Item B1 Appendices 2 0
STATE OF FLORIDA
DEPARTMENT OF COMMUNITY AFFAIRS
"Dedicated to making Florida a better place to call home"
CHARLIE GRIST THOMAS G. PELHAM
Governor Secretary
October 29, 2010
The Honorable Sylvia Murphy
Mayor, Monroe County
102050 Overseas Highway, Suite 234
Key Largo, Florida 33037
Re: Letter of Understanding for the Monroe County Evaluation and Appraisal Report
Dear Mayor Murphy:
The Department has reviewed your letter outlining the scope of work for the preparation
of the County's Evaluation and Appraisal Report (EAR). The Department agrees with the
summary of the issues set forth in the attached document. This letter serves as confirmation of
our understanding. However, we have the following recommendations concerning the proposed
Scope of Work.
• The County's major issues list includes the compatibility with military installations. In
addressing compatibility, the Department recommends that the County carefully consider
the requirements of Chapter 163, Florida Statutes, as they were amended by the 2010
Florida Legislature and evaluate the need for sound attenuation standards and other
techniques to ensure the compatibility of development proximate to military installations.
• The County has included "Continued Public Waterfront Access; Protect and Expand
Water Dependent/Water Related Uses" as a major issue. The Department recommends
the inclusion of criteria that encourages the preservation of recreational and commercial
working waterfronts.
• Economic Sustainability is listed as a major issue. The County will be examining the
goals, objectives and policies in the comprehensive plan to evaluate numerous aspects of
economic sustainability. As part of the evaluation, the Department encourages an
evaluation of the need to establish a commercial land use designation.
• Included in the major issue, "Natural Resource Protection,"is an evaluation of the
effectiveness of the Tier system. The Department recommends delaying the evaluation of
the Tier system until the next evaluation of the comprehensive plan. This would provide
additional time to implement and observe changes resulting from the tier designation
challenge that will not be fully implemented prior to 2011.
2555 SHUMARD OAK BOULEVARD ♦ TALLAHASSEE, FL 32399-2100
850-488-8466 (p) ♦ 850-921-0781 (f) ♦ Website: www.dca.state.fl.us
♦ COMMUNITY PLANNING 850-488-2356(p) 850-488-3309(f) ♦ FLORIDA COMMUNITIES TRUST 850-922-2207(p) 850-921-1747(f)
♦ HOUSING AND COMMUNITY DEVELOPMENT 850A86-7956(p) 850-922-5623(f)
Sylvia Murphy, Mayor
October 29, 2010
Page 2
• The EAR is an opportunity to compare the content of the comprehensive plan with
current statutory requirements to ensure that the plan is up to date. The Department
recommends that the County evaluate changes made to Section 380.0552(7)0), Florida
Statutes, which requires that growth be directed to areas served by central wastewater
treatment facilities. In so doing, the County should also evaluate the need to establish a
minimum score for applications for non-residential development in order to guide
development away from environmentally sensitive areas when there is a lack of
competition for the non residential building allocation.
• The EAR will also need to address all of the remaining applicable requirements set forth
under Section 163.3191(2), Florida Statutes.
We appreciate the effort you and your staff have shown in developing the EAR scoping
issues for Monroe County. We look forward to continuing to work with you as you prepare your
EAR. If you or your staff have any questions or need additional assistance, please contact
Rebecca Jetton, Area of Critical State Concern Program Manager, at(850) 922-1766.
