HomeMy WebLinkAbout10-01-2007 Assignment of Conservation Easement of Winter Springs Golf CourseBROWN, GARGANESE, WEISS & UAGRESTA, P.A.
A waxy at Law
Debra S. Babb-Nutcher°
Offices in Orlando Kissimmee, Cocoa, Tara L. Barrett
Joseph E. Blitch
Ft. Lauderdale & Tampa Vivian P. Cocotas
Usher L. Brown'
Scott J. Dornstein
Suzanne D'Agresta°
Mitchell B. Haller
Anthony A. Garganese°
Katherine W. Latorre
J.W. Taylor
Terri E. Oster
Jeffrey S. Weiss
Amy J. Pitsch
'Board Certified Civil Trial Lawyer
'Board Certified City, County & Local Government Law
'Board Certified Appellate Practice
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434
Winter Springs, Florida 32708-6912
Erin J. O'Leary'
Catherine D. Reischmann°
William E. Reischmann, Jr.
Of Counsel
Re: Assignment of Conservation Easement of Winter Springs Golf Course
Dear Mayor Bush and Members of the City Commission:
This correspondence is in response to your request on September 24, 2007 for an
opinion as to whether the City has the right to assign an interest in the Winter Springs Golf
Course conservation easement to a third party. In accordance with section 704.06, Florida
Statutes, said easement was granted to the City by Big Cypress Associates, Ltd. on
December 26, 1984 and is recorded at Book 1604, Page 131 in the Official Public Records
of Seminole County, Florida ("Easement").
EXECUTIVE SUMMARY
The express terms of the Easement and section 704.06, Florida Statutes grant the
City the right to assign an interest in the Easement to a third party. However, the third party
must be a government agency, a charitable organization, or a trust, and be an eligible
donee under the Internal Revenue Code. In addition, the third party must agree to fulfill the
conservation purpose of the Easement.
LEGAL ANALYSIS
Under Florida law, conservation easements may be granted and acquired pursuant
to section 704.06, Florida Statutes. In 1984, the Easement was granted to the City
225 East Robinson Street, Suite 660 • P.O. Box 2873 • Orlando, Florida 32802-2873
Orlando (407) 425-9566 Fax (407) 425-9596 • Kissimmee (321) 402-0144 • Cocoa (866) 425-9566 • Ft. Lauderdale (954) 670-1979
Website: www.orlandolaw.net • Email: firm@orlandolaw.net
October 1, 2007
Page 2
pursuant to the authority set forth under this section. Section 704.06(2), Florida Statutes,
provides that conservation "easements may be acquired in the same manner as other
interests in property are acquired . . . and shall not be unassignable to other
governmental bodies or agencies, charitable organizations, or trusts authorized to acquire
such easements, for lack of benefit to a dominant estate." (emphasis added). In addition,
the following entities may hold a conservation easement:
Any governmental body or agency, or by a charitable
corporation or trust whose purposes include protecting
natural, scenic, or open space values of real property,
assuring its availability for agricultural, forest, recreational, or
open space use, protecting natural resources, maintaining or
enhancing air or water quality, or preserving sites or properties
of historical, architectural, archaeological, or cultural
significance.
§ 704.06(3), Fla. Stat. (2007).
Therefore, Florida law expressly prohibits making a conservation easement
unassignable. In other words, a conservation easement may be assigned. If assigned,
however, Florida law requires that a conservation easement be held by a government body
or agency or charitable organization or trust organized for conservation purposes.
Accordingly, because the Easement was granted to the City under section 704.06,
Florida Statutes, the City may assign the Easement to qualified third parties.
In addition, the express terms of the Easement are consistent with the
aforementioned statute and also recognize the City's statutory right to assign the
Easement. On page 4 of the Easement, the Easement provides:
TO HAVE AND TO HOLD the said Conservation Easement
and Restrictions unto the said Grantee, its successors and
assigns forever, subject to the condition that the Grantee and
its successors and assigns may not transfer said
Conservation Easement and Restriction, with or without
consideration unless: (1) the Grantee as a condition of the
transfer requires that the conservation purposes continue to be
carried out and (2) the transferee is an eligible donee as that
term is defined in the Internal Revenue Code and regulation
issued thereunder.
