TO: Local Planning Agency
FROM: Bill Spikowski
DATE: November 8, 1996
SUBJECT: Motel Densities
The second critical land-use issue that we agreed to consider this fall is the proper range of densities for new motels at Fort Myers Beach. Your current regulations allow a minimum of three hotel/motel units in place of each regular dwelling unit. This ratio is substantially lower than the county's rules in effect until 1994, but it still has not been examined for appropriateness at Fort Myers Beach, given its overcrowded conditions yet high dependency on tourism.
This memorandum provides some history as to how this issue has been treated by Lee County in the past. It then presents data and observations on tourism trends, and closes with general suggestions as to how the town of Fort Myers Beach might proceed in preparing its comprehensive plan policies on motels.
CURRENT REGULATIONS FOR MOTELS
At Fort Myers Beach, there is only a slight distinction between motels and some other types of accommodations for tourists. Land development regulations must make a clear distinction, however, if they provide a density multiplier or bonus for motels. Your current regulations define a hotel/motel as:
In order to qualify for density multipliers, motels also must be registered with the state and must pay Lee County's tourist development tax. Hotels and motels are further divided into "efficiency motels" (primarily for tourists) and "business motels" (all others).
Limited kitchen facilities are allowed in efficiency motels, but they may not be as extensive as a separate room. A building that looks like a motel but does not meet all of these tests is treated by your current regulations as multifamily housing, and is therefore subject to much stricter density regulations. (Attached is a full copy of your current hotel/motel regulations.)
In addition to zoning, motel operators must comply with two other specific regulations. The first is registration with Florida's Department of Business and Professional Regulation. The state requires certain safety and sanitary standards but has no authority over location or density. The state has separate classifications for hotels (> 25 rooms), motels (> 6 rooms with separate bathroom/exit for each), resort condominiums, transient or nontransient apartments, roominghouses, and resort dwellings.
The second additional regulation is compliance with Lee County's tourist development tax. This tax is paid by those who rent accommodations for less than six months each year; the current rate is 3% of the rent. Proceeds are used to operate the Lee County's Visitor and Convention Bureau (53.6%), for beach-related improvements (33%), and to repay bonds for the Lee County Sports Complex (13.4%).
A new motel (or hotel) that qualifies under the current zoning regulations can have substantially more rental units than would be allowed for multifamily housing. Under the current rules, a minimum of three "business" hotel/motel units are guaranteed for each one regular dwelling that would otherwise be allowed (in zoning districts where motels are permitted); this ratio is two for one for "efficiency" motels. With a maximum number of new dwelling allowed under the comprehensive plan of 6 units per acre, 18 hotel or motel units can be built. In addition, a landowner can request higher densities yet during a planned development rezoning (with no maximum cap), provided that the town council finds that the higher density would be "compatible with the surrounding area."
These density multipliers are the same as Lee County has been using since 1994, when it repealed the previous rule that categorized hotels and motels into three types: transient (25 units per acre); efficiency (2.5 units for each multifamily dwelling unit); and convention (50 units per acre).
It was the "convention" category that allowed Diamondhead to have 154 rooms on 3.1 acres. A similar project is the proposed Gullwing Hotel near Pointe Estero, which had been the subject of a 1983 court order that required Lee County to allow an additional 20 units to the 37 multifamily units that were already under construction. The proposed project, on a 2.68-acre site, was changed to a hotel in the early 1990s, with a current development order allowing 135 hotel units plus extensive meeting rooms and a large restaurant.
On October 16, Lee County adopted further changes to its hotel/motel regulations. (A copy of these changes is attached; note that they will not apply at Fort Myers Beach unless the town council makes its own changes to the land development regulations.) Lee County's newest changes have eliminated the dubious distinction between efficiency and business motels and replaced them with density ratios based on the actual floor area of each rental unit, regardless of unit type. For each allowable dwelling unit, the following number of new hotels and motels will be allowed:
Three rental units under 350 square feet; or Two rental units under 650 square feet; or One rental unit over 650 square feet.
However, if approved through a planned development rezoning, even higher ratios may be approved, "provided all other aspects of the development (height, traffic, intensity of use, etc.) are found to be compatible with the surrounding area."
TOURISM TRENDS AT FORT MYERS BEACH
It is difficult to determine in the abstract whether Lee County's motel density restrictions are too high, too low, or just about right. The following sections provide background information to aid the Local Planning Agency in its deliberations on this matter.
The following chart summarizes official data on the density of a selection of existing motels at Fort Myers Beach:
NAME # of rental units # of total acres rental units per acre Lani Kai Island Resort, 1400 Estero 100 0.98 102 Ramada Inn, 1160 Estero 70 0.87 80 Lighthouse Island Resort, 1051 5th St. 40 0.72 56 Azure Tides, 5350 Estero 8 0.15 53 Sun Tan Village, 5607 Estero 13 0.29 45 Outrigger Beach Resort, 6200 Estero 144 3.92 37 Days Inn, 1130 Estero 33 0.98 34 Buccaneer Resort Inn, 4864 Estero 25 0.98 26 Holiday Inn, 6890 Estero 103 3.91 26 Neptune Inn, 2310 Estero 65 2.86 23 Sandbar Resort, 5480 Estero 12 0.61 20 Carousel Motel, 6230 Estero 26 1.52 17 Wild Waves Resort, 3870 Estero 6 0.46 13
There are about 1150 motel rooms in the town of Fort Myers Beach using a total of 45 acres of land, yielding an average density of 25.5 rental units per acre. This is only slightly higher than the average density of the 4770 multifamily units in the town, which use a total of 212 acres for an average density of 22.5 dwelling units per acre.
