This is an independent review of the application materials and County information publicly available as of July 24, 2026. It is not a County staff report or a legal determination. Where this assessment says a requirement has not been demonstrated, that means I did not find sufficient support in the publicly available materials reviewed; it does not necessarily mean the evidence does not exist or cannot be provided as the County’s review continues. I welcome corrections supported by publicly available documentation.
Executive Summary
Adler Creek is a proposed agricultural enclave of approximately 594 to 610 acres in St. Johns County. The application remains under active County review and is scheduled for a public hearing on August 19, 2026. As of July 24, six County review comments remained open: one Environmental Review comment, four Planning and Zoning comments, and one Recreation Review comment.
Based on the application materials currently available, Adler Creek appears to satisfy several basic requirements of SB 686. The property is below the statutory acreage limit, St. Johns County is below the applicable population limit, and the submitted perimeter analysis appears to show that more than 50% of the property adjoins land designated for residential development.
However, several potentially significant requirements are not yet adequately documented:
- Ownership or control: The records identify multiple property owners, while the application does not include documentation establishing that a single person or entity controlled all parcels as of January 1, 2025.
- Agricultural use: The application asserts that the property has been continuously used as timberland, but the submitted materials do not include the referenced Forest Management Plan or other records demonstrating five years of continuous bona fide agricultural use.
- Perimeter qualification: The application appears to satisfy the first 50% perimeter test, but it does not provide the mapping and calculations needed to substantiate the separate urban-service-area test applicable to the surrounding parcels.
- Proposed density: The County has identified a statutory maximum density of six units per acre based on the adjacent RES-C designation. The applicant’s requested density and proposed development program, however, do not appear to be stated in the application materials.
- Public services and infrastructure: The application references utility availability and a willingness to enter into a proportionate-share agreement, but several supporting documents and specific infrastructure commitments are not included in the presently available record.
Overall assessment: Adler Creek appears to have a plausible path to certification, but the currently available record does not yet sufficiently substantiate all mandatory requirements. This does not mean the property is ineligible. The application remains under County review, and the applicant may provide additional documentation or clarification before the August 19 hearing.
About this review: I am not an attorney, and this is not a legal opinion. I am a former Chief Audit Executive with decades of experience evaluating evidence against federal, state, local and international requirements. This assessment applies that evidentiary lens to the publicly available application materials; it is not a recommendation that the County approve or deny the application.
Disclaimer: I am not an attorney, and this is not legal advice. This assessment is my independent review of the application materials and County information publicly available as of July 24, 2026. Adler Creek remains under active County review, and additional information may be submitted before the scheduled public hearing.
This executive summary is based on a more detailed review of the publicly available application materials against the requirements of SB 686. Because the County’s review remains underway and the public record may continue to change, I am not publishing the full working analysis at this stage. I will update this assessment as additional County findings and application materials become available. The supporting analysis is available upon request for those seeking to understand the methodology or documentation supporting a particular observation.
County review status as of July 24, 2026
Public hearing: Scheduled for August 19, 2026.
Applicant’s requested density: Does not appear to be stated in the application materials.
Statutory maximum density: 6 units per acre, based on the base density allowance of the adjacent RES-C FLUM designation (Comprehensive Plan Policy A.1.13.1.m(1)).
Outstanding County review comments: One Environmental Review comment, four Planning & Zoning comments, and one Recreation Review comment remain open. Without the text and disposition of those comments, their precise effect on certification cannot yet be assessed.
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Beth Tate 
Which organization is the hearing scheduled for? It’s a Wednesday.
d
The Board of County Commissioners scheduled a special meeting on Wednesday, August 19 to hear the 6 Ag Enclave certifications.