Executive Summary
Heritage East is a proposed agricultural enclave of approximately 615.41 acres near State Road 207 and Interstate 95 in St. Johns County. County staff has completed its certification review, determined that the application passes the statutory certification test, and forwarded the matter for review by the Board of County Commissioners at the August 19, 2026 public hearing.
Based on the application materials currently available, Heritage East appears to satisfy the threshold requirements for certification, including acreage, county population, common ownership, agricultural-use history, and the qualifying Future Land Use Map perimeter test. Staff’s conclusion that the application passes the certification test has also been confirmed in press reporting.
Several matters should nevertheless be clarified or documented in the certification record:
- Public services: The application asserts that water, wastewater, transportation, schools, and recreation facilities are available or scheduled, but provides little supporting capacity documentation. Its statement that the applicant will negotiate “to the extent necessary” is less definite than an express offer to enter the binding proportionate-share agreement described in the statute.
- Urban-service perimeter: The applicant calculates that 78% of the perimeter meets the urban-service requirement by using the County Development Area Boundary. The County should expressly confirm that this boundary qualifies as an urban service district, area, or line and independently verify the calculation.
- Density and proposed uses: The requested density of 13 units per acre appears supportable if the identified adjacent Mixed Use property legally permits the same density. The application also references commercial and industrial uses, but the authority for those uses appears tied to a different statutory pathway than the under-700-acre route claimed for certification.
- Conservation easements and environmental review: Recorded conservation-easement areas should be mapped and reconciled with the certification boundary and perimeter calculations. The County site previously showed two Environmental Review comments and one Recreation Review comment; staff’s completed review indicates those comments did not prevent a favorable certification determination.
Overall assessment: Heritage East passes the staff-level certification review and is ready for consideration by the commissioners. The remaining points identified in this assessment are matters to understand in the final record or in later development review, not a basis for predicting that certification will fail.
This is an independent review of the application materials and County information publicly available as of August 13, 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.
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 August 10, 2026. The Heritage East 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.
Detailed SB 686 Checklist Assessment
This assessment is based on the application materials reviewed and the County status reported as of August 12, 2026. It distinguishes between requirements that appear satisfied and matters that may still warrant clarification in the public record or later development review.
County review status as of August 12, 2026
Public hearing: Scheduled for August 19, 2026.
Applicant’s requested density: 13 units per acre.
Statutory maximum density: 13 units per acre.
County review comments: The County site previously showed two Environmental Review comments and one Recreation Review comment. Staff has nevertheless completed the certification review and concluded that the application passes the statutory test.
Application status: County staff has completed its review, determined that Heritage East passes the certification test, and placed it before the commissioners for the August 19 hearing. The August 12 site entry stating “Do not send comments out” appears to be an internal workflow instruction; without further explanation, it should not be treated as a substantive certification finding.
Project description: Certification of Two Parcels as an Agricultural Enclave Per Sections 163.3162(4) and 163.3164(4), Florida Statutes. This certification request is identified as ENCERT 2026-05 Agricultural Enclave Certification (Heritage Development East) and includes approximately 615 acres. The subject property is located East of Interstate 95 and south of State Road 207.
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Beth Tate 