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Item T9Meeting Date: _October 21, 2015 Department: Plannin.&Environmental Resources Bulk Item: Yes No X Staff Contact /Phone #: Mike Roberts (305)289-2502 AGENDA ITEM DING: A public hearing to consider approval of a resolution transmitting to the State Land Planning Agency an Ordinance by the Monroe County Board of County Commissioners amending the Livable Communikeys Program Master Plan for Future Development of Big Pine Key and No Name Key by amending the Tier Designation for property owned by Longstock II, LLC, having Real Estate Numbers 00300090-000000; 00300180-000000 00300590-000000 and 00300670- 000000 from Tier I to Tier III on Figure 2.1 (Tier Map For Big Pine Key And No dame Key). ITEM BACKGROUND: The property owner, Longstock II, LLC submitted a request to amend Figure 2.1 of the Livable CommuniKeys Program Master Plan for Future Development of Big Pine Key and No Name Key (LCP) by amending the Tier- Designation for Parcel #'s 00300090-000000; 00300180-000000; 00300590-000000 & 00300670-000000 from Tier I to Tier III. Being the LCP is incorporated by reference into the Monroe County 2010 Comprehensive Plan, amendments to the LCP require a text amendment to the Comprehensive Plan. The subject parcels consist of a developed RV Campground (the former Sea Horse RV Campground) containing 1.30 documented units, consisting of 125 transient units and 5 market rate units. The site is developed, scarified land and contains no native habitat. The Tier Map for Big Pine Key and No Name Key was developed based on relative wildlife habitat quality as defined in the Habitat Conservation Plan (HCP). Monroe County developed the Tier Maps pursuant to county -wide Smart Growth Initiatives adopted in Goal 105 of the Comprehensive Plan and Strategy 1.1 of the LCP. The Tier designations for parcels on Big Pine Key and No Narne Key are intended to be based upon habitat sensitivity identified in the HCP (see Tier descriptions below) and primarily as represented on the weighted Harvest Grid Map (Figure 2.5 of the HCP). The subject parcels do not meet the criteria for Tier I designation as provided in Policy 205.1.1, MCC § 130-130 or the Habitat Conservation Plan. Excerpt from Table 2.7 Tier classification system (vacant privately -owned lands). (HCP g. 43) Tier Description Lands where all or a significant portion of the land area is characterized as environmentally sensitive I and important for the continued viability of HCP covered species (mean H per 10x 10 meter cell = 0.259 x I0-). These lands are high quality Key deer habitat, generally representing large contiguous patches of native vegetation that provide habitat for other protected species as well. Scattered lots and fragments of environmentally sensitive lands that may be found in platted 2 subdivisions (mean H per 10 x 10 meter cell = 0.183 x 10-3). A large number of these lots are located on canals and are of minimal value to the Key deer and other protected species because the canal resents a barrier to dispersal. Scattered lots within already heavily developed areas that provide little habitat value to the Key deer 3 and other protected species (mean H per IOx10 meter cell = 0.168 x 10-3). Some of the undeveloped lots in this Tier are located between existing developed commercial lots within the US-1 corridor or are located on canals. 'H' values for the 1.0m2 cells within the subject parcels range between 0.000162 and 0.000188 and as noted above the parcels are scarified and contain no native habitat. Based on staffs analysis, the proposed amendment is consistent with the above Tier 3 description. PREVIOUS RELEVANT BOCC ACTION: On March 19, 2003 the Monroe County Board of County Commissioners (BOCC) approved Resolution 119-2003 authorizing submittal of the Habitat Conservation Plan for Key beer and other protected species on Big Pine Key and No Name Key (HCP). On December 17, 2003 the BOCC passed Resolution 5 2-2003 approving the Livable CommuniKeys Master Plan (LCP) for Big Pine Key and No Name Key as the policy document to direct growth and development of Big Pine Key and No Name Key. The LCP implements the HCP as well as provides for the development needs of the community. The LCP was completed in August 2004, adopted by the Board of County Commissioners on August 18, 2004 and incorporated by reference into the Monroe County 2010 Comprehensive Plan by Policy 101.20.2(1). The LCP was amended in June 2009 (Ordinance 020-2009) to revise certain figures to depict only the lands covered by the HCP; to implement the R.OGO requirements of the HCP'; to define the number of dwelling units to be permitted over the life of the Incidental Take Permit (ITP), including the limitations on Tier I development; to establish certain control dates for development and mitigation; and to regulate the construction of fences and accessory structures. On September 21, 2012 the BOCC adopted Ordinance 022-2012 to amend the LCP to amend the Tier designation on Figure 2.1 (Tier Map for Big Pine Key and No Name Key), and Table 2.7, Institutional Uses, for the Seacamp property from Tier I to Tier III. CONTRACT/AGREEMENT i1 ! CHANGES: 1 STAFF RECOMMENDATIONS: Staff recommends approval to amend the Master Plan for Future Development of Big Pine Key and No Name Key by amending the Livable Communieys Program Master Plan for the Future Development of Big Pine Key and No Name Key Tier Map (Figure 2.1) from Tier I to Tier III TOTAL1INDIRECTBUDGETED: • 1 .11 + rs r• REVENUE PRODUCING: Yes No ,w3 APPROVE Y: County Attorney to, DOCUMENTATION: Included Revised 6115 AMOUNT PER ONT Year OMB/Purchasing Risk Management - Not Required, 2. 1 � i� 4 5 7 8 MONROE COUNTY, FLORIDA 9 MONROE COUNTY BOARD OF COUNTY COMMISSIONERS 10 RESOLUTION NO. - 2015 11 12 A RESOLUTION BY THE MONROE COUNTY BOARD OF 13 COUNTY COMMISSIONERS TRANSMITTING TO THE 14 STATE LAND PLANNING AGENCY AN ORDINANCE BY 15 THE MONROE COUNTY BOARD OF COUNTY 16 COMMISSIONERS AMENDING THE LIVABLE 17 COMMUNIIEYS PROGRAM MASTER PLAN FOR FUTURE 18 DEVELOPMENT OF BIG PINE KEY AND NO NAME KEY 19 AMENDING THE TIER DESIGNATION FOR PROPERTY 20 OWNED BY LONGSTOCK 1I, LLC, HAVING REAL ESTATE 21 NUMBERS 00300090-000000;00300180-000000;00300590- 22 000000 AND 00300670-000000 FROM TIER I TO TIER III O 23 FIGURE 2.1 (TIER MAP FOR BIG PINE KEY AND NO NAME 24 KEY). 25 26 27 WHEREAS, the Monroe County Board of County Commissioners conducted a public 28 hearing for the purpose of considering the transmittal to the State Land Planning .Agency a 29 proposed amendment to the Monroe County 2010 Comprehensive Plan as described above; and 30 31 WHEREAS, the Monroe County Planning Commission and the Monroe County Board 32 of County Commissioners support the requested text amendment; and 33 34 NOW THEREFORE, BE IT RESOLVED BY THE BOARD OF COUNTY 35 COMMISSIONERS OF MONROE COUNTY, FLORIDA: 36 37 Section 1: The Board of County Commissioners does hereby adopt the recommendation of 38 the Planning Commission to transmit the draft ordinance, attached as Exhibit A, 39 for adoption of the proposed text amendment. 40 41 Section 2: The Board of County Commissioners does hereby transmit the proposed 42 amendment to the State Land Planning Agency for review and comment in 43 accordance with the State Coordinated Review process pursuant to Section 44 163.3184(4), Florida Statutes. 45 Resolution No, Oxx - 2015.Pane 1 of 2 46 47 48 49 50 51 52 53 54 55 56 57 Section 3: The Monroe County staff is given the authority to prepare and submit the required transmittal letter and supporting documents for the proposed amendment. Section. 4: The Clerk of the Board is hereby directed to forward a certified copy of this resolution to the Senior Director of Planning and Environmental Resources, PASSED► AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting held on the 2l'` day of October, 2015. 58 59 60 61 62 Attest: AMY HEAVILIN, CLERK 63 64 65 By: 66 Deputy Clerk 67 68 (SEAL) Mayor Danny E. lolhage Mayor Pro Tem Heather Carruthers Commissioner George Neugent Commissioner David Rice Commissioner Sylvia Murphy BOARD OF COUNTY COMMISSIONERS OF MONROE COUNTY, FLORIDA M. Mayor Danny L. Kolhage Resolution No. Oxx - 2015 Page 2 of 2 Exhibit A to Transmittal Resolution -2015 1� 3 4q t 5 6 7 ORDINANCE 2015 8 9 AN ORDINANCE Y THE MONROE COUNTY BOARD OF COUNTY 10 COMMISSIONERS AMENDING THE LIVABLE COMMUNIKEYS 11 PROGRAM MASTER PLAN FOR FUTURE DEVELOPMENT OF BIG 12 PINE KEY AND NO NAME KEY AMENDING THE TIER DESIGNATION 13 FOR PROPERTY OWNED BY LON STO K 11, LLC, HAVING REAL 14 ESTATE NUMBERS 00300090-0000;0030010-0000;00300590-00000 15 AND 00300670-000000 FROM TIER I TO TIER III ON FIGURE 2.1 (TIER 16 MAP FOR BIG PINE KEY AND NO NAME KEY); PROVIDING FOR 17 SEVEABILITY; PROVIDING FOR THE REPEAL OF INCONSISTENT 18 PROVISIONS; PROVIDING FORT E TRANSMITTAL TO THE STATE 19 LAND PLANNING AGENCY; PROVIDING FOR THE FILING WITH THE 20 SECRETARY OF STATE AND FOR AN EFFECTIVE ATE; AND 21 PROVIDING FOR THE INCLUSION IN THE MON OE COUNTY 2010 22 COMPREHENSIVE PLAN. 23 24 25 WHEREAS, on December 17, 2003 the BOCC passed Resolution 562-2003 approving the 26 Livable CommuniKeys Master Plan (LCP) for Big Pine Key and No Name Key as the policy 27 document to direct growth and development of Big Pine Key and No Name Key. The LCP 28 implements the habitat Conservation Plan (HCP) as well as provides for the development needs 29 of the community; and 30 31 WHEREAS, the LCP was completed in August 2004, adopted by the Board of County 32 Commissioners on August 18, 2004 and incorporated by reference into the Monroe County 2010 33 Comprehensive Plan by Policy 1.01.20.2(1); and 34 35 WHEREAS, Longstock I1, LLC submitted an application requesting to