Loading...
HomeMy WebLinkAboutSubmittal Community Affairs ReviewJEB BUSH Governor AD - STATE OF FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS "Dedicated to making Florida a better place to call home" MEMORANDUM TO: Lindy McDowell, DEP Susan Harp, DOS Gary Donn, FDOT 6 Terry Manning, South Florida RPC P.K. Sharma , South Florida WMD Emily Crump, AG Mary Ann Poole, FWC Date: February 23, 2006 Thaddeus L. Cohen Seactruy SUBMITTED INTO THE PUBLIC RECORD FOR ITENI_Si.bON iia-oc . Subject: Proposed Comprehensive Plan Amendment Review Objections, Recommendations and Comments Reports Enclosed are the Departments Objection, Recommendations and Comments Reports on the proposed amendments to the comprehensive plan(s) from the following local government(s): Miami -Dade Co. 06-1 These reports are provided for your information and agency files. Following the adoption of the amendments by the local governments and subsequent compliance review to be conducted by this agency, we will forward copies of the Notices of Intent published by each local government plan. If you have any questions, please contact Mr. Ray Eubanks at Suncom 278-4925 or (850) 488-4925. RE/ts Enclosure 2555 SHUMARD OAK BOULEVARD TALLAHASSEE, FLORIDA 3 23 99-2100 Phone: 850.488.8466/Suncom 278.8466 FAX: 850.921.0781/Suncom 291.0781 Internet address: httn://www.dca.state.fl.us CRITICAL STATE CONCERN FIELD OFFICE 2796 Overseas Highway, Suite 212 Marathon, FL 33050-2227 (305) 289-2402 1 COMMUNITY PLANNING 2555 Shumard Oak Boulevard Tallahassee, FL 32399-2100 (850) 488.2356 EMERGENCY MANAGEMENT 2555 Shumard Oak Boulevard Tallahassee, FL 32399.2100 (850) 413-9969 HOUSING & COMMUNITY DEVELOPMENT 2555 Shurnard Oak Boulevard Tallahassee, FL 32399-2100 (850)488.7956 - 043.23 fcc 04 — d4393 Z- j DG— Dd3,3 p14 4F STATE OF FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS "Dedicated to making Florida a better place to call home" JED BUSH THADDEUS L. COHEN, AIA Govornor Secretary February 20, 2006 The Honorable Carlos Alvarez Mayor, Miami -Dade County 111 N.W. 1M Street Miami, Florida 33128 Dear Mayor Alvarez: The Department has completed its review of the proposed Comprehensive Plan Amendment for the Miami -Dade County (DCA No. 06-1), which was received on December 21, 2005. Copies of the proposed amendment have been distributed to appropriate state, regional, and local agencies for their review and their comments are enclosed. „SUBMITTED INTO THE PUBLIC RECORD FOR ITEM: �� ON • The Departinent has reviewed the comprehensive plan amendment for consistency with Rule 9J- 5, Florida Administrative Code (F.A.C.) and Chapter 163, Part II, Florida Statutes (F.S.) and has prepared the attached Objections, Recommendations, and Comments (ORC) Report which outlines our findings concerning the comprehensive plan amendment. The issues identified in the report concern facilities analysis, such as water supply and transportation and internal inconsistency with existing comprehensive plan policies regarding moving the Urban Development Boundary. Additionally, many of the amendments are inconsistent with Chapter 163, Florida Statutes, Chapter 187, Florida Statutes, Rule 91-5, Florida Administrative Code and the' South Florida Strategic Regional Policy Plan. If you have any questions about this ORC report or the Department's position, please contact Paul Darst, Senior Planner, at (850) 922-1764. Sincerely, Roger Wilburn 1/. Regional Planning Administrator RW/pds Enclosures: , Objections, Recommendations and Comments Report - Review Agency Comments cc: Ms. Diane 0' Quinn Williams, Director, Department of Planning and Zoning Ms. Carolyn A. Delde, Executive Director, South Florida Regional Planning Council 2555 SHUMARD OAK BOULEVARD • TALLAHASSEE, FLORIDA 32399-2100 Phone: 850.488.8468/Suncom 278.8466 FAX: 850.921.0781/Suncom 291.0781 Internet address: htta://www.dca,state.fl.us CRITICAL STATE CONCERN FIELD OFFICE COMMUNITY PLANNING EMERGENCY MANAGEMENT HOUSING a COMMUNITY DEVELOPMENT 2798 Overseas tfptavay. Stile 212 2555 SMmurd Oak Boulevard 2555 shamed Oak Boulevard 2555 Slumlord Oak Boulevard Marathon, FL 33050-2227 Tallahassee, FL 32379-2100 Tallahassee. FL 32399-2100 Tallahassee. FL 32390.2100 (305)280.2402 (650)488-2356 1650)413-0969 (850)488-7958 DEPARTMENT OF COMMUNITY AFFAIRS OBJECTIONS, RECOMMENDATIONS AND COMMENTS REPORT FOR MIAMI DADE COUNTY AMENDMENT 06-1 SUBMITTED INTO THE FUBLIC RECORD FOR ITEM 17:'15-1 ON Il-oq-os. February 20, 2006 Division of Community Planning This report is prepared pursuant to Rule 9J-11.010, F.A.C. Introduction The following objections, recommendations