Backup Documents 12/11-12/2012 Item #10 W ORIGINAL DOCUMENTS CHECKLIST & ROUTING SI
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNAT
Print on pink paper.Attach to original document.Original documents should be hand delivered to the Board Office.The completed routing slip and original
documents are to be forwarded to the Board Office only after the Board has taken action on the item.)
ROUTING SLIP
Complete routing lines#1 through#4 as appropriate for additional signatures,dates,and/or information needed.If the document is already complete with the
exception of the Chairman's signature,draw a line through routing lines#1 through#4,complete the checklist,and forward to Ian Mitchell(line#5).
Route to Addressee(s) Office Initials Date
(List in routing order)
1.
2.
3.
4. Colleen M. Greene, ACA County Attorney's Office 12/12/12
5. BCC Office Board of County Commissioners
6. Minutes and Records Clerk of Court's Office
PRIMARY CONTACT INFORMATION
(The primary contact is the holder of the original document pending BCC approval.Normally the primary contact is the person who created/prepared the executive
summary.Primary contact information is needed in the event one of the addressees above,including Sue Filson,need to contact staff for additional or missing
information.All original documents needing the BCC Chairman's signature are to be delivered to the BCC office only after the BCC has acted to approve the
item.)
Name of Primary Staff Colleen M. Greene, ACA Phone Number 239-252-8400
Contact
Agenda Date Item was 12/12/12 (12/11/12 BCC) j/ Agenda Item Number 10W
Approved by the BCC
Type of Document Settlement Agreement Number of Original
Attached Documents Attached
INSTRUCTIONS & CHECKLIST
Initial the Yes column or mark"N/A"in the Not Applicable column, whichever is Yes N/A(Not
appropriate. (Initial) Applicable)
I. Original document has been signed/initialed for legal sufficiency. (All documents to be CMG
signed by the Chairman, with the exception of most letters, must be reviewed and signed
by the Office of the County Attorney.This includes signature pages from ordinances,
resolutions,etc. signed by the County Attorney's Office and signature pages from
contracts,agreements,etc. that have been fully executed by all parties except the BCC
Chairman and Clerk to the Board and possibly State Officials.)
2. All handwritten strike-through and revisions have been initialed by the County Attorney's N/A
Office and all other parties except the BCC Chairman and the Clerk to the Board
3. The Chairman's signature line date has been entered as the date of BCC approval of the CMG
document or the final negotiated contract date whichever is applicable. _
4. "Sign here"tabs are placed on the appropriate pages indicating where the Chairman's CMG
signature and initials are required.
5. In most cases(some contracts are an exception),the original document and this routing slip N/A
should be provided to Ian Mitchell in the BCC office within 24 hours of BCC approval.
Some documents are time sensitive and require forwarding to Tallahassee within a certain
time frame or the BCC's actions are nullified.Be aware of your deadlines!
6. The document was approved by the BCC on 12/12/12(enter date)and all changes CMG
made during the meeting have been incorporated in the attached document.The
County Attorney's Office has reviewed the changes,if applicable.
7. _ Please return the original documents to Colleen M.Greene,ACA C CMG
10 1
MEMORANDUM
Date: December 12, 2012
To: Colleen Greene, ACA
County Attorney's Office
From: Ann Jennejohn, Deputy Clerk
Minutes & Records Department
Re: Settlement Agreement re: DOAH Case No. 12-0495
between Named Petitioners, Department of Environmental
Protection (DEP) and the Collier County Board of County
Commissioners
Attached for further processing is a (scanned) copy of the original agreement referenced
above (Item #10W) approved by the Board of County Commissioners on Wednesday,
December 12, 2012.
After forwarding for necessary signature(s), please return any signed and/or
supplemental documents to the Minutes & Records Department, so there will be a
complete record for the Board.
If you have any questions, please call me at 252-8406.
Thank you.
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HerreraSandra
From: HerreraSandra
Sent: Tuesday, December 18, 2012 12:13 PM
To: Ann P. Jennejohn
Subject: RE: BCC 12/12/12 (12/11/12)Agenda Item 10W Settlement Agreement-Vanderbilt
Rhea.pdf
From: HerreraSandra
Sent: Tuesday, December 18, 2012 12:12 PM
To: Ann P. Jennejohn
Subject: BCC 12/12/12 (12/11/12) Agenda Item l0w Settlement Agreement-Vanderbilt
Good Afternoon,
I will be hand delivering the attached original signature pages for the above agenda item. The remainder of the
signatures will be delivered by Kathleen Robbins, of Vanderbilt Beach Residents Associations. Ms. Robbins is requesting
to have the fully executed settlement agreement recorded at their expense. If you have any questions, call me or Nancy
Bradley. Thank you!
