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1. Citrus groves and other agricultural development were <br />not mentioned. The Citrus industry is a vital aspect <br />of the Indian River County economy and lifestyle. A <br />complement of supporting industry including packing <br />houses and fruit shipping have also developed and be- <br />come vital elements of our local economy. In the area <br />proposed on the maps there are approximately 1596.19 <br />acres of producing groves. The fruit produced within <br />this area is known world wide as the "Famous Orchid <br />Island Fruit". A complement of roads, bridges, utility <br />lines, canals, barns and the homes of the grove owners <br />and workers presently exist within the area. We would <br />like to emphasize that the groves are a developed in- <br />dustrial area. <br />2. The issue of vested rights has not been adequately <br />addressed. Many developers have spent thousands of <br />dollars and met development standards applied by Indian <br />River County. According to the draft definitions and <br />criteria, these sites will be included in the undeveloped <br />area. The expense incurred by the developers and the local <br />government approval indicates that these sites will soon <br />be developed at urban densities and this should be reflect- <br />ed on the proposed maps. <br />3. Indian River County -has spent the past seven years <br />developing a Comprehensive Plan. On the local level <br />.the barrier island has been extensively studied and <br />analyzed. It is our intention to govern growth and <br />development of the barrier island through local land <br />use and zoning regulations. These regulations have <br />obviously proved very effective in'the past and will <br />continue to be effective in monitoring growth and <br />development. The Comprehensive Plan provides -for the <br />extension of water and sewer services to the barrier <br />island and financial and contractual committments <br />toward planning.and installation of these services have <br />been made by the County. The Planning process included <br />anticipating the revenue which would-be generated from <br />providing service to the future barrier island residents. <br />A proposal to limit or slow growth other than from the <br />local level will eliminate the effectiveness of our plan <br />and place an undue financial burden upon the County. All <br />of the barrier island within Indian River County is <br />developed or has the capability of being developed under <br />the constraints of the Comprehensive Plan "maximum density <br />of 3 to 6 units/acre".. <br />4. The definitions have not been uniformly applied within <br />Indian River County or beyond the County's boundaries. <br />There are many miles of coastline to,the north which <br />were not proposed as an undeveloped coastal barrier. <br />Existing development of this land is similar to or less <br />intensive than designated areas within Indian River County. <br />5. It appears that the Federal Government is incrementally <br />withdrawing from the flood insurance business. This <br />procedure places an undue hardship on owners of land and <br />structures in the areas which will become ineligible for <br />Federal Flood Insurance first. Private industry will not <br />immediately assume the responsibility of insuring such a <br />limited and high risk flood hazard area, lie cannot over <br />emphasize the point that the Federal Government should <br />remove itself totally from the flood insurance business <br />on a wholesale basis. <br />County staff, resource and time limitations did not allow for an exten- <br />sive study of the technical aspects of the Draft definitions and cri- <br />teria. The proposed maps are arbitrary and unreasonable. We strongly <br />urge the Department of the Interior to remove all of our County from <br />the proposed maps. <br />M11171982 19 <br />N;,rl 49 mc 161 <br />