HomeMy WebLinkAboutBPMC 011922 Backup1
FULLER-ARMFIELD-WAGNER
AN APPRAISAL OF
MITIGATION CREDITS
WITHIN THE
BEAR POINT MITIGATION BANK
SOUTH HUTCHINSON ISLAND
ST. LUCIE COUNTY, FLORIDA
PREPARED FOR
St. Lucie County Board of County Commissioners
c/o JoAnn Riley, Property Acquisition Manager
2300 Virginia Ave.
Fort Pierce, FL 34982
DATE OF APPRAISAL – December 31, 2021 (Prospective value)
Prepared by:
Daniel D. Fuller, MAI State-Certified General Real Estate Appraiser RZ567
FULLER-ARMFIELD-WAGNER
Appraisal & Research, Inc.
426 Avenue A
Fort Pierce, Florida 34950
Appraisal No. 20249
FULLER-ARMFIELD-WAGNER Appraisal & Research, Inc.
426 Avenue A, Fort Pierce, Florida 34950
(772) 468-0787 / dan_faw@bellsouth.net
Daniel D. Fuller, MAI, SRA, State-Certified General Real Estate Appraiser RZ567
December 16, 2021
St. Lucie County Board of County Commissioners
c/o JoAnn Riley, Property Acquisition Manager
2300 Virginia Ave.
Fort Pierce, FL 34982
Re: Bear Point Mitigation Bank, St. Lucie County, Florida - Valuation of mitigation
credits as follows: Value of State credit, Value of Federal credit, Value of
combined State and Federal credit, plus the value of fractional sales.
Dear Ms. Riley:
Per our contract for appraisal services, on December 13, 2021, I inspected the referenced
real estate, and I have made an analysis of the market influences affecting the property for
the purpose of providing an opinion of the market value of referenced Bear Point
Mitigation Bank mitigation credits, as of December 31, 2021. Because the date of
appraisal occurs in the future, December 31, 20 21, the appraisal is considered
Prospective.
The appraisal adheres to the Uniform Standards of Professional Appraisal Practice
(USPAP), and St. Lucie County Appraisal Standards, presented in a USPAP stated
“Appraisal Report” format.
• Client: St. Lucie County Board of county Commissioners.
• The appraisal and report are subject to the Ordinary Limiting Conditions, Extraordinary
Assumptions, and Certification included within this report.
• The Intended User of this appraisal report is the St. Lucie County Board of County
Commissioners and/or their representatives, and the appraisal report does not have
another intended user.
• The Intended Use of this appraisal is to develop pricing for sales of mitigation credits,
and the appraisal was not developed for another use.
• Note: The effects on property values of the global outbreak or “novel coronavirus”
known as COVID-19 is unmeasurable as of the date of appraisal, thus the reader is
cautioned and reminded that the conclusions presented in this appraisal report apply
only as of the effective date indicated and the appraiser makes no representation as
to the effect on the subject property of any unforeseen event related to the pandemic,
subsequent to the effective date of the appraisal.
FULLER-ARMFIELD-WAGNER
Ms. Riley
December 16, 2021
Page 2 of 2
Therefore, it is my opinion as of December 31, 2021, the Bear Point Mitigation Credits
should reflect the following price levels:
• Value of one State credit - $180,000
• Value of one Federal credit - $180,000
• Value of combined (dual) State & Federal credit - $180,000
• Value of 1/10th credit (State or Federal) - $18,000
• Value of 1/10th Dual credit - $36,000
Plus, as discussed, it is my opinion sales of fractional interest below 1/10 th should be
considered to keep offerings competitive, plus, if possible, increase marketing activity to
engineers, Realtors, etc. to attract transactions to offset operating costs (see fractional
interest sales comments beginning on page 63).
I believe you will find my appraisal and report complete, but if there are questions, please
contact me at your convenience.
Sincerely,
Daniel D. Fuller, MAI
State-Certified General Real Estate Appraiser RZ567
DDF/asf #20249
FULLER-ARMFIELD-WAGNER
i
TABLE OF CONTENTS
SUMMARY OF IMPORTANT FACTS ............................................................................................ 1
PROPERTY TYPE AND USE “AS IS” ............................................................................................ 2
SCOPE OF WORK .......................................................................................................................... 2
COMPETENCY ............................................................................................................................... 3
DEFINITIONS .................................................................................................................................. 4
ORDINARY LIMITING CONDITIONS AND UNDERLYING ASSUMPTIONS ............................... 5
EXTRAORDINARY ASSUMPTIONS .............................................................................................. 6
CERTIFICATE OF APPRAISAL...................................................................................................... 7
OWNER OF RECORD AND SALES HISTORY ............................................................................. 8
LEGAL DESCRIPTION ................................................................................................................... 8
EASEMENTS ................................................................................................................................... 8
LOCATION MAP ............................................................................................................................. 9
PROPERTY PHOTOGRAPHS ..................................................................................................... 10
AREA DATA .................................................................................................................................. 13
NEIGHBORHOOD DATA ............................................................................................................. 13
PROPERTY DESCRIPTION ......................................................................................................... 14
Summary of Income ......................................................................................................... 16
HIGHEST AND BEST USE ........................................................................................................... 17
EXPOSURE ................................................................................................................................... 17
SITE / AERIAL MAP ...................................................................................................................... 17
BEAR POINT MITIGATION SERVICE AREA MAP ..................................................................... 18
VALUATION .................................................................................................................................. 19
SALES COMPARISON APPROACH ........................................................................................... 19
Property Appraised .......................................................................................................... 19
Mitigation Banks Analyzed ............................................................................................... 19
Summation and Value Conclusion .................................................................................. 25
QUALIFICATIONS OF THE APPRAISER .................................................................................... 28
FULLER-ARMFIELD-WAGNER
1
Summary of Important Facts
• Property Type: 317+ acres, mostly mangrove saltwater marsh.
• Property Use “as is”: Mitigation Bank and mosquito control impoundment.
• Location: West side of S.R. A-1-A and east bank of the Indian River,
west of the south Ft. Pierce City Limits, and approximately
1.5 miles south of the Fort Pierce Inlet to the Atlantic
Ocean.
• Purpose of Appraisal: Establish Market Value
• Property Rights Appraised: Mitigation Credits
• Date of Appraisal: December 31, 2021 (Prospective appraisal)
• Date of Inspection: December 13, 2021
• Inspected by: Daniel D. Fuller, MAI
• Date of Appraisal Report: December 16, 2021
• Report Prepared: December 2021
• Report Format: USPAP defined “Appraisal Report” format.
Property Data
• Total Land: 317+ acres – total area of mitigation bank
• Improvements: Various site improvements including pumps, culverts,
weirs, etc. constructed to support the mitigation bank and
mosquito control impoundment.
• Mitigation Credits - Initial credits –
49.8 State - Department of Environmental Protection
(DEP) credits
43.3 Federal – Army Corp of Engineers (ACOE) credits
Remaining Bear Point credits for sale as of 12/13/2021
8.1 State - Department of Environmental Protection (DEP)
credits
7.0 Federal – Army Corp of Engineers (ACOE) credits
CGW Mitigation Bank, Bear Point Credits for sale, as of
December 13, 2021 –
2.32 State - (DEP) credits
0.976 Federal – (ACOE) credits
• Highest and Best Use: Continue Mitigation Bank & mosquito impoundment use.
Market Value, Mitigation Credits, as of December 31, 2021 (prospective value):
• Value of one State credit - $180,000
• Value of one Federal credit - $180,000
• Value of combined (dual) State and Federal credit - $180,000
• Value of 1/10th credit (State or Federal - $18,000
• Value of 1/10th Dual credit - $36,000
Plus, as discussed, it is my opinion sales of fractional interest below 1/10th should be
considered to keep offerings competitive, plus, if possible, increase marketing activity to
engineers, Realtors, etc. to attract transactions to offset operating costs (see fractional interest
sales comments beginning on page 63).