(emphasis added).
Therefore, the Easement grants the City the right to assign the conservation
easement to a third party, so long as the assignee is an "eligible donee" under the Internal
k
October 1, 2007
Page 3
Revenue Code' and the assignee agrees to carry out the conservation purposes of the
Easement.
If the City Commission desires to assign an interest in the Easement, the details of
the assignment will need to be structures to comply the conditions set forth in section
704.06, Florida Statutes, and in the Easement. I look forward to discussing this matter at
a Commission meeting in the near future.
Siqcy,
Anthony A. Garganese
City Attorney
AAG:jaw
cc: City Manager
' In general, an "eligible donee" under the Internal Revenue Code appears to be either:
(1) a governmental entity with the purpose of retaining the conservation easement for public
purposes, or (2) a corporation, trust, or community chest, fund or foundation operated religious,
charitable, scientific, literary, or education purposes, or (3) a non-profit corporation organized
under section 501(c)(3), which is a private foundation or organization which receives more than
1/3 of its support from charitable contributions including grants, gifts and membership fees. See
Internal Revenue Code, Section 170 (h)(3) (defining "qualified organization" for charitable
donation purposes).
ri
x BROWN, GARGANESE, WEISS & UAGRESTA, P.A.
A ttorniey at Law
Debra S. Babb-Nutcher° Offices in Orlando Kissimmee, Cocoa, Tara L. Barrett
Joseph E. Blitch Ft. Lauderdale & Tampa Vivian P. Cocotas
Usher L. Brown' Scott J. Dornstein
Suzanne D'Agresta° Mitchell B. Haller
Anthony A. Garganese° Katherine W. Latorre
J.W. Taylor Terri E. Oster
Jeffrey S. Weiss Amy J. Pitsch
Board Certified Civil Trial Lawyer
'Board Certified City, County & Local Government Law
Board Certified Appellate Practice
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434
Winter Springs, Florida 32708-6912
Erin J. O'Leary'
Catherine D. Reischmann°
William E. Reischmann, Jr.
Of Counsel
Re: Assignment of Conservation Easement of Winter Springs Golf Course
Dear Mayor Bush and Members of the City Commission:
This correspondence is in response to your request on September 24, 2007 for an
opinion as to whether the City has the right to assign an interest in the Winter Springs Golf
Course conservation easement to a third party. In accordance with section 704.06, Florida
Statutes, said easement was granted to the City by Big Cypress Associates, Ltd. on
December 26, 1984 and is recorded at Book 1604, Page 131 in the Official Public Records
of Seminole County, Florida ("Easement").
EXECUTIVE SUMMARY
The express terms of the Easement and section 704.06, Florida Statutes grant the
City the right to assign an interest in the Easement to a third party. However, the third party
must be a government agency, a charitable organization, or a trust, and be an eligible
donee under the Internal Revenue Code. In addition, the third party must agree to fulfill the
conservation purpose of the Easement.
LEGAL ANALYSIS
Under Florida law, conservation easements may be granted and acquired pursuant
to section 704.06, Florida Statutes. In 1984, the Easement was granted to the City
225 East Robinson Street, Suite 660 • P.O. Box 2873 • Orlando, Florida 32802-2873
Orlando (407) 425-9566 Fax (407) 425-9596 • Kissimmee (321) 402-0144 • Cocoa (866) 425-9566 • Ft. Lauderdale (954) 670-1979
Website: www.orlandolaw.net • Email: firm@orlandolaw.net
M
October 1, 2007
Page 2
pursuant to the authority set forth under this section. Section 704.06(2), Florida Statutes,
provides that conservation "easements may be acquired in the same manner as other
interests in property are acquired . . . and shall not be unassignable to other
governmental bodies or agencies, charitable organizations, or trusts authorized to acquire
such easements, for lack of benefit to a dominant estate." (emphasis added). In addition,
the following entities may hold a conservation easement:
Any governmental body or agency, or by a charitable
corporation or trust whose purposes include protecting
natural, scenic, or open space values of real property,
assuring its availability for agricultural, forest, recreational, or
open space use, protecting natural resources, maintaining or
enhancing air or water quality, or preserving sites or properties
of historical, architectural, archaeological, or cultural
significance.
