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Introduction/Summary/Written Comments County of Monroe Growth Management Division 2798 Overseas Highway Suite 410 Marathon, Florida 33050 Voice: 305,289,2500 FAX: 305,289, 2536 Board of County Commissioners Mayor Dixie Spehar, District] rv1ayor Pro Tem Charles "Sonny" McCoy, District 3 George Neugent, District 2 David Rice, District 4 Murray E, Nelson, District 5 MEMORANDUM FROM: Board of County Commissioners Timothy J. McGarry, AICP/lJI1 Director of Growth Manag~kt I & TO: DATE: March 1, 2005 SUBJECT: Public Hearing and Workshop on Comprehensive Package of Amendments to Comprehensive Plan and Land Development Regulations to Implement Goall 05 - Tier System Introduction At its March 17, 2005, specially scheduled meeting, the Board of County Commissioners will conduct a public hearing continued from Febnlary 16, 2005, on proposed amendments to the Comprehensive Plan and Land Development Regulations to implement Goal 105, commonly referred to as the "Tier System". Included as part of this public hearing, will be a Board workshop to discuss with special counsel and staff, legal and policy issues related to the proposed Tier system. Purpose The purpose of this memorandum is to provide a suggested agenda for consideration by the Board in conducting the hearing and workshop; present a descriptive summary of revisions made by the staff since the February public hearing to the set of draft ordinances, and outline possible options for Tier II designated properties. Agenda for Public Hearing Unlike the previous three public hearings on the comprehensive set of amendments to the Comprehensive Plan and Land Development Regulations, the staff is recommending that the hearing be conducted for all seven ordinances, including the two transmittal resolutions, Page I of 10 concurrently. Therefore, the seven public hearing agenda items continued from the February meeting should be read into the record at the start of the public hearing. The staff has prepared an agenda and approximate timeline for each item, which is attached to this memorandum. The staff suggests that this agenda be set by the Board prior to entering into the official public hearing. To facilitate the public hearing, the staff is recommending that the Board workshop be conducted first to allow the County's Special Legal Counsel and Growth Management Division staff to interact with the Board on legal, planning and policy issues and questions related to the Tier systl>nL Although the workshop will be open to the public, participation in the workshop will be limited to Commission members, County staff: invited State representatives, and Special Legal Counsel. The staff suggests that the workshop conclude at approximately noon or sooner. After lunch, the public will be invited to provide input on the proposed amendments. Once public input is received, the staff suggests the Board discuss the proposed amendments and provide further direction to staff on any revisions to the draft ordinances needed to be prepared prior to the April 20, 2005, public hearing. Summary of Revisions to Draft Ordinances In response to direction from the Board of County Commissioners, public input, and further staff review, the staff has made various revisions to the draft ordinances. New text is shown in bold underline and deleted text is shown with a dsMhle striliethf€lMgk. The following is a summary of revisions by ordinance with substantive revisions identified: 1, Amendments to Comprehensive Plan to delete HEI requirements and revise environmental standards based on Tier System. . Made one minor revision to correct a typographical error in text. 2. Amendments to Comprehensive Plan to revised ROGOfNROGO based on Tier System and provide for lottery system option. . Added provisions for lottery system under Policy 101,2.3 and 101.5.1. [substantive) . Added Policy 101.5.4 that establishes the purposes for competitive and lottery systems for the awarding of market rate allocations. [substantiveI . Added "8. Payment to Land Acquisition Fund" under Policy 101.5.5(compctitivc system) and Policy 101.5.6 (lottcry system) that provides a provision allowing applicants to receive up to three points by Page 2 of 10 making a monetary payment to County's Land Acquisition Fund (see details under amendments to Land Development Regulations in 4 below). [substantive] . Added Policy 101.5.6 that provides for the lottery system option; establishes the minimum threshold point total at 30 to enter system; prohibits use of lottery tor market rate allocations on Big Pine Key and No Name Key; and provides for a point system paralleling the one applied to the competitive system. [substantive] 3. Amendments to Land Development Regulations to delete HEL reVIse existing conditions report and incorporate Tier system. . Revised Section 9.5-336 to require adding a list of threatened/endangered or protected species observed on site. 4. Amendments to Land Development Regulations to revise ROGO based on Tier system, provide for lottery option for market