that
will come up later at a board meeting, they can chat and mingle
and even talk with each other. It's not as if you can't talk with
each other, you just can't do it about matters that will come
back before the board.
COMMISSIONER MAC'KIE: But Donna and I can go to lunch
and talk about our husbands, we just can't talk about anything
we might conceivably ever vote on.
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MR. WEIGEL: That's right. And as we --
COMMISSIONER MAC'KIE: Let's do that.
MR. WEIGEL: -- as we tell you from time to time, however,
you may be absolutely correct, but you may have to defend the
perception that's out there. So if you put yourself in a position of
some risk in that way -- and we may win in the end, and the
questions of proof I think are actually fairly difficult, but the fact
is, is it's not maybe the better thing to do with any kind of
repetition.
CHAIRMAN CARTER: But David, I think that goes to the
perception of the community. You know, if the community has
complete confidence in their elected officials, whether it's City
Council, Board of County Commissioners, school board, you
name it, I don't think that that perception thing will run rampant.
But when there's been difficulties, and when there is a
perception, there is conclusion, there is something going on, we
just have to judiciously avoid social interactions where if
Commissioner Coletta and I go to lunch together and we walked
out of a board meeting and went down and had lunch together,
right away there's a perception we're doing something that is not
really above line. Where we might be talking about baseball,
football or anything else. And we just have to be careful.
MR. WEIGEL'. That's exactly right. And another thing that --
kind of a ground rule, you might say, is it wouldn't be bad to have
a third person there for possible defensibility, when you put
yourself -- if you should find yourself in those kinds of situations.
But we don't recommend them. They're not absolutely per
se against the law, no question about that, but at the same time
there are issues of perception that do come up from time to time.
Let us talk briefly about telephone communications and
computer communications. Obviously commissioners and
committee members can't chat with each other on the telephone
about upcoming matters. That's absolutely inappropriate. You
cannot communicate by computer back and forth on upcoming
matters. That's wrong. We can't countenance that in any way
from a legal standpoint.
But from time to time a commissioner will send an
informational memo to the other commissioners, stating a point
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January 16, 2001
of view or something's that's coming up. That the Attorney
General has indicated is not wrong, per se, it just can't be taken
any steps further.
The memo should not be soliciting a response. The
receivers of that memo should not undertake to respond,
whether asked to respond or not. It is not a problem with the
Sunshine Law, but once there's any kind of response, that is, tit
for tat back and forth, then we have a Sunshine Law problem and
it would be per sea violation.
So it can be done, it is done, and it's not legally a problem.
And I think it can be certainly an important mechanism from time
to time to provide some focus.
The same thing happens at like a civic association where
there's maybe a topic of general community interest. A
commissioner there, knowing or not knowing -- hopefully you'll
know if other commissioners are there, kind have your antenna
up. But you can't use the committee or the event as a
subterfuge to communicate to other commissioners. Don't do
that. It's better to drink it all in.
You may have a platform that you've always maintained
which you restate there, but please don't get involved in the
individual issues and place yourself in a position of having to
defend that, although you were speaking to the group as a whole,
that you were actually communicating to another commissioner
of what you hope for them to know and to do.
COMMISSIONER FIALA: Back to memos should not be
soliciting a response.
MR. WEIGEL: Absolutely.
COMMISSIONER FIALA: Well, say for instance I wanted to
ask Commissioner Henning, I mean in the public, if there has
been an increase in odor from the landfill over the past week and
I put it in writing and I sent him a memo. I would naturally be
looking for a response. How would I do that?
COMMISSIONER COLETTA: No, you can't.
CHAIRMAN CARTER: You can direct --
MR. WEIGEL: Well, as I --
COMMISSIONER FIALA: You can't do that?
MR. WEIGEL: -- as I speak with some of the other
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committees throughout the county, I say -- that's a hypothetical
question, I understand, but beyond that, the fact is you shouldn't
do it, it's inappropriate to do it.
COMMISSIONER FIAI. A: Well, then how do you ask
somebody a question?
MR. WEIGEL: You'll have --
COMMISSIONER MAC'KIE: Ask Tom.
MR. WEIGEL: -- to ask someone else.
MR. OLLIFF: You can either ask me, or in the open forum of
the meeting you can certainly ask. Because then that becomes
a public question where the public's party to both the question
and the answer.
COMMISSIONER FIAI. A: But if you don't have a chance to
ask it in the public because the meeting is a week and a half
away, I can ask you and then you can ask Tom.
MR. OLLIFF.' And hope -- well, no, I can't ask Tom for you. I
can't play go-between for you. You can ask me and hopefully I
can get you the information that you're looking for.
COMMISSIONER FIALA: Oh, I see, okay.
It's pretty difficult then to seek any information, isn't it, if
you're gathering research or--
COMMISSIONER MAC'KIE: Just ask Tom.
CHAIRMAN CARTER: Just go to staff.
COMMISSIONER MAC'KIE: Go to staff.
CHAIRMAN CARTER: Go to them and they will get you the
information that you want.
COMMISSIONER FIALA: This is a good thing we're doing this
today. Luckily I haven't had to ask that question.
CHAIRMAN CARTER: But if you have 51 complaints on you
name the subject and you put out to the commissioners, for your
information, I have received 51 complaints on the da, da, da, da,
da, there's nothing wrong with that, it's informational. All you're
doing is alerting them to what has taken place on a singular
subject. You're not asking for a response, you're communicating
information.
COMMISSIONER COLETTA.' Now, let me carry that the next
step, too. I just recently -- give you an exact example.
I had a gentleman making a request on a zoning matter
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that's in District 3. I would like to be able to send it on to
Commissioner Henning. Can I do that as a forward thing, or
since it came to me, can I just forward it on to him for his
information, or am I violating the Sunshine by doing that?
MR. WEIGEL: That's another close one.
COMMISSIONER MAC'KIE: He's not --
CHAIRMAN CARTER: No, he's not --
COMMISSIONER MAC'KIE: -- Joe's not saying and tell me
what your response is, he's saying here's some information from
a constituent. If he said here's some information and copy me on
your response to the constituent, that would be communicating
between the two.
MR. WEIGEL: Well, it is. But what we have occurring here,
though, it would appear, particularly this is land use related.
COMMISSIONER COLETTA: Zoning.
MR. WEIGEL: Yeah, zoning.
For instance is that you are becoming part of the ex parte
communication process yourself. Now -- so the commissioner
who receives from you will have to say well, I received
something from you outside of the board meeting in regard to
such and such.
It's okay because he reports it, but he or she must put that
on record or they've got a problem. And it can flow back perhaps
in a less complimentary way. You must be very careful about
those things.
If someone is coming to you, again, it may be you say thank
you for sending this to me, and let them send to it the other
commissioners as far as --
COMMISSIONER COLETTA: It sounds like to them -- could I
send it to like a county manager and have him forward it on --
MR. WEIGEL: You absolutely can.
COMMISSIONER COLETTA: -- because I -- the person who
originally sent it would feel insulted if I called him back and said
would you please send to it somebody else.
MR. WEIGEL: And that's a very good --
COMMISSIONER COLETTA: Okay, I'm glad we thought that.
MR. WEIGEL: -- position. You can boot it out to anyone else,
but just your colleagues up there that it gets problematical with.
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January 16, 2001
COMMISSIONER FIALA: Okay. So then one step further
again with the memo soliciting a response. Does that only mean
between us as commissioners? Can I ask Jim Mudd or Norm
Feder?
MR. WEIGEL: No problem. We're talking no problem with
regard to that, Commissioner. You can ask questions of all staff.
It's just the decision-making process, the state says among you,
you are the decision-makers, has to be out in the open so that
you can't pass information back and forth among yourselves or
ask questions and receive information outside of the public
notice, public meeting forum.
But sure, you can ask Tom or our office or anyone for
information. And that's separate and apart from -- if we have
enough time at the very end of the meeting, we'll talk a little bit
more about the ability -- the very last topic under board
administration, the ability to work with staff and how broad that
is. It's actually quite broad. But there are a few little things to
take care of along that line.
You can ask questions of staff or of Tom or of us at any
time. Don't ask us, however, to carry your information to another
commissioner. We can't do that.
COMMISSIONER COLETTA: And on the other note, how do
we handle our constituents when they come in and they say well,
I know for a fact that -- I was just talking to Commissioner
Henning --
COMMISSIONER MAC'KIE: Say shhh.
COMMISSIONER COLETTA: -- that he is of this opinion or
that opinion. Do we cut them off at that point in time and just
tell them that they're violating the Sunshine Law-- MR. WEIGEL: Well, I think--
COMMISSIONER COLETTA: -- if they go any further?
MR. WEIGEL: See, they're not -- you're not violating it by
hearing it, but I think it's appropriate to say I'd rather --
something to cut them off would be good, just because that's the
better practice.
COMMISSIONER COLETTA: Okay.
MR. WEIGEL: I wouldn't encourage them to continue their
discussion and go into great detail. Say okay, that's fine, we'll
Page 16
January 16, 2001
learn from them at the meeting.
But by virtue of the fact that you're not soliciting from that
intermediary what the other commissioners are thinking is good
on your part. But anyone, whether it's the staff or whether it's
the private individuals that have issues and questions to press
before you, should not themselves be communicating what other
commissioners' thoughts are.
And some commissioners tend to keep their thoughts a little
more to themselves and just receive information and not allow
themselves to be potentially utilized that way, which is
something to consider.
COMMISSIONER COI. ETTA: Another question, too, if I may.
MR. WEIGEL: Sure.
COMMISSIONER COLETTA: Just until we get to the point
where we truly feel comfortable with this, is there a possibility
that maybe memorandums to the other commissioners might be
directed through your office and then you in turn can send them
back out? This would prevent anything where maybe there might
be the suggestion that we're looking for a reply or something?
Would that be a safe way of doing it?
MR. WEIGEL: You can always do that. We'd be happy to --
from any individual commissioner--
COMMISSIONER COLETTA: That's the way I'll do it.
MR. WEIGEL: We'll obviously respond instantly, or nearly so,
and provide you what you need to know.
COMMISSIONER HENNING: Mr. Weigel, could you give us
examples of an informational memo that is appropriate and one
that is not appropriate?
MR. WEIGEL: Okay, well, be aware of the informational
memo that has a question mark or kind of has an upward lilt as
you read it at the end kind of soliciting a response. But if you -- a
commissioner may write and say I have a concern about the
enormous amount of stormwater that's accumulating in North
Naples. Just a hypothetical.
That can be communicated to other commissioners. And it's
just a statement. It's not saying give me solutions or let's start
talking or let's meet for lunch, none of that. But that's the kind
of thing that's okay, if you have a concern or there's a topic on
Page 17
January 16, 200t
the horizon coming up, something like that. But that's really all
the kind of attention that you should give it, if you choose to
create that kind of memo at all.
I'm almost at the end -- clearly at the end of my time and
probably the end of my rope here, but I do want you to know that
fortunately, or unfortunately, as the case may be, in fact the
violation of the Sunshine Law, if one should occur -- and this
county has a very good record in them not occurring. But if it
should occur, it's a second degree misdemeanor and it is subject
to up to $500 and potentially a little bit of jail time.
Now, no one expects that to happen, but at the same time, if
it's egregious, you never know what the court may do. And our --
our philosophy and our experience with the courts are it would
appear that the courts look at these things rather rigorously.
If there is a question or an issue that comes up where
ostensively there might be a meeting that you're not sure about,
please ask the county attorney office. And to the extent that
minutes or things can be created to take care to some degree of
the recordkeeping and other requirements, we will assist to
make sure that as much is done as possible after the fact. But
we hope never to have after-the-fact situations, if at all possible.
I did want to mention about telephone communications.
When a commissioner is ill, out of pocket, is unable to attend a
meeting, if there is a core, that is a quorum, that is physically
present at the board meeting, then and only then could a
commissioner who can't be, physically be at the meeting,
participate by telephone or video and telephone.
We've done this a couple times in the past, and it's worked
pretty well. The telephone hookup is such where the
commissioner who's away can hear everything that goes on at
the meeting room and that the public can hear that
commissioner at any time that absent commissioner wishes to
speak.
With that, I'm going to turn this over -- if there are -- certainly
if there are other questions, we can take them at any time during
the course of the day on any subject at any time, but I'm going to
turn this over to Assistant County Attorney Bill Mountford, who's
going to talk briefly about the closed session, the executive
Page 18
January 16, 2001
session, which I'm so happy--
MR. OLLIFF: David, just --
MR. WEIGEL: -- that this board has embraced.
MR. OLLIFF: -- before you change topics, could you just give
them a brief on E-mail as well? Because there is a tremendous
amount of correspondence that goes back between the board
and the staff within regards to E-mail. MR. WEIGEL: Thanks, Tom.
E-mail is a public record. That which you receive in the
course of business is of public record, that which you create in
the course of your business, commissioners, is of public record.
To E-mail back and forth amongst you is no different than a
typewritten or a handwritten memo or note. It should be treated
the same way. And of course because these are public records,
and Mr. Pettit will be talking about that briefly, right after Bill
Mountford, they have to be given special consideration also. And
we've got a few ideas on that we think would be quite helpful.
COMMISSIONER COLETTA: You might mention also that if
you receive E-mail that even generally refers to the county in any
way or business for the county at home, it should be forwarded
back into the office to be archived.
MR. WEIGEL: If you receive it at home? Yes, that's correct.
And obviously there are different electric or mechanical ways to
do that. One is to -- maybe you can print it at home and make
sure it becomes part of the record. Archiving is what's
important. I think that's very good.
COMMISSIONER MAC'KIE: And at some point later today
we're going to talk about E-mail specifically? Because that's one
where I think we could do a better job of making the records
available to the public --
MR. WEIGEL: That's exactly right.
COMMISSIONER MAC'KIE: -- than we are doing.
MR. WEIGEL: I know Mike has a lot to tell you about that.
Thank you very much.
MR. MOUNTFORD: Commissioners, Bill Mountford.
In certain cases the necessity of meeting in closed session
to discuss settlement negotiations and/or litigation strategy
cannot be over emphasized. To the credit of this board in the
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January 16, 2001
past, they have done that. Most recently they did it just before
the board was presently constituted in the beach renourishment
litigation. And of course to the attorneys involved, that was a
very great help.
Closed sessions are not needed all the time. They're only
needed in situations where there may be significant questions as
to liability or significant damage questions, and the board's
guidance is needed by the attorney handling that matter.
As you're well aware, nobody wants to start a lawsuit. It's
costly, it takes time, and it only happens when all else has failed.
But over the years, certain time-tested factors have in my
opinion come down, which is determinative of where we're going
in a lawsuit.
And the first thing we have to know is what reasonable
result we want to achieve. The second thing that's important is
a good strategy to get that result. And third, which isn't
mentioned a lot of places, is the cost effectiveness of your
desired goal. And of course lastly, not letting your opponent
know where you want to go. And that should be self evident.
Based upon my years of experience, every case I've ever
been involved in has a hook. And a hook is usually a result of
pretrial preparation, and it surfaces somewhere. And that hook
will have a significant effect on the outcome of the litigation.
Usually it has to do with a liability issue or a damage issue,
sometimes a combination of both. That hook is of no value to
the attorney if the other side knows about it.
I think the easiest example I'm aware of is in Florida. Most
cases go to non-binding arbitration. I do not know any
competent attorney that will go to a non-binding arbitration on
behalf of its client and let it all hang out. Because if the other
side is half competent, you know by the time you go to trial,
they're going to have an answer for that, letting it all hang out,
and you're going to be behind the eight ball. And that happens
time after time. So that's why the importance of the closed
session cannot be over emphasized.
Now, it's also to me significant, and I hope to the board, that
there's no sense in spending $10,000 to resolve a case that could
have been settled for 500, unless there is a purely legal principle
Page 20
January 16, 2001
that we're trying to put forth. But other than that, we very rarely
cure legal principles in litigation I do, personal injury, that type of
stuff. There's usually two versions, two sides to each issue, and
there are merits and demerits to both sides.
The procedure is basically very simple. The -- at a public
meeting the board attorney has to request that he wants to
discuss litigation or trial strategy with the board at a closed
session. Public notice is given. At that time the Chair announces
at an open public meeting that they're going to go into closed
session. The closed session of course is recorded by a court
reporter. At the conclusion of the closed session the Chair
comes back out and announces that the session was terminated
and goes back on the record. And at the end of the litigation, the
transcript of what occurred in closed session is made available
to the public.
If you have any questions, I'll try to answer them.
CHAIRMAN CARTER: I think the key thing is in closed
session we do not make a decision, we discuss strategies. And
you said that. And that's what we do, strategies.
MR. MOUNTFORD: The statute's very specific.
CHAIRMAN CARTER: Right. And when we come back, we
will give direction to legal staff to take us forward, but we're not
going to tell the world what we're doing. At the end, as you said,
when it's resolved everybody knows what went on. MR. MOUNTFORD: Correct.
CHAIRMAN CARTER: And I think that's important for the
public to know that when you said cost effectiveness, we are
saving tax dollars, when we are sued as a county, by not letting
it all hang out. Because if you do that, watch the numbers go up.
So it's to me I think a pretty logical, simple process that what
we're doing is preserving our rights, the rights of the citizens of
the county that we represent, and that's why we go to closed
session judiciously on certain cases.
MR. MOUNTFORD: I couldn't have said it better.
CHAIRMAN CARTER: Well, it's just a layman trying to work
through the legalese.
MR. MOUNTFORD: I like -- lay people make more sense to
me than a lot of lawyers, but -- I've been a lawyer a long time.
Page 21
January 16, 2001
CHAIRMAN CARTER: I won't go there.
MR. PETTIT.' Good morning, commissioners. My name is
Mike Pettit. I've been in the county attorney's office about six
years. I had a brief departure to private practice and came back
during that time.
