Florida Department of Economic Opportunity
107 East Madison Street
Caldwell Building
Tallahassee, Florida 32399-4120
19 October 2014
Ms. Brookens et al.
I’m writing to share some concerns regarding proposed changes to Sarasota County’s comprehensive Plan. I stand with Becky Ayech, John Wesley White, Maynard Hiss, Bill Zoller, Cathy Antunes, Dan Lobeck, Ann Kaplan, Mollie Cardamone and others who are questioning the process and outcome of the proposed revisions to Sarasota County’s comprehensive plan. I’ve worked with all the above-mentioned citizens, some for decades, and while we don’t always agree, I can attest to the fact that all of the above care deeply about the future of our county. I’ve attached some brief material related to my qualifications at the end of this document.
To begin with, I don’t object to any interest group prodding the County Commission to initiate major changes to our comprehensive plan. But when the County commits to doing so, it should be following adopted procedures, fully involving the Planning Commission, taking a comprehensive approach, and proceeding in a logical sequence. In my opinion, the County has failed to do so.
My intent is to focus on some procedural or structural issues others may not have focused on, and there are three I find most relevant: Failure to involve the Local Land Development Regulation Commission, Failure to be comprehensive, and Improper phasing of adoption.
Failure to Appropriately Involve the Local Land Development Regulation Commission
1) Since 2011 an adopted Scoping Process pursuant to Sec. 94-85 has required that staff conduct a two part scoping process wherein “the proposed amendment will be clearly defined and all pertinent issues identified.” The County followed this process when considering changes to the Transfer of Development process in 2013 and it required LPA (Planning Commission) involvement. Commissioner Barbetta mistakenly implied this wasn’t the case.
2) The Board initiated the scoping process in this case when they directed staff to prepare a scoping document and posted that intent on the 2050 webpage (screenshot from County 2050 webpage below). The staff initiated the scoping process as directed and held the required workshops.
3) The next step according to the law and the flow chart used in the TDR process should have involved going to the Planning Commission and providing for public comment. Then, once the Planning Commission weighed in, it should have gone back to the County Commission, which authorizes the scope and processing of the CPA (or not). This makes perfect sense because you would want the LPA involved in determining what should and shouldn’t be considered in an amendment.
4) Instead the County Commission aborted their adopted scoping process. Instead of following the adopted procedure they were partway into, on May 8th 2013 they took a short-cut, aborting the legally-required scoping route they started on, thus depriving the public and Planning Commission of the opportunity specifically laid out in Staff flow charts.
