Selling Florida Keys Land: ROGO, Tiers & Options

Updated October 28, 2026 by SWFL Land

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Selling vacant land in the Florida Keys comes down to three questions: which government controls the lot, whether it has or can get a building allocation, and what habitat tier it is in. Those answers decide who will buy the lot and what they will pay. Your main options are selling to a public buyer such as the Monroe County Land Authority, listing with an agent, selling to a neighbor, or selling to a cash buyer. This guide explains the rules behind each option.

This guide is general information, not legal, tax or financial advice. Keys land rules change often. Confirm details with the county or city, a Florida real estate attorney or a land use professional before you make a decision.

Why Is Keys Land Different From the Rest of Florida?

The Florida Keys are a state-designated Area of Critical State Concern. Florida Statute 380.0552 ratifies that designation, and its stated intent is to “establish a land use management system that protects the natural environment of the Florida Keys.” The Village of Islamorada notes that the Keys area was first designated in 1974.

Two parts of the statute matter most to a lot owner:

State approval of local rules. Land development regulations and comprehensive plan changes in the Keys take effect only after the state land planning agency (FloridaCommerce) approves them. The agency must act within 60 days.
A growth cap tied to evacuation. Growth is limited by keeping the hurricane evacuation clearance time for permanent residents at no more than 24.5 hours. Every new home adds to that clearance time, so the number of new homes is rationed.

The result is that a vacant lot zoned for a house is not automatically buildable. A new home needs an allocation, and allocations are limited.

Who Controls Your Lot?

Monroe County has five incorporated municipalities: Islamorada, Key Colony Beach, Key West (the county seat), Layton and Marathon. Everything else is unincorporated and governed directly by the county, which handles building permits and code enforcement there. The county also includes a mostly uninhabited mainland area within Everglades National Park and Big Cypress National Preserve.

Unincorporated Monroe County: includes Key Largo, Tavernier, Big Pine Key, Summerland Key, Cudjoe Key, Sugarloaf Key, Ramrod Key, Little Torch Key, Big Coppitt, Stock Island, Duck Key and Conch Key.
Islamorada: Plantation, Windley, Upper Matecumbe, Lower Matecumbe and Tea Table Keys, from about MM 72.5 to MM 90.8.
Marathon: from about MM 47 to MM 61, excluding Key Colony Beach.
Key Colony Beach: at MM 53.5, a separate city.
Layton: on Long Key at MM 68.5.
Key West: MM 0 to about 4. Key West also has its own separate Area of Critical State Concern designation.

Your lot’s jurisdiction determines which allocation system it competes in.

How Do ROGO, NROGO and BPAS Work?

ROGO and NROGO in Unincorporated Monroe County

Unincorporated Monroe County uses ROGO, the Rate of Growth Ordinance, for residential construction and NROGO for nonresidential. The county describes both as “competitive permit allocation systems where those applications with the highest scores are awarded building permits.” Details are in Chapter 138 of the county’s Land Development Code.

Each ROGO year has four quarters. Year 34 ran from July 15, 2025 to July 13, 2026. Points favor infill areas with infrastructure and penalize velocity zones and sensitive habitat. Examples from the county’s point table:

Tier III: up to +30
Central sewer: +4
Land dedication: up to +5
Perseverance points, which accrue each year an application stays in the system
Key Deer Corridor: -10
V-zone structure: -6
CBRS unit: -4

BPAS in Key West, Islamorada and Marathon

The three larger cities each run a Building Permit Allocation System. Key West’s BPAS is in Year 14 (2026 to 2027) and takes separate market-rate and affordable applications. Islamorada calls its BPAS “Islamorada’s version of Monroe County’s ROGO,” with quarterly cycles. Islamorada reports 7 market-rate allocations in 2024, 2 in 2025 and 1 in 2026, and states: “When all allocations are awarded, no building permits will be issued for new construction on VACANT land.” Marathon also uses BPAS.

What Did Senate Bill 180 Change?

Senate Bill 180 (2025) raised the evacuation clearance time limit from 24 to 24.5 hours, which made up to 900 new allocations possible across the Keys. Key points from local reporting:

Allocations are awarded over at least 10 years, one per parcel.
Priority goes to owner-occupied, affordable and workforce housing.
Monroe County expected to receive about 588 and to issue about 40 a year.
On Dec. 17, 2025, the Governor and Cabinet, sitting as the Administration Commission, unanimously approved the distribution: 300 allocations released Jan. 1, 2026, then 150 every two years through 2035, pro-rata among Monroe County, Islamorada, Marathon and Key West.

Separately, county ROGO allocations were set to run out in July 2026, and county staff recommended using 62 set-aside administrative relief allocations to keep issuing permits through July 2027.

