6-8-21 9A&9B Longwater and BellmarTrochessettAimee
From:
Sent:
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Patricia Forkan < pforkan@comcast.net>
Thursday, June 03, 2021 12:55 PM
TaylorPenny; Burt.Sanders@colliercou ntyfl.gov; McDanielBill; SolisAndy; Rick Locastro
TrochessettAimee; CaolzziAixa
review of materials regarding the RLSA/Eastern Lands
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Dear Commissioners,
The League of Women Voters has assembled a number of statements, news clips, etc to serve as a refresher for Vour
upcoming Bellmar/Longwater decision on June 8th. I left copies for each of you wlth Aimee Trochessett to distribute.
We hope you find the material useful.
Thank you for your hard work on the whole Eastern Lands situation. We hope you can find a way to say no to the
current proposal. The League is not opposed to growth. Rather, we support smart growth along with protecting the
endangered species found there,
Sincerely,
Patricia Forkan
Board member, LWVCC
Chair, Environmental Affairs Committee
RECENED
JUN O 3 ZO21
""sI3F?3[fs;;$f;H$I'oFor Your Review:
INDIVIDUAL COMMENTARY PRESENTED TO THE
BOARD OF COUNTY COMMISSTONERS,
COLLIER COUNTY COURTHOUSE
on Tuesday, May 25to, 2O2l
In opposition to the approval of two additional villaqes to be built in the
Rural Lands Stewardship Area (RLSA) of Eastern Collier Countv. Florida.
. The League of Women Voters of Collier County
. Registered voters and concerned citizensr The Conservancy of South West Florida
e The Calusa Group of the Sierra Club Florida
. South Florida Wildlands Association (to follow)
. The Center for Biological Diversity (to follow)
. Earlier LWV testimony. Guest editorials
By:
6t02t2021
LEAGUE OF
WOMEN VOTERSSof Collier County
Intro and overview on behalf of the LWV of Collier County
Good morning Commissioners. My name is ChallglleNJgklg.moe. l'm
here on behalf of the Collier County League of Women Voters as past
president, as a member of the environmental community and as a
member of the Florida LWV board of Directors.
We endorse quality development that simultaneously preserves critical
lands, wildlife, and water quality to benefit current and future
generations. To accomplish this, best practices need to be used by the
County in the analysis of the latest scientific data, county
demographics, and budgetary data. lf done properly, the result will be
a fair balance of the burden of growth between citizens, the
environment and developers. We believe a fair balance currently does
not exist with Longwater and Bellmar. The numbers don't add up
putting too much of the burden on the residents of Collier County, not
only in increased taxes, but more traffic and a diminished quality of life.
There are also major inconsistencies with the goals of the RLSA. These
problems need to be addressed today.
I would like to remind you League members have been very
involved in the RLSA program for MANY years - some
from the initiation of the RLSA program, through the Five-year
Review, and through the recent Two-Year Review process. As
concerned citizens, they will be discussing in detail the following
topics:
Fiscal neutrality will not be achieved when the economic
assessment uses unrealistically low population estimates.
The water and sewer infrastructure is far from fiscally neutral.
. The County is asked to sign off on a conceptual town plan
that is not a formal application for a town. This is an attempt
. 'to sidestep fundamental procedures and would set a terrible
precedent for future development in the RLSA.
The "town" envisioned in the "town agreement" is
fragmented into non-contiguous sections and is nothing
more than a sprawling development all along Big Cypress
Parkway, exactly contrary to the goals of the RLSA to avoid
sprawl.
Developers must commit to building village centers upfront
otherwise the county will pay the cost of increased pressure on
existing infrastructure.
Charlotte Nycklemoe
LWVCC, Past President
LWVFL, Board of Director's
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CoNspR\ANCY
ot SouthwestFlorida
OUR WATEB, LAND, WILOLIFE, FUTUEE.
Protecting Southwest Florida's uniqua natural
'hvironmen.t
and quality of tife ... now and torevet-
May 28,2021
The followinB is a summary list of issues regarding Longwater Village SRA, Bellmar Village SRA, and the
Town Agreement.
The Goal of the RLSA is to direct development or intensification away from listed species and
their habitat. Contrary to the RLSA's goal, 2,000 acres of Longwater and Bellma/s sites would
be directly within primary panther habitat, which is some of the last remaining habitat of our
state animal and symbol of Florida. The Town of Big Cypress, would increase the total loss of
primary panther habitat to over 3,200 acres.
Longwater and Bellmar will result in a 592.2 Million deficit for traffic improvements based on
the percentage of improvements the developments' traffic will consume and after impact fee
rates.
An economic assessment is only as good as its inputs. Longwater and Bellma/s economic
assessments include a hiBh vacancy rate, which is unlikely for rural areas, and provides a low
number of persons per housing unit, These inputs underestimate the village populations, which
ultimately understates costs for services such as fire, EMt police, and schools.
The developer failed to include in their economic assessment an analysis of Longwater's and
Bellmar's fiscal impact on water and wastewater, which is clearly required per RLSA policy 4.18
and 4.08.07.1. lust because the CCWSD is an enterprise fund which impacts ratepayert does
not abdicate the developerfrom providing this required assessment. Ratepayers are also Collier
County taxpayers.
Collier County staff provided conflicting analyses of Longwater and Bellma/s impacts on water
and wastewater at the BCC and CCPC hearings. The Conservancy still believes that Longwater
and Bellmar are not fiscally neutral for impacts to water and wastewater, as is legally required.
It is unfair to ratepayers that the CCWSD will reimburse Collier Enterprises 52.7 Million for
upsizing transmission mains between Rivergrass and Longwater. This is a costs that should be
paid by the developer.
Fhe Overlay requires that villages demonstrate they are fiscally neutral or positive os o whole to
Collier County ond its tax base, which is unique only to SRAS. Longwater and Bellmar must be
treated differently than PUDs when assessing the project's fiscal impacts. However, staff stated
that they are using an existing framework for assessing SRAs. As example, they are pulling from a
"basket of funding" sources, such asfuel taxes, to payfor road improvements. Thisshould not
be allowed as all costs for SRAs must be paid for by the SRA and the developer.
The Town Agreement is meant to fix serious traffic issues that will be caused by the villages by
creating a Town Core and keeping residents local. However, the Town Core provides no timing
or phasing mechanism which requires the developer to provide retail, office or employment
opportunities. lt all depends on market conditions, which could be after 20 years, or after oll
homes are built within the villages. Paragraph 3, is a weak attempt to fix the issue, because the
CorE€wancy of Soslhn€st Flodda has b€n awE d€d CtEdty llavilatorb prestiiorjs 4€tar top ratirq foi good
gownanca, sound liscaj managem€nt and co.nr trnert to accountatility and tramparcncy, Chadty Navigator ls Amgicab
brgest arid rnost rssp@l€d indep€ndent q€luator of cfErities.
I Naplss, Florida34102 | 239.262.O3O4 t Fax 239.262.0672 | www. conservancy. org1495 Smith Preserv€ Way
only requirement of the developer is to hold a public hearing for the Town sRA. once that
hearing is held, there is no binding stipulation requirint that the developer begin construction of
the town.
The Town Core and Village Centers lack any plans to demonstrate whether they meet the
requirements of the RLSA. The Village Centers and the Town Core are supposed to be the
vibrant centers orthe "heart''ofthe communities. However, the applicant provides no
drawings as to the street layout or design.
The collier MPo's 2045 LRTP predicts serious traffic congestion issues on lmmokalee Rd, even
after committed improvement are completed. This recent survey provided by collier county
transportation department corroborates the fact that lmmokalee Road will have serious
unresolved traffic issues: httos:/,/www.survevmonkev.com/r/33gc86M
Contrary to staff and the applicant's comments, the Villages w// be using Big Cypress parkway
frequently' our traffic expert found that 8o% of vehicle trips on Big cypress parkway will be
from village traffic. Collier County taxpayers will be subsidizing Big Cypress parkway.
Collier County Planning staff stated that Longwater and Bellmar,s designs depict typical
suburban development, rather than a village. substantial changes were not made to Longwater
and Bellma/s master plans to solve the laundry list of design issues mentioned by staff in
previous reviews.
Longwater and Bellmar's traffic will exacerbate failing road segments, even after planned road
improvements are considered.
The R[sl(s goal is to prevent the premature conversion ofagricultural lands to non-agricultural
uses. However, Longwater and Bellma/s loss of agricultural lands equates to 10%of thestate,s
total yearly loss.
The sprawling development pattern of the villages, and the strip commercial rown core design
is opposite of the intent of the RLsA to create compact, pedestrian-friendly sRAs. As example,
the village centers and the Town Core are located along Big Cypress parkway, to capture
vehicular drive by traffig but the centers and cores are vast distances from most neighborhoods.
