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19. Rule 9J -5.010(3)(b)(3) requires adequate sites for housing for low and moderate income families. Comment: The immediate vicinity of this propose �1 amendment is comprised of several established, well-maintaineld, moderate income residential neighborhoods. The site of the proposed amendment could easily develop in a similar manner if the plan is not amended. , 20. Rule 9J -5.015(3)(b) requires an intergovernmental coordi- nation element with objectives to coordinate the County plan with the plan of a City which provides service but has no regulatory authority over the use of the land, and to address the impacts of developments on adjacent municipalities. Comment: "Coordination of the local comprehensive plan with the plans of adjacent municipalities ... shall be a major objective of the local comprehensive planning process." F.S. 163.3177(4)(a). Taking this legislative mandate seriously would result in careful consideration of the impact of this proposed amendment on nearby stable residential neighborhoods. Additional traffic and safety problems, delivery trucks and garbage pickup noise and changing neighborhood character are all likely impacts. The City Planning and Zoning Board rejected this proposed amendment 7-2, and the City will be the provider of wastewater service to this site. CONCLUSION From the above analysis, Citizens for Responsible Zonling conclude that the proposed amendment to the Comprehensive Plan is not consistent with the overall provisions and purposes of the Comprehensive Plan. Since the internal consistency requirement for plan amendments under F.S. 163.3187(2) are not met, this proposed plan amendment should be denied by the Board of County Commissioners. The pertinent documents cited to in these comments are attached as exhibits and/or incorporated by reference. -6- Prepared by: WILLIAM G. COLLINS II,ATTORNEY AT LAW. SUITE 408/ BARNETT BANK BLDG./ 601 TWENTY FIRST STREET f VERO BEACH FLORIDA 329601 TELEPHONE 13051 562 -WW Attorney Collins entered into the record a certified copy of the Minutes of the December 18, 1986, meeting of the Planning and Zoning Board of the City of Vero Beach. (Those minutes have been placed on file in the Office of the Clerk to the Court.) Attorney Collins concluded his presentation by emphasizing that the Citizens for Responsible Zoning conclude that the proposed amendment to the Comprehensive Land Use Plan is not consistent with the overall provisions and purposes of the Comp Plan, and since 12 requirements for consistency are not met under Florida Statute, feet this proposed Comp Plan amendment should be denied by the Board of County Commissioners. Commissioner Eggert asked staff if the County is still functioning under the 9J.5 requirements, and Robert Keating, 61 BOOK FAG - APR 14.987