Saturday, July 29, 2017

Citizen Participation in Sarasota County Planning: An Open Letter

July 28, 2017

To: Sarasota County Planning, Matt Osterhoudt, Allen Parsons, Tate Taylor, Vivian Roe

This letter is a follow-up comment pursuant to the Comp Plan Amendment (CPA) meeting you conducted for the Planning Dept. on June 26th. It’s our understanding that the plan amendment then under consideration, 2015-G -- easing constraints on open space and buffers for developments proposed as villages or hamlets under the 2050 Plan -- may no longer go forward. But public comment during two meetings at which we were present (January 18 and June 26, 2017) made clear that the process for CPAs raises two related issues.

First, the  perception exists that with 2015-G the County, as a public entity, seems to be exploring a proposal with little relevance or benefit to any constituency other than the development industry. The changes under consideration seem related only to specific private business concerns -- yet the public meeting and process is termed “publicly initiated.”

Second, it was noted - by myself and others - that while the Board initiated this evaluative process, and Planning is doing its due diligence by holding public meetings, there is no generally understood method by which Sarasota residents might similarly initiate such public evaluations of Comp Plan changes.

When the County acting as a public entity explores certain Comp Plan options that benefit specific parties, it creates a "problem of optics," as they say. The voting public sees the County proceeding with what it calls a “publicly initiated” Comp Plan amendment, but sees no opportunity to be equally proactive. At the Gulf Gate meeting, there was a sense of being invited merely to react to a proposal introduced by an unspecified party.

Greater transparency of origin and purpose of comp plan amendment initiatives would help. To that end, this comment is offered to open a dialog that could lead to a more open and balanced public process.

Please correct or elaborate if any of the following statements regarding the steps leading to the BCC’s approving a proposed public initiative for a comp plan amendment is false or incomplete:

  • The Board votes to proceed with these initiatives. That vote can include discussion, or simply be part of the consent agenda.
  • When presented to the Board, the originator of the initiative is identified, and the perceived public benefit of the amendment is explained.
  • If the proposed amendment applies to a specific parcel or parcels, the location and number of these parcels and acreage are presented as an indicator of the nature of the perceived public benefit.
  • Any actual Comp Plan Amendment is voted on publicly by the Board, with Public comment forming part of the proceeding.

If the actualities differ from what is stated above, please clarify so that we are not proceeding upon mistaken assumptions.

When a proposed amendment comes before the Board for a vote, and the Board decides that it only serves developers, it might advise whoever is proposing the amendment to initiate a private Comp Plan amendment process.

Perceived Imbalances

Conversely, we would propose to open a dialogue with County to address the perceived imbalance between public and private sectors, with special reference to several moments in the planning and land use process. Proposed topics include:

  • Basic visioning of community / sector /  neighborhood character and design.

  • Practical introduction to public initiatives of Comp Plan Amendments.

  • An introduction to Critical Area Planning.

  • Strong expansion of public notification and input regarding any land use or rezoning changes to Public Lands, and to surplusing and sale of same -- see Ord. 2016-087.

  • Putting in place a system to revisit and revise antiquated FLU designations. Given the accelerated pace of development and change in Florida, especially in places like Sarasota that are “in demand,” actual conditions on the ground change constantly. It’s both reasonable and wise to dynamically review old designations when their contexts have changed. Doing so would pre-empt conflicts arising when developers play 35-year-old land use cards that are hopelessly out of sync with all surrounding conditions.

An example

Suppose residents of an area -- say Clark Rd. east of I-75 for the sake of the argument -- wished to ask the Board to explore the idea of requiring a 750-ft buffer for all commercial projects, for the sake of preserving the rural character of the road. (750 feet here is chosen as an illustration, since it’s greater than the existing 2050 rule).

In this case, while the incentive for such a proposal would appear to come from "private" persons, its actual inspiration and purpose stems from a shared public vision of East Clark Rd. as a rural Heritage Road. To be clear, the amendment’s intent in our example is not to prevent development, but to have development fit within a shared public vision. The citizens seek a role in deciding the character of this portion of the County.

So the proposed amendment comes with a public purpose and benefit. If developers were required to abide by the 750’ foot rule, they might discover that the rural appeal of the area -- the fact that it looks entirely unlike Clark Rd. to the west of the highway -- could draw buyers seeking a locale that is neither urban nor suburban. Creativity could be one result.