Furthermore, lake sizes within Longwater and Bellmar far exceed the allowable square foot per
the LDC, creating sprawling plans.
comments from Bonnie Michaels. BCC meeting for Longwater, Bellmar
and the Town co-cept . I'Aay ZS, ZOZI
I'm Bonnie Michaels speaking for the League of Women voters. r've been
a taxpayer in cottier county for over 20 years and I have a great interest
in where | [ive. I have attended a[ the RLSA meetings.
I have one important message. "Be sure you have no doubt thot all the
information presented by staff and coltier Enterprises is IM% accurate.,,
Remember the concerns of those who spoke before me.
You have a monumental decision that witt change cc forever. The most
important thing you can do is to be absotutely sure about the detaits
about the crucial issues that have been disputed.
lf you have any doubt about what others pointed out such as:
. Increased traffic
o Costs of roadsr Fragmenting of floways. Fiscal neutrality impossible as impact fees won't cover costs. Devetopment directed toward instead of away from tisted species
habitat...How can you have a development a mile away from the
Panther Refuge?
Vote to get more input.
Ask yoursetf, witl we have real watkable and bikeabte
neighborhoods or more of the same gated ones? where is the smartgrowth and innovation?
You are asked to sign off on a conceptual town ptan that is not a
formal apptication for a town. This is a terrible precedent and
attempt to sidestep fundamenta[ procedures. rt feets like the cart
before the horse. And then there is the timing...when?
Everyone loves the land conseryation perk but much of that land underthe RLSA rules couldn,t be devetoped anyway.
Restoration and panther corridors are popular but it witt be the tast thing
on the [ist...l5-20 years before that is complete. lt is atso very expensive.
What happens to witdtife in the meantime? Guess they witt be roaming in
neighborhoods tooking for shelter and food.
Landowners already are publicizing the town, before approvat, with steek
brochures and are pushing to move on quickty. What difference does a
day, a week or month make to get it right?
Commissioners have come and gone over the years and during this
process. Good information, decisions, and dialogue have gone by the
wayside. For exampte, there was some agreement back in 2008 until the
surprise announcement of the increase of 16,000 acres to 45,000 acres
without public input. This makes me wary and not so trustfut untit att
info is vetted.
Staff has left and been replaced as wett. Kris Van Langen is gone and so
are many of the white paper suggestions. Staff recommendations have
changed through the years as well. Staff today says they are using up to
date science for panthers. What does that mean and why are there
discrepancies and differences of opinion? Detaits, detaits.
Before they dig up the earth and disptace gopher tortoise homes, bird
nests, take away forging for bears, deer and panthers, and more, be sure
you have no absotutety no doubt that all the information is 100%
accurate.
Have courage to make the decision that makes Collier County a good
model for growth and not a disaster. Our quatity of tife and your legacy is
on the [ine.
Fiscal Neutralltv comments on Understatement of Population in lonswater and Bellmar
May25,2O2l
Good afternoon Commissioners. I am Lynn Martin, a full-time resident of Collier County and a
member of the Environmental Affairs Committee of the League of Women Voters.
In looking at the Economic Assessments for Longwater and Bellmar, I question whether these
new developments will actually be fiscally neutral to the tax base of the County, as required.
The SRA Application shows a commitment of 90% single family homes and !0% multi-family
while the economic assessment shows 58 % single family and 42% multi-family. The
multifamily homes assume 1.05 permanent residents while the single-family homes assume
2.21 permanent residents. lf the applicant builds 90% single family homes instead of 58o/o,
there will be over 1,000 additional permanent residents.
The persons per household is inconsistent with the Collier County average of 2.45 persons per
household used in impact fee studies which is the BEBR 2017 estimate. The Florida lmpact Fee
Statute requires the use ofthe most recent and localized data. The 2045 LRTP which uses
recent and audited TAz data, estimates between 3 and 3.75 persons per household specifically
in the RLSA. Even with the 38% vacancy rate used by DPFG, the numbers don't work.
By assuming a greater percentage of multifamily homes, and not using recent and localized
data, the total number of residents and the number of children is undercounted in the
economic assessment. 669 students in a community of 2,75O homes in eastern collier doesn't
make sense. This understatement impacts the cost of providing all the services required to
support the community: water, wastewater, schools, law enforcement, fire, ems, library
materials; traffic would be understated with more cars on the road per household.
With more people than planned, additional costs will be incurred to add infrastructure to
maintain the required county level of service. The villages will use more of the capacity of the
new water and wastewater treatment plant than projected. The level of service for water was
lowered by the county in 2020 to increase the capacity ofthe current system and move the
capital expenditures for the new facilities beyond the 10 year horizon of the study. Will it be
lowered again? And while Collier Enterprises should be paying a higher impact fee since
Longwater and Bellmar aren't included in the lmpact Fee Study, instead, the County will be
paying Collier Enterprises up to 52.7 million to upsize the pipes in Rivergrass to serve as a
conduit to Longwater. And, shouldn't the economic assessment at least use the same level of
service for Longwater and Bellmar as was used for Rivergrass?
The economic assessment must use the most recent localized population data to make sure
the developer is paying their fair share of the costs of growth from this village. With a
discrepancy in population, these villages will not achieve fiscal neutrality as required without
an additional assessment.
My name is Rhonda Roffand I will be commenting today on behalf of the 2000 SWFL members
of S" Cul*u G-up of Si" C including our almost 700 members in Collier County.
The Siera Club opposes the proposed developments for Longwater and Bellmar as they are not
aligned with the original intent of the RLSA program, will cause more traffio congestion within
our Counfr, and will put the taxpayers of Collier County on the hook for tens of millions of
dollars.
Let's be clear about what the Villages being considered today really are: they are taxpayer subsidized
communities that are fraught with muddled land use planning. If the County Commissioners move
fiorward widr these two Villages it will also create a requirement for new and expanded roadways. Some
estimates show that Longwater and Bellmar will result in more than $90 million deficit traftic impacts.
Already Collier County has significant traffic congestion and Longwater and Bellmar will cause
significant trafic impacts on the alr€ady stranded Immokalee Road. Collier County already has several
failing roadways and moving forward with these projects will firther deteriorate the county's existing
infrastructure. Having to create more roadways will only strain the County's budget for years to come,
adding traffic congestion to the region, and killing wildlife such as the Florida panther and the FL black
bear with additional road collisions. Furthermore, the proposed developments of Longwater and Bellmar
will result in the destruction ofover 2,000 acres of primarily panther habitat. It is quite simple: the fiscal
costs to taxpayers and environmental costs ofthese developments far exoeed any ofthe perceived
economic benefits.
New since the RLSA and the proposal ofthese villages:
Climate concerns including forced migration from the coasts
New pressures on listed species including other new development in Panther and bear habitat,
expanded use in BCNP and proposed VSP in FPNWR
Simultaleously and serendipitously, fl vot€rs passed the LWC amendment, improperly spent
until recently, but, thanks to Carlton Ward and Gov DeSantis, $300M will be targeted toward
protecting wildlife conidors including agricultural land and heritage.
L
2.
.).
Another bill Gov Desantis recently signed will allocate $200M for resiliency planning, mainly to
protect people and property from sea level rise and increasingly intense storms.
Gov DeSaltis recently authorized the buyout of20,000 acres in westem broward county which
was owned by the Kanter family to avsrt their proposal to explore and possibly drill or fi-ack for
oil and gas.
So.. ..the county wants the revenue, Collier enterprises wants to sell the land, and society has a collective
need to preserve what is left ofthe wildlands for the myriad benefits they aford all ofus collectively,
Housing to accommodate our burgeoning population must be planned much more smartly, clustered in
less sensitive habitat, preferably by infill. Can you see that this is all possible using a better paradigm?
In closing, the Siera Club respectfully urges you to not move forward with approving the villages of
Longwater and Beltmar. Doing so will only create more sprawling, low density developments within
Collier County that are antithetical to smart growth principles. Instead we invite you to be on the right
side ofhistory and protect the remaining working and wild lands of rural Collier County for the benefrt of
future generations.
5.
I am Susan Calkins, and I am speaking to the issue of the town agreement you are
being asked to approve. lt isn't a town plan but rather a promise to submit one
(comprised of these villages) sometime in the future. No application has been
submitted and there has been no substantive staff analysis of consistency with
the RLSAO. Moreover, this'town," as depicted in Collier Enterprises
advertisements, is fragmented into non-contiguous sections and is really nothing
more than a sprawling development of gated "villages" strung out along Big
Cypress Parkway - villages which, in the words of county staff's own consistency
memorandum, are "essentially a suburban development plan placed in the RLSA
and contrary to what is intended in the RLSAO." This proposed town doesn't
avoid sprawl, it lS sprawl. lt doesn't discourage automobile trips, it necessitates
them.
