Agency Rulemaking and Citizen AccessThe Legislature has made great strides in modifying the Administrative Procedures Act, Chapter 120 Florida Statutes, (APA) to increase agency accountability and legislative oversight in rule making. Further ReformAFCD supports continued legislative reform of the APA to prohibit incorporating as a comment, recommendation, or condition of permit approval, any policy that has not been expressly authorized or required by general law and adopted as a rule under the APA. Citizen AccessBetter citizen access early in the local comprehensive planning and permitting processes will provide the greatest opportunity for effective citizen participation to resolve policy issues and assist in policy formulation. Excessive LitigationLitigation at the end of the permitting process causes delay and forces negotiated results often outside the scope of the planning or permitting program at issue. The virtually unlimited opportunity to sue builds disrespect and dissatisfaction from all parties and further undermines the growth management process. Third party litigation at the end of the permitting process should be minimized and limited to technical compliance issues. |