Collier County 2070

Photo by Carlton Ward Jr.

Saving Special Places • Building Better Communities

Fine-Tuning Collier County’s RLSA Program

Collier County’s Rural Lands Stewardship Area (RLSA) to the northeast of Naples encompasses close to 200,000 acres of prime agricultural and pristine natural lands containing some of Florida’s finest remaining panther habitat. Surrounding unincorporated Immokalee, the region is characterized by tomato farms, vast cattle ranches, citrus groves, and natural flow ways.

But as with other rural areas, the RLSA remains vulnerable to sprawling development. This threat will only be intensified if the proposed M-CORES Southwest Central Florida Connector toll road is constructed, making the area even more easily accessible for development.

Adopted in 2002, the RLSA establishes an overlay in the county’s future land use map, using the transfer of development rights (TDR) to cluster development in more appropriate locations to protect the region’s natural and agricultural lands and waters. But the program is not working as intended.

While more than 90% of RLSA land was intended to remain in conservation and agriculture, a 2007 review by Collier County revealed that, if built out, only 53% of the land would remain rural, with the balance open for development. 1000 Friends conducted an analysis of the RLSA program in 2013, also finding that too large an area of land was identified as suitable for development.

Collier RLSA Adoption Map

In 2018, Collier County launched a restudy of the RLSA program, holding a series of workshops to gather input. With support from the Martin Foundation, in 2019 1000 Friends of Florida reviewed previous studies, including those undertaken by Smart Growth America and the Conservancy of Southwest Florida.

1000 Friends has identified a series of recommendations, including that the TDR credit system be recalibrated to curtail “receiving areas” deemed appropriate for development, that wildlife habitat – particularly for panther – be considered when establishing receiving areas, and that development in receiving areas be compact in form so that new infrastructure is not a financial burden on county taxpayers.

The RLSA program has tremendous potential but needs reform. In late October 2019, the Collier County Commission reviewed its Rural Lands Stewardship Area Restudy White Paper and voted to make some changes to the program. They did not address meaningful changes to the TDR credit system so that issue still remains.

Background on the Collier County RLSA Program

Collier County’s RLSA program has a long history. In 1999 the Governor and Cabinet found a series of the county’s comprehensive plan amendments not meeting required state standards. The county addressed those shortcomings in part with the establishment of its optional RLSA program, established in compliance with the RLSA optional tool established under Florida Statutes to “accommodate future land uses in a manner that protects the natural environment, stimulate economic growth and diversification, and encourage the retention of land for agriculture and other traditional land uses.”

The stated goal of the Collier County RLSA program is:

To address the long-term needs of residents and property owners within the Immokalee Area Study boundary of the Collier County Rural and Agricultural Area Assessment by protecting agricultural activities, preventing the premature conversion of agricultural land to non-agricultural uses, directing incompatible uses away from wetlands and upland habitat, enabling the conversion of rural land to other uses in appropriate locations, discouraging urban sprawl, and encouraging development that implements creative land use planning techniques.

Collier’s RLSA establishes a transfer of development rights program within the comprehensive plan’s future land use map to transfer potential development from sensitive lands to areas more appropriate for development. RLSA “sending areas” are based on the natural resource value of the land, and include flow ways, habitat stewardship areas, and water retention areas, primarily in private ownership. “Receiving areas” are intended to cluster development in more appropriate locations without promoting net new development.

Program Shortcomings

When the Collier County RLSA overlay was implemented in 2002, the program was considered a cutting-edge approach to protecting this 300-square-mile area. But as is often the case with new, cutting-edge initiatives, problems soon were identified with the program’s implementation.

Collier County undertook an analysis of the program in 2007 which found “…more intensive development, in the forms of towns and villages (called Stewardship Receiving Areas or “SRAs”), was much greater under the RLSA than was initially anticipated by the County Commissioners and the original RLSA committee.” In fact, while it was maintained that more than 90% of the land would remain in conservation and agriculture, the 2007 review revealed that only 53% would remain rural, with the remaining lands developed with towns and sprawl.

An analysis undertaken by 1000 Friends in 2013 likewise found that the acreage allocated to SRAs was too large:

The complexity of the system resulted in excessive credits beyond what was initially anticipated and well outside the land planning and management goals and objectives of the RLSA program. Importantly, the spatial extent of Open Space Land available for SRAs is too large and much greater than the original 16,805 acres of development footprint.

In its 2013 report, 1000 Friends made a series of eight recommendations, including to:

• re-evaluate the RLSA Overlay credit system;
• sustain rural and agricultural working lands;
• consider panther habitat in protection of rural agricultural landscapes;
• identify appropriate locations for new towns;
• address infrastructure costs;
• limit infrastructure in the Big Cypress Area of Critical State Concern;
• incorporate Immokalee within the RLSA Overlay; and
• limit extensions of stewardship agreements to one-year exemptions.

In 2018, Collier County launched a comprehensive RLSA restudy and held a series of public workshops to gather input. With support from the Martin Foundation VERIFY, in 2019 1000 Friends conducted another analysis of Collier County’s RLSA program. 1000 Friends continued to find that the RLSA Overlay did not meet all of the objectives identified by Florida Statutes, the Administration Commission final order, and Collier County, including:

• protecting environmentally sensitive areas, resources and habitats;
• protecting wetlands and water quality;
• retaining agricultural land;
• retaining rural land uses other than agriculture; and
• discouraging urban sprawl.

In addition to upholding its 2014 recommendations outlined above and upon our assessment of reviews conducted by Smart Growth America and the Conservancy of Southwest Florida, in its 2019 report 1000 Friends recommends that the following be at the forefront of Collier County’s considerations during the RLSA restudy:

• recalibrating the transferable development rights credit system so that that an appropriate
number of credits are available to sever from sending areas;
• considering habitat, especially Florida panther habitat, when siting stewardship receiving
areas; and
• ensuring that development of stewardship receiving areas follows a compact urban form so that new infrastructure does not become a financial burden on Collier County taxpayers.

Collier County 2070

Collier County 2010 Base Line
Collier County 2070 Trend
Collier County 2070 Alternative

The RLSA could be home to as many as 360,000 people and, as shown in 1000 Friends’ Florida 2070 report, the area is highly vulnerable to sprawl and excessive water consumption. The maps (to be inserted soon), derived from the report, show development (in red) in Collier County in 2010, and project development by 2070 if the county’s population grows to the extent projected by the University of Florida’s Bureau of Business and Economic Research, and development remains at its current density in the county. The maps also show water consumption in the county in 2010 (increasing in intensity from blue to red to black) and in 2070 under the current development trajectory.

To ensure protection of this important region, it is important that commissioners adopt policies that will restore the original RLSA intent of protecting the region’s natural lands, waters and wildlife.