Additionally, this "agreement" shifts many of the costs of the town to the County
- again, contrary to RL54 policies. In this agreement the County pays for a
Community Park, despite the fact the RLSA requires the applicant to provide the
community park. Similarly, the County is paying some permit fees and mitigation
costs normally paid by the applicant. You had better be sure this agreement is not
"giving away" other requirements of the RLSAO.
Furthermore, this Agreement makes no promises. The 515 acres added by the
Town Agreement will be primarily a commercial area ("town core") spread out
along Big Cypress Parkway. However, the Town Agreement states that "There
shall be no timins conditions placed on the development of the Town Core which
will be developed based on market conditions." Timing on building a commercial
area is key to the self-sufficiency intended for towns in the RLSA, yet Collier
Enterprises may not build the proposed town core for decades - or maybe
market conditions will never support such a proposal.
As I said, Collier Enterprises has not yet submitted a town application but rather a
promise to submit one under certain conditions favorable to Collier Enterprises.
ln effeclthis proposal makes a mockery of the RLSA program by side-stepping
fundamental procedures and setting a terrible precedent for the future
development of the 36,000 acres remaining to be developed within the RLSA.
As stated earlier, we are witnessing just the beginning of development within the
RLSA - this is no time to be sloppy. No time to ignore the intent of the RLSA
program. This is the time to get it right. We know what towns look like (think Ave
Maria and Babcock Ranch) - and this proposal surely won't create one.
Good Evening Commissioners, l'm Gavlene Vasaturo and a member of
the LWVCC.
Bellmar Villase
Refuge.
How can this be consistent with the RLSA's requirement to direct
development away from listed species habitat?
The Applicant's environmental consultant (or Collier Enterprises)
concluded in essence that the sites for Longwater and Bellmar have
little to no value as panther habitat. That's because Collier Enterprises
ignores the best available science on panther habitat-such as the 2006
Kautz Study and the USFWS descriptive land cover types for panthers.
An Applicant is required to update the natural resource scoring for its
proposed SRA- Collier Enterprises updated its panther surveys and the
telemetry data, but refuses to consider the panther studies that have
specifically delineated primary panther habitat. Collier Enterprises says
it does not need to consider these studies because their sites are not
listed as "preferred" panther habitat in the 2002 LDC. However,
panther scientists now consider more land cover types than those listed
in the 2002 LDC to be preferred panther habitat.
Locating Longwater and especially Bellmar in these areas will adversely
impact long-term survival of panthers.
entified as
ln return
12,300 acres of land preserved.
However, Collier Enterprises removed the wetlands restoration from its
plan that is critical to restoring the Camp Keais flowway. Two months
ago, USFWS Panther Refuge Manager Kevin Godsea wrote the Collier
County Planning Commission explaining how important restoration of
this flow way is for downstream conservation lands such as the panther
refuge and asked the County to require hydrological restoration of
Camp Keais Strand. Mr. Godsea pointed out that two farm fields in SSA
15 restrict the flowway to a narrow point and that restoring these farm
fields to wetlands is necessary to restore the flowway. He noted that
the SSA restoration plan had included restoring these farm fields, but
then Collier Enterprises removed this from its plan. The letter concludes
"we believe that [this wetlands restoration] should [be included] as it
was clearly the intent when the RLSA was established."
Before making your decision on these villages, please ask Collier
Enterprises to put restoration ofthese farm fields back into its restoration
plan, [or to stand behind its promise by stating in the SSA that it is not
entitled to restoration credits until the flow-way has been restored.]
Also. Collier Enterprises is not reallv sivins up rishts to develop the
12.300 acres because the RLSA Program alreadv prohibits residential
development on the maioritv of these acres.
You can't put L house per 5 acres in most ofthe areas set aside as SSAs
because they are nearly all FSAs, HSAs and WRAs. The RLSA program
prohibits development, mining and recreation in these areas.
More importantly, while CE is setting aside "environmentally sensitive,,
land, it will be fragmenting this land by constructing roads through the
Water Retention area that is SSA 17 and i.8 and surrounding large
portions of this WRA with houses, roads, people and lights. Scientific
studies show that such fragmentation and disturbances will constrain
wildlife movement and seriously degrade the WRA.
when Countv Staff acknowledges that impact fees will not cover the
costs of infrastructure necessary to support these villages and Staff
The RLSA Program requires an Applicant to show that its project will be
fiscally neutral to the County at build-out. lt is not appropriate for a
RLSA Developer to rely on funds from taxpayers or other County
funding sources to meet this requirement. [ln return for being allowed
to develop this rural area where infrastructure costs will be much
higher than for developed areas ofthe County, the Program requires
Landowners to show that they will cover the costs for needed
infrastructu re.]
Ask County Staff how Longwater and Bellmar can be considered fiscally
neutral under the requirements of the RLSA Program.
make up the shortfall?
LEAGUE OF
WOMEN VOTERS8of Collier County
Judy HushoQ - Comments on Bellmar /Longwater for the BCC, May ZS,2O2L
As you know Bellmar, Longwater and Rivergrass together make up the Big cypress stewardship
District, one of only two privately owned special stewardship Districts authorized by the state
of Florida to be formed in collier county. The other is the Ave Maria stewardship District,
The Big cypress Stewardship District Act has distina purposes and requirements: (1.) to provide
the landowner, Collier Enterprises, with the abilitv to fund basic infrastructure and services
required for developments within the District through, for example, the issuance of revenue
bonds repaid sofely by the land/property owners in the District; and (21to ensure thot collier
of those privote develooments
As was required of Barron collier in the development of the Ave Maria stewardship District,
collier Enterprises should also pay for ALL infrastructure within its Big cypress stewardship
District without expecting one cent from Collier County or its Taxpayers.
When Barron Collier developed Ave Maria, it independently arranged for the funding
maintenance and operation of all infrastructure improvements including public roadways,
water and wastewater facilities, parks, schools, etc. with an estimated cost of over 5650 Million
through the issuance of revenue bonds which did not in anylnay impact collier county or its
general taxpayers.
In fact, the only aspect ofthe development of Ave Maria which impacted county taxpayers and
for which the County's lmpact Fee methodology was employed was in connection with the
widening of a regional road, Oil Well Road. The cost to the County was S20M for which, over
the past 2o-years, the Ave Maria Stewardship District has repaid STMillion through impact fees
payable to the County as homes are occupied in Ave Maria.
The landowner infrastructure-funding requirement that applied to the Ave Maria stewarship
District (and frankly to all such other privately-owned and managed stewarship Districts in the
State of Florida) should also apply to Collier Enterprises and its development of Bellmar as well
as all of its developments within its Big Cypress Stewardship District.
ln 2004, Big Cypress sought and was granted permission, at its sole cost and expense, to install
and oversee the infrastructure for water, wastewater and stormwater within its borders, in
addition to other functions. Until August of 2018 plans were underway to install wells, etc.
Then, as a result of negotiations between Collier Enterprises and the Collier County Water and
Sewer District, things changed and the County expanded its service territory into the rural
undeveloped areas ofthe County to construct the approximately $76M Northeast Utility Facility
(NEUF) required to serve new customer growth in the proposed new villages.
We need to keep things in focus. Ave Maria also has a state approved Stewardship District and
the landowners, at their sole cost and expense, installed wells, treatment plants, piping,
internal roadways, etc. To finance this, they floated 5651M in Ave Maria Bonds.
Neither Collier Enterprises nor the Commissioners have a right to ignore the requirements of
State Law and burden the County and its Taxpayers with Collier Enterprises' infrastructure
funding obligations within the boundaries of its own Stewardship District.
Collier Enterprises should have similar debt obligations for their developments to those of Ave
Maria.
The County is relying on impact fees to pay back the County's utility investments. Mark
lssacson stated at a Feb 24 public meeting that "impact fees do not and are not intended to pay
for growth; the general fund must loan the impact fee fund hundreds of millions to cover the
impact fee fund debt." This is especially true for development in rural areas, not for infill.
For the NEUF, for example, 66% of the water will to to the three Collier Enterprises villag€s, but
the amount paid in impact fees falls short of costs by S43M. There are other expenses
associated with piping from the NEUF to the developments which the developer is not picking
up.
