Monroe County Planning Commission will consider a request for a text amendment to increase options for hotels to offer affordable housing. Last Stand has provided the commissioners with our recommendations for changes to the request in the following letter:The Board of Last Stand has the following recommendations after reviewing the proposed text amendment submitted by Longstock II, LLC to amend LDR 139-1(a) (5) to exclude affordable housing density from cumulative density/intensity calculations for hotel/motel development on a site.

• If allowing increased density for affordable housing (AH) on a hotel/motel property, it makes sense that the housing should be restricted to employer housing for those who work on site. It is, after all, the hotel/motel industry which generates high demand for affordable housing from its low-income-earning workers. Restricting to employer housing may limit some of the traffic and congestion on our streets that would be generated by any increase in permanent dwelling units.

• This proposal would drastically increase the potential density presently allowed in some zoning districts (see attached chart). Since the applicant indicates that this text amendment would use under-utilized areas within the recommended zoning districts, then there would be no need for variances if and when any additional units, above and beyond what is allowed now, are requested. We propose that language be added to the text amendment indicating that no variances will be allowed should these additional dwelling densities be requested. Increasing density becomes a nuisance to the community and surrounding properties if there is a decrease in open space, parking, setbacks, landscape buffers, landscape requirements, or an increase in lot clearing or height. As the Applicant rightly acknowledges, our land development codes have been written with habitat protection and water quality objectives in mind. Let us not lose sight of those objectives by allowing development that is too densely compacted.

• The proposed density increases are excessive. Last Stand recommends that there be a better balance of hotel units to AH units. When additional density is to be used, a ratio of 1 affordable housing unit for every 5 hotel rooms may be a more realistic density allocation. Instead of an across-the-board density increase, a calculation that would allow for workforce housing without creating such high-density increases should be considered.

• Finally, the concern for compliance is always a challenge for county staff. If there is to be additional AH density allocated under this amendment, a method to enable enforcement of occupancy by qualified tenants would be to impose an annual fee, payable to the County, to help fund the required Affordable Housing/Employer Housing monitoring.

The challenge of Affordable Housing in Monroe County is an ongoing concern, and Last Stand appreciates Staff’s efforts to address it. However, there is a delicate balance that needs to be maintained between economic growth and the ability of our sensitive environment to sustain itself. Much has changed since this application was first submitted. Where there was concern that there was a limited capacity for funding assistance, since Hurricane Irma we have learned that hundreds of millions of dollars in public funding has been pledged to the Florida Keys for housing. These monies will help to alleviate some of the pressure on lost housing. Also, there is an offer by the State to allocate additional affordable housing ROGOs, and, while Last Stand is not in favor of this latest offer, the County should be careful not to overly increase density when it is unclear what associated infrastructure costs would be borne by local taxpayers and how any future development would be managed.

Thank you for considering our recommendations and for your efforts to protect our precious but vulnerable Florida Keys.