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by DCA. EAR based amendments, including the revised Future Land Use Element Policy 13.3, have been transmitted to DCA for review. Based on DCA's review of the EAR, no objections to the revised Future Land Use Element Policy 13.3 are anticipated In this case, the subject request is for a minor node reconfiguration and a decrease in land use intensity. With respect to Policy 13.3, staff feels that the proposed land use amendment meets the policy's third criterion. For typical amendment requests, substantial evidence justifying a change in circumstances would need to be documented Because the subject amendment involves only a re -orientation of future land uses, as well as a decrease in land use intensity, a physical change in circumstances need not be documented In this case, the change in circumstances relates to overall land use efficiency. The proposed amendment would allow commercial development, consistent with market demand, while simultaneously increasing publicly controlled conservation areas and environmentally important wetland habitat. That environmentally important wetland habitat (Subject Propertyl) is currently designated C/I. Because that habitat is more appropriately designated C-1, and does not require a C/I land use designation, and because there is a demand for the C/I designation on Subject Property 2, the proposed node reconfiguration would increase overall land use efficiency. By facilitating the creation and public control of the wetlands without a large expenditure of public resources. the proposed amendment is the most efficient manner in which to protect and preserve that land Staffs position is that the opportunity to increase publicly controlled conservation areas and to increase environmentally important wetland habitat constitutes a change in circumstances affecting the subject properties. Therefore, the proposed amendment meets the third criterion of Future Land Use Element Policy 13.3 and is consistent with Future Land Use Element Policy 13.3. - Future Land Use Element Policy 1.4 Future Land Use Element Policy 1.4 states that the conservation land use designations are applied to those areas which are vital or essential to the normal functions of ecosystems and have been identified in the Conservation Element as meriting preservation. The wetlands that currently exist and that will be created on Subject Property 1 meet that criteria. Because the proposed amendment redesignates Subject Property 1 to Conservation, the amendment is consistent with Future Land Use Element Policy 1.4. - Future Land Use Element Policy 1.15 Future Land Use Element Policy 1.15 states that the commercial land use designation should be within the urban service area and is intended for retail and wholesale trade, offices, business and personal services, and similar uses. Near the existing portion of the Horizon Outlet Center, adjacent to commercially designated and zoned land, within the urban service area, with access to SR 60, and with urban services available, Subject Property 2 is appropriate for commercial uses. The proposed amendment would allow commercial development on Subject Property 2. Therefore, the proposed amendment is consistent with Future Land Use Element Policy 1.15. - Future Land Use Element Policy 1.20 Future Land Use Element Policv 1.20 states that nodes shall have a desienated size based on the intended use and service area population, existing iand use pattern and other demand characteristics. The amount of CA designated land is based on service area population, the existing land use pattern. and other demand characteristics. The proposed amendment will not alter the amount of C/I designated land. Therefore, the proposed amendment is consistent with Future Land Use Element Policy 1.20. JANUARY 27, 1998 0 -21- BOOK 10"! FAGE 4��