FULLER-ARMFIELD-WAGNER
2
Property Type and Use “as is”
• Property Type: 317+ acres, mostly mangrove saltwater marsh.
• Property Use “as is”: Mitigation Bank and mosquito impoundment.
Scope of Work
Ms. JoAnn Riley representing the St. Lucie County Board of County Commissioners engaged
my services to provide an opinion of the market value of Bear Point Mitigation Bank mitigation
credits as follows: Value of State Credit, Value of Federal Credit, Value of Combined credits, and
Value of partial credits, as of December 31, 2021 (Prospective Opinion of Value).
To provide an opinion of value, the following Scope of Work was required with the following
summary of the history of the mitigation bank required to form the Scope of Work.
• The Bear Point Mitigation Bank covers some 317 acres, fronting the east bank of the Indian
River. The mitigation bank’s topography is mostly mangrove saltwater marsh, plus encircling
the waterfront there is an impoundment dike with drainage culverts, pumps, weirs, etc. added
to the site for the dual purpose of mosquito control and enhancement of the saltwater marsh
and mangrove population.
• The Bear Point Mitigation Bank is administered and maintained by the St. Lucie County
Mosquito Control Department.
• Unless approved by DEP, Bear Point mitigation credits can be sold only for projects within
DEP identified mitigation service area and credits can only mitigate mangrove disturbed area.
• The Bear Point Mitigation Bank service area covers Hutchinson Island and the mainland
Indian River waterfront from the Sebastian Inlet on the north to St. Lucie Inlet on the south.
• Beginning in 2003 the mitigation bank was credited with dual designation of:
49.8 State - Florida Department of Environmental Protection (DEP) mitigation credits
43.3 Federal – Army corps of Engineers (ACOE) mitigation credits
• Remaining Bear Point Credits for sale as of December 13, 2021:
8.1 State DEP mitigation credits
7.0 Federal ACOE mitigation credits
• Chown ownership of Bear Point credits for sale, as of December 13, 2021:
2.32 State DEP credits
0.976 Federal ACOE credits
• Mitigation Banks can be developed and/or operated by governmental agencies or private
entities with the DEP and/or ACOE approving credits based upon the type and/or quality of
preserved topography. A mitigation bank operator (administrative and/or maintenance) is
required for long term business sustainability such as the St. Lucie County Mosquito Control
Department’s administration and maintenance of the Bear Point Mitigation Bank.
The Bear Point Mitigation Bank was developed by St. Lucie County as part of a mosquito control
impoundment, first by assembling two ownerships covering 317+ acres, followed by clearing
non-native flora, and installation of water control devices through the impoundment banks to
sustain water for mosquito control and mangrove growth. This all occurred prior to 2003 when
the bank was permitted to sell mitigation credits. Reportedly the acquisition and development
costs have been paid by past sales of credits, thus in my opinion as of the date of appraisal
acquisition and development costs are not considered an indication of the market value of a
mitigation credit.
FULLER-ARMFIELD-WAGNER
3
Although within Bear Point, demand for mitigation credits have been soft, since sales of mitigation
credits have occurred within some 95+ mitigation banks within the state, valuation via the Sales
Comparison Approach is an applicable method of forming an opinion of market value applicable
to the subject’s credits.
Research found, other than Bear Point and the adjacent and overlapping CGW Mitigation bank
located in Indian River County, mitigation banks typically have separate / defined service areas,
also while there is 95+ permitted banks within the state, only a few banks have Mangrove
Forested Credits like the subject.
Thus, research extended statewide for mitigation banks with Mangrove Forested or similar
saltwater mitigation credits for sale. In addition to the subject, research found seven developed
mitigation banks offering mangrove or saltwater forested, state and federal credits.
The Income Capitalization Approach could be considered a method to value the remaining
mitigation credits assuming all were sold to one entity in one transaction or a “bulk” sale.
However, as per the client’s direction the Scope of Work requires valuing mitigation credits as
typically sold in the mitigation market to an end user, or retail sales prices.
• Client: St. Lucie County Board of County Commissioners.
• The appraisal and report are subject to the Ordinary Limiting Conditions, Extraordinary
Assumptions, and Certification included within this report.
• The Intended User of this appraisal report is the St. Lucie County Board of County
Commissioners and/or their representatives, and the appraisal report does not have
another intended user.
• The Intended Use of this appraisal is to develop pricing for sales of mitigation credits, and
the appraisal was not developed for another use.
• Note: The effects on property values of the global outbreak or “novel coronavirus” known
as COVID-19 is unmeasurable as of the date of appraisal, thus the reader is cautioned
and reminded that the conclusions presented in this appraisal report apply only as of the
effective date indicated and the appraiser makes no representation as to the effect on the
subject property of any unforeseen event related to the pandemic, subsequent to the
effective date of the appraisal.
FULLER-ARMFIELD-WAGNER
4
Definitions
APPRAISAL REPORT FORMAT
Per Uniform Standards of Appraisal Practice (USPAP 2016-2017) – Standards Rule 2-2, each written real property appraisal
report must be prepared under one of the following options and prominently state which options is used:
Appraisal Report or Restricted Appraisal Report.
MARKET VALUE DEFINED
Market Value, per Florida case law (State Road Department v. Stack, 231 So. 2d 859 FL 1st DCA 1969) defined as:
The amount of money that a purchaser willing but not obligated to buy the property would pay an owner
willing but not obligated to sell, taking into consideration all uses to which the property is adapted and
might be applied in reason. Inherent in the willing buyer -willing seller test of the fair market value are
the following:
• A fair sale resulting from fair negotiations.
• Neither party is acting under compulsion of necessity (this eliminates forced liquidation or sale at
auction). Economic pressure may be enough to preclude a sale’s use.
• Both parties having knowledge of all relevant facts.
• A sale without peculiar or special circumstances.
• A reasonable time to find a buyer.
PROSPECTIVE VALUE OPINION – Source, Appraisal Institute, Dictionary of Real Estate Appraisal, 6th ed.
A value opinion effective as of a specified future date. The term does not define a type of value. Instead, it
identifies a value opinion as being effective at some specific future date. An opinion of value as of a
prospective date is frequently sought in connection with projects that are proposed, under construction, or
under conversion to a new use, or those that have not yet achieved sellout or a stabilized level of long-
term occupancy.
MITIGATION CREDIT – Source, defined by the appraiser
A mitigation credit is defined as a credit or offset for damages to, in this case, mangrove forested property
– with credits issued by the State of Florida Department of Environmental Protection (DEP) (state credits)
and/or the Army Corps of Engineers (ACOE) (federal credits) with mitigation credit based on the quality of
the mitigation bank.
DUAL MITIGATION CREDIT – Source, defined by the appraiser
A dual mitigation credit is defined as a combined – one State of Florida Department of Environmental
Protection (DEP) and one Army Corps of Engineers (ACOE) mitigation credit.
ARM’S LENGTH TRANSACTION – Source, Appraisal Institute, Dictionary of Real Estate Appraisal, 6th ed.
A transaction between unrelated parties who are each acting in his or her own best interest.
MARKET AREA – Source, Dictionary of Real Estate Appraisal, 6th ed.
The geographic region from which a majority of demand comes and in which the majority of competition
is located. Depending on the market, a market area may be further subdivided into components such
as primary, secondary, and tertiary market areas, or the competitive market area may be distinguished
from the general market area.
SALES COMPARISON APPROACH – Source, Appraisal Inst., Dictionary of Real Estate Appraisal, 6th ed.
