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E¢,n ym N Mr : f . a m G - cn • LLZfgmJ>J cco 4 all o:i I c coI t. 4 1 , ...13 -� O , 1,,,,, �� p II C ots e. : -__--Ili-- . .. ,It'iikl,,.., ...,1 7 ate. .•�� co a co• a cow r' N co•'C. 0,� N M a @ri co ii d-E.y � r" _,4 11 ■ t o rw - I / • .> a cc ers I` c 0 co t 1 ' ' a@ w a ti, J • f� 24 _....„. , v , r j y .. . ., . • .NN p a<$NE QJ'Co .a)II1r ' - a)aj II o U U X 1, C. yj L 03 • o a a a a U 0 N N U to v N 1 it • ,_ \ .._ $\ V (NIO 2 N •) 1. \ -.:w..�-- L • SUMMARY OF ARGUMENTS APPLYING LDC Section 5.03.06. DOCK FACILITIES- CRITERIA OBJECTORS' EXHIBIT 1 LDC Section 5.03.06. - DOCK FACILITIES- (text may be bolded and/or in ALLCAPS for emphasis) A. Generally. Docks and the like are primarily intended to adequately secure moored vessels and provide safe access for routine maintenance and use, while minimally impacting navigation within any adjacent navigable channel, the use of the waterway, the use of neighboring docks, the native marine habitat, manatees, and the view of the waterway by the neighboring property owners. H. Dock facility extension. Additional protrusion of a dock facility into any waterway beyond the limits established in LDC subsection 5.03.06 E. may be considered appropriate under certain circumstances. In order for the [Hearing Examiner] to approve the boat dock extension request, it must be determined that at least 4 of the 5 primary criteria, and at least 4 of the 6 secondary criteria, have been met. These criteria are as follows: 1. Primary Criteria: a. Whether the NUMBER of dock facilities and/or BOAT SLIPS proposed is appropriate in relation to the WATERFRONT LENGTH, LOCATION, upland land use, and zoning. (The number should be APPROPRIATE; typical, single-family use should be no more than 2 slips; typical multi-family use should be 1 slip per dwelling unit; in the case of unbridged barrier island docks, additional slips may be appropriate). As to the first primary criterion, although we agree that the LOW DENSITY, RESIDENTIAL upland land use, and RSF-3 zoning of the subject property may ALLOW for a 32 FOOT BDE to be granted where APPROPRIATE, there is no express right to such principal uses having two boat slips for two vessels! That's especially the case where, as here, they are proposed to be longer and larger in length. Simply put, our position is that as to the number of boat slips, proposing two (2) longer, large boats is NOT appropriate in relation to the Vanderbilt-Conners Lagoon area LOCATION, NOR as to the subject lot's 80' WATERFRONT LENGTH. In that regard, MOORING TWO LARGER LENGTH VESSELS IS INCONSISTENT WITH THE GENERAL AND LONG-STANDING PATTERN OF DEVELOPMENT AND Page 1 of 15 APPROVAL OF DOCK FACILITIES IN THE Vanderbilt Connors lagoon area neighborhoods. Two longer, larger vessel boat slips are not the "TYPICAL" intensity of accessory use for the "TYPICAL"lots in the Lagoon area's straight-zoned residential districts. IN RELATION TO THE Subject Lot's INDIVIDUAL AND MORE GENERALIZED Vanderbilt-Conners Lagoon area LOCATION, based upon my detailed review of the Property Appraiser's website's official aerials circa 2022, and all prior HEX BDE approvals in the Lagoon area (identified in the table found in Attachment "A," incorporated by reference as if set forth here) I have been unable to locate or determine the existence of any other lot with an 80' waterfront width that has two large vessels moored in a canal. Although narrower lots in the Lagoon area LOCATION have allowed for one larger vessel and multiple jet skis on a smaller lift or pre-existing dock and smaller watercraft, those have typically been designed with a perpendicular dock arrangement, especially where the adjacent water-way widths are three (3) or more times wider than here. (See, BDE HEX Decisions 20-17 & 22-36). Factually, THERE AREN'T ANY OTHER DOCK FACILITIES WITH TWO LARGER VESSELS MOORED in this LOCATION and finding it is APPROPRIATE under the circumstances here, as proposed, has not been supported by either petitioners' or staffs ipse dixit conclusions. Neither petitioner nor staff has provided any meaningful analysis to reach the circular conclusion that simply because typically a single-family residence MAY be allowed two slips, therefore, a priori, two boat slips at this LOCATION is somehow magically appropriate without any more considered. The argument appears to be that simply because you could have two regardless of whether you met the requisite circumstances or not, you are entitled to have two boat slips. Page 2 of 15 Further, by seeking two boat slips for longer, larger vessels the petitioners' number of vessels is inappropriate in relation to the waterfront lot width/linear length of the subject as evidenced by their combined vessel LOA's being 27' more than the third Secondary criterion (2.c.) allows. Stated differently that's more than 67% greater than