UNF Digital Commons. University of North Florida. Timothy Keyser

Transcription

1 University of North Florida UNF Digital Commons Sawmill Slough History Environmental Center State of Florida Division of Administrative Hearings: Petitioners' First Request for Admissions to University of North Florida and the St. Johns River Water Management District Timothy Keyser Follow this and additional works at: Part of the Civic and Community Engagement Commons, Civil Law Commons, Civil Procedure Commons, Dispute Resolution and Arbitration Commons, Environmental Law Commons, and the Environmental Studies Commons Recommended Citation Keyser, Timothy, "State of Florida Division of Administrative Hearings: Petitioners' First Request for Admissions to University of North Florida and the St. Johns River Water Management District" (1990). Sawmill Slough History This Book is brought to you for free and open access by the Environmental Center at UNF Digital Commons. It has been accepted for inclusion in Sawmill Slough History by an authorized administrator of UNF Digital Commons. For more information, please contact Digital Projects All Rights Reserved

2 MICHAEL W. WOODWARD, STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS Petitioner, v. DOAH CASE NO UNIVERSITY OF NORTH FLORIDA and ST. JOHNS RIVER WATER MANAGEMENT DISTRICT, SJRWMD FILE OF RECORD NO C Respondents. PETITIONERS' FIRST REQUEST FOR ADMISSIONS TO UNIVERSITY OF NORTH FLORIDA AND THE ST. JOHNS RIVER WATER MANAGEMENT DISTRICT Petitioner requests that Respondents, UNIVERSITY OF NORTH FLORIDA and the ST. JOHNS RIVER WATER MANAGEMENT DISTRICT, admit the following pursuant to Fla.Civ.P Each of the following documents attached to or mentioned with this request is a true copy of the original and is genuine: a. Student Government Resolution dated June 29, b. Alumni Association letter dated April 24, c. Sawmill Slough Resolution dated February 28, d. Psi Chi Resolution dated April 12, e. Nursing Student Council Resolution dated April 19, f. Wellness Club Resolution dated March 22, g. College Republicans Resolution dated March 21, h. Zeta Tau Alpha Resolution dated March 20,

3 i. Pre-Law Club Resolution dated March 2, 1989 j. United Faculty Resolution dated Arpil 5, k. Exceptional Children Resolution dated March 14, Mathematics/Statistics Club Resolution dated March 16, m. Fencing Club Resolution dated March 20, n. Alpha Sigma Pi Resolution dated March 23, This road widening project is the first phase of a larger project known as the modified campus loop road. 3. The modified campus loop road is among other things, intended to connect with an eastern connection. 4. The eastern connection is designed to serve an off campus research and development park and an adjacent commercial area. CERTIFICATE OF SERVICE TIMOTHY KEYS Attorney for itioner Florida Bar No.: Post Off ice Box 92 Interlachen, Florida (904) I CERTIFY that a copy hereof has been furnished to Marcia P. Parker, Attorney for University of North Florida, 1300 Building, 2

4 1300 Gulf Life Drive, Jacksonville, Florida and Clare E. Gray, Attorney for St. Johns River Water Management District, Post Office Box 1429, Palatka, Florida by u. s. mail this ~day of June,

5 @~ lr ~ [M) rf rr D cdl J ' ~... STUDENT GOVERNMENT ASSOCIATION.. ENATE LEGISLATIO Nu inb er :s:.:.;r;_,;:s;.;;,.9s:; ;.4.;;...;9o;. _ WHEREAS, WHEREAS, WHEREAS, WHEREAS, the Student Body of UNF demonstrated strong opposition to the completion of the Loop Road, and; SGA passed SR 89S-471 opposing the Loop Road, and; the proposed Modified Loop Road fails to address the concerns outlined in SR 89S-471, and; the administration failed to meet its responsibility to seek more studen~ consultation concerning the proposed Modified Loop Road. THEREFORE, let it be resolved that SGA, as representatives of the Student Body, is opposed to the Modified Loop Road and respectfully submits this resolution as a formal protest to the UNF's administration's proposal to build the Modified Loop Road. \ '. i Respectfully Sul:mitted., Intrcxiuced by Student Advocate Board Board or Ccmnittee SENATE ACTION Date June 28, Be i~~q ~; o;~*!f::-~s-:-:-tur-~i;9hereb-- ~-a,.,.,c;.. sej=d;:::..,.-ve-toed--~--,-< r~

