M-CORES Planning Issues
Saving Special Places • Building Better Communities
On October 8, 2020, 1000 Friends of Florida submitted the following letter to FDOT Secretary Kevin Thibault:
Dear Secretary Thibault:
As you know, 1000 Friends of Florida opposed the 2019 legislation authorizing the three Multi-use Corridors of Regional Economic Significance (M-CORES). Nevertheless, we sought and accepted your appointments to the M-CORES task forces to advocate, in good faith, a strict adherence to the statutory commandment to “evaluate the need for, and the economic and environmental impacts of, hurricane evacuation impacts of, and land use impacts” of each of the corridors. (Emphasis added).
Our organization was founded in 1986 to promote a sustainable approach to development, deter sprawl, and protect Florida’s unique natural environment. It is widely documented that transportation systems are the prominent driver of land use patterns – good and bad. The enormity of the M-CORES project, unless it is thoughtfully planned and properly targeted, can be a formidable stimulator of inappropriate growth. We maintain that the priority for limited transportation dollars should be to address transportation issues in existing communities and provide multiple transportation options.
1000 Friends’ bi-partisan Board of Directors met last week and discussed the M-CORES task force reports. The Board is unanimous in its determination that there are three major shortcomings to the reports that must be addressed as follows:
- Require a preliminary determination of transportation need and financial feasibility PRIOR to the PD&E process, to prevent hundreds of millions of taxpayer dollars being spent designing roads that may be neither needed nor financially feasible according to FDOT standards.
- If both transportation need and financial feasibility are found, require the purchase or protection of key environmentally sensitive lands at interchanges PRIOR to construction to protect natural lands and waters from the impacts of sprawl.
- If both transportation need and financial feasibility are found, require the protection through easement or other means of key interchange lands within a 5-mile radius UNLESS those lands are currently served by municipal water and sewer or are designated for future development as an industrial job center.
Each of these requirements are discussed in greater detail below and have been shared previously. We also note with concern a lack of clarity on the role of local and state government in the comprehensive planning process, also discussed below.
Undertake preliminary determination of transportation need and financial feasibility:
The task forces’ opportunities to influence this process were sharply and summarily curtailed by the Florida Department of Transportation (FDOT) and its consultants for M-CORES “due to the early stage of planning … and the limited data and analysis on potential need and impacts available at this time,” according to language that appears in all three draft task force reports. This was a major concession, legally and practically, for task force members and the organizations they represent. It was never formally proposed to members for approval before it appeared in the draft reports.
This might have been mitigated by an explicit commitment from FDOT to suspend planning for M-CORES pending a preliminary determination of transportation need and financial feasibility prior to the PD&E process — the sequence called for under the state’s corridor planning process. Each of our task force members proposed this provision for inclusion in their task force reports. However, it was not adopted in any of the reports.
Because of this, hundreds of millions of public dollars are being spent on the PD&E process with the possibility of an eventual determination that the roads are neither needed nor financially feasible. Furthermore, by its automatic inclusion in FDOT’s 5-year work program without meaningful legislative or gubernatorial oversight, M-CORES will have a significant impact on the state transportation system, with the rest of the state subsidizing these corridors for a generation at the expense of their own transportation needs. We consider the absence of any commitment from FDOT to undertake a preliminary determination of need and financial feasibility before moving ahead with the PD&E process a serious obstacle to our ultimately supporting the reports.
If need and feasibility are established, implement the following changes:
1. Protect key natural lands at interchanges:
Also under the M-CORES legislation, the program is legally obligated to “protect the environment and natural resources” and “revitalize rural communities.” These are higher-than-usual standards for transportation projects implemented under state law. Each of our task force representatives submitted two proposals to ensure M-CORES complies with these statutory requirements. These proposals are consistent with provisions in the Wekiva Parkway plan — touted early on by FDOT as a model for the M-CORES process — namely, that provisions be included to limit the potential of interchanges to induce sprawl, and that significant natural lands should be acquired before funding of construction.
One proposal would have fulfilled the legal obligation to protect the environment and natural resources by preventing the loss of sensitive land and impairment of vulnerable waters where they would be most at risk, in the proximity of M-CORES interchanges. It would have required the protection within 10 miles of each planned interchange by acquisition, easement or other legal instrument — before construction begins —of the following: lands identified as Clip 1, 2 or 3 in the Florida Natural Areas Inventory; all lands identified for purchase by Florida Forever, Rural and Family Lands, and other state, county and municipal conservation land acquisition programs; springs and locally designated springs protection zones and resource preservation areas; and Florida Ecological Greenways priorities 1 or 2.
Far from being arbitrary or excessive, this proposal is appropriate to meet the high standard dictated in the law. It was not adopted, however.