rate allocations, and revise requirements for affordable housing allocations. . Added defInitions for "competitive system" and "lottery system" under definitions (Section 9.5-120). [substantive] . Added language identifying the purposes of the compehtlve and lottery systems expanding upon the proposed amendment lan!:,JUage to the Comprehensive Plan (see 2. above). [substantive) . Added language in Section 9.5-122 that provides for a minimum of 20 percent of market housing allocations will be available for the lottery system; prohibits the use of the lottery system for any Big Pine Key and No Name Key allocations; and provides that the BOCC may annually increase or decrease the ratio of lottery allocations, but by no more than 50 percent of the previous year's allocation. (substantive) . Added language in Section 9.5-122.1 and Section 9.5-122.2 that establishes procedures tor administering, reviewing, and awarding of lottery applications; and requires that an individual, entity, or organization may only submit and have one application in the lottery system, may not have any other applications in ROGO, and may not have previously received an allocation award under the lottery system. [substantive) . Added language in Section 9.5-122.1 (f)(4) that allows BOCC to make available for an allocation award up to 100 % of the next five years of available affordable housing ROGO allocations. (substantive] Page 3 of 10 . Added language in Section 9,5-122.1(h)(l) and (2) that was inadvertently left out of previous ordinance. . Added language in Section 9.5~ 122.1 (k) to retroactively allow existing applications in the ROGO that had been withdrawn to increase the application's competitive score through either land dedication or lot aggregation to have the application's original controlling date restored and be awarded any perseverance point(s) lost due to the withdrawal of the application. [substantive) . Added language in Section 9.5-123 (g) that limits allocations awarded under administrative relief to 50 percent of the total available market rate allocations in anyone quarter. Isubstantive) . Added Section 9.5-122.4 (j) that provides for monetary payment to the County's land Acquisition Fund to receive up to three points; requires that the monetary value of a point will be established annually by BOCC; the value will be based upon the average ad valorem value of privately-own, vacant, IS/URM platted lots divided by four (I.e., the number of points awarded for a buildable IS/URM lot); and requires that payment will be made to the fund prior to issuance of building permit. (substantive) . Added Section 9.5-122.5 that establishes eligibility criteria and requirements for lottery system allocations; makes the point system for lottery applications the same as for competitive applications; places through a restrictive covenant the following restrictions on lottery allocation awards: prohibiting use of the dwelling for vacation rental or tourist housing uses; prohibiting the leasing of dwelling for tenancies of less than six months; and requiring that ownership of the property can not be transferred for two years from date of the allocation award to two years from the date of the certificate of occupancy without approval of the BOCC based on meeting specific hardship criteria. I substantive I 5. Amendments to the Land Development Regulations to establish the Tier Overlay District. . Added language in Section 9.5-256(a) to exclude Ocean Reef from Tier system. . Amended language in Section 9.5-256(b) to clarifY and increase specificity of the criteria to make it less ambiguous and more legally defensible. I substantive] 6. Amendments to Land Development Regulations to revise NROGO based on the Tier system. Page 4 of 10 [No revisions: it should be noted that the provisions tor the payment for points options proposed under ROGO is not included in this draft ordinance.] 7. Amendment to Monroe County Land Use District Map to include Tier Overlay District. . Added Map #16 to Tier Overlay District Map, which was inadvertently omitted in the original agenda package. Tier Discussion Overview The designation of a Tier II has been an issue since the review and adoption of Goal 105 in 2001 to provide a framework tor implementing the mandate of Rule 28-20.100 F.A.C and the Florida Keys Carrying Capacity Study (FKCCS). Tier II is intended to be the transition area between the State and Federal acquisition areas in Tier I and the major development areas in Tier III. The habitat in Tier II is not as sensitive as that found in the larger habitat patches in Tier I, but still, provides important habitat for migrating birds and small animals. Tier II was also conceived as a sprawl reduction area, where further development is to be discouraged due to the lack of existing development and infrastructure. Many more platted lots in the County exist than can be permitted over the next 20 years; and Tier III, with more existing development and available infrastructure is the more appropriate area to receive development allocations. Goall05 