and comments are based upon the Department's review of the Miami -Dade County 06-1 proposed Comprehensive Plan Amendment pursuant to Section 163.3184, F.S. Objections relate to specific requirements of relevant portions of Chapter 9J-5, F.A.C., and Chapter 163, Part 11, F.S. Each objection includes a recommendation of one approach that might be taken to address the.cited objection. Other approaches may be more suitable in specific situations. Some of these objections may have been raised initially by one of the other external review agencies. If there is a difference between the Department's objection and the external agency advisory objection or comment, the Department's objection would take precedence. The County should address each of these objections when the amendment is resubmitted for our compliance review. Objections which are not addressed may result in a determination that the amendment is not in compliance. The Department may have raised an objection regarding missing data and analysis, items which the City considers not to be applicable to its amendment. If that is the case, a statement justifying its non -applicability pursuant to Rule 9J-S.002(2), F.A.C., must be submitted. The Department will make a determination as to the non -applicability of the requirement, and if the justification is sufficient, the objection will be considered addressed. The comments which follow the objections and recommendations are advisory in nature. Comments will not form a basis for determination of non-compliance. They are included to call attention to items raised by our reviewers. The comments can be substantive, concerning planning principles, methodology or logic, as well as editorial in nature dealing with grammar, organization, mapping, and - reader comprehension. Appended to the back of the Department's report are the comment letters from the other state review agencies, other agencies, organizations and individuals. These comments are advisory to the Department and may not form a basis for Departmental objections unless they appear under the "Objections" heading in this report. SUBMITTED INTO THE PUBLIC RECORD FOR I. CONSISTENCY WITH CHAPTER 163, F.S., AND RULES 9J-5 8c 9J-11, F.A.C. The Department has completed its review of the propo INTO THE Amendment 06-1 and has the following objections and co en PUi3LIC„RECORD FOR ITEM l(ofiIS ON OBJECTIONS NON -AVAILABILITY OF POTABLE WATER SUPPLY The Department objects to all seventeen of the proposed Miami -Dade County land use amendments (Applications Nos. 1, 2, 3, 4, 5, 6, 7, 10, 11, 13, 15, 17, 20, 21, 22, 23, and 24) because they are not supported by an adequate potable water supply analysis. The total increased potable demand from the applications in Amendment 06-1 is estimated at approximately 3.1 million gallons a day. The Countyst demonstrate that it has available potable water supply to serve this increased demand. Until this is done it would be inappropriate to approve land use changes to the comprehensive elan which would entail increased water consumptior,The amendment also does not address any changes in the Capital Improvements Element that may be needed to provide for the facility enhancements to serve the proposed land use changes. The Department has received reports on Amendment 06-1 from the Florida Department of Environmental Protection (DEP) and the South Florida Water Management District (SFWMD or District) concerning water availabilityinM_ami- Dade Coun . According to the District's report, the County as applied for a consolidated 20-year consumptive use permit for all of its wellfields, which is currently being processed by the District; however. data available to the District indicate.thalt traditional water supply sources will not..adequate to meet the County's future water supply needs. In order for the County to get a permit to meet increased demands, it will be necessary for the County to meet the criteria for issuance, including identifying and implementing effective alternative water supplies. The District's report states that i t this point in time the County cannot demonstrate that there are adequate water supplies to serve the cumulative evelopment proposed in the 06-1 Amendment. Adoption of the land use amendments in the absence of an assured water supply and necessary facilities would also be internally inconsistent with existing Miami - Dade County policy requiring coordination between future land uses, the availability of water, and necessary capital improvements, as expressed in CDMP Water and Sewer Sub -Element Objective 1 and Policy 1B, Objective 