- Limit sprawl at interchanges:
The other proposal would have promoted the revitalization of rural communities by protecting their character, agricultural lands and existing businesses from the negative impacts of new interchanges nearby. It would have barred construction of any interchanges until all land not currently served by municipal water and sewer or not designated for future development as an industrial job center within a 5 mile radius of the future interchange is protected by conservation easement, agricultural easement, purchase of development rights or other similar instrument. This also was not adopted.
We are of course aware that there are numerous provisions in the task force reports intended to provide some measure of protection for sensitive environmental assets and rural communities. Some of these provisions were proposed by our representatives. We appreciate their inclusion.
However, the reports fail to guard adequately against the heightened threat posed by interchanges to both vulnerable natural resources and rural communities. Rather than commit to acquiring conservation lands, the reports call for FDOT and its partners to identify opportunities to advance acquisition and funding priorities — an aspirational goal that falls short of a requirement and fails to specify a complete list of priorities.
- Address comprehensive planning issues:
Regarding the protection of land and environmental assets surrounding interchanges, the reports leave it up to local governments to consider whether land uses and environmental protections are appropriate or whether comprehensive plans need to be amended. It is indeed fitting for local governments to have a say in these decisions, but not the last word. A decision by a local government not to amend its comprehensive plan should be respected by FDOT, even if it forces a rerouting of a transportation corridor or rules out a local interchange. However, if local governments allow interchanges to become engines of sprawling development, the harmful impacts will almost certainly be felt far beyond their boundaries and impact resources of regional and even statewide significance, thus requiring state oversight per Florida’s adopted comprehensive planning process.
It is important to understand that future development in many of these rural counties would be stimulated primarily due to the investment of hundreds of millions of public dollars over the coming decade. This clearly reflects that the state indeed has a vested interest in and responsibility for what occurs in these rural counties, as it is financing the road system stimulating this development and its associated impacts. It would be more effective and cost-efficient for the state to invest in broadband, independent of the construction of roads, as a much-needed rural economic development strategy that would enhance employment, education and other opportunities without stimulating sprawl.
Further, the impacts of the toll roads are not confined by any county’s borders. Water is a prime example. Should one county choose sprawling development patterns that increase water withdrawals and degrade water quality, those impacts can be manifested throughout the corridor. Given that the waters in most of the corridor feed the Floridan Aquifer, in comprehensive planning parlance a “resource of statewide significance,” again the state should play a leading role in the planning process to protect Florida’s drinking water.
Additionally, the process for final review and approval of the task force reports at the final meetings later this month has not been settled for task force members. We request a formal vote to register either support, conditional support, or cannot support on the final report so that each task force representative’s position can be clearly indicated for the record.
Unless the draft task force reports are amended to require a determination of need and economic feasibility before M-CORES planning continues into the PD&E process, and then amended to meet the higher legal standards for environmental protection and community revitalization through the protection of key lands at interchanges as outlined in this letter and previous task force submissions, we will be unable to support them.
Chair, 1000 Friends of Florida
1000 Friends of Florida Board Member
Southwest Central Connector Task Force Member
William Thomas Hawkins
Former 1000 Friends of Florida Policy & Planning Director
Suncoast Connector Task Force Member
1000 Friends of Florida President
Northern Turnpike Connector Task Force Member
1000 Friends of Florida Board Member
Past Secretary, Florida Department of Transportation
1000 Friends of Florida Board Member & Past Chair
Past Secretary, Florida Department of Environmental Regulation
cc: Will Watts, Chief Engineer, Florida Department of Transportation
Huiwei Shen, Chief Planner, Florida Department of Transportation
1000 Friends of Florida recommendations regarding
high-level needs, guiding principles and implementation strategies for M-CORES
On July 20, 2020, 1000 Friends of Florida submitted the following to the FDOT M-CORES toll road task forces:
“On behalf of 1000 Friends of Florida, please find attached recommended language, following the format provided by FDOT at its last task force meetings, regarding high-level needs, guiding principles and implementation strategies for M-CORES. We urge you to incorporate them in the documents you will be preparing this week at the M-CORES task force meetings.
The attached recommendations are based directly on the language in state statute that defines purpose and goals. We believe the implementation actions identified here are required to accomplish the statutory purpose and to achieve the goals set in the statute.
As reflected in these recommendations, we firmly believe that before hundreds of millions of dollars are spent on planning the three corridors, there first should be a formal determination of need and financial feasibility pursuant to state (and federal where applicable) guidelines. Only if both need and feasibility are determined, should planning proceed for the applicable corridors.
We appreciate your consideration of these recommendations.”
Broadband, Economic Development and M-CORES
On June 2, 2020, 1000 Friends of Florida issued the following statement:
Many of the counties and communities in the M-CORES corridor face serious economic challenges that need to be addressed. Insufficient broadband services is but one example. Swaths of the rural lands in the proposed M-CORES corridor are not adequately serviced with broadband, leading to significant short- and long-term economic implications.
