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Evaluation of Compliance With Plan Amendment Criteria. Policy 13.3 requires that no Plan amendment be approved unless there is a showing that the: - 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. • Plan Amendment Fails to Comply with Policy 13.3. There is no indication in the staff analysis that there has been a substantial change in circumstances affecting the subject property. No quantitative analysis appears: 1) identifying shifts in market conditions and demand of industrial land to warrant loss of a 15 acre industrial site with no replacement; 2) presenting market justification for increased commercial land as mandated pursuant to Policy 1.20, typically including identification of proposed activities, an analysis of unmet primary and secondary markets, consideration of competitive forces, and, equally important, the need to identify alternative sites that are currently available and zoned for commercial development; and 3) the existing rationale for increasing density, including the addition of 30+/- dwelling units. Evaluation of Consistency with Comprehensive Plan and Other Timely Issues. The Plan amendment fails to comply with Policy 13.2 since the Plan amendment does not comply with the following Comprehensive Plan Policies and State coastal resource management requirements: • Policy 1.20: Criteria for Node Size. • Policy 1.23: Criteria for Node Expansion. • State Coastal Management Policies for the Coastal High Hazard Area. • Policy 2.8: Criteria for Managing Impacts on Public Facilities. • Policy 13.3: Criteria for Amending the Comprehensive Plan. • Policy 13.2: Plan Amendment is Inconsistent with the Comprehensive Plan Summary Plan Amendment Evaluation • Policy 1.20: Criteria for Node Size. 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. • Policy 1.23. Criteria for Node Expansion. The proposed Plan amendment expands the subject C/I node, 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. • State Coastal Management Policies for the Coastal High Hazard Area. The proposed Plan amendment fails 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. • Policy 2.8: Criteria for Managing Impacts on Public Facilities. 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. • Policy 13.3: Criteria for Amending the Comprehensive Plan. There is no indication in the staff analysis that there has been a substantial change in circumstances affecting the subject property. No quantitative analysis appears: 1) identifying shifts in market conditions and demand of industrial land to warrant loss of a 15 acre industrial site with no replacement; 2) presenting market justification for increased commercial land as mandated pursuant to Policy 1.20, typically including identification of proposed activities, an analysis of unmet primary and secondary markets, consideration of competitive forces, and, equally important, the need to identify alternative sites that are currently available and zoned for commercial development; and 3) explaining the rationale for increasing density, including the addition of 30+/- dwelling units. • Policy 13.2: Plan Amendment is Inconsistent with the Comprehensive Plan for reasons stated herein. JUNE 139 1995 74 414