§ 704.06(3), Fla. Stat. (2007).
Therefore, Florida law expressly prohibits making a conservation easement
unassignable. In other words, a conservation easement may be assigned. If assigned,
however, Florida law requires that a conservation easement be held by a government body
or agency or charitable organization or trust organized for conservation purposes.
Accordingly, because the Easement was granted to the City under section 704.06,
Florida Statutes, the City may assign the Easement to qualified third parties.
In addition, the express terms of the Easement are consistent with the
aforementioned statute and also recognize the City's statutory right to assign the
Easement. On page 4 of the Easement, the Easement provides:
TO HAVE AND TO HOLD the said Conservation Easement
and Restrictions unto the said Grantee, its successors and
assigns forever, subject to the condition that the Grantee and
its successors and assigns may not transfer said
Conservation Easement and Restriction, with or without
consideration unless: (1) the Grantee as a condition of the
transfer requires that the conservation purposes continue to be
carried out and (2) the transferee is an eligible donee as that
term is defined in the Internal Revenue Code and regulation
issued thereunder.
(emphasis added).
Therefore, the Easement grants the City the right to assign the conservation
easement to a third party, so long as the assignee is an "eligible donee" under the Internal
October 1, 2007
Page 3
Revenue Code' and the assignee agrees to carry out the conservation purposes of the
Easement.
If the City Commission desires to assign an interest in the Easement, the details of
the assignment will need to be structures to comply the conditions set forth in section
704.06, Florida Statutes, and in the Easement. I look forward to discussing this matter at
a Commission meeting in the near future.
Sinc y,
Anthony A. Garganese
City Attorney
AAG:jaw
cc: City Manager
' In general, an "eligible donee" under the Internal Revenue Code appears to be either:
(1) a governmental entity with the purpose of retaining the conservation easement for public
purposes, or (2) a corporation, trust, or community chest, fund or foundation operated religious,
charitable, scientific, literary, or education purposes, or (3) a non-profit corporation organized
under section 501(c)(3), which is a private foundation or organization which receives more than
1/3 of its support from charitable contributions including grants, gifts and membership fees. See
Internal Revenue Code, Section 170 (h)(3) (defining "qualified organization" for charitable
donation purposes).
BRAWN,
Debra S. Babb-Nutcher°
Joseph E. Blitch
Usher L. Brow (°
Suzanne D' g,estaestaGafganeSe°
Anthony
J W . Taylor
Jeffrey S. Weiss
GARGANESE,
A tt at Law
County & Local Government Law
•Board Certified Civil Trial LawYe
.
Board Certified City,ellate Practice
'Board Certified App
do KeCocoa,
��mOffices inOranale&a
FtLaude
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434 6912
XXIEISS & YAGRE'STA' P•A•
Tara L. Barrett
Vivian P. cocotas
Scott J. Dornstein
Mitchell B. Haller
Katherine W • Latorre
Terri E. Oster
Amy J- Pitsch
Erin J. O'Leary °
Catherine D. Reischmann
William E. Reischmann, Jr -
of Counsel
Winter Springs, Florida 32708-
Re: Assignment of Conservation Easement of Winter Springs Golf Course
h and Members of the City Commission:
Dear Mayor Busrequest on September 24, 200n for
an
onse to your
This correspondence is in resp has thiright to assign an interest in the Winter ction 4 Springs
Florida
opinion as to olf
whether thSemten to a th rd party. In accordance with
course conservation ea granted to the City by Big Cypress Associates, Ltd. d
on
Co e 131 in the Official Public Records
Statutes, said easement was gran
December 26, 1984 and is recorded atBook 1604, Page
Dec Florida ("Easement").
of Seminole County,
EXECUTIVE SUMMARY
rant th'
However, the third pa
the Easement and section 704.06, Florida Statutes g
The express terms of cement to a third party be an eligj�
City the right to assign an interest in the Ea or amust agree to fulfill
must be a govern
men agency, a charitable organization,the third party trust, an
donee under the Internal Revenue semeat e. In addition,
conservation purpose of the E
LEGAL ANALYSIS
easements may be granted and acquired
1
Under Florida law, conservation in 1984, the Easement was granted
Florida Statutes.
to section 704.06, _0)(2 •Cocoa (866) 425-9566 • Ft. Lauderdale1.
