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HomeMy WebLinkAbout7/12/1994� MINUTEnTTACHED BOARD OF COUNTY COMMISSIONERS INDIAN RIVER COUNTY, FLORIDA A G E N D A REGULAR MEETING TUESDAY, JULY 12, 1994 9:00 A.M. - VERO BEACH HIGH SCHOOL AUDITORIUM VERO BEACH HIGH SCHOOL 1707 16TH STREET VERO BEACH, FLORIDA COUNTY COMMISSIONERS John W. Tippin, Chairman (Dist. 4) James E. Chandler, County Administrator Kenneth R. Macht, Vice Chairman ( Dist. 3 ) Fran B. Adams ( Dist. 1) Charles P. Vitunac, County Attorney Richard N. Bird (Dist. 5) Carolyn K. Eggert (Dist. 2) Jeffrey K. Barton, Clerk to the Board 9:00 A. M. 1. CALL TO ORDER 2. INVOCATION - None 3. PLEDGE OF ALLEGIANCE - Comm. John W. Tippin 4. ADDITIONS TO THE AGENDA/ EMERGENCY ITEMS 5. PROCLAMATION AND PRESENTATIONS None 6. APPROVAL OF MINUTES A. Regular Meeting of June 14, 1994 B. Regular Meeting of June 21, 1994 7. CONSENT AGENDA None B. CONSTITUTIONAL OFFICERS AND GOVERNMENTAL AGENCIES None 9:05 a. m. 9. PUBLIC ITEMS A. PUBLIC DISCUSSION ITEMS 1. An Appeal by Attorney Warren Dill of the Planning & Zoning Commission's Decision that Grocery Stores 6 Supermarkets are Like Uses as Appfied in the Indian River County Land Development Regulations (memorandum datid. July 6; 1994) L- JUL 12 1994 9. PUBLIC ITEMS (cont'd. ): A. PUBLIC DISCUSSION ITEMS (cont'd. ): 2. An Appeal by Halvorsen Development Corp. of a Planning E Zoning Commission Decision to Deny Site Plan Approval for a 46,560 Sq. Ft. Shopping Center at the Southeast Corner of S.R. A -I -A & Mooring Line Drive (memorandum dated July 6, 1994) B. PUBLIC HEARINGS None 10. COUNTY ADMINISTRATOR'S MATTERS None 11. DEPARTMENTAL MATTERS A. COMMUNITY DEVELOPMENT None B. EMERGENCY SERVICES None C. GENERAL SERVICES None D. LEISURE SERVICES None E. OFFICE OF MANAGEMENT AND BUDGET None F. PERSONNEL None G. PUBLIC WORKS None H. UTILITIES None 12. COUNTY ATTORNEY None 13. COMMISSIONERS ITEMS A. CHAIRMAN JOHN W. TIPPIN 13. COMMISSIONERS ITEMS (cont'd. ): B. VICE CHAIRMAN KENNETH R. MACHT Land Acquisition Advisory Committee Recommendation (memorandum dated July 6, 1994) C. COMMISSIONER FRAN B. ADAMS D. COMMISSIONER RICHARD N. BIRD E. COMMISSIONER CAROLYN K. EGGERT 14. SPECIAL DISTRICTS A. EMERGENCY SERVICES DISTRICT None B. SOLID WASTE DISPOSAL DISTRICT None 15. ADJOURNMENT ANYONE WHO MAY WISH TO APPEAL ANY DECISION WHICH MAY BE MADE AT THIS MEETING WILL NEED TO ENSURE THAT A VERBATIM RECORD OF THE PROCEEDINGS IS MADE WHICH INCLUDES THE TESTIMONY AND EVIDENCE UPON WHICH THE APPEAL WILL BE BASED. ANYONE WHO NEEDS A SPECIAL ACCOMMODATION FOR THIS MEETING MAY CONTACT THE COUNTY'S AMERICANS WITH DISABILITIES ACT (ADA) COORDINATOR AT 567-8000 X 408 AT LEAST- 48 HOURS IN ADVANCE OF MEETING. JL 12 IP,14 Tuesday, July 12, 1994 The Board of County Commissioners of Indian River County, Florida, met in Regular Session at the Vero Beach High School auditorium, Vero Beach, Florida, on Tuesday, July 12, 1994, at 9:00 o'clock a.m. Present were John W. Tippin, Chairman; Kenneth R. Macht, Vice Chairman; Fran B. Adams; Carolyn K. Eggert; and Richard N. Bird. Also present were James E. Chandler, County Administrator; Charles P. Vitunac, County Attorney; and Barbara Bonnah, Deputy Clerk. Chairman Tippin called the meeting to order and led the Pledge of Allegiance to the Flag. APPROVAL OF MINUTES The Chairman asked if there were any additions or corrections to the Minutes of the Regular Meetings of June 14, 1994 or June 21, 1994. There were none. ON MOTION by Commissioner Eggert, SECONDED by Commissioner Bird, the Board unanimously approved the Minutes of the Regular Meetings of 6/14/94 and 6/21/94, as written. LAND ACQUISITION ADVISORY COIVIlVIIU TEE Chairman Tippin announced that the Board would consider Item 13-B as the first item of business rather than waiting until the end of today's meeting. Commissioner Bird announced a conflict of interest in this matter and stated he would abstain from any discussion or vote. He advised that LAAC made a recommendation to the Board of County Commissioners to reject the Trust For Public Land's counteroffer on the Korangy property. He explained that his realty firm has a listing on the Korangy property which is under option to the Trust For Public Land. MEMORANDUM OF VOTING CONFLICT FORM 8B IS ON FILE IN THE OFFICE OF THE CLERK TO THE BOARD 4,a�K FACT (� July 12, 1994 BOOK The Board reviewed the following memo dated 7/6/94: TO: Board of County Commissioners FROM: Chairman Ren Macht, Chairman -OW Land Acquisition Advisory Conudittee DATE: July 6, 1994 SUBJECT: LAAO Motions Made as Recommendations to the Board of County Commissioners 92 Na- f ON MOTION by Jay Smith, SECONDED by Robert Schoen, the Board agreed by a vote. of 9 to 3, Pat Brown, Janice Broda and Ruth Stanbridge voting in opposition, to recommend that the Board of County Commissioners reject the Trust for Public Land's offer of $826,250 for the sale of the Rorangy Tract. ON MOTION by Janice Broda, SECONDED by Pat Brown, a motion was made and rejected, by a vote of 8 to 4, Ruth Stanbridge, Carolyn Corum, Pat Brown and Janice Broda voting in favor of the motion, to recommend to the Board of County Commissioners that they direct staff to hire a review appraiser. ON MOTION by Jay Smith, SECONDED by John Morrison, the Committee agreed by a vote of 7 to 5, Carolyn Corum, Pat Brown, Robert Swift, Robert Schoen, and Janice Broder voting in opposition, to recommend to the Board of County Commissioners that they not enter into the contract with The Nature Conservancy at this time but to look into other options. Thank you for your consideration of the above recommendations. ON MOTION by Commissioner Eggert, SECONDED by Commissioner Macht, the Board by a vote of 4-0, (Commissioner Bird abstaining) accepted the above report from the Land Acquisition Advisory Committee. 2 July 12, 1994 APPEAL BY ATTORNEY WARREN DILL OF THE PLANNING & ZONING COMIVIISSION'S DECISION THAT GROCERY STORES AND SUPERMARKETS ARE LIKE USES AS APPLIED IN THE IRC LAND DEVELOPMENT REGULATIONS County Attorney Charles Vitunac asked everyone, including staff, who planned to testify in this hearing to stand and be sworn en masse. He further instructed those who do come forward to the microphones placed at each side of the auditorium to state whether or not they have been sworn in. If not, they will be sworn in at that time. Attorney Vitunac thereupon swore in everyone standing. Community Development Director Bob Keating introduced the following staff members: Planning Director Stan Boling; Senior Planner John McCoy; County Engineer Roger Cain; Traffic Engineer Bill Strange; and Public Works Director Jim Davis. Director Keating explained that this is the first of two appeals to be heard today and this hearing concerns an appeal by Warren Dill of a Planning & Zoning Commission (P & Z) action upholding a staff decision made in his capacity as Community Development Director. He advised that the issue in this case is whether or not supermarkets are allowed in a CL zoning district, and he stressed that this is not a site specific question but rather a general use question which affects the CL zoning district throughout the county. Director Keating presented the following staff recommendation for denial of the appeal filed by Attorney Warren Dill on behalf of the concerned residents of The Moorings: July 12, 1994 I r- -# BOOK PAGE 1 I � TO: James E. Chandler County Administrator D SION HEAD CONCURRENCE: Robert M.KbatJng,alp ,P Community Develop Director I& THROUGH: Stan Boling, AICP Planning Director FROM: John W. McCoy, AICP �� A Senior Planner, Current Development DATE: July 6,-.1994 SUBJECT: An Appeal by Attorney Warren Dill of the Planning & Zoning Commission's Decision That Grocery Stores & Supermarkets are Like Uses as Applied in the Indian River County Land Development Regulations It is requested that the data herein presented be given formal consideration by the Board of County Commissioners at its regular meeting of July 12, 1994. This is the first of two appeals that relate to the proposed Sea Mist Shoppes development. The other is an appeal by the applicant of the Planning and Zoning Commission's denial of the Sea Mist Shoppes major site plan application. These appeals are scheduled to be heard consecutively, with the use issue considered first and then the site plan issue. BACKGROUND: •The Appeal: Points of Disagreement Attorney Warren Dill has filed an appeal on behalf of concerned residents of The Moorings regarding a use determination made by the Planning & Zoning Commission at its June 9, 1994 regular meeting. (see attachment #1). The Planning & Zoning Commission's action upheld a staff determination that: 1. grocery stores and supermarkets are the same use in the context of the county zoning code, specifically section 911.10(4) of the County's Land Development Regulations; and 2. that such grocery store/ supermarket use is permitted in the CL zoning district (see attachment #2). The zoning code (Chapter 911) specifically lists the use "grocery stores" but does not specifically list the use "supermarkets" nor "shopping centers". •The Appeal: History & Effect Upon receipt of a request from Mr. Dill for a determination regarding "supermarkets" (see attachment #3), staff reviewed the July 12, 1994 4 II � i I request pursuant to LDR section 911.04(2)(b) (attachment *4) and issued a determination that: 1. Relative to the county zoning code, "grocery store" use includes "supermarket" use; and 2. Grocery stores/supermarkets are permitted uses in the CL zoning district. The residents appealed this decision, since the decision affects the Mooring's commercial property and the proposal for the Sea Mist Shoppes. Since the Planning & Zoning Commission, after considering the appeal, agreed with staff's decision, the residents are now appealing the Planning & Zoning Commission's decision. It should be noted, however, that the results of the appeal will affect where grocery store/ supermarket uses are. allowed throughout the unincorporated area of the county. The Board of County Commissioners is now to consider the appeal and either grant the appeal and overturn staff's and the Planning & Zoning Commission's decision or deny the appeal and uphold staff's and the Planning & Zoning Commission's decision. If the Board grants the appeal and overturns the decision of staff and the Planning & Zoning Commission, the Board will then need to: A. Specifically define by size and/or use characteristics the terms "grocery store" and "supermarket" B. Specify which zoning district(s) a "supermarket" use is allowed. C. Specify the type of approval (eg permitted, administrative permit, or special exception) needed for a "supermarket" use in a given district. If administrative permit and/or special exception approvals are specified, then specific land use criteria must also be specified. PLANNING & ZONING COMMISSION ACTION At its regular meeting of June 9, 1994, the Planning & Zoning Commission voted 3 to 2 to uphold thestaff's determination that grocery store/ supermarkets are similar uses as applied in the Indian River County Land Development Regulations. In denying the appeal, the Planning & Zoning Commission found that the staff did not fail to follow any of the four appeal criteria. Since it takes four votes to overturn a decision of the Community Development Director and only two votes "favored" overturning staff's decision, the 3 to 2 vote to deny the appeal by the Planning & Zoning Commission is an effective action. ANALYSIS: •Definitions Since the LDRs do not define the terms "grocery store" or "supermarket", staff considered several different sources to determine how the terms "grocery store" and "supermarket" are defined. A grocery store trade magazine resource cited by the appellant is "The Progressive Grocer". "The Progressive Grocer's" 1994 Marketing Guide Book defines the terms as follows: Grocery Store: "Any retail store selling a line of dry grocery, canned goods, 'or non-food items plus some perishable items." July 12, 1994 L_ 5 BOOK �2 Ph JE ~/ 1 BOOK P� Supermarket: "Any full line, self service grocery store with sales volume of $2 idillion or more annually." The Guide Book further defines an even larger grocery store (over 30,000 square feet) as a "superstore". Thus, "The Progressive Grocer" defines supermarket as a type and subset of grocery store, with a supermarket characterized as having $2 million or more in annual sales. According to testimony at the Planning and Zoning Commission meeting by the appellant's planning consultant, this sales volume would roughly equate to a 4,204 square foot store, based -on $11.38. per square foot. The applicant has cited definitions of "grocery (store)" and "supermarket" from two dictionaries (see attachment #1). The definitions are consistent with the definitions in other common dictionaries that staff uses. Listed below are the definitions for grocer, grocery store, and supermarket from Websters Ninth New Collegiate Dictionary: Grocer: a dealer in staple food stuffs, meats, produce and dairy products and usually household goods. Grocery Store: 1. Commodities sold by a grocer, 2. A grocer's store. SuperMarket: a self service retail market selling foods and household merchandise. These definitions, including the appellant's, indicate that the same type of merchandise is sold at grocery stores 'and supermarkets, and that the uses are essentially the same. Definitions indicate that supermarkets are large grocery stores, which is precisely staff's point. "Supermarkets" may logically be defined as a type of grocery store (a large grocery store). •COMPARISON OF "GROCERY STORE" AND "SUPERMARKET" USES It was staff's intent, in using the term "grocery store" when drafting the zoning code, to include supermarkets. That is why the term supermarkets does not appear in the zoning code. In essence, it would be redundant to list the same use twice. Since "supermarket" is not a specifically listed use category, however, staff went through the procedure set -out in the LDRs to determine the most similar use to "supermarket". According to the LDRs, such a determination shall be made based upon a review of the Standard Industrial Classification (SIC) code, a source which is used as a general framework for the zoning code. Other factors which may be considered shall be characteristics such as: traffic generation, parking requirements, noise, compatibility to surrounding uses, lighting, hours of operation, intensity, visual impacts, and type of traffic. Staff's determination was made based upon a review of the SIC code and a comparison of these criteria and other logical factors. •SIC Review The Standard Industrial Classification (SIC) (attachment #5) is a system for classifying establishments by type of economic activity. The SIC manual groups, by 4 digit SIC number, those types of establishments that primarily engage in the same activity (use). The SIC code is one of the most extensive compilations of industry classification available. Since the SIC code was used as a general framework -and reference tool for developing the zoning code, the SIC code is also used in interpreting the county's zoning code. July 12, 1994 F-7 L 6 M _I Section 911.04(2)(b)2 (see attachment #4) of the County's LDRs states that staff shall review the Standard Industrial Classification (SIC) code as the primary basis for determining unlisted uses, such as the "supermarket" use. When comparing the SIC code and the county's commercial use table, it is clear that "supermarkets" are to be considered a type of grocery store. In reviewing the CL zoning district list of allowable uses (attachment #2) and the SIC code's industry number classification (attachment #5), it can be seen that the lists follow one another precisely, as illustrated below. Zoning Code Use Table Category SIC Code Industry # & Reading Grocery Store 5411 Grocery Stores Meat & Fish Market 5421 Meat & Fish Market (Seafood) Inc. Freezer Provision Fruit & Vegetable Market 5431 Fruit & Vegetable Markets Candy, Nut & Confectionery Stores 5441 Candy, Nut, and Confectionery Stores Dairy Products Store 5451 Dairy Product Stores Retail Bakeries 5461 Retail Bakeries The food store uses listed in the zoning code track the SIC code industry numbers, meaning that any sub -use listed within the industry number that is not listed in the zoning code would be included and allowed under the SIC use category stated in the zoning code. In reviewing the SIC code (attachment #5), supermarkets appear as a subset of grocery stores (Industry #5411). This would be comparable to allowing a produce market under Fruit & Vegetable Markets (Industry # 5431). The SIC code clearly considers supermarkets to be a type of grocery. In using the SIC as the framework of the zoning code, it is clear that supermarkets were intended to be permitted as a type of grocery store, and that the unlisted "supermarket" use falls under the "grocery store" category. •Review of Other Characteristics Section 911.04(2)(b)2 of the LDRs (attachment #4) indicates that staff may consider other factors in a use determination. These factors include traffic generation, type of traffic, parking requirements, compatibility to surrounding uses, noise, lighting, visual impacts, hours of operation, and intensity of use. In comparing these factors for grocery stores and supermarkets, staff found no significant differences. Below is a more detailed summary of the comparison of these factors: Supermarket Grocery Parking 1 space per 200 sq.ft. 1 space per 200 sq.ft. Traffic Impact Fee $2860 per 1,000 sq.ft.; for $2860 per 1,000 sq.ft.; District 2 stores 10,000 sq.ft. or less for stores 10,000 sq.ft. or less $1628 per 1,000 sq.ft.; for $1628 per 1,000 sq.ft.; stores 10,001-50,000 sq.ft. for stores 10,001-50,000 sq.ft. Type of Traffic Primarily passenger vehicle Primarily passenger (some delivery) vehicle (some delivery) Hours of Operation 9:00 a.m. - 9:00 P.M. 9x00 a.m. - 9:00 p.m. -Noise, lighting, and visual impacts are factors that are similar for the two uses. Since grocery stores/supermarkets are commonly found in association with shopping centers, these factors are affected significantly by the .size and design of the shopping center, rather than by the specific uses. 7 July 12, 1994 BOOR 92 PAGE 18(i ,j� I BOOK 92 PACE "Si -Intensity: Grocery stores/supermarkets are of similar intensity on a per unit area basis. For retail food stores, the intensity decreases *as the store size increases, as measured on a per area unit basis. -Trip Generation: The Institute of Transportation Engineers, Trip Generation Manual (4th Edition) lists "shopping centers" and "supermarkets" as use categories for traffic generation purposes. The manual does not list "grocery stores". The Trip Generation Manual does confirm that, generally, the number of trips decreases • on a per 11000 square foot basis as the size level of the store increases.- -Compatibility to Surrounding Uses: Compatibility with surrounding areas is addressed at two levels. The first level deals with the broad compatibility issues at the land use and zoning levels. Essentially, this is a question of whether two different zoning districts should abut. Since the CL zoning district is a district which allows the convenience type uses needed to support residential areas, the CL district is routinely found in close proximity to residential areas. The practice of locating restricted commercial areas in close proximity to residential uses and allowing convenience type shopping uses within the restricted commercial areas is a commonly accepted planning practice that makes sense and is supported by a wealth of planning literature. Planning literature also shows that grocery stores and supermarkets are both treated as convenience uses that serve neighborhood areas and are appropriate uses in restricted commercial areas. Thus, in relation to appropriateness and compatibility within restricted commercial districts such as the CL district, there is no difference between grocery stores and supermarkets. For that reason, CL districts are compatible with adjacent residential areas when buffering is provided with site design. The second level deals with site related compatibility issues; these are addressed at the time of site plan.review and approval. Involving physical separation and buffering, traffic operations, general layout, lighting, screening of solid waste storage areas, and other site design criteria, these characteristics address site oriented compatibility concerns. Design features and compatibility measures are the same for grocery stores and supermarkets. Thus, in relation to site plan design compatibility features, there is no difference between grocery stores and supermarkets. A comparison of compatibility characteristics indicates that the two uses are the same. •PERMITTED USE IN THE CL DISTRICT The appellant also disagrees with staff's determination that the grocery store/supermarket use is a permitted use in the CL district. The appellant indicates that he considers the size of the proposed Sea Mist Shoppes grocery store/supermarket to violate the purpose and intent of the CL zoning district. The CL district purpose and intent reads as follows: "CL: Limited commercial district. The CL, limited commercial district, is intended to provide areas for the development of restricted commercial activities. The CL district is intended to accommodate the convenience retail and service needs of area residents, while minimizing the impact of such activities on any nearby residential areas." 8 July 12, 1994 I � ® s The appellant has stated that "grocery stores are allowed in the CL zoning district because they are compatible with the purpose of the district,*and supermarkets are not." It is staff's position that supermarkets are not a listed use in any district because supermarkets are a type of grocery store, and clearly allowed in the CL zoning district. Presently, there are approximately 10 grocery stores/supermarkets • in the unincorporated area of the county, all of which are located in areas -zoned CG (General Commercial). Most of the grocery stores/supermarkets are associated with shopping centers -that have close to or greater than 100,000 square feet of retail area. There are no grocery stores/supermarkets presently located in the CL zoning district. It should be noted, however, that staff has processed applications for shopping centers with grocery stores/supermarkets in the CL zoning district. One such example was for a Food Lion that was proposed at the northwest corner of 27th Avenue S.W. and 9th Street S.W. In fact, that site was rezoned from residential zoning to CL to accommodate the Food Lion and other retail stores within a proposed shopping center. The appellant goes on to state "...Also, Super Markets are not allowed in the CL district because the size is far in excess of what is needed to serve area residents and the resulting impacts have an adverse effect on nearby residential areas. Super Markets are more appropriately located in the CG district because it is intended to accommodate general retail sales uses of this type." This statement contradicts planning literature that staff has researched. General planning theory breaks -up commercial uses/types into three levels: neighborhood, community, and regional. A small shopping center (under 50,000 square feet, such as proposed with the Sea Mist Shoppes application) is appropriate for a neighborhood service area, according to the literature. A larger shopping center of 100,000 square feet - 300,000 square feet in size would serve as a community service area and would be typified by shopping centers such as Ryanwood (108,670 square feet), South Vero Square (158,302 square feet), and Riverwalk (207,736 square feet). A regional center would be greater than 300,000 square feet and be typified by a regional mall style of development.' The community and regional levels are appropriate in the General Commercial district (CG), while the Limited Commercial district (CL) would be appropriate for smaller centers with grocery stores/ supermarkets that serve neighborhood areas. The Urban Land Institute's Shopping Center Development Handbook states that, "The supermarket is an anchor tenant in the traditional neighborhood centers." 'Shopping Center Development Handbook, Urban Land Institute, McKeever, Ross J. and Griffin Nathaniel M. et.al., p. 7, copyright 1977. BOOK 92 PACE July 12, 1994 FF­ FXE Below is a generalized guide that breaks -down shopping center size_ by service area from various sources. CHARACTERISTICS CP SHOPPING CBPTffit8 CENTER TYPE LEADING TENANT TYPICAL Gross GENERAL RANGE USUAL NIINIMOM MINIMUM FLOOR AREA (HABIs FOR Leasable Area IN GLA SITE ARCh SUPPORT POP. CUMIFICATION) (GLA) OF RSQUINED NEID OOD supermarket or 50,000 sq.ft. 30,000 - 3 acme 2,500 - 40,000 CENTER drugstore Supermarket a 100,000 a .ft. 4,000 pecale CMQWNITf- Variety, discount, 150,000 sq.ft. 100,000 - 10 acres or 40,000 - CERTER or junior sq.ft. 300,000 sq.ft. more 150,000 people department store REG=%L CENTER One or more full- 400,000 sq.ft. 300,000 - 30-50 acres or 150,000 or 100,000- line department CENTER 1,000,000 more mare people stores of at least 250,000 sq.ft. or more plus sales of department 100,000 sq.ft. of sq.ft. GLA store Source: Shopping Center Development Handbook, McKeever a Griffin, published by Urban Land Institute. CENTER TYPE FUNCTION LEmII4G RADIUS MIN. BITE FLOOR AREA NIA+IDSH TENJUM OF POP. ANSA OF SERVICE AMR STORES NEIGSHOIO WD sales of Supermarket a i mile 4,000 4-8 30-75,000 5-20 CENTER convenience and drug ators acres sq.ft. goodspersonal CM1MUAITY Same function Variety store 2 miles 35,000 10-30 100,000- 15-40 CENTER as neighborhood small acres 250,000 plus sales of department sq.ft. apparel a store appl J ance REGIONAL Same function One or more 4 miles 150,000 40-80 400,000- 40-80 CEATER as comity large, major acres 1,000,000 center plus department sq.ft. Nam of stores general mar..MwnA� N a furniture Source: Urban Planning A Design Criteria, Third Edition, DsCharia A Koppleman published by Van Nostrand Reinhold. Note: These tables are summaries and general guidelines to the different levels of commercial centers. As other pages in the source state, service areas vary in size and shape based on unique geographical constraints, density, and proximity to other commercial areas. The radius or the driving time becomes .larger or longer when surrounding residential uses are low density, (when there is a unique geographical constraint) or the commercial site is' -distant from other commercial and urban areas. All of the literature is clear that grocery stores/supermarkets are key components of neighborhood commercial centers, and that neighborhood commercial centers provide sales of convenience and personal services. Therefore, according to this planning literature, a shopping center 50,000 square feet or less with a grocery store/ supermarket would be consistent with the purpose and intent of the CL zoning district. Such is the case with the Sea Mist Shoppes proposal. -Distinction Between Zoning Districts Like most jurisdictions, Indian River County has a set of zoning districts that are hierarchal in nature. Its three principal commercial districts, CN (neighborhood), CL (limited), and CG (general), are structured to accommodate different types of service areas, and the uses permitted in each district have been established according to these service area needs. July 12, 1994 Eut Serving the smallest geographic area, the Neighborhood District .(CN) allows the least intense and most common its intent being to allow uses which serve primarily the of the immediate area, the CN district permits those use convenience oriented. For that reason, grocery stores a in the CN district. Commercial uses. With residents s which are re allowed As with CN, the CL district was also established as a restricted district. The restricted nature of the CL district reflects the fact that the purpose of the district is to serve an area larger than a --neighborhood, but not a countywide area. For that reason, the CL district prohibits those types of uses that have a broader market area. Consequently, automobile dealerships, large discount/ department stores, fruit and vegetable packing houses, and other similar uses are not allowed in the CL district. Those uses draw from a larger area of the county and are. allowed in the CG, General Commercial, district: The appellant draws a comparison between department stores and grocery stores/supermarkets based solely on traffic generation. The appellant indicates that a supermarket generates about 3 times the traffic that a department store does on a per unit area basis. The appellant provides no documentation such as trip rates per 1,000 square feet to substantiate the claim. The ITE Trip Generation Manual 4th Edition does not list department stores as a use, but it lists an average annual daily trip rate of 125 trip ends for supermarkets per 1,000 square feet, and average annual daily trip ends of 70.13 for discount stores per 1,000 square feet and a rate of 91.65 trip ends per 1,000 square feet for a shopping center of 50,000 square feet. Thus, ITE standards indicate that retail facilities such as department stores do not -generate 3 times more trips than supermarkets on a per unit area basis. It should also be noted that trip generation is not the distinguishing factor in determining what uses are allowed in the CL district as opposed to the CG district. Department stores are limited in size in the CL district not because larger department stores generate more trips, but because larger department stores will draw customers from a larger area than the CL district uses are intended to serve. *REVIEWING PLANNING AND ZONING COMMISSION DECISIONS LDR section 902.07(5) states that, in its review of Planning and Zoning Commission decisions, the Board is to make findings in four areas, as follows: 1. Did the reviewing official/Planning and Zoning Commission fail to follow the appropriate review procedures? 2. Did the reviewing official/Planning and Zoning Commission act in an arbitrary or capricious manner? 3. Did the reviewing official/Planning and Zoning Commission fail to consider adequately the effects of the proposed development upon surrounding properties, traffic circulation -or public health, safety and welfare? 4. Did the reviewing official/Planning and Zoning Commission fail to evaluate the application with respect to the comprehensive plan and land development regulations of Indian River County? 11 EOOK 92 FAZE � July 12, 1994 F_ In regards to these four areas, staff's opinion is as follows: 1. The reviewing official/Planning and Zoning Commission did not fail to follow appropriate review procedures. Staff's review and response to the appellant's inquiry was procedurally correct. All procedures for processing the appeals have been followed. 2. The reviewing official/Planning and Zoning Commission did not act in an arbitrary or capricious manner. The procedures for reviewing use determinations were followed, as indicated in the analysis section of this report. Also, staff and the Planning and Zoning Commission used the SIC code, •planning literature, and widely -accepted traffic standards in its review, as previously cited in the analysis section of this report. 3. The reviewing official/Planning and Zoning Commission did not fail to adequately consider the effects of the proposed development upon surrounding properties. As previously discussed in. the analysis section of this report, these characteristics were reviewed in comparing "grocery stores" to "supermarkets". 4. The reviewing official/Planning and Zoning Commission did not fail to evaluate the determination with respect to the comprehensive plan and land development regulations. As previously discussed in the analysis.section of this report, the framework of the LDR zoning code use table and the LDR buffer requirements were considered. The intent of the CL district and accommodation of convenience uses were also considered, as indicated in the analysis section of this report. SUMMARY In summary, grocery store/ supermarket is the same use. This use is allowed in the CL zoning district to serve neighborhood commercial type needs. Therefore, neither staff nor the Planning and Zoning Commission made an error in interpreting or applying the land development regulations. RECOMMNDATION: Based on the analysis above, staff recommends that the Board of County Commissioners: 1. Find that neither the Community Development Director nor the Planning and Zoning Commission failed in any of the 4 areas of review, as described in this report, and 2. Deny the appeal and uphold the Planning & Zoning Commission's decision that "grocery stores" and "supermarkets" are the same use within the Indian River County Land Development Regulations and that "supermarkets" are permitted in the CL zoning district. July 12, 1994 M 11A M -1 Director Keating next reviewed the following letter written to Attorney Warren Dill by Senior Planner John McCoy: Telephone: (407)567-6000 May 9, 1994 Mr. Warren Dill Wabasso One Building 9025 US 1, Suite 4 Sebastian, FL 32958 RE: Sea Mist Shoppes SP -MA -94-06-023 Dear Mr. Dill: RECEIVED MAY 1 0 1994 Staff is in receipt of your letter requesting a use determination for the above referenced project. It appears from your letter that you are contending that grocery stores and supermarkets are two different uses rather than two words for the same use. In response to your inquiry, staff reviewed the Standard Industrial Classification (SIC Code), ITE Trip Generation Manual (4th Edition), parking requirements, traffic impact fee rates, and Webster's Dictionary to see if these sources make a distinction between grocery stores and supermarkets. As referenced in section 911.04(2)(b)2, the principal basis for reviewing unlisted uses is the SIC. The SIC treats grocery stores and supermarkets as synonymous uses, giving the two words the exact same classification (category 5411). Given that the two items are listed as the same use in the SIC, and that the other referenced sources do not treat these two terms as different uses, staff has determined that "grocery stores" and "supe -.-markets" refer to the same use, and that such use is permitted in the CL zoning district. Should you have any questions regarding this matter, please do not hesitate to contact me at (407) 567-8000, extension 242. Sinc ely, John W. Mcoy, AICP Senior Planner, Current Development JM/ca 12 July 12, 1994 After reviewing staff's recommendation for denial, Director Keating wished to point out what he believed to be an incorrect statement in the second to the last paragraph in the following letter from Attorney Warren Dill: April 27, 1994 Robert M. Keating, AICP Community Development Director 1840 25th Street Vero Beach, FL 32960 re: Determination of Similar Use BY FACSIMILE THIS DATE Dear Bob: As you know, I am representing various concerned residents of The Moorings, regarding the Sea Mist Shoppes proposed to be located in the heart of this tranquil residential community ("the site"). Of most concern is the proposed 27,000 to 28,000 square foot Publix super market, with an adjacent 10,700 square feet of undisclosed retail uses. The site (approx. 5.32 acres) is zoned Limited Commercial (CL). I understand that there are only two (2) properties in the County with CL zoning. The other is located on the corner of CR 510 and State Road A1A. Neither property seems appropriate for CL zoning, particularly, The Moorings site, which is encircled by homes. This site was originally zoned C -1A in the late nineteen sixties. This was before planning and comprehensive plans evolved to the level of importance and legal significance they now hold. When the zoning was changed from C-lA to CL, I believe little thought was given to the appropriateness of the CL district on this site. It appears to have been an automatic roll over from the original zoning to the new classification. While such actions are not per se inappropriate when dealing with county wide rezonings, they can be troublesome when site specific development is proposed, as we are now seeing. This site is inappropriate for the CL classification, and the proposed use of it for a 27,000 to 28,000 square foot Publix Super Market is questionable as a permitted use. "Grocery stores" are "permitted uses" in the CL district, but Super Markets are not listed in Section 911.10(4), Land Development Regulations. The Application refers to the use as a "grocery store" in order to "fit" the use allowed in Section 911.10(4). If the applicant is willing to limit the use store to the sale of just groceries .then the listed use (grocery store) would seem more appropriate. However, it is common knowledge that Publix sells a lot more than groceries. The term "grocery store" is not defined in the Land Development Regulations. A "grocery store" commonly denotes a facility of much more modest scope than a Super Market. There is no question that this is a Super Market, even the letterhead for Publix refers to it as "Publix Super Markets". No one has ever denied that the proposed Publix is a Super Market in all prior communications. I understand that the Publix on Miracle Mile is 24,000 to 25,000 square feet. It is smaller than the Publix proposed for The Moorings site. To say this is a "grocery store" is misleading. 