North By Northwest: State Rejects Palm Coast’s Sprawling Growth Horizon
FlaglerLive | September 1, 2010
On Aug. 28, the Florida Department of Community Affairs, which reviews local governments’ growth plans to ensure against runaway development, declared Palm Coast’s plan to open up the Bulow Creek area along Old Kings Road to high-density development in compliance with state objectives. Palm Coast can now proceed virtually unhampered—except by its own city council, which is unlikely—to permit a developer to build 2,500 homes on some 800 acres there, along with 2.5 million square feet of commercial and industrial development. That, for Palm Coast’s government, was the good news last Friday.
The bad news was that the Department of Community Affairs also rejected another critical amendment to Palm Coast’s long-term growth plan that’s essential to the city’s development in its northwest and west, where it is moving to approve two huge new developments that would add 12,000 homes between them, and millions of square feet of commercial and industrial developments.
- Conservation in Contempt: How Palm Coast Opened the Way to Urbanizing Bulow Creek
- DCA Finds Bulow Creek Comp Plan Amendment In Compliance
- DCA Finds Northwest Overlaw and Planning Horizon Amendment Not in Compliance
- Read DCA’s Full Report on Palm Coast’s Northwest/2035 Amendment
- Enterprise Flagler’s Tax and Build Plan Revealed: How They’ll Seek Your Vote
- It’s Raining Taxes, Cont’d: Behind Scenes, County Manager Floats Sales Tax Increase
Palm Coast wanted to extend its long-term “planning horizon” to 2035 and establish an “overlay” zoning area in its northwest. In May, DCA demolished the proposed amendment with 18 objections, recommending in almost every case against approval. After the city administration made some changes to placate the state—an administration that has publicly spoken derisively of DCA—the Palm Coast City Council went ahead and unanimously approved the amendment anyway, back in July.
Last Friday, DCA declared Palm Coast’s amended plan not in compliance with state objectives and land regulations.
In just one of its 18 objections, DCA had found the plan a recipe for sprawl under all 13 criteria by which the state defines sprawl: the plan would allow the development of low-density housing with no evidence that more such housing is needed (especially not with 18,000 lots in Palm Coast). The plan would sprawl in rural areas at substantial distances from Palm Coast’s existing urban centers. Developments “leapfrog” in isolated patterns that don’t necessarily connect to city services. Premature urbanization “fails to adequately protect and conserve natural resources, such as wetlands, floodplains, native vegetation, environmentally sensitive areas, and natural groundwater aquifer areas. (The site in question is 75 percent wetlands and 49 percent floodplains). Further, the sprawling plan allows for patterns that “disproportionately increase the cost of providing and maintaining” typical municipal facilities and services such as drinkable water, sewer, stormwater management, parks, and so on.
Another significant objection essentially concluded that Palm Coast’s future population assumptions—a critical component that goes to the need for additional housing of such magnitude—are somewhere between guesswork and fraud. The plan’s 2035 update, DCA concluded, “is not based on population projections and need analysis that are professionally acceptable because they are based on flawed and unsustainable assumptions.” The damning language gets more precise: “For instance, the assumption that the city will capture 91.4 percent of the county’s growth rate throughout the planning timeframe is not justified.” The city, in sum, acted as if the rest of the county has no relevance to its planning horizon (a finding that won’t necessarily surprise planning officials in the county or in other cities).
“In the population projections,” DCA’s objection continues, “the methodology states that the city’s population will continue to grow at the rate it has been growing because the NCOA will be available for urban growth” (the NCOA being the Northwest Corridor Overlay Area). Which is to say that Palm Coast’s administration is projecting growth tautologically: Palm Coast will grow because Palm Coast will grow, or because it’s making room for growth. What data Palm Coast provided to make its point was either vague or unsubstantiated. DCA didn’t buy the argument.
The state also objected to Palm Coast’s virtual contempt for protection of natural resources and wildlife (including through a network of roads that would fragment bear habitat, for example, while adversely affecting the survival of endangered and threatened species). Planning for schools was inadequate. Many other objections were listed. (Read DCA’s full report.)
DCA’s report amounts to a rejection of Palm Coast’s vision of itself as a necessarily growing, sprawling city. By accepting the development of the Bulow Creek area, DCA was agreeing to what amounts to “filling out” Palm Coast’s developable land between I-95 and the Intracoastal. By rejecting Palm Coast’s leap-frogging in time (to 2035) and geography (across its Northwest and west), DCA was signaling that sprawl has its limits, even when a city annexes land as aggressively as Palm Coast has. The city has almost doubled in area since its incorporation in 1999—from 50 square miles to 89 square miles. DCA is telling Palm Coast that annexation is not in and of itself an entitlement to development.
A look at Palm Coast’s “comprehensive plan” underscores DCA’s issues with the city’s creative way with numbers and assumptions.
For example, the old plan had a projected Palm Coast population of 141,557 by 2020, a figure it termed “an underestimation by several thousands.” Those lines were deleted from the plan, for obvious reasons: the projections proved to be an overestimation by several thousands, if not tens of thousands, as the housing crash—and 18,000 empty lots and a surfeit of foreclosures inside the old city limits—has radically altered those projections. But the following lines were not deleted: “The growth of the City’s economic base, including jobs and shopping, has not kept pace with its residential growth. The residential growth is predominantly comprised of single-family homes on quarter acre lots. Few housing alternatives are available.” White it’s true that the city’s tax base is disproportionate to its commercial and industrial base, it doesn’t follow that the only way to add balance to that mix is to add 12,000 more homes that would make the added industrial and commercial land uses more viable. Yet that’s the direction the plan took (and the disproportionately whacky logic city council members approved).
Much has been and is being made of Palm Coast’s overwhelmingly residential tax base as doing harm to the city’s interests. Yet the city has one of the lowest property tax rates in the state, in a state that has some of the lowest property tax rates in the country. Property tax rates in Palm Coast, in other words, are among the lowest in the nation, and disproportionately so, despite the city’s lopsided reliance on residential property taxes. The comprehensive plan does not explain what, besides mere assumptions, is compelling a move toward more sprawl to justify more industrial and commercial tax base. (In the plan’s wording: Economic and business development to provide a proper balance of jobs, shopping opportunities, and tax base.”)
Another inconsistency is discovered in the plan’s section on affordable housing. “Approximately 60% of the total households in the City fall into an income category (i.e. defined as extremely low, very low, low, or moderate) where there is an identified need for affordable housing opportunities.” It’s not clear how the city’s sprawling west ensures that affordability is still a priority for 60 percent of the city’s population.