amend Figure 2.1 of 36 the Livable CommuniKeys Program Master Plan for Future Development of Big Pine Key and 37 No blame Key by amending the Tier Designation for Parcel #'s 00300090-000000; 00300180- 38 000000; 00300590-000000 & 00300670-000000 from Tier I to Tier III; and 39 40 WHEREAS, the Monroe County Development Review Committee considered the proposed 41 amendment at a regularly scheduled meeting held on the 28th day of July, 2015; and 42 43 WHEREAS, at a regularly scheduled meeting held on the 261h day of August, 2015, the 44 Monroe County Planning Commission held a public hearing for the purpose of considering the 45 transmittal to the State Land Planning Agency, for review and comment, a proposed amendment 46 to the Monroe County Year 2010 Comprehensive Plan; and 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 Exhibit A to Transmittal Resolution -2015 WHEREAS, The Monroe County Planning Commission requested additional detail regarding the analysis of the proposed amendment and continued the hearing until September 30, 2015; and WHEREAS, at a regularly scheduled meeting held on the 30tn day of September, 2015, the Monroe County Planning Commission resumed the public hearing for the purpose of considering the transmittal to the State Land Planning Agency, for review and comment, the proposed amendment to the Monroe County Year 2010 Comprehensive Plan; and WHEREAS, the Monroe County Planning Commission made the following findings: 1. The proposed amendment is not anticipated to adversely impact the community character of the surrounding area; and 2. The proposed amendment is consistent with the Goals, Objectives and Policies of the Monroe County Year 2010 Comprehensive Plan; and 3. The proposed amendment is consistent with the Livable CommuniKeys Master Plan for Big Pine Key and No Name Key and the Habitat Conservation Plan; and . The proposed amendment is consistent with the Principles for Guiding Development for the Florida Keys Area of Critical State Concern, Section 380.0552(7), Florida Statute; and 5. The proposed amendment is consistent with Part II of Chapter 163, Florida Statute. WHEREAS, at a regular meeting held on the 21" day of October 2015, the Monroe County Board of County Commissioners held a public hearing to consider the transmittal of the proposed amendment, considered the staff report and provided for public comment and public participation in accordance with the requirements of state law and the procedures adopted for public participation in the planning process; and WHEREAS, at the October 21, 2015, public hearing, the BOCC voted to the amendment to the State Land Planning Agency; and WHEREAS, the State Land Planning Agency reviewed the amendment and issued an Objections, Recommendations and Comments (ORC) Report on 20— which. did not identify any issues with the proposed amendment; and WHEREAS, the ORC report states_ a response to the ORC Report, Monroe County and as 2 Exhibit A to Transmittal Resolution -2015 92 NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS ISSIONERS OF ON OE COUNTY, FLORIDA: �9'y3 4 95 Section 1. The Livable CommuniKeys Master Plan for Big Pine Key and No Name Key as 96 adopted by reference into the Monroe County 2010 Comprehensive Plan is 97 amended as follows: 98 99 (1) Amending the Tier designations on Figure 2.1 for four (4) parcels having real 100 estate numbers 00300090-000000;00300180-000000;00300590-000000 and 101 00300670-000000 from Tier I to Tier III as shown on Exhibit 1 attached 102 hereto and incorporated herein. 103 104 Section 2. Sever bility. If any section, subsection, sentence, clause, item, change, or 105 provision of this ordinance is held invalid, the remainder of this ordinance shall 1.06 not be affected by such validity. 107 108 Section 3. Repeal of Inconsistent Provisions. All ordinances or parts of ordinances in 109 conflict with this ordinance are hereby repealed to the extent of said conflict. 110 111 Section 4. Transmittal. This ordinance shall be transmitted by the Director of Planning to 112 the State Land Planning Agency pursuant to Chapter 163 and 380, Florida 113 Statutes. 114 115 Section 5. Filing and E ective Date. This ordinance shall be filed in the Office of the 116 secretary of the State of Florida but shall not become effective until a notice is 117 issued by the State Land Planning Agency or Administration Commission 118 finding the amendment in compliance with Chapter 163, Florida Statutes and 1.1.9 after any applicable appeal periods have expired. 120 121 Section 6. Inclusion in the Comprehensive Plan. The number of the foregoing 122 amendment may be renumbered to conform to the numbering in the Livable 123 CommuniKeys Master Plan for Big Pine Key and No Name Key as adopted by 124 reference into the Monroe County 2010 Comprehensive Plan and shall be 125 incorporated in the Livable CommuniKeys Master Plan for Big Pine Key and 126 No Name Key. 127 3 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 14$. 149 Exhibit A to Transmittal Resolution -2015 PASSED AND ADOPTED by the Board of County Commissioners of Monroe County, Florida, at a regular meeting held on the day of , 2015. Mayor Danny L. Kolhage Mayor pro tent Heather Carruthers Commissioner David Rice Commissioner George Neugent Commissioner Sylvia Murphy VOARD OF !UNTY COMMISSIONERS OF ! COUNTY,l• 1. (SEAT.,) ATTEST: AMY HEAVILIN, CLERK IM Mayor Danny L. K:olhage MONROE COUNTY ATTORNEY • AS . ASSISTANT QOVNTX ATTORNEY ff MEMORANDUM MONROE COUNTY PLANNING & ENVIRONMENTAL RESOURcEs DEPARTMENT We strive to be caring, professional and,tair To: The Monroe County Board of County Commissioners Through: Mayt6 Santamaria, Senior Director of Planning & Environmental Resources From: Michael Roberts, Sr. Administrator, Environmental Resources Date: September 30, 2015 Subject: Request for an Amendment to Figure 2.1 of the Livable CommuniKeys Program Master Plan fior the Future Development of Big Pine Ivey and No Name Key Tier Map from Tier I to Tier .III, far property owned by Longstock II, LLC located on Big Pine Ivey, having real estate no's. 00300090-000000; 003001 80-000000; 00300590-000000 & 00300670-000000 (File 2015-116) Meeting; October 21, 2015 1 2 I REQUEST 3 4 A request to amend Figure 2.1 of the Livable CommuniKeys Program Master Plan for Future 5 Development of Big Pine Key and No Name Key by amending the Tier Designation for 6 Parcel Ws 00300090-000000; 00300180-000000; 00300590-000000 & 00300670-000000 7 from Tier I to Tier III (Exhibit I). 8 Subject Parcels (outlined in blue) (2012) File No. 2015-1 16 Pg. 1 1 11 BACKGROUND INFORMATION & RELEVANT PRIOR COUNTY ACTIONS 2 3 Site Information 4 Address: 201 County Road, Big Pine Key 5 Legal Description: Lots 1, 2, 3, 4 and 5 Block 1; Lots 1 through 1.8 Block 2 Sam-N-Joe 6 Subdivision Plat Book 3 Page 76 of the Public Records of Monroe County Florida and 7 Lots 1 through 9, Block 3, Darios Subdivision Plat Book 3 Page 92 of the Public Records 8 of Monroe County Florida. 9 Real Estate (RE) Numbers: 00300090-000000; 00300180-000000; 00300590-000000 & 10 00300670-000000 1.1 Applicant: Longstock 11, LLC 12 Size of Site: 3.93 acres 13 Land Use District(s): IS (North 1/z) and URN (South 1/2) 14 FLUM Designation: RM (North 1/2) and RH (South 1/2) 15 Tier Designation: I 16 Flood Zone: AE - 8 17 Existing Use: Sea Horse RV Campground 18 The parcel consists of a developed RV Campground containing 130 documented units, 19 consisting of 125 transient units and 5 market rate units (Letter of Development Rights 20 Determination dated 9/29/2014). 21 Existing Vegetation / Habitat: Scarified; Developed Land 22 Community Character of Immediate Vicinity: The surrounding community is a mix of dense 23 residential development interspersed with sparsely developed and undeveloped areas. The 24 adjacent land use (zoning) districts consist of IS, URM and SR land use districts. 25 26 0 On March 19, 2003 the Monroe County Board of County Commissioners (BOCC) 27 approved Resolution 119-2003 authorizing submittal of the Habitat Conservation Plan for 28 Key Deer and other protected species on Big Pine Key and No Name Key (HCP). 29 d On December 17, 2003 the BOCC passed Resolution 562-2003 approving the Livable 30 CommuniKeys Master Plan (LCP) for Big Pine Key and No Name Key as the policy 31 document to direct growth and development of Big Pine Key and No Name Key. The 32 LCP implements the HCP as well as provides for the development needs of the 33 community. 34 ® The LCP was completed in August 2004, adopted by the Board of County 35 Commissioners on August 1.8, 2004 and incorporated by reference into the Monroe 36 County 2010 Comprehensive Plan by Policy 101.20.2(1). 37 0 The LCP was amended in June 2009 (Ordinance 020-2009) to revise certain figures to 38 depict only the lands covered by the HCP; to implement the ROGO requirements of the 39 HCP; to define the number of dwelling units to be permitted over the life of the Incidental 40 Take Permit (ITP), including the limitations on Tier I development; to establish certain 41 control dates for development and mitigation; and to regulate the construction of fences 42 and accessory structures. File No. 2015-116 p g. 2 I The Board of County Commissioners adopted Ordinance 022-2012 on September 21, 2 2012 to amend the Livable CommuniKeys Program Master Plan for Future Development 3 of Big Pine Key and No Name Key, to amend the Tier designation on Figure 2.1 (Tier 4 Map for Big Pine Key and No Name Key), and Table 2.7, Institutional Uses, for the 5 Seacamp property from Tier I to Tier III, as directed by the Board. of County 6 Commissioners in Resolution 562-2003. 7 8 DRC Review 9 At its regularly scheduled meeting on July 28, 2015, the Monroe County Development. 