13 July 12, 1994 Section 911.04(2)(b) Unlisted Uses, sets for the precise procedure and criteria for determining whether there is a similar use allowed for a requested use that is not listed. If a similar use can not be determined, than the proposed use is not allowed, unless the regulations are changed. If you go through the "criteria for reviewing uses not listed" in Section 911.04(2)(b)2, you will come to the same conclusion that grocery stores and Super Markets are not synonymous terms. The key elements in the review process are: traffic generation (delivery trucks and vehicles) parking requirements compatibility to surrounding land uses noise lighting visual impacts hours of operation intensity of use The magnitude of the adverse impacts of these factors increases at a much faster rate for a Super Market than for a grocery store. There is certainly a distinction between a grocery store and a Super Market. In the CL district this distinction is critical. The CL district has attempted to limit the impacts of commercial development on "near by residential areas" (Section 911.10(2)(e)) by quantifying the maximum size of Department Stores to 40,000 square feet (Section 971.42(2)). For a "grocery store" to have no more impact than a 40,000 square feet Department Store it would have to be about one-half the size, based on traffic generation. I have reviewed the County file for the Sea Mist Shoppes and discussed this with John McCoy. Apparently an official written determination of similar use has not been prepared. It is requested that you make this determination in accordance with the provision of Section 911.02(2)(b), since there is no definition for a "grocery store" and a "Super Market" is not listed in Section 911.10(4). The County may want to examine the appropriateness of proceeding with a site plan review, when a major proposed use (Super Market) is not clearly permitted (listed) in the CL district, until an official determination has been made in accordance with and subjected to the review procedures in the Land Development Regulations. Very truly yours, Warren W. Dill cch 14 July 12, 1994 BOOK 92 PAGE F�I 8® 80OX 92 Fqf. 789 Director Keating felt that Attorney Vitunac may want to address the quasi-judicial question. TO: FROM: DATE: RE: Board of County Commissioners Charles P. Vitunac, County Attorney July 6, 1994 Standard of Review for Site Plan Appeal I have been asked to state briefly the legal prerogatives of the Board of County Commissioners regarding site plan appeals under the Indian River County Code and State law and in partiedlar regarding the Publix site plan for The Moorings, which is under appeal. SUMMARY OF SITE PLAN REVIEW The site plan review requirements are given in Section 914.15 of the Code and can be reduced to the following three inquiries, each of which will be discussed in turn: 1. Is the use allowed by the zoning code? By the time the Publix site plan appeal is heard, the Board of County Commissioners may have resolved the issue whether a "supermarket" is within the ambit of the term "grocery store" and hence allowed in a CL zone. If the use is not allowed, the site plan must be rejected. If the use is allowed, the Board.must next determine if the site plan meets the objectively determinable standards. 2. Are all objectively determinable standards met? These standards are specifically enumerated in the code and can be objectively determined. By the time this appeal is heard the County staff and- the Planning and Zoning Commission may have made a recommendation for approval or not based on the objectively determinable standards issues. County policy is to have the applicant re -work the site plan until the County staff finds that all requirements are in order. Therefore, it: is not expected that objectively determinable standards requirements will be a decisional issue. However, if they do become an issue the burden of proof is on the applicant to present competent, substantial evidence showing compliance with each objectively determinable standards requirement. This review by the BCC is quasi- judicial. This means that, once unrebutted proof hap been made showing compliance with each requirement of the Code, the Board is required to grant the permit applied for, at least in so far as this objectively determinable standards issue is concerned. 3. Is the site plan consistent with the comprehensive plan? State law requires that all land use decisions be consistent with the comprehensive plan. There are no'exceptions. A site plan approval is such a land,use decision. How does Indian River County ensure that its site plan decisions are consistent with the comprehensive plan? 15 July 12, 1994 M "Consistency" is defined in Section 163.3194(3)(a), F.S., as follows: A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspect of the development permitted by such order or regulation are compatible with and further the objectives, policies, land uses, and densities or intensities in the comprehensive plan and if it meets with all other criteria enumerated by the local government. In the first instance, the County relies on Section 163.3213(3), F.S., which directs that any challenges to the consistency of the Land Development Regulations (LDRs) with the comprehensive plan must be filed within 12 months of the date of LDR adoption and are thereafter barred. Since_this time has elapsed without challenges a person may not now claim that the LDRs are inconsistent with the comprehensive plan, and there is ' a presumption that the LDRs are consistent with the comprehensive plan. The Board may take notice of the numerous public hearings, both during the day and at night, by both the Planning and Zoning Commission and the Board of County Commissioners, which were held to ensure that the County LDRs were made consistent with the Comprehensive Plan. The second means is the thorough review by staff professionals of the proposed site plan and its relation to the LDRs, zoning code, and comprehensive plan --all done with public input. The County. land use professionals have all determined that the site plan is consistent with the comprehensive plan. As a third means of ensuring compliance the County has established the following hierarchy of land use controls: General Outline of Land Use Controls ("controls") A. Comprehensive Plan B. Zoning Regulations C. Site Plans, PVDs, Subdivision Plats Regulations D. Building Permits E. Certificates of Occupancies Consistency with the comprehensive plan is ensured by requiring that each control be consistent with the control next in priority. (The comprehensive plan is the highest priority.) If each control is consistent with the one above it, then it also will be consistent with the comprehensive plan. This method reduces the numerous reviews that a thorough comprehensive plan analysis would otherwise require. Only the next higher level of control must be reviewed. Thus, for a site plan review, once the objectively determinable standards are met only the zoning code need be looked at. The._first'three controls will be discussed individually: 16 800K 92 PACE ' I July 12, 1994 500K 92 FACE '791 A. Comprehensive Plan The highest control, the comprehensive plan, is a statutorily mandated legislative plan to control and direct the use ,and development of property within the county. The plan is similar to a constitution for all future development within the county and is developed by the BCC in its legislative discretion subject only to state law requirements. It is the adopted portion of the comprehensive plan (i.e., goals, objective standards, land use map, and other reference tables) that carry the force of law. B. Zoning Regulations The LDRs are the means by which the comprehensive plan is implemented and their implementation involves the exercise of discretionary powers within limits imposed by the comprehensive plan. The requirement of the state that all LDRs conform to the comprehensive plan is in effect a limitation on the local government's otherwise broad zoning powers. In the last few years, Indian River County has made all its zoning and other •land development regulations consistent with the comprehensive plan. As already mentioned any challenges based on inconsistency of LDRs with the comprehensive .plan -not filed within 12 months of LDR adoption are time-barred by Section 163.3213(3)1 F..S. C. Site Plan The County's site plan regulations are also LDRs, which have been adopted through the public hearing process, and are thus presumed to be in compliance with the comprehensive plan. However, specific site plans must, be reviewed for consistency with the LDRs. Section 914.15 of the Code requires that "site plans shall be reviewed pursuant to all applicable zoning district regulations and regulations for specific land uses, as applicable" and that "the development of any areas subject to the provisions of this ordinance shall be consistent with the policies regarding land development as established in the various elements of the Indian River County comprehensive plan." This section lists some 26 matters to consider, most of which are objectively determinable standards. Thus the burden. of proof is on the proponent of the plan to show consistency or compliance with the aforementioned requirements. STANDARD OF REVIEW Once the evidence for both sides has been presented what is the standard of review available to the Board of County Commissioners? When enacting the comprehensive plan and initial LDRS the Board acts as a legislative body subject to the deferential "fairly debatable" rule. When reviewing.site plan issues, however, the Board is acting as a quasi-judicial body. This means that there must be competent, substantial evidence for every required finding, and that the decision of the Board must be based on whether the applicant has met the requirements of existing law. It would not be appropriate to consider what the law should be (That would be a legislative decision). A county cannot unreasonably withhold site plan approval -once the legislatively adopted existing legal requirements have been met. The following excerpts from controlling court cases may. assist the Board in understanding the review standards: 17 July 12, 1994 M M M M CABS EXCERPTS 1. it . . . the function of a . . . commission is reviewing a property owner's proposed site plan for development of the owner's property in accord with the city zoning laws was not legislative in nature, but rather administrative [i:e., quasi-judicial]." (City of Delray Beach) 2. of . . . a city cannot unreasonably withhold approval [of a site plan] once the legislatively adopted legal requirements have been met." (City of Delray Beach) 3. "All persons similarly situated should be able to obtain plat approval upon meeting uniform standards. otherwise the official approval of a plat application would depend upon the whim or caprice of the public body involved." (City of Delray Beach) 4. "The administrative procedure for site plan approval is quasi-judicial in nature, and conducted to factually determine if a proposed site plan submitted by the property owner conforms to the specific requirements set out in the administrative -regulations governing the erection of improvements on the property . . . Those conditions should .be set out in clearly stated regulations. Compliance with those regulations should be capable of objective determination in an administrative proceeding. While the burden may be on the property owner to demonstrate compliance, no legislative discretion is. involved in resolving the issue of compliance." (City of Delray Beach) S. "When the public entity ,- conducts site plan . . . review, it merely applies_ established ruses of law to existing and uncontested facts." (City of Delray Beach) 6. " . . . the authority of a town to deny the land owner the right to develop his property by refusing to approve the plat of such development is, by statute, made to rest upon the specific standards of a statute or implementing ordinances. Thereafter, the approval or disapproval of the plat on the basis of controlling standards becomes an administrative act." (City of Coral Springs) 7. "It is elementary that once a party complies with all legal requirements for platting there is no discretion in governmental authority to refuse approval of the plat." (City of Coral Springs) a. "Section 14 of the Broward County Plat Act . . . provides that such approval may be 'subject to such conditions as the governing body of the . . . county commissioners . . . may deem to be in the best interest of the public.' Without pursuing the validity of that provision . . . we hold that , having met all of the legal requirements for obtaining plat approval, the county must approve [the] plat . . ." (Broward County case) 9. "opposition of surrounding property owners must be considered by the city . . . since the statement of intent of the . . . ordinance includes the desire to achieve aesthetic and compatible relationships between adjacent properties. But the opinions of neighbors by themselves are insufficient to support a denial of a proposed development. We agree with the city that project density is a legitimate concern . . . But it is a concern that must be addressed and expressed in appropriate ordinances." (City of Deland) 18 July 12, 1994 BOOK 92 Fta h2 10. "The correct law applicable in this case is that the ordinance should be given its plain meaning and that any doubts should be construed in favor of a property owner. The circuit court's reliance upon the undefined and uncertain standards contained in the statement of intent when clear and specific numbers of units are expressed in that same ordinance is not an interpretation that recognizes the plain meaning of the ordinance." (City of Deerfield Beach) 11. "The site plan merely regulates the layout of a piece of property, the design of the buildings, and the actual locations of the buildings on that site. The city's zoning ordinance control the uses to which a particular piece of property may be put. The plan board, therefore, is not to be concerned with the particular use of a piece of property as long as it fits within the permitted uses of the city's zoning ordinances." (City of Gainesville) 12. "The plan board members voted to deny the petition because of the parcel's intended use . . . not because it failed to comply with appropriate criteria for site plan approval." (City of Gainesville) (This was found to be illegal.) 13. "The test in reviewing a challenge to a zoning action on grounds that a proposed project is inconsistent with the comprehensive land use plan is whether the zoning authority's determination that a proposed development conforms to each element and the objectives of the land use plan is supported by competent and substantial evidence. The traditional and non -deferential standard of strict judicial scrutiny applies. (Machado case) 14. "A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspects of development permitted by such order or regulation are compatible with and further the objectives, policies, land uses and densities or intensities in the comprehensive plan, and if it meets all other criteria enumerated by the local government." (Machado case) 15. "Zoning laws are in derogation of the common law and as a general rule are subject to strict construction in favor of the right of a property owner to the unrestPicted use of his property. Permitted uses must be interpreted broadly, prohibited uses strictly so that doubts are resolved in a property owner's favor." (City of South Miami) Attorney Vitunac explained that the Board is acting as a quasi-judicial body today, which is a very important distinction. Legislative means that the Board would sit up here and decide what the definition should be for the future, and adopt an ordinance to that effect. Arguments can be made at a later time to change the Zoning Code in the future, but today the Board is not sitting as a legislative body, even though their determination today will affect the definition of all grocery stores in the county in the CL zone. 19 July 12, 1994 Director Keating continued the presentation of all the information that was provided to the P & Z Commission to support the decision that grocery stores and supermarkets are the same use. Staff's recommendation is that the Board first find that neither he nor the P & Z Commission failed in any of the four areas for review; and second, deny the appeal and uphold the P & Z Commission's decision that grocery stores and supermarkets are the same use within the context of the Zoning Code. Chairman Tippin asked if the Board had any questions at this point. There being none, he opened the public discussion. Attorney Warren Dill, appearing on behalf of the concerned residents of the Moorings, specifically Gene Winne, William Lampert, Robert Salmon, Jr., John W. Zilg and George Millington, commented on the great number of people in attendance this morning considering that approximately 80 percent of the residents of the Moorings and South Beach usually are up north at this time of the year. Attorney Dill listed the speakers who will be presenting documents and giving testimony this morning: Gene Winne -- overview of the use issue and size factor. Warren Dill -- legal review of the criteria. Prof. Ronald W. Cotterill -- discussion of Stanard Industrial Classification (SIC) Code and explanation of staff's incorrect conclusion. Robert Swarthout -- planning issues required to be considered by the Board, i.e. parking, adverse impacts, property values, compatibility, etc. Before beginning their presentation, Attorney Dill wished to make sure that the record of this meeting contains everything that was presented to the P & Z Commission and to the County Planning staff prior to today's hearing. He pointed out that two items were omitted from this hearing: 1) His initial letter requesting staff to make this determination, and 2) The actual decision by John McCoy, the designee of Community Development Director Robert Keating, determining that supermarkets and grocery stores were synonymous terms. Attorney Dill also requested that the following items be made part of this record: Staff's memo of recommendation. Minutes of the June 9, 1994 P & Z Commission meeting. All the letters, petitions and correspondence sent to the County Commission. 20 yg BOOK S F'AU,F 79 July 12, 1994 BOOK 92 FAi;E 195 The Board reviewed the following memo dated 7/11/94: TO: Board of County Commissioners FROM: Alice E. White, Executive Aide DATE: July 11, 1994 SUBJECT: Correspondence on the Proposed Publix Store at the Moorings Development Due to the restrictions placed on receiving correspondence with respect to cases coming before the County Commission when seated as a quasi-judicial board, we have held the correspondence sent to County Commissioners regarding the proposed Publix store at the Moorings development in our office. Mr. George Shaw and Mr. Walter Bush brought in three stacks of letters and they claim that these total 1200 against the proposed Publix store. •Through our office mail, we have received'a total of 64 letters against the store. I do not have the staff or the time to check and see if there are any duplications In this correspondence. The letters in opposition list the following reasons for opposition: traffic concerns aesthetic character of neighborhood lowering of property values noise and bright lighting night deliveries and late hours need for additional police protection violation of County Code regarding compatibility with the built and natural environment litter air pollution no need for supermarket river pollution varmints .supermarket not same as convenience retail store. We have also received 4 letters and 1 phone call in favor of the Publix store listing the following reasons for support: property rights of land owner will add to residents property values decrease of traffic on US#1 lack of grocery store on barrier island fulfills a need. The correspondence is available for review at the appeal hearing, as well as petitions and correspondence presented at the Planning and Zoning Commission meeting on May 12, 1994. 21 July 12, 1994 NOTE FROM BARBARA BONNAH, DEPUTY CLERK, CLERK TO THE BOARD: All of the above listed items plus any and all exhibits presented during this meeting that haven't been inserted into these Minutes will be placed on file in the Office of the Board of County Commissioners for 3 years. (Please see index at the back of these Minutes.) Attorney Ralph Evans, representing the applicant of the site plan, had a general objection to the evidence being presented into evidence today. He believed the Board's job today is to review the record presented by the applicant at the P & Z Commission meeting and make the right decision based on substantial competent evidence. Attorney Vitunac noted that we treat the BCC as de novo for various reasons, and he recommended that the Board admit all the letters and give them what weight they deserve, which is acknowledgement. The letters are not sworn and they are subject to cross examination. He felt the Board should weigh that when reading them. Attorney Evans thereupon presented for the record a certified copy of a transcript made at the P & Z Commission hearing. (Exhibit C) Chairman Tippin announced that the Board will accept all evidence and testimony presented today. Attorney Dill wished to point out that Halvorsen Development Group, as represented by Attorney Evans, is not a party to this issue. This has nothing to do with the Sea Mist Site Plan. Attorney Vitunac felt it is clear to everyone that the Sea Mist people are an interested party who have a sole interest at stake here, which is affected by this determination. If.there is a lawsuit after this based on a ruling adverse to them, that group can file a lawsuit. In his opinion, they are a party. Attorney Dill noted that having made his objection for the record, he would continue his review of the legal criteria in this matter. He referred to the following memo from Assistant County Attorney Terry O'Brien titled Interpretation of Zoning Laws: 22 July 12, 1994 BOOK 92 PAGE 79 6 OK G ma 1/ i TO: Board of County Commissioners u THRU: Charles P. Vitunac, County Attorney FROM: Terrence P. O'Brien, Assistant County Attorney DATE: July 6, 1994 RE: INTERPRETATION OF ZONING LAWS General Law There are certain maxims which the courts universally apply to the construction of zoning laws. Perhaps the first and the controlling maxim is that • zoning ordinances which are in derogation of the common law and operate to deprive an owner of an otherwise lawful property use should be strictly construed in favor of the property owner. This is so since the federal and state constitutions give great protection to property rights. This rule leads to a very narrow construction when a word or phrase used to describe a use which is to be prohibited in a particular zoning district, and a very liberal construction of a word or phrase used to describe a use which is to be permitted. A corollary to this rule of strict construction is that, in ambiguous cases, a zoning ordinance will not be extended by implication against the property owner. For example, if an ordinance were to list permitted uses and prohibited uses and the proposed use was not in either list, the courts would not allow the use to be impliedly placed in the prohibited category if there was a reasonable doubt concerning the meaning of the use. The courts will by virtue of strict construction say that the proposed use belongs in the permitted category. Florida Law The law in Florida is succinctly stated in Mandelstam v. City Commission of the City of South Miami, 539 So . 2d 1139 (1988 ) wherein the court stated in pertinent part as follows "'permitted uses must be interpreted broadly, prohibited uses strictly, so that doubts are resolved in a property owner's favor.... Zoning laws are in derogation of the common law and, as a general rule, are subject to strict construction in favor of the right of a property owner to the unrestricted use of his property." Florida law vis-a-vis County Staff interpretation Mr. Keating, as Director of Community Development, has interpreted the County Land Development Regulations to mean that the word "Supermarket," which is not defined in the Code, is subsumed in the term "Grocery Store," and is therefore a permitted use in the CL District. It is the opinion of this office based on the law stated above that this is a legally correct conclusion. 23 July 12, 1994 Attorney Dill pointed out that the Board is not bound by the opinion given by Attorney O'Brien, and must base a decision on the evidence presented today. If evidence is presented today that the Board feels is substantial enough to warrant the decision that grocery sores and supermarkets are not the same, that decision can be made without going against the County Attorney's opinion. Attorney Vitunac stated that he agreed with that. Attorney Dill proceeded to present the legal criteria to be considered by the Board in making their determination today. REASONS TO REVERSE MR. KEATING'S POSITION THAT GROCERY STORES AND SUPERMARKETS ARE THE SAME USE Section 902.07(4) requires the following findings: (a) Did the reviewing official fail to follow the appropriate review procedures? - Yes (1) Failed to consider that the purpose of the CL District is only intended to accommodate convenience retail needs of area residents while minimizing the impacts of new uses on nearby residential areas. (2) Misinterpreted the use of the Standard Industrial Classification (SIC) Code by failing to consider the six (6) digit classification and improperly concluding that every item listed under a Major Group heading was intended to be a permitted zoning use. (3) Inadequate consideration was given to the following required criteria: traffic generation (delivery trucks and vehicles) visual impacts (property values) parking requirements hours of operation (lam - 10pm) noise (dumpsters, sweepers, diesel intensity of use trucks, generators, air conditioners) compatibility to surrounding land uses (odors, vermin, safety and crime) lighting (4) Staff failed to recognize the difference in its own definitions of grocery store and supermarket. (5) Staff failed to recognize that the LDR definition of "Retail sales, general" applies to general commercial uses and specifically listed "supermarkets". (6) Staff failed to adequately consider the uses appropriate in the CL district as controlled by the definition..."the CL district is intended to provide areas of restricted commercial activities. The CL district is intended to accomodate the convenience retail and service needs of area residents, while minimizing the impact of such activities on any nearby residential areas". (Emphasis added.) Section 911.10(2)(e)LDR. (b) Did the reviewing official act in an arbitrary' or capricious manner? NO (c) Did the reviewing official fail to consider adequately the effects of the proposed development upon surrounding properties, traffic circulation or public health, safety and welfare? Yes See reasons in items (a) (1) and (3) above (d) Did the reviewing official fail to evaluate the application with respect to the comprehensive plan and land development regulations of Indian River County? Yes See reasons in items (a) (1), (2), (3) and (5) above Upon making the above findings, the Board has the authority to make a Motion to reverse the decision of the Community Development Director, including his designee, which concluded that grocery stores and supermarkets are the same use, and you find that they are not the same use. Under Section 902.07(4) the Board may make additional finding of fact if it desires. 24 BOOK 92 P1 E �! Jib July 12, 1994 Boob 92 PmE bU SIC CODE COMPARISONS "In reviewing the CL zoning district list of allowable uses (attachment #2) and the SIC code's industry number classification (attachment #5), it can be seen that the lists follow one another precisely, as illustrated below." (See Staff report page 4.) Zoning Code Use Table Category Grocery Store Meat & Fish Market Fruit & Vegetable Market Candy, Nut & Confectionery Stores Dairy Products Store Retail Bakeries SIC Code Industry # & Heading 5411 Grocery Stores 5421 Meat & Fish Market (Seafood) Inc. Freezer Provision 5431 Fruit & Vegetable Markets 5441 Candy, Nut, and Confectionery Stores 5451 Dairy Product Stores 5461 Retail Bakeries 'Me food store uses listed in the zoning code track the SIC code industry numbers, meaning that any sub -use listed within the industry number that is not listed in the zoning code would be included and allowed under the SIC use category stated in the zoning code." (See Staff report page 4.) LDRs USES (SECTION 911.10(4)) Eating and Drinking Establishments Hamburger stands OCR ME D CN CL C G CH Restaurants Lunch bars Cafeterias A P P P P Carry -out restaurants Oyster bars A A P P P P Drive through restaurants - Restaurants Dairy bars Restaurants, carry -out P P Bars and lounges - - Snack shops Drive-in restaurants S P P Bottle clubs - Food service, institutional I - Theaters, dinner S A Miscellaneous Retail r—I j SIC (CODE) EATING AND DRINKING PLACES 5812 Eating Places Establishments primarily engaged in the retail sale of prepared food and drinks for on - premise or immediate consumption. Caterers and industrial and institutional food service establishments are also included in this industry. Automats(eating places) Hamburger stands Beaneries Hot dog (frankfurter) stands Box lunch stands Ice cream stands Buffets(eating places) Industrial feeding Cafes Lunch bars Cafeterias Lunch counters Carry -out restaurants Luncheonettes Caterers Lunchrooms Coffee shops Oyster bars Commissary restaurants Pizza parlors Concession stands, prepared Pizzerias food (e.g., in airports Refreshment stands and sports arenas) Contract feeding Restaurants Dairy bars Restaurants, carry -out Diners(eating places) Restaurants, fast-food Dining rooms Sandwich bars or shops Dinner theaters Snack shops Drive-in restaurants Soda fountains Fast food restaurants Soft drink stands Food bars Submarine sandwich shops Food service, institutional Tea rooms Frozen custard stands Theaters, dinner Grills(eating places) 25 July 12, 1994 Attorney Dill introduced Gene Winne, 2096 Windward Way, who stated that he represents the consensus of the concerned residents of the Moorings. He emphasized that the issue this morning is that supermarkets are not listed anywhere in the Land Development Regulations (LDRs) as permitted uses, while grocery stores are. He believed that the Board will agree that supermarkets should not be allowed in the CL District, pointing out that staff has ignored the size of a supermarket when defining grocery stores. Mr. Winne maintained that it would be good government to consider a supermarket a special exception, consistent with Section 911.04 of the LDRs. Attorney Evans objected to references to the proposed site plan, which is a separate appeal from the matter of supermarket vs. grocery store. Chairman Tippin stated that the point was well taken but that we would proceed the best we can, noting that it is hard to separate the two. Mr. Winne continued presenting arguments against allowing a supermarket on the subject site, i.e. increased hours of operation, increased crime and need for more security, reduction in property values, 18 -wheeler trucks unloading day and night, intensive lighting, offensive odors from garbage handling, etc. He pointed out that the developer does not own the subject property at the present time; he only has an option to buy the property. The Moorings property owners would like to buy the property from the present owner. Attorney Evans again objected to Mr. Winne' s references,. to the site plan issue. Mr. Winne concluded by emphasizing that you do not have to be a lawyer or be on the County Planning staff to understand the simple difference between a grocery store and a supermarket. Attorney Dill referred to the following letter received from The Progressive Grocer which is part of today's backup material (Page 42). He understood this magazine is funded by large supermarket chains, and felt the letter is self-serving and does not offer an objective opinion: 26 92 8OC) July 12, 1994 �Sftmfold Fanan Stern AX0, cr06M Rai) 325-3500 wol�irhF.Ner A1edr The Megersie of Supemeebirg June 6, 1994 Tom Vincent Halvorsen Development Corp. 1900 Glades Rd. Suite 260 Boca Raton, Fla. 33431 Dear Tom: Per our conversation, let me clarify how the food distribution industry defines grocery stores and supermarkets. Grocery stores is the umbrella term for any type of food store that sells food and non-foods items, including a mix of canned and packaged goods, along with perishables items. A supermarket is defined as any grocery store with at least $2 million in annual sales -that feaU= self-service and a full line of groceries, non-foods and perishables departments. In other words, all supermarkets are, by definition, grocery stores. Keep in mind that these definitions are determined by industry consensus, including top executives of major chains and wholesalers, trade press editors, as well as representatives from associations such as the Food Marketing Institute, the National Grocers Assn. and the National -American Wholesale Cmocers' Assn. This ensures that we are all on the same page when we are talking about different types of stores. The attached pages may help clarify the situation frather. As you can see on the table showing 1993 grocery industry sales, "All grocery stores" is the topline number, with 136,000 stores. "Supermarkets" make up one segment of grocery stores, with the others being convenience stores, wholesale club stores and other stores (which include mom_ and -POP stores, delis, etc.). I have also included a page of published definitions from Progressive Grocer's 1994 Marketing Guidebook. Feel free to call me if you have questions. My direct line is 203-977-2923. yours, Priscilla Donegan Managing Editor July 12, 1994 27 M M _I Attorney Dill next introduced Ronald Cotterill, a Professor of Agriculture Economics and the Director of the Food Marketing Policy Center at the University of Connecticut, who gave the following presentation. (Exhibit E) AFFmAyrr OF PROFESSOR RONALD W. COTTERILL STATE OF CONNECTICUT ) COUNTY OF TOLLAND ) RE: Appeal of Indian River County Planning and Zoning Commission Staff determination that Supermarkets and Grocery Stores are synonymous and an economic analysis of the Sea Mist Shoppes Proposal. I, RONALD W. COTTERILI, being duly sworn, state: 1. That I am the Director of the Food Marketing Policy Center and a Professor of Agricultural Economics at the University of Connecticut. I am the Executive Director of an International Food Marketing Research consortium that includes research economists from more than 22 universities in the U.S., Canada, the U.S.D.A., the E.P.A., the F.D.A., and the General Accounting Office of the U.S. Congress. I have written numerous books, journal articles, reports and papers on the organization and performance of food industries. Food retailing is my special area of expertise. Among other projects I have contracted with the Bureau of Census to obtain special data to analyze supermarkets and grocery stores in all standard metropolitan areas in the U.S.' My curriculum vita is attached to this Affidavit as Exhibit "A". 2. The Moorings Concerned Residents has requested that I, a) explain exactly how the Standard Industnal Classification (SIC) Code defines food stores including grocery stores and supermarkets; b) define and determine whether supermarket and grocery store are synonymous terms and c) determine whether, from an economic perspective, the proposed Sea Mist Shoppes Development violates the Indian River County Zoning Code. 3. The basis for my conclusions includes: my prior research and knowledge of the food retailing industry, a set of documents (listed in Exhibit "B") furnished by Moorings Concerned Residents and their retained legal counsel, Warren W. Dill, trade and government publications, interviews with Bureau of Census staff, and market area data for Vero Beach and Indian River County assembled under my direction by Mr. Gene Winne and Mr. John W. Zilg of Moorings Concerned Residents. 