Why is this important? Because when developers ask for and receive 50-foot buffers (a 450-foot reduction) and other changes to the 2050 Village Plan, they are motivated almost exclusively by the specific density needs and business model of the particular project they happen to be working on.

If residents strongly believe that their area possesses distinctive general features -- without which it would lose its essential character -- they’ll work to ensure that its quality and appeal is not undermined by asystematic, ad hoc developer exceptions.

To summarize: When the County as "the Public" explores amendments that appear to primarily benefit private business, it may appear to cater to special interests. Clarifying both who is instigating an initiative and the details of the public benefit can reduce such mixed signals.

By the same token, residents who wish to have a say in shaping the future of Sarasota (East County for example) would benefit from a clarified participatory process, through which the County may receive collaborative insights to help shape the future vision.

The 2050 Plan was created to represent the vision of the people of Sarasota. To the frustration of many residents, it has been compromised repeatedly as developers line up for exceptions and amendments. Before East County becomes a mirror image of West County, we’d like to collaboratively foster public participation in shaping the undeveloped areas of Sarasota.

A version of this comment will be submitted to the UDC Portal with a request for a meeting with Planners and UDC consultants.

We invite Planning to explore this with us as well through the same public meeting process that you recently so ably conducted at Gulf Gate.


Tom Matrullo
Co-Founder, Citizens for Sarasota County

Sarasota County Council of Neighborhood Associations (CONA)

Manatee-Sarasota Group of the Sierra Club

Carlos Correa
President of HOA, Pinetree Villages, The Enclave

David Johnson
Secretary, Meadow Walk Homeowners Association, Inc.

Glenna Blomquist
NextDoor Lead, Mockingbird Parish

Keith C. Russo
Chair, Lake Sarasota Community Group

Dan Lobeck
President, Control Growth Now

William Zoller

Lourdes Ramirez

Sura Kochman

Adrien Lucas

Dennis Robertson

Margaret Hoffman

Lynn Nilssen

Geraldine Swormsted

Gayle Reynolds

Damon White

Gretchen White

Cathy Antunes
Co-Founder, Citizens For Sarasota County

Skip Parrish

LeRoy William Hasselbring

Vickie Nighswander

Susan Schoettle

Tom Walker
Co-Leader, Nation Group of Sarasota/Manatee

Patricia Troy
If you wish to add your name, write to

Thursday, July 27, 2017

Sierra Club Response to County Open Space and Green Belt Initiatives

Space and Green Belt

From:  Gayle Reynolds, Manatee/Sarasota Sierra Club
To:   Vivian Roe, Sarasota County Planning and Development Services
Re:   Comments submitted on behalf of the Manatee/Sarasota Sierra Club regarding Amendment No. 2015-G to the Sarasota 2050 Plans Open Space and Green Belt policies.