2 and Policy 2B, Policy 3B, and Objectives 5 and 6. Citations Florida Statutes: ss. 163.3161(3);" 163.3167(13); 163.3177(6)(a), (c), (d), and (h)1; and 163.3180(2)(a). Florida Administrative Code: Rules 9J-5.005(2) and (5); 9J-5.006(3)(b)1; 9J- 5.006(3)(c)3; 9J-5.011(1)(a) and (f); 9J-5.011(2)(b)2; 9J-5.011(2)(c)1; 9J-5.016(1)(a); 9J-5.016(2)(b), (c), and (f); 9J-5.016(3)(b)1, 3, and 5; 9J-5.016(3)(c)1.d, e, f, and g; and 9J-5.016(4)(a). Recommendations The County should not adopt the proposed land use changes until it can demonstrate the necessary coordination of land use approvals with an assured supply of potable water. Revise the amendments to demonstrate coordination of the proposed land use changes with the planning and provision of potable water supplies. Identify any needed facility improvements for the 5- and 10-year planning time frame. These improvements should be coordinated with the Water, Sewer, and Solid Waste Element and the Capital Improvements Element, including implementation through the 5-year schedule of capital improvements for any facilities needed during that time frame. Additionally, demonstrate that the proposed land use changes are consistent with the CDMP objectives and policies cited above. INTERNAL INCONSISTENCY WITH THE COMPREHENSIVE PLAN, MOVING THE URBAN DEVELOPMENT BOUNDARY The Department objects to the nine proposed Miami -Dade County land use amendments (Nos. 5, 6, 7, 10, 11, 13, 17, 23, and 24) which are outside the Urban Development Boundary (UDB) because they are not internally consistent with the Miami -Dade County Comprehensive Development Master Plan (CDMP), specifically Land Use Element Policies 8G, 8H, and 3E and Conservation Element Policy 3E. In order to accommodate the urban developments proposed in these amendments, .it would be necessary for the Urban Development Boundary in the CDMP to be expanded to encompass the amendment sites. Miami -Dade County's policy • . . regarding movement of the UDB is established in Land Use Element Policies 8G and 8H. (Note that Land Use Element Policy 8G was renumbered as Policy 8F in recently adopted Amendment 05-2ER, and, similarly, Land Use Element Policy 8H was renumbered as Policy 8G; however, for purposes of consistency with the amendment package and the correspondence received, the older designations 8G and 8H will be used in this ORC report.) Policy 8G provides guidance on the potential development capacity that should be available within the UDB, and it addresses how demand and land supply for residential and nonresidential uses are determined. SUBMITTED INTO THE 2 PUBLIC ECORD FOR ITEM/:r/q or1_oo, For residential land use, Land Use Element Policy 8G states that the UDB should contain developable land having capacity to sustain projected countywide residential demand for a period of 10 years after adoption of the most recent Evaluation and Appraisal Report (EAR), plus a 5-year surplus (a total 15-year Countywide supply beyond the date of the most recent EAR adoption in 2003, thus extending the date to 2018). The transmitted Amendment 06-1 package includes the Miami -Dade County staff analysis, which concludes that the present boundaries of the UDB contain sufficient developable land to satisfy residential demand for the next 15 years. Therefore Applications No. 7, 10, 11, 13, 17, 23, and 24, because of their proposed or allowed residential uses, do not meet the requirements of Land Use Element Policy 8G for expanding the UDB, and their adoption would be inconsistent with Policy 8G. For non-residential land uses, Land Use Element Policy 8G states that the adequacy of nonresidential land supplies shall be determined on the basis of land supplies in subareas of the County appropriate to the type of use, as well as the Countywide supply within the UDB. The adequacy of land supplies for neighborhood- and community -oriented business and office uses shall be determined on the basis of locali7Pd subarea geography such as Census Tracts, Minor Statistical Areas (MSAs) and combinations thereof. Tiers, Half -Tiers and combinations. thereof shall be considered along with the Countywide supply when. evaluating the adequacy of land supplies for regional commercial and industrial activities. The Miami -Dade County staff analysis concludes that the present boundaries of the UDB contain adequate non-residential land supplies, according to the requirements of Land Use Policy 8G. Therefore Applications 5, 6, 7, 11, 17, 23, and 24 do not meet the requirements of Land Use Element Policy 8G for expanding the UDB, and their adoption would be inconsistent with