Sandra Herrera, Certified Paralegal to:
Colleen M. Greene,Assistant County Attorney
Kevin L. Noell,Assistant County Attorney
Office of the County Attorney
W. Harmon Turner Building F
3299 East Tamiami Trail,Suite 800
Naples, Florida 34112-4902
Phone: (239) 252-8400
Facsimile: (239)252-6300
Sandraherreraca colliergov.net
1
Covfy,offc llier
10 W
CLERK OF THE OiRC IT COURT
Dwight E. Brock COLLIER COUNTY OUR OUSE Clerk of Courts
Clerk of Courts 3301 TAM1AMI
BOX [L E ST Accountant
P.O. BOX 4 3044
NAPLES, FLORIDA` 4101-3044 Auditor
Custodian of County Funds
"ICJ
December 28, 2012
Kathleen Rohan Robbins
10525 Gulf Shore Drive, #231
Naples, FL 34108
Re: DOAH Case No. 12-495 Settlement Agreement
Dear Kathleen,
Attached, per our conversation, are two (2) certified copies of the agreement
referenced above, approved by Collier County's Board of County Commissioners
on Wednesday, December 12, 2012.
Please feel free to contact me if you need anything further from our office regarding
the agreement.
Sincerely,
DWIGHT E. BROCK, CLERK
Ann Jennejohn,
Deputy Clerk
Attachment
Phone (239) 252-2646 Fax (239) 252-2755
Website: www.collierclerk.com Email: collierclerk @collierclerk.com
lOWE
STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
ROLLIN O. RHEA, ROBERT O. NAEGELE, JR.,
VANDERBILT BEACH RESIDENTS
ASSOCIATION, INC., BEACHWALK RESIDENTS
ASSOCIATION, INC., THE BEACHMOOR
CONDOMINIUM OWNERS ASSOCIATION, INC.,
AND THE MANGROVE ACTION GROUP, INC.
Petitioners,
v. DOAH CASE NO.: 12-0495
OGC No.: 11-0927
Re: DEP File#: CO-922 V
COLLIER COUNTY BOARD OF COUNTY
COMMISSIONERS, AND FLORIDA
DEPARTMENT OF ENVIRONMENTAL INSTR 4776117 OR 4866 PG 1203
PROTECTION, RECORDED 12/18/2012 1.41 F PAGES 11
DWIGHT E. BROCK, CLERK OF THE CIRCUIT COURT
COLLIER COUNTY FLORIDA
REC$95.00 INDX$5.00
Respondents.
SETTLEMENT AGREEMENT
This Settlement Agreement is reached by and between Rollin O. Rhea, Robert O.
Naegele, Jr.,Vanderbilt Beach Residents Association, Inc., Beachwalk Residents Association,
Inc., The Beachmoor Condominium Owners Association, Inc., and The Mangrove Action Group,
Inc. ("Petitioner"), Department of Environmental Protection ("DEP") and the Collier County
Board of County Commissioners ("County") (collectively "The Parties") and is effective upon
approval by the County.
Recitals
Whereas, on June 24, 2011, pursuant to Florida Statute Section 120.542, the County filed
with the DEP Petitions for Variance from requirements that major structures be located a
sufficient distance landward of the beach and frontal dune, as found in Florida Administrative
Code (F.A.C.) Rule 62B-33.005(8). The County sought to construct new beach structures,
including an elevated viewing deck, concession and restroom facility at Vanderbilt Beach Road
Park, westward of the Coastal Construction Control Line ("CCCL"). See DEP File Numbers
CO-922 V and CO-922.
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Whereas, on October 31, 2011, the DEP issued a Final Order Granting the County's
Petition for Variance from Rule 62B-33.005(8), F.A.C. ("Final Order").
Whereas, on January 20, 2012, Petitioners filed a Petition for Formal Administrative
Hearing challenging the Final Order and seeking a reversal of the same for reasons set forth in
such Petition.