The process of deriving a value indication for the subject property by comparing sales of similar
properties to the being appraised, identifying appropriate units of comparison, and making appropriate
adjustments to the sale prices (or unit prices, as appr opriate) of the comparable properties based on
relevant, market-derived elements of comparison. The sales comparison approach may be used to
value improved properties, vacant land, or land being considered as though vacant when an adequate
supply of comparable sales is available.
FULLER-ARMFIELD-WAGNER
5
Ordinary Limiting Conditions and Underlying Assumptions
1. The opinions value given in this report represents the opinion of the signer as of the DATE
SPECIFIED. Real estate is affected by an enormous variety of forces and conditions will vary with future
conditions, sometimes sharply within a short time. Responsible ownership and competent
management are assumed.
2. This report covers the premises herein described only. Neither the figures herein nor any analysis
thereof, nor any unit values derived therefrom are to be construed as applicable to any other property,
however, similar the same may be.
3. It is assumed that the title to said premises is good; that the legal description of the premises is
correct; that the improvements are entirely and correctly located on the property; but no investi gation
or survey has been made, unless so stated.
4. The opinion(s) given in this appraisal report is gross, without consideration given to any
encumbrance, restriction or question of title, unless so stated.
5. Easements on the subject parcels are unknown. Easements may or may not be recorded or may exist
by customary use or other legal means. The appraiser has not nor is he qualified to search legal records
as to the existence of other easements.
6. Information as to the description of the premises, restrictions, improve ments and income features
of the property involved in this report is as has been submitted by the applicant for this appraisal or has
been obtained by the signer hereto. All such information is considered to be correct; however, no
responsibility is assumed as to the correctness thereof unless so stated in the report.
7. The physical condition of the improvements described herein was based on visual inspect ion. No
liability is assumed for the soundness of structural members since no engineering tests were made of
the same. The property is assumed to be free of termites and other destructive pests.
8. Possession of any copy of this report does not carry wit h it the right of publication, nor may it be
used for any purpose by any but the applicant without the previous written consent of the ap praiser or
the applicant, and in any event, only in its entirety.
9. Neither all nor part of the contents of this report shall be conveyed to the public through advertising,
public relations, news, sales or other media, without the written consent of the author; particularly as to
the valuation conclusions, the identity of the appraiser or the firm with which he is connected, or any
reference to the Appraisal Institute, or to the SRA or MAI designations.
10. The appraiser herein, by reason of this report is not required to give testimony in court or attend
hearings, with reference to the property herein appraised, unless arrangements have been previously
made.
11. The Contract for the consulting services is fulfilled by the signer hereto upon the delivery of this
report duly executed.
12. It is assumed that there is full compliance with all applicable federal, state, and local environmental
regulations and zoning laws unless non-compliance is stated, defined and considered in the appraisal
report.
13. Unless otherwise stated in this report, the existence of hazardous material, which may or may not
be present on the property, was not observed by the appraiser. The appraiser has no knowledge of the
existence of such materials on or in the property. The appraiser, however, is not qualified to detect such
substances. The presence of substances such as asbestos, urea-formaldehyde foam insulation, or
other potentially hazardous materials may affect the value of the property. The value estimate is
predicated on the assumption that there is no such material on or in the property that would cause a
loss in value. No responsibility is assumed for any such conditions, or for any expertise or engineering
knowledge required to discover them. The client is urged to retain an expert in the field, if desired.
FULLER-ARMFIELD-WAGNER
6
Extraordinary Assumptions
EXTRAORDINARY ASSUMPTION – Source, Appraisal Institute, Dictionary of Real Estate Appraisal, 5th ed.
An assumption, directly related to a specific assignment, which, as of the effective date of the
assignment results, which, if found to be false, could alter the appraiser’s opinions or conclusions.
Extraordinary assumptions presume as fact otherwise uncertain information about physical, legal, or
economic characteristics of the subject property; or about conditions external to the property such as
market conditions or trends; or about the integrity of data used in an analysis.
1. The subject’s size and mitigation credit data were provided by client representative Lauri
Heistermann with St. Lucie County Mosquito Control District, and the data is assumed
to accurately represent the subject.
2. A legal description for the subject was not provided by the client, thus the legal
description included in this report was prepared by the appraiser and should be used
only for appraisal purposes.
FULLER-ARMFIELD-WAGNER
7
Certificate of Appraisal
I certify that, to the best of my knowledge and belief:
a) The statements of fact contained in this report are true and correct.
b) The reported analysis, opinions, and conclusions are limited only by the reported
assumptions and limiting conditions and are my personal, impartial and unbiased professional
analyses, opinions, and conclusions.
c) I have no present or prospective interest in the property that is the subject of this report,
and no personal interest with respect to the parties involved.
d) I have no bias with respect to the property that is the subject of this report or to the parties
involved with this assignment.
e) My engagement in this assignment was not contingent upon developing or reporting
predetermined results.
f) My compensation for completing this assignment is not contingent upon the development
or reporting of a predetermined value or direction in value that favors the cause of the client,
the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a
subsequent event directly related to the intended use of this appraisal.
g) My analysis, opinion, and conclusions were developed, and this report has been prepared,
in conformity with the Uniform Standards of Professional Appraisal Practice.
h) Daniel D. Fuller inspected the property that is the subject of this report.
i) No one provided significant real property appraisal assistance to the person signing this
certification.
j) The reported analyses, opinion, and conclusions were developed, and this report has been
prepared, in conformity with the requirement of the Code of Professional Ethics & Standards
of Professional Appraisal Practice of the Appraisal Institute including the Uniform Standards
of Professional Appraisal Practice.
k) The use of this report is subject to the requirements of the Appraisal Institute relating to
review by its duly authorized representatives.
l) "As of the date of this report, I, Daniel D. Fuller, MAI, SRA, have completed the
requirements under the continuing education program of the Appraisal Institute.
m) This appraisal assignment was not based on a requested minimum valuation, a specific
valuation, or the approval of a loan.
n) I have previously appraised this property within the three years prior to engagement for
this assignment, but I have not performed any other services relating to this property in the
three years prior to engagement for this assignment.
Daniel D. Fuller, MAI
State-Certified General Real Estate Appraiser RZ567
FULLER-ARMFIELD-WAGNER
8
Owner of Record and Sales History
Owner of Record: St. Lucie County
2300 Virginia Avenue
Fort Pierce, FL 34982
Sales / Listings / Contracts / Leases
The most recent sale of the subject occurred in September 2000 with the assemblage of two
ownerships by St. Lucie County. Since the transactions are some 21 years old and since the
subject was improved and awarded mitigation credits, the property is superior to its condition
in 2000. Thus, for the reasons identified the September 2000 sales are not further analyzed.
The subject is not for sale or under a sale/purchase contract other than the sale of DEP and
ACOE awarded mitigation credits.
The subject is not encumbered with a lease.
Deed Restrictions
None known.
Legal Description
I was not provided the subject’s legal description thus the following legal description was
compiled by the appraiser for appraisal purposes and should not be used for legal purposes,
including transfer of subject’s title.
Abridged; portions of Sections 12 and 13, and all or portions of Government Lots 2, 3, 4 and
5, Township 35 South Range 40 East, St. Lucie County, Florida.
Easements
On February 25, 2004, St. Lucie County executed a Conservation Easement covering the subject
to the Board of Trustees of the Internal Improvements Trust Fund of the State of Florida and the
South Florida Water Management District. The easement was granted per the Department of
Environmental Protection mitigation bank, department permit No. 0175246-001.
There are no known easements negative to value, however, easements may be in-place by non-
recorded instruments, or other conditions, thus your attention is directed to Ordinary Limiting
Conditions #5.
