Florida Dept of Community Affairs Flexes Muscle Rather than Brains

DCA’s ruling that Palm Coast’s Comprehensive Plan Amendment adopting a Northwest Corridor Overlay Area makes no sense.

Palm Coast, FL – September 2, 2010 – Last week the Florida Department of Community Affairs (DCA) notified the City of Palm Coast of its intent to find the City’s Comprehensive Plan Amendment "NOT IN COMPLIANCE" with state statutes. In fact, I find the department’s actions are not in compliance with its own mission statement.
Palm Coast’s Comprehensive Plan Amendment extends the planning horizon from 2020 to 2035. It also establishes a Northwest Corridor Overlay Area (NCOA). Both changes are the result of plans to develop two planned communities on approximately 15 thousand acres annexed into the city last year. Neoga Lakes covers 6,378 acres with plans for 7,000 residential units, and 2.3 million square feet of non-residential space. Old Brick Township’s 5,273 acres, contiguous with Neoga Lakes, is planned for 5,000 residential units 50,000 square feet of office, 100,000 square feet of retail, and 1 million square feet of light industrial space.

Growth management

The DCA seems to be caught up in some parallel universe inhabited only by Amendment 4 proponents and CAVE people (Citizens Against Virtually Everything). Perhaps spooked by upcoming sunset legislation that might eliminate them; they’re behaving like dogs lifting their legs; marking as many trees as possible to advertise their territory. But even the DCA recognizes that Florida’s population will grow in the future. Its website says, "….the department assists Florida’s communities as they plan for the impacts of growth and development. With Florida welcoming hundreds of new residents each day, local communities face significant challenges. They must provide adequate roads, schools, water, parks and sewer facilities for their residents, even as they strive to retain the character that made them such desirable places to live in the first place." Extending the City’s planning horizon from 2020 (only ten years away) to 2035 makes a lot of sense when two developments with a 20 to 30 year build out are under consideration.


The DCA as well as some journalists have equated the two planned communities with "sprawl." Nothing could be further from the truth. This land is not virgin territory. It has been ravaged by timbering and agriculture uses over the years. It has been significantly changed. The hydrology has been altered. If the NCOA is not approved, how will this land be developed? Current land use allows only one residential unit for every five acres. Think of a home every five acres, each with its own septic tank, well, and fences, miles from jobs and shopping. There will be no provision for wildlife corridors, no plan to improve the hydrology and protect wetlands. There will be no large contiguous open spaces permanently dedicated to nature. Missing will be passive parks, lakes, or trails for local residents. Also absent will be land set aside for schools, offices, commercial and industrial buildings. In other words, there won’t be any place to work or shop.
The two planned communities implement the latest concepts in intelligent planning; urban villages. Green standard housing is concentrated in clusters, leaving huge natural preserves integrated with schools, office space, retail, and light industrial space. Representatives of the two communities have worked for 2 ½ years to achieve an integrated plan for the 7,000 acres. They worked closely with several other agencies, listening to their concerns, including their suggestions, and gaining their support.


The Florida Fish and Wildlife Commission said about the project, "Working with FWC staff, the applicant developed a land use plan that incorporates measures to avoid or minimize adverse impacts to regionally significant wildlife species and associated habitat….We conclude that the current DRI will not pose a significant impact to regionally significant wildlife species or habitat onsite or offsite."
"With the majority of the state’s fish and wildlife habitat in private ownership, the FWC recognizes the critical role that private landowners play in conserving the state’s natural resources”.
The Flagler County School Board says, “The draft agreement includes mitigation to address the capital impacts of 4,000 non age restricted residential units with a total proportionate share mitigation amount of $25,155,556. The draft mitigation plan includes the following: donation of a school site, payment of school impact fees, payment of property taxes to support capital improvements, and payment of impact fee surcharge”.
Both Neoga Lakes and Old Brick Township are Developments of Regional Impact (DRI). In addition to DCA, the Northeast Florida Regional Council reviews and approves Comprehensive Plan Changes and DRIs. They gave their approval to the comp change saying, “By consent at its August 5, 2010 Board meeting, the Northeast Florida Regional Council commended the City of Palm Coast and its staff for the tireless efforts in developing the North Corridor Overlay Area (NCOA). … The Council recognizes the countless number of hours that Palm Coast staff dedicated to the development of the plan. … by requiring DRI review, coupled with the planning and environmental principles established in the NCOA, the City provides a level of protection for development in this area of the region.”
A representative of the Audubon Society has been closely following developments. At a recent City Council meeting he said (paraphrased) "I’m neither for nor against development, but if there is going to be development, this is the way I’d like to see it happen."
Planners met with their counterparts in St. Johns County to make sure the Palm Coast wildlife corridor aligns with that planned for St. Johns. The St. Johns River Water Management District has been closely involved as the project has moved forward.
Even if you object to a lack of coordinated Palm Coast’s planning efforts in the past, you should embrace the NCOA concept. It is a policy and framework above and beyond the comprehensive plan to guide development over a wide area of our city in a manner best suited for both residents and mother nature.
I recently had a conversation with a local resident who argued that we don’t need more property entitled for residential development when we already have 40,000 entitled but vacant lots. I countered making two points:
  1. My partner is the conversation lived in one of the communities surrounding the original ITT core of what is now Palm Coast. Using his own logic, his development would never have been approved in time to be ready for his arrival here. New arrivals need choices.
  2. The other point I made is that 40,000 lots represents only a potential. It’s not reasonable to think they will all be built upon. I’ve played golf in Grand Haven for 10 years. During that time, I’ve birdied every hole at least once and had three eagles. Par is 72, so my potential is a round of 51; not possible though I still keep trying. My very best round on the course is 74; that’s 23 strokes above my potential.[And that was a long time ago.]