RobinsonaS Street, Suite 660 • P.O. Box 2873 •Orlando, Florida 32802-2873
225 East 25 9596 •Kissimmee (321) 402 orlandolaw.net
Orlando (407) 425 9566 Fax (407) Website: www•orlandolaw.net •Email: firm@
r
,yf I[ to assign the conservation
L,,c assignee is an "eligible donee" under the Internal
i
Z onil-I rers
ea °rgani ati , fo charitable
P fees. See
able
x
BROWN, GARGANESE, WEISS & UAGRESTA, P.A.
A ttame)s at Law
Debra S. Babb-Nutcher° Offices in Orlanc{oT Kissimmee, Cocoa, Tara L. Barrett
Joseph E. Blitch Ft. Lalf elroiale & Tampa Vivian P. Cocotas
Usher L. Brown' Scott J. Dornstein
Suzanne D'Agresta° Mitchell B. Haller
Anthony A. Garganese° Katherine W. Latorre
J.W. Taylor Terri E. Oster
Jeffrey S. Weiss Amy J. Pitsch
Board Certified Civil Trial Lawyer
'Board Certified City, County 8 Local Government Law
Board Certified Appellate Practice
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434
Winter Springs, Florida 32708-6912
Erin J. O'Leary'
Catherine D. Reischmann°
William E. Reischmann, Jr.
Of Counsel
Re: Assignment of Conservation Easement of Winter Springs Golf Course
Dear Mayor Bush and Members of the City Commission:
This correspondence is in response to your request on September 24, 2007 for an
opinion as to whether the City has the right to assign an interest in the Winter Springs Golf
Course conservation easement to a third party. In accordance with section 704.06, Florida
Statutes, said easement was granted to the City by Big Cypress Associates, Ltd. on
December 26, 1984 and is recorded at Book 1604, Page 131 in the Official Public Records
of Seminole County, Florida ("Easement").
EXECUTIVE SUMMARY
The express terms of the Easement and section 704.06, Florida Statutes grant the
City the right to assign an interest in the Easement to a third party. However, the third party
must be a government agency, a charitable organization, or a trust, and be an eligible
donee under the Internal Revenue Code. In addition, the third party must agree to fulfill the
conservation purpose of the Easement.
LEGAL ANALYSIS
Under Florida law, conservation easements may be granted and acquired pursuant
to section 704.06, Florida Statutes. In 1984, the Easement was granted to the City
225 East Robinson Street, Suite 660 • P.O. Box 2873 • Orlando, Florida 32802-2873
Orlando (407) 425-9566 Fax (407) 425-9596 • Kissimmee (321) 402-0144 • Cocoa (866) 425-9566 • Ft. Lauderdale (954) 670-1979
Website: www.oriandolaw.net - Email: firm@orlandolaw.net
October 1, 2007
Page 2
pursuant to the authority set forth under this section. Section 704.06(2), Florida Statutes,
provides that conservation "easements may be acquired in the same manner as other
interests in property are acquired . . . and shall not be unassignable to other
governmental bodies or agencies, charitable organizations, or trusts authorized to acquire
such easements, for lack of benefit to a dominant estate." (emphasis added). In addition,
the following entities may hold a conservation easement:
Any governmental body or agency, or by a charitable
corporation or trust whose purposes include protecting
natural, scenic, or open space values of real property,
assuring its availability for agricultural, forest, recreational, or
open space use, protecting natural resources, maintaining or
enhancing air or water quality, or preserving sites or properties
of historical, architectural, archaeological, or cultural
significance.
§ 704.06(3), Fla. Stat. (2007).
Therefore, Florida law expressly prohibits making a conservation easement
unassignable. In other words, a conservation easement may be assigned. If assigned,
however, Florida law requires that a conservation easement be held by a government body
or agency or charitable organization or trust organized for conservation purposes.
Accordingly, because the Easement was granted to the City under section 704.06,
Florida Statutes, the City may assign the Easement to qualified third parties.