From 1999 to 2001 the Sarasota County 2050 Plan was developed and approved in 2002 as an alternative to the agricultural zoning that previously allowed one unit per five acres east of the Urban Service Boundary, I-75.  Although the drafting process consumed hundreds of staff hours and time donated to review and commentary by public interest groups, today we find many of the core principles of Sarasota 2050 Comprehensive Plan Amendment No. 2015-G have been incrementally removed or significantly weakened.
Presented as a “citizens sponsored” comprehensive plan amendment, 2015-G would result in significant density increases while reducing open space requirements from 50% to 33%. The 500’ green belt requirement around villages could be reduced down to 200’ or an undetermined and unspecified width determined by the Board of County Commission.
Contrary to policies supported by the Sierra Club that would preserve native habitat, the amendment weakens the limits on uses for Open Space and Greenbelts.  Other than lakes, at present any “storm water facility” counted as Open Space must be “regional.”  That language is deleted, allowing all swales and canals for instance to count as Open Space.  
Additionally concerning, added as allowed Open Space alternatives are “existing linear facilities that have been enhanced,” such as an FPL easement which has been “enhanced” somehow, or a path which has been converted into a road.  This loosening of open space uses is a significant issue for the Sierra Club because the more alternatives that are allowed to count as Open Space, the less a developer may be required to preserve native habitat, another and most significant Open Space use.  
The amendment’s allowable uses within the Greenbelts would also be weakened and it would strike the current important language which states, “New uses are restricted within this Greenbelt to native habitats and to low intensity agriculture and wetland mitigation that do not involve the conversion of native habitat.”  While a provision was added in the writing of the Sarasota 2050 Plan to let the County Commission also approve a “golf course using best management practices, regional storm water facilities and public parks” in Open Space designated as Greenbelt of a development, so long as it is “appropriate” and adjacent to the developed area.” That adjacency requirement would be deleted, and “new plantings, berms and walls” added as approvable Greenbelt uses, as well as all other uses which are allowed in Open Space. One of the original objectives of 2050 was to eliminate walls and vertical hardscapes.
Also most significantly, the policy that any Greenbelt “preserves native habitats, supplements natural vegetation, and protects wildlife within the area” would be modified with the caveat, “with exceptions and alternatives as noted below.” This change alone greatly diminishes the incentives, protections and importance of preserving native habitat in Greenbelts as well as the loss of their function and value in the ecosystem.
One principal result of these changes would be to strike the requirement, that any agriculture and wetland mitigation in a Greenbelt, shall not convert any native habitat to those uses.  The current wording could be read as allowing the alternative uses only after preserving native habitat and that potential would be lost with the amendment revision.
Most importantly, this amendment would remove the opportunity for the public to have a voice in the process and oppose inappropriate open space/green belt uses and reductions.
The County has revealed no calculation as to how much additional development the amendment could allow by reducing the amount of Open Space and Greenbelts currently required in Sarasota 2050 developments, either for new ones and any previously approved ones.  Previously approved developments could come back for these greenbelt and open space revisions under the weakened standards.
The changes in this amendment could potentially add a significant increase in developable acreage and increased densities to proposed and existing developments, which equates to a lot more rooftops in the east county than is currently allowed in the 2050 Plan.  The county must tell the tax payers how much population increase could occur due to the associated density increases with these proposed open space revisions.  
The public interest has already lost far too much of the original 2050 Plan. Amendment G-2015 is neither sustainable nor in the public interest and would degrade our quality of life and protections for Rural Heritage, native habitats and species.  
The Sierra Club recommends retaining the existing 2050 policies for Green belts and Open Space and withdrawal of this bad proposal to reduce open space and green belt policies.
Gayle Reynolds

Friday, July 14, 2017

LTE: Save surplus land around Celery Fields

A Letter to the Herald Tribune from Christopher Mahon - raises a very important point - thank you, Christopher:

To the Editors:
It is so nice to see that the Sarasota city commissioners have the imagination and foresight to consider buying the Players Theatre property downtown, even without definite plans for its use. Would that such attitudes were contagious. 
The Celery Fields were developed as a strictly utilitarian flood-control project. It was only later that the area came to be an ecotourism destination known nationwide. How often do the unintended consequences of government action turn out to be wonderful? 
Well, we can still blow it. On Aug. 23, the Sarasota County Commission will vote on the proposed concrete and construction-debris recycling plant adjacent to the Celery Fields, already rejected by the Planning Commission. 
Concerned citizens must show up to ensure the right outcome. But we must go further. We must remove the four pieces of our land from the surplus list and save them for our posterity. 
The land parcels in question were deemed surplus when the property was being developed because they had no use as flood-control area. However, just as the Celery Fields has evolved into an irreplaceable recreational site, so, too, can the “surplus” parcels. 
Whether they become an interpretive botanical park, community gardens, or something no one’s yet considered, it doesn’t take a genius to see that having undeveloped land contiguous to the Celery Fields is nearly priceless, and will be even more so in the future. 
If the county government lacks the foresight to protect this land, the people of this county don’t. 
Christopher Mahon, Sarasota

Statement on Waste Facility Application from Control Growth Now

Control Growth Now of Sarasota County has issued this statement with regard to the application to site a waste processing facility near the Park, Preserve and Bird Sanctuary known as The Celery Fields.

