Item I22May 14 01 11:10a Commissioner Williams (305) 289-6306 p,3
BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
ADD -ON
Meeting Date: Wednesday, June 20, 2001 Division: BOCC
Bulk Item: Yes ^ No XX Department: Comm. Nora Williams
AGENDA ITEM WORDING: 1. Approval of special resolution and actions resulting from latest
Department of Community Affairs Affordable Housing Summit, June 5, 2001. 2. Approval of funding
for county -wide affordable housing planner.
ITEM BACKGROUND:
PREVIOUS REVELANT BOCC ACTION:
CONTRACT/AGREEMENT CHANGES:
STAFF RECOMMENDATIONS:
TOTAL COST: BUDGETED: Yes _ No XX
COST TO COUNTY:
REVENUE PRODUCING: Yes No AMOUNT PER MONTH Year
APPROVED BY: County Atty _ OMB/Purchasing Risk Management
DIVISION DIRECTOR APPROVAL:
DOCUMENTATION:
DISPOSITION:
Revised 2/27/01
Included
-Ypk)d&&V—'j
a� (Nora Williams, Commissioner)
To Follow XX Not Required_
AGENDA ITEM # _' a a
County of Monroe
Growth Management Division
2798 Overseas Highway
Suite 410
Marathon, Florida 33050
Voice: (305) 289 2500
FAX: (305) 289 2536
MEMORANDUM
TO: Board of County Commissioners
FROM: Timothy J. McGarry, AICP
Director of Growth Manag e
DATE: June 19, 2001
Board of County Commissioners
Mayor George Neugent, District 2
Mayor Pro Tern Nora Williams, District 4
Comm. Charles "Sonny" McCoy, Dist. 3
Comm. Murray E. Nelson, District 5
Comm. Dixie M. Spehar, District 1
SUBJECT: Growth Management Division Staff Update and Suggestions
on Proposed Comp Plan and LDR Changes
Overview
To prepare for her update to the Commission at its June 20, 2001, meeting, Commissioner Nora
Williams, Land Use Liaison requested the Growth Management Division staff to prepare an
update and responses to the initial list of proposed Comprehensive Plan and Land Development
Regulations (LDRs) changes approved conceptually by the BOCC in March 2001. The information
provided to Commissioner Williams for her status report is contained in this memorandum.
Purpose
Each proposed change in the Comprehensive Plan or Land Development Regulations identified in
the list approved in concept by the BOCC for submittal to DCA is addressed as well as the need
for a comprehensive plan amendment for the long-range plan approach for eventual build -out.
For each proposal, an update on the progress of any amendments being prepared in response to
the proposed change is provided; any staff concerns or issues with the proposal are identified;
any needed action or direction by the BOCC is recommended; and a time frame by which the
amendments will be in effect or before the BOCC is identified.
20 Year Land Acquisition and Affordable Housing Plan
The Growth Management Division staff believes that the significance and importance of
developing and implementing a long-range "end -game" approach for land acquisition, build -out,
and affordable housing, as espoused in Commissioner William's document Securing Our Future:
A 20 Year Plan, requires that the preparation of such a plan be initiated and directed by first
amending the existing Comprehensive Plan. The proposed approach to addressing eventual
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build -out of the Keys is a significant and fundamental shift in the policy direction of the existing
Comprehensive Plan.
The focus of the present comprehensive plan is primarily one of reaction to pressing short-term
issues and deficiencies, both manmade and natural, while delaying to the future, the more
politically difficult and critical decisions, which will face the County as it must come to grips with the
need to balance environmental quality with quality of life issues. The proposed approach
recognizes that the County must now move forward to squarely and aggressively focus on the
long-term build -out issues of property rights, provision of affordable housing and preserving and
conserving environmental and natural resources commensurate with sustainable development
principles and practices.
This amendment would provide a solid and sound policy basis for coordinating and directing the
completion of various elements of this ambitious effort, some of which were outlined in the
"additional actions" part of the "Statement from the Board of County Commissioners Concerning
Affordable Housing," approved on April 18, 2001, by the BOCC. The amendment should provide
a commitment and policy direction on such policy issues as changes to ROGO (see elsewhere in
this report), incorporation of the of the Carryout Capacity Study, Hurricane Evacuation Update,
community master plans resulting from Livable CommuniKeys Program, land acquisition, and
affordable housing.