allowable. I'd ask the HEX to note that the LDC expressly states that the maximum 50% percentage allowable length of ALL vessels "should be maintained," and is a factor properly applied here in evaluating this criterion because if not considered as an applicable circumstance here AS TO the LDC's expressly stated LOT WATERFRONT LENGTH, then there is no other place in the overall analysis of whether the number of boat slips in relation to waterfront length is considered to be appropriate or not. To suggest that the third Secondary criterion fully addresses this consideration regarding MAINTAINING THE TOTAL allowable length requires the HEX to ignore the above-quoted LDC text. We believe doing so by simply finding the third Secondary criterion would not be met is an incomplete and inadequate analysis. We believe the HEX ought to find this criterion has not been met because in relation to the lot's waterfront length two boat slips for longer, larger vessels is NOT APPROPRIATE AND in relation to this LOCATION proposing two longer, larger vessels is also NOT APPROPRIATE! To the extent petitioners' may already own the two vessels proposed to be moored at the requested dock facility and they argue that acts as a compelling rationale for mooring both vessels at this site allowing them to do so as a matter of right legitimizes vessel owners to inappropriately use the BDE process as a substitute for keeping their second vessels at a more hurricane-safe marina or boat storage house. In more stark terms, "wanting" to moor two longer, larger vessels does not establish and demonstrate why two boat slips under a BDE petition are "needed." Page 3 of 15 Finally, Petitioner's spare, self-serving conclusion of meeting this criterion without any substantive analysis of the facts or applicable law is neither competent NOR substantial evidence, and we therefore respectfully ask that the HEX find this criterion has NOT BEEN MET. b. Whether the water depth at the proposed site is so shallow that a vessel of the general length, type, and draft as that described in the petitioner's application is unable to launch or moor at mean low tide (MLT). (The petitioner's application and survey should establish that the water depth is too shallow to allow launching and mooring of the vessel(s) described without an extension). STAFF RIGHTLY STATES THIS CRITERION HAS NOT BEEN MET and we therefore respectfully ask that the HEX SO find. c. Whether the proposed dock facility may have an adverse impact on navigation within an adjacent marked or charted navigable channel. (The facility should not intrude into any marked or charted navigable channel thus impeding vessel traffic in the channel). MET d. Whether the proposed dock facility protrudes no more than 25 percent of the width of the waterway, and whether a minimum of 50% of the waterway width between dock facilities on either side of the waterway is maintained for navigability. (The facility should maintain the required percentages). Although asserted by petitioner and staff to have been MET, and not to disagree and argue they have not been met, we strongly suggest that if the parenthetical mandatory text for 25 and 50 percentage waterway widths are EVER NOT maintained, and a design for a dock facility that does not maintain the required percentages is APPROVED, then that mandatory portion of the LDC provision has not been applied or properly considered. That would render it impermissible mere surplusage. Accordingly, our position is that under those clearly inappropriate circumstances, the HEX WOULD THEN BE compelled to DENY such a request regardless of whether the required number of Primary and Secondary criteria are otherwise met!! Page 4 of 15 e. Whether the proposed location and design of the dock facility is such that the facility would not interfere with the use of neighboring docks. (The facility should not interfere with the use of legally permitted neighboring docks). We cannot agree, and believe this criterion has NOT BEEN MET, notwithstanding petitioners' three paragraph, quoted text from their agent, which has been relied upon by staff for its positive recommendation without any meaningful analysis. None of that discussion addresses how proposing two boat slips does NOT interfere with both DeSoto's and Dunns' use of their legally permitted dock facilities. In fact, petitioner asserts that, "[i]n terms of specifics, the docking facility to the east[Dunns'] is oriented so that ingress/egress occurs from the east(away from the subject property). This property should therefore not be affected by the project at all[.]" As is evident, that assertion and conclusion BOTH totally ignore and fail to consider that there is also a westerly facing dock for watercraft. Similarly, their agent offers photo imagery illustrating backing distances and vessel lengths in the Lagoon area while ignoring that none of those proffered