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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, 2020 (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. 20168
FULLER-ARMFIELD-WAGNER Appraisal & Research, Inc.
426 Avenue A, Fort Pierce, Florida 34950
(772) 468-0787 / Fax (772) 468-1103 / Faw_app@bellsouth.net
Daniel D. Fuller, MAI, SRA, State-Certified General Real Estate Appraiser RZ567
December 15, 2020
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 9, 2020 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, 2020. Because the date of appraisal occurs
in the future, December 31, 2020, 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 15, 2020
Page 2 of 2
Based upon the available data and analyses of the data as present in this report, it is my
opinion the Prospective Market Value of mitigation credits within the Bear Point Mitigation
Bank, as of December 31, 2020, is:
• Value of one State credit - $160,000
• Value of one Federal credit - $160,000
• Value of combined (dual) State and Federal credit - $320,000
• Value of 1/10th credit (State or Federal) - $16,000
• Value of 1/10th Dual credit - $32,000
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 #20168
FULLER-ARMFIELD-WAGNER
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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 ......................................................................................................... 15
HIGHEST AND BEST USE ........................................................................................................... 16
EXPOSURE ................................................................................................................................... 16
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 .................................................................................. 24
QUALIFICATIONS OF THE APPRAISER .................................................................................... 27
FULLER-ARMFIELD-WAGNER
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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, 2020 (Prospective appraisal)
• Date of Inspection: December 9, 2019
• Inspected by: Daniel D. Fuller, MAI
• Date of Appraisal Report: December 15, 2020
• Report Prepared: December 2020
• 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 12/09/2020
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 09, 2020 –
2.37 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, 2020 (prospective value):
• Value of one State credit - $160,000
• Value of one Federal credit - $160,000
• Value of combined (dual) State and Federal credit - $320,000
• Value of 1/10th credit (State or Federal - $16,000
• Value of 1/10th Dual credit - $32,000
FULLER-ARMFIELD-WAGNER
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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 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, 2020 (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 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 (DEP) mitigation credits
43.3 Federal (ACOE) mitigation credits
• Remaining Bear Point Credits for sale as of December 9, 2020:
8.1 State (DEP) mitigation credits
7.0 Federal (ACOE) mitigation credits
• CGW Mitigation Bank, Bear Point credits for sale, as of December 9, 2020:
2.37 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
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Since sales of Bear Point mitigation credits have been active, plus mitigation credits sell from
some 90+ 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.
However, research found other than Bear Point, and the adjacent and overlapping CGW
Mitigation bank located in Indian River County, mitigation banks have separate / defined service
areas, also while there is 90+ permitted banks within the state, not all 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 six developed
mitigation banks offering saltwater mitigation credits, 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.
• 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 Corp 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 Corp 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
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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
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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 conc lusions.
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 the 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
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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
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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 19 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
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FULLER-ARMFIELD-WAGNER
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Subject photographed – 12/09/2020
South entrance to Bear Point Mitigation Bank
Typical berm along Indian River, note rock riprap protection from Indian River
FULLER-ARMFIELD-WAGNER
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SW view from berm across Indian River
Typical culvert thru berm w/ water control structure
FULLER-ARMFIELD-WAGNER
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Typical mangrove growth
Waterway within migitation area
FULLER-ARMFIELD-WAGNER
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Area Data
Area Data, in brief:
• The subject is located on the west bank of Hutchinson Island (aka “barrier island”), fronting
the Indian River.
• There are three incorporated cities within St. Lucie County, Fort Pierce, Port St. Lucie, and
St. Lucie Village.
• Fort Pierce is the oldest city with a 2010 census population of 41,590 and 1/2018 US Census
Bureau population estimate of 46,071, an increase of approximately 10% for the seven-years
period (1.4%/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.
• Port St. Lucie was incorporated in the early 1960’s with population in 2010 of 164,603, and
1/2018 US Census Bureau population estimate of 195,248, an increase of approximately
18.6% for the seven-years period (2.7% per year).
• The 2010 census placed the County’s total population at 277,789 with 1/2018 US Census
Bureau population estimate of 321,128, an increase of approximately 15.6% for the seven-
year period (2.2% per year).
• Over the past seven years the population growth within the City of Fort Pierce remained
relatively nominal and growth is expected to continue at a relatively slow pace. The majority
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 70%
developed, plus large acreage tracts in the southwest environs of the City are experiencing
full development mode.
