LTC 217-2008 Anchoring & Mooring Public Meeting?~ MIAMIBEACH
OFFICE OF THE CITY MANAGER
NO. LTC # 217-2008 LETTER TO COMMISSION
TO: Mayor Matti Herrera Bower and Members of the City Commission
FROM: Jorge M. Gonzalez, City Manager
DATE: August 28, 2008
SUBJECT: ANCHORING AND MOORING PUBLIC MEETING
The purpose of this LTC is to provide the Mayor and City Commission with the attached
legislative proposal regarding anchoring and mooring, as well as the notice of a public
meeting regarding this proposal. The meeting has been scheduled by the Florida Fish and
Wildlife Conservation Commission, to present and receive public input on proposed
legislation regarding Anchoring, Mooring and Vessel Management. A copy of the
Commission's 2009 Session Legislative Proposal is attached.
The meeting will take place at 6:30 p.m. on September 9, 2008, at the Hilton Clearwater
Beach Resort. The Administration has discussed this meeting with the City's state lobbyists,
who will attend the meeting on behalf of the City.
If you have any comments or need additional information, please do not hesitate to contact
me.
c: Executive Staff
Fred Beckmann, Public Works Director
Kevin Crowder, Economic Development Division Director
Attachments:
2009 Session Legislative Proposal
Florida Administrative Weekly Meeting Notice
Agenda for September 9, 2008 Meeting
Directions to the Meeting Location
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Florida Fish and Wildlife Conservation Commission
Legislative Affairs
620 South Meridian Street, Room 138 • Tallahassee, FL 32399-1600
(850) 487-3795 • Suncom 277-3795 • FAX (850) 410-5265
2009 Session Legislative Proposal
Title: Vessel Management
Submitted by Division of Law Enforcement
1. Issue
This issue will seek legislative solutions to issues relating to vessel management and
statutory cleanup of certain parts of Chapter 327 F. S. Vessel management issues
include: local government authority to further regulate vessels, anchoring/mooring
restrictions, and identifying vessel ownership.
2. Background
Commission Direction:
In response to stakeholder concerns, specific to unregulated anchoring and mooring,
Commissioners requested staff to research the issue and report back to them at a
subsequent meeting. At the 2006 December Commission meeting, staff presented
that unregulated anchoring of vessels presents the following problems:
- the accumulation of anchored vessels in inappropriate locations
- unattended vessels
- vessels with no anchor watch (dragging anchor, no lights, bilge)
- vessels which are not properly maintained
- vessels ignored by owners that tend to become derelict and
- confusion with the interpretation of statutes that provide jurisdictional
guidance for local governments which has caused inconsistent regulation of
anchoring/mooring fields on state waters and confusion among the boating
community.
The Commission asked staff to explore the issues further for possible solutions.
Staff presented its recommendations during the 2007 June Commission Meeting
and identified that the issue was somewhat broader than unregulated anchoring and
mooring. Confusion also exists in several areas within the subject of waterway
management, interpretation of current Florida boating laws, and local government
authority.
Some of the causes for issues presented include: the cost of boat access has
exceeded supply, the effect of 2004-2005 hurricanes and storms, an increase in the
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number of vessel registrations, limited funding to remove derelict vessels, difficulty
interpreting jurisdictional authority, and a lack of growth management planning on
the waters of the state.
The Commission was provided two recommendations:
1) Develop a model anchoring/mooring ordinance that local governments could
adopt. If the Legislature approves allowing local government more authority to
regulate anchoring, development of a model anchoring/mooring ordinance would
help ensure uniformity and consistency in anchoring and mooring regulations
statewide.
2) Clarify State and local authority to regulate vessels. The premise here would be
to address the issues of unregulated anchoring, waterway management, and
local government authority. It would allow us to suggest cleanup language for
some of the more confusing boating statutes. Examples of this approach include
combining and clarifying sections 327.22 (Regulation of Vessels by municipalities
or counties), 327.40 (Uniform waterway markers for safety and navigation;
informational markers), 327.41 (Uniform waterway regulatory markers), 327.46
(Restricted areas), 327.60 (local regulations; limitations), Florida Statutes and
rule 68D-22 (Uniform Waterway Markers in Florida Waters), Florida
Administrative Code.
The Commission instructed staff to move forward with recommendation (2) and
pursue legislative approval for statutory changes during the 2009 Legislative
Session.