Control Growth Now urges the Sarasota County Commission to deny approval of the pending applications for land use changes to property near the Celery Fields, an internationally renowned birding sanctuary as well as an important stormwater management facility, for a construction debris recycling facility.  In addition to the potential for adverse impacts to the environment and experience of the Celery Fields, the land use changes would dramatically increase heavy truck traffic on Palmer Boulevard, which is already experiencing traffic congestion, and would be incompatible with nearby neighborhoods.  As the Sarasota County Planning Commission unanimously determined, the County should reject the petitions, including specifically an amendment to the Critical Area Plan for this property, as specifically allowed by the Sarasota County Comprehensive Plan for reasons of the admitted traffic impacts of the proposed change.  Further, the County Commission should withdraw the subject land and two other adjacent parcels for sale as “surplus property” for industrial development and instead incorporate them into the Celery Fields preserve, to better protect the environment, neighborhoods and mobility in the area.
   -- Dan Lobeck, CGN President

The Board of Sarasota County Commissioners will hear the matter on Wednesday, Aug. 23, 2017.

Tuesday, July 11, 2017

Lyons on the curious case of Sarasota's accommodation - for a dump at the Celery Fields

Please read Tom Lyons' Herald Tribune column on the curious, accommodative stance of Sarasota County toward the proposed, highly unwise idea to put a Waste Demolition plant next to a serene Preserve and Internationally touristed Bird Sanctuary, our all-round beautiful Celery Fields.

Among other things, Lyons notes:
County staff also quietly proposed changing county rules that would have barred the plant because the site was much too small, and did so as if the change was just some non-controversial tweak.
Staff essentially just passed along a designer-proposal created by land use agent Bo Medred. Medred pretended his proposal -- allowing unenclosed waste processing within 500 feet of homes -- would be useful and noninvasive, and the county - both the Planning Commission and the Board - bought it hook, line, and sinker.

See the Citizens' Timeline narrative here

especially this bit:

In October, 2016, Bo Medred asked the County to change its law and standards to accommodate Mr. Gabbert's desire to put a Waste Processing Plant at Apex Rd. and E. Palmer Blvd., next to the Celery Fields.
  • Oct 20, 2016 - Bo Medred proposes new standards to reduce the number of acres required for unenclosed Waste Processing from 35 acres to 15 acres. Ordinance No. 2016-082, approving Zoning Ordinance Amendment No. 119. 
  • Jack Bispham, chair of the Planning Commission, recused himself from the proceeding. Bispham is the brother-in- law of Mr. Gabbert.
  • No information or testimony from an expert on Waste Processing was cited or offered by county staff or a commissioner.

Bo Medred's proposed amendment to the County's law and standards begins with Donna Thompson of County Real Estate at about 2:08 hrs. (That single segment can also be viewed here.)

Planning Commission Hearing Oct 20, 2016 on Ord. 2016-084, Amend.119

  • During the PC hearing (at 2:32), Bo Medred displayed this photo of a dump in Buffalo NY to illustrate his argument as to why this 15-acre model is perfectly suitable for residential areas of Sarasota County. People's homes visible behind the piles of waste: 

Medred displayed this photo of a Waste Processing Facility on 15 acres in Buffalo NY
to the Planning Commission.

If nothing else, see the exchange around 2:33 between Planning Commissioner Laura Benson and Bo Medred:
Benson: (referencing the Buffalo illustration):  Those pictures were big dirty things.
Bo Medred: That's a . . . that's a . . . that's an opinion. 
See also the exchange with Commissioner Jack Hawkins concerning the noise levels of concrete and asphalt crushing operations that begins about 2 hrs. and 39 minutes. No staff or Commissioner put into evidence any documents about the potential problems and issues with siting a waste processing facility. No accredited expert was invited to testify as to siting, pollution, noise, or other impacts upon residences.

Planning Board ACTION:

Oct. 20, 2016 - The Planning Commission APPROVED the amendment by a vote of 6-0 (Bispham recused hmself) as a Special Exception use to be analyzed on a case-by-case basis, as Bo Medred recommended.  VIDEO

With the blessing of the Planning Commission, Bo Medred moved on, taking the proposed amendment to the Sarasota Board of County Commissions in December.

On Dec. 14, the Board approved a text amendment allowing unenclosed waste processing facilities near residences via Consent Agenda -- i.e., it wasn't even discussed.

Monday, July 10, 2017

Transcript of June 1 Celery Fields Hearing (Sarasota Planning Commission)

A full transcript of the June 1, 2017 Planning Commission Hearing on James Gabbert's proposal to build a giant unenclosed waste plant near the edge of the Celery Fields is now available. Read it here.

The final hearing of the Board of Sarasota County Commissioners on the matter is set for Aug. 23, 2017.