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DSAC Minutes 12/07/2016 December 7, 2016 MINUTES OF THE MEETING OF THE COLLIER COUNTY DEVELOPMENT SERVICES ADVISORY COMMITTEE Naples, Florida, December 7, 2016 LET IT BE REMEMBERED, the Collier County Development Services Advisory Committee in and for the County of Collier, having conducted business herein, met on this date at 3:00 P.M. in REGULAR SESSION at the Collier County Growth Management Department Building, Conference Room #609/610, 2800 N. Horseshoe Drive, Naples, Florida, with the following members present: Chairman: William J. Varian Vice Chairman: Blair Foley David Dunnavant James E. Boughton Clay Brooker Dalas Disney Chris Mitchell Robert Mulhere Mario Valle Stan Chrzanowski Norman Gentry Marco Espinar Ron Waldrop (Excused) Laura Spurgeon DeJohn Jeremy Sterk ALSO PRESENT: Jamie French, Deputy Department Head Judy Puig, Operations Analyst, Staff Liaison Eric Fey, Sr. Project Manager, Public Utilities Caroline Cilek, LDC Manager Mike Ossorio, Director, Code Enforcement Division Matt McLean, Director, Development Review Stephanie Amann, Manager, Financial & Operational Support 1 DEVELOPMENT SERVICES ADVISORY COMMITTEE AGENDA December 7, 2016 3:00 p.m. Conference Room 610 NOTICE: Persons wishing to speak on any Agenda item will receive up to three (3) minutes unless the Chairman adjusts the time. Speakers are required to fill out a "Speaker Request Form," list the topic they wish to address, and hand it to the Staff member seated at the table before the meeting begins. Please wait to be recognized by the Chairman, and speak into a microphone. State your name and affiliation before commenting. During discussion, Committee Members may direct questions to the speaker. Please silence cell phones and digital devices. There may not be a break in this meeting. Please leave the room to conduct any personal business. All parties participating in the public meeting are to observe Roberts Rules of Order, and wait to be recognized by the Chairman. Please speak one at a time and into the microphone so the Hearing Reporter can record all statements being made. I. Call to Order-Chairman II. Approval of Agenda III. Approval of Minutes from November 2, 2016 IV. Public Speakers V. Staff Announcements/Updates A. Code Enforcement Division update—[Mike Ossorio] B. Public Utilities Department update— [Tom Chmelik or designee] C. Growth Management Department Transportation Engineering Division & Planning Division updates—[Jay Ahmad or designee] D. Collier County Fire Review update—[Shawn Hanson and/or Shar Hingson] E. North Collier Fire Review update—[Dale Fey] F. Operations & Regulatory Mgmt. Division update—[Stefanie Amann] G. Development Review Division update—[Matt McLean] VI. New Business A. Reduced Discharge Rates [Jerry Kurtz] B. LDC Amendments [Caroline Cilek] VII. Old Business VIII. Committee Member Comments eX. Adjourn 2017: January 4, 2017 GMD Conference Room 610—3:00 pm February 1, 2017 GMD Conference Room 610—3:00 pm March 1, 2017 GMD Conference Room 610—3:00 pm Page 1 of 1 December 7, 2016 Any persons in need of the verbatim record of the meeting may request a copy of the audio recording from the Collier County Growth Management Department-Contact Mr. Evy Ybaceta at 239-252-2400. I. Call to Order-Chairman Chairman Varian called the meeting to order at 3:00pm II. Approval of Agenda Mr. Dunnavant moved to approve the Agenda. Second by Mr. Foley. Carried unanimously 10-0. III. Approval of Minutes from November 2,2016 Meeting Mr. Disney moved to approve the minutes of the November 2, 2016 meeting as presented. Second by Mr. Sterk. Carried unanimously 10- 0. IV. Public Speakers None Mr. Mitchell arrived at 3:02pm Mr. Mulhere arrived at 3:03pm V. Staff Announcements/Updates A. Code Enforcement Division update- [Mike Ossorio] Mr. Ossorio provided the report"Collier County Code Enforcement Division Blight Prevention Program - Cumulative Code Enforcement statistics- 7/2009—9/11/2016"for information purposes. He noted: • Staff continues to participate in Level 1 and other training sessions. • A new conference room is available for use by Staff for mock Code Enforcement hearings, training,etc. • The Division is increasing their presence in the Bayshore area given the US National Pickleball Championships and other tournaments are now held at East Naples Community Park. Mr. Gentry arrived at 3:05pm B. Public Utilities Division update- [Tom Chmelik or designee] Mr. Fey reported: • A new"inbox" has been created at"collierutilities.net" for correspondence regarding ability to serve letters, etc. • A new template has been developed for"availability