Whereas, the Parties have resolved their differences and agree that the terms contained in
the Settlement Agreement constitute a fair and appropriate resolution of their dispute.
Now therefore, it is agreed:
1. The Parties stipulate that the County will, in writing, formally withdraw (by
submitting a Notice of Withdrawal in this case) the Petition for Variance, in the form attached
hereto as Exhibit 1, within 7 days of the execution of this Agreement. The parties agree to the
issuance of an order closing the file to be issued by the Administrative Law Judge in this
proceeding and to the issuance of an order by DEP closing the file in this matter.
2. The County will not now or in the future (a) proceed with the current design, or a
substantially similar design, proposed in DEP File Number CO-922 and 922V, (b) pursue
permits for, nor (c) construct any elevated or elevated pile supported structure within or adjacent
to the Vanderbilt Beach properties which the County owns, including the Beach Park, Parking
Garage, and Vanderbilt Beach Road right of way.
3. The County will amend its current permit application, CO-922, before DEP, to
incorporate the terms of this Settlement Agreement and eliminate any proposed improvements
which are inconsistent with the Settlement Agreement.
4. Petitioners will support any other application by the County to the DEP or other
authorities to allow construction of an additional restroom facility at the Collier County
Vanderbilt Beach Park as long as such application complies with the following:
(a) The restroom facility shall be situated in the FEMA AE construction zone,
located close to the existing restroom, but not in the Vanderbilt Beach right of way,
constructed at-grade without elevation, and shall not exceed 1,000 square feet in area and
20 feet in height. The restroom facility shall be designed and constructed to be
architecturally compatible with the structures in the surrounding Vanderbilt Beach area.
(b) There shall be minimal alteration of the natural vegetation on the
construction site and any alteration will include landscaping to enhance the natural
appearance of existing site vegetation.
(c) The existing restroom facility may remain with such upgrades as are
allowed by local flood regulations.
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(d) There shall be retention and/or relocation of existing picnic facilities as
necessary to accommodate the improvements referred to above.
(e) The County will seek site plan and architectural input from the Petitioners
before proceeding with design work and will make its architects/engineers available to
consult with Petitioners and/or Petitioners' architect. The Petitioners shall have the right
of approval of the site plan and architectural design, which approval shall not be
unreasonably withheld, with respect to the proposed bathrooms.
5. The County will undertake the beach dune restoration and vegetation activities
proposed in the existing permit application DEP File # CO-922 as soon as practicable, not to
exceed 180 days.
6. The new restroom facility construction will be completed within one year of the
permitting. A six month extension may be granted by Petitioners.
7. A temporary bathroom may be placed on site during construction only from
October through April until construction is completed.
8. This Settlement Agreement shall be enforceable by action in circuit court, venue
in Collier County. In the event of disagreement as to the application of the terms of this
Agreement, Collier County shall immediately cease the permitting application process, which
shall be stayed while the Parties seek a determination by the circuit court. If the County does not
stay its application process, the circuit court is authorized to issue a temporary injunction,
without the requirement of a bond.
9. The term of this agreement shall be 15 years from the date of approval by the
Board of County Commissioners.
10. The Parties agree that each Party shall bear its own attorneys fees and costs.
11. Time is of the essence.
THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK
SIGNATURE PAGE(S) TO FOLLOW
10
So agreed this I 2-/IL-day of tCernber 2019,
This document is signed in counterparts.
ATTE$,Tc` ,' BOARD 0" 'CO TY CO MISSIONERS
DWIGHT E.:BROC , CLERK OF COL E'� C 1 , T LORIDA
`:
, B ► Ll
A• c;t ;,40;lia _ I. RI( GE OW A A. HILLER, CHAIRWOMAN
App ova i`s:l
and
AgittVdLTY:...
Jeffre l• 1..w, Esq.
Cornell el ty Attorney's Office
3299 :''=st 1:miami Trail, Suite 800
Naples, F t 4112
(Attorney County)
Thomas G. Tomasello, Esq. West Gregory, Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard, MS #35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY& RUDOLPH, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
Robert O.Naegele, Jr. Rollin O. Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner i
r item It LOV\I
Derek Allen, President Kathleen Robbins Agenda 11,I
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Associatiot Date i ° (y
6 '
Petitioner Date
Recd512'2{�IZ
VAA ‘ 1:,,,)
Deputy C-rk 7
I
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So agreed this I2 `day of pp,Cembfr 2011,
This document is signed in counterparts.