The County's impact fee formulas are not, and were never intended to be, applicable to rural
areas where there is no existing infrastructure. The County should not be relying on impact fees
to cover development in areas without some existing infrastructure. These are three de novo
communities. Lucy Gallo of DPFG, the creator of Collier Enterprises' own economic impact
assessments for Bellmar, Longwater and Rivergrass, was part of an impact fee assessment team
in Sarasota County that concluded that "impact fees do not cover development in rural areas,"
and that two different types of impact fee calculations are required when determining the true
impact of a development in urban infill versus rural areas.
Per RLSA Rules, Collier Enterprises is required to provide a fiscal analysis for the impacts of
each of these villages on the Collier County Water & Sewer District. However, this analysis
was never provided by the developer.
There is a way to keep the taxpayers of Collier County whole.
The cMP 4.08.07.1.2 states that "lf a negative fiscal impact of the project to a unit of local
government is identified, the landowner will accede to a special assessment on his property
to offset such a shortfall or in the alternative make a lump sum payment to the unit of local
government equal to the present value of th€ estimated shortfall."
The rules of the County are clear and say that when there is a shortfall, the developer is
responsible forpayingthe difference. Inthiscasethe BCCshould requestthis payment. You
should also require a more open and verifiable model for calculating fiscal neutrality with
separate options for infill and rural development. In addition to the impact fees not covering
development, the impact fee calculations are biased to the low side for population and
transportation which benefits the developer. Lynn Martin has explained this further, suffice it
to say that the input values to the model are under-valued resulting in an unreasonable
calculation of fiscal neutrality
This all means that a develope/s contribution of at least S18OM is required In addition to
lmpact Fees for these developments. This is $60M for each of the three developments. This
developerrs contribution needs to be calculated and assessed before construction and must
consider the NEUF and the fact that the development is not fiscally neutral. Taxpayers should
not be required to cover this.
As Commissioners it is your obligation to see that neither he County Taxpayers nor the NE Rate
Payers are not burdened with the development expenses for these developments and
development should be paused until ways are negotiated to ensure that this happens.
Reference:
GMP Section 4.08.07.1.2
lmposition ofSpecial Assessments. lf the Report identifies a negative fiscal impact ofthe project
to a unit of local government referenced above, the landowner will accede to a special
assessment on his property to offset such a shortfall or in the alternative make a lump sum
payment to the unit of local government equal to the present value ofthe estimated shortfall.
The BCC may grant a waiver to accommodate affordable housing.
VILI.AGE CENTERS - NO GUARANTEE THEY WILL BE BUILT TIMETI IF EVER
The question I raise today is, how committed are developers to building village centeE in a
tlmely manner, if at all. This is a very serious issues for the County, especially when considering
the cumulatlve effect of multiple developments in the R[SA. Wlthout village centers, the
burden of increased traffic and pressure on existlng amenltles will fall on the shoulders of the
County and its residents.
When reviewing the lontwater and Belmar applications, staff added a village center trigger
point at approximately 2/3 occupancy. Two previously approved RISA developments,
Rivergrass and Hyde Park, do not have villate center trigger polnts. They could go as high as
100% occupancy before ever building a village center. So, what do those numbers look like?
For Longwater and Belmar that translates to approxlmately 3, 500 homes. For Rivergrass and
Hyde Park,43O0 homes. The total for all four villages, is 7,8fl) homes without any village
center commltments. fhese numbers are estimates, but you get the idea.
One miSht suSSest that the likelihood of this scenarlo playing out is slim. Surely, developers will
build a village center sooner, Maybe, but they have no obllgation to do so. We've learned from
history that build-out predictions cannot be trusted. Homes In Ava Maria have been selling for
15 years and to date less than half of the homes have been sold. lf using the parameters set
forth for Longwater and Belmar, theoretically Ava Maria would not yet be required to build a
village center. However, Ava Maria committed to a village center upfront, investing in the best
interests of future resldents. Longwater and Bellmar residents could spend loto 15 years
driving long distances for goods and services. where do they go? To Golden Gate Estates or
other parts of colller county. The applicant suggests their developments and proposed village
centeE will help Golden Gate residents but in reality, it is dolng Just the opposite by adding
pressure on a community already struggling for lack of amenities and increasing traffic on an
already overloaded road system.
When it comes to the tlming of village centers, we've heard the phrase ,.based on market
conditions". Sounds good but it ls just a way of avoiding making a commltment. Without
upfront village center commitments for Longwater and Belmar, the county could be facing
huge infrastructure costs down the road.
We have to do better, and we need to do it today,
League of Women Voters
Loralee LeBoeuf
1590 Galleon Drive
Naples, FL 34X.02
CorqspRvANCY
ot Southwest Florida
OUB WATER, LAND, WILDLIFE. FUTUBE.
Protecting souttnsst Florid.a's anlque nalufal enulronment and quality ot life.., now and fotever'
Longwater and Bellmar Villages:
A grand deal or a raw deal for Collier County?
on Tuesday, May 25, the collier county Board of county commissioners will cast
the final vote on two proposed 1,000-acre villages, called Longwater and Bellmar,
located in the Rural Lands Stewardship Area (RLISA) of eastern Collier County. The
landowner-developer is Collier Enterprises. The location of both 1,000-acre
villages is east of Golden Gate Estates and south of Oil Well Rd. Longwater is
proposed less than a quarter mile east of De soto Blvd N and would extend from
oil well Road to the north to about L2th Ave NE to the south. Bellmar is proposed
about a half mile east of De Soto Blvd N and would extend from about 4th Ave NE
to the north to about 8th Ave SE to the south. The developer has plans to
combine Longwater, Bellmar, and Rivergrass (their third village) into an even
larger town, called Town of Big Cypress, by connecting all three villages with a
515-acre Town Core along a new road, called Big Cypress Parkway. The 5111
million Big Cypress Parkwayl will be mostly be funded by Collier County's
taxpayers.
How Manv Homes and People are anticipated?
According to the developer's plans, the two villages would add approximately
5,300 homes and 11,000 permanent and seasonal residents to Collier County.
When Rivergrass' population is included, approximately 16,000 new residents
would live in the developer's three villages just east of Golden Gate Estates.2
I Total estimated cost of Big Cypress Parkway is S110,854,883 from Collier MPOs 2040 LRTP Amendment Adoption
Repon -Table 5 - Cost of LRTP Amendment Needs Projects.
, Hyde park village is another village off of De Soto Elvd and oil well Road from a different developer. Hyde Park
was recently approved and it will add 1,800 more homes and an additional 4300 residents, accordinS to the
develope/s plan. lf all four villages are approved, they would equate to approximately 20,000 new residents in the
same viciniW of eastern Collier.
Page 1115
Additional housing within the Town Core will add even more people. The
estimated build out date of all three villages is twelve years from approval or
approximately year 2O32-2033. The developer states that the Town Core will be
built based on market conditions. However, it is nearly certain that the Town
Core will not be built until the taxpayer-funded Big Cypress Parkway is built.
ls the 12.300 acre preserve a fair exchange for a new town
At the hearings and in their advertising, Collier Enterprises proudly exclaims that
in exchange forthe County's approval ofthree 1,000-acre villages and a 5lS-acre
town core, that 12,300-acres will be preserved. The developer's website states:
"Collier Enterprises will preserve more than 72,@0 environmentolly sensitive acres
as port of the plan for the Town of Big Cypress ond the villoges of Rivergross,
Longwoter, ond Bellmor."3 However, that statement leaves out a lot of
informationregardingthepreservethatyoushouldknow. InrealitytheCountyis
getting a raw deal. Here is what Collier Enterprises is 4! telling you:
