Appendix Letters of Request for Additional Information A B

Appendix 1 Letters of Request for Additional Information A B C D E F Northeast Florida Regional Council Florida Department of Community Affairs Department of Environmental Protection St. Johns County St. Johns River Water Management District Florida Department of Transportation Letters of Request for Additional Information ENGLAND-THIMS & MILLER, INC. Appendix 1 Northeast Florida Regional Council Bringing Communities Together Baker ♦ Clay ♦Duval ♦ Flagler ♦ Nassau ♦ Putnam ♦ St. Johns April 8, 2005 Mr. Donald P. Hinson White’ Ford Timber and Investment Company s 3020 Hartley Road, Suite 100 Jacksonville, Florida 32257 Re: Request for Additional Information: SilverLeaf Development of Regional Impact Application for Development Approval Dear Mr. Hinson: The Northeast Florida Regional Council (NEFRC) has completed its review of the SilverLeaf Plantation DRI Application for Development Approval (ADA). Based on our review and that of the other reviewing agencies, the Council staff and a number of the reviewing agencies are requesting additional information that is needed before an adequate assessment of the project can be made. Please respond to the following questions from the NEFRC staff. Also, respond to the requests by each of the reviewing agencies, which are hereby incorporated as part of the Council’ request for additional information (attached). As you are s aware, the St. Johns River Water Management District was granted an extension and will provide their sufficiency review comments by April 22, 2005. A complete copy off sufficiency responses must be forwarded to all reviewing agencies in the same quantity as was requested for the original ADA. Sincerely, Edward Lehman DRI Review Coordinator cc: Mr. Don Smith Mr. Doug Miller Dr. Joseph Addae-Mensa Ms. Rachael Bennett Ms. Lindsey Haga Mr. Jim Robinson Ms. Kathryn Whittington Mr. John Metcalf Ms. Teresa Bishop 6850 Belfort Oaks Place ♦Jacksonville, FL 32216 ♦(904) 279-0880 ♦Fax (904) 279-0881♦ Suncom 874-0880 ♦ Suncom Fax 874-0881 WebSite: www.nefrc.org ♦Email: nefrc@nefrc.org Equal Opportunity Employer SilverLeaf Plantation Sufficiency Review Question 10 – General Project Description Table 10-1A proposes a land use equivalency table. Please note that reasonable maximum and minimum ranges of development for each use will need to be included in the SilverLeaf Plantation D.O. Please explain why on Table 10-1, Land Use by Phase, there are no Middle/K-8 school age students projected in Phase 3, when there are more single family and multi-family units project for phase 3 then in the previous phases where Middle/K-8 school age students generated? Also, explain why no High School students are projected to be generated in the Phase 1 and Phase 2 according to this table? In addition, the number of total students projected in this Table does not match the number of students generated by the project set forth in the Fiscal Impact Analysis of the SilverLeaf Plantation DRI. Please make corrections were appropriate. Question 11 Revenue Generation Summary Provide support for the development values assumed on Table 11.2.4. The values, especially for the non-residential components, are higher than those utilized in other DRIs recently reviewed in St. Johns County. Because FIAM is a per capita methodology, higher values for the non-residential development components will influence the fiscal impacts of the proposed project. What FIAM locational area was the SilverLeaf Plantation project placed for proposed of the fiscal analysis? Since FIAM is designed as a per capita methodology, how does the model address change in costs and revenue patterns over time because of changes in population, in the case of northeast St. Johns County rapidly changing populations. How were the project populations from recently approved and pending DRIs in St. Johns County addressed in the FIAM model run for SilverLeaf Plantation? What are the inflation rates by year utilized for both cost and revenues resulting from the FIAM analysis for the SilverLeaf Plantation project? Were there any adjustments to the inflation rates on either the cost or revenue side for any of the budget categories? If so please explain which categories and the adjustment made. Please provide the Council with a copy of the calibrated model and run including the documentation for the SilverLeaf Plantation project including a copy of the Data Input Tab for the SilverLeaf Plantation run. Provide support for the statement/assumption in the Fiscal Impact Analysis of the SilverLeaf Plantation DRI “ The capital costs associated with law enforcements, fire and EMS are all projected to equal the impact fees collected.” It looks like there was no analysis of needed capital projects to support the emergency management needs generated from the development of this project. Explain how this assumption was reached. List the law enforcement; fire and EMS facilities needed by phase as a result of the development of the SilverLeaf project along with the cost of each those facilities. It is our understanding that the fiscal analysis assessed by FIAM utilized the proposed impact fees which have yet to be implemented. If for some reason these proposed impact fees are not implemented as set forth in the analysis a new fiscal impact assessment will be needed. Question 13 – Wetlands The ADA states “ portions of the SilverLeaf Plantation wetlands are encumbered by existing conservation easements” These impacts include the proposed . North/South Corridor as well right of way for the East/West roadway. What entity/agency received the rights forgone under the conservation easement for onsite wetlands? Specifically identify the entity/agency with rights of the conservation easements wear the wetland impacts are projected to occur. What was the original purpose/reason for placing these wetlands under a conservation easement? What activated are allowed within the wetlands under the conservation easement? Page 13-2 of the ADA provided a discussion of Low-Quality Wetland Areas, Moderate-Quality Wetland Areas, and High-Quality Wetland Areas. Reference to low quality wetlands and impacts to such. Provide a map showing the location of low-Quality wetland Areas, Moderate-Quality Wetland Areas, and the HighQuality Wetland Areas. 13.5 Please provide confirmation from the entity that will receive the rights of the conservation easement for preserved wetlands and associated buffers that they are willing to accept the conservation easement. Question 16 – Flood Plains Applicant states “ majority”of flood plain areas fall within proposed conservation or open space uses. The question requires the applicant to specifically identify those areas to be developed that lie within the flood plain (i.e. extreme southeast corner). Locate and quantify. Applicant states all such development will meet SJRWMD requirements but fails to locate and describe mitigation. The question requires that applicant to specifically identify those areas to be developed that lie within the flood plain (i.e. extreme southeast corner). Locate and quantify. Question 17 – Water Supply The ADA has committed to the use of reclaimed water (“ reuse” water to the ) extent available. Further the ADA indicates that the residential reuse lines will be installed in all areas where the utility service provider can feasibly provided a supply. Letters from both utilities JEA and St. Johns County indicate the “ reuse” water is not presently available. However both indicated a desire to provide reuse water in the future. Is it the intent of the Applicant to installed reuse lines to residential, recreation and common areas prior to the availability of reuse water from the utilities in anticipation the reuse water will be available in the future? Provide a breakdown of the potable water demand by entity providing the service. Question 19 Stormwater Management What measures will be implemented to guarantee that the Community development District or property owners association will have the expertise to maintain the drainage system after completion of development? Provide concurrence from St. Johns County on their willingness to take ownership and maintenance responsibilities of portions of the Stormwater drainage system as stated in the ADA. Question 21 – Transportation Please modify the MSV column of Table 21-1 to show whether the study is one that is incorporated in the local governments’ concurrency spreadsheets, or one that was completed as part of the preparation of the ADA. The internal trip capture totals don’ seem to follow any logic and seem to have a t number of anomalies. Consistently within Tables 21-4 through 21-9, internal totals are the exact same for residential uses, when logic dictates that this shouldn’be the case. For example, Tables 21-4 and 21-5 show exact same t number of internal trips for the residential components of the Village Center South, even though the single-family component consists of 1500 dwelling units and the condominium component consists of 250 dwelling units. This seems to occur throughout the tables and does not seem consistent with sound traffic planning judgment. Table 21-3 shows the 6-laning of C.R. 210 between Russell Sampson Road and I-95 as a Phase 1 improvement with the Twin Creeks DRI as the entity responsible for its construction. Staff agrees that Twin Creeks will have some responsibility for widening C.R. 210 east of I-95, but at this time it is premature to assume any other improvements. There is no commitment for the 6-laning of C.R. 210; the analysis should be modified o analyze this segment as a four-lane segment. Staff is concerned about the decrease in traffic volumes between 2010 and 2020 on a number of segments within the impact area, in particular C.R. 210 west of I95. Additional justification to justify the decrease in trips needs to be provided. Besides stating that the applicant will participate in a Transportation Demand Management Organization (or with TDMO structure), what commitments will be made to reduce peak hour traffic to warrant the 2.8% decrease in trip generation. There is no evidence that other DRIs in this region have had any success with TDMOs in reducing the number of single occupant automobiles. Provide a map that specifically shows the four pods or villages that were considered in the phase trip generation. Question 23 – Hurricane Preparedness Applicant responded to the question by stating no demand is generated because no part of the proposed development lies with the evacuation zones. The behavioral analysis states on page B-6 Table B-1 the 25% of people are expected to evacuated for a category 3 storm from non-surge areas. On page B12 Table B-2 the behavioral analysis states that 10% of evacuating persons (high and middle income) living in non-storm surge zones intend to use public shelters. Those calculations needs to be made and stated and the public shelters are and note if the County is in a deficit position for shelter space. An analysis of evacuation impacts should be provided to account for the percentage of people expected to evacuate for a Category 3 storm in non-surge areas. Question 24 – Housing Provide the source for the housing supply numbers provide on Page 24-4 of the SilverLeaf ADA; 1,050 very-low income units, 4035 low-income units, and 2,990 moderate-income units, available with the housing impact area. These numbers are far greater than recent studies completed for other DRI that are located within or overlap with the SilverLeaf Housing Impact Area. If available please provide a copy of the housing supply source utilized to generate these numbers. Was the demand for affordable housing units generated by the FIAM run for the SilverLeaf Plantation? Question 25 – Police and Fire Protection Police The ADA indicates the donation of a site for a sheriff/fire/EMS facility in Phase 3. Does the timing of this donation meet the timing of need for the facility by the County? Provide concurrence from the County on the timing of the donation of the site. Fire Please provide the correspondence from the St. Johns County Fire Marshall acknowledging notice of the proposed development and phasing, and specifying the additional manpower/equipment necessary to serve the development. Question 26 – Recreation and Open Spaces As it relates to the Regional Park who will be responsible for the cost of providing the active recreational amenities i.e. playing fields, multi use courts, hiking trails and other active recreation facilities? Who will be responsible for providing the active-based recreational facilities at the neighborhood parks to be provided in each neighborhood? Question 27 – Education That is the source of the projections for number of children per household? Please note that the St. Johns County School District has not yet agreed on this projection. The ADA indicates that SilverLeaf will cooperate with the St. Johns School Board to advance fund the construction of an Elementary School and K-8 School. Does “ advance fund the construction,”mean that it is the intent of SilverLeaf to be reimbursed for construction costs of the School facilities? Please provide a copy of letter from St. Johns School Board, which provided concurrence with projected school age population, the number of students by school type by phase and the projected schools types and numbers needed due to the SilverLeaf project. Question 30 – Historical & Archaeological Sites Please provide a copy of the letter from Division of Historical Resources, State Historic Preservation Office indicating their concurrences with the survey and its results. Florida Department of Community Affairs 2555 Shumard Oak Boulevard Tallahassee, Fl 32399-2100 (850) 488-8466 April 5, 2005 Edward Lehman DRI Review Coordinator Northeast Florida Regional Planning Council 6850 Belfort Oaks Place Jacksonville, FL 32216 Re: SilverLeaf Plantation DRI –St Johns County (DCA Project