Goal 105 of the 2010 Comprehensive Plan identifies Tier II as the Transition and Sprawl Reduction Area. Tier II is defined in Policy 105.2.1 as any geographic area: o with scattered f,1fOUPS and fragments of environmentally sensitive lands, o with existing platted subdivisions which are not predominately devcloped or served by complete infrastructure facilities, and o not within close proximity to established commercial areas 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 not exceeded, and prevent further encroachment on sensitive natural resources. Within a Transition and Sprawl Reduction Area are typically found: scattered small non-residential development and platted subdivisions with less than 50 percent of the lots developed; incomplete infrastructure in tem1S of paved roads, potable water, or electricity; and scattered clusters of environmentally sensitive lands, some of which are within or in close proximity to existing platted subdivisions. Page 5 of 10 Issues considered in development of the Tier system and Tier II 1. Existing Environmental Requirements and RaGa The LOR regulations including the Habitat Evaluation Index (HEI) and Threatened and Endangered Species Maps have been the subject of much concern and discussion. . An HEI is only performed on land classified as hammock and pineland on the adopted 1986 Existing Conditions Maps, therefore any re-growth hammock areas over the last 20 years have received a positive one score in ROGO, which is a major loophole in the existing regulations and has led to permit appeals and the Notice of Yiolation by DCA. Much of the hammock patches in Tier II are re-growth areas, . The Endangered Species Maps have not been updated as required in the 20 I 0 Comprehensive Plan and do not include Species of Special Concern and all federally listed species habitat that have been studied in the County. The DCA appeals of ROGO allocations and Notice of Violation (NOY) were for lots in Tier II which were not receiving negative points for habitat and species of special concern because of how the existing regulations are written. Tier Solution: Rather than update the maps and existing regulations to reflect conditions existing in 2005 and continue the lot-by-Iot review for ROGO, Goal 105 directed the County to prepare over lay maps and designate all areas of the County into one of three tiers and to revise the allocation system to direct the preponderance of future residential development to Tier IlL The point differential in Tier II reflects the relative environmental value of the area between Tier I and Tier III. If the Tier system were not adopted, at the very least, the County would be "highly" encouraged by DCA to change its regulations which would result in more negative points being assigned to properties with characteristics similar to those proposed for a Tier II designation. 2. Implementing the FKCCS and Rule 28-20.1 00 F.A.C, The Florida Keys Carrying Capacity Study's (FKCCS) terrestrial model recommends prevention of further fragmentation and degradation of tropical hardwood hammocks, pinelands and transitional wetlands. The existing and proposed Florida Administration Commission Rule requires the County to implement the findings of the FKCCS, Ticr Solution: Tier I is designed to preserve and restore the major viable areas of remaining hammock and pinelands in the County. A patch of four acres was identified as the minimal size for isolated patches of hammock to be included in Tier I. Tier I was identified in Goal 105 for acquisition by State and Federal agencies. Tier II contains habitat areas of less than four acres. These smaller hammock patches were also considered in the FKCCS and are used by forest interior species of birds and small animals and as resting places for migrating birds. Goal 105 recognized the value of these Page 6 of 10 areas by directing that they be included in Tier II, that Tier II be designated a second priority for acquisition, and that County funds also be used for purchasing Tier II vacant lands. 3. Property Rights; the Liability in Platted Lots There are cUlTently approximately 7,150 platted, vacant IS, URM lots in unincorporated Monroe County outside of Big Pine Key and No Name Key, including more than 3,300 lots in Tier III. Based on this total number of lots, it would take nearly 45 years at the CUlTent allocation rate before all these platted lots could receive permits. The ROGO system was designed to allocate the few penuits that are given each year to applications in the more appropriate areas both from an environmental and planning perspective. As long as permits are rationed, a methodology to fairly distribute these allocations is required. This results in both a tinancial and legal liability in the large number of platted lots in the County Tier Solution: Determining how best to allocate new residential permits and which properties should be acquired to protect property rights is accomplished through the Tier designations as directed in Goal 105. Tier III is defined as the Intill Area; this is where the majority of future residential allocations should occur - the major positive point awards. Tier II is the transition, sprawl reduction area; it is less appropriate for development from a planning and environmental prospective ~ moderate positive points. Tier I is the Natural area; it is the least appropriate areas for 1:,1fowth and the most environmentally sensitive ~ zero positive points. Property rights are preserved because the point system provides a mechanism for acquiring enough additional points to be awarded a permit. But because of the differential of points the majority of growth will go into the infill areas. 