Comments to the bocc on 07/17/2024 by Last Stand addressing concerns about new rogos

President of Last Stand, Ann Olsen's comments at the July 17, 2024 BOCC meeting regarding potential new ROGO allocations.

Good morning, Mayor and Commissioners,

I’m Ann Olsen, and I’m speaking on behalf of Keys Last Stand.  We’ve been following the evacuation modeling and ROGO situation since before the models were run last year.  Our concerns remain the same – that the Keys are already at capacity and the evacuation model omits too many of our permanent residents (like students, liveaboards, mobile home residents) while also including too many flaws (like undercounting vacation rentals, ignoring traffic congestion and real-life road speeds, and assuming the phase 1 evacuees actually left on time and the roads are clear for resident evacuation).  Yet now, even that flawed evacuation model seems ready to be ignored in favor of more development.  And we are not alone in our concerns – last week, you received a letter from 16 different Keys organizations expressing these same concerns and requesting another look at what’s considered a buildable lot for the ROGO issue.

Let’s look at the numbers… 

  1. First, we’ve already exceeded what was previously declared maximum buildout for the Keys by the recently provided 1400 building allocations. And nothing in terms of infrastructure has been improved in order to keep exceeding that max build-out.

  2. FL Commerce has already indicated in the current modeling that there is only room for 220 more allocations KEYS-WIDE to remain within the 24-hour evacuation statute.

  3. Yet, last month at a County meeting, commissioner Cates publicly stated (quote) “We will get more ROGOs. Something like 2,000 over the next 20 years… I think that’s where it will end up going” (end quote). (I’m assuming he just meant the unincorporated county, so we may be back to that 3,000 number we keep hearing).

  4. Adding any more than 220 ROGOs means changing the evacuation statute; at precisely the same time, meteorologists tell us Rapid Intensification and storm strength are increasing due to a warming climate, and SLR increases our road flooding.  If anything, the response should be to decrease the evacuation time.

5.  And this is all supposedly being done to decrease takings liabilities, yet no one is looking seriously at the true risk of takings. 

So, let’s start that process by taking a closer look at the buildable lots.  County staff made an initial cut at the 7,954 open lots by removing submerged lands, mangroves, and lots without sufficient zoning.  That process got us to 3,000 lots Keys-wide. It’s time to take a more serious look at the 3,000 lots and apply some additional reductions.  We ask you today to direct staff to further review those lots and remove:  

  • Those with acquisition dates (purchases, inheritances, transfers) after 1992 when development expectation was significantly reduced.

  • Lots where the land owner has made NO effort for ANY permit over the past 32 (or more) years.

  • Any Tier 1 properties (or really anything other than Tier 3 because nothing else will really rise to the top of the competitive ROGO system).

  • Properties that have commercial applications besides building a residence, like Suburban Commercial, Mixed Use, or other zoning. 

  • And please follow previous staff recommendations to remove unimproved subdivisions that have no roads, sewers, or water service, where, again, development expectations are no longer reasonable.

  • Lastly, please omit from the numbers:

    • The 444 Administrative Relief ROGOs you already have “banked” for the County,

    • And an estimate of the lots you expect to retire using current and suggested programs, like Land Dedication, Lot Aggregation, Less Than Fee Program, Land Mergers, and other Land Acquisition Programs.

Last winter, we were pleased to hear there would be a working group looking at these issues, but now all we have are surveys (we feel are) driving responses toward a pre-determined outcome. One recent survey respondent has already named the survey a “scare tactic,” threatening all property owners with a 1 BILLION dollar property tax increase to ward off takings (and to quote Ms. Matthews, “that’s 1 billion with a B”). 

The outcome of this decision will affect the Keys environment and its residents for generations to come, and there’s no going back until the development is approved.  Please prioritize public safety and the quality of life for the majority of your Keys’ residents over a handful of developers and a significantly smaller number of private property rights cases than what’s currently being discussed.  So please ask staff to take another cut at these numbers – this decision is too important to be “winging it” without real data.

Thank you.

Ann Olsen, President

For the Last Stand Board


Last Stand is a non-profit organization of volunteer citizens interested in preserving the Florida Keys' unique quality of life and fragile, beautiful natural environment. We have worked tirelessly since 1987 to protect Key West and the Florida Keys.

Last Stand • P.O. Box 146 • Key West, FL 33041      www.keyslaststand.org

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Full comments at the july 17, 2024 bocc meeting regarding new rogo allocations

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Coalition of fl keys organizations urges county to limit new rogos and protect community safety and the environment