No. ADA-0405-016) ADA 1st Sufficiency Review Dear Lehman: The Department has completed the First Sufficiency review of the Application for Development Approval (ADA) for the SilverLeaf Plantation Development of Regional Impact (DRI) located in St. Johns County. To assist us to adequately assess the impacts of the proposed SilverLeaf Plantation DRI, we are requesting additional information as follows: Part II: General Questions Question 9 –Maps Map H –Master Development Plan: Include the proposed land uses, maximum development for each land use (in terms of number of residential units and non-residential square feet) and phases of development as identified in Table 10-1, page 10-4 of the ADA. Map I –Master Drainage Plan: Revise the map to delineate existing and proposed drainage systems. This information may be presented on two separate maps (existing and proposed) Question 10 –General Project Descriptions Part 1A: The SilverLeaf Plantation Pre-application documents, dated November 24, 2004; and a letter to the Submerged Lands Section of FDEP (included in the ADA as Exhibit 13-1 and dated 30 December 2004), describe the DRI as consisting of approximately 7,500 acres. Edward Lehman April 5, 2005 Page Two However, the ADA identifies the property as consisting of approximately 7,285 acres (Page 101), a difference of 215 acres, and based the impact analysis on the 7,285 acres. Please, explain the reduction in acreage for the DRI. Part 1E: The ADA (Pages 10-7 & 10-9) refers to A Needs Analysis, completed by Fishkind and Associates and included as Appendix 1. This study is missing in the ADA. Please, provide this study for review. Part III: Environmental Resources Impacts Question 13 –Wetlands Part A3: Exhibit 13-3 Wetland Conservation Easements Map as a base, include acreage breakdown of wetlands which are to be preserved in their natural or existing state and those to be impacted within the SilverLeaf Plantation DRI. Part IV: Transportation Resource Impacts Question 21 –Transportation Part F: The ADA indicates that the project’ transportation impact will be mitigated by payment s of a proportionate share contribution by way of a pipelining procedure. The applicant should be aware that the Department will be reviewing the project design for a demonstration of consistency with all the criteria provided under Section 163.3180(12), Florida Statutes (F.S.). The criteria include ensuring that the project contains an integrated mix of land uses and is designed to encourage pedestrian or other non-automotive modes of transportation; and the proportional share contribution is sufficient to pay for one or more required improvements that will benefit a regionally significant transportation facility. Additionally, the Department will like to see that the proportionate-share contribution for local and regionally significant traffic impacts is approached as follows: 1. Calculate the proportionate share amount based on local and regionally significant traffic impacts; 2. Identify one or more required improvements that will benefit a regionally significant transportation facility; 3. Re-run the analysis to demonstrate that the required improvements will in fact benefit a regionally significant transportation facility; and 4. Include specific amounts and improvements in the development order. The funds directed to the required improvements by the development order should be at least as much as the calculated proportionate share amount. Edward Lehman April 5, 32005 Page Thee Part V: Human Resource Impacts Question 24 –Housing The applicant has not identified the Methodology used to do the Affordable Housing Analysis, whether the methodology recommended under Rule 9J-2, F.A.C., or the East Central Florida Regional Planning Council Housing Methodology, or any other methodology. Please, describe the methodology utilized. Thank you for the opportunity to comment on this ADA. Please contact Joseph Addae-Mensa, Senior Planner, at 850-922-1783, if we may be of further assistance regarding this matter. Sincerely, Mike McDaniel Growth Management Administrator Division of Community Planning MM/jam cc: Teresa Bishop, AICP, Planning Director, St. Johns County Department of Environmental Protection Northeast District 7825 Baymeadows Way, Suite B200 Jacksonville, Florida 32256-7590 April 4, 2005 Mr. Edward Lehman Growth Management Director Northeast Florida Regional Planning Council 6850 Belfort Oaks Place Jacksonville, Florida 32216 Dear Mr. Lehman: Re: SilverLeaf Plantation DRI; St. Johns County Application for Development Approval The Northeast District Staff has reviewed the SilverLeaf Plantation DRI application for development approval. The following sufficiency questions and recommendations are offered on this project: Wetlands Question 13 A 6: Please provide the acreage and location of wetlands that will be disturbed. The Department aggress that contiguous wetland systems are important. On page 13-5 it is stated that impacts to the largest contiguous wetland systems have been minimized and are generally caused by roadway crossings. If roadway crossings are necessary, has there been an effort to minimize impacts from these crossings, i.e. elevated roadways, etc.? Surface Water Protecting water quality is a priority of the Department. Will a Water Quality Monitoring Plan be provided? Water Supply Both St. Johns County Utilities and JEA indicated in their Letter of Service Availability that they have sufficient potable water capacity available from existing and planned water facilities to meet the potable water needs of the development. However, the utilities must answer in detail Question F.1, items a, b and c (page 17-6), to demonstrate that their water supply facilities will have the excess capacity to service this development. This information was not clearly provided in their letters. Our records indicate that St. Johns County Utilities and JEA do not have the required excess capacity at the present time to supply potable water needs for this development, and it may require the construction of a new water plant or the expansion of existing plants to serve the facility. It is necessary that both utilities provide additional information regarding their plans to expand their water system capacity to demonstrate that they will have the required excess capacity to service this development. The utilities must clarify if they have made any other commitments for their excess capacity i.e. other development projects. Wastewater Reuse of reclaimed water for this area should remain an important goal for both the development and the utilities. Stormwater Map I Master Drainage Map: Is this the pre-development or post-development map? There was only one drainage map, please provide another map addressing the missing information. The applicant will have to apply for a DEP-NPDES Generic Permit for Stormwater Discharge during Construction Activities. This application must be submitted to the NPDES Stormwater Notices Center in Tallahassee. In addition if dewatering activities are necessary during construction please contact the Northeast District office for a permit application. Best management practices for erosion control are recommended for this project to be in a plan and incorporated in the development order. This plan should include an erosion control specialist to oversee erosion control throughout the development, specific strategies and commitments for sedimentation and erosion control such as: a double row of silt screening on all lands adjacent to wetlands; several lines of silt barriers in the surface waters; daily monitoring, recording and repairing of control devices; along with standard strategies that are included in Chapter 6 of the “ Florida Development Manual: A Guide to Sound Land and Water Management.” Waste Management of solid waste generated during construction of the development has not beeen addressed. Although, on-site disposal of construction debris is exempt from the state’ permitting requirements, disposal of construction debris that will adversely affect s the environment is prohibited. Please address the management of construction debris such as waste paint, solvent based glues and caulks, paint thinner, CCCA treated lumber and cleaners containing hazardous substances. How will these wastes be separated from non-polluting construction debris? Please identify off-site disposal locations for the construction debris. It is always possible that the former land use (agricultural) could have lead to environmental concerns that have not been brought to the attention of the Department. Currently no sites are being assessed or remediated, by our waste clean up section, within the project boundaries. Based on the maps provided there are 3 former petroleum contaminated sites within the project boundary. Each of the sites has received a Site Rehabilitation Completion Order form the Department for the contamination found and no further action is required. Thank you for the opportunity to comment on this project. If you have any questions or comments I can be reached at (904) 807-3209 or Jennifer.Auger@dep.state.fl.us. Sincerely, Jennifer M. Auger Environmental Planning & Intergovernmental Affairs DRI-2005000002 Submittal 1 Comp Dt: Please note that application re-submittals will not be accepted until all Divisions/Programs have completed their reviews and St. Johns County has formally notified the Application Representative. View Previous Submittal: View Comments 1 Update Close Dept Code COENG DEVSVC DRIPL EHD EVRPL FRSVC GMSD Housing OCA PLANDIR Department Engineering Division Development Services DRI Planning Environmental Health Department Environmental Planning Fire Services Growth Management Services Director Housing Office of County Attorney Planning Director Date Rcvd Date Sent Comments Due Date Date Reviewed Issue Open Cnt Issue 8 0 21 1 18 1 0 3 0 0 12 2 1 2 0 8 0 21 0 18 1 0 0 0 0 12 2 1 2 0 3/10/2005 3/29/2005 4/5/2005DML 3/10/2005 3/29/2005 4/4/2005MHG 3/10/2005 3/29/2005 4/5/2005LKH 3/10/2005 3/29/2005 3/14/2005MJT 3/10/2005 3/29/2005 3/29/2005JPB 3/10/2005 3/29/2005 3/28/2005JJR 3/10/2005 3/29/2005 4/6/2005LKH 3/10/2005 3/29/2005 4/5/2005TMC 3/10/2005 3/29/2005 3/29/2005ICL 3/10/2005 3/29/2005 3/10/2005 3/29/2005 3/10/2005 3/29/2005 4/5/2005TLB 4/3/2005JPS 4/4/2005RSR PUBWORKDIR Public Works Director REC SURVE TRAPL UTIL Recreation Survey Concurrency/Transportation Planning County Utility Department 3/10/2005 3/29/2005 3/17/2005PGO 3/10/2005 3/29/2005 3/10/2005 3/29/2005 4/4/2005JDT 3/30/2005SR Document1 1 of 10 6/15/2005 2nd Submittal DEVELOPMENT OF REGIONAL IMPACT COMMENTS Application Number: DRI2005000002 Response to Comments / Submittal #: 1 Project Name: SilverLeaf Plantation DRI Applicant: Doug Miller DEPARTMENTS CONCURRENCY/TRANSPORTATION PLANNING 1. Planned and Programmed Improvements: The applicant has included the SR 9B Extension From CR 244 to I-95 as a part of the Planned improvements at buildout which is within ten (10) years. Staff believes that the northern-most section of the road will be complete within that time period, but does not concur with the southern section being complete, under construction, or funded at that time. 2. Trip Generation: Staff can not find any documentation that supports the use of a Transportation Demand Management (TDM) credit or in the proper application of a credit during site plan analysis. The applicant has referenced studies and provided copies of excerpts forms studies as supporting documentation for the use of TDM credits. Staff reviewed the supporting documents provided by the applicant and could not determine where in that literature it either recommends the use of a TDM credit or a proper application of a credit if one is agreed upon. St. Johns County is supportive of any method that will reduce the demand for the limited capacity that exist in our network. However, without any empirical, indisputable data that shows a relationship between the establishment of a TDMA and a reduction in vehicle trips in areas similar to St. Johns County, staff cannot support this credit. In Appendix B of the 2nd edition of the Trip Generation Handbook by I.T.E., issues are raised on several points concerning how to translate data from surveyed participants for use in establishing trip generation numbers. The focus of this discussion centered on the distinction between persontrips verses vehicle-trips and a reduction in vehicles verses a reduction in vehicle trips. It also talks about how TDM strategies concentrate on commuter (employee) trips verses noncommuter trips. In other words, if you agree on a credit, the credit should only apply against work trips to the office by employees and not by non-employees. Additionally, it states that the data that does exist only tracks the reduction in the number of vehicles arriving at the work site and not the reduction in the number of trips those vehicles take. In conclusion, the use of a TDM credit has not been justified or properly applied for this analysis. For the sake of discussion, if the credit is to be used, it cannot and should not be applied across the board on each of the land uses. Document1 2 of 10 6/15/2005 PLANNING DIRECTOR Application reviewed and signed off. DRI PLANNING 1. Question 4, the response indicates the SJP, LLC owns land within one half mile of the proposed DRI. Please provide a map of the other lands under ownership. 2. Question 9 –Map H needs to be revised to adequately show connectivity between and within land uses. For example, an access arrow is provided into the regional park without demonstrating through access to the proposed east/west 16A extension and access arrows are shown between residential pods (parcels 23,24,33,34) without through access to other access arrows. In addition, show pathways and pedestrian connectivity. 