letters" for water and waste water service and Staff intends to expand the activity to include a template for Florida Department of Environmental Protection letters to reduce the likelihood of delays. • Staff will be reviewing and recommending changes to the utilities conveyance process over the coming months. C. Growth Management Department/Transportation Engineering and/or Planning-[Jay Ahmad or designee] None 2 December 7, 2016 D. County Fire Review update— [Shar Hingson and/or Shawn Hanson] Ms. Hingson reported: • Jackie de la Osa(Collier) and Ted Ross(Tice)were named State Fire Inspector and Fire Marshal of the year respectively. • The Fire Alarm Committee is working on policy changes. • Inspections and plan reviews are on a 2— 3 day turn around time frame. E. North Naples Fire Review update—[Dale Fey] Mr. Fey reported 478 plan reviews were conducted last month with a 7 day turnaround time and inspections are currently on a 2—3 day schedule. F. Operations & Regulatory Mgmt. Division update [Ken Kovensky] Ms. Amman submitted the"Collier County November 2016 Monthly Statistics"which outlined the building plan and land development review activities. The following was noted during the report: • The consultants conducting the Fee Study have initiated their work including a site visit. • Inspections were at an average of 907/day last month. G. Development Review Division update [Matt McLean] Mr.McLean and Mr. French reported • The rate of plats being recorded is decreased and Staff is monitoring the trend — The Committee requested Staffprovided data on the trend of the recording over historic time periods. • There are currently 45 job bankers employed in the Division and Staff is monitoring business activity to determine any changes which may be required to sustain an acceptable level of service. • Rich Long has been appointed to the position of"Building Director." • CityView has a mobile app available for those who wish to use the service. VI. New Business A. Reduced Discharge Rates [Jerry Kurtz] Mr.Kurtz and Emilio Robau presented the PowerPoint "Collier County Additional Basin Restricted Allowable Discharge Rates"noting: • In 2015, Staff began an initiative to revise the discharge rates in the County basins. • The purpose was to increase Levels of Service (LOS) for flood protection provided by South Florida Water Management District and Collier County operated canals and improve quality issues in these areas. • The proposal was developed by a team that included Members of County Staff, representatives of Big Cypress Basin,meetings with individual members of DSAC, etc. and creates 16 additional discharge basins to the 6 already in place. • The study included performing a comprehensive evaluation of the potential areas to be affected by implementation of the new discharge rates in each basin and analyzing the potential financial impacts for future developments and redevelopment. • Single family home sites are exempted from the required discharge rates. • The changes will be forwarded to the CCPC and the BCC for consideration and intended to be incorporated into the Code of Laws and Ordinances. 3 December 7, 2016 • The rates will be applicable to new development and redeveloped areas(areas proposing improvements greater than 50 percent of the existing value). • He is seeking a recommendation from the DSAC on the proposed changes. Mr. Valle arrived at 3:25pm Some Committee Members noted: • The requirements for redevelopment may substantially impede or penalize those proposing reconstruction given their existing site conditions provide for certain discharges. • They is an equity question for those properties not yet developed that need to conform to the new rates when properties adjacent or in the vicinity previously developed were not required to abide by the rates. • The redevelopment issue emphasizes the need for the County to review any LDC requirements for those property owners wishing to redevelop properties. Mr. Robau reported: • The 50 percent existing value requirement is similar to the current requirements in the LDC for redevelopment. • Collier County Ordinance 2001-27 that addresses allowable post discharge formulas for County canals allows for"variances"and states"Variations to the above requirements may be allowed by County Staff approval based upon special engineering studies prepared by a Registered Professional Engineer. Unless otherwise specified by the previous SFWMD permits or SFWMD criteria, a stormwater event of 3 day duration and 25 year return frequency shall be used in computing off site discharge rates. Allowable discharges will be designated by SFWMD on a case by case