4, Tier II and Affordable Housing Many of the Tier II lots are generally less expensive to purchase because they are not on open water or canals or they are environmentally sensitive and cUlTently are receiving negative points under ROGO. Tier Solution: Although under the proposed system Tier II lots are made less competitive under the ROGO than Tier III lots, the proposed system does not penalize such lots if used for affordable housing. If the lot is to be used for an "affordable" house it would not be affected by the negative points for Tier II because affordable housing is not allocated using the ROGO point system. Under the CUlTent system affordable housing on many of these lots proposed for Tier II can't be built since they would incur negative points. Alternatives for Tier II Page 7 of 10 The staff has identified four basic alternatives for consideration by the Board: Option 1: Keep existing proposal - Provide for a ten point spread between Tier II (+20) and Tier III (+30) designated areas. The proposed ROGO points based on the Tier Maps was recommended by the Planning Commission after careful consideration of the previous issue discussion items. The differences in the Tiers both from an environmental and sprawl reduction initiative are considered and the point difference will direct the majority of growth to Tier 111. Staff Evaluation: The ten point difference is too si!,rnificant and significantly raises the cost to develop these properties. Less of a point differential between the two designations would still be consistent with Goal 105 and help encourage more development in Tier 111 than Tier II. Option#2: Reduce point difference - Reduce the point spread to four between Tier II (+26) and Tier III (+30) designated areas. This proposal still recognizes that Tier II is a less appropriate area to develop new residential uses but reduces the point differential to the equivalent of donating one ROGO lot. Stafl Evaluation: It is an appropriate level of mitigation and further recognizes that under the proposed new administrative relief procedures every Tier II not involving clearing of habitat will be awarded a permit as the preferred relief option. Option#3: Expand Vesting of Applications - Provide for grand fathering of current applications in Tier II with a + I point tor habitat and award +30 to these applications. Although it is recognized that the existing LDR and HEI do not accurately reflect the existing conditions of a lot since they are based on the 1986 habitat maps, grandfathering those applicants who have invested based on the existing system may be an equitable option to resolve concerns about any development expectations these applicants may have concerning their properties. [Currently 60% of the applications in proposed Tier II designated areas in the upper Keys have scored + 1 for habitat current in ROGO,] Stafl Evaluation: This option is a fair and equitable solution to some of the problems raised by property owners affected by thc transition in systems. However, rather than a stand-alone option, the staff believes that it has merit for inclusion with either of the two proceeding options. It will only impact a limited number of property owners and have little impact on the overall system. Option#4: Elimination of point difference - Provide for no point difference between Tier II (+30) and Tier III (+30) Page 8 of 10 Under this proposed option, Tier II would still have a reduced clearing rate providing some protection for the environmental quality of an area, even though the point difference between Tier II and Tier III would be eliminated. Staff Evaluation: To make both Tiers an equal number of points would be inconsistent with Goal l05 and would require that Goall 05 and its policies to be amended. In addition, it should be reC06111ized that currently 40% of the applications in Tier II in the upper Keys have received negative habitat points and many of the lots that received positive points have only be able to do so due to the loophole in current regulations. The concerns raised by DCA staff in its pennit appeals and Notice of Violation may create a problem for that agency in supporting this option. Recommendations for Tier U Staff recommendations for Tier II options in order of preference from the most preferred to the least preferred are: 1. Combination of Option#2 with Option#3: Reduce the point difference between Tier II and Tier III designated areas to four points and give 30 points to applications for Tier II designated properties currently in the ROGO system that have received a positive habitat point for scarified or disturbed habitat. 