10 Review Committee reviewed the proposed amendment. The information provided in the staff l I report and discussed at the meeting supports the Chair's decision to recommend approval to 12 the Planning Commission and Board of County Commissioners. 13 14 PC Review 15 At its regularly scheduled meeting on August 26, 2015, the Monroe County Planning 16 Commission reviewed the proposed amendment. The Planning Commission requested staff 17 to provide additional data related to the potential for impacts to the Key deer and continued 18 the request to the September 30, 2015 meeting date. 19 20 At its regularly scheduled meeting on September 30, 2015, the Monroe County Planning 21 Commission reviewed the proposed amendment. The information provided in the staff report 22 and discussed at the meeting supports the Planning Commission's decision to recommend 23 approval to the Board of County Commissioners.. 24 25 111 PROPOSED AMENDMENT 26 27 Request for an Amendment to Figure 2.1 of the Livable CommuniKeys Program Master Plan 28 for the Future Development of Big Pine Key and No Name Key Tier Map from Tier I to Tier 29 II1, for property owned by Longstock 11, LLC, Big Pine Key, having real estate no's. 30 00300090-000000; 00300180-000000; 00300590-000000 & 00300670-000000, as depicted 31 below. 32 File No. 2015-116 pg. 3 a 2 3 4 Existing, Adopted Figure 2.1 Fi Lyure 2. 1: F_1�]Ure 2. 1 Inset rdap Proposed Amendment fo� Parrels:� - j ■ 5 6 7 8 Review of Amendment 9 10 The Tier Maps for Big Pine Key and No Name Key has been developed based on relative I I wildlife habitat quality as defined in the Habitat Conservation Plan (HCP). Monroe County 12 developed the Tier Maps pursuant to county -wide Smart Growth Initiatives adopted in Goal 13 105 of the Comprehensive Plan and Strategy 1.1 of the LCP. 14 File No. 2015-116 pg- 4 I "The Habitat Conservation Plan (HCP) focuses on the Key deer as an "umbrella species" and 2 operates under the assumption that avoiding and minimizing impacts to Key deer habitat, will 3 also provide direct protection to both populations and habitats of other terrestrial species. In 4 the development of the HCP, the ecology and population dynamics of the Key deer was 5 studied for• three years and a Population Viability Analysis (PVA) model, including a spatial 6 component, was produced to evaluate the impacts of development scenarios on the Key deer 7 population. Based on the Key deer studies done for the HCP and the resulting spatial model, 8 lands in the study area were classified into three "Tiers," Tier 1 lands are higher quality Key 9 deer habitat. Tier 3 Lands are the lowest quality Key deer habitat. Most of the parcels in Tiers 10 2 and 3 are interspersed among developed parcels and among canals. These areas provide 1 I little habitat value to the covered species." (Pg. 2 Habitat Conservation Plan) 12 13 As noted in the HCP, "the Key deer are wide ranging and utilize virtually all available habitat 14 in the project area, including developed areas (Figure 2.1, Lopez 2001)." Figure 2.1 does 15 indicate the utilization or distribution of Key deer, during the 3 year study period, within or 16 adjacent to the subject properties but it is not as significant as other locations. (Pg. 20 Habitat 17 Conservation Plan). 18 19 20 21 22 23 24 25 26 27 File No. 2015-116 pg. 5 I Figure 2.2 (Exhibit 5) of the HCP provides the Lower Keys marsh rabbit habitat, as identified 2 by the U.S. Fish and Wildlife Service. This figure displays the Lower Keys marsh rabbit 3 habitat on Big Pine Key and No Name Key (Faulhaber 2003) based on the most recent data 4 on its distribution within the covered area (Figure 2.2), Figure 2.2 does not indicate Lower 5 Keys marsh rabbit habitat within or adjacent to the subject properties. (Pg. 23 Habitat 6 Conservation Plan), 7 8 9 20M Raba HaU'ta'l FON Daoffei 10 12 13 14 15 Approximate location 16 of subject parcels 17 18 19 20 21 22 Figure 2- .2Lower Keys marsh rabbit habitat (Source: United States Fish and Wildlife 23 senice). 24 25 As provided on page 35 of the HCP: 26 27 In order to address impacts to carrying capacity and mortality, the spatial 28 model includes a carrying capacity and a "harvest" (i.e., human -related 29 mortality) grid in a Geographic Information System (IS). The grids 30 represent the entire study area as an array of lOxlO meter cells; each 31 cell's value represents its contribution to the total carrying capacity or 32 harvest of the study area. 33 34 A weighting factor grid supported the development of the carrying 35 capacity and harvest grids. The objective of the weighting grid was to 36 address location -specific conditions that affect carrying capacity and 37 harvest. For example, two grid cells of the same vegetation type may 38 contribute differently to the carrying capacity of the Key deer depending 39 on their proximity to canals: a pineland cell located in the middle of 40 large pineland area would provide better habitat to the Key deer than an 41 isolated pineland cell surrounded by canals. Similarly, development of a 42 pineland cell near US-] would create a lesser vehicle collision impact 43 (due to shorter travel distance to US -I} than development of pineland 44 cell located farfrom US-] (due to the longer travel distance to US -I). 45 46 Six parameters entered into the weighting factor grid (Figure 2.4): 47 File No. 2015-116 perL_, 6 5 6 7 8 9 10 11 12 13 Figure 2.4 (Exhibit 6) depicts the 6 grid layers used to generate the weighting factor for the final carrying capacity grid. The deer corridor deer density, house density and distance from US 1 parameters reflect low utilization of the subject properties by Key deer. The final carrying capacity grid (Figure 2.5) represents the contribution of each 1 W0 meter cell to the total carrying capacity of the study area after applying the weighting factor. Lopez (2001) estimated the number of Key deer that could be supported by available habitat in Big Pine Key and No Name Key. The final harvest grid represents the proportional contribution of each 1Ox10 meter cell to the total harvest in the study area. Lopez (2001) determined that approximately 8.4 percent of the File No2015-116 pg. 7 I deer population dies from human -related causes (total mortality is about 17 percent). He 2 allocated this percentage equally among all the lox l O meter cells for the study area. Then, he 3 applied the weighting factor to each cell; the result was a differential contribution of the cells 4 to the total human related mortality, or harvest, H. 5 Harvest Grid File No. 2015-116 pg. 8 Carrying Capacity Grid Figure 2.5. Key deer PVA model grid layers (darker shades = higher value for the deer) 2 For the Big Pine Key and No Name Key planning, area the Tier Maps are intended to be 3 based upon habitat sensitivity identified in the HCP, primarily as represented on the weighted 4 Harvest Grid Map (Figure 2.5 of the HCP, above). 5 File No. 2015-116 Pg- 9 In response to the Planning Commission request for additional scientific detail, Dr. Roel Lopez (Texas A&M University) provided the original harvest grid data to the Planning & Environmental Resources Department on. September 1, 2015 in order for staff to more closely evaluate the H values for the subject parcels. rotst # i .t1k Ai t?�nx pYpp `, �' Rl St S{t P 4 5..t gp S f 4 1 f �€ t y ,r S4 3R 1(41; {' n ? iS�d)€���?{ �r{fin �� �`;}t11Fs E� x✓�� 1? a:t i ! S� �r ��? t}? s ':i` ?'�)�; tl Fk dJt� `it ���? i {, ���k��kka � �,.,�'; Legend It i t AtM11t , BPK_Ft _Grid i 1 F' fea Value( High : 0.000260112 F `��ri�?? �.? � � �"{f '��. y{ }c !� : { i' '}��s �d�s 1Gsl �tiips%�L 'Low:0 s ( I, Y`�' t t(d-b LP�ivs StYSt„'F+llY,(x��`s�t4�t§i{';tii�?5ri H-grid data provided by Roel Lopez, PhD. Texas A&M University Subject parcels outlined in blue The `H' grid data provided by Dr. Lopez reflects the low habitat value of the subject parcels. The actual `H' values for the subject parcels range from 0,000176 to 0.000188 per 10 x 10 meter cell, well below the Tier I mean of 0.000259, The subject parcels are developed land outside existing deer corridors (HCP Figure 5.2, below) and do not meet the criteria for Tier I designation as provided in Policy 205.1.1, MCC §130-130 or the Habitat Conservation Plan, as noted below: File No. 201 5-1 l 6 pa. 10 4 5 6 7 8 9 HCP Figure 5.2 Key deer corridor across Sands Subdivision Sands corridor with subject parcels in blue File No. 2015-116 Pg, 11 1 2 3 4 H-Grid depicting deer corridor from Figure 2.4 (page 7 of this report) and the Sands Corridor from Figure 5.2 with subject parcels in blue 5 The Big Pine Key and No Name Key planning area the Tier Maps are intended to be based 6 upon habitat sensitivity identified in the HCP, primarily as represented on the weighted 7 Harvest Grid Map (Figure 2.5 of the HCP). The HCP describes the habitat description and 8 associated H values that should be reflected in the Tier designation. These descriptions are 9 provided in Table 2.7 (below). 10 11 Table 2.7 (HCP pg. 3) 'Fier classification system (vacant rivately-owned lands) 12 Tier I Description Lands where all or a significant portion of the land area is characterized as environmentally sensitive and important for the continued viability of HCP covered species (mean H per 1 10x10 meter cell = 0.259 x 1.0-'). These lands are high quality Key deer habitat, generally representing large contiguous patches of native vegetation that provide habitat for other protected species as well. Scattered lots and fragments of environmentally sensitive lands that may be found in platted 2 subdivisions (mean H per 10 x10 meter cell = 0.183 x 10-3). A large number of these lots are located on canals and are of minimal value to the Key deer and other protected species because the canal presents a barrier to dispersal. Scattered lots within already heavily developed areas that provide: little habitat value to the 3 Key deer and other protected species (mean H per 10x 10 meter cell = 0.168 x 10--). Some of the undeveloped lots in this Tier are located between existing developed commercial lots within the US-1 corridor or are located on canals. File No. 2015-116 pg. 12 I The proposed amendment is consistent with the above Tier descriptions. The site is 2 developed and the mean H value per 10 x 10 meter cell is 0.000182 (0.182 x 10-3). 