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MAY 25 isom BOOK 89 uu 653 DCA Objections Of the three comprehensive plan amendment requests transmitted to DCA during the last transmittal period, this request received the most objections. In fact, all four of the objections cited by DCA are substantive. These four objections are: • The proposed amendment is not consistent with Future Land Use Policy 1.21 which discourages strip commercial development. • The proposed amendment is not consistent with Future Land Use Policy 1.23 which requires a 70% level of node development prior to node expansion. • The proposed amendment is not consistent with Future Land Use Policy 13.3 which prohibits plan amendments unless an oversight or mistake in the original plan, or a change in circumstances affecting the subject property, has occurred. • Based on projected population, the proposed amendment does not justify the need for additional C/I designated land. _ Therefore, the proposed amendment does not discourage the proliferation of urban sprawl. DCA raised the referenced objections despite the fact that staff prepared an addendum to the staff report presented to the Board at its transmittal hearing. A copy of that addendum is appended to this staff report as Attachment 9. As drafted and submitted to DCA, the referenced addendum specifically addressed those issues which formed the basis of DCA's objections. With respect to urban sprawl, node expansion, and circumstances necessary to justify a plan amendment, staff attempted to provide sufficient justification to show that the proposed amendment is consistent with established county policy. Despite the addendum, DCA determined that the subject amendment is inconsistent with various provisions of the county's plan. In so doing, DCA contends that the county is not following its own policies. For several of these issues, particularly urban sprawl, DCA notes that the proposed amendment would conflict with the state comprehensive plan, even if local plan inconsistency was not an issue. Given DCA's objections, it appears that this amendment, if adopted, will not be found in compliance. Regardless, staff has analyzed the request. As indicated in the detailed analysis, staff, like DCA, has identified the conflicts between the proposed amendment and the Comprehensive Plan policies. For that reason, staff feels that DCA's objections cannot be adequately addressed without denying the amendment request. Concurrency of Public Facilities This site is located within the county Urban Service Area, an area deemed suited for urban scale development. The Comprehensive Plan establishes standards for: Transportation, Potable Water, Wastewater, Solid Waste, Drainage and Recreation (Future Land Use Policy 3.1). The adequate provision of these services is necessary to ensure the continued quality of life enjoyed by the community. The Comprehensive Plan and Land Development Regulations also. require that new development be reviewed to ensure that the minimum acceptable standards for these services and facilities are maintained. Policy 3.2 of the Future Land Use Element states that no development shall be approved unless it is consistent with the concurrency management system component of the Capital Improvements Element. For Comprehensive Plan amendment and rezoning requests, conditional concurrency review is required. 52