3. Question 9 - Staff believes the proposal for Mixed Use at the intersection of SR 16 and the proposed SR 16A extension is inconsistent with Policy A.2.1.9 (d) and (f) of the Future Land Use Element, which describes the general development pattern for the Northwest sector. Given the close proximity to the Village Center South mixed-use area, please address the provision of this strip commercial pod. 4. Question 9 - Describe the vehicular and pedestrian access from the Village Center South to the mixed-use component (parcels 52 & 53) located off of CR 2209. Revise Map H to display east/west interconnectivity in order to avoid a reliance on the major roadway network. 5. Question 9/10- The general project description includes statements of the provision of neighborhood parks within each neighborhood (i.e. minimum 5 ac parks). How will each residential neighborhood be divided? Neighborhoods bifurcated by roadways will be considered separate and distinct, therefore subject to individual neighborhood design standards of the NW sector plan. Definition of neighborhoods will dictate total number of parks to be provided. Please provide total number of neighborhood parks within each residential community, including locating parks within 0.25 mile walking distance, and locate on Map H. 6. Question 10 - Staff does not accept the inclusion of the conservation easements as wholly resultant of the DRI application in terms of a benefit from the project. The land currently exists under perpetual conservation easements. Given the existing preservation controls, describe the necessity for including the land within the project. 7. Question 9 -Please provide information regarding the planned access to the out parcel located within the proposed project site. How will individual access be incorporated into the overall plan of development? 8. Question 9 - Describe the access to school sites as well as interconnectivity with adjacent recreation and residential areas. Staff expects continued discussions with the School Board in order to coordinate efforts with secondary access to the proposed school sites. 9. Question 10 - Documentation must be received from the School Board with regard to concurrence with the student population projections. 10. Question 10 - St. Johns County Library Services requests consideration of a library site of at least 3-5 acres depending on the requirements for water retention on-site. The library site could be in combination with the academic village, park sites, school or commercial sites, if the developer agrees. Document1 3 of 10 6/15/2005 11. Question 10 - Please describe more fully the compatibility issues with adjacent farmland and the proposed residential areas along the southern property boundary. Page 10-20 describes consistency with the character of the surrounding development through the provision of adequate buffering. Given the agrarian/rural character of the community, how will the project address compatibility through the implementation of Policy A.2.1.9 (a) and (b). 12. Question 10 -Provide minimum and maximum development totals for the proposed land use equivalency table. Does the applicant intend to allow full conversion of uses? 13. Table 10-1 describes the proposed land uses by phase. How does the provision of 1.14 million of retail support the NW goal of discouraging bedroom communities by supplying a balanced ratio of uses? Please document compliance that the proposed SilverLeaf development program will maintain the ratio of uses adopted under Policy A.2.1.8. 14. Question 10 - The demographic information uses a static 2.44 household population. Please provide supporting documentation for an unchanging household size. 15. Question 10 - Staff does not accept the inclusion of the conservation easements as wholly resultant of the DRI application in terms of a benefit from the project. The land currently exists under perpetual conservation easements. Given the existing preservation controls, describe the necessity for including the land within the project. 16. Question 26 - Please expand upon the functional open space of the FPL easement. Staff echoes comments provided by the Recreation Department regarding this use; if included as part of the required open space, display on Map H. 17. Question 30 - Please furnish acceptance letter from the State Historic Preservation Office regarding the archaeological survey completed for the site. 18. The following questions were not completely answered in the ADA submittal. Additional information will be required and additional reviews may be necessary to find the document sufficient. Please provide more information on these questions: Exhibits for 12A, 13A, 28, 27 and 29. 19. Question 14 - The response describes the applicant's commitment to provide installation of reuse lines where feasible for each utility provider. Given the responses by the utility providers, it does not appear reuse will be provided to the site. What plans exist to install/provide irrigation lines supplied by stormwater in absence of the reuse supply? NOTE: Policy D.5.3.1 of the Infrastructure element requires utilization of stormwater for irrigation. 20. Question 17 - The analysis included under Table 17-2 assumes water supply for irrigation will be collected from 80% reuse and 20% stormwater. Given the responses from the utility providers that reuse is unavailable at this time, these assumptions are unreliable. Please recalculate the analysis using appropriate assumptions regarding supply sources. Planning Division Reviewer: Lindsay Haga, Planner II (904) 209-0591 lhaga@co.st-johns.fl.us Document1 4 of 10 6/15/2005 GROWTH MANAGEMENT SERVICES DIRECTOR Application reviewed and signed off. PUBLIC WORKS DIRECTOR Map J depicts the transportation study boundary excluding the extreme north western portion of St. Johns County. The assumptions that led to the establishment of this boundary appear questionable because SR 13 is one of the very few routes leading to Duval county. Specific concerns include assumptions regarding the date and capacity of proposed roadways in the northwest segment of St. Johns County, including SR 9B, the Racetrack Road realignment, the connection between Racetrack Road and I-95 via Bartram Park Blvd., capacity/operational improvements at I-95 and CR 210, and the CR 210 interchange at U.S. 1. If this area of St. Johns County was included several critical segments and intersections would be included in, and possibly result in significant modifications to, the traffic impact assessment of the development. Table 21-3 includes the Bartram Park Blvd. connection from Racetrack Road to I-95. It is noted that this connection is not currently a requirement of the Bartram Park DRI until and unless the relatively few residential units located in St. Johns County are constructed. The assumption that this link will be in place by any time certain therefore appears questionable. Table 21-3 appears to include 6 lanes on CR 210 west of the limited access limits of the I-95 interchange. I am aware of no proposed or approved project that includes six lanes west of the limited access limits of the I-95 interchange. Please clarify. Table 21-3 appears to include roadway improvements proposed by the Twin Creeks and Ashford Mills Developments of Regional Impact. It is noted that these are not approved developments, and that the inclusion of specific projects as committed improvements for the purpose of traffic impact evaluation is questionable. It is possible that the developments will not be improved, and more likely that specific improvements may not be included in a prospective development approval. It is further requested that the details of how traffic from these not yet approved developments is accounted for in the SilverLeaf traffic impact study. Table 21-3 reflects the County's obligation to reconstruct Russell Sampaon Road from its current dirt road configuration to a two-lane collector roadway from CR 210 to the Taylor-Woodrow (St. Johns Forest) entrance as a 2004/05 obligation. That should be 2007/08. Tables 21-4, 21-5, 21-6, 21-7, and 21-8 reflect relatively high internal capture rates for ITE codes 230, 820 and 220. The appropriateness of these internal capture rates appears questionable. Leo Maguire Road extension on its proposed alignment (map J) is entirely within the SilverLeaf development, connecting CR 2209 to the CR 16A extension via a circuitous route that is not consistent with the NWSJC Sector Plan. Table 21-23 indicates that the construction cost of this internal circulation collector is proposed as mitigation credit. Absent the SilverLeaf development this road would certainly not be needed or appropriate on the proposed alignment and the need on any alignment is questionable. Therefore, the appropriateness of this roadway construction as a transportation mitigation credit is questioned. The CR 16A extension as depicted on map J is not consistent with the NWSJC Sector plan, is entirely internal to the SilverLeaf development, and is redundant (parallel) with the reserved right-of-way intended as a corridor for future connection to I-95. Due to these characteristics, its appropriateness Document1 5 of 10 6/15/2005 as a mitigation credit as reflected in Table 21-23 is appears questionable. The mitigation plan presented in Table 21-23 does not include any improvements to CR 16A west of the point where the proposed CR 16A extension connects to the existing road. The CR 16A extension is reflected as a 4lane facility, while the existing CR 16A is a sub-standard 2-lane facility on an inadequate right-ofway. Construction of the facility as described will place an unacceptable volume of traffic on the existing CR 16A, with no committed plan or funding source for its improvement. It is suggested that improvements to CR 16 A, between SR 13 and its connection to the proposed CR 16A extension, be added to the SilverLeaf development's mitigation plan. The reserved right-of-way reflected on Map J does not appear (I did not see them) to be described or discussed in the transportation section. The intent and other details of this proposal should be clearly reflected. It is noted that the SilverLeaf development will consume at least 30 percent of the capacity of CR 2209 at build out, yet the full cost of construction of this facility is credited to the development's mitigation contribution. The I-95 / CR 210 interchange is an existing problem within the SilverLeaf development's study area. At this time the Interchange Modification Report that will establish the long-term improvements required at this interchange will not be completed for approximately one year. It appears that this interchange could be the closest point for SilverLeaf to access I-95 for some time. Therefore, it appears prudent that the possibility that this development may need to participate in improvements to this critical interchange be left open. ENVIRONMENTAL PLANNING 1. The portion of the east west road right-of-way reservation lying east of the North South Corridor road does not follow the original route as depicted on the Northwest Sector map. The road placement on the Northwest Sector map for this portion of the east west road was deliberate. The route depicted on the Northwest Sector map has substantially fewer environmental impacts than the route now depicted on Map H. Comprehensive Plan Policy A.2.1.2 (a) reads, “ The Northwest Sector Overlay map generally depicts arterial and major collector roadways and other designated roadways” Further, Comprehensive Plan Policy A.2.1.2 (k) reads, “ . Major collector and arterial roadways shall not divide neighborhoods. Connectivity shall be controlled to preserve natural systems, maintain neighborhood development edges and to direct the movement of traffic, bikes and pedestrians” The placement of the road as depicted on Map H does not . bound a development or neighborhood edge and definitely does not preserve the natural system. This major road as proposed is placed directly through the Big Island Swamp wetland system impacting a large acreage of wetlands and would precipitate the need for numerous wildlife and wetland crossings. Please return the placement of this roadway to the original route as depicted on the Northwest Sector map. 2. Several references are made that, “ SilverLeaf Plantation plans to install residential reuse lines in all areas where the utility service provider can feasibly provide a supply of that utility”including, but may not be limited to, references on pages 14-3, 17-4, 17-7. This statement is very misleading in that Exhibits 17-1 and 17-2 demonstrate that it is now known that reuse water cannot be provided at this time. The letter from JEA dated January 10, 2005, reads “ JEA does not have sufficient reclaimed water capacity available to serve the DRI”and the letter from the St. Johns County utilities dated February 7, 2005, reads that the County does not have reuse water available but will “ work with local and state agencies to make reuse water available to this development” So when it is stated that, “ . SilverLeaf Plantation plans to install residential reuse lines in all areas where the utility service provider can feasibly provide a supply of that utility” does that mean the lines will be installed, at a minimum, in the St. Johns County utility service area believing that reuse water will be available in the future or will the development install reuse lines throughout the project for future use? Please discuss what is meant by this statement. Document1 6 of 10 6/15/2005 3. Parcel P. It is stated in the application that this Parcel has an existing timber contract held by Rayonier Woodlands LLC. Please provide details concerning the nature of that contract, in particular, the areas allowed for timbering and the date when the contract will expire. This has direct bearing on the review of this proposal in that the majority of Parcel P is wetlands with an existing Conservation Easement in that it is questioned if this Parcel be available for development in the future thereby affecting the review of this current proposal for open space and wetland preservation. Therefore, please provide the requested information so a more informed review can be made and comments can be rendered. 