My primary areas of responsibility are representing the
county in all matters of litigation and also providing advice and
counsel for the human resources department and risk
management department.
I'm going to speak briefly about public records. Before I do
that, I just want to mention something that came up in David's
topic. The situation where your constituent comes in and says
well, I've talked to commissioner so and so and I've talked to Mr.
so and so and they're going to vote this way.
And I was lucky enough in a litigation we had last year with
the county to have several commissioners be able to say under
oath that as soon as that statement from the constituent came
forward, they were able to say I'm sorry, but I can't listen to that
statement. I'm not trying to be impolite, but I can't know what
commissioner so and so -- and I can't take that into account
anything I decide. And I thought that was powerful evidence for
the county in that litigation. So I just leave you with that
thought.
The materials you've got, briefly, I have a brief outline I
prepared. There's a more in-depth outline of the public records
law that was done. It's behind tab two, all these materials are,
by Patricia Gleason from the Attorney General's office. She's
something of a guru to I think all we state and local government
lawyers on Sunshine and public records issues. She's always
available to talk to on the phone and she lectures at seminars
around the state on this subject.
In addition, I provided you, and this may be overkill, a copy
of Chapter 119, which is the Public Records Act, but it's there so
you can flip to it quickly, if you wish.
And also a copy of our Resolution 98-498, which is a
resolution we passed to have a uniform county policy on charges
that we can lawfully assess when somebody makes an expansive
public records request that requires extensive use of either
Page 22
January 16, 2001
technology or supervisory clerical resources.
Also, Mr. Weigel mentioned, and I'll mention again, the
Government in the Sunshine Manual. It's easy to read, it's not
overly legalistic, and what I like about it is it does give you all
the practical situations and circumstances that have come up
that you may run into that at least have been reported either by
the Attorney General's office or the courts of the state.
When we talk about public records law, the first place I
think you need to start is the policy of the state strongly favors
open access to public records. And that policy is so strong, it's
imbedded in our state constitution, in Article 1, Section 24. The
legislature passed Chapter 119, which contains all of the laws
governing the day-to-day issues that arise with public records.
And the Florida courts have liberally construed the constitutional
provision and the Public Records Act in favor of open access to
public records.
And so I think every time you're confronted with a public
records question, and this would go for staff as well, you have to
put that question in the context of that policy. Because chances
are it's going to be a public record, chances are there's no
exemption that restricts it from public access.
And just obviously each situation has to be reviewed on its
own merits, but there's a strong policy in favor of open
disclosure. And like I said, the constitution, our Seminole legal
document for the structure of government and law in Florida, the
legislature and the courts are all in agreement here.
What is a public record? Seems like it would be simple
enough, but sometimes it isn't. The Florida Supreme Court has
said -- I'm going to have to read this. A public record
encompasses all materials, made or received by an agency in
connection with official business which are used' to perpetuate,
communicate or formalize knowledge, regardless of whether
such materials are in final form.
And in the short outline I included, as well as in Ms.
Gleason's materials from the Attorney General, you'll see all
kinds of examples of public records. But let me focus on a
couple that I think are important to kind of get in all of our minds
how broad this definition can be.
Page 23
January 16, 2001
Copies of letters or other documents received by citizens
which are in turn given to the mayor of a city in his official
capacity have been held to be public records. And Commissioner
Fiala mentioned attending a civic association meeting. She goes
to the meeting and other people at the meeting, not in the
employment of Collier County, citizens who are there because
they've got a concern about an issue, have obtained documents
from some third party not in the employment of Collier County,
and they present those documents to Commissioner Fiala, and
she's there to transact official business because she's there as a
representative of that district and that constituency. She brings
those documents to her office. They're public records. That's
how far removed it can be and still be a public record.
CHAIRMAN CARTER: Can I ask you a question --
MR. PETTIT: Sure.
CHAIRMAN CARTER: -- though? When that take place -- I
want to know if I'm right. When someone hands me a document,
I always advise them, you give me that document, it is now
public record.
MR. PETTIT.' There's an argument that in certain limited
circumstances it might not be. But I think the only qualification I
would make, it is highly likely or almost certainly to be a public
record. If it's obviously -- if it's in the context of you out there
acting as a commissioner.
CHAIRMAN CARTER: Right. In my role, they hand me
something in regards to--
MR. PETTIT: It almost certainly is going to be a public
record. Now, it may be subject to some exemptions which we
can talk about as we move through my discussion here, but it
almost certainly is going to be a public record.
CHAIRMAN CARTER: I always felt that they should
understand that if you give us information, then therefore it does
become a part of the portfolio of the subject being discussed.
Consequently, if they don't want it in that portfolio or they don't
want to be involved in it, they now have an option to make a
choice to either just come and speak to the issue or they have
options. Because I don't think the public in general understands
this whole openness and Sunshine. And this is why it's good if
Page 24
January 16, 2001
anybody's watches today really tracks that this is what we're
doing there and why we have to do what we do.
MR. PETTIT: And that's of course why people will come in
and say I've talked to Commissioner Coletta and he's going to
vote this way. And they tell you that. And they're not intending
to do something improper most -- 99 percent of the time. They
just don't understand the restrictions that we operate under.
COMMISSIONER FIALA: It's hard for us to understand.
COMMISSIONER COLETTA: Could --
COMMISSIONER FIALA: Another-- I'm sorry.
COMMISSIONER COLETTA: Go ahead, ladies first.
COMMISSIONER FIALA: At home I have a big file of
committees that I've worked on over the years. Say for instance
something about landscaping a median comes up and I want to
go back into my records. If I brought those records into my office
from my home, they then become public record? Being that
they're -- they're my own, but I'm bringing them into my office
now,
MR. PETTIT.' I believe if the records are being brought in to
perpetuate knowledge in the transaction of official business, the
answer is yes. I don't mean to answer that legalistically, but I
want to point out a couple things. Why are you bringing the
records in? Because in a moment I'm going to talk about
commissioner calendars and what's on those calendars, and
we'll talk a little bit about sometimes some things aren't public
records.
But in your circumstance, if you brought that in and you're
going to use that information to vote or deal with your
constituents in the transaction of official business, I believe that
would be a public record.
CHAIRMAN CARTER: On the other hand, if she made notes
from her files and just brought the notes in, the notes would only
be--
COMMISSIONER COLETTA: But the files, no matter where
they are, have now been accessed, so they're part of public
records.
MR. PETTIT-' Well, let me address this. There's two
questions.
Page 25
January 16, 2001
Did you have a question first, Commissioner Coletta?
COMMISSIONER COLETTA.' Yes. Well, it's concern over the
fact that public records really aren't public because there's a fee
attached to them. And in some cases I think the fee is
unreasonable.
I had an experience back about four years ago when I was
trying to get a little bit of background on what was actually
happening in the county commission, where I was billed 60 some
dollars. And I thought it was very unfair at that time. And I
always said some day I'd have an opportunity to address it, and I
think this is the time to do it. I've instructed my secretary also,
because of this one instance, that if anyone comes in looking for
public records that relates to me, I'll pay the first $10 of the fee.
But I want the fee to be much more realistic than it is. I
want access to be much more open. If we're going to be a
Sunshine -- if it's a Sunshine in the Sunshine, it should be truly in
the Sunshine. If E-mail is available, it should be available on the
web to anyone out there.
There is no public record that should be difficult to access
or hard to find. If it is, if they ask for something that's totally
unreasonable, they're looking for hundreds and hundreds and
hundreds of records, I see assessing a reasonable fee for it. But
I think we have to be more realistic, because all we're doing is
we're acting as a barrier. We're saying that the people that have
the wealth can go ahead and get the public records, and those of
lesser means don't have access.
And this is really a problem for me, and I'm glad I had the
opportunity to bring it up in this meeting.
CHAIRMAN CARTER: Well, Commissioner, he can respond to
it, but I respectfully agree to disagree. You go to the library and
you want something, they charge you to make a copy of it. If you
open it up that anybody can get anything for free, how much of
the public taxpayers dollars are we going to spend for somebody
that wants to come down and look at you name the issue?
I think a reasonable fee I don't have a problem with. I think
people should be willing to accept that as a part of the process.
If there's something -- and there may be exclusions to this, I
don't know. But I've never been one to open the door and say
Page 26
January 16, 2001
here, just come in and we'll take our staff time and we'll spend
hours and hours --
COMMISSIONER COLETTA: I didn't say that.
CHAIRMAN CARTER: -- and do all this stuff. And what
happens, we've had cases where people say I want all this stuff,
and we'll make boxes of copies of stuff.
COMMISSIONER COLETTA: And I agree with you, they
should be charged --
CHAIRMAN CARTER: And in two minutes they'll say well,
I've seen enough and they're gone. And we have probably spent,
oh, a couple thousand dollars at least --
COMMISSIONER COLETTA: Commissioner Carter, that's not
what I was saying. When I originally asked for records, they
were a limited number. And I thought the fee was very unjust. I
can understand charging someone that wants to do massive
research for their -- the time for staff. But anything that's
reasonable, when someone is asking for four or five copies of
something, at that point in time we should make it available in
such a way that it's not going to be a financial burden for those
people to assess public records.
COMMISSIONER MAC'KIE: Don't you think our staff kind of
uses their discretion from time to time on that? I would hope
they do.
Do they, Tom? I mean, they have authority to -- if somebody
wants two pages, they can just copy it and give it to them, can't
they?
MR. OLLIFF: We do. There is a policy that says that the
county may charge up to and I believe it's five cents a copy, plus
whatever is reasonable staff time.
And I think -- hopefully the staff is using some discretion in
that regard so that people who are abusing are -- because that
does happen -- are, when people are coming and looking for an
excessive amount of information, that we do have the ability,
under policy, to charge. But hopefully they're not doing that for
the person who's coming in looking for a four or five-page copy
document of something.
And if you do hear about that, I'd love to know about it.
COMMISSIONER COLETTA: I certainly will pass it on to you
Page 27
January t6, 2001
at that time, if it ever does come up.
MR. PETTIT: This is a subject we may --
CHAIRMAN CARTER: I just don't like to open a box and let
people say hey, I can get 100 copies. I'm not going to go there.
MR. PETTIT: We may want to revisit this subject. And
Commissioner Coletta, in particular, review Resolution 98-498 in
this package, which really sets out our charges. It's 15 cents
and it says shall charge. The resolution then says we may
charge for other kinds of charges. And it's something you may
want to review, and we can talk more about it.
Documents that are circulated for review, even if you think
they're not a final document, become public records. In other
words, it's the for-your-information or
this-is-a-draft-what-do-you-think type document. Once those are
circulated among county staff or from board to staff or from staff
to board, those become public records.
Handwritten notes or public records, if you use them to
perpetuate or formalize your knowledge -- we go back to
Commissioner Fiala at the meeting, and she takes detailed
notes, because she wants to remember what was discussed, and
she comes back and she has a file that relates to that subject
matter, she puts them in the file. She's perpetuated that
knowledge. That's a public record.
Now, there may be a situations where handwritten notes
aren't public records. For example, same meeting Commissioner
Fiala goes, listens, takes no notes, comes back and thinks I need
to get something to Ed Kant, the transportation director -- who
was here, I think he left -- about this. You jot down a few notes
to collect your thoughts and kind of remember what you heard.
Then you generate a typed memo to Mr. Kant. I think the
underlying notes probably aren't public record. The memo is.
Because it was anticipating there was a precursor document.
And you didn't circulate them to anybody. You didn't intend to
keep them necessarily and you didn't give them to David Weigel
or Tom Olliff or whoever to look at.
I think the best caution we can give, if you've got a question
on whether something is or is not a public record, consult our
office, consult the materials we've given you.
Page 28
January 16, 200t
Let me talk about the not official business situation, and I'll
get Commissioner Mac'Kie with this. In another piece of
litigation, we had to produce all the calendars of all the
commissioners for a set period of time. And on her calendar
every week she picked her kids up at soccer practice. That's not
official business if -- I think we went ahead and produced that
anyway and didn't redact it. But we would have the right,
because it's not official business, to delete that. That means we
still have to produce the calendar page, but that's deleted, and
all we have to be able to do is to defend why we deleted it.
But remember, those calendars, if you intersperse your
personal and official business, there may be places where it gets
murky and it could become a public record. Typically, though, if
it's clearly not official business, it wouldn't be.
COMMISSIONER MAC'KIE: Like don't put on there therapy
session. Probably not going to --
CHAIRMAN CARTER: Well, we all need that, right?
MR. PETTIT: That might be exempt.
COMMISSIONER MAC'KIE.' Might not. Might be official.
MR. PETTIT: Exemptions are something different from
public records in the sense that you've already done the public
record analysis, it is a public record, but the legislature or the
constitution has decided no, this doesn't have to be produced.
And they come in several types, and they can be tricky. There
are temporary exemptions and permanent exemptions. Let's talk
about a temporary one that Mr. Mountford mentioned.
When that court reporter takes down the notes of your
executive session on the litigation, that's exempt at that point.
That can't be given. The press can't come in and get it, the other
side can't come in and get it. As soon as you win the lawsuit,
lose the lawsuit, settle the lawsuit and the lawsuit goes away,
however, then that's open for anybody. So it's only temporary.
A permanent exemption would be -- an easy example is the
Social Security numbers of current and former county
employees. And we typically get requests for personnel records.
The disciplinary record, good and bad, is all going to be a public
record. But we go through and we delete Social Security
numbers. And I think there are some exceptions for pension
Page 29
January t6, 2001
information and health information. And those may appear in a
personnel file, and we're allowed to exempt the personnel file on
those matters.
Code enforcement officers, at least current ones, and it
occurred to me that maybe former ones this doesn't apply, but
certainly current ones we cannot disclose telephone numbers,
addresses, for obvious reasons. And we have similar things in
the law for police officers and states attorneys and those kinds
of folks.
But I think the most important one -- and I don't want to run
out of time before I get to this -- is the exemption for
attorney/client product, work product. And the definitions in
here, it's records prepared by an attorney or at the express
direction of the attorney, for the county containing legal
conclusions, theories, strategies or thoughts about pending or
imminent civil, criminal or administrative litigation affecting the
county or in which the county is involved.
It's a difficult definition. And it's tough because it's not like
in private practice where if Commissioner Carter's my client and
he comes in and he asks me to write a memo to interpret a
statute to help him do his business and I do that, that's -- nobody
can get that, absent some very unusual circumstance.
Here, if Commissioner Carter sends a memo to David Weigel
and says I need to understand Statute such and such, would you
please write a memo and tell me how it applies. Now stop and
think about it. No attorney asked to you write that request,
you're not -- you were not the attorney representing the county at
the time, and the request doesn't relate to civil litigation or any
kind of litigation. Your request and Mr. Weigel's response in my
opinion are public record. It's not protected in the same way
that it would be in a private setting.
So you have to have those special magic aspects to it to be
protected. There has to be litigation or imminent litigation.
There has to be a decision by an attorney to write something, or
the attorney asks somebody to write something. And that
happens. Sometimes I'll ask somebody on Tom's staff, in the
course of litigation, would you prepare a chart for me, would you
prepare a list for me. Those things are protected.
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January 16, 2001
The restrictions we may place on public records, and this
speaks to some of the issues raised by Commissioner Coletta,
are narrow. We can't set an arbitrary requirement that the
request has to be in writing. We can't set an arbitrary time limit
in which we will produce the document. We can't say gee, that
request is kind of vague, we don't understand it, you need to
make it more particular.
The Florida Supreme Court has said that the amount of time
to respond is the reasonable time in which we would have to
retrieve the record and delete any exemptions.
And I think what's important here, the Florida Supreme
Court used the word reasonable. That's a quote. Reason and
dialogue with the person making the request. And over the years
through trial and error, sometimes error, unfortunately, what I've
learned is people make public records requests. And if you go
right back to them and if they seem just ridiculous or overbroad
or too much, you sit down and you talk with them about it and
then you put it in writing and say this is what I understand your
request to be, and then you get busy and you answer it.
And most people -- the press has been reasonable in that
regard. Most people, even when they're feeling hostile to the
county, will be reasonable about the amount of time at issue.
You can explain these boxes are in off-site storage, we're going
to have to have somebody look through the box. Most people are
pretty reasonable. And so I think dialogue is important with the
person making the request. And it eases our administrative
issues.
Some of the ideas we have to facilitate access I think again,
going to Commissioner Coletta's point, and maybe Commissioner
Mac'Kie was touching on this as well, as I understand it at least
one board here in Southwest Florida now has a standalone
computer which allows people to access calendars and e-mails
of commissioners. So they can come in, they don't have to
borrow -- bother Ms. Filson and her staff. And we usually try to
work with her staff when she gets these big requests, either
through us or to her. We have paralegals that are trained and
public records, a lot of work with her staff. But it might be
something to consider. And I think Mr. Weigel has a little more
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January 16, 2001
information on that than me. So there are ways to ease the
burden and also address the concern and let's let the public see
what we have.
Finally, very quickly, we have civil and criminal penalties on
public records. The civil penalties really come when somebody
files a lawsuit and says you didn't give me the public records or
you didn't let me copy the public records. And if we lose the
lawsuit, even if we acted in good faith -- good faith to me would
be two things: One is we think we have an exemption and we're
wrong, or two is it sits on somebody's desk because they're real
busy trying to get a road built or they're real busy with some
other project and it just doesn't get answered in a timely fashion.
It's not intentional, it's just this is what happened. We have to
pay their attorneys fees. And if there is a knowing violation of
public records law by a public official, an intentional destruction
of a record, for example, I'm going to destroy this record because
I don't want anybody to see it, that person can be subject to
impeachment, suspension, removal, first degree misdemeanor,
$1,000 fine. So you can see again the policy at work. It's a
strong policy that contains a lot of teeth.
If you've got any other questions, I'll be glad to answer them
now or at some other point.
MR. WEIGEL: How are you doing up there? If there's any
need for a break or anything, we can take one at any point.
