MEMORANDUM
DATE: January 14, 2008
TO: Planning and Zoning Board
FROM: The Mellgren Planning Group, in capacity of consultant for the City
THRU: Richard D. Cannone, Director of Development Services
SUBJECT: Application #34-07-PA by Diplomat Properties, LLC for a Future Land Use Plan Map Amendment of property within the Diplomat Country Club, and Application #33-07-TC for a Comprehensive Plan Text Amendment
I. BACKGROUND INFORMATION
APPLICANT:
Diplomat Properties, LLC, Applicant
Debbie Orshefsky Esquire, Agent
OWNERSHIP:
Diplomat Properties, LLC
LOCATION:
For purposes of this report, the subject properties will be referred to as Parcels A, B and C as described below, and as depicted on the location sketch below:
Parcel A: generally described as a portion of Tract B, Block 1 and a portion of Block 11 of the Diplomat Golf Estates Plat (46-24, BCR) consisting of 5.2393 net acres and 5.5648 gross acres.
Parcel B: Block 13 of the Diplomat Golf Estates Plat (46-24, BCR), consisting of 1.448 net acres and 2.1344 gross acres
Parcel C: generally described as a portion of Block 11 of the Diplomat Golf Estates Plat (46-24, BCR) consisting of 86.7777 net acres and 88.5610 gross acres.
LOCATION MAP
REQUEST:
The Applicant is requesting both a City and County Future Land Use Plan Map Amendment for 96.26 gross acres of the Diplomat County Club north of Hallandale Beach Boulevard, south of Atlantic Shores Boulevard, east of NE 14th Avenue and west of the De Soto Waterway.
The Applicant is also requesting an amendment to the text of the City Future Land Use Element of the Comprehensive Plan.
The applications are as follows:
1. Application #34-07-PA for a Future Land Use Plan Map amendment to change the land use designation of Parcels A, B and C as follows:
a ) Parcel A (5.565 acres): from General Commercial to Dashed Line Area (Irregular 11.24 du/ac).
b) Parcel B (2.134 acres): from Low (7) Residential to Dashed Line Area (Irregular 11.24 du/ac).
c) Parcel C (88.56 acres) from Commercial Recreation to Dashed Line Area (Irregular 11.24 du/ac).
2. Application #33-07-TC(A) to amend the text of the Future Land Use Element of the Comprehensive Plan to allow for dashed-line areas.
3. Application #33-07-TC(B) to amend the text of the Future Land Use Element of the Comprehensive Plan to allow hotels, motels and similar lodging as an ancillary use in the Commercial Recreation Future Land Use Plan designation.
PLANNING DISTRICT:
Diplomat/Three Islands
PARCEL SIZE (NET):
Parcel A: 5.239 Acres
Parcel B: 1.448 Acres
Parcel C: 86.777 Acres
Total: 93.464 Acres
EXISTING ZONING:
Parcel A: CR-P, Commercial Recreation (Passive) District
Parcel B: RS-5, Residential Single-Family District
Parcel C: CR-P, Commercial Recreation (Passive) District
EXISTING USE:
Parcel A: southerly extension of Diplomat Golf Course
Parcel B: marina
Parcel C: main portion of Diplomat Golf Course, including the existing country club and a 60-room hotel
PROPOSED USE:
Residential: 1,050 dwelling units
Commercial Recreation: country club and the 349 hotel units.
EXISTING COMPREHENSIVE PLAN FUTURE LAND USE DESIGNATIONS:
Parcel A Parcel B Parcel C
City: General Commercial Low (7)Residential Commercial Recreation
County: Commercial Low (5) Residential Commercial Recreation
SURROUNDING ZONING AND LAND USE PLAN DESIGNATION OF APPLICATION SITE:
LAND USE PLAN ZONING
North: Low-rise multiple-family residential, single-family detached residential and northern extension of golf course
East: Low-rise multiple-family residential, De Soto Waterway and single-family detached residential
On August 18, 1998, the City Commission approved Application #50-98-DB by Diplomat Properties for Major Development approval of the redevelopment of the Diplomat Country Club including 60 hotel rooms.