'Andrew W. Franklin and Ronald W. Cotterill, "An Analysis of Local Market Concentration Levels and Trends in the U.S. Grocery Retailing Industry", Food Marketing Policy Center Research Report No. 19, University of Connecticut, May 1993, 108 pages. 28 July 12, 1994 BOOK 4. After reading the documents in this matter, and analyzing all the information available to me I conclude as follows: a) The Bureau of Census has created and maintains the SIC Code. b) The Bureau of Census SIC Code is a complex multi level classification system that in its most detailed form defines "grocery stores" and "supermarket" as distinct and mutually exclusive categories and uses. In other words, supermarkets and groceries are not synonymous terms in the SIC Code, nor can they be considered to have similar characteristics for purposes in urban planning. c) The Indian River County Planning Staff inappropriately applies a 1960 conceptual nation of supermarket and neighborhood (shopping) center (reproduced in this Affidavit as Exhibit "D') to the supermarket of today. If correctly applied the result would be the permissibility of only very small convenience and or specialty oriented supermarkets. As a general class of retail activity supermarkets should not be a "permitted use"x in the Limited Commercial (CL) zoning district. d) Given the Indian River County Zoning Regulations for "Limited Commercial" land use areas, specifically the requirement that a proposed development "accommodate the convenience retail and service needs of area residents, while minimizing the impact of such activities on any nearby residents" and the general purpose and intent for Commercial Districts... "to promote the economic well being of the county ... and ensure commercial development compatible with existing and proposed development," (Section 911.10 LDRs) the proposed Sea Mist Shoppes violates the Indian River County Code. 5. In a letter to Mr. Warren W. Dill, dated May 9, 1994, Indian River County Planning Staff states 'Me SIC (Standard Industrial Classification) treats grocery stores and supermarkets as synonymous uses, giving the two words the exact same classification (Category 5411)." To determine exactly how the Bureau of Census defines "grocery store" and "supermarket" and how they classify them in the SIC Code, I contacted Mr. Richard Graham, Assistant Chief, Cross Industries Branch, Bureau of Census, Washington, D.C. and discussed the issue with him. Mr. Graham faxed me the relevant page from the 1992 Industry and Product Classification Manual (p. 274) and a copy of the actual survey form that Census sent to food retailers in the 1992 Census. The entire fax is attached as Exhibit "C". 6. The SIC code is a complex multi level classification system that in its detailed form defines grocery stores and supermarkets as distinct mutually exclusive categories and uses. Indian River County Planning Staff is correct when they state =In the Limited Commercial "CL" zone, supermarkets come in too many formats and sizes, and can adopt too many very different merchandising strategies to infer reliably that a supermarket meets the requirements of the Indian River County Zoning Code. 29 July 12, 1994 r � � that grocery stores are classed as SIC 5411 (See page 274 reproduced in Exhibit "M; however, they are not correct when they state that category 5411 is synonymous with supermarkets. The four digit category has four components: convenience food stores/no gas (SIC 541120), convenience food stores with gas (SIC 541130), delicatessens (SIC 541140) and grocery stores (SIC 541110). Thus the four digit industry "grocery stores" has a six digit store type with exactly the same name: "grocery stores". Those six digit grocery stores are mutually exclusive from delicatessens and convenience stores. Just as all grocery stores are not warehouse stores, all grocery stores are not supermarkets. Moreover the definition of the six digit "grocery store" given in the industry and product classification manual, as reproduced in Exhibit "C" is: These are retail stores commonly known as supermarkets, food stores, grocery stores and warehouse stores, which are primarily engaged in the sale of all kinds of canned foods and dry good, other packages or in bulk, such as tea, coffee, spices, sugar, flour, fresh fruits and vegetables. They may also sell fresh and/or frozen meats, fish, poultry, eggs, and bakery and dairy products. Grocery stores, with or Supermarkets without fresh meat -retail Warehouse stores Food market -retail One can see that even at the six digit level where one has winnowed convenience stores and delis out, the "grocery store" category still includes separate store types, e.g. grocery stores, with or without fresh meat, supermarkets and warehouse stores. Moreover the Census definition strictly speaking contains an error. The first sentence should read "... grocery stores or warehouse stores." In fact if one examines the 1992 Census of Retail Trade - Food Survey Instrument (Exhibit "C' , item 7 asks the retailer to identify an exact six digit SIC store type and among the choices are "Grocery Store - SIC 541111" and "Food Supermarket - SIC 541112". So the SIC Code in its most detailed form defines supermarkets and grocery stores as mutually exclusive and distinct use categories. I conclude that the SIC classification system at no level of aggregation, considers grocery stores to be synonymous with supermarkets. 7. Note that the Bureau of Census does not define a supermarket. The accepted industry definition is a store that carries at least fresh meat, fresh produce and fresh dairy products as well as dry grocery products and is above a specified sales volume. Progressive Grocer requires annual sales of more than 2 million, but has not adjusted this cutoff for inflation over the past 15 years. USDA has done the adjustment and uses a 3.3 million (1992 Dollars) cutoff.' A.C. Neilsen, a leading Market Research Group, uses a 4.0 million dollar cut off. More than scale is involved when a supermarket increases in size, product mix changes Analysts commonly identify sit different supermarket formats: the conventional supermarket (less than 30,000 square feet), the superstore (more than 30,000 square feet, with substantial nonfood and specialty departments), the combination store (a superstore with a complete drug store in it, 60,000 - 80,000 square feet), a warehouseAimited assortment supermarket (less than 30,000 square feet), a super warehouse supermarket (over 30,000 square feet) and a hypermarket (supermarket with over 40% nonfood over 100,000 square feet and often over 200,000 square feet).` 'Doris J. Newton, "Nontraditional Retailers Challenge the Supermarket Industry", Fob Review, Vol. 16, No. 1, USDA, Washington D.C., Jan. - April 1993, p. 3. °Ronald W. Cotterill, "Food Retailing: Mergers, Leveraged Buyouts and Performance" in L. Duestch,lndustry Studies, Prentice Hall; Englewood Cliffs, 1993, p. 467-168. 411 July 12, 1994 MY CONVENIENCE MAILING VERSUS GENERAL FOOD SHOPPING NEEDS 8. Consumers often frequent different types of supermarkets and grocery stores to buy food. A shopper usually goes once a week or possibly less frequently to a superstore, super warehouse store or hypermarket supermarket to make major food purchases. Shoppers also have a need for limited grocery retailing near where they live. Indian River County Zoning Regulations recognize this. The Limited Commercial (CL) District allows "restricted commercial activities... to accommodate the convenience retail (my emphasis) and service needs of area residents". (Sec. 911.10) In the SIC Code and in food industry trade publications, food stores that offer convenience retailing are clearly demarcated as convenience food stores. These stores are not supermarkets. Based upon my knowledge of this industry, other small grocery stores that are not supermarkets and small supermarkets (less than 10,000 square feet) that specialize in service or high quality specialty lines of meats or seafood or deli products also provide convenience retailing for area, (as opposed to immediate area) residents. Such stores are independent as opposed to chain store grocers. Independent grocers know that their competitive advantage verses large supermarket chains such as Publix, Albertson or Winn Dixie is precisely what the Indian River County Zoning Code requires... restricted commercial (in this case retail) activity that targets convenience food retailing and service needs of area residents. 9. This position is supported by the commercial facilities chart that planning commission staff refer to (Exhibit "D') when that chart is placed in historical context. The chart comes from 3rd Edition of Urban Planning and Design Criteriapublished in 1982 and reproduces specification from a 1960 edition of the Community Builders Handbook. According to this chart a neighborhood shopping center offers a "sale of convenience goods and personal services". It's service area has a 1/2 mile radius with 4000 minimum population. With 30,000 to 75,000 square feet it has a supermarket and drugstore as leading tenants with another 3 - 18 stores and shops. In 1960 this description may have been appropriate because the typical supermarket was under 10,000 square feet', and a drug store was even smaller. Today the very same neighborhood center would be anchored by a small independent supermarket (or grocery store with sales below 3.3 million). This charts delineation of the radius of area, 1/4 mile, is too small for 1960 and today. Consumers regularly drive 3 -4 miles to this type of shopping center.' Consumers regularly drive as far as 10 - 15 miles to shop at large supermarkets (superstores, combination stores or hypermarkets). 'National Food Commission, Food Retailing Technical Study, No. 7, U.S.G.P.O.: Washington, 1966, p. 191. "Che service area radius for the community and regional shopping centers in this chart are also inexplicably low. Consumers drive more than 4 miles to a 1 million square foot shopping mall. July 12, 1994 M 31 M BOOK 92 M THE SEA. MIST SHOPPES PROPOSAL 10. The Sea Mist Shoppes Development is essentially a strip shopping mall anchored by a 27,860 foot Publix supermarket. Publix is a very successful, privately held, supermarket chain that conducts business in many Florida cities. No other chain in the U.S. has as many dominant (very large market shares) positions in local markets as Publix.' The chain's merchandising, store format, and general marketing strategy are not consistent with the Indian River County Limited Commercial zoning designation with its requirement to serve convenience retail and service needs and to serve area residents needs. The Publix Southeast Division serves the Miami marketing area which includes Indian River County.' The division operates 149 supermarkets. That total includes 21 combination (very large food and drug) stores, 111 super stores (over 30,000 square feet) and only 17 conventional supermarkets. These Publix stores average 12 checkout stations per store. Although Progressive Grocer does not give the average size of these Publix stores, the Winn Dixie, Miami Division operates a much larger proportion of conventional supermarkets (94 out of 136 supermarkets with all others being superstores), and its supermarkets average 39,000 square feet. Publix stores must, on average, be much larger. The proposed Sea Mist Publix is clearly smaller than nearly all Publix supermarkets operating in the Miami area, but as part of the chain store system it will, for efficient management and operation, be essentially operated like the larger Publix stores. The convenience retail and service needs of the area residents will not be satisfied. This type of supermarket is designed to satisfy major food shopping trips for bulky and storable food products and nonfood products, as well as fresh, perishable, and specialty food and service items. It will not satisfy the quick in and quick out convenience service needs of area residents. 11. The site location characteristics of this proposal are highly questionable from an economic perspective. Sea Mist Shoppes essentially locates a small superstore or very large conventional supermarket on a long narrow island at the south end of residential development in the county. The trading area for this supermarket, is very limited by water to the east and west, and must extend several miles North and South, outside of the South Beach "area", to capture sufficient customers. According to the 1990 U.S. Census South Beach area population is 2,856. The Indian River County Comprehensive Plan estimates total resident and seasonal population for the South Beach area to be 4,083 in 1990 and 4,707 in 1995.' The fluctuation in Barrier Island population is probably significantly greater than the difference between these numbers with the summer (6 months) population being much lower than the census population estimate as legal resident "snow birds" go north for the summer. Consequently the South Beach "area" does not come close to providing a sufficient customer base for the proposed supermarket. Given the 'Metro Market Studies, Grocery Distribution Guide: 1994 Edition, Wellesley Hills, Mass., 1994. 'Progressive Grocer, 1994 Marketing Guidebook, Trade Dimensions: Stanford, CT., 1993 P. 338346. The following data in this paragraph are from this source. 91ndian River County Comprehensive Plan, p. 32. 32 BOOK fF July 12, 1994 I immediate access by two bridges to several much larger supermarkets on the mainland and a small upscale merchandised grocery store, the Village Market (on the beach near the north municipal/county line), it is very unlikely that residents north of South Beach will travel to the proposed supermarket. The only economically rational addition to the trading area therefore lies to the South. Immediately South of the site is Round Island Park. The St. Lucie County portion of the Barrier Island below it is less developed then South Beach at this time. Its current population is approximately, 2,300.t0 Although the area is rapidly growing the population is also subject to violent seasonal fluctuations. 12. Until future growth occurs these facts lead me to conclude that the 27,860 sq. ft. supermarket may very well operate at low capacity rates, thereby incurring high operating costs per unit, unacceptable return on investment and higher prices to consumers without enhanced retail services or quality products. This result violates the Indian River County Zoning codes purpose and intent.. "to provide an efficient use of land ... promote the economic well being of the County and ensure commercial development compatible with existing and proposed development". 13. The structure of the supermarket industry in Vero Beach also strongly suggests, that competition among the very few and very large local market share firms that operate in Vero Beach will be significantly lessened to the detriment of all Vero Beach residents. Progressive Grocer indicates that Indian River County is served by only 10 supermarkets and 6 of the 10 had sales above 12 million dollars in 1993. Food sales in the County totaled $200 million dollars in 1993." Using store identity and square footage estimates provided by Concerned Mooring Residents for the 8 supermarkets located in Vero Beach and the South/Central portion of the county, I have computed the following market shares: Vero Beach Supermarket Market Structure Publix (4 stores, 137,632 square feet) 52.1% Winn Dixie (2 stores, 59,320 square feet) 22.4% Albertson (1 store, 45,000 square feet) 17.0% Keen's (1 store, 22,500 square feet) 8.590 100% In comparison to other cities in Florida and the U.S. this is a very concentrated market with Publix as the dominant firm. Supermarket chain in such cities can price in an oligopolist, i.e., non competitive fashion.' Adding another Publix and locating it as a geographic monopoly on the Barrier Island does not promote 1'Estimate provided by Gene Winne, 6/20/94, telephone conference. It op.cit., p. 339 12An oligopoly market is one served by a few, large firms, see for example: Leonard Weiss, Concentration And Price, MIT Press: Cambridge, 1989, or Cotterill. op.cit. 33 July 12, 1994 BOOK M - competition and the economic welfare of Vero Beach residents. Currently the impact of the highly concentrated market structure on prices may be mitigated by the location of four different company supermarkets (1 Publix, I Winn Dixie, 1 Albertson and 1 Keen's) at or very near the bridge entrance roads in downtown Vero Beach. As Island residents come onto the mainland they can patronize the store that offers the best value that week. Locating a Publix on the Island may not only raise prices there, it will raise prices on the mainland because retailers there will no longer compete for Island business. u 14. For these reasons I recommend rejecting the Sea Mist Shoppes Proposal. Respectfully Submitted, G � Ronald W. Cotterill, Ph.D. STATE OF FLORIDA COUNT OF INDIAN RIVER Sworn to, and subscribed before me this 1/day of July, 1994, by _Ronald W. Cotterill who produced C'onntxri�-o,— Aas identification. we /! vw tP /3'7 / WAMM W. ILL cakfam oases: sn.rr,tess 09MMTJMN"rMMW*&dM 12�f1a�l�'� ✓/ Notary Public My Commission Expires: My Commission No. is: "David Levy and James Reitzes, "Product Differentiation and the Ability to Collude; Where Being Different Can Be an Advantage", Antitrust Bulletin, Summer 1993, p. 349 - 368. Locating a Publix on the Island is Spatial or Geographic "Product Differentiation". 34 July 12, 1994 600K _I KOK 92 *11-80;5 Attorney Dill next introduced Robert R. Swarthout, a city planning consultant, who stated that he has been a professional city planner for 23 years and is a member of the American Institute of Certified Planners. Mr. Swarthout reviewed the unlisted uses in 911.04-2B. He stressed that there is nothing in the Zoning Code to prompt staff to interpret the SIC that grocery stores are supermarkets. He reviewed traffic generation volumes by square foot basis; the kinds of traffic generated at various times of the day; parking requirements; and compatibility to surrounding land uses. Mr. Swarthout projected slides of the back of a supermarket showing loading platforms, cardboard recycling bales; and trucks standing in the alley. He stressed that compatibility is a big issue in this matter, giving the example of the impact this will have on the private residences on Bowline Drive that will face the loading area of the proposed supermarket. After a very lengthy presentation, Mr. Swarthout concluded by emphasizing that supermarkets do not belong in neighborhood areas with Limited Commercial zoning. Attorney Dill announced the conclusion of the presentation of their appeal. Attorney Ralph Evans, representing Halvorsen Development Corporation, began his presentation by commenting on two issues: 1) The standing of the appellant in this hearing and their obligation today to demonstrate to this Board that they have a substantial interest affected by the decision of the Community Development Director, and 2) The legal requirements in this county for appealing a decision or lack of a decision of the Planning & Zoning Commission. Attorney Evans summarized the arguments presented at the P & Z Commission meeting. Attorney Evans introduced Henry Skokowski, a practicing planner certified with the American Planning Association. Mr. Skokowski stated that he has been in practice for 17 years and has a bachelor's degree in architecture, a master's degree in urban design, and his specialty is city regional planning. In offering additional support to staff's thorough comprehensive review and conclusion that a supermarket is a grocery store, Mr. Skokowski made the following arguments: 35 July 12, 1994 M M M 1) Under the Bureau of Revenue's Florida Retail Sales and Use Tax code classifications, a grocery store is classified 01 under food and beverage group, and tax imposed under that category applies to small stores, big stores, supermarkets, all types of stores. 2) The Community Builder Handbook Series says that a supermarket is the anchor tenant in community centers. 3) There is no specific definition in the County's LDRs for a grocery store or for a supermarket. 4) The 1993 issue of Dollars and Cents of Shopping Centers says that a neighborhood center provides for the sale of daily living needs, convenience goods, such as food, drugs, hardware, and personal service. A supermarket is the principal tenant of this type of center. 5) The publication Urban Planning and Design Criteria says that the leading tenants of the neighborhood center are supermarkets and drug stores. It also says the site area is four to eight acres and that the gross floor area is 30,000 to 75,000 square feet. 6) Grocery store is a category term that is used throughout IRC's Zoning Code. There is no distinction in the CL district. No square footage limitation can be found anywhere in the Code that defines a supermarket or a grocery store. Attorney Evans next introduced Tom Vincent, vice president of Halvorsen Development who made the following points: 1) There is no specific planning data that says that size distinguishes or establishes the difference between a grocery store and a supermarket. 2) Controls within the zoning regulations and LDRs control, monitor, and create compatibility for any particular use, permitted use, in a given zoning district. 3 ) The test for the CL district speaking to meeting the needs of the area residents is not subjective. There is no criteria in the Code that clearly establishes and defines how you meet the needs of the area residents. 4) There is nothing in the Code saying that store hours have any relationship to the classification of a particular use. 5) 18 -wheeler trucks service smaller units just as often as they do the larger units. In fact, a lot of combination trips are saved by the larger delivery trucks. 6) Most stores built today are state of the art units and do not look like the photographs presented by the appellant. 7) There is a significant separation between the back of the proposed commercial use and the front yards of a few of the private residences. 36 r July 12, 1994 I Attorney Evans next introduced applicant Ron Ferrin, who advised that the tenant, Publix, has gone to great lengths to introduce a new prototype store that would allow them to operate within 27,000 square feet. They have spent a lot of money to try to make this site compatible and appear consistent with the surrounding community. Director Keating summarized at length the thorough, comprehensive review this matter received from the County Planning staff. Walter Bush, 1935 Mooringline Drive, questioned the tests used by staff in determining the needs of the servicing the immediate neighborhood. He felt that based on their traffic report the shopping center will attract people outside the community. Therefore, it does not meet that test. Tom Buchanan, 1150 Reef Road, questioned whether a grocery store sells wine and beer, and Director Keating replied that beer and wine are grocery store items, in his opinion. Halda Groveman stated she did not live in the Moorings, but she was interested the difference between supermarkets and grocery stores. She listed an extensive number of non -grocery items sold in today's supermarkets. She emphasized that she and her husband came to Vero Beach because they were told it was a good stable community, that the growth was managed, and that it was safe. She wished to see it kept that way. Ralph Richards, 955 Starboard Drive, stressed the compatibility issue. He pointed out that Publix's hours are from 7:00 a.m. to 10:00 p.m. every day of the week, and trucks arrive prior to 7:00 a.m. He did not believe that is compatible with the neighborhood. Ann Clark Hickman, 2185 Via Fuentes, stressed the safety factor of big trucks coming in at all hours. She urged the Board to keep the barrier island pristine and beautiful for everyone who will come after us. She didn't have anything against Publix; she just didn't want to live near a supermarket. Lloyd Smiley, resident of the Moorings, read aloud a letter published in the newspaper objecting to the planned monstrous Public Market and related stores in the Moorings. 37 July 12, 1994 -I Matthew McCullen, 1001 Bay Road, emphasized that a supermarket is out of scale in physical size for this site and this community. He stressed that the proposed supermarket is vigorously opposed by the vast majority of residents and property owners of the entire south beach area. Nancy Offutt, government affair coordinator for the Vero Beach/Indian River County Board of Realtors, expressed their concern that whenever a use is going to be deleted from a zoning classification, the property owners and the public should be officially notified and that the procedure is strictly followed so that they can rely on the Comprehensive Land Use Plan and its amendments. If the Commission's decision today in effect does remove supermarket or any use from the CL zoning district, the Board of Realtors asks that the decision be subject to the formal procedure for changes in the LDRs through public hearings and public notice. Joseph Hickman, resident of the Moorings, pointed out that on chart 5411 presented by staff, grocery store and supermarket are listed separately. He felt that if they are listed separately, they cannot be the same. Attorney Dill asked and was granted 3-5 minutes of rebuttal time, during which he and Professor Cotterill summarized their arguments in appeal of staff's determination that a grocery store is a supermarket. Commissioner Eggert felt very deeply that there is a difference between a grocery store and a supermarket, as we know it today. She felt this was reflected in earlier talks back in 1982 when our Comprehensive Plan was being prepared. Under the retail sales general section of the Land Development Regulations, it speaks to General Commercial (CG). She recalled that we talked about supermarkets, department stores and variety stores belonging in CG. Back then, it was called Light Commercial, but now this is called Limited Commercial in a neighborhood. We wanted something there that had less impact than anything that would go into General Commercial, something that would maintain the environmental integrity of that neighborhood. Having worked and lived all over this country she didn't know of any place where they don't distinguish between grocery stores, supermarkets and convenience 38 July 12, 1994 Boa BOOK 'PAGE stores. She understood the use of the Standard Industrial Classification (SIC) code. One of the hardest things she has found in serving on the Planning & Zoning Commission and as a County Commissioner is the Department of Transportation telling you exactly where to put median cuts. It doesn't matter what is along the edge. They tend to stuff the people into the criteria; they don't fit the criteria to the people. This is becoming increasingly frustrating. Commissioner Eggert believed there is a big difference in intensity between a supermarket and a grocery store. She felt Director Keating should have chosen variety store rather than grocery store as she has always defined grocery store and as she assumed it was continuing to be defined in our Indian River County Code. A variety store is a permitted use in General Commercial only. For that reason she would move that Director Keating did fail in reviewing this in several of the criteria and move to uphold the appeal. COMMISSIONER EGGERT'S MOTION TO UPHOLD THE APPEAL THAT A SUPERMARKET NOT BE ALLOWED IN LIMITED COMMERCIAL DIED FOR LACK OF A SECOND. In response to questions by Commissioner Adams, Director Keating explained that Sam's is classified as a department store, which is an administrative permit use in the CL Zoning District and limited to 40,000 square feet. Director Keating advised that there is no size limitation for department stores in a CG District. Department stores attract customers from a much larger area and they sell much more than convenience goods and personal services. He did not feel Sam's primary focus is to sell food. Commissioner Adams asked if trip generations were similar between grocery stores and department stores, and Director Keating said he would check with Traffic Engineering. Commissioner Adams had mixed feelings on this whole episode, and agreed with Commissioner Eggert that supermarkets have grown to be big grocery stores. She felt it is just a matter of semantics and that a good debater could win it either way. However, we have been dealing under the assumption all these years that they are the same and we have allowed the same use in our LDRs and have approved permit applications based on that. This may be the test case that says maybe it's time to split it out but the question is do we split it before or after, and that is where we are having a problem. 39 July 12, 1994 Director Keating advised that Public Works Director Jim Davis is checking the ITE trip generation manual. Chapter 952 of the LDRs lists trip rates by the number of uses based on some studies done in Florida. We do not specifically call out department stores but we have commercial of various sizes. Generally, as a commercial establishment size increases, the trip generation rate per 1,000 square feet decreases. The trip rate per 1,000 square feet is substantially higher for the much smaller convenience store use. Commissioner Eggert understood that Director Keating was referring to convenience store versus supermarket or grocery store, and Director Keating stated that was correct. There is no grocery store delineation in Chapter 952, and he didn't think there is any in the ITE trip rate. Commissioner Adams noted that Attorney Warren Dill offered that there is no square footage definition for the terms supermarket or grocery store, and she inquired if Professor Cotterill was aware of one. Professor Cotterill, analyst from Connecticut, stated that anything below 10,000 square feet would be a grocery store. Attorney Evans pointed out that under the County's Code anything below 28,000 square feet is a grocery store, and Commissioner Adams noted there are houses in the Moorings with more square footage than that. Tom Vincent, Vice President of Halvorsen, returned to the dais and pointed out that there is no documented, substantial evidence to suggest or imply that there is a factual square footage threshold between the two, which is obviously the cause of this debate. He felt it is important to understand that when the ITE manual refers to a supermarket line item, it typically is used for a free-standing site. All the other categories that Director Keating referenced for commercial square footage thresholds of 100,000 to 200,000, or 200,000 to 400,000, etc., are established on the concept that most commercial food store/shopping center situations are multiple use centers where people can shop at several retail locations within the center rather than going to several isolated commercial uses. In other words, you eliminate or mitigate multiple trips with a single, free-standing store. 40 BON UZ 'a",1814 July 12, 1994 J Commissioner Macht understood that we have been approving supermarkets under the general rubric of grocery stores for years. Based on precedent and in order to be consistent with the law, he felt the conclusion we should come to is whether or not it is in the best interest of the people in question. He felt Attorney Dill has made a very compelling argument, and perhaps we ought to make a differentiation. However, we have to make our decision based on current law that is in the best interest of all of the citizens of Indian River County. Commissioner Macht felt we are going to have to find that a grocery store is a supermarket, and a supermarket is a grocery store. One is a manifestation of the other and he didn't see how we can escape that. MOTION WAS MADE by Commissioner Macht, SECONDED by Commissioner Bird that the Board deny the appeal filed by Attorney Warren Dill. Under discussion, Commissioner Bird thought the dialogue today has been excellent and that all of the expert testimony was well stated. However, he felt the timing of it is wrong. He felt that if we recognized there was a problem between grocery stores and supermarkets, or if we had realized that by lumping them together we allowed them to be a permitted use in a Limited Commercial zoning district, we could have addressed the problem numerous times over the past few years. We could have addressed the problem during the numerous public hearings on the adoption of our Comprehensive Land Use Plan and the Land Development Regulations, and certainly when we adopted the zoning that presently exists on that property. In that scenario, and according to staff's interpretation, it did allow a grocery store or supermarket to be built in a Limited Commercial district. Commissioner Bird believed that if anyone in this room over the last year or two, or any of the attorneys, or any of the citizens of this county would have called the Planning Department and expressed their concern about that piece of Limited Commercial property there in the Mooring's, they would have been told that it was possible for someone to get site plan approval for a supermarket of this size. Although it wasn't built, a site plan was approved in the past for a grocery store/supermarket of approximately this size (Food Lion). It was never built and the site plan approval expired. Commissioner Bird strongly believed in private property rights and upholding the ordinances and the land development regulations that have been adopted in this county. Based on the date that this application 41 July 12, 1994 I was filed and the laws that were in place at that time, he felt we should uphold staff's determination and deny the appeal. Chairman Tippin concurred with Commissioner Bird for most of those very same reasons. Because it is an allowed use, he.would support the Motion. However, times do change and he felt we must revisit this matter. Commissioner Adams also felt there is a difference, but the Board has to go with the way the regulations stood at the time the application was submitted. She also agreed that this allowed use should be readdressed. Commissioner Eggert appreciated the other Commissioners' feelings on this, but she pointed out that this matter had been discussed for a number of years and somehow managed to slip through. She believed that a different choice could have been made here as to what category a supermarket falls under, that is, a supermarket as we know it today. THE CHAIRMAN CALLED FOR THE QUESTION. The Motion to deny the appeal of the determination that "supermarkets and grocery stores are like uses as applied to the IRC LDRs" passed by a vote of 4-1, (Commissioner Eggert dissenting). The Chairman announced that the time being 1:30 p.m. we would take a one hour lunch break and reconvene at 2:30 p.m. 42 806W E; July 12, 1994 BOOK 9 ` L -E At 2:30 p.m., the Chairman reconvened the July 12, 1994 meeting of the Board of County Commissioners with the same members present. PUBLIC DISCUSSION -APPEAL BY HALVORSEN DEVELOPMENT CORP. OF A P&Z COMMSSION DECISION TO DENY SITE PLAN APPROVAL FOR PROPOSED SHOPPING CENTER ON AIA AND MOORINGLINE DRIVE Chairman Tippin asked everyone intending to testify today to please stand and be sworn by County Attorney Charles Vitunac. Planning Director Stan Boling presented staff's recommendation for approval of the site plan submitted by Halvorsen Development Corporation: TO: James E. Chandler County Administrator • _ VI I N H CE: ober M. Recti , AI Community De6vel men irector THROUGH: Stan Boling, AICP Planning Director FROM: John W. McCoy, AICP� Senior Planner, Current Development DATE: July 61 1994 SUBJECT: An appeal by Halvorsen Development Corporation of a Planning & Zoning Commission Decision to Deny Site Plan Approval for a 46,560 sq.ft. Shopping Center at the Southeast Corner of S.R. A -1-A and Mooring Line Drive. It is requested that the data herein presented be given formal consideration by the Board of County Commissioners at its special meeting of July 12, 1994. This is the second of two appeals related to the proposed Sea Mist Shoppes Development. BACKGROUND: Halvorsen Development Corporation, through its agent (Attorney Ralph Evans), has appealed a decision by the Planning & Zoning Commission to deny a major site plan application to develop a 46,560 sq. ft. shopping center at S.R. A -1-A and Mooring Line Drive (see attachment #1). The appeal alleges that the Planning & Zoning Commission failed to approve a plan that, with conditions recommended