This is an independent review of the application materials and County information publicly available as of July 28, 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
Osceola Lakes is a proposed agricultural enclave of approximately 143.29 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 28, six County review comments remained open: one Environmental Planning comment, four Planning and Zoning comments, and one Recreation comment.
Based on the application materials currently available, Osceola Lakes appears to satisfy several core requirements of SB 686. The property is below the statutory acreage limits, St. Johns County is below the applicable population limit, the record presents substantial evidence of agricultural use, and the applicant’s perimeter analysis reports that 79.9% of the property adjoins land designated Residential-B or Residential-C.
However, several potentially significant requirements remain unclear or incompletely documented:
- Proposed density: The application materials do not appear to state the density of the proposed development. Because §163.3162(4)(a) requires at least one adjacent parcel or development to permit the same or a higher density than the proposed development, the statutory comparison cannot yet be completed.
- Perimeter qualification: The applicant’s figures support the first perimeter threshold, but the record should more clearly demonstrate how the separate existing-development or urban-service-area component of the statutory definition is satisfied.
- Agricultural use: Three parcels have longstanding agricultural classifications. One parcel reportedly received agricultural classification beginning in 2023, so the applicant relies on aerials, forestry activity, harvesting history, and a management plan to establish earlier continuous bona fide agricultural use.
- Public services and infrastructure: The applicant states that County water and wastewater are available and offers to enter a binding proportionate-share agreement. The referenced May 16, 2026 utility-availability letter was not found in the materials reviewed, and no executed infrastructure agreement is included.
Overall assessment: Osceola Lakes appears to present a credible agricultural-enclave case and a plausible path to certification. The missing proposed density is nevertheless a material threshold gap, not merely an application detail. The application remains under County review, and the applicant may provide additional documentation or clarification before the August 19 hearing.er 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 28, 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 Planning comment, four Planning and Zoning comments, and one Recreation 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 