Last Stand Opposes Proposed Changes to Key West’s Workforce Housing Regulations
February 20, 2025
Members of the Planning Board
City of Key West
1300 White Street
Key West, FL 33040
Dear Planning Board Members,
Re: Agenda Item #13 – Text Amendment to the Land Development Regulations
Last Stand of the Florida Keys is a non-profit organization established to preserve the Florida Keys and ensure a sustainable future for all. We advocate for promoting, preserving, and protecting the quality of life in the Florida Keys, with particular emphasis on the natural environment.
Last Stand opposes the proposed Text Amendment to Sections 122-1466 and 122-1467 of the Land Development Regulations. This proposal would reverse the workforce housing requirements established in Ordinance 19-11, which mandates that 30% of units in both new and redeveloped market-rate housing projects be set aside as affordable workforce housing.
The proposed changes would exempt redevelopment projects from these requirements, limiting them to only new developments. Additionally, with only four BPAS market-rate units available for allocation, this amendment severely restricts new affordable workforce housing development, with potentially only one workforce housing unit being built under the current ordinance.
This proposal is at odds with the City’s long-standing recognition of affordable workforce housing as a critical issue and the #1 priority for Key West. It fails to address the growing housing crisis, which is exacerbated by the increasing demand for second homes and vacation rentals. By eliminating the requirement for redeveloped market-rate housing, the proposal effectively prioritizes market-rate and vacation properties over the needs of local workers.
We are also concerned with the definition of workforce housing in this proposal, which requires 70% of income earned in the Keys to qualify as workforce housing. This definition, however, does not specify that the income must come from gainful employment, allowing rental income, business equity, or debt income to be counted. This broad definition could allow people whose income does not rely on work to qualify for workforce housing, further straining the housing market and making it harder for the actual workforce to afford housing.
Furthermore, we are troubled by the proposed changes geared toward increasing rents. The plan includes raising the affordable housing threshold to 160% of the median income and adjusting the rents to a higher percentage of income. The proposal also reduces the percentage of affordable units for low-income individuals. Where is the analysis to support these rent increases and changes to the income thresholds? The financial impact of these adjustments needs to be thoroughly examined to ensure they do not exacerbate the housing crisis or price out the workers who rely on affordable housing.
While we understand that developers face financial challenges and may be deterred from upgrading properties due to these requirements, affordable workforce housing must take precedence. The financial burden on developers should not outweigh the urgent need to house the workforce that sustains Key West.
Additionally, we strongly oppose the linkage provisions outlined in this proposal, which would allow affordable housing to be built off-site, potentially as far as unincorporated Monroe County west of Big Pine Key. This would remove affordable housing options from Key West, forcing workers—such as teachers, healthcare professionals, and hospitality employees—to commute long distances, creating environmental, logistical, and social challenges. These provisions would undermine the very fabric of our community, where people should be able to live and work within the same area.
We urge the Planning Board to reject both the elimination of the inclusionary housing requirements for redevelopment and the linkage provisions. Key West’s workforce needs affordable housing within the city, not in distant locations that disrupt the stability and cohesion of our community.
Thank you for your attention to this critical issue. We trust you will consider the long-term impact on Key West’s residents and community as you review the proposed amendments.
Sincerely,
The Last Stand Board of Directors
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
