March 4, 2026
Dear Members of the Planning & Zoning Board,
I am writing to respectfully request that you carefully consider and adopt the environmental safeguards previously recommended by the Alachua County Environmental Protection Department (EPD) in your review of the Tower Hill/Tomoka Hills golf course amendment scheduled for March 10.
This amendment — changing course access from “employees of Tower Hill” to “Tomoka Hills Property Owner Association members and guests” — may appear narrow in scope, but it represents a meaningful operational shift. What was originally presented and approved as a limited employee amenity now opens the door to a far broader membership structure tied to future residential and commercial buildout. That is not a minor technical edit — it is a material change in use intensity.
More concerning is the pattern that has accompanied this proposal from the outset.
At prior hearings and neighborhood meetings, several inconsistencies and shifting representations were documented:
- The golf course was first approved on agricultural land as a relatively simple, stand-alone use, only to later be folded into a larger Planned Development framework.
- Maps presented to residents differed from later submittals, particularly regarding density areas and apartment locations.
- The transition from agriculture to low-density residential was framed as necessary to “support” the golf course, despite earlier statements that the golf course was permissible under existing zoning.
- Traffic and concurrency impacts were revised or recalculated after initial presentations.
- The scope of amenities — including clubhouse elements and residential integration — evolved after prior approvals.
Planning Board Member Burgess rightly described this as feeling “out of order,” and residents characterized it as a “moving target.” When projects are incrementally reshaped after approvals are secured, it undermines both transparency and public trust. It forces the Planning Board to accommodate changes that were not clearly presented at the outset.
That approach is not just frustrating — it is fundamentally unfair to the reviewing body and to the community. Incremental modification after approval is a troubling and, frankly, a dastardly way to conduct large-scale land use proposals. It places decision-makers in a reactive posture instead of allowing for informed, holistic evaluation from the beginning.
Beyond process concerns, the environmental stakes remain high:
- The golf course holds a Consumptive Use Permit for up to 250,000 gallons per day from the Floridan Aquifer.
- The site lies within the Mill Creek Sink watershed, with known rapid connectivity to Hornsby Springs.
- County EPD previously raised concerns about water quality, karst vulnerability, and minimum flow levels not being met in the Lower Santa Fe and Ichetucknee systems.
Given these realities, we respectfully request that the Board require, at minimum:
• Limitation of pond size
• Reduction or elimination of fertilizer use
• Restriction of irrigated areas
• Use of native and Florida-Friendly landscaping
• Automatic leak detection systems (not just flow meters)
• Adoption of drought-resistant planting lists
• Pursuit of Audubon International Certification or equivalent third-party oversight
• Reduction or elimination of fertilizer use
• Restriction of irrigated areas
• Use of native and Florida-Friendly landscaping
• Automatic leak detection systems (not just flow meters)
• Adoption of drought-resistant planting lists
• Pursuit of Audubon International Certification or equivalent third-party oversight
These are reasonable, science-based safeguards aligned with the City’s own conservation goals.
The Planning & Zoning Board serves as the community’s first line of defense in ensuring that land use changes are transparent, consistent, and protective of public resources. When project elements evolve after approvals are granted, it becomes even more important that the Board insist on clarity, accountability, and enforceable conditions.
Please treat this amendment not as a minor wording correction, but as an opportunity to restore integrity to the review process and to require meaningful environmental protections.
Thank you for your service and for your thoughtful consideration.
Respectfully,
Sierra Club Suwannee-St Johns Group
Executive Committee