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F, Boa 47 PAPE SEP 1991 413 DEPARTMENT OF VETERAN AND COMMUNITY AFFAIRS COMMENTS ON THE -PROPOSED COMPREHENSIVE PLAN FOR INDIAN RIVER COUNTY I. OBJECTIONS 1. The land use element does not designate proposed future general distribution, location, and extent of the uses of land for housing, business, industry, agriculture, recreation, conservation, education, public buildings and grounds, other public facilities, and other categories of the public and private uses of land as required by §163.3177(6)(a), Florida Statutes. This element mentions a future land use map; however, no land use map was included with the materials submitted for our review. Further, we call your attention to the provisions of §163.3194(1), Florida Statutes, which states: "After a comprehensive plan or element or portion thereof has been adopted in conformity with this act, all development undertaken by, and action taken in regard to development orders by, governmental agencies in regard to land covered by such plan or element shall be consistent with such plan or element as adopted." If the County is to take three years to bring their zoning into conformance with the land use element (P65), they may not approve any development during the interim that is not consistent with the land use element. 2. The portions of the proposed sanitary sewer, solid waste, drainage and potable water element that address sanitary sewer, drainage and potable water do not describe the needs and the general facilities that will be required for the solution of problems and needs as required by §163.3177(6)(c), Florida Statutes. The sanitary sewer and potable water portion of the plan does not indicate what facilities are presently in operation, their capacity and existing demand. Further, there is no information on projected future demand and the facilities that will be required to meet this demand. While some of the general planning philosophy appears sound, there is little guidance provided as a basis for decisions on future courses of action. The drainage portion of the plan contains some good policies but does not describe the needs and general facilities that will be required. The extensive areas covered by soils with very poor drainage characteristics (p. 20) are not identified, and a large catchment area is proposed (p. 20) as a prime location of new urban develop- ment. Further, since the County lacks a master drainage plan and the engineering capabilities necessary to ensure effective storm water management (p. 20), there appears to be a serious problem. For the County to proceed with land use planning and development without a better grasp of their drainage problems, real and potential, could result in the needless expenditure of funds to correct problems that could have been avoided by prior planning. 3. Fiscal proposals for capital improlements that will require the expenditure of public funds are not included as required by §163.3177(3), Florida Statutes. II. GENERAL COMMENTS 1. The Urban Service Area for Indian River County, Figure 2, in the sanitary sewer, solid waste, drainage, and potable water element, appears to cover the barrier island east of the Indian River. Without a land use map we do not know what development density is proposed for the barrier island; however, based on policy statements in the land use element this area should be developed at a low density which could negate the need for urban services.