ORC REPORT - MAY 13, 1989 / COMPREHENSIVE PLAN AMENDMENTS 1989
ORC Report - May
31, 1989
Comprehensive Plan
Amendments 1989
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COMPREHENSIVE PLAN
AMENDMENTS
1989
(ORC Report - May 31 1989)
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2 7 4 0 C E N T E R V I E W D R I V E . TAL L A HAS SEE, F LOR I,D A J 2 J 9 9
BOB MARTINEZ
C~
THOMAS G PElHAM
Seamry
September 11, 1989
The Honorable Rita Garvey
Mayor of Clearwater
City of Clearwater
Post Office Box 4748
Clearwater, Florida 34618-4748
Dear Mayor Garvey:
The Department has completed its review of the proposed
comprehensive plan for the City of Clearwater, which was
submitted on May 31, 1989. Copies of the proposed plan were
distributed to appropriate state, regional and local agencies for
their review and their comments are enclosed.
I am enclosing the Department's Objections, Recommendations
and Comments Report" issued pursuant to Rule 9J-ll.OlO, Florida
Administrative Code. Upon receipt of this report, the City of
Clearwater has 60 days in which to adopt the proposed plan or
adopt the plan with changes. The process for adoption of local
comprehensive plans is outlined in s.163.3184, Florida Statutes,
and Rule 9J-ll.Oll, Florida Administrative Code.
Within five working days of the date of adoption, the City
of Clearwater must submit the following to the Department:
Five copies of the adopted comprehensive plan;
A copy of the adoption ordinance;
A listing of additional Changes not previOUSly reviewed;
A listing of findings by the local governing body, if any,
which were not included in the ordinance; and
A statement indicating the relationship of the additional
changes to the Department's Objections, Recommendations and
Comments Report.
EMERGENCY MANAGEMENT. HOUSING AND COMMUNITY DEVELOPMENT. RESOURCE PLANNING AND MANAGEMENT
The Honorable Rita Garvey
September II, 1989
Page Two
The above plans and documentation are required for the
Department to conduct the compliance review, make a compliance
determination and issue the appropriate notice of intent.
As a deviation from the requirement above, you are requested
to provide one of the five copies of the adopted plan directly to
the Executive Director of the Tampa Bay Regional Planning
Council. The regional planning councils have been asked to
review adopted plans to determine local comprehensive plan
compliance with the Comprehensive Regional POlicy Plan. Your
cooperation is appreciated in this matter.
If you would like the Department to participate in the
public hearing for plan adoption, such request should be received
by the Department, certified mail, at least 14 days prior to the
scheduled hearing date.
If you have any questions, please contact Bob Nave, Bureau
Chief or Meredith Dahlrose, Review Team Leader, at (904)487-4545.
mk
aul R. Bradshaw, Director
Division of Resource Planning
and Management
PRBjmdz
Enclosures: Objections, Recommendations and Comments Report
Review Agency Comments
cc: Mr. Jim Polatty, Director of Planning and Development
DEPARTMENT OF COMMUNITY AFFAIRS
OBJECTIONS, RECOMMENDATIONS AND COMMENTS
FOR
CLEARWATER
Septem ber II, 1989
DivIsion of Resource Plannmg and Management
Bureau of Local Plannmg
Thll report .1 prepared purauant to Rule 9J.ll 010
INTRODUCTION
~
The following objections, recommendations and comments are
based upon the Department's review of the comprehensive plan
pursuant to s.163.3184, F.S.
Objections (A. in the attached report) relate to specific
requirements of relevant portions of Ch. 9J-5, F.A.C., and
Ch. 163, F.S. Each objection includes a recommendation of one
approach that might be taken to address the cited objection.
Other approaches may be more suitable in specific situations.
Some of these objections may have initially been raised by one of
the other state agencies. If there is a difference
between the Department's objection and the state agency advisory
objection or comment, the Department's objection would take
precedence.
Each of these objections must be addressed by the local
government and corrected when the plan is resubmitted for our
compliance review. Objections which are not addressed may result
in a determination that the plan is not in compliance. The
Department may have raised an objection regarding missing data
and analysis items which the local government considers not
applicable to its plan. If that is the case, a statement
justifying its non-appliCability pursuant to Rule 9J-ll.004(2) (f),
F.A.C., must be submitted. The Department will make a
determination on the non-applicability of the requirement, and if
the justification is sufficient, the objection will be considered
addressed.
The comments (B. in the attached report) which follow the
objections and recommendations section are advisory in nature.
Comments do not represent objections and will not form bases of a
determination of non-compliance. They are included to call
attention to items raised by our reviewers. The comments can be
substantive, concerning planning principles, methodology or
logic, as well as editorial in nature dealing with grammar,
organization, mapping, and reader comprehension.
Appended to the back of the Department's report are the
comment letters from the other state review aqencies and other
aqencies, organizations and individuals. These comments are
advisory to the Department and may not form bases of Departmental
objections unless they appear under the "Objectionsl! heading in
this report.
OBJECTIONS, RECOMMENDATIONS AND COMMENTS
City gf Clearwater
PUBLIC PARTICIPATION
A. OBJECTIONS
1. 9J-5.004(11
The submitted public participation procedures adopted
by the local governing body of local planning agency
which provide for and encourage future public
participation in the planning process, do not include
consideration of amendments to the adopted plan,
subsequent evaluation and appraisal reports and
procedures which include provisions for notifying real
property owners, keeping the general public informed,
providing written comments, public hearings, and
consideration of and response to public comments.
Recommendation
Include adopted public participation procedures which
include consideration of amendments to the adopted
plan, subsequent evaluation and appraisal reports, and
contain the following provisions.
(a) Assure the real property owners are put on notice of
official actions affecting the use of their property;
(b) Keep the general public informed;
(c) Assure opportunity for public written comment;
(d) Assure required public hearings are held; and
(e) Assure consideration and response to public comments.
B. COMMENTS
None
EVALUATION AHQ APPRAISAL REPORT
A. OBJECTIONS
None
B. COMMENTS
None
FORMAT REOUIREMENTS
1
A. OBJECTIONS
1. 9J-S.OOS(l) ld)l.
An overall table of contents for the proposed
comprehensive plan (both volumes) is not inc~uded.
Recommendation
Include a table of contents for the comprehensive plan.
This table may be generalized with more detailed tables
included within each element.
2. 9J-S.OOS(l) ld)1. ang ~
A table of contents (which included a list of tables,
maps, and figures) is not included for the Coastal
Management Element.
Recommendation
Include a table of contents for the Coastal Management
Element.
3. 9J-5.005(1) fd)2.
Many of the tables and maps in the comprehensive plan
are not located on numbered pages. All elements, except
Coastal Management and Recreation and Open Space,
include a table of contents which identifies a page
number for all tables and maps within the element, yet
the pages on which these tables and maps actually appear
may not be numbered.
Recommendation
Include page numbers on all pages on which tables or
maps appear.
4 . 9J - 5 . 005 ll) l d) 6 .
Titles and/or sources are not included for the
following tables and maps:
Table 6-12 pg. 79 Future Land Use
Table 6-13 pg. 81 Future Land Use
Table 6-14 pg. 83 Future Land Use
Table 7-1 pg. 13 Traffic circulation
Table 7-2 pg. 25 Traffic Circulation
Table 9-10 pg. 37 Aviation
Table 11-1 pg. 9 Drainage
2
Table 11-6 pg. 20 Drainage
Table 11-7 pg. 21 Drainage
Table 11-8 pg. 22 Orainage
Table 11-9 pg. 23 Drainage
Map pg. 1-2 Coastal Management
Map pg. 8-9 Coastal Management
Table 3 pg. 10-11* Coastal Management
Table 4 pg. 14-15* Coastal Management
Table 5 pg. 21-22* Coastal Management
Map pg. 21-22* Coastal Management
Map pg. 23-24* Coastal Management
Map pg. 35-36* Coastal Management
Map pg. 36-37* Coastal management
Table 6 pg. 39-40* Coastal Management
Table 7 .. 50-51* Coastal Management
pg.
Table 8 pg. 51-52* Coastal Management
Table 9 pg. 52-53* Coastal Management
Table 11 pg. 53-54* Coastal Management
Table 12 pg. 54-55* Coastal Management
Map pg. 63-64* Coastal Management
Map pg. 81-82* Coastal Management
Map pg. 83-84* Coastal Management
Table 13-2 pq.22 Conservation
Table 13-3 pg. 31 Conservation
Table 13-4 pg. 46 Conservation
Table 16-1 pq. 3 Capital Improvements.
Map 16-1 pq. 15 Capital Improvements
* Located between these pages. No page number indicated.
Maps are not assigned an identification number.
...
Recommendation
Include titles and/or sources for the above referenced
tables and maps.
5. 9J-5. 005 (11 (e)
The maps used in the comprehensive plan do not include
the municipal boundaries for the adjacent communities
of Dunedin, Safety Harbor, Oldsmar and Largo. without
the delineation of adjacent municipal.boundaries there
is no way to determine whether lands adjacent to the
city are unincorporated or part of an adjacent
community.
Recommendation
Include a delineation of adjacent municipal boundaries
on all appropriate maps.
B. COMMENTS
3
None
POPULATION ESTIMATES AHD PROJECTIONS
A. OBJECTIONS
None
B. COMMENTS
None
Goals. Ob;ectives gng Policies
A. OBJECTIONS
1. 9J-S.005(6). 9J-S.003(32). 9J-S.003(57) 9J-5.003(64)
(a) Goals which do not state a long-term end towards which
programs or activities are directed are not acceptable.
(b) Ob;ectives which are not measurable, not supported by
the data and analysis and are stated in an unspecific,
tentative and/or conditional manner are unacceptable.
(c) Policies which are tentative or conditional, or do not
describe the activities, programs and land development
regulations which will implement the plan, are
unacceptable.
(d) Requirements identified in Chapter 9J-S, F.A.C., which
are required to be addressed by objectives and policies
must be based upon relevant and appropriate data.
(e) Land development regulations to be adopted pursuant to
s. 163.3202, F.S., must be adopted and implemented
within one year after the due date for submission of
the revised comprehensive plan.
Recommendation
A goal must be written to state the long-term desired
result (Rule 9J-S.003(32), F.A.C.). Ob;ectives must be
written in a way that provides specific measurable
intermediate ends that mark progress toward a goal
(Rule 9J-S.003(S7), F.A.C.). A measure such as a
quantity, percentage, etc., and a definite time period
for its accomplishment must be included in the
objectives. Policies answer the question of "how" by
specifying the clearly defined actions (programs and
activities) local governments will take to achieve each
objective and ultimately the identified goal (Rule 9J-
4
5.003(64), F.A.C.).
If desired, local governments may choose to assign the
measurability to a policy: however, it must be clearly
linked to the pertinent objective and the final
combination must provide a clear basis for assessing
the effectiveness of the plan. .
It is also incumbent upon the local government to
establish that it has met the intent of the Rule when
it deviates from the requirement related to measurable
objectives. The Department is primarily concerned that
local governments provide the basis for assessing the
effectiveness of their plan.