and then included in the original staff report demonstrate such longer vessels doing such backing maneuvers and distances where, like that being proposed here, there is a second lift and longer boat moored waterward of the legally permitted boat slip. Staff asserts that it is only the otherwise conforming now fixed dock that would cause any interference. To the contrary, it is the petitioners' own desire to add their second, more water-ward, longer and larger boat and lift that clearly increases the angle of approach to the neighboring western dock! Stated differently, both the proposed boat lift and its pilings as well as the beam and length of a second, 36' vessel will increase the interference with use of both neighboring docks. At this point I'd ask the HEX to consider the supporting sworn testimony of Ms. DeSoto, Mr. Dunn, and Mr. Kravitz in this regard, in particular as to the preclusive impact of approving a waterward Page 5 of 15 protrusion on use and requiring adjacent property owners to then seek similar BDE approvals to maintain their customary usage in a safe manner. 2. Secondary criteria: a. Whether there are special conditions, not involving water depth, related to [either] the subject property or waterway, which justify the proposed dimensions and location of the proposed dock facility. (There must be at least 1 special condition related to the property; these may include type of shoreline reinforcement (N/A, standard concrete sea wall with cap), shoreline configuration (N/A-linear shoreline), mangrove growth (N/A-none), or seagrass beds (N/A-none) ). We contend that this criterion has NOT BEEN MET, because as stated above none of the listed circumstances (describing examples of what may qualify as a Special Condition for the PROPERTY) exist here. Petitioners' agent's analysis concludes that the platted canals and lots in the Lagoon area are what necessitates the nearly uniform shore-parallel docking facilities found throughout the Lagoon area. A candid evaluation of that conclusion leads inexorably to our position that, as petitioners otherwise state and acknowledge, there is nothing unique or SPECIAL about the subject waterway or lot. The stated basis for considering it to be a special aspect of the waterway or property is argued by petitioners' agent as having resulted from complying with the required 15' side setbacks of the two adjacent, neighboring lots, which limits the dock facility's location and dimensions to the remaining 50' waterfront length. Somehow, following the LDC requirements is suggested to justify that required compliant circumstance is a Special Condition. Reduced to its logical core the argument being made appears to be that because the existing "standard" lots and canal are "uniform" and almost all the same those conditions somehow act to transform this otherwise unremarkable lot and waterway into being a "special condition." Page 6 of 15 The staff report states that the criterion has met been because; 1) "neighboring dock facilities must be taken into account," and 2) "that the actual length of shoreline factors into the proposed dock design." Both of these are statements made in agreement with the petitioners' analysis. However, both the petitioners' rationale and staffs assertions are nothing more than a restatement of an analytical methodology, at best. It's patently obvious these should be a required part of the analytical framework and an actual analysis reaching a reasoned conclusion to support finding the criterion has been met. However, what they are NOT, is an actual substantive analysis of the applicable facts that would demonstrate what or how the proposed dimensions and location of the two-boat slip dock facility is justified. This is especially hard to accept as competent evidence by what is acknowledged by both to be the circumstances found in/at almost every other location in the Lagoon area, i.e., the Subject property has the exact same shoreline configuration and shoreline reinforcement as that of almost every other "more or less uniform" lot and canal in the Lagoon area. Similarly, petitioners state that, ". . . this shore-parallel configuration makes full use of the riparian area difficult or not possible should the applicant want to moor a boat that is larger than the combined 15' side setbacks of the applicant and their neighbor . . .". This point ignores completely that only certain, uncharacteristic shoreline configurations (not an as stated rather uniform and standard shoreline length as is found here) may justify a proposal's size and location as a Special Condition. Neither the applicant nor staff have provided a substantial analysis or any evidence in the record to support the conclusion that this criterion is being met for the subject property. At best staff reiterates the agent's positions. Most compellingly, however, the applicant appears to argue that because there