basis upon request. This language should aid in addressing the redevelopment discharge rate concerns. • The results of the financial analysis indicate: • The increased cost to a 12 acre commercial development site is 1.47 percent(mainly due to fill material costs). • The increased cost to a 430 acre residential development is 4.42 percent(which could be reduced to 1.85 percent if onsite stormwater retention lakes were excavated deeper than 12 feet increasing the amount of fill material available on site). • The option of deeper on site retention lakes is generally not available to commercial sites given they are much smaller in size. • The SFWMD currently does require reduced discharge rates on projects when necessary and the proposed requirements are not intended to be punitive but provide the following benefits: • Addresses concerns on the current Levels of Service(LOS) for flood protection. • Enhances groundwater recharge opportunities and improves hydrology for wetlands. • Reduces pollution through source capture. • Improves water quality of receiving waters and reduces freshwater flows to estuaries. • Provides consistency in Environmental Resource Permitting(SFWMD and County) and fulfills Growth Management Plan commitments. Staff noted: 4 December 7, 2016 • Other options such as deepening and widening the existing canal system throughout the County are not feasible given their current state of development. • Other areas of Florida are experiencing the same issues and reducing allowable discharge rates in basins. • When the canals system was originally developed it was never envisioned to handle the current volume of discharge experienced throughout the region. Speaker Ryan White, Davidson Engineering posed questions with Mr. Robau noting the financial analysis yielded no loss in development potential for the sites,water will be detained on site for a longer period of time with the new requirements and PUD's with appropriately vested permits will not be subject to the new requirements. Josh Nageon De Lestang, Big Cypress Basin addressed a question posed by the Committee on the criteria used to determine when the canal weirs should be"fully"opened to control flooding during a major storm event. The SFWMD Staff is responsible for the decision and it occurs on a case by case basis following detailed deliberations during an anticipated storm event. One concern affecting the deliberations is releases of large volumes of water during October/November of a given year substantially drawdown the water in the system with little chance of recovery until the next rainy season. Mr.Mulhere moved to endorse the report and its findings. Second by Mr. Foley. Carried unanimously 14—0. Mr. Mulhere moved to recommend the Board of County Commissioners approve the proposed discharge rates as presented by Staff. Second by Ms.Spurgeon DeJohn. Motion carried 11 `3'es" —3 "no." Mr. Disney,Mr. Dunnavant and Chairman Varian voted "no." B. LDC Amendments [Caroline Cilekj Ms. Cilek provided a Memo to the DSAC dated November 30, 2016 and the "2016 Cycle LDC Amendments Summary Sheet with Advisory Board and Board Recommendations" which outlined the request for two recommendations for proposed Land Development Code Amendments as follows: Stormwater Management S': 6.(1 .01 Water Marta Yement Re uire epts 6,05.03 Stormwater Plans for Single Family Dwelling Units,Two-Family Dwelling Units,and Duplexes. The amendment expands the requirement for a stormwater plan for all new buildings, additions, or redevelopment of single-family dwellings,two-family dwellings, and duplexes. Mr. Foley,DSAC-LDR Subcommittee provided an overview of the propose changes noting the Subcommittee met several times to develop the changes which include requiring all impervious areas on site be considered as opposed to solely building roof areas,establishing criteria for the types of stormwater plans required for different regions based on percentage of impervious areas covered, addressing owner/builder requirements for the plans, etc. Mr. Foley moved to recommend the Board of County Commissioners approve the proposed amendment as presented by Staff. Second by Mr. Valle. Carried unanimously 14—0. December 7, 2016 Golf Course Conversion Mr. Mulhere stated he was abstaining from the item as he has a conflict of interest. LDC SECTION(S): 5.05.15 Conversion of Golf Courses The amendment introduces a new section in the LDC to assess and mitigate the conversion of golf courses to a non-golf course use. Mr. Brooker, DSAC-LDR Subcommittee reported the amendment was prepared by Staff at the direction of the BCC. He provided an overview of the proposed changes