Objectives and pOlicies may be written using the word
"should" instead of "shall" provided that the local
government does not view the use of "should" to mean
"may" or to imply discretion. Regardless of which word
is used, the local government should make efforts to
achieve the stated goals and objectives.
For the comprehensive plan elements, objectives and
pOlicies must be written for each of the requirements
identified in Chapter 9J-5, F.A.C., unless there is a
valid explanation why the requirement does not apply.
These requirements, by themselves, are not objectives
or policies and cannot be used as such in the elements.
All goals, objectives and policies within the plan
shall be based upon relevant and appropriate data.
Objectives and policies need to be supported by the
data and analysis in order to have validity within the
plan.
Objectives and policies related to land development
regulations pursuant to s. 163.3202, F.S., must reflect
that the regulations will be adopted and implemented
consistent with the requirements of 5.163.3202, F.S.
B. COMMENTS
1. See individual elements.
PLANNING TlMEFRAMES
A. OBJECTIONS
1. 9J-5.005(4)
Consistent planning time frames have not been used
throughout the proposed plan. For example, the
5
timeframe of the Future Land Use Map series is not
specified while the Future Traffic Circulation Map
states the year 2000. Some subelements, such as
Sanitary-Sewer, Solid Waste, and Potable Water use the
year 2010 for the overall timeframe. The Future
Aviation Land Map has no timeframe indicated.
Recommendation
Select and consistently use a short-term planning
timeframe for the first five-year or longer period
subsequent to the plan's adoption and an overall
timeframe of at least 10 years. The future conditions
maps should reflect the longer planning timeframe and
should be so labeled.
B. COMMENTS
None
LEVEL OF SERVICE STANDARDS
A. OBJECTIONS
See individual elements
B. COMMENTS
See individual elements
FUTURE ~ USE ELEMENT
A. OBJECTIONS
~
1. 9J-S.006(ll(bl
The following natural resources are not included on the
existing land use map or map series: existing and
planned waterwells, floodplains, wetlands, and soils.
Recommendation
Include the above referenced natural resources on the
existing land use map or map series. Cross-reference
if located elsewhere in the plan.
2. 9J-S.006(ll (fll.
The city has only partially addressed the requirement
to indicate generalized land uses adjacent to its
6
boundaries on the existing land use map series. While
land uses are indicated for enclaves within the
planning districts, they are not indicated for all
lands adjacent to the City. For example, the map for
Planning District 3D (pg. 42) does not indicate
generalized land uses west of Belcher Road and south of
SR 580 in what appears to be part of Dunedin.' The
lack of municipal boundary delineations for adjacent
communities makes it difficult to determine whether
this area is part of Dunedin or unincorporated Pinellas
County. This problem was noted in an objection cited
for 9J-S.00S(1)(e).
Recommendation
Revise the existing land use map series to include
generalized land uses for all land adjacent to
Clearwater city limits. Add municipal boundary
delineations for adjacent communities.
Analvsis
None
Goals. Obiectives and Policies
3. 9J-S.006(3}(bl
(a) Objective 1.2 (pg. 3) concerning the permitting for
structural development or land alteration in wetlands,
beach dunes, floodplains, etc., is not supported by one
of more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(b) Objective 1.3 (pg. 3), as written, is a policy
statement describing a specific action which may be
used to support an overall objective to protect natural
resources by preventing soil erosion and surface water
degradation resulting from development processes. In
addition, the current objective is not supported by one
or more pOlicies that implement the objective.
Recommendation
Revise objective 1.3 to address the prevention of soil
erosion and surface water degradation resulting from
development processes. The current objective could
then be used as a policy to implement the new
7
objective.
(c) Objective 1.4 (pg. 3) use much of the same language as
and appears to duplicate Objective 1.1. In addition,
Objective 1.4 is not supported by one or more pOlicies
that implement the objective.
Recommendation
Include a new Objective 1.4 with a stated purpose
distinct from objective 1.1 and one or more policies
that implement the new objective or delete current
Objective 1.4.
(d) Objective 1.5 (pg. 3) stating that the population
density restrictions in the coastal area ~ considered
t2 be consistent with evacuation plans is unclear as to
consistency with these plans. In addition, Objective
1.5 is not supported by one or more policies that
implement the objective.
Recommendation
Revise Objective 1.5 to state that the population
density restrictions are or shall ~ consistent with
evacuation plans. Include one or more policies that
implement the objective.
(e) Objective 1.6 (pg. 3) concerning the filing of land
needs assessments by public and private utility
providers, is not supported by one or more policies
that implement the objective.
Recommendation
Include one or more policies that implement the Objective.
(f) Objective 2.3 (pg. 4) concerning the delineatloon of
community activity centers, is not supported by one or
more policIes that implement the objetctive. policies
that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(h) Objective 2.6 (pg. 5) stating that by 1991, the city
shall encourage the use of innovative land development
regulations by consideration of streamlined plan
amendment review requirements does not describe a
specific action which will result in the encouragement
8
of their use. In addition, Objective 2.6 is not
supported by one or more pOlicies that implement the
objective.
Recommendation
Revise Objective 2.6 to state that the City ~ill adoDt
streamlined plan amendment review requirements.
Include one or more policies that implement the
objective.
(i) Objective 3.1 (pg.5) concerning the screening of
existing outdoor storage of construction or building
materials, scrap or salvage, is not supported by one or
more pOlicies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(j) Objective 3.5 (pg. 7) concerning the review and
evaluation of the city's tree protection ordinance, is
not supported by one or more policies that implement
the objective.
Recommendation
Include one or more pOlicies that implement the
objective.
(k) objective 3.6 (pg. 7) concerning a historic
preservation overlay district, is not supported by one
or more policies that implement the objective.
Recommendation
Include one or more pOlicies that implement the
objective.
(1) The concurrency management and information system
proposed in Objective 4.1 (pg. 7) does not include
consideration of level of service (LOS) standards for
recreation and open space.
Recommendation
Revise Objective 4.1 to include consideration of LOS
standards for recreation and open space in the
concurrency management and information system.
9
4 . 9J - 5 . 006 (3) (c)
(a) POlicy 1.1.1 (pg. 3) contains the key phrase overridina
Dublic interest which may be used as a basis for the
approval of a permitting action. The plan does not
define overridina Dublic interest and, therefore, does
not specify a clearly defined action.
Recommendation
Include a definition of overridina Dubllc interest so
that the basis for a specific action to be taken is
clearly understood.
(b) Policy 2.1.2 (pg. 4) is vague in that it does not
describe how the City will use land use decisions to
"support" economic opportunity, creation of jobs, and
maintenance of existing industries.
Recommendation
Revise POlicy 2.1.2 to describe ~ the city will use
land use decisions to "support'. economic opportunity,
create jobs, and maintain existing industries.
(c) Policy 2.2.3 (pg. 4) is vague in that it does not
describe how the City will continue to "support" the
tax increment financing program and redevelopment
efforts in the downtown area
Recommendation
Revise POlicy 2.2.3 to describe ~ the City will
continue to "support" tax increment financing and
redevelopment efforts in the downtown area.
(d) Policy 4.1.1 (pg. 7) which implements the concurrency
provisions of Objective 4.1 must consider redevelopment
as well as new development and must consider the LOS
standards for recreation and open space. It does not
include these considerations.
Recommendation
Revise Policy 4.1.1 to include consideration of
redevelopment and LOS standards for recreation and open
space.
5. 9J-5.006(3) (c)5.
Policy 3.2.1 (pg. 5) identifies several mixed land use
categories (Commercial/Tourist, Downtown Development
10
District, and Residential/Office) used on Future Land
Use Maps but does not adequately define these
categories as to type, composition, predominant
character, and intensity/density of mixed use.
Recommendation
Revise Policy 3.2.1 to include an expanded description
of the type, composition, predominant character, and
intensity/density of mixed land uses allowed in the
above referenced mixed land use categories.
6 . 9J - 5 . 006 ( 3) {c} 7 .
Policy 3.2.1 (pg. 5) which identifies land uses shown
on Future Land Use Maps by referencing zoning district
classifications does not adequately define (except for
residential uses) the types of uses or
densities/intensities allowed.
I
Recommendation
Revise Policy 3.2.1 to include a description of the use
allowed in each zoning district classification (define
all abbreviations such as CG, GN, OL, etc.) and include
the density/intensity of development allowed in each of
these zoning districts.
7. 9J-5.006{3l (cl8.
A policy which addresses the identification,
designation and protection of historically significant
properties is not included.
Recommendation
Include a policy which addresses this requirement.
Cross-reference if addressed elsewhere in the plan.
Future LAnQ Use MaD{s)
6. 9J-5.006(4}
'The Future Land Use Map Series (pqs. 13-28)
does not indicate the planning time frame depicted and
does not clearly delineate the city's boundaries and
those of adjacent communities as noted in the objection
cited for 9J-5.005(1) (e) and are not supported due to
missing data and policies and inadequate objectives and
policies as noted in objections cited for 9J-
5.006(10) (b), 9J-5.006(3) (b), 9J-5.006(3) (c) and 9J-
5.006(3) (e)8.
11
Recommendation
Include the planning timeframe (year 2000) on all maps
in the Future Land Use Map Series and clearly delineate
the city's boundaries and those of adjacent communities
on these same maps. Provide missing data and policies
and revise inadequate objectives and pOlicies to
adequately support the Future Land Use Maps.
B. COMMENTS
None
TRAFFIC CIRCULATION ELEMENT
A. OBJECTIONS
Data
1. 9J-S.007(1}(bl
Map 7-1 (pg.3), Functional Highway Classification,
incorrectly classifies some state roads as Drimarv
arterials. These should be Drincica1 arterials
according to FOOT functional classification categories.
Road names/numbers are not legible.
Recommendation
Revise the legend on Map 7-1, by changing primary
arterial to crincipal arterial. Include legible road
names/numbers.
2. 9J-5.007(1)(c}
Map 7-1 (pg. 4), Lane Arrangement, is not legible. Lane
arrangement distinctions are barely discernible.
Recommendation
Revise Map 7-1 so that it is legible. Provide greater
distinction among lane arrangement categories by using
a bolder presentation format. Include legible road
names/numbers.
Analvsis
3. 9J-S.007(2}(bl
The analysis of projected traffic circulation levels of
services is inadequate. The description of the
methodology and assumptions used is not sufficiently
12
detailed to determine whether they are, to the maximum
extent feasible, compatible with the policies and plans
of the FOOT and the Pinellas County MPO. The MPO 2010
traffic demand volumes which were used to interpolate
1990, 1995 and 2000 traffic volumes are not included in
the element.
Recommendation
Include additional information on the methodology and
assumptions used to project future traffic circulation
levels of service and demonstrate that these have been
coordinated with the FOOT. Include the MPO 2010
traffic demand volumes.
Goals. Ob;ectives and policies
4. 9J-5.007(3) (b)
(a) Objective 5.1 (pg. 31) refers to maior collector
streets. since there are no major collectors
identified in the element, it is not clear which
streets are being referenced.