ATTEST: BOARD ., 0 Y C I MISSIONERS
DWIGHT E.BROCK,CLERK OF COL E', C► LORIDA
By: 1 1../
,DEPUTY CLERK GE'" A A.HILLER,CHAIRWOMAN
App iv: Ion .
and - i ciency:
Ail' I7
ift_
Jeffre • ; w,Esq.
Collie el ty Attorney's Office
3299 : : miami Trail,Suite 800
Naples,F i 4112
(Attorney , County)
r�
Thomas G.Tomasello,Esq. West Gregory,Esq.
THOMAS G.TOMASELLO,P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee,FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard,MS#35
Scott Shirley,Esq Tallahassee,FL 32399-3000
' ARD,SHIRLEY&RUDOLPH,P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee,FL 32302-1874
(Attorneys for Petitioners)
Robert 0.Naegele,Jr. Rollin 0.Rhea
Petitioner Petitioner
Theodore Raia,President Doty V.William,President
Mangrove Action Group,Inc.,Petitioner The Beachmoore Condominium Owners
Association,Inc.,Petitioner
_ati 01
Derek Allen,President Kathleen Robbins
Beachwalk Residents Association,Inc. Vanderbilt Beach Residents Association,Inc.
Petitioner
0
So agreed this 12-' day of December 201 2,,
This document is signed in counterparts.
ATTEST: BOARD • 0 Y C• MISSIONERS
DWIGHT E.BROCK,CLERK OF COL E', C I LORIDA
By: lLa
,DEPUTY CLERK G 1 • A.HILLER,CHAIRWOMAN
App iv: ,,oi .
and ; • 'ciency:
.111107
C'' ("1"----. c-"--q,e....c...--Z-
Jeffre RI -,7•w,Esq. ��C/►e L�� e�.rC;
Coll ie ti ty Attorney's Office
3299 : : : iami Trail,Suite 800 A c l i' �%'Cc,u On.e c-
Naples,F■� 4112 pep(^ -;�-�. �- c f- E,,,,. Aen�,, / ft z.,Tr.CHc--
(Attorney County) J `7 00 co - --,o•, �cz.. /PI, 31 Vol, -5 3 O,
-1 -7;, lic- ► ,,ssc� F.1 323 `19 -300
te --
r, 'l ,y- - , ,/ _
Thomas G.Tomasello,Esq. West Gregory,Esc
THOMAS G.TOMASELLO,P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee,FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard,MS#35
Scott Shirley,Esq Tallahassee,FL 32399-3000
' ARD,SHIRLEY&RUDOLPH,P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee,FL 32302-1874
(Attorneys for Petitioners)
Robert 0.Naegele,Jr. Rollin 0.Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William,President
Mangrove Action Group,Inc.,Petitioner The Beachmoore Condominium Owners
Association,Inc.,Petitioner
—i62SJULA_Ettl&&&le___
Derek Allen,President Kathleen Robbins
Beachwalk Residents Association,Inc. Vanderbilt Beach Residents Association,Inc.
Petitioner
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So agreed this I2- day of December 20 ,,
This document is signed in counterparts.
ATTEST: BOARD •F-\CO TY CO. ISSIONERS
DWIGHT E. BROCK, CLERK OF COL E' C I , LORIDA
By: ` LA
,DEPUTY CLERK GE*,I A A. HILLER, CHAIRWOMAN
App ova :o:-! ,
Li
and $. ciency:
AN ;� �-
Jeffre ' . 1 1.-'e w,Esq.
Collie s ty Attorney's Office
3299 st; :miami Trail, Suite 800
Naples, F► '4112
(Attorney County)
Thomas G.Tomasello,Esq. West Gregory,Esq.
THOMAS G. TOMASELLO,P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee,FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard,MS#35
Scott Shirley,Esq Tallahassee,FL 32399-3000
ARD, SHIRLEY&RUDOLPH,P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(A - eysfor ''titlon'rs)
/I/1 / ! _
Robert O. aegele,Jr. Rollin O.Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William,President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
Derek Allen,President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner
10W
So agreed this 12- day of jiVcer►nber 201a,
This document is signed in counterparts.