o IN EXCHANGE FOR THE PRESERVE, THE DEVELOPER CAN BUILD SIX
VILLAGES, NOT THREE! In exchange for those 12,300 acres, the landowner
generates enough credits to not only build Rivergrass, Longwater and
Bellmar Villages plus the 515-acre Town Core, but they can build three
additional villages of nearly 1,000-acre each!a That's a total of six villages,
3 TownofBigcypress.com. Accessed Apr'll 30, 2O2L.
'The applicant earns credits for preserving areas called "Stewardship Sending Areas" or SSAS. These SSAS
Senerate credits toward Stewardship Receiving Areas (SRAS). SRAs include villages and towns. Th€ developer wlll
generate 52,295 credhs for setting aside SSA14 SSA15, SSA17, and SSA18. {SSA14 = 12,893 credits; SSA 15 =
31,367 credits;SSA 17 = 4,528 credits; SSA 18 = 3,507 credits) Those SSAS equate to 12,372 acres (SSALA = L,7f3
acres; SSA 15 = 5,253 acres; SSA 17:3,148 acres; SSA 18 = 2,258 acres). The developer is using credits right now
from those ssAs toward three villages totaling 3,OOO acres: Rivergrass, Longwater, and Bellmar. Rivergrass
Resolution 2020-024 shows that 6,198 credits were used; Longwate/s Submittal 5 -SRA credit agreement shows
that 6,697 credits will be used; Bellmars's Submittal 6 - SRA Credit agreement shows that 6,742 credits will be
used. Total Credits applied toward 3,000 acres for 3 vlllages = 19,637. The proposed Town Core would consume
an estimated 3,559 credits (515.1 acres - 159.2 acres for public beneflt acres which do not consume credits per
Amendment 4-20 = 355.9 acres); 355.9 acres x 10 credits = 3,559 credits). Credits used forvillages = 19,637 +
estimated 3,559 credits used per Town Core = 23,196 estimated credits consumed. Therefore, there are 29,099
remaining credits (52,295 - 23,796 = 29,099 remaining credits.) Based onthe proposed RLSAAmendments, 10
credits per SRA acre would be requlred. So 29,009 acres/ 10 credits = 2,909 remaining SRA acres, Thls meansthat
Page 2116
from the 14300 acres of preserves there are enough ffedits for an addrtional 2,9o9-acae Town or threeaddltional 970 acre virrages, in addhion to long' ater, Belmar, and Rivergrass and the srs-Town core,5 Math:5sA14, 15, u,and 18 = 5,0s7.2 acres of wRAs; 4,260.4 acres of FsAs; and 2,996.4 acres of HsAs. poticy5.1
prohibits development and miningwithinall FsAs, unless the acre has an NRt score of 1.2 or less. There are 77acres within the acres of FsAs that score 1.2 or less. Thus,4,183 acres ofthe totar 4280.4 acres of FsAs isprotected' Policy 5'3.1 prohibits site clearing and alteratlon in FsAs, wRAs, and HsAs within 80% of the propery,
unless lands are to be used for agriculture. since FsAs are already protected, then we will apply policy s-g.r'to tneremaining 8,053 acres of wRAs and HsAs. 8,053 x 80% = 6,442 acres. Thus, there are approximately 6,442 ares ofwRAs and HsAs which are protected, plus 4,183 acres of FsAs = 10,62s total areas ofthe 12,372 site ls alreadyproteded simply by being located within the RLSA. 10,625 / 12,372 = 86%.
plus the town core! should collier Enterprises choose to build villages that
are less than 1,000 acres, they could build far more than six villages.
Another option the landowner has, in exchange for the credits generated
from the 72,300-acre preserve, is to build Longwater, Bellmar, and
Rivergrass Village and the 515-acre Town Core
acre Town!
p/us an addltional 2,909
PRESERVE SITE.
Collier Enterprises' is not giving up rights to develop all 12,300 acres by
placing those lands in preservation. The 12,300-acre property is located in
an area of the RLSA that strictly limits development. In other words, even if
the developer wanted to develop the 12,300 acres, most of it is protected
anyway. Nearly all of the developerrs 12,300 acres are located in a
Flowway Stewardship Area (FSAs), Habitat Stewardship Areas (HSAs), or
Water Retention Areas (WRAs). The RLSA program includes policy 5.3.1,
which states that only 20% of FSAs, HSAs, and WRAS, sites can be cleared
and altered, thus, 80% cannot be cleared and altered. Also, policy 5.1
prohibits all residential uses, general conditional uses, mining, and
recreational uses within FSAs, unless the lands have an NRI score ol !,2 or
less. Under these policies, 10,825 acres or gO% ofthe 12,300 acre preserve
would be off limits to development and mining by virtue of the property,s
location within the RLSA.S Furthermore, since the preserve is an
agricultural preserve, the landowner may continue to use the lands for
farming and ranching operations.
Page 3115
Developers who choose to utilize benefits of the RLSA program can earn a
2O-fold increase in residential density over the baseline zoning. Instead of
building one home per 5 acres, they can build up to 4 homes per acre. This
is accomplished through a credit system. In exchange for the 12,300 acre
preserve, Collier Enterprises will generate enough credits to entitle more
than 20,918 homes over 5,230 acres, should they choose to maximize
allowable density of 4 homes per acre.6 Furthermore, the developer can
continue to utilize the 12,300 acre preserve for agricultural uses, in the
same way they have being using the land for decades. However, if the
developer chooses to build under the baseline zoning of one home per 5
acres and not set aside the preserved lands, Collier Enterprises would be
allowed to build less than 2,500 homes over a 12,300 acre footprint.T
THE DEVELOPER STATES THEY ARE RESTORING FLOWWAYS WITHIN THE
CAMP KEAIS STRAND, WITHIN THE 12,300 ACRE PRESERVE, BUT THE
RESTORATION IS INADEQUATE FOR HYDROLOGIC RESTORATION.
Kevin Godsea, Refuge Manager of the US Fish and Wildlife Service's
(USFWS) Florida Panther National Wildlife Refuge (FPNWR), states in a
lettef to the Collier County Planning commission that the USFWS is
concerned that the villages' conservation plan omits important wetland
restoration activities necessary to improve and restore hydrology in the
Camp Keais Strand flow way:
'"The opplicotion does not oddress the need for hydrologic restoration
of the adjocent Camp Keias Strand Flowway Stewordship Area.
Hydrologic restoration of the Comp Keois Strand is clearly a
component of the RLSA Stewardship Sending Areos, ond is critically
important for downstream conservotion lands such as the FPNWR ...
6 rylggL Footnote 4 shows that SSA14, 15,77, and L8 = 12,372 total a(es and will generate 52,295 total credits for
Collier Enterprises, lf the RLSA Amendments are approved, then 10 credits per acre are required. Landowners who
opt to use the RLSA program can build u p to 4 homes per acre. Thus, 5 2,295 credits / 10 credits per acre = 5,229.5
SRA acres x 4 homes = 20,918 homes. lf the RLSA Amendments are not approved, then 8 credits per acre is
required. 52,295 credits / 8 credits per acre = 6,537 acres for sRAs. 6,537 acres x 4 = 26,147 homes. Although the
applicant is choosing to build less than 4 homes per acre for the villages, averaging about 2.6 homes per acre; the
applicant is still building far more homes per acre utilizing credits generated from the preserve than the than '-
home per 5 acres a llowed u nder baseline zoning. Furthermore, the three villages will only consume some of the
52,295 credits Senerated from the preserve. All other villages and/or Towns can be built at 4 homes per acre.
7 One home per 5 acrcs = -2O or zoy". L2,372 actes x2O% = 2,474 homes.
8 United States Department of Interior, United States Fish and Wildlife Service, Florida Panther National wildlife
Refuge. Letter to Collier County Planning Commission, dated May 2, 2021 from Kevin Godsea, Refuge Manager
Page 4115
The applicant's original plons for the Town of Rurol Londs West
included restoring these approximotely 935 qcres of farmlond in the
middle of Camp Keois Strond Stewardship flowwoy in SSA75, to
benefit the hydrology of downstream conse rvotion londs. This
wetlonds restorotion wos not included in the plans for Rivergrass
Village, Longwoter Village or Bellmar Village, ond we believe that it
should, os this type of wetland restorotion was cleorly the intent
when the RLSA was estoblished."
o LONGWATER AND BELLMAR ARE JUST ONE PART OF A MASSIVE
Development plans do not stop at Longwater and Bellmar. Twelve
landowners, including Collier Enterprises, comprise a group called Eastern
Collier Property Owner or ECPO. ECPO has plans for 45,000 acres of
development is enormous. Forty-five thousand acres is about the same
geographic extent as two Fort-Lauderdales or one Washington D.C.
Longwater and Bellmar fail to be fiscallv neutral:
Per the RLSA's rules, villages are required to be "plonned and designed to be
fiscally neutral or positive to Collier County . . ."0 In other words, developers
cannot rely on funds from taxpayers to cover costs for infrastructure and
services necessary to support the villages. This strict fiscal neutrality rule is
unique to RLSA developments because the RLSA is 20 to 30 miles from the
coast, making costs for pipes, roads, and services, such as school bussing, more
expensive than for developments within the County's urban boundary.
e A BUSINESS-AS-USUAL APPROACH 15 INAPPROPRIATE FOR ESTIMATING THE
VILLAGES'COSTS.
Despite the RLSA's unique but stringent rule for fiscal neutrality, Collier
County planning staff stated that they are using an existing framework for
calculating the villages'fair share of costs. A business-as-usua I approach to
calculating a developer's fair share of costs for infrastructure and services is
not appropriate for RLSA development miles past the urban boundary.
e Stantec Consulting Services (2018, August) Eastern Collier Multiple Species Habitat Conservation Plan.
ro Collier County Future Land Use Element RLSA Overlay Policy 4.18
Page5l16
Longwater and Bellmar must be held accountable to meet the R6A's strict
fiscal neutrality rules not using the existing framework.