3 4 The `H' values for the associated Darcels are: Sea Horse RV Park feet) from TAMU data rr r�r rrrrrr r rr M, .1r r r r rr 'i'r .r rrrrrr rr rr �r r�rrrr ® r rr• r rrr 0030 0-0i 7 Mr 5 6 In addition to the `H' values described above, the HCP provides qualitative criteria for each 7 Tier. The table below provides the qualitative description of each Tier and a comparison of 8 the site characteristics to the specified criteria. 9 10 Tier Description Subject Parcels Site Characteristics Lands where all or a significant 0 The subject parcels are scarified portion of the land area is and densely developed with NO characterized as environmentally environmentally sensitive habitats sensitive and important for the 0 As stated above, the subject site continued viability of HCP covered does not contain native vegetation 1 species. that provides habitat for Key deer a High quality Key deer habitat, or other protected species generally representing large contiguous patches of native vegetation that provide habitat for other protected species as well Scattered lots and fragments of The subject parcels are close to environmentally sensitive lands that suitable habitat, however the may be found in platted subdivisions parcels themselves are scarified 2 m Located on canals and are of and are platted subdivisions minimal value to the Key deer and (Dario's and Sam'N'Joe) other protected species because the � Parcels are not. on a canal —and canal presents a barrier to dispersal no barrier to Key deer dispersal is resent. Scattered lots within already heavily ® The subject parcels are heavily developed areas that provide little developed subdivisions and habitat value contain no habitat. 78% of land 3 a Some undeveloped hots are located within 500' is developed land. between existing developed • No commercial uses are adjacent commercial lots within the US -I to the subject parcels, corridor or, 9 The site is not located on a canal ® are located on canals. File No. 2015-116 pg. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 There is no `H5 impact associated with the proposed amendment to the Master flan. The subject parcel contains no native habitat and supported 130 lawfully established units. The amount of H impact for this type of development is based on traffic generation because vehicle collisions with Key deer are the most important human -related cause of mortality for the Key deer (HCP page 41). Based on the average daily trip assumptions in the HCP (9.5 A.DT/unit), the 130 units developed on the site generate 1,235 average daily trips (ADT). The subject parcels lie partially within the IS land use district (north 1/2) and partially within the URM land use district (south 1/2). The corresponding FLUM designations are Residential Medium (R) on the north and Residential High (RH) on the south. There is no change proposed for the site's land use district or FLUM designations. Note that as originally platted, the four parcels consisted of 32 platted lots. Land Use District Future Land Use -34. COISISTENCY WITH THE MONROE COUNTY YEAR 2010 COMPREHENSIVE PLAN, THE FLORIDA STATUTES, AND PRINCIPLES FOR GUIDING DEVELOPMENT A. The proposed amendment is consistent with the fallowing Goals, Objectives an Policies of the Monroe County Year 20�10 Comprehensive Plan. Specifically, the amendment furthers: Gaul 101 Monroe County shall manage future growth to enhance the quality of life, ensure the safety of County residents and visitors, and protect valuable natural resources. File No. 2015-116 pg. 14 Objective 101.20 Monroe County shall address local community needs while balancing the needs of all Monroe County communities. These efforts shall focus on the human crafted environment and shall be undertaken through the Livable CommuniKeys Planning Program. GOAL 105 Monroe County shall undertake a comprehensive land acquisition program and smart growth initiatives in conjunction with its Livable CommuniKeys Program in a manner that recognizes the finite capacity for new development in the Florida Keys by providing economic and housing opportunities for residents without compromising the biodiversity of the natural environment and the continued ability of the natural and man-made systems to sustain livable communities in the Florida Keys for future generations. Qjective 105.1 Monroe County shall implement smart growth initiatives in conjunction with its Livable CommuniKeys and Land Acquisition Programs which promote innovative and flexible development processes to preserve the natural environment, maintain and enhance the community character and quality of life, redevelop blighted commercial and residential areas, remove barriers to design concepts, reduce sprawl, and direct future growth to appropriate infill areas. Policy 10.2.1 Monroe County shall designate all lands outside of mainland Monroe County, except for the Ocean Reef planned development, into three general categories for purposes of its Land Acquisition Program and smart growth initiatives in accordance with the criteria in Policy 205.1.1. These three categories are: Natural Area (Tier 1); Transition and Sprawl Reduction Area (Tier II) on Big Pine Key and No Name Key only, and Infili Area (Tier III). The purposes, general characteristics, and growth management approaches associated with each tier are as follows:. 1. Natural Area (Tier 1). Any defined geographic area where all or a significant portion of the land area is characterized as environmentally sensitive by the policies of this Plan and applicable habitat conservation plan, is to be designated as a Natural Area. New development on vacant land is to be severely restricted and privately owned vacant lands are to be acquired or development rights retired for resource conservation and passive recreation purposes. However, this does not preclude provisions of infrastructure for existing development. Within the Natural Area. designation are typically found lands within the acquisition boundaries of federal and state resource conservation and park areas, including isolated platted subdivisions; and privately -owned vacant lands with sensitive environmental features outside these acquisition areas. 2. Transition and Sprawl Reduction Area (Tier II): Any defined geographic area on Big Pine Key and No Name Key, where scattered groups and fragments of environmentally sensitive lands, as defined by this Plan, may be found and where existing platted subdivisions are not predominately developed, not served by complete infrastructure facilities, or not within close proximity to established commercial areas, is to be designated as a Transition and Sprawl Reduction Area. New development is to be discouraged and privately owned vacant lands acquired or development rights retired to reduce sprawl, ensure that the Keys carrying capacity is File No201.5-11 b po, 15 I not exceeded, and prevent further encroachment on sensitive natural resources. 2 Within a Transition and Sprawl Deduction Area are typically found: scattered small 3 non-residential development and platted subdivisions with less than 50 percent of the 4 lots developed; incomplete infrastructure in terms of paved roads, potable water, or 5 electricity; and scattered clusters of environmentally sensitive lands, some of which 6 are within or in close proximity to existing platted subdivisions. 7 8 3. Infill Area (Tier 111): Any defined geographic area, where a significant portion of Land 9 area is not characterized as environmentally sensitive as defined by this Plan, except 10 for dispersed and isolated fragments of environmentally sensitive lands of less than I four acres in area, where existing platted subdivisions are substantially developed, 12 served by complete infrastructure facilities, and within close proximity to established 13 commercial areas, or where a concentration of non-residential uses exists, is to be 14 designated as an Infill Area. New development and redevelopment are to be highly 15 encouraged, except within tropical hardwood hammock or pineland patches of an acre 16 or more in area, where development is to be discouraged. Within an. Infill Area are 17 typically found: platted subdivisions with 50 percent or more developed lots situated 18 in areas with few sensitive environmental features; full range of available public 19 infrastructure in terms of paved roads, potable water, and electricity; and 20 concentrations of commercial and other non-residential uses within close proximity. 21 In some Infill Areas, a mix of non-residential and high -density residential uses 22 (generally 8 units or more per acre) may also be found that form a Community 23 Center. 24 25 Policy 201 .1.1 The County shall establish the following criteria at a minimum to use when 26 designating Tiers:: 27 2. Lands on Pig Pine Ivey and No Name Ivey designated as Tier I, 11, or III shall be in 28 accordance with the wildlife habitat quality criteria as defined in the Habitat 29 Conservation Plan for those islands. 