Sincerely,
-s�
Charles Gauthier, AICP, Director
Division of Community Planning
Enclosure
CG/rj
cc: Ms. Christine Hurley, AICP, Growth Management Director
Ms. Carolyn A. Dekle Executive Director, South Florida Regional Planning Council
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MONROE COUNTY
EVALUATION AND APPRAISAL REPORT
DRAFT ISSUE COMPILATION REPORT
Pursuant to Florida Statutes,the Monroe County EAR will present an evaluation and
assessment of the Comprehensive Plan related to the following topics:
Introduction
1. Purpose of the EAR
2. County Profile
3. Overview of the Report
Chapter 1: Public Involvement Process
1. A summary of the public participation program and activities undertaken by the
County in preparing the report[163.3191(2)(D]
Chapter 2: Community-Wide Assessment
1. Population Analysis: Trends and Projections[163.3191(2)(a)]
a. Population Growth Trends
b. Population of Municipalities and Unincorporated Area
c. Population Growth in Surrounding Counties
d. Population Projections for Monroe County
2. Land Use Inventory
a. Land Area in Existing Plan
b. Current Existing Land Use Area
c. Reasons for change: [163.3191(2)(a)]
i. City of Marathon
ii. Village of Islamorada
iii. Mainland Monroe County
d. Impact of Change in Land Area
e. Amount of Vacant and Developable Land[163.3191(2)(b)]
i. Characteristics
ii. Adjacent Uses
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iii. "Off the Market" parcels (those not available for development, e.g.,
conservation - FDEP, Land Authority)
iv. Existing Land Use Map
v. Future Land Use Map
vi. Existing to Future Land Use Comparative Analysis [163.3191(2)(d)]
vii. Future Land Use Map Amendments (2004-2010)
f. Location Analysis
Chapter 3:Assessment of Comprehensive Plan Elements[163.3191(2)(h)]
1. Introduction
2. Future Land Use
3. Conservation and Coastal Management
4. Traffic Circulation
5. Mass Transit
6. Ports,Aviation and Related Facilities
7. Housing
8. Potable Water -
9. Solid Waste
,
10.Sanitary Sewer
11.Drainage
12.Natural Groundwater Aquifer Recharge
13.Recreation and Open Space
14.Intergovernmental Coordination
15.Capital Improvements
16.Cultural Resources
Chapter 4: Major Issues Analysis
1. Statement of Issue
a. Brief background of each major issue.
i. What is it?
ii. Can it be quantified?
iii. Compare the Past and the Present
1) What was the situation at the time of the Plan development?
2) What is the situation today?
3) If the issue can be quantified, compare the quantities in the
adopted plan with the current quantities.
EAR Compilation Report 2 Keith and Schnars,P.A.
November 17, 2010
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b. An analysis of each major issue for its potential social, economic, and
environmental impacts of these issues.[163.3191(2)(e)]
i. Why is it an issue?
ii. What events have occurred to cause the issue, (e.g. active hurricane
season)?
iii. What does this mean?
iv. Does the issue represent an opportunity not previously identified?
v. Why was it unanticipated?
2. Policy Framework[163.3191(2)(g)]
a. The identification of plan objectives related to each major issue.
b. Evaluation of the extent to which the objectives have been achieved.
c. Relevant Variables: A discussion on any unforeseen and unanticipated
changes and circumstances which have resulted in problems and.
opportunities with respect to major issues in each element, including
applicable legislative changes.
d. Identification of goals, objectives and policies which no longer apply.
3. Strategies to Address Issue[163.3191(2)(i)]
a. The identification of any actions or corrective measures, as appropriate:
i. Any land use map amendments anticipated to address the identified
major issues.
ii. An updated Capital Improvements Element.
iii. Any new and revised goals objectives and policies for major issues
identified within each element.
i
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Chapter 5: Special Topics
1. School Concurrency[163,3191(2)(k)]
a. An assessment of the success or failure of the coordination of the future land
use map and associated residential development with public schools and
their capacities.
i. Map Location of Schools and Community Facilities (Existing land Use
Map)
ii. Future Land Use Categories where schools are allowed
iii. Land Capacity
iv. School Capacities
v. School Busing Information
vi. Timing: Capacity vs. Enrollment
vii. Exemption _
b. An assessment of the joint decision making processes engaged in by the
County and the School Board in regard to establishing . appropriate
population projections and the planning and siting of public school facilities.
i. Coordinating Mechanisms between the County and the School Board
ii. Co-Location/Shared Use of Facilities
iii. Comprehensive Policy Effectiveness Review
iv. Population Projection Methodologies
2. Water Supply Planning[163.3191(2)(I)J
a. An assessment of whether the County has been successful in identifying
alternative water supply projects and traditional water supply projects,
including conservation and reuse, necessary to meet the water needs
identified in 373.0361(21(a) F.S.,within the County's jurisdiction.
b. Assess the degree to which the County has implemented the water supply
work plan for building public, private, and regional water supply facilities,
including development of alternative water supplies, identified in the Potable
Water Element as necessary to serve existing and new development.
c. The assessments will explore the following:
i. How does the Plan (future, infrastructure, and conservation, ICE, and
CIE elements) ensure water to support future development, including
Miami-Dade County?
ii. What actions were taken?
iii. What degree has the Water Supply planning objectives been
achieved?