4. Parcel H. It is not understood why this Parcel has been included in this proposal. This parcel is covered by an existing Conservation Easement that excludes all portions from development. The Conservation Easement’ expressed purpose is to “ s assure that the Property will be retained forever in its existing natural condition and to prevent any use of the Property that will impair or interfere with the environmental value of the Property” So there are no developable rights on . this Parcel. Further, this parcel is a narrow ribbon of almost exclusively wetlands that is surrounded by the outparcel. Please explain the need for the inclusion of this piece in the project. 5. Parcel E. It is not understood why this Parcel has been included in this proposal. The majority of this parcel is covered by an existing Conservation Easement that excludes all portions from development. The Conservation Easement’ expressed purpose is to “ s assure that the Property will be retained forever in its existing natural condition and to prevent any use of the Property that will impair or interfere with the environmental value of the Property” So there are no . developable rights on that portion of the Parcel. Further, except for a very minute portion, this Parcel is wetland as demonstrated on Exhibit 13-3. Please explain the need for the inclusion of this piece in the project. 6. Parcels G, 1, 2. All or part of these Parcels are covered by an existing Conservation Easement that excludes the portions covered from development. The Conservation Easement’ expressed s purpose is to “ assure that the Property will be retained forever in its existing natural condition and to prevent any use of the Property that will impair or interfere with the environmental value of the Property” So there are no developable rights on these Parcels. Further, these parcels are . wetlands as demonstrated on Exhibit 13-3. Please explain the need for the inclusion of these parcels in the project. 7. Map D. This map displays Plantation PUD with a more southerly boundary than it has. Please correct. 8. All references to the upland buffer require revision. There are numerous references to providing upland buffers for this project that are consistent with and provided through the St. Johns River Water Management District and their permitting process and being provided at the Planned Unit Development review. Article IV of the Land Development Code sets forth required upland buffers adjacent to contiguous wetlands. This project is required to commit to and provide at the Development Order level upland buffers and associated building setbacks consistent with the Land Development Code requirements. Please incorporate this language into all applicable areas that now reference the SJRWMD and other appropriate areas including but not limited to references made on pages 10-3, 13-4, 13-7 and 14-3. 9. Please provide text and a map that sets forth location and acreage of wetlands that currently exist, that are proposed to be preserved and that are proposed to be impacted. When adding the wetland impacts on Table 10-2 for FLUCFCS codes 411W, 620, 621 and 630 the acreage of Document1 7 of 10 6/15/2005 impact totals 310 acres but on page 13-5 the text sets forth 325 acres of impacts. Please provide information on the variation between these two figures and the requested additional text and map. 10. The text on page 13-5 sets forth that the majority of impacts will be to “ low quality wet pine plantation” But when Map F is compared to Map H to try and determine the location of . impacted wetlands it appears that the majority of impacts are to Wetland Coniferous Forest not Wet Pine Plantation. Please reconcile this discrepancy. 11. Map G depicts locations of areas reviewed for significant wildlife. On that map it is seen that three of the areas reviewed documented the presence of the Florida Black Bear and these locations were scattered on the property -- one on the west portion, one in the central portion and one on the east portion of the property. Therefore, it logically may be assumed that the Florida Black Bear may be present throughout the property. Further, only two wildlife crossings have been proposed and they are depicted on Map H. The locations of the two depicted are acceptable locations however additional wildlife crossings are needed to allow for wildlife movement. Appropriate additional locations of wildlife crossings are where the east/west road crosses the Wards Creek wetland and where the North South Corridor crosses Trout Creek. 12. Map G depicts several recorded observations of Bald eagle on the property. Please discuss the methodology used to survey the property for the presence of bald eagle nests. Once this information is received a review will be made and comments may be rendered that require revision to this document. Further, as you are aware the Land Development Code Section 4.01.10 provides for the protection of the bald eagle in St. Johns County. Due to the number of sightings and the location of the property with respect to the St. Johns River it may reasonably be concluded that a bald eagle nest may exist on the property. Therefore, please add language that states the protection of the any identified Bald Eagle nest will comply with Section 4.01.10 of the Land Development Code. 13. When comparing Map G to Map H it is seen that gopher tortoise Site A, with a high density of gopher tortoise present (1.26 tortoise/acre), is to be provided to the County for a school site and a Community recreation area. Will the mitigation for the gopher tortoise be provided with the mitigation for this project or will that mitigation fall to the County? 14. Consistent with the vision of the Northwest Sector Plan, please develop a Greenway system with named corridors that are identified and preserved and display the system on the Master Development Plan. 15. Please provide a copy of all environmental surveys that have been completed for review and comments. 16. Figure 26-1 provides a conceptual plan for the Regional Park and although there is a disclaimer attached to this figure that all is conceptual and depends on permitting it needs to be stated at this time that any activity on this land shall meet all requirements of the Land Development Code for upland buffers, listed species and any other applicable requirement. 17. Please provide a non-shaded aerial map. The shading renders the map useless. 18. As per Article IV of the Land Development Code, Stormwater ponds cannot be placed in nor graded into the upland buffer. Please review and correct language to reflect this requirement. Document1 8 of 10 6/15/2005 Information Only: Jan P. Brewer 904/209-0617 jbrewer@co.st-johns.fl.us DEVELOPMENT SERVICES Application reviewed and signed off. ENGINEERING DIVISION 1. The traffic emanating from the TAZ's is beyond what RS&H has projected for the CR 2209 study for St. Johns County. 2. Appendix 21, Tab G3 - The CR 2209 improvement is noted as a new 2-lane roadway between CR 210 and SR 16. The RS&H traffic projections require a minimum of 6 lanes between CR 210 and SR 16 and 4 lanes between SR 16 and CR 208. 3. Based on the recent permit application for CR 2209 between CR 210 and IGP, a right-of-way width of 250' is required to accommodate 6 lanes. This width excludes storm water management facilities. Recent CR 2209 CADD drawings from England, Thims, and Miller show that a right-of-way width of 200' is being considered through SilverLeaf. 4. Regarding a January 10, 2005 letter from St. Johns County to Don Smith, did the applicant submit JUATS output to FDOT per the request in the letter? 5. Were any adjustments made to the study area boundary? 6. The JUATS output requires thorough examination, since model results may be questionable in this vicinity of the County. 7. The Map J in the ADA binder does not show the same study intersections as the Map J in the binder for the ADA Transportation Appendix. Were all of the intersections listed in the MOLU addressed in the ADA? 8. On p. 6 of App 21-G, the number of persons per dwelling unit was assumed to be the same for both single and multifamily housing (2.44) Why? Information Only: The following comments provided by RS&H who are currently under contract with the County for the Design and Permitting of CR 2209: FIRE SERVICES As indicated in an Impact Letter dated 2/10/05, most of the proposed SilverLeaf DRI will be covered with existing fire stations or fire stations that will be constructed prior to 2008. We are unable to determine full coverage, as the proposed village roads have not been sent to us to model. As growth continues, The Fire Service Model indicates that future growth within the region will support additional fire station(s) for overlapping coverage. We do see in your proposal that you anticipated a fire services facility within your Project by Phase III, and on map H this facility Document1 9 of 10 6/15/2005 appeared in a mixed-use area labeled number 39. After discussion with the Fire Chief, and his staff, Fire Service agrees that a future fire station site will be necessary within your project. However this fire station site needs to be transmitted to the County Fire Department at the end of Phase I (January 2012). The site needs to be 3 upland acres, with road access. Our Growth model indicates that Mixed Use area 29 would be the best site location however area 39 is acceptable. We recommend discussion with the property owner representative on the site location prior to changing Map H. ENVIRONMENTAL HEALTH DEPARTMENT Application reviewed and signed off. COUNTY UTILITY DEPARTMENT Information Only: No comments. Reviewed by: Samuel T. Ramirez, SJCUD UDM, 904-471-2161 ext. 15 RECREATION Initial review looks like the project provides adequate regional facilities for the site. Recreation request to be involved in the final design of the facility- for example, we have a need in the area for more tennis courts than are presented in the conceptual Master Plan. Please make a commitment to provide a 8-12 foot wide, paved trail either along the FPL power lines, the North-South corridor, or other similar location, providing the potential for connectivity to other trails. HOUSING Application reviewed and signed off. SURVEY Please provide a digital file in dwg format (from the surveyor) of the legal descriptions in Section III C of each of the parcels indicating parcel numbers or letters. Please show the exceptions as exceptions. Information Only: Comments by: Gail Oliver, PLS, County Surveyor, Phone: 904-823-2485, Email: goliver@co.st-johns.fl.us OFFICE OF COUNTY ATTORNEY Application reviewed and signed off. Document1 10 of 10 6/15/2005 April 22, 2005 Ed Lehman, Director of Growth Management Northeast Florida Regional Council 6850 Belfort Oaks Place Jacksonville, FL 32216 Subject: SilverLeaf Plantation Development of Regional Impact (DRI) Application for Development Approval (ADA) Dear Mr. Lehman: St. Johns River Water Management District (District) staff have reviewed the above-referenced ADA for the SilverLeaf Plantation DRI in St. Johns County and have the following comments. District staff met with the applicant during our review process to discuss our concerns. We would like to thank the applicant for granting additional time in order to meet with us and thus allow us to complete our review. Question 10 –General Project Description • Conservation, Preservation, and Open Space Designations The applicant states that 3,500 acres of the total 7,285 acres in the DRI will be conserved, preserved or used as open space. Large areas within the DRI boundaries are already subject to existing conservation easements and therefore have already been preserved in perpetuity. In describing the acreage and locations of preservation, conservation or open space areas, please differentiate between (1) the areas already preserved or proposed to be preserved by conservation easement (regardless of the SilverLeaf DRI) and (2) new areas proposed to be conserved, preserved or used as open space in connection with the SilverLeaf DRI. In addition, please explain the difference, if any, in the use of areas described as “ conservation,” “ preservation,”and “ open space.” • DRI Uses Proposed in Conservation Easement Areas In a number of locations, the DRI proposes land uses on property that is currently subject to conservation easements held by the District. Such uses are not allowed by the conservation easements. Therefore, please explain how these areas can be developed in accordance with the proposed Master Development Plan (Map H), and please quantify the proposed impacts to existing conservation easements and to proposed conservation easements. Also, please explain how the Master Development Plan was designed to minimize impacts to conservation easements (for example, it is not clear that the conservation easements near the western boundary must be impacted by school and residential development). Ed Lehman April 22, 2005 Page 2 of 4 The District has tentatively approved the mitigation value of conservation easements that have been proposed for areas shown as Community Recreation on Map H. The District is concerned that active recreational use of the property would affect the mitigation value of those proposed conservation easements. Please clarify the proposed recreational use of the area surrounding and within the proposed conservation easements. • Affects on Regional Ecological Values Many of the conservation easements held by the District and located within the DRI were proposed, accepted, and valued as being part of a plan that provides regional ecological value. Many of the conservation easements are connected to regionally significant ecological resources, including lands and conservation easements acquired by the District and other governments for environmental