2. Combination of Option#l with Option#3: Retain the existing point differential between Tier II and Tier III designated areas and give 30 points to applications for Tier II designated properties currently in the ROGO system that have received a positive habitat point for scarified or disturbed habitat. 3. Option #4: Eliminate the point differential between Tier II and Tier III designated areas, amend Goal 105, and retain more stringent clearing requirements for Tier II designated areas. Page 9 of 10 A TT ACHMENT PUBLIC HEARING AND TIER SYSTEM \VORKSHOP AGENDA A. 9:05 A.M. Public Hearing ~ Agenda Items B 1 through B7 continued from February 16, 2005 (Goal 105 Comprehensive Plan and LOR Amendments) B. 9:05 A.M. Board of County Commissioners W orkshop* 9:10 A.M. Discussion of legal issues [Tyson Smith, Esq., White and Smith] 10:15 A.M. Florida Forever Program and Boundary Expansion [Representative from DEP] 10:30 A.M. Discussion of revisions to draft ordinances [Staff! II :00 A.M. Discussion of Tier II Options [StaHl 12:00 P.M. Adjourn Workshop C. I :30 P.M. Public Comment D. 2:30 P.M. BOCC/Staff Discussion and Direction E. 3:30 P.M. Adjournment *Notice: Although the workshop portion of the public hearing is open to the public, participation in the workshop is limited to Commission members, County stan: and legal counsel. Page 10 of 10 March 17, 2005 Board of County Commissioners WO<1<shop Workshop - Major Revisions . Lottery system option. . Payment into acquisition fund for ROGO points. . Borrowing for affordable housing. . Limitation on administrative relief allocations. . Vesting of ROGO applications withdrawn to increase scoring. Workshop - Lottery System . Provides minimum of 20% (-251year] of market per quaner available under lottery option; soce may increase or decrease by 50% of previous year . Option intended for applicants that haven't the financial resources for the competitive market but are not eligible for or want to pursue the affordable housing option - i.e.. dual income working families. . Ehgibility reQuirements: Can't be on Big Pine Key Of No Name Key. Must have minimum score of 30 points required to be el~ible fOI Ionery. May submit onty one application per enhly; no other ROGO applications May not have received a previous alk>cation award through the lottery. ." 1 Workshop - Lottery System . Each application assigned unique number quarterly and selected by random. . Restrictions placed on award to eliminate potential abuse: - Prohibits use for vacation rental or tourist housing uses. - Prohibits leasing of dwelling of tenancies of less than six rronths. - Requires SOCC approval of property transfer from the date of allocation award to two years from certificate of occupancy; such approval contingent upon demonstrated hardship. Workshop - Payment for Points . Provides for monetary payment to County Land Acquisition Fund to receive up to three ROGO points. . Value of points to be set by SOCC annually and be based on the ad valorem value of privately-own vacant, IS/URM platted lots divided by four (number of points for dedication of IS/URM lot). . Current value is -$8,000 per point. Workshop - Other Revisions . Authorizes SOCC upon recommendation of Planning Commission to borrow up to five years (20 ROGO quarters) of affordable housing. . Limits administrative relief allocation awards to no more than 50 % of market allocation awards available per quarter. . Retroactively allow ROGO previously withdrawn to increase points by dedication of land or lot aggregation to have controlling date restored and lost perseverance point. JI''' \I 2 March 17, 2005 Board of County Commissioners Workshop Tier Workshop - Tier II Purpose . Purpose: Discuss Questions asked - Tier II. . How Tier 11 is important to the implementation of the FKCCS and Rule 28-20. . Goal 1 05 and the role of Tier II. . Tier 11 Issues -existing regulations, property rights and affordable housing. . Options. Tier Workshop - Tier II Framework . Goal 105 - framework for implementing the FKCCS and Rule 28-20. . Tier 11 - Transition and Sprawl Reduction. .:. Scattered fragments of environmental lands. .:' Platted subdivisions partially developed. .:' Vacant lands acquired or development rights retired to prevent sprawl. ." 