30 31 Big Pine Key/No Name Ivey Livable Cornmuni eys Plan 32 33 Strategy 1.1 34 Create a Tier Map for the planning area depicting the locations of Tier 1, Tier 11 and Tier 35 I1I lands as described in Comprehensive Plan Policy 105.2.1. Base the Tier Map on the 36 habitat needs of federally endangered resident species in the planning area as set forth in 37 the anticipated ITP and HCP in terms of relative H of parcels within the planning area. 38 39 Strategy_ 1,.2 40 Assign relative H units to all parcels within the planning area as per the method described 41 in the HCP in order to ensure compliance with the permitted level of tape of federally 42 endangered species contained in the anticipated ITP. 43 44 Action Item 1.2.1 K 45 Use the parcel -specific H unit spreadsheet included with the HCP to assign H to 46 individual parcels within the planning area. File No. 2015-116 pa. 16 H 2 Action Item 1..2: 3 For development proposal applications involving multiple parcels, sum the H units for the individual parcels to generate the total H impact of the development. 5 6 Strategy 2.1 Continue to utilize the Land Use District Maps and supporting FLUM to 7 regulate land use type, density and intensity on an individual parcel basis within the 8 planning area. The distribution of future development shall be guided by a Tier System 9 Overlay Map pursuant to the Comprehensive Plan Smart Growth Initiatives (Goal 105). 10 11 Action 2.1.2 Adopt the Tier System Map separate from but as an overlay of the Land 12 District Maps. The Tier System Overlay Map shall be used primarily to guide the 13 distribution of development through the application of the residential rate of growth 14 ordinance and the non-residential rate of growth ordinance pursuant to the strategies set 15 forth in this Master Plan. 16 B. The proposed amendment is consistent with the Principles for Guiding Development 17 for the Florida Keys Area, Section 380.0552(7), Florida ,Statutes. 18 19 For the purposes of reviewing consistency of the adopted plan or any amendments to that 20 plan with the principles for guiding development and any amendments to the principles, the 21 principles shall be construed as a whole and no specific provision shall be construed or 22 applied in isolation from the other provisions. 23 24 (a) To strengthen local government capabilities for managing land use and development 25 so that local government is able to achieve these objectives without the continuation of 26 the area of critical state concern designation. 27 (b) To protect shoreline and marine resources, including mangroves, coral reef 28 formations, seagrass beds, wetlands, fish and wildlife, and their habitat. 29 (c) To protect upland resources, tropical biological communities, freshwater wetlands, 30 native tropical vegetation (for example, hardwood hammocks and pinclands), dune ridges 31 and beaches, wildlife, and their habitat. 32 (d) To ensure the maximum well-being of the Florida Keys and its citizens through sound 33 economic development. 34 (e) To limit the adverse impacts of development on the quality of water throughout the 35 Florida Keys. 36 (f) To enhance natural scenic resources, promote the aesthetic benefits of the natural 37 environment, and ensure that development is compatible with the unique historic 38 character of the Florida Keys. 39 (g) To protect the historical heritage of the Florida Keys. 40 (h) To protect the value, efficiency, cost-effectiveness, and amortized life of existing and 41 proposed major public investments, including: 42 1. The Florida Keys Aqueduct and water supply facilities; 43 2. Sewage collection and disposal facilities; 44 3. Solid waste collection and disposal facilities; File No. 2015-116 pg. 17 1 4. Key West Naval Air Station and other military facilities; 2 5. Transportation facilities; 3 6. Federal parks, wildlife refuges, and marine sanctuaries; 4 7. State parks, recreation facilities, aquatic preserves, and other publicly owned 5 properties; 6 8. City electric service and the Florida Keys Electric Co-op; and 7 9. Other utilities, as appropriate. 8 (i) To limit the adverse impacts of public investments on the environmental resources of 9 the Florida Keys. 10 0) To make available adequate affordable housing for all sectors of the population of the 11 Florida Keys. 12 (k) To provide adequate alternatives for the protection of public safety and welfare in the 13 event of a natural or manmade disaster and for a post disaster reconstruction plan. 14 (1) To protect the public health, safety, and welfare of the citizens of the Florida Keys and 15 maintain the Florida Keys as a unique Florida resource. 16 17 C. The proposed amendment is consistent with Part II of Chapter 163, Florida Statutes 18 (F.S.). Specifically, the amendment furthers: 19 20 163.3161(4), F.S. — It is the intent of this act that local governments have the ability to 21 preserve and enhance present advantages; encourage the most appropriate use of land, 22 water, and resources, consistent with the public interest; overcome present handicaps; and 23 deal effectively with future problems that may result from the use and development of 24 land within their jurisdictions. Through the process of comprehensive planning, it is 25 intended that units of local government can preserve, promote, protect, and improve the 26 public health, safety, comfort, good order, appearance, convenience, law enforcement and 27 fire prevention, and general welfare; facilitate the adequate and efficient provision of 28 transportation, water, sewerage, schools, parks, recreational facilities, housing, and other 29 requirements and services; and conserve, develop, utilize, and protect natural resources 30 within their jurisdictions. 31 32 163.3161(6), F.S. - It is the intent of this act that adopted comprehensive plans shall have 33 the legal status set out in this act and that no public or private development shall be 34 permitted except in conformity with comprehensive plans, or elements or portions 35 thereof, prepared and adopted in conformity with this act. 36 37 163.3177(1), F.S. - The comprehensive plan shall provide the principles, guidelines, 38 standards, and strategies for the orderly and balanced future economic, social, physical, 39 environmental, and fiscal development of the area that reflects community commitments 40 to implement the plan and its elements. These principles and strategies shall guide future 41 decisions in a consistent manner and shall contain programs and activities to ensure 42 comprehensive plans are implemented. The sections of the comprehensive plan 43 containing the principles and strategies, generally provided as goals, objectives, and 44 policies, shall describe how the local government's programs, activities, and land 45 development regulations will be initiated, modified, or continued to implement the File No. 2015-116 pg. 18 1 2 3 4 5 6 7 8 9 to 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 comprehensive plan in a consistent manner. It is not the intent of this part to require the inclusion of implementing regulations in the comprehensive plan but rather to require identification of those programs, activities, and land development regulations that will be part of the strategy for implementing the comprehensive plan and the principles that describe how the programs, activities, and land development regulations will be carried out. The plan shall establish meaningful and predictable standards for the use and development of land and provide meaningful guidelines for the content of more detailed land development and use regulations. Comprehensive Plan Amendments may be proposed by the Board of County Commissioners, the Planning Commission, the Director of Planning, or the owner or other person having a contractual interest in property to be affected by a proposed amendment. The Director of Planning shall review and process applications as they are received and pass them onto the Development Review Committee and the Planning Commission. The Planning Commission shall hold at least one public hearing. The Planning Commission shall review the application, the reports and recommendations of the Department of Planning & Environmental Resources and the Development Review Committee and the testimony given at the public hearing. The Planning Commission shall submit its recommendations and findings to the Board of County Commissioners (BOCC). The BOCC holds a public hearing to consider the transmittal of the proposed comprehensive plan amendment, and considers the staff report, staff recommendation, and the testimony given at the public hearing. The BOCC may or may not recommend transmittal to the State Land Planning Agency. If the amendment is transmitted to State Land Planning Agency, they review the proposal and issue an Objections, Recommendations and Comments (ORC) Report. Upon receipt of the ORC report, the County has 180 days to adopt the amendments, adopt the amendments with changes or not adopt the amendment. ►n=19 4[ol ji► 1akIn7�V�r��i i Monroe County Planning and Environmental Resources Department recommends approval to amend the Master Plan for Future Development of Big Pine Key and No Name Key by amending the Livable CommuniKeys Program Master Plan for the Future Development of Big Pine Key and No Name Key Tier Map (Figure 2.1) from Tier I to Tier III, as depicted on Exhibit 1. VII. ATTACHMENTS Letter from Key Deer Protection Alliance Letter from Henry Lee Morgenstern USFWS E-mail (8/18/2015 & 9/24/2015) File No. 2015-116 pg. 19 IN (FIGURE3 AMENDMENT TO THE LIVABLE COMMUNIKEYS PROGRAM MASTER PLAN FOR 4 THE FUTURE DEVELOPMENT OF BIG PINE KEY AND NO NAME KEY TIER MAP r I TO TIER III File No. 2015-I l6 p�. 