by staff, meets approval criteria. The applicant requests that the Board of County C issioners overturn the Planning and Zoning Commission's denial and approve the site plan application. In accordance with site 0Xan appeal procedures, 43 July 12, 1994 (reference LDR Section 914.13) the Board of 1ounty Commissioners is now to consider the site plan application and is to approve, approve with conditions, or deny the site plan application. *Planning and Zoning Commission Review of the Old (May 12th) Site Plan At its regular meeting of' May 12, 1994, the Planning and Zoning Commission considered an earlier submittal, voting 2 to 3 on a motion to deny the application (see attachment #2). Since a majority of 4 votes is required for the Planning and Zoning Commission to take action, the earlier site plan was deemed denied. Subsequently, the developer, in accordance with the LDAs, appealed the Commission's action to the.Board of County Commissioners. Although the Board waad�ss scheduled to hear that appeal at its June 21, 1994 regular meeting, the developer waived his right to have that appeal hearing within 30 days. Therefore, the June 21, 1994 hearing was canceled. Subsequent to waiving his rights to appeal the decision on the "May 12th" site plan, the developer submitted revised plans which the Planning and Zoning Commission considered at its special meeting of June 28, 1994. • Impetus for a New (Revised) Site Plan At the May 12th Planning and Zoning Commission meeting, representatives of The Moorings Property Owners Association raised • questions regarding several technical site plan issues, including: project open space, project driveway internal separation distances, and parking and loading space provisions. Prior to the -May 12th meeting, each of these specific issues had been discussed in TRC deliberations and had been considered by the departments responsible for reviewing these issues. In fact, planning staff, in its TRC discrepancy letter, requested verification from the applicant that the plan met the 25% open space requirement, and public works staff raised the driveway internal separation distance issue. At the May 12th meeting, concerned residents and the applicant, as well as planning and public works staff, discussed these issues. After the May 12th meeting, planning staff requested that the applicant verify and document that, as indicated on the original site plan, the site plan satisfies the applicable 25% open space requirement. Public works staff also requested that the applicant document how the site plan satisfies the LDR driveway internal separation distance requirements. In response, the applicant revised the original site plan to: a. Provide more green open space area and to document, with working -drawing calculations, that the project -'satisfies the 25% open space requirement; and b. Increase the driveway internal separation distances and add a third project driveway. Upon receiving the site plan revisions, planning staff made a determination that the changes were substantial enough to constitute a "new site plan" and warrant a review by the Planning and Zoning Commission. While this site plan is similar to the site plan considered at the May 12, 1994 Planning and Zoning Commission meeting, the County Attorney's Office has indicated that this site plan must be treated as a new submittal by the Planning and Zoning Commission and the Board of County Commissioners. *Planning & Zoning Commission Action on the New (June 28th) Site Plan July 12, 1994 4 At its special meeting of June 28th 1994, the Planning & Zoning Commission voted 3 to 3 to approve the new site plan (see attachment #3). Since a majority of 4 votes is required for the Planning & Zoning Commission to take action, this site plan was deemed denied. Subsequently, the developer, in accordance with the LDR's, has appealed the Commission's action to the Board of County Commissioners. BACKGROUND AND HISTORY OF PARCEL: sZoning and Land Use Map History The subject parcel is currently zoned commercial and was originally zoned commercial as part of the initial Moorings Development plan. From the late 1960s to the present, the subject property has continuously been depicted as commercial on county zoning maps. Although many surrounding parcels were rezoned from commercial to residential in the 19701x, a few adjacent parcels are still zoned CL (see attachment #5). From the late 1960's to 1985, the subject property was zoned C1 -A (restricted commercial), which is a zoning district that is similar to the present CL district. Both districts allowed/allow commercial uses such as grocery stores, restaurants, and many other retail uses. In 1985, as part of a county -wide administrative rezoning process, the subject property was rezoned from C1 -A to CL, which is its current zoning. Also, it should be noted -that the county's comprehensive plan land use map, first adopted in 1982, has always designated the subject parcel as commercial. The property is designated as commercial on the current comprehensive plan land use map. •Site Plan Proposal History This site has been the subject of three previous site plan applications, none of which proposed a grocery store/supermarket over 11,000 sq. ft. in size. The first application was filed in October 1986 and was not approved, due to a lack of response and follow-through by the applicant. This plan proposal depicted 58,000 square feet of commercial building floor area and 23% open space on site. (Note: Only 20% open space was required in the CL zoning district until 1991, when the requirement was increased to 25%.) The second application for major site plan approval was submitted on January 27, 1988 and, after staff review, was approved by the Planning and Zoning Commission at its regular meeting of March 24, 1988. The plan depicted 53,200 square feet of commercial building floor area and proposed to provide 34% open space using a 2 story design. Due to a lack of permitting and construction by the applicant, this site plan approval lapsed on March 241 1989. The third application for major site plan approval was submitted August 18, 1989 and, after staff review, was approved by the Planning and Zoning Commission at its -regular meeting of October 12, 1989. The plan depicted 60,000 square feet of commercial floor area and proposed to provide 34% open space using a 2 story design. This design was similar to the design approved as part of the second site plan application. The approval of this application expired October 12, 1990, due to failure of the applicant to obtain a -building permit and commence construction. PROPOSED DEVELOPMENT AND LOCATION: Kimley-Horn and Associates, Inc. has submitted a revised major site plan on behalf of Halvorsen Development Corporation to construct a 46,560 square foot shopping center at 2105 South S.R. A -1-A. The submitted site plan is similar to the plan reviewed by the Planning 45 July 12, 1994 � a � and Zoning Commission at its May 12, 1994 meeting. The subject property is located at the southwest corner of Mooring -Line Drive and S.R. A -1-A (see attachment #5) and is zoned CL, Limited Commercial. Shopping centers are permitted uses in the CL zoning district. The subject site is cleared, with the exception of some scattered trees on the site. The developer proposes to build a 46,560 square foot shopping center which will consist of a grocery store/supermarket, a retail area, and a --bank (see attachment #6). Area residents have displayed a great deal of interest and concern regarding the proposed development, and planning staff have coordinated closely with area prdperty owners associations and neighborhood groups regarding this project proposal from its inception. ANALYSIS: 1. Size of Site: 5.32 acres or 231,832 sq. ft. 2. Zoning Classification: CL, Limited Commercial 3. Land -Use Designation: C/I, Commercial/Industrial 4. Building Area (for the four proposed buildings): Publix: 27,860 sq. ft. Retail: 10,700 sq. ft. Retail: 5,000 sq. ft. Bank: 3,000 sq. ft. Total: 46,560 sq. ft. Note: A sit down restaurant has been removed as a proposed use. 5. Open Space: Required: 25.0% Provided: 25.2% (creditable) Note: There is a difference between the creditable amount (green area) and overall amount. The difference is the 2.5' overhang area provided at parking spaces. The 2.5' is not creditable towards satisfying the 258 open space requirement. One of the items questioned by residents at the May 12, 1994 Planning and Zoning Commission meeting was the site plan's open space percentage. Because of the questions, the applicant re-examined the open space figure and found that, contrary to previous information and "verification" offered by the applicant, additional open space was required to,meet the 25% requirement. The applicant has addressed this concern in the submitted revised plans by reducing required parking area and converting some previously proposed parking area to green area. The reduction in the amount of required parking was achieved through the elimination of a proposed sit-down restaurant. This new open space area is located south of the stand-alone retail building. Staff has requested that the applicant again re -check the green area calculations for this project. Again, the applicant has verified that the revised site plan meets the 25% open space requirement. 46 July 12, 1994 800 l The traffic impact= analysis and the proposed off-site traffic improvements were reviewed and approved by the county's Traffic Engineering Division. 6. Traffic Circulation: -Overall Analysis: As required by the LDRs, the- developer .submitted a traffic impact analysis performed by a professional engineer (see attachment #9). This analysis, which has been reviewed and accepted by the County Traffic Engineer, assumes a "worst case scenario" of 47,500 square feet of development including 2,300 square feet of restaurant use (note: the site plan.depicts 46,560 square feet and no sit down restaurant use).' According to the analysis, at build -out (assumed to occur in 1995), the project would generate 4,438 daily trips and 408 peak hour trips. Of the total project trips, 57.9% would be pass -by capture trips from vehicles already on the roadways. Thus, the new trips anticipated from the project are 11868 daily trips and 172 peak hour trips. Based on existing traffic volumes and estimated volumes resulting from the project, 1995 roadway level of service conditions with project traffic were analyzed. The analysis shows that SR A -1-A in and around the project site and in the entire south beach area would meet a "B" level of service (LOS) (see attachment #9). The LOS "B" is two levels above the county's minimum acceptable peak season/peak hour/peak direction LOS "D" standard. -External: The revised plan proposes three -driveway connections, two to Mooring Line Drive and one to Windward Way. The driveway on Windward Way and the eastern driveway on Mooring Line Drive are shown as full movement driveways. The western driveway on Mooring Line Drive would prohibit out bound left turns. The western driveway on Mooring Line Drive is designed to handle employee and delivery traffic, and would function to separate this type of traffic from store customers. _ For northbound traffic on S.R. A -1-A, a left -turn lane would need to be provided on S.R. A -1-A for traffic turning left onto Windward Way. The existing 36' of pavement within the Windward Way right-of-way would be restriped to provide 3 lanes of traffic, two eastbound and one westbound. This would provide a left turn lane and a right -turn lane/through lane for eastbound traffic. For southbound traffic on S.R. A -1-A, there would need to be a right -turn deceleration lane provided on S.R. A -1-A for traffic turning westbound onto Mooring Line Drive. Also, the pavement and the median within the Mooring Line drive right- of-way would need to be modified to provide a median opening for left turns into the proposed shopping center at two points. A left turn lane would need to be provided on the westbound segment of Mooring Line Drive by striping -out the existing 26' of pavement for a left turn into the center and through lane. An additional 4' of pavement would need to be added to the eastbound segment of Mooring Line Drive to complete a 24' wide segment, and the pavement would be striped to accommodate a through/left-turn lane and a right -turn lane. (Please see attachment #6 for a depiction of these required traffic improvements.) Residents who have reviewed the revisions have raised a concern that the proposed additional median cut is spaced closer than the 330' separation distance referenced in LDR section 952.12(9)(b) (see attachment #8). The Public Works 47 July 12, 1994 Department, however, has indicated that the 330' dimension is for traffic -way corridors (i.e. thoroughfare plan roads), where the median has a traffic control function rather than an aesthetic function. Since Mooring Line Drive is classified as a local road and its primary function is to provide access to adjacent lots and tracts, it is the opinion of the Public Works Director that the spacing of the second median cut is not regulated pursuant to LDR section 952.12(9)(b) (see attachment #8). Internal Traffic Circulation: The Windward Way driveway and eastern driveway on Mooring Line Drive would provide customer access to the site. The western driveway on Mooring Line Drive would provide access to the site for delivery vehicles and employees, thereby separating the high volume, high turnover customer traffic from delivery and long term employee parking. Delivery vehicles would enter the site through the western driveway on Mooring Line Drive and exit through the driveway on Windward Way. Internal driving aisles would provide access to all of the parking spaces, loading areas, and the drive through facility proposed for the bank. The Traffic Engineering Division has reviewed the internal circulation plan, including the truck routing, and -has found that the internal traffic circulation plan complies with the LDRs, including the internal driveway separation distances referenced in section 952.12(8)3. 7. Off -Street Parking: Required: 233 spaces Proposed: 234 spaces Tire stop waiver granted Note: In the revised plans, the developer has removed some parking spaces along with deletion of any proposed sit-down restaurant use. Pursuant to section 954.07(4)(d)2, the applicant has requested a tire stop waiver for parking spaces which do not abut landscaped areas. The Public Works Director and Community Development Director have the authority waive the tire stop criteria if they determine that the following criteria are met: a. The waiver would not allow vehicles to encroach upon landscape or pedestrian areas (such areas shall be protected by tire stops, curbing, or the equivalent); b. The waiver would not allow vehicles to abut or "head into" one another in any fashion other than bumper to bumper [any bumper to fender (or side) parking configurations shall require tire stops, curbing, or the equivalent]; c. The waiver would not apply to spaces accessed from driveways that serve as circulation driveways which channel traffic around or through the site or parking lot area; and d. The site plan parking area traffic circulation design provides circulation driveways, as needed, to adequately channelize traffic flow. In the opinion of the Public Works Director and the Community Development Director, the application meets all of the above referenced criteria. Therefore, the Public Works Director and Community Development Director have waived the tire stop requirement, consistent with the proposed site plan. 48 BOOK 92 PvjE892 July 12, 1994 I Boa. 92 pnE Note: The tire stop waiver was granted for both the May 12th plan and the revised plan. 8. Stormwater Management: The stormwater management plan has been submitted to the Public Works Department, which has granted tentative approval of the stormwater plan. The applicant will be required to obtain a Type "B" stormwater management permit prior to site plan release. Public Works will- require post development discharge to be no more than pre -development discharge and will require that the site's discharge not create adverse impacts to the existing drainage system. 9. Compatibility with the Surrounding Area: Given the area's predominately residential use, staff gave a great deal of attention to compatibility of the proposed project with surrounding uses. While staff has the ability to apply and enforce only the land development regulations, staff had requested that the developer exceed the county's land development regulation requirements in relation to several elements of the plan. Those elements included: landscaping, buffering, signage, and loading/unloading areas. Staff also recommended that the developer exceed the county's buffering requirements, which the developer has done in this site plan proposal, mostly by adding additional shrubs to the buffers. The applicant has also agreed to use a low level monument style sign rather than a pylon sign. The monument style sign will be more compatible with the residential style of subdivision signs in the area, rather than typical commercial pylon signs. In response to staff comments, the applicant has proposed to provide walls and a roof to the loading/unloading platform located at the rear (west side) of the proposed grocery store. In reviewing the site plan, staff has attempted to keep the project's main entrances on Mooring Line and Windward Way and off Bowline Drive to limit the mixing of commercial and residential traffic. Previous shopping center proposals for this property proposed driveway connections on Bowline Drive (closer to residential areas). Thus, the proposed traffic circulation plan should reduce the intrusion of commercial traffic into residential areas, as compared to previous site plan proposals. Pursuant to LDR section 952.13(2), staff has recommended that the developer re-examine the need for a wall to buffer the loading area behind the proposed Publix. It is staff's position that a wall would serve as a better noise block than just the berm and vegetative buffer. Staff notes that, like Previously approved plans for the site, the proposed third (new) driveway will bring commercial traffic closer to the residential area than the May 12th plan. The applicant has agreed to construct a 6' - 8' wall, with specific provisions made to ensure drivers leaving loading areas could see over the wall prior to exiting the loading area. 10. Landscaping and Buffering: The landscape plan is in conformance with Chapter 926. This includes required perimeter buffering. The site is bordered on several sides by residenirial zoning (see attachment #5). To the west and southwest, the adjacent Property is zoned RS -3. Where a CL district commercial 49 July 12, 1994 M project abuts the RS -3 district, the LDRs require that a Type "B" buf fer be constructed to separate the uses. To the north, the property is zoned RM -10. Where a CL district commercial project abuts the RM -10 district, the LDRs require that a Type "C" buffer be constructed to separate the uses. To the south of the jreaysthe rHarbor troj ect whiwas approved satimeshare/ental development. The _ Harbor Inn property is zoned CL. Since that property is zoned CL, there is no buffering required by the LDRs. At the request of staff and residents, however, the developer is depicting on the site plan a Type "C" buffer along the south property line of the shopping center parcel. The LDR's require that the developer provide a 6' opaque feature where the Type "B" buffer is required adjacent to the single family residential zoning. The developer is proposing a berm which would be 6' above the pavement for Bowline Drive • and 3' above the elevation of the shopping center. There would-be plant material installed on top of the berm to provide additional height for the buffer. The slope of the berm would extend from the parking lot into the right-of-way for Bowline Drive. The Public Works Department has conditionally approved the developer's request to extend the berm into the right-of-way. (Please see attachments #6 and #7 for details of the berm and buffering adjacent to Bowline Drive.) As submitted, the site plan exceeds all plant material quantities for the buffer areas and the S.R. A -1-A landscape strip. The property to the east is zoned RM -10. However, no special type of buffering is required since there is a thoroughfare plan road (S.R. A -1-A) between the two properties. A standard 10' wide landscape strip is required between the proposed shopping center parking lot and the S.R. A -1-A right-of-way. The applicant is proposing to plant the 10' landscape strip within a 15' wide utility easement that runs along the project's S.R. A -1-A frontage. The landscape material, however, could conflict with the ability of utility providers to construct and maintain utilities within the easement. Therefore, the applicant will be required to maintain the required 10' landscape strip, regardless of any utilities construction or maintenance activity. The applicant has three options to remedy the conflict: a. obtain a release of the easement, b. redesign the site plan to remove the landscaping from the 15' utility easement, or ce obtain and execute a covenant for removal and replacement of the landscape material, in the event of utility work disturbing the buffer. The applicant has indicated that he will pursue option "c.", and will obtain and execute a covenant for removal and replacement of required landscape materials. The covenant will need to ensure that the applicant or.its successor will replace any required landscape material removed during utility work in the easement. A covenant or release of easement must be obtained prior to site release. Any redesign (option "b.") would need to be re-evaluated and re -considered by the Technical Review Committee (TRC) and the Planning and Zoning Commission. - 50 Bm 92 July 12, 1994 mm 92 mrA90 11. Utilities: The project will be served by water and wastewater from the City b,f Vero Beach. These utility provisions have been approved by the Environmental Health and Vero Beach Utilities Departments. 12. Dedications and Improvements: •External Sidewalks: The county's land development regulations require that a 5' wide public sidewalk be provided along Bowline Drive and Windward Way. Section 914.15(6)(b)2aiii allows the Public Works Director and Community Development Director to waive the sidewalk requirement when a physical constraint is present that would preclude proper construction of a sidewalk segment. In this instance, the landscape berm (considered necessary for buffering). would constitute such a physical constraint. Therefore, the Public Works Director and Community Development Director have waived the sidewalk requirement along Bowline Drive. No sidewalk then will be required along Bowline Drive. •Off -Site Traffic Improvements:. The off-site traffic improvements are covered in the traffic circulation element of this report. 'I Site Lighting: The CL zoning district requires that site lighting be. installed as a required improvement. The applicant has proposed a site lighting plan that appears to meet the requirements of the land development regulations. There is a provision in section 954.07(4)(e) of the land development regulations that prohibits the source of illumination for site lighting from being visible from adjacent properties. Staff believes that the lighting plan meets this requirement, but reserves the right to require field adjustment after issuance of the certificate of occupancy (C.O.), to correct any lighting "spill-over" problems. *Signage: At staff's request, the developer has committed to a monument style sign, but cannot be required to provide such as sign based on the LDRs. 13. Environmental Issues: There are no wetlands or native upland habitat on the site. The only environmental concern staff initially had with the proposal was the impact of commercial site lighting on sea turtles. This concern has been adequately addressed by the applicant. 14. Concurrency: The applicant has executed a concurrency acknowledgement agreement for the project, indicating that the Project does not have concurrency and that an initial concurrency certificate must be obtained prior to the issuance of a building permit. Therefore, all concurrency related requirements related to site plan approval have been satisfied. 15. Surrounding Land Use and Zoning: North: South: East: West: July 12, 1994 Multi-family/RM-10 Timeshare/CL Multi-family/RM-10 Single family/RM-10 51 M M _I APPEAL CRITERIA For site plan appeals to the Board, there are no specific appeal criteria to be considered as there are in appeals from decisions of the community development director. Therefore, this appeal is to be considered by the Board in the same manner that the Planning and Zoning Commission considered the-ziteplan request. The issue, then, is whether or not the site plan meets all applicable county LDR requirements. ' In making its decision to deny the site plan, the Planning and Zoning Commission failed to specify its reasons for denial. It is staff's position that, with the referenced conditions, the site plan meets all applicable LDR criteria and should be approved. RECOMMENDATION: Based -on the above analysis, staff recommends that the Board of County Commissioners grant the appeal and approve the "June 28th" site plan with the following conditions: 1. That prior to site plan release, the applicant shall obtain a covenant, which is satisfactory to the County Attorney's Office, that provides for removal and replacement of required landscape material within the 15' utility easement, or a release of 10' of the 15' utility easement. 2. That prior -o the issuance of a Certificate of Occupancy (C.O.), all off-site traffic improvements described in section 6 of this report must be completed, and deemed acceptable by the County Traffic Engineering Division. 3. That the applicant must shield all lighting in accordance with section 954.07(4)(e). This could require lighting adjustments and modifications after issuance of a Certificate of Occupancy (C.O.). 4. That the developer shall install a 6' to 8' high wall the length of the loading area that serves the grocery store/supermarket. A portion of the wall height may be reduced to provide a line of sight for trucks exiting the loading area. 5. That the landscaping will need to be field verified to ensure that all corner sight distances are maintained and that any required 6' opaque vegetation feature is opaque to a height of 6' as measured from the project site. ATTACHMENTS: 1. Letter of Appeal 2 Minutes from May 12th Planning & Zoning 3. Draft Minutes from June 28th Planning & 4.., Site Plan Application 5. Location Map 6. Site Plan 7. Berm Section 8. LDR excerpt 952.12(9)(b) 9. Traffic Impact Analysis Excerpts 52 July 12, 1994 Commission Zoning Commission I Director Boling noted there have several points of contention in terms of whether or not this revised site plan meets the requirements of the LDRs with regard to traffic, parking, etc. He felt the Board needs to concentrate on four of those areas. One will involve the traffic study itself, the trip distribution and the assumptions that went into that, and the impact on how different driveways on different parts of the project are classified. A different classification of driveway would mean a different type of requirement in terms of the separation distance between where the driveway enters the property and the next intersection with an internal driveway. Concerns also were raised about the median on Mooringline Drive, the two driveway cuts within that median, and the application of the LDRs regarding median openings. Another issue to consider is the maneuverability within the loading area and getting into the loading areas. Director Boling advised that a fourth issue, which is major, gets back into the scope of review. He referred to the following memo from County Attorney Charles Vitunac dated 7/6/94: (Exhibit 1.2) TO: Board of County Commissioners FROM: Charles P. Vitunac, County Attorney DATE: July 6, 1994 RE: Standard of Review for Site Plan Appeal I have been asked to state briefly the legal prerogatives of the Board of County Commissioners regarding site plan appeals under the Indian River County Code and State law and in particular regarding the Publix site plan for The Moorings, which is under appeal. SUMMRY OF SITE PLAN REVIEW The site plan -review requirements are given in Section 914.15 of the Code and can be reduced to the following three inquiries, each of which will be discussed in turn: 1. Is the use allowed by the zoning code? By the time the Publix site plan appeal is heard, the Board of County Commissioners may have resolved the issue whether a "supermarket" is within the ambit of the term "grocery store" and hence allowed in a CL zone. If the use is not allowed, the site plan must be rejected. If the use is allowed, the Board must next determine if the site plan meets the objectively determinable standards. 53 July 12, 1994 _I M 2. Are all objectively determinable standards met? These standards are specifically enumerated in the code and can be objectively determined. By the time this appeal is heard the County staff and the Planning and Zoning Commission may have made a recommendation for approval or not based on the objectively determinable standards issues. County policy is to have the applicant re -work the site plan until the County staff finds that all requirements are in order. Therefore, it is not expected that objectively determinable standards requirements will be a decisional issue. However, if they do become an issue the burden of proof is on the applicant to present competent, substantial evidence showing compliance with each objectively determinable standards requirement. This review by the BCC is quasi- judicial. This means that, once unrebutted proof has been made showing compliance with each requirement of the Code, the Board is required to grant the permit applied for, at least in so far as this objectively determinable standards issue is concerned. 3. Is the site plan consistent with the comprehensiveplan? State law requires that all land use decisions be consistent with the comprehensive plan. There are no exceptions. A site plan_ approval is such a land use decision. How does Indian River County ensure that its site plan decisions are consistent with the comprehensive plan? "Consistency" is defined in Section 163.3194(3)(a), F.S., as follows: A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other as ct of the development permitted by such order or regulation compatible with and further the objectives, p6licies, land uses, and densities or intensities in the comprehensive plan and if it meets with all other criteria enumerated by the local government. In the first instance, the County relies on Section 163.3213(3), F.S., which directs that any challenges to the consistency of the Land Development Regulations (LDRs) with the comprehensive plan must be filed within 12 months of the date of LDR adoption and are thereafter barred. Since this time has elapsed without challenges a person may not now claim that the LDRs are inconsistent with the comprehensive plan, and there is a presumption that the LDRs are consistent with the comprehensive plan. The Board may take notice of the numerous public hearings, both during the day and at night, by both the Planning and Zoning Commission and the Board of County Commissioners, which were held to ensure that the County LDRs were made consistent with the Comprehensive Plan. The second means is the thorough review by staff professionals of the proposed site plan and its relation to the LDRs, zoning code, and comprehensive plan --all done with public input. The County land use professionals have all determined that the site plan is consistent with the comprehensive plan. As a third means of ensuring compliance the County has established the following hierarchy of land use controls: General Outline of Land Use Controls ("controls") A. Comprehensive Plan B. Zoning Regulations 54L'0K.9 2f--". July 12, 1994 C. D. E. Site.Plans, PVDs, Subdivision Plats Regulations Building Permits Certificates of Occupancies Consistency with the comprehensive plan is ensured by requiring that each control be consistent with the control next in priority. (The comprehensive plan is the highest priority.) If each control is consistent with the one above it, then it also will be consistent with the comprehensive plan. This method reduces the numerous reviews that a thorough comprehensive plan analysis would otherwise require. Only the next higher level of control must be reviewed. Thus, for a site plan review, once the objectively determinable standards are met only the zoning code need be looked at. The first three controls will be discussed individually: A. Comprehensive Plan The highest control, the comprehensive plan, is a statutorily mandated legislative plan to control and direct the use and development of property within the county. The plan is similar to a constitution for all future development within the county and is developed by the BCC in its legislative discretion subject only to state law requirements. It is the adopted portion of the comprehensive plan (i.e., goals, objective standards, land use map, and other reference tables) that carry the force of law. B. Zoning Regulations The LDRs are the means by which the comprehensive plan. is implemented and their implementation involves the exercise of discretionary powers within limits imposed by the comprehensive plan. The requirement of the state that all LDRs conform to the comprehensive plan is in effect a limitation on the local government's otherwise broad zoning powers. In the last few years, Indian River County has made all its zoning and other land development regulations consistent with the comprehensive plan. As already mentioned any challenges based on inconsistency of LDRs with the comprehensive plan -not filed within 12 months of LDR adoption are time-barred by Sectiot-163.3213(3), F.S. C. Site Plan The County's site plan r44ulations are also LDRs, which have been adopted through the public hearing process, and are thus presumed to be in compliance with the comprehensive plan. However, specific site plans must' be reviewed for consistency with the LDRs. Section 914.15 of the Code requires that "site plans shall be reviewed pursuant to all applicable zoning district regulations and regulations for specific land uses, as applicable" and that "the development of any areas subject to the provisions of this ordinance shall be consistent with the policies regarding land development as established in the various elements of the Indian River County comprehensive plan." This section lists some 26 matters to consider, most of which are objectively determinable standards. Thus the burden of proof is on the proponent of the plan to show consistency or compliance with the aforementioned requirements. STANDARD OF REVIEW Once the evidence for both sides has been presented what is the standard of review available to the Board of County Commissioners? July 12, 1994 55 M M _I M When enacting the comprehensive plan and initial LDRs the Board acts as a legislative body subject to the deferential "fairly debatable" rule. When reviewing .site plan issues, however, the Board is acting as a quasi-judicial body. This means that there must be competent, substantial evidence for every required finding, and that the decision of the Board must be based on whether the applicant has met the requirements of existing law. It would not be appropriate to consider what the law should be (That would be a legislative decision). A county cannot unreasonably withhold site plan approval once the legislatively adopted existing legal requirements have been met. The following excerpts from controlling court cases may assist the Board in understanding the review standards: CASE EXCERPTS 1. " . . . the function of a . . . commission is reviewing a property owner's proposed site plan for development of the owner's property in accord with the city zoning laws was not legislative in nature, but rather administrative [i.e., quasi-judicial]." (City of Delray Beach) 2. " . . . a city cannot unreasonably withhold approval [of a site plan] once the legislatively adopted legal requirements have been met." (City of Delray Beach) 3. "All persons similarly situated should be able to obtain plat approval upon meeting uniform standards. Otherwise the official approval of a plat application would depend upon the whim or caprice of the public body involved." (City of Delray Beach) 4. "The administrative procedure for site plan approval is quasi-judicial in nature, and conducted to factually determine if a proposed site plan submitted by the property owner conforms to the specific requirements set out in the administrative -regulations governing the erection of improvements on the property . . . Those conditions should be set out in clearly stated regulations. Compliance with those regulations should be capable of objective determination in an administrative proceeding. While the burden may be on the property owner to demonstrate compliance, no legislative discretion is. involved in resolving the issue of compliance." (City of Delray Beach) S. "When the public entity conducts site plan . . . review, it merely applies_ established rages of law to existing and uncontested facts." (City of Delray Beach) 6. " . . . the authority of a town to deny the land owner the right to develop his property by refusing to approve the plat of such development is, by statute, made to rest upon the specific standards of a statute or implementing ordinances. Thereafter, the approval or disapproval of the plat on the basis of controlling standards becomes an administrative act." (City of Coral Springs) 7. "It is elementary that once a party complies with all legal requirements for platting there is no discretion in governmental authority to refuse approval of the plat." (City of Coral Springs) S. "Section 14 of the Broward County Plat Act . . . provides that such approval may be 'subject to such conditions as the governing body 56 MDK 92 fAu July 12, 1994 Bo, 0 2 ma ­831 of the county. commissioners may deem to be in the best interest of the .public.Without pursuing the validity of that provision . . . we hold that , having met all of the legal requirements for obtaining plat approval, the county must approve [the] plat . . ." (Broward County case) 9. "Opposition of surrounding property owners must be considered by the city . . . since the statement of intent of the . . . ordinance includes the desire to achieve aesthetic and compatible relationships between adjacent properties. But the opinions of neighbors by themselves are insufficient to support a denial of a proposed development. We agree with the city that project density is a legitimate concern . . . But it is a concern that must be addressed and expressed in appropriate ordinances." (City of Deland) 10. "The correct law applicable in this case is that the ordinance should be given its plain meaning and that any doubts should be construed in favor of a property owner. The circuit court's reliance upon the undefined and uncertain standards contained in the statement of intent when clear and specific numbers of units are expressed in that same ordinance is not an interpretation that recognizes the plain meaning of the ordinance." (City of Deerfield Beach) 11. "The site plan merely regulates the layout of a piece of property, the design of the buildings, and the actual locations of the buildings on that site. The city's zoning ordinance control the uses to which a particular piece of property may be put. The plan board, therefore, is not to be concerned with the particular use of a piece of property as long as it fits within the permitted uses of the city's zoning ordinances." (City of Gainesville) 12. "The plan board members voted to deny the petition because of the parcel's intended use . . . not because it failed to comply with appropriate criteria for site plan approval." (City of Gainesville) [This was found to be illegal.] 