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iv. How should the Plan be updated?
v. Effectiveness in implementing the capital improvements called for in
the 10 year work plan.
vi. Water Management District Plan
vii. Water Supply Facilities
viii. Florida Keys Aqueduct Authority (FKAA) Water Supply Plan
ix. Capacity/Demand
x. Existing and Future Population
xi. Fire Suppression
xii. Funding
xiii. Consistency with the Lower East Coast Regional Water Supply Plan
3. Coastal High-Hazard Area (CHHA) [163.3191(2)(m)]
a. An evaluation of whether any past reduction in land use density within the
coastal high-hazard area impairs the property rights of current residents when
redevelopment occurs including, but not limited to, redevelopment following a
( natural disaster
b. Identify strategies to address redevelopment and the property rights of
affected residents balanced against public safety considerations
c. The evaluation will explore the following:
i. Evaluate Redevelopment Feasibility and Property Rights in Coastal
High-Hazard Areas.
ii. Map Coastal High Hazard Area.
iii. Evaluate Impact of Redevelopment (e.g. Reduction of Existing
Density).
iv. Evaluate Feasibility of Allowing Re-establishment of All Affected
Dwelling Units.
1) Hurricane Evacuation Requirements.
2) Private Property Rights.
v. Explore Potential Strategies for Redevelopment:
1) Allow nonconformities to continue until redevelopment.
2) Allow re-establishment of nonconforming use/density after a
natural disaster.
3) Purchase of excess rights; acquired rights eliminated.
4) Purchase of repetitive loss structures (HMGP).
5) Transfer of Development Rights: Excess property rights would be
transferred to parcels outside the CHHA.
EAR Compilation Report 5 Keith and Schnars,P.A.
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allowed if no increase in overall density and within hurricane
evacuation clearance times)
4. Compatibility with Military Installations
[163.3175 and 163.3177(6)(a), F.S.]
a. Evaluate the effectiveness of the County's coordination process for land uses
adjacent or closely proximate to NAS-Key West and other military activities
within Monroe County.
b. Evaluate the need for sound attenuation standards and other techniques
proximate to military installations.
5. Transportation Concurrency
•
a. An assessment of the extent to which a concurrency exception area
designated pursuant to 163.3180(5) F.S., or a multimodal transportation
district designated pursuant to 163.3180(15) F.S., has achieved the purpose
for which it was created and otherwise complies with the provisions of
163.3180 F.S.[163.3191(2)(o)]
NOTE: Not applicable, there are no concurrency exception areas or
multimodal transportation districts within the County.
b. An assessment of the extent to which changes are needed to develop a
common methodology for measuring impacts on transportation facilities for
the purpose of implementing a concurrency management system in
coordination with the municipalities and counties, as appropriate pursuant
to 163.3180(10) F.S./163.3191(2)(p)]
i. US1 Task Force,
ii. Existing Methodology
iii. Miami-Dade County
Chapter 6: Assessment of Changes to Florida Statutes, Administrative Rules,
State and Regional Plans[163,3191(2) (f)J
EAR Compilation Report 6 Keith and Schnars,P.A.
November 17, 2010
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EAR MAJOR ISSUES
A. PUBLIC PARTICIPATION
Public participation was initiated through a website created for the update of the
_County's Comprehensive Plan and the EAR process (http: www.keyscompplan.com).
The site contains a brief overview of the EAR process, information about public
workshops and meetings, and links to other EAR related documents. The following
meetings and public hearings were held in order to identify the major local issues on
which the County will focus its EAR:
• February 12, 2010: A meeting with the County's Division Directors:was
conducted. The purpose of the meeting was to introduce staff to the
Comprehensive Plan _ update process and to `obtain preliminary comments
regarding potential EAR major issues.
• February 24, 2010: The Planning Commission meeting was held at the Marathon
Government Center. The purpose of the meeting was to provide a briefing
i regarding the Comprehensive Plan update process and to survey the
commissioners regarding the major issues upon which the EAR should focus.
• February 24 - 26, 2010: One-on-one interviews were conducted with the Board
of County Commissioners. The purpose of these meetings was to provide a
briefing regarding the Comprehensive Plan update process and to survey the
commissioners regarding the major issues upon which the EAR should focus.