It would serve as a tangible demonstration of the County's resolve and commitment to addressing
its future and be a valuable lobbying tool for seeking extensive legislative and financial support
from the state and federal governments. Most importantly, the plan amendment process itself will
provide opportunities for the community's involvement in the key decisions affecting its future and
vision for that future. It will provide an opportunity for the BOCC to forge a consensus among its
members and the community in addressing the critical issues facing the County in implementing
the "end game."
Recommendation: The BOCC should request that staff prepare an amendment(s) to the
Comprehensive Plan that provides a sound policy basis and direction for development of a 20-
year land acquisition and affordable housing plan for the ultimate build -out of the Keys.
Time Frame: If the BOCC supports this recommendation, the staff anticipates that the draft
amendments could be ready for submittal to the Development Review Committee by August and
reach the BOCC by later this fall..
Comp Plan and LDR Changes
Lower ROGO Boundaries for affordable housing and sharing of nutrient reduction
credits: This proposal is contained in the proposed Rule change (new sections 28-20.101
and 28-20.200) and would allow affordable housing ROGO allocations and nutrient
reduction credits to be transferred across ROGO planning boundaries and, even municipal
boundaries, if the County and municipality enter into a memorandum of agreement. The
proposed Rule would amend both the County's Comprehensive Plan and Land
Development Regulations; however, it is unnecessary to include reference to nutrient
reduction credits in the LDRs.
Recommendation: None
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Time Frame: The Rule should become effective sometime in October of this year.
Increase percentage of affordable housing set aside to allow for at least eighty units
to be set aside per year for affordable housing projects: The current LDRs allow the
number of ROGO allocations reserved for affordable housing to be increased at a
maximum of 30 percent per year. This limitation was deliberately placed in the ordinance
to minimize the disruption to the ROGO process, which abrupt changes would create. At
the present time, the County will have available within the next six months to a year: 201
lost allocations dedicated specifically for affordable housing; the restoration of the County's
annual allocation under the proposed Rule with all 37 ROGO allocations being dedicated
solely for affordable housing; and approximately 40 affordable ROGO allocations which
have continued to be rolled over in the system. Add these numbers to the 31 ROGO
allocations (20 percent of allocation) to be made available in ROGO Year 10, the total
number of affordable ROGO housing available in Year 10 may reach over 300 units, which
is more affordable housing allocations than the total awarded in the previous nine years.
ROGO and too a major extent development regulations are not a constraint to affordable
housing, the lack of money is. Artificially constraining the supply for market housing may
only increase the cost of the existing housing stock and pressures for the conversion of
affordable to market rate housing.
The current regulations already allow for a gradual increase in the annual ROGO allocation
for affordable housing. The staff believes that ROGO does not need to be further modified
at this time, especially since the proposed change in approach to long-term development
of the County increases the desirability for fundamental changes in the ROGO system.
Recommendation: At this time, the BOCC should not pursue a LDR amendment to
allocate at least 80 units per year for affordable housing, but should continue to monitor
the situation and increase affordable housing allocations in response to the needs of public
and private affordable housing providers.
Time Frame: N/A
• Make affordable housing an allowable use on properties zoned suburban
commercial (SC): The staff has prepared amendments to the LDRs to allow for
affordable housing designated for working households to be constructed as a principal use
in the SC zoning district. The staff anticipates that this draft will be submitted to the
Development Review Committee to initiate the amendment process shortly.
Recommendation: None
Time Frame: The staff anticipates that the proposed LDR amendment allowing affordable
employee housing as a principal use within the SC district will be brought to the BOCC by
September of this year.
• Add ROGO points for no- or low-cost option with real environmental impacts:
Although providing more opportunities for low cost incentives to improve the score of
ROGO applicants may appear on the surface to enable households with less economic
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means to compete in ROGO, it will have little or no effect unless higher income households
are excluded from being eligible for the same points. The changes in ROGO are already
in place, which award households ROGO points for dwellings ("modest housing") of 1,300
square feet or less in habitable space (+2 points), modular housing (+2 points) and
residential structures built on non -waterfront property (+1 point).
Another consideration is the monitoring the use and maintenance of these environmental
improvements which can be an administrative nightmare. For instance, residences that
have been awarded ROGO points for a cistern as a secondary water source have been
known to sell these same cisterns after the certificate of occupancy has been issued to
other property owners.
Since the County Growth Management Division is seriously considering proposing to make
ROGO a true lottery system to replace the current system when it ends in July 2002, the
staff believes further tinkering is not worthwhile or productive.