conservation. The District is concerned that the DRI could affect the conservation easement areas in a manner that reduces the regional ecological value of those conservation easements, which would in turn affect a number of permits that have been issued by the District. Please explain how the proposed development would maintain the regional ecological value of the conservation easements, particularly the connectivity of those conservation easements to other preserved areas. • ROW Reservation Proposed in District Conservation Easement Area The District objects to the location of the applicant’ reservation of right-of-way (ROW) for s the St. Johns River Crossing Corridor. The ROW, as currently located, would bisect an approximately 1,033-acre area that is subject to two conservation easements held by the District. We do not believe such a road through this conservation area is consistent with our property interest. Please evaluate other locations that would eliminate the impacts to this 1,033-acre area (for example, the northeastern corner of the DRI is not encumbered by a conservation easement). We note that the proposed reservation does not conform to any of the Florida Department of Transportation’ published river crossing corridor alignments. s The ROW would require ramps in the town center, to the east of the town center, and to the west of Interstate 95 (see Map H). Please quantify the acreage needed for these ramps. Please explain how these ramps would be incorporated into the town center design. The District is also concerned about environmental impacts that the ROW/ I-95 interchange could have on the property east of the interchange. The area east of the interchange is part of the 21,898-acre Twelve Mile Swamp Conservation Area. The District and the Board of Trustees of the Internal Improvement Trust Fund jointly own that property. • • From page 10-14, please update or supplement the following information: Ed Lehman April 22, 2005 Page 3 of 4 • From page 10-16, please update or supplement the following information, relative to the negotiation referenced on page 10-14: • From page 10-44, please update or supplement the following statements, relative to the negotiation referenced on page 10-14: • On pages 10-45 and 10-46, the application indicates in several locations that SilverLeaf Plantation plans to install residential reuse lines in all areas where the utility service provider can feasibly provide a supply of reclaimed water. Please update or supplement those statements, relative to the negotiation mentioned above, providing specific information such as timing and amounts of reclaimed water projected to be available. From page 10-69, please update or supplement the following information, relative to the negotiation referenced on page 10-14. Please indicate whether the applicant intends to seek to convert the consumptive use permit for agricultural use referenced on page 10-69 to public use: • Question 13 –Wetlands • Exhibit 13-3 shows proposed impacts to wetlands located in conservation easements. Because the District holds conservation easements on wetlands and uplands throughout the DRI project, please also depict proposed impacts to uplands located in conservation easements. The upland areas are important for a number of reasons. For example, many wildlife species that depend on wetlands spend critical portions of their life cycles in uplands, and uplands are necessary for maintaining the ecological value of wetlands. Many of the conservation easements were accepted and valued based on the representation that the conservation easement areas would remain connected to other conservation easement areas. (The conservation easements were conveyed in perpetuity.) Ed Lehman April 22, 2005 Page 4 of 4 Question 17 –Water Supply • This section indicates throughout that JEA and St. Johns County Utilities will provide potable water service; please update or supplement this section, relative to the negotiation mentioned in Question 10. Exhibit 17-3 appears to indicate that if the proposed service area boundary is approved, two providers will still serve the DRI. Please indicate the impact of this development on the applicable supplier’ District-issued s consumptive use permit. We note that the letter from Tim Perkins of JEA in Exhibit 17-2 states “ Initial review . . . indicates . . . projections are in excess of what we would expect . . . .”Please clarify or provide revised projections. Since Mr. Perkins’letter indicates that sufficient reclaimed water capacity is not available, and Mr. Shinkre’ letter in Exhibit 17-1 indicates that reclaimed water will not be immediately available, s measures to limit the amount of turf and irrigated acreage within the development should be discussed. Please indicate the amount of landscaping that will be native vegetation and waterwise. • • • We appreciate the opportunity to comment on the sufficiency of the SilverLeaf Plantation DRI ADA. Please be advised that this letter does not substitute for or constitute permit review. If you or the applicants have any questions, please contact District Policy Analyst Geoffrey Sample at (386) 329-4436/Suncom 860-4436 or gsample@sjrwmd.com. Sincerely, Linda Burnette, Director Office of Communications and Governmental Affairs LB/GCS cc: Scott Clem, St. Johns County John Metcalf, Pappas Metcalf Jenks & Miller Jennifer Auger, FDEP Tara Boonstra, SJRWMD Caroline Silvers, SJRWMD Robin Harrell, SJRWMD Brenda Winningham, DCA Rachael Bennett, England-Thims & Miller, Inc. Rick McCann, FFWCC Robert Christianson, SJRWMD Wally Esser, SJRWMD Melinda Granlund, SJRWMD Jeff Cole, SJRWMD Geoffrey Sample, SJRWMD Florida Department of Transportation Jacksonville Urban Office DISTRICT II 2250 Irene Street Jacksonville, Florida 32204 April 5, 2005 Mr. Edward Lehman Senior Regional Planner Northeast Florida Regional Planning Council 6850 Belfort Oaks Place Jacksonville, Florida 32216 RE: Silverleaf Plantation, DRI Application for Development Approval (ADA) Question 21 - Transportation Dear Mr. Lehman; The Department has reviewed Application for Development Approval of the proposed Silverleaf Plantation Development of Regional Impact (DRI) and has focused on the transportation analysis section of the ADA. The following are the Department’ comments and recommendations for your consideration of this submittal. s I. General Comments & Concerns: 1.) Silverleaf Plantation-Land Uses: The Silverleaf Plantation Development of Regional Impacts is proposed on 7,285 acres in St. Johns County. The site is located between CR 210 to the north and International Golf Parkway to the south. It is also bounded by I-95 to the east and CR 16A to the west. Connections to the site are proposed onto a new road to be built, the North-South Connector (CR 2209) and CR 210 in 2010. In 2015 and 2020 new connections are added to CR 16A. The development proposes the following land uses in Phase-I (2010): 2,110 single family homes, 200 apartments, 990 townhouses, 100,000 square feet commercial, 50,000 square feet office, and 50,000 square feet industrial, producing an estimated 30,969 trips (after internal capture and pass-by is applied). By Phase-II (2015), there will be added 2,230 single family homes, 400 apartments, 870 town homes, 300,000 square feet of commercial, 100,000 square feet of office, and 70,000 square feet of industrial, producing an estimated 32,569 more trips after internal capture and pass-by is applied. The accumulated total build out scheduled for Phase-III (2020) will include 6,800 single family homes, 1,300 apartments, 2,600 town homes, 1,140,000 square feet of commercial, 300,000 square feet of office, and 330,000 square feet of industrial which will produce an estimated total trip output of 91,442 trips (after internal capture and pass-by is applied). 2.) Roadway network: Several State facilities including I-95, I-295, SR 16, US-1, SR 13, and the Shands Bridge will be impacted by this development, as well as, several County roads that connect to these State facilities. It is the impact in traffic increase on the State facilities and how that impact is mitigated that concerns the FDOT. The traffic analysis and the proposed mitigation plan under-estimates the impacts to the State facilities, and the applicant provides very little mitigation funds to address the impacts on the State facilities. State Roads do not create new trips, it is new development that adds trips on the existing State roads, and it is these trips that degrade the State facilities. Assumptions were made in the traffic analysis, discussed here after in the technical section of this letter, that addresses specifically our concerns with the results of traffic analysis. 3.) North-South Connector/CR 2209: Much of the impact produced by this development, according to the ADA, will be on the new North-South Connector to be constructed parallel to I-95. The applicant acknowledges the need for this facility on page 21-18 of the ADA. It states that in Phase-I the applicant will build the North-South connector and, “ This road has been identified as a regional improvement needed to reduce reliance on I-95 for north- south travel and relive congestion on I-95.” Map 21G-1 show, 7 connections, from the Silverleaf development onto the North-South Connector. This road will not attract traffic from the higher speeds and limited access of I-95 until it is connected to the future 9B extension. The Department is concerned that this roadway and the Leo Maguire roadway will act specifically as internal roadways for the development. The realization is that the North South connector will not be used as an Urban Arterial moving traffic north and South to alleviate I-95, but will become a very congested road with numerous driveways with low speed (including school traffic at the AM), and much delay as we consider all the developments planned to encroach on the road. Moreover, the 7.36 miles section of the North-South connector is part of the Silverleaf development network and will be constructed (see Table 21-23 of the ADA) as a 4 lane Rural section with a number of driveways. For mitigation, the County should only credit the applicant for half of the road since it is basically becoming a local road/internal road serving primarily the Silverleaf project. 4. Schedule of improvements shared with other developments: FDOT also has concerns over the timing of this development and other recently approved and pending developments in the area (i.e. Ashford Mills, Twin Creeks, Rivertown etc). Please review Exhibit-1 (attached at the end of our comments) which shows all committed improvements by other developers within the time frame of this Silverleaf project. Notice that much of the work committed for many roads are all planned within the next five years (2005-2010). In other words, should any one developer changes its plans the dependency on the capacity promised may alter sincerely the analysis and the impacts. The Silverleaf development proposes to build a large amount of development by 2010 as do Twin Creeks and Ashford Mills. The concern is that without all the assumed/proposed/employment included in these developments, without all the roadway improvements to be built by these developments, the impact of this development will be drastically different than the applicant’ analysis shows. If any one of the approved DRIs cannot complete its road s improvements or provide the jobs as planned, the proposed analysis with its conclusion will result in a totally different picture. With the history of land use and developer timelines changed via the NOPC process, it is our concern that all the assumptions will not be fulfilled, leading to state roads that will be gridlocked by large tracts of housing with none of the promised employment in place 5.) Employment assumptions: Another assumption made in this process is that with all of the employment promised for St. Johns County will be filled by the population that resides in St. Johns County. As stated above, the concern is that without all the assumed employment in the northwest sector of the County from all the approved developments and from the proposed Silverleaf DRI, all the population moving in this area will continue to go to Jacksonville. The assumption made in this application, is that all the employment promised for St. Johns County will be fulfilled by the population that resides in St. Johns County. Nationwide average commute times do not agree with this assumption. The affordability of these homes may not coincide with the employment opportunities that are attracted to St. Johns County. Moreover, Table 11.2.1 shows a total of 790 full time jobs by 2020 in this project, and a total of 3,319 part time and full time jobs. This is not reflective of a large employment base which will keep the population within the County and reduce commute time. 6.) River Crossing: Earlier in this process, when we received the Pre-Application package, the applicant has proposed to reserve R-O-W for the proposed River Crossing corridor. In addition, Map-H of the ADA specifically illustrates an East/West R-O-W Reservation corridor which seems to connect to I-95 to the east via the conservation area with a possible interchange, and, to the west the corridor connects to CR 16A and to CR 210. However, the applicant did not address any further the R-O-W reservation for the River Crossing. As you know the Department is currently studying the future possible alignments to the River Crossing. The Department is studying all possible alternatives because it is evident that there is a strong need for an additional bridge between the Shands and the Buckman Bridge. The FDOT’ long term goal is to provide for a future regional network of roads and bridges that s support growth and yet provides traffic relief in the County’ northwest sector. It should be noted that the current s PD&E study will be completed by the end of 2006 and will only then have established the