June 20, 2020

The Honorable Governor Ron DeSantis

Commission of Agriculture Nicole Fried

Attorney General Ashley Moody

Chief Financial Officer Jimmy Patronis


RE:  Florida Keys Area of Critical Concern and the awarding of 1300 Building Allocations

Dear Governor DeSantis and Members of the Administration Commission:

Last Stand has been organized to promote, preserve, and protect the quality of life in the Florida Keys and its environs.  We attempt to effect positive changes to our quality of life and environment and to make decision makers aware of the full consequences of their actions.

Last Stand supported the petitioners in the recent administrative hearing regarding the Florida Keys Workforce Housing Initiative which involved the increase by 1300 building allocations (or ROGOs) of affordable housing for the Keys.  As an Area of Critical Concern, there is a statutory cap that limited development in the Keys and this Initiative ignored the County’s and Keys Cities’ efforts to limit development allocations to a level that has been in place for over a decade.

Last Stand is requesting that the Commission withdraw the granting of these 1300 ROGOs for the following reasons:

  • Florida Statute requires a hurricane evacuation clearance time for permanent residents of no more than 24 hours.  At the December 2019 administrative hearing, testimony revealed that there was an error in the 2012 hurricane evacuation model which resulted in the evacuation time to be 26.5 hours for the current authorized development.  The last eight years has seen additional development which would further increase the number of evacuees.
  • While the DEO recommended to the Administration Commission in 2018 that there would be an agreement that these new residents would evacuate early, there is no mechanism that would ensure that these individuals would actually evacuate early.  One can assume that these residents would leave at the same time as other residents and increase the time for evacuation, thus endangering all residents.
  • Monroe County has published a Draft 2019 Travel Time and Delay Study which found the Level of Service (LOS) had fallen below the County’s LOS standard of “C”.
  • Adding 1300 ROGOs will require expanding the County’s and Cities’ infrastructures (e.g. schools, wastewater facilities, drinking water, etc.) to meet the needs of these residents, adding both a financial and environmental burden to this fragile ecosystem known as the Keys.

As an Area of Critical Concern, the State has an obligation to protect the citizens and the environment from this unwanted growth.  Last Stand requests the Commission review this allocation of 1300 ROGOS and vote to rescind the order.

Yours truly,

Last Stand Board