are two 15' side setbacks leaving only 50' for a shore parallel dock Page 7 of 15 on the 80' linear waterfront, that by desiring to have a second vessel larger than the combined 15' setbacks between two adjacent lots, i.e., 30' of navigable water, that this self-created "want" justifies consideration as a Special Condition. To borrow a phrase, these supporting arguments to find a Special Condition are nothing more than stating, "the ends [two longer, larger boat slips]justify the means [being construed as a Special Condition to garner approval of its BDE]!" There is nothing distinguishable about petitioners' lot or adjacent waterway that gives or makes it a Special Condition. Only the request itself for a second shore parallel boat slip pushing the balance of the docking facility to waterward past the 20' maximum protrusion from shoreline limit is any different! Again, somehow the "want" is argued to justify the sought "need!" Before concluding argument on this criterion, we ask the HEX to take judicial notice of the HEX's denial of a BDE petition in Decision # 2022-42. On page three thereof this criterion was found to have been NOT MET due to the absence of any other Special Condition existing on an otherwise indistinguishable 70' width lot with a near identical straight shoreline configuration and seawall reinforcement, as exists here for the Subject property and waterway. Lastly, we assert that none of what petitioners and staff base their shared finding that this criterion has been met constitutes substantial evidence, and thus, in the absence of any supporting evidence and in consideration of our foregoing points we respectfully ask that the HEX find this criterion has NOT BEEN MET. b. Whether the proposed dock facility would allow reasonable, safe access to the vessel for loading and/or unloading and routine maintenance, without the use of excessive deck area not directly related to these functions. (The facility should not use excessive deck area). We would simply point out that this criterion has NOT BEEN MET TO THE EXTENT THAT A NARROWER FINGER DOCK THAN THE FOUR FOOT SOUGHT COULD SAFELY PROVIDE THOSE FUNCTIONS ALLOWING THE PROTRUSION TO BE REDUCED. Page 8 of 15 c. For single-family dock facilities, whether the length of the vessel, or vessels in combination, described by the petitioner exceeds 50 percent of the subject property's linear waterfront footage. (The applicable maximum percentage should be maintained). The petitioner and staff appear to recognize the third Secondary criterion has NOT BEEN MET, as the 50% maximum percentage of this 80' waterfront lot frontage, i.e., a maximum of 40' - cannot and will NOT be maintained if both vessels with a 67' total LOA are allowed to be moored in the proposed two boat slip docking facility! We agree- However, as was noted above in the first Primary Criteria (1.a)., and emphasized in more detail for the fourth Primary Criteria (1.d.), we strongly suggest that if the parenthetical mandatory text above pertaining to the maximum percentage of any property's linear waterfront footage in relation to the LOA of the number of combined vessels is EVER NOT maintained - such that IF a design for a dock facility that does not maintain the required percentages is ever APPROVED - THEN that mandatory portion of the LDC provision would not have been applied or properly considered. Such a result would render the mandatory requirement meaningless; treating those words in more legalistic terms as mere surplusage. Accordingly, our position is that under those clearly inappropriate circumstances, the HEX is compelled to DENY such requests where, as here, this criterion has NOT BEEN MET. d. Whether the proposed facility would have a major impact on the waterfront view of neighboring waterfront property owners. (The facility should not have a major impact on the view of a neighboring property owner). Our strong position is that as proposed this criterion has NOT BEEN MET because INITIALLY if one takes staff's acceptance of the petitioners'agent's position of what constitutes the "waterfront view" to mean only a property owner's rights of view along their riparian lines out to a waterway, then theoretically an otherwise compliant dock facility that extended out to the horizon across an open waterway would not be seen as imposing a "major impact" on the Page 9 of 15 waterfront view of a neighbor! Under the petitioners' analysis so long as the structure remained within the lot's riparian lines it WOULD NEVER HAVE a major impact. That position clearly contradicts the also applicable provision in LDC Sec. 5.03.06. A., which states, dock facilities should be only "minimally impacting . . . [on] the view of the waterway by the neighboring property owners." That provision seeks to balance the needs of adjacent property owners such that the intentions of an applicant do not create a major impact on their