LONGWATER AND BELLMAR WILL RESULT IN A 592.2 MILLION DEFICIT FOR
TRAFFIC IMPACTS.
The Conservancy's traffic expert, Norm Marshall of Smart Mobility, lnc.,
estimates that Longwater will result in a 548.4 million deficit and Bellmar
will result in a S43.8 million deficit for transportation improvements based
on the percentage of improvements the developments' traffic will consume
and after impact fee revenues are paid by the developer.ll County staff
believes they are charging the highest costs per current impact fee rates.
However, Villages are required to be held to a higher standard of fiscal
neutrality and cover all costs associated with the developments. Even if
staff correctly assumed that they cannot charge the developer any more,
per the RLSA's rules, staff should have recommended denial of the projects
because they are not fiscally neutral.
COLLIER COUNTY ERRONEOUSLY DISREGARDS VILLAGE TRAFFIC AS
BACKGROUND TRAFFIC WHEN ASSESSING FAIR SHARE OF COSTS FOR ROAD
IMPROVEMENTS.
How is the developer getting away with not paying their fair share of
impact fees for traffic? Collier County staff is failing to require the developer
to pay for traffic improvements due to population increases caused by the
villages. Staff claims that many of the road improvements that the county
is planning for, such as new and widened roads, are due to background
traffic from general population growth, rather than traffic from the
individual villages. However, the Long Range Transportation plan provides
evidence which proves that the Longwater and Bellma/s traffic 13 the
background traffic causing the need for some of the roadway
improvements. The County must acknowledge that the villages are the
cause of many of the planned road improvements and the developer must
pay for their portion of the road improvements.
TAXPAYERS WILL SUBSIDIZE A NEW ROAD USED PRIMARILY BY TRAFFIC
FROM THE DEVELOPER'S VILLAGES.
u Norm Marshall of Smart Mobility Inc. in a presentation to the Collier county Planning commission for Longwater
on February 18, 2021.
Page 5116
Traffic expert, Norm Marshall of Smart Mobility, estimates that 86% of the
vehicle miles traveled on Big Cypress Parkway will originate and/or end in
one of the three villages.l2 Even though Big Cypress Parkway will primarily
serve the villages, the 5111 million road is on the County's Long Range
Transportation Plan to be paid for by the Collier County taxpayers, not the
developer. Big Cypress Parkway is needed by the developments, so the
developer must pay for the road, not taxpayers.
IT IS INAPPROPRIATE TO USE FUEL TAXES AND GRANTS TO SUBSIDIZE
TRANSPORATION IMPROVEMENTS NECESSITED BY VILLAGE TRAFFIC.
Collier County staff stated at the Longwater and Bellmar hearings that they
can apply fuel tax revenue and grant monies to fund road improvements
that are needed due to projected population growth in eastern Collier.
However, because RLSA rules require that each development must be
fiscally neutral or positive to the county's tax base, it is inappropriate to
use fuel taxes to fund the road improvements caused by Longwater and
Bellmar, unless it can be demonstrated that the fuel tax revenue is
generated solely by the villages. Furthermore, grant monies should not be
used to fund road impiovements necessitated by village traffic. Grant
funds should be used to cover other projects, outside of the RLSA.
THE ECONOMIC ASSESSMENTS UNDERSTIMATE POPULATIONS OF THE
VILLAGES, THEREBY UNDERESTIMATING COSTS OF THE VILLAGES:
Because of the RLSA's fiscally neutrality requirement, an accurate economic
assessment is imperative to demonstrate that impact fees cover the
projects' costs not only for infrastructure, but also for services such as
emergency medical services {EMS), fire, schools, and sheriff protection.
However, Longwater and Bellma/s economic assessments underestimate
the village populations two ways:
(1) DPFG INCLUDES HIGH VACANCY RATE: Collier Enterprises'
economic consultant (DPFG) stated at the hearings that they
included Collier County's vacancy rate of 38% when determining
person's per housing unit.13 This vacancy rate of 38% is much
higherthan both lmmokaleeat2T% and Golden Gateattt%,
12 Norm Marshall of Smart Mobility tnc. Review of Rivergrass Village SM Traffic lmpact Statement.
13 March 4th, 2O2l testimony from Lucy Gallo of DPFG. Hearing video 2:39:37.
Page 7115
which are rural areas, like the RLSA, and adjacent to the RLSA.la
Because Naples has a high percentage ofseasonal second homes
and vacation homes, the county's overall rate equates to a higher
vacancy rate than the other two locations. lmmokalee's rate is
likely higher than Golden Gate, because the area has a high
concentration of seasonalfarm workers, Even though lmmokalee
and Golden Gate are adjacent to the RLSA, the consultant chose
to use Collier County's overall higher vacancy rate. Also, the 2045
MPO provides a map of vacancy rates. The map shows that
Longwater and Bellmar are predicted to have a vacancy rate of 15
to 25% in 20451s. Ultimately, a higher vacancy rate equates to a
lower population for the villages, which means costs are
understated in the fiscal neutrality assessment.
(2) OLD DATA: The second way the developer underestimates
population of the villages and impact fees is by using old county
data that provides fewer people per home than more recent
county data showing more residents per home.16
Ultimately, an underestimation of populations within the economic assessments
equates to a lower representation of costs to provide Longwater and Bellmar with
infrastructu re and services-
ra Collier County 2016-2020 Consolidated Plan and 2016-2017 Annual Action Plan. Vacancy rates found on page 85.
The document states that the count\/s overall vacancy rate is 37yo, however, at the March 4, 2021 hearing for
Longwater, Ms. Gallo of DPFG stated they applied a vacancy rate of 38%. The report states that tmmokalee's rate
is likely higher than Golden Gate's because there ls a high percentage of seasonal migrant workers.
1s Collier MPO 2045 Long Range Transportation plan, Technical Compendium, p. 23. Figure 16.
16 Longwater and Bellmar's economic assessments state that only 1,05 persons per housing unit will reside in the
multi-family homes and 2.21 person's per housing unit will reside in the single family homes (permanent
populations). This data is from Collier County's 2016 Emergency Medical Services lmpact Fee Update, which in
turn, gets lts data from a 2011 American Housing Survey and 2013 American Community Survey. Sothedatais
approximately ten years old. Ms. Gallo, the DPFG consultant stated, that they are using data from the Counvs
most recent impact fee data, However, we found numerous more recent sources from the county. Even though
the newer data provides person's per household, which excludes the vacancy rate, the numbers could be adjusted
to reflect vacancy. The more recent data includes the following: The Collier County Fisca I Year 2019 Water and
Wastewater lmpact Fee Study, which provided data showing between 2.25 and 2.55 person,s will live per
household in Collier County; the 2020 Collier County Annual Update and Inventory Report provides an average of
2'5 person's per household for Collier county; and the 2045 Long Range Transportation Plan (LRTP) shows that
2.01to 3.00 person's per household will live in the area of Longwater or Bellmar. DPFG argued that their study
included only permanent populations and accounted for housing types. However, the LRTP'S and the other studies
could be adjusted to include a vacancy rate and housing types.
Page 8116
o THE DEVELOPER FAILED TO PROVIDE THE REQUIRED FISCAL IMPACT
ANALYSIS FOR WATER AND WASTEWATER IMPACTS.
Per RLSA Policy 4.18, Collier Enterprises is required to provide a fiscal
analysis for Longwater and Bellmar's impacts on the Collier County Water
Sewer District. However, this analysis was never provided by the
developer. According to the AUIR, the County is building a new water and
wastewater treatment plant in the Northeast Service Area to serve the
villages, and a few other nearby developments, at a cost of S156.4 million,
for just phase one.17 Also, the 2020 AUIR shows that S28 million will be
spent for storage tanks and pipelines for an interim wastewater facility that
will be decommissioned once phase one of the new plant is operational.
Longwater and Bellmar will consume over 4!o/o of the capacity for phase one
of the new plant,18 making it even more imperative to provide an analysis to
correctly assess the developer/s fiscal impact on those plants. However,
instead of requiring the developer to provide the legally required analysis
for water and wastewater, Collier County accepted the developer's flawed
methodology, which not only excluded this important analysis, but
excluded a third party review. The County provided their own fiscal impact
analysis during the Longwater and Bellmar hearing using previously
undisclosed sources and data. The Conservancy has yet to fully review the
new analysis.
a.
Collier County could collect more impact fees from the developer. At the
March 18, 2021 Longwater hearing, the Collier County Attorney stated:
"We do not chorge the full impoct fees thot we can. Thot's a policy decision
fby the Board of County Commissioners]." "lf you reolly wont to be fiscolly
neutral you would set impact fees, ond I mean oll the impact fees os high as
legally possible. We don't do that."