• March 10, 2010: Monroe County Division Directors and other key personnel
were surveyed on the major issues upon which the EAR should focus.
• April 9 - 11, 2010: A series of public workshops were conducted in the lower,
middle and upper keys to survey the participants regarding the major issues of
importance upon which the EAR should focus.
• April 21, 2010: A public workshop was held on Sugarloaf Key. The purpose of
the meeting was to survey the participants regarding the major issues of
importance for the EAR
• May 13, 2010: At the Scoping Meeting, agencies, adjacent cities and
municipalities met with County staff for the purpose of ensuring that all
important EAR issues are identified; agency/municipality concerns are
EAR Compilation Report 7 Keith and Schnars,P.A.
November 17, 2010
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addressed; and to assist the County in developing strategies to address issues
that are within their jurisdiction or expertise.
• July 14, 2010: A public workshop was conducted for the purpose of confirming
the final draft list of major issues.
• September 15, 2010: At this hearing, the BOCC approved the Compilation
Report of issues upon which the EAR should focus, with the addition of
expanding the evaluation of coordination process for land uses regarding Special
Topic 4, "Compatibility with Military Installations" to include "other military
activities" and under Major Issue I, "County-wide Visioning and Planning" to add
evaluation of maximum net density provisions; and approved the transmittal of
a Letter of Understanding and the Compilation Report to the DCA requesting
concurrence.
B. LIST OF MAJOR ISSUES
I. County-wide Visioning and Planning
Capitalize upon and protect the uniqueness(sense of place) of the various communities )
within the planning areas; implement the recommendations within the existing
visioning plans.
a. Do the County's policies recognize and preserve the unique
development/redevelopment patterns and community character within each
Planning Area?
1. Building Scale and Massing
2. Architectural standards
3. Existing Land Uses (especially water dependent uses)
4. Habitat and Species Protection
5. Infrastructure
i. Wastewater
ii. Stormwater
iii. Roads/bridges
6. Encouraging redevelopment of sites that are currently developed vs. vacant
land (NROGO constraints on redevelopment)
7. Evaluate floor area ratio maximums in each of the Future Land Use
categories for compatibility.
8. Evaluate opportunities for discouraging density increases, including
requiring any Future Land Use Map amendment to transfer allocated or
maximum net density.
9. Evaluate the issues relating to maximum net density. )
EAR Compilation Report 8 Keith and Schnars,P.A.
November 17, 2010
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b. Do the County's policies reflect the recommendations of the existing community
visioning plans?
1. Stock Island Livable CommuniKeys Plan
2. Key Largo Livable CommuniKeys Plan
3. Tavernier Livable CommuniKeys Plan
4. Draft Lower Keys Livable CommuniKeys Plan
5. Scenic Highway and Overseas Heritage Trail Master Plans
c. Do the Comprehensive Plan policies need to address outside jurisdictional
constraints?
1. FEMA injunction or processes that need to be amended related to the FWS
biological opinion relative to the FEMA injunction.
II. Economic Sustainability
Promote economic sustainability, in a manner consistent with environmental
stewardship,-with.a special focus upon existing businesses.
a. Designate economic business development locations on the Future Land Use
Map.
b. Do the County's policies enhance and promote the economic strength of the
County in a sustainable manner that protects natural resources?
c. Do the County's land use categories and maps provide sufficient land, at
appropriate intensities, within Tier 3 (adjacent to existing services) to
adequately provide for non-residential development?
- 1. The analysis will be based upon the results of the Economic Analysis.
d. Do the County's existing policies promote job diversification, creation, retention?
e. Do the County's policies encourage existing business redevelopment?
f. How successful is the County in promoting business opportunities to designated
areas? t _
g. Is the County successful in working with the various Chambers of Commerce in
attracting economic development opportunities?
h. Do the County's _ policies promote effective coordination with the Tourist
Development Council to attract visitors who value and appreciate the natural
resources and environmental sustainability of the Florida Keys, e.g., eco-
tourism?
i. How successful is the County in promoting business opportunities to designated
areas?
j. Evaluate the need to establish a commercial land use designation.
k. Is there a need for a separate Economic Development Element of the
Comprehensive Plan?
( j
EAR Compilation Report_ 9 Keith and Schnars,P.A.