Okay.
MR. MANALICH: Good morning, commissioners. I'm Ramiro
Manalich, chief assistant county attorney.
The topic before you today at this point, ethics, is something
that I guess has been slightly covered by the media in recent
months, so obviously we should spend a little time on it.
Actually, in all seriousness, the purpose of my presentation
today is to acquaint you with the basics of the ethics laws that
affect the county. Now, under the theory that the visual
compliments the oral presentation, I'll try to integrate some of
the slides -- some of my comments.
And in this first slide, I think we kind of get the flavor for the
whole idea behind the ethics law, which is the citizens, the
public, the media being able to watch their government and
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January 16, 2001
have, as a result of being able to watch it, confidence in the
integrity of that government. And that's what these laws are set
up to try to accomplish.
Let's take a few moments and let's talk, because really, we
have three levels of laws that affect you as public officials in
Collier County. Now, in the graphic there, you basically see
some chess pieces. The reason I put that up there is essentially
when we talk about the ethics issues, we're looking at three
levels of analysis. And I'm reminded in the Seventies popular
series Star Trek with Mr. Spock, the very intelligent Vulcan
would play chess on three levels. And if he made a move on one
level, it might affect a piece on the third level.
And while I don't want to over complicate this, what I want
is to sensitize you to the fact that since we have three levels of
laws, the state, the county and the human resources rules and
procedures for employees, any time an ethics question comes
up, it may involve more than one level.
This is a quick example to sensitize you to this. Let's
suppose we have a gift from a lobbyist in the amount of $110.
Well, if that gift is given by the lobbyist to one of you under
circumstances, it clearly demonstrates that it was out of family
relationship or more likely personal friendship circumstances
why it was given, you have a defense, and you can accept that
gift under the local ordinance, because it's built in, that
exception to the local ordinance. However, don't get too comfy
with that, because actually under the state law you would still be
in violation, because the state law doesn't recognize that
defense.
So my only point there is not to create fear or anxiety, my
point is merely to sensitize you that we must look at three levels
on these issues.
Now, essentially if we look first at the -- well, let me make a
few general comments before we get into each of those levels.
I think as some of the other speakers have commented here
today, when we're dealing where there's public records,
Sunshine Law or certainly ethics, we have developed over, you
know, millions of years of our existence on this planet instincts,
you know, and we have -- when you approach situations of
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January 16, 2001
concern or danger, we react.
And pay attention to that. I mean, if you have a situation
where you're at a meeting, you're faced with any situation where
something inside of you raises concern, listen to it. And if you
don't know the answer right then and there, think about it and
follow up, follow up with our office. We're always available. But
that's a good thing to have that reaction occur.
The other thing I would say in general is especially when it
comes to gifts, which was a lot of what the local legislation was
designed to deal with, my general advice on that, despite all the
technical rules, is when in doubt, do not accept. And only accept
when you can point to a specific authority or exception that
allows to you accept. And that by far is the safest rule of thumb
to follow.
Another thing, David alluded to this earlier in his
presentation, which is, you know, we talked about perception.
And sometimes unfortunately perception tends to actually
become reality. And in ethics issues it is especially true. And we
can advise you and we will try -- David always tries to advise you
in terms of here's the legal technical requirements. But he also
tries to be an advisor in a general sense and say think beyond
just the legal technical requirements. What are the political and
public relations ramifications of this particular action or
non-action, as it may be.
Consider another thing, which is the lengthy process which
the State Commission on Ethics has set up for investigating and
dealing with ethics complaints.
If you consider that that process can go on for a number of
months, you should be careful in these situations so you don't
get into the process in the first place. Because even though you
may be vindicated when all is said and done, you will have had to
go through that process, and harm can be done just by going
through the process, just like people can be restored by having
prevailed in the process.
Let's talk then briefly about each of the levels of the ethics
laws that affect you. And first of all, we have the statutes. Now,
what you see pictured there is obviously law emerging from the
legislature. And this is the wisdom of the legislature, which has
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January 16, 2001
set up the legislative intent between the state -- or behind the
state ethics laws. And in your package you have these laws, and
I won't ask to you refer to them as we go, I'll just kind of
highlight them for you.
But basically what the legislature tells us is that their goal
was to make sure that by these laws our public officials are
independent and impartial, and that public office not be used for
private gain.
At the same time they tell us we don't want to discourage
people that are qualified, active and prominent in their
communities from being involved in public service. So you have
a balancing act there.
And quite honestly, I guess maybe at some point back in the
beginning of ethics time we may have had somebody thinking
and saying, well, gee, you know, on the one hand we have on this
end of the spectrum the classic banana republic where
government is for sale in all regards, and on this end we have a
bunch of reclusive monks that are extremely pure of soul but
have never interacted with the real world. And I think the
legislature basically said well, let's try to draw a reasonable
balance somewhere in between those two extremes. And these
statutes are their effort at doing so. And I will say, our board has
chosen to go further than the statutes have under terms of their
restrictions.
Now, what I want to first acquaint you with is under Section
112.3t3 of the statutes, which is referenced in your outline. And
these ethics statutes are -- the salient provisions are in your
graphic there. But these are the core prohibitions which exist in
the statutes, which are very fundamental and you should just be
aware of.
And the first one is the solicitation or acceptance of gifts.
The state law prohibits you from soliciting gifts if they are in any
way -- if it's under -- or accepting of, if it's any way based on your
performance of public duties. So obviously that prohibits a bribe.
Another prohibition is doing business within one's agency.
That is, you cannot engage in business relationships with the
county. Now, there is an exception for that and that is if that
relationship arose prior to the time you began elective office,
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January 16, 2001
then that relationship or contract, if there is one, is allowed to
run its course, absent any other violations in that situation.
Unauthorized compensation. That is basically what we
would call constructive bribery. And what that means is that you
cannot accept anything of value if you know or should know,
under the exercise of reasonable care, if it was given to
influence the performance of your public duties.
Salary and expenses. That's just merely a mention that
when in the course of proper legislative deliberation you have to
vote on something that may affect that. When it's obvious --
when it's properly before you as a board, that's okay.
More importantly, misuse of public position. Basically that
says you cannot use any information or resources available to
you through your office which are not otherwise available to the
general public to secure a special benefit for yourself or for
others related to you.
Conflicting employment or contractual relationship. That
basically says that you cannot have an employment or
contractual relationship if it will result in frequently recurring
conflicts on matters that come before the board or that would
impair your ability to be impartial and general as a member of the
board.
Disclosure, use of certain information, we've already talked
about that.
Prohibition on lobbying. The only thing you should be aware
there is that for a period of two years after you leave the board,
you cannot return before this body to lobby or advance a
legislative agenda for compensation.
COMMISSIONER MAC'KIE: I have a question on that point.
Do we -- see if I can ask it generically. But does that prohibition
extend to lobbying the agencies of this board, its staff and its
advisory boards?
MR. MANALICH: I am inclined to believe that it does. And,
you know, the words in the statute are -- may not personally
represent. And I've had in the past some limited discussion with
Ethics Commission attorneys, and I'm inclined to believe it does
extend that far. The agency is not just the governing body.
COMMISSIONER MAC'KIE: In other words, if two years after
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January 16, 2001
you're on -- after -- within two years of being on this board, we
should not lobby Norm Feder for a roadway, we should not lobby
Tom Olliff or Leo Ochs for a park, we should not lobby staff or
committees, under Ramiro's opinion.
MR. MANALICH: Well, what I would qualify, though, is the
statute for -- particularly for commissioners does say before the
governing body. That is the words used. So whereas agency is
usually viewed more generally, here it's rather specific.
COMMISSIONER MAC'KIE: So it's the opposite of what I just
said, it's completely legit to do that, to lobby staff members?
MR. MANALICH: Based on this particular statute, I think it
only extends to appearances before the board. But I think it
would be worthwhile to look a little closer and see if there's
another provision that would extend it any further.
CHAIRMAN CARTER: Gray area is what I'm hearing,
Commissioner --
MR. MANALICH: A little bit on this one. I mean, not under
this statute. Under this statute it says --
CHAIRMAN CARTER: This is very black and white, but --
MR. MANALICH: Right.
CHAIRMAN CARTER: -- you're saying there may be other
provisions --
MR. MANALICH.' I'd probably want to check a little further
just to see if there's any other prohibition that would say as the
agency as a whole.
COMMISSIONER MAC'KIE: And the lobbying -- you can lobby
on behalf of an organization as long as you're not paid for that --
MR. MANALICH: Correct.
COMMISSIONER MAC'KIE.' -- within the two years?
MR. MANALICH-' This says for compensation.
CHAIRMAN CARTER: So if I was president of the Pelican
Bay Property Owners Association after leaving this board and I
came in front of this board on an issue, then it would be perfectly
legitimate if it was in that two-year window.
MR. MANALICH-' Correct, and then there was no
compensation.
CHAIRMAN CARTER: No compensation.
MR. OLLIFF: And just so the board's aware, I think the issue
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January 16, 2001
here is probably Commissioner Constantine at the last board
meeting. And we did go out into the hallway, and we wanted to
make sure that before he registered to speak and got up at the
podium that there was a non-compensation relationship between
he and the civic association, and that's the reason that he did
make the presentation that he did.
MR. MANALICH: Now, one of the things I would also, as a
general theme throughout this presentation, I would introduce
the term funny facts. And that is obviously all of these situations
and opinions and conclusions are based on the straight up facts,
you know, for instance, no compensation. But if there's any what
I would call funny facts, that is, some indirect compensation,
that could be a problem. But, you know, in the sense that if
there's truly no payment, then no, it would not be.
But again, you know, there are many situations where we
have to make sure that we're dealing with all of the facts and
there are not other facts that have not been, you know, disclosed
that could affect the result. Because that's what the
Commission on Ethics will always tell you, for example, when
advisory opinions are requested, the opinion's only as good as
the facts presented.
CHAIRMAN CARTER: But just on your one issue, I'm thinking
in the future, let's say any commissioner that sits here and
leaves this board, now he wants to deal with an agency of
government, of county government, we're saying that there's a
probability within that two years after he or she leaves this
commission, they cannot do business with government, Collier
County government?
MR. MANALICH: No, no, I think that what we're talking
about here is lobbying before the governing body. The particular
statute I'm referring to is you cannot appear for compensation
before this governing body to advance a particular item.
CHAIRMAN CARTER: But if I was an engineer and I left this
board and I took a contract with the Department of
Transportation of this county six months, a year afterwards, then
that would not be considered an ethical violation?
MR. MANALICH: No, at this point I'm not aware of anything
extending it that far.
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January 16, 2001
CHAIRMAN CARTER: And I'm only thinking in the future, if
you want good people to continue to run for commission chairs, I
would really not -- hate to see them put in that position. I mean,
they're not here for a lifetime, they're here for a term or two or
whatever their desire is, and they want to go back into the
private sector, I don't want to see them penalized to say well,
you can't have anything to do with the largest employer of the
county.
MR. MANALICH: And that to me is not a restriction at this
point.
CHAIRMAN CARTER: Other than they can't lobby in front of
the --
MR. MANALICH: Correct, for compensation.
Another area that you'll want to be aware of is voting
conflicts. And basically the statute there prohibits you from
voting as a member of this board on any matter which would
enure to the special private gain or loss of you, a relative, a
principal that employs you, a business associate. Any one of
those you cannot vote on that matter and you have to file -- you
have to announce the -- disclose the conflict and then file your
memorandum, which I think you're becoming familiar with doing.
COMMISSIONER MAC'KIE: Can we talk about that for a
second? Disclose the conflict, what does that mean? I've been
dissatisfied sometimes, frankly, in the past with board members'
disclosure or lack thereof. Just -- is a statement that I have a
conflict and can't vote on this sufficient?
MR. MANALICH: No, I don't think it is. Basically the statute
says such public officer shall, prior to the vote being taken,
publicly state to the assembly the nature of the officer's interest
in the matter from which he or she is abstaining from voting, and
then within 15 days a memorandum to that effect. So I think a
little bit more is required.
COMMISSIONER HENNING: Can you explain the perception
of conflict of interest, or it isn't a -- directly a gain or a loss, but
there is some business dealings with the item that is coming
before the board?
MR. MANALICH: Well, interestingly, that particular provision
is not found within the Chapter 112 ethics code. There's actually
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January 16, 200t
a Sunshine Law open meeting section, Chapter 286. But it does
provide that in the event that any one of you believe that there is
a perception that you will have a potential conflict in voting in
any manner, you have the right to choose, if you wish to invoke
that provision, to avoid the perception and conflict out.
Because under the Sunshine Law, the typical requirement is
that you must vote, you cannot abstain, unless you have. proper
legal grounds to do so. And relying on that statute in good faith
would be a proper legal ground.
So that is another tool that you can avail yourself of if you
believe that the public trust will be diminished because of a
potential conflict which creates a perception.
COMMISSIONER HENNING: Okay. And I think that we need
to -- this board needs to discuss that. Commissioner Mac'Kie,
Commissioner Coletta and myself are in business, and there is
that perception out there that we don't want to see -- we want to
show the public that we are in the best interest and not for
private gain.
COMMISSIONER COLETTA: And I think we both have done
that to a large extent. I myself on November 21st, the first day
of assuming office, have ceased doing all business with the
county with my own firm. And I'll continue that role until that
point in time I either sell the business or I retire from public
office. And even though it was on a bid system I thought, like
perception is what you said, and that's absolutely correct. I
receive no business from the county. I gave up like, I think it
was, $25,000 worth of business a year for the position. And I
welcome that opportunity.
COMMISSIONER MAC'KIE: I respect that so much, Jim. I
mean, that's a real sacrifice. You just cut your compensation for
this job in half.
CHAIRMAN CARTER: That's right.
And see, I'm back to this point again that I don't want to
deter people that are sitting here who still have businesses who
come for a time and serve, to go back to those businesses -- it
would be a terrible thing if people are going to start trying to ride
that train and grind them down because there is a perception
that maybe because so and so walked into your shop or his shop,
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January 16, 2001
they're getting a deal because he's a county commissioner. I
mean, that is ludicrous. There's not enough money in this job to
do what he just did. He's not here for that purpose.
And I know it's building public trust, but I am really
concerned about that, Ramiro, because I gave up my business -- I
totally divorced myself from my business when I came to this
job. And that was okay, because I'm at a point in my career
where it's a different scenario. But there are other people that I
would like to see take these positions over time. Why should
they make that sacrifice? They're making a big enough sacrifice
to come and sit in these chairs because they want to give back
to the communities, little lone have to take some sort of hit
along the way here that says, you know, there's something funny
going on because they're in business.
COMMISSIONER COLETTA: I think we've all entered into
this. Even Donna Fiala had given up her position well prior to
assuming this because of a possible conflict of interest. And so,
you know, I think we're all in the same mindset. We went into
this with our eyes open and knowing what we're doing. And I
know Tom Henning has done quite a bit himself, just from my
own experience before we got into the -- when we were running
for office, to try to avoid these conflicts if he did receive office.
And it's saying we go in with our eyes open. And I can accept it.
MR. MANALICH: Again, the conflict -- the perception issue,
that's one that you can make a choice on that. The law does not
necessar -- does not mandate that. That's available to you if you
believe it's important enough to cause you to conflict. But your
only conflict basis is if it will -- the vote would result in special
private gain or loss to you or your business, et cetera.
COMMISSIONER HENNING: What's the ethics law -- or the
Sunshine on the ethics?
MR. MANALICH: 286.102.
CHAIRMAN CARTER: But I guess to get down to where
you're going --
MR. MANALICH: 012, I think.
CHAIRMAN CARTER: -- our old county ordinance is the one
that we'll really begin to apply, because the state ordinances we
are probably all okay. Now we get to the county and that
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January 16, 2001
becomes a different animal.
MR. MANALICH: Well, it will get a little bit more interesting
here. And I'll try to wrap up so we don't take too much more
time on the state.
Obviously financial disclosure, I just want to make you
aware that -- and Sue Filson does a very good job of this, of
coordinating with you to make sure that your appropriate forms
with annual disclosure of financial interest are submitted.
There's been some recent changes. I won't bore you too much
with the results.
But one of the things is that automatic fines do go into play
if they're submitted late. There's obviously a hearing and appeal
process if you're late, but obviously you want to avoid that.
Interestingly, for gifts, you have -- if you're going to pay and
argue it's not a gift, you must make any payment for the gift
within 90 days of receiving it. And they're now determining that
only a promise to pay for a gift is not a defense, unless it's in
writing and enforceable in the courts.
Probably one of the most interesting aspects of the recent
legislative changes on the ethics laws has to do with disclosures
and the local option, as it's known. And that is we have received
communication, which Ms. Filson and I have discussed,
indicating that very few of our appointed boards are now
required to have the financial disclosure. Essentially the state
has eased up on that requirement.
And there is, however, a local option where local governing
bodies can choose by ordinance to require these appointed
boards to make these disclosures. Now that's a policy decision
which probably either at this forum or maybe in the future we
would look to you to provide some guidance on whether you wish
to exercise that local option or merely impose upon your
voluntary advisory board members the requirements of the law.
At this point the only boards -- and Ms. Filson, correct me if
I'm wrong -- but the ones I show that are going to be requiring
the disclosure under the state view are the water -- Wastewater
Authority, the Airport Authority, those two, we determine
actually if they should be, not the statement, code Enforcement
Board, certain specified employees and the Planning
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January 16, 2001
Commission.
So essentially all of your other advisory boards will not
require, under the state's view, in the new law, the financial
disclosure. You have the local option to require that of them if
you wish but, you know, I think there's some policy
determinations to be made there as to whether that's a good or
bad thing. Will it discourage, you know, otherwise capable
people because of, you know, additional requirements, or is it
something that for openness of government is necessary?
CHAIRMAN CARTER: Could we get, Ramiro, some input from
what is going on state-wide on this, how other counties are
dealing with this?
