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South Florida Regional Planning Council meets June 7 at Hawk's Cay Resort, Duck Key.  They will hear public comments on the proposed Development of Regional Impact proposed for Florida City.  Here are two documents outlining major concerns about the development.  The first is Audubon of Florida's letter, the second is Ocean Reef's resolution.  They were presented at the May meeting of the South FL Regional Planning Council.

First the Audubon letter:

Restoration and Sustainable Growth Threatened by proposed DRI in Miami-Dade County

Atlantic Civil, Inc. has submitted a Development of Regional Impact (DRI) pre-application to the South Florida Regional Planning Council (SFRPC), encompassing 1,465 acres in southern Miami-Dade County. The proposed DRI is outside the urban expansion area (UEA) (2015 projection), as well as the urban development boundary (UDB). This proposed development would undermine two (2) Comprehensive Everglades Restoration Plan (CERP) Projects, and is located on lands actively pursued for acquisition by both the South Florida Water Management District (SFWMD) (Save Our Rivers Model Lands Basin) and Miami-Dade County (Environmentally Endangered Lands Program).

To ensure a sustainable South Florida, it is important to:

  • avoid destroying wetlands, while initiating a multi-million dollar wetland restoration project within the same basin,
  • consider the system-wide cumulative impacts of growth management decisions on restoration, and
  • actively engage in growth management throughout the watershed to protect the viability of restoration.

Recommendation: The South Florida Regional Planning Council should deny the proposed Florida City DRI until the completion of the SFRPC-sponsored South Miami-Dade Watershed Plan, and the BBCW and C-111 N Spreader Canal Project Implementation Reports.  

Undermines CERP Projects

Biscayne Bay Coastal Wetlands (BBCW) - The purpose of the BBCW project is to “re-hydrate wetlands.” The proposed development directly conflicts with the Barnes Sound Wetland sub-component to restore sheet flow. This development would convert wetlands to concrete and asphalt, contrary to the goals of the restoration project envisioned for this area.

C-111 North Spreader Canal - The purpose of the C-111 North Spreader Canal is to “re-hydrate the Model Lands [and] establish sheet flow[.]” The proposed Florida City DRI would drain 1,465 acres of historic wetlands within the federally-designated 100-year floodplain just north of the C-111 Project area, and pollute water discharging into the Models Lands Basin and the C-111 North Spreader Canal during large storm events.

Inconsistent with the Miami-Dade County Comprehensive Development Master Plan

Land Use Policy 2B discourages urban development in agricultural and open land areas and prioritizes the provision of services to areas within the UDB first and the UEA second. Development of environmentally sensitive areas outside the UDB and UEA is inconsistent with goals of the Comprehensive Development Master Plan (CDMP).

Land Use Policy 3E requires the development and implementation of a South Miami-Dade Watershed Plan “to assure compatible land use and zoning decisions in the Study Area consistent with long term objectives for a sustainable South Dade.” The Miami-Dade County CDMP recommends, “heightened scrutiny to proposed changes in the UDB, land use designations, and zoning” until the Watershed Plan is completed.

Conclusions

Undeveloped areas in the vicinity of the BBCW and C-111 North Spreader Canal CERP Projects should be protected from development until the completion of the Project Implementation Reports and the South Miami-Dade Watershed Plan. Development outside the UDB should be denied until these projects have identified land use and water management strategies that will ensure the enhancement of the environmental, economic, and community values of the area. 


Here is Ocean Reef's resolution:

A resolution of the Ocean Reef Community Association Board of Directors expressing concerns about a large-scale mixed use development, proposed by Atlantic Civil, Inc., referred to as the Florida City Development of Regional Impact (DRI), and directing staff to communicate ORCA’s concerns to the South Florida Regional Planning Council  in the development review process and oppose any element or phase of the development that will negatively impact the health, safety and welfare of Ocean Reef residents or will have a detrimental effect on the environment and economic base of Ocean Reef.

Whereas, Atlantic Civil, Inc. proposes to develop 1,465 acres of a 3,187 acre tract located approximately  at the junction of Card Sound Road, U.S. 1 and the Florida’s Turnpike in south Miami-Dade County, hereinafter called the “Florida City DRI”; and,

Whereas, the proposed Florida City DRI development consists of 6,000 dwelling units, 300,000 square feet of retail, 90,000 square feet of office, an 1,800 seat theater, 240 hotel rooms, a Kindergarten to 8th grade school, a high school and 60 acres of parks to be developed over a ten-year period; and,

Whereas, the proposed development requires approval as a Development of Regional Impact under Chapter 380, Florida Statutes; and,

Whereas, the subject parcel requires amendments of the Miami-Dade County Comprehensive Development Master Plan Future Land Use Map (FLUM) and, the 2005 Urban Development Boundary (UDB), as it is located outside the 2005 Urban Development Boundary; and,

Whereas, a significant amount of vacant, developable land already exists with existing or programmed infrastructure and public services within the existing UDB north of the subject development to easily accommodate the demand for tens of thousands of new dwellings and large scale commercial, office and other non-residential development in South Miami-Dade without having to expand the existing UDB further towards the Florida Keys and environmentally sensitive lands; and,

Whereas, an expansion of the UDB will only further encourage urban sprawl and leap-frog development, and the additional loss of valuable, irreplaceable agriculture lands and open space in Southwest Miami-Dade County; and,

Whereas, the expansion of the 2005 Urban Development Boundary will lead to further requests to expand the Urban Development Boundary (UBD) in Southwest Miami-Dade County to the further detriment of Ocean Reef and the fragile Everglades, Florida Bay, Biscayne Bay, and Florida Keys ecosystem; and,

