Commentary: Confronting The Illusion of Affordable Housing

Palm Coast’s Comprehensive Plan says, “Citizens of all income levels shall have the opportunity to obtain quality housing at a reasonable cost.” Yet…

PALM COAST, FL – March 7, 2019 – The Housing Element Section of Palm Coast’s Comprehensive Plan says, “Citizens of all income levels shall have the opportunity to obtain quality housing at a reasonable cost.”

Further, it Finds: “The cornerstone of a City’s quality of life is its housing stock. Citizens of all income levels desire safe, secure, good quality housing at a reasonable cost.”  And “the public sector plays a role in helping to ensure that the housing needs of all citizens are met by attempting to balance the cost of housing with the income levels of available jobs in the community.” The affordability goal remains unfulfilled.

A Palm Coast family with the city’s median household income of $51,208 (US Census Bureau) can afford a monthly housing budget (rent or mortgage, taxes, insurance) of $1,280 (at 30% of earnings). Flagler County’s median income is $51,049, carrying with it a maximum monthly housing budget of $1,276. That means that half of the local population cannot afford a $200,000 home. Yet:

  • The median selling price for a single-family home (2019 year-to-date) in Flagler County is $241,500, affordable only for those earning more than 38% above the county median household income.
  • Only 31.3% of homes sold countywide were within reach of those with a median household income. In the city, the percentage of affordable homes rises to 36.8%.
  • Of nearly 900 county homes listed for sale by MLS, only 12.3% have a listing price below $200,000. By the same standard, only 16.4% of Palm Coast homes are affordable.

Two sides of affordable housing

Most people conflate the two sides of affordable housing. On one side is the very difficult and seemingly intractable issue of housing for those that are, or should be, in the social welfare system; the homeless, the mentally ill, the disabled, the indigent, those simply down on their luck, etc.

This commentary addresses the second side of affordable housing, dealing with the segment of society that is employed or employable. Simply put, the housing stock in Flagler County and Palm Coast is inadequate to suit the needs of the bottom half of the earnings ladder.

To have a meaningful discussion about affordable housing, one must understand its two sides. Whether I call it affordable housing, workforce housing, or entry-level housing, nearly everyone reflexively jumps to the conclusion that I’m talking about the social welfare side of affordable housing. They dig their heels in, citing the dark side of Section 8 housing and using euphemisms like “those kinds of people.”

Entry-level housing

The Flagler County School District is the county’s largest public sector employer. The starting pay for Flagler County teachers and first responders is roughly the same; under $40,000 per year, well below the median household income. Their maximum monthly housing budget is about $945 (30% of earnings). Their house hunting is limited to homes selling for no more than $150,000, or only 4.5% of the homes sold year-to-date and only 1.2% of all county homes listed for sale. There is only one Palm Coast home currently listed below $150,000.

The rental side is similarly bleak. MLS lists a total of 95 homes, duplexes, apartments and condos available as long-term rentals. Only two are listed for $950 or less. Only 24 meet the budget of the median household income family. The median rent is $1,450.

The lack of available housing options hinders efforts to recruit employee. Our largest private sector employer is our growing hospital. Entry-level healthcare workers face the same housing affordability dilemma as teachers and first responders. Hospitality, service, and retail workers, at the heart of our county’s economy, are even more challenged. Housing stock is one of the criteria evaluated by companies contemplating a move to our location.

An exhibit at the National Building Museum, based on data from Fannie Mae, reveals that nuclear families account for only 20% of American households, down from 43% in 1950. Singles, living alone, account for nearly 30% of today's households. U.S. housing has not kept up with these trends.

Can we build a $150,000 home in Palm Coast?

Palm Coast has roughly 15,000 undeveloped (but buildable) 10,000 SF lots which can be purchased for a median price of $20,500. This is less than half of what a developer will pay to develop a community of lots from raw land, but I’ll talk about that later.

Assume the minimum-sized single-family residential home allowed in Palm Coast; 1,200 living square feet with a two-car attached garage. In the list of costs below, all but a small percentage of the permit and inspection fees are fixed.