ATTEST: BOARD • 'CO TY CO MISSIONERS
DWIGHT E. BROCK, CLERK OF COL E'' C I LORIDA
By: ► u
, DEPUTY CLERK GE•VA A. HILLER, CHAIRWOMAN
App .va :o, :'
and ,• ' ciency:
.4117 1
Jeffre : 1...'.•w,Esq.
Collie •t ty Attorney's Office
3299 st :miami Trail, Suite 800
Naples, F t 4112
(Attorney County)
Thomas G. Tomasello, Esq. West Gregory,Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee,FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard,MS #35
Scott Shirley,Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY& RUDOLPH, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
, 2c32..-1-4. (9 e%e(e_e__---
Robert 0.Naegele,Jr. Rollin 0. Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
Derek Allen, President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner
1oyv
So agreed this I 2- day of December 20/c1;
This document is signed in counterparts.
ATTEST: BOARD O F'CO TY CO MISSIONERS
DWIGHT E. BROCK, CLERK OF COL E'' C I ' T LORIDA
By: I Ltt
, DEPUTY CLERK GE TA A. HILLER, CHAIRWOMAN
App •va 'o:4
Li
and 1- • it ciency:
.41/1111 /,'
Jeffre. l.'•w, Esq.
Collie • '` ty Attorney's Office
3299 :st; :miami Trail, Suite 800
Naples, F t '4112
(Attorney County)
Thomas G. Tomasello, Esq. West Gregory, Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard, MS #35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY& RUDOLPI I, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
Robert O. Naegele,Jr. Rollin O. Rhea
Petitioner Petitioner
ilk_.�
Theo•ore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
. IL 1 • ' .. Iil.A�a. .
Derek Allen, President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner
10W
So agreed this 12 day of DecembPr 201 a,
This document is signed in counterparts.
ATTEST: BOARD 0'"CO TY CO MISSIONERS
DWIGHT E. BROCK, CLERK OF COL E', CI P T LORIDA
By: la
, DEPUTY CLERK GE•71A A. HILLER, CHAIRWOMAN
App eva lo
and f;- • 4 ; /i'lciency:
.. fitt
ICI
Jeffre I• . ' 1.—.w, Esq.
Collie I •'t ty Attorney's Office
3299 :'',st 1:miami Trail, Suite 800
Naples,F l., 4112
(Attorney County)
Thomas G. Tomasello, Esq. West Gregory, Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard, MS #35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY& RUDOLPH, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
Robert O.Naegele,Jr. Rollin O. Rhea
Petitioner Petitioner '.
, /✓''t/mss /f� 4T—i-'..-.W.�-.
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
Derek Allen, President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner
10W
So agreed this I/ day of t cer tber 20 ,,
This document is signed in counterparts.
ATTEST: BOARD O//h^CO NTY CO MISSIONERS
DWIGHT E. BROCK, CLERK OF COLUIE'■ C I U T LORIDA
By: >I il
, DEPUTY CLERK GECTA A. HILLER, CHAIRWOMAN
f.
App .va +o..1,;
and Y-.' Iciency:
Aidaiii :i ,
I
Jeffre 1. . 1.'z ow, Esq.
Collie . ty Attorney's Office
3299 :';st :miami Trail,Suite 800
Naples, Ft- 4112
(Attorney County)
Thomas G.Tomasello, Esq. West Gregory, Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard,MS#35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD. SHIRLEY& RUDOLPH, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys,for Petitioners)
Robert O.Naegele,Jr. Rollin O. Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
erek Allen,President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner
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AGENDA ITEM TITLE: „/ ITEM NO
THIS COMPLETED FORM IS TO BE PLACED IN THE"SPEAKER FORM BOX"IN THE BOARD ROOM PRIOR TO THE
SUBJECT BEING HEARD.
j� beet�^ /( ���,y PLEASE PRINT CLEARLY
NAME: kO bee �2 Iki4l�C�✓(�i
ADDRESS:
•1Qq 3 v i 2.
REPRESENTING: PETITIONER OTHER:
COLLIER COUNTY ORDINANCE NO.99-22 R IRES THAT ALL LOBBYISTS SHALL,BEFORE ENGAGING IN ANY LOBBYING
ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY COMMISSIONERS),REGISTER WITH THE
CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT.
YOU ARE LIMITED TO 3 MINUTES FOR YOUR COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR.