Recommendation
Revise Objective 5.1 to identify which streets are
being referenced. It is likely that the city is
referring to County and city collectors.
(b) Objective 5.2 (pg. 31) concerning the operation of all
traffic signals by a central computer system, is not
supported by one or more policies that implement the
objective.
Recommendation
Include one or more policies that implement the
objective.
(c) Objective 5.3 (pg. 31) stating that ~ ~ the city
will establish an internal reporting system to provide
timely status evaluation of LOS conditions is not
acceptable due to the implementation date. Regulations
or procedures implementing concurrency management must
be adopted in accordance with 5.163.3202, Florida
Statutes, which requires the adoption of land
development regulations no later than 1 year after the
city's scheduled plan submission due date.
13
Recommendation
Revise Objective 5.3 to include an implementation date
consistent with the requirement of s.163.3202, Florida
Statutes. ~ Mav !i2Q would be acceptable.
(d) Objective 5.4 (pg. 31) concerning the impact ~f
proposed development on existing and planned roadway
levels of service, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(e) Objective 5.5 (pg. 32) which promotes infill
development by allowing a reduction in roadway
operating conditions to below adopted level of service
standards or further degradation of currently deficient
roadways, is not acceptable based on the criteria
outlined in 5.5a). The creation of an economic or
social benefit may be interpreted as meaning many
things and does not provide clearly defined criteria
needed to evaluate a proposed project. Given the
geographic configuration of the city's incorporated
area and its planning district boundaries, almost any
location could be considered infill.
Recommendation
(f)
Objective 5.5 should be revised to include a specific
definition of economic social benefit (e.g., low income
housing) which will be used to evaluate project
proposals. Any reduction in levels of service or
further degradation of currently deficient roadways
should require a plan amendment and only be considered
when a proposed project furthers a plan objective to
meet a h19h Drioritv need as may be identified
elsewhere in the plan. Specific priority infill areas
should be established and identified as such on the
Future Land Use Map.
Objective 5.6 (pg. 34) incorrectly states that the FOOT
has established a minimum level of service (LOS) standard
"0" for County arterials and city and County
collectors. The FOOT only establishes minimum LOS
standards for the state highway system. In addition,
LOS standards should be located in policy statements.
14
Recommendation
Revise Objective 5.6 by deleting reference to County
and city roadways or by restating the objective so it
is clear that the FOOT does not establish minimum LOS
standards for County and City roadways. This objective
should be restated as a policy and a new objective
provided. .
(g) Objective 5.7 (pg. 34) proposing to adopt minimum level
of service "E" for SR. 60 and US 19 within the Downtown
Clearwater and Clearwater Mall areas based on a Special
Transportation Areas (STA) designation for these areas,
is not acceptable. The Downtown and Clearwater Mall
areas have not received STA designation approval by all
required agencies. In addition, LOS standards should
be located in policy statements.
Recommendation
Adopt a minimum level of service standard "0" or
"maintain and improve 'I if the facilities are
backlogged, for SR 60 and US 19 within the above
referenced areas and include these in the policy which
lists "backloggedn facilities. Delete current
Objective 5.7 and replace it with a new objective
stating that the City will seek STA designation for the
Downtown Clearwater and Clearwater Mall areas by a
certain date. A supporting policy should be included
stating that the city will coordinate with the Pinellas
County MPO, the FOOT and the Tampa Bay Regional
Planning Council in its STA designation efforts. Upon
STA approval the city should amend the plan to reflect
this designation.
(h) Objective 6.1 (pg. 35) concerning that roadway
improvements to achieve desired levels of service be
included in the appropriate local governments budget,
is not supported by one or more pOlicies that implement
the objective.
Recommendation
Include one or more policies that implement the
objective.
(i) Objective 6.2 (pg. 36) stating that ~ 122Q
developments that impact "baCklogged" facilities will
be subject to additional service enhancement proposals
in order to maintain and not further degrade the
roadway's average operating speed is not acceptable due
to its implementation date. Page 2 of the Monitor~ng
15
and Evaluation Procedures states that whenever an
objective or policy uses a term such as, ~ ~, this
is defined as no later then the ~ of 1990.
Regulations implementing concurrency management must be
adopted in accordance with s 163.3202, Florida
Statutes, which require the adoption of land
development regulations no later than 1 year:after the
City's scheduled plan submission due date. In
addition, the use of the term At lower thAn ~ ~ is
not appropriate since service enhancement proposals to
maintain/improve levels of service should be required
on all backlogged facilities operating below adonted
~ standards, whether currently at LOS "Ell or lower.
Recommendation
Revise Objective 6.2 to include on implementation date
consistent with the requirements of s163.3202, Florida
statutes. BY ~ l22Q would be acceptable. In
addition, the words ~ lower than ~ ~ should be
replaced by below adonted ~ standards.
(j) Objective 6.3 (pg. 36) concerning funding for
improvements to achieve desired level of service
standards be included in the Transportation Improvement
Program,is not supported by one or more pOlicies that
implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(k) Objective 6.4 (pg. 36) inappropriately included
programming for construction of a county roadway (Keens
Rd). The city has no juriSdiction or authority to
program this construction without agreement by the
County.
Recommendation
(1)
Include justification for the inclusion of this project
or delete the Keene Rd. project from the objective.
Objective 6.5 (pg. 37) concerning the expenditure of
funds to alleviate the most severe congestion problems,
is not suppported by one or more policies that
implement the objective.
16
Recommendation
Include one or more policies that implement the
objective.
em) Objective 6.7 (pg. 37) concerning the determination of
preliminary corridors, alignments, and right~of-way
needs, for future major collector street extensions or
expansions, is not supported by one or more pOlicies
that implement the objective.
Recommendation
Include one or more policies that implement the
Objective.
en) Objective 6.8 epg. 37) states that the City will
protect existing and future corridors from building
encroachment to the maximum extent feasible. This
conditional phrase makes the objective unacceptable.
Recommendation
Revise Objective 6.8 by deleting or defining the
conditional phrase tQ ~ maximum extent feasible and
specifically state how the City will protect existing
and future corridors from building encroachment.
(0) Objective 6.9 (pg. 37), stating that RY ~ the City
shall institute a concurrency management system, is not
acceptable due to the implementation date. Page 2 of
the Monitoring and Evaluation Procedures defines ~
~ to mean no later than the end of 1990.
Regulations implementing concurrency management must be
adopted in accordance with s.163.3202, Florida
Statutes, which require the adoption of land
development regulations no later than 1 year after the
city's scheduled plan submission due date.
Recommendation
(a)
Revise Objective 6.9 to include an implementation date
consistent with the requirements of 5.163.3203, Florida
Statutes.BY Hgy 1iiQ would be acceptable.
9J-S.007(3l (cl
Policy 5.1.1 (pg. 31) is vague in that it does not
describe ~ the City will SUDDOrt efforts to establish
the Pinellas Trails recreational path.
5.
17
Recommendation
Revise Policy 5.1.1 to describe bRw the city will
"support" the establishment of this recreational path.
(b) Policy 5.3.1 (pg. 31) stating that,~ ~ any request
for amendment to the Future Land Use Map will be
accompanied by a traffic analysis that will assess the
impact on the traffic circulation system,is not
acceptable due to the implementation date. Page 2 of
the Monitoring and Evaluation Procedures states that
whenever an objective or policy uses the term, ~
liiQ, this is defined as no later than the gng of 1990.
Procedures such as traffic impact analyses, which
implement concurrency management must be adopted in
accordance with s.163.3202, Florida statutes, which
require the adoption of land development regulations no
later than 1 year after the city's scheduled plan
submission due date.
Recommendation
Revise Policy 5.3.1 to include an implementation date
consistent with the requirements of 1 163.3202, Florida
statutes. ~ ~ ~ would be acceptable.
(c) POlicy 5.5.1 (pg. 32), stating that level of severice
standards for arterial and collector streets will
become effective ~ June 1990, is unacceptable because
level of service standards are established and become
effective upon adoption of the plan.
Recommendation
Revise Policy 5.5.1 by deleting the phrase ~ ~
.l2.2.Q. .
(d) Policy 5.5.1 (pg. 32) establishing peak-hour level of
service standards for numerous roads and road segments
is unacceptable due to the lack of road functional
classification information which is needed to determine
whether the proposed standards are appropriate for each
road or road segment listed.
Recommendation
(e)
Include the functional classification for all roads and
road segments listed in this policy.
POlicy 5.5.18 (pg. 33) proposing to adopt minimum level
of service (LOS) "E" for state and county facilities is
not acceptable. Pinellas County has adopted LOS liD"
18
for its facilities and the City should be consistent
with the County to the maximum extent feasible. Unless
adequate justification is provided the City may only
adopt LOS "En for city collectors and state minor
arterials.
Recommendation
Revise Policy 5.5.1B by deleting all road segments that
are functionally classified as state primary arterial
or county minor arterial, or county collector, or
provide justification for the adoption of LOS "E" for
these roadways. Any road segments deleted that are
operating at or above LOS "0" should be listed in
Policy 5.s.1A.
(f) POlicy 5.s.1C (pg. 33) Phased Level Q! Service, does
not include all roadways currently operating below
minimum LOS standards for the facility ("backlogged"
but not "constrained") and provide that urrent
operating conditions be maintained and imDroved.
Recommendation
Include in Policy s.5.1C all "baCklogged" roadways and
identify minimum LOS standards to be achieved. The
City should revise this pOlicy to specifically state
that its objective is to maintain ~ imcrove operating
conditions on these roadways and that it will
coordinate with appropriate agencies to achieve the
Objective. Include specific criteria which will
establish current base operating conditions and means
to measure changes in these conditions. The City
should use volume to capacity ratios, average operating
speed, or other acceptable criteria. Backlogged
facilities in the DrODosed Special Transportation Areas
(STA's) should be identified. Include the FOOT
functional classification for each roadway listed.
(g) Policy 5.5.1C (pg. 33) includes a state roadway segment
(S.R. 580) that iscurrently operating at LOS "011.
This roadway should not be included in a policy which
proposes to improve the roadway listed to LOS "Oil.
Recommendation
Delete S.R. 580 from Policy 5.5.1.C and add to 5.5.l.A
or 5.s.1.B as appropriate.
Policy 5.5.1 does not identify all "constrained"
roadway facilities operating at below minimum LOS
(h)
19
standards and provide that the current operating
conditions be maintained.
Traffic Circulation Hag
6. 9J-5.007(4}
(a) Roadway names/numbers are not legible on Map 19 (Right-
of-Way Requirements) and Map 20 (Future Traffic
Circulation System 2000 - Lane Arrangement).
Recommendation
Include legible names/numbers for roadways shown on the
above referenced maps.
(b) Future Traffic Circulation Map 19 (Right-of-Way
Requirements) and Map 20 (Future Traffic Circulation
System 2000- Lane Arrangement) are not supported due to
inadequate analysis of projected levels of service and
to inadequate policies establishing level of service
standards as noted in objections cited for 9J-
5.007(2)(b) and 9J-S.007(3) (c).
