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

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