Whereas, the proposed development, which is all located within the 100-year flood plain, has potential adverse impacts for the full implementation of the Everglades Restoration Plan as it may well change the existing flood water holding capacity of the area, and the historic drainage and flow patterns of surface water to the Everglades, Florida Bay and Biscayne Bay; and,

Whereas, storm water from such development could lead to increased storm water pollution loading into Florida Bay and the Everglades, further degrading the quality of water surrounding Ocean Reef and the Florida Keys which is vital for sustaining the commercial fishing and tourism economy of the Florida Keys; and,

Whereas, the proposed development is in a location approximate to the Florida Keys Aqueduct Authority’s well fields that provide Ocean Reef with its primary source of drinking water and may have potential detrimental impacts on the yield capacity of this well system, which is already severely constrained; and,

Whereas, the proposed development will place increased permanent and transient population within easy access to Monroe County that will further add to the number of “weekend and day-trippers” to the Florida Keys further overwhelming the capacity of the County’s infrastructure and services; and,

Whereas, the project is located within an area recommended in the Miami-Dade Hurricane Evacuation Plan for evacuation during a Category 2 or greater hurricane; and,

Whereas, the proposed development will utilize SW 360th Street to create a main exit point at the critical junction of Highway 1 and Card Sound Road, which is the sole hurricane evacuation route for Ocean Reef and  the Florida Keys; and,

Whereas, the loading of additional evacuation traffic from this proposed development at this critical road junction may detrimentally place the safety of the persons living and visiting Ocean Reef and the Florida Keys at much greater risk by increasing hurricane evacuation times and the possibility of life-threatening traffic jams during evacuation; and,

Whereas, future development in the Florida Keys is directly tied to the time necessary to evacuate the Florida Keys, as evacuation is mandatory for residents and visitors for any Category 3 or greater hurricane; and,

Whereas, under the current Hurricane Evacuation Model, the Florida Keys are already over the 24 hour standard that is required by the State of Florida and the County’s Year 2010 Comprehensive Plan; and,

Whereas, increasing the evacuation times for the Florida Keys resulting from the impacts of this development may even further limit the development of the Florida Keys in a manner that detrimentally impacts the Florida Keys economy and the capabilities of the County and its municipal governments to acquire environmentally sensitive lands, provide needed work force housing, and generate sufficient revenues to fund wastewater improvements to meet the stringent 2010 wastewater treatment standards mandated by the State; and,

Whereas, the ORCA Board is further concerned that such an adverse impact may jeopardize the ability of the County to fully meet the commitments of the partnership that the County recently entered into with the State of Florida to revise Rule 28.20 Florida Administrative Code government the Florida Keys Areas of State Critical Concern;

NOW THEREFORE BE IT RESOLVED BY THE OCEAN REEF COMMUNITY ASSOCIATION BOARD OF DIRECTORS THAT:

Section 1:  The intensity and location of development proposed under the Florida City DRI may have significant adverse primary impacts on Ocean Reef and the Florida Keys in terms of hurricane evacuation, potable water supply, the Everglades Restoration Program, and Florida Bay and Biscayne Bay water quality.  Potential secondary adverse impacts on the County resulting from the development will be an increase in the numbers of day and weekend trippers to primarily the Upper and Middle Keys further overwhelming the already constrained capacity of the County’s infrastructure and services.

Section 2:  The project will only further encourage and induce additional urban sprawl in South Miami-Dade by expanding the Urban Development Boundaries eventually leading to the elimination of the last acres of open space and agricultural lands remaining in South Miami-Dade County and placing even further unnecessary strains on the viability of the Everglades and Florida Bay ecosystem.

Section 3:  If approved as proposed, the project and similar large-scale developments already occurring unimpeded in South Miami-Dade County may well threaten the County’s long-term ability for sustainable development in terms of providing economic and housing opportunities for residents without compromising the biodiversity of the natural environment and continued ability of the natural and man-made systems to sustain livable communities in the Florida Keys for future generations.  In the short-term it threatens to limit the County’s ability to follow through on commitments made to the Governor and Cabinet and Florida Department of Community Affairs to address wastewater, affordable housing, and acquisition of significant upland habitat issues.

Section 4:  ORCA’s representative is directed to work with the County’s representatives to the South Florida Regional Council to represent Ocean Reef’s concerns before that body concerning the proposed Florida City DRI and before other state and local governing and advisory bodies as appropriate.  ORCA’s representative is also directed to report back to the Board with status reports and recommendations on any further Board action on this proposed development.

Section 5:  Staff is instructed to continue to monitor the DRI review and approval process for this project, including reviewing and providing input on the final DRI application and supporting amendments to the Miami-Dade County Comprehensive Development Master Plan Future Land Use Map and 2005 Urban Development Boundary; and prepare recommendations, as appropriate, for ORCA’s Board to be submitted to the State of Florida, South Florida Regional Planning Council, Miami-Dade County, or other appropriate governing or advisory body.

Section 6:  ORCA will oppose, and direct its staff to oppose, any element or phase of the proposed development that it is shown to have a deleterious and negative impact, either directly or indirectly, on the health, safety and welfare of its residents and on the environment and tourism economic base of the Florida Keys.

Section 7:  Staff is requested to send an executed copy of this resolution to the Florida Department of Community Affairs, South Florida Regional Planning Council and Miami-Dade County Commission requesting that Ocean Reef’s concerns and issues identified by this resolution be fully addressed by the applicant in its project assessment for the DRI and application for amendments to the Miami-Dade County Comprehensive Development Master Plan Future Land Use Map and 2005  Urban Development Boundary. 

Passed and adopted by the Ocean Reef Community Association Board of Directors, at a regular meeting of said Board held on the ___ day of April 2004.

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