Recommendation
Include additional analysis of projected levels of
service and revised pOlicies establishing level of
service standards for the City's traffic circulation
system.
7. 9J-5.007l4} (a}
A Future Traffic Circulation Map showing the general
location of proposed collector roads, arterials roads,
and limited access facilities is not included.
Airports and rail lines are only incidentally
identified on the base map.
Recommendation
Include a Future Traffic Circulation Map showing
collector roads, arterials roads, and limited access
facilities. Use the roadway functional classifications
used on Map 7-1. Highlight airports and rail lines.
This map should be located in the adopted portion of
the plan.
B. COMMENTS
None
20
~ TRANSIT ELEMENT
A. OBJECTIONS I
Data
None
Analvsis
None
Goals. Obiectives and Policies
1. 9J-5.008(3) (b)
(a) Objective 8.1 (pg. 45) states that ~ !ii1 the city
shall require persons seeking to develop large-scale
housing projects for the elderly, handicapped or low
income populations to locate within 2,000 feet of an
existing bus route ~ notify the Pinellas Suncoast
Transit Authority (P.S.T.A.) of the proposed location
of the facility prior to issuance of a certificate of
occupancy. The option to merely notify the P.S.T.A.
negates the purpose of the objective which is to assure
transit services for these largely transit dependent
populations.
Recommendation
Revise Objective 8.1 by deleting the option of
notifying the P.S.T.A. An earlier implementation date
should be considered.
(b) Objective 8.2 (pg. 45) stating that within ~ ~ after
the adoption of future mass transit right-of-way (ROW)
or transit corridor maps by the MPO and/or FOOT, the
city shall adopt development regulations to prevent
structural encroachment into the proposed ROW tQ ~
maximum extent feasible. This conditional phrase makes
the Objective unacceptable. In addition, regulations
protecting future transit ROWand corridors should be
in place prior to or adopted immediately after future
transit ROW or corridor maps are adopted in order to
provide maximum protection and avoid unnecessary future
expenses and/or delays in transit development.
Recommendation
Revise Objective 8.2 by deleting or defining the
conditional phrase to the maximum extent feasible.
Consider having development regulations in place prior
21
to or immediately after future transit Row or corridor
map adoption by the MPO and/or FOOT.
(c) Objective 8.5 (pq. 46) concerning ferry service between
Clearwater Beach and downtown is not supported by one
or more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
2 . 9J - 5 . 008 (3 l (c l
(a) Policy 7.1.1 (pg. 45) does not describe how the city
will "encourage" fixed route and demand response
transit service to increase the nObility of the transit
service population.
Recommendation
Revise Policy 7.1.1 (pg. 45) to describe how the City
will "encourage" fixed route and demand-response
transit service.
(b) Policy 7.2.1 (pg. 45) does not describe how the City
will "support" the establishment of park-and-ride lots
and smaller outlying terminals.
Recommendation
Revise Policy 7.2.1 (pg. 45) describe ~ the City will
"support., the establishment of park-and-ride lots and
smaller outlying terminals.
Future ~ Transit ~
3. 9J-5.008(4l (all. ~ lQl
The Future Mass Transit Map (Map 21) does not include
proposed mass transit service areas and does not
identify major trip generators or attractors based on
the future land use map or map series.
Recommendation
Include proposed mass transit service areas and major
trip generators and attractors on the Future Mass
Transit Map (Map 21) or on a supplemental map.
22
B. COMMENTS
None
PORTS. AVIATION AND RELATED FACILITIES
Aviation component. There are no port facilities in ctearwater.
A. OBJECTIONS
Data
None
Analvsis
None
Goals. Obiectives and Policies
1. 9J'-5.009(3l(bl
(a) Objective 10.2 (pg. 51) concerning the renovation of
tie-down spaces at the Executive Airpark, is not
supported by one or more policies that implement the
objective.
Recommendation
Include one or more policies that implement the
objectivee
(b) Objective 10.3 (pg. 51) concerning the expansion of
tie-down spaces at the Executive Airpark, is not
supported by one or more policies the implement the
objective.
Recommendation
Include one or more policies that implement the
objective.
(c) Objective 11.1 (pge 52) concerning the relocation of
the fuel farm, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
23
(d) Objective 11.2 (pg. 52) stating that the Airpark expansion
shall specifically consider protection of the city's
water wells is vague and is not consistent with
Objective 22.8 (pg. 104) Conservation Element) which
addresses the protection of City owned and maintained
water wells.
Recommendation
Revise Objective 11.2 to include a specific action to
occur which addresses the protection of city water
wells. A suggested revision is to delete the word
consider and replace it with Drovide 1Qx.
2. 9J-5.009(3} (b}l.
An Objective which addresses coordinating the expansion
of existing or new airport facilities with the future
land use and conservation elements is not included.
Recommendation
Include a specific and measurable Objective which
addresses the coordination with the future land use and
conservation elements.
3. 9J-5.009(3}(c}
(a) Policy 10.1.1 (pg. 51) stating that the city shall
maintain operating policies, does not describe an
activity which would implement Objective 10.1 to
replace deteriorated shade hanger and maintenance
facilities.
Recommendation
Revise Policy 10.1.1 to include a specific
activity (ies) which will implement the objective to
replace deteriorated shade hanger and maintenance
facilities.
(b) Policy 10.1.2 (pg. 51) is not supported by the analysis
on page 58 of the supporting document which identifies
Scenarios 3 and 4 as using federal funds, not Scenario
2. Also use of the word consider makes this policy
tentative.
Recommendation
Revise Policy 10.1.2 to include references to the
appropriate scenario. Delete the word consider.
24
(c) The intent of Policy 12.1.1 (pg. 52) is unclear. The
policy does not define the relationship between State
and Federal funds and the funding program of FOOT and
it is not clear how these relate to implementing the
goal and objective.
Recommendation
Revise Policy 12.1.1 to establish clear intent. The
FOOT funding program referenced should be identified.
Future Ports. Aviation. and Related Facilities ~
4. 9J-5.009l4l fal ADS iQl
Map 22, Future Aviation Land (pg. 53) does not show
airport facilities (only total shown), adjacent land
uses, natural resources, and proposed points of ingress
and egress and is at a scale ill-suited to shown them.
The planning timeframe is not indicated.
Recommendation
Since Map 22 is at a scale ill-suited for inclusion of
the missing features, it is suggested that Figures 9-7,
Airpark Plan (pg. 41 of the supported document) be
revised to include adjacent land uses, natural
resource, proposed points of ingress and egress, and
planning timeframe. This map should then be located in
the adopted portion of the plan since it is a future
conditions map.
B. COMMENTS
None
HOUSING ELEMENT
A. OBJEcrIONS
Data
None
Analvsis
1. 9J-5.010l2l (bl
The analysis of housing need of the anticipated
population does not include projected need by cost or
rent.
25
Recommendation
Include an analysis of the projected housing need by
cost or rent.
2. 9J-5.010(21(dl
The analysis of the housing need projected to be met
by the private sector indicates a total need fiqure but
does not include a breakdown by type, tenure, cost or
rent, and income range of households served.
Ilecommendation
Include a breakdown of the housing need to be met by
the private sector by type, tenure, cost or rent, and
income range of households served.
Goals. Obiectives and Policies
3. 9J-5.010(31 Cbl
Objective 13.4 (pg. 58) stating that the city will
support construction of two assisted housing projects
is not supported by one or more policies that describe
specific implementing actions to be taken by the city
to support this effort.
Recommendation
Include one or more policies which describe specific
implementing actions the City will undertake to
"support" the construction of two assisted housing
projects.
4. 9J-5.010(3} (c)
a) POlicy 13.1.2 (pg. 57) is vaque in that it does not
describe how the city will "encourage" project designs
which provide for a mix of dwelling types at varying
costs.
Recommendation
Revise Policy 13.1.2 to describe how the city will
"encouragell project designs which provide for a mix of
dwelling types at varying costs.
b) Policy 13.4.3 (pg. 58) does not support related
Objective 8.1 (pg. 45, Mass Transit Element) which
requires large-scale projects for low income households
to be located within the mass transit service area.
26
Recommendation
Revise Policy 13.4.3 to state that assisted housing
should be located in close proximity to employment
centers and/or mass transit services.
c) Policies 13.6.4 and 13.6.5 (pg. 59), both stating that
the City will "encourage" lending institutions to be
more responsive to low and moderate income households
and neighborhoods, are vague in that they do not
describe how the City will provide encouragement.
Recommendation
Revise Policies 13.6.4 and 13.6.5 to describe ~ the
city will "encourage" lending institutions to be more
responsive to low and moderate income household and
neighborhood needs.
d) Policy 13.7.3. (pg. 60) stating the City shall tlstrivetl
to maximize intergovernmental revenues is tentative
and does not describe a specific implementing activity.
Recommendation
Revise Policy 13.7.3 by deleting the tentative word
"strive" and add a specific activity. For example, the
policy could state the the City shall Drovide
coordinatina services tQ assist in maximizing... etc.
B. COMMENTS
1. The inclusion of POlicy 13.5.5 (pg. 59) is unnecessary.
Deleting this policy will not alter the desired result.
SANITARY SEWER. SOLID WASTE. DRAINAGE. POTABLE WATER. AHn NATURAL
GROUNDWATER AOUIFER RECHARGE ELEMENT
SANITARY SEWER SUBELEMENT
A. OBJECTIONS
Date A.nS:l Analvsis
1. 9J-S.OIO(1}(e}
The following data is not included for the private
wastewater treatment facilities listed on page 14:
a) the entity having operational responsibility:
27
b) the geoqraphic service area and predominant types
of land use served;
c) the design capacity ( Regency Heights, Top of the World
and Tropical Breeze) excepted;
d) the current demand on capacity; and
e) the level of service provided.
Recommendation
Include the above referenced data for private
wastewater treatment facilities.
2. 9J-5.010l11 lf12.
The general performance, based on the best available
data, evaluating the adequacy of current level of
service, general condition, expected life and impact on
adjacent natural resources is not included for private
wastewater treatment facilities.
Recommendation
Include the above analysis for private wastewater
treatment facilities.
Goals. Obiectives. and policies
3. 9J-5.011l21 lbl
Objective 14.1 (pg. 63) concerning level of service
standards for sanitary sewer, is not supported by one
or more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective. since the LOS standard for sanitary sewer
is actually a policy requirement (9J-5.011(2) (c)2.), it
is suggested that Objective 14.1 become POlicy 14.1.1
and that a new objective be provided. The objective
could be to maintain adequate levels of service for
existing and future populations through the year 2000.
4. 9J-S.011l2l lel
a) The intent of POlicy 14.2.5 (pg. 63) is not clear. It
appears to repeat the content of POlicy 14.2.2, with
the exception of including the extension of services to
properties that have Detitioned for annexation.