Policy 8G. Land Use Element Policy 8H specifies that certain specified areas shall either not be considered for addition to the UDB or shall be avoided for addition to the UDB. Certain other areas shall be given priority for inclusion after demonstrating that a countywide need exists, in accordance with Policy LU-8G. Application 17 is located within the Redland area south of Eureka Drive, an area that shall not be considered when considering land areas to add to the UDB. Applications 6, 7, and 10 are located within Future Wetlands delineated in the Conservation and Land Use Element, areas that shall be avoided when considering land areas to add to the UDB. Applications 10, 11, 13, 17, 23, and 24 are located within lands designated Agriculture on the Land Use Plan Map, areas that shall be avoided when considering land areas to add to the UDB. The Department objects to these applications, which are in areas that shall not be considered or in areas that shall be avoided for addition to the UDB, because their addition to the UDB would be inconsistent with Land Use Element Policy 8H. su E M I TT E D i N TO TH E PUBLIC RECORD FOR ITEM IbYlll ON 11-0/ �06 Application 17 contains an accompanying text amendment which would revise Land Use Policy 8H(i)(c) by removing the Redland area south of Eureka Drive. The proposed text amendment portion of Application 17 is inconsistent with CDMP Land Use Element Policy 1R, which requires that Miami -Dade County take steps to reserve the amount of land necessary to maintain an economically viable agricultural industry, . and with Land Use Element Policy 10, which requires that Miami -Dade County shall seek to prevent discontinuous, scattered development at the urban fringe particularly in the Agriculture Areas, through its CDMP amendment process. In the absence of supporting data and analysis indicating that the Application 17 text amendment is consistent with the aforementioned policies, The Department finds the text amendment to be internally inconsistent with the CDMP and inconsistent with Chapter 163, F.S., Rule 9J-5, F.A.C., and the State Comprehensive Plan. The Department objects to Applications 23 and 24 because they are not internally consistent with the Miami -Dade County Comprehensive Plan and in particular Land Use Element Policy 3E. Policy 3E established the South Miami -Dade County Watershed Study and Plan. The Watershed Study is a collaborative effort of Miami - Dade County, SFRPC, and SFWMD. The purpose of the Watershed Study is to provide a wide-ranging analysis of population growth, infrastructure, land ownership (including agricultural, industrial, and urban land uses), pollution, water resources, wildlife, and natural areas. A primary goal of the study is to protect Biscayne Bay and Biscayne National Park. Pursuant to CDMP Land Use Element Policy 3E, until the Watershed Study is approved (originally expected by 1 January 2006; however, the expected completion date is now March 2006) a Miami -Dade County BOCC-appointed review committee (the Biscayne National Park Buffer Development Review Committee) will evaluate and make recommendations on all requested development proposals and CDMP amendments in the Study Area east of US Highway 1 and outside the UDB. Among the separate applications making up Amendment 06-1, only Applications 23 and 24 (both located within the City of Homestead) are within this circumscribed area. Application 23 was reviewed by the Buffer Development Review Committee, which recommended to the County Commission that Application 23 be denied and not transmitted to the DCA. Application 24 was reviewed by the Buffer Development Review Committee, which recommended to the County Commission that Application 24 be denied but transmitted to the DCA. The Department understands the action of the Buffer Development Review Committee, in recommending denial of Applications 23 and 24, as an indication that approval of these land use applications would be injurious to accomplishment of the Watershed Study objectives and inconsistent with Land Use Element Policy 3E. CDMP Conservation Element Policy 3E states that the area west of the Turnpike, east of the Dade-Broward Levee, north of NW 12th Street and south of Okeechobee Road shall be reserved for limestone mining and approved ancillary uses as provided for in Chapters 2 and 33 of the Miami -Dade County Code. Application 6 appears to be located within this area and thereto t inconsistent with this policy. �'�f �1�� C�'Q THE PUBLIC RECORD FOR 4 ITEM ON II-69-o6 SUBMITTED INTO THE PUBLIC RECORD FOR Citations p=1 ITEM if+;i ON )-b'I-Ob. Florida Statutes: sections 163.3177(2) and 163.3187(2). Florida Administrative Code: Rule 9J-5.005(5); 9J-5.005(6); 9J-5.006(2)(b) and (c); 9J-5.006(5)(a), (g), and (1);.and 9J-5.013(c)(6. Recommendations Retain the current land use designations and the current UDB location. Alternatively, provide data and analysis which demonstrates that the proposed land use and text amendments are consistent with Land Use Element Policies 8G, 8H, and 3E and Conservation Element Policy 3E and with Chapter 16.3, F.S., and Rule . Chapter 9J-5, F.A.C. FAILURE TO ESTABLISH MEANINGFUL AND PREDICTABLE STANDARDS FOR THE USE AND DEVELOPMENT OF LAND The Department objects to proposed text Amendment/Application 25, which amends CDMP Land Use Element Policy 8G, because, by comparison with the existing Land Use Element Policy 8G, Application 25 is more vague and does not establish meaningful and predictable standards for the use and development of land, as required in F.A.C. Rule 9J-5.005(6). Not only is Application 25 less meaningful and predictable than existing Policy 8G, but it does not compensate for its lessened rigor by requiring additional planning for the area outside the UDB. Application 25 calls for the addition of considerably more factors to be included in the establishment of the UDB. The Department does not object to improving and refining the existing CDMP policy guidance regarding the UDB, but any such revision should improve the meaningfulness and predictability of the existing policy guidance, not diminish it. The proposed addition to Policy 8G of a requirement to consider "market value of land averaged by section of land" brings into the calculation of residential demand the market value of land. Such a consideration is likely to skew the UDB analysis toward including cheaper land outside the UDB. This may well have the practical effect of removing the UDB as a barrier to development in the outskirts of Miami - Dade County; however, the amendment does not indicate how the cost of land is to be included in the UDB. analysis. . The proposed addition of considerations of public facilities and services and employment areas, and other (unspecified) socioeconomic needs of the community into the UDB analysis is not objectionable on its face, but the amendment does not specify how these factors are to be brought into the analysis, and it does not limit the additional factors to be considered to only the listed factors in the proposed amendment. Thus it contributes to the greater vagueness of the Application 25 proposed revision of Policy 8G. The proposed revision of Policy 8G appears to be more difficult to interpret for purposes of establishing a UDB boundary than the original policy. The existing Policy 8G is clearly stated, making it possible to calculate the necessity, or lack 5 1 SUBMITTED INTO THE PUBLIC RECORD FOR �d, keri ko i-11 � p thereof, for moving the UDB. The proposed revision is ling that r d ` -bto estimation of demand shall include, but not be limited to, a num%er of tactors. T rus is likely to have the effect of making the calculation or delineation of the UDB less predictable and perhaps more subjective than with the existing Policy 8G. Such a change, resulting in.a less than predictable standard, is not consistent with F.A.C. Rule 9J-5.005(6), with its requirement that goals, objectives and policies shall establish meaningful and predictable standards for the use and development of land and provide meaningful guidelines for the content of more detailed land development and use regulations. Citations Florida Statutes: sections 163.3177(1) and 163. 3177(6)(a). Florida Administrative Code: Rules 9J-5.005(6) and 9J-5.006(3)(c)7. Recommendations Do not adopt Application 25 or, alternatively, revise it to address the objections stated above. Provide the necessary data and analysis to demonstrate that it is consistent with the CDMP, Chapter 163, Rule 9J-5, the Strategic Regional Policy Plan for South Florida, and the State Comprehensive Plan. IMPACT ON PUBLIC TRANSPORTATION FACILITIES The Department objects to Applications 5, 10, 11, 13, 17, 22, and 23, because the County fails to coordinate the transportation system with the proposed future land use map changes and ensure that proposed population densities, housing and employment patterns, and land uses are consistent with the transportation modes and services proposed to serve these areas. The amendments do not demonstrate that adopted level of service standards will be maintained through the 5-year planning time frame with the development allowed in the proposed land use