The two most expensive rooms in a house are the kitchen and baths. Adding another bedroom or two, a foyer, a flex room or a den/study costs less per square foot, encouraging builders to build larger homes so they can amortize the lot cost, water & sewer connection fees, and impact fees over a larger space, thus lowering the overall cost/SF. This discourages builders, as a matter of policy, from building smaller, less expensive homes


 Land (existing Palm Coast infill lot)


 Park System Impact Fee


 Fire & Rescue Impact Fee


 Education Impact Fee


Transportation Impact Fee (for infill lots)


 Water & Sewer Connection Fees


 Building and Permitting Fees


 Construction at $120/SF (including landscaping and driveway)


 Total Cost (exclusive of builder/developer profit)



Even if the land is free, we can't realistically build a new single-family home in Palm Coast for a starting teacher or first responder. And there is a dearth of affordable existing home inventory.

New Development

Is new development, either an undeveloped parcel within Palm Coast or elsewhere in the county, a better option for affordable housing? Not really. It costs nearly $600 per lot frontage foot to build a road and infrastructure with buildable lots, assuming a double loaded road (homes on both sides of the road). Double that number if the road is single loaded. That puts the raw lot cost of a 60-foot lot at roughly $35,000. Add to that the cost of the raw land, the cost of engineering, wetland mitigation, surveying, platting, rezoning, entry features, amenities, additional sewage lift stations, etc. Realistically, the final cost of the lot approaches $50,000. Additionally, the city transportation impact fee for non-infill lots is $1,349 higher per house.

What can we do?

There are several impediments to affordable housing. Not the least of them is the institutionalized NIMBYism of Flagler residents. Everyone wants their pizza delivered expeditiously, but they want the pizza delivery person to live in Putnam, Volusia, St Johns County, or at least Mondex. This feeling is visceral. It is powerful. It is also irrational. Who among us has never lived in rental housing, a one-bath home, a home without a garage, or a home smaller than 1,200 SF? Are we saying that we do not want to live near our 25-year old selves?

Palm Coast City Council recently ignored a nearly unanimous (6 to 1) recommendation by the Planning & Land Development Regulation Board (PLDRB) to reduce the minimum requirement for a permitted single-family home to a one-car attached garage from the currently required two-car attached garage. Does a single teacher or nurse need a two-car garage? Such a change would affect only a small percentage of new homes but would reduce that home’s cost by roughly $15,000. There are hundreds of pre-Land Development Code single-car garage homes in Palm Coast. They go unnoticed because they are, well, unnoticeable.

We can allow greater density. There have been no building permits issued in all of Flagler County for multi-family construction in over four years. With a maximum allowable density of only 12 units per acre, Palm Coast has effectively discouraged apartment development. Apartments are so scarce that apartment rents rival single-family and duplex housing rents.

There are new apartments in the permitting cycle with construction planned to begin this year. At least some of the rents are projected to be less than $1,000 monthly. These are made possible by subsidies available through Palm Coast’s Opportunity Zone and Innovation District within Town Center. Yet their arrival is being met with much-anticipated NIMBYism.

On the single-family home side, narrower lots will require fewer linear feet of new roads and reduce stormwater management needs (and costs). Smaller lots will reduce environmental impact and the need for landscape irrigation. Smaller footprint homes will lower construction costs and reduce stormwater runoff.

Restrictive building codes

Modular homes are the product of a more efficient method of construction, built in an environmentally controlled factory rather than on-site. Modular homes meet Florida building codes and are not prohibited as a class in Palm Coast. Yet there are no modular homes here. The reason lies within the Architectural Design Regulations of the Land Development Code (LDC). Requirements dealing with pitched roofs, massing requirements, articulation, fenestration, shutters and awnings tend to be incompatible with modular construction standards.

Manufactured Homes: Revisiting the Palm Coast Comprehensive Plan

Policy – Within one (1) year of Plan adoption, the City shall establish a mobile/manufactured home (bearing the HUD approval insignia) zoning district, which is not subject to the same architectural and aesthetic regulations as applied in the City’s other residential zoning districts. The City’s LDC shall provide that lawfully existing mobile homes may be allowed, subject to conditions, to continue as non-conforming uses.