neighbor's waterfront view of the shared waterway. We believe the most well- reasoned application of these provisions is clearly intended to mean and be applied to more than just the constrained waterway view only visible within the adjacent neighbors' properties riparian lines. To apply the provision in this manner would result in finding this criterion would be met in almost each and every case where, like here, there are hundreds of standard and uniform lots and canals of various widths platted in a rectilinear pattern. Our position is that the LDC should not be interpreted in a manner where there is never any circumstance where it would apply. If as petitioner's riparian line position argues an adjacent neighbor's waterfront view would never be minimally impacted or suffer a major impact from an otherwise approvable BDE, then we assert that position effectively removes all discretion from the HEX's requisite consideration of the actual circumstances. That result is not only untenable, but contrary to the express intent of these provisions. Again, if applied as petitioners suggested, the criterion itself effectively becomes a nullity in almost every circumstance. A more practical and pragmatic approach is to apply these LDC provisions in a manner that evaluates more than whether a dock facility lies between an applicant's riparian lines or not. Accordingly, the degree to which a neighbor's pre-existing waterfront view of the shared waterway is reduced by a proposed dock facility should be evaluated as quantitatively as is Page 10 of 15 possible. To that end, a significant aspect of how a neighbor's waterfront view may be impacted has to do with what are the neighbor's traditional waterfront locations for viewing the shared waterway. In relation to those observation points, what are the relative heights above the waterway of the proposed obstructing object(s). For example, is their view to be considered from only a more waterward existing dock facility, or also from a pool or patio area on the land in the rear yard. If neither of these apply, consideration should be given to an observer's vantage point from their residential structure weighing the setback distances, number of habitable stories, and corresponding elevation above the waterway relative to the proposed obstructing objects. Also, the location of the proposed dock facility and neighboring properties relative to their position in or along a canal's or waterway's end and opening should be given weight, as well as the distance to the opposing shoreline(s). In the previously noted HEX Decisions 20-17 & 22-36, the opposing shoreline was well over three times that here for this unnamed canal, such that the adjacent neighbors' waterway views were not substantially diminished by the slight longer, perpendicular dock protrusions that were approved. Here, both adjacent neighbors have existing dock facilities with deck areas suitable for waterway viewing. Additionally, each has a traditional viewing space from their upland rear yard. The DeSoto residence is two-stories over a garage and other non-habitable space. The De Soto effected view is to the east and is only six lots from the end of the canal waterway. In stark contrast the effected waterway view from the Dunns' residence is primarily a westerly waterway canal view being only the fourth residence from the easterly canal end and it is only from an at grade, one-story dwelling unit that is setback slightly farther than its westerly neighbors. Qualitatively, taken together the factors above tend to show the overall view impact to the De Soto residence is lesser than that of the Dunns'. One can see clearly from a bird's eye view above that there is a greater impact on waterway view for the eastern Page 11 of 15 property than that to west of the Subject property. Additionally, the lower elevation of observation from the Dunn's on-grade residence is impacted much more than DeSoto. As can be seen from above there is a substantial loss of view of the waterway from both sides that in each instance is more than "minimal." But certainly, far more so from the Dunns' view and vantage points. More quantitatively the various points of waterway view for both adjacent neighbors are shown by what is depicted on what we are asking to have submitted into the record as "Objectors' Exhibit 2;" that being a copy of petitioners' dock facility location & dimensions drawings from their resubmitted application materials. Drawn thereon are corresponding sightline angles of view from selected perspectives. In contrast to petitioners' purely qualitative considerations, we have and are presenting evidence of approximately how many degrees of view of the adjacent waterway would be lost by each adjacent neighbor if the proposal would be approved without conditions. In addition, we're offering actual photo-imagery of the view impacts from the Dunn's property. [if