6 University of North Florida at Jacksonville Phi Theta Kappa Alumni Association 4567 st. Johns Bluff Road Jacksonville, FL IOTA OF FLORIDA April 24, 1989 Dr. Adam Herbert, President University of.north Florida 4567 St. Johns Bluff Road Jacksonville, FL Dear Dr. Herbert, The University of North Florida's Chapter of Phi Theta Kappa National Honor Fraternity has delayed expressing an opinion on the proposed loop because we wanted to ensure we had all the pertinent facts surrounding this controversy. We have conscientiously discussed this issue with our members and attended the public hearing on April 19, Phi Theta Kappa is known on campus for its concern for the best interests of the University and its students. This concern extends to those things which cannot speak - the wildlife and plantlife which share our land. It is our belief that humankind can no longer withdraw from its responsibility to stop the destruction of the environment. We share the belief of others that the University of North Florida should be known as a university which puts a concern for the environment ahead of monetary and developmental concerns. Therefore, after careful deliberation, we feel compelled to join our fellow students, faculty members, administrators, other University employees, and concerned citizens in voicing our opposition to the construction of the proposed loop. Cordially, President Juanita Lepianka '. Vice Presiden~ (/ ~~~sor

7 l i. I. z 1 '. the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lotst crossing traffic, as they do now, and; WHEREAS, Only the northern connector will provide- a second WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut.-.i!e IT THEREFORE RESOLVED, that The,,.~~t1W.ff!4J~tl\t\W)~ei.!&a:9:MP _cfuojof the University of North Florida supports the construction of_,,_ the northern connector only and requests that the administration not complete the loop road. DATE: Title

8 kjkjkjjjjjjjjhhhhh RESOLUTION ':... I ~.. WHEREAS. The university wants to build both the loop road and the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangero~s traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossin g traffic, as they do now, and; WHEREAS, Only the northern connector will provide a second WHEREAS, only the northern connector entrance could cut. roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake...,Oneida, wh~ch handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, that Psi Chi of the University of North Florida supports the construction of the northern connector only and requests that the administration not complete the loop road. DATE: z;/;~!p9 Title

9 RESOLUTION :;. ; _the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS,' Only the northern connector wi 11 proviq_e a second WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major n~ture trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be WHEREAS, Only the.northern connector will not disturb any existing nature trails, boardwalks,.or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut faculty, library books, staff, and oth~r vitally needed BE IT THEREFORE RESOLVED, that The Nursing Student Council of the University of North Florida supports the construction of the northern connector only and requests that the administration not complete the loop road. DATE: ---~~'C:;9- Signature. Title ~7.urt->M-Af_~ r.;_~_i!lc 1;Dfr-r-

10 ,.... ;... ' RESOLUTION the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangero.us traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots~ crossing traffic, as they do now, and; WHEREAS, Only 'the northern connector will provide a second WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be WHEREAS, Only the northern connector will not disturb any existing nature trails, boardwalks, or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, that The Wellness Club of the University of North Florida supports the construction of the northern connector only and requests that the administration nq.t complete the loop road. DATE: Signature.,~-'J Title

11 RESOLUTION the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS, Only the northern connector will provide a second WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road wi 11 cross two major nature trai l.s, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be... existing nature trails, boardwalks, or parking lots, and; SY. and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, that The ~~t~~~~~l!i~ the University of North Florida supports the con~ction of the northern connector only and requests that the administration not co~plete ~he loop road. DATE: Signature Title _.CliairJ.n.a.o 1 i?. ('). ' v.j.i l.'i-f!<~-{:tj::5=.<ff J_a~\d:t C;.{tf f:l -~~J

12 RESOLUTION the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS, Only tne northern connector will provide a second WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5X and by returning back to the state the money already allocated for the loop road, the university tould avoid having to cut,~,f!l~c.ill:'j\t'a~ ~iu..~~h.j 'ai(jlj.jw~ BE IT THEREFORE RESOLVED, that MiI I Iii Epsi is:fi of the University of North Florida supports the construction of the northern connector only and requests that the administration not complete.the 1 cop rbad. DATE: Title P~ct ~\/ ~ 'J_..J ~1Ct.._~~ s;_<:._c;_~_vul...2u.4id~ \A. I

13 ~: RESOLUTION.WHE~AS, The university wants to build both the loop road and the northern connector and; so if and when UNF does grow to 10,000 ~tudents or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no, safer.than it is lots~ crossing traffic, as they do. now, and;,. WHEREAS, Only the northern connector will provide a second,.. WHEREAS, Only the northern connector entrance could cut roughly entrance, providing a.safer and more efficient,alternative WHEREAS, Only the northern connector could better provid~ traffic management, and; WHEREAS, The expensive loop road will have a negative impact.on the environment and will run through environmentally sensitive WHEREAS, The loop road will -cross two major nature trails, which. will have to be rerouted while th~ northern connector crosses no trails and;. WHEREAS, The loop road will necessitate i;.he relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to'be existing nature trails, boardwalks., or parking lots, and; WHEREAS, The university is unde~ pressure to cut its budget by 5% and by returning back to the state the money 'already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, that The ~~' LaWU&0[11@.b of the University of North Florida supports the construction of the northern connector only a~d requests that the administration not complete the loop road. DATE: (.')Title ~. I/ 1" I ' - 1-C. (