In addition, the express terms of the Easement are consistent with the
aforementioned statute and also recognize the City's statutory right to assign the
Easement. On page 4 of the Easement, the Easement provides:
TO HAVE AND TO HOLD the said Conservation Easement
and Restrictions unto the said Grantee, its successors and
assigns forever, subject to the condition that the Grantee and
its successors and assigns may not transfer said
Conservation Easement and Restriction, with or without
consideration unless: (1) the Grantee as a condition of the
transfer requires that the conservation purposes continue to be
carried out and (2) the transferee is an eligible donee as that
term is defined in the Internal Revenue Code and regulation
issued thereunder.
(emphasis added).
Therefore, the Easement grants the City the right to assign the conservation
easement to a third party, so long as the assignee is an "eligible donee" under the Internal
ni6
October 1, 2007
Page 3
Revenue Code' and the assignee agrees to carry out the conservation purposes of the
Easement.
If the City Commission desires to assign an interest in the Easement, the details of
the assignment will need to be structures to comply the conditions set forth in section
704.06, Florida Statutes, and in the Easement. I look forward to discussing this matter at
a Commission meeting in the near future.
Sin yy,
Anthony A. Garganese
City Attorney
AAG:jaw
cc: City Manager
' In general, an "eligible donee" under the Internal Revenue Code appears to be either:
(1) a governmental entity with the purpose of retaining the conservation easement for public
purposes, or (2) a corporation, trust, or community chest, fund or foundation operated religious,
charitable, scientific, literary, or education purposes, or (3) a non-profit corporation organized
under section 501(c)(3), which is a private foundation or organization which receives more than
1/3 of its support from charitable contributions including grants, gifts and membership fees. See
Internal Revenue Code, Section 170 (h)(3) (defining "qualified organization" for charitable
donation purposes).
r
BROWN, GARGANESE, WEISS & D'AGRESTA, P.A.
A ttorne)s at Law
Debra S. Babb-Nutcher° Offices in Orlandot Kissimmee, Cocoa, Tara L. Barrett
Joseph E. Blitch Ft.
Lauderdale &Tampa Vivian P. Cocotas
Scott J. Dornstein
Usher L. Brown'
Suzanne D'Agresta° Mitchell B. Haller
Anthony A. Garganese° Katherine W. Latorre
J.W. Taylor Terri E. Oster
Jeffrey S. Weiss Amy J. Pitsch
Board Certified Civil Trial Lawyer
'Board Certified City, County & Local Government Law
'Board Certified Appellate Practice
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434
Winter Springs, Florida 32708-6912
Erin J. O'Leary'
Catherine D. Reischmann°
William E. Reischmann, Jr.
Of Counsel
Re: Assignment of Conservation Easement of Winter Springs Golf Course
Dear Mayor Bush and Members of the City Commission:
This correspondence is in response to your request on September 24, 2007 for an
opinion as to whether the City has the right to assign an interest in the Winter Springs Golf
Course conservation easement to a third party. In accordance with section 704.06, Florida
Statutes, said easement was granted to the City by Big Cypress Associates, Ltd. on
December 26, 1984 and is recorded at Book 1604, Page 131 in the Official Public Records
of Seminole County, Florida ("Easement").
EXECUTIVE SUMMARY
The express terms of the Easement and section 704.06, Florida Statutes grant the
City the right to assign an interest in the Easement to a third party. However, the third party
must be a government agency, a charitable organization, or a trust, and be an eligible
donee under the Internal Revenue Code. In addition, the third party must agree to fulfill the
conservation purpose of the Easement.