20 ILI% We I�Li_q 'Vakp A 'Differvitcc! *y- D-r 'Pr4ree.)OA Mayte Santamaria Senior Director of Planning & Environmental Resources Monroe County, Florida Development Review Committee Meeting Tuesday, J11ly 28, 2015 Re: Proposed Change in Seahorse RV Parif s Tier Designation: Implementation of the Habitat Conservation Plan for the Florida Key Deer and Other Protected Species on Big Pine Key and No Name Key and Associated Incidental Take Permit and Implementation of the Livable Communi-Keys Program's Master Plan for Development on Big Pine Key and No Name Key. Dear Mayte Santamaria: The Key Deer Protection Alliance participated in the development of both the Habitat Conservation Plan for Big Pine Key and No Name Key and the livable Communi-Keys Master Plan for Future Development on Big Pine Key and No Name Key. We are concerned that any decision regarding a change in use and a change in the Tier designation of Seahorse property on Big Pine Key will negatively affect the population dynamics, the carrying capacity and/or the secondary impacts to the federally -listed endangered Key deer. Please consider the following comments and our request that the United States Fish and Wildlife Service examine these proposed changes to the Seahorse property on Big Pine Kay and scientifically demonstrate they will not have any negative effects on the Key deer. Implementation of the Habitat Conservation Plan for the Florida Key Deer and Other Protected Species and Associated Incidental Take Permit # TEo83411-0. After more than eight years of negotiation, the Florida Departm, ent of Transportation, Monroe County and the Florida Department of Community Affairs established the Big Pine Key Habitat Conservation Plan (HCP) in coordination with the Service on June 9, 20o6. The goal of the HCP was to address impacts to several species listed under the Endangered Species Act (ESA) resulting from potential development activities over a twenty-year period (20o6-2o26) on Big Pine Key and No Name Key. The development of the HCP included extensive public involvement and was based on years of scientific study. This scientific research lead to the development of a population viability analysis (PVA) model (Lopez 2001) which evaluates the impacts of development scenarios on the Key deer population and the development of a conservation priority classification system aimed at protecting species habitat while accommodating responsible development. OEM While the HCP was being developed, Monroe County crafted its first Livable Communi-Keys (LCP) Program Master Plan for Future Development on Big Pine Key and No Name Key. Public involvement was extensive and a workable compromise was achieved and adopted by the Board of County Commissioners on December 17, 2003. The Countyy's Master Plan for Future Development of No Name Key and Big Pine Key is in xorably linked to the Service's HCP and IT°P. The LCP, which is considered wholly a part the Monroe County Comprehensive Land Use Plan, was developed as a companion document to the HCP. Reference to the Master Plan is made extensively throughout the HCP. A change to the Comprehensive Land Use Plan, the LCP or the HCP requires a detailed analysis to mare sure appropriate changes are made to the corresponding documents. The "Tier Classification System": Monroe Coup _ versus Big Pine Key and No Name..Key. The conservation ,priority classification systern `aka the Tier systern) for Big Pine Key and No Name Key is different from that of unincorpor ted Monroe County.' In Monroe County, the Tier system is based on location., size and quality of upland terrestrial habitat. On Big Pine Key and No Name Key, the Tier system is based on the P '"A model, which is made up of two main components: a matrix model of population dynamics; and, a spatial model of carrying capacity and secondary impacts. Sir parameters entered into the calculation of the weighting factors2, only one of which (patch quality) is related to the duality of the upland terrestrial habitat. The six parameters are: house density, deer corridors, patch quality, deer density, distance from. US-1 and water barriers. r •ar on - .a ��• r r •r r The Importance of ALL Habitats to the Key eer Key deer are currently using all of the habitat that is available to them on Big Pine Key and No Name Key, including the habitat of the Seahorse property. Key deer corridors are critical to provide for the necessary movement of the Key deer within its range. Habitat utilized by the Key deer as a corridor is often densely developed and/or scarified and, which is often difficult to maneuver through. Even a junkyard can be valuable Key deer habitat if it is utilized by the Key deer as a corridor. I As stated in Policy 205.1.1 of the Comprehensive Land Use Plan, Policy 10 .2.1 is not relevant to the Tier classification system used on Big Pine Key and No Marne Key. 2 The "Tier Classification System" in Table 2.7 on page 43 of the Habitat Conservation. Plan for Big Pine Key and No Name Key is data that is identified for "privately -owned vacant land". ra-IM The Sands Corridor, which ties in very close proximity to the Seahorse property, is also made up of dense residential development on scarified land. This corridor is essential to the north - south movement of the Key Deer herd across US-i. This is precisely why the Incidental Take Permitprohibits all new development that results in any habitat loss in the Sands Corridor. Chan Tier Classification from Tier i to q on Big Pine fey Should Involve the Service. The I tt I gjq-'L;Ubb the effl 'I loll lot Mal, 111111411 the record. And, thank you for your time and interest in this matter. Sincerely, //s// Alicia Putney, Secretary (305) 304-9212 HIENRY „ Attorney at Law P.O. Box 337 FLORIDA 32190 Phone: (386) 749-0122 -Mail Address: Henry_LeeM@yahoo.com To: Bryan Powell, U.S. Fish and Wildlife Service [Sent to email: <bryan_powell@?a fws.gov>] From: Henry Lee Morgenstern, Esq.. Date: September 9, 2015 Re: Tier change for Seahorse lots on. Big Pine Key Dear Mr. Powell, I represent Last Stand and Key Deer Protection Alliance regarding Monroe County's proposal to change the Seahorse trailer park lots on Big Pine Key (BPK) from Tier I to Tier 3 for the purpose of developing them into affordable housing. Attached is your memo of August 18, 2615, where you say that FWS is supportive of this change. I am writing to suggest that the Service re -consider this position. First, it appears that such a Tier change may be unnecessary. See attached email indicating that MC staff is now considering amending their land use rules to allow affordable housing in Tier I on Big Pine Key. (The HCP has no prohibition against, nor even mentions, affordable housing, so such an alternative would not involve the Service or the HCP in any way.) Second, it is my opinion that changing the Tier 1 designation on any lot on BPK to Tier 3 would be a "non -minor" amendment of the HCP as defined in HCP Sec. 6.3, p. 69. As stated in that section, all non -minor amendments require a new application, NEPA, public notice period, and other procedures listed. Changing a Tier I designation on BPK to Tier 3 is a non -minor HCP amendment because: 1. The existing Tier designations are part of the HCP. Sec. 2.4.5, pp. 43-44. Therefore, changing the Tier designations constitutes a change (amendment) to the HCP. 2. Amendments are only "i-ninor" if they "do not deplete the level or means of mitigation„ and "do not alter the terms of the permit." HCP Sec. 6.3. 3. All of the "Avoidance and Minimization" guidelines listed in Sec. 5.3.2, pp. 57-60 are "terms of the permit" and are also integral parts of the "level or means of mitigation" referred to in Sec.6.3. See definition of"mitigation" in Sec. 5.3, p. 56. Note that ALL Qf these guidelines are part of the mitigation contemplated by the HCP, regardless of whether they deal 14' ith H Value. H Value is only one of the mars}) considerations conteinplated by the HCP. 4. Changing a lot from Tier 1 to Tier 3 on BPK would "deplete the level or means of mitigation" by decreasing the species protection afforded by Guidelines 4, 5, 8, 10, and 21: a. As to Guideline 4: Units that would have been counted in the 10 unit maximum for Tier 1 will no longer be so counted. The reason this guideline limits developments in Tier 1 to 10 units or H less than .022, "whichever results in a lower H" is because it is possible for 10 Tier 1 units to have a cumulative H value greater than .022. Thus, the Guideline 4 cap on the total H in Tier 1, as identified in the HCP, will be increased, depleting the mitigation afforded by that cap. b. The comment in your memo that you can change a Tier designation based on "the existing conditions of [the] parcels" (i) arbitrarily changes the baseline on which the entire HCP is based on a piecemeal basis, without uniform criteria or justification in the body of the HCP, see HCP Sec. 1.5, and (ii) would mean that anyone can just let the habitat value on their parcel deteriorate and thereby avoid the requirements of the HCP. This "alters the terms of the permit." c. As to Guideline 5: The changed lot will now be allowed to have multiple -family and other development previously not allowed in Tier 1, changing the terms of the permit. d. As to Guideline S: The changed lot will now be allowed to have commercial development previously not allowed in Tien- 1. This would "deplete the mitigation" intended by the HCP of specifically discouraging commercial development, and the traffic it entails, south of Lytton's Way, due to the impact on US road kills. It also changes the terms of the permit. e. As to Guideline 10: The development priority on the lot will change, giving higher priority to habitat that was formerly in Tier 1. for example, Tier 3 development on BPK gets +20 RGGG points, while Tier I on BGK gets zero points. f. As to Guideline 21: Changing a lot from