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BOD)( F'1;E 12. The Plan's Transportation development impact policy statement #1 says that for assessing the impact of additional proposed development, the road design capacity of a four -lane divided road is 24,000.22 Comment: Adding the estimated 9450 additional trips generated by the proposed general commercial use of this parcel to the current 22,700 AADT23 would put 17th Street not only above the Plan's design capacity, but above the level -of -service C design capacity of 31,000 as set out in the 1986 Barton-Aschman Study.24 13. The Plan's Housing Element Objective is to encourage the development of a safe and convenient housing supply which is accessible to public services and facilities.—to satisfy the needs of all income levels within the community.25 Comment: A plan amendment which deletes property suitably planned for Medium Density Residential development (up to 10 units/acre) does not further, but hinders the Housing Element objectives. 14. The Plan's Intergovernmental Coordination element says the County should establish an advisory committee representing all governmental entities ... to interface plans.26 Comment: Such coordination with Vero Beach would,show the property adjacent to be residential, as the County.Plan currently has the parcel proposed for amendment designated. RULE 9 J-5 COMPLIANCE 15. Rule 9J-5.005(4) requires internal consistency between plan elements. Comment: Since this proposed plan amendment appears incon- sistent with at least a dozen of the Comprehensive Plan's statements, policies, objectives, etc., it is questionable whether this minimum criteria can be achieved. 16. Rule 9J -5.006(2)(C) requires a Land Use Analysis of the character of vacant or undeveloped land to.determine its suitability for use. Comment: An analysis of this site against the performance standards of the Plan for medium density residential would show the site suitable for that use.27 17. Rule 9J-5.006(3) requires statements of goals and objectives. Comment: We are unaware of this proposed plan amendment furthering any of the Plan's stated goals and objectives. In view of the inventory of vacant sites planned for commercial use,28 we suggest no public goals or objectives would.be furthered by this proposed plan amendment. 18. Rule 9J -5.007(3)(b)(2) requires coordination of the traffic circulation system with the future land uses shown on the future land use map. Comment: Rather than coordinating land uses with the traffic system objectives,29, this proposed amendment would result in the gobbling up of great chunks of road capacity by in- creasing trip generations by 10 times over currently planned. uses (multiple residential) or other alternative uses (professional offices) for this parcel. t' 5-