A map locating the subject and photographs of the subject comprise the following Exhibits.
FULLER-ARMFIELD-WAGNER
9
FULLER-ARMFIELD-WAGNER
10
Subject photographed – 12/13/2021
South entrance to Bear Point Mitigation Bank
Typical berm along Indian River, note rock riprap protection from Indian River
FULLER-ARMFIELD-WAGNER
11
Typical culvert w/ water control thru berm w/ view of mangrove growth
SW view from berm across Indian River
FULLER-ARMFIELD-WAGNER
12
Water control structure within County property east of Mitigation Bank
FULLER-ARMFIELD-WAGNER
13
Area Data
Area Data, in brief:
• The subject is located within the St. Lucie County barrier island neighborhood immediately
south of the Fort Pierce city limits, fronting the east bank of the Indian River.
• The subject is within St. Lucie County governmental jurisdiction.
• Fort Pierce is the oldest city with a 2010 census population of 41,590 and 2020 US Census
Bureau population estimate of 44,476, an increase of approximately 6.9% for the ten-year
period (0.69%/year).
• Port St. Lucie was incorporated in the early 1960’s with population in 2010 of 164,603, and
2020 US Census Bureau population estimate of 202,914, an increase of approximately 23%
for the ten-year period (2.3% per year).
• St. Lucie Village is a mostly residential community with a population of some 600 persons,
and historically very little change in the community thus the community has nominal impact
on the County.
• The 2010 census placed the County’s total population at 277,789 with 2020 US Census
Bureau population estimate of 322,265, an increase of approximately 16% for the ten-year
period (1.6% per year).
• Over the past ten years the population growth within the City of Fort Pierce remained
relatively nominal and expected to continue to grow at a relatively slow pace. A majority of
the near-term growth in St. Lucie County is expected to occur in and surrounding the City of
Port St. Lucie. To a great degree this occurs because the City of Ft. Pierce has little vacant
land for new growth vs. the platted areas of the City of Port St. Lucie approximately 75%
developed, plus large acreage tracts in the southwest environs of the City of Port St. Lucie
remain available for development. Thus, a majority of the County’s near-term growth is
expected to occur in and around the City of Port St. Lucie with near term growth in the City
of Ft. Pierce and northerly St. Lucie County expected to continue at its slow pace.
• Finally, prior to the announcement of the coronavirus pandemic real estate conditions
throughout St. Lucie County were strengthening, although depending upon location,
strengthening occurred at different levels. However, post pandemic, demand in residential
markets strengthened, as has demand in the industrial markets, however demand in the
retail and office markets softened but appears to be stabilizing, but it is likely long-term
trends in all markets will not be clearly defined for several months.
Neighborhood Data
Neighborhoods are defined as – Source: Appraisal Institute, The Dictionary of Real Estate Appraisal, 6th ed.
1. A group of complementary land uses; a congruous grouping of inhabitants, buildings, or business
enterprises.
2. A developed residential superpad within a master planned community usually having a distinguishing
name and entrance.
The subject’s immediate neighborhood consists of a mix of residentially developed properties
and “wetlands”, lying between the Atlantic Ocean and the Indian River.
North of the subject Hutchinson Island is some 80% developed within the city of Fort Pierce,
and south of the subject the Hutchinson Island is some 20% developed, with development
patterns largely affected by the large area of “wetlands” south of the subject.
FULLER-ARMFIELD-WAGNER
14
Additionally, within the subject’s immediate neighborhood the undeveloped tracts are mostly
under governmental ownership, purchased for preservation for public use as well as mosquito
impoundments, although recently various parcels have been permitted for low density
residential development with one property in construction with a single-family lot oceanfront
subdivision.
The neighborhood is expected to remain “as is” for the interim period, with any change in
development trends likely to occur over a very long term with the subject compatible with use
trends within the neighborhood.
Property Description
• Project Area: 317 acres
Subject consists of a portion of an assemblage of two ownerships, former owners Daggett
(74.99 acres) and Koblegard (249.18 acres), followed by an investment through the County’s
Mosquito Control department to restore the property to obtain mitigation credits for sale. The
property received 49.8 mitigation credits from the DEP and 43.3 credits from the ACOE.
Initial 80% of monies collected from the sales of credits was directed to Daggett and Koblegard
to pay the land purchase. It is my understanding the grantors have been paid in full, thus
income from sales of credits is applied to the cost of maintaining the property to DEP and
ACOE mitigation standards.
The 2021 price of mitigation credits were:
1 - State credit - $160,000
1 - Federal credit - $160,000
1 – dual credit - $320,000
1/10th of single State, Federal credits or dual credits: $16,000 or $32,000
Bear Point does not sell less than 1/10th credits.
Data provided indicates in 2021 ledger deductions of 0.34, 0.03, 0.01, and 0.01, for a total of
0.39 State credits of which 0.05 credits were sold from previously purchased credits by CGW
Mitigation Bank, and 0.34 credits utilized by previous FDOT purchase. Also, 0.34 ACOE
(federal) credits previously purchased by FDOT were utilized. Because the sales were from
the inventory of credits held by other entities, only ledger debits occurred in 2021, thus no
income to Bear Point.
Data provided indicates in 2020 ledger deductions of 0.04, 0.10, 0.05, 0.03 and 0.18 for a total
of .40 State credits sold by Chown/CGW Mitigation Bank with no income to Bear Point. Bear
Point sold combined 0.10 State credits and 0.10 federal credits in one transaction producing
$32,000 income from the sale. (Note: buyer used 0.07 ACOE credits of 0.10 credit purchased.)
Plus, 0.10 ACOE credit producing $16,000 income to Bear Point. Total 2020 income to Bear
Point, $48,000.
FULLER-ARMFIELD-WAGNER
15
In 2019 data provided indicates in ledger deductions of 0.01, 0.03 and 0.26 State credits
directed by court actions for sale from the CGW Mitigation Bank inventory of Bear Point
credits, thus no income to Bear Point. In July 2019 Bear Point sold 0.20 State mitigation credits
to a developer with Bear Point receiving $32,000 income from the sale.
Data provided indicates in 2018 SJWMD directed the purchase of 0.31 State credits and court
directed purchases of .01 and 0.1 State credits with a total of $12,000 income to Bear Point.
Apparently, 0.32 credits were deducted from the state ledger for sales from the inventory of
previously purchased CGW Mitigation Bear Point credits.
In 2017 - DEP directed 0.10 State and 0.10 Federal credits were sold to a development
located within Rivera Beach, Florida, totaling $24,000. In 2016, 0.20 State credits were sold,
and 0.30 dual credits were sold with a total income of $19,500. In 2015, 0.10 dual credits and
0.10 State credits sold. CGW Mitigation Bank previously purchased 3.39 DEP (State) credits
and 1.236 ACOE (Federal) credits, purchased for resale. The remaining Bear Point credits
held by CGW Mitigation Bank and available for purchase total 2.77 DEP and 0.976 ACOE
credits. Sales of credits for re-sale are no longer allowed. Bear Point mitigation bank has 8.2
DEP credits and 7.2 ACOE credits remaining for sale.
In the subject’s case, apparently in recent years because of the lack of large-scale waterfront
residential development projects within subject’s service area, most demand is from dock
installations or expansions or purchases for accidental mangrove damage. Other mitigation
banks surveyed also experience demand for and sales of small quantities of credits, but
occasionally they have experienced larger purchases for developments or road improvement
projects. The subject’s service area is somewhat small, covering Hutchinson Island and the
west bank of the Indian River, ranging from the Sebastian Inlet on the north to the St. Lucie
Inlet on the south. From Sebastian Inlet to the Fort Pierce Inlet the
Bear Point service area overlaps with the CGW Mitigation Bank located in Indian River
County. This is the only known location within the state with overlapping mitigation banks.