Tier 1 will allow intensified uses on adjacent lots, regardless of the nature of such adjacent lots, or the effect such intensified uses may have on the protected species, "depleting the mitigation" intended by the guideline. In conclusion, my clients respectfully suggest that the Service withdraw its support of the proposed Tier change, or at a minimum advise the county that any such change would be non - minor, requiring all the procedures in HCP Sec. 6.3. Thank you for your consideration. cc: Mayte Santamaria Alicia Putney %signed and sent electronically/ HENRY LEE MORGENSTERN, Esq. 2 Roberts -Michael From: Powell, Brian <brian_powell@fws.gov> Sent: Thursday, September 24, 2015 4:51 PM To Roberts -Michael Cc: Ashleigh Blackford Subject: Re: Big Pine Key Tier designations Mike, The Service reviewed the revised report you provided regarding the Tier amendment request for the Seahorse RV property on Big Pine Kev. We also verified the existing; land use with a site visit and through review of aerial photographs. The Service agrees that the condition of the Seahorse RV property (developed prior to the Big Pine HCP) is consistent with the definition of the Tier 3 designation and is supportive of the requested change. I will provide you with a letter that formally supports the requested change with justification of our support. I hope to have this letter to you early next week. Please feel free to contact me if you have any questions. Brian Powell Fish and Wildlife Biologist U.S. fish and Wildlife Service South Florida Ecological Service Office 1339 20th Street Vero Beach, F1 32960 772-469-4315 - office 772-562-4288 fax On T'ue, Sep 8, 2015 at 4:27 PM, Roberts -Michael <R.oberts-Micliael�c ,iiionrotc;ottnt-�'-1 ..(�fov> wrote: Thanks for your earlier review and recommendations. I have attached a revised report incorporating your suggested edits. The Planning Commission heard the proposed amendment on August 26, 2015. The e-mail you provided (text below) was provided to the Commission. Some members of the Commission read your message to indicate that the Service was not in fact supportive of the proposed amendment, but were rather requesting additional supporting analysis. I have NOT supplied any further analysis, other than providing the qualitative descriptions you suggested. Please review the edited version — and if you can, respond with language that assures the Commission that the Service concurs with the Planning & Environmental Resources Staff recommendation. Thanks for your time and assistance. Michael Roberts, CEP PINS Sr. Administrator / Environmental Resources Monroe County Planning & Environmental Resources From Powell, Brian [mailto: rlan Po ell fws.caov] Sent: Tuesday, August 18, 2015 4:45 PM To: Roberts -Michael Cc: Ashleigh Blackford Subject: Re: Big Pine Ivey Tier designations ME As we discussed this afternoon, the Service would be supportive of the requested tier designation change if the justification for each individual parcel is supported by the current tier designation description. Two of the parcels show an "H" value that is within the Tier 2 value range, however the existing condition of those two parcels is representative of the qualitative description of the Tier 3 designation. As such I think it would be more appropriate for the staff report to highlight that and use it as the justification for the change rather than the "H" value. Brian Powell Fish and Wildlife Biologist U.S. Fish and Wildlife Service South Florida Ecological Service Office 1339 20th 'Street Vero Beach, Fl 32960 772--469-4315 - office 772-562-4288 fax On Thu, Aug 13, 2015 at 11:57 AM, Roberts -Michael wrote We are currently processing the attached Tier amendment request for a property on Big Pine Key. The parcel is currently designated Tier 1, but as you will note from the attached report, it meets none of the criteria for that Tier designation. Please review the attached and if you have any objections or comments please let me know. Thanks Michael Roberts, CEP; PWS Sr. Administrator / Environmental Resources Monroe County Planning & Environmental Resources (305) 289-2502 9 P, S. A 110i6 PWAIQ � y cfLORIDA t. , ,1LVc (;ark ,Vak4' A Tiffeicgcc ! Board of County Commissioners: Key Deer Protection Alliance Remarks by Alicia Putney Monroe County Board of County Commission October 21, 2015 — Marathon Agenda Item T-9 Sea Horse (Big Pine Key) Proposed Tier Change The Key Deer Protection Alliance participated in the development of both the Habitat Conservation Plan and the Livable Communi-Keys Master Plan for Big Pine Key and No Name Key ---two separate processes that began in 1998 and lasted through 2006. The Habitat Conservation Plan's Coordinating Committee was made up of representatives of USFWS, FWC, three applicants: FDOT, FDCA and Monroe County, and two citizen representatives, one of which was myself. The preparer of the HCP was the consulting firm URS, with Dr. Ricardo Calvo chosen as the Project Leader by FDOT. FDOT led the process and bore the majority of the cost. The Key Deer Protection Alliance has participated in the development review of this Application by Longstock beginning with the Development Review Committee meeting in July of this year. During this process we, along with Last Stand, asked attorney Henry Lee Morgenstern to evaluate whether or not a tier map designation change could legally take place outside of the purview of an HCP amendment. Mr. Morgenstern, an Endangered Species attorney who also participated in the Habitat Conservation Plan, concluded that the only way to legally make a change in a Tier designation would be via a major amendment to the HCP. A major map amendment would involve the full NEPA process and take years. (Mr. Morgenstern's letter to the Service outlining the issue is attached to what I just handed you.) We agree with Mr. Morgenstern's assessment and would like to suggest an alternative approach — an approach that would help affordable housing on Big Pine Key and would also put the BOCC in the driver's seat. The alternative approach boils down to tabling this Application and directing Staff to fast track a text amendment to the Master Plan that would allow affordable housing in all three Tiers on Big Pine Key. Such a text amendment would allow this Applicant to move forward with an affordable housing project, while at the same time avoiding the complications of a major amendment to the HCP. r I , PROPOSED TEXT AMENDMENT For example, the proposed text amendment would allow Affordable Housing on Tier I and Tier II lands on Big Pine Key providing all the following five criteria are met: (1) the redevelopment project would not increase the existing density; (2) the redevelopment project would not include any clearing of native habitat; (3) the redevelopment project would not increase the existing intensity in use, including vehicular traffic; (4) the property is not in a Key Deer Corridor, as defined by the HCP; and (5) the property is not within the 500-meter buffer zone of Lower Keys marsh rabbit habitat, as defined by the HCP. You are probably wondering why an alternative approach is being suggested, given that Staff does not agree in the need for a major amendment to the HCP. The basis for suggesting an alternative approach stems from the fact that we respectfully disagree with Staff on four fundamental issues. More specifically: 1.) We believe that the Tier I designation was a correct designation based on the science of the HCP. As indicated on page 11 of the September 30`" Staff Report (which is included in what I just handed each of you), nearly all of the properties surrounding the subject parcels were also designated as Tier I lands. This was not a mistake. 2.) We believe that while Monroe County may have produced the physical maps, the HCP science and H-value data determined the boundaries of the Tier designations. 3.) We believe that if this proposed map amendment is approved by this Board it would set a dangerous precedent that would place all Tier I parcels at a higher risk of development; and that action would result in many tier map amendment requests that otherwise would not have been sought by the owner. 4.) We believe that this higher risk of development for all Tier I parcels will have a negative impact on the long-term viability of the federally listed endangered Key deer. Please vote no on this Application. Please help us protect the Key deer while ensuring more affordable housing projects on Big Pine Key. Please direct staff to fast track a text amendment that would allow affordable housing in all Tier designations on Big Pine Key. This is a win -win approach. It is the prudent path to follow. Please choose it. Thank you. HENRY LEE MORGENSTERN Attorney at Law P.O. Box 337 SEVILLE, FLORIDA 32190 Phone: (386) 749-0122 E-Mail Address: Henry_LeeM@yahoo.com To: Bryan Powell, U.S. Fish and Wildlife Service [Sent to email: <bryan_powell@fws.gov>] From: Henry Lee Morgenstern, Esq. Date: September 9, 2015 Re: Tier change for Seahorse lots on Big Pine Key Dear Mr. Powell, I represent Last Stand and Key Deer Protection Alliance regarding Monroe County's proposal to change the Seahorse trailer park lots on Big Pine Key (BPK) from Tier 1 to Tier 3 for the purpose of developing them into affordable housing. Attached is your memo of August 18, 2015, where you say that FWS is supportive of this change. I am writing to suggest that the Service re -consider this position. First, it appears that such a Tier change may be unnecessary. See attached email indicating that MC staff is now considering amending their land use rules to allow affordable housing in Tier 1 on Big Pine Key. (The HCP has no prohibition against, nor even mentions, affordable housing, so such an alternative would not involve the Service or the HCP in any way.) Second, it is my opinion that changing the Tier 1 designation on any lot on BPK to Tier 3 would be a "non -minor" amendment of the HCP as defined in HCP Sec. 6.3, p. 69. As stated in that section, all non -minor amendments require a new application, NEPA, public notice period, and other procedures listed. Changing a Tier 1 designation on BPK to Tier 3 is a non -minor HCP amendment because: 1. The existing Tier designations are part of the HCP. Sec. 2.4.5, pp. 43-44. Therefore, changing the Tier designations constitutes a change (amendment) to the HCP. 2. Amendments are only "minor" if they "do not deplete the level or means of mitigation" and "do not alter the terms of the permit." HCP Sec. 6.3. 