28
Recommendation
Revise Policy 14.2.5 to clearly differentiate the
intent of this policy as compared to Policy 14.2.2 or
delete Policy 14.2.5 and combine with Policy 14.2.2 to
establish criteria for determining the extension of
sanitary sewer facilities in a single pOlicy.:
b) Policy 14.5.1 (pg. 65) does not describe how the City
will II encourage " long-term agreements with golf course
operators and other individuals or groups to Drovide
reclaimed water for irrigation. There also appears to
be an error in the use of the word Drovide. Golf
courses would generally use reclaimed water, not
provide it.
Recommendation
Revise POlicy 14.5.1 to describe ~ the City will
"encourage" long-term agreements. Delete the word
Drovide and replace with use, if appropriate.
5. 9J-S.Ol1(2l (c)2.
A Policy establishing level of service standards for
sanitary sewer is not included.
Recommendation
Include a Dolicv which establishes level of service
standards for sanitary sewer. It is suggested that
Objective 14.1 become Policy 14.1.1 and that a new
objective be provided.
B. COMMENTS
None
SOLID WASTE SUBELEMENT
A. OBJECTIONS
Data and Analvsis
1. 9J-S.Oll(l) (f)3.
The analysis on page 5 states that the resource
recovery plant will likely reach capacity in 1995 and
that Pinellas County is currently working on plans for
an additional resource recovery plant to be located on
Keystone Road. However, the analysis does not indicate
when the proposed new resource recovery plant would
become operational or discuss the alternatives
available to the City should this additional disposal
29
~
capacity not become available to service the City's
additional demand.
Recommendation
Include additional analysis which contains an estimated
completion date for the new resource recovery facility
and a discussion of alternative actions available to
the City should this facility not be available to
handle the City's needs after 1995.
Goals. Obiectives and Policies
2 . 9J - 5 . 011 ( 2) (b)
a) Objective 15.1 (pg. 71) concerning level of service
standards for solid waste, is not supported by one or
more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective. Since the LOS standard for solid waste is
actually a policy requirement (9J-5.011(2) (c)2.), it is
suggested that Objective 15.1 become POlicy 15.1.1 and
that a new objective be provided. The objective could
be to maintain adequate levels of service for existing
and future populations through the year 2000.
b) Objective 15.2 (pg. 71), to develop collection and
transport strategies which minimize costs and use
optimally located waste transfer facilities by 1995
(end of), contains an excessively lengthy
implementation timeframe. The development of these
strategies should and could be easily accomplished much
earlier in the planning process.
Recommendation
Revise Objective 15.2 to provide for a more appropriate
(earlier) completion date.
3. 9J-5.011(2) (c)
a) POlicy 15.4.1 (pg. 72), to ~ everY reasonable effort
to utilize recycling and disposal techniques that
conserve resources and minimize environmental impact,
is tentative.
Recommendation
Revise Policy 15.4.1 by deleting the phrase ~ everY
30
reasonable effort tQ and describe the recyclying and
disposal techniques to be used.
b) Policy 15.6.4 (pg. 72) does not describe ~ the City
will "support and encourage" amnesty days.
Recommendation
j
Revise policy 15.6.4 to describe ~ the City will
"support and encourage" annesty days.
4. 9J-5.011(2l (c)2
A policy establishing level of service standards for
solid waste is not included.
Recommendation
Include a policy which establishes level of service
standards for solid waste. It is suggested that
Objective 15.1 become Policy 15.1.1 and that a new
objective be provided.
B. COMMENTS
1.
On page 5 it states the stormwater
landfills (along with methane gas)
and burned to produce electricity.
error in the text.
runoff from certain
will be recovered
This is an apparent
DRAINAGE SUB-ELEMENT
A. OBJECTIONS
Data ~ Analvsis
1. 9J-5.011l1l(fl1.
A facility capacity analysis by geographic service area
(drainage basin) indicating capacity surpluses and
deficiencies for existing conditions and for the
planning period based on projected demand at current
LOS standards reSUlting from population growth and land
use distributions as indicated in the future land use
element, is not included.
Recommendation
Include a facility capacity analysis based on existing
and projected demands. The analysis should be based on
the best available data.
31
2. 9J-5.011(l} (a)
Major natural drainage features are not shown and/or
are not adequately identified on drainage basin Maps
11-4 thru 11-16. The City of Clearwater Topography map
(Map 11-2) is not legible.
Recommendation
Highlight the major
drainage basin Maps
easily identified.
of the City.
3. 9J-5.011l11lh)
natural drainage features on
11-4 thru 11-16 so that they are
Include a legible topographic map
Existing regulations and programs which govern land use
and development of natural drainage features are
identified; however, an assessment of the strengths and
deficiencies in those regulations and programs is not
included.
Recommendation
Include an assessment of the strengths and deficiencies
of the identified existing regulations and programs.
Goals. Ob;ectives and Policies
4. 9J-5.011l21 lbl
(a) Objective 16.1 (pg. 75) concerning level of service
standards for drainage, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more pOlicies that support the
objective. Since the LOS standard for drainage is
actually a policy requirement (9J-5.01l(2) (C)2.) it is
suggested that Objective 16.1 become POlicy 16.1.1 and
that a new objective be provided. The objective could
be to maintain adequate levels of service for existing
and future populations through the year 2000.
(b) Objectives 16.2-16.7 (pgs. 75-78) all refer the City's
Master Drainage Plan, while Objective 17.1 (pg. 78)
refers to the city Stormwater Management Plan. The
difference in these plans, if any, is not clear.
Recommendation
Distinguish between the various plans proposed under
32
Goals 16 and 17. If no differences exist, it is
suggested that the city use the terminology stormwater
Manaaement Plan in all objectives and policies since
the plan will not only address drainage (flooding) but
water quality (discharge) issues as well. (c)
Objective 16.6 (pg. 77) to protect and enhance the
quality of receiving waters Qy 1222 and related Policy
16.6.6 to identify impaired bodies of water and
prioritize them for improvement and enhancement ~ ~
appear to be inconsistent with Objective 23.1 (pg. 105,
Conservation Element) which is to protect, improve and
enhance surface waters from stormwater runoff
discharging into both interior and coastal surface
water ~ l2.il.
Recommendation
Explain the different timeframes established in these
objectives and policy. Revise, if necessary, to
achieve consistency.
5. 9J-5.011(21 (C)
(a) Policy 16.6.4 (pg. 77) to max~m~ze water recharge
potential in designing drainage improvement, where
feasible, is conditional in nature.
Recommenda t io-.11
Revise Policy 16.6.4 by deleting or defining the phrase
where feasible and describe how the City will maximize.
water recharge potential in designing drainage
improvements.
(b) Policy 16.6.9, stating that flood control projects
shall be consistent with the watershed or waterbody
specific management plans, is a restatement of Policy
16.6.7 and is unnecessary.
Recommendation
Delete POlicy 16.6.9.
6. 9J-5.011(21(cl2
A Dolicy establishing level of service standards for
drainage is not included.
Recommendation
Include a Doliey which establishes level of service
standards for drainage. It is suggested that Objective
33
16.1 become POlicy 16.1.1 and that a new objective be
provided.
B. COMMENTS
None
POTABLE WATER SUB-ELEMENT
A. OBJECTIONS
Data ang Analvsis
1 . 9J - 5 . 0 11 l 1) l c )
The proportional capacity of the Pinellas County water
system currently used by or allocated to the City is
not included.
Recommendation
Include proportional capacity data for the Pinellas
County water system.
2. 9J-S.Ollll1(fl1.
A facility capacity analysis, by geographic service
area, indicating capacity surpluses and deficiencies is
not included.
Recommendation
Include a facility capacity analysis. This analysis
should include an evaluation of the ability of Pinellas
County to supply future potable water needs.
Goals. Obiectives and Policies
3. 9J-S.Ol1l21lbl
(a) Objective 18.1 (pg. 83) concerning level of service
standards for potable water, is not supported by one or
more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective. Since the LOS standard for potable water
is actually a policy requirement (9J-S.011(2) (c)2, it
is suggested that Objective 18.1 become Policy 18.1.1
and that a new objective be provided. The objective
could be to maintain adequate levels of service for
34
existing and future populations through the year 2000.
(b) The intent of Objective 18.3, stating that the City
will continue to maintain the water system in a safe,
sound and efficient manner on a daily basis Qy~, is
unclear. To continue a function implies that it has
already been established and is ongoing. '
Recommendation
Revise Objective 18.3 by deleting by BY ~ and
replacing it with throuqh 1995 or other appropriate
timeframe.
(c) Objective 18.4 (pg. 84) includes a standard to be
applied, oDtimum, but is not specific.
Recommendation
Revise Objective 18.4 to include a definition of ootimum.
(d) Objective 18.6 (pg. 84) addressing water conservation,
has a scheduled completion date of as late as the end
of 1995. Given the limited supply of potable water
available to the city and the potential degradation of
this supply due to urban growth, an earlier date is
needed.
Recommendation
Revise objective 18.6 to include an earlier completion
date for achieving these water conservation measures.
4. 9J-5.011(2)(cl
(a) Policy 18.2.1 (pg. 83) does not describe how the city
will "ensure" that land development codes and
ordinances adequately address water system provisions.
Recommendation
Revise Policy 18.2.1 to describe how the City will
"ensure I' that these codes and ordinances adequately
address water system provisions.
(b) Policy 18.2.5 (pg. 83) to develop a system and
construct improvements which will, tQ tbg deqree
Dossible, conserve energy, water and other valuable
resources is conditional in nature.
35
Recommendation
Revise policy 18.2.5 by deleting or defining the
conditional phrase tQ thg dearee Dossible.
(c) Policy 18.2.6 (pg. 83) does not describe how the city
will "encourage" the development of innovative
techniques to augment water supplies.
Recommendation
Revise Policy 18.2.6 to describe ~ the City will
"encourage" the development of innovative techniques to
augment water supplies.
(d) Policy 18.2.8 (pg. 83) does not describe how the City
will "ensure" that water management projects are
designed and operated to maintain and enhance natural
and man-made systems.
Recommendation
Revise Policy 18.2.8 to describe how the City will
"ensure" that these projects are designed and operated
to maintain and enhance natural and man-made systems.
(e) Policy 18.6.1 (pg. 85) to consider establishment of a
City permit for shallow well installation is tentative
in nature.
Recommendation
Revise Policy 18.6.1 by deleting the word consider. A
permitting system is necessary to properly manage the
use of this water resource.
(f) Policies 18.6.5, 18.6.6 and 18.6.7 (pg. 85) addressing
water pressure and fire flow, are inappropriately
located. They are not related to and do not support
Objective 18.6.
Recommendation
Relocate these policies to support a related objective.
Placing them under Objective 18.4 should be considered.
(9) Policy 18.6.9 (pg. 85) does not describe how the city
will "provide" education to inform citizens of the need
and opportunities for conserving potable water.
Recommendation
36
Revise Policy 18.6.9 to describe how the city will
"provide" education to its citizens on the issue of
potable water conservation.
(h) Policy 18.7.4 (pq. 86) does not describe ~ the City
will "actively pursue" the coordinated approach to
interjurisdictional problems. .