How many lots are competing? A state report cited 7,954 vacant lots Keys-wide. In March 2024, the county estimated only about 3,000 were buildable: about 2,200 unincorporated, about 550 in Marathon, about 200 in Islamorada and about 84 in Key West. No official source publishes an expected wait time for an allocation, and you should be cautious of anyone who quotes one as fact.

What Is the Tier System?

Monroe County assigned habitat tiers to parcels in 2005 and 2006:

Tier I: environmentally sensitive land.
Tier II: a transition or sprawl-reduction area, found only on Big Pine Key and No Name Key.
Tier III-A: a special protection area.
Tier III: infill, meaning platted subdivisions that are at least half built and have infrastructure.

You can look up your parcel’s tier with the county’s Tier Overlay property search, linked from the county’s Tier System page. Because Tier III earns up to 30 ROGO points, tier is one of the biggest factors in whether a lot in unincorporated Monroe County can realistically be built on.

What Is Administrative Relief?

Administrative relief is a process for owners whose allocation applications have not succeeded over a long period. Here is what we could verify:

A state rule, Florida Administrative Code Rule 28-20.140, requires the county and Land Authority to report each year on acquiring Tier I lands, Big Pine Tier II lands and “parcels where a Monroe County building permit allocation has been denied for four (4) years or more.”
The county’s comprehensive plan holds unused ROGO allocations “only for affordable housing and Administrative Relief.”
The Land Authority’s 2026 Acquisition List includes a category for “Property Eligible for ROGO Administrative Relief.”
Islamorada has adopted administrative relief resolutions that grant a “Building Permit Allocation” after finding the owner is entitled to “beneficial use.”

We could not verify the exact eligibility timeline in the county code, or whether the county’s remedy in a given case is a purchase offer or an allocation. Talk to a Florida land use attorney before relying on administrative relief.

Some owners consider a takings claim. According to Keys Weekly, the county has faced 58 takings-related cases since 1987 and lost five, which cost more than $6.8 million in total. Those are legal disputes with their own costs and risks.

Who Buys Keys Land Besides Private Buyers?

The Monroe County Land Authority

The Monroe County Comprehensive Plan Land Authority was created in 1986 under Florida Statute 380.0663. It serves “as an intermediary between landowners and the governmental entities that regulate land use.” It buys land for conservation, affordable housing and property-rights protection, through programs that include Less Than Fee, Density Reduction and Re-Sale. It is funded by a half-cent of the tourist impact tax and state park surcharges. Contact: 1200 Truman Ave., Suite 207, Key West; 305-295-5180.

Its 2026 Acquisition List, approved Dec. 17, 2025, prioritizes Tier I, II and III-A properties, especially within the Big Pine HCP area. The Land Authority Advisory Committee packet for Jan. 29, 2026 listed these contracts:

Little Torch Key, Tier I, 6,000 sq ft: $12,500 ($25,000 per ROGO point)
Big Pine Key, Tier I, 4.23 acres: $270,000 ($16,875 per ROGO point)
Sugarloaf Key, Tier I, one lot: $95,000
Summerland Key, Tier I, two lots: $220,000
Largo Beach, Tier III, 12,100 sq ft: $380,000

These are individual contracts, not market averages. No official source publishes an average Keys lot price.

The Density Reduction Program

Under Resolution 445-2021, the county buys residential development rights from willing sellers, typically on Tier III parcels with at least one transferable development right (TDR), and retires the right to build.

Florida Forever

The Florida Keys Stewardship Act (2016) sets aside $5 million a year from Florida Forever for Keys land acquisition. Between July 2016 and September 2024, 556 development rights were retired: 372 by the county, 162 by the Florida Department of Environmental Protection and 22 by FloridaCommerce.

What Is Different About Big Pine Key and No Name Key?

Big Pine and No Name Key are the only Tier II areas, and Tier III-A does not exist there. The National Key Deer Refuge was established in 1957 and covers about 9,200 acres. The Key deer is endangered.

In June 2006, the US Fish and Wildlife Service approved a Habitat Conservation Plan covering about 7,000 acres on the two islands, protecting the Key deer, the Lower Keys marsh rabbit and the eastern indigo snake. The related Incidental Take Permit expired June 30, 2026. Since July 1, 2026, permits are reviewed through the county’s Permit Referral Process under a 2010 FEMA/NFIP Biological Opinion. According to local reporting, the 3-to-1 mitigation requirement and the cumulative impact cap continue, and the maximum number of new residential units under the program rose from 200 to 236. ROGO also penalizes the Key Deer Corridor (-10) and No Name Key.

How Do Flood Zones Affect Keys Land?

New buildings must be elevated above flood levels, and under the 50% rule, substantially improved or damaged buildings must also be elevated. Monroe County’s minimums under ASCE 24-14:

Zone A: lowest floor at least base flood elevation (BFE) plus 1 ft.
Zone V and Coastal A: lowest horizontal structural member at least BFE plus 1 ft.
Enclosures below BFE: limited to access, limited storage and parking.