13. "The test in reviewing a challenge to a zoning action on grounds that a proposed project is inconsistent with the comprehensive land use plan is whether the zoning authority's determination that a proposed development conforms to each element and the objectives of the land use plan is supported by competent and substantial evidence. The traditional and non -deferential standard of strict Judicial scrutiny applies. (Machado case) 14. "A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspects of development permitted by such order or regulation are compatible with and further the objectives, policies, land uses and densities or intensities in the comprehensive plan, and if it meets all other criteria enumerated by the local government." (Machado case) 15. "Zoning laws are in derogation of the common law and as a general rule are subject to strict construction in favor of the right of a Property owner to the unrest:Acted use of his property. Permitted uses must be interpreted broadly, prohibited uses strictly so that doubts are resolved in a property owner's favor." (City of South Miami) 57 July 12, 1994 Director Boling reviewed the 5 conditions of site plan approval as set forth in staff's recommendation. Commissioner Adams inquired about the distance between the canopy trees on the 15 -ft. buffer, and Director Boling explained that the opaque barrier will have vegetation 3 -feet above the berm level. There being no further questions of staff, Chairman Tippin opened the public discussion. Attorney Ralph Evans, 2920 Cardinal Drive, representing the applicant, referred to the following letter dated June 29, 1994: (Exhibit 1.3) FtALPii L. Evnxs ATroxxsv AT LAM • 2920 CARDINAL DRIVE - P. O. BOX 3247 VERO BEACH. FLORIDA 32964 TEL (407) 231-1800 - FAX (407) 231-2612 Z�j293031 7 June 29, 1994 Q, JUN1994 :.� roasP„;�rJmr Robert M. Keating, AICP t Community Development Director 1840 25th street Vero Beach, FL 32960 In Re: Site plan for Sea Mist Shoppes Dear Mr. Keating: As you know, I represent Ronald Ferrin, and his agents, in regard to the above referenced site plan application. Please accept this letter as notification to you of my client's initiation of an appeal pursuant to section 914.13, Indian River Code (1994) from the action, or lack thereof, made by the Planning and Zoning Commission at its special meeting held on June 28, 1994 in regard to the site plan application. _. Generally, this appeal is initiated on the basis that the Planning and Zoning Commission, failed to garner the requisite four votes necessary to recommend or not to recommend approval of site plan, and therefore, such lack of votes is deemed to'be a denial of the site plan.. Additionally, the site plan, without the necessity of revision and with the conditions placed on it, meets the requisite criteria in Indian River County for approval, as was demonstrated by substantial competent evidence presented in support of this application. As required by law, please advise the County Administrator of this appeal. As I understand it, in anticipation of an appeallbeing initiated from this site plan application, it has been scheduled for review before the Board of County Commissioners on July 12, 1994. I appreciate your attention to this matter. If there are any questions, please do not hesitate to contact me. Very truly yours, a RAL H L. EVANS 58 July 12, 1994 boa 92 fAu 833 Attorney Evans reminded the Board that their function here today is quasi-judicial. He advised that he would be introducing several people during the following presentation of Halvorsen's appeal who will explain this site plan in every detail and would be happy to answer any questions the Board may have. Attorney Evans introduced Keith Pelan of Kimley-Horn who pointed out the details of the site plan on a diagram of the 5.3 acre site located at the southwest corner of AIA and Mooringline Drive, concentrating on the driveway classifications cited in staff's recommendation. Mr. Pelan noted that after Public Works Director Jim Davis advised that an upcoming DOT project calls for 3 lanes on A1A from the St. Lucie County line north to Vero Beach, they agreed to enter into a developer's agreement to 3 -lane the section of AlA from a - point south of this project to just north of Harbor Drive, the entrance to the Mooring's club. Assuming permitting and everything else gets taken care of, that would happen simultaneously with this project. Mr. Pelan next addressed various site plan requirements, i.e. setbacks, 25 percent open space, maximum floor area, and parking spaces. Concentrating on the loading areas, he noted that the Code requires two loading spaces of a minimum of 141x 151. The plan provides three loading areas, one being a 24' x 80' depressed truck well for the grocery store which will accommodate two tractor trailer trucks unloading simultaneously side by side. The second loading area is 241x 35' and is located at the corner of the grocery store and also will service the retail building. The third area is not specifically designated as a loading area. It is in the southeast corner of the site and is basically for smaller trucks to service the retail store from the front and from the rear along a rear sidewalk. Mr. Pelan showed an illustration of the area where there has been some concern about the ability to maneuver trucks, explaining that the second driveway off of Mooringline Drive will serve to separate all the service traffic from the main customer traffic. Mr. Pelan then addressed the following: solid waste disposal (the various dumpster locations); the two different types of lighting on the site; location of signage; sidewalks; and street lighting. In response to Commissioner Macht's concerns about lighting, Director Boling advised that the County Code requirement is to 59 July 12, 1994 shield the light source from adjacent properties and vehicles that are on the roadways and any direct glare. Mr. Pelan next addressed Commissioner Adams' questions regarding traffic circulation, noting that the majority of trips will come off of Mooringline Drive. Commissioner Adams felt the entrance sign might be more effective if placed at the southern driveway. She questioned why there isn't an entry or exit off of AlA. Public Works Director Jim Davis explained that the LDRs address driveway connections based on the functional classification of the roadway. If the property borders more than one roadway, that access would be the roadway with the lesser functional classification. In this particular case, AlA is an arterial route and there are connections to the Moorings Development at Mooringline Drive and south at Bowline Drive. Basically, the access would be to the minor roadway and not another access onto AlA, and that is in harmony with the DOT's Access Management Program that was approved by the Legislature. Lengthy discussion ensued regarding the truck access and whether the 25 -ft. width of the driveway off of Mooringline Drive would be sufficient to handle two-way traffic. Attorney Evans introduced Tom Vincent, vice president of Halvorsen Development Corporation, who distributed packets containing the following material. Lengthy discussions were held after each topic: (Exhibit 1.4 - green folder) SEA MIST SHOPPES SITE PLAN SEC. 914.15(7)(b) SETBACKS: SEC. 911.10(7): 25 FT. FRONT, 10 FT. SIDE, 10 FT . REAR SITE: 61 FT FRONT; 47 FT SIDE; 71 FT REAR MINIMUM OPEN SPACE: SEC. 911.10(7): 250 SITE: 25.2% BUFFERYARD REQUIREMENTS: SEC. 911.10 (8) : TYPE B WITH 6 FT OPAQUE ABUTTING SINGLE FAMILY; TYPE C WITH 6 FT OPAQUE ABUTTING MULTI -FAMILY; 10 FT AT AlA SITE: "B" AT BOWLINE DRIVE, "C" AT MOORING LINE DRIVE; 15 FT AT AlA; AND "C" AT WINDWARD WAY. 60 July 12, 1994 B:oDK92 ;MSE 835 MAXIMUM FLOOR AREA: SEC.* 911. 10 (7 ) NOT LESS THAN 10, 000 S.F. , INFLUENCED BY OPEN SPACE, PARKING, MAXIMUM BUILDING HEIGHT, AND COVERAGE. SITE: 20.1% BUILDING SEPARATION: LOT COVERAGE: SEC. 911.10(7): 40% SITE: 20.1% REQUIRED IMPROVEMENTS: SEC. 911. 10 (6) : BIKEWAYS, SIDEWALKS, STREET LIGHTS SITE: BIKEWAYS EXISTING ALONG AlA; SIDEWALKS TO BE CONSTRUCTED ALONG MOORING LINE AND BOWLINE DRIVES; EXISTING STREET LIGHTS AT AlA INTERSECTIONS, MOORINGS STREETLIGHT DISTRICT TO PROVIDE ADDITIONAL WITH ASSESSMENT TO THIS PROPERTY DENSITY/INTENSITY: SITE: USES: SEC. 911.10(4) FLOOR TO AREA RATIO: .2 : 1 SEC. 914.15(8) CONCURRENCY MANAGEMENT [Chap. 910] *LEVELS OF SERVICE: SOLID WASTE; ROADWAY; DRAINAGE; POTABLE WATER; SANITARY; AND PARKS. ZONING [Chap. 911] *COMMERCIAL LIMITED HAS 79 (1 07 IN CG) PERMITTED USES INCLUDING BANKING, RETAIL, AND GROCERY STORES; *MANDATES REQUIRED IMPROVEMENTS: BIKEWAYS, SIDEWALKS, AND STREETLIGHTS; *SIZE & DIMENSION MINIMUMS: LOT SIZE: NOT LESS THAN 10,000 SQ. FT. & NOT LESS THAN 100 FT. WIDE; SETBACKS: FRONT, 25 FT., REAR & SIDE, 10 FT.; *MAX. BUILDING COVERAGE, 40%; *MINIMUM OPEN SPACE, 25%; *MAX. BUILDING HEIGHT, 35 FT.; *BUFFER REQUIRED: TYPE "Bn 6 FT. OPAQUE BETWEEN SINGLE FAMILY, AND TYPE "Cu 6 FT. OPAQUE BETWEEN MULTI—FAMILY. ACCESSORY USES & STRUCTURES [Chap.917] POTABLE WATER AND SANITARY SEWER [Chap. 918] LANDSCAPING & BUFFERING [Chap. 926] *BUFFERS TYPE "B" & "C"; VEHICULAR AND NON—VEHICULAR STANDARDS, SIGHT DISTANCES; IRRIGATION FLOODPLAIN/STORMWATER [Chap. 930] STORMWATER MANAGEMENT 61 July 12, 1994 TRAFFIC [Chap. 952] *TRIP GENERATION *TRIP DISTRIBUTION *LEVEL OF SERVICE *EXISTING AND FUTURE CONDITIONS *PEAK HOUR, DIRECTION, SEASON *ENTRANCE REQUIREMENTS *DRIVEWAY CONFIGURATION, LOCATION *TURNING LANES/MEDIAN PARKING [Chap. 954] *NUMBER REQUIRED *LOADING DOCKS DRI [Chap. 916] TREES PROTECTION/LANDSCAPING [Chap. 927] ENVIRONMENTALLY SENSITIVE AREA PROTECTION UPLAND HABITAT [Chap. 929) WELLFIELD/AQUIFER PROTECTION [Chap. 931] COASTAL MANAGEMENT [Chap. 932] HISTORICAL PRESERVATION [Chap. 933] MINING/EXCAVATION [Chap. 934] SPECIFIC LAND USE CRITERIA [Chap. 971] [Chap.928] Economic concessions S Imcrovements: 1. Type "C" Buffer at Windward Way (not required!) ...........................$ 3,500.00 2. Exceeded Buffer requirements with plantings/tree densities (Over 2 1/2 times actual number of trees required) ............................$ 6,000.00 3. Additional sidewalks at Publix frontage and R.O.W...................$ 4,500.00 4. Added parapet walls above roof lines and continuous manpard roofs with concrete tile (shields all roof top equipment!!)................$100,000.00 5. Added wall/roof enclosure at loading - dock platform and added 6'-8' wall at loading dock......................S 9.000.00 Total......................$123,000.00 62 July 12, 1994 b L I r f E"10K 92 FBF PROJECT COMPARISON Moorings Commercial Center vs. Sm Mit S6oppes ' . �i y'� r.^ :.�• : Com'. . .. �i� � :� �•. > .;;iG'.i' :�;gS"'. .�' �.• �:: L.'-Y:� >t�fpfii4. s,�ii?�o�r .��.•�,,<: . Y � '� • `'� �MUR l f ,.• .;.n�wr rM..:?w•f'i^t!'?.'..•..•�'.� _. �iZ't•_r' ,� .,. � � j; U w ! .j . `D , is �' � y., ai�1F •Qi . y_ '. yltwl:�;<..t. . . rh•'.. �Yt��ll °'Mii1v , t".v lv• ': - r � f` a.:iA�";;f �r �r �'. f`r� i�yfi LAND USE BY SQUARE FEET Retail 39,500 13,850 Medical Office 4,500 0 O4•ie 12,000 0 Reshmot Grooary Bank 4,000 1,850 0 27,860 0 3,000 TOTAL 60.000 46,560 -22% PARIUNG SPACES PROVIDED 326 234 -2VIs OPEN SPACE Cin: are feet 37,095 59,500 +36.5% TRAMC GENERATION PM Peals Ilour 245 172 -30'/. Dai 24 1,868 -26% BOWLINE DRIVE BERM V He' 6' Ha + 2' Ha Rk ACCESS POINTS P 3 • Previovdp approved access driveda Bowline skive now proposed on Mooring Line Drive WWRQfO"46AP SUM JULY 11, 1994 TOM VINCENT HALVORSEN HOLDINGS 1900 GLADES ROAD SUITE 260 BOCA RATON, FLORIDA 33431 RE: PUBLIB FACILITY SEA MIST BROPPES OF VERO BEACH SWC AlA i MOORING LINE DRIVE VERO REACH, .INDIAN RIVER COUNTY, FLORIDA Dear Tom: Thank you for,your recent phone call which updated me on the progress of the above referenced location. July 12, 1994 63 Needless to may, I was somewhat concerned with the questions concerning the seasonality of this location, as well as some views that had been circulating about the possibility of the facility only being opened on a "seasonal" basis. Allow me to expound upon this. First of all, when working diligently on this particular location to determine the viability of the site, the Publix Real Estate Department did take into consideration "seasonality". This, of course, has.always been a factor that we use when evaluating our locations. Since most of our existence is in the For example, when I was a Manager in the Tequesta location, we experienced a seasonality drop in sales of approximately 303-403 between Easter and the first few weeks of October. There are also other areas that we service, such as Longboat Key, Naples, and areas in Dade, Broward, Palm Beach, Martin, and Indian River County that also fluctuate in sales. Publix recognizes that many of the customers are occupying two residences and limit their time here in Florida. When Publix made the determination to approve the location, all of the seasonality factors were taken into consideration. As far as operating stores on a seasonal basis, please be assured that Publix does not have any locations that close during the "off season" periods. Many of the management teams utilize the time to work on other projects during this period. It would be very difficult to even consider operating stores on a seasonal basis, because of two primary factors: (1) being associated with employees. Publix offers year-round opportunities for its workers and would find it very difficult to try to relocate them during the off-season periods; (2) It is important to note that we could not justify having to move all of the inventory out of the store for the off-season periods. With all of this in perspective, I would hope that you could convey to any concerned parties that this location will be operated year-round and the seasonality factors have been well taken into consi erat on. Please feel free to contact analogy of these scenarios, questions you may have. me if you would like a further or if I can answer any additional As always, your continued interest in our company is greatly appreciated. 64 July 12, 1994 SINCERELY, PUBLI$ SUPER XARnTS, INC. �n TOM ADAMS REAL ESTATE MANAGER BOOK 9 FftiU1DC7 J no0 PALES Board of County Commissioners sea Dist shoppes site Plan Approval Hearing July 12, 1994 Comparable Projects (Commercial/Retail Developments Adjacent to Residential) 1. Neapolitan Way Naples, Florida 2. The Trails Shopping Center Ormond Beach, Florida 3. Regency Square Boca Raton, Florida 4. Village Commons West Palm Beach, Florida 5. Cobblestone Crossing Jacksonville, Florida 6. Alafaya Square Oviedo, Florida 7. Plantation Promenade Plantation, Florida S. Riverchase Shopping Center Naples, Florida 9. Proposed Shopping Center Coral Ridge Drive and Lakeview Drive Coral Springs, Florida 65 July 12, 1994 M M M L SEA MIST SHOPPES TRADE AREA 2) Floralton Beach 750K -1.5M 10 # S. F. # M. F. RESIDENTIAL DEVELOPMENT PRICE RANGE UNITS UNITS INDIAN RIVER COUNTY 1) The Moorings 130K -3M 350 800 2) Floralton Beach 750K -1.5M 10 3) Porpoise Point 225k -1.2M 111 4) Bonita Beach 150K -1M 19 45)The Sands 5) Surfside Estates 150K-lM 23 6) Anglers Cove 125K -1M 12 7) Oceanridge Subdivision 295K -1.5M 63 SUBTOTAL 8) Little Harbor 500k -2M 10 3925 9) Oceanside 400k - 700k 42 10)Seagrove 200k -600k 212 11)Sandpointe 500k-2 M 35 12)Shorelands 300k -500k 37 13)Smugglers Cove 200k -500k 37 14)Wyn Cove 150k- 225k 26 15)Treasure Cove 225k -325k 23 16)River Ridge Estates 300k -500k 19 17)The Dunes 175k -2.75M 12 18)Rio Mar 250k -1M 310 19)Castaway Cove 1-6 190k-iM 482 20)Indian Bay 150k -1M 42 21)Ocean Corp 125k -200k 100 22)River Oaks 100k -250k 92 "23)Bethal By The Sea/Veromar 200k -350k 916 24)Cache Cay 250k -750k 73 25)Pebble Bay Estates 350k- 850k 46 26)Hidden Harbor 250k -325k 17 27)Johns Island 120k -3M 401 1000 28)Seawatch 120 29)Victoria 50 30)Vera Cruz 75k -125k 56 31)Oceangate 145k -175k 40 32)Bermuda Bay 80 167 33)Seaforest Court 25 34)Maroon Subdivision 20 35)The Fountains 45 36)Sunny Sands 35 37)Vista Del Mar 100k -125k 245 38)La Mer 100k -150k 128 39)Park Shores 275 SUBTOTAL 3509 2986 ----------------- ST. LUCIE COUNTY 40)Atlantic View 100k -230k 102 41)Bryn Mar 80k -180k 156 42)Barkley Bay 125 43)Ocean Harbor 111 44)Queen Cove 300 45)The Sands _ 45 46)Treasure Cove Dunes 25 47)Sea Palms 116 48)Hibiscus 58 SUBTOTAL 416 ------------------ 622 TOTAL UNITS 3925 3608 TOTAL SF AND MF 7533 AVG PERSONS PER HH 2.32 TOTAL ESTIMATED POP 17477 "ST LUCIE % OF TRADE AREA 13.78% 66 92 P, u 840 July 12, 1994 J Attorney Evans next introduced Kurt Crist, landscape architect from Michael A. Billick, Inc., who addressed the Type C buffer required on Mooringline Drive and the Type B buffer along Bowline Drive. He also elaborated on the vegetation included in the Type C buffer along Windward Way and the right-of-way buffer along AlA. Commissioner Eggert asked what type of trees they have planned for the parking lot, and Mr. Crist advised that they have proposed 92 trees, which is more than twice as many as the minimum requirement. They plan to plant cabbage palms, 12 -ft. live oaks and 12 -ft. Washingtonia palms in the parking areas, with Ligustrum trees up next to the building. Commissioners Adams and Eggert preferred to see 14 ft. or 16 ft. trees planted rather than the 12 -ft. trees, and Mr. Crist felt that was a very good suggestion because it would give a couple more years' jump on thais trees. He noted that there will be a regular maintenance program. Attorney Evans next introduced John Atz, registered professional engineer with Kimley-Horn and Associates of Vero Beach. Mr. Atz advised that beginning with the LDRs, he would review the code requirements and some of the methodology and thought that went into the transportation study. He next addressed trip generations for a commercial project. Continuing, Mr. Atz reviewed the traffic circulation of the site, and briefly explained their plans to minimize construction traffic. They intend to approach the DOT with a request for a temporary driveway connection off of AlA to accommodate construction traffic, but he could not guarantee the DOT will permit it. Mr. Atz next addressed the drainage requirements pursuant to the County's requirements as well as those of the St. Johns River Water Management District. Attorney Evans next introduced Henry Skokowski, who basically reviewed the proposed project in context to allow the Board to have a bigger picture of the land use planning and issues. He pointed out that the proposed project falls well within the concept of a neighborhood center. The project is separated by roads from all the abutting neighbors; it does not relate to the front yards of any single family homes. It is well buffered and screened. It is compact, efficient, and will service the neighborhood. 67 July 12, 1994 Attorney Evans announced that their presentation was concluded, but he requested some time at the end to address any issues raised in response to what they have presented. Attorney Steve Henderson, representing the Moorings, Property Owners Association and Jack MacLean, individually, distributed several pages of handout material. 'Noss, HENDERSON, VAN GAASBECE, BLANTON & ROVAL, P.A. July 7, 1994 VIA Hand Delivery Mr. Robert M. Keating, AICP INDIAN RIVER COUNTY ADMINISTRATION BUILDING 1840 25th Street Vero Beach, Florida 32960 RE: Appeal Under Section 902.07, Indian River County Code Dear Bob: On behalf of the Moorings Property Owners Association, Inc. and Jack MacLean, individually, please accept this letter as an appeal under §902.07 of your interpretative decision under §952.12 (9) of the Indian River County Code. In the Staff Report on the Moorings Project dated June 24, 1994, at the top of page 5 thereof, the Staff Report states: "Residents who have reviewed the revisions have raised a concern that the proposed additional median cut is spaced closer than the 330 foot separation distance referenced in LDR Section 952.12 (9)(b) the Public Works Department, however, has indicated that the 330 foot dimension is for traffic -way corridors (i.e. thoroughfare plan roads), where the median has a traffic control function rather than an aesthetic function. Since Mooringline Drive is classified as a local road and its primary function is to provide access to adjacent lots and tracts, it is the opinion of the Public Works Director that the spacing of the second median cut is not regulated pursuant to LDR Section 952.12 (9) (b) .11 July 129 1994 68 na � � , ATTORNEYS AT LAW DONALD C.FEUERBACH ROBIN A. BLANTON 817 BEACHLAND BOULEVARD LISA D. HARPRING KEVIN S. DOTY JUDITH GOODMAN HILL STEVE L. HENDERSON P, O. BOX 3406 FRED L. KRETSCHMER. JR. THOMAS A. KOVAL �c Y $$0 BEACH, FLORIDA 32964-3406 MARGARET S. LYON CLINTON W. LANIER LEWIS W. MURPHY. JR. GEORGE H. MOSS 1407, 231.1900 KATHLEEN WALSH STRATTON EVERETT J. VAN GAASBECK E. CLAYTON YATES FAX: 14071 231.4387 OF COUNSEL CHARLES E. GARRIS FORD J. FEGERT July 7, 1994 VIA Hand Delivery Mr. Robert M. Keating, AICP INDIAN RIVER COUNTY ADMINISTRATION BUILDING 1840 25th Street Vero Beach, Florida 32960 RE: Appeal Under Section 902.07, Indian River County Code Dear Bob: On behalf of the Moorings Property Owners Association, Inc. and Jack MacLean, individually, please accept this letter as an appeal under §902.07 of your interpretative decision under §952.12 (9) of the Indian River County Code. In the Staff Report on the Moorings Project dated June 24, 1994, at the top of page 5 thereof, the Staff Report states: "Residents who have reviewed the revisions have raised a concern that the proposed additional median cut is spaced closer than the 330 foot separation distance referenced in LDR Section 952.12 (9)(b) the Public Works Department, however, has indicated that the 330 foot dimension is for traffic -way corridors (i.e. thoroughfare plan roads), where the median has a traffic control function rather than an aesthetic function. Since Mooringline Drive is classified as a local road and its primary function is to provide access to adjacent lots and tracts, it is the opinion of the Public Works Director that the spacing of the second median cut is not regulated pursuant to LDR Section 952.12 (9) (b) .11 July 129 1994 68 na � � , ` r bo s, fnf 8 We consider this to be a decision or action by you as Community Development Director, either in the sense that Jim Davis is acting as your "designee" or on the basis that his opinion is adopted in your report and therefore becomes your opinion or decision. Our grounds for appeal are as follows: (1) The wording of the applicable ordinance is strongly mandatory to wit: it (9) Median openings. To assure traffic safety, capacity and control, median openings located within a traffic -way corridor shall be spaced the maximum distance apart that will allow safe and adequate circulation . . . (b) No median openings shall be spaced at a distance less than 660 feet from any signalized intersection or median opening, except the median openings may be spaced at a lesser distance based upon a traffic study and impact analysis; but in no case shall median openings be spaced at less than 330 feet . . ." (emphasis added). (2) The term "median" is defined in Ordinance Section 901.03 as "the physical pertion of a highway separating the traveled ways for traffic in opposite directions." (3) There is no definition of "Traffic -Way Corridor" anywhere in the LDRs and consequently, the only reasonable definition that can be given to it is a broad one such as a highway, road or street. The exemption created for the benefit of this developer is based, erroneously, on distinctions that are not expressed in nor justified by the LDRs. More specifically, there is no LDR that would create a distinction between the requirement for median separations on local as opposed to collector or arterial roads. Furthermore, there is no exemption or waiver from the median separation requirement for medians which serve an aesthetic function, nor is there any definitions that would provide guidance as to when a median is considered functional and when it is considered nonfunctional or aesthetic. If the purpose of a median and the purpose of a median cut minimum distances is to "assure traffic safety, capacity and control . . . ", then the ordinance should be interpreted in a manner which promotes safety, not in a manner which potentially creates hazardous conditions. Even if such distinctions existed in the ordinance, it is clear that this median strip will indeed serve a traffic control function, particularly when Mooringline Drive is loaded with increased traffic flows. The first time we. were aware of your interpretation of Section 952.12 (9) was when the staff report was issued. It is unclear as to when this interpretation was rendered, but we maintain that it was not made public until the distribution date of the report. Consequently, our appeal is timely under the provisions of Section 902.07 (3) (b) . 69 July 12, 1994 I have enclosed our check in the amount of $200.00 payable to Indian River County representing the filing fee for this appeal. Please advise as to when the appeal will be scheduled for hearing. We would expect that the provisions of Section 902.07 (6) would be given effect and that a final determination with respect to the public site plan would be deferred until this matter is heard by the Planning and Zoning Board and County Commission, if appealed. I look forward to hearing from you. Kindest regards, MOSS, HENDERSON, VAN GAASBECK, BLAND & KOVAL .A. Steve L. derson S LH; klm cc: Mr. Jack MacLean, Director The Moorings Property Owners Association, Inc. William G. Collins, II, Deputy County Attorney Indian River County Warren W. Dill, Esquire, via Fax No. 388-0871 MOSS, HEA'DE$sox, VAn GAASBECS, BI.ANTOR & HpVAL, P A. Attorney Henderson explained that the areas he would cover are fairly narrow, such as the median issue. There is no median opening provided for this project, and it is their opinion that is a violation of the ordinance. He referred to Section 952.12 dealing with access control: 70 Boor July 12, 1994 J 'BOOK 12 ifuuiS4. 1 952.12 ACCESS CONTROL Minimum Separation Requirements for Median(s) (9) Median openings. To assure traffic safety, capacity and control, median openings located within a traffic -way corridor shall be spaced the maximum distance apart that will allow safe and adequate traffic circulation. (b) No median opening shall be spaced at a distance less than six hundred sixty (660) feet from any signalized intersection or me- dian opening, except that median openings may be spaced at a lesser distance based upon a traffic study and impact analysis; but in no case.shall median openings be spaced at less than three hundred thirty (330) feet. Public streets shall be given pri- ority consideration for median openings. (4) Subdivision collector road a street which serves as the principal entrance street of a residential subdivision or provides for traffic circulation within a subdivision. (5) Minor or Local Street a street of limited continuity used primarily for access to abut- ting property, including cul-de-sacs and nonthrough streets. Attorney Henderson advised that Public Works Director Jim Davis feels that this section should not be applicable to this meeting because this median separation requirement is designed for thoroughfare collective roads and not for what he calls a local road. Director Davis also says that it does not have traffic control function and that it serves as an aesthetic function. Attorney Henderson advised that they have some traffic engineers who disagree with those conclusions. Attorney Henderson explained that he filed an appeal under Section 902.07 which contains the procedures that are to be followed in appeals from decisions of the community development director or his designee (in this case, the Public Works Director): 71 July 12, 1994 M Section 902-07. Appeals from decisions of the community development di- rector or his designee. (1) Purpose and intent. This section is estab- lished to provide a mechanism for the hearing and resolution of appeals of decisions or actions by the community development director or his des- ignee and for further appeals from decisions and actions from the planning and zoning commis- sion. (d) Notice of the appeal, in .writing, shall be mailed by the planning division to the owners of all land which abuts the property upon which an appeal is sought, at least seven (7) days prior to the hearing. The prop- erty appraiser's address for said owners shall be used in sending all such notices. The notice shall contain the name of the applicant for the appeal, a description of the land sufficient to identify it, a descrip- tion of the appeal requested, as well as the date, time and place of the hearing. (6) Effect of filing an appeal. The filing of an appeal shall terminate all proceedings which fur- ther the action appealed until the appeal is re- solved, except when the halting of such action poses a threat to life or property. The planning and zoning commission shall make this determi- nation. Notwithstanding this provision, proceed- ings involving review of a development applica- tion may proceed when an appeal of an administrative decision has been filed and will be considered concurrent with the development ap- plication request. M Attorney Henderson maintained that the above procedures have not been followed here, and for the record, he suggested that this Board lacks quasi-judicial jurisdiction to hear this site plan matter today. Attorney Henderson stressed that the ordinance is compelling in the sense that it requires a 330 -ft. separation. There is no distinction between aesthetic versus functioning medians. There are no distinctions in the ordinance between local and collective roads. These are criteria or distinctions that have been created by the Public Works Director and the Community Development Director. Attorney Henderson next addressed the issue of compatibility with regard to the Comprehensive Land Use Plan. He read aloud the following Policy 1.16: 72 800K 92 PAGE 846 July 12, 1994 600K 92 PAGE 84 Excerpts from Comprehensive Land Use Plan Future Land Use Element Incompatible Uses and Blighted Areas Incompatible uses include those which are out of character or scale with surrounding areas as well 'as those which negatively impact surrounding areas with noise, smoke, glare, traffic, etc. Several uses are by their nature incompatible with residential areas; these—include airports, landfills and many industrial and commercial operations. These uses have the potential to lower property values and reduce the development potential of surrounding property. These problems can be reduced through effective land use patterns that provide for separation and incorporate the use of buffers. Areas which contain incompatible uses are often older areas in transition from one use to another. 