Plus, in most instances DEP does not typically permit sales of credits outside of a mitigation
bank’s service area, and for these reasons sales within Bear Point continue at a very modest
pace. It is however noted that in 2017, DEP directed the mentioned out of service area Riveria
Beach development to Bear Point Mitigation Bank for purchasing credits.
In 2012 sales volume increased by FDOT and FPUA purchases for regional projects. As
previously discussed, in recent years’ demand is primarily from private parties seeking
mitigation credits for dock expansions, new installations, or accidental mangrove damage.
Although a review of mitigation bank ledgers and per discussions with mitigation bank
representatives, demand increase in 2019 with in some instances significantly higher volume
of sales in 2020 / 2019 vs. 2018 and prior years, but there are also instances where like
subject, sales volume is very modest.
Finally, per County personnel, it appears there is little resistance to the $160,000 single credit
price, primarily because in most instances, purchasers do not require full credits rather
purchases in 1/10th increments is most common, with Bear Point pricing of $16,000 per 1/10th
FDEP credit and $16,000 for 1/10th ACOE. Bear Point credit pricing follows most mitigation
banks with 1/10th credits pricing based on the prorated price of a full credit, but most banks
also allow purchases of the 1/100th credits, in fact the majority of transactions for mangrove
FULLER-ARMFIELD-WAGNER
16
credits is in 1/100th interest. Thus, subject’s limit of minimum 1/10th purchase may be a
detriment to demand. But the most competition to subject’s sales comes from the sales
produced by the CGW Mitigation Bank/Chown inventory of Bear Point credits obtain in a bulk
purchase several years ago. At the time of sale, demand was soft thus the bulk sale provided
income to payoff the site grantors. The buyer’s intent was to resell credits at a profit, which is
occurring, but apparently the seller offers credits in hundreds vs. Bear Point selling minimum
one tenth credits. Selling smaller quantities attracts buyers as often buyers r equire less than
0.10 credits. The Chown/CGW inventory as of December 13, 2021, consists of 2.32 DEP
credits, and 0.976 ACOE federal credits.
Also, in the past Bear Point sold 25 dual credits to FDOT for future road, etc., projects. It
appears FDOT is only beginning to utilize the credits.
In my opinion, the bulk sale of credits should not have occurred as the future income from
higher priced credits is negatively affected.
The cost to maintain the bank has held relatively steady, $37,615 for physical year 2014-2015
and 2015-2016, with $44,504 for 2016-2017, and $33,955 for 2017-2018 and $32,042 for
2018-2019, and July 1, 2019 - June 30, 2020, totaling $36,176 with an annual average of
$36,858. The January 2020 to December 31, 2021, operating costs are an estimated
$45,774.90. It is noted since 2015 the average annual income has not supported operating
expenses.
The following is a summary of income for the Bear Point Mitigation Bank from 2007 – 2021
Year Income to SLC Total Sales Price of Dual Credit
2021 $0 $0 $320,000
2020 $48,000 $48,000 $320,000
2019 $32,000 $32,000 $160,000
2018 $12,000 $12,000 $160,000
2017 $24,000 $24,000 $160,000
2016 $19,500 $19,500 $130,000
2015 $4,550 $22,750 $130,000
2014 $23,400 $117,000 $130,000
2013 $4,550 $22,750 $130,000
2012 $131,950 $659,750 $130,000
2011 $11,050 $55,520 $130,000
2010 $44,335 $221,675 $130,000
2009 $6,338 $31,688 $130,000
2008 $46,673 $233,363 $130,000
2007 $43,121 $215,603 $97,000
Highest and Best Use
Highest and Best Use of the Bear Point Mitigation Bank is the continued sales of mitigation
credits and continue to operate the mosquito impoundment.
FULLER-ARMFIELD-WAGNER
17
Exposure
Exposure time: - Source, Appraisal Institute, Dictionary of Real Estate Appraisal, 6th ed.
1. The time a property remains on the market.
2. The estimated length of time the property interest being appraised would have been offered on the
market prior to the hypothetical consummation of a sale at market value on the effective date of the
appraisal. Comment: Exposure time is a retrospective opinion based on an analysis of past events
assuming a competitive and open market (USPAP, 2016-2017 ed.).
Exposure - Research found mitigation credits sell at a slow pace, with the exposure period to sell
one credit may require several years, although this occurs in all banks as many of the banks sell
as few as 1/100th credits.
`
Site Map (general area of Bear Point Mitigation Bank in red)
FULLER-ARMFIELD-WAGNER
18
Bear Point Mitigation Service Area Map
(Arrow indicates subject - Service Area in Green)
FULLER-ARMFIELD-WAGNER
19
Valuation –
At the time when St. Lucie County remained obligated to pay-off the Daggett and Koblegard
for the land purchase, analysis via the Cost Approach method may have been deemed
creditable to at least determine the minimum breakeven sales price. However, since the terms
of the purchase agreements are reported to be final, and because the assignment is to
appraise market value, in my opinion, analysis of the potential sales price of credits via the
Cost Approach is no longer a valid valuation method, thus the Cost Approach is not performed.
Valuation via the Sales Comparison Approach is valid and begins in the following section.
Sales Comparison Approach
The Sales Comparison Approach is a form of comparison shopping. When sales and listings
of similar credits are available within the subject's market area the credits are compared to
the subject for a value indication. Where there are an adequate number of physically
comparable credits the approach often proves to be the best indication of value as buyer
tendencies can be readily measured and applied to the subject of the appraisal.
Property Appraised
As of December 31, 2021 (Prospective valuation), Bear Point Mitigation Bank credit inventory
is expected to total 8.1 DEP credits and 7.0 ACOE credits.
In 2021 St. Lucie County did not engage in any direct sales of Bear Point credits. Form a
previous FDOT bulk purchase of credits consisting of 25 dual credits, on July 1, 2021, FDOT
utilized 0.34 state and 0.34 federal credits, requiring ledger debit of the utilized credits but no
2021 income to Bear Point. Also, as will be detailed later in the CGW Mitigation Bank sales
discussion, other debits of previous bulk credit sales were applied to the Bear Point ledger in
2021
Research discovered some 95 permitted mitigation banks within Florida with six banks, plus
the subject, known to offer Mangrove Forested Estuary Credits, plus Bear Point credits have
sold from an inventory of a previous bulk purchase of credits. Since generally credits have to
equal damage, in other words mangrove mitigation credits are required to be purchased for
mangrove damage, at this time generally other types of mitigation credits cannot be applied,
thus other credit types are not considered in the valuation process.
In alphabetic order mitigation banks researched and analyzed include –
• CGW Mitigation Bank
• Everglades Mitigation Banks II
• Florida Gulf Coast Mitigation Bank
• Little Pine Island Mitigation Bank
• Mangrove Point Mitigation Bank
• Tampa Bay Mitigation Bank
• Webster Creek Mitigation Bank
FULLER-ARMFIELD-WAGNER
20
CGW Mitigation Bank – located in Indian River County covers a service area along
Hutchinson Island beginning at Eau Gallie Boulevard in Brevard County, extending south to
the Fort Pierce Inlet. A portion of the service area overlaps the Bear Point service area,
Sebastian Inlet to the Fort Pierce Inlet, which is somewhat unusual as there are no other
known overlapping mitigation service areas. The bank is approved for sales of Freshwater
General Wetlands/Palustrine credits with the Palustrine at time interchangeable with
mangrove credits. Plus, the bank coverage area overlaps subject’s coverage area, thus the
bank is included in this analysis. Per the bank’s manager, Mr. Craig Chown, CGW credits sold
in 2021 at $160,000 per credit with direct prorations for smaller credit purchase.