Since adoption of the 1984 Lee Plan, the density of new multifamily buildings has been limited to 6 dwelling units per acre. This is quite a low figure compared to the average existing multifamily density of 22.5 per acre. Much of the multifamily development that has taken place since 1984 has taken advantage of pre-1984 approvals or court orders (for example, at Bay Beach). Because of the substantial density multipliers that Lee County has allowed for motels and the continued demand for short-term rental units, landowners have had an obvious incentive to build motels instead of condominiums, except where previous approvals had allowed higher densities.
Our task at this point is to decide whether this incentive should remain the same. Given the difficulties in increasing densities on a barrier island with severe evacuation constraints, removing or reducing this incentive would probably mean lower motel densities rather than higher multifamily densities.
One unanswered question is the economics of renting motel rooms versus renting full dwelling units (with kitchens and bedrooms). Conflicting testimony has been presented on this question over the past several months. Some have asserted that the rental market for condominiums (or suite-type motel units) is poor relative to the supply; and others have stated that full-sized condominiums remain the best and most profitable rental market at Fort Myers Beach. This question is an important one upon which LPA members may be able to shed additional light.
The following pages illustrate recent tourism data that has been collected for the Visitor and Convention Bureau by Research Data Services, Inc. in its 1995 Annual Visitor Profile. Figure 1 shows the occupancy rate by month for the past five years. The "flattening" of the February-March peak season is evident, along with the strengthening of tourism during November, January, April, and May. Figure 2 shows average daily rental rates for the same period, which predictably follows the demand as reflected in occupancy rates. Figure 3 compares the 1995 average daily rates with other parts of Lee County. Rates at Fort Myers Beach remain well below those on Sanibel and Captiva, but well above those in Fort Myers, Cape Coral, and Bonita Springs.
WHAT SHOULD BE DONE?
Local governments regulate motel densities in many different ways. Several Florida coastal communities were surveyed, with the following relevant results.
The city of Sarasota allows unlimited hotel and motel units anywhere in their downtown; multifamily units are also allowed there at 50 dwelling units per acre. Sarasota also allows motels by special exception in several of their higher-intensity multifamily districts (those allowing up to 18 through 35 dwelling units per acre). Two hotel or motel units are allowed for each dwelling unit.
The city of Deerfield Beach allows hotels and motels by special exception in its highest-intensity multifamily district, which allows up to 25 dwelling units per acre. If approved, motels may have up to 38 units per acre.
The city of Sanibel has what might be called a reverse multiplier for all resort housing (which includes motels and any other units that can be rented for less than 4 consecutive weeks). In its highest density category, 5 regular dwelling units are allowed per acre, with an assumed capacity of 2.2 persons per unit. Where resort housing is allowed, its density is calculated to maintain the same presumed number of persons. This is an attempt to gauge the relative impact of varying housing types by projecting the number of residents, rather than by measuring the physical size or other measure of impact. The following table shows Sanibel's presumed average rates, and the resulting density multiplier.
Type of Resort
Motel rooms and
1-bedroom units up to 600 sq. ft.
0.88 2-bedroom units 3.5 persons
0.63 3-bedroom units 4.25 persons
0.52 4-bedroom units 5.0 persons
As a consequence of Sanibel's low multifamily density cap and its "reverse" multiplier, only one new motel has been built in the 20+ years since incorporation, and it was not a financial success. A similar approach would cause the same result at Fort Myers Beach.
In summary, density multipliers for motels are not universally used. Where high densities are allowed for multifamily units, multipliers aren't necessary. Where density caps are relatively low (such as Sanibel and Fort Myers Beach), some positive density multiplier will be needed if new and refurbished motels are to play an important role in the community. However, it is clear from recent history that density multipliers that are too high will result in buildings that will overwhelm the small-town character of much of Fort Myers Beach.
Two other issues are relevant here before closing. The first is to clearly note that the 6-unit-per-acre density cap that has been in force since 1984 is consistent with the single-family and even many of the duplex units at Fort Myers Beach, but is extremely out of scale with the existing multifamily areas (whose average existing density is 22.5 units per acre). Since that cap would be very difficult to increase, it may be inevitable that substantial density multipliers for motels should remain, despite their side effect of discouraging conventional multifamily development.
The other point is the commonplace observation that what is appropriate at one location may not be so at another. The existing single density cap across the entire island could lead to a situation where attempts to protect quiet residential neighborhoods could stifle the tourism economy in the main business district. This situation may be best addressed through a variety of comprehensive plan categories (with differing density caps or motel multipliers). Or it could be addressed through your land development regulations, for instance by having lower density multipliers for motels in multifamily zones than for those in commercial zones. (Note that new motels are not allowed in the RM-2 multifamily district, although existing motels there may be completely rebuilt at up to the maximum allowable density.) And since excessive building heights and high density are closely related, the solution selected for the height problem may work to resolve the density question as well.
We have scheduled a discussion of this issue at your meeting of November 19th at 12:00 noon at Town Hall.