58 POLICY 1.16: Land development regulations shall provide performance standards for commercial development which at a minimum address the following: Land use campatibility, buffering and landscaping; Access points, traffic controls, and parking; Signage; Gross floor area, impervious surface ratios; Open space; Character of an area; Environmental Impact Attorney Henderson next addressed Table 2.29, Standards for Commercial/Industrial Uses: July 12, 1994 73 M M _I TABLE 2.29 STANDARDS FOR COMMERCIAL/INDUSTRIAL USES MANUFACTURING/ WHOLESALE/CONTRACTORS "'RETAIL L CONVIENCE GOODS OFFICE h HIGHWAY ORIENTED N INDUSTRIAL TRADES SERVICES 4 SERVICES BUSINESS SERVICES , SERVICES v ~ DESCRIPTION Activities including the Storage, shipping, transfer Sale of goods and services Frequently purchased goods , Non -retail oriented services Goods and services depending assembly, manufacture or or sale of large quantities including apparel,furniture, and services including food, including financial, realty, on vehiclular traffic. processing of materials of products and materials. and appliances. groceries, drugs, household technical, professional and Lodging, food and beverage ,�. or goods. Heavy repair Heavy commercial activities and personal products. some medical services. establishments. Auto services. including building trades Personal services, sales, service and repair. and services. Fuel sales. LOCATION Central, fringe and Central and fringe areas. Central areas, preferably Central and dispersed areas. Central and dispersed areas. Dispersed and fringe areas. dispersed areas. grouped. Near highway interchanges. SITE REQUIREMENTS Public water, sewer, solid Public water, sewer, solid Public water, sewer, solid Adequate public services and Adequate public services and Adequate public services and wastes facilites. Close to wastes facilites. Close to wastes facilites. Close to facilities. facilities. facilities. Emergency services. Emergency services. Emergency services. Generally small lots. Various lot sizes. Generally large lots. Various lot sizes. Various lot sizes. Various lot sites. Office parks and developments. Malls and centers. v 'p TRANSPORTATION Direct access to major Direct access to major /Oir*ecfJand controlled access Mrert'ind controlled Access to collector and Acces to major roadways. REQUIREMENTS transportation services. and intermediate roadways. to mar.and minor arterials acLess'to collector and' arterial roadways. On site parking. Hear to railroads, principal Easy road access. and collector roads. minor arterial roadways. On site and shared parking arterials. On site parking. On site parking. On site and shared parking On site parking. facilities. Pedestrian facilities. Pedestrian Pedestrian access. access. • access. RELATIONSHIP TO Compatible with Wholesale Compatible with industrial Compatible with most May be self s.tanding, small May mit with most other Should not be mixed with COMMERCIAL/INDUSTRIAL and Construction Trades. and some office uses. commercial but not industrial center, or part of large commercial uses and some most other commercial uses. USES May support some offices and Suited for integrated uses. Ideal for integrated integrated center or industrial uses. services. Not suitable with centers with on site center. shopping area. General retail and offices. ammenities including some ® o retail uses. r � 1 RELATIONSHIP TO Within easy commuting Within easy commuting Close to residential areas. Adjacent to residential Adjacent to residential Should be separated from RESIDENTIAL AREAS distance to residential distance to residential Adjacent Multi -family development but buffered. development but buffered, residential development. areas.. Not suitable as areas. Not suitable as development should be adjacent use. adjacent use unless heavily buffered. buffered. rY, BOOK 92 PAGE 8400 Attorney Henderson noted that the above table is not an adopted portion of the Comp Plan, but it provides insight as to the planners' thoughts about siting commercial nodes. He pointed out the two categories of Retail & Services and Convenience Goods & Services. He noted that they seem to permit the location of convenience goods and services adjacent to residential development with buffers, but over on Retail and Services, it suggests that they be close to residential areas, but certainly not adjacent to single family residences. Attorney Henderson stressed that there is an adjacent problem here with single-family homes on Bowline Drive. Admittedly, the property owners had the opportunity since the 1980s to question the node and the commercial zoning. He realized that the Board is sort of stuck with the zoning and with the Comp Plan, but he felt there is flexibility in the zoning and the Comp Plan to deny this project on the basis of incompatibility. Attorney Henderson introduced his client, Jack MacLean, who plans to present specific information on some deficiencies in the site plan itself and some other matters. Jack MacLean, 139 Anchor Drive, president of the Moorings Property Owners's Association, planned to talk about three specific areas they believe are failures in the site plan -- not enough green space -- Mooringline Drive is a major roadway driveway -- the area from which customers would come. Mr. MacLean distributed copies of Exhibit 3, a 28 -page presentation of arguments supporting their request that the Halvorsen site plan appeal be denied. 75 July 12, 1994 � O Table of Contents Rey Definitions Supermarket Survey Conclusions Aerial Photographs of Indian River County Supermarkets Number of Residences Located Within 300 ft. of Supermarkets Estimated Value of Resident Homes and Apartments Within 300 ft. of I.R.C. Supermarkets Letter from David Nolte, Indian River County Property Appraiser Delivery Truck Companies That Supply I.R.C. Supermarkets Approximate Area of Maneuvering Pavement Queuing Study of Existing Publix Supermarkets (July 1994) Photographs of Unloading Zones at I.R.C. Supermarkets LDR Violations a) Median Opening Violations b) Unloading Area Violation c) Erroneous Categorization of Windward Way Drive Summary 76 July 12, 1994 2 3 4-11 12 13 14 15 16 17 19-20 21 22 23 28 92 PnF850 BOOK 92 FACE 851 Median Opening Violation Please refer to letter from Attorney Steve Henderson to Robert Keating. 952/29 "No medial opening shall be spaced at a distance less than six hundred sixty (660) feet from any signalized intersection or median opening, except that median openings may be spaced at a lesser distance based upon a traffic study and impact analysis; but in no case shall median openings be spaced at less than three hundred thirty (330) feet. Public streets shall be given priority consideration for median openings." 901/30 "Median (traffic) : The physical portion of a highway separating the travelled ways for traffic in opposite directions." 952/29 "These regulations may be modified by the public works director on a case by case basis when warranted by circumstances unique to the particular development." Webster unique 1. existing as the only one or as the sole example. 2. having no like or equal; standing alone in quality; unequaled; unparalleled; incomparable. 3. impossible to duplicate within a stated or implied scope, as a geographical area or range of experience; unlikely to be matched; extremely rare. 4. limited in occurrence to a given class, 'situation or area. 5. limited to a single outcome or result; without alternative possibilities. 6. the embodiment of unique characteristics; the only specimen of a given kind. 77 July 12, 1994 TRAFFIC (500) to two thousand (2,000) vehicles. The iainimum distance from the street right- of-way line at any ingress or egress driveway to any interior service drive or parking space with direct access to such driveway shall be a minimum of fifty (50) feet measured on a line perpendicular to the street right-of-way. Intermediate drive- ways shall provide minimum ingress lanes fourteen (14) feet wide and egress lanes twelve (12) feet wide. Where left and right turn egress is allowed, dual egress lanes shall be provided with a minimum four -foot separation from the ingress lane. Interme- diate driveways sliall provide minimum ve- hicle turning radii of thirty-five (35) feet. 3. ,Major driveways. A major driveway shall provide fqr a maximum average daily trip volume of two thousand (2,000) to five thou- sand (5,000) vehicles. The minimum dis- tance from the street richt-of-wav line at any ingress or egress driveway to any inte- rior service drive or parking space with di- rect access to such driveway shall be one hundred (100) feet_ measured on a line per- pendicular to the street right-of-way. Major driveways shall provide minimum 'ingress lanesfourteen(14) feet wide and egress _lanes twelve (12) feet wide. Where left and right turn egress is allowed, dual egress lanes shall be provided with a miiumum four -foot separation from the ingress lanes. Mejor driveways shall provide minimum-ve- hide turning radii of forty (40et. ;(9) Median openings. To assure traffic safety, capacity and ontrol, median openings located ,within traffic-wav com hall be spaced the ,maximum distance a t w safe and adequate traffic circulation. (a) Median openings shall be permitted only i where traffic studies justify the need, taking into consideration the following: 1. Potential number of left turns into § 952.13 3. Distance of proposed opening from ad- jacent intersections or other openings; 4. Length and width of the left -turn storage lane as functions of the esti- mated maximum number of vehicles to be in the lane during peak hours; and 5. Traffic control, including signalization, that will be necessary at the median cut. If a traffic signal at a median cut is within one thousand five hundred (1,500) feet of another traffic signal, the two (2) shall be coordinated. (b) No median opening shall be spaced at a distance less than six hundred sixty (660) feet from any signalized intersection or me- dian opening, except that median openings may be spaced at a lesser distance based upon a. traffic study and impact analysis; but in no. case . shall median openings be spaced at less than three hundred thirty (330) -feet. Public streets shall be given pri- ority consideration for median openings. (c) All median openings shall include adequate storage and transition lanes, where war- ranted. (d) These regulations may be modified by the public works director on a case by case basis when warranted by circumstances unique to the particular development. (Ord. No, 90-16, § 1, 9-11-90; Ord. No. 93-8, § 19, 3-18-93) Section 952.13. Vehicular circulation. (1) Off-street parking areas. All developments shall comply with the minimum off-street parking requirements, of this code, as established in Chapter 954, Parking. Such parking areas shall be landscaped in compliance with the provisions of this Code. Where the public works director deems necessary, applicants shall install at their expense pavement markings and/or external traffic control signs to ensure the safe movement of traffic. driveways; (2) Off-street loading areas. All developments 2. Length of frontage along the street requiring off-street loading areas pursuant to right-of-way line of the property pro- Chapter 954, Parking, of this Code, shall provide posed to be served; such areas in locations which will not interfere Supp. No. 10 952/29 78 July 12, 1994 BOOK 92 FADE 85 BOOK 92 PAGE 85 J' The unloading area for this supermarket does not comply with county regulations 952/26 "Loading and unloading activities must in no way hinder vehicular ingress or egress." 1. This unloading plan does not permit this since it can fail whenever two or more trucks are ready to unload at the same time, and must fail with three or more trucks. 2. Proof has been provided that on a frequent and repeatable basis 3 or more vehicles are attempting to unload at the same time (see queuing study) 3. This site is one of the few in I.R.C. that attempts to utilize a .storage area in combination with a driveway for planned automobile parking. 4. The applicant has not proved and cannot prove that this Publix plan will meet article 952/26. 79 July 12, 1994 M M s § 952.12 INDIAN RIVER COUNTY CODE sions of section 952.12(5) Driveway width Number of and rum. Drive In Windows or Bays Queue Distance (f) Loading and unloading activities must in 3 10 vehicles/200 ft. no way hinder vehicular ingress or egress - 4 13 vehicles/260 ft. (g) All driveways shall maintain adequate 5 16 vehicles/320 ft. sight distance, as provided in this code. 6 19 vehicles/380 ft. (h) Ingress lanes: These standards may be reduced by the com- munity development director upon showing 1. Ingress left -turn lane requirements: A of good cause. twelve -foot wide left -turn lane with ap- propriate storage and transition shall (c) Commercial, sites having fifty thousand be provided at each driveway where the (50,000) square feet of. gross floor area or peak hour inbound left -turn volume is more shall provide for an exclusive access thirty (30) vehicles or more. drive at the primary entrance of the devel- 2. Ingress right -turn lanes: For any opment and all points of ingress and egress project, a twelve -foot wide right -turn located on a collector or arterial roadway, lane with appropriate storage and tran- not including service entrances. Said sition shall be provided at each drive(s) shall be used for providing access driveway where the adjacent roadway to all parking aisles and shall not contain average daily traffic exceeds ten thou - parking spaces; also, parking space(s) shall sand (10,000) vehicles per day, per - not directly access onto such exclusive ac- mitted roadway speeds exceed thirty - cess drive(s). five (35) miles per hour, and driveway (d) Provisions for circulation between adjacent volume exceeds one thousand (1,000) parcels on arterial roads shall be provided vehicles per day with at least forty (40) through coordinated or joint parking sys- right -turn movements during peak pe- tems, or other methods as approved by the riods. For any project, a right -turn lane public works director. as described in this subparagraph shall be provided at each driveway where (e) Driveway entrances must be designated to right -turn ingress volumes exceed accommodate all vehicle types having occa- seventy-five (75) vehicles per peak hour. sion to enter the site. The following table presents vehicle *types with their respective - - (2) Number and spacing of driveways. minimum inside and outside turning radii: (a) One driveway shall be permitted for in - Egress Ingress gress and egress purposes to any project. Type (feet) (feet) (b) The approving body may either increase or Passenger car, van, 25 25 reduce the following separation distances pickup based upon a recommendation by the public Single unit truck 35 42 works director after an analysis of street Bus 45 42 frontage trip generation, or other factors, Tractor -trailer (40 45 40 as deemed appropriate: feet) (c) A joint access driveway shall be considered Tractor -trailer (50 45 45 as adequate access. for any two (2) adjacent feet) parcels and shall be encouraged. For a Tractor -trailer (60 45 45 project where more than one driveway is feet) - requested, the applicant shall submit a Driveway entrances off collector and arte- traffic report justifying the need, describing rial routes shall conform with the provi- the internal circulation and parking system, Supp. No. s 952/26 80 July 12, 1994 Boa ' 92 PACE 854 BOOK 92 FACE 855 The applicant made the driveway splits by a "quick and dirty" use of traffic counts, with no regard for the changed driving patterns which must follow construction of this development. We have made a far more analytic evaluation which shows different splits, which leads to the categorization of the Windward Way driveway as a "Major" driveway, and must cause rejection of this site plan due to failure to meet article 952/29. Driveway In4r*ess Egress Analysis The basic criteria for this analysis is a judgement -weighted review of driveway ingress/egress, based on the following criteria: A) Drivers tend to favor the closest driveway. Measurements and calculations for this criteria are made external to the shopping center. B) Drivers tend to enter the driveway which leads to the drivers needing the least time traveling the shopping center to get to their optimum parking space. Measurements and calculations for this criteria are made internal to the shopping center. C) Judgement must then be used to integrate the above issues. Mr. MacLean distributed envelopes with little pieces of wood cut into scale models representing various sizes of delivery trucks and asked the Commissioners to arrange the pieces along the back of the property as if they were trying to unload. He suggested they take the largest truck first and put it in the depressed delivery ramp. He wanted the Commissioners to see what happens when 6 or 7 trucks make their deliveries at once. Mr. MacLean was convinced that you can't put 6 trucks behind there and not get in the way of parking, and he pointed out that it is a 2 -way road and that the entire 25 -ft. road has to be kept clear in order to maintain the County's regulations. He stressed that Chapter 952.26 stresses that "Loading and unloading activities must in no way hinder vehicular ingress or egress." Discussion ensued regarding the intent of the ordinance that the deliveries to the facilities will not interfere with the 81 July 12, 1994 customers coming in and out, and by segregating the deliveries to the rear of the stores fulfills, to some degree, the objective to segregate deliveries from the customers using the facility. Mr. MacLean next addressed the issue of Windward Way being a major roadway. If it is a major road, they maintain that this site plan fails because it does not have the required 100 -ft. separation from the main road. He also questioned the calculation of 1997 car movements within Windward Way. In conclusion, Mr. MacLean presented the following summary: Summary 1. 87% of all Moorings residents voted against this project; over 700 families who could not be here at this meeting wrote letters opposing Publix. The South Beach Property Owners Association and its members oppose it. With almost a thousand letters and communications against this property - only three people wrote in favoring it. 2. The reason that this shopping center (CL Zoning) was not strongly opposed in the comprehensive land -use plan is that it was then described as a "specialty food market", "shopping village", "a number of boutiques" and "groups of individual diverse shops". 'Now it has become a supermarket - and larger than the Publix at Miracle Mile. 3-. In a survey of nine other supermarkets in the county the proposed Sea Mist project: A) .Effects more residents (within 300 ft.) than the total of all nine existing supermarkets. B) Could effect property values of almost $40 million of residences, five. times greater than of the total of the other nine supermarkets. The county assessor has real concerns about this issue. Potential degradation of property assessments run into the millions of dollars C) Would be only supermarket in the county: that forces all traffic onto non -arterial roads. D) Would be one of the -few -supermarkets in the county that forces truck unloading to share space with automobiles. 4, The Site Plan violates'three important criteria contained in the•county planning regulations: A) The new median cut on the Mooring Line median is too close to the existing Bowline Drive median cut article 952/29, Section 9. 82 July 12, 1994 BOOK 92 PAGE 856 BOOK 92 PACE 857 B) The unloading space •behind the store must interfere with free flow of vehicular traffic article 952-21. C) The Windward Way driveway has been incorrectly described as an intermediate driveway. Proper classification as a major driveway (over 2 movements/day) and thus, the site plan is in violation of article. { This Site P1an:Does'Not Meet Indian River County Regulations and Must Be Rejected.: Mr. MacLean advised that he would ask Michael Dudeck, Roger Mosely and Scott McGuire to talk briefly and then would come back to Mr. VitunacIs letter of July 6 because he felt it proves his case. Michael Dudeck, traffic engineer from D & D Transportation Associates, Inc. of Boca Raton. Mr. Dudeck commented from the following letter dated 7/12/94: D & D Transportation Associates, Inc. 7301 A W. Palmetto Park Road Boca Raton, FL 33433 July 12, 1994 Mr. John MacLean Moorings Property Owners Association 139 Anchor Drive Vero Beach, FL 32963 Re: Traffic Engineering Review Traffic Impact Analysis Seas Mist Shoppes SR Al A Indian River County Dear Mr. MacLean: During the past few months, you have asked D & D Transportation Associates, Inc. to review the Traffic Study accomplished by Kimley Horn and Associates for the proposed Sea Mist Shopping Center just west of SR Al A between Windward Way on the south and Mooring Line Drive, the major roadway in the Moorings, on the north. 83 July 12, 1994 The initial work we did was limited in scope and was easy to address. It included a review of the Kimley Horn Traffic Study and a determination whether or not the effort was in conformance with Section 952.07 of the Indian River County LDR's. My review concluded that the mechanics of the Study were in conformance with generally accepted traffic principles. At the time I completed my review, I did not have the final Site Plan, nor was I asked to review Internal Circulation and traffic demands on the project's proposed driveway operation. Subsequently, Mr. Scott McGuire and I discussed my preliminary review, and I was asked to review the report again in order to address the traffic demands that full development of the proposed Site Plan would place on the driveways serving the Site as well as any other possible areas of LDR non-compliance. By way of background, in 19901 had a major input in developing Section 952 while serving as Indian River County Traffic Engineer. Upon receipt of this assignment from Mr. McGuire, and after thorough review, I again today confirm my position that both driveways should be treated as "Major Driveways" since they fully meet the code definition as well as promoting: traffic safety and reducing the possibility of internal congestion occurring within the Site. Even using the Kimley Horn methodology, the 2,000 TEDD "trigger" was definitely exceeded for the Mooring Line Drive and only missed by 3 TEPD (2 in and 1 out move for a 24 hour period). The need for both driveways to be classed as "Major" was because if the Windward Way traffic distribution was only 0.1 % more, the 2,000 TEPD trigger will be exceeded. A recent review of the number of potential shoppers residing along SR Al indicated that if the Moorings population were removed from the census data, the number of potential customers south of the Site along SR A 1 A would approach the number to the north of the Site between the Moorings and the 17th Street Bridge. This would indicate that the Kimley Horn Report underestimated the number of people using the Center from the south. Even if it was off by as little as 0.1 %, the Windward Way driveway would officially have to classified as Major. Subsequently, I reviewed the July 12th Property Owners presentation to the County Commissioners on this issue of driveway classification. I find this work very comprehensive in nature, and I am in agreement with it. The report is thorough and makes several excellent points which most reports normally don't address in detail. A second important issue is the subject of whether the second median cutin Mooring Line Drive was in conformance with the County LDR's. In making this review, I was shown the memorandum by Staff that this median cut was not subject to the LDR's since it was not listed on the County "Thoroughfare Plan". I strongly dig -agree with this position by Staff. Section 952.03 of the LDR's clearly state that "the requirements set forth in this Chapter should be applicable to all land development activities in the unincorporated area of Indian River County". This clearly indicates that all of the operational safety criteria from the project have to meet the minimum standards set forth in Chapter 952 of the LDR's, and the present plan of two closely spaced median cuts along Mooring tine Drive does not satisfy this requirement. My findings indicated that the treatment of the driveways, median cuts, internal loading areas, and parking criteria involved with the proposed Sea Mist Site Plan must meet the LDR standards. My professional judgment has not changed. 84 July 12, 1994 5OOK 9� AGE 858 boot 92 FACE 859 I have also accomplished an additional review of the project with the specific objectives of evaluating whether or not Mooring Line Drive was a Collector or Local roadway. A field review indicates that Mooring Line Drive "collects the traffic from several Local Access Streets and connects the traffic onto an Arterial, namely SR Al A". A review indicated that Mooring Line Drive has an 80 foot Right -of -Way, which is what the County has as a minimum width for a "collector". It also functions as a Collector. The mere fact that staff has yet to place Mooring Line Drive on the "Thoroughfare Network" does not change its function. The Thoroughfare Network is subject to periodic review by Staff, and it is an ever changing Network. I have more than 30 years of Traffic and Transportation Engineering experience at the Municipal, County and State levels and have always advocated applying at least Minimum Design Standards to the roadways being used by the motoring public. Another important issue is the mixing of truck unloading and automotive parking in this Site Plan. In my opinion, the studies and field reviews of truck loading and unloading done by the property owners is completely in line with my experience. Several trucks often make deliveries at the same time and thus could cause circulation problems for this site. At the present time, I utilize a Shopping Center driveway behind a Publix Market for my office. Several times in the past few months, other motorists and I wishing to park adjacent to our offices were completely blocked by delivery trucks. We were forced to go through the entire Center before we could reach our destination. Generally and ideally, the service areas in the rear of supermarkets are for the exclusive use of delivery vehicles. The proposed plan causes a mixture of private vehicles and heavy duty trucks which is contrary to code requirements. The latest plan is a violation of Section 952.26 of the LDR's because it will encourage an interfacing of heavy delivery and service trucks with passenger vehicles. In conclusion, based upon my research, knowledge of the County LDR's, projections included in all of the above mentioned data, it is my Professional Traffic Engineering Judgment that, as designed, the proposed development does not meet the LDR standards with regard to a) the second median cut on Mooring Line Drive which adversely safety, b) the incorrect classification of the Windward Road Driveway, c) the certainty that the loading provisions of 952126 are not met by the proposed plan and d) The Windward Way Driveway should be a "Major Driveway with a 100 foot queuing area per Section 952-29 of the LDR's. Sincerely, Michae. GuG_ck Jr. .Eoe. Raj Bhanmugan, senior associate of Barton-Aschman Associates, Inc., commented from the following letter dated 7/12/94: 85 July 12, 1994 BARTON-ASCHMAN ASSOCIATES, INC. 5310 N.W. 33rd Avenue, Suite 206 • Fort Lauderdale, Florida 33309 USA • (305) 733-4220 • Fax: (305) 733-4665 July 12, 1994 Mr. Jack McLean 139 Anchor Drive Vero Beach, FL 32963 RE: Sea Mist Shoppes Review Dear Mr. McLean: Per your request, I have thoroughly reviewed the traffic report and the revised site plan prepared 'by the consultant, Kimberly Horn Associates, for the Sea Mist Shoppes development. The consultant apparently has followed the current engineering practices and standards in developing this report. One of the most questionable items in the analysis is the traffic split towards the north and south of the site.. They have distributed the traffic, under the county engineering directions, sixty (60) percent to and from north, thirty (3 0 ) percent to and from south, . and five ( 5 ) percent each to and from east and west. This directional split could determine how much of the site traffic will be using Windward Way as opposed to Moorings Drive. Of course, the amount of project traffic on these roadways and subsequently on'the driveways has a bearing on the driveway design. The county engineers staff are probably correct in recommending 60/30 traffic splits from north and south considering the area of influence to be Indian River County. In my opinion the area of influence should extend further south to the North St. Lucie Bridge. Therefore based on 1990 census data and the residential population data that you provided me a conservative estimate would be an equal split of the traffic from the north and the south. Evenly distributing the 4438 trips between the north and the south driveways of the Sea Mist Shoppes site -will require both these driveways to be designated as "Major Driveways" with 100' set back in accordance with Section .952.29 of the Indian River County LDR. Additionally, I would like to bring the following points to your attention: • The traffic report cites 57.9 percent passerby capture based on the ITE trip generation manual. The manual, however, cautions this estimation and recommends using engineering judgement whenever possible. In my observation this figure is high and a lower value based on engineering judgement should have been used. • An operating AIA is used observations that. July 129 1994 speed equivalent to posted speed of 45 mph on in the intersection analysis. From my brief the operating speed appeared to be higher than 86 boa, 92 PAGE 060 BOOK 92 MME 861 • The site plan shows 67 parking spaces (approximately 29 percent) to be located along the back of the building which are in conflict with the loading and unloading area. This concern is further magnified by the less than average maneuvering area available for delivery trucks. According to a recent survey conducted by Knight, McGuire & Associates, Inc. the Sea Mist Publix site found to have less than half the maneuvering area provided by similar supermarket sites in the area. You also raised the question if the two openings along Mooringline Drive should be defined as median openings. According to AASHTO green book "A median is defined as the portion of a divided highway separating the travel way for traffic in opposite directions: Therefore, the physical separator that exists in.the middle of Meoringline Drive is called a median separator, and since these openings provide access to left -turning vehicles they are functional median openings. Since the two openings on Mooringline Drive are functional median openings their locations do not meet the 330' spacing referenced in the LDR. These spacing requirements -become a major concern due to the additional traffic from the Sea Mist Shoppes site. Over 1000 trips per day are anticipated to make left turns into the site through these median openings; approximately 20 to 30 of which would be trucks. I hope these findings help you in your course of action. Should you have any questions, please call me. Sincerely, BARTON-ASCHMAN ASSOCIATES, INC. Raj Shanmug , .E. Senior Associate E0 fta PARSONS TRANSPORTATION GROUP 87 July 12, 1994 00 00 Ca 0 0 001� -o On Cn B) Internal Traffic Flows (Based on Distance, Time and Conveniece Assumptions) (i) Traffic Flow Only on the Front of the Buildinas Trip Generation Sq Ft in Thsnds No. of Trips Generated. NIS Split (from IIIA) Driveway Traffic Volumes Mooringline Mooringline Windward Drive (West) Drive (East) Way Publix 27.86 2530 50/50 See Table Below 1265 1265 Unnamed Stores 10.7 972 40/60 See Table Below 389 50 583 Outparcel Stores 5.0 454 40/60 See Table Below 182 272 Bank 3.0 272 80/20 0 218 54 Total 46.56 F4438 Total 46.56 4228 49/51 See Table Below 2054 2174 (i) Total Traffic Flow Front Parking - 4228 49/51 0 2054 2174 Delivery Trucks - 40 50/50 20 0 20 North Back Parking - 50 100/0 50 0 0 South Back Parking - 120 33/66 40 0 80 Total 46.56 F4438 49/51 110 2054 2274 1 1 .1 g00K 92 FADE �� Scott McGuire, engineer from Knight, McGuire & Associates, Inc., commented from the following letter dated 7/12/94: Knight, McGuire & Associates, Inc. Consulting Engineers and Planners 2901 Cardinal Drive Vero Beach, Florida 32963 David S. Knight, P.E. Scott B. McGuire, P.E. July 12, 1994 Mr. Jack McLean, President Moorings P.O.A. 139 Anchor Drive Vero Beach, FL 32963 Publix Study Dear Mr. McLean, Phone 407-231-2533 FAX 407-231-1398 Enclosed please find graphs and other data related to our study of the shopping center -sites in Indian River County. As you' can see from the enclosures it is apparent that more than two trucks will be occupying the loading areas for a substantial portion of time. Given the Sea Mist Shoppes site geometry as submitted it is obvious that the loading and unloading will interfere with the circulation of the passenger vehicles behind the supermarket. This condition'willbe in violation of Indian Rivera County Code Section 952/21. In addition to the above referenced information I have also supplied calculations related to the approximate area of maneuvering pavement for similar supermarkets in Indian River County. We have found that- the proposed area at the Sea Mist Shoppes is less than one-half of the County average and in my engineering judgement is inadequate. call. If you have any questions please do not hesitate -to give me a - - Sincerely, Scott B. McGuire, P.E. Rol_ dCd/Rft7dabk 89 July 12, 1994 With permission from Chairman Tippin, Attorney Ralph Evans questioned Mr. McGuire about the studies conducted by McGuire & Associates, specifically the data regarding loading zones. Mr. McGuire advised that the number of loading zones at the different stores definitely varied; some met the requirements, some did not. He noted that two loading zones would be required of a typical Publix in this county. Most of the stores have a loading zone on either corner of the store rather than having both in one spot. Lengthy debate ensued regarding loading zone requirements and whether anyone could regulate the number of trucks that come in at any given time. In response to Commissioner Bird's questions, Mr. MacLean explained that the problem is with 6 or 8 trucks sitting in the back of the store without hindering a free flow of vehicular traffic. Mr. MacLean referred again to Attorney Vitunac's memo of 7/6/94 on Standard of Review for Site Plan Approval. Item #2 states, "However, if they do become an issue, the burden of proof is on the applicant to present competent, substantial evidence showing compliance with each objectively determinable standards requirement." Mr. MacLean felt that Attorney Vitunac has made it crystal clear that they (Halvorsen) have the burden of proof on the site plan issues, and he didn't think they have come close enough. Attorney Warren Dill stated he is representing Gene Winne, William Lampert, Robert Salmon, John Zilg, and George Millington. He advised that because of the time factor he would like to ask Peter Armfield to come forward at this time to give his professional opinion as to the possible devaluation of property surrounding the proposed shopping center. Peter Armfield, president of Armfield-Wagner, real estate appraisers, found that there are no exact replications_ of this type of development where a luxury residential community is located this closely to a shopping center which includes a supermarket. After looking at other shopping centers and other Publix stores and studying lot sales on the beach, they noticed there is a detrimental effect on lot sales when they are located next to incompatible uses such as condominiums or commercial zoning. Traffic influences are generally thought to be negative and decrease the quality of life in such a location. The lot sales that they investigated indicated as much as 30 to 40 percent decrease in value from interior lots that did not have those kinds .9 July 12, 1994 BOOK 92 FACE 864 BOOK 92 PnE 865 of influences. Based on their research, it is his opinion that the properties closest to the proposed shopping center probably would have a decline in value in the range of 10 to 15 percent. He was unable to form a conclusion on other property located within the Moorings. Attorney Ralph Evans interjected a question as to whether Mr. Armfield felt that those same properties might be affected in a positive way, but Mr. Armfield explained that his conclusion was that it would be uncertain; he didn't think he had sufficient reasoning to support either a negative or a positive influence. In response to a question asked by Ron Ferrin, one of the owners of the subject property, Mr. Armfield gave the same answer that he had given to Commissioner Bird earlier. They found no measurable significant difference in the prices of the lots abutting the proposed shopping center property whether they were purchased years ago or more recently. Attorney Warren Dill wished to address several procedural items. He requested that the record for this afternoon's meeting contain the following items: 1) All documents that were admitted into the record of the Planning & Zoning Commission Meeting of June 28, 1994. 2) Staff's report and attachments for today's meeting. 3) Minutes of the P & Z meetings of 5/12 and 6/28/94. 4) Letters received by the Board from various residents. TO: Board of County Commissioners FROM: Alice E. White, Executive Aide DATE: July 11, 1994 SUBJECT: Correspondence on the Proposed Publix Store at the Moorings Development Due to the restrictions placed on receiving correspondence with respect to cases coming before the County Commission when seated as a quasi-judicial board, we have held the correspondence sent to County Commissioners regarding the proposed Publix store at the Moorings development in our office. Mr. George Shaw and Mr. Walter Bush brought in three stacks of letters and they claim that these total 1200 against the proposed Publix store. Through our office mail, we have received' a total of 64 letters against the store. I do not have the staff or the time to check and see if there are any duplications 'in this correspondence. 