Staff Work:
Prior to the 2007 June Commission Meeting, staff presented this issue to the Florida
Boating Advisory Council (BAC) during its April 2007 meeting and held six public
workshops around the State. This provided us the opportunity to vet the issue to
stakeholders and the public, better define the issues/concerns, and identify potential
solutions relating to anchoring and mooring. Approximately 273 individuals attended
the public meetings and the Council meeting. Attendees included: marina
operators, boaters, private property owners, and representatives from local
governments, affected state agencies, and law enforcement agencies. The BAC
recommended that FWC clarify local and State authority to regulate vessels.
At each meeting, stakeholders and interested persons provided several concerns.
The most common are listed below:
• Boat Access -there is a fear that boating storage and access to state waters
is diminishing, resulting in availability to a select few who can afford it.
• Over regulation -Boaters feel there is too much regulation by some local
governments causing inconsistencies from one jurisdiction to another. Many
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of the examples stem from local government anchoring restrictions that are
inconsistent with state statutes. An example would be restricting vessels from
anchoring outside of established mooring fields within city jurisdictional
waters.
• Inconsistent/confusing statutes and rules -Local government officials and
state agencies tasked with establishing boating regulatory areas have
difficulty interpreting some of the boating statutes specifically when trying to
discern authority to regulate vessel restrictions. The most prevalent example
would include who has the authority to post regulatory signage and for what
purpose.
• Pollution from anchored/moored vessels, including: waste, aesthetics, noise.
• Derelict vessels -unregulated anchoring leads to some vessels becoming
derelict.
• Resource protection -certain entities have requested more statutory authority
to protect corals, seagrasses, and other marine natural resources.
During the meetings, there were both non-regulatory and regulatory solutions
proposed. Public recommendations were considered and used to develop a scope
of work to review the statutory basis for vessel management on Florida waters. The
purpose was to consult with an outside entity with subject matter expertise that
would provide staff with policy recommendations based on the outcome of the legal
review. Staff enlisted the assistance of the University of Florida, College of Law to
assist with this project.
Sub-Teams:
Because many of the identified issues are either, in part, shared, or solely within the
statutory purview of the Department of Environmental Protection, Department of
Community Affairs, and the Florida Fish and Wildlife Conservation Commission, a
working group was formed consisting of agency representatives. This team met on
several occasions providing guidance and direction to the University of Florida
College of Law as they finalized the above policy recommendations.
Another team was formed consisting of DEP and FWC legal staff to draft legislative
language that will be brought to stakeholders and interested parties.
This work developed sixteen recommendations. The review incorporated issues
related to, regulating anchoring and mooring in state waters, local authority for vessel
management and the establishment of boating restricted areas and signage, and
cleanup of certain boating statutes within Chapter 327 F. S. To assist with this
analysis, a detailed legislative history was conducted, along with a review of boating
law administration in other states.
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Based on the outcome of the review, the following policy recommendations were
made:
• (1) The general policy of the state should be the promotion of consistency and
uniformity in the regulation of vessels and navigation, while recognizing local
circumstances.
• (2) The state should explicitly regulate vessels and navigation and return
authority to local governments on a case by case basis based upon statutory
guidance that is designed to promote uniformity and consistency.
• (3) The state should impose a statewide limit on the storage of vessels on lands
underlying navigable waters of sufficient duration to avoid undue interference
with navigation, a protected right under the public trust doctrine.
• (4) Any such statewide storage duration limitation should be based upon data
and analysis designed to ensure that mooring and anchoring by cruising vessels
is not unduly infringed and should include a "safe harbor" provision.
• (5) The Board of Trustees of the Internal Improvement Trust Fund should be
charged with the establishment and administration of vessel storage limitations
on lands underlying navigable waters.
• (6) Local governments should be permitted to further limit vessel storage,
including anchoring, for good cause upon review and approval by the Board of
Trustees of the Internal Improvement Trust Fund and in consultation with other
resource agencies.
• (7) Local governments and state resource agencies should be permitted to seek
the establishment of boating restricted areas for good cause upon review and
approval by FWC, in consultation with other resource agencies and other local
governments as appropriate.
• (8) In addition to navigation and safety, good cause should include aquatic
resource protection and, where warranted by local conditions, upland riparian
property and riparian resource protection. Good cause should not include the
consideration of compatibility with non-water-dependent riparian land uses.
