Last Stand's June 30, 2023 Comment Letter to State DEO RE: Updating Hurricane Evacuation Model
Here's the official PDF version of the letter sent to DEO: Last Stand Hurricane Evacuation Model Comments to DEOAnd here's the text version below:
June 30, 2023
Sent by email: FLKeysEvac@DEO.MyFlorida.com
Florida Department of Economic OpportunityDivision of Community DevelopmentAttention: BCPGThe Caldwell Building107 East Madison Street, MSC-400Tallahassee, FL 32399
RE: Florida Keys Hurricane Evacuation Model Update
Dear DEO Staff,
Thank you for conducting the recent Hurricane Evacuation Model Update Community Meetings in Monroe County. After listening to your plans, we ask that you prioritize “safety first” over all other considerations. As the 2023 Model update will significantly impact public safety, we respectfully submit the following comments and concerns pertinent to the safe evacuation of the Florida Keys in the event of a major hurricane.
Since the update of the Florida Keys Hurricane Evacuation Model in 2012, there have been significant changes in Monroe County (more residential development, more commercial development, and more tourism), resulting in significantly more people and more traffic to safely evacuate on a single, mostly two-lane road out of the Florida Keys.
Related to safe hurricane evacuation is the “carrying capacity” of the Florida Keys. Both freshwater and wastewater infrastructure is already at a breaking point, as evidenced by recent repeated freshwater and wastewater pipe breaks and the associated replacement and repair costs expected to exceed one billion dollars.
We strongly agree that the US Navy personnel and their families, as well as residents of mobile homes, should be included as permanent residents in the updated Model.
We strongly believe the existing paradigm of “two-stage evacuation” (Phase 1 at 48 hours; Phase 2 at 24 hours) is inadequate, unsafe, and problematic for these reasons:
the reality of “rapid intensification storms” (tropical storms that escalate to CAT 3-4-5 hurricanes in under 24 hours) has become the recent norm
the reality of sea-level rise associated with climate change (producing even persistent sunny-day flooding) means storm-surge flooding may inundate portions of the only evacuation route (US1) far earlier than previously calculated
the assumption, that all tourists and visitors will evacuate 48 hours ahead of predicted landfall of a major hurricane and not create barriers in traffic to a safe evacuation of residents, was unrealistic in 2012 and is much less realistic today
there has been a significant increase in tourists and visitors occupying vacation rentals, due to the proliferation of AirBNB and VRBO lodgings (this fact is underscored by the dramatic increases in Tourist Development Tax revenues); vacation rental occupants are not knowledgeable of Monroe County emergency mandates, notifications, or evacuation timing (48 hours for visitors)
the 2012 Model excluded over 20,000 “vacant homes”, yet it has been documented that 15,101 of them (75%) are for “seasonal, recreational or occasional use” (IC-12, Vol 1-11 South Florida), meaning they could be occupied at any time
there is no enforcement mechanism to implement the “two-stage evacuation”
While we understand that FS Section 380.0552 provides general guidance for the Modeling process, we urge your team to consider the need to make substantive changes in the assumptions of the updated Model, to increase the likelihood of safe evacuation for Florida Keys residents. Those changes should include:
considering “regional factors” (ending the Evacuation Model at Florida City ignores the massive growth that has taken place over the past 10+ years; the assumption that Dade County residents would not be on US1 and the Florida Turnpike when Florida Keys residents arrive is unrealistic and places lives at risk)
considering impacts of the additional 1,350 housing units now available to Monroe County in addition to the 3,550 housing units previously planned to be available until 2023 (in the 2012 MOU; in 2020, the Third District Court of Appeal made clear that the 1300 additional housing units “fail to maintain a hurricane evacuation clearance time for permanent residents of no more than 24 hours, as required by … Florida Statutes; the Court repudiated the scheme that these new 1,300 building permits [permanent households] would simply be required to evacuate at 48 hours, in order to appear to meet the 24-hour evacuation mandate; however, the Florida Legislature recently overruled the Court’s decision, resulting in those additional 1,300 plus another 50 housing units being active)
adjusting the 24-hour “flow rate” to match the reality that many people will not evacuate at night (the 2012 Model assumes this 24-hour “flow rate”, however model experts dispute this assumption of steady flow during a 24-hour period
revisiting the hurricane evacuation clearance time for permanent residents of no more than 24 hours (the impacts of climate change and lack of improvements in weather forecasting [to accurately predict rapid intensification, timing, and the path of storms] are important considerations)
including the active participation of independent and objective experts and professionals in Weather and Hurricane Forecasting and Emergency Management. This would add critical knowledge to the process and supplement DEO’s concentration and experience in economic development and tourism
We also ask you to consider the “lessons learned” from the landfall of Hurricane Ian on the west coast of Florida on September 28, 2022, and the 149 lives lost. It appears changing numbers on paper does not translate into safe hurricane evacuation.
While the recent Hurricane Evacuation Model Update Community Meetings in Monroe County are past, we believe ongoing public input on key decisions is critical to the success of the process, culminating in a robust, updated Model and resulting in safe hurricane evacuation in the Florida Keys. Therefore, we suggest the development and communication of a calendar, with reasonable advance notice, of planned important dates and decisions to facilitate ample opportunities for public input and education of the residents of Monroe County.
Thank you for the opportunity to provide input and feedback to this important process. We believe our shared, #1 concern is public safety, and we feel the updated Model should reflect the above known issues. We base our comments on experts in the field and stand ready to supply specific data and/or contacts with knowledgeable experts to aid in the current Modeling process.
For the Last Stand Board of Directors,Ann Olsen, President