LEGAL ANALYSIS
Under Florida law, conservation easements may be granted and acquired pursuant
to section 704.06, Florida Statutes. In 1984, the Easement was granted to the City
225 East Robinson Street, Suite 660 • P.O. Box 2873 • Orlando, Florida 32802-2873
Orlando (407) 425-9566 Fax (407) 425-9596 • Kissimmee (321) 402-0144 • Cocoa (866) 425-9566 • Ft. Lauderdale (954) 670-1979
Website: www.orlandolaw.net • Email: firm@orlandolaw.net
I
October 1, 2007
Page 2
pursuant to the authority set forth under this section. Section 704.06(2), Florida Statutes,
provides that conservation "easements may be acquired in the same manner as other
interests in property are acquired . . . and shall not be unassignable to other
governmental bodies or agencies, charitable organizations, or trusts authorized to acquire
such easements, for lack of benefit to a dominant estate." (emphasis added). In addition,
the following entities may hold a conservation easement:
Any governmental body or agency, or by a charitable
corporation or trust whose purposes include protecting
natural, scenic, or open space values of real property,
assuring its availability for agricultural, forest, recreational, or
open space use, protecting natural resources, maintaining or
enhancing air or water quality, or preserving sites or properties
of historical, architectural, archaeological, or cultural
significance.
§ 704.06(3), Fla. Stat. (2007).
Therefore, Florida law expressly prohibits making a conservation easement
unassignable. In other words, a conservation easement may be assigned. If assigned,
however, Florida law requires that a conservation easement be held by a government body
or agency or charitable organization or trust organized for conservation purposes.
Accordingly, because the Easement was granted to the City under section 704.06,
Florida Statutes, the City may assign the Easement to qualified third parties.
In addition, the express terms of the Easement are consistent with the
aforementioned statute and also recognize the City's statutory right to assign the
Easement. On page 4 of the Easement, the Easement provides:
TO HAVE AND TO HOLD the said Conservation Easement
and Restrictions unto the said Grantee, its successors and
assigns forever, subject to the condition that the Grantee and
its successors and assigns may not transfer said
Conservation Easement and Restriction, with or without
consideration unless: (1) the Grantee as a condition of the
transfer requires that the conservation purposes continue to be
carried out and (2) the transferee is an eligible donee as that
term is defined in the Internal Revenue Code and regulation
issued thereunder.
(emphasis added).
Therefore, the Easement grants the City the right to assign the conservation
easement to a third party, so long as the assignee is an "eligible donee" under the Internal
October 1, 2007
Page 3
Revenue Code' and the assignee agrees to carry out the conservation purposes of the
Easement.
If the City Commission desires to assign an interest in the Easement, the details of
the assignment will need to be structures to comply the conditions set forth in section
704.06, Florida Statutes, and in the Easement. I look forward to discussing this matter at
a Commission meeting in the near future.
Sinc y,
Anthony A. Garganese
City Attorney
AAG:jaw
cc: City Manager
' In general, an "eligible donee" under the Internal Revenue Code appears to be either:
(1) a governmental entity with the purpose of retaining the conservation easement for public
purposes, or (2) a corporation, trust, or community chest, fund or foundation operated religious,
charitable, scientific, literary, or education purposes, or (3) a non-profit corporation organized
under section 501(c)(3), which is a private foundation or organization which receives more than
1/3 of its support from charitable contributions including grants, gifts and membership fees. See
Internal Revenue Code, Section 170 (h)(3) (defining "qualified organization" for charitable
donation purposes).
BROWN, GARGANESE, WEISS & UAGRESTA, P.A.
A ttarnejas at Law
Debra S. Babb-Nutcher°
Offices in Orlando Kissimmee, Cocoa, Tara L. Barrett
Joseph E. Blitch
Ft. Lauderdale & Tampa Vivian P. Cocotas
Usher L. Brown'
Scott J. Dornstein
Suzanne D'Agresta°
Mitchell B. Haller
Anthony A. Garganese°
Katherine W. Latorre
J.W. Taylor
Terri E. Oster
Jeffrey S. Weiss
Amy J. Pitsch
'Board Certified Civil Trial Lawyer
'Board Certified City, County & Local Government Law
'Board Certified Appellate Practice
October 1, 2007
The Honorable Mayor John F. Bush and
Members of the City Commission
c/o City Clerk
1126 East State Road 434
Winter Springs, Florida 32708-6912
Erin J. O'Leary'
Catherine D. Reischmann°
William E. Reischmann, Jr.
