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CHR’s Riverview 2 should now be rejected

10 min read

To the editor:

The over-arching premise and justification for approval of the four-story, 39-unit Riverview II — Fish House project has been to achieve the 3% Below Market Rate Housing (BMRH) target for Community Housing & Resources’ (CHR) housing established by the Sanibel Plan. However, as I explain below, the current CHR housing percent is 3% already, and when Riverview I is complete by year end, the percent will be 3.6%. Riverview II is unnecessary to achieve the goal of 3% established in the Sanibel Plan and should not be built for that reason, as well as for all the other reasons explained below.

This information is pivotal now because although Riverview II was approved by Sanibel City Council in March, it was done so with the requirement that residents of the building be Sanibel workers (or in limited cases, a Captiva worker or a retiree). Now even that is being challenged by Lee County to allow residents of the building to work anywhere, thereby taking advantage of the opportunity to live on Sanibel, and work on the mainland. This insistence by Lee County is antithetical to the understanding of the purpose of CHR housing as: supporting Sanibel businesses to attract and retain workers; improving the life-style of Sanibel workers; and reducing causeway traffic. As a result, city council is reconsidering its approval of Riverview II.

Compounding the concern about this project is that to many islanders, the project is not appropriate for Sanibel for a host of reasons. It certainly violates the Sanibel Plan, and shocks the sensibility with an unprecedented massive building when entering the island, thereby creating discord given the small-town feel and culture of the island.

In light of Lee County’s insistence that Sanibel abandon city council’s well-grounded requirement, and the realization that CHR will have exceeded the Sanibel Plan target of 3%, and the ongoing unease in the community, city council should certainly now disapprove Riverview II.

– 3% target pre-Hurricane Ian

I’ve attended all three relevant city council meetings. I’ve asked repeatedly how this 3% number is calculated. Allegedly nobody knew. People just kept referring to it, so I decided to figure it out. I turned to the Sanibel Plan.

I found that to determine the 3%, the Plan counts only residences that are occupied by full-time residents, not residences occupied by tourists or our nonresident seasonal population. The Plan states that in 2004, full-time resident households constituted 40% of the island’s total residences. At that time, the Plan states there were a total of 8,285 residences, so 3,314 were full-time. With 88 CHR units at the time, this results in CHR units of 2.6% (8,285 x 40% = 3,314; 88 / 3,314 = 2.6%).

The Plan language defines this in Section 3.6.1, page 194: “(T)here are approximately 8,285 units on Sanibel. Nearly 60 percent are occupied by tourists and nonresident seasonal population.” Page 199: “Currently, [i.e., in 2004], there are 88 BMRH units, representing about 2.6 percent of Sanibel resident households. The 2004/2005 Evaluation and Appraisal Report suggests a program target for BMRH units of 3 percent of Sanibel’s residential households.”

– 3% target post-Ian

Post Hurricane Ian, we no longer have 8,285 residences as specified in the Plan. At the July 21, city council meeting, consultant Stantec presented on wastewater runoff and stated that the total number of houses and co-ops is 6,302. This is a reduction of about 2,000 dwellings. Assuming the Plan’s 40% full-time residence figure, then 2,502 full-time residences exist now 6,302 x 40% = 2,502).

Post Hurricane Ian, we no longer have 88 CHR units, but rather 76. This resulted in the CHR housing units equalling 3% of residential units on Sanibel, the target goal 76 / 2,502 = 3%).

Riverview I will be complete by year-end, so its 15 units cause the CHR housing on Sanibel to increase to 3.6%, exceeding the 3% target (76 + 15 / 2,502 = 3.6%). Note that Riverview I therefore was commenced even after we had already achieved our 3% goal for CHR housing.

If Riverview II is built with an additional 39 units, CHR housing will be equal to 5.1% of full-time residences, almost double the stated goal of the Plan (76 + 15 + 39 /2,502 = 5.1%).

CHR representatives have repeatedly claimed that the 39 units of the Riverview II would for the first time allow Sanibel to achieve the 3% BMRH goal. That argument has been a strong support motivator for civic minded Sanibel residents, even though many of these same people have reservations about the project. However, as stated above, CHR never explained the basis for that 3% claim, and the claim is not correct.

– Project should be disapproved

1) Sanibel CHR housing will be at 3.6 % when Riverview I opens, thereby exceeding the Plan target of 3%.

2) Testimony at the July 21, city council meeting proved that CHR does not have a wait list for Riverview II. That testimony proved that the current CHR wait list will be cleared when Riverview I opens this fall, since a new applicant was told that a unit would be available when Riverview I opens. During public comment, testimony revealed that 58 businesses did not return after Ian representing at least 1,000 employees. This unfortunate fact certainly reduced the long term demand for CHR housing.

3) The present likelihood of Riverview II falling under HUD regulations would require that the residences be rented to mainland workers and unemployed social welfare cases, as opposed to only Sanibel workers. This is antithetical to the purpose as understood by Sanibel residents. CHR has enjoyed support because it has always been integral to their mission to house Sanibel workers thereby helping Sanibel businesses recruit and retain workers, improving the lifestyles of Sanibel workers, and reducing causeway traffic. Without those factors, support for CHR evaporates. City Councilmember Laura DeBruce summed it up at a city council meeting by asking: Why would we go through this if it was not for Sanibel workers?