proposed alignment for the new River Crossing. The Department appreciates the applicant’ suggesting some solutions and making future plans to address the River s Crossing. Yet, since no commitment has been made in the ADA, in the text or in mitigation tables, the department would like clarification. The reservation of the proposed corridor or any of the land associated with an alignment of the River Crossing found within the Silverleaf development is important. This is not only important to the department, but it is crucial to the over all traffic flows since so many developments were approved and/or are pending, will certainly need this corridor in the near future. Moreover, many residents of St. Johns County will 2 continue to travel to the large employment centers in Duval County. Therefore, consideration for reserving the corridor as the FDOT’ study gets completed is very important. The R-O-W reservation should be for 10 years or at s least for the first Phase (by 2010). Since a small portion of the Silverleaf development will be constructed in the first phase, (900 residential units will be constructed and 60,000 sq. ft of retail), this proposal seem reasonable and fair. The Department requests some consideration regarding the R-O-W needs and reservation of lands within the Silverleaf project in order to protect the corridor for the River Crossing future needs. II. Technical Comments 1.) Area of Influence: Maps J-11 thru J-13 show Significant impacts > 5%. This maps show links that have not been covered in the ADA traffic analysis. The pre-application meeting comments (included in the ADA in the regular appendices section titled ‘ Pre-Application Summary’ it was agreed to by the applicant that maps would be ) provided that shows specifically by link where the 5% impact ends. Maps J-11 thru J-13 does not meet this criterion. Please revise these maps to show 5% break by link number. The applicant needs to explain how the area of influence was determined south of International Golf Parkway. The JUATS model used by applicant ends just south of International Golf Parkway. In addition, the applicant should define the process by which impacts were assessed for links outside of model area. 2.) Trip Generation, Internal Capture and Pass-by: The trip generation for the stated land contained in Tables in the ADA is consistent with the ITE Trip Generation, 7th Edition. Thus, the development is estimated to generate a total of 30,968 daily trips in Phase I (2010), 63,538 daily trips in Phase II (2015) and 91,442 trips in Phase III (2020). The project is estimated to generate at the PM peak 2,613 total external trips in Phase I, the PM peak in 2015 is shown to be 5,353 total external trips, and the PM peak in 2020 is shown to be 8,672 after internal capture and pass-by are removed in all three Phases. The analysis doesn’ show the Internal Capture and/or the pass by trips t in any of the tables. Revise Tables to show the trips which were allocated to internal capture and pass by. 3.) Traffic Factors, K& D: Question 21-A of the ADA asks the applicant to state the K’ and D’ used to perform s s the traffic analysis. They are not mentioned in the answer to question 21-A, but the K’ were located in tables 21-10 s through 21-12. However the D’ and how they were applied to the links is not documented in the ADA. The D’ s s and how they were applied to roadway links should be documented in the ADA as asked for in question 21-A and provided in Tables 21-10 through 21-12. Provide table that shows the traffic with all traffic factors K’ and D’ s s. 4.) Background (Existing + Projected) Traffic: The applicant states that 2010, 2015, and 2020 Background Traffic for the study area was developed using two methodologies: (1) using historical growth trends and (2) model projected volumes. The applicant states that the selection from the two methods was based on using the more conservative (i.e. higher volume). The requests clarification and revision to the applicant’ applied background s traffic based on the following: (a). Phase-I (2010) background traffic: At the peak hour, approved concurrency traffic has not been directly incorporated in any of the materials provided in the ADA. Although the model is stated to incorporate socioeconomic data for approved developments in the region, it is inappropriate to assume that the model will reliably project volumes at the peak hour incorporating future developments as the model tends to underestimate trips from new developments. Table 1 (below) illustrates the differences between the total committed peak hour trips recognized by St. John’ County compared to the 2010 background s peak hour traffic developed by the applicant. As Table 1 (above) shows, the applicant’ traffic is considerably high in some instances and lowers in s others when compared to the committed peak hour trips. This suggests the unreliability of the applicant’ s model and inappropriateness of using the model to determine future peak hour trips when there are committed future trips related to already approve developments. Based on the large range in differences observed, the use of an inappropriate methodology could have significant effects on analysis results and in determining the impacted facilities and the roadway improvements needed to mitigate the impacts. Applicant should revise the background traffic to reflect appropriate peak hour trips for Phase-1 to correct the discrepancies shown in Table-1. 3 Table 1: Background Traffic: Applicant 2010 Peak Hour Traffic and St. John’ County Committed Peak Hour Traffic s 2010 Applicant Background Traffic 1,093 1,599 500 2,145 1,173 1,146 1,401 1,143 1,143 1,775 2,250 2,425 2,076 3,321 4,900 5,652 4,233 7,074 7,889 9,489 562 2,009 1,210 176 321 1,166 1,479 1,479 2,333 2,562 3,484 4,231 4,299 3,929 3,091 5,021 2,990 774 402 640 2,596 3,283 2,443 4,624 Link ID 81 82 83 89 90.1 90.2 91.1 91.2 92.1 92.2 93.1 93.2 124 125.1 125.2 126 130 131 132 133 17 21.3 23.1 23.2.1 24 33 34.1.1 34.1.2 34.2 34.3 35.1 35.2 36.1 36.2.1 36.2.2 37.1 37.2 64 65 69 73.1.1 73.1.2 73.2 73.3 Roadway SR 13/SR 16 SR 13 SR 13 SR 16 SR 16 SR 16 SR 16 SR 16 SR 16 SR 16 SR 16 SR 16 SR 5 (US 1) SR 5 (US 1) SR 5 (US 1) SR 5 (US 1) SR 9 (I-95) SR 9 (I-95) SR 9 (I-95) SR 9 (I-95) CR 13 CR 13A CR 16A CR 16A CR 16A CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 (Palm Valley Rd) CR 210 (Palm Valley Rd) Greenbriar Rd. Greenbriar Rd. Leo Maguire Parkway International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. SJC Committed Trips 1,170 1,091 586 1,446 1,106 1,106 1,732 1,779 1,977 4,268 4,914 5,016 4,297 3,548 3,546 4,104 5,134 7,397 8,086 9,277 224 2,075 745 284 476 1,138 2,235 2,235 3,395 4,066 5,066 5,066 3,260 2,007 2,007 1,793 1,793 660 962 1,059 2,838 2,838 3,094 3,094 Difference (77) 508 (86) 699 67 40 (331) (636) (834) (2,493) (2,664) (2,591) (2,221) (227) 1,354 1,548 (901) (323) (197) 212 338 (66) 465 (108) (155) 28 (756) (756) (1,062) (1,504) (1,582) (835) 1,039 1,922 1,084 3,228 1,197 114 (560) (419) (242) 445 (651) 1,530 4 Table 1: Background Traffic: Applicant 2010 Peak Hour Traffic and St. John’ County Committed Peak Hour Traffic (Continued) s 2010 SJC Applicant Background Committed Trips Difference Traffic Link ID Roadway 74.1 International Golf Pkwy. 2,111 1,901 210 74.2.1 International Golf Pkwy. 1,456 1,675 (219) 74.2.2 International Golf Pkwy. 1,456 1,675 (219) 76 Race Track Rd. 2,432 3,136 (704) 77 Race Track Rd. 1,631 1,251 380 78.1.1 Race Track Rd. 2,347 2,018 329 78.1.2 Race Track Rd. 2,195 2,018 177 78.2 Race Track Rd. 2,914 2,163 751 79 Roberts Rd. 1,416 2,005 (589) 80.1 Russell Sampson Rd. 830 418 412 80.2 Russell Sampson Rd. 1,380 418 962 (b). Phase-I, II and III (2010, 2015, 2020) background traffic The department is concerned that the background traffic is projected to decrease on several links in the future years , in phases II and III (2015, 2020) , as shown in Table 2 (below). The applicant should revise its Tables with the background traffic for all three phases of the development and/or documentation should be provided to justify the decreases as shown hereafter in Table-2. Table 2: Decreasing Background Traffic on Links Link ID 81 90.1 91.1 125.2 126 21.3 23.2.1 23.2.2 Roadway SR 13/SR 16 SR 16 SR 16 SR 5 (US 1) SR 5 (US 1) CR 13A CR 16A CR 16A 2010 Background Peak 1093 1173 1401 4900 5652 2009 176 N/A 2015 Background Peak 1414 1496 1926 3191 4682 2353 575 1166 2020 Background Peak 1268 1388 1544 3700 5345 2244 535 1131 2015>2010? 2020>2015? No No No No No No No No 24 33 34.3 35.1 35.2 36.1 36.2.1 36.2.2 37.1 64 65 CR 16A CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 (Palm Valley Rd) Greenbriar Rd. Greenbriar Rd. 321 1166 2562 3484 4231 4299 3929 3091 5021 774 402 587 1005 2925 3982 4888 5181 4855 4794 4104 1028 593 522 1231 2018 3144 3474 4616 4195 4131 4166 923 576 No No No No No No No No No No No 5 Table 2: Decreasing Background Traffic on Links (Continued) Link ID 73.1.1 73.1.2 73.2 73.3 74.2.1 74.2.2 76 78.1.2 78.2 80.2 Roadway International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. Race Track Rd. Race Track Rd. Race Track Rd. Russell Sampson Rd. 2010 Background Peak 2596 3283 2443 4624 1456 1456 2432 2195 2914 1380 2015 Background Peak 2803 3643 3007 5874 1922 1922 1946 3021 3774 1322 2020 Background Peak 2464 3204 2990 5830 1697 1697 3706 2195 2394 995 2015>2010? 2020>2015? No No No No No No No No No No No 5.) Model, Distribution, and Assignment: The applicant has utilized the JUATS model to establish the trip distribution. The JUATS model used by applicant ends just south of International Golf Parkway. No explanation was provided to define the process by which impacts were assessed for links outside of model area. The applicant should clarify the following issues regarding the distribution: a) Percent distribution: • The applicants distribution Maps J-5 through J-7 show that in Phase-1 (2010) only 22 percent of project traffic go north of the St. Johns/Duval County line, and only 5 percent proceed south of IGP. All other traffic stays in the general area of the DRI. This trend does not seem reasonable and continues to get worse in 2015 and 2020. • In Phase-II (2015) only 11 percent cross the county line to the north, and only 3 percent proceed south of IGP. In 2020 only 14-18 percent go north, with 3 percent heading south of IGP. Many work trips from this development go to Ashford Mills, St. Johns, World Commence Center, Twin Creeks, Nocatee, and Bartram Park developments, while the work trips from those developments go to the Silverleaf development. The amount of job related development that has been approved in St. Johns County, and is proposed to be in place in 2010, 2015, and 2020, is unreasonable. Without this employment to attract all these trips, a totally different distribution will occur, with the majority of trips heading north. b) Timing: • The timing of the employment used to dampen the impacts of this development is also unreasonable. Twin Creeks is proposed to be built out by 2010. The timing of roadways attributed to these developments is also critical. The applicant’ model shows a heavy reliance on the North-South Connector, the Nocatee s Expressway, and 9B. c) Employment: • While travel demand modeling is an acceptable tool, its use can be limited in certain situations. The model sees the attractiveness of the nearby employment in time savings over a TAZ located in downtown Jacksonville. Even if all of the proposed development and employment were to occur, it is unreasonable to believe that 70 to 80 percent of the people that will live in the Silverleaf development will work with 5 miles of their home. • The addition of more attractions, whether justified or not, in St. Johns county only, thereby pumping up the socioeconomic data higher that currently acceptable, while straight line growth is applied to the rest of the model, will lead to trips staying in St. Johns County. Note the fact that the market justification for this development and others in St. Johns County is it’ proximity to the major urban area of Jacksonville. s • Table 11.2.1 of the ADA shows by 2010, 94 full time jobs with 6,492 population, by 2015, 314 full time jobs with 13,378 population, And by 2020 a total of 790 full time jobs with 21,051 full time residents in Silverleaf; the total jobs, part time and full time at 3,319. In conclusion the total employment proposed • • 6 • reflects only 13.6 percent of the population of Silverleaf in 2020 (24,319). With these projections, it appears that the trip distribution suggested in the analysis seems unreasonable. The applicant should provide justification and revise the trip distribution as it relates to the employment trips. The applicant’ s distribution Maps J-5 and J-7 should be revised to reflect a reasonable distribution. d). Connections: • Distribution Map J-5 for 2010 Phase-I shows a connection from TAZ 911 to CR 16A with 48.86% external project traffic associated with it. However in the 2010 model provided and the model plot in the Transportation Appendix, no connection to CR-16A is provided. Map J8, PM peak Hour Roadway Conditions 2010, also shows this connection with 1,277 peak trips in both directions with a level of service B. This connection on Map J4 is not proposed until Phase- II, 2015. • Distribution Map J-5 for 2010 Phase 1 shows Leo Maguire Parkway connected to 16A with 25.87% external project traffic associated with it. However in the 2010 model provided and the model plot in the Transportation Appendix, no connection for Leo Maguire Parkway to CR 16A is provided. Map J-8, PM peak Hour Roadway Conditions 2010, also shows this connection with 1,424 peak trips total with a level of service C. • No connections from the proposed Silverleaf development to CR 16A are proposed for Phase -I, 2010. Model plot shows no connections. However many maps not only show connection, but attribute traffic and LOS to these connections. • In the Phase-III, 2020 model and the Phase III, 2020 model plot from the Transportation Appendix shows that the TAZ 911 not loading on the centroid connector that connects it to CR 16A. This connector is the longer of the three connected to TAZ 911. The centroid connector to CR 16A should be shortened and the distribution ran again. e). Socioeconomic data and Zdata inconsistencies: • Discrepancies in the socioeconomic data for the development as represented in the travel demand model were found. The zdata2 files which load the employment in each TAZ were incorrect for the TAZs representing the Silverleaf development. According to the employment conversion shown in the ADA on page 6 of Appendix 21-G, the employment has been calculated in the following manner: 1.24 employees per 1,000 square feet of industrial. 