Staff conducted an evaluation of the proposed amendment relative to its impact on City and public facilities. The following is a summary of amendment impact. For a detailed analysis, please refer to Exhibit “A” to this report.
Potable water. No available raw water capacity at this time. Staff, in conjunction with the Public Works Department, is preparing a plan for the City’s future water supply. New wells and treatment facilities will be needed, subject to South Florida Water Management District approval, at an estimated cost of $42 million dollars.
Sanitary sewer. There is sufficient capacity to serve the proposed amendment, with a remaining capacity of .240 mgd (enough to accommodate approximately 686 du) under the City’s Large User Agreement with Hollywood.
Public schools. Student impact to the junior high school and high school will be acceptable. The student impact to Hallandale Elementary, which is already overcrowded at 121 percent of its capacity (111 percent when year-round session is factored in), will be 44 additional students.
Transportation. The amendment will not degrade the for area roads with the exception of NE 14th Avenue, which would be degraded from the current LOS “D” to LOS “F” by 2012, and will be at LOS “F” by 2030 with or without the amendment. Hallandale Beach Boulevard west of Diplomat Parkway is already operating at LOS “F” and will continue to do so.
Parks and recreation. The amendment will generate a need for almost 6 acres of parks and open space, according the City’s adopted LOS Standard of 3 acres per thousand residents. The City has sufficient recreation and open space acreage to accommodate the amendment and the projected population through the short (5 years) and intermediate range (10 years) planning horizons. The City will need to evaluate whether it will be able to meet its adopted Level of Service Standard of 3 acres per 1,000 residents beyond the 10 year horizon, as it is anticipated that the proposed amendment and recently approved developments may increase the projected population in the City beyond what is currently anticipated. Future residents of the proposed amendment site will likely have access to the Diplomat Golf Course, which is a private recreational facility, as well as other on-site facilities possibly shared by the country club, if it is to remain. However, the golf course is not a deed-restricted open space.
Hurricane evacuation LOS and shelter capacity. Broward County Emergency Management Agency has indicated that evacuation Level of Service and shelter capacity will not be diminished below acceptable levels by the amendment.
Affordable housing
The applicant “is prepared to work with the City to provide a financial contribution to the City to be used by the City to construct or have constructed up to 158 (i.e. 15 percent of the proposed 1,050 new residential units) at locations within the City of Hallandale Beach.”
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IV. STAFF ANALYSIS OF APPLICATION
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A. Application #33-07-TC(A) would amend the text of the Future Land Use Element to allow “dashed-line areas” on the City’s Future Land Use Plan Map. Dashed line areas are planned unit developments or similar large-scale development sites, such as the proposed Diplomat Golf Course redevelopment, that are circumscribed by a dashed line on the Future Land Use Plan Map. Within the property circumscribed by the dashed line on the map, a maximum residential density is indicated. In the case of the subject amendment, that density is 11.24 du/ac (net). The maximum number of dwelling units allowed within the dashed-line area is obtained by multiplying the total acreage by the maximum density, even though most of it is not intended for residential use.
The difference between an amendment site circumscribed by a dashed line and one that is not, is that the dashed-line area allows a developer to shift the residential density within the overall amendment site. For example, the 1,050 dwelling units that would be allowed within the Diplomat Golf Course could be allocated in any combination among the four sites designated for residential use and shown on the map in Exhibit “B”, such that maximum number of units within any of the four residential pods proposed for the amendment site is unlimited, as long as the maximum overall density of 11.24 du/ac (1,050 units) is not exceeded.
Application #33-07-TC(B) would allow hotels, motels and similar lodging in the Commercial Recreation land use plan designation as an ancillary use. This proposed text amendment is consistent with the language in the Commercial Recreation permitted uses section of the Broward County Land Use Plan.