• (9) Good cause for local regulation of vessel storage on the water stricter than
state limitations and the establishment of boating restricted areas should be
determined based on adequate data analysis and only after adequate public
participation.
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• (10) Local governments seeking authority to further regulate vessel storage and
create boating restricted areas should be required to adopt surface water use
policies in their comprehensive plan. Boating restricted areas should be
consistent with adopted surface water use policies but should not be considered
land development regulations for purposes of Chapter 163, Florida Statutes.
• (11) All boating restricted areas should be delineated using a spatially explicit,
uniform maritime boundary description methodology and made generally
available through a geographic information systems database maintained by the
State and linked to global positioning systems technology.
• (12) Obsolete, unnecessary and confusing definitions contained in Chapter 327
should be removed or clarified. Where terms are used only once, or only in the
context of a specific section or provision, consideration should be given to
defining these terms in their statutory context.
• (13) The statutory recitation of the federal safety equipment preemption should
be clarified to avoid confusion and ensure consistency.
• (14) The statutory authorization to create a general permit process for new
mooring fields should be either repealed or amended to increase the current size
limitation of 50,000 square feet, which is insufficient to safely accommodate the
swing radius of more than a few vessels, and has resulted in strained
interpretations of the extent to which sovereign submerged lands are preempted.
• (15) The current signage exemption provided for inland lakes and canals should
be repealed because it lacks an adequate policy justification to distinguish these
water bodies from those along the coast and creates additional uncertainty about
local regulatory authority.
• (16) The current statutory language providing that vessels "operated" on the
waters of the state must be titled, those "using" the waters of the state shall be
registered within 30 days of purchase, and those that are "used" on the waters of
the state must display a registration number should be clarified.
Stakeholder Work:
Publicly advertised stakeholder meetings were scheduled and held for the purpose of
vetting the policy recommendations and to seek guidance on which
recommendations agencies should consider for the 2009 Legislative Session.
Meetings were held on April 5, 2008 in Orlando and at the Florida Boating Advisory
Council Meeting held on April 11, 2008 in Tallahassee. Approximately 58 individuals
attended these publicly advertised meetings. Although attendees did not represent
potential affected groups, most present provided comments. Representatives from
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the sub-team were also in attendance to answer questions specific to their statutory
responsibilities. Staff continues to work with stakeholders and affected parties.
Annotated recommendations were received at each meeting and recorded.
Current Staff Action:
Because of this issue's broad scope, FWC staff is concentrating on all or part of
recommendations 1, 3, 4, 8, 11, 12, 15, and 16 primarily. Currently DCA and DEP
are considering what recommendations they will be willing to take up. Agencies will
then begin working on associated draft language in an attempt to vet through
stakeholders in June and July.
Below denotes staff rational for taking up specific recommendations:
Rational:
• Recommendation (1 ): Our goal is to promote uniformity and consistency when
regulating vessels and navigation. This is based on stakeholder input and the
fact there are myriad, illegally posted regulatory areas throughout the state.
Currently Chapter 327 does not explicitly provide for this. The thought is if this
was put into statute, it would define legislative intent. This is also something
that could be inserted within F.A.C 68D-23. During public meetings,
stakeholders and the interested public seem to agree with this principle.
• Recommendation (3, 4, and 8): During the 2008 Legislative Session there was
an attempt to further provide local government the ability to: regulate vessels
within their jurisdiction outside of legally established mooring fields and
establish regulatory areas. for the protection of seagrass. Specifically, the
action was to incorporate a "time of stay" provision which allowed a vessel to
anchor but only for a certain time frame. Currently there is no provision in
Florida law to allow this. Chapter 327.60 F. S. (2) stipulates: "Nothing contained
in the provisions of this section shall be construed to prohibit local
governmental authorities from the enactment or enforcement of regulations
which prohibit or restrict the mooring or anchoring of floating structures or live-
aboard vessels within their jurisdictions or of any vessels within the marked
boundaries of mooring fields permitted as provided in s. 327.40. However,
local governmental authorities are prohibited from regulating the anchoring
outside of such mooring fields of non-live-aboard vessels in navigation."
