09-10-24

Via email

Mayor Holly Merrill Raschein

Commissioner Michelle Lincoln

Commissioner Jim Scholl

Commissioner David Rice

Commissioner Craig Cates

RE: Wilson-Avirett Tier Change

Dear Mayor and Commissioners,

Last Stand would like to express strong opposition to the proposed Wilson-Avirett Tier change proposed in the environmentally protected area of North Key Largo. The entire 13 miles of sparsely developed land along CR 905 and along Card Sound Rd is designated Tier I (environmentally sensitive). This is true for every lot and parcel in North Key Largo regardless of its present land use. 

North Key Largo was once targeted by developers to house 25,000 to 45,000 people. The outcry against the potential loss of native hammock from these proposed developments reinforced the Florida Keys becoming an Area of Critical State Concern. This designation and the subsequent land buying by the state facilitated the protection and restoration of the environment of North Key Largo. Despite historical disturbances from human use, today it remains preserved. North Key Largo is now the largest contiguous West Indian hardwood hammock in the continental United States.

There are still a few areas not in conservation, but within those privately owned neighborhoods, the state has bought many of the vacant residential lots to help overcome the fragmentation of the hammock there and provide a corridor for wildlife such as the federally endangered Key Largo cotton mouse, Key Largo woodrat and Schaus Swallowtail. 

It is because of the history and success of all these efforts to conserve and preserve this fragile and limited piece of the Florida Keys that Last Stand strongly objects to reducing these protections. All of North Key Largo should remain Tier I.

After careful review of the Wilson-Avirett application, county staff recommended denying the proposed tier change and noted that the Tier I designation was not an error. The property meets the Tier I designation “in accordance with criteria of Comprehensive Plan 36 Policy 205.1.1 and Section 130-130(c)(1) of the Land Development Code.” The county staff report noted this proposed change is inconsistent with “the provisions and intent of the Monroe County 2030 Comprehensive Plan.” Changing the designation to Tier III is inconsistent with the Tier I zoning for residential properties adjacent to the Wilson-Avirett property and throughout North Key Largo.  Further, this proposed change would establish a precedent that may allow other similar changes in this fragile area. The two nearby neighborhoods, which have Tier I properties, are relatively undeveloped as many parcels have been purchased as conservation lands by the state or county. According to the staff report, “The proposed amendment would negatively impact the minimally developed community character of the surrounding Tier I subdivisions/properties.” 

The property is properly classified as Tier I for several reasons. As noted in the staff report, it is in an area with “minimal existing development and infrastructure,” is the location of two endangered plant species, and is within the footprint of the Florida Forever program dedicated to conservation land acquisition funded by the state legislature. The 3.3-acre parcel is a Species Focus Area for endangered and threatened species identified by US Fish and Wildlife Service and recognized as such by the county. Ecological restoration of this land with the purpose of creating quality connected upland habitat in North Key Largo, is possible over time.  

Since the Tier overlay maps were implemented in 2005-06, nothing has changed to justify a change in this property’s Tier I status.  Under the Florida Keys Area of Critical State Concern framework, the county opted to reduce commercial and residential development in North Key Largo because the area contains the largest tropical hardwood hammock in North America and serves as a vital hurricane evacuation route. This policy has remained in place over many years and could negatively impact community safety by extending hurricane evacuation times. 

North Key Largo has long served as a vital habitat for numerous species of wildlife and plays a crucial role in maintaining the ecological balance of our community. Any alteration to the protections put in place risks dismantling the accomplishments made so far.

Furthermore, the preservation of such areas is not just a matter of environmental concern but also a matter of ethical responsibility towards future generations. These protected areas represent our commitment to sustainable development and ensuring that our natural heritage remains intact for the benefit and enjoyment of all.

Thank you for considering Last Stand’s perspective on this crucial matter. We hope the county continues to work towards upholding their commitment to environmental stewardship by maintaining the Tier I designation of the Wilson-Avirett property.

From the Board of Last Stand