not already done introduce the Dunn photometric images as "Objectors' Composite Exhibit 3," asking Mr. Dunn to describe when, by whom, & how those images were made, 9if necessary to overcome nay objection, ask Mr. Dunn if was present when the photos were taken YES, in his opinion do the photos portray a fair and accurate representation of condition then present) and then have him describe the impact if not done before]. In this case, neither the applicant nor the staff have offered more than subjective opinions and conclusions to support finding this criterion has been met. On the other side of the coin, we have presented competent and substantial evidence of a quantitative and observable nature to support our position that the HEX should find this criterion has NOT BEEN MET. Page 12 of 15 e. Whether seagrass beds are located within 200 feet of the proposed dock facility. (If seagrass beds are present, compliance with subsection 5.03.06(H)(2) of this LDC must be demonstrated).N/A f. Whether the proposed dock facility is subject to the manatee protection requirements of subsection 5.03.06(E)(11) of this LDC. (If applicable, compliance with section 5.03.06(E)(11) must be demonstrated). N/A g. If deemed necessary based upon review of the above criteria, the [HEX] may impose such conditions upon the approval of an extension request that it deems necessary to accomplish the purposes of this Code and to protect the safety and welfare of the public. Such conditions may include, but shall not be limited to, greater side setback(s), and provision of light(s), additional reflectors, or reflectors larger than four (4) inches. We are proffering to the HEX, that IF at the end of his analysis considering all of the foregoing points that the BDE should be APPROVED, we ask that the HEX respectfully consider the following conditions be imposed on any such approval: 1. that the addition of a boat canopy or boathouse be prohibited, 2. that the finger decking be reduced to minimize the waterward protrusion of the second boat slip, 3. that in lieu of a boat lift as proposed that the second, more waterward boat only be moored and secured to the fixed dock using available technologies and hardware, such as "sliders." IN CONCLUSION, IF THE PETITIONERS ARE UNWILLING TO ACCEPT THE CONDITION MY CLIENTS ARE WILLING TO LIVE WITH AS A COMPROMISE, AND AGREE TO ONLY MOOR THE SECOND LARGER VESSEL IN THE WATERWAY USING A SUITABLE MEANS TO SECURE THE VESSEL TO THE FIXED DOCK, THEN WE BELIEVE THEY SHOULD LOOK ELSEWHERE TO FIND PROPER DOCKAGE THAT DOES NOT: 1) MORE THAN MINIMALLY IMPACT ADJACENT NEIGHBORS' WATERWAY VIEWS, Page 13 of 15 2) HAS A LESSER IMPACT ON SAFE NAVIGATION OF THEIR NEIGHBORS' VESSELS TO AND FROM THEIR DOCKS, 3) HAS A TRUE SPECIAL CONDITION, AND 4) MAINTAINS THE MAXIMUM ALLOWABLE PERCENTAGE FOR COMBINED VESSEL LENGTHS! MR. HEX, THE FOREGOING TESTIMONY AND RECORD EVIDENCE DEMONSTRATES THAT UNDER THE TOTALITY OF THE CIRCUMSTANCES YOU SHOULD FIND THAT SUFFICIENT CRITERIA WERE NOT MET AND THAT AS PROPOSED THE TWO BOAT SLIP DOCK FACILITY PETITION SHOULD BE DENIED! THANK YOU, AND WE ARE AVAILABLE TO ANSWER ANY QUESTIONS. Page 14 of 15 PRIOR BDE APPROVALS IN THE VANDERBILT-CONNERS AREA LAGOON HEX BDE REPORT# APPVL DATE LOCATION REQUEST APPROVED 19-50 12/18/19 116 Heron 1 vessel & slip + 1.9' extension w/ boathouse 20-08 10/06/20 250 Egret 1 vessel & slip +1.1' extension for after- the-fact BDE 20-17 10/23/20 300 Oak 1 boat & slip & 2 jet skis, + 24' 90° dock,75' lot, on 750' waterway 22-02 09/23/21** 10091 Gulf Shore 1 48' boat & 2 jet skis +24' irregular end of canal separated small lot w/VAR's 22-36 08/11/22** 336 Oak add 1vessel +23'-75' lot to 1 pre-existing dock, 90° dock on -700' waterway 22-43 09/08/22** 152 Heron 1 40' angled boat & slip + 2.6' for boathouse overhang 22-47 12/12/19** 260 Conners 1 40' boat & slip, angled dock,+11 undated; hearing date ATTACHMENT "A" Page 15 of 15 47' BDE-PL20210002320 415 Seabee Avenue Attachment I—Additional Public Correspondence, received after first hearing on October 13, 2022, and After Publication ems" l A `". -rn* lc' �;it" I• c1 g1 1 vio , \343 1: 13: 375 . I. 391 :p .t t::er 424 40.7 453 467• J ,4g; , 4 1, t I-L -� 1 x • 4 46. 4" a i , i. �� ram, • ii, 4` `41 Conners AVE • ?.7g4 ' ; 364 I 11 r a@ p. 4 13 • 80 ' 396 404 418 F 4.14 450 54 490 r ...�..# .._ .' .tom ^' us1 _ji _8,Tql. r. L., , .. , , ,.. ,i,.[.. .. ____ : , .4 11 . 403 Ilk. ON k 34•9 %lb, 7 383 H i 415 il P • iI i L - t II a ` NM i' -• Seabee AVE TA vii. irtiri, > ' '� e 366 378 39.1 '406 418 430 I /452. '478: . 