• Demand in most market segments collapsed between late 2005 and early 2007, however,
prior to the Coronavirus pandemic demand returned in most market segments, although
demand varies within the County, as an example, new residential subdivision is financially
feasible within the Tradition neighborhood of Port St. Lucie but generally new subdivision
development within the Fort Pierce city limits and/or within northerly St. Lucie County is at
best marginally financially feasible.
• While from approximately mid 2015 to the 1st quarter of 2020 demand in most real estate
markets within the County strengthened until March 2020 when the Coronavirus pandemic
caused a national economy shutdown. Although with very uncertain data it appears long-
term the pandemic may negatively affect some portions of the commercial market
segments, at least on a national level, including office, retail, and institutional markets.
However, as of the date of appraisal it remains to early into the pandemic to adequately
measure the pandemic’s economic affect. At the same time demand in the residential
markets remains strong, caused by population shifts from multi-family to single family
dwellings, plus migration to the Treasure Coast from northern US regions and south
Florida. The depth of the demand in the residential market is unknown, but the Florida
“snowbird” season is approaching which is typically a boost in residential demand and
likely to occur in the 2020 – 2021 season. Thus, growth within the residential markets is
expected to continue within the city of Port St. Lucie at least for the near term. Residential
growth is positive, boosting demand in all mentioned commercial and other market
segments, however residential growth within he Fort Pierce and neighboring markets is
expected to continue at a modest pace. Industrial growth is most positive for the Fort
Pierce markets which is a positive to the Fort Pierce economy.
FULLER-ARMFIELD-WAGNER
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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.
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 Mosquito
Control to restore the property to obtain mitigation credits for sale. The property received 49.8
mitigation credits from the Department of Environmental Protection (DEP) and 43.3 credits
from the Army Corp of Engineers (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 2020 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 credit: $16,000 or $32,000
Bear Point does not sell less than 1/10th credits.
FULLER-ARMFIELD-WAGNER
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Data provided indicates in 2020 ledger deductions of 0.04, 0.10, 0.05, plus deductions of 0.03
and 0.18 to close by year end of a total of .40 State credits sold thru the CGW Mitigation Bank
with no income for these purchases to Bear Point. Bear Point sold 0.10 State mitigation 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.)
In 2019 data provided indicates in ledger deductions of 0.01, 0.03 and 0.26 State credits
directed by court actions thru the CGW Mitigation Bank with no income for these purchases
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 through CGW Mitigation Bank,
utilizing CGW previously purchased 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 sales for dock mitigations but occasionally they have
experienced larger purchases for development 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.
The following is a summary of income for the Bear Point Mitigation Bank from 2007 – 2020
Year Income to SLC Total Sales Price of Dual Credit
2020 $32,000 $32,000 $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
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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
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.
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. It is noted since 2015 the average annual income has not supported operating
expenses.
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.
Highest and Best Use
Highest and Best Use of the Bear Point Mitigation Bank is the continued sales of mitigation
credits and mosquito impoundment.
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 very slow pace, thus the exposure period
required to sell one credit may require several years.
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Site Map (general area of Bear Point Mitigation Bank in red)
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Bear Point Mitigation Service Area Map
(Arrow indicates subject - Service Area in Green)
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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 buyers’
tendencies can be readily measured and applied to the subject of the appraisal.
Property Appraised
As of December 31, 2020 (Prospective valuation), Bear Point Mitigation Bank credit inventory
is expected to consist of 8.1 DEP credits and 7.0 ACOE credits.
Research discovered an increase in permitted mitigation banks to some 90+ within Florida,
including three new or relatively new banks with mangrove credits for a total of six banks
analyzed, plus the subject, known to offer Mangrove Forested Estuary Credits, and in 2016
one of these banks reportedly sold out of Mangrove Credits within some instances other
credits within the banks allowed some level of offset. However, 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.
Mitigation banks researched and analyzed include –
• CGW Mitigation Bank
• Webster Creek Mitigation Bank
• Everglades Mitigation Banks II
• Little Pine Island Mitigation Bank
• Tampa Bay Mitigation Bank
• Florida Gulf Coast Mitigation Bank
• Nature Coast Mitigation Bank
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.
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The bank is owned and managed by Mr. Craig Chown, with the following data provided by Mr.
Chown. Mr. Chown reports initially the bank was 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. Mr.
Chown did not offer an accurate number of credits sold in 2017 but generally 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. Plus, 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. Plus, in 2020, 0.18 federal credits were sold.