Regarding manufactured and modular homes, the LDC states as follows:

13.03.05.  Manufactured dwellings and mobile homes bearing a Florida Department of Community Affairs Seal. Manufactured dwellings and mobile homes that bear a Florida Department of Community Affairs Seal shall comply with the regulations for single-family residential and duplex architectural design. In addition, they shall meet the following:

A. A continuous perimeter stem wall foundation or monolithic foundation floor slab system that meets all criteria of the Florida Standard Building Code, shall be provided. Exterior walls of these dwellings shall bear directly on the foundation. Isolated elevated pier foundations are prohibited. Interior load-bearing foundations and/or walls shall be continuous.

B. The electrical service entrance shall be located on the dwelling.

C. The exterior face of all stem wall foundations and/or monolithic design shall be architecturally finished with Portland cement stucco, brick, stone, siding materials, or other durable material approved by the Land Use Administrator.

D. The main entranceway shall be covered with a roof structure. The roof structure shall be consistent with the roof structure of the principal dwelling and shall cover, at a minimum, the required exterior landing at the door. The entry roof structure may be an extension of the main roof system or a separate roof system that matches the main roof slope, materials, and architectural style. If separate, the roof structure shall be consistent with the principal dwelling.

To put the meaning of the preceding text in other words; “Not In My Back Yard.” Palm Coast has neither mobile home communities nor modular homes. This is akin to red-lining. It is exclusionary zoning.

Lack of action is far-reaching. The median age of Flagler County residents rose from 47.2 in 2010 to 50.3 in 2017 (US Census Bureau). That’s 5.3 months per year. 30.2% of Flagler’s population is 65 or older, making it demographically one of the oldest counties in the country. [Thank God for The Villages.] Don’t think that this rather dramatic shift is not the result, at least in part, of our inaction on affordable housing.

Inaction effects not only the quantity but the quality of our available labor force. Those earning below the median household income are more likely to be transportation-impaired; without reliable transportation or without the income to cover long commuting expenses. The best workers, especially in these times of full employment, will find work near home. Less qualified employees will have to seek employment further away. By limiting nearby affordable housing, Flagler County is lowering both the size and the quality of its available labor pool.

Living up to the Comprehensive Plan

The Comprehensive Plan was not created by a third party. It was not thrust upon an unwilling City Council. It was not a preemption document emanating from Tallahassee. It was written locally and adopted by the City Council. It should not simply be hung on a wall to prove our benevolence. It should be found not only in the text but also in the spirit and implementation of the Land Development Code.

My comments are admittedly focused on Palm Coast, in part because the clear delineation between their “goal,” as reflected in the Comprehensive Plan, and the reality of their action is most stark. It’s also because Palm Coast represents nearly 80% of the county population and therefore, its housing stock. It is the “gorilla in the room,” a moniker of which they are generally proud.

But my commentary is aimed at everyone; both elected officials (in other municipalities and at the county) and residents. It is a connected world. There are lots of moving parts to affordable housing. For instance, the abundance of cars parked in driveways (and swales) on your street is less due to the lack of garage space than to the lack of affordable housing. Homes designed to be single-family residences are now housing multi-generational families. Many residents are renting extra rooms to non-family members to help cover the cost of their own housing.

As the Comprehensive Plan says, “The cornerstone of a City’s quality of life is its housing stock. Citizens of all income levels desire safe, secure, good quality housing at a reasonable cost.”  And “the public sector plays a role in helping to ensure that the housing needs of all citizens are met by attempting to balance the cost of housing with the income levels of available jobs in the community.”

Prompt action is required. The health of our local economy and our quality of life depend on it.

8 replies
  1. Toby
    Toby says:

    Reply to Charles

    Yes. I rented as well. Even spent a short time in a single-wide. But in Palm Coast, the rentals are too expensive for entry-level workers. Builders and realtors are not creating the problem. The problem is created by the Land Development Code.