Recommendation: The BOCC should drop this proposal from further consideration and
development.
Time Frame: N/A
Expand donated lots that qualify for ROGO points to include lots in acquisition
areas throughout the County: The staff believes that this approach has merit if applied
to "new" acquisition areas that the County intends to identify and approve for resource
conservation and protection purposes. Currently an effort is underway in working with
local, state, and federal agencies as part of the Comprehensive Plan Task Force to identify
these acquisition areas. Such a change would not require any amendments to the
Comprehensive Plan or LDRs.
However, the staff is concerned about initiating changes to award ROGO points to areas
which are to be acquired primarily to "extinguish" development rights without having the
results of the Carrying Capacity Study and other supporting information to determine
ultimate build -out scenarios or options. Furthermore, as discussed previously, the staff
firmly believes that with the end of the present ROGO system, the County should move
forward to a true "lottery" system, which the staff believes is much more equitable and fair.
Such a new ROGO system can only be appropriately put in place after the County has
reached some consensus on build -out issues (where and how many residential and
transient residential units and non-residential should be accommodated over 20 years and
still achieve the sustainable development goals of the County) and designated specific
geographic areas of the Keys for in -fill development and acquisition. The location, types,
and of intensity of this development will be more beappriopriately addressed in the Livable
CommuniKeys master planning program. Progress continues to be made refining the
parcel layer of the County's Geographic Information System (GIS), which will enable the
County staff with assistance of other state and federal agencies to begin work on the
identification of these acquisition and development in -fill areas.
Page 4 of 8
Recommendation: The BOCC should direct staff to continue its efforts on identification of
land acquisition areas and areas suitable for further development to bring forward to the
Board for approval in accordance with the comprehensive plan amendment to be
prepared for the 20 year land acquisition and affordable housing plan discussed
previously.
Time Frame: The staff anticipates that working with the Comprehensive Plan Task Force,
that additional land acquisition areas for natural resources conservation and preservation
can be identified for approval by the BOCC by September 2001; areas needed to be
acquired primarily for extinguishing of development rights will be recommended to the
BOCC as will be outlined in the proposed comprehensive plan amendment.
Allow mobile or manufactured homes designed for 150 mph winds on affordable
housing properties: This proposal causes some concern for the Growth Management
Division for several reasons. It would encourage mobile homes in areas and zoning
districts where it is now prohibited, which will require amending the Comprehensive Plan.
The staff is concerned that manufactured housing is not a better alternative than modular
housing, which is only slightly more expensive and is not incompatible with conventionally
built housing. Affordable housing is already a Not -In -My -Backyard issue, by allowing
mobile homes in areas that now exclude them will only increase the resistance to
affordable housing.
Lastly, although manufactured housing can be modified to handle a 150 mph peak wind
load, it is still more susceptible to damage from debris and flying objects than conventional
and modular housing. Such damage can easily destroy the integrity of the mobile home to
withstand wind and rain in a storm.
Recommendation: The BOCC should drop this proposal from further consideration.
Time Frame: N/A
Create an affordable housing overlay zone: Essentially the ability for affordable
housing to receive higher density bonus including proposed changes to allow employee
housing with a density bonus in SC districts achieves the intent of an overlay zone. If the
BOCC is looking for a different approach, such as allowing attached housing for affordable
housing projects in IS zoned areas, the staff needs some direction. However, the staff
believes the an affordable housing overlay zone may be an option to address part of the
problem of the conversion of affordable housing to market rate housing (see next item).
Recommendation: The BOCC should provide further direction to staff on the concept of an
affordable housing overlay zone, if it believes that the proposed LDR changes to the SC
district are insufficient.
Time Frame: The staff anticipates that draft LDR changes allowing for density bonus for
employee housing will be before the BOCC in September of this year.
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• Don't allow modest/affordable housing to be replaced by significantly larger, non -
affordable housing, by making "replacement unit" for existing housing comparable
in square footage, if original house was below the square footage allowances for
affordable housing: An aggressive land acquisition program and further restrictions on
the availability of property for development in the Keys will not only increase the value of
existing residences, but place greater pressure on conversion of these structures with
larger ones. At this time, the staff is unsure how or should these conversions can be
legally restricted while at the same time not incurring the wrath of property owners;
however, further research needs to be done on this issue.