The Villages will result in severe traffic issues:
!7 Collier County 2019 and 2O2O AUIR/Capital lmprovement Etement Schedule Updateon Public Facilities provided
cost for Phase I water and wastewater plant.
13 Longwater and Bellma/s SRA Public Facilities lmpact Assessments. The two projects will consume 41% of the
capacity of the 4MGD wastewater plant and 43% of the capacity of the water plant. Note: This includes the potable
water and wastewater demand for residential, commercial, and civic uses.
Page9l15
Because the projects are not designed according to the RLSA s rules which require
self-sufficient walkable/bikeable communities, traffic from the 11,000+ new
residents will pour out of Longwater and Bellmar and head west towards Naples.
Village residents will be compelled to drive toward existing coastal communities to
seek out goods, services, entertainment and employment opportunities that the
villages will not provide. The additional traffic will exacerbate the county's existing
traffic congestion issues.
r IMMOKALKEE ROAD WILL BE AN '1AVOIDABLE IRAIN WRECK".
Longwater ond Bellmar will cause significant troffic impocts to deficient
lmmokalee Rood. Traflic expert, Norm Marshall of Smart Mobility, Inc.,
reviewed development plans for Longvvater and Bellmar and stated that
lmmokalee Rd will be "An Avoidoble Troin Wreck." The 2045 Long Range
Transportation Plan confirms Mr. Marshall's prediction. Figure A-9 from the
2045 LRTP depicts several segments along lmmokalee Road that will fail,
even with planned projects that are supposed to alleviate congestion.
7: Collier County LRTP Network Deficiency Plot (from LRTP Figure A-91
* Key: Red extremely deficient
:. (V/C > 1.15), Orange
deficient (V/C 1.0 to 1.15)
and Yellow barely adequate
(V/c 0.9 to 1.0).
The blue highlights in the
figure show planned MPO
road expansion proiects
which are generally designed
to serve development as
discussed below.
LONGWATER AND BELLMAR WILL ADD TRAFFIC TO FAILING ROADS, EVEN
AFTER COMMITTED ROAD IMPROVEMENTS ARE COMPLETE.
At the March t8,2O2t Longwater hearing, Collier County staff admitted that
there are several roadways that are projected to fail capacity limits even
before the projects are built; however the villages' traffic will make those
Page 10 116
same roads even worse. Although the County has committed roadway
improvement plans to alleviate traffic congestion on some of the roadway
segments, not allfailing road segments will be cured' Logic follows that
more traffic should not be added to failing roads. Regardless, staff is still
recommending approval.
IMPACTS FROM THE VILLAGES WILL BE SIGNIFICANT
ln their August 15,2O2O Review of Longwater, Collier County Planning Staff
stated, "Given the close proximity of these four proposed developments
[includes Hyde Pork] ond the relotively limited roodwoy network in the
surrounding orea, it seems very likely that the cumulative impoct of oll this
troffic will result in level of service deficiencies for multiple roodway
segments and intersectians. " Why then did staff ultimately recommend
approval?
LONGWATER AND BELLMAR WOULD DESTROY 2,OOO ACRES OF PRIMARY
PANTHER HABITAT.
The endangered Florida panther is our state animal and a symbol of Florida.
Longwater and Bellmar would result in destruction of 2,000 acres of
primary panther habitat. The newly proposed Town of Big Cypress
increases the loss of primary panther habitat to over 3,200 acres.le This
would be a tragic loss for the panther as the species is already restricted to
less than 5% of its historic range and only 120 to 230 panthers are left in
existence. The loss of additional primary habitat from these two villages
places the panther closer toward the brink of extinction.
THE PROJECTS,WOULD RESULT IN A SIGNIFICANT LOSS OF ADULT
BREEDING PANTHER HABITAT
The panther will also lose very important adult breeding habitat not only
within Longwater and Bellma/s sites, but also within the adjacent
s ctS data from USFWS shows the following impacts to Primary zone Panther habitat: l-ongwater - 1,000 acres;
Bellmar - 1,000 acret Rivergrass - 739 acres; Town Core - 515 acres. The total impact within the SRA boundaries
is3,254affes. There are additional impactsto primary panther habitat outside ofthe boundaries for lake tracts
that we did not include in the total acres.
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preserves due to the light, noise, and traffic from the developments.
Leading panther habitat modeler Dr. Robert Frakes explains why Adult
Breeding Habitat is so important to the panther:
"This population may olready be ot or close to carrying capocity, yet
the panther population is probobly below what is reguired for long-
term genetic viability. Therefore, protection of the remaining
breeding hobitot in south Florida is essentiol to the survivol and
recovery of the subspecies ond should receive the highest priority by
re g u loto ry a ge nci e s."20
THE VILLAGE PLANS FAILTO ADDRESS LANDSCAPE CONNECTMry FOR
WILDLIFE.
Bellmar's site is located only about 1.25 miles from the Florida Panther
National Wildlife Refuge and serves as part of a critical wildlife corridor to
the panther refuge. The refuge was established in 1989 to aid in the
recovery of endangered species, including the Florida panther. The Refuge
Manager is concerned that Longwater and Bellmar's plans do not "Address
the landscope connectivity needs of wildlife such as the Florido ponther ond
block beor.'21
VILLAGE RESIDENTS COULD PRESSURE PANTHER REFUGE TO HALT
PRESCRIBED BURNING.
The Florida Panther National Wildlife Refuge (FPNWR) manager states that
they use "prescribed burning to monoge the fire-adopted ecosystems for
the benefit of wildlife and to reduce high fuel loads".22 The villages are
within the path of the smoke that will emanate from some of the
prescribed burns. Even if residents and businesses sign an agreement
acknowledging the need for prescribed burning, we are concerned that
village residents and business owners will eventually pressure the Refuge to
stop this necessary management tool, which would impact the ecosystem
health of tens of thousands of acres of conservation lands.
20 Frakes RA, Belden RC, Wood BE, James FE (2015) Landscape Analysis ofAdult Florida Panther Habitat. pLoS ONE
10(7): e0133044. doi:10.1371/ournal.pone.O133O44
ur United States Oepartment of Interior, United States Fish and Wildlife Service, Florida Panther National Wildlife
Refuge. Letter to Collier County Planning Commission, dated May 2, 2021from Kevin Godsea, Refuge Manager
22 lbid.
Page 12 116
PANTHER HABITAT.
Do not be fooled by those who argue thatthe endangered Florida panther
does not use agricultural lands within designated primary panther habitat.
This claim is simply untrue and it is unsupported by the best available
science. The science clearly shows that agricultural lands within primary
panther habitat, such as Longwater and Bellmar, provide the Florida panther
with core life cycle needs for the purposes of prey support, hunting and
stalking, and landscape connections to forested habitats and movement
corridors.
Loss of Agricultural Lands will be significant:
The goal of the RLSA's Group 2 policies is to "protect agricultural lands from
premature conversion" to other uses, such as development, and to "continue the
viability of agricultural production through the Collier County Rural Lands
Stewardship Area Overlay." However, Longwater and Bellmar provide evidence
that productive agricultural lands are not being adequately protected.
r THE VILLAGES WILL CONTRIBUTE TO 10% OF THE STATES'ANNUAL LOSS OF
AGRICULTURAL LANDS.
Agricultural lands are a finite resource. However, each year nearly 20,000
acres of Florida's agricultural lands are converted to development or are
compromised.23 Longwater and Bellmar alone would contribute to a loss
equivalent to nearly 10% of the states' total yearly loss of agricultural lands.
The majority of the village's sites are used for active row crops.2a This is
very unfortunate, because agricultural lands provide long-term food
security for the region, more access to healthy foods, significant
23 American Farmland Trust. 2O2O Farms UnderThreat. The State ofthe States, Agricultural Land Conversion
HiShlight Summary: Florida. From 2001-2006, 298,400 acres of farmlands were developed or compromised. That
equates to 19,893 acres per year over 15 years. Longwater and Bellmar will convert 1,91.1 acres of agricultural
lands to development, which is 10% of the state's yearly average of 19,893.