(PLEASE PRINT CLEARLY) Agenda Item # o.c,J
MEETING DATE // (Circle Meeting Type) Regular Special Workshop Budget
AGENDA ITEM TITLE e L: ,Litt --PA 13(' �,�o A)L• ��o,n AL�l7 L
NAME ��J .�`� f b
Y'!QVc &i CAufr oc ADDRESS #07—C— .Vcd.‘-._ ' /JW ' M
Representing/petitioner: Other:
COLLIER COUNTY ORDINANCE NO.2003-53,AS AMENDED BY ORDINANCE 2004-05 AND 2007-24,REQUIRES THAT ALL LOBBYISTS
SHALL,BEFORE ENGAGING IN ANY LOBBYING ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY
COMMISSIONERS),REGISTER WITH THE CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT.
YOU ARE LIMITED TO THREE(3)MINUTES FOR YOU COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR
PLACE COMPLETED FORM ON THE TABLE LEFT OF THE DIAS IN THE BOARD ROOM PRIOR TO THE SUBJECT BEING HEARD
AGENDA ITEM TITLE: / v \/\./ 3 e t f I e 1■e I\ D /Q ,,w/
a ��e� ITEM NO:
THIS COMPLETED FORM IS TO BE PLACED IN THE"SPEAKER FORM BOX"IN THE BOARD ROOM PRIOR TO THE
SUBJECT BEING HEARD.
\\A PLEASE PRINT CLEARLY
NAME: ac� h�i P 1L\d2S
1
ADDRESS: 2� P a c. N w ‘\ '
REPRESENTING: PETITIONER �' ( OTHER:
COLLIER COUNTY ORDINANCE NO.99-22 REQUIRES THAT ALL LOBBYISTS SHALL,BEFORE ENGAGING IN ANY LOBBYING
ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY COMMISSIONERS),REGISTER WITH THE
CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT.
YOU ARE LIMITED TO 3 MINUTES FOR YOUR COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR.
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AGENDA ITEM TITLE: �Y�i�jG{. '7').`"''''11"'e.-7..
c a r ITEM NO:
/ '
THIS COMPLETED FORM IS TO BE PLACED IN THE"SPEAKER FORM BOX"IN THE BOARD ROOM PRIOR TO THE
SUBJECT BEING HEARD.
— PLEASE PRINT CLEARLY
NAME: C. ,'yGG,77 47/ r 4' "
I /
ADDRESS: �:J� ✓ .O.Y .. kt tYw jrv.e.- fit .{.,?..•
REPRESENTING: PETITIONER OTHER: "1
COLLIER COUNTY ORDINANCE NO.99-22 REQUIRES THAT ALL LOBBYISTS SHALL,BEFORE ENGAGI IN ANY LOBBYING
ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY COMMISSIONERS),REGISTER WITH THE
CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT.
YOU ARE LIMITED TO 3 MINUTES FOR YOUR COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR.
(PLEASE PRINT CLEARLY) Agenda Item # "'6
MEETING DATE /1/////°- Circle Meeting Type)) R ular S
e e9 Special Workshop Budget
AGENDA ITEM TITLE cf ,,o'Old
NAME / / /1 � "/6 DDRESS D' /
Representing/Petitioner: . 0 4A J/y�c�`�y °4/7,jy1 'yk4 �
COLLIER COUNTY ORDINANCE NO.2003-53;AS AMENDED'BY ORDINANCE 2004-05 AND 2007-24,REQUIRES THAT ALL LOBBYISTS
SHALL,BEFORE ENGAGING IN ANY LOBBYING ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY
COMMISSIONERS),REGISTER WITH THE CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT,
YOU ARE LIMITED TO THREE(3)MINUTES FOR YOU COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR
PLACE COMPLETED FORM ON THE TABLE LEFT OF THE DIAS IN THE BOARD ROOM PRIOR TO THE SUBJECT BEING HEARD
(PLEASE PRINT `
CLEARLY) Agenda Item # /0 '
MEETING DATE /:,1 ////A0/a- (Circle Meeting Type 4:r Special Workshop Budget
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AGENDA ITEM TITLE J O 4 P CA5E I -4"t.S S /1-0MM i
NAME Kathleen Robbins ADDRESS 10525 Gulf Shore Dr #231, Naples, 34108
Representing/Petitioner: O}heri/anderbilt Bch Residents Assn.