Also, from the CGW inventory of Bear Point credits, 2019, 0.25 state credits and 0.12 federal
credits. In 2020 CGW sold 0.40 state Bear Point credits (including to close before end of 2020,
0.03 and 0.18 credits), but in 2020 zero federal credits were sold. As of 12/31/2020, CGW
Bear Point owned credit balances are 2.37 state credits and 0.976 federal credits.
Mr. Chown previously reported the price of CGW 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 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.
Mr. Chown also reports marketing success by advertising credits at 1/10th price levels as
demand is predominately for 1/10th credits.
The Mitigation Banking firm now handles sales for CGW and Mr. Chown’s Bear Point credits
as of December 2020, personnel indicate CGW pricing remains at $160,00 per credit, as
previously reported.
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 without Army Corp approvals.
In April 2019 credits were awarded thus initial sales are slow. Sales price was initially set at
$300,000 per credit and remains at $300,000 per credit with pro-rated fractional sales.
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 bank is 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 for saltwater mangrove credits slow in recent years,
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,
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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 and remains $120,000. 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 appears to have stabilized within the
bank’s service area with 2020 issues of 1.08 state credits and 0.18 federal credits.
In the past Mr. Sicbaldi reported 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, FPL does
not intend to push the price to the top of the market.
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, but with the purchase of a dual full credit the price remains at $160,000.
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 1/10th or 1/100th credits for
mangrove trimming, etc. but demand was relatively string in 2019.
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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 1/100th credit, and from 0.06 to 0.09 credits the price
is $1,950 per 1/100th 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 bank selling mangrove credits.
Mr. Desmond with “Ecoresolve” also reported for 2020 and into 2021 prices for forested
saltwater credits are increasing to $280,000 per credit or the same per dual credit. Although
not applicable to subject credits, Mr. Desmond reported the banks non-tidal wetlands or
Palustrine classified wetlands, are priced at $170,000 per credit. Federal or state 1/10th credit
each $28,000.
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.
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
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agency), the price remained the same for 2020, $225,000 per credit, except in the background
the seller has been charging a 4% for “depositing” which in 2021 and moving forward will be
included in the fee for new fee of $234,000.
Florida Gulf Coast Mitigation Bank – covers some 1,587.5 acres within Levy County,
Florida, with a large 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 with
.99 credits sold in 2019. Sales in 2020 include 0.23 state saltwater marsh credits and 0.07
federal emergent credits.
Sales prices are a reported $330,000 State or Federal credits with partial credits prorated. For
2020-2021 prices remain at $330,000 per credit or $330,000 for dual credits.
Nature Coast Mitigation Bank – This is a 200.43-acre mitigation bank with 38.29 acres of
upland assessment areas, 146.32 wetland assessment areas, and 14.55 acres of non-
mitigation credit areas consisting of sovereign submerged lands and associated saltmarsh
edge along the river, and 1.27 acres of non-mitigation credit roads.
The total amount of 23.96 UMAM functional wetland credits awarded include 8.69 Freshwater
Forested, 12.71 Estuarine Forested, 2.12 Estuarine Herbaceous, and 0.44 Freshwater
Herbaceous. Freshwater credits to include both forested and herbaceous areas are only
authorized for use within the Upper Coastal watershed portion of the customized service area
for freshwater wetland impacts. Estuarine credits to include both forested and herbaceous
areas can be utilized within the entire customized service area for estuarine wetland impacts.
The mitigation bank is new thus no sales of State or Federal credits occurred in 2019 or 2020.
The reported sales price per Estuarine Forested credits is $300,000 with price proration for
partial credits.
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Summation and Value Conclusion
The mitigation banks researched indicated the following dual and partial credit sales prices
for 2020:
Single Credit 1/10th Credit 1/100 Credit
Bear Point (subject): $160,000 $16,000 not priced
Dual Credit
$320,000 $16,000 not priced
Webster Creek Single Credit
(State Credits) $300,000 $30,000
Single Credit
CGW: $160,000 $16,000 not priced
Dual Credit
$320,000 $32,000 not priced
Single Credit
Everglades II: $100,000 $12,000 $2,000
Dual Credit
$120,000
Single Credit
Little Pine Island: $280,000 $28,000 0.01 - 0 .05 $2,300
Dual Credit 0.06 – 0.09 $1,950
$280,000 $28,000
Dual Credit
Tampa Bay: $234,000 $23,400 $2,340
(County credits = DEP/ACOE credits)
Single Credit
Fla. Gul Coast: $330,000 $33,000 not priced
Dual Credit
$330,000 $33,000 not priced
Single Credit
Nature Coast: $300,000 $30,000 not priced
Dual Credit
$600,000 $60,000 not priced
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 have been instances where
governmental projects require credits, i.e., in very recent years FDOT has been the largest
purchaser from various mitigation banks.