2.5 employees per 1,000 square feet of retail commercial. 2.39 employees per 1,000 square feet of office (service) According to the amount of development listed on page 21-2 of the ADA, the following errors were found in the modeling zdata files: 2010 has 130 extra employees attributed to the Silverleaf development 2015 has 500 extra employees attributed to the Silverleaf development 2020 has 625 extra employees attributed to the Silverleaf development. • Other zdata inconsistencies were found with the 2020 model which include the addition of 2400 enrollment attributed to the Twin Creeks DRI (applicants TAZ 887 and 888). The applicant shows 700 school enrolment (Table 21G-10) and St. Johns County lists none. TAZ 864 in zdata 2 shows total employment of 6377. The employment adds up as follow; 2562+538+442=3506 (not 6377). Correct the zdata files and rerun the distribution for 2020. The applicant lists network and TAZ zone editing that were performed on the model. The applicant provides no documentation that after all of these ‘ corrections’the model was calibrated and validated for use as a reliable travel demand model. Applicant has corrected some data presented as “ omissions and errors from the base JAUTS” but no documentation of the validation of the base year model has been , presented. Application of future model volumes with no validation of the corrected base model is not accepted practice. No statistics from running RMSE (Root Mean Square Error) or HEVAL (Highway Evaluation) have been included in this submittal. The applicant should provide documentation of a validated base year model and revise the model runs and the distribution and assignment to correct all the above mentioned discrepancies. • 7 6. ) Results of the Trip Distribution in all three Phases: There are additional concerns with the end result of the applicant’ distribution process. We have noticed discrepancies that show on a handful of links the PM peak hour s project trips decrease slightly from Phase-I in 2010 to Phase-II in 2015, and from Phase- II to Phase-III in 2020, which is extremely unrealistic. The following Table-3 illustrates these decreasing PM peak traffic as Phases progress to the future. The applicant should provide an explanation and revise the Peak hour distribution to correct the inconsistencies (see Table 3 below). Table 3: Decreasing Project Traffic on Links Link ID 83 91.2 125.1 125.2 126 132 133 34.1.1 34.1.2 34.2 34.3 35.1 35.2 64 65 69 76 77 78.2 80.1 80.2 Roadway SR 13 SR 16 SR 5 (US 1) SR 5 (US 1) SR 5 (US 1) SR 9 (I-95) SR 9 (I-95) CR 210 CR 210 CR 210 CR 210 CR 210 CR 210 Greenbriar Rd. Greenbriar Rd. Leo Maguire Parkway Race Track Rd. Race Track Rd. Race Track Rd. Russell Sampson Rd. Russell Sampson Rd. 2010 Project Peak 1 0 52 152 50 183 573 47 72 168 92 783 758 21 27 772 53 70 41 0 223 2015 Project Peak 38 331 38 63 154 182 765 27 10 153 685 1300 1263 14 26 729 113 139 6 0 348 2020 Project Peak 36 278 80 18 53 2 307 100 3 183 623 1146 1100 27 88 671 94 131 1 0 163 No No No No No No No No No 2015>2010? 2020>2015? No No No No No No No No No No No No No No No No No No 7.) Link Analysis, LOS and MSV: The 2004, 2010, and 2020 Roadway link analyses were re-conducted to determine level of service (LOS) and whether any of the links in the study area would be significant (defined as when project traffic from the proposed development was determined to be 5% or greater of the MSV) or adverse (defined as when the MSV is breached). This new analysis was based on several assumptions regarding the MSV used including the reversion of State roads referencing MSV based on ‘ studies’to use MSV dictated by the 2002 FDOT LOS Handbook. The pre-application meeting comments (included in the ADA in the regular appendices section titled ‘ Pre-Application Summary’ state that “ analysis of future operating conditions will use FDOT’ ) the s volumes from the LOS Generalized Tables for State Roads.” All MSVs on State roadways should use FDOT volumes. In addition, the analysis deviates from the applicant’ submittal by correcting MSV based on the phasing s of capacity improvements. Examples of these changes are documented in Table 4 (below). It should be noted that the analysis process used the applicant’ background and project traffic, over which concerns s have been raised before and are documented in the previous sections (see comments #5 and #6). The changes in significance and adversity on the links are bolded in Table 5 (below). The applicant should revise its analysis to reflect the correct MSV and LOS for State facilities as agreed upon in the Transportation Methodology. In addition, the revised tables should identify the LOS for each facility in a separated column to allow us to see which facilities are failing. 8 Table 4: Revised MSV Assumptions Link ID Roadway Year(s) 2010, 2015, 2020 2010, 2015, 2020 2010, 2015, 2020 2010, 2015, 2020 Applicant MSV 4,160 Revised MSV 3,290 Justification MSV should reference FDOT LOS Handbook Table 4-5 MSV should reference FDOT LOS Handbook Table 4-5 MSV should reference FDOT LOS Handbook Table 4-5 There is no change in capacity from existing conditions so the MSV should not change. MSV should not decrease from years 2015 to 2020. Changes in MSV do not take place until 2015 per ADA Table 21-19 92.2 SR 16 93.1 SR 16 4,790 3,290 93.2 SR 16 4,910 3,290 133 SR 9 (I-95) 10,180 9,640 35.2 CR 210 2020 5,280 6,290 36.2.1 CR 210 2010 4,930 1,940 36.2.2 CR 210 2010 4,930 1,940 Changes in MSV do not take place until 2015 per ADA Table 21-19 37.1 CR 210 (Palm Valley Rd) 2010 3,290 2,050 Changes in MSV do not take place until 2015 per ADA Table 21-19 37.2 CR 210 (Palm Valley Rd) 2010 3,290 2,050 Changes in MSV do not take place until 2015 per ADA Table 21-19 73.3 International Golf Pkwy. 2010 8,130 5,420 Changes in MSV do not take place until 2015 per ADA Table 21-20 Table 5: Changes in Link Adversity and Significance With Revised MSV Revised Analysis Total PM Traffic Significant and Adverse? Applicant Analysis Significant and Adverse? Link ID Roadway Revised MSV Adverse? 5% Significance? 2010 Analysis Adverse? 5% Significance? 133 36.2.1 36.2.2 37.1 37.2 SR 9 (I-95) CR 210 CR 210 CR 210 (Palm Valley Rd) CR 210 (Palm Valley Rd) 10,062 4,270 3,295 5,123 3,052 9,640 1,940 1,940 2,050 2,050 Yes Yes Yes Yes Yes Yes Yes Yes Yes No 2020 Analysis Yes No Yes Yes No No No No Yes No No Yes No No No No No No No No 93.1 93.2 SR 16 SR 16 3,015 3,236 3,290 3,290 No No Yes Yes No No No No No No No No 9 8.) Intersections: The two stated methods (using model turns or trends analysis) are based on the same methods for developing the background traffic links. However there are several inconsistencies between the background and project volumes projected for the links and the corresponding approach volumes on those links shown for the turning movements. Realizing that some traffic drops between intersections, a percent difference of less than 10% would be reasonable. a) As shown in Table 6 (below), several links have total traffic differences of well beyond 10% from their respective intersection approach volumes. Even with turning patterns changing with development, the applicant’ s future turns don’ have a consistent association with existing turns. To resolve these inconsistencies, a more t appropriate method would be to coordinate existing turns with model turns to determine turn percentages to apply to the approach link volumes. Table 6: Intersection to Link Total Traffic Inconsistencies Intersection ID 9 9 10 10 10 10 11 13 13 14 14 14 14 14 14 4 4 4 4 4 5 5 5 5 5 5 6 15 18 Intersection Description SR 13/CR 13 and SR 16 SR 13/CR 13 and SR 16 SR 16 and CR 16a SR 16 and CR 16a SR 16 and CR 16a SR 16 and CR 16a SR 16 and IGP/CR 13a (Pacetti Road) IGP and I-95 Northbound Ramps IGP and I-95 Northbound Ramps US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP CR 210/CR 223 Road CR 210/CR 223 Road CR 210/CR 223 Road CR 210/CR 223 Road CR 210/CR 223 Road and Greenbriar Approach Link # 90.1 90.1 90.2 90.2 90.2 24 91.2 74.1 74.1 74.2.2 74.2.2 74.2.2 125.1 125.1 125.1 65 Approach Roadway SR 16 SR 16 SR 16 SR 16 SR 16 CR 16A SR 16 International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. SR 5 (US 1) SR 5 (US 1) SR 5 (US 1) Greenbriar Rd. Greenbriar Rd. Greenbriar Rd. CR 210 CR 210 Greenbriar Rd. Greenbriar Rd. Greenbriar Rd. Greenbriar Rd. Greenbriar Rd. Greenbriar Rd. CR 16A CR 210 CR 210 Year 2010 2015 2010 2015 2020 2010 2010 2010 2015 2010 2015 2020 2010 2015 2020 2010 2015 2020 2015 2020 2010 2015 2020 2010 2015 2020 2010 2010 2015 Turning Movement Volume 1,347 1,801 1,368 2,384 2,981 271 802 3,461 2,159 1,227 1,242 1,262 2,085 2,641 2,797 1,146 1,495 1,905 1,279 1,803 219 231 259 963 1,216 1,531 53 2,921 2,743 Link Volume 1216 1634 1189 2105 2652 324 1143 2249 3224 1520 2027 1843 3373 3709 3991 429 619 664 1045 1351 795 1042 950 429 619 664 176 2654 3610 Difference 131 167 179 279 329 -53 -341 1,212 -1,065 -293 -785 -581 -1,288 -1,068 -1,194 717 876 1,241 234 452 -576 -811 -691 534 597 867 -123 267 -867 % Difference 10.77% 10.22% 15.05% 13.25% 12.41% -16.36% -29.83% 53.89% -33.03% -19.28% -38.73% -31.52% -38.19% -28.79% -29.92% 167.13% 141.52% 186.90% 22.39% 33.46% -72.45% -77.83% -72.74% 124.48% 96.45% 130.57% -69.89% 10.06% -24.02% and Greenbriar 65 and Greenbriar 65 and Greenbriar 33 and Greenbriar 33 64 64 64 65 65 65 23.2.1 34.3 34.3 Greenbriar Road and CR 244 Greenbriar Road and CR 244 Greenbriar Road and CR 244 Greenbriar Road and CR 244 Greenbriar Road and CR 244 Greenbriar Road and CR 244 CR 16a and CR 210 CR 210 and Leo Maguire Parkway CR 210 and CR 2209 (N-S Corridor) 10 b.) Table 7 (below) illustrates the inconsistencies in turning movement generation. The methodology used by the applicant for the turning movement generation has also resulted in several intersection approaches experiencing decreases in project traffic between the phasing years. This is documented in Table 7(below). The applicant should provide explanation and revise the analysis rectify the inconsistencies and provide documentation to justify any of these decreases. Table 7: Intersection to Link Total Traffic Inconsistencies Intersection ID 12 12 13 14 14 14 14 14 14 1 1 1 4 4 6 6 6 Intersection Description IGP and I-95 Southbound Ramps IGP and I-95 Southbound Ramps IGP and I-95 Northbound Ramps US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP US 1 and IGP Race Track Road and CR 2209 Race Track Road and CR 2209 Race Track Road and CR 2209 CR 210/CR 223 and Greenbriar Road CR 210/CR 223 and Greenbriar Road CR 16a and CR 210 CR 16a and CR 210 CR 16a and CR 210 Approach Link # 73.3 73.3 74.1 74.2.2 74.2.2 74.2.2 125.1 125.1 125.1 77 77 78.1.1 33 33 33 23.2.1 23.2.1 Approach Roadway International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. International Golf Pkwy. SR 5 (US 1) SR 5 (US 1) SR 5 (US 1) Race Track Rd. Race Track Rd. Race Track Rd. CR 210 CR 210 CR 210 CR 16A CR 16A Year 2010 2020 2015 2010 2015 2020 2010 2015 2020 2015 2020 2020 2015 2020 2020 2015 2020 Turning Movement Volume 566 867 163 36 51 71 12 8 14 111 117 40 0 4 78 111 184 Link Volume 457 767 279 64 105 146 52 38 80 139 131 294 40 120 120 137 263 Difference 109 100 -116 -28 -54 -75 -40 -30 -66 -28 -14 -254 -40 -116 -42 -26 -79 % Difference 23.85% 13.04% -41.58% -43.75% -51.43% -51.37% -76.92% -78.95% -82.50% -20.14% -10.69% -86.39% -100.00% -96.67% -35.00% -18.98% -30.04% c.) Tables 8 and 9 (below) illustrate the inconsistencies, which show the applicant’ decreasing turning movement from phase to s phase. Many of the individual movements at the intersections have decreasing total and project traffic in the future years as shown in Tables 8 and 9. Applicant should revise its turning movement analysis at the specified intersections to provide the correct movements and document the findings. Table 8: Decreasing Turning Movement Total Traffic Volumes (1) Intersection ID Location Description Movement EBT EBR 2010 Volume 1502 215 2028 1669 535 1766 2212 653 3 3 336 573 106 180 2015 Volume 1994 218 2707 1714 613 2121 3034 605 24 30 404 671 195 330 2020 Volume 1508 196 2214 994 352 1901 2660 609 14 17 399 630 177 297 2015 > 2010? 2020 > 2015? No No No No No No No 2 CR 210 and I-95 Southbound Ramps WBT SBR EBL EBT 3 7 CR 210 and I-95 Northbound Ramps SR 13 and CR 16a WBT WBR WBR SBL EBR NBL NBT No No No No No No No 8 SR 13 and SR 16 SBT 11 Intersection ID 9 Table 8: Decreasing Turning Movement Total Traffic Volumes (Continued) 2010 2015 2020 (1) Location Description Movement Volume Volume Volume WBR SR 13/CR 13 and SR 16 SBL EBR WBR NBL NBT SBL 606 355 441 0 898 154 0 88 116 216 570 1141 891 1878 1915 1246 258 266 233 166 283 740 223 535 10 105 129 308 20 30 946 787 41 61 164 933 200 108 1140 191 77 233 201 n/p n/p 482 300 267 310 337 937 269 520 10 156 190 234 250 342 742 1142 33 50 151 911 216 804 1113 133 613 162 185 837 506 483 21 1027 368 30 196 402 524 526 1119 1116 2044 762 480 371 19 789 315 25 168 346 464 472 1003 940 1827 1496 1219 422 247 226 271 303 1423 243 313 8 93 114 289 247 323 914 835 23 34 566 539 215 682 659 87 530 106 691 2015 > 2010? 