By Natallie Liz, REALTOR® | Island Welcome Real Estate
If you have ever looked at a vacant lot in the Florida Keys and wondered why you can't simply buy it and start building, you have already met ROGO and BPAS.
They sound more complicated than they are. I was born and raised in Key West and spent 25 years teaching in Monroe County public schools, so let me explain them the way I would at the whiteboard: one idea at a time.
And there is real news this year. Monroe County's ROGO system is changing, so even people who knew the old rules should take a fresh look.
What ROGO and BPAS mean
ROGO stands for Rate of Growth Ordinance. BPAS stands for Building Permit Allocation System. Which name you hear depends on where the property sits:
- Unincorporated Monroe County uses ROGO.
- Key West, Marathon and Islamorada each run their own BPAS. Islamorada describes its BPAS as the equivalent of the county's ROGO, and Key West notes that its system is sometimes called ROGO too.
The simplest way to think about it: new homes in the Keys are rationed. To build a new residential unit, you generally need an allocation, and allocations are limited in number. Monroe County, Marathon and Islamorada all score applications, so a higher score generally means a better position in line.
Why the Keys have these limits
The Florida Legislature designated the Keys an Area of Critical State Concern in 1974, citing environmental sensitivity and development pressure. A big part of that framework is hurricane evacuation. Monroe County describes its carrying capacity in terms of the time needed to evacuate safely, based on a 24-hour model.
The limits are tied to how many people can get up one highway before a storm, and to protecting the land and water around us.
How scoring works in Monroe County
ROGO is competitive. The county says its point system steers development toward areas with infrastructure and away from velocity zones and environmentally sensitive land. A few examples from the county's currently posted criteria:
- Plus 4 points where a central wastewater system is available.
- Minus 6 points for a structure in a "V" flood zone.
- Perseverance points for staying in the system over time. These vary by the property's tier, which is the county's land classification.
- Extra negative points for certain habitat areas, including development in the Key Deer Corridor and on No Name Key.
Treat those as examples, not a calculator. The county has said the coming amendments will change the allocation periods and the process, so the details may shift.
Where things stand right now
Unincorporated Monroe County: paused until a new pool opens
July 13, 2026 was the closing date for the final quarter of the current pool of market-rate ROGO allocations. The county is now amending its Comprehensive Plan and Land Development Code to accept and distribute a new pool of 657 allocations, authorized by Chapter 2023-17, Laws of Florida.
The county anticipates the next allocation period will open July 13, 2027, though it notes the amendments are still in process. Building permit applications for new market-rate homes are still being accepted and reviewed, but a ROGO application cannot be submitted until the new period starts. Approved permit applications will be held until then.
Key West: a very small number of units
Key West's system dates to 1993. The state later granted 91 new units for annual allocation through July 2023. The city has posted materials for its Year 14 application cycle for 2026-2027, and its planning staff offers pre-application meetings.
Key West also lists possible paths outside BPAS: a Beneficial Use Determination for eligible vacant lots, a Lawful Unit Determination for housing established before the 2010 Census, and Transferable Development Rights for transient units or licenses.
Marathon: two rounds a year
Marathon says all new residential structures must obtain a BPAS allocation. Awards happen twice a year, in periods ending January 13 and July 13. The city's current schedule shows 12 total allocations in even years and 15 in odd years. Market-rate allocations are split between general and owner-occupied pools, and affordable allocations are counted separately.
Islamorada: few market-rate awards
Islamorada's BPAS has separate market-rate, affordable and nonresidential categories, with the highest scores receiving allocations first. On the Village's posted schedule for 2025 and 2026, many quarters list only affordable and nonresidential allocations, and the quarters with market-rate awards show just one. The Village also states that once all allocations are awarded, no building permits will be issued for new construction on vacant land.
What to check before you buy a vacant lot
Before you fall for the view, here is what I would look into:
- Confirm the jurisdiction. Different government, different rules. If the lot is in another municipality, such as Key Colony Beach or Layton, call that city directly.
- Ask about allocation status in writing. Has this lot received an allocation? Is a permit or application attached? Don't rely on a listing description alone.
- Look at what affects the score. Ask the planning office about tier, flood zone, habitat and wastewater, and request the current score sheet.
- Be realistic about time. There may be years between buying and breaking ground, and no one can promise you an allocation.
- Compare your other options. Sometimes buying an existing home, or a property with a lawfully established unit, fits your goals better than waiting. A land use attorney can review what applies to a specific property.
- Talk to the planners first. They are the ones who can speak to that parcel.
A quick reminder from me: I am a REALTOR®, not an attorney, lender, tax advisor or insurance agent. This is general information. Please consult those professionals, along with the county or city planning office, before you make a decision.
Frequently asked questions
If I buy a vacant lot in the Keys, can I build on it?
Not automatically. New residential units generally need a limited, competitive allocation through ROGO or BPAS. Check the lot's status with the local planning office before you commit.
Does ROGO apply if I repair or replace an existing home?
Monroe County's April 2026 notice said its June permit deadline for the final ROGO quarter did not include repair or replacement of existing dwelling units. Whether a specific unit is treated as existing is a question for the county's planning staff.
When does the next Monroe County ROGO period open?
The county anticipates July 13, 2027, but the amendments are still in process and the date could change. Check the county's ROGO page for updates.
Official pages to bookmark
Let's talk it through
I know these islands like family, and I am glad to help you figure out which questions to ask. If you are curious about what you own, start with what's my home worth. If you would rather see what is available, you can search homes here. Or reach me directly at (305) 879-7658 or [email protected].
ROGO, BPAS and related rules, dates and allocation numbers can change, so please verify all details with the appropriate county or city office.
Natallie Liz, REALTOR® | Island Welcome Real Estate | (305) 879-7658