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While demand in most banks increased in recent years, and noticeably demand increased in
most mitigation banks in 2018, historically absorption has been soft, including soft demand in
the Bear Point service area. There are exceptions such as the Tampa Bay Mitigation Bank
and Little Pine Island mitigation banks were demand remains relatively strong, but again, in
the case of Little Pine Island, demand is mostly for 1/10th or 1/100th sales. Although once a
bank is established, owners/developers can expect absorption of credits will require an
extended multi-years period, and it is noted while in recent years new banks have come on-
line, including previously cited Webster Creek, Florida Gulf Coast and Nature Coast banks
but demand for credits have been soft.
In the past mitigation bank managers reported 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, thus economically, purchasing credits from an established mitigation bank becomes
financially feasible especially in the case of purchasing fractional buyers. But also, because
predominately demand is for 1/10th credits, marketing includes 1/10th credit pricing. In 2019,
however, it is noted pricing in the newer mitigation banks has significantly increased to the
$300,000+ per credit range, although managers and mitigation salespersons report there is
room for negotiations.
Finally, 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 has received St. Johns River Water Management
permitting and working towards FDEP and ACOE permitting. Plus, there are another three
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.
Again, while it is also noted prices have increased in new projects, time is required to measure
absorption, and since demand remains soft within Bear Point and other mitigation banks, price
increases at this time are not expected.
It is also noted that in some instances, banks have set minimum price levels for under 1/10th
credit sales, which is considered feasible to offset processing costs while like Bear Point, the
minimum credit for purchase is 1/10th regardless if the customer requires something less than
1/10th of a credit.
It appears, mixed pricing occurs for dual credit pricing with full pricing per credit predominately
occurring in higher demand markets, although in 2020 Bear Point dual credits were priced at
$320,000. Plus, it appears managers are calculating 1/10th pricing based on the full credit
price, no discounts.
In summary, based on the available data, it appears generally Bear Point 2020 pricing was
within the range of market price levels for mangrove forested credits: $160,000 for one credit
(State or Federal), $320,000 for a dual credit, and $16,000 for 1/10th of a credit.
FULLER-ARMFIELD-WAGNER
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It is also noted demand for credits within Bear Point mitigation bank falls in the middle of the
demand range for the mitigation banks analyzed. Demand could be stronger for Bear Point
credits from St. Lucie County’s ownership, but competition is created with the overlap of CGW
Mitigation service into the Bear Point service area, also Mr. Chown, an owner within the
overlapping CGW mitigation bank, holds Bear Point credits for resale, and with strong
marketing Mr. Chown is succeeding in capturing a large percent of the Bear Point market,
plus, development demand within the subject’s service area is not at the same level as found
in Florida’s west coast communities with higher development pace, areas covered by Little
Pine Island and Tampa Bay service areas.
It is also noted in December 2016 real estate investors, and market followers were projecting
demand strengthening in the real estate development markets within the Bear Point Mitigation
Bank service area, however, based on my observations of development demand within the
Bear Point service area, development will continue at a modest pace for 2021, unless
development on remaining vacant Hutchinson Island properties hits a new boom level and/or
new governmental (i.e. FDOT) projects are planned or if FDEP allows sales out of the service
area to support mitigation banks where mangrove credits are sold out.
Finally, again, regardless of the projected 2021 development pace within the Bear Point
service area, in my opinion, as echoed by all mitigation managers, pricing does not appear to
be an issue, especially because predominately demand is for fractional interests. But also,
pricing of dual credits at the level of two credits may not be achievable when demand arrives
for full dual credits but certainly because there is a shortage of Mangrove Forested credits
within the state, an owner of Forested Mangrove credits, in my opinion, hold price levels in
line with similar bank offerings, but expecting price negotiations for dual credits.
Therefore, it is my opinion as of December 31, 2020 the market value price of Bear Point
Mitigation Credits remains as follows:
• Value of one State credit - $160,000
• Value of one Federal credit - $160,000
• Value of combined (dual) State and Federal credit - $320,000
• Value of 1/10th credit (State or Federal) - $16,000
• Value of 1/10th Dual credit - $32,000
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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 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