The bank was initially granted 63.2 credits and then 3 additional credits were added for a total
66.2 DEP credits, plus the potential of 54.6 ACOE credits.
In 2017 the state registry of sales reported 3 sales of partial credits totaling 3.2-1/0th credits.
The state ledger reports, 0.45 credits sold in 2017 with an approximate 16.25 remaining
credits, subject to 12.50 credits reserved but not sold or deducted from the state’s ledger, as
of 12/24/17 the last ledger entry for 2017. In 2018 a total of 0.12 state credits were sold and
in 2019, 0.25 credits were sold resulting in a net 3.38 remaining state credits. In 2020, 0.14
state credits were sold with net 3.24 credits remaining. In 2020, 0.18 federal credits were sold.
In 2021, 0.41 state credits were sold with net available balance of 2.82 credits.
Also, in the past St. Lucie County completed a bulk sale of credits to CGW Mitigation Bank,
then owned by Mr. Craig Chown. Mr. Chown has since purchased the CGW inventory of Bear
Point credits. Because the CGW Mitigation Bank is not permitted for sale of mangrove credits,
the purchase of Bear Point credits increases the inventory and variety of credits available for
sale by CGW or Mr. Chown. From the original CGW inventory of previously purchased Bear
Point credits, in 2019, 0.25 state credits and 0.12 federal credits were sold. In 2020, CGW
sold 0.50 state Bear Point credits, plus 0.07 federal credits were sold. In 2021, CGW sold 0.50
state credits but no federal credits. As of 12/31/2021, CGW Bear Point will own 2.32 state
credits and 0.976 federal credits.
Mr. Chown previously reported the price of CGW, Bear Point owned credits, was set in 2016
at $160,000 per credit, in other words $160,000 per state and $160,000 per federal credit, but
the sale of a full credit has not occurred in recent years and at that time based on conversation
with Mr. Chowan, with the sale of two full credits a discount can be negotiated. Apparently,
there are no discounts for partial interest purchases with the price set at $16,000 per 1/10 of
a state or federal credit. Based on recent sales debited from the Bear Point ledger, Mr. Chown
is marketing 1/100th credits, and as evidenced by the sales and discussions with the other
mitigation bank marketing persons 1/100th credits are in demand as typically buyers only
require some level of 1/100th credits. Per discussions with Mr. Chown for this report, the 2021
price per credit remains at $160,000. However, Mr. Chown reports 2022 price are increasing
to $180,000 per credit with dual credit pricing available for negotiations, and partial credits
continue to be prorated. (Pricing is applicable to Bear Point credits as well as CGW credits.)
FULLER-ARMFIELD-WAGNER
21
Everglades Mitigation Banks I and II – located in Dade County with a service area covering
Dade, Broward and a portion of Palm Beach County.
The banks are owned by Florida Power and Light (FPL) and managed by Mr. Joe Sicbaldi, an
FPL employee. The mitigation banks combined are relatively large covering some 13,151
acres with originally 2,194.03 total mitigation credits consisting of freshwater and saltwater
credits.
In 2017 Mr. Sicbaldi reported demand was slow for saltwater mangrove credits, primarily
because of the built-out nature of the service area. However, in 2019 demand increased. Mr.
Sicbaldi confirmed the sale of six credits in 2008, six in 2009, ten sold in 2010, 0.45 credits
sold in 2011, 2.31 credits in 2012, 2.08 in 2013, 1.68 dual credits in 2014, 1.3 credits in 2015,
1.49 dual credits in 2016, and it appears 1.01 dual credits sold in 2017, and in 2018, within
phase II, 0.8 state and 3.77 federal credits sold.
The price in 2014, 2015, and 2016 was $100,000. The 2017 price for a dual credit was
$120,000 per credit and remains $120,000 per credit. Mr. Sicbaldi also reported than the
minimum price for a credit of 0.01 is $2,000.
In 2019 Phase I issued 0.18 state credits and 0.50 federal credits. In 2019 Phase II issued
1.15 state credits and 0.50 federal credits. Demand appeared to stabilize in 2020 within the
bank’s service area with 2020 issues of 1.08 state credits and 0.18 federal credits. However,
in 2021 demand significantly strengthened. No state or federal sales of saltwater credits
occurred in Phase I in 2021. In Phase II 1.64 state credits and 0.06 federal credits sold.
In the past Mr. Sicbaldi reported in 2022 there is no intent to lower the price but at the same
time because FPL is in the business of selling power and not managing mitigation banks, thus
FPL does not intend to increase or push the price to the top of the market. Thus 2022 pricing
will remain at $120,000 per credit and $120,000 per dual credit with the minimum credit 0.01
at a minimum price of $2,000.
Florida Gulf Coast Mitigation Bank – covers some 1,587.5 acres within Levy County,
Florida, with a substantial portion of the bank fronting the Gulf of Mexico including Gulf
frontage northwest to the Ochlockonee Basin. The bank includes Saltwater Tidal Marsh
Wetlands Credits.
The bank is relatively new with initial credits released in January 2017, June and November
2018. Saltwater Tidal Marsh credits (including mangroves) total 20.88 with 0.03 credits issued
in May 2019. ACOE (federal) credits for Estuarine Intertidal, Emergent total 20.4 credits wit h
.99 credits sold in 2019. Sales in 2020 include 0.23 state saltwater marsh credits and 0.07
federal emergent credits. In 2021, 0.03 state credits were sold, plus 3.48 credits were release
from a previous sale, also 0.02 federal credits were sold. The 0.03 state and 0.02 federal
credits were sold to FDOT for SR 30 R/W work.
Sales prices are a reported $330,000 State or Federal credits with partial credits prorated.
Initially 2020-2021 prices were set at $330,000 per credit, however, adjusted in 2021 to
$400,000 for state and federal saltwater credits or $400,000 for dual credits.
FULLER-ARMFIELD-WAGNER
22
Little Pine Island Mitigation Bank - located in Sarasota County with a service area covering
north Sarasota County to south Collier County, including Lee County, east to US Hwy. 41.
The bank is owned by Mariners Properties Development, Inc. and managed by Mariner
Properties staff in a public-private partnership with the State of Florida. The mitigation bank is
located on Little Pine Island within the Charlotte Harbor Aquatic Preserve laying between the
Lee County mainland and Little Pine Island fronting the Gulf of Mexico, bridge connected. In
total the bank covers some 1,565 acres, with initially approved 807 combined salt and
freshwater credits, including 190.5 forested saltwater credits, and then in 2011, 400+
additional credits were approved.
Prior to 2011, verified with Shelia O’Connor representing Mariner Properties, seven forested
saltwater credits sold at a price of $110,000 per credit and in 2011, 4.6 credits sold and in
2012, 2.09 credits sold, and in 2013 a total of 13 combined credits sold due to FDOT
construction projects. In 2014 the price increased to $125,000 per credit with 3 credits sold in
2014. In 2015 the price was again increased to $130,000 with a combined 4+ credits selling
in 2014. In 2015 and 2016 pricing remained at $130,000 for the mangrove credits and $85,000
for herbaceous/grassy dual saltwater credit. Per Ms. O’Connor, in 2016 in total 1.85 saltwater
credits sold. Ms. O’Connor reports in 2017 the bank has some 200 combined,
mangrove/saltwater credits and the price increased to $160,000 for one mangrove credit,
either state or federal, with the purchase of a dual full credit the price remains at $160,000 per
credit.