Of Counsel
Re: Assignment of Conservation Easement of Winter Springs Golf Course
Dear Mayor Bush and Members of the City Commission:
This correspondence is in response to your request on September 24, 2007 for an
opinion as to whether the City has the right to assign an interest in the Winter Springs Golf
Course conservation easement to a third party. In accordance with section 704.06, Florida
Statutes, said easement was granted to the City by Big Cypress Associates, Ltd. on
December 26, 1984 and is recorded at Book 1604, Page 131 in the Official Public Records
of Seminole County, Florida ("Easement").
EXECUTIVE SUMMARY
The express terms of the Easement and section 704.06, Florida Statutes grant the
City the right to assign an interest in the Easement to a third party. However, the third party
must be a government agency, a charitable organization, or a trust, and be an eligible
donee under the Internal Revenue Code. In addition, the third party must agree to fulfill the
conservation purpose of the Easement.
LEGAL ANALYSIS
Under Florida law, conservation easements may be granted and acquired pursuant
to section 704.06, Florida Statutes. In 1984, the Easement was granted to the City
225 East Robinson Street, Suite 660 • P.O. Box 2873 • Orlando, Florida 32802-2873
Orlando (407) 425-9566 Fax (407) 425-9596 • Kissimmee (321) 402-0144 • Cocoa (866) 425-9566 • Ft. Lauderdale (954) 670-1979
Website: www.orlandolaw.net • Email: firm@orlandolaw.net
t
October 1, 2007
Page 2
pursuant to the authority set forth under this section. Section 704.06(2), Florida Statutes,
provides that conservation "easements may be acquired in the same manner as other
interests in property are acquired . . . and shall not be unassignable to other
governmental bodies or agencies, charitable organizations, or trusts authorized to acquire
such easements, for lack of benefit to a dominant estate." (emphasis added). In addition,
the following entities may hold a conservation easement:
Any governmental body or agency, or by a charitable
corporation or trust whose purposes include protecting
natural, scenic, or open space values of real property,
assuring its availability for agricultural, forest, recreational, or
open space use, protecting natural resources, maintaining or
enhancing air or water quality, or preserving sites or properties
of historical, architectural, archaeological, or cultural
significance.
§ 704.06(3), Fla. Stat. (2007).
Therefore, Florida law expressly prohibits making a conservation easement
unassignable. In other words, a conservation easement may be assigned. If assigned,
however, Florida law requires that a conservation easement be held by a government body
or agency or charitable organization or trust organized for conservation purposes.
Accordingly, because the Easement was granted to the City under section 704.06,
Florida Statutes, the City may assign the Easement to qualified third parties.
In addition, the express terms of the Easement are consistent with the
aforementioned statute and also recognize the City's statutory right to assign the
Easement. On page 4 of the Easement, the Easement provides:
TO HAVE AND TO HOLD the said Conservation Easement
and Restrictions unto the said Grantee, its successors and
assigns forever, subject to the condition that the Grantee and
its successors and assigns may not transfer said
Conservation Easement and Restriction, with or without
consideration unless: (1) the Grantee as a condition of the
transfer requires that the conservation purposes continue to be
carried out and (2) the transferee is an eligible donee as that
term is defined in the Internal Revenue Code and regulation
issued thereunder.
(emphasis added).
Therefore, the Easement grants the City the right to assign the conservation
easement to a third party, so long as the assignee is an "eligible donee" under the Internal
October 1, 2007
Page 3
Revenue Code' and the assignee agrees to carry out the conservation purposes of the
Easement.
If the City Commission desires to assign an interest in the Easement, the details of
the assignment will need to be structures to comply the conditions set forth in section
704.06, Florida Statutes, and in the Easement. I look forward to discussing this matter at
a Commission meeting in the near future.
Sinc y,
Anthony A. Garganese
City Attorney
AAG:jaw
cc: City Manager
' In general, an "eligible donee" under the Internal Revenue Code appears to be either:
(1) a governmental entity with the purpose of retaining the conservation easement for public
purposes, or (2) a corporation, trust, or community chest, fund or foundation operated religious,
charitable, scientific, literary, or education purposes, or (3) a non-profit corporation organized
under section 501(c)(3), which is a private foundation or organization which receives more than
1/3 of its support from charitable contributions including grants, gifts and membership fees. See
Internal Revenue Code, Section 170 (h)(3) (defining "qualified organization" for charitable
donation purposes).