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assign a land use designation to the annexed land as well as to modify any plan provisions necessitated by the annexation Instead of amending its existing comprehensive plan just to reflect the annexed area, the City has opted to prepare a completely new plan. The City's proposed new plan has been submitted to DCA as a draft comprehensive plan amendment. Through its review process, DCA has requested comments on the amendment/new plan from surrounding local governments, state agencies, and the regional planning council Within 60 days of the City s comprehensive plan amendment transmittal, DCA will issue an ORC (objections, recommendations, comments) report. In preparing the ORC, DCA will consider any comments from the County as well as comments from other agencies, groups, or individuals. Because of Florida's annexation laws, the County had no authority to object to Felismere's recent annexation of 3,800 acres of unincorporated county land. The County does, however, have an opportunity to affect the City's land use designation of the referenced 3,800 acres. That opportunity is afforded to the County through the state's comprehensive plan amendment process. Since receipt of Fellsmere's proposed new comprehensive plan, staff has reviewed the document and prepared comments. Those comments have been compiled in the attached draft letter written to DCA for the Chairman's signature. It is now the Board's responsibility to review the draft letter, make any changes, and either approve or not approve transmittal of the letter to DCA. ANALYSIS Although the City's proposed comprehensive plan is a completely new document, the principal concern with the plan relates to the recently annexed 3,800 acres of unincorporated county land Because the plan, once approved, will dictate how that land can be developed, the policies in the plan are important. Currently, the 3,800 acre tract still has its County land use designation. That County land use designation limits most of the property to agricultural uses with a residential allowance of 1 unit to 5 acres and 1 unit to 10 acres. The portion of the property in the southwest quadrant of the I-95/CR512 interchange has a commercial/industrial designation. The County's land use designation for the property is based on several factors. One is the County's residential land use allocation ratio That ratio is about 3, indicating that the County already has three times as much land as is needed to accommodate the projected 2020 population. Besides the lack of need for additional residential development, other factors that influenced the County's land use designation were: surrounding land uses, urban sprawl prevention, and protection of the site's environmental resources. Obviously, the County's restrictive land use regulations applicable to the 3,800 acre tract constituted the principal motivation for the landowner to annex to Fellsmere. With that annexation and this plan amendment, the landowner will have circumvented the County's overall long range plan. A similar initiative is being considered by the City of Sebastian, where more than 2,000 acres of unincorporated County land outside of the urban service area boundary are proposed for annexation and re -designation for urban development With respect to the Fellsmere comprehensive plan amendment, staff's comments are itemized in the attached draft letter. The principal comments are that the City has not provided a justification of the need for the significant increase in development potential; has not provided any restrictions to limit urban sprawl; and does not depict any transportation system for the 3,800 July 23, 2002