COLLIER COUNTY ORDINANCE NO.2003-53,AS AMENDED BY ORDINANCE 2004-05 AND 2007-24,REQUIRES THAT ALL LOBBYISTS
SHALL,BEFORE ENGAGING IN ANY LOBBYING ACTIVITIES(INCLUDING,BUT NOT LIMITED TO,ADDRESSING THE BOARD OF COUNTY
COMMISSIONERS),REGISTER WITH THE CLERK TO THE BOARD AT THE BOARD MINUTES AND RECORDS DEPARTMENT.
YOU ARE LIMITED TO THREE(3)MINUTES FOR YOU COMMENTS AND ARE TO ADDRESS ONLY THE CHAIR
PLACE COMPLETED FORM ON THE TABLE LEFT OF THE DIAS IN THE BOARD ROOM PRIOR TO THE SUBJECT BEING HEARD
10 W ‘lk
STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
ROLLIN O. RHEA, ROBERT O. NAEGELE, JR.,
VANDERBILT BEACH RESIDENTS
ASSOCIATION, INC., BEACHWALK RESIDENTS
ASSOCIATION, INC., THE BEACHMOOR
CONDOMINIUM OWNERS ASSOCIATION, INC.,
AND THE MANGROVE ACTION GROUP, INC.
Petitioners,
v. DOAH CASE NO.: 12-0495
OGC No.: 11-0927
Re: DEP File #: CO-922 V
COLLIER COUNTY BOARD OF COUNTY
COMMISSIONERS, AND FLORIDA
DEPARTMENT OF ENVIRONMENTAL
PROTECTION,
Respondents.
SETTLEMENT AGREEMENT
This Settlement Agreement is reached by and between Rollin O. Rhea, Robert O.
Naegele, Jr.,Vanderbilt Beach Residents Association, Inc., Beachwalk Residents Association,
Inc., The Beachmoor Condominium Owners Association, Inc., and The Mangrove Action Group,
Inc. ("Petitioner"), Department of Environmental Protection ("DEP") and the Collier County
Board of County Commissioners ("County") (collectively "The Parties") and is effective upon
approval by the County.
Recitals
Whereas, on June 24, 2011, pursuant to Florida Statute Section 120.542, the County filed
with the DEP Petitions for Variance from requirements that major structures be located a
sufficient distance landward of the beach and frontal dune, as found in Florida Administrative
Code (F.A.C.) Rule 62B-33.005(8). The County sought to construct new beach structures,
including an elevated viewing deck, concession and restroom facility at Vanderbilt Beach Road
Park, westward of the Coastal Construction Control Line ("CCCL"). See DEP File Numbers
CO-922 V and CO-922.
10 -'$lII
Whereas, on October 31, 2011, the DEP issued a Final Order Granting the County's
Petition for Variance from Rule 62B-33.005(8), F.A.C. ("Final Order").
Whereas, on January 20, 2012, Petitioners filed a Petition for Formal Administrative
Hearing challenging the Final Order and seeking a reversal of the same for reasons set forth in
such Petition.
Whereas, the Parties have resolved their differences and agree that the terms contained in
the Settlement Agreement constitute a fair and appropriate resolution of their dispute.
Now therefore, it is agreed:
1. The Parties stipulate that the County will, in writing, formally withdraw (by
submitting a Notice of Withdrawal in this case) the Petition for Variance, in the form attached
hereto as Exhibit 1, within 7 days of the execution of this Agreement. The parties agree to the
issuance of an order closing the file to be issued by the Administrative Law Judge in this
proceeding and to the issuance of an order by DEP closing the file in this matter.
2. The County will not now or in the future (a) proceed with the current design, or a
substantially similar design, proposed in DEP File Number CO-922 and 922V, (b) pursue
permits for, nor (c) construct any elevated or elevated pile supported structure within or adjacent
to the Vanderbilt Beach properties which the County owns, including the Beach Park, Parking
Garage, and Vanderbilt Beach Road right of way.
3. The County will amend its current permit application, CO-922, before DEP, to
incorporate the terms of this Settlement Agreement and eliminate any proposed improvements
which are inconsistent with the Settlement Agreement.