noting the Subcommittee met several times to review the proposed amendments and expressed the following concerns: • In addition to the general LDC requirements for rezones,the process involves Stakeholder outreach meetings, developing a web site, a financial analysis on the existing land use,etc. items not required by other applicants proposing zoning changes. • The redevelopment requires provision of a"Greenway"adjacent to existing residential uses with access for off site property owners(who currently do not have legal access to the property) incurring a general encumbrance and liability for the existing or future property owner. • Raises fundamental equity questions on the affected owner's property rights in comparison to other landowners proposing redevelopment in the County. • The proposed amendment may be"over reaching" given Staff reported to the Board of County Commissioners at the time the directive was issued there are sufficient criteria in the existing LDC to address the conversions. During Committee discussion it was noted the conversion issue may not be highly prevalent in Collier County as most of the existing golf courses are found in private, gated communities not suited to conversion given the current layout of the established neighborhoods. The Members of the Subcommittee present reported they had not developed a formal recommendation for the DSAC on the proposed amendment. DSAC-LDR Subcommittee Recommendation-(Mr. Brooker, Mr. Foley and Mr. Mulhere) Mr. Brooker moved for Subcommittee to recommend the Development Services Advisory Committee recommends the Board of County Commissioners not approve the proposed amendment as presented by Staff. Second by Mr. Foley. Carried unanimously 2—Q Mr. Mulhere abstained due to a conflict of interest. DSAC Recommendation Mr. Brooker moved to recommend the Board of County Commissioners not approve the proposed amendment as presented by Staff based on the rationale it overly restricts an owner's use of private property, it impedes his fundamental property rights and there are already criteria established for rezoning in the Land Development Code which address the issue. If the proposed amendment is to be approved, the Board of County Commissioners considers addressing the concerns raised by the Subcommittee. Second by Mr. Disney. Carried unanimously 12—0. Mr. Mulhere and Mr. Espinar abstained due to a conflict of interest. VII. Old Business None 6 December 7, 2016 VIII. Committee Member Comments Chairman Varian reported this is Mr. Disney's last meeting as member of the Committee. The Committee recognized Mr. Disney's service to the citizens of Collier County. IX. Adjourn Next Meeting Dates January 4,2017 GMD Conference Room 610—3:00 pm February 1, 2017 GMD Conference Room 610—3:00 pm March 1,2017 GMD Conference Room 610—3:00 pm There being no further business for the good of the County, the meeting was adjourned by the order of the Chair at 5:07PM. COLLIER COUNTY DEVELOPMENT SERVICES ADVISORY COMMITTEE Chairman, William Varian These Minute ere approved by the Board/Chairman on 14 , as presented or as amended 7 FORM 8B MEMORANDUM OF VOTING CONFLICT FOR COUNTY, MUNICIPAL, AND OTHER LOCAL PUBLIC OFFICERS LAST NAME—FIRST NAME—MIDDLE NAME NAME OF BOARD,COUNCIL,COMMJSSION,AUTHORITY.OR COMMITTEE g MAILING ADD SS , is THE BOARD,COUNCIL,COMMISSION,AUTHORITY OR COMMITTEE ON 3y ) w WHICH I SERVE IS A UNrr CITY r COUNTY / CITY UNTY ❑OTHER LOCAL AGENCY AI/474 NAME OF POLITICAL SUBDIVISION: DATE ON WHICH VOTE OCCURRED MY POSITION IS: 0 ELECTIVE APPOINTIVE WHO MUST FILE FORM 8B This form is for use by any person serving at the county,city,or other local level of government on an appointed or elected board,council, commission, authority,or committee. It applies equally to members of advisory and non-advisory bodies who are presented with a voting conflict of interest under Section 112,3143, Florida Statutes. Your responsibilities under the law when faced with voting on a measure in which you have a conflict of interest will vary greatly depending on whether you hold an elective or appointive position. For this reason, please pay close attention to the instructions on this form before completing the reverse side and filing the form. INSTRUCTIONS FOR COMPLIANCE WITH SECTION 112.3143, FLORIDA STATUTES A person holding elective or appointive county, municipal, or other local public office MUST ABSTAIN from voting on a measure which inures to his or her special private gain or loss. Each elected or appointed local officer also is prohibited from knowingly voting on a mea- sure which inures to the special gain or loss of a principal (other than a government