Recommendation
Revise Policy 18.7.4 to describe how the city will
"actively pursue" the coordinated approach to
interjurisdictional problems.
5. 9J-5.011(2) (c)2
A Dolicv establishing level of service standards for
potable water is not included.
Recommendation
Include a Dolicv which establishes level of service
standards for potable water. It is suggested that
Objective 18.1 become POlicy 18.1.1 and that a new
objective be provided.
B. COMMENTS
None
NATURAL GROUNDWATER AOUIFER RECHARGE SUB-ELEMENT
A. OBJECTIONS
~ ~ Analvsis
None
Goals. Obiectives and Policies
1. 9J-5.011(2) (bl5.
An objective which addresses protecting the functions
of natural groundwater recharge areas is not included.
Although there are no major or prime recharge areas
identified within the city, the element text indicates
37
that much of the area provides some recharge potential.
Given the importance of protecting valuable and limited
water resources, this issue should be addressed.
Recommendation
Include an objective which addresses the pro~ection of
natural groundwater recharge areas.
2. 9J-S.Ol1(2l (c)4.
A policy which addresses regulating land use and
development to protect the functions of natural
groundwater recharge areas is not included.
Recommendation
Include a policy which addresses protecting the
functions of natural groundwater recharge areas. The
policy could address minimizing building coverage,
requiring permeable parking surfaces, etc.
B. COMMENTS
None
COASTAL MANAGEMENT ELEMENT
A. OBJECTIONS
~ ang Analvsis
1. '9J - 5 . 012 (2) (a)
The Coastal Zone Boundary and Existing Land Use maps
(between pages 1 and 2 and 63 and 64, respectively) are
depicted at a scale that is too small to distinguish
between the patterns which identify various land use
categories. These maps are not legible.
Recommendation
Include Coastal Zone Boundary and Existing Land Use
maps that are legible. Relocate the map currently
between pages 63 and 64 to a more appropriate location
near its counterpart located between pages 1 and 2.
2 . 9J - 5 . 012 (2) (c)
A summary statement on page 70 recommends that develop-
opment and redevelopment in the coastal zone be con-
sistent with the Ob]ectlves and policies of the
38
Historic Preservation Element. The proposed Clearwater
Comprehensive Plan does not contain a Historic
Preservation Element.
Recommendation
Delete reference to the Historic Preservation Element
or include it as part of the adopted comprehensive
plan.
3 . 9J - 5 . 012 ( 2 l (d l
An inventory and analysis of estuarine pOllution
conditions and actions needed to maintain estuaries
including an assessment of general estuarine conditions
and identification of known pollution problems: an
assessment of the impact of development and
redevelopment proposed in the future land use element
and of facilities proposed in other elements upon water
quality, circulation patterns, and accumulation of
contaminants in sediments: identification of remedial
actions needed: and identification of regulatory
programs to be used to maintain or improve estuarine
environmental quality, is not included.
Recommendation
Include the above referenced inventory and analysis.
Cross-reference if located elsewhere in the plan.
4. 9J-5. 012 (2) (elL
The hurricane evacuation analysis did not identify
evacuation routes and did not adequately discuss
transportation and hazard constraints on evacuation
routes, their effect on evacuation times and what
measures the City could adopt to maintain or reduce
evacuation times.
Recommendation
Identify evacuation routes and include a thorough
discussion of constraints on evacuation routes and
their affect on evacuation times. It would be
desirable to include a map which includes evacuation
routes, locates specific transportation and hazard
constraints, and locates public shelters. Outline
measures the City could adopt to reduce evacuation
times.
39
..
5. 9J-5.012(21 (e13.
The coastal high-hazard area (CHHA) has not been
adequately identified because the areas which have
experienced severe damage (piers, cabanas, lift
stations, etc.) noted in Objective 19.2 (pg. 91) are
not delineated. The infrastructure within the CHHA is
not inventoried or the potential for relocation
analyzed.
Recommendation
Include a specific delineation of the CHHA, an
inventory of infrastructure within this area and an
analysis of the potential for relocation. A map of the
CHHA, at a scale sUfficiently large to be easily read,
should be included.
Goals. Obiectives and Policies
6. 9J-5.012C31 Cal
The intent of Goal 21 (pq. 94) to limit public
expenditures that serve coastal areas is clear but its
impact is not clear because "committed development" is
not defined nor is "significant additional population
densities."
Recommendation
Define "committed development" and "significant
additional population densities" in order to clarify
the impact of this goal statement.
7. 9J-S.012C31 Cbl
(a) Objective 19.1 (pg. 91) concerning the protection of
beaches and dunes using the State Coastal Construction
Control Line, is not supported by one or more policies
that implement the objective.
Recommendation
(b)
Include one or more policies that implement the
objective.
Objective 19.4 (pg. 91) Ccncerning public access to
beaches, is not supported by one or more policies that
implement the objective.
Recommendation
Include one or more policies that implement the
objective.
40
~
(c) Objective 20.4 (pg. 94) concerning tertiary treatment
at Clearwater's sewage treatment plants, is not
supported by one or more pOlicies that implement the
objective.
Recommendation
Include one or more pOlicies that implement the
objective.
(d) Objective 20.5 (pq. 94) stating Clearwater shall
"strive" to renourish eroded beaches is tentative in
nature and is not supported by one or more policies
that implement the objective.
Recommendation
Revise Objective 20.5 by deleting the word "strive".
Include one or more pOlicies that implement the
objective.
(e) objective 20.6 (pg. 94) concerning the dredging of
Dunedin Pass, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more pOlicies that implement the
objective.
(f) Objective 20.7 (pg. 94) concerning the renourishment of
sand keys eroded beaches, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective. The city should consider restating
Objective 20.7 as a policy under Objective 20.5.
(q) Objective 21.2 (pg. 95) concerning the removal of
mobile homes from the coastal zone, is not supported by
one or more policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
(h) Objective 21.3 (pg. 95) stating that densities in the
coastal area shall not be increased is not consistent
41
with Goal 21 which refers to not promoting sianificant
additional pODulation densities.
Recommendation
Revise Objective 21.3 and/or Goal 21 to achieve
consistency. Prohibiting additional densities in the
coastal zone would be preferable in order to limit
exposure of life and property to storm hazards.
(i) Objective 21.4, stating that hurricane evacuation times
shall be reduced by 1993, is not supported by data and
analysis as cited in the objection for 9J-5.012(2) (e)l.
Recommendation
Include supporting data and analysis for reducing
hurricane evacuation times by 1993.
(j) Objective 21.6 (pg. 96) concerning the replacement of
Clearwater pass bridge, is not supported by one or more
policies that implement the objective.
Recommendation
Include one or more policies that implement the
objective.
8 . 9J - 5 . 012 ( 3) (c)
(a) Policy 19.5.1 (pg. 92) dealing with the impacts of
development and redevelopment on wetlands, water
quality, etc., is not related to Objective 19.5 which
addresses historic resources.
Recommendation
Relocate Policy 19.5.1 to a related objective.
Objective 20.1 is suggested for consideration.
(b) Policy 21.1.2 (pg. 94) stating that revisions to the
land development code will be prepared within 1 year of
plan adoption, is unacceptable. Land development
regulations that implement the plan are required to be
adopted in accordance with 5.163.3202, Florida
statutes, which requires their adoption no later than 1
year after the city's scheduled plan submission due
date.
Recommendation
Revise Policy 21.1.2 to include an implementation date
42
consistent with the requirements of s.163.3202, Florida
Statutes. BY ~ 1990 would be acceptable.
(c) Policy 21.1.4 (pgs. 94-95) in its permitting
considerations for new marinas does not include
protecting the West Indian manatee, an endanqered
species. .
Recommendation
Revise POlicy 21.1.4 to include consideration of areas
of essential manatee habitat in the city's marina
permitting criteria.
(d) Policy 21.1.6 (pg. 95) stating that coastal densities
are expected to remain within 10% of existing densities
implies a probable increase. An increase in coastal
area density is inconsistent with Objective 21.3 (pg.
95) which states there will be no increase in coastal
zone densities.
Recommendation
Revise Policy 21.1.6 and/or Objective 21.3 to achieve
consistency. Prohibiting additional densities in the
coastal zone is preferable in order to limit exposure
of life and property to storm hazards.
(e) Policy 21.4.1 (pg. 95) proposes to conduct a hurricane
evacuation analysis. Such an analysis was required to
be submitted with the proposed plan. This analysis was
cited in the objection for 9J-5.012(3) (e)l. as being
missing.
Recommendation
Delete Policy 21.4.1. Include a hurricane evacuation
analysis as required by 9J-5.0-12(2) (e)l. Noted
deficiencies could then be addressed in a new policy or
policies under Objective 21.4.
(f) Policy 21.5.1 (pg. 96) allowing the reconstruction of
structures in the coastal high-hazard area (CHHA) that
have experienced over 50% damage to the habitable floor
area is inconsistent with the objective requirements of
9J-5.0l2(3)(b)5., 6. and 8., which are to limit public
expenditures that subsidize development in the CHHA; to
direct population concentrations away from known or
predicted CHHA's; and to reduce or eliminate the
exposure of human life and public and private property
to natural hazards. The reference to 50% damage to the
habitable foor area is not consistent with the
43
definition of "Substantial Improvement" in Florida's
Coastal ~ Protection Act 2f lii2. In addition,
redevelopment of any substantialy damaged structure
should be consistent with the established densities in
the adooted comprehensive plan but is no case greater
than the existing density at the time of damage.
Recommendation
Revise POlicy 21.5.1 to include a definition of
substantially damaged structure that is consistent with
the Coastal Zone Protection Act of 1985 and to state
that any redevelopment will be consistent with the
densitites established in the adooted comprehensive
plan but is no case greater than the existing density
at the time of damage.
(g) Policy 21.5.3 (pg. 96) stating that long-term repair
and redevelopment shall constitute upgrading structures
and accessory facilities to exoand habitable space is
unacceptable. Allowing expansion of habitable space is
inconsistent with objective requirement 9J-
5.012(3) (b}8. to reduce or eliminate the exposure of
human life and private and public property to natural
hazards and 9J-5.012(3} (b}5. to direct population
concentrations away from the CHHA.
Recommendation
Revise Policy 21.5.3 by deleting reference to allowing
the expansion of habitable area of structures located
in areas subject to natural hazards.
~ Master Plans for Deeowater Ports
Not applicabl. There are no ports in Clearwater.
B. COMMENTS
None
CONSERVATION ELEMENT
A. OBJECTIONS
Data ADQ Analvsis
1. 9J - 5 . 013 (11 (a 1 5 .
The data and analysis has not identified the West
Indian Manatee (endangered specie) and analyzed how the
manatee and its marine habitat can be protected.
44
Recommendation
Include data and analysis on the West Indian Manatee
which will provide base information to support
objectives and policies addressing manatee and manatee
habitat protection.