Some stakeholders commented on the suggested term "storage of vessels"
should be broken down to distinguish between unattended stored vessels,
attended stored vessels, occasionally attended stored vessels, cruising vessels
or transient vessels (some preference was offered for the term transient instead
of cruising), and abandoned and derelict vessels. One option would be a
rationale fora "bright line" length of stay limit because of the difficulty in
separating these forms of storage and the ability to enforce them if different
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rules were to apply to each. One stakeholder suggested that if there was a
statewide limit, consideration be given to a "sojourner's permit," which would allow
extended term cruising. Another stakeholder suggested that the statewide length
of stay, if any, should be six months, which would effectively encompass the
Florida cruising season. The sub-team agreed breaking down different vessels
based on their actions while navigating would add confusion and that it would be
better to find a standard consensus. Several boating groups were concerned that
the legislative action was premature until staff completed its research and
consensus reached through properly vetting the issue.
Currently there is no provision allowing agencies to post regulatory signage to
keep vessels off seagrass other than DEP (Board of Trustees), which is allowed to
post signage within aquatic preserves and state parks. The goal would be to add a
provision in statute under certain circumstances that allows local governments to
post regulatory signage. Several local govemments support this issue. Boater
groups fear that this authority would cause additional unwarranted regulatory
actions on certain boaters by local govemments. Many stakeholders who
commented opposed the consideration of upland riparian property as a good
cause basis for boating restricted areas. Several stakeholders who commented
considered the term "resource" to be vague. There was apparent agreement
among most stakeholders that good cause should not include incompatibility with
non-water dependent riparian land uses, which the presenters described as
"aesthetic nuisances." We would seek to draft language that narrowed the scope
to allow for "seagrass regulatory signage."
Our goal would be to provide uniform standards that did not unduly burden certain
vessels' freedoms to navigate.
Recommendation (11): This recommendation would standardize the way boating
restricted areas are delineated. Currently local governments are submitting this
information in numerous ways. A recent research project denoted varying
inconsistencies with local government regulatory boundaries. Law Enforcement
issues arise when having to explain established boundaries of a regulatory area
to the court. A uniform boundary description provided in 68D-23 would assist
local government with establishing legal zones as part of their uniform waterway
marker permit process. There appeared to be broad support for this
recommendation among stakeholders.
• Recommendation (12): This recommendation pertains to statutory cleanup of
Chapter 327. The cleanup will consist of clarifying or removing confusing
language and defining terms in statutory context. This chapter was enacted in
1959, at a time when vessel congestion and resource and water use conflict was
minimal. It has been substantially revised on several occasions and amended on
an issue by issue basis. As a result, in addition to creating general policy
confusion, the statute retains vestiges of repealed provisions and obtuse
terminology. This cleanup would assist state agencies, local governments, and
other governmental entities understand their authority to regulate. There
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appeared to be support for this recommendation among stakeholders. The sub-
team agreed that careful attention would be needed to ensure stakeholders and
legislative members that legislative intent was not altered.
• Recommendation (15): During the 2004 Legislative Session an exemption was
provided in s. 377.40 F. S. that allows for creation of regulatory areas within
inland lakes and associated canals, which could create inconsistencies between
coastal water bodies and those inland. It creates additional uncertainty about
local regulatory authority. Our goal would be to repeal this provision so all waters
of the state are under the same umbrella. Most stakeholders supported this
recommendation.
Recommendation (16): This recommendation would assist law enforcement in
tracking vessels stored on state waters. Currently the registration statutes cause
vessels used on the waters of the state must be registered. In other words,
those stored and not being "operated" do not need a current registration, causing
difficulties when attempting to identify owners of vessels left unattended. The
terms "used" and "using" occur throughout the vessel registration statutes
causing confusion. Stakeholders appear to support this recommendation.
On April 16, 2008, the sub-team met to gain consensus and for the DEP and DCA to
decide what recommendations they will take up. Pending that decision, a team of
agency representatives will draft language to bring forward to stakeholders.
3. Who is affected by this issue?
Local governments and their law enforcement personnel, Department of
Environmental Protection (DEP), Board of Trustees of the Internal Improvement
Trust Fund, Department of Community Affairs (DCA), Florida Fish and Wildlife
Conservation Commission, Inland Navigation Districts, United States Coast Guard,
U.S. Corps of Engineers, Florida and non-resident boaters, Marine Industry, Boater
groups, environmental groups, and Commercial and residential waterside property
owners.
4. What is the fiscal impact on FWC, the private sector, and other agencies?
On FWC
Unknown until the issue is developed further.
On Private Sector
Unknown fiscal impact.
On Other Governmental Agencies
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Unknown fiscal impact.
5. Is there atax/fee issue?
Vessel Anchoring:
It is unknown if there is a tax/fee issue for vessel anchoring at this time.