One major loophole in the Comprehensive Plan and LDRs (Section 9.5-268) is the
provision that entitles any lawfully established principal dwelling unit to be replaced no
matter what the density provisions of the zoning district in which it located. Although this
policy is intended to protect homeowners and permanent residents from losing their
residences in cases of an "act of God," it also allows developers to buy out over density
affordable housing developments, such as mobile home parks, and rebuild with market
rate housing at higher densities than allowed under the LDRs.
After hashing over several alternatives, the staff believes that one option has some merit
which would go a long way to protecting some of the affordable housing stock. The staff is
considering through amendments to the comprehensive plan and LDRs to create an
"affordable housing overlay zone" for all existing mobile home and trailer parks. These
parks are typically owned by a property owner, who leases out spaces for placement of
trailers. The trailers are generally owned by their occupants.
The overlay zone would protect the density of these parks, which are typically over density
as long as they are retained for mobile homes or restricted to affordable housing. If the
parks are to be redeveloped for conventional or modular housing, then an affordable
housing deed restriction would have to be placed on the property to retain the density.
Section 9.5-268 will also need to be revised to limit the on -site density replacement
entitlement of these mobile home parks.
Recommendation: The BOCC should request the staff to continue its efforts to develop
this approach to protecting and conserving existing affordable housing stock, as well as
other possible policies and regulations.
Time Frame: The staff anticipates that proposed comprehensive plan and LDR
amendments would come before the BOCC this fall.
• Link any new commercial development to the production of affordable housing,
either physical production of that housing or a monetary cost set -aside: In the
proposed Nonresidential Rate of Growth Ordinance (NROGO) provisions have been
included to require a nominal impact fee of $1 to $2 per square feet of new or transferred
commercial floor area for the Employee Fair Share Impact Fee. These fees are intended
to write down the costs of permitting and connection fees. For now, the proposed fees are
minimal due to the limited nature of the new development to be allowed under the
proposed system and the need for further study to identify an appropriate employee
housing linkage that is both fair, reasonable, and legally defensible.
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Although it may seem to be just a simple matter of establishing some high fee schedule
per square foot, further study is needed to establish in quantifiable terms the linkage
between nonresidential development and need for employee housing. The law is very
clear that in the establishment of any impact,fees, that the development (e.g., businesses)
must have caused a need for a facility (e.g., additional service workers increases the need
for additional employee housing) and that the development must benefit (e.g. additional
service workers can be accommodated to serve the businesses by the provision of
additional affordable housing) from the provision of this facility (e.g., additional employee
housing).
This linkage will be further examined as part of a land use market study for commercial
and transient residential development, which is to be completed over the next 12 months.
Recommendation: None
Time Frame: The proposed NROGO ordinance will be before the BOCC by July or
August, it is anticipated that with the completion of the nonresidential land use market
study sometime this year, proposed amendments to the Employee Fair Share Impact Fee
ordinance could be prepared later this year.
Any new multiple -unit market rate residential development should include a mix of
market -rate and affordable housing and should have caps on square footage to
encourage modest housing: The staff has already prepared proposed amendments to
the LDRs to provide for a mix of market rate and affordable housing. The proposed
amendments will be shortly submitted to the Development Review Committee to initiate the
approval process.
Recommendation: None.
Time Frame: The staff anticipates that proposed amendments to the LDRs to allow a mix
of housing will be before the BOCC in September.
Create incentives to encourage redevelopment of existing commercial space to
affordable housing. The existing LDRs already allow for the redevelopment of existing
commercial space to affordable housing, except that commercial floor space can be traded
for dwelling units; however, a property owner is required to go through ROGO for the
dwelling units. Although, commercial space can not be traded for dwelling units, the
proposed NROGO will allow demolition and off -site transfer of this floor space which will
help encourage the redevelopment of obsolete commercial space to affordable housing.
In addition, the staff has prepared proposed amendments to the LDRs that provide
incentives for the development of employee housing by reducing the development penalty
for developers of commercial development in Suburban Commercial Districts. The
proposed incentive will allow up between 2,000 and 4,000 square feet of floor area to be
exempted in determining the development density for employee housing constructed on
the same parcel.
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Recommendation: None
Time Frame: The staff anticipates that the proposed LDR amendments on NROGO will be
before the BOCC in July and the proposed amendments on changes in SC zoning district
by September of this year.
cc: James L. Roberts, County Administrator
Mark Rosch, Executive Director, Land Authority
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