In perspective, the increase in entitled (permitted) residential units for the two communities will be only 30% with phased 20 to 30-year build outs. Flagler County grew by about 50% in ten years. Plus, the Old Brick Township DRI ties phase two and three residential growth to successful commercial growth. Until the jobs are there, growth is suspended.

Remember, these projects and the NCOA are part of a LONG RANGE PLAN. In that context, they are appropriate and deserve our support. If you don’t think planning should be done this way, what would you suggest?
6 replies
  1. Evelyn Palmeri
    Evelyn Palmeri says:

    Florida Dept of Community Affairs Flexes Muscle Ra

    The argument that development benefits our community is no longer academic. It’s been proven wrong.

    A short tour of Flagler county shows the bleached bones of "intelligent planning; urban villages" from one end of the county to the other with piles of dirt where tens of thousands of trees once stood. Down my way is the highest peak in Flagler county, the infamous Mt. Follywood standing proudly behind the newest Publix and east of the new, beautifully appointed, subsidized by us taxpayers, public housing project on Rte. 100 — just south are the lesser peaks of the Mt. Bobby Ginn range on John Anderson Hwy.

    Your statement that the tracts in questions aren’t "virgin" because they were "ravaged by timbering and agriculture" is risible and the Audubon Society which once stood proudly against ravaging the landscape has become so politicized it now stands foursquare with the Army Corps of Engineers and others tasked with protecting our natural resources, in the camp of the developers.

    You ask: What would you suggest?

    I suggest that we relieve the tax payers from the burden of paying the salaries of all those dedicated people who spend their time thinking of ways to bend to the will of developers and put a moratorium on further development until such time as there’s a proven need for more dwelling units and commercial space.

    Only then will we be able to make intelligent decisions about our needs and by that time perhaps developers will have all gone broke leaving the rest of us in peace to enjoy our "five acres, each with its own septic tank, well, and fences, miles from jobs and shopping" — it is, after all, only the American dream of hundreds of millions of us CAVE persons going back to the pilgrims.

    Elitists like yourself who are so much smarter than the rest of us wouldn’t understand that.

    BTW – your simile about dogs marking their territory is a bit crude.

  2. Eric
    Eric says:


    Excellent article! Concise and factual. If there is to be growth in our area, then the carefully planned developments of Neoga Lakes and Old Brick Township are good examples of how to approach them in the real world. If a community doesn’t have a sane and rational plan for growth, then it will ultimately stagnate over time.

  3. Evelyn Palmeri
    Evelyn Palmeri says:

    Florida Dept of Community Affairs Flexes Muscle Ra

    I’m neither a developer nor an environmentalist.

    We bought a lot in an established town and built a single house following the rules and regs handed down by the housing authorities in the city and county.

    Unlike meddling do-gooders and those who know far better than we, how we should live my life, I don’t claim to know how people will want to live 35 or even ten years from now. Things are changing so rapidly, by then, there may be no need for millions of square feet of commercial space because we’ll all have replicators ala those on the Star Ship Enterprise and old geezers like us will have gotten a one-way ticket to that Valhalla in the sky where only little vine-covered clouds are issued occupancy permits.

  4. Joe
    Joe says:




  5. Toby
    Toby says:

    Reply to Evelyn

    Let’s see – you live in Flagler Beach which is located on what once was a pristine barrier island until developers came along and built your house and other structures there. ”A developer is someone who wants to build houses near the beach. An environmentalist is someone who already has a house near the beach.” If your mindset prevailed, there would be no Palm Coast or Flagler Beach.

Leave a Reply

Want to join the discussion?
Feel free to contribute!

Leave a Reply