3 Tier Workshop - Tier II Basics Tier II Overview . Transition area between major acquisition areas (Tier I) and the preferred development areas in Tier III. \ . Habitat not as sensitive as larger patches in Tier I. . However provides important habitat for small species. . Sprawl reduction; less appropriate area for development. County has more platted lots than can permit in 40 years. ' . County/community/neighbor acquisition area. Tier Workshop - Tier II ISSUE Existino Environmental Reouirements & ROGO . HEI based on 1985 habitat maps- do not reflect current conditions: receive a +1 in ROGO. . Endangered species 1992 map - does not include "species of special concern" (SSC). . DCA Notice Of Violation and appeals of permits in Tier II - Partnership Agreement and negotiations, State dropped NOV. . Rule Year 8 - 1) acquisition outside CNA 2)amend ROGO or HEI to protect habitat. Tier Workshop - Tier II Solution Tier sYStem - oradation of environmental sensitivitv . Tier I - endangered species, best habitat. . Tier II - used by interior forest and migratory bird species and small animals. fragmented habitat. . Tier III -<:leveloped, some scattered habitat. Without point differential for Tier 11 County would need to revise HEI to reflect current conditions and give negative points for habitat and SSC. 11''' \I 4 ... 5 Tier Workshop - Tier II Issue Imolementina the FKCCS and Rule 28-20.100 FAC. . FKCCS recommerlds prevention of further fragmentation and degradation of tropical hardwoOd hammocks, pinelands and wetlands. . The Florida Administration Commission Rule - Year 6 requires the County to implement the findings of the FKCCS. Tier Workshop - Tier II Solution Goal 105 framework for imolementina FKCCS/Rule . Tier I - Best habitat- acquire, preserve and restore; State and Federal acquisition. . Tier II - Smaller patches - second priority for acquisition; local funding for acquisition. . Tier III - Little habitat value - Infill area. Tier Workshop - Tier II Issue Prooertv Riahts: the Liabilitv in Platted lots . 7,150 platted vacant IS, URM lots. . 3,300, nearly half are in Tier III. . 45 years at current allocation rate for all IS, URM lots. . Rationing system - ROGO designed to allocate few permits to most appropriate areas. legal and financial liability in platted lots. iI''' \I 6 Tier Workshop - Tier II Solution Tier desionation allocates points and new permits to appropriate areas . Tier 111- Infill a'rea, major positive points. . Tier 11- Transition/sprawl reduction; area is less appropriate from a planning and environmental, moderate positive points. . Tier I - Natural area, zero positive points. Property rights preserved because there is a means to acquire additional points for permit. Tier Workshop - Tier IIlssue/solution Tier II and Affordable Housino . less expensive because not on water and/or have negative points because of environmental. . Therefore are used for affordable housing. Solution . . Affordable housing" is not allocated under RaGa in the proposed system. . If not in a hammock can be allocated in Tier II. Tier Workshop - Tier II Options Option 1: Existing proposal - Provide for a ten point spread between Tier II (+20) and Tier III (+30). . Planning Commission recommendation. . Directs most growth to Tier III. Staff Evaluation: . Point spread may be too large. . less spread may still be consistent w/Goal 105. ." 7 Tier Workshop - Tier II Options ODtlon#2: Reduce pOint difference to four points between Tier II (+26) and Tier III (+30). Staff Evaluation: I . Still encourages most development in Tier III. . Equivalent to donating one ROGO lot. . Requires donation of one ROGO lot as basic mitigation. rather than 2.5 to reach 30 points. . Administrative relief after 4 years with minimum of 30 pOints and no habitat. Tier Workshop - Tier II Options ODtion#3 Tier II lots without upland habitat +30 points; Tier II lots, clearing more than 1,000 sq fl of upland habitat, -5 points (+25 points). Staff Evaluation: . Still encourages most development in Tier III. . Recognizes environmental resources and provides needed additional protection. . Consistent with the current negative points for moderate quality hammock (-5). Tier Workshop - Tier II Options ODtion#4: Vest Applications -Grandfather current applications in Tier II with a + 1 point for habitat and award +30. Staff Evaluation: . 60% of existing applicants in upper Keys in Tier II have a + 1 score. . Actual environmental value of lot may not be reflected in points because of HE I. . May be a fair solution for those who made investments based on existing evaluation system. 11'" \I 8 Tier Workshop - Tier II Options ODllo1'III'5: Eliminate point difference between Tier II (+30) and Tier III (+30). Staff Evaluation: . Tier II will still have dearing reduced to 40%. . Tiers with same points is inconsistent with Goal 105. . 40% of Tier II applications in Upper Keys have negaUve environmental points. . Those with positive points because of 'Ioophole" in HE!. Concems of DCA raised by permit appeals and NOV. Preferred: Option#3: Tier II lots without upland habitat +30 points; Tier II lots clearing more than 1,000 sq ft of upland habitat, -5 paints (+25 points). Second: Combination of Option#2 with Option#4: Reduce the point difference between Tier II and Tier III designated areas to four points and give 30 points to applications for Tier II designated properties currently in the ROGO system that have received a positive habitat point for scarified or disturbed with hammock. ... 