B. Application #34-07-PA to amend the Future Land Use Plan Map would allow 1,050 dwelling units in a location where residential use is not currently permitted, and which is now part of the Diplomat Golf Course and related facilities. The amendment will not eliminate the golf course, and will have minimal impact on the land area currently devoted to golf course use and also designated Commercial Recreation on the Future Land Use Plan Map.
The application proposes four distinct and separate areas within the golf course and marina properties where residential use would be permitted. The four areas total approximately 16 acres out of the entire 93.46-acre amendment site. The dashed-line area allows all of the four sites to be proposed as one unified land use plan amendment, and allows the 1,050 dwelling units and hotel use to be distributed among the four sites in any combination that will comply with the development standards of the City’s Zoning and Land Development Code.
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Application # 33-07-TC for amendment of the text of the Future Land Use Element is discussed under “Staff Analysis,”
Analysis of Application # 34-07-PA for amendment to the Future Land Use Plan Map requires consideration of several comprehensive planning issues, discussed below.
Amount, location and character of growth
Consideration of the proposed map amendment includes a central policy issue: what is the desired amount, location and character of future growth?
By the year 2015, the official Broward County population projections indicate that the Hallandale Beach population will grow by almost 9,400 people and 2,850 dwelling units. By the year 2030, the projections indicate a total growth of almost 19,700 people and 5,400 dwelling units. The City has already approved several residential development projects that will help the City realize approximately 50 percent of the projected growth, assuming all are constructed. Application # 34-07-PA would add 1,050 units to the City, or approximately 37 percent of the projected number of new dwelling units. The subject amendment would, by itself, account for almost 20 percent of the number of residential units projected to be built by the year 2030, and as a result, would likely increase the City’s population in excess of projections, particularly when combined with other major developments recently approved.
The City is currently undertaking development of a Citywide Master Plan. The purpose of the plan is to determine where future growth should occur, how intense it should be, and what kind of form it should take (ex: low-rise, high-rise, mixed-use, transit-oriented, etc.). It is anticipated that a substantial portion of future growth will be directed to areas in need of redevelopment due to slum and blighting conditions in the form of revitalized neighborhoods with neighborhood commercial centers, and to properties fronting principal arterials such as Hallandale Beach Boulevard and US-1 in the form of mixed commercial/ residential development that would likely be more intense than neighborhood redevelopment.
Neighborhood compatibility
The surrounding area is predominantly characterized by low and mid-rise multiple-family residential buildings as well as several single-family detached residences. The rear yards of seven of the single-family residences border the golf course. On the southern periphery of the golf course is a two-tower high-rise development (The Duo) and a commercial shopping center. The immediate neighborhood consists of properties fronting Atlantic Shores Boulevard between NE 14th Avenue and Diplomat Parkway, and properties fronting Diplomat Parkway north of E. Hallandale Beach Boulevard to just north of Atlantic Shores Boulevard. The immediate neighborhood is characterized by low and mid-rise multiple-family residential development and single-family detached residences.
The 1,050 proposed residential units and additional hotel rooms would be concentrated on approximately 16 acres of the 93.46 acre site. The applicant has not identified how many units would be constructed within each of the four proposed residential areas in the amendment site. The applicant also has not provided any details as to height and massing, and such details are not required for plan amendment applications.
Given the intensity of development and site configuration, it can be expected that one or more tall high-rise buildings will be constructed. There is potential, therefore, for the scale of potential buildings to be out of proportion with the immediate neighborhood. Additionally, the country club site as a whole has the potential to grow out of scale with the immediate neighborhood if the country club remains, or if the hotel use expands. Approximately 2,500 parking spaces will be required for the residential and hotel uses, which may comprise approximately one million square feet of structured parking area.
Impact on public facilities and services. Impacts on public facilities and services are analyzed under “Interdepartmental Review Summary.”
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VI. APPLICABLE CODES AND ORDINANCES
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The golf course is presently designated Commercial Recreation and is zoned CR-P, Commercial Recreation Passive District. The City’s Comprehensive Plan and the City’s Zoning and Land Development Code presently permits golf courses as a principal use and other uses such as hotels as accessory uses. Section 32-163 of the