changes. The Department objects to Applications 5, 10, 11, 13, 17, 22, and 23, because these proposed land use amendments are not internally consistent with CDMP Land Use Element Policy 2A, which requires that all development orders authorizing new, or :significant expansion of existing, urban land uses shall be contingent upon the provision of services at or above the LOS standards specified in the Capital Improvements Element. The County must demonstrate that the improvements needed to maintain adopted LOS standards on roadways in the vicinity of the proposed land use amendments are scheduled in the CIE. In addition, the definition of the UDB in the CDMP Land Use Element contains a requirement that the construction of new roads, or the extension, widening and paving of existing arterial or collector roadways to serve areas outside the UDB at public.expense will be permitted only if such roadways are shown on the Land Use Plan Map and in the Transportation Element. The roadway improvements needed to maintain adopted LOS standards because of the development proposed by Application 5 has not been depicted on the Land Use Plan Map and in the 6 Transportation Element, which is necessary for this application to be consistent with the CDMP. The Department objects to Applications 5, 10, 11, and 17 because the County has not provided adequate supporting data and analysis to indicate how it will protect the interregional function of affected FIHS roadways. The development of Application 5 would add trips to and exacerbate conditions on I-75 from NW 92 Avenue to SR 826, Palmetto Expressway/SR 826 from NW 122 Street to I-75 and from NW 154 Street to NW 68 Avenue, and Okeechobee Road/US 27 from the Turnpike (HEFT) to Krome Avenue; all of these facilities are projected to deteriorate below their adopted LOS standards by 2015. Krome Avenue/SR 997 in the vicinity of Applications 10 and 11 is currently operating below its adopted LOS, based on old 1996 data. It is projected to operate below its adopted LOS in 2015 in the vicinity of Applications 10, 11, and 17. The Florida Department of Transportation reported that it was unable to determine the future impact of Application 17 on Krome Avenue/SR 997 because insufficient data was provided with the amendment. The development of Application 17 would add trips to the HEFT from SW 184 Street to SW 211 Street, which is projected to deteriorate to LOS F by 2015. Citations Florida Statutes: Sections 163.3161(3), 163.3177(3) and (6)(a), and 163.3177(j)5. Florida Administrative Code: Rules 9J-5.005(2); 9J-5.006.(2)(a); 9J-5.006(3)(b)1 and (3)(c)3; 9J-5.019(2); 9J-5.019 (3)(a), (f), and (h); 9J-5.019 (4)(b)2, (4)(c)1, and (4)(c)13; and 9J-11.007(1). Recommendations Regarding the objections for the specific applications listed above, the County should: 1. Utilize the most recently available estimates for average daily and peak hour vehicle trips in the analysis of the existing transportation levels of service. Provide the necessary data and analysis to enable a determination of the effect of the potential development allowed by Applications 10, 11, and 17 on the applicable portions of the HEFT and Krome Avenue/SR 997. 2. Address the need for newfacilities and expansions of alternative transportation modes, to provide a safe, and efficient transportation network and enhance mobility. 3. Demonstrate how it will maintain its adopted level of service standards through the 5-year and 10-year or greater planning time frames, including the incorporation into the 5-year capital improvements schedule (in the CIE) of roadway improvements needed to maintain adopted LOS standards during the 5-year planning time frame. The schedule shall include estimated public facility costs, including a delineation of when facilities will be needed, the general location of the facilities, and projected revenue sources to fund the facilities. SUBMITTED INTO THE PUBLIC RECORD FOR ITEM �«� ONii-oq oc 4. Depict on the Land Use Plan Map and in the Transportation Element the roadway improvements needed to maintain adopted LOS standards because of the development allowed by Applications 5, 10, 11, 13, 17, 22, and 23, in order for these applications to be consistent with the CDMP. IMPACT ON PUBLIC SCHOOLS The Department objects to the following individual applications within Amendment 06-1 because their potential development is likely to have an adverse impact on public schools: Applications 10, 13, and 23. Amendment 06-1 does not demonstrate that there is adequate existing or programmed capacity at vicinity schools for the additional students