November 17, 2010
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III. Land Use/Mobility
Promote Attractive, Well-Planned Development Adjacent to Services, and Existing
Commercial "Hubs", with an Emphasis on Redevelopment.
a. Do the County's policies relating to the ROGO system promote well-planned
development in appropriate areas?
b. Do the County's policies relating to the NROGO system promote well-planned
development in appropriate areas?
1. Does the commercial square foot per new unit of housing limit, established in
Policy 101.3, provide the appropriate framework for redevelopment or for
adequate community needs?
2. Should the County undertake a market demand analysis to determine the
future non-residential needs of the community?
c. Do the County's policies relating to the Tier system promote well-planned
development in appropriate areas? .
d. Do the County's policies effectively address the issues related to Mainland
Monroe County?
e. Do the County's policies adequately address growth management issues within
the Mainland Planning Area? _
f. Do the County's policies promote well-planned redevelopment projects? _
g. Do the County's policies adequately reflect the conclusions of the County's
Future Land Use Needs Analysis?
h. Do the County's policies and vesting determination process effectively protect
lawfully existing uses, densities and intensities?
i. Identify appropriate locations for fire stations on the Future Land Use Map.
j. Evaluate changes made to Section 380.0552(7)(j), Florida Statutes, which
requires that growth be directed to areas served by central wastewater
treatment facilities.
k. Evaluate the need to establish a minimum score for applications for non-
residential development in order to guide development away from
environmentally sensitive areas when there is a lack of competition for the non
residential building allocation.
The County Should Meet or Exceed Hurricane Evacuation Requirements as required by
9J-5 F.A.C.
a. Do the County's policies effectively balance the need for evacuation clearance
with growth?
EAR Compilation Report 10 Keith and Schnars,P.A.
November 17, 2010
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b. Does the current hurricane evacuation model use adequate assumptions and will
the model reflect any successful policy changes implemented since the first 2001
Model?
Support Historic Preservation.
a. Do the County's policies effectively promote preservation of historic sites and
structures?
b. Should the County include policies that offer incentives or promote cultural
attractions?
Assure Continued Public Waterfront Access; Protect and Expand Water
Dependent/Water Related Uses.
a. Do the County's land use policies effectively promote the preservation and
expansion of public water front access strategies (hotels, motels, restaurants,
marinas,public open/green space)?
b. Does the Comprehensive Plan include criteria and regulatory incentives that
encourage the preservation of recreational and commercial waterfronts, as
required--under Chapter 163, F.S.; how. effective have those criteria and
incentives been?
c. Based upon the evaluation noted above, include criteria, as may be necessary, to
encourage the preservation of recreational and commercial working
waterfronts.
Increase Availability and Use ofAlternative Modes Transportation.
a. Do the County's policies promote the use and development of alternative modes
of transportation, e.g.,pedestrian/bicyclist-trails; mass transit?
b. 'Has the County provided pedestrian and bicycle paths and other alternate forms
of transportation?
c. How successful is the County in coordinating its Livable CommuniKeys plans with
FDOT's work plans?
d. How successful is the County in implementing mass transit for its elderly and
less fortunate population?
e. Has the County addressed mass transit opportunities?
IV. Natural Resource Protection
Preserve and protect natural resources, including water, habitat and species.
a. Do the County's policies protect potable water supply?
EAR Compilation Report 11 Keith and Schnars,P.A.
November 17, 2010
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b. How has the County protected Threatened, Endangered and Special Status
Species and their habitats?
c. How has the County protected wetland areas, benthic resources and
environmentally sensitive lands?
d. Evaluate the effectiveness of the following initiatives:
1. Land Acquisition
2. Habitat Conservation Plan for Big Pine and No-Name Keys (Incidental Take
Permit)
e. How has the Comprehensive Plan addressed water quality and what protection
measures are in place?
f. Has the County addressed the Nutrient Reduction Criteria?
g. How has the County conserved water resources; are enforcement efforts
effective?
h. Is the County's solid waste collection and disposal system adequate?
i. Are the County's policies and practices adequate to protect native species and
habitat from invasive animals (feral cats/raccoons/snakes/goats)?
Complete Wastewater and Drainage Upgrades.
a. How successful is the County in providing sewer and drainage improvements
through the Key Largo Wastewater Treatment District and FKAA?
b. Do the comprehensive plan policies incorporate the most recent State and
Federal regulatory requirements relative to waste water and stormwater
treatment standards?
c. How do the County's fiscal constraints impact the implementation of the Waste
Water Master Plan?
d. Should funding alternatives for Stormwater Management Master Plan
implementation be explored?