2a The Conservancy viewed GIS land cover data of the village sites April 28, 2021. The GIS data shows that the
developments of Longwater and Bellmar Villages would result in a loss of 1,91X acres of agricultural lands, which
includes 1,511of row crops and 360 acres of improved pastures. (1,911/approx.20,000 acres ofstate loss =.0955
or 10%)
Page 13 116
contributions to the economy, employment, water recharge, habitat for
listed species and habitat connections, and flood risk reduction.
o 71% OF THE LANDS TARGETED FOR DEVELOPMENT WITHIN THE RLSA ARE
USED FOR AGRICULTURAL PRODUCTION,
As previously mentioned, Collier Enterprises, along with eleven other RLSA
landowners have plans to develop 45,000 acres of the RLSA. Most of the
45,000-acres worth of development would convert agricultural lands. The
Town of Ave Maria, which is partially built, is included in the 45,000 acres.
Excluding 5,027 acres for Ave Maria, 39,973 acres remain for development
under the landowners plan.2s Of those 39,973 acres, 28,319 acres or TtYo
of the lands targeted for development in the RLSA are farmlands used for
production.26 This equates to a great loss of agricultural jobs and rural
character of Collier County.
Because of the R6A's vast distance from the County's existing urban area where
most of the infrastructure, road network and services are already provided, the
RLSA has stricter rules for development. All RLSA development is required to be
innovative, compact, self-sufficient, ped estria n-f riend ly and adhere to smart
growth standards. Instead, Longwater and Bellmar are sprawling, auto-centric
developments, and typical of most gated suburban developments within
Southwest Florida. Longwater and Bellmar must be denied as they do not meet
the RLSA's design standards. Collier County planning staff made strong negative
statements about Longwater and Bellma/s designs.
r COLLIER COUNTY PLANNING STAFF STATED THAT LONGWATER,S DESIGN
DEPICTS A TYPICAL SUBURBAN DEVELOPMENT, RATHER THAN A VILLAGE.
Here is what staff stated: "The Longwoter Village SRA does not fully meet
other requirements of, and does not reflect the innovotive plonning tools . . .
pertoining to design, compoctness, housing diversity, wolkobility, mix of
E lbid,Table 4-3 p.88; Covered (development and mining) activities equate to 39,973 acres (1.9,596.5 acres within
Prlrnary zone Panther habitat and 20,375.5 acres within Secondary Zone)
25 stantec Consulting Services (2018, August) Eastern Collier Multiple Species Habitat Conservation Plan.
Table 4-3 p.88 shows that 19,467 acres of citrus groves, 8,722 acres of row ffops, and 130 acres of pecan farms
would be converted to development. This totals 28,319 acres.
Page 14 116
uses, use density/intensity continuum or gradient, etc. ln stoffs view, this
SRA is with some exceptions, o suburbon development plon typical of that in
the coostol urbon areo ploced in the RLSA ond is controry to whqt is intended
in the RLSAO,"27 Even though very minimal changes were made to
Longwater's design since the statement was made, staff ultimately
recommended approval of the projects, The question is: Why?
r COLLIER COUNTY PLANNING STAFF STATED THAT BELLMAR,S DESIGN
DEPICTS A TYPICAL SUBURBAN DEVELOPMENT, RATHER THAN A VILLAGE.
Here is what planning staff stated:'The Bellmar Villoge SRA still does not
fully meet the intent of the policies in the RLSAO pertoining to innovative
design, compactness, housing diversity, walkobility, mix of uses, use
density/intensity continuum or grodient, interconnectness, etc. In stolfs
view, this SRA is, with some exceptions, o suburban development plan typicol
of thot in the coostal urban area placed in the RLSA and is contrary to whot
is intended in the RLSAO..."28
Again, even though very minimal changes were ultimately made to
Bellmar's design since the statement was made, staff ultimately
recommended approval of the projects. The question is: Why?
To summarize, here is the reol deal that the Countv and Collier
In summary, the real deal that the developer is offering to the county is 12,300
acres of mostly non-developable lands, lacking in adequate flow-way restoration
in exchange for credits that would allow the developer to build SIX 1,000-acre
villages! Longwater and Bellmar Villages alone would significantly increase the
county's population, create severe traffic impacts, contribute to 10% ofthe
states'total yearly loss of agricultural lands, pass tens of millions of dollars of
costs on to taxpayers, and destroy two thousand acres of primary panther habitat
of the endangered Florida panther. Instead of a grand deal, as portrayed by the
27 collier county consistency Review Memorandum for Longwater village sRA. February 11,2020, p. 19of20
28 colller county consistency Review Memorandum for Bellmar viltage aRA. May 27,2020, p. 110f11.
Page 15 116
developer, Collier County would be getting a raw deal by approving Longwater
and Bellmar. Please help us to not let this happen.
Collier County is at a crossroads and its future hangs in the balance. Please help us
to ensure that Longwater and Bellmar Villages are not the model for all other RLSA
development. After all, they are just the beginning of a colossal development plan
by twelve eastern Collier landowners to cover much of eastern Collier County with
a patchwork of towns and villages. As members, supporters, volunteers, and
concerned citizens, we urge you to Act Now before the quality of life that we
enjoy so much in Collier County is nothing more than a distant memory.
Page 16 116
TESTIMONY OF PATRICIA FORKAN
LEAGUE OF WOMEN VOTERS, COLLIER COUNTY
Chair, Environmental Affairs Committee
Cof f ier County Planning Commission, March 4,2021
Good morning Commissioners. My name is Patricia Forkan and l'm here
on behalf of the Collier County League of Women Voters where I serve
on the Board of Directors and as chair of the Environmental Committee.
We are here to present reasons why you should not approve the
applications, as proposed, for the construction of over five thousand
homes to be located in two villages identified as Longwater and Belmar.
The League has already submitted two detailed analyses (Feb 15 and
25) with all the main reasons why you should oppose these massive
developments.
In our submissions we show they will be built the middle of
panther habitat, and will adversely impact traffic, pollution, wetlands
and water retention areas. ln addition, Collier taxpayers will be
obligated to pay tens of millions of dollars in costs for the required
public facilities for the benefit of private developers
You have heard, or will hear, other speakers address you as
concerned private citizens, including specialists in water issues,
panthers, fiscal responsibility, roads, traffic, etc.
l'm here to promote sound environmental policies and wise
management of natural resources in the public interest, and to
promote public understanding and participation in all levels of
governmental decision making. As a nonpartisan political organization,
our mission is to empower and inform voters to influence public policy
through education and advocacy.
Here in Collier County, we have been actively engaged in opposing
bad planning and more sprawl, but not growth itself. lndeed, we
support, smart, responsible growth. Our concerns with the two
amended submissions before you are coming right on the heels of the
County's approval of Rivergrass - while approval for yet another
nearby rural village of 3000 more homes is pending. We wonder if the
County's Growth Management department is adequately representing
the public interest.
County planners review project submissions to assure they
comply with RLSA requirements, then present their original
recommendations. Afterward, they work closely with developers and
send you a final review which they expect you to approve. That
document often ignores many RLSA standards,
One example: initial concerns by staffthat the proposed location
of Longwate/s commercial area "cannot be considered as a Village
Center." This finding was dropped from the subsequent consistency
review. WHY?
The public is becoming aware of the threat posed by runaway and
unnecessary growth and is looking to its elected and appointed leaders
to get serious about the County's future. While the Rural Lands
Stewardship Area is not in the public's immediate view, the decisions
made now will impact all county residents if you do not require the
stringent development rules of the RLSA as originally agreed to by the
Eastern landowners.
It is clear from our own studies, and according to a
communication that you have received from the Arnold & Porter law
firm, that many of these rules have not been followed. Their exhaustive
analysis of the Belmar and Longwater applications is in the public
record. lt is as scathing an indictment of a development project as
we've ever seen.
We also want to remind you, and our fellow citizens, that County
law requires that growth pay for growth and that Collier County
taxpayers should not be forced to subsidize private development in
rural Collier County.
Belmar and Longwater will require enormous public subsidies of
utility infrastructure from roads to fire stations to water and waste-
water treatment facilities. When the citizens learn of how they are
going to be squeezed by private developers and landowners, they are
not going to be happy. As a public-interest organization, we speak for
them.
Developers propose building gated communities comprised of
90% single-family homes, without town centers, and with no attention
paid to walkability, bikeability, affordability....and, yes, even liveability.
It is clear to the League, and we have stated so in our submitted
reviews, neither project is consistent with the RLSA Overlay or the long-
outdated Land Development Code.
Finally, the problems with Longwater and Belmar cannot be fixed
by dangling the proposed Town agreement in front of you, and it
should have no bearing on your decisions regarding the two Villages.
The proposed town agreement is extremely inconsistent with the RLSA
proSram.
You must ask yourselves do these proposals reflect the standaros,
spirit and vision contained in the RLSA and the public re-study
recommendations? We don't think they do.
Eastern Collier County is one of Florida's last frontiers and it
should not be subject to poor land planning and design. We ask you to
vote against proposals as they are now written.
Thank you.
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