In 2017, 0.29 federal credits and 1.55 state credits sold. For 2017 the bank priced fractional
purchases were as follows; 0.01 to 0.05 credits priced at $2,300 per 1/100th credit, and from
0.06 to 0.09 credits the price is $1,950 per 1/100th credit, and then each 10th credit is priced
at $17,600, and again one full credit is priced at $160,000.
Per mitigation bank ledgers it appears in total 1.68 credits sold in 2018, but Mr. Desmond
Duke with “Ecoresolve”, a mitigation bank marketing firm representing Pine Island Mitigation
Bank, could not provide further details of state and/or federal credits. Per 2019 ledgers, 0.43
State and 0.51 Federal credits sold. Most of the sold credits were 1/10 th or 1/100th credits for
mangrove trimming, etc. but demand was relatively strong in 2019.
Also, per Desmond Duke with “Ecoresolve”, for 2018 and forward in 2019 prices have
increased to $180,000 per one credit, federal or state with 1/10th credit $18,000, and again,
0.01 to 0.05 credits priced at $2,300 per credit, and from 0.06 to 0.09 credits the price is
$1,950 per credit.
In 2020 Pine Island mitigation bank ledgers indicate 2.73 state credits and 4.4 federal credits
were issued, thus demand significantly increased, but all issues were fractional. Mr. Desmond
stated the saltwater credits typically sell in fractions which has been found to be a true
statement from all banks selling mangrove credits.
In 2021, Pine Island bank ledger reported 39 transactions with total sales of 2.22 state credits,
and 36 federal credit transactions totaling 0.54 credits. The state transactions include 1.18
state credits for a street rehab project, plus 0.22 state credits and 0.21 state credits for a new
FULLER-ARMFIELD-WAGNER
23
development, otherwise sales are mostly 100th interests, averaging 0.022 credits per 37 the
transactions. While the bank sold 2.22 state credits, most transactions were of 100th interests
which is typical for sales of saltwater credits, resulting in an extended sellout period.
Mr. Desmond with “Ecoresolve” also reported for 2020 and into 2021 prices for forested
saltwater credits increased to $280,000 per credit or the same per dual credit. In 2021 credit
prices increased to $325,000 and the same for dual credits. Partial credits are prorated as in
the past.
Mangrove Point Mitigation Bank - Mangrove Point Mitigation Bank is 314 acres of protected
lands located in Hillsborough County, FL within the Tampa Bay & Coastal Areas Drainage
Basin (SWFWMD) with Saltwater Mangrove/Estuarine Forested, Estuarine emergent and
Palustrine Emergent Credits.
Mangrove Point Mitigation Bank is located directly on Tampa Bay. Large areas of rare and
sensitive salt tern habitat were destroyed by dredging done in the 1950s to control
mosquitoes. The mitigation bank is in the process of restoring this rare and sensitive habitat
to help increase habitat for the Reddish Egret and other endemic species.
The bank is permitted 34.53 state credits for Mangrove Forest. With initial release of 2.8
credits on 11/5/2020, in 2021 a total 0.82 credits sold including 0.79 credits utilized for I-75 @
US 301 with the remaining sales in two transactions of 0.21 and 0.01 credits.
Federal Credits permitted total 38.1, Estuarine Intertidal Forested, with initial release of 3.46
credits, and in 2021 sales of 1.02 credit to an FDOT project.
Saltmarsh and Mangrove credits are priced at $400,000 for dual credits, or $400,000 per
credit.
Tampa Bay Mitigation Bank - located in southeast Hillsborough County with a service area
surrounding the Tamp Bay covering portions of Hillsborough, Manatee, Pasco, and Pinellas
Counties.
The bank was developed and is owned by Tampa Bay Mitigation, LLC, private ownership, and
managed by the owners. The TBMB site consists of 161 acres of land surrounding the
headwaters of Andrews Creek, on the southeast portion of the peninsula between Little
Cockroach Bay and Cockroach Bay, in the Southshore area of Hillsborough County.
In total the bank covers some 42 acres of saltwater marsh and 90 acres of freshwater land
and initially 111.55 dual mitigation credits. Per Mr. Jamie Scarola, a civil engineer and
owner/development partner in TBMB, in 2009 dual credits sold at $100,000 to $150,000 per
credit, with Mangrove Forested credits selling at $150,000 per credit. Apparently in 2012 and
2013 there were no sales but in 2014 and 2015 sales volume improved with the 2014 price
for mangrove forested credits $150,000, increased to $200,000 in 2015. In 2016 the bank sold
out of state and federal forested mangrove credits, selling at $200,000 per credit. The bank,
however, has Hillsborough County forested mangrove credits, which substitute for federal and
state credits, priced at $225,000 per credit. Partial credits are prorated from the $225,000
price.
FULLER-ARMFIELD-WAGNER
24
Per discussions with Mr. Scarola in late 2016, with the mangrove forested DEP and ACOE
credits fully absorbed, DEP and ACOE will be forced to either allow out of service area
purchases for the TBMB service area or allow Hillsborough County forested mangrove credits
as a replacement or allow saltwater marsh credits to offset the mangrove forested credits.
DEP and ACOE credits have been replaced with County credits, but saltwater credits have
not replaced mangrove forested credits.
In 2018 and into 2019, the bank continues to substitute Hillsborough County forested
mangrove credits for federal and state credits, continuing $225,000 per credit pricing. Partial
credits are prorated from the $225,000 price. The 2019 price remained at $225,000 per
mangrove credit, and per Victoria Colangelo with The Mitigation Banking Group (marketing
agency), the price remained the same for 2020, $225,000 per credit, except in the background
the seller has been charging an additional 4% for “depositing”, which beginning in 2021 and
forward the plan was to include the fee with the credit price for a total fee of $234,000, but that
did not occur with the 2021 fee remaining at $225,000 per credit. I could not establish 2022
fees.
Webster Creek Mitigation Bank – is a new mitigation bank located in 1.5 miles south of New
Smyrna Beach, Volusia County. The project consists of 116.64 permitted acres with 78.76
acres of wetlands and uplands preservation area with the remaining area consisting of
wetland, upland restoration and enhancement. Forested Marine credits totaling 20.18 (State
credits) were issued for sale, plus Herbaceous Marine State credits of 1.75 with 0.15 credits
sold in 2019. The bank has been awarded only State credits thus no Army Corps approvals
or credits.
In April 2019 credits were awarded thus initial sales are slow. Sales price was initially set at
$300,000 per credit and remains in 2021 at $300,000 per credit with pro-rated fractional sales.
In 2021, sales of forested marine credits total 0.32, sold in 5 transactions. In 2021, 0.21 credits
have sold in one transaction for a bridge replacement, plus 0.01 credits were reserved, thus
demand was soft in 2021. Again, I could not establish 2022 fees but with modest sales fees
are not expected to increase.
While demand in most banks increased in recent years, and noticeably demand increased in
most mitigation banks in 2021. Because absorption is via fractional interest, absorption of
credits will require extend years, and it is noted while in recent years new banks have come
on-line, including previously cited Florida Gulf Coast and Webster Creek banks, demand in
the new banks remains in start-up mode.
Along with the new banks cited, there are proposed or partially permitted banks with saltwater
and/or mangrove credits expected in the future, including the Green Wing Mitigation Bank
located in Brevard County. Green Wing received St. Johns River Water Management
permitting and working towards FDEP and ACOE permitting. Plus, there are several banks
proposed, although initially some have been denied permitting thus their future is uncertain.
The expected increase in development, and increased pricing makes mitigation bank
development appear financially feasible, although it appears absorption needs to substantially
increase to support financial feasibility.