4) Riverview II violates the Sanibel Plan, despite the testimony of the Planning Department, because it does not conform to the CHR housing density or appearance requirements. In fact, the March 31, city council resolution approving the project states that the Planning Commission said that it is consistent with the Plan, but city council itself explicitly refused to state that the project was consistent with the Plan.

5) At the Planning Commission meeting on Feb. 24, at which the commission approved the project and sent it to the city council, only five of the seven commissioners voted in favor. One voted against as not consistent with the Sanibel Plan, and the vice chair of the commission recused herself because she is also president of the board of CHR. At that meeting, congratulatory comments were made that this project would allow reaching and exceeding the Sanibel Plan’s 3% target for CHR housing, without explaining how that target is calculated. As explained above, the statement is not correct. The figure is already 3.6% without the project, and 5.1% if the project is built. In addition, oddly at that meeting, the minutes show that the commissioners expressed at least six times that they wanted more information, and CHR and the planning staff acknowledged they just were not prepared to answer their questions. They just repeated that the deadline requires speed and haste resulting in understandable lack of preparedness. Still, the commission, without having its questions answered, approved the project and sent it on the city council. These Feb. 24 minutes can be viewed at mysanibel.com.

6) The project undermines Sanibel’s small town culture and appearance thereby burdening residents and businesses by its density. All municipality zoning codes include regulations limiting density because it is undesirable. Density negatively impacts the quality of life of the island by bringing unnecessary noise, traffic, construction misery, damaged views, light pollution in the night sky, strain on public systems and casting shadows on adjacent properties. Variances have been required.

7) No financial information has been provided about the ongoing expense through taxes to city residents. City taxpayers already pay CHR $440,000 per year through the city, as shown on the city’s financial reports. Will taxes increase for ongoing expenses for this project if it is built?

8) What capital expenses might the city and taxpayers be liable for in this project. What if there are cost overruns — who is responsible? What if the project is cancelled now? Why did CHR buy the property before the building was even approved by the city? This fact inevitably placed undue pressure on the city to approve the project, and to continue to support it now, while opposition to it grows in the community.

9) City council and CHR are creating a dense, identifiable, lower income housing district, so unthinkable under the Sanibel Plan. Fifteen units in Riverview I, 39 units in Riverview II and 14 units across Periwinkle on Center Street. Sixty-eight units in undue concentration. The Sanibel Plan opposes this as follows at Page 201: “Policy 3.5 — Distribute BMRH units on Sanibel to provide a variety of residential settings and avoid undue concentration for very low, low and moderate income housing.”

10) Riverview II violates the Sanibel Plan because the units do not conform to the aesthetic standards of the community. Instead, it is a massive building far outside the resort area. The Plan stipulates as follows at page 196: “Sanibel’s BMRH program deliberately breaks with many of the patterns established by public housing programs elsewhere. To underscore the fundamental equality of all citizens, BMRH units are constructed and landscaped to be virtually indistinguishable from the rest of the community. That eliminates the stigma that is usually attached to being in public housing, ensure that such housing conforms to the aesthetic standards of the community, and thereby fosters a well-earned sense of civic pride. It is the city’s goal to maintain that emphasis, as expressed in the Goal Statement for Housing and Policy 3.1 in this section.”

The leadership of the island should cancel this project immediately for all the reasons stated above. Since there appears to be no demand from Sanibel workers, the units would be offered to mainland workers, which does not help Sanibel. The neighborhood of Riverview II just endured the torture of construction of Riverview I, a major building in itself, including months of pile driving, and are you really going to subject them to another round? It’s been stated that this is an acceptable location for Riverview II because it is the commercial district. However, that district is one commercial building wide on either side of Periwinkle Way, so more appropriately thought of as a commercial strip. Behind that strip is houses. To people from the fancier residential areas, I expect this is just the route to the causeway, but to many it is our neighborhood. So the prior comment seemed insensitive, and I thought that society had gotten away from concentrating infrastructure and other municipal support features in certain neighborhoods. Sure, municipal zoning calls for placing facilities in various zones for good reasons, but the significant number of zoning variances granted to the two Riverviews, even required in the commercial district, changes the neighborhood in shocking ways, and I don’t think that should be tolerated. This would not be tolerated by residents in other Sanibel neighborhoods.

There has been some discussion that building a smaller version of this project, i.e. two floors of apartments over parking (a three-story building), might be an acceptable compromise. That is not true. All the above objections apply to a slightly smaller building. That compromise mitigates none of these problems. It would undermine the Sanibel Plan and the culture of the island in density, numbers and size and purpose. That’s it! To compromise is to satisfy some weaker impulse that should be resisted.

For all these reasons, city council should disapprove this project. You can listen to city council meetings live, but you cannot participate unless you are there, so sending an email to city council is important if you want your thoughts to be considered. Use the address sancouncil@mysanibel.com and the City Clerk will distribute your message to the city council members. By my count, there have been 65 public comments or emails in opposition to this project, many people saying that they have supported CHR, but they oppose this project. Feel free to contact a city council member directly. They want to hear from us. I’ve done my best to present correct information. I’m happy to discuss this further.

Carolyn Marino

Sanibel