agency)by whom he or she is retained(including the parent organization or subsidiary of a corporate principal by which he or she is retained);to the special private gain or loss of a relative;or to the special private gain or loss of a business associate.Commissioners of community redevelopment agencies under Sec. 163.356 or 163.357, F.S., and officers of independent special tax districts elected on a one-acre,one-vote basis are not prohibited from voting in that capacity. For purposes of this law, a "relative includes only the officer's father, mother, son, daughter, husband, wife,brother,sister,father-in-law, mother-in-law, son-in-law, and daughter-in-law.A"business associate" means any person or entity engaged in or carrying on a business enterprise with the officer as a partner,joint venturer,coowner of property, or corporate shareholder(where the shares of the corporation are not listed on any national or regional stock exchange). ELECTED OFFICERS: In addition to abstaining from voting in the situations described above,you must disclose the conflict: PRIOR TO THE VOTE BEING TAKEN by publicly stating to the assembly the nature of your interest in the measure on which you are abstaining from voting;end WITHIN 15 DAYS AFTER THE VOTE OCCURS by completing and filing this form with the person responsible for recording the min- utes of the meeting,who should incorporate the form in the minutes. APPOINTED OFFICERS: Although you must abstain from voting in the situations described above, you otherwise may participate in these matters. However, you must disclose the nature of the conflict before making any attempt to influence the decision, whether orally or in writing and whether made by you or at your direction. IF YOU INTEND TO MAKE ANY ATTEMPT TO INFLUENCE THE DECISION PRIOR TO THE MEETING AT WHICH THE VOTE WILL BE TAKEN: • You must complete and file this form(before making any attempt to influence the decision)with the person responsible for recording the minutes of the meeting,who will incorporate the form in the minutes. (Continued on other side) CE FORM 85-EFF. 1/2000 PAGE 1 APPOINTED OFFICERS (continued) • A copy of the form must be provided immediately to the other members of the agency. • The form must be read publicly at the next meeting after the form is filed, IF YOU MAKE NO ATTEMPT TO INFLUENCE THE DECISION EXCEPT BY DISCUSSION AT THE MEETING: • You must disclose orally the nature of your conflict in the measure before participating. • You must complete the form and file it within 15 days after the vote occurs with the person responsible for recording the minutes of the meeting,who must incorporate the form in the minutes.A copy of the form must be provided immediately to the other members of the agency,and the form must be read publicly at the next meeting after the form is filed. DISCLOSURE OF LOCAL OFFICER'S INTEREST I, t m-- thereby disclose that on 20/6 (a)A measure came or will come before my agency which(check one) inured to my special private gain or loss; f f // nured to the special gain or loss of my business associate, t ._/C;4//,'"-7,v . inured to the special gain or loss of my relative, inured to the special gain or loss of ,by whom I am retained;or inured to the special gain or loss of ,which is the parent organization or subsidiary of a principal which has retained me. (b)The measure before my agency and the nature of my conflicting interest in the measure is as follows: Date Filed atur= NOTICE: UNDER PROVISIONS OF FLORIDA STATUTES §112.317, A FAILURE TO MAKE ANY REQUIRED DISCLOSURE CONSTITUTES GROUNDS FOR AND MAY BE PUNISHED BY ONE OR MORE OF THE FOLLOWING: IMPEACHMENT, REMOVAL OR SUSPENSION FROM OFFICE OR EMPLOYMENT, DEMOTION, REDUCTION IN SALARY, REPRIMAND, OR A CIVIL PENALTY NOT TO EXCEED$10,000. CE FORM 8B-EFF.1/2000 PAGE 2 FORM 8B MEMORANDUM OF VOTING CONFLICT FOR COUNTY, MUNICIPAL, AND OTHER LOCAL PUBLIC OFFICERS LAST NAME—FIRST NAME—MIDDLA NAME NAME OF BOARD,COUNCIL,COMMISSION,AUTHORITY,OR COMMITTEE \A /14 1.1 ( f— !"V /� CS?