MR. MANALICH: This was recently passed. We certainly
could undertake that analysis --
CHAIRMAN CARTER: Or maybe FAC can help us a little bit
with this, Florida Association of Counties. MR. MANALICH: Okay.
CHAIRMAN CARTER: I think I'd like more information before
I would get into any kind of a lengthy discussion on that, to see
the pros and cons.
Again, up front I don't want to discourage quality people
from serving. Sue Filson has enough trouble getting people to
volunteer to get on these boards. I certainly don't want to throw
up a roadblock that stops qualified people from saying yes, I
would serve on this board, but I'm not about to make a financial
disclosure to sit on a board that I'm volunteering to do and
there's no compensation so there's no personal gain here.
I don't know, I can see the ones we've listed. Why?
Because of the peculiarities that surround that. We have it there
and it makes sense. But the others, I would like to have a lot
more information.
MR. MANALICH: Okay.
COMMISSIONER FIALA: Along that same line, as far as gifts
and financial disclosures go, many times we as commissioners
are invited to functions, usually fundraising things for some
social organization, Shelter for Abused Women or something
along that line. And I've spoken to David about this just a little
bit, but I'd like it to be on the record as well. They would like the
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January 16, 2001
commissioners there, just if nothing else to show that we're
interested in their organization or at least wanting to know more
about their organization.
Conversely, that we're invited to a luncheon to be a speaker
or just to a banquet just to -- you know, just to say oh, one of the
commissioners came and recognized us. But it cost $250 to go.
Well, most of that of course is a donation to the organization
itself. There's a little piece of it there, say $50, that actually pays
for the cost of the event.
I had to go to something like that recently. Somebody
called me at the last minute. Her date had dropped out and she
said would you go with me. And I said -- and of course she's
been my friend for 20 years, but still I said, "1 don't think I can go
now because I think that would appear as a gift." I said, "How
about if I pay you for the meal?" She said, "Well, the rest I'm
taking as a donation off my taxes." I said, "1 might need to pay
you on this," because -- for the rest. I paid her for the dinner and
for the function itself, obviously, even though it wasn't anything
that I would ever be lobbying about or for. It gets kind of
convoluted there.
MR. MANALICH: I mean, a couple of things we're -- as soon
as we get to the ordinances here we'll see, but when you talk
about food and beverages, typically what's involved in these
functions, if you go and if it's under the circumstance of law by
the ordinance, you may be able to accept it, but you're going to
have to report it on a form required to be reported if it's in
excess of the state per diem rates; a form that's required to be
reported.
There's also a resolution in effect which allows you to bring
to the board on the consent agenda a request to attend some of
these functions and have the board pay for it if it can be
reasonably shown to serve a valid public purpose to have you
there.
COMMISSIONER FIALA.' That's my second question. What I
decided to do was -- my husband and I decided, actually, before I
even ran for this office. Because there's been so many things
that have taken place in the last few years, I felt that rather than
request any dollars, I would just pay for it out of the salary that I
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January 16, 2001
get. Now, I know that -- so we've set aside 20 percent of my
salary, which is actually a pay cut for me from my last job, but 20
percent to pay for all of my own things, because I want to stay
visible.
Like for instance, I go to two Kiwanis clubs a week. $25 a
week is just spent on Kiwanis. That's before I get into anything
else. Naturally I have to continue to go to East Naples Civic
Association and their banquets and their luncheons.
When you start adding all of that stuff up, it's a lot of money.
And I just feel it's unfair to ask the county for these things
because I want to stay active in the community. So I've been
paying for it out of my own pocket. Which is fine. I planned on
doing that right from the start.
But I was wondering --
MR. MANALICH: I think the local ordinance does provide
perhaps some relief for you and that in regard -- and we'll look at
in just a moment -- that if it's a type of function that fits within
what the ordinance described, it's not considered a gift, then you
can accept it as long as you disclose that you attend it.
CHAIRMAN CARTER: I think you're going to take us there,
Ramiro.
I would agree, Commissioner Fiala, you've always been in
Kiwanis, or I'm a Rotarian. That didn't change. I've always done
that. I would never expect the county to pay for me being a
Rotarian.
But there are other public functions in which there's an
expectation in the community for us to be there. And we've been
-- you know, I think we really need to get on a list and do some
rotation. But when you start looking at the major organizations
who want us to celebrate their success with them on -- at the
annual banquet, installation of officers, whether it be the EDC or
the Chamber or CBIA or other functions like that. And I think we
used to, under the old ethics ordinance, there was a liability
there that it didn't cost you out of pocket to go to that, because
-- and it might have been a very small amount.
But when we went to zero gifts, that changed the picture.
And even -- and I will take the Naples Daily News. They've been
an advocate. There should have been a line item in our budget
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January 16, 200t
that dealt with these issues, because there's an expectation in
the community that we be there. And they feel that we should
have a line item and that we should do that so that we don't get
into any kind of conflicts.
So that may not take us into the charitable organizations
like the heart ball, cancer ball, or whatever it is. I think that may
become more of a personal choice. But if you went to the annual
banquet of the NAACP or you went to, I'm going to say, the
Chamber's annul banquet, one commissioner representing the
board be there. If others choose to go then, you know, it's paid --
you pay for that.
COMMISSIONER MAC'KIE: Well, I even think, for example,
tomorrow, I think it's tomorrow, I'm going to go to the EDC's
legislative delegation luncheon. $25, I'm going to pay for it and
I'm going to ask for the board to reimburse me. Look for it on a
consent agenda. Because I'm going so that I can have more of
an opportunity for a rapport with the legislative delegation on
behalf of Collier County. I don't have a question, I think we all
ought to be there, and I think that it is appropriate on behalf of
the people we represent to be there and that, therefore, it's an
appropriate expense for the county to pay.
I'm there on behalf of taxpayers, that's my job; therefore, I'm
not reticent to have taxpayers pay. If I'm there on my own
behalf, then I certainly should pay for it myself.
MR. MANALICH: I think there are mechanisms in our
existing framework here where if attending some of these
functions can be shown reasonably to relate to your public duties
CHAIRMAN CARTER: I think our point is --
MR. MANALICH: -- I think it can be done.
CHAIRMAN CARTER: -- it should not cost you to sit in this
chair to represent the public that you serve.
COMMISSIONER MAC'KIE: And it does already in a lot of
ways. And so actually -- you know, by reduction of salaries and
income, as Jim and others have -- I have learned to live with, but
not -- you know, we need not to be embarrassed if we're going
representing taxpayers to have taxpayers pay for it. They
elected us to do that. We need to be embarrassed if we go and
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January 16, 2001
let, frankly, the Chamber comp. us on the deal. Because then it
looks like I'm there on behalf the Chamber. I'm not there on
behalf of the Chamber, I'm at the Chamber on behalf of the
taxpayers, therefore, the taxpayers should pay for it.
COMMISSIONER FIALA: I wonder if you are a speaker at
that Chamber function.
CHAIRMAN CARTER: That changes. And he will take you
there. Because that's a different scenario.
MR. MANALICH: Now, one thing I should mention about the
statutes that do address you being a speaker there, it's under the
rules governing honoraria, and that is always be careful not to
accept payment for an oral presentation or for any writing itself.
You can -- under the statute, you can attend and be paid the
reasonable expenses of attending, but not for the speech itself or
for any writing that you do.
The gift law under the state -- and I'll wrap up the state so
we can turn real quickly to the county ordinance. Under the gift
law of the state, what you need to know is that it prohibits gifts
in excess of $100 from lobbyists. Between 25 and 100, under the
state law, the lobbyist has to report it.
The other feature of the state gift law is that you have to
report all gifts in excess of $100. Interestingly, by the way, the
legislature wrote an exception; it says, however, prohibited gifts
don't have to be reported, so you don't incriminate yourself. Just
that little side note there.
CHAIRMAN CARTER: Legislators always have a way of
taking care of themselves.
MR. MANALICH: One of the things that the statutes provide
-- and this is a good transition for us into the county ordinances --
is that local governments can adopt more stringent standards of
conduct. And that's what this board has recently done through
two ordinances. And I'd like to now turn to our county --
CHAIRMAN CARTER: Before you go there, let me check with
my court reporter and see how she's doing. Would you like --
thank you, ma'am. I think this is a good time. We're going to
make a transition. Why don't we take 10 and give our court
reporter a break.
(Recess.)
Page 47
January 16, 2001
CHAIRMAN CARTER: Hi, everybody.
Ready to go, Mr. Manalich?
MR. MANALICH: Yes, thank you. Welcome back,
commissioners. We'll turn to the county ordinance part of the
presentation on ethics. And what you see pictured on the screen
before you is a fictional county commissioner being fawned over
by lobbyists and being given an expensive gift.
CHAIRMAN CARTER: Never happen in my life.
MR. MANALICH: That's why it's fictional.
But what I want -- the reason that's up there is because
really the county ordinances are designed to deal primarily with
this situation. And as such --
COMMISSIONER MAC'KIE: We need one of those just say no,
circle with a slash through it on top of it.
MR. MANALICH: There was a committee that was appointed
by the previous board from the community, an ethics advisory
committee, which came up with some recommendations that
essentially recommended that a local ethics code be enacted.
And the primary motivation for that was to toughen up the
restrictions on gifts, have some reporting requirements for
lobbyists, and create a local enforcement mechanism. And those
were -- that was the legislative intent behind this first ordinance
that you have in your package, 99-22.
And essentially what that ordinance did was first and
foremost it reduced the state threshold from $100 from gifts from
lobbyists to public officials down to $50. Secondly, it created a
lobbyist registration requirement with the clerk to the board's
office, which is done on an annual basis. And third, it provided
that county managerial employees, and that is essentially all
employees at the division administrator level, are prohibited from
coming back to lobby the county for a period of two years. But
that only applied to those county managerial employees that
were with -- that came with county government after the
effective date of the ordinance. So it only applied to those who
were hired after the effective date of the ordinance. So if one of
the county manager employees which was here at the time of
the passage of the ordinance, that person is not prohibited, if
they leave county employment, from coming back and
Page 48
January 16, 2001
interacting with county government.
Now, the second ordinance was really I guess what you
would call Gifts 2. And that's why we have the gift box again up
there on the screen. And basically this was an ordinance
specifically targeted to deal with more gift issues.
The first thing that the ordinance did was it lowered the
local threshold from $50. Remember we had gone in the first
ordinance from 100 at the state level from lobbyists down to 50.
This ordinance now took it down to zero. So it was zero
tolerance for gifts from lobbyists. And it also created additional
gift prohibitions and exceptions from the definition of what is a
gift.
Now, the reason that occurs is because conceptually, if
you're basically going to have a zero gift type policy, then in
order to prevent innocent situations from being wrapped up in
that very sweeping prohibition, you have to create some
reasonable exceptions. And the board chose to create those
through the passage of 2000-58 in the ordinance.
Now, in the -- what you should be aware of is the following
exceptions of things that are not gifts and consequently under
the local ordinance not prohibitive. The first one is gifts received
where family or personal relationships clearly demonstrate that
that is the reason for the gift rather than the business of the
persons. So that is one that you can rely upon.
Another one touches on -- Commissioner Fiala and some of
the others had commented earlier about food and beverage
accepted at different functions. And what it basically says is
that if it's offered free in the course of a professional or civic
meeting at which attendance is desirable because it will assist
in the performance of public duties -- in other words, you're
gaining valuable information, etc. -- or if it's food and beverage at
such a function provided to all panelists or speakers, when
you're participating as a panelist or speaker, it can be accepted.
But it goes on to say that notwithstanding those provisions,
you can only accept it if it goes -- if the value of the food and
beverage is up to the state per diem. Now, that's not very
generous, because the state per diem is currently three for
breakfast, six for lunch and 12 for dinner.
Page 49
January 16, 2001
MR. MANALICH:
COMMISSIONER
MR. MANALICH:
county --
But then it also adds, if under circumstances beyond the
control of the donee, meaning you, it exceeds the per diem, you
can still accept it at that type of function, but you have to file a
form indicating you attended the event. And that form is filed at
the office of the county manager.
So those are the circumstances where you can accept food
and beverages at those types of functions. Now, you can get
into, you know, subtle little issues in these things. Because, for
instance, the words used there if under circumstances beyond
the control of the donee, what that means is you can't go to a
function and say everybody else is getting the rubber chicken, I'll
take the filet mignon as a special order, and I can still take it.
No, this says if under circumstances beyond your control, so you
have to take whatever is offered to everyone else.
COMMISSIONER FIALA: So let me just make sure that I
understood what you just said. So the -- we're allowed for
breakfast $3.00. And we go as a speaker to a Kiwanis Club and
the breakfast is $10, through --
You can accept it --
FIALA: -- no fault of your own.
-- and you report it on the form to the
COMMISSIONER FIALA: So then we have -- for the other
$7.00, we have to report it on a form. COMMISSIONER MAC'KIE: Yes.
MR. MANALICH: Correct. And now, the form doesn't
actually ask you to list the value. It says basically if you're told --
if you're informed -- which is the best, I mean, actually told
exactly what it costs -- or you have reason to believe it may be in
excess of those thresholds, the safe thing to do is to report it on
the form.
CHAIRMAN CARTER: I'll give you two examples, Donna.
Tonight I speak before the -- an association of internal auditors,
Southwest Florida, at their dinner meeting at Bonita Bay. I've
been invited there to be the speaker. I have to disclose, what is
it, $12.00 is what the fee is. If their dinner exceeds more than
that, I have to turn in a form that just says I went there, I spoke,
and that's the end of it.
Page 50
January.16, 2001
Tomorrow morning I speak in front of the Chamber of
Commerce, Wake Up Naples, and I don't know what their
breakfast value is, but I will have to turn in a form on that. But I
am the speaker. I have been invited there to perform a function
as a part of the position that I'm elected to.
So I think these are just clear-cut examples. When you get
those, there's food, you just turn in the form and it says I
followed the rules.
MR. MANALICH: Now, there's a --
CHAIRMAN CARTER: Because there's not many breakfasts
that are served for three or lunches served for six or dinners for
12, and of course that's one of the issues we've got on the
legislative agenda.
COMMISSIONER FIALA: And it's mandatory you're there --
CHAIRMAN CARTER: Mandatory that you're --
COMMISSIONER FIALA: -- you're serving your community.
CHAIRMAN CARTER: Right. And all you do is turn in the
form that says I've been there, done that, and this is -- we don't
even have to calculate the difference is what I'm hearing you
saying, Ramiro. You're just saying that we were there. MR. MANALICH: Correct.
COMMISSIONER FIALA: I'd like to request 35 of those for --
CHAIRMAN CARTER: Well, yeah, you get a stack of forms
and you turn them in. I mean --
MR. MANALICH: Yeah, one in --
CHAIRMAN CARTER: -- my associate turns them in each
time, they go down to Tom's office, and we have complied with
the ordinance, we have complied with the rules. And it's just a
matter of doing that, so anyone that wants to come in and look,
they can check the dates I was there, and that's what I did and
what you did.
MR. MANALICH: And remember, you also have the other
option which is you can always for certain functions, if there's
some degree of doubt, you can have the other resolution where
you can present to the board the reasons why it serves a public
purpose for you to be there, and the county can actually also pay
for you to attend. You don't have to do that, it's just another
option that we've talked about.
Page 51
January 16, 2001
Now, in relation to this also, the ordinance recognizes that
unsolicited advertising or promotional material of a value less
than $50, as well as gifts given for participation in a seminar
which are less than $50 and given as a matter of course to all
the attendees, that can also be accepted without concern, and
you don't have to report that. It's just the food and beverage one
that requires the reporting. MR. OLLIFF: Ramiro--
CHAIRMAN CARTER: Let me ask you this question. This is
outside of county business. Let's say that the National
Association of Bird Watchers invites me to speak in Minneapolis
on how to provide leadership in their organization. Now, I'm
being asked to go and speak on my professional skills prior to
what I ever did as a county -- what I did prior to being a county
commissioner. This in no way affects that, does it? Because
this is outside income, those people will never come in front of
me as a commissioner, I'm going out and carrying out in private
practice. No more than if Commissioner Ma¢'Kie did some work
for a company which had no relationship here.
COMMISSIONER MAC'KIE: They're not lobbyists.
CHAIRMAN CARTER: They're not lobbyists.
MR. MANALICH: Yeah, the --
CHAIRMAN CARTER: We don't have to do anything --
MR. MANALICH.' Exactly.
CHAIRMAN CARTER: Now, there's another part of earned
income on a state thing at the end of the year that we have to
disclose that, but it has nothing to do with county business. You
as a professional can attend this seminar. No problem, as I
understand.
MR. MANALICH: Yeah, I think you're okay there. Good
distinction.
COMMISSIONER HENNING: Could it be -- what would their
opinion be on the piping plover on Marco Island, though?
CHAIRMAN CARTER: Well, I'm not talking about that. I'm
talking about professional leadership skills that need to be
applied in their organization. I'm not talking about the technical
or professional scientific data that -- whatever they deal with. I
never get into those subjects. I'm only talking about leadership
Page 52
January 16, 2001
skills, management skills, motivational skills. That's what I'm
talking about. I don't care whether -- what it is. It could be the
national association of gas pump operators. It doesn't make any
difference to me.
MR. MANALICH: Now, one other thing that the 2000
ordinance did with regard to gifts is it prohibited gifts up the
chain from public officials to other public officials, and from
subordinates to superiors. So for example, absent a special
occasion, which is listed as such things as marriage, birth of a
child, illness or retirement, the county manager cannot give gifts
to the Board of County Commissioners as they're being the
superiors. Likewise, I cannot give a gift absent those
circumstances to Mr. Weigel, because we are both considered
public officials and I'm subordinate and he's the superior.