  2. Charles compton
    Charles compton says:

    Affordable housing

    As you state , entry level pay for teachers and 1st responders is around 40000 per yr.
    Who bus a house when they are starting out…. My wife and I worked 10 years saving for a down payment so we could afford a home. We rented, we worked overtime.
    The builders and realtors are creating this housing issue out of greed. Let the market dictate the prices. Work hard save your money and buy when you can afford. Lets not build low value homes in higher value neighborhoods just so yo can get a sale….

  3. Jane Force
    Jane Force says:

    smaller homes

    Why not allow 1,000 sf 2 bedroom 1 bath a 1 car garage houses for retires, singles or newly weds. It is a fact 2 bedrooms sell faster that 3 bedrooms the 3 bedrooms faster that 4 bedrooms in Palm Coast. There is a demand for smaller homes!

  4. Heather
    Heather says:

    FPC Graduate

    My 22 yr old FPC graduate was approved for $200,000 mortgage today. Even him making $46,000 a year, rent and home ownership seem just out of his reach in Palm Coast. It’s a shame the tax payers are going to lose out on their 13 year investment in him. He’s an outstanding product of being raised in Flagler County, but most likely he will have to find housing in a more affordable county.

  5. Charles Compton
    Charles Compton says:

    Land development code

    Toby thanks for responding, changing the LDC will only increase density, which allows for builders to maximize the amount of profit per square ft of land. This is the only motivation for building smaller. Back in the days of the great building boom in Palm Coast, builders built many smaller homes, a disproportionate number of which became rentals. Those neighborhoods to this day are unkempt and reflect poorly on PC.
    There is a need for reasonable housing, but the current LDC is why we came here, it protects a lifestyle as do the code enforcement rules. …..Changing the zoning is opening Pandora’s box, I’ve witnessed the outcome 1st hand , it ain’t pretty, that’s why we are here. I’ve seen beautiful old neighborhoods ruined by zoning changes. When the builders lawyers went before the board the argument was my client has the right to maximize the value of his property. And the crooked politicians opened the door….It’s all about money…….not about the poor people who can’t afford housing……

  6. John Kent
    John Kent says:

    Third side of Affordable

    There is also a third side to affordable. As Palm Coast home owner would I be able to afford my real estate taxes that are set to rise sky high because those affordable housing companies are EXEMPT!?
    Take for example MID Florida Housing company that owns 16 affordable single family homes in Palm Coast and pays NO TAXES at all. They get AFF HOUSING – 100% EXEMPTION. Yet every family I saw living in one of their homes has 2-3 kids. Do they go to private school with parents paying for it? NO! They use public school system with transportation provided. So who pays for it? You and me, dear home owners of Palm Coast! Who pays for services city and county provide? You and me again, dear home owners of Palm Coast and Flagler County!
    Shall we be able to afford our homes if we set to pay taxes for all those affordable houses they are about to build here? I doubt it.
    Then again question of affordability is an interesting one. I want to live in West Palm Beach but can’t afford it. Maybe owners of those multimillion dollar homes are going to build me something affordable in a midst of their paradise and pay taxes so I can use their excellent school system too?
    Have to send Toby there to make it happen! LOL

  7. Frank
    Frank says:

    As a vacant lot owner

    Several times over the years I considered building a home and relocating. Due to the city building fees I can’t justify building and relocating to Palm Coast. I’m a white collar professional who can afford to build a home using cash.

    For the amount of money required to build I can live in other cities in Fl which offer much more to do for someone like myself. And a lower median age level spurs imagination, inventiveness and excitement A 35 minute one way drive for a night out is not for me.

    So when I ask myself what is there really to do in PC for someone like myself. The answer is extremely limited. Good luck any keep up the good work your doing.

  8. Nick
    Nick says:

    If I can do it, you can too

    I was a single male, making less than $45k and 22 years old when I purchase a piece of property and BUILT my 4 bedroom, 3 bathroom house. It’s not that difficult when you work hard and save your money. Not to mention mortgage companies don’t require 20% down anymore. If I can do it, you can too.

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