Who Pays for Growth in Collier County, Florida: Part 2
This is the second in a five-part series of articles about how new planned development in Southwest Florida’s Collier County perpetuates an insolvent and destructive model of growth, despite the existence of policies that claim to prevent that very problem. Read part one here, and part three here.
Part 2: “Innovative” Growth or Business as Usual?
In Florida, the post-World War II suburban experiment took shape in an unusually reckless form, through land scams and the mass building of subdivisions far in advance of jobs, services, or demand. As a result, the backlash to this radical experiment also began early in Florida. The state is the birthplace of New Urbanism, a school of thought within urban design and architecture that seeks to recapture the advantages of pre-automobile principles of compact, walkable, mixed-use communities.
Boating in rural Collier County. Image via Flickr.
Florida's wave of growth management reforms of the 1980s through early 2000s were undoubtedly written with the intent to curb the excesses of suburbia. The state law governing local comprehensive plans even contains a remarkable list of criteria defining "sprawl" and instructs cities and counties to "discourage sprawl." (Read it yourself: section (6)(a)9 on "future land use elements" at this link.) This section of the law, in turn, is frequently cited by local lawmakers in Florida in shaping and applying their own growth management plans.
Collier County is no exception. Its standards for new development on rural land repeatedly emphasize “innovative” and “creative” growth, a break with what has come before. The same words in the state law that says local land use planning "shall…discourage sprawl"—not may, but "shall"—are the words peppered throughout Collier County's Land Development Code in the sections that govern new development in rural areas. Compact. Walkable. Connected. Functional mix of uses.
Do words have meaning anymore?
That's the question one is left with after listening to Planning Commission testimony on Collier Enterprises' proposed mega-developments in remote, rural Collier County: the villages of Longwater and Bellmar, which if authorized will join the already-approved Rivergrass to form a contiguous, brand new town of nearly 4,000 acres and potentially over 20,000 residents.
These transformative master-planned communities are to be located 15 miles east of Interstate 75 while nearly all of the county’s existing housing, jobs, and amenities are west of the Interstate. They are the epitome of automobile-oriented, horizontally expansive suburbia—exactly what the state legislators who wrote the comp plan law likely meant by “sprawl.” Their developer has attempted to launder them as something very different.
"Village" and "town" above are not colloquial terms here: they have specific legal definitions. Those definitions call unambiguously for development that embraces key principles of compact, traditional urbanism. In part one of this series, I quoted from the county's official definition of a "town" within the RLSA. Here's part of that definition again:
Policy 4.7.1:
Towns have urban level services and infrastructure that support development that is compact, mixed use, human scale, and provides a balance of land uses to reduce automobile trips and increase livability… Towns shall have a mixed-use town center that will serve as a focal point for community facilities and support services.
And here, from the legal definition of a "village":
Policy 4.7.2:
Villages…shall include a mixed-use village center to serve as the focal point for the community’s support services and facilities. Villages shall be designed to encourage pedestrian and bicycle circulation by including an interconnected sidewalk and pathway system serving all residential neighborhoods. Villages shall include neighborhood scaled retail and office uses.
Everything we have seen so far suggests that in order to be permitted, these three villages—which Collier Enterprises has explicitly stated it intends to legally combine at a later date into a town, subject to the "town" criteria above—ought to have certain characteristics. They ought to be places where you can walk (pedestrian circulation) a short distance from your home (human scale) and find a variety (mixed use) of businesses and services at the heart of the community (town center) that allow you to meet many of your life's needs without getting in a car (reduce automobile trips). In a more holistic sense, the language clearly evokes, well, actual villages and towns like those built for centuries all over the globe before the advent of modern suburbia.
None of this is going to be remotely true of these developments. The developer presents them as compliant anyway by taking advantage of the ambiguities in the county's code, arguing for expansive interpretations of plain-English words that defy common-sense understanding. Let's unpack a few specific terms to see how this Orwellian game functions.
Is this compact development?
Are these proposals "compact"? The developer's renderings might easily mislead you on this matter. The concept plans for the three villages appear to show a modest grid of neighborhood streets arranged into blocks—"village" doesn't seem an out-of-place descriptor after all. Here is that map presented, deliberately, without any indication of scale:
What you're looking at here is a series of three neighborhoods just like traditional urban ones in the same way that a Great Dane and a Chihuahua are both dogs, says urban planner Joe Minicozzi of Urban3, who analyzed the proposed developments and testified as an expert witness at the public hearings. If you were to look at side-by-side illustrations of a Great Dane and a Chihuahua drawn at matching scales, you would end up with a very misleading picture of what these animals actually look like.
