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representatives) was close to the unincorporated proportion of the total County population. Another <br />advantage of this alternative was that the smaller municipalities, with the exception of the Town of <br />Orchid, had direct representation on the MPO Board. <br />Each of the other options considered resulted in inadequate representation on the MPO Board for <br />the smaller municipalities. While the seven member option would have included the three smallest <br />municipalities (Town of Indian River Shores, City of Fellsmere, and Town of Orchid) with <br />unincorporated residents and provide them representation through County Commission <br />representatives, eight and nine member alternatives would have assigned a shared representative for <br />the three smallest municipalities. Because of the dissimilarities among these municipalities, it was <br />determined that a shared representative approach would not be feasible. After careful consideration, <br />it was determined that all municipalities except Orchid should have voting representation on the <br />MPO Board. <br />When the initial MPO apportionment plan was developed in 1993, an important consideration was <br />whether the IRCSD could be represented as a voting member of the MPO Policy Board. Although <br />representatives of the general purpose local governments within the MPO area agreed that the <br />IRCSD should have voting representation on the MPO Board, FDOT disagreed. According to <br />FDOT, Chapter 339, F.S. specifically listed criteria for MPO membership and that criteria would <br />not allow a school board to have voting representation on an MPO Board. <br />1993 Apportionment Plan <br />Table 3 depicts the MPO Policy Board structure established by the 1993 Indian River County MPO <br />apportionment plan. As indicated in that table, the MPO Policy Board had nine voting members. <br />These included four County Commissioners, two Vero Beach City Councilmen, one Sebastian City <br />Councilman, one Fellsmere City Councilman, and one Indian River Shores Town Councilman. The <br />MPO Board also included as nonvoting members one representative of the Town of Orchid and one <br />representative of the IRCSD. As structured, the MPO Board had direct representation from five of <br />the six general purpose local governments within the MPO area. Only the Town of Orchid, which <br />had a 1990 population of 10, did not have direct representation on the MPO Board. <br />1999 Apportionment Plan Analysis <br />Since 1993, FDOT's position regarding school board voting representation on MPO Policy Boards <br />has changed. For example, FDOT, in addressing initiatives by the Broward MPO to add a school <br />board member to its MPO Policy Board, has interpreted Chapter 339, F.S. to allow school board <br />representatives to serve as voting members of MPO Boards. This is based on Chapter 339's <br />provision that representatives of agencies operating major modes of transportation may have voting <br />representation on MPO Boards, and a recognition that school boards are agencies operating a major <br />mode of transportation. <br />As written, Chapter 339.175(2)a, F.S., states that an MPO "may include, as part of its apportioned <br />voting members, an ... official of an agency that operates or administers a major mode of <br />transportation." In Indian River County, the Indian River County School District (IRCSD) provides <br />a greater number of trips over a greater number of miles with a larger fleet than any other <br />transportation provider, including the County's public transportation provider. Unlike the County, <br />3 <br />