that would be generated by the proposed changes allowed by these applications. Application 10 would generate 616 additional students. This number of additional students at vicinity schools would raise the FISH capacity at the elementary school from 105 percent to 144 percent. Application 13 would generate 308 additional students. This number of additional students at vicinity schools would raise the FISH capacity at the elementary school from 140 percent to 155 percent, at the middle school from 171 percent to 177 percent, and at the high school from 153 percent to 156 percent of school capacity. Application 23 would generate 282 additional students, if the land were to be . developed as residential, which is allowed under the proposed Business and Office land use category. This number of additional students at vicinity schools would raise the FISH capacity at the elementary school from 156 percent to 175 percent and at the middle school from 124 percent to 130 percent of school capacity. This number of additional students would cause the elementary and middle schools serving the site to exceed the FISH capacity standard of 115 percent. Citations Florida Statutes: sections 163.3161(3) and 163.3177(6)(a) Florida Administrative Code: Rule 9J-5.006(3) (b)1 Recommendation Applications 10, 13, and 23 should not be adopted unless and until the applicants, Miami -Dade County, and the Miami -Dade County School Board reach agreement on mitigation for school impacts from the proposed land use amendments. II. STRATEGIC REGIONAL POLICY PLAN FOR SOUTH FLORIDA The following individual applications within Miami -Dade County Amendment 06-1 are inconsistent with Strategic Regional Policy Plan for South Florida: Application 4 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goal 11 and Policies 11.1 and 11.8. SUBMITTED INTO THE PUBLLC RECORD FOR P215 ITEM up} n ON fl-01-oe. Application 6 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 11 and 20 and Policies 11.12 and 20.2. Application 7 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 11, 12, 16, and 20 and Policies 11.10, 12.6, 16.2, and 20.2. Application 10 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 5, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 5.1, 5.3, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 13 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 5, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 5.1, 5.3, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 17 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 5, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 5.1, 5.3, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 20 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 7, 11, 13, and 20 and Policies 4.8, 4.10, 7.1, 11.10, 13.2, and 20.3. Application 21 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 23 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 5, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 5.1, 5.3, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 24 is generally inconsistent with Strategic Regional Policy Plan for South Florida, Goals 4, 7, 11, 12, 16, and 20 and Policies 4.8, 4.10, 7.1, 11.12, 12.6, 16.2, and 20.2. Application 25 is generally inconsistent with the Strategic Regional Policy Plan for South Florida, Goals 4, 5, 7, 11, 12, 16 and 20 and Policies 4.8, 4.10, 5.1, 5.3, 7.1, 11.12, 12.6, 16.2 and 20.2. Citations Florida Statutes: s. 163.3184(1)(b) Florida Administrative Code: Rule 9J-5.001(1) Recommendations Revise the amendment to be consistent with and further the referenced goals and policies of the Strategic Regional Policy Plan for South Florida. SUBMITTED INTO THE PUBLIC RECORD FOR ITEM iP(.:ON 1\-09-0(ef III. STATE COMPREHENSIVE PLAN The above cited amendments do not further and are not consistent with the following goals and policies of the State Comprehensive Plan (Chapter 187, Florida Statutes): • WaterResources Goal and Policies 1, 2, 5, 9, 10, 11, and 14 Land Use Goal and Policies 1, 2, and 6 Urban and Downtown Revitalization Goal and Policies 6 and 12 Public Facilities Goal and Policies 1, 2, 7, and 10 Transportation Goal and Policies 2, 3, 9, 12, and 13 Economy Policy 3 Agriculture Goal and Policy 5 Plan Implementation Policy 8 Revise the amendment to be consistent with and further the referenced goals and policies of the State Comprehensive Plan. This may be accomplished by revising the amendment as recommended for the specific objections above. SUBMITTED INTO THE PUBLIC RECORD FOR ITEM :4:; ON h-0-or,. 10 SLBMITTED INTO THE PUBUC RECORD FOR b(0 ITEM ON n-oq-o(, __,