91 July 12, 1994 The letters in opposition list the following reasons for opposition: traffic concerns aesthetic character of neighborhood lowering of property values noise and bright lighting night deliveries and late hours need for additional police protection violation of County Code regarding compatibility with the built and natural environment litter air pollution no need for supermarket river pollution varmints supermarket not same as convenience retail store. We have also received 4 letters and 1 phone call in favor of the Publix store listing the following reasons for support: property rights of land owner will add to residents property values decrease of traffic on US#1 lack of grocery store on barrier island fulfills a need. The correspondence is available for review at the appeal hearing, as well as petitions and correspondence presented at the Planning and Zoning Commission meeting on May 12, 1994. Chairman Tippin acknowledged the submission of the above documents listed by Attorney Dill. NOTE FROM BARBARA BONNAH, DEPUTY CLERK, CLERK TO THE BOARD: All of the above listed items plus any and all exhibits presented during this meeting that haven't been inserted into these Minutes will be placed on file in the Office of the Board of County Commissioners for 3 years. (Please see index at the back of these Minutes.) Attorney Dill commented extensively from the following memo dated 7/5/94, noting that he understood today's backup did not include a copy of the memo he wrote to Attorney Vitunac: 92 BOOK 92 pnF 866 - July 12, 1994 Fr- -1 BOOK 92 PACES67 MEMORANDUM ON THE STANDARDS FOR SITE PLAN REVIEW DATE: July 5, 1994 TO: Charles P. Vitunac County Attorney FROM: Warren W. Dill, Esq. RE: Standards and Requirements for the Review of Site Plans This memorandum is in response to your draft memorandum dated June 17, 1994 pertaining to "Standard of Review for Site Plan Approval". This response will focus primarily on the Case Excerpts numbered 1 through 15 in your draft memorandum. As we have previously discussed and I believe you agree, your reference to the term "technical requirements" throughout the memorandum is inaccurate. I realize that the Planning Department repeatedly uses this term (technical requirements) but it is not the scope of review established in the Land Development Regulations (LDRs) nor is it the standard by which the courts have reviewed Site Plan decisions. The correct basis for the review of site plans is found in Chapter 914, LDRs: Chapter 914. Site Plan Review and Approval Procedure Section 914.02. Purpose and intent. The -purpose of this section is to establish uniform requirements and procedures for reviewing applications for site plan approval. It is further the intent of this section to establish procedures and standards to implement the goals and policies of the Indian River County Comprehensive plan, and to ensure compliance with the intent, standards, and procedures of all applicable land development regulations. Section 914.15. Review standards and requirements. (1) Purpose and intent. The purpose of this section is to establish standards for reviewing site plans in order to ensure compliance with applicable county regulations. (2) Applicability. Site plans shall be reviewed pursuant to all applicable zoning district regulations and regulations for specific land uses, as applicable. (7) Use and maintenance of site and zoning standards. (b) All zoning district criteria must be met, including but not limited to: (10) Use(s). (8) Other Critical Site Plan Project Requirements and Review Standards. ...Site plan applications shall comply with all land development regulations ... (2) Zoning, chapter 911; (All zoning requirements must be complied with.) The phrase "technical requirements" does not appear above, its use by staff is misleading and there is no basis in the LDRs for its use and limited connotation.. The term implies mechanical things like "counting the number of parking spaces", "calculating the percent of open space", "checking the number of trees required for buffering", etc. These are certainly Bart of the review procedure but they are not the only factors (standards) to be considered when a site plan 93 July 12, 1994 in reviewed. If only mechanical/mathematical factors were to be considered why would site plans be subject to an independent review by the P & Z Commission and the County Commission. These bodies are not merely a "rubberstamp" for staffs recommendation. The standards and requirements for review of site plans are established by local government as a legislative act, when they are incorporated in the LDRs. The court's review is limited to an examination of the review standards and a determination of whether those standards have been met by the applicant. The burden of proof is on the applicant to show by competent and substantial evidence that all relevant standards in the LDRs have been met. It is not staffs responsibility to carry this burden. The relevant standards in the LDR's require the site plan to meet all applicable zoning district regulations (See 914.15(1),(2) and (8) above). The purpose and intent of the Commercial zoning district and the definition of the Limited Commercial (CL) zoning district are standards in the LDRs that must be met before a site plan can be approved. Section 911.10 Commercial districts. (1) Purpose and intent. These districts are intended to permit the development of commercial property to ... promote the economic well being of the county, .. . and ensure commercial development compatible with existing and proposed development. Section 91.10 General Districts. (2)(e) CL: Limited commercial district. The CL, limited commercial district, is intended to provide areas for the development of restricted commercial activities. The CL district is intended to accommodate the convenience retail and service needs of area residents, while minimizing the impact of such activities on any nearby residential areas. The definition of the CL district is a very specific standard that must be met. It is the heart of the site plan application, without this standard there would be no site plan for the Sea Mist Shoppes. Certainly it is reasonable to expect an applicant to meet this standard. Unfortunately for everyone, the proposed site plan for the Sea Mist Shoppes does not meet this standard and various others (the economic well being of the County is at risk due to a devaluation of surrounding property; the use is not compatible with surrounding properties; the second median cut on Mooring Line Drive is contrary to the LDRs; the procedure to establish the traffic projections and directional flow fails to adequately consider all relevant factors). Having reviewed the above standards and requirements that site plans are expected to meet in Indian River County, I will next list each of the 15 excerpts (quotes) from your memorandum and follow each one with my analysis. CASE EXCERPTS 1. "... the function of a ... commission is reviewing a property owner's proposed site plan for development of the owner's property in accord with the city zoning laws was not legislative in nature, but rather administrative (i.e., quasi-judicial)." (City of Delray Beach) This statement is correct but it could confuse the Commissioners. The fact that site plan review is quasi-judicial, rather than quasi -legislative, mainly affects the way subsequent, judicial review (of the Board's decision) is conducted - the traditional "fairly debatable" standard (for legislative actions) will not be applied by a court reviewing the Board's action on a site plan review. 94 July 12, 1994 92 rnF 868 I BCOK 9 FAIIJE S6 This excerpt supports our position when it states that the Commission is to review the site plan "in accord with the City zoning law'". In our case, the Commission will review it in accord with the LDRs, which includes all zoning requirements, i.e. the limitation of the use to a grocery store and the definition of the CL district, as well as other factors referenced above. 2. "...a city cannot unreasonable withhold approval (of a site plan) once the legislatively adopted legal requirements have been met." (City of Delray Beach). This excerpt notes that the prerequisite for the landowner/developer is meeting "legislatively adopted legal requirements." These would include the zoning classification (use) and definition of the CL district as well as other factors previously noted. According to this excerpt, it is only "once" these requirements have been met that the Board's discretion comes into play. Even then, this excerpt implicitly recognizes that ("quasi-judicial" or not) the Board retains some degree of discretion, saying " a city cannot unreasonably withhold approval of a site plan (emphasis supplied). Removing the double negative, this excerpt says the Board, "once the landowner meets the "legislatively adopted legal requirements" (assuming that can be done; a point we do not concede here), can still reasonably withhold approval of a site plan. 3. "All persons similarly situated should be able to obtain plat approval upon meeting uniform standards. Otherwise the official approval of a plat application would depend upon the whim or caprice of the public body involved." (City of Delray Beach) The above quote talks about "plat approval," and a site plan is not a plat. Plats are simply maps "showing the location and boundaries of individual parcels of land subdivided into lots, with streets, alleys, easements, etc., usually drawn to scale," HENRY CAMPBELL BLACK, BLACK'S LAW DICTIONARY at p. 1036 (5th ed. 1979) (emphasis supplied), while a site plan shows the layout of a particular lot - i.e., building, driveway "cuts", parking, drainage, etc., location. Case law recognizes the distinction between platting and obtaining site plan approval, too. The two cannot be equated, since "even with an accepted subdivision plat, (a landowner can) ... not begin development except in accordance with an approved site plan." City of Gainesville v. Republic Inv. Corp., 480 So. 2d 1344, 1345 (Fla. 1st DCA 1985) (bracketed matter supplied). Additionally, site plan approval is a local matter, determined only according to city or county ordinances, see, id. (citing Gainesville Zoning Code), whereas platting must be accomplished in accordance with statewide statutory requisites, found in Chapter 177, Part I, Florida Statutes (1993). I.submit that in the instant case, Excerpt #3 will be unnecessarily confusing to the Board members, since there is no issue of plat approval before the Board. 4. "The administrative procedure for site plan approval is quasi-judicial in nature, and conducted to factually determine if a proposed site plan submitted by the property owner conforms to the specific requirements set out in the administrative regulations governing the erection of improvements on the property . .. Those conditions should be set out in clearly stated regulations. Compliance with those regulations should be capable of objective determination in an administrative proceeding. While the burden may be on -the property owner to demonstrate compliance, no legislative discretion is involved in resolving the issue of compliance." (City of Delray Beach). This excerpt goes back to the first and second excerpts, which it parallels in some respects. Excerpt #4 is directed to the Board's action after the landowner has shown that "the legislatively adopted legal requirements have been met," as required by Excerpt #2. Thus, this Excerpt #4 is only relevant if the Board determines that a "grocery store" is a "supermarket" and determines that the proposed use meets the definition of the CL district and meets the other, requirements listed above. 95 July 12, 1994 M M M The Key phrase in Excerpt #4 is "legislative discretion." (Emphasis supplied). As noted in the analysis of Excerpt #1, the fact that the Board has no legislative discretion does not mean the Board has no discretion, but rather that it does have judicial discretion. This raises the question of what amount of discretion is properly exercised by the Board in its quasi-judicial capacity. The Delray Beach case was upheld by the supreme court as in line with Board of County Commissioners of Brevard County v. Snyder, 627 So.2d 469 (Fla. 1993), therefore Delray Beach means that the degree of discretion described in Synder (specifically at p. 475 of the opinion) applies to site plan reviews. This discretionary language in Synder basically says that where the landowner's proposal is reasonable under local regulations (i.e., consistent with the local development plan), but "the Board action is also consistent with the plan," then no property right of the landowner is infringed by denying the landowner's proposal. The same degree of discretion is applicable here. So long as the Commissioners action in denying the site plan is consistent with any one relevant provision in the LDRs, no property right of the applicant has been taken. All we are asking the Commissioners to do is to review the site plan for the Sea Mist Shoppes for consistency with all provisions of the LDR's and disallow the proposed configuration (size) and site layout sought by the applicant. In Synder the Board had discretion to limit their approval of a rezoning request to within a specified number of different zoning districts, here, the Board has discretion to limit their approval to a smaller (down sized) site plan and accordingly, to deny the proposed site plan because it is not consistent with the relevant provisions of the LDRs (the size of the use is not consistent with the definition of the CL district, the use devalues surrounding property, the size of the use is not compatible with surrounding properties, the second median cut is not authorized and the traffic analysis failed to address certain key factors). 5. "When the public entity ... conducts site plan ... review, it merely applies established rules of law to existing and uncontested facts." (City of Delray Beach) The point of this excerpt is that the Board should apply "established rules of law," as opposed to "unreasonably" denying approval (Excerpt #2) or deciding based merely "upon the whim or caprice of the public body involved" (Excerpt #3). We agree with this requirement and direct you to the LDRs cited above for the "established rules of law" that the Board is to follow. 6. ". . . the authority of a town to deny the land owner the right to develop his property by refusing to approve the plat of such development is, by statute, made to rest upon the specific standards of a statute or implementing ordinances. Thereafter, the approval or disapproval of the plat on the basis of controlling standards becomes an administrative act." (City of Coral Springs) 7. "It is elementary that once a party complies with all legal requirements for platting there is no discretion in governmental authority to refuse approval of the plat." (City of Coral Springs) These Excerpts are taken together because they are subject to the same analysis I raised in Excerpt #3 above. This is not a "plat approval" issue. By bringing in this case it is a source of needless confusion for the Board. Although I disagree with the appropriateness of this case, I find it interesting that you did not include the Court's decision which was to uphold two out of the three disputed requirements placed on the plat. The Coral Springs court opined: The petitioner's position is that all legal requirements were met inasmuch as the city commission's additional requirements were not properly promulgated standards and therefore were not legal. Respondent city points out the existence of certain standards made applicable by virtue of its home rule powers, in . addition to the landscape standard contained in a city ordinance applicable to condition one. See section 166.02, Florida Statutes (1983). 96 kOX 912-1 T-'Atf.8,70 July 12, 1994 BOOK 92 PAGES l We hold that condition one (requiring an additional 10 foot buffer strip) is validly imposed as a reasonable application of section 20-153 of the Code of Ordinances " of the City of Coral Springs. Condition two (requiring entrances and exits to be labeled "Right Turn Out Only" is similarly valid based upon the legal requirement that an applicant demonstrate that there will be safe and adequate access in the area sought to be platted. Broward County v Coral Ridge Properties, Inc., 408 So -2d 625 (Fla. 4th DCA 1981). The circuit court held the third condition (no construction allowed until the adjacent road was widened) invalid on the basis that the Court simply finds that to include such a condition on the plat without any indication in the record as to when or if said portion of the roadway will be four-laned could preclude the landowner from any reasonable use of owner's property indefinitely. City of Coral Springs accordingly was directed to delete condition No. 3 or provide further hearing on said issue. Condition No. 3 was in the nature of a building moratorium directed to a specific parcel of land and without meeting any of the formal requirements for such a moratorium. As such it was appropriately stricken. This case supports two of our major contentions: 1) the standards and requirements found in the LDRs for site plan review encompass more of the regulations than just "technical" requirements and 2) conditions may be imposed on a site plan approval that do more than simply implement some "technical' requirement or formalize the applicant's gratuitous agreement to do something beyond that specifically stated in the LDRs. Reasonable conditions may be placed in any site plan (that first meets all the standards and requirements contained in the LDRs) approval that can be backed up from some provisions found in the LDRs. This is especially important to us because once the developer has a site plan that can be approved, we have a list of operating conditions that we would like the Commissioners to consider. 8. "Section 14 of the Broward County Plat Act ... provides that such approval may be subject to such conditions as the governing body of the ... county commissioners ... may deem to be in the best interest of the public.' Without pursuing the validity of that provision ... we hold that ..., having met all of the legal requirements for obtaining plat approval, the county must approve [the] plat ..." (Broward County case) Again, this excerpt deals with plat approval. In addition to the previously noted distinctions (Excerpt #3) between plat approval and site plan approval, I would point out that to my knowledge, the LDRs do not include a vague "catch-all" provision based only on "the best interest of the public," which is what was decried in this excerpt. 9. "Opposition of surrounding property owners must be considered by the city ... since the statement of intent of the ... ordinance includes the desire to achieve aesthetic and compatible relationships between adjacent properties. Buf the opinions of neighbors by themselves are insufficient to support a denial of a proposed development. We agree with the city that project density is a legitimate concern ... But it is a concern that must be addressed and expressed in appropriate ordinances." (City of Deland) The gist of this excerpt is that "aesthetic and compatible relationships between adjacent properties" is RrojReLly considered in site plan review, but that "opinions of ... neighbors" alone are insufficient for a denial based on such concerns. We have shown and will show again, 1) through our professional land use planner and expert witness Robert W. Swarthout, AICP that the proposed site plan is incompatible with neighboring parcels and 2) through our appraiser Peter Armfield, MAI that this site plan will result in the devaluation of surrounding properties. Under the Deland case, the Board would be justified in denying the Sea Mist Shoppes site plan; however, under Synder and Delray Beach, the Board would probably have to tell the applicant What changes he would have to make in order for the site plan to be approved. 97 July 12, 1994 II 10. 'Me correct law applicable in this case is that the ordinance should be given its plain meaning and that any doubts should be construed in favor of a property owner. The circuit court's reliance upon the undefined and uncertain standards contained in the statement of intent when clear and specific numbers of units are expressed in that same ordinance is not an interpretation that recognizes the plain meaning of the ordinance." (City of Deerfield Beach) This excerpt is misleading and out of context. The quote says simply that if a specific numeric density is stated in the ordinance, an undefined term ("low-density") elsewhere in the ordinance cannot be used to deny a site plan due to its density. This is not an issue in the instant case. This excerpt was cited in the Deland case referenced above and was distinguished by the Life Concepts case cited in Deland. The standards and requirements for site plan review are clearly written in the LDR and those are the standards that the proposed site plan must meet. The above excerpt is from a 1982 case. Since then local governments, such as Indian River County have spent a great deal of time and money formulating their LDRs to be as clearly written as possible. 11. 'The site plan merely regulates the layout of a piece of property, the design of the buildings, and the actual locations of the buildings on that site. The city's zoning ordinance controls the uses to which a particular piece of property may be put. The plan board, therefore, is not to be concerned with the particular use of a piece of property as long as it fits within the permitted uses of the city's zoning ordinances." (City of Gainesville) 12. 'The plan board members voted to deny the petition because of the parcel's intended use ... not because it failed to comply with appropriate criteria for site plan approval." (City of Gainesville) [This was found to be illegal.] The quotes in Excerpts #11 and 12 above pertain to a situation where the city enacted a building moratorium while the site plan approval was underway. As I previously noted in the discussion of Excerpts #6 and #7, if no outright 'building moratorium" is imposed on this site, I fail to see the relevance of these case excerpts to the instant case. My clients have never advocated the position that no development should be permitted on this site. All we have ever requested is that the applicant be required to comply with the LDRs and limit the size of the commercial use to what is allowed in the CL districts to provide "restricted commercial activities" to serve the needs of "area residents". 13: 'The test in reviewing a challenge to a zoning action on grounds that a proposed project is inconsistent with the comprehensive land use plan is whether the zoning authority's determination that a proposed development conforms to each element and the objectives of the land use plan is supported by competent and substantial evidence. The traditional and non -deferential standard of strict judicial scrutiny applies. (Machado case) 14. "A development order or land development regulation shall be consistent with the comprehensive plan if the land uses, densities or intensities, and other aspects of development permitted by such order or regulation are compatible with and further the objectives, policies, land uses and densities or intensities in the comprehensive plan, and if it meets all other criteria enumerated by the local government." (Machado case) I generally have no problem with the above excerpts, we have and will continue to present competent and substantial evidence through expert witnesses and documents to support our position that the proposed Sea Mist Shoppes site plan does not meet all applicable standards and requirements of the LDRs. The last sentence of Excerpt #13 goes to judicial review of whatever decision the Board makes, rather than what the Board may do. It probably should be eliminated, so not to add more confusion to the issue. 98 bo 92 wOU- July 12, 1994 BOOK 92 FACE 873 15. "Zoning laws are in derogation of the common law and as a general rule are subject to strict construction in favor of the right of a property owner to the unrestricted use of his property. Permitted uses must be interpreted broadly, prohibited uses strictly so that doubts are resolved in a property owner's favor." (City of South Miami) This excerpt is a statement of the general law and should come as no surprise to anyone. No one has ever suggested that the applicant does not have the right to use their property. See my comment under Excerpt #12. The relevancy of this excerpt to site plan review standards is questionable, since this excerpt deals with the overall concept of zoning. If there were any ambiguities in the LDRs suggesting that the land could not be used, then this excerpt would be useful; however, that is not the case. There _gre volummes of quotes that can be pulled from cases dealing with property rights; however, each one comes with a specific set of facts and circumstances that are used as the basis for local governments decisions and for judicial review. The more reasoned court decisions hold that every land owner has the right to a reasonable use of his land, not necessarily the highest and best use. If you are aware of any facts that would suggest the property owner will be denied a reasonable use of the land if the site plan is required to meet the applicable LDR requirements, then I would like to know what they are. This concludes my review of your June 17, 1994 Memorandum to the County Commissioners. In accordance with the previously agreed procedures by all parties, I request that you forward a copy of this response to the County Commissioners simultaneously with your Memorandum. If for some reason you elect not to forward your memorandum to the County Commissioners prior to the July 12, 1994 meeting, I would like you to forward this response to them anyway, so that they will have an opportunity to review it prior to the July 12th meeting. Attorney Dill introduced Robert Salmon, 1155 Reef Road, president of Windward, a condominium of 65 homeowners living across the road from the proposed supermarket. Mr. Salmon presented a black, 3 -ring binder (Exhibit 9) containing one page of printed material plus an aerial view of the site for the proposed project, a plat map of the Moorings, 26 color photographs showing the entrances into the Moorings, various residences in the Moorings, single-family homes on Bowline Drive which will face the loading area for the supermarket, condominium buildings, marinas, and material describing the Moorings Harbor Square Development Plan which was approved by the IRC Planning & Zoning Commission in 1989 but never built. Color photographs in the back of the folder showed the loading areas and rear access area of the Publix at Miracle Mile. Mr. Salmon commented on Section 911.10 of Ordinance 90-16: M July 12, 1994 � � r INDIAN RIVER COUNTY ZONING ORDINANCE #90-16 OF 9/11/90 COMMERCIAL DISTRICTS #911:10 PURPOSE & INTENT: The commercial districts are established to implement. the Indian River County Comprehensive Plan policies for commercial development. These districts are intended to permit the development of commercial property, to provide a efficient use of land and public intrastructure, promote the economic well being of the county, protect the natural resources and beauty of the county, and ensure commercial development compatible with existing and proposed development. In order to achieve this purpose, these districts shall regulate the size, scope, and location of commercial uses and provide standards to ensure development compatible with the built and natural environment. The "CL" district is intended to provide areas for the development of restricted commercial activities, and intended to accommodate the convenience retail and service needs of area residents, while minimizing the impact on any nearby residential areas. The word "minimizing" is crucial to the judicial intent of the County Zoning Ordinance. The American College Dictionary, 1966 edition clarifies the meaning. "Minimizing (verb) to reduce to the smallest possible amount or -degree. To represent at the lowest possible estimate." A negative loss of.119.3% does not agree with minimizing the impact on any nearby residential areas. We hope that County officials, after reviewing all the evidence, will reject for the third time the developer's plan for a supermarket in The Moorings. Mr. Salmon concluded his presentation by urging the Board to deny the Halvorsen appeal. Attorney Warren Dill reviewed the following material titled Authority to Deny Site Plan Approval dated 7/12/94: 100 a00K 94W F'A E 874, July 12, 1994 L_ ma 92 iv -qn 8 6 July 12, 1994 - AUTHORITY TO DENY SITE PLAN APPROVAL Chapter 914. Site Plan Review and Approval Procedure Section 914.02. Purpose and intent. The purpose of this section is to establish uniform requirements and procedures for reviewing applications for site plan approval. It is further the intent of this section to establish procedures and standards to implement the goals and policies of the Indian River County Comprehensive plan, and to ensure compliance with the intent, standards, and procedures of all applicable land development regulations. — Section 914.06... Procedures for Site Plan Review. (6) Planning and zoning commission decision. The planning and zoning commission (Board of County Commissioners) shall consider each site plan ... and shall base its decision on the use, size and dimension regulations for the respective zoning district, the site review standards *established herein and all other applicable land development regulations, and comprehensive plan policies. The planning and zoning commission (Board of County Commissioners) may impose conditions on-site plan approval which ensure compliance with all applicable land development regulations and comprehensive plan policies. Section 914.15. Review standards and requirements. (1) Purpose and intent. The purpose of this section is to establish standards for reviewing site plans in order to ensure compliance with applicable county regulations. (2) Applicability. Site plans shall be reviewed pursuant to all applicable zoning district regulations and regulations for specific land uses, as applicable. (7) Use and maintenance of site and zoning standards. (b) All zoning district criteria must be met, including but not limited to: (10) Use(s). (8) Other Critical Site Plan Project Requirements and Review Standards. ...Site plan applications shall comply with all land development regulations ... (2) Zoning, chapter 911; STANDARDS NOT MET The purpose of all zoning in the county is found in Section 911.01(2) Purpose and intent: (2) Purpose and intent ... to secure safety from fire, panic and other dangers; ... to conserve the value of buildings ... REASONS TO DENY SITE PLAN The letter from Sheriff Wheeler concerning the proposed development states in part that ... "It is reasonable to believe from past experience that there will be an increase in vehicle accidents, shoplifting, car burglaries and other types of crimes associated with retail and commercial businesses." The appraisal from Armfield-Wagner states in part that ... "it is our conclusion that the values of the properties located in closest proximity to the proposed shopping center will experience a reduction of value in the range of approximately 10% to 15%." July 12, 1994 101 M M STANDARDS NOT MET Section 911.10 Commercial districts. (1) Purpose and intent. These districts are intended to permit the development of commercial property to ... promote the economic well being of the county, ... and ensure commercial development compatible with existing and proposed development. REASONS TO DENY SITE PLAN This development will cause the devaluing of property and the design of the sight plan is not compatible with adjacent existing properties. STANDARDS NOT MET Section 911.10 General Districts. (2)(e) CL: Limited commercial district. The CL, limited commercial district, is intended to provide areas for the development of restricted commercial activities. The CL district is intended to accommodate the convenience retail and service needs of area residents, while minimizing the impact of such activities on any nearby residential areas. REASONS TO DENY SITE PLAN The site plans flagrantly violate this standard. A 47,000 sq. foot Shopping Center, with a 28,000 sq. foot Publix Super Market is far greater than what is needed to accumulate the convenience retail and serve the needs of area residents. STANDARDS NOT MET Section 952.12 Median Openings (9) Median Openings. To assure traffic safety, capacity and control, median openings located within a traffic -way corridor shall be spaced the maximum distance apart that will allow safe and adequate traffic circulation... (b) 'No median openings shall be spaced at a distance less than 660. feet from any signalized intersection or median opening, except the median openings may be spaced at a lesser distance based upon a traffic study and impact analysis; but in no case shall median openings be spaced at less than 330 feet ..." REASONS TO DENY SITE PLAN The site plan violates this section because the second (westerly) median opening is less than 330 feet from the first median opening on Mooring Line Drive. _ STANDARDS NOT MET Section 954.09 Off-street Loading Regulations These requirements shall apply to all commercial and industrial uses. (1) A minimum number of loading spaces or berths shall be provided and maintained as follows: Building(s) Size in but not Sq. Ft. Over over No. of Spaces/Berths 25,000 59,999 Industrial and Commercial:2 102 , �► July 12, 1994 roK D2 -mu T (2) Loading spaces or berths shall have minimum dimensions of fourteen (14) feet by thirty (30) feet, _ plus each space or berth shall have an additional two hundred fifty (250) square feet of loading or maneuvering area immediately contiguous to the space or berth. REASONS TO DENY SITE PLAN There is a question as to the appropriateness of the Publix Supermarket loading space and the retail loading space next to Publix. Inadequate loading facilities will interfere with the free flow of traffic and cause undue congestion in the area in violation of Section 952.13 LDRs. STANDARDS NOT MET Section 952.12(8) Types of Driveways. (8) Types of driveways. Each driveway shall be classified as one of the following types and regulated accordingly: (3) Major driveways. A major driveway shall provide for a maximum average daily trip volume of two thousand (2,000) to five thousand (5,000) vehicles. The minimum distance from the street right-of-way line at any ingress or egress driveway to any interior service drive or parking space with direct access to such driveway shall be one hundred (100) feet measured on. a line perpendicular to the street right-of-way... REASONS TO DENY SITE PLAN The entrance on Windward Way is at 1997 daily trips. The traffic report by the developer does not adequately address the number of vehicles coming from the South of the project all the way from the Ft. Pierce Inlet area. Additional information should be requested by the Staff or voluntarily provided by the Developer to accurately determine the traffic count coming from the South and entering the Shopping Center from Windward Way to determine whether there should be a distance of 100 feet before any internal turn off of the Windward Way entrance road. (This requirement is what triggered the return of the site plan to the P & Z Commission and caused the need for the second median cut and entrance into the Shopping Center off of Mooring Line Drive.) STANDARDS NOT MET Section 914.06... Procedures for Site Plan Review. (6) Planning and zoning commission decision. The planning and zoning commission (Board of County Commissioners) shall consider each site plan ... and shall base its decision on the use, size and dimension regulations for the respective zoning district, the site review standards established herein and all other applicable land development regulations, and comprehensive plan policies. Comprehensive Plan - Future Land Use Element IncomQatible Uses and Blighted Areas (page 58) Incompatible uses include those which are out of character or scale with surrounding areas as well as those which negatively impact surrounding areas with noise, smoke, glare, traffic, etc. Several uses are by their nature incompatible with residential areas; these include airports, landfills and many industrial and commercial operations. These uses have the potential to lower property values and reduce the development potential of surrounding property. These problems can be reduced through effective land use patterns that provide for separation and incorporate the use of buffers. 103 July 12, 1994 � ® s REASONS TO DENY SITE PLAN The proposed site plan is out of character and scale with the surrounding residential land uses and it will result in a reduction of property values because of the noise, smell, traffic, intensity of use and lighting generated by the shopping center. The site is to small and the use is to intense to provide adequate buffering for the neighboring homes. IF ANY ONE (1) OF THE REVIEW STANDARDS ABOVE IS NOT MET, THEN YOU HAVE THE AUTHORITY IN THE LDRs TO DENY THE SITE PLAN. Attorney Dill introduced Robert Swarthout, professional city planner, who was sworn in by County Attorney Vitunac. Mr. Swarthout requested that the extensive testimony he made this morning about compatibility be made a part of the record for this evening. Mr. Swarthout briefly addressed the same issues Attorney Dill had reviewed: 1) Definitional statement of the CL district. 