This is an independent review of the application materials and County information publicly available as of August 2, 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
Star IV Investments is a proposed agricultural enclave of approximately 176 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 August 1, three County review comments remained open: two Environmental Review comments and one Recreation Review comment.
Based on the application materials currently available, Star IV Investments appears to satisfy the basic acreage and county-population limits, and ownership appears reasonably supportable. However, the application has not established eligibility for certification under SB 686.
Several significant requirements remain unmet or incompletely documented:
Perimeter qualification: The applicant’s own exhibit shows only 46% of the property boundary adjoining Residential-B or Residential-C land, below the 50% required by §163.3164(4)(c)2. No alternative statutory route has been adequately demonstrated.
Proposed density: The applicant did not state a requested density. The County lists a statutory maximum of 6 units per acre, but the separate same-or-higher-density comparison cannot be completed without the density actually proposed.
Agricultural use and qualifying date: The timberland history makes agricultural use plausible, but the filing does not fully document continuous bona fide agricultural use or establish that all qualifying conditions existed as of January 1, 2025.
Public services and protections: Service availability, proportionate-share obligations, conservation easements, and other applicable constraints remain incompletely documented. Environmental and Recreation comments remain open.
Overall assessment: Star IV Investments does not presently qualify for certification on the submitted record. Unlike gaps that may be cured by supplying missing records, the applicant’s 46% perimeter calculation appears substantive unless qualifying segments were omitted or a different statutory route can be established. 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. Star IV Investments application 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 August 1, 2026
Public hearing: Scheduled for August 19, 2026.
Applicant’s requested density: Applicant did not state a requested density.
Statutory maximum density: 6 units per acre.
Outstanding County review comments: Two Environmental Review 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.
Updated project description: On July 22, the County description was revised to identify the request as ENCERT 2026-04 Agricultural Enclave Certification (Star IV Investments), covering approximately 176 acres west of State Road 16, south of Grand Oaks, and north of Windward Ranch.
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Beth Tate 
It will be interesting to see whether the County review includes details about each proposal that allow the public to see what the decisions will be based on.