4. Petitioners will support any other application by the County to the DEP or other
authorities to allow construction of an additional restroom facility at the Collier County
Vanderbilt Beach Park as long as such application complies with the following:
(a) The restroom facility shall be situated in the FEMA AE construction zone,
located close to the existing restroom, but not in the Vanderbilt Beach right of way,
constructed at-grade without elevation, and shall not exceed 1,000 square feet in area and
20 feet in height. The restroom facility shall be designed and constructed to be
architecturally compatible with the structures in the surrounding Vanderbilt Beach area.
(b) There shall be minimal alteration of the natural vegetation on the
construction site and any alteration will include landscaping to enhance the natural
appearance of existing site vegetation.
(c) The existing restroom facility may remain with such upgrades as are
allowed by local flood regulations.
0 wesoma
(d) There shall be retention and/or relocation of existing picnic facilities as
necessary to accommodate the improvements referred to above.
(e) The County will seek site plan and architectural input from the Petitioners
before proceeding with design work and will make its architects/engineers available to
consult with Petitioners and/or Petitioners' architect. The Petitioners shall have the right
of approval of the site plan and architectural design, which approval shall not be
unreasonably withheld, with respect to the proposed bathrooms.
5. The County will undertake the beach dune restoration and vegetation activities
proposed in the existing permit application DEP File # CO-922 as soon as practicable, not to
exceed 180 days.
6. The new restroom facility construction will be completed within one year of the
permitting. A six month extension may be granted by Petitioners.
7. A temporary bathroom may be placed on site during construction only from
October through April until construction is completed.
8. This Settlement Agreement shall be enforceable by action in circuit court, venue
in Collier County. In the event of disagreement as to the application of the terms of this
Agreement, Collier County shall immediately cease the permitting application process, which
shall be stayed while the Parties seek a determination by the circuit court. If the County does not
stay its application process, the circuit court is authorized to issue a temporary injunction,
without the requirement of a bond.
9. The term of this agreement shall be 15 years from the date of approval by the
Board of County Commissioners.
10. The Parties agree that each Party shall bear its own attorneys fees and costs.
11. Time is of the essence.
THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK
SIGNATURE PAGE(S) TO FOLLOW
w
10 VI 4Alk
So agreed this day of 20 .
This document is signed in counterparts.
ATTEST: BOARD OF COUNTY COMMISSIONERS
DWIGHT E. BROCK, CLERK OF COLLIER COUNTY, FLORIDA
By:
, DEPUTY CLERK GEORGIA A. HILLER, CHAIRWOMAN
Approval for form
and legal sufficiency:
Jeffrey A. Klatzkow, Esq.
Collier County Attorney's Office
3299 East Tamiami Trail, Suite 800
Naples, FL 34112
(Attorney for County)
Thomas G. Tomasello, Esq. West Gregory,Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard, MS #35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY &RUDOLPH,P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
Robert O.Naegele, Jr. Rollin O. Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
Derek Allen, President
Beachwalk Residents Association, Inc.
Petitioner
So agreed this day of 20
This document is signed in counterparts.
ATTEST: BOARD OF COUNTY COMMISSIONERS
DWIGHT E. BROCK, CLERK OF COLLIER COUNTY, FLORIDA
By:
, DEPUTY CLERK GEORGIA A. HILLER, CHAIRWOMAN
Approval for form
and legal sufficiency:
Jeffrey A. Klatzkow, Esq.
Collier County Attorney's Office
3299 East Tamiami Trail, Suite 800
Naples, FL 34112
(Attorney for County)
Thomas G. Tomasello, Esq. West Gregory, Esq.
THOMAS G. TOMASELLO, P.A. Assistant General County
1107 Terrace Street Office of the General Counsel
Tallahassee, FL 32303 Department of Environmental Protection
3900 Commonwealth Boulevard, MS #35
Scott Shirley, Esq Tallahassee, FL 32399-3000
ARD, SHIRLEY &RUDOLPH, P.A. (Attorney for DEP)
Post Office Box 1874
Tallahassee, FL 32302-1874
(Attorneys for Petitioners)
Robert O.Naegele, Jr. Rollin O. Rhea
Petitioner Petitioner
Theodore Raia, President Doty V. William, President
Mangrove Action Group, Inc., Petitioner The Beachmoore Condominium Owners
Association, Inc., Petitioner
Derek Allen, President Kathleen Robbins
Beachwalk Residents Association, Inc. Vanderbilt Beach Residents Association, Inc.
Petitioner