342 354 4 11\ Excp:V ;j� '•I' 4 - r� t • Ks 497 1I .157 375 WO L ?5C ;er Q• + "" r Collier County GIS Applicant/Petitioner— 415 Seabee Avenue Letters of Objection — 449 Seabee Avenue (S. Palumbo) From: Interstate Properties<interprop33@yahoo.com> Sent: Wednesday, February 8, 2023 10:47 AM To: KellyJohn Subject: Objection letter for pre-application 20210002320 Attachments: Boat dock extension objection.docx EXTERNAL EMAIL:This email is from an external source. Confirm this is a trusted sender and use extreme caution when opening attachments or clicking links. Hello Mr. Kelly, Please find attached My letter for the Boat dock extension at 415 Seabee Ave. Naples Fl 34108 Best Regards, Salvatore Palumbo A Company Managed for Your Needs. Interstate Properties 999 Broadway Suite 400 Saugus, Massachusetts 01906 Office: 781 231-6800 Fax: 781 233-1176 Re: 415 Seabee Ave Pre-Application Number: 20210002320 From: Salvatore Palumbo 449 Seabee Ave Naples Fl 34108 February 8, 2023 Mr. Kelly, My name is Salvatore Palumbo and I have resided at 449 Seabee Ave Naples Florida for the last 30 Years. It has come to my attention that the resident at 415 Seabee Ave has filed an application for a boat dock extension. I would like to state that I adamantly reject the proposal for the boat dock extension at 415 Seabee Ave. I am located 2 houses down from this location and this would prohibit my visibility and enjoyment of my current view. This proposal would also cause my property value to decline, causing financial hardship. 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OU IICC C z W • U z ce 6 W Z o M O z z c w = z W c, ow O LU > � m Z o ce Qo -P¢ z O \ , ¢ w W ww I- o W Ow >- O E-. w ¢ mw >- =o -' O � o J CO �1 - O � � w _ � .W w < -1---=.--- rt .Ca w- - — --- - --44 N - W-z-----0—C m — 5 a < w - N= Et v 0, Q mp fl _ LL 52,0 E ¢ o � zoo O '�. V•) w o m f-- 0 0 � 2 �- w Z v CD =- W Om a) E• �, za 0 w � o zj � m = 0 N 0 0 = I_ 0 a) 0 = O D O a -a }- I- > (Es 0 y ' Q w ~ O 6 Z LL 0 - U. Ow Y -- ( zcr ¢ cam c~n 1W- m � Cl)votill 3I-U = o2_ N ila_ NI cJ z < ILL 0US. m Z r z z Off , z c��., aD zm 0 zcn i = \\t 0 0 o m0 I w m cIli 0fx o w r ; r L o Z 3- BDE-PL20220002146 167 Sunset Cay Attachment G—Public Correspondence Received after Publication of Staff Report • ' ..� Stella Marls DR S ""W-M" • Zoning:C-1 ' •.•t N. /w �� r y t'i `{, i i ►YI1 31-9-` 30.:3.2 gr24 2. 286 ` 274, 270 i 2.2 258 2.54 250 24,• _ `, ` ` �" 4 t , 46 `-17 ...sift N,• .yt2p"•fl r[', •• 'lreF...'• . / '�.':: :.p A, . _.- ____ 235 C,ai,. 1731 jot j 227,2 if . o R:28 it:6_ 2G9.- -._. S:09 RI•l � i216 ZR r • ':.', t , 4. ; - , 'I i • . � h • thin,2ixi � ,I,.:. . '' • • Zont g RSF.4 • , 4. .► sunset r +S.. , . .i _ _ i1 / ,. 9u, , ,4 82 , . . 174 r 9l' 14,' • i ,.- S.. .., t 1 . , .4,;... ,--- a/ �_ j_. �_ ..-,--s_ --_ - .. • _. t� T ... �y , 1.74 1 I Collier County GIS Applicant/Petitioner— 167 Sunset Cay Letters of Objection — 290 Stella Maris Drive (D. and C. Heffelmire) From: Dan Heffelmire<dan@hbspecialties.com> Sent: Monday, February 6, 2023 10:03 AM To: KellyJohn Cc: Connie Heffelmire Subject: RE: Collier County, FL-The Hearing Examiner will be meeting on February 9, 2023 at 9:00 AM EXTERNAL EMAIL:This email is from an external source. Confirm this is a trusted sender and use extreme caution when opening attachments or clicking links. Mr.John Kelly, I am writing you in regards to, BDE-PL20220002146—167 Sunset Cay— Request for a 35-foot boat dock extension. 1. My wife, Connie, and myself are opposed to the this dock extension request. This 35 foot extension onto the 20 foot normal dock is over the top excessive in our common water canal. 2. Connie and I own the property 290 Stella Maris Drive South, which is a little East and across the canal of this property. 3. We purchased this property to retire at and we have just completed a total remodel. One of the reasons we selected this location was for the amazing view of the open water canal. 4. Having a dock extending 55 feet out into the canal will largely negatively block our view of the canal to the west, which is the most desired view for everyone on this canal. a. A 55 ft boat/yacht most likely will be 20ft above the water and this is just building a wall 20' x 55' and it blocks the view for everyone east of this dock. b. This is an infringement on the beauty of this canal,that we paid extra for. This dock extension is very excessive and it will negatively impact all of us who live east of this property. There is a marina 500' (estimated)from this property and they are designed to handle yachts of this size. He should rent a spot in the marina. Sincerely, Dan &Connie Heffelmire 290 Stella Maris Dr. South. From: KellyJohn <John.Kelly@colliercountyfl.gov> Date: February 2, 2023 at 2:33:13 PM EST Subject: Collier County, FL-The Hearing Examiner will be meeting on February 9, 2023 at 9:00 AM Good afternoon, Collier County's Hearing Examiner will be meeting on February 9'2023, at 9:00 AM.The meeting will be at held at the County's Growth Management Building, Conference Rooms 609+/610, located at 2800 North Horseshoe Drive which is immediately north of the Naples Municipal Airport (there is a large RaceTrac gas station at the corner on Airport Rd.). You are