So those are essentially the provisions of the 2000
ordinance. If we can go to the next frame, this dire looking
picture is up there only for one reason and that is not for
intimidation but rather as a reminder that under this scenario the
stakes are higher. Because although the committee that you
appointed, the advisory committee, found that a local
enforcement mechanism was preferable, what that really means
is that we now have jail penalties for these violations, which
feasibly could be imposed in a court of law. The ordinance is
enforced before a judge.
So you just need to make yourselves aware of that.
Because under the typical complaint process with the
Commission on Ethics under the state scheme, there are only
civil penalties; penalties affecting your status as a
commissioner, fines but no jail. Here under the local ordinance,
we do have jail penalties. Now--
CHAIRMAN CARTER: That would be carried out under the
state's attorney? I mean, if someone filed against -- MR. MANALICH: That's correct.
CHAIRMAN CARTER: -- you know, a sitting commissioner,
then --
MR. MANALICH: Yes, the state attorney would prosecute
that.
CHAIRMAN CARTER: -- the state attorney's office would be
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January 16, 200t
the one that would do that.
MR. MANALICH: Now, if we can turn to the next topic,
basically one thing I just want to make you aware of; it does not
affect you directly, but that is there is another level of rules that
affect your county employees.
CHAIRMAN CARTER: Before we go there, can I ask one
other quick question? What about people who are elected to --
I'm going to take the new taxing authority in Pelican Bay; they
went to a dependent district and those people are elected to
those positions. They're under the same ethics ordinance that
we are?
MR. MANALICH: Well, this basically applies to public
officials, and we have defined public officials, if I can turn to the
definition just for a moment, as elected officers, advisory board
members, county managerial employees and the county attorney.
CHAIRMAN CARTER: So if either they're elected or
appointed, they would be under the same --
MR. MANALICH: Elected officer I think is limited. Let me
check. But it's limited only to the Board of County
Commissioners.
CHAIRMAN CARTER: Okay.
MR. MANALICH: So I don't necessarily-- David, I'd invite
your comment. I don't think it reaches them.
MR. WEIGEL: I --
COMMISSIONER MAC'KIE: You know, for school board, for
example, they're not subject to our rules.
MR. WEIGEL: No, they are not. And Mr. Carter is certainly
correct, that this is a dependent district. It's a very -- a fairly
independent dependent district, elected and not appointed by
this board. So I tend to think that they probably don't come
under our ordinance, but we'll have to look at that again very
closely.
CHAIRMAN CARTER: But they would still fall under the
state.
MR. WEIGEL: Absolutely.
CHAIRMAN CARTER: Thank you. Okay.
COMMISSIONER HENNING: I have one question on the
county's ordinance before we move on. I have a friend who is a
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January 16, 2001
lobbyist. For a long time we've been friends. And we used to get
together for breakfast or lunch, and either he would buy my lunch
or I would buy his lunch. And right now we're in the area that we
split the check evenly. Do I have anything to worry about if we
go back to our old practice of one person buying one week, the
next person buying another week?
MR. MANALICH: I guess several comments on that. First,
under the state law, assuming the lunch is under $100, which
most likely it is, obviously, no, there should not be a problem.
Now, under the county law there is the exception for it is not a
gift if personal relationships clearly demonstrate that that is the
reason for the item of value being received. So I think you could
in good faith, given the type of scenario you've described, say
that there would be no violation of the county ordinance under
that defense.
But then again, we reach into the issue of perception and,
you know, potential exposure to a complaint being filed and
having to respond to it just to dispel that. And frankly, the better
advice may be simply to each pay your own bill there.
COMMISSIONER HENNING: Okay.
MR. MANALICH: Okay, just in passing, as I was going to
mention, the human resources policies and procedures were
promulgated by the county manager having provision a code of
ethics. And that applies just to employees. And what it says is
basically that they are not to accept anything of value if it is
intended or gives the appearance of rewarding or influencing the
performance of public duties. And Mr. Olliff I know has sent
memos at Christmastime and other times reminding employees
of this prohibition.
Lastly, if we can turn to the next frame, I want to talk about
this particular resolution, No. 95-632. And this is a resolution
setting forth the policy of the board in regard to providing a legal
defense and paying legal expenses of county commissioners,
staff and advisory board members.
And I bring this up -- Debbie, if I could turn to the next one --
because I want you to view it kind of as you see in the picture
here, as kind of a partial safety net for you.
If all else fails, if I was mistaken in some way or if you didn't
Page 55
January 16, 2001
hear a particular part of the discussion, something went wrong
and a violation was alleged, you do have the ability to have your
legal fees paid for by the county in defending those allegations.
And that's provided for in this resolution. But essentially what
you have to do is you have to make sure that you follow the
steps required in the resolution.
And ultimately what it involves is notifying the county
administrator and county attorney that a complaint has been
lodged, and allowing them to make an initial assessment, and
then bring the item to the board for the board to determine if a
legal defense will be provided up front or if a wait and see
attitude will be adopted and reimbursement if you prevail. So
that is an available mechanism so you're not completely alone in
case of a misstep off the ethics high wire.
At this point, I think that really is the survey of the ethics
law that I wanted to give you. If you have any further questions,
I'd be happy to answer them.
COMMISSIONER HENNING: I'd like to talk about the code of
conduct of county employees. And I know this is under the
privilege of the county manager. Are county employees allowed
to accept Christmas cookies at Christmastime?
MR. OLLIFF: No. And I think if you want to take it to its
furthest extent, it's probably not as much a part of the county's
HR policy as much as it is backing up Ramiro's analogy to the
next level. The county ordinance would even make, if you want
to get very technical about it, the acceptance of a Christmas
card a violation.
And I think as a result of that, I would suggest to the board
that there's probably some tweaking that would be
recommended in terms of that ordinance, because it's the
acceptance, it's the act of acceptance that is prohibitive.
And so as we've gone through the examples, to open the
card and the envelope is to accept the card, because you cannot
return it at that point. But you had no idea what was in the
envelope when you went to open the envelope.
So I think there are some just minor adjustment that
probably needs to be made to that ordinance in order to make it
a little more practical. But in terms of acceptance of cookies,
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January 16, 2001
those kinds of things, those are strictly prohibited. And we in
fact this year returned directly any and all food related items
that were provided to any and all departments that I'm aware of
directly back to the center.
CHAIRMAN CARTER: We got a memorandum that I know we
added to people, we just told them, don't send us any.
MR. MANALICH: Now again, employees have the same
exceptions to the gift law, although I don't think, as Tom
indicated, they necessarily address all of these situations, but
they do have the same exceptions about personal and family
relationships or attending functions where it serves a public
interest for them to be there or be involved to either speak or
panelist or whatever, and then they have the same provisions
there. So there are some circumstances where some things can
be accepted.
COMMISSIONER HENNING: Let me share a conversation
that I had with a constituent, a school teacher. A librarian came
and (sic} speak to the kids on a certain subject and they were
really impressed and they were -- the children were having a field
trip the next day. And the librarian felt that she needed to
decline the invitation because they were going to The Registry
and having a lunch after that.
And I feel that we're going just a little bit too far in the
incidence of that. And I would hope that we can, as a board, do
something to where our employees are a little bit more
comfortable in those situations.
And I understand in the administration side the administers
have to be very careful of how they conduct themselves in the
public's eyes, because they're a decision-making people. Now, a
librarian is not a decision-making person.
CHAIRMAN CARTER: I guess in that case it's carrying out
the function of the job to ask you to participate in something
that's related to the job for the benefit of the public. I wouldn't
have any problem with that, Ramiro.
MR. MANALICH: I think -- in that situation, I think you would
be covered by food and beverage except as part of a group
function where attendance is desirable because it's interrelated
with your public duties. Again, if it exceeds the per diem, the
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January 16, 2001
form has to go to the county manager, in that scenario. But, you
know, there's a lot of permutations of this, and there are some
that are not covered by these exceptions.
CHAIRMAN CARTER: Well, what I would hope is that
through this process that our administrators and the whole
management team would encourage our people that when they
have a question like that, rather than turning it down, to go ask
the question and get that resolved real quick so they understand
that we're not tying their hands but there is a procedure to go
through so they can participate.
MR. MANALICH.' And I will tell you, to the credit of Mr. Olliff
and his staff, we receive many questions on a routine basis from
them, and I think they're being quite conscientious about it.
MR. OLLIFF: It's not to our credit, we just don't understand.
CHAIRMAN CARTER: Well, I think it's a difficult period for
us, and we all would rather err on the side of being conservative
and not doing it versus doing it and finding out that we have done
something that was improper.
So we're really trying -- to our listening audience, is that
we're really trying to do it right, but at the same time we want to
provide the services. We want our people involved with the
community.
So we -- I would hate to see these things get in the way.
Because a librarian certainly isn't going to make any decision
about anything that's going to affect the operation of the library
because she went on a field trip to help some children better
understand something that was sponsored by somebody on the
outside. It just -- it's inconceivable to me that someone would
misconstrue that. But it happens. And I would hope that it
doesn't happen, because we're really trying to get the job done
right.
I know we're behind --
MR. WEIGEL: Thank you. Well, I appreciate that.
CHAIRMAN CARTER: -- I apologize.
MR. WEIGEL: I just -- no, that's fine. And I'll mention, as I
said at the beginning, we're going to be talking, coordinating
with Tom Olliff with the division administrators, the departments,
so that they get the message. We probably won't talk to them
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January 16, 2001
about quasi judicial stuff, the librarian and that group, but we
can certainly talk about the other aspects that we can assist
them with information-wise.
Our next topic --
COMMISSIONER MAC'KIE: Before you leave that, I've got to
make a little plug for something that I have been trying to get our
county manager -- and I know he has been investigating this, but
something that I've been looking at for quite a while is a program
called Communities of Character. And it is a training program
basically for character education that cities and even states --
it's specifically oriented toward government. It's not cheap. I've
done some fundraising that we could get some support on having
that -- having that education program brought to our county. I
know the Sheriff is doing it with his employees. I know the City
of Naples is considering doing it. And it's my goal to have that
implemented here and to have us designated as a community of
character.
And there are real -- there are specific actions required for
that. But all of that, it's as simple as, you know, the Sheriff's
example is good, is every cop, you know, is offered a free donut,
and that's just sort of a caricature, but do we think that -- does
the cop know that the donut might be offered with the
expectation that you're going to hang around more at that
7-Eleven? You know, just to get you thinking about those kinds
of things.
And I really hope that -- and it's on my list of things to talk to
Tom about, but I hope you guys will be interested in that
community of character education.
CHAIRMAN CARTER: I really support that, Commissioner
Mac'Kie. I know the Sheriff went through that process, I know
the president's forum of Southwest Florida had that same person
speak to the presidents and COE's of major companies here
maybe six months ago. I can't remember the time. And I
believe, Tom, that you were a part of that meeting -- MR. OLLIFF: I was.
CHAIRMAN CARTER: -- where you had an opportunity to
hear what it's all about. And I think it's a commendable program.
And I would hope that governments and businesses would -- in
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January 16, 2001
this area would embrace that, as the Sheriff's Department has,
because it does so much for character building in the
community, gets everybody involved to better understand what
character is all about, and the tremendous productivity that
comes out of groups that go through it, absenteeism goes down
COMMISSIONER MAC'KIE: Workers comp claims go down.
CHAIRMAN CARTER: Go down. I mean, it has amazing
effects on it. So I would completely endorse anything that we
could do to perpetuate that program here.
COMMISSIONER MAC'KIE: Just didn't want to miss a
chance to plug it.
CHAIRMAN CARTER: I thank you for doing it.
MR. WEIGEL: Just to mention, our next speaker, long-time
Assistant County Attorney Margie Student, will be talking about
ex parte communications. Recognizing that the clock is
continuing to move, I've asked Margie and the following speakers
to expedite somewhat.
COMMISSIONER MAC'KIE: Hey, we've ordered lunch. You
guys are the ones that --
MR. WEIGEL: Six dollar lunch, I'm sure.
But the fact is, is that we're here as long as you'd like us,
but we will wrap it up a little more quickly, if you prefer. Or we
can hold out other opportunities to continue this even over to the
back end of a board meeting, which you probably wouldn't want
to do.
But with that, Margie, could you tell us a little bit more
about the ex parte
MS. STUDENT: Yes, thank you, David.
Good morning, commissioners. For the record, Margie
Student, assistant county attorney. And I'm here to talk about ex
parte communications and quasi judicial boards.
And there's some legalese mumbo jumbo right there in the
title. Ex parte means from one side, or one-sided communication.
Quasi judicial means sort of like a court. And when you as a
commission sit there and hear quasi judicial matters, the five of
you are sort of like a panel of judges. And that's the reason that
we have the Jennings Rule. And in the interest of time, I am
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January 16, 2001
going to go through quickly.
The first item on my outline is background. And I give you a
little history of the Jennings Rule that came out of Dade County
and the ex parte communication involving a variance over there.
And really, the rationale for the prohibition -- or not really
prohibition, but the presumption that a problem arises when
there's an ex parte communication is to assure that the
proceedings before the quasi judicial board are fair and impartial,
and to also provide a forum in which all sides of an issue can be
presented, debated and discussed prior to the final decision
being made.
Jennings was decided in 1991. And in the wake of Jennings,
the legislature acted. But before we go to that, I just want to
touch on the difference between a quasi judicial hearing and a
legislative matter. A legislative matter is the establishment of
policy. And the body has broad discretion in making its decision.
Examples of legislative matters that come before you in the land
use area include land development code amendments, comp.
plan amendments and broad county-wide rezonings.
In a quasi judicial action, it's the implementation of policy
which is already being established by law -- by the application of
the law to a given set of facts. And examples that you see here
every other week on that are variances, conditional uses and site
specific rezones. We see them not only in the form of straight
rezones, but also rezones to PUDs.
And as you're aware, there's a set of criteria that are set
forth in the code and also in the staff report where staff does
their analysis of whether or not the project meets those criteria.
And that is the application of a set of facts to the laws that
govern that particular item.
The Florida legislature responded to the Jennings Rule by
passing a statute. It was found in 286.0115(1}. And the
legislation removes the presumption that ex parte contact is
quasi, and quasi judicial matter is prejudicial. And it provided
that local government could pass a resolution or an ordinance
waiving the Jennings Rule so long as the government adopted
procedures require that any ex parte contact be disclosed prior
to the final decision-making on the issue.
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January 16, 2001
And in fact we did that by resolution that we adopted in
June of 1995. That was Resolution 95-376. And I think at
various times our office has made copies of this resolution
available to you. And it deals with different types of contacts
that the board is involved with in quasi judicial matters. And the
first would be oral ex parte communications. And again, those
have to be made part of the record prior to the final decision
being made on matter.
Examples of oral ex parte communications might be
telephone calls or meetings. And in -- the ideal situation would
be to have a file folder set up and divided -- have a folder in the
larger folder for each agenda item, and then whenever you've
had a meeting or you've had a telephone call with someone, that
you jot down with whom you had the meeting and the substance.
It's the substance that has to be disclosed.
So maybe if the person expressed a concern about traffic
impact, that could be listed. Or if it was an environmental
concern, that could be jotted down. And then it could be brought
to the board meeting, so if anybody had any further question on
it, they could look at it.
Also, the -- a resolution in the statute deals with written
communications. That's a little more simple because you
receive either a letter or an E-mail, so it's a little simpler to bring
that to the meeting and have it available for any member of the
public that might wish to examine it. And you could have a
similar process where you would have a file folder divided up into
separate sub-folders by agenda item and put the written
communication in there and have it available at the meeting.
COMMISSIONER MAC'KIE: Marjorie, I just want to interrupt
you to say --
MS. STUDENT: Sure.
COMMISSIONER MAC'KIE: -- you know, there's got to be an
easier way than that for us to comply with this. You know, I
think that there are easier ways. You know, for example, I don't
understand why at every -- at the beginning of every board mee --
or every quasi judicial when we all say I've met with A or B, you
know, we need to say I met with Joe Smith who opposed the
project and I met with Jim Jones who supported the project.
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January 16, 2001
And that's adequate, I think, because that tells who and what
was generally discussed. And then the lawyers in the room have
the right to cross-examine at that moment, and they can do it or
not.
But on this business about E-mail and letters, I wish that
there were just a statement on the agenda or somehow
automatically put into the minutes that here's where our E-mail
is kept, here's where our Gorrespondence is kept, all of that is
available and is hereby made a part of the record. Gan't we do
something like that instead of all of us Goming with our little file
folders?
MS. STUDENT: I think we Gould. And as I said -- I didn't say
that we had to do it, I said in a perfect or the ideal. And we're
here to help in any way we Gan to see that the disGIosure is
made to meet the intent of the law. That's not to say that you
have to do that, that was in the ideal situation.
And as I said, we're here to -- and I think that is a possibility
we could look into further. Because what's important is that the
public has access to it and they know the contents and the
substance of it and that they have an ability to rebut that or
present any arguments that they wish to at the public hearing
before the final decision is made. And I think, you know, those
are the key items.
COMMISSIONER MAC'KIE: And so for this -- for my idea to
be meaningful, it would have to be that here is, for example, this
standalone computer, that anybody who wants to come up and
see -- read all of our E-mails before a meeting to see what our
communication was on that sub -- I mean, it has to be meaningful
disclosure so that at the meeting, if they have something they
want to rebut, they have to be able to do it. We can't just sit at
the meeting and say our E-mails are in the computer, oh, and the
hearing's right now so shut up. You know, we would have to -- MS. STUDENT: I think there would have to be advanced
notice.
COMMISSIONER MAC'KIE: Advanced notice, and advanced
notice of our correspondence files. Couldn't we just somehow
make a blanket notification of those two things and then we're
done?
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January 16, 2001
MS. STUDENT: I think it's something we could certainly look
into and probably come up with the mechanics of it; you know,
not obviously today in this meeting, but very soon.
And what we might be able to do also is to scan any other
correspondence besides E-mail into the computer as well. And
so that would be available, and also any expert opinions,
because they're covered by the law and our resolution as well.
