Read Last Stand’s recommendations for the County’s Infrastructure Capacity Study

Last Stand is pleased that the BOCC, at its August 19 meeting, instructed staff to come up with recommendations regarding the scope and an estimate of the cost of a long-term Infrastructure Capacity Study by an independent consultant which focuses on whether the water, wastewater, electricity transmission, and roads infrastructure of the Keys will be sufficient to service our resident and functional populations.  Last Stand was one of 21 organizations throughout the Keys that had requested such a study.  In developing recommendations for the scope of the study, we ask that County staff take into account the following suggestions:

• Our organizations had requested a 20-year horizon for the study.  At the BOCC meeting, the Commissioners indicated that they prefer a 10-year horizon because the longer the time period for the study, the less reliable the results will be.   Last Stand would prefer that the study have a 20-year horizon because infrastructure has long lead times and decades-long lifecycles. Infrastructure being planned today may not be operational for a decade.  That said, because the purpose of the study is to assess infrastructure capacity limitations on how many more residential and commercial building allocations can be awarded after the 900 new residential allocations that were authorized by the State in 2025 have been fully issued and because the 900 new allocations presumably will have been issued within 10 years after the study is performed, we believe a 10-year horizon for the study should be adequate, provided it assesses the infrastructure capacity remaining after all the 900 allocations have been issued.

• The analysis of water infrastructure capacity needs to take into account the fact that water demand has increased at a much higher rate than projected population growth. This indicates that current methods for projecting growth in water demand are not capturing how water demand is actually changing.

• The analysis of water infrastructure capacity needs to focus on how much supply from the aquifers on the mainland is expected to be available for the Keys given the impact of sea-level rise, saltwater intrusion, and increased demand for water on the mainland due to growth throughout the region, legislative trends toward removing growth limitations in the area surrounding the FKAA wellfield, and the expected proliferation of data centers.  The analysis should also factor in the costs of relying more heavily on reverse osmosis going forward. 

• The water capacity analysis of water infrastructure capacity also needs to take into account changes in sources of water consumption, such as trends in irrigation use (especially considering the rate of commercial and hotel redevelopment) and new swimming pools, which can meaningfully affect overall demand independent of population growth.

• Regarding the analysis of electricity transmission infrastructure capacity, there has been talk for years about a transmission “choke point” between Islamorada and Marathon.  The consultant will need to pay particular attention to this issue.

• The study should include a fresh and thorough analysis of the functional population of the Keys:

  • Treat infrastructure demand as an independent indicator of growth, rather than simply assuming that rising demand reflects rising per-capita use (See Exhibit A)

  • Apply methodologies developed specifically for tourist destinations, rather than standard population-projection models (See Exhibit A) 

  • Project future growth based on actual trends, not solely on ROGO allocation projections, and acknowledge that ROGO-based growth has not tracked clearly with actual infrastructure demand

  • Update occupancy estimates for permanent vs. transient residential units, using both census data and utility usage to help distinguish permanent residents from units rented out as vacation rentals

  • Avoid treating census-designated "seasonal residences" as mostly vacant; use water and electric usage patterns to distinguish occupancy intensity, since a seasonally used home has a very different usage signature than one rented out most of the year

  • Take into account the proliferation of vacation rentals, destination venues, and RVs used as residences, whether they are legal or illegal

  • Use airport and rental car data as independent proxies for visitor volume

• It is very important that the consultant perform its own analysis of the issues and not simply rely on information provided by the utilities.

• We strongly encourage the County to involve the Keys municipalities in the study.  Hopefully the municipalities will share in the cost of the study, but this should not be a prerequisite.

• Moving forward with the study should not be conditioned on receiving money from the State of Florida to fund the study.  We believe it is critical that an infrastructure capacity study for the Keys be conducted before any more building allocations are requested from the State.  Of course, we encourage the County to investigate possible sources of funding.  We just don’t want to slow down the process or have approval of the study be conditioned on obtaining outside funding.
  

Respectfully submitted:

Keys Last Stand