2) Purposes and intent statements. 3) Two main driveways are needed based on the traffic analysis. 4) A supermarket is not a compatible use. 5) Heavy traffic generated by a supermarket. 6) The supermarket will serve a broader area than just the South Beach area south to the St. Lucie County line. Mr. Swarthout concluded by emphasizing that there is no question in his mind that a supermarket in this location is not a compatible use, no matter how many buffers, no matter how deep the buffer strips, or how tall the fence. Attorney Dill next introduced Gene Winne, resident of the Moorings, who intended to briefly review some of the issues he addressed in the supermarket vs. grocery store discussion this morning. He referred to the letter he wrote containing the petition signed by over 900 people from the South Beach area who were firmly against a supermarket being built on this site. He pointed out that the subject property, lot 57, was zoned the equivalent of Commercial Limited in late 1968, and many of the 104 July 12, 1994 BOOK R P, fu 878 I Boos 9 2 PAIGE 8 19 residents purchased their property based on Moorings Realty's representation that the site would be developed similarly to the Village Shops. Mr. Winne pointed out that at least one sitting Commissioner back in 1968 recalls clearly that the zoning plan contemplated small, attractive specialty shops to service the immediate area, not a supermarket. He also questioned the need for a supermarket in this location. There are 11 existing supermarkets in Indian River County that are all located on General Commercial sites in large shopping centers and all are on major highways. No other supermarkets are on limited commercial parcels. There are about 37 CL zoned sites in Indian River County, of which the average size is 15 acres. This one is 5.3 acres. Most of the other sites are undeveloped, none are intensively developed, most have no existing abutting residential, and none have high intensity residential on more than one side. There are many reasons why this site doesn't meet the standards of compatibility, some of which are aesthetics, noise, intensified lighting, traffic, odors, rodents, and garbage locations being less than 200 feet from the front doors of homes on Bowline Drive. With regard to the matter of crime, Mr. Winne read aloud a letter received from Sheriff Gary Wheeler dated 5/12/94: 04jeriff 97FI6E GARY C. WHEELER • INDIAN RIVER COUNTY MEMBER FLORIDA SHERIFFS ASSOCIATION MEMBER OF NATIONAL SHERIFFS ASSOCIATION 4055 41st AVENUE VERO BEAOH, FLORIDA 32880-1808 PHONE 407.588.8700 May 12, 1994 Mr. Gene Winne 2096 Winward Way Vero Beach, FL 32963 Dear Mr. Winne: In response to your request, I am expressing the concerns of the Sheriffs Office regarding the proposed retail space at AIA and Mooringline Drive. 105 July 12, 1994 Since January of 1993, I have assigned a deputy on a 24-hour, 7 -day a week basis to the south beach area. I have found the assignment necessary to protect the residents and homes of the south beach area The deputy stays busy answering calls for service, enforcing traffic laws and crime preventative patrols. The proposed retail space may have an adverse effect and cause increased demands for the deputy's time. It is reasonable to believe from past experience that there will be an increase in vehicle accidents, shoplifting, car burglaries and other types of crimes associated with retail and commercial businesses. It is hely that the additional demand will increase response time by the deputy to calls for service from area residents. Sincerely, Gary C. Wheeler, Sheriff Mr. Winne felt the only reasonable outcome from this chaos is the residents' continuing efforts to buy the subject property at a value that is fair to all of the involved parties. Attorney Warren Dill announced the conclusion of their presentation. Chairman Tippin asked if anyone wished to speak in this matter. Tom Buchanan, 1150 Reef Road, opposed a shopping center containing a supermarket. He noted that when he moved to the Moorings back in 1977, he understood that a small shopping center of exclusive shops would be built on this site. He believed that the residents were grandfathered to what the original developer told them. Ann Clark Hickman, 2185 Via Fuentes, expressed concerns about adequate access for emergency vehicles entering the Moorings. She urged the Board to consider how very special the Moorings area is and determine that a Publix is wrong for this area. She wanted the Moorings kept special. 106 July 12, 1994 ROOK FELE 880 �� �� � dUUK ��yAC[��/���� Richard Burkhart, resident of the Moorings, objected to having a supermarket built on the proposed site. Be requested that the following letter dated 5/28/94 be made part of the record: Richard H. Burkhart 1936 Mooring Line Drive Vero Beach, FL' 32953 May 28^ 1994' Mr Richard N. Bird Board Of County Commissioners 1840 25th. Street Vero Beach, FL. 32953 Dear Dick:" At this time of year you are used to hearing from me in regard to budget decisions/ however I will leave that for later and talk to you about the Publix Project proposed for the Moorings. I have lived' voted, and paid taxes in Vero Beach for the past thirteen years. I also was elected`to six two year terms on a Planing and Zoning Commission in Connecticut, in a town I lived in for fifty four years. Spot -zoning and excessive development, was�urned down by that board sixteen times during that twelve year period' with fourteen cases ending up in the courts, all decided in favor of the commission. I mention the above facts only to lend some credibility to my experience and insight with regard to the above proposed project. In 1981 and agai-n in 1989 a site plan approval was given to a "phased project" in a limited comercial zone, which is now the property involved in the proposed application involving a 27,000 square foot PubIix super market. As you will note in attachment #2 the interpretation of the approved site plan in 1989 for the entire Moorings community was for a low density, low profile, shoppping village primarily intended to serve The Moorings' low density residental community as well as the adjoining limited-commericial zoned Moorings Harbor Inn. In keeping with the two unit/acre residental zoning in 1983 I was shown a site plan which was truly limited -commercial in that the anchor specialty food market was either 5800 or 7800 square feet with several other adjoined small spaces for retail service business. Clearl'y, they were, as indicated in attachment #2' part and parcel of the total "grandfathered" approved site plan of the Moorings to be spaces for retail and service business primarily serving the fully developed project. When the limited -commercial site for the Moorings Harbor Inn was zoned, and approved' specific plans, square foot indications of the three condominuim buildings, the sales offices adjoining, as well as the yacht basin and dock master's residence were required for approval. In my view, it is reasonable to assume that specifics were required at that time, either (1981-1983-1989) for the Moorings ShoppinQ Village. In all my experience a development plan for an area as large as theMoorings, would never be approved on a piece meal basis. The entire project had to be submitted in detail so the fully developmed project could be considered for approval. This is the cornerstone of sound planning, followed by every planning and zoning ~ 107 July 12 1994 commission I ever heard of. If sound planning was followed in approving the Moorings Harbor Inn and adjecent buildings, it. also is my view, that when shown in 1983, a site plan showing a 6800 +_+r\ 73 0 ► square foot building representing the largest entity in the village, that I was looking at the "specialty food market" which has now illegally grown to 27,000 Flus or minus square feet. There are many, many emotional and subjective reasons as to why this project is not desired. There are in my view many, many objective reasons why this is not good planning in the long run. The whole s=outh Beach will be adversly affected. Property values will suffer and thus tax revenue loss will follow. Everyone knows that a supermarket of this size increases the posibility of employee accidents, motor vehicle accidents, bike path and pedestrian accidents, all have a realistic chance of increasing over the present situation, and, will ta::•:: the present 911 facilities which are nearby. The people of South Beach made substantial contributions to have those 911 facilities located nearby. Eighty-five percent of the people in the Moorings do n+_+t want a 27,000 square foot ++Wit. supermark:e't• in their area. To support some of the above alligations, it might be of interest to quote Mr Stan Boling Chief Administrator, Planning and Development. Commission in a letter of August 14, 1989. Quote "Finally, you might be interested to know that a 1983 planning staff report indicated that at "plan -approved" build -out,' the entire Moorings project (including golf course and open spaces) would be developed at a gross density of units/acre". Ifi my view this indicates a low denisity approach which is the way Florida should be developed, and a 27,000 square foot super market. -in a residental neighborhood does not fit that. point of view. A copy of the above mentioned letter was sent, to Robert. M. Keating, Dorothy Hudson,. Moorings Development, and Ruth Jefferson. I urge you to not allow this project to go forward as projected. Very truly yours Richard H. Burkhart Mr. Burkhart concluded by saying that there are many, many emotional and subjective reasons why this project is not desired. There are also many objective reasons why this is not good planning in the long run. He urged the Board not to allow this project to go forward as projected. Lomax Gwathmey, 23 Sea Horse Lane, stated that as the director of the Civic Association of Vero Beach in Indian River County, he would like to read aloud the following letter from the Association to the Board of County Commissioners: ioa BOOK � P.1rE �� July 12, 1994 BOOK 92 FnE 883 THE CIVIC ASSOCIATION P.O. Box 3381 7THE of Vero Beach, FL CIVIC ASSN. Vero Beach and Indian River County 32964-3381 "Since 1968, preserving, fostering and promoting the beauty, natural resources and good government of Vero Beach and Indian River County." July 12, 1994 The Board of County Commissioners of Indian River County 1840 25th Street Vero Beach, Florida 32960 Subject: Moorings Site Plan Appeal by Halvorsen Development Co. Ladies and Gentlemen: The Board of Directors of the Civic Association of Vero Beach and Indian River County, in keeping with its purposes and objectives, "...to preserve, foster, and promote good government, the natural resources and the beauty of Vero Beach and Indian River County," strongly recommends disapproval of the subject appeal for the following reasons: 1. Zoning of subject property to commercial restricted was granted in December 1968 as a part of the larger rezoning request by the Moorings Development Company. Those living here at the time noticed this with raised eye- brows, but it was emphatically described as "low-key," for the purpose of providing a modicum of convenience to the residents of the Moorings. 2. Proof of this concept. was well expressed by Mr. H. Milton Link, President of the Moorings Development Company when testifying before the Board of County Commissioners on August 19, 1970, to obtain a new waterfront zoning classification to permit waterfront multi -family residences. Excerpts from an article in the Press - Journal dated August 27, 1970 (Enclosure #1) reads as follows: "The contemplated shopping facilities include a gasoline filing station.:to handle both automobile and boat 'traffic, a grocery store, drug and sundry store, restaurant, barber shop and beauty shop, and a few office spaces. "The restaurant will be the key facility. We want the best possible, since it must be good enough,, to attract people from Vero Beach, Ft. Pierde and all areas of both counties," said Link. } "Ihe rest of the since the purpose is to conveniently buy a You might call it a added." July 12, 1994 stores will be relatively small, just as its name implies --a place few necessary items close to home. neighborhood store concept," Link 109 3. This concept --a small enclave of village -type shops and small grocery store --remained firm over the years, although its construction did not take place. The concept was re -iterated in the planning staff's recommendations to the Board of Commissioners at its meeting November 20, 1985 to consider, among other things, the establishment of the boundaries for the ten (10) acre commercial node located in the Moorings on A- 1 -A between Mooring Line Drive and Spyglass Lane which was a part of establishing the Master Land Use Plan (Enclosure #2). "Existing Land Use Pattern The area surrounding the node area is predominantly residential. There are single-family residences and condominiums located to the east, north, and west of the node's general location. Vacant land is located to the south of the node. Within the node's proposed boundary, there is a sales office for The Moorings Development Corporation location on the corner of Windward Way and A -1-A on Lot 56. There is a Savings and Loan institution currently being constructed on the corner of Windward Way and A -1-A on Lot 57. The Savings and Loan is the first phase of 'The Trellises" commercial center being developed by The Moorings Development Corporation. The proposed site plan includes a small grocery and drug store, specialty retail shops, and offices. This commercial center should adequately serve the residents in the south beach area." Note again the concept "small grocery store," persisting 17 years after the original zoning was granted. 4. And now after 25 years a developer comes along and wants to place a large supermarket on the site, claiming it to be allowable under the zoning designation. 5. We believe a law suit is not required to determine that a supermarket and grocery store are not the same. Common horse sense tells us they definitely are not the same. if you asked 100 people at random, probably 98 would say they were not the same. s6. We believe in property rights. In this case, we believe the people of the Moorings have more property rights, particularly those adjacent to the area in. question, than does a developer who doesn't even own the land. If under the prevailing circumstances he has some semblance of "vested interest," it certainly is small compared to the investment and property rights of the adjacent residential properties. 110 July 12, 1994 Boob 92 PACE 88 I Botox 92 PALE 885 7. We believe to rule in favor of an individual, whose primary motive is profit, and against a great many individuals who have been lead to believe in the original concept for the development of this land, would be a miscarriage of justice. With all the other attendant degradations to the area --noise, sight pollution, security, traffic impact from both north and south on A -1-A already over capacity, drainage and environmental Problems, we strongly recommend you not approve this site plan. For a Bo _ of Directors, Robert M. Tenbus, President Wayne Varley, 875 Reef Road, explained that he represents the South Beach Property Association for 22 subdivisions in the South Beach area which contain approximately 2200 households. He emphasized that the Association represents more than 1000 registered voters who own properties that represent 18 percent of the ad valorem taxes collected for Indian River county. Based on the affirmation of the majority of its members, the Association opposes the development of any lands that will jeopardize the quality of life presently enjoyed within the South Beach boundaries. The present plan for a 27,000 sq. ft. supermarket is detrimental to that quality of life. Specifically, they object to the devaluation of real estate property, the overall increase of traffic on AlA, and the odors, noises, and other problems associated with the supermarket. Walter Bush, 1935 Mooringline Drive, wished to read into the record a letter from Peter B. Benedict, headmaster at St. Edwards School who had to leave early: "St. Edwards School is concerned for the safety of our students, parents, and visitors when they exit and enter our upper school campus. We believe that any commercial development at the Moorings would add significantly to the A1A traffic and thus aggravate what is already a dangerous traffic situation." George Torrency, resident of Vero Beach, advised that he is a retired university professor of law and government. He emphasized that there is no evidence at all to indicate that the owner or the developer of the subject property will suffer any pecuniary loss if 111 July 12, 1994 � s � this proposed supermarket is turned down. He felt that the residents are just as concerned about the taking of property rights since they are the ones who are losing property value. He also wished to point out that both the north and south entrances are not adequate with regard to physical conditions, the number of automobiles, or the public's safety. Ron Lisak, local attorney residing at 1526 Smugglers Cove, felt the proposed development does provide a public convenience and necessity since the closest shopping area to the South Beach area is on the mainland across the 17th Street Bridge. He personally believed that most of the property values on the barrier island and certainly in the South Beach area will probably increase as a result of the proposed development. He further believed that all the residents in this area will benefit greatly from the availability of these goods and services. Mr. Lisak concluded by saying that the only thing that is irrelevant here is: A) Has the property owner complied with the Comprehensive Land Use Plan and the Land Development Regulations; and B) Is there any rationale based upon substantial evidence submitted into the record today to deny site plan approval. Dr. Arthur Rappaport, 1860 Cutlass Cove Drive, stated his objections to the medical pathologies that occur when the body's senses are assaulted by environmental trauma, such as odors, unsightly garbage disposal, and rodents running around. He urged the Board to deny the site plan appeal. Attorney Ralph Evans wished to make a few closing statements in rebuttal to the arguments presented by Attorney Warren Dill and others here this evening regarding economic impact. Chairman Tippin didn't think that is necessary, because he didn't think that economics has a bearing. It is not a part of government business to consider economics in making this decision. Attorney Evans understood that he could rest assured that the evidence presented relative to the economic impact is not substantial competent evidence in the Board's decision, and Chairman Tippin replied, "I think you may." Attorney Evans asked Keith Pelan, project manager with Kimley- Horn, to speak to the criticism that has been made that this plan doesn't have enough loading space. Mr. Pelan stressed that the plan provides two loading areas, both of which are greatly in excess of the requirement of the Code. July 12, 112 1994 BOOK 2 PACE 886 boflK 92 rti, E 8 There is ample loading and maneuvering space behind the Publix Store and the parking area. It is roughly 11 feet in excess of what normally would be required for 2 -way traffic. They are comfortable that the plan works with regard to the LDRs. John Atz, engineer from Kimley-Horn, returned to the podium to readdress the issue of Mooringline Drive being a major driveway. Tom Vincent, vice president of Halvorsen Development, stated they are here today as the agent of the property owner. Halvorsen does have an interest here, and when you are talking about property owners' rights and the rights to develop a piece of property, this particular property owner's right is not any less important or less significant than anyone else in this room or any other person that has an objection to this project. He emphasized that this is not a zoning hearing to consider the land use or related compatibility issues. He felt that if consideration is given to all of the testimony given today by the consultants and professionals, the Board will find that they have in fact provided substantial, competent evidence to satisfy each and every one of the requirements in Section 914.15 of the LDRs. Ron Ferrin, owner of the subject property, reiterated that they have come before the Board today for approval of an economically viable use of the land that they feel will enhance and maintain the quality of life that has been established here in Indian River County. Attorney Ralph Evans closed his presentation by emphasizing that the proposed site plan meets all requirements of the LDRs. He asked the Board to vote favorably for site plan approval. There being no others who wished to be heard, the Chairman closed the public discussion. At Chairman TippinIs request, Attorney Vitunac read aloud Excerpt #4 from his memo of 7/6/94: "The administrative procedure for site plan approval is quasi-judicial in nature, and conducted to factually determine if a proposed site plan submitted by the property owner conforms to the specific requirements set out in the administrative regulations governing the erection of improvements on the property. Those July 12, 1994 113 M M M conditions should be set out in clearly stated regulations. Compliance with those regulations should be capable of objective determination in an administrative proceeding. While the burden may be on the property owner to demonstrate compliance, no legislative discretion is involved in resolving the issue of compliance." Attorney Vitunac suggested to the Board that if they want to deny the site plan, the reasons for denial should be based on objectionable determinable requirements, i.e., median cut, driveway issue, parking -- something that can be quantified and resolved without resorting to legislative requirements as the City of Delray Beach has done. There has to be a certainty to site plans, because the site plan is about the third or fourth level down from the Comp Plan, at which point a property owner should have some idea that after compliance with listed requirements he will be able to develop his property in accordance with the Code. Likewise, the property owner has the burden of proof to show that he has met all the LDRs. There has been testimony tonight based on objectively determinable ideas, and he is not saying you have to approve the site plan or not. He is saying that if you do not approve it, your reasons should not be on the zoning type issues or what should be there, or something that doesn't have a specific quantifiable objective to it. There was evidence presented on both sides tonight. He felt the issue was fairly presented to the Board on whether the developer has met his LDR requirements. If he has, he is in compliance with the Comp Plan, because the entire Indian River County Code is in compliance with the Comp Plan, and has been since 1990. Commissioner Bird felt that perhaps we should have considered the compatibility issue more at the time we placed the CL zoning there. Maybe it is too late to do that, but there have been some points raised by the opposition that there are areas of the LDRs and the site plan review procedures that require compatibility. Commissioner Bird asked Attorney Vitunac to elaborate on the how much weight should be given to compatibility of the site plan. Commissioner Bird also asked staff to specifically address the three points that Mr. MacLean raised in objection to the site plan. Attorney Vitunac advised that compatibility as to use already had been determined by the Board this morning. There are incidents of a supermarket which cause harm and the County previously adopted July 12, 1994 114 ma 92 PAu 888. Bom PALE 889 LDRs which supposedly solved those problems. These LDRs are all in compliance with the Comp Plan. There are some 26 areas that if complied with are supposed to cover the harm that a supermarket causes in a CL zone. For instance, there are requirements for lighting, trees, buffering, separation from the road, median cuts, driveways, and traffic cuts. It is the applicant's job and his burden of proof to comply with all of those requirements, and the Board can ask staff if they have complied in everything. There has been evidence presented that they haven't complied on at least 3 issues that are objectively determinable. Commissioner Bird was concerned about the commingling of the commercial traffic going in and out of this shopping center with the residential traffic on the two main entrances. He wondered if we found that situation in any other areas in our county. He asked if it was staff's recommendation or insistence that these two entrances be used for this shopping center rather than trying to get an additional curb cut on AlA or whether there is any option to that. County Public Works Director Jim Davis, after being sworn in by County Attorney Vitunac, advised that the LDRs state that when a property has more than one road frontage, the access to the property would be by the road with the lesser functional classification. In this case, we have AlA which is an arterial route which fronts to the east of the property, and three local roads that surround the property to the north, west and south. When the County approved the Moorings development many years ago, it pretty much established an access plan onto State Road A1A. It did so by platting the lots along the local roads that connect to the arterial route, AlA. He believed that has been consistent with most of our planned developments, such as Grand Harbor, where you have mixed land uses of single- and multi -family, residential and commercial. The lesser roads provide the driveway connections to the larger connections, and the other roads provide connections to the arterial. Recognizing that this was a platted lot within the Moorings development, staff considered access and relied heavily on DOT's access management policy. It is staff's opinion that the DOT would encourage access by those roads and would not permit an access onto A1A. That has been very consistent with their thinking, particularly since the Legislature approved the management policy on access. It is staff's feeling that the access should be Mooringline Drive as it was previously planned when the Moorings PUD development was platted. July 12, 1994 115 M Director Davis stated that the median openings along Mooringline Drive are basically defined in the LDRs. Chapter 952 states, "to assure traffic safety, capacity, and control, median openings located within a traffic -way corridor shall be spaced the maximum distance apart that will allow safe and adequate traffic circulation." The words "traffic -way corridor" have always, since the development of the Code, been construed to mean those roadways on the County's Thoroughfare Plan. Those are collector and arterial roadways that have been classified higher than just a local road. In the LDRs, a "median" is defined as "the physical portion of a highway separating the traveled ways for traffic in opposite directions. " The word highway is further def ined as a roadway the primary function of which is to serve traffic.. There are other definitions in the LDRs on other type streets, particularly local streets which are primarily intended to provide direct access to property. Staff and the traffic engineering community have utilized other engineering publications such as the AASHTO Code Green Book and the Florida DOT Green Book. There are distinctions between highways and local roads. Director Davis asked the Board to view some photographs of Mooringline Drive that he took that morning. The first one shows the median, with a 25 mph speed limit sign posted on the median. He noted that many driveways connect onto the roadway, the roadway itself terminates just east of the Indian River and serves primarily as access to the abutting lots, the single- and multi- family lots that access that particular roadway. The point is that the road has a speed limit of 25 miles an hour. It is not functioning as a highway; it is functioning as a local street. In our opinion, it is not included in the County's Thoroughfare Plan as a collector or an arterial route which would be a highway under the Code. Commissioner Eggert appreciated Director Davis' opinion on the definitions, but she was concerned about two left turns of this type that close together with traffic going east on top of that, and considers that a really unsafe situation, especially when one of those will be used by trucks. Director Davis noted that most trucks would be coming from AlA. Commissioner Eggert also was concerned about the traffic coming around Bowline Drive, and Director Davis explained that the second opening meets the separation requirements in the Code that 116 July 12, 1994 MOK U2 PACE8196 BOOK 92 PAGE 891 there must be at least 70 feet between the Bowline Drive median opening and this median opening. The spacing meets the LDR requirements. Commissioner Eggert also was concerned about the road behind Publix and the noise from trucks that would be backing up and going forward. She also questioned whether there is enough space for trucks to maneuver. Director Davis felt that most of the parking spaces in the rear of the store will be occupied by employees, not the general public. In addition, the other 10,700 square feet of retail space also will have employees who will be demanding to park and use the facility. His suggestion had been to place a sign west of the trash compactor that says "EMPLOYEE PARKING" to try to segregate customer from employee parking. There is still adequate parking to the north and east to accommodate customers and those people wanting to use the facility. He believed most shopping centers encourage their employees to park in particular locations, and it would be logical to assume that it would be best for employees to park in the rear. Commissioner Eggert understood that the rear road is 2 -way, and Director Davis confirmed that it is a 25 -ft. wide, 2 -way road. Commissioner Eggert still considered the space too confining, but Director Davis explained that the applicant has indicated that it meets the 250 sq. ft. minimum dimension for that particular portion of the LDRs. Commissioner Eggert thought it unrealistic, based on her experience of going up and down AlA and going down to Fort Pierce, to believe that fewer trips are going to come from the south. She believed there will be a lot more trips from St. Lucie County who enter on Windward rather then go up to Mooringline Drive. It is not clear how much more traffic it will take to get over the 2,000 variable. Director Davis advised that staff considered the trip distribution and feels the primary influence area would be to the north. As you go south of the Moorings, there is quite a bit of undeveloped frontage down by Round Island Park. We found much of the development in St. Lucie County is substantially south of the project site. Our trip distribution patterns showed that about 30 percent would come from the south and 70 percent would come either from the Moorings development or from the north, and that was a very conservative figure in trip distribution. Commissioner Adams asked if the Technical Review Committee had signed off on the two issues of median openings and trip July 12, 1994 117 F7 distribution, and Director Davis advised that they signed off on the median opening issue, but felt the trip distribution issue of 30 percent from the south was a conservative number. Commissioner Adams noted that Attorney Vitunac has pointed out that we are dealing specifically with site plan approval this evening. She understood the position of the residents, but the fact is that it has been zoned CL and the property owner has a right to develop within our regulations. If we wanted to change the regulations about a supermarket not being a grocery store -- if that was a problem -- we should not have had this CL in there if we did not want to allow a commercial development in there. She felt that under the situation we really don't have a choice, and because of that she intended to move that this site plan be approved with the conditions outlined by staff. MOTION WAS MADE by Commissioner Adams, SECONDED by Commissioner Bird that the Board approve the site plan subject to the conditions set out in staff's recommendations. Under discussion, Commissioner Bird maintained that if we were looking at zoning this property today, based on all we have heard today, it would be difficult to vote to place CL zoning on the property knowing that a supermarket such as Publix or another major grocery store could be built there. The fact is that the zoning has been there for some time and has gone through the public hearing process to remain there. The other problem is the size of the grocery store and the fact that it might be detrimental in some respect to the neighborhood. Nevertheless, he believed it has been demonstrated to be an allowable use. Based on staff's review of this matter that they have met the requirements of our site plan ordinance, he felt compelled to stand by our ordinance and vote its approval. Commissioner Macht asked Director Keating and Director Davis, after hearing everything, if they had any reservations that the LDRs had not been adequately satisfied. They had none. Commissioner Macht asked Attorney Vitunac, that being the case, if it changes his charge to the Board that we have no choice. Attorney Vitunac stated that he felt the Board does have a choice because there has been competent substantial evidence presented on both sides of the issue. The burden of proof is 51 percent, so it is up to the Board to decide if they have met that burden. 09 Uff Ur.. f4PLI 6J2 July 12, 1994 118 BOOK 92 P E693 Commissioner Macht felt a lawsuit would ensue whichever way it goes. If we grant the application, the burden of the lawsuit and cost would be on the opposition. On the other hand, if we deny it and lose in court, then all the citizens of Indian River County suffer the cost and resulting damages. Attorney Vitunac advised that as far as defending a lawsuit, the County would be in the safest position to grant site plan approval. Commissioner Eggert stated she has great respect for staff and T believed staff knows that, but she has a real problem with access, safety, and+ noise, especially when it comes to the road behind Publix. For those reasons she would not support the motion. THE CHAIRMAN CALLED FOR THE QUESTION. The motion to grant site plan approval to Halvorsen Development passed by a vote of 4-1, Commissioner Eggert dissenting. 119 July 12, 1994 EDITS PRESENTED AT JULY 12, 1994 PUBLIC HEARINGS Morning Appeal AA. Agenda backup material (complete packet) A. Letter written to Att. Warren Dill by Senior Planner John McCoy dated 5/9/94: B. Letter received from Attorney Warren Dill dated 4/27/94 B.2 Memo from Attorney Vitunac dated 7/6/94 - Standard of Review for Site Plan Approval C.1 Transcript of P & Z Commission Meeting of 6/9/94 C.2 Memo from Alice White dated 7/11/94 C.3 Memo from Assistant County Attorney Terry O'Brien re Interpretation of Zoning Laws D. Reasons to Reverse Mr. Keating's Position that Grocery Stores and Supermarkets are the Same Use DD. Letter from Progressive Grocer to Tom Vincent of Halvorsen Development Corp. dated 6/6/94 E. Affidavit of Professor Ronald W. Cotterill Afternoon Appeal 1.1 Agenda backup material (complete packet) 1.2 Memo from County Attorney Charles Vitunac dated 7/6/94 Standard of Review for Site Plan Approval 1.3 Letter from Attorney Ralph Evans dated 6/29/94 1.4 Green folder containing information on Sea Mist Shoppes Site Plan 2 Letter from Attorney Steve Henderson dated 7/7/94 3 Presentation of Arguments Against Publix - Jack MacLean 4 Letter dated 7/12/94 submitted by Michael Dudeck 5 Letter dated 7/12/94 submitted by Raj Shanmugan 6 Letter dated 7/12/94 submitted by Scott McGuire 7 Memo from Alice White dated 7/11/94 8 Memo from Attorney Warren Dill dated 7/5/94 9 (black binder) Sec. 911.10 of Ord. 90-16 10 Authority to Deny Site Plan Approval dated 7/12/94 11 Letter from Sheriff Gary Wheeler dated 5/12/94 (page 87 of backup) 12 Letter dated 5/28/94 submitted by Richard Burkhart 13 Letter from Civic Association by Robert Tenbus dated 7/12/94 July 12, 1994 120 92 PALE804 too 4 There being no further business, on Motion duly made, seconded and carried, the Board adjourned at 9:35 p.m. ATTEST: J. arton, Clerk John W. Ti p`' , Chairman Minutes approved on 121 July 12, 1994