COMMISSIONER MAC'KIE: Well, let's -- I'm not suggesting
we start scanning documents, then, because then we're going to
have to triple our staff. I'm just saying let's just have our E-mail
available and our correspondence files available and let there be
adequate public notice perhaps in the notice of the meeting, we
advertise that, David, or somehow so that it's meaningfully
disclosed, but thoroughly.
MR. WEIGEL: You're absolutely correct. And anything we do
that enhances what we are already doing is to the good. But for
commissioners or planning commissioner members or the EAC
commission members, any of those that have these quasi judicial
type of determinations, if they say well, I've talked to several
people about this, that's really not good enough. And so we do
need some specificity. If we don't have at least a degree of
specificity, we're at larger risk for the decision that the board
makes to not sustain a challenge. And that's where we all want
to do -- be is to do it once and not have to come back and do it
again.
COMMISSIONER MAC'KIE: And I just -- the only reason I
interrupted is, you know, I know these board members, they are
diligent. You tell them the best way to do it is to have a little file
folder with every agenda item and every slip of paper and every
Post-It note, that's what they're going to show up with, you
know. And I think that is unnecessary if we could be more
creative, like I said, in advertising with the notice of the meeting
here's how you can see written and electronic communications
that may have been received ahead of time, and we disclose that
we got them or we didn't.
And then at the meeting I understand we need to be better
than just saying I talked to people at the Chamber of Commerce
about this, we need to say I've talked to the Chamber reps who
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January t 6, 2001
supported it or opposed it. But is just a general statement like
that adequate, they supported it or opposed it, or am I supposed
to say well --
MS. STUDENT: Let me just go into a little detail, if I might.
The law says the substance, so the substance could mean that --
you know, if it's a traffic issue or one of the salient issues that
might be considered in making a decision.
But I want to advise you of a local court opinion that we
have here that it's at the bottom of the outline. It was Hoffman
versus City of Marco. And what happened there, it was a boat
dock matter, and the boat dock went to their PAB and then the
appeal went to the city council. And what happened was the city
council made their disclosure, but they didn't state -- they just
said, you know, they talked to some people and they didn't fully
state the substance.
And the court held -- now, bear in mind, that's just our local
circuit court -- held that that was okay, that they followed the
resolution and the law because there was a burden on the
attorney that once that small of a disclosure was made, that they
had the duty to inquire further.
Now, the problem with that is that's just our circuit court
here in Collier County. If we had a case like this that went up to
the Second District Court of Appeal or maybe even the Supreme
Court, they might say that's not enough. So what we want to do
is come up with, you know, the protections that we need so as
we've stated in other presentations here this morning, we have
enough where it puts people on notice of what they need to do
and we don't have to go through the whole process of defending
a case up and back down again.
And I think that Commissioner Mac'Kie's suggestion is very
good, and it's certainly something that I'll be happy to work on
with the board to come up with a workable solution within the
parameters that we have under Jennings.
COMMISSIONER MAC'KIE: And David, that's -- you know, in
my judgment that's your job to get us those mechanisms to tell
us how -- what we'll -- here's your recommendation on how we
comply with the policy. Because I'm sorry if I'm overreacting to
the thing about the --
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January 16, 2001
MS. STUDENT: Again, that wasn't to say we needed to do
that. That was just in the -- that was just the ideal. That was by
no means to say that --
MR. WEIGEL: We haven't seen the ideal addressed in court
or mandated --
MS. STUDENT: No.
MR. WEIGEL: -- in court. But we do know that the word
reasonable shows up under Sunshine Law, Public Records Law
and the ex parte communications. And we think that reasonably
probably -- that we would be of assistance in a reasonable way to
enhance what we're doing a little bit. And this is an opportunity
to tell all the commissioners that we're looking forward to
provide some choices for you that I think won't be too difficult to
do as far as staff or you all, as far as that goes.
CHAIRMAN CARTER: Well, I would look for a system that is
reasonable, that we can put this material in, and keep in mind
that the day of issues coming to us, we get people handing out
stuff and not to be confused with what was in the file before we
even came to the dais and we had the discussion on it. And
frankly, I really don't appreciate a lot of stuff that's handed to me
the day that the issue is brought forward, because I don't have
time to go through it, I don't know what the substance of it is, I
don't know how it was built. So there's got to be some
consideration to all of that when this takes place.
MR. WEIGEL: That's a very good point. And for the newer
commissioners to this board, when we have had petitioners
come before this board on quasi judicial matters and they bring
in more documentation than what I have right here and submit it
to the record and bring it over to our court reporter, I always
make a point to say to the committee -- to the board, as well as
for the record, that petitioners' submitted materials which have
not been before this board, have not been reviewed by this
board, are merely submitted technically to the record. And we
identify those things so that if we do run into some kind of an
issue later on, it will be very clear that this record and this board
did not really have these things to use for their decision making.
COMMISSIONER MAC'KIE: The only thing, as you develop a
policy -- because I think this is a place where we need some
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January 16, 2001
improvement -- that I wish that the policy could also include
some opportunity for the attorneys in the room to acknowledge
adequate disclosure, somehow, you know, agree that they've
been advised and that -- because I worry that they're going to
raise they didn't have an adequate right to cross-examine.
MR. WEIGEL: Right. We always run the risk of that without
accentuating that as an issue for them to comment on. It's one
of those things we'll have to look at carefully, and we can.
MS. STUDENT: And I think it will take a collaborative effort,
but we will come up with something. Thank you very much.
MR. OLLIFF: And keep in mind, we're not the only
jurisdiction doing this. So, I mean, with David's blessing, maybe
we'll work with him and do some surveying of some other
communities to see how they handle the same issue.
MR. WEIGEL: Our next victim is -- we're going to have a duo
here. Ms. Heidi Ashton and Jackie Hubbard-Robinson are going
to talk about tourist development tax and some examples.
COMMISSIONER MAC'KIE: And out of curiosity, how did this
come to be on the county attorney's workshop agenda today?
MR. WEIGEL: This one?
COMMISSIONER MAC'KIE: Yeah.
MR. WEIGEL: We just thought that particularly for the new
commissioners, that they would want to know a little bit of what
this thing is and just some of the basics, really.
COMMISSIONER MAC'KIE: I'm glad we're doing it. Just
curious.
MR. OLLIFF: We actually have a separate TDC workshop for
you as well that sort of talks about the operational end of it, to
talk about the history, what's worked well, what hasn't. I'll let
the board hopefully give us some policy direction in that regard
as well later.
MS. ASHTON: Good morning, commissioners. I'm Heidi
Ashton, assistant county attorney. I've been an assistant county
attorney for eight years, and I currently work on real estate and
eminent domain; however, I've spent four and a half years
working on tourist development tax issues.
So today I'm going to talk to you about tourist development
tax issues, what the tourist development tax is, how it's
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January 16, 2001
calculated, how it's determined, how the funds are used once
collected, and go over some questions at the end that I hope will
assist you in performing your duties as commissioner. And at the
second half, Jackie Hubbard Robinson will be talking about
current issues.
Let's begin with what the tourist development tax is. It's a
local option tax, and as a tax it's required to be authorized by
general or special law. And in this case it's authorized by
Section 125.0104, Florida Statutes. We've also adopted an
ordinance, Ordinance 92-60, as amended.
In your package, I've provided a copy of the statute, and I've
also provided a copy of the ordinance as amended. But rather
than giving you the ordinance and all the copies, I've copied the
codified version from the Code of Laws and Ordinances, which is
your big book you have probably sitting on your shelf. And the
section is Section 126-81 of the Code of Laws and Ordinances.
Next, who pays the tourist development tax? The tax is a
tax for the privilege of renting or leasing living quarters or
accommodations in a hotel, motel, apartment, condominium,
mobile home park or recreational vehicle park, for a term of six
months or less. And the person that actually pays the tax is the
lessee, and that is paid to the landlord, and the landlord is
required to submit the tax to the Collier County Tax Department.
What is the amount of the tax? The amount of the tax is a
percentage of the dollar or fraction of the dollar for the rental or
lease. For example, if for a monthly rental of, say, a
condominium, if the rent were $400.71, the amount that would be
subject to the tax would be rounded upwards to $401. And it
would be based on the percentage of the tax that the county
collects.
Collier County currently collects -- it's a total of a three
percent tax, but the -- in 1992, the county adopted an existing
two percent tax, and then in 1995, we adopted an additional one
percent tax, which became effective in 1996. So currently we
have a three percent tax that's being collected.
The statute authorizes --
COMMISSIONER MAC'KIE: Heidi, there's not a deadline,
those -- none of that is set to Sun -- is scheduled to Sunset at this
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January 16, 2001
point?
MS. ASHTON: No, there was a possibility it would Sunset,
but the issue went back to the voters for like an informational --
it's called a straw vote of the taxpayers, and that was a year or
two ago. I'm sorry, my time is a little skewed. It was last year?
Okay. I'm working too hard.
But there is a possibility of going up to a six percent tax.
We've exhausted the three percent that's available under Section
125.0104, Subsection (5)(A}. If we were to go any higher, it
would have to be for like a sports franchise facility or for a
convention center, just, you know, for your information as we go
forward.
COMMISSIONER MAC'KIE: I'm sorry, we can raise to six per
-- we could raise -- we could add up to three without it being for
sports or convention?
MS. ASHTON: We have a current three percent. We've
reached our maximum. We can do an additional one percent for
a sports franchise facility.
CHAIRMAN CARTER: We can't add across the board --
otherwise, we can't add another penny or two and use it across
the board. It has to be for a specific facility, as I understand it.
MS. ASHTON: Correct, if we're to go beyond three percent.
CHAIRMAN CARTER: Yeah.
MS. ASHTON: Except for high tourism counties, they can
enact an additional one percent. But we don't qualify as a high
tourism county. So at this point if we were to go any higher --
CHAIRMAN CARTER: Would you say that again real loud and
~clear? We do not qualify as a high tourism county?
MS. ASHTON: That just shows you how much more and
larger populated areas even, and we collect as much as we do.
COMMISSIONER MAC'KIE: Well, that's news to me. I
thought we could add a penny if we wanted to for promotion, for
example.
MS. ASHTON: No, we're up to three percent. And that's as
high as we can go. Only one percent for possibly a convention
center or another one percent for a sports franchise facility.
CHAIRMAN CARTER: Are there other options in that list?
Would you have a list of possibilities you might give to us
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January 16, 2001
sometime, Heidi, so that we could -- maybe that's the only two
choices --
COMMISSIONER MAC'KIE: Is that it?
CHAIRMAN CARTER: -- but maybe there are others.
MS. ASHTON: Really, those are the only two choices. There
are two kinds of categories, but I'd be happy to provide you a
memo or something that would outline the other uses and the
other potential one percent. There might be other types of taxes
out there, but as far as the tourist development tax, we've
reached our max under the three percent.
COMMISSIONER MAC'KIE.' I just can't help but mention this,
another plug, if you haven't been to a web site called
Floridagrowth.org that Mr. Weigel -- I'm sorry, Mr. Olliff sent to all
of us recently, it's the comprehensive planning growth
management study on the state level, go, because it's extremely
interesting. But one of the proposals that might come out of that
committee is that the infrastructure be an approved use for
tourist tax.
CHAIRMAN CARTER: You're right, Commissioner Mac'Kie,
you really need to track that. Two things: Make sure what they
do does not negatively affect what we're trying to do in our
Growth Management Plan. So you've got to watch as this thing
evolves. So far, what I read, we're in concert with some other
plusses, if they stay on track. But you've got to watch for the
wiggles that come at the end of these things. So I would
encourage everybody to keep track of that.
MS. ASHTON: Okay, the next question is can the tax be
increased or decreased? And if it were, it would have to be done
by an ordinance amendment, and it would require a four/fifths
vote of the Board of County Commissioners.
The next question is how may tourist development tax
revenues be used? The taxes have to be used as expressly
authorized by the statute. And our governing statute is Section
125.0104, Subsection (5)(A) of the Florida Statutes. And we
currently look at that section, as well as our Ordinance 92-60, as
amended. Our ordinance can further narrow what's allowed in
the Statute, but we can't expand what's in the Statute.
We have generally four categories of uses, and I've
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January 16, 2001
paraphrased them for ease, for if you want to look at the full text,
you can look at the copy of the ordinance and the statute that
I've provided to you. But the first category is to finance the
acquisition, construction or operation of museums publicly
owned or open to the public. The second is to finance the
acquisition, construction or operation of fishing piers publicly
owned or open to the public. The third is to finance beach park
facilities and beach improvement and maintenance activities.
And the fourth is to promote and advertise county tourism within
the State of Florida, nationally and internationally. And that
category also includes special events.
You may have heard in the past reference to guidelines that
the county has. In 1999 we repealed county ordinance adopted
guidelines for the promotion and advertising category, so we
currently have no board adopted guidelines governing those.
And guidelines aren't required to be adopted by the statute; that
was something that the county had for administrative purposes.
But we do have beach guidelines that were adopted in 199:3.
They were adopted by motion of the board, as opposed to an
ordinance which makes it law or a resolution which expresses
policy. I've attached a copy of those guidelines in your package
for your reference. One of the things the guidelines did is it
created the requirement that items go to the City of Naples
beach committee prior to going to the Tourist Development
Council. But those are not binding on you. It reflected the policy
back then. And you can either continue with that policy or not.
It also reflected a statute that's different from today. If you
looked at the guidelines, you'd see beach park facilities and
some of those improvements were not allowed under the
guidelines. And that was how the statute read at the time, it
didn't allow beach park facilities.
COMMISSIONER MAC'KIE: Are there some glitch
amendments we need to be doing there to make our guidelines
match current implementation?
MS. ASHTON: I think because it was adopted by motion, as
opposed to a resolution, that it's not necessary that those be
repealed. You may want to take a look at them at some time and
adopt new policies governing the beach, since they are going to
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January 16, 2001
the beach -- City of Naples beach committee. And that's not
something that's required by statute, that just reflects the desire
of the county.
COMMISSIONER MAC'KIE: I wouldn't want them not to go to
the committee. My question is, are there facilities that are
permitted that we are in fact using tourist tax for that contradict
those guidelines, and we are doing that because these are
merely guidelines? And if that's the case, we ought to clean up
the guidelines.
MS. ASHTON: Well, I think there are some expenditures that
are contrary to the guidelines. But again, if you want, at your
next board meeting you could expressly declare that those are
not -- it's not the policy of this current board. Or you could adopt
other guidelines.
Again, I believe that those guidelines reflected the policy of
the board at that time. And because it was not adopted by
resolution or ordinance, it's not something that necessarily
needs to be officially repealed.
CHAIRMAN CARTER: Would that be something, though, we
should incorporate in the workshop on the TDC and look at that
and give direction at that time, as there may be some other
things, rather than trying to bring it piecemeal? I think I'd like to
look at the bigger picture, and this may be one part of it. And I
appreciate that being raised this morning.
COMMISSIONER MAC'KIE: I'd like not to have a messy
record. I mean, if we can clean it up, let's make it nice and neat.
CHAIRMAN CARTER: Well, we may discover some other
things that will need to be cleaned up.
COMMISSIONER MAC'KIE: While we're cleaning, let's clean
it all up.
CHAIRMAN CARTER: That's right.
MS. ASHTON: The last item I'd like to cover is the Tourist
Development Council. And that is an advisory board to the Board
of County Commissioners. And it's required by statute that they
make a recommendation to this board on any uses, expenditures
of the funds, so if an item comes to you and did not go to the
TDC, we would run the risk that it might be challenged and found
to be an illegal expenditure. And I just wanted everyone to be
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January 16, 2001
aware of why it has to go to them.
I'd like to go to the questions now. The first hypothetical is
an owner of a condominium in Collier County decides to go out of
town for the months of January and February and rent his or her
condominium. Is this rental subject to the tourist development
tax? And the answer is yes. Because it's the rental of living
quarters in a condominium for a period of less than six months.
And if anyone finds themself in this situation, they can go to our
tax collector and fill out a form and submit the tax.
There are some exemptions. The public can contact the
county to determine if they qualify for an exemption.
COMMISSIONER HENNING: Who do they contact within the
county?
MS. ASHTON: Pardon me?
COMMISSIONER HENNING: Who do they contact in the
county?
MS. ASHTON: Well, they could probably contact Greg
Mihalic at the Office of Housing and Urban Improvement, would
be the best person to contact. I believe there's some
exemptions for full-time students and for migrant camp facilities.
CHAIRMAN CARTER: But it's one of those interesting
enforceable issues where less -- you know, a lot of people don't
do that. And how do you enforce it? And --
MS. ASHTON: Really, I think it's more of a Good Samaritan
issue at this point, because I don't think we have the manpower
to enforce it. Although if it were determined that somebody
didn't comply, their -- you know, the criminal punishment would
be a misdemeanor.
CHAIRMAN CARTER: Well, condo management associations
could really help us a lot in this area by following the rules at
this. Because every time you don't do that, you're taking away
from the tax that helps maintain beaches, parks -- MS. ASHTON: Sure.
CHAIRMAN CARTER: -- all the things used by those folks
that we're renting those units to. So all we can do is encourage
their support in this area.
COMMISSIONER MAC'KIE: And collection, am I wrong, is the
tax collector's job? Don't we pay him two percent of the total
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January 16, 2001
tax to collect this money? I'm sure that if anybody's diligent, it's
Guy Carlton getting out there trying to collect it. So that isn't
even within our purview, I don't think. I think that's his job.
MS. ASHTON: The next hypothetical is an editorial in the
Naples Daily News questions why tourist development tax dollars
are not being used for road construction projects. Is this an
appropriate expenditure? And the answer is no, it's not a use
that's expressly authorized under Section 125.0104, Subsection
(5)(A). And I did actually see this editorial, so I thought it was a
good one to refer to.
