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NOV 2 31993 n ry BOOK 91 PAGE t 0 In contrast to objections, comments cannot form the basis of a non- compliance determination. However, the comment_ does indicate a DCA finding that should be addressed. ANALYSIS This section includes a summary of proposed changes to address DCA's objections and comment. It also includes an analysis of the reasonableness of each of the proposed amendments. Finally, this section includes a discussion of the consistency of the proposed amendments with the comprehensive plan. SUMMARY OF CHANGES TO ADDRESS DCA'S OBJECTIONS AND COMMENT In order to address DCA's objections and comment, planning staff coordinated with DCA staff. As a result, staff identified various revisions which will resolve DCA's concerns. These revisions include changes to proposed policies and to the staff report. Staff's position is that these changes will resolve DCA's objections and retain the intent of the proposed amendments. • DCA's principal objection to this proposed amendment focused on the Citrus Highway. In its ORC report, DCA noted that the CPDR (corridor plan for the proposed road) has not been completed. The CPDR will analyze the need for and impacts of the Citrus Highway, and recommend a specific route. DCA's position is that the results of the CPDR are needed to support the justification for the Citrus Highway as well as the selection of a particular route. Previously, DCA expressed concern that, since the Citrus Highway is not identified in the county's comprehensive plan, FDOT's plans to do a corridor study for the Citrus Highway were inconsistent with the county plan (see attachment 3). DCA warned FDOT that the expenditure of state funds for road projects (even for feasibility studies) not identified on the local government's comprehensive plan conflicts with provisions of Chapter 163 Part III, F.S. DCA then asked FDOT to cooperate with the affected local governments to resolve the noted concern by requesting that the affected local governments amend their plans. One reason that this amendment was initiated was to address that concern. After the county initiated this comprehensive plan amendment and transmitted it to DCA, DCA revised its position by stating that any comprehensive plan amendment related to the proposed Citrus Highway must be consistent with the results of the CPDR. After coordinating with FDOT, DCA's current position is: • a CPDR is necessary to determine the need for and the best route of the proposed Citrus highway; FDOT can fund the CPDR; based on the results of the CPDR, the county may initiate an amendment incorporating the Citrus Highway into the comprehensive plan. Based on DCA's position, staff has revised the proposed amendment to eliminate any references to the Citrus Highway. After completion of the CPDR, the County will amend its plan, as necessary. 34