Cities may set stricter rules. Key Colony Beach, for example, is entirely in the Special Flood Hazard Area (AE and VE zones), with BFEs of 6 to 13 ft (NGVD29), and requires 3 ft of freeboard. Look up any lot’s zone on FEMA’s Map Service Center. Hurricane Irma made landfall on Cudjoe Key on Sept. 10, 2017 at 9:10 a.m. as a 130 mph Category 4, a reminder of why buyers focus on elevation.

How Do You Look Up a Keys Parcel?

Monroe County Property Appraiser (mcpafl.org; 500 Whitehead St., Key West; 305-292-3420): Property Search, GIS maps and a Tax Estimator. Record cards show a Parcel ID (format 00526340-000000) and an Account# or Property ID, the alternate key.
Tier Overlay search: linked from the county’s Tier System page.
Monroe County Tax Collector (monroetaxcollector.com): offices open Monday to Friday, 8:00 to 4:45, and the Big Pine Key office Tuesday to Thursday.
Clerk of Court: Official Records search for deeds, mortgages and liens; tax deed auctions; offices in Key West (500 Whitehead St.), Marathon (3117 Overseas Hwy) and Plantation Key (88770 Overseas Hwy, Tavernier).
MCeSearch (mcesearch.monroecounty-fl.gov): permit history by property for unincorporated Monroe County.
FEMA Map Service Center (msc.fema.gov): flood zones.

For a full list, see our Florida land due diligence checklist.

What Happens if You Fall Behind on Taxes?

In Monroe County, property taxes become payable each year on Nov. 1 and are delinquent as of April 1. Under Florida’s tax certificate system in Chapter 197, unpaid taxes can lead to a tax certificate being sold on the parcel. A certificate holder may apply for a tax deed “at any time after 2 years have elapsed since April 1 of the year of issuance.” Tax deed sales in Monroe County are held through the Clerk’s online auction site. If you are behind, read selling land with back taxes. If your land already sold at a tax deed sale, see Florida tax deed surplus funds.

What Are Your Options to Sell?

Option	Best fit	Things to weigh
Monroe County Land Authority or other public buyer	Tier I, Tier II and Tier III-A land, especially in the Big Pine HCP area; parcels eligible for administrative relief	Purchases depend on program priorities and funding; contact the Land Authority directly to ask about your parcel
Sell development rights (TDRs or ROGO exemption)	Lots that carry a transferable right	You may keep or sell the land separately; program rules apply
List with a real estate agent	Tier III lots with an allocation, permit or strong building path	Commission and listing time; buyers will ask about allocation status
Sell to a neighbor	Lots next to an existing home or a neighbor’s land	Limited pool of buyers; you handle the negotiation
Sell to a cash buyer	Any tier or status, inherited lots, tax-delinquent lots, owners out of state	Price reflects the lot as-is; no commission; compare more than one offer

A cash buyer like SWFL Land (Libera Capital Group LLC) makes written offers, usually within 24 hours, and closes through licensed Florida title companies. We buy lots with approved permits, permits in review or completed plans, and lots with no permits at all. A public buyer may pay more for certain Tier I parcels, and an agent may get more for a buildable Tier III lot with an allocation. Comparing options is the best way to decide. Our article on land exit strategies goes deeper, and how to comp vacant land explains pricing.

Florida Keys Land FAQs

What is ROGO in the Florida Keys?

ROGO is Monroe County’s Rate of Growth Ordinance, a competitive scoring system that awards residential building allocations in unincorporated Monroe County.

Is BPAS the same as ROGO?

They serve the same purpose. Key West, Islamorada and Marathon each run their own Building Permit Allocation System instead of the county’s ROGO.

How do I find my lot’s tier?

Use the Tier Overlay property search linked from Monroe County’s Tier System page.

How long is the wait for a building allocation?

No official source publishes a wait time. It depends on your jurisdiction, score and the number of allocations released.

Will the Land Authority buy my lot?

It depends on its priorities. The 2026 Acquisition List prioritizes Tier I, II and III-A land, especially in the Big Pine HCP area. Contact the Land Authority at 305-295-5180.

How many new allocations did SB 180 create?

Up to 900 Keys-wide, released starting with 300 on Jan. 1, 2026, then 150 every two years through 2035.

Can I sell a Keys lot with no allocation?

Yes. A lot does not need an allocation to be sold, but buyers will price it based on its allocation status. SWFL Land buys lots with or without one. Request a cash offer.

Where can I learn more about selling land in the Keys?

See our Florida Keys (Monroe County) page. Wholesalers can visit our Monroe County wholesaler page, and more guides are in the Land Resource Center.

Selling Vacant Land in the Florida Keys: ROGO, Tiers and Your Options