COMMISSIONER MAC'KIE: I might phrase it differently. It
might be an appropriate expenditure, but it's an illegal one. MR. OLLIFF: Right.
COMMISSIONER MAC'KIE: You know, we might wish we
could, but we can't.
MS. ASHTON: And the last hypothetical is a resident of
Collier County desires to -- desires that tourist development tax
revenues be used to fund a nature center that will be used only
by residents of Collier County. Is this an appropriate expenditure
of tourist development tax funds? And the answer is no, because
it's benefitting only the residents, and tourist development taxes
must be used to promote tourism.
COMMISSIONER MAC'KIE: If, however, there were an
international botanical garden about to come into Collier County
that would attract tourism from all over the world, that is
something that's permitted under the statute to be funded but
not currently listed as a permitted use in our ordinance; is that
true?
MS. ASHTON: That's correct. As I previously mentioned,
our ordinance does not list everything that's allowed under the
statute. A few things in the statute that are not under the
ordinance and would require an ordinance amendment to go
forward is a nature center, a zoological park, or if we decided we
wanted to fund a tourism bureau.
CHAIRMAN CARTER: On the other hand, that still has to
stay under the three cents.
COMMISSIONER MAC'KIE: That's right.
MS. ASHTON: That's correct.
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January 16, 200t
COMMISSIONER MAC'KIE: But in literature, they call it
foreshadowing.
MS. ASHTON: That concludes my portion of the
presentation. If you have any questions, I can either take them
now or I can turn the microphone over to Jacqueline Hubbard
Robinson.
MR. WEIGEL: As Jackie comes to the microphone, I'll
mention she's been with our office less than a year but a very
welcome addition, having previously been seven to eight years
city attorney for Ft. Myers, Board Certified local government law.
COMMISSIONER MAC'KIE: Can I just say that in my
experience, just a very good addition to the staff. Just does a
really good job in giving the bottom line, and that's what I always
like.
MS. ROBINSON: Thank you very much, and good morning to
all of you. I will try and keep my presentation fairly short. I think
Heidi did an excellent job in presenting most of what I would
have just added to.
Basically what I'd like to present to you this morning is to
try and demonstrate for you the kind of legal issues that occur
simply from a request to you to authorize the expenditure of
tourist development tax dollars. And some of these issues are
very difficult issues. They're not very easy.
If you'll turn to Section 5 of your booklet and go about
halfway in, you'll see where my presentation starts with some
color outlays that are similar to the ones that are up there on the
screen.
COMMISSIONER MAC'KIE: Behind the green page.
MS. ROBINSON: Right, behind the green page in the middle
of that Section 5.
First of all, there are a set of charts that follow those little
photographs which basically just outline for you what is in this
section. And there's no need for me to go through those.
The first section is what I call statistical analysis. This
analysis was presented to the Tourist Development Council at
their January 8th meeting. And you may already have this, but if
you don't, it's very important, I think, for you to take a look at it
because it explains to you the manner in which the tourist
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January 16, 2001
development tax revenues have been expended in this past year,
and some of the plans for the expenditure of this revenue in the
coming year.
The first chart shows the various types of projects that were
funded by tourist development tax revenues by category. And
the county has developed these categories, and these categories
appear to be in conformity with the state statute. So in Category
A, you have beach renourishment projects, and these total some
$12,992,900 in the year 2000, and they covered all manner of
types of projects, from cleaning beaches to building facilities on
those beaches. And if you notice, at least one of those projects
was not approved by the DCA but was apparently approved by
the County Commission.
Category B is for advertising/promotion and special events,
and the county expended over two million dollars for
advertising/promotion and special events in the year 2000.
The next category is Category C, which is for museums.
And the county expended $786,400 for museums.
The final category's for disaster funds, and I know you're
going to have a workshop with the TDC, so you may ask them to
give you a little bit more information regarding the disaster
funds. It appears that one million -- over a million dollars was
expended of these funds, and it's not clear from the chart exactly
how they were expended.
The next chart shows you that fortunately for Collier County
the tax revenues collected by year has increased substantially of
tourist development tax revenues. In 1996 the county collected
approximately six million dollars in tourist development tax
revenues. And it's projected by the year 2001, the current year,
that you're going to collect over nine million dollars in tourist
development tax revenues. So this is a very important source of
revenues for the county.
The next chart, if you turn the page you'll see a bar chart,
and it shows that between February, March and April of each
year for the past -- at least from '97, the bulk of revenues come in
within those three months of the year. So those are the high
tourist season months for Collier County.
The next chart is a pie chart, and it shows you that -- of all
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January 16, 2001
the tourist development revenues that come in, at least that
came in for the year 2000. And this is an interesting one to me,
because I didn't realize that it would be quite broken down in this
fashion. But Collier County as a whole provides 51 percent of
your tourist development --
COMMISSIONER MAC'KIE: Unincorporated Collier County.
MS. ROBINSON: Unincorporated Collier County.
And Naples provides 21 percent, and Marco Island provides
26 percent. So that's pretty interesting, I thought.
COMMISSIONER FIALA: Very.
MS. ROBINSON: The final chart is -- it shows you a flow
chart. It's shows you how the revenues come in. And they've
taken one particular month which is the month of November.
And the revenues come in from the various portions of the
county, they go to the tax collector's office, and then they flow
back out to the various projects. And those various projects, as I
said before, do in fact conform with the state statute. So I don't
think there's a problem there.
COMMISSIONER MAC'KIE: Can I ask a question about that,
Jackie? That chart, because I found that really interesting, that
is only a one month?
MS. ROBINSON: That's a one month.
COMMISSIONER MAC'KIE: I'd love to see an annual on that,
because -- I wonder if it holds true, does it, that 80 percent goes
to beaches, about 10 to museums and about nine to advertising
promotion and one to disaster?
MS. ROBINSON: Yes. When I reviewed the charts at that
meeting, it appeared to conform. I think that they have these
percentages that they try to adhere to throughout the whole
year.
COMMISSIONER MAC'KIE: So it's basically 80, 10, nine and
one. I mean, that's pretty easy to remember. And the nine is
lower than I thought.
MS. ROBINSON: Well, that's -- and I'm sure you had a very
interesting discussion with them, because it's such an
interesting area of county business, this tourist development tax
revenue.
So now there are many legal issues that are always
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January 16, 2001
presented. I want to -- and bear in mind three things as
commissioners when matters have gone to the Tourist
Development Council -- and they will make a recommendation to
you regarding whether you should approve these expenditures or
not. But there are three things that you should always keep in
mind as you decide whether or not you're going to approve an
expenditure from the tourist development tax revenues.
First the use of tax revenues should never exceed the
specific purpose for which the tax was created. Now, this is a
rule of law in the State of Florida, but it's also in general a rule of
law in the country for tax revenues, because tax revenues are
considered a very special type of revenue.
COMMISSIONER MAC'KIE: Jackie, is that written someplace
in here?
MS. ROBINSON: At the end -- I have a little chart at the end
that lists everything that I think you should note, and I'll review
that at the very end of my presentation. That is in here. This
isn't. Except by analogy.
In fact, Florida law requires that all tax expenditures to be
spent must be spent only as set forth in the statute that
specifically authorizes the tax. Therefore, if the statute does not
provide for a particular type of expenditure, then the money
cannot be lawfully spent. And it's a very hard rule that they use
here.
Secondly, Collier County has both a two percent tax, tourist
development tax, and that provides for 70 percent of the
collected revenues to be spent for beach park facilities, or beach
improvement.
And then there's an additional one percent tax that's for
beach improvement, maintenance, renourishment, restoration,
and erosion control. So you actually have two separate funding
sources that together make up the three percent, and the
specifics of each have to be adhered to.
And third, tourist development tax expenditures should
conform to your tourist development plan. And there's a tourist
development plan for Collier County that's been in place I think
since '92 it's been amended.
So those three things bear in mind -- if you have a question
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January 16, 2001
about the appropriateness of an expenditure, those three
questions should at least come into mind.
And so occasionally you will be presented with very novel
issues, and you have recently, because I've worked on three
novel issues since I have been here, and I've only been here
about four and a half months. Now -- so I'll talk to you about two
of those. It's really interesting.
One you've already ruled on and decided to do something
about. The other one is there. And the one I'd like to spend the
most time talking about is the Vanderbilt Beach parking garage
facility.
Now -- so a simple request will come in to you, can we use
tourist development tax funds to pay for a parking garage facility
at Vanderbilt Beach. And there are three questions similar to the
process I just described to you that should be asked that came
up with this case. One, does the parking garage fall within the
definition of a beach improvement or beach park facility?
And second, did the parking garage need to be approved by
the Tourist Development Council? Because in this case it
wasn't.
And third, if an expenditure conforms to the plan, does it
matter if it was not approved by the Tourist Development
Council?
In this particular case, we worked -- our office worked very
closely with parks and recreation to get all the background
documents and facts regarding this issue, and we've spent a lot
of time discussing it. We looked for case law that was right on
point to see if we could see -- find a case that said a parking
garage was a beach park facility and could locate none, not in
the State of Florida, anyway.
However, we did locate a couple of Attorney General
opinions, which are not legal opinions, not binding, but can be
used as sort of a guide. And they're based upon a lot of good
research by the Attorney General, so we often use them when
there's no case law appropriate.
In this particular case we did find a couple of Attorney
General opinions that were written prior to the statutory change
that was done by the Florida legislature. And by using those
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January t6, 2001
cases and viewing the language in the changed statute, which,
by the way specifically provided for the expenditure of tourist
development tax funds for parking facilities after -- for beach
park facilities after these matters were decided by the Attorney
General's Office who decided after a request from a county
asking whether they could build a parking garage, was told no,
you couldn't, then the legislature changed the statutes, and we
believe that you can build a parking garage using tourist
development tax funds now. So that was that issue.
The second issue was if the Tourist Development Council
doesn't agree to it and won't recommend the expenditure, can
the county commission go ahead and approve the expenditure
anyway? And there are several ways to look at this issue.
In this particular case with Vanderbilt park -- with the
Vanderbilt parking garage, the Tourist Development Council did
not approve it -- well, not approve, decided not to recommend it.
However, they had previously recommended a parking facility
that was paid for with tourist development revenues. And it
appears from the minute that they didn't even deal with the issue
of whether or not it met the plan or anything, it just wasn't on
their list of priorities and they weren't ready to go forward with it
at that time.
So based upon their prior actions and based upon the
change in the statute, our conclusion was that yes, the County
Commission could build a parking garage and use tourist
development tax funds to pay for it.
There's some other issues involving the parking garage at
Vanderbilt Beach which I won't go into. They have to do with the
manner in which the county acquired that property, which was
by a deed of conveyance from the developer. And in the deed of
conveyance itself it says that it's a gift. This is a gift we're
giving to Collier County. And also, you should note that in that
deed, they have some restrictions on height. You can't build
above 20 feet, et cetera.
Those issues are being dealt with through meeting with the
developers to see if they're willing to agree to let us build a
parking garage. And if they don't, there's probably legal action
that can be taken by the county to avoid those deed restrictions.
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January 16, 2001
So that's one little question that had all those issues. The
other one you've dealt with already, which is the T-groins on
Hideaway Beach. The main issue on that one is whether or not it
was a public expenditure. And the reason why that is important
is because, as I said before, Florida law is very clear that you
may expend tax dollars, but only if tax dollars are being
expended for what is -- can easily be defined as a public
expenditure for a public purpose.
Now, if the public purpose somehow encompasses a private
purpose incidentally, then it's all right. But you can't have an
expenditure of tax dollars for a purely private purpose. And I
think the discussions that you've had along those lines are
certainly in conformity with our opinion from our office on that
issue. And if you have additional questions, both memoranda are
in this handout to you, so you can read it further. And if you have
any questions, I'll be happy to speak with you about those.
Then finally, at the end of the handout for our section, these
are the key issues that I'd like for you to keep in mind regarding
the use of tourist development tax revenues for specific projects.
And yes, these are written.
First the determination of whether a particular project is
tourist related and primarily promotes a purpose, a public
purpose, is a factual determination that must be made by the
Board of County Commissioners. So when a request for
expenditures comes to you, bear in mind that when you accept it
or decide to pay for it, that you will make a finding that it is for a
public purpose and that it promotes tourism.
Secondly, the expenditure of any tax requires this
articulation of the public purpose, so hopefully you'll be in the
habit of articulating a public purpose each time you approve a
tourist development tax expenditure. The primary purpose then
should be to serve the general public, even though you may
incidentally serve members of a private sector.
Now, Section 10 of the Florida Constitution prohibits the
pledging of public funds or the use of the county's taxing power,
or a pledge of the county's credit to aid a private corporation, an
association or partnership or any private person. You have to
bear that in mind. Because this is the language that always
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January 16, 200t
shows up when a private citizen decides to contest an
expenditure, and they go into court to sue the county, they're
going to say that you violated the Florida Constitution because
you have approved expenditures that are going to benefit a
private person and not the public. So you have to bear that in
mind.
Fin -- also, tourist tax revenue expenditures must fall within
the tourist development plan approved by the County
Commissioners and the Tourist Development Council. If it's not
approved by the Tourist Development Council but it's in the plan,
then your majority vote is fine. If it's not approved by the Tourist
Development Council and it's not in the plan, and you wish to go
forward on a project, then that requires a super majority vote and
an amendment of your plan to include what it is you want to
build. All right? That's very important.
And Florida law requires that taxes may be assessed and
collected only in a manner prescribed by statute.
And finally, once the tourist development plan has been
enacted, it may not be substantially changed, unless you go
through the method that I just spoke to you about. And that concludes my presentation.
COMMISSIONER MAC'KIE: Any questions, board members?
All right, thank you, Jackie. Very good.
MS. ROBINSON: These are some handouts I'd like to hand
out to you. And there are a couple of determine memoranda
regarding the use of tourist development funds that you might
find interesting.
COMMISSIONER MAC'KIE: Thank you.
David, what's next?
MR. WEIGEL: Well, we're really almost done. Thank you.
I want to say that this opportunity to talk a little bit about
this topic of civil emergencies is what I'd like to say is to let you
know that you're with the good hands people. You always knew
that, of course, with the county manager's emergency operations
center, what good care they take of you. And we certainly do
work with them in a coordinated way. And this is an opportunity
for us outside of the normal emergency weather schedule in the
spring when I know that emergency -- the emergency services
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January 16, 2001
divisions is going to be addressing you specifically. They asked
and we were delighted that they could jump in with us, and so
Ken Pineau and I'll both talk to you briefly about civil
emergencies.
Now, in the large green book you have, Tab No. 6, it doesn't
have a lot of backup. Well, why? The reason is if we'd given to
you all the backup that we'd like for you to have, it would have
made that book almost unwieldy.
On August 23rd of this past year, our office created and we
provided to all of the commissioners a civil emergencies
workbook, law and procedures, and we're flattered to know that
with the commissioners that have left, they evidently took them
with them, because they're not around anymore.
So we created these again, and these are provided with you
as ancillary to your green workshop book that you have. And so
everything that I'm going to be talking about comes from the blue
book, or the white book, as yours may be, as opposed to the
green book.
Now, what do we have when bad things come to Collier
County? Well, we may have a situation calling for a declaration of
state of emergency. The red tab on your blue or white book, if
you pull that open, will take you, if the get to the right side of the
page, will take you to the ordinance definition of a declaration of
emergency. And this is Ordinance 84-37, adopted by the Board of
County Commissioners in 1984.
As you can see on the lower left page, the definition of
emergency is any occurrence or threat thereof, whether
accidental, natural or caused by man, in war or in peace, which
results or may result -- which results or may result in a
substantial injury or harm to the population, or substantial
damage to or loss of property.
Put that back into modern terms, if we're not talking about
severe weather, then we may be talking about fire. And tis the
season for at least one of those right now.
When there is in fact emergency conditions, they don't just --
the conditions may exist, but they have to be formally recognized
at the local legal.
Now, the State of Florida, through Chapter 252 of the Florida
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January 16, 2001
Statutes, has quite a number of statutes talking about state of
emergency. The Governor has significant power, although the
Governor's powers are somewhat limited in regard to local
application. The Governor can declare a state of emergency; he
can declare it for the whole state, for part of a state, for a region,
depending on whatever the issue may be. They did it a couple of
years ago in regard to the fires that were occurring in various
places of the state.
But when it gets right down to local government and the
conditions in Collier County, the Board of County Commissioners
has significant power and of course responsibility in regard to
emergencies.
It takes an act to the board to declare an emergency. But if
the situation is such and the timing is such that a full quorum of
the board cannot meet to declare an emergency, on the very
same page where the declaration of state of emergencies is
shown, specifically provides for the order of hierarchy of
authority to declare an emergency. If you can't get a quorum of
the board, then the chairman of the board can so declare. If the
chairman's unavailable, the vice-chairman may declare it. If the
vice-chairman is unavailable, the county manager may declare.
And so it goes.
The extent of the statement of emergency, this is done by
what we call a proclamation/resolution. It is a proclamation
that's defined by state statute. Resolution is what works with
the clerk's office. So you will see some exemplars in this binder
that you have of just those very things, harking back to 1992,
Hurricane Andrew, and two years ago, I guess it was, Georges, or
whatever it was, it was either a hurricane or a tropical storm.
Georges.
But the fact is, is that we work hand in glove with the
county manager and of course the emergency operations center
to have these things prepared and ready to go, so whomever is
the declarant on behalf of the Board of County Commissioners,
these things can be enacted and go in place.
A local state of emergency lasts for seven days, is subject
to renewal, but is never anything that stays in place indefinitely.
Now, if I speak too much, I'll talk over what Ken Pineau is
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January 16, 2001
going to tell you. But included in this ordinance is the policy for
closing down county operations. And the policy for closing down
county operations includes responsibilities of the county
manager, some employee responsibilities, obviously there are
capital facilities as well as safety management functions that
county staff has on a regular daily basis. And these things are
not lost in the lurch when it comes time for state of emergency.