14 RESOLUTION the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS, Only the northern connector will provide a second. WHEREAS, Only the northern connector entrance could cut roughly WHEREAS, Only the northern connector would better manage traffic circulation, and; WHEREAS, The expensive loop road will have a negative impact on wetlands, and; WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern co~nec~or crosses no trails, and; _ WHEREAS, The loop road wi 11 necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots and; 5X and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, that the UNF~ ir'~-.. ~-... ~.~-~":mr..._ ~~ifjl~li?z!!tl!id of the University of.,..,north F- 6 construction"'t'1rf the northern connector only and administration not complete the loop roadjj DATE: -~f,d Yj J_Uj _ I Title. 1-1k~f-VJLE/JLE[

15 RESOLUTION ~he narthern connector and; so if and when UNF does grow to l0,000 students or more, a new and potentially more dangerous traffic problem. will have to be WHEREAS, The.completed loop road would be no safer than it is now since cars would still have to turn in and out af the parking lots, c~ossing traffic, as they do now, and; WHEREAS, Only the norther~ conn~ctor will provide a second WHEREAS, Only the northern connector entrance could cut roughly' WHEREas, Only the northern connector could better provide t~affic managemenf, and; WHEREAS, The expensive loop road will have a nagative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot.ta the far end of Lake Oneida, which means that if the Red Maple Boardwalk is ta be maintained as a handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid havin~ to cut!~ =;F~~: ~~~~;~~~ty t~;~~~.f! 'Ffoi-hfac-'sup~~;~~-~,...- construction of the northern connector only and.requests that the administration not complete th"e loop road. DATE: ---~~J~1l~j~ Title -~ U~""-tt~J~ "-~ --~'=~ / c -11. L JLr:::::> _ C \ \<_.

16 RESIJLUTION.th~ northern connector andr so if and when UNF does grow to l~o, 000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The.completed loop road would be no safer than it is now since cars would still have to turn in and out of the parking lots, crossing traffic, as they do now, and; WHEREAS~ Only the norther1:1 conn.ector wi 11 provide a second WHERE~S, Only the northern connector entrance could cut toughly ~nirance, providing a safer and more efficient alternative WHERE~S, Only the northern connector could better provide traffic managemen~, and; WHEREAS, The expensive loop road will have a n~gative impact on WHEREAS, The loop road will cross two maj~r na~ure tr~ils, which will have to be rerouted while the northern connector crosses no trails and; 1 WHEREAS, The loop road will necess.itate the relocation of the nature trails parking lat to the far end of Lake Oneida, which handicapped facility,.another expensive boardwalk will have to be. existing nature trails, boardwalks, or parking lots, and; WHEREAS, The university is under pressure to cut its budg~t by 5% and by returning back to the ~tate.the money already allocated for the loop road, the university could avoid having to cut BE IT THEREF~~E RESOLVED, that ~{.fie1%-fl;~tnf!t~~ of the University of North Florida supports the construction of:~he northern connector only and requests that the administration not complete the loop ~oad. DATE: Title

17 RESOLUTION '. ':.,the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS, Only the northern connector will provide a second WHEREAS, Only the northern connector entrance could cut roug~~y WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5% and by returning back to the state the money already allocated for the loop road, the university could avoid. having to cut BE IT THEREFORE RESOLVED, that The Fencing Club of the University of North Florida supports the construction of the northern connector only and requests that the administration not complete the loop road. DATE: ----~~~ Title

18 RESOLUTION the northern connector and; so if and when UNF does grow to 10,000 students or more, a new and potentially more dangerous traffic problem will have to be WHEREAS, The completed loop road would be no safer than it is lots, crossing traffic, as they do now, and; WHEREAS, Only the northern connector will provide a second WHEREAS, Only the northern connector entrance could cut rough1y WHEREAS, Only the northern connector could better provide traffic management, and; WHEREAS, The expensive loop road will have a negative impact on WHEREAS, The loop road will cross two major nature trails, which will have to be rerouted while the northern connector crosses no trails and; WHEREAS, The loop road will necessitate the relocation of the nature trails parking lot to the far end of Lake Oneida, which means that if the Red Maple Boardwalk is to be maintained as a handicapped facility, another expensive boardwalk will have to be existing nature trails, boardwalks, or parking lots, and; 5Y. and by returning back to the state the money already allocated for the loop road, the university could avoid having to cut BE IT THEREFORE RESOLVED, t;~t~~f the University of North Florida supports the construction of the northern connector only and requests that the administration not co~plete the loop road. DATE: ----~~~~-~-:Z. Title --~ m~ ~ ~ ~-#~~--- (!: Jei')

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