Now more than ever people are using broadband to conduct their professional and personal business remotely. A significant number of Floridians have been working from home, using video-conferencing applications to connect with co-workers, family and friends; attending school online; taking advantage of telemedicine; and using other online platforms.
In the short-term, some rural residents’ ability to maintain social distancing requirements while continuing to work or participate in online schooling has been severely compromised. In the long-term, the residents and businesses of rural areas of Florida — and not just those within the M-CORES corridor — will continue to fall behind in economic, education and other indices if broadband connectivity is not significantly enhanced in the near future.
Successful and sustainable 21st century rural economic development is not contingent on building roads to attract new rooftops or manufacturing plants. Instead the provision of broadband allows residents who want to choose a rural lifestyle to participate in the global economy. And in turn, this rural lifestyle allows greater protection of natural lands that store and cleanse drinking water for millions of Floridians, and agricultural lands that serve as a backbone of Florida’s economy.
It is not necessary to build roads to provide broadband. In fact, tying the provision of broadband to road construction is likely to delay its availability considerably as, notwithstanding the ambitious timeline outlined in the M-CORES legislation, it will take years for the roads to move from the planning to construction phase. This is particularly troublesome given the current pandemic and increased need to conduct more business and schooling online.
Instead, the State of Florida should explore opportunities to speed up the provision of broadband independent of road construction. This includes allowing broadband lines along existing highways and public utility lines to serve rural areas of Florida by creating “smart hubs” in rural communities. State-of-the-art broadband could be provided first to public buildings including city halls, libraries, schools and other facilities which then could serve as “trunks” to extend broadband to residences and business locations in the communities. This would speed up considerably the timeline on providing broadband along with its economic development benefits.
In the aftermath of COVID-19 it is likely that significantly more Floridians will choose to work from home, online education opportunities will expand, and telemedicine and other online services will proliferate. If communities in the M-CORES corridors (and indeed other rural parts of the state) are not allowed to participate in this new reality as soon as possible, the economic disparities will only worsen.
At least one thing is clear: Workers and others with broadband access do not need to be tethered to a specific location. This allows people in even the most remote communities to participate in the global economy. It’s time to uncouple the provision of broadband from road construction to choose a more sustainable and economically strengthened economy for rural communities in the 21st century. Uncoupling broadband from road construction is an opportunity to choose a more sustainable and prosperous future for all of Florida.
Improving and sustaining the economy of Florida’s rural areas requires broadband service immediately; it does not require new highways.
1000 Friends of Florida Identifies Concerns with the M-CORES Planning Process; Asks FDOT to Add Issue to Upcoming Task Force Meeting Agendas
On Tuesday, January 14, 2020, 1000 Friends of Florida sent a letter to the Florida Department of Transportation regarding concerns associated with the M-CORES planning process. These relate to numerous requirements in Senate Bill 7068 and sections 338.223 and 339.135, Florida Statutes, applicable to planning for and evaluating the M-CORES corridors.
“Provisions in state law clearly indicate that, among other things, the Task Forces are charged with identifying the need for, economic impacts of, and economic feasibility of their respective M-CORES corridors,” notes Tim Jackson, a transportation planner and long-time member of 1000 Friends’ Board of Directors. “It is imperative that these and other issues be added to the agenda for the next meeting of each of the three task forces to allow time to identify the data needed and timeline to make informed recommendations.” FDOT staff have agreed to meet in late January to discuss these concerns.
The letter also includes legal requirements and recommendations related to environmental impacts and feasibility, land use and hurricane evacuation impacts, appropriate federal, state and local review and consistency, and alternatives analysis, including a no build option. The letter concludes with the recommendation that each Task Force be allowed to submit at least one minority report in the event that consensus is not achieved among the task force members.
M-CORES legislation (SB 7068) passed during the 2019 Session, with the requirement that construction start on three tolled roads linking Collier County to the Florida Panhandle by December 31, 2022. Explains 1000 Friends Communications Director Vivian Young, “Given the level of federal, state and local review needed for transportation projects, this is an unrealistic timeline for a major undertaking of this scope.”
SB 7068 also required that a Task Force be established for each corridor, including representation by conservation groups. Task Force appointments include Board Member Andrew Dickman for the Southwest Florida Connector from Collier to Polk County, President Paul Owens for the Northern Turnpike Connector linking the northern terminus of the Florida Turnpike to the Suncoast Connector, and former Policy Director Thomas Hawkins for the Suncoast Connector from Citrus County to the Panhandle. FDOT began conducting these meetings in August of 2019.
“With the Task Forces due to submit their reports to the Governor and Legislature on October 1 of this year, time is of the essence to ensure that all legal requirements are met,” says Tim.