Registration:
Section 328.56, F.S. only requires motorized vessels "used" on the waters of the
state to be registered. Vessels are only considered to be "used" if the vessel is
being operated and do not include vessels that are left anchored, moored or docked
on the waters of the state. Therefore, these vessels are not required to display a
valid registration decal. A proposed solution would require owners to maintain a
current registration while the vessel is in State waters. It is common for owners to
anchor or moor their boats in State waters year-round; therefore, the proposal
would not allow for a lapse in vessel registration status and would require the boat
owner to register their boat annually if anchored or moored in state waters.
6. Draft statutory language:
Statutory language is being developed for this issue to be presented in the 2009
Legislative Session
7. What are the affected statutes and rules?
327.22 Regulation of vessels by municipalities or counties
327.40 Uniform waterway markers for safety and navigation; informational
markers
327.41 Uniform waterway regulatory markers
327.46 Restricted areas
327.60 Local regulations; limitations
328.56 Vessel Registration Number
328.03 Certificate of title required
327.56 Safety and marine sanitation equipment inspections; qualified
327.58 Jurisdiction
253.04 (3) Duty of board to protect, etc., state lands; state may join in action brought
253.035 Coastal anchorage areas
68D-23 Florida Administrative Code; Uniform Waterway Markers in Florida Waters
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The Fish and Wildlife Conservation Commission, Division of Law Enforcement, announces
a public meeting to which all interested parties are invited.
DATE AND TIME: Tuesday, September 9, 2008, 6:30 p.m. - 8:30 p.m.
.LOCATION: Hilton Clearwater Beach Resort, 400 Mandalay Avenue, Waters Edge Ballroom,
Clearwater Beach, Florida 33767
GENERAL SUBJECT MATTER TO BE CONSIDERED: To discuss issues and solicit public
comment concerning draft statutory language pertaining to anchoring, mooring, and vessel
management.
A copy of the agenda maybe obtained by contacting: Major Paul Ouellette, Fish and Wildlife
Conservation Commission, 620 South Meridian Street, Room 235, Tallahassee, Florida 32399-
1600, phone (850) 488-5600.
Pursuant to the provisions of the Americans with Disabilities Act, any person requiring special
accommodations to participate in this workshop is asked to advise the agency at least five
calendar days before the meeting by contacting: ADA Coordinator, (850)488-6411. If you are
hearing or speech impaired, please contact the agency by calling (850)488-9542.
THE PERSON TO BE CONTACTED REGARDING THE WORKSHOP: Major Paul
Ouellette, Fish and Wildlife Conservation Commission, 620 South Meridian Street, Room 235,
Tallahassee, Florida 32399-1600, phone (850)488-5600.
AGENDA
Fish and Wildlife Conservation Commission
Anchoring, Mooring, and Vessel Management Proposed Legislation
Meeting
September 9, 2008 -Clearwater Beach
I. WELCOME
II. INTRODUCTIONS AND ANNOUNCEMENTS
a) Introductions - FWC Staff
b) Introductions -Participants
c) Announcements
III. MEETING
a) Purpose of this meeting -review draft language and
receive public input
b) Input from participants
c) Discussion
ADJOURN
PLEASE SIGN IN.
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Directions to the Clearwater Beach FL Hotel
From The North: Take I-75 South to 275 South. Exit onto Highway 60 West toward Clearwater
Beach. At the roundabout, exit right on to Mandalay Avenue. The hotel is on the left.
From The South: Take I-275 North to Roosevelt Blvd West to Bayside Bridge turning right (going
North). Turn left on Highway 60 /Gulf to Bay. At the roundabout, exit right on to Mandalay Avenue.
The hotel is on the left.
From The East: Take I-4 West to I-275 South to Highway 60 West toward Clearwater Beach. At
the roundabout exit, turn right onto Mandalay Avenue. The hotel is on the left.
From Tampa International Airport: From terminal, follow signs to Clearwater Highway 60. Take
left exit onto Highway 60 West toward Clearwater Beach. At the roundabout exit, turn right onto
Mandalay Avenue. The hotel is on the left.
From St. Petersburg / Clearwater Airport: Start out going West on Roosevelt Boulevard to the
Bayside Bridge and turn right (going North) to Hwy 60 West towards Clearwater Beach. At the
roundabout, exit right on to Mandalay Avenue. The hotel is on the left.