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5. Criteria for Amending the Comprehensive Plan. Is the proposed Plan amendment consistent with Policy 13.3 which states specific criteria for amending the Comprehensive Plan Future Land Use Element? [Policy 13.3. Indian River County shall approve plan amendments only upon a showing that one of the following criteria has been met.• ° The proposed amendment will correct an oversight in the approved plan. ° The proposed amendment will correct a mistake in the approved plan. ° The proposed amendment is warranted based on a substantial change in circumstances affecting the subject property.] 6. Consistency of Plan Amendment with Comprehensive Plan. Is the proposed Plan amendment consistent with Policy 13.2 which requires consistency with the Comprehensive Plan and other timely issues. [Policy 13.2. Applicants requesting amendments to the Comprehensive Plan or Future Land Use Map shall be evaluated to consider consistency with the Goals, Objectives and Policies of all elements, and other timely issues.] ANALYSIS OF ISSUES Evaluation of Proposed Change in Node Size. Policy 1.20 requires that the node size be "based on the intended use classification and service area population, existing land use pattern and other demand characteristics. The staff analysis rationalizes that the amendment merely "slu fts land uses and no intensity/density increase" occurs. The following analysis indicates that the Plan amendment is inconsistent with Policy 1.20. • Summary Analysis. The size of land uses as well as the density, intensity and land use mix within the node are dramatically changed yet no substantial evidence is presented to justify the changes. • Loss of Industrial Land with No Analysis Consistent with Policy 1.20. A market sensitive rationale for removing the Industrial designation on the 15+/- acres comprising the subject site #1 (nearly 20% of the industrially designated land within the subject C/I node), is never presented as required pursuant to Policy 1.20. The County loses a site capable of accommodating 100,000 square feet or more of industrial activity and no replacement site is offered, nor is any quantitative data presented to support the action. Policy 1.20 places a burden on the County to articulate viable alternative land use strategies for preserving sites for industry. The subject Plan amendment is not a "swap -out" since the County loses 15+/- acres of industrial land which is not replaced by a shift in industrial land use designation to other lands near the FEC railroad west of US 1 which may be adaptive to industry. • Significant Addition of Commercially Designated Land in Residentially Designated Area East of US 1 with No Supportive Market or Demographic Analysis or Analysis of Alternative Sites. A market sensitive rationale is not presented for adding 15+/- acres of commercially designated land (subject sites # 2, 3 and 4 east of US 1)to the node. All three sites are adjacent to existing or planned residential areas. A market justification is mandated pursuant to Policy 1.20, and typically includes identification of proposed activities, an analysis of unmet primary and secondary markets, and consideration of competitive forces. Equally important is the need to identify alternative sites that are currently available and zoned for commercial development. • In concert with lands under common ownership which abut subject sites #2 and #4, these two sites would comprise two sites of 13.8+1- acres each and each site is approximately the she of the Vero Mall site -- one of the largest shopping centers in the County. The County's Comprehensive Plan states that the "availability of commercially designated land far exceeds that which is currently developed (Indian River County Comprehensive Plan Future Land Use Element, page 65.8). The Future Land Use Element states that the C/I nodes contain 1,172 acres of vacant land while the total vacant land available for varied types of commercial, industrial, and mixed use development is 2,592 acres (page 66). Prior to adding substantial commercial land to a previously residentially designated area, a market driven analysis is mandated pursuant to Policy 1.20. Again the analysis should address, identification of proposed activities, an analysis of unmet primary and secondary market demands based on changed population trends and market conditions, and consideration of competitive forces. Equally important is the need to Identify alternative sites that are currently available and zoned for commercial development. JUNE 139 1995 72 8a 95 PAGE 412