3. All of the "Avoidance and Minimization" guidelines listed in Sec. 5.3.2, pp. 57-60 are "terms of the permit" and are also integral parts of the "level or means of mitigation" referred to in Sec.6.3. See definition of "mitigation" in Sec. 5.3, p. 56. Note that ALL of these guidelines are part of the mitigation contemplated by the HCP, regardless of whether they deal with H Value. H Value is only one of the many considerations contemplated by the HCP. 4. Changing a lot from Tier 1 to Tier 3 on BPK would "deplete the level or means of mitigation" by decreasing the species protection afforded by Guidelines 4, 5, 8, 10, and 21: a. As to Guideline 4: Units that would have been counted in the 10 unit maximum for Tier l will no longer be so counted. The reason this guideline limits developments in Tier 1 to 10 units or H less than .022, "whichever results in a lower H" is because it is possible for 10 Tier 1 units to have a cumulative H value greater than .022. Thus, the Guideline 4 cap on the total H in Tier 1, as identified in the HCP, will be increased, depleting the mitigation afforded by that cap. b. The comment in your memo that you can change a Tier designation based on "the existing conditions of [the] parcels" (i) arbitrarily changes the baseline on which the entire HCP is based on a piecemeal basis, without uniform criteria or justification in the body of the HCP, see HCP Sec. 1. 5, and (ii) would mean that anyone can just let the habitat value on their parcel deteriorate and thereby avoid the requirements of the HCP. This "alters the terms of the permit." c. As to Guideline 5: The changed lot will now be allowed to have multiple -family and other development previously not allowed in Tier 1, changing the terms of the permit. d. As to Guideline 8: The changed lot will now be allowed to have commercial development previously not allowed in Tier 1. This would "deplete the mitigation" intended by the HCP of specifically discouraging commercial development, and the traffic it entails, south of Lytton's Way, due to the impact on US 1 road kills. It also changes the terms of the permit. e. As to Guideline 10: The development priority on the lot will change, giving higher priority to habitat that was formerly in Tier 1. For example, Tier 3 development on BPK gets +20 ROGO points, while Tier 1 on BGK gets zero points. f. As to Guideline 21: Changing a lot from Tier 1 will allow intensified uses on adjacent lots, regardless of the nature of such adjacent lots, or the effect such intensified uses may have on the protected species, "depleting the mitigation" intended by the guideline. In conclusion, my clients respectfully suggest that the Service withdraw its support of the proposed Tier change, or at a minimum advise the county that any such change would be non - minor, requiring all the procedures in HCP Sec. 6.3. Thank you for your consideration. cc: Mayte Santamaria Alicia Putney /signed and sent electronically/ HENRY LEE MORGENSTERN, Esq. FA r 1 2 4 5 6 7 8 9 LE Tar 1 �:: • a:■ ����� � Tara a 4 1,1=6 A "' 11a.e Approx. Location of ¢�¢ ., . �� t� Subject Parcels .�. W1 A...1Y 111111111w II� IJJ -rrl File No. 2015-116 HCP Figure 5.2 Key deer corridor across Sands Subdivision Sands corridor with subject parcels in blue pg. 1 I 71 P S. Deb C"l ee' Last Stand Comments to the BOCC October 21, 2015 Agenda Item T.9 Presented by Deb Curlee, Vice -President Last Stand opposes this proposed Resolution to change the Tier designation of the Seahorse/Longstock property on Big Pine Key through a tier map amendment. Instead, we request that you consider an alternate process: a text amendment to the Master Plan, which would allow affordable housing in Tier I and Tier II parcels on Big Pine Key. Let us be clear: Last Stand is not opposed to this affordable housing project. In fact, we support more affordable housing — on Big Pine and throughout the Keys. However, we are opposed to using the map amendment process to accomplish even this laudable goal. We are concerned about triggering unintended consequences. There are eleven federally -listed Endangered and Threatened Species on Big Pine and No Name Keys. The Habitat Conservation Plan (or HCP) and Incidental Take Permit (or ITP) were developed after eight years of study, model testing, analysis, peer review, and public meetings. The resulting assignment of Tier designations on Big Pine and No Name was done deliberately and differently than in the rest of Monroe County. The amount of vegetation on a given parcel was only one factor in six. All of the Tier criteria were based on solid science and considered the entire Big Pine and No Name area — as a unique, contiguous project unit. When we look at that extensive scientific process, we understand why the subject property, and so many like it on Big Pine and No Name, came to be designated Tier I — despite the fact that some of those properties were fairly developed and had less hardwood hammock than some other Tier I parcels. Last Stand believes that the Tier l designation at Seahorse — and all those properties surrounding it that were also designated as Tier I — was not made in error. Because of our concerns we consulted Attorney Henry Morgenstern, who was actively involved in this HCP/ITP process. He believes it would require a full NEPA review to make the proposed changed from Tier I to Tier III, S s Based on Mr. Morgenstern's opinion, Last Stand thinks that the Big Pine and No Name area should continue to be looked at as a single project unit, or serious questions will arise as to whether the ITP is being followed. Last Stand believes that relying on a map amendment for the Seahorse/ Longstock project would set an unfortunate precedent, opening the floodgate for hundreds of requests for similar, individual map amendments. This would over- burden staff and possibly trigger actions by the US Fish and Wildlife Service that would be burdensome for the County. Accomplishing a text amendment to the Master Plan would allow orderly redevelopment of Tier I and Tier II properties for affordable housing without any risk of requiring the US Fish and Wildlife Service to re-examine the HCP and ITP process.Po r- e o4 l lr-ge,'f e re Dsed , For the BOCC to keep its decision -making power, maintain orderly control of Tier changes and advance the Seahorse project (and other affordable housing projects on Big Pine), we respectfully request that you direct staff to explore the Master Plan text amendment process to allow affordable housing in Tier I and Tier II on Big Pine. Thank you. j9 W United States Department of the Interior `F` FISH AND WILDLIFE SERVICE South Florida Ecological Services Office 1339 20'h Street aTMr•``d Vero Beach, Florida 32960 October 21, 2015 Michael Roberts Senior Administrator, Environmental Services Monroe County Growth Management 2798 Overseas Highway, Suite 400 Marathon, Florida 33050 Service Consultation Code: 2015-TA-0363 Project: Big Pine Key -No Name Key Habitat Conservation Plan, Subject: Seahorse RV Campground Tier Designation Change County: Monroe Dear Mr. Roberts: This letter is in response to Monroe County's request for technical assistance dated August 13, 2015, related to the Tier amendment request on the Seahorse RV Campground property (Campground). The Tier amendment request was to change the Tier designation of the Campground from Tier I to Tier 3. The Campground is an existing RV campground containing 130 documented units. The Campground does not meet the Tier 1 definition described in Section 2.4.5 of the Big Pine Key No Name Key Habitat Conservation Plan (HCP); and is more appropriately described as a Tier 3 property. If approved, this Tier change will not result in a decrease in protective measures and/or mitigation requirements under the HCP because the Campground was an existing development prior to the implementation of the HCP. Therefore, a change in Tier designation or land use at the Campground will not affect the baseline used in the HCP. Additionally, the replacement or redevelopment of existing dwelling units will not impact the H value of the Campground property nor will it require mitigation in accordance with the HCP and County's Livable CommuniKeys Program Master flan. Finally, if the 'Pier designation change is approved and the Campground is subsequently redeveloped, the property will be subject to current Monroe County ordinances including deed restrictions for free roaming cats, which will be an overall improvement in protection for species identified for conservation under the HCP. Based on the above discussion, the Service has no objection to and supports the request to amend the Tier designation at the Campground as presented in the September 8, 2015, staff report submitted to the Service. A, Michael Roberts If you have any questions, please contact Brian Powell at 772-469-4315. Sincerely yours, aZ-e--6C � P �Rox a Hinman Field Supervisor South Florida Ecological Services Office Page 2