Antunes Letter: 2050 Action Network

It is important to create a written record of public opposition to proposed 2050 changes and the inconsistent and absent elements of the process which brought these changes forward. 

All who care about the next half century of Sarasota development are asked to write to the County Commission and to the state Department of Economic Opportunity (DEO)  to protest 2050 changes.  Please send your personal comments to: 

Ray Eubanks                  
Valerie Brookens           
Sarasota County BCC  

(Letters we receive will be republished on the blog unless authors request otherwise.)

Cathy Antunes:

Dear Mr. Eubanks and Ms. Brookens,

I am writing regarding my concern and opposition to the Sarasota County amendments submitted to change Sarasota 2050.

The County has publicly characterized the amendments submitted to the Department of Economic Opportunity as part of a comp plan review process required every 10 years by the State of Florida.  The amendments submitted are work product triggered by a handful of landowner/developers, who are focused on facilitating development of rural land outside Sarasota County’s Urban Service Boundary (USB). The amendments are not the result of a review of the economic, environmental and quality of life interests of the County as a whole.  My concerns in this regard include, but are not limited to:

The public process and gathering of data and public input has been mishandled and incomplete.  The scoping process was eliminated. Open houses and public workshops throughout the phases were inconsistent (no workshops regarding phase one changes) and poorly timed (open houses held in rural areas during fair week, a workshop held in the City of Sarasota during a City Commission meeting, workshops held during the holiday season and the dead of summer).  To my knowledge, public input has not resulted in any substantive addition or change to these amendments.

Policy negotiation and the substance of policy changes was a private process between a handful of landowners and County staff. This process has been mischaracterized as “public” in Sarasota County’s 2050 amendments submittal.  This is not a plan update - the impetus to change was the dissatisfaction of a small number of landowner/developers, and they wrote the policy changes. 
The County hired an unqualified consultant who recommended eliminating planning standards to such an extent her report was universally panned by independent planning professionals.  Rather than fire the consultant and hire a qualified expert, the County continued to rely on this consultant’s recommendations to craft the amendments.
The amendments fail to consider housing capacity or total potential housing units within the USB, where existing infrastructure investments exist and are not maximized.  Housing supply, demand and existing infrastructure investments are not included as limiting factors in the approval of new development.

The County has violated Sarasota 2050 by failing to implement objective US3 and policy US 3.1 - which required streamlined infill and redevelopment policies for development within the USB.  The County missed their self-imposed deadline - two years post approval of Sarasota 2050 (the deadline passed eight years ago).

The County has violated Sarasota 2050 by failing to create a “County/Municipal Coordinated Planning Program” as required in policy US 5.1.  Such a program, thoughtfully executed, would inventory total potential housing units within Sarasota’s four municipalities (the cities of Sarasota, Venice, Longboat Key and North Port), and compare existing potential housing to projected housing demand.  I’d expect such a program would look at coordinating best planning practices, such as embracing walkability design standards in County redevelopment.  It appears such fundamental planning is missing, as County potential housing inventory is at least 125,000 units (includes unincorporated County, City of Sarasota and North Port), and the County’s projected 10 year demand is roughly 16,000 units.  The failure to implement policy US 5.1, and approve development with an eye toward projected housing demand and existing infrastructure investment and maintenance, pension and benefits obligations seriously undermines Sarasota’s economic future.

Is the practical result of these amendments a de facto elimination of Sarasota’s Urban Service Boundary?  It appears these amendments represent a substantial change which renders Sarasota’s USB meaningless and places the financial burden for subsidizing surplus development on existing taxpayers.

Fiscal Neutrality is an important aspect of Sarasota 2050, squarely placing the financial burden for all infrastructure on the development.   After all, if landowners/developers don’t want to take on that risk, they can wait until we need to move the Urban Service Boundary.  The County is requesting the Department of Economic Opportunity approve changes to 2050 standards without requiring the County to demonstrate how fiscal neutrality will be enforced.  The most concerning language indicates fiscal neutrality will be demonstrated “to the satisfaction of the County Commission”.  Such language makes fiscal neutrality subjective and compromises Sarasota’s economic future by eliminating appropriate market risks to be born by the developer.  

There is an underlying assumption by the County at work here, that Sarasota 2050 is “not working”, that the County must find a way to facilitate/subsidize building in our rural lands.   In a market economy, there are times when the market conditions are not advantageous for a project.  Creating public policy which eliminates market risks for a handful of landowner developers, and then in turn placing those financial risks on taxpayers is the epitome of poor planning.  

Has Sarasota County demonstrated these amendments are compliant with the Endangered Species Act?  What will the impact be on Florida panther, wood stork and other habitat?

Has Sarasota County demonstrated these amendments are compliant with the Clean Water Act?  The rural area is an important water recharge area.  What will the impact be on our aquifer?  Will there be sufficient clean water to meet demand?

Has Sarasota County’s agricultural future (or lack thereof) been considered in these amendments?  How about community need for local food sources? A diversified local economy (which includes agriculture)? 

Has Sarasota County demonstrated the amendment changes are consistent with wise transportation planning?  Sarasota County’s transportation debacle at University and I75 is not an FDOT issue - it is the direct result of the County’s (and Manatee County’s) failure to implement wise planning standards as they relate to transportation issues.  This failure to plan properly is exacting a toll in human life and safety, as well as a monstrously expensive diverging diamond interchange.  A former member of the Sarasota Planning Commission related to me that the new mall at University and I75 was approved without a customary DRI study.  We are seeing jobs shift as stores close in existing malls to open in the new mall at University and I-75.  The community was told the project would create “jobs, jobs, jobs”,  but we are getting “accidents, accidents, accidents.”

In conclusion, I share a deep concern with many of my neighbors that these proposed amendments do not create economic opportunity for Sarasota County, but actually undermine our future prosperity and quality of life.  Sarasota County’s planning approvals appear to be setting up the cannibalization of the value of existing residential and commercial real estate to benefit surplus new development. It seems to me best practices warrant maintaining our USB, implementing design standards proven to bring economic return (like walkable development) and appropriate conservation of natural resources (water, farmland, wildlife habitat). 
I am not satisfied that our County has given these concerns proper weight and consideration.  


Cathy Antunes

No comments:

Post a Comment