V. Climate Change/Hazard Mitigation
Monroe County should support and promote "green" initiatives; address climate
change; and develop and implement hazard mitigation/adaptation best practices.
a. Do the County's polices promote energy conservation and provide strategies
geared to reduction of green house gas emissions?
EAR Compilation Report 12 P P Keith and Schnars,P.A.
November 17, 2010
'c• ? MONROE COUNTY COMPREHENSIVE PLAN UPDATE
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b. Do the policies of the County include appropriate mitigation/adaptation
strategies?
1. Local Mitigation Strategy
2. .Post-NFIP Below Flood Enclosures
3. Repetitive Loss Structures
4. Vulnerable Infrastructure
i. Water
ii. Wastewater
iii. Transportation
iv. Culverts
5. Evaluate the Impact of Sea Level Rise:
i. Government Buildings
ii. Roadways
iii. Land Use Strategies
iv. Saltwater Intrusion
1) People -
2) Environment
3) Land values
'� 4) NEPA Adaptation/Mitigation Requirements
c. Is there a need for a separate Energy and/or Climate Change Element?
VI. Financial Feasibility
Assure adequate capital funding to complete necessary improvements or purchase
lands for conservation or affordable housing purposes.
a. Does the County have adequate Capital Project Funding Capacity?
1. Wastewater .
2. Land Acquisition
i. Conservation
ii. Affordable Housing
iii. Stormwater
iv. Roads/Transportation Facilities/Bridges
v. Parks and Recreation
vi. Solid Waste
b. Has the County investigated creative funding sources to assist in paying for its
capacity related public facilities and services, which may include adopting new
revenue sources, increasing impact fees, and promoting business throughout the
County?
•
EAR Compilation Report 13 Keith and Schnars,P.A.
November 17, 2010
' " �`� �r �1!1�( NROE� COUNTY COMPREHE SIVE PLAN UPDATE
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c. Have developer funded improvements been successful in helping the County
meet financial feasibility?
d. Do the County's policies reflect an adequate land acquisition policy related to
habitat preservation and a prioritization of land acquisition based on risk to the
County related to takings cases?
e. Are there other methods the County could use to create additional funding for
land acquisition?
f. Will the County's CIE be able to meet statutory requirements related to the
financial feasibility by December, 2011?
g. Evaluate the adequacy of the County's existing Impact Fee Program.
VII. Affordable Housing
Promote the development of affordable, attainable and senior living housing that is
well-planned, attractive and energy efficient.
a. Do the County's policies effectively promote affordable, workforce and senior
living housing?
b. Do the County's policies promote energy efficientbuilding design?
c. How do the County's policies impact the implementation and cost of housing?
d. Should affordable housing policy incentives be focused more on rental or
homeownership?
e. Has the County identified or planned redevelopment areas that are suitable for
affordable/workforce housing?
- VIII. Public Involvement/Information
Promote robust public involvement and information sharing regarding land use issues -
throughout the planning and development process.
a. Do the County's policies effectively promote public involvement within.the
planning process?
b. What strategies are used by the County to inform the public of upcoming
planning issues?
c. Do the County's public outreach strategies reach out to a broad-range of citizens
and property owners?
EAR Compilation Report 14 Keith and Schnars,P.A.
November 17, 2010
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COU.I� CtJMPREHE.I�SI'�E PT�A� UPDATE
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IX. Intergovernmental Coordination ._
Provide effective and efficient intergovernmental, interdepartmental and interagency
coordination.
a. Do the County's land use policies, community plans, practices, and capital
improvement project schedule effectively coordinate with the plans and
activities of other municipalities and agencies, e.g. hurricane evacuation staging,
and planning, FDOT roadway widening?
b. Do the County's policies encourage effective and efficient interdepartmental data
sharing and review?
c. Evaluate the issues relating to the FKAA providing adequate water pressure for
fire service?
d. Identify the appropriate portions of the FKCCS Study and Model to be used by
the County for development review analysis.
e. Evaluate the County's coordination activities with the South Florida Regional •
Planning Council for the use of the Carrying Capacity/Impact Assessment Model
and Routine Planning Tool:- -- - - .. -.-..-
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EAR Compilation Report 15 Keith and Schnars,P.A.
November 17, 2010