Goals. Obiectives ~ Policies
2. 9J-S.013(2)(bl
(a) Objective 22.2 (pg. 101) to protect floodplains,
drainage ways, and all other natural areas having
functional hydrological characteristics hY l22Q is a
function of the city's land development regulations
(LOR's) and should be adopted in accordance with the
schedule outlined by s. 163.3202, Florida Statutes,
which requires the adoption of land development
regulations within 1 year after the City's scheduled
proposed plan submission due date.
Recommendation
Revise Objective 22.2 to include an implementation date
in accordance with s. 163.3202, Florida Statutes. ~
~ ~ would be acceptable.
(b) Objective 22.4 (pg. 102) to manage all conservation
areas by 1991 is not consistent with Objective 22.3 to
maintain and enhance the City's wildlife and natural
native vegetative resources (including conservation
areas) by 1992.
Recommendation
Revise the objective as necessary to achieve a
consistent implementation schedule for protection of
conservation areas. If regulated through the city's
land development regulations, the implementation date
should be in accordance with s. 163.3202, Florida
Statutes.
(c) Objective 22.6 to protect beaches, dunes, and dune
vegetation for natural functions and open space uses hY
1992 is not acceptable due to the implementation date.
The protection of these resources should be addressed
in the city's land development regulations which must
be adopted in accordance with the requirements of s.
163.3202, Florida Statutes, which requires the adoption
of land development regulations within 1 year after the
City's scheduled proposed plan submission due date.
45
Recommendation
Revise Objective 22.6 to include an implementation date
in accordance with s. 163.3202, Florida Statutes. BY
~ ~ would be acceptable.
(d) Objective 22.8 (pq. 104) to protect all city~owned and
maintained potable waterwells from contamination due to
inappropriate land uses and related activities ~ 1995
is unacceptable due to the implementation date. The
plan has identified the city's waterwells, established
a protection area (1000' radius) and has established
the importance of these wells in meeting the city's
potable water needs. Considering the urban character
of the city and the potential for increased
groundwater/surface water degradation, wellfield
protection should be an immediate concern.
Recommendation
Revise Objective 22.8 to include the preparation and
implementation of a wellfield protection ordinance
early in the planning period.
3. 9J-5.013(2l(cl
(a) POlicy 22.1.1 (pg. 101) to prohibit land use activities
that will significantly diminish air quality is vague
because the types of land use activities to be
prohibited are not identified.
Recommendation
(b)
Revise Policy 22.1.1 to identify the types of land use
activities to be prohibited.
POlicy 22.4.7 (pg. 103) to protect the urban forest
from destruction or disturbance due to inappropriate
proximity to incompatible land uses does not describe
how the City will "protect" this natural resource.
Recommendation
Revise Policy 22.4.7 to describe how the City will
"protect" the urban forest from destruction or
disturbance by incompatible land uses. Identify
potential incompatible land uses.
(c) Policy 22.5.2 (pq. 103) to protect and preserve
riverine floodways from all new land uses other than
recreation/open space does not describe ~ the City
will "protect and preserve II this natural resource.
46
Recommendation
Revise POlicy 22.5.2 to describe how the city will
"protect and preservell riverine floodways from
inappropriate land uses.
(d) Policy 22.5.4 (pg. 103) to protect all mangrove species
and to provide pUblic awareness of mangrove resources
does not describe how the city will "protect" mangroves
and ~ it will "provide" public awareness of mangrove
resources.
Recommendation
Revise Policy 22.5.4 to describe how the city will
"protect" mangroves and "provide" public awareness of
this natural resource.
(e) Policy 22.6.5 (pg. 103) does not describe activities,
programs or land development regulations which
implement Objective 22.6.
Recommendation
Delete Policy 22.6.5. Revise Policy 22.6.7 to include
reference to beaches and dunes and thus read "all
beaches, dunes, and dune vegetation shall be protected
by local ordinance... etc.
(f) Policy 22.7.4 stating the city shall consider
establishment of conservation easements is tentative in
nature.
Recommendation
Revise Policy 22.7.4 by deleting the word consider.
(g) Policy 22.8.1 (pg. 104) to recognize wellfield
protection areas as sensitive areas surrounding potable
water wells which must be protected from contamination
does not describe specific measures the city will take
to protect these areas.
Recommendation
Revise Policy 22.8.1 to describe specific measures the
City will take to protect potable water wellfields from
contamination. The adoption of a wellfield protection
ordinance is suggested.
(h) Policy 23.1.1 (pg. 105) makes reference to city storm-
water drainage plans which shall include water quality
47
protection and enhancement criteria. Drainage plans
that address water quality issues should be referred to
as stormwater Manaaement Plans.
Recommendation
Revise POlicy 23.1.1 to state that water qua~ity
protection and enhancement criteria will be
incorporated into all city stormwater Manaaement Plans.
This will then be consistent with the language used in
Policy 23.1.2.
(i) Policy 23.1.6 (pg. 105) stating that the city shall
systematical Iv and timelY prepare watershed and
waterbody specific management plan for waterbodies
within the city is vague. The meaning of
svstematicallv and timely is unclear.
Recommendation
Revise POlicy 23.1.6 to describe the criteria to be
used in the systematic selection of waterbody planning
projects and specify timeframes for completion of these
management plans.
B. COMMENTS
None
RECREATION IRQ ~ SPACE ELEMENT
A. OBJECTIONS
Data
1. 93-5.014(1)
Private recreation sites available to the public have
not been identified.
Recommendation
Include the identification of private recreation sites
available to the public.
Analvsis
2. 9J-5.014(2) (c)
A series of recreation and open space facility maps
(Maps 14-1 thru 14-17) depict recreational uses with
generalized service areas but do not indicate the
48
time frame represented by these maps. It is not clear
whether these maps are included to meet the cited
requirement.
Recommendation
Include the planning time frame represented oQ all the
above referenced maps. If these are included to meet
the requirements of 9J-5.014(2) (c), then the general
location for the proposed new neighborhood park should
be shown on Map 14-4 and the proposed 4 new miniparks
on Map 14-5. All future conditions maps must be
included in the adopted portion of the plan as required
by 9J-5.005(1) (c)4.
Goals. Obiectives ADS Policies
3 . 9J - 5 . 014 (3) (b} 2 .
An objective which addresses coordinating public and
private resources to meet recreational demands is not
included.
Recommendation
Include an objective which addresses coordinating
public and priovate resources to meet recreational
demands.
4. 9J-5.014(3l(cl
(a) Policy 24.1.5 (pg. 111) to construct a substantial
Dortion of park parking lots of permeable materials is
vague because the meaning of substantial Dortion is not
clear.
Recommendation
Revise Policy 24.1.5 to identify what is meant by
substantial Dortion. This could be defined as a
percentage (e.g., 80%) of the total parking lot area.
(b) Policy 24.1.8 (pg. 111) to "ensure" that recreational
lands and facilities are accessible to special user
groups does not describe how the city will "ensure"
that these facilities are accessible to special user
groups.
Recommendation
Revise Policy 24.1.8 to describe how the City will
49
"ensure" the accessibility of these facilities to
special user groups.
(c) Policy 24.3.5 (pg. 112) to guarantee the perpetuity of
adequate public recreation and open space lands within
the City does not describe a specific implementing
action the City will undertake to achieve the related
objective.
Recommendation
Delete Policy 24.3.5. It is suggested that the
language of this policy be integrated into Policy
24.3.4 so that it reads "Guarantee the perpetuity of
adequate public recreation and open space lands by
establishing a minimum Level of Service standard of 4
acres... etc.
(d) POlicy 24.3.6 (pg. 113) stating that the City will
consider the varying desires of the city's population
when implementing recreation plans, with special
attention to the needs of low and moderate income
groups, minorities, youth and the elderly, is tentative
in nature.
Recommendation
Revise Policy 24.3.6 by deleting the word consider. A
suggested replacement is the word address.
(e) POlicy 24.3.10 (pg. 113) to consider the programs of
sports associations, little theatre organizations, and
other local community groups in the implementation of
recreation plan, is tentative in nature.
Recommendation
Revise Policy 24.3.10 by deleting the word consider. A
suggested replacement are the words coordinate with.
(f) Policy 24.4.2 (pg. 113) stating the City will "promote"
the conservation and/or sensitive development of upland
natural areas does not describe how the city will
"promote" conservation and/or sensitive development of
these natural areas.
Recommendation
Revise Policy 24.4.2 to describe how the city will
"promote" the conservation and/or sensitive development
of upland natural areas.
50
(g) Policy 24.4.5 (pg. 113) which prohibits development
which alters "conservation land uses" as designated in
the Future Land Use Element except through mitiaation
is inconsistent with POlicy 22.3.1 (pg. 102,
Conservation Element) which prohibits destruction or
disturbance of conservation land uses except for
restoration. ~
Recommendation
Revise the above referenced pOlicies as needed to
achieve consistency or provide an explanation of how
these pOlicies are consistent as written.
B. COMMENTS
1. The Florida Department of State offers information and
assistance to local governments in the development or
redevelopment of lands thought to have historical or
archaeological significance. It is suggested that
consultation with the FOOS be added to Policy 25.5.4
(pg. 114).
INTERGOVERNMENTAL COORDINATION ELEMENT
A. OBJECTIONS
Data
None
Ana1vsis
None
Goals. Ob1ectives and Policies
1. 9J-S.01S(3) (b)
(a) Objective 25.1 (pg. 117) stating that the Clearwater
Comprehensive Plan shall be forwarded to the school
board, adjacent local governments, and agencies does
not provide a specific measurable intermediate end that
marks progress toward the goal. The objective does not
state for what purpose these copies are being forwarded
and what results are expected.
Recommendation
Revise Objective 25.1 to provide a specific measurable
intermediate end that marks progress toward achieving
the stated goal.
51
~
(b) Objective 26.2 (pg. 118) stating that the City shall
adopt DOT LOS standards for state arterials, as they
may be modified by additional service designations
(STA's, etc.) approved by DOT, does not provide a
specific measurable intermediate end that marks
progress toward the goal. LOS standards for state
arterials will have already been adopted. It appears
that the true objective is to obtain STA designation
through intergovernmental coordination.
Recommendation
Revise Objective 26.2 to state that the City will
obtain STA designation for Downtown Clearwater and
Clearwater Mall areas through coordination with and
approval by the Pinellas County MPO, Tampa Bay RPC, and
F.D.O.T. and upon approval will amend LOS standards for
state arterials within the designated area as needed.
(c) Objective 26.3 (pg. 118), stating that the city shall
formally adopt a sewage treatment level of service, the
Federal/State treatment standards, does not provide a
specific measurable intermediate end marking progress
toward the goal and, as written, may be confused with
the sanitary sewer LOS standard stated in Objective
14.1 (pg. 63), Sanitary Sewer Subelement.
Recommendation
Revise Objective 26.3 to provide a specific measurable
intermediate end which marks progress toward the goal
and to avoid any confusion with sanitary sewer LOS
standards. A suggested revisions is to state that By
March 14, 1991, the city will formally adopt E.P.A. and
F.D.E.R. sewage treatment standards and will maintain
these standards through the year 2000.