I won't go into the detail on that. If you have questions, I'd
probably ask you to direct those to either Tom Olliff or Ken
Pineau. But those are part of what's in your backup here. And so
I hope that this binder will in fact be a handy reference for you.
Couple more things and then I'll step aside. In 1998, the
board adopted Ordinance No. 98-62, which does address
recovery, reconstruction, some mitigation activities, facilities
restoration, and debris clearance. This was something we did
hand in glove in working with our Growth Management Plan, at
which also had an ordinance adopted. The plan had an
ordinance adopted by the board affecting it in 2000. And that's
Ordinance 2000-27. And that addresses the maintenance or
reduction of hurricane evacuation times, and also provides a
definition of the coastal high hazard areas, as specifically
applied in Collier County.
With that, again, we hope that we've provided you the
assurance, not only on this topic but the other topics, that you
are in good hands. But when it comes to time of emergency, our
office stands right up there with the other offices to see to it that
the governance that you provide is as seamless as possible. And
Ken?
MR. PINEAU: Good afternoon, commissioners. I'm Ken
Pineau, your emergency management director for the past 13
and a half years.
I'd like to give you a brief overview of your responsibilities
as it pertains to Chapter 252 of the Florida Statutes, otherwise
known as the State Emergency Management Act. Last year this
was rewritten, and I'll go through some of the substantive
changes as we go along through my presentation.
I'd also like to brief you on your emergency management
powers during emergencies, the powers of the Governor, states
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January t6, 2001
of local emergency and our mutual aid agreement that we have
with other communities.
As the governing body for Collier County, you have innate
responsibilities for the protection of the lives and property of not
only the citizens, but the guests to Collier County to the
maximum extent possible. This includes the entire jurisdictional
limits of Collier County.
In order to accomplish this, each county must have an
emergency management department that has jurisdiction over
and serves the entire county. The department must have an
emergency management director, which is appointed by the
governing body or, as it was just recently changed last year, to
the chief administrative officer, the county manager. And the
emergency management director serves at the pleasure of that
appointing body.
The director has the direct responsibility for the
organization, administration and operation of the emergency
management agency. In addition, the director has the
responsibility for serving as a liaison with not only the Florida
division of emergency management, but all other emergency
management agencies within the state and the country.
When disasters or emergencies exceed the capabilities of
the local jurisdiction, as Mr. Weigel mentioned, we should issue a
state of local emergency. That not only accesses state
assistance, but also it triggers the mutual aid response that we
can get from other communities.
What we normally try to do is have the -- a proclamation
pre-crafted prior to the event of a hurricane. Now, all the other
emergencies like weapons of mass destruction and brush fires,
this occurs obviously afterwards.
The state of emergency, as Mr. INeigel mentioned, has a
period of seven days. We've never been -- we've never had the
opportunity to extend that. Although I think back in 1992 we
probably should have, but it was slipped by in the process. That
was probably due to my fault.
The state of local emergency allows the county to waive the
normal competitive bid procedures and formalities otherwise
required by law pertaining to public works, the performance of
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January 16, 2001
public works, entering into contracts, incurring obligations, use
of volunteers, rental of equipment, acquisition and distribution,
with or without compensation of complies, materials and
facilities.
Now, something new that came up this year as a result of
the new update of the Chapter 252, upon the request of the
emergency management director, Collier County public schools
has to provide sheltering facilities, as well as staff, to man these
facilities. They also shall provide transportation assistance for
emergency evacuation when required.
Now, let's go into the emergency management powers of the
Governor. In major or catastrophic disasters beyond Collier
County's control, Governor Bush may assume direct operational
control over all or any part of the emergency functions within the
state or portions of the state. These emergency powers,
however, can be delegated. The Governor may issue an
executive order which triggers a state of emergency for portions
of the state. This state of emergency normally lasts for 60 days,
but that has been extended on occasion. As Mr. Weigel
mentioned, the brush fires up in the northeast Florida area a
couple of years ago, that went on and on and on for a period of
several months.
The executive order shall activate the mitigation response
and recovery aspects of state-wide emergency management
plans.
Now, for -- something else has come up. The definitions of
minor, major and catastrophic disasters. Well, a minor disaster
is something that we can handle on our own. It's probably
nothing more than an emergency. A major disaster is something
that will require not only state assistance but some federal
assistance.
And something that has been addressed with the new
update to Chapter 252 is that licensed medical professionals, the
doctors and nurses that are licensed in the other states, will also
have the right to practice in the State of Florida, if there has
been a major disaster declared.
A catastrophic disaster is an automatic assumption to the
President of the United States that federal military forces will be
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January 16, 2001
required. The last time we had to activate that of course was
Hurricane Andrew in Miami/Dade.
The Governor, some of his responsibilities, he can order a
mandatory evacuation from a threatened area. He can define
evacuation routes, although our routes are pretty well defined
here. We really don't have that many of them. He controls
ingress and egress into a disaster area; he can suspend the limit,
sale or transport of alcoholic beverages, firearms and explosives;
make provisions for temporary emergency housing; take
measures for limiting gas, water and electric power distribution
in the general public interest. That's also something new that's
been identified this year. He could also establish curfews in the
disaster area; he authorizes the use of forces and cleanup in
recovery operations when proper permission to enter private
property has been attained.
Now, mutual aid agreement -- and I'll just wrap this up -- we
recently signed the state-wide mutual aid agreement. Not only
with the other 66 counties in the 400 and so municipalities in the
state, but every independent district in the State of Florida has
the potential to sign the agreement. Now, we're getting them
from the independent fire districts now that have gone up to the
state. And this allows us to either provide assistance to other
agencies, like we have in the past. In 1992 we provided a lot of
assistance to Miami/Dade during Hurricane Andrew. In 1994 we
went up to Washington County as a result of Tropical Storm
Alberto to provide some emergency management assistance
there. And I believe in 1996 in Hurricane Opal, some of the folks
from our domestic animal department also provided some
assistance up in the Pan Handle.
So the mechanics are in force. It's pretty self-explanatory.
It's an excellent mutual aid agreement, I believe. And not only
for the State of Florida, but there is a nationwide emergency
management compact, and through the State Division of
Emergency Management we may also be called to provide
assistance in roughly 35 states right now, as well as the
Commonwealth of Puerto Rico and some of the other
independent agencies.
Under the state-wide mutual aid agreement, we must render
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January 16, 2001
assistance, when requested, to the fullest extent possible,
depending on our manning situation here. We try to do our best
to honor those requirements.
That, commissioners is a brief overview of the board and
Governor's responsibilities during emergencies. If you have any
questions, I'd be happy to answer them.
COMMISSIONER MAC'KIE: I have just one.
MR. PINEAU: Yes, ma'am.
COMMISSIONER MAC'KIE: When we are asked to declare a
state of local emergency and we get to the meeting and the
proclamation's already prepared, I noticed here that we have the
power to do a lot of things in that proclamation. Is that the place
where we would do it? As has been explained to me in the past,
the usual effect of that declaration of emergency is to prevent
price gouging, to open shelters and to -- and that's about it. MR. PINEAU: Yeah. I --
COMMISSIONER MAC'KIE: So do you make the decision
based on experience or based upon on a protocol about which of
these -- I mean, we could suspend the sale of alcohol, we could
set curfews, we could do a lot of things.
MR. PINEAU: I'm not sure if we can do that anymore,
according to the statutes.
COMMISSIONER MAC'KIE: Is that what you're telling us?
MR. PINEAU: Right.
COMMISSIONER MAC'KIE: Okay. Because that's new.
MR. PINEAU: Unless it's delegated by the Governor.
COMMISSIONER MAC'KIE: But at this point -- when was that
statutory changed then?
MR. PINEAU: It came out in 2000, the latter part of 2000.
COMMISSIONER MAC'KIE: So the only authority left to the
County Commission now, unless the Governor should delegate it,
is what?
MR. PINEAU: Actually, the only powers that you have right
now is to eliminate the normal competitive bid procedures and
for the performance of public works, entering into contracts --
COMMISSIONER MAC'KIE: That's it?
MR. PINEAU: -- incurring obligations. That's basically--
COMMISSIONER MAC'KIE: We --
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January 16, 2001
MR. PINEAU: -- according to the --
THE COURT REPORTER: Excuse me?
COMMISSIONER MAC'KIE: Sorry.
We can't prohibit price gouging?
MR. PINEAU: There's nothing in the statutes that says that
you can or cannot, that I'm aware of.
COMMISSIONER MAC'KIE: And what about, is there
anything that says we can establish shelters?
MR. PINEAU: Shelters I think is part of doing business, I
think. That's--
COMMISSIONER MAC'KIE: So what we have here in this --
mine's a white book -- that David gave us, the code book, Civil
Emergencies, the first -- Chapter 38, which is the local ordinance
on emergencies, do we need to revise, because it's very much
behind the curve now with this new 2000 statutory change.
Because we can't do -- we can do about 20 percent of what it
says we can do in this -- in our ordinance. So it sounds like
something we need to review.
MR. WEIGEL: I think we do need to review it. I'm a little
less circumscribing of the local powers under the new statute.
And by the way, the resolution proclamations that we did in
the past were more for information purposes, because price
gouging was automatically in place when the board declared --
COMMISSIONER MAC'KIE: So how does that happen
automatically, David? That was really my question. Which of
these -- assuming, and in the past apparently we did have this
list of 10 --
MR. WEIGEL: Yeah.
COMMISSIONER MAC'KIE: -- emergency measures that
could be implemented by declaration of local emergency. How
did we know which of those were automatically included and
which were not?
MR. WEIGEL: Well, the ones that we didn't include typically
in the resolution were ones that would take an action from the
board. For instance, declare certain areas off limits to all but
emergency personnel, which is sub 4 of that category of about
10.
COMMISSIONER MAC'KIE: And maybe I'm beating this horse
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January 16, 200t
to death, but if you look under the tab, David, for the
proclamation resolution stuff-- MR. WEIGEL: Right.
COMMISSIONER MAC'KIE: -- it listed things like evacuation
and shelters and work schedules, but it didn't say anything about
price gouging or -- it made me worried that there might be a little
glitch in the translation there. MR. WEIGEL: No --
COMMISSIONER MAC'KIE: How do we know which of those
10 powers we are exercising upon the adoption of a resolution?
MR. WEIGEL: Well, okay, if you -- what you're looking at I
think is the first page of the resolution. But if you go to the
second page, just above the signature area, where the eight
categories, including--
COMMISSIONER MAC'KIE: I think that's just the one that
talks about procurement policies.
MR. WEIGEL: I know it's in there. Here it is.
Be it further resolved, to the top of the second page. It's in
the action part of the ordinance -- of the resolution, where the be
it further resolved and proclaimed it's unlawful and offensive in
Collier County for any person to charge more than a normal
average retail price.
COMMISSIONER MAC'KIE: Thank you. So that --
MR. WEIGEL: We've made it a habit of always having that
there so it's an action item or informational item for anyone that
sees this resolution, because not everyone sees the ordinance
that's out there.
COMMISSIONER MAC'KIE: So if, God forbid, we have an
emergency with the fire in this season or a hurricane, will we no
longer -- you need to tell us if we're going to no longer have the
authority to do that. And, you know, what exactly we have the
authority to do. It's a little troubling. Because those are
important powers.
MR. WEIGEL: Well, it is. As I mentioned, I'm not of the
opinion that we've absolutely lost these in reconciling this with
the amendment that came with Chapter 252 this year.
COMMISSIONER MAC'KIE: So maybe we'll look at that, and
if you see that we have problems, it's something that we'd want
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January 16, 2001
to put --
MR. WEIGEL: We'll bring it forward --
COMMISSIONER MAC'KIE: -- before our legislature.
MR. WEIGEL: Yeah.
COMMISSIONER MAC'KIE: Because we can't not have those
really important local powers for a local emergency. MR. WEIGEL: Right. Very good.
MR. OLLIFF: But nothing that Ken indicated affected our
ability to have a local ordinance that affects the price gouging
portion of that. The changes to the statute were primarily more
for the shift in responsibility from local to the Governor's Office
in terms of issues like being able to establish curfews and being
able to ration the sale of fuels, explosives and alcohol and those
kinds of thing. Which to my recollection, Ken, I don't recall that
this local body has ever actually enacted any of those type of
issues. So I think the things that we traditionally have always
decided upon are still available for local --
COMMISSIONER MAC'KIE: And if --
MR. OLLIFF: -- decisions.
COMMISSIONER MAC'KIE: -- that's the case, I would again,
for housekeeping, would want our ordinance to be amended to
match the state law so that we don't think we have the ability to
suspend the sale of firearms if we don't.
MR. OLLIFF: And keep in mind, the board also still continues
to have under state statute the health, safety and welfare
responsibilities for the community. And the county's emergency
operation center and emergency management director has
certain responsibilities during a case of an emergency that are
outlined by statute as well, and we become the coordinating
agency for a large number of other public safety agencies in the
area.
COMMISSIONER MAC'KIE: And the last comment I had was
just whether, Tom, you've looked at -- and when Mr. Fernandez
was here, I was happy that he had established these procedures
of, you know, who's in charge of what during an emergency
county policy during emergencies in March of '98. I just thought
that is so important, that it would be worthy of your review to be
sure you agree with the way it was set up.
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January 16, 2001
MR. OLLIFF: And some of that may need to be amended,
based on recent reorganizations.
COMMISSIONER MAC'KIE: That's all I have. Does anybody
else have questions?
COMMISSIONER HENNING: I just have one comment. The
emergency management's web page is really awesome.
COMMISSIONER MAC'KIE: Uh-huh.
COMMISSIONER HENNING: It's one of the best.
MR. PINEAU: Gary Arnold has probably developed the best
emergency management web page in the country.
COMMISSIONER HENNING: It should be a nationally award --
MR. PINEAU: It has been recognized twice nationally.
MR. OLLIFF: I will tell you, there are certain things county
government has traditionally done well, and emergency
management is one of those. And a lot of that credit goes to
Ken. But I do want to -- the board as part of this to understand,
especially as brush fire season is upon us, and what's the index
now, Ken?
MR. PINEAU: 552 today, which is getting to be close to the
critical stage.
MR. OLLIFF: And as some of these issues, generally we're
always dealing with either hurricanes and/or brush fires, just
depending on which time of year it is, we will call on you to
establish declarations of emergency, when the necessary -- when
the need arises.
And just from a practical standpoint, we will ask to you
meet downstairs in the emergency operations center where we
are set up down there to actually have a makeshift County
Commission meeting, which can be televised from that location,
where we will ask you then to adopt a resolution proclamation
declaring that state of emergency and put things into effect.
But a lot of that is just we wanted to you know location-wise
and hopefully as part of your orientation tour, you got a feel for
where those meetings occur, where the other agency heads sit
and where those decisions get made. But as some of these
things occur, I think we would suggest that you probably come
down and actually sit and spend some time in the EEOC, just so
that you can get a feel for how some of that decision-making
Page 93
January 16, 2001
gets made, because I think it will help you as you go along in
your tenure.
COMMISSIONER MAC'KIE: It's fascinating, anyway. It's
really fascinating.
MR. OLLIFF: Thank you, Ken.
MR. WEIGEL.' I'll just mention that we're very pleased that
you could allow us to meet with you today and make this
presentation.
We have as a postscript in your binder ordinance information
about board meetings and reconsideration. It's fairly
self-explanatory. We're happy to continue, but we're also just
happy to see if you'd like to read it and get back to us, that
would be wonderful, too. I know we've had the opportunity to
talk with a few of the commissioners one-on-one in regard to
those items.
COMMISSIONER MAC'KIE: Are there any questions, board
members have? This would be a good forum, if anybody has any
other reconsideration.
COMMISSIONER HENNING: Which tab is that, seven?
MR. WEIGEL: It's tab seven in the book there.
COMMISSIONER MAC'KIE: Just the -- I know there are
exceptions, but in general, the deadline for bringing an item back
for reconsideration is 30 days?
MR. WEIGEL: That's right. It does state in the ordinance, no
motion for reconsideration shall be made later than 30 days from
the initial determination. With our current two meeting a month
type of board meeting arrangement, that makes it incumbent
upon the commissioner to provide their memo request for
reconsideration to the county manager at least six days before
that second meeting following the meeting where an action was
taken.
COMMISSIONER MAC'KIE: In other words, you have about a
week after a meeting to decide if you want to reconsider or not,
if you voted in the majority. And if you do, get it to Tom fast.
MR. WEIGEL: That's right. And you may have up to two
meetings to do that memo, but it always has to be at least six
days prior to the meeting. And then if the board does vote to
reconsider, the matter shall come back -- the matter in chief will
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January 16, 2001
have come back two regularly scheduled meetin.qs later.
COMMISSIONER MAC'KIE: Any other questions on that?
Anything else on our agenda?
MR. OLLIFF: Notathing.
COMMISSIONERMAC'KIE: Any other questions in general,
board members, or are we going to go eat our lunches?
COMMISSIONERHENNING: Motion to adjourn.
CHAIRMAN CARTER: Thank you very much tothe county
attorney's office for a really informative presentation, and we'll
adjourn.
There being no further business for the good of the County,
the meeting was adjourned by order of the Chair at 12:45 p.m.
BOARD OF COUNTY COMMISSIONERS
BOARD OF ZONING APPEALS/EX
OFFICIO GOVERNING BOARD(S) OF
SPECIAL DISTRICTS UNDER ITS CONTROL
ATTEST:
DWIGHT E. BROCK, CLERK
Page 95
January 16, 2001
These minutes approved
presented ~//
by the Board on ~//~/~--J- ...... ,
TRANSCRIPT PREPARED ON
REPORTING SERVICE, INC.~
PUBLIC
or as corrected
as
BEHALF OF GREGORY COURT
BY CHERIE' R. LEONE~ NOTARY
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