9 Third: Combination of Option#1 with Option#4: Retain the existing point differential between Tier II and Tier III designated areas and give 30 points to applications for Tier II designated properties currently in the ROGO system that have received a positive habitat point for scarified or disturbed with hammock. Least: Option #5: Eliminate the point differential between Tier II and Tier III designated areas, amend Goal 105. and retain more stringent clearing requirements for Tier II designated areas. This option may require revision to the HEI and Endangered Species Maps and additional negative points in ROGO. Tier Workshop - Tier II Questions? fl~' " 10 March 17, 2005 Dear Commissioners: Below is a summary of my request for changes in the Tier System proposal now before you: I. If landowners, can be enticed or incentivized to build affordable housing on commercial properties that would result in the elimination of potential commercial growth while helping to solve our housing problem. Request: Give greater density bonuses for building affordable homes on commercially zoned property. II. Because affordable housing creates, by its nature, smaller unit sizes the need to set aside 20% ofthe land for open space is not necessary. Applying the same standard to affordable projects sites as we do to bigger market rate sites is not realistic and unnecessarily reduces the number of units we can build on any given site. Land is precious and we need to use it conservatively. Request: In determining buildable area on M.D. or S.c. or any other commercial land used for affordable housing allow 100% rather than the 80% now used to determine the net buildable area. III. The allowing of mixed income affordable housing developments of 80% affordable and 20% deed restricted market rate is currently in our code. This was included as a way to encourage owners of very valuable property to build affordable housing however the incentive now being requested by the planning board of 3 ROGO points for these deed restricted market rate units is not sufficient to accomplish the goal and entice the owners of this land to use it for affordable projects. Request: Please consider 5 or 6 ROGO points as the incentive for the 20% deed restricted market rate units now allowed in affordable mixed income properties. Might I also suggest that one ROGO point be awarded fro each affordable unit built thus a developer could amass ROGO points toward off-site permitting, This would be a major incentive to build affordable housing. 1 IV. The method of notice of the Tier System hearings and implementation is now advertisements in the newspaper. Because of the dramatic change in the value of land represented in the Tier System the result is a major across the board land use change or in effect a comprehensive re-zoning of property. Request: Direct notice of all Tier I and Tier II property owners by certified mail or tax bills or in some more direct way than by newspaper ads are in order. This notice should include a description of what the change is and how it will affect their property. Sincerely yours, Edwin O. Swift, III EOS/mhc 2 Tier System Marathon Gov. Center March 17, 2005 For the record my name is H. T. Pontin May 3, 1968 I bought 3 land parcels on the west end of Big Pine Key bordering U.S. # I and everything on it. Oct. 30, 1980 Case # 74-37-CA-17 Judge Gomez awarded me the balance of the 20 acres and the Bay Bottom with everything on them to do with them whatever I wished. Jan. 3, 1984 I applied for a county permit to fill in to plant trees. The state had not approved the County Comprehensive 2010 Use plan. The U. S. Army Corps had no jurisdiction above the Mean High Water Line to approve or deny. March 1984 A Joint application was initiated instead of two separate applications for a state and corps permit. May 12, 1984 I filed for the now required, Joint Permit from the D .E.R. and Corps of Engineers with a $1,000.00 fee. Jurisdiction was not questioned at that time. May 21,1984 My Monroe County Jan. 3, 1984 permit was denied July 13, 1984 The Army Corps denied my joint permit as they could not issue a permit until I first received one from Monroe County. Sept. 4. 1984 I filed for a new County fill permit paying another fee. Sept. 14, 1984 Monroe County Sept 4, 1984 permit and the Joint State and Corps permit both needed the others permit first in order to grant or deny a fill permit thereby creating a catch 22. Feb. 28, 1986 The new County Comprehensive 2010 land Use Plan was adopted and became effective with the State and Corps Sept 15, 1986. April 15, 1986 Mr. Charles Pattison, working for Monroe County, put my Sept. 4, 1985 fill application on hold. Up until this time permits could have been granted or denied as there were no Tier System regulations. I have tried many times to offer a solution but the answer is always put in writing that, "no comments can be made as you have a case pending". Property rights are upheld by the U. S. Supreme Court. Therefore, I request that the Tier System, which adversely effects the owners' property rights and jurisdiction be put on hold, like my fill application is, until a ruling on my case is made by the court. H. T. Pontin, 951 W. Indies Dr., Ramrod Key, Fl. 33042 HT~