(d) Objective 26.4 (pg. 118), stating that the City shall
formally adopt, as potable water level of service
standards, the state D.E.R. standards for potable water
systems, does not provide a specific measurable
intermediate end which marks progress toward the goal
and, as written, may be confused with the stated
potable water LOS standards in Objective 18.1 (pg. 83),
Potable Water Subelement.
Recommendation
Revise Objective 26.4 to provide a specific measurable
intermediate end which marks progress toward the goal
and to avoid any confusion with potable water LOS
standards. A suggested revision is to state that By
52
1990, the city will formally adopt F.D.E.R. potable
water treatment standards and will maintain these
standards through the year 2000.
(e) Objective 26.5 (pg. 118), stating that Clearwater shall
participate in countywide solid waste management
programs, does not provide a specific measurable
intermediate end marking progress, toward the goal.
Recommendation
Revise Objective 26.5 to provide a specific measurable
intermediate end that marks progress toward the goal.
A suggested revision is to state that Clearwater shall
participate in countywide solid waste management
programs to increase the volume of recycled materials.
2. 9J-5.015(3}(c}
(a) Policy 25.1.2 (pg. 117), stating that the city
"encourages" recognition of recent state legislation
regarding continued state funding for schools which are
designated as historic, does not describe ~ the City
will "encourage II recognition of this legislation.
Recommendation
Revise Policy 25.1.2 to describe how the city will
"encourage" the recognition of this state legislation.
(b) Policy 25.1.5 (pg. 117), stating that Clearwater shall
~ additional intergovernmental coordination
mechanisms to enhance services, does not specify
clearly defined actions to be taken to achieve the
objective.
Recommendation
Revise POlicy 25.1.5 to state clearly defined actions
that will be undertaken to achieve the objection. It
is suggested that the policy be revised by deleting the
word ~ and replacing it with establish or propose.
(c) Policy 26.1.3 (pg. 117), stating that Clearwater shall
participate in and support regional conflict resolution
mechanisms ~ accropriate, is conditional in nature.
Recommendation
Revise Policy 26.1.3 by deleting or defining the
conditional phrase ~ accrocriate.
53
(d) Policy 26.6.1 (pg. 119), stating that Clearwater shall
"encourage" the establishment of a Technical Advisory
Committee (TAC), does not describe how the City will
"encourage" the establishment of this committee.
Recommendation
Revise Policy 26.6.1 to describe how the City will
"encourage" the establishment of a TAC. A suggestion
is to delete the word encouraoe and replace it with
formallv DrODose.
3 . 9J - 5 . 015 (31 (c 1 6.
Policy 26.1.1 (pg. 117) stating that any major
substantive conflicts as noted by resolution shall be
considered for submittal to TBRPC's informal regional
mediation process, is tentative in nature. .
Recommendation
Revise Policy 26.1.1 by deleting the word considered.
B. COMMENTS
1. Objective 26.6 (pg. 119) and related policies refer to
master drainage plans. If these plans are to address
both water quantity and quality, a more appropriate
reference would be master stormwater management plans.
CAPITAL IMPROVEMENTS ELEMENT
A. OBJECTIONS
Data
None
Analvsis
1. 9J-5.016(21(bl
The analysis of general fiscal implications of existing
deficiencies and future needs found in the needs
assessment (pgs. 8-13) does not address the relative
priority of need among facility types.
Recommendation
Expand this analysis to include a discussion of the
relative priority of need among facility types.
Establish a priority schedule.
54
2. 9J-5.016C2l Ccl
The basis for cost estimates used in the needs
assessment (pgs. 8-13) is not explained for other than
road projects.
Recommendation
Explain the basis for cost estimates for aviation,
sewer, solid waste, drainage, coastal zone, and parks
and recreation projects included in the needs
assessment.
3. 9J-5.016C2l Cel
An analysis of how the timing and location of capital
improvements can be used to foster efficient land
development and further the goals, objectives and
policies of the future land use element, taking into
consideration the plans of state agencies and the
Southwest Florida Water Management District, is not
included.
Recommendation
Include the above referenced analysis as required.
4. 9J-5.016C21Cfll.-S.
The assessment of the City's ability to finance capital
improvements does not include: .
a) Forecasting revenues and expenditures for 5 years;
b) Projections of debt service obligations for currently
outstanding bond issues;
c) Projection of ad valorem tax base, assessment ratio and
millage rate;
d) Projections of other tax bases and other revenue
sources such as impact and user fees; and
e) Projection of operating cost considerations.
Recommendation
Include the above referenced items as required.
Goals. Objectives and Policies
S. 9J-5.016C31Cb)
Objective 28.2 (pg. 126) states that the City shall
limit public expenditures and not promote sianlficant
additional population densities in the coastal area.
55
Sianificant is undefined and therefore the intent of
the objective is not clear and its impact on coastal
population densities cannot be determined.
Recommendation
Revise Objective 38.2 to include a definition. of
sianificant. In general, population densities in the
coastal areas should be reduced.
6. 9J-5.016l3} (c)
a) Policy 28.2.1 (pg. 126), states that no new development
or substantial redevelooment will be permitted in the
coastal high hazard area. Substantial redevelopment is
undefined and therefore the intent of the objective is
not clear and its impact on the CHHA cannot be
determined.
Recommendation
Revise POlicy 28.2.1 to include a definition of
sianificant redevelooment. This definition should be
consistent with the provisions of the Florida Coastal
Zone Protection Act of 1985.
b) Policy 28.3.1 (pq. 127) defines essential public
facilities as including education and health systems.
Essential public facilities are then defined in Policy
28.3.2 as those subject to minimum LOS standards and
concurrency management. Therefore, education and
health systems are not essential public services as
defined in Policy 28.~.2.
Recommendation
Revise Policy 28.3.1 by deleting reference to education
and health systems.
c) POlicy 28.3.2.1 (pg. 127) which proposes to adopt peak-
hour LOS standards for state, county and city roadways
1s not supported by analysis and objectives and
policies as cited in objections for 9J-5.007(2) (a), 9J-
5.007(3)(b), and 9J-5.007(3) (c). In addition,
reference to an implementation date is unnecessary as
minimum LOS standards become effective upon adoption of
the plan.
Recommendation
Include missing analysis and revised objectives and
policies in the Traffic circulation Element to support
the proposed LOS standards in Policy 28.3.2.1. Delete
Bv June 1990 from this pOlicy.
56
l jl ....
d) POlicy 28.5.3 (pg. 130) stating that the city will
institute a concurrency management system bv 1990 and
that determination of concurrency thresholds and
standards for approval shall be part of the system, is
unacceptable. By definition in the plan, bv 1990 means
the end of 1990. Regulations implementing concurrency
management must be adopted within 1 year of the city's
scheduled plan submission due date as required by s.
163.3202, Florida statutes. Concurrency thresholds and
standards are minimum level of service standards which
are determined and established at the time of plan
adoption.
Recommendation
Revise Policy 28.5.3 to include an implementation date
consistent with the requirements of s. 163.3202, F.S.
By May 1990 would be acceptable. Delete reference to
determining concurrency thresholds and standards as
part of the concurrency management system.
Reouirements for Capital Improvements Implementation
7. 9J-5.016(4l (all.
(a) The proposed Schedule of Capital Improvements (pgs.
132-135) is not supported by adequate analysis as noted
in an objection cited for 9J-5.016(2)(f)1.-S. The
missing analysis is needed to support Table 16-2 (pg.6)
Summary of Funds available for Capital Improvements
which in turn supports the Schedule of Capital
Improvements. Financial feasibility has not been
demonstrated.
Recommendation
Include the missing analysis as noted in the objection
cited for 9J-5.016(2) (f)l.-S.
(b)
The proposed Schedule of Capital Improvements is not
adequately supported due to deficiencies in the Traffic
Circulation Element as noted in objections cited for
9J-S.007(2) (b) and 9J-S.007(3) (c).
Recommendation
Correct the deficiencies noted in the Traffic
Circulation Element in order to provide adequate
support for the adopted Schedule of Capital
Improvements.
57
, .
B. COMMENTS
None
STATE COMPREHENSIVE ~ CONSISTENCY
A. OBJECTIONS
1. 9J-5.021
The Clearwater Comprehensive Plan does not adequately
address and further the following State Comprehensive
Plan goals and policies:
(a) 7(b)25 - to protect public and private property and
human lives from the effects of natural
disasters;
(b) 8(b)2 - to identify and protect the functions of
water recharge areas and provide incentives
for their conservation;
8(b)10 - to protect groundwater quality;
(c) 9(b)3 - to avoid the expenditure of state funds that
subsidize development in high-hazard coastal
areas;
(d) lO(b)13 - to encourage the use of public and private
financial and other resources for the
development of recreational opportunities; and
(e) 19(b)6 - to ensure that historic resources are taken
into consideration in the planning of all
capital programs and pOlicies and that these
programs and projects are carried out in a
manner which recognizes preservation of
historic resources.
Recommendation
Revise the local comprehensive plan to adequately
address and further the above State Comprehensive Plan
goals and policies.
B. COMMENTS
None
58
..... ~....
REGIONAL POLICY ~ CONSISTENCY
A. OBJECTIONS
1. 9J-S.021Cll
The Clearwater Comprehensive Plan is inconsistent with
the following Tampa Bay Regional Policy Plan goals and
policies:
(a) Goal 7.6 -
(b) Policy 7.8.2 -
(c) Goal 7.9 -
(d) Policy 8.8.1 -
development approval with consideration
of evacuation level/location;
formation of post-hurricane
redevelopment plans to discourage
rebuilding of devastated structures to
their pre-hurricane characteristics and
location;
no new infrastructure in hurricane
high-risk areas;
upgrading and retrofitting of drainage
systems in urban area to include
stormwater treatment for water quality;
prohibit dredging or spoiling of
undisturbed bay bottom;
(f) Policies 10.8.S- protect barrier islands from development
that impedes evacuation, geological
function and environmental character.
(e) Policy 9.4.S -
(g) Policies 13.2.1
13.2.2
(h) Policy 16.6.3-
(i) Policies 16.5.1-
16.5.2
16.6.1
16.7.2
Goal 16.7
(j) Policy 17.2.4 -
(k) Policy 19.8.8-
(I) Policy 19.8.9-
- locations for hazardous waste handling and
management facilities.
discourage strip commercial development.
appropriate location of residential,
commercial and industrial land
uses.
siting of controversial public facilities;
level of service standards on regionally
significant roadways; and
level of service standards on regionally
significant roadways in Special
59
~
l... .11II,
,~
Transportation Areas (STA'B) and approval of
STA's.
Recommendation
Revise the local comprehensive plan to be co~sistent
with the above referenced Tampa Bay RCPP goals and
policies.
B. COMMENTS
None
INTERNAL CONSISTENCY
A. OBJECTIONS
See individual elements.
B. COMMENTS
None
PLAN IMPLEMENTATION REOUIREMENTS
A. OBJECTIONS
None
B. COMMENTS
None
MONITORING AHQ EVALUATION REOUIREMENTS
A. OBJECTIONS
None
B. COMMENTS
None
60
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