FULLER-ARMFIELD-WAGNER
25
Summation and Value Conclusion
The mitigation banks researched indicated the following dual and partial credit sales prices
for 2021 and 2022:
Single Credit 1/10th Credit 1/100 Credit
Bear Point (subject) (2021): $160,000 $16,000 not offered for sale
Dual Credit
$320,000 $16,000 not offered for sale
Single Credit
CGW & Bear Point credits (2021): $160,000 $16,000 not priced
(Note: 2022 prices $180,000) Dual Credit
$160,000 $16,000 not priced
Single Credit
Everglades II (2021 & 2022): $120,000 $12,000 $2,000 – minimum
Dual Credit
$120,000
Single Credit
Fla. Gulf Coast (2021 & 2022): $400,000 $40,000 not priced
Dual Credit
$400,000 $40,000 not priced
Single Credit
Little Pine Island (2022): $325,000 $32,500 0.01 - 0 .05 $4.150
Dual Credit 0.06 – 0.09 $3,500
$325,000 $32,500 (est. based on past ratios)
Dual Credit
Tampa Bay (2021): $225,000 $22,500 $2,250
(County credits = DEP/ACOE credits)
Webster Creek (2021) Single Credit (state only)
(State Credits) $300,000 $30,000
With increasing demand, the higher volume mitigation banks have increased prices. However,
it is obvious from the data, other than FPL/Everglades II bank, Bear Point and CGW credits
mangrove and/or saltwater credits are the lowest price in the state. Because most mitigation
banks predominately sell fractional credits in the 1/100th interest range, the per credit price is
less of an issue, and it is likely as indicated often by dual pricing, a full credit or more can be
purchased at a discounted price, i.e., most often dual credits are now priced the same as a
single credit.
The current Bear Point price of $160,000 per credit was set in 2017, thus in 2022 five years
have passed without an increase, and because Bear Point prices are now falling somewhat
below the general price range, an increase in prices to say $180,000 per credit, matching
expected 2022 pricing in the CGW bank, calculates to an average annual increase of 2.5%,
about the average annual rate of inflation from 2017 to mid-2021.
FULLER-ARMFIELD-WAGNER
26
A price increase to say $180,000 calculates to $18,000 per 1/10th credit or $1,800 per 1/100th
credit which is generally somewhat unnoticeable considering prices in other mitigation banks.
Further, because predominately banks researched now price dual credits at the same level
as a single credit, thus it is my opinion Bear Point dual pricing should be adjusted to match
the market or say $180,000 for a dual credit. Pricing for more than one credit can be
negotiated.
Fractional Interest Sales
Demand for mitigation credits fluctuates with real estate development demand and in the case
of most mitigation banks offering saltwater credits where mangroves are affected,
predominately demand is generated from homeowners permitting new or expanding docks,
or in some instances, mitigating unintentional destruction of mangroves, thus predominately
demand has been for fractional credits. However, there are instances where governmental
projects require credits, i.e., in very recent years FDOT has been the largest purchaser from
various mitigation banks.
Plus, there are uncontrollable potentially positive market occurrences which could potentially
improve demand for Bear Point credits, i.e., new boom level development of remaining vacant
Hutchinson Island properties or planned governmental (FDOT) projects moving into
development stages or FDEP permitting sales out of the Bear Point service area, but there is
uncertainty if any of the mention will occur.
Mitigation bank managers report price does not seem to be an issue because the alternative
to simply purchasing credits to offset mitigation requirements an owner/developer can start a
private mitigation bank, which can be very time consuming and costly which is unlikely to
occur. Thus, it appears within a mitigation bank assigned area demand should reflect real
estate and economic market conditions.
However, demand in the Bear Point mitigation bank has been essentially zero during 2020
and 2021, most likely caused by competition from sales of former CGW owned Bear Point
credits. Mr. Chown reports minimal 1/10th credit sales, but the Bear Point ledger reports 1/100th
sales. As mentioned most banks sell 1/100th fractional credits vs. Bear Point minimal offering
of 1/10th credits. Also, Mr. Chown actively markets CGW credits as well as his Bear Point
credits, thus current succeeding in capturing the Bear Point market.
It appears, mixed pricing occurs for dual credit pricing. It also appears managers are
calculating 1/10th pricing based on the full credit price, no discounts. Also, predominately
demand for mangrove credits are from fractional interest purchasers at the 1/100th level. Bear
Point is not offering credits smaller than 1/10th interest but reducing salable credit size to
1/100th interest will likely increase transactions, but while net annual sales may not
significantly increase, in the case of Bear Point any sales will provide income to offset
operating costs.
FULLER-ARMFIELD-WAGNER
27
Therefore, it is my opinion as of December 31, 2021, the Bear Point Mitigation Credits should
reflect the following price levels:
• Value of one State credit - $180,000
• Value of one Federal credit - $180,000
• Value of combined (dual) State and Federal credit - $180,000
• Value of 1/10th credit (State or Federal) - $18,000
• Value of 1/10th Dual credit - $36,000
Plus, as discussed, it is my opinion sales of fractional interest below 1/10th should be
considered to keep offerings competitive, plus, if possible, increase marketing activity to
engineers, Realtors, etc. to attract transactions to offset operating costs.
FULLER-ARMFIELD-WAGNER
28
QUALIFICATIONS OF THE APPRAISER
DANIEL D. FULLER, MAI
Education
Indian River Community College, Graduated 1967, A/S Degree
Professional Memberships
Member Appraisal Institute (MAI)#7876 - Appraisal Institute
Senior Real Property Appraiser (SRPA) - Appraisal Institute
Senior Residential Appraiser (SRA) - Appraisal Institute
Florida - State Certified General Real Estate Appraiser RZ567
Registered Florida Real Estate Broker
Work Experience
1992 - Pres. President, Fuller-Armfield-Wagner Appraisal & Research, Inc., Fort Pierce, FL
1987 - 1992 Vice President & Partner, Armfield-Wagner Appraisal & Research, Inc., Fort Pierce, FL
1983 - 1987 Staff Appraiser, Armfield-Wagner Appraisal & Research, Inc., Vero Beach, FL
1981 - 1983 Salesman/Appraiser, Florida Licensed Realtor-Associate, Procino Realty, Ft Pierce, FL
1979 - 1983 Staff Appraiser, Harbor Federal Savings and Loan Association, Fort Pierce, FL
1974 - 1979 Staff Appraiser, St. Lucie County Property Appraiser's Office, Fort Pierce, FL
Real Estate Appraisals made for the following:
Accountants PNC Bank
Attorneys Port St. Lucie, City of
Dept. of Natural Resources Regions Bank
Federal Deposit Ins. Corp. Resolution Trust Corporation
Federal Home Loan Bank Board Seacoast Bank
Federal National Mortgage Corp. St. Lucie County
Florida Community Bank South Florida Water Management District
Fort Pierce, City of SunTrust Banks
Centerstate Bank nka SouthState Bank TD Bank
Iberia Bank TITF
Indian River County Vero Beach, City of
Martin County Wells Fargo
Types of Appraisals Completed
Airplane Hangars Offices
Automobile Dealerships Packing Houses
Car Washes Ranches
Commercial Recreational Vehicle Parks
Groves Residential
Industrial Restaurants
Insurable Value Retail Shopping Centers
Land Locked Parcels Service Stations
Mini-Warehouses Subdivision
Motels Warehouses
Multi-Family Wetlands
Vacant Lands
Qualified as Expert Witness
Circuit Court -
St. Lucie County
Martin County
Indian River County
Okeechobee County
Palm Beach County
U.S. Bankruptcy Court -
West Palm Beach District
Accomplishments
Past President - Society of Real Estate Appraisers - Indian River Chapter 211 (1989 - 1990)
Past Instructor - Indian River Community College - Appraising Income Producing Real Estate
Past Board Member - East Florida Chapter of Appraisal Institute