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Transfer
proposal dangerous
Those who make the decisions
concerning land use in Monroe County, on the local level, have been
studying several issues aimed at providing incentives for developers to
build affordable housing units.
Some of the ideas are innovative,
and others just seem to be a relinquishing of control over the process.
The latter category encompasses a new proposal to allow the transfer of
market rate Rate of Growth Ordinance (ROGO) allocations between sites
throughout the Keys.
The current regulations do not allow
developers to transfer market rate units from one site to another
without a special agreement with the county and state Department of
Community Affairs called a 380 agreement. The use of those 380
agreements have come under fire in recent months as developers are
putting them into play to skirt land use regulations like the transfer
of ROGO exemptions from place to place.
The 380 agreements must have a
significant public benefit, which this county commission has interpreted
to mean an affordable housing component. The 380 agreements have been
used thus far primarily to allow developers to purchase trailer parks
and rebuild some affordable units while moving the market rate units to
higher priced locations.
And in each agreement proposal, the
county loses a portion of its already desperately low inventory of truly
affordable housing for its residents.
This new ordinance proposal, on
first perusal, is simply a 380 agreement that cuts the state out of the
loop and allows the developer to make an agreement just with Monroe
County. The market rate unit transfer can only be done with an approved
agreement that contains an affordable housing component, but it doesn’t
outline any specific criteria on numbers that the developer must use.
This proposal instead says that each proposal can be acted on by the
commission on a case-by-case basis.
And as we have seen way too often in
the past, each case sets a precedent for the next.
Some officials involved in growth
management say that the existing trailer park redevelopment ordinance
contains a minimum of 30 percent of the units as a set criteria and that
should solve the problem of demanding a minimum criteria.
Those same officials also say that the existing land use criteria, like
hurricane evacuation times and traffic level of service will come into
play to regulate the proposals.
It is our thought that this new
proposal gives the developer too much control over the process.
The developer can pick the site
where they wish to build the market rate units, be it in the same
development area or outside the development area. They can eradicate 70
percent of the mobile homes or trailers in an area, leaving that area
short of units it already has.
We feel this proposal is also not of
benefit to the sites where the units are going.
In the case of the Seahorse RV Park
on Big Pine and Rowell’s Marina on Key Largo 380 proposal, the developer
wants to move 135 market rate units to Key Largo, and replace it with
100 affordable units on Big Pine. Key Largo folks don’t want 135
units at Rowell’s Marina, and Big Pine doesn’t want to lose Seahorse
with its 128 units that rent for under $500 per month. The hurricane
evacuation benefit becomes a sham when you delete 28 units from Big
Pine, and add 130 to Key Largo.
Key Largo also raises a good
argument that they have the same problems with workforce as the rest of
Monroe County, and they get 135 new market rate units to which they have
to supply services, and not one unit to house the folks necessary to
provide those services.
And then there is the argument that
by allowing affordable units outside ROGO, we are defeating the purpose
of managed growth anyway, and increasing by 100 the number of housing
units.
We need affordable housing for our
workforce. Service workers and services workers are leaving in droves
due to housing costs. There must be a way to stem the tide.
This newest proposal doesn’t appear
to us to be a good way to do that in any manner. We lose affordable
units with every transfer. We gain market rate units that will probably
be bought by part-time residents. We increase the potential population,
even knowing that we can’t get out of here in the state-mandated 24-hour
period in the face of a major storm. We make no concessions for
workforce housing for the areas gaining none.
There are a lot of fatal flaws in
this proposal.
The most serious flaw is that
developers can buy our affordable housing stock, hold it over our heads
that they can do way with it, and negotiate a better deal for
themselves.
The county should keep what control
it has and instead look at innovative ways to option or buy our
remaining trailer parks. |