�! rer De-0 Se(( AZQ osC1 4.fidIP MAILING AJVR SSN J THE BOARD,COUNCIL,COMMISSION,AUTHORITY OR COMMI I ItE ON 6 - ` _` WHICH I SERVE ISA UNIT�OFA�:- CITY ` COUNTY D CITY .Fl-C.6 NTY U OTHER LOCAL AGENCY tr, 1`�� NAME OF POLITICAL SUBDIVISION' rrr \ C v f� DATE ON WHICH VOTEOCCURREDMY POSITION IS: � IL-Z�- 2 b ) 4, U ELECTIVE ,u--HrPOINTIVE WHO MUST FILE FORM 8B This form is for use by any person serving at the county,city,or other local level of government on an appointed or elected board,council, commission, authority, or committee. It applies equally to members of advisory and non-advisory bodies who are presented with a voting conflict of interest under Section 112.3143,Florida Statutes. Your responsibilities under the law when faced with voting on a measure in which you have a conflict of interest will vary greatly depending on whether you hold an elective or appointive position. For this reason, please pay close attention to the instructions on this form before completing the reverse side and filing the form. INSTRUCTIONS FOR COMPLIANCE WITH SECTION 112.3143, FLORIDA STATUTES A person holding elective or appointive county, municipal, or other local public office MUST ABSTAIN from voting on a measure which inures to his or her special private gain or loss. Each elected or appointed local officer also is prohibited from knowingly voting on a mea- sure which inures to the special gain or loss of a principal (other than a government agency)by whom he or she is retained(including the parent organization or subsidiary of a corporate principal by which he or she is retained);to the special private gain or loss of a relative; or to the special private gain or loss of a business associate, Commissioners of community redevelopment agencies under Sec. 163.356 or 163.357, F.S., and officers of independent special tax districts elected on a one-acre, one-vote basis are not prohibited from voting in that capacity. For purposes of this law, a 'relative" includes only the officer's father, mother, son, daughter, husband, wife, brother, sister, father-in-law, mother-in-law, son-in-law, and daughter-In-law. A"business associate'means any person or entity engaged in or carrying on a business enterprise with the officer as a partner,joint venturer, coowner of property, or corporate shareholder(where the shares of the corporation are not listed on any national or regional stock exchange). * • * • • * * * * * * * * * ELECTED OFFICERS: In addition to abstaining from voting in the situations described above,you must disclose the conflict: PRIOR TO THE VOTE BEING TAKEN by publicly stating to the assembly the nature of your interest in the measure on which you are abstaining from voting; and WITHIN 15 DAYS AFTER THE VOTE OCCURS by completing and filing this form with the person responsible for recording the min- I utes of the meeting,who should incorporate the form in the minutes. APPOINTED OFFICERS: Although you must abstain from voting in the situations described above, you otherwise may participate In these matters. However, you must disclose the nature of the conflict before making any attempt to influence the decision, whether orally or in writing and whether made by you or at your direction, IF YOU INTEND TO MAKE ANY ATTEMPT TO INFLUENCE THE DECISION PRIOR TO THE MEETING AT WHICH THE VOTE WILL BE TAKEN: • You must complete and file this form(before making any attempt to influence the decision)with the person responsible for recording the minutes of the meeting,who will incorporate the form in the minutes. (Continued on other side) CE FORM 8B-EFF.1/2000 PAGE 1 APPOINTED OFFICERS (continued) • A copy of the form must be provided immediately to the other members of the agency. • The form must be read publicly at the next meeting after the form is filed. IF YOU MAKE NO ATTEMPT TO INFLUENCE THE DECISION EXCEPT BY DISCUSSION AT THE MEETING: • You must disclose orally the nature of your conflict in the measure before participating. • You must complete the form and file it within 15 days after the vote occurs with the person responsible for recording the minutes of the meeting,who must incorporate the form in the minutes.A copy of the form must be provided immediately to the other members of the agency,and the form must be read publicly at the next meeting after the form is filed. DISCLOSURE OF LOCAL OFFICER'S INTEREST I, ( `J r f v Lc�C hereby disclose that on 2" 1 - (a)A measure came or will come before my agency which(check one) inured to my special private gain or loss; inured to the special gain or loss of my business associate, _ inured to the special gain or loss of my relative, (�nured to the special gain or loss of L t. ,by whom I am retained;or inured to the special gain or loss of ,which is the parent organization or subsidiary of a principal which has retained me. (b)The measure before my agency and the nature of my conflicting interest in the measure is as follows: Date Filed Si nature NOTICE: UNDER PROVISIONS OF FLORIDA STATUTES §112.317, A FAILURE TO MAKE ANY REQUIRED DISCLOSURE CONSTITUTES GROUNDS FOR AND MAY BE PUNISHED BY ONE OR MORE OF THE FOLLOWING: IMPEACHMENT, REMOVAL OR SUSPENSION FROM OFFICE OR EMPLOYMENT, DEMOTION, REDUCTION IN SALARY, REPRIMAND, OR A CIVIL PENALTY NOT TO EXCEED$10,000. CE FORM 88-EFF.1/2000 PAGE 2 it