2020 > 2015? No No No No No No No No No No 10 SR 16 and CR 16a SBT EBT WBT NBT SBT No No No No No No No No No No No No No No 11 12 13 SR 16 and IGP IGP and I-95 Southbound Ramps IGP and I-95 Northbound Ramps SBR SBR EBT EBR EBL EBR NBL 14 US 1 and IGP SBR EBR WBL NBL NBR EBL WBR SBL EBL EBT WBT 1 Racetrack Road and CR 2209 No No No No No No 4 CR 210 and Greenbriar Road No No No No No No No No No No No No No No No No No No No No No No 6 CR 16a and CR 210 SBR EBT EBR NBL EBL EBT EBR WBL WBT WBR NBR SBL 15 CR 210 and Leo Maguire Parkway 18 CR 210 and CR 2209 SBR (1) For intersections realigned in future years, the movements refer to the intersection alignment in the 2010 condition. n/p = Not provided. 12 Table 9: Decreasing Turning Movement Project Traffic Volumes 2010 Volume 287 241 148 0 1 26 0 16 0 0 0 46 28 113 69 4 3 3 98 60 17 7 12 13 8 11 7 n/p 2 1 3 139 98 15 0 0 9 6 0 0 2015 Volume 523 342 242 11 13 0 19 0 27 194 137 0 0 106 2020 Volume 468 176 131 10 12 0 17 0 23 160 119 0 0 0 0 6 4 2 23 17 51 2 2 15 11 0 0 No No No No No No No No No No No No No No No No No No No No No 2015 > 2010? 2020 > 2015? No No No No No No No No No No No No No No No No Intersection ID 2 Location Description CR 210 and I-95 Soutbound Ramps CR 210 and I-95 Northbound Ramps SR 13 and CR 16a SR 13 and SR 16 Movement EBT SBR EBL SBL SBT EBR WBR NBL (1) 3 7 8 10 SR 16 and CR 16a SBL EBT WBT NBT 11 12 13 SR 16 and IGP IGP and I-95 Southbound Ramps IGP and I-95 Northbound Ramps SBT SBR EBT EBR NBT SBT 14 1 US 1 and IGP Racetrack Road and CR 2209 SBR WBL NBR EBT WBL NBR EBT WBT EBL 4 5 CR 210 and Greenbriar Road Greenbriar Road and CR 244 6 CR 16a and CR 210 SBR (1) For intersections realigned in future years, the movements refer to the intersection alignment in the 2010 condition. n/p = Not provided. 9.) Intersection LOS Analysis: We conducted intersection analysis using the applicant’ traffic. In this s analysis, there were several locations where we noticed Level Of Service (LOS) failure not previously identified by the applicant. Many of these intersections with the LOS failures occur along state roadways such as US 1, SR 13, and SR 16, as shown in the following Table 10 (below). Please note, that necessary roadway improvements identified by the applicant were incorporated into the analysis as applicable. Thus the applicant should revise its intersection analysis to incorporate all the failing intersections along US 1, SR 13, and 16. In addition, there are LOS failures in 2010 and 2015 at the CR 210/I-95 interchange not identified by the applicant. A review of the applicant’ Synchro 6 files identified two inaccuracies that may have resulted in the differing LOS s results: • The eastbound to southbound on-ramp was not included in the intersection analysis, presumably because it is fed by a free-flow eastbound right turn lane. However, this ramp access point from CR 210 should be included as traffic making the right turn will still need to slow down even to make the free-flow turn, thus affecting the CR 210 approach. • In addition, the southbound off-ramp approach to CR 210 does not include the proposed shared leftturn/right-turn lane. The inclusion of the proposed lane configuration affects the optimal signal-timing at the intersection 13 It should also be noted that the improvement in LOS (LOS F in 2015, LOS C in 2020) at the southbound ramps intersection at CR 210 is due mainly to a large decrease in traffic making the southbound right turn movement at the intersection. This decrease in traffic, previously identified in Table 8, is too large and unreasonable (1,714 vehicles in 2015 and only 994 vehicles in 2020), it underscores the importance of having reasonable traffic volumes to analyze. The analysis should be revised to rectify the volumes used at the southbound ramp intersection at CR 210. 10.) Interchange at CR 210 at I-95: The Department is concerned with the I-95/CR 210 interchange and the necessary improvements identified by the applicant to achieve acceptable level of service. The proposed improvements will require an Interchange Modification Report (IMR) which should be based on traffic forecasts currently being developed by FDOT. As a result, it is inappropriate to comment on level of service at the ramp junctions with the I-95 mainline. There are other parties currently involved in identifying the necessary improvements to the interchange, mainly the County and the Twin Creek Developer. More importantly, the decision lies in the hands of the Federal Highway Administration (FHWA). The FHWA doesn’ permit any degradation of t the LOS on the main line. With an IMR and/or an IJR there are still issues to be resolved. It is our understanding that there are no plans to add any capacity on I-95, and therefore, with all the additional traffic contemplated for the interchange within the near future, it will be very difficult to find solutions for this interchange. Finally, the applicant’ proposed improvements are planned to be in place by 2010, a time frame that seems very ambitious s (when considering the need for approval from FHWA, the need for the IMR and construction time). Applicant should revise its analysis to address all the failing movements shown in Table-10 hereafter. Table 10: Intersection Analysis LOS Comparison Applicant LOS Intersection ID 2 3 7 Location Description CR 210 & I-95 Southbound Ramp CR 210 & I-95 Northbound Ramp SR 16 & CR 16a Intersection A Intersection B 8 9 10 11 12 13 14 15 16 17 SR 13 & SR 16 SR 13/CR 13 & SR 16 SR 16 & CR 16a SR 16 & IGP/CR 13a IGP & I-95 Southbound Ramp IGP & I-95 Northbound Ramp US 1 & IGP CR 210 & Leo Maguire Parkway US 17 & SR 16 East US 17 & SR 16 West Intersection C 2010 B C F N/P A C F B B C B D C F F C C C C C C D C C F C C D D D D D B D D 2015 B D D 2020 B C D 2010 E C F C B F F A E C B E E F F F F D F C C E F F F F F D F D D E F F F FDOT LOS 2015 F D F 2020 C C E Note: For unsignalized intersections, the LOS shown refers to the stopped movements. Note: Necessary roadway improvements identified by the applicant were incorporated into the analysis as applicable. n/a = not applicable n/p = not provided 14 Table 10: Intersection Analysis LOS Comparison (Continued) Applicant LOS 2015 2020 C D C C D C B D D D C B B C C D D C F C C D D D C C C C FDOT LOS 2015 2020 B E F F D C B F E F D B B B F E F D E F B E D F B C C C Intersection ID 24 25 26 1 4 5 6 18 19 20 21 22 23 27 Location Description CR 2209 & SR 16 CR 2209 & IGP SR 16 & CR 2209 Racetrack Road & CR 2209 CR 210/CR 223 & Greenbriar Road Greenbriar Road & CR 244 CR 16a & CR 210 CR 210 & CR 2209 CR 244/Russell Sampson Road & CR 2209 CR 2209 & Leo Maguire Parkway Extension CR 16a & Leo Maguire Parkway Extension CR 2209 & CR 16a CR 2209 & Silverleaf Plantation Town Center CR 16a & Dam Road 2010 C D C C C C E C D C n/a B n/a C 2010 B E B F C B E C E C n/a C n/a B Note: For unsignalized intersections, the LOS shown refers to the stopped movements. Note: Necessary roadway improvements identified by the applicant were incorporated into the analysis as applicable. n/a = not applicable n/p = not provided 11.)Cost Estimates (Proportionate Share Calculations): Cost estimates should be based on FDOT’ 2004 Cost s estimates which can be found on the Department’ web site. As you know the costs of construction and R-O-W rose s significantly the last few years. Therefore, the fairshare calculation should be revised to reflect current costs estimates. 12.)Intersections proportionate share: The Department cannot consider a proportion of an intersection as its fairshare cost estimate. When an intersection fails, it is the responsibility of the applicant to correct the deficiencies, all movements and the intersection as a whole. The new development trips are the cause of the failure of the intersections. The operation of an intersection must be corrected to reduce the conflicts and to provide for safe improvements. Therefore, the Department strongly suggests that all intersections which are identified as failing are improved fully, to restore them to an operational function. FDOT cannot consider only a proportion of the intersection because the whole intersection needs to be addressed. Many of the intersections are at County roads junctions, and the County will have to address these operational issues as well. III. Mitigation Plan: 1.) Mitigation Plan: The applicant’ total mitigation plan is $109,789,615.00 as shown on Table 21-24 of the ADA. Based on a revised s analysis as requested (in the above comments), and based on revised cost estimates, we expect the list of roads impacted by the project and the final costs to change. The cumulative costs for all three Phases of the development will change. The department has additional concerns regarding the mitigation, the issues are as follows: a.) River -Crossing: As FDOT continues to study the need for a River Crossing and provide a final alignment. As discussed before (see general comments/Section-I, subsection-6) it is crucial that the reservation of the R-O-W for the possible River Crossing alignment is considered. The County as well should emphasize the need to reserve future corridors that may traverse property owners in this area of the County. The Department’ goal is to provide an adequate and efficient transportation system that promotes s economic growth but also preserves the integrity of the State highway system. As funds permit FDOT will continue to construct facilities that provide additional capacity where necessary. It is in this spirit that we address the need to have the developer consider reservation of the proposed corridor shown on Map-H and 15 Map(s)- J(s) for at least the first 10 years (to 2015) to permit us to complete the study and come up with the plan and the funding to construct the new and much needed River Crossing. b.) State Roads: Tables 21-13 through 21-21 within the ADA which based on the applicant’ analysis, s provides a list of roadway determined to be significant/adverse; Thus, these facilities are impacted by the new development and the new trips created by the Silverleaf. Among these facilities, many links are State roads: i.e. SR 9A, SR 9B, I-95, US-1 and SR 16 as shown in Table 11 (below). Yet, the Applicant mitigation plan address only roads that serve the development and ignore the State facilities, this approach is unreasonable and unacceptable to the Department. As we stated before, new trips are created by development that can only be approved by the County. The State roads do not create new trips, and fixing the degraded facilities cannot become only the State responsibility. We urge the applicant to reconsider its mitigation plan whereby the State roads are equitably considered. Both local and State roads will be impacted and both should be improved accordingly. The applicant’ s proposed mitigation only shows CR 2209 and CR 16 connector to be the main improvements. These facilities are surely the Silverleaf Plantation development much needed roads and therefore should be partially credited (not fully credited as proposed in Tables 21-23 and 21-24). The applicant’ mitigation s plan should be revised accordingly. c.) Local Roads: As stated above, the applicant’ proposed mitigation plan seem to indicate that only the s County Roads will be addressed for mitigation. The Department understands the County’ need to have the s development community build the new roads to serve the developments. In the same token the County also should understand that existing State roads must be maintained at acceptable LOS. When the new trips reach State roads and funds are unavailable to add capacity, there should be a reasonable solution. Therefore, the Department suggests the mitigation plan is revised to provide an equitable solution to all the traveling public. Table 11: Impacted State Facilities 2010 Link ID 82 89 90.1 126 131 133 19.1 19.2 19.3 20.1 20.2 21 72 558.1 558.2 544 N/A N/A N/A Roadway SR 13 SR 16 SR 16 SR 5 (US 1) SR 9 (I-95) SR 9 (I-95) I-95 I-95 I-95 I-95 I-95 I-95 I-295 SR 9A SR 9A SR 9A SR 9B US 17 US 17 DRI Traffic 19 50 43 50 138 573 573 N/A 532 346 234 193 82 89 89 74 N/A 42 31 Total Traffic 1,618 2,195 1,216 5,702 7,212 10,062 10,800 N/A 11,852 15,868 12,547 16,052 14,209 7,776 7,776 7,392 N/A 2,829 3,224 MSV 1,590 1,590 1,590 5,420 9,640 9,640 10,050 N/A 9,840 13,420 9,840 10,050 9,840 6,510 6,510 6,250 N/A 3,150 3,150 Adverse? Yes Yes No Yes No Yes Yes N/A Yes Yes Yes Yes Yes Yes Yes Yes N/A No Yes DRI Traffic 74 127 138 154 204 765 765 N/A 718 468 311 253 113 126 126 106 N/A 105 72 Total Traffic 2,138 2,629 1,634 4,836 8,502 10,764 11,542 N/A 12,155 18,376 14,558 18,212 17,722 7,890 7,890 7,904 N/A 3,234 3,595 2015 MSV 1,590 1,590 1,590 5,420 9,640 9,640 10,050 N/A 9,840 13,420 9,840 10,050 9,840 6,510 6,510 6,250 N/A 3,150 3,150 Adverse? Yes Yes Yes No No Yes Yes N/A Yes Yes Yes Yes Yes Yes Yes Yes N/A Yes Yes DRI Traffic 108 212 212 53 280 307 307 955 883 621 422 347 220 0 393 290 392 162 108 Total Traffic 2,410 2,885 1,600 5,398 9,802 11,827 12,723 13,372 12,787 20,913 16,604 20,407 19,155 2,428 9,807 9,767 7,379 3,404 3,776 2020 MSV 1,590 1,590 1,590 5,420 9,640 9,640 10,050 10,050 9,840 13,420 9,840 10,050 9,840 6,510 6,510 6,250 6,510 3,150 3,150 Adverse? Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes 16 2) In conclusion: FDOT is confident that after the applicant has revised the trip distribution and assignment and all corrections were made (as requested in the above comments), then all the facilities impacted by the development, including the State roads, and the mitigation plan is revised to address State facilities such as: I-95, SR 16, SR 13, US-1, then we can negotiate the final recommendations. Thank you for giving the Department the opportunity to provide comments regarding the Silverleaf Plantation DRI. If you have any questions, please call me at: (904) 360-5647. Sincerely, Lea E. Gabbay Growth Management Administrator DRI Coordinator Fn: ADA-Silverleaf-fn CC: Teresa Bishop, (SJC) Shawn Collins, (SJC) James Stansbury (DCA) James Bennett (FDOT) David Rae (URS) 17