In reality, the Big Cypress villages are massive. Here they are juxtaposed with the city of Naples itself, for a better indication.
The Big Cypress villages are quite spread out internally, as well. The planned gross population density of Longwater is 2.6 dwelling units per acre; Rivergrass clocks in at 2.5, and Bellmar at 2.7. Here is a photographic comparison to give you a sense of what that means: it is low by any urban standard and many suburban standards (including existing Collier County subdivisions). Below we see Rivergrass, on the left, compared to Kentlands, an early New Urbanist master-planned community built in the 1990s in Maryland. Kentlands, at a fraction of the area of the Rivergrass village alone, fits almost half again as many housing units: 3,500 versus 2,500:
Everything about the new proposals is super-sized. The misleading scale of what is being presented extends all the way down to the block sizes. Many of the blocks in Longwater, Rivergrass, and Bellmar are gargantuan, sometimes more than half a mile long. But you wouldn't know it intuitively from the rendering, unless you are used to recognizing how the suburban development pattern—which presumes that everyone travels by car—has stretched out the scale of everything we build and do to distances that are uncomfortable to travel without a car.
A typical urban block width in America is 1/16 of a mile, or 330 feet. Downtown Naples has generous 450x400-foot blocks. Here, for comparison, is the developer’s plan for the Rivergrass village, with select block lengths labeled and an inset, to-scale comparison to a typical New Urbanist development:
What does the developer have to say about the compactness? Well, here's the transcript from the April 1, 2021 Planning Commission hearing. On page 48, Collier Enterprises' planning consultant Robert Mulhure says,
[The Land Development Code] reads as follows: SRA developments are a compact form of development. It doesn't say may be. It doesn't say should be. It doesn't say will be. It says they are. That is a legislative decision that's already been made. They are compact. Now, I can go on, but let me go catch my breath.
The argument is literally that because the plans for Longwater have been submitted under a framework (the RLSA) that stipulates compact development, they are by definition compact. Regardless of anything about their design or scale.
This is some "It depends on what the definition of is, is"-level lawyering.
Is this walkable?
Very few of the homes in these communities will actually be within a convenient walking distance of their respective village centers. Many will be one to two miles away: too far for most people to go out to eat or pick up groceries. The distances are enhanced by the circuitous street layouts branching off of central spine roads instead of forming connected grids; by the proliferation of cul-de-sacs; and by large ponds in the centers of many blocks. Urban3 calculated the percentages of residences within distance thresholds of 1/4 mile, one mile, and over one mile.
The developer's attorney, Richard Yovanovich, dismissed these observations to the Planning Commission as follows:
Where Mr. Minicozzi came up with his quarter-mile walkability standard, I don't know. It's not in your Comp Plan. It's not in your Land Development Code.
A quarter-mile radius to define a walkshed is an extremely commonly used standard in transportation planning, which Mr. Yovanovich likely knows, but he's not wrong that the Collier County code is not specific about this point.
Yet the intent of the code is clear: to not only facilitate pedestrian circulation but to reduce vehicle trips. To argue that the mere presence of sidewalks and crosswalks, across distances that few reasonable people will choose to walk, achieves this goal stretches logic too far. In the absence of an unambiguous, measurable definition, county leadership ought to at least interpret the words in their own regulatory documents in a way a reasonable layperson could be expected to.
Nothing about this is walkable. Much about it could have been with a layout that took walkability seriously. Instead, the developer has made generous use of mid-block lakes to meet open space and stormwater retention quotas and, presumably, to provide private backyard water views. Collier Enterprises claims lakes as its get-out-of-jail-free card to make the blocks as large as it wants, according to planner Mulhure:
And the lakes on the land-use table in the RLSA fall under open space… And if you have a block length that exceeds the maximum of 3,500 foot of perimeter, if there's a lake and other elements within that block, you are allowed to exceed that perimeter. The staff reviewed this. We're consistent with the requirements.
These lakes arguably violate the rule that the maximum square footage for a non-residential use in a neighborhood is 3,000 square feet. If you really want to see some hair-splitting, read the part of the testimony (page 61) where the developer responds that a lake is not a "use."
“The center is not required to be in the center.”
Collier County unambiguously calls for villages to have a "village center" featuring neighborhood-serving businesses and amenities, and for towns to have a mixed-use "town center" that will "serve as a focal point." Let’s look where Collier Enterprises has chosen to put its "centers"—at the edge of each community, not in the center at all. The red arrows in the image point to the village centers of Rivergrass (top) and Longwater (bottom).