receiving this e-mail as you had previously expressed an interest in one or more of the following zoning petitions: 1. BDE-PL20210002320—415 Seabee Ave—Second Hearing, request for a 12-foot boat dock extension; 2. BDE-PL20220002146— 167 Sunset Cay— Request for a 35-foot boat dock extension; 3. BDE-PL20220000501—231 Dolphin Cove Ct—Request for a 2.75-foot boat dock extension; and/or 4. NUA-PL20220004583—326 Alachua St—Request for a non-conforming use alteration to allow the replacement of a carport. Each of the aforementioned items was continued to the February 9th meeting as a result of a previously scheduled meeting having been cancelled. The electronic Agenda for this meeting is available at: http://colliercountyfl.igm2.com/Citizens/Detail Meeting.aspx?ID=2103.The electronic agenda includes all materials, including the Staff Report and public correspondence,that have been provided to the Hearing Examiner for the purpose of conducting this meeting and evaluation of the subject petitions. Meetings of the Hearing Examiner are public meetings and the public is invited to attend, in-person or remotely via Zoom. Persons interested in either participating or monitoring the meeting via Zoom must register via the following URL: https://bit.ly/2923HEX. Feel free to provide this link to any persons expressing a desire to attend this meeting remotely. Please note that the County will do its best to avoid any complications involved with remote participation; however, issues due occur from time to time. You are asked to not wait until the last minute to test your connectivity to Zoom. As always,you're welcome to contact me in the event you have questions or concerns not previously addressed. Please, be certain to note which of the four projects you are writing or calling about. As always,thank you for taking an active role in your community. Respectfully, John Kerry Planner II Zoning Division-Zoning Services Section 2800 North Horseshoe Drive,Naples Florida 34104 Phone:239.252.5719 Fax:239.252.6363 Email:John.Kellv4colliercountvfl.gov Tell us how we are doing by taking our Zoning Division Survey at http://bit.ly/Col I ierZon i ng aj COY County Growth Management Department Under Florida Law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by telephone or in writing. V '1) Golden Gate Water Reclamation Facility (CU) (PL20210001657) V �r r-.. M p, ap t r PUBLIC HEARING NOTICE tee". , ` .., ' • GOLDEN GATE WATER RECLAMATION •8}� 'r ''�,� �.4,..,,,.+ 4vs...94,1000� : FACILITY(CU);PETITION NO. PL20210001657 .� . , #��!*o� ;r*ILI''��*�1j��ae e �.��e .•40. HEX: FEBRUARY 9.2023-9:00 A.M. ..+_ w -__ GROWTH MANAGEMENT BUILDING,210 HORSESHOE DR.N.,ROOM.60gf&gl' NAPLES.FL3110A rt y'. }. TIMOTHY FINN:239-2 X 4 ,e �".. N .. y r - '� • • , i .. , ISe'��'y a P `/ ;'. ..P /6,••, 4Z",.. 4 :1 W Z w yijo,...40,......m..0-1- , e. c sibs'! ! r e r' s"' . " ' 'Vit'- '.I '. PUBLIC HEARING NOTICE • • GOLDEN GATE WATER RECLAMATION '9 • FACILITY (CU); PETITION NO. PL20210001657 , j' ' C2 : HEX:FEBRUARY 9, 2023 -9:00 A.M. GROWTH MANAGEMENT BUILDING, 2800 •' " �t = � HORSESHOE DR. N., ROOM 609/610, ce - - NAPLES, FL 34104 g` r A TIMOTHY FINN: 239-252-4312 ;' 'i, E. .* ° '> Y•, g _S<<1 '"Alt' 3� 4r�'K'\^ try' ;r,^i! 1' 3.P 0:i -•t �'[ .�1 � 3 3^' .y�r . „ 'k • ...; 9''.i } ;...yam y• < .V y '* x-i', • +5P•, ../ ( P''`' ,4.' ar'�\ fit.d%`›;BX 1. r. 1"iF. . .f•,. r ,P:- .4 `• Y t'Y 1 f, S �A a r=v�•' .'—'. ;�a 'J W: ' ,Ak,...t: Updated January 25, 2023 Golden Gate Water Reclamation Facility (CU) (PL20210001657) ' ,kt,jal.t. , .'. .4\ pn: ''''': ' " -41 11 .) '' A .. �' x �:',. . P 'Tom[ t'.S+ •f.a,... �. ;i, ,,, PUBLIC HEARING NOTICE 'i _ b ,;'. t = f .� GOLDEN GATE WATER RECLAMATION Tor w .v."-• + :. FACILITY(Cu)-PETITION NO. PL20210001657 .r 4�k v kI, _1r4 ♦.v,�IN 4 . HEX: FEBRUARY 9.2023-9:00 A.N. '!t*V._ E. '• GROWTH MANAGEMENT BUILDING IRO HORSESHOE DR.N.,ROOM.-60k6,4i NAPLES.FL 3410A �t -`' 1,. TIMOTHY FINN:239-25X � 3 T4- i at f ��y. w y/ yy fit �„. �~iy K• • �,,�� rr J' , ' r �.r • a ,•.(4: a rt,i 3pr .��,�A'4,-,, ,, it ;.. } off;. 0 i"AS'a �ilvY3 4 :'-- 4-c•t' 1.-. , el ,,Q r,. 40,.. ,� 1 ., Ra 's,.' " , l�t��t t^v3 F�- .a:y. ,'•,r ei- , PUBLIC HEARING NOTICE414 'I nimm.iiiii Ali. -_*.'-„I‘--:-.76-. -4 GOLDEN GATE WATER RECLAMATION ," Fr °Il y� FACILITY (CU); PETITION NO. PL20210001657 , ,r HEX: FEBRUARY 9, 2023 -9:00 A.M. .-it a GROWTH MANAGEMENT BUILDING, 2800 , '`', .: .' * F HORSESHOE DR. N., ROOM 609/610, a .,-4 . ,T - NAPLES, FL 34104 .4 . 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P.A. & Associates Paa1.MAAfe.NEW ALUMINUM CARPORT THE CONTRACTOR, Q , • XI _ ac.L P.o BOA Isea Architect - Planner NAPLES,FL 34108-1588 P Iz )ezf ufe ADDRESS: cm[aaaePwncasm+� wwrr. Nj N uc.Izzos —0 4 . ;n 3880 u m ST.H. 326 ALACHUA ST,IMMOKALEE,FLORIDA 34142 M q z m Q NAPLES,FL Sat O3 E-MAIL JAIMEARCHITECTIOOMAILCON OZ DESCRIPTION^ A.... ._-_--- ------- --------------- ris