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F- • The Redesignation of the Industrial Site to Residential (8 units/acre) Increases the Density of Development in the Node and the Potential Dwelling Unit Count without a Supportive Analysis of Changes in Demographic and Housing Conditions, including Past, Present and Future Trends Pursuant to Policy 1.20. The proposed density for the subject site #1 is 8 units/acre. This 15+/- site could accommodate 120 dwelling units. Under the existing land use designations, subject sites #2, 3, and 4 M would accommodate a maximum of 90 units (only 39 units if Subject site #2 remains zoned A-1. • The Increase in Density and Intensity of Development Generates Substantial Impact on Residential Land Use and Facilities East of US 1 which Would Not Be Similarly Impacted Without the Expanded Node and Intensified Land Use East of US 1. The proposed amendment impacting Subject Site #2 and 3 introduces potentially intense large scale commercial land uses with only 25 foot front setbacks to adjacent areas now accommodating single family homes. Similarly, the commercial development on subject site #4 introduces the potential of a 100,000 - 200,000 square feet shopping mall within 450 feet of high value single family property adjacent to the Indian River. Similarly, the potential shopping mall on site #4 also abuts property designated for medium density residential development. Facility impacts are discussed later in this section. Evaluation of Proposed Node Expansion. Policy 1.23 requires that a node should not be expanded unless 70% of the land area Less R/W) is developed with non-residential and non-agricultural uses, or approved for non- residential and non-agricultural development, or otherwise warranted by the proposed development. The staff analysis rationalizes that the amendment merely "shifts land uses and no intensity/density bmwase" occurs. The following analysis indicates that the Plan amendment is inconsistent with Policy 1.23. • Fails to Demonstrate Compliance with Node Expansion Criteria. The propose Plan amendment expands the subject CA node as demonstrated above, including generation of 1) adverse land use impacts on single family homes; 2) increased density including the potential increase of 30 dwelling units; 3) over 13 acres of commercial land use east of US 1, including potential construction of more than 100,000 square feet of commercial floor area. When combined with lands under common ownership, the two sites (#2 and #4) could accommodate upwards of over 200,000 sq. ft. of additional gross leasable area of retail commercial use. Despite the expanded node, the proposed amendment does not include a detailed analysis demonstrating compliance with criteria for expanding nodes as stated in Policy 1.23. Evaluation of Coastal Management Issues. The Florida State Division of Emergency Management Computer Model indicates that the CHHA is located in the vicinity of subject property #4 and extends westward to 46th Avenue and therefore embraces the subject site. State policy 9J-5.003(14) recently amended the definition of "coastal high hazard area" to include the evacuation zone for the Category 1 hurricane as established in the regional hurricane evacuation study applicable to the local government. The proposed Plan amendment falls to address planning policies related to managing development in coastal high hazard areas. Since subject site #4 is likely in, or at best very near the Category 1 hurricane storm surge zone, the proposed Plan is likely to generate several related coastal planning and management issues which should be approached more prudently. The implications of an additional 5.5+/- acres of "General Commercial" land use together with the potential resource management issues should be addressed. The current analysis of record fails to address such issues. Evaluation of Public Facility Impacts. Policy -2.8 requires that the public facilities shall have capacities sufficient to meet levels of service established in the Plan and the intensity of future development identified on the Future Land Use Map. If subject site #4 is combined with the adjacent commercial site to the north the resulting commercial site will comprise 13.91+/- acres and could accommodate 100,000 to 200,000 square feet of gross leasable area of retail sales activity. Such a shopping facility could generate between 8,500 to 10,000 trips per day. • CR 510 from US 1 to AIA is projected to be at level of service F by 2010 according to the County's Comprehensive Plan Transportation Element (page 18.3). The Indian River County 2020 Cost Feasible Transportation Plan recommends an expenditure of $3.18+ million in improvements, including an additional 2 lanes and increased right-of-way (Memorandum from Keith Burnsed to MPO, January 3,1995). The recommended improvements have not received a commitment from the County or the State. Realizing the projected shortfall in level of service on CR 510 -- a major hurricane evacuation route -- it appears premature to approve any development that could increase intensity on CR 510. Such action could give an investor or land owner a "false reading" regarding reasonable development expectations. • Plan Amendment Fails to Demonstrate Compliance with Policy 2.8. The staff analysis fails to address public facility impacts on CR 510 despite the projected shortfall in 2010 LOS and lack of funding commitments for require improvements. JUNE 139 1995 73