In the public testimony you can find a long, pedantic discussion of whether "center" implies being surrounded by the residential village on all four sides, or whether, in fact, "The center is not required to be in the center.” But what is clear is that putting the village center where it is dramatically increases the average walking distance to it for residents. Making it so the only access from the residential areas is along a single spine road only increases the lack of connection. It is in no rational way a “focal point” of the community anymore. And with the “centers” exiled to the periphery, these communities are not meaningfully mixed use—not any more than a series of separate piles of toppings constitutes a pizza.
There are two likely reasons Collier Enterprises has chosen to move the “center” to the edge. One is that they expect businesses will need to cater in part to customers who arrive by car from outside these communities, and this is more viable if they are situated on an external arterial road and not within the community. This assumption is not unreasonable, but it's also not ironclad: see, for example, the very successful master-planned community of Baldwin Park in Orlando, where the full-size Publix grocery store is in the actual center of the neighborhood. If a destination is worthwhile, customers will come to it.
The other reason is more straightforward, though, and makes the option discussed in the prior paragraph moot: Rivergrass, Longwater, and Bellmar will all be gated communities, and Collier Enterprises needs the retail to be outside the gate. Of course, no one is requiring that these villages be gated. But in the eloquent words of Mr. Yovanovich to the Planning Commission, "People like gates."
The gated layout hurts the ability of the three villages to ever 1) meaningfully interconnect as a cohesive town, or 2) achieve the expectation of discouraging automobile trips and being internally self-sufficient. But hey. People like gates.
What counts as “interconnected”?
Click through to see full-resolution, interactive version. Map by Collier Enterprises.
Another code requirement is connectivity. Towns, according to the Land Development Code, “shall create an interconnected street system designed to disperse and reduce the length of automobile trips.”
Here’s the developer’s own map on the Town of Big Cypress promotional website. You tell me how interconnected these villages look.
I mentioned above that the intention is to get three villages approved first, then retroactively declare them a “town.” But “towns” contain requirements that villages do not, such as a town center with more intensive commercial uses. What Collier Enterprises proposes for a town center is a linear strip of development along the yet-to-be-built Big Cypress Parkway, in between Longwater and Bellmar. To access it will require leaving either neighborhood, and there are only a couple points of connection: one can assume that nearly all of these “local” trips will be taken by car.
Even within the town center, it appears that the plan is to neatly separate development types—affordable housing from retail and restaurants from an office park.
Does this reduce automobile trips?
It’s hard to immediately appreciate how remote the location this proposed development is from, well, any other center of activity in Collier County. A trip in current road conditions (i.e. without any congestion induced by the new development) to the heart of Naples is 30 miles and takes 40 minutes to drive, according to Google. It’s 15 miles (20 minutes) just to get through the monotony of Golden Gate Estates and back to I-75—a likely minimum daily commute for most, since almost all of the county’s commercial activity and jobs are found west of the interstate.
None of the currently proposed plans stand to alter that imbalance. If all of the submitted commercial space is built, Urban3 found, the three villages will together have a jobs-to-population ratio of 1:28. This is compared to a long term goal of 1:1.7 for the RLSA, matching the county as a whole.
Frequent, long-distance driving will be a way of life for the residents of the Town of Big Cypress. It’s hard to reasonably envision any way around that. In fact, it’s hard not to think that part of the developer’s rationale for building this far out might be to market homes to Miami-area supercommuters. Fort Lauderdale is an hour and a half away on an essentially never-congested, straight-shot freeway across the Everglades.
This is auto-centric suburbia by any measure, yet it's proudly touted by the developer as the product of a process designed to produce compact, "innovative" approaches to growth that stand in contrast to suburbia-as-usual.
Can the County Enforce Its Own Rules?
In all of this, the obvious intent of the code is at war with the (often ambiguous) letter of the code as interpreted to give maximum leeway to the developer. That leeway is a policy choice. When Rivergrass was up for approval in 2020, both county planning staff and the Planning Commission recommended denial. Staff wrote in their report on Rivergrass that it is “a suburban development plan typical of that in the coastal urban area placed in the RLSA and is contrary to what is intended in the RLSA.”
The County Commission could likewise decide that words have meaning and to go with the intent. Will they instead hide behind an "our hands are tied" excuse when it comes to defining concepts such as walkable and compact?
And will they hide behind the same excuse when it comes to another crucial requirement of new development in Collier County: fiscal neutrality? In the next two installments of this series, we will dig into how these proposed developments will not pay for themselves in either impact fees or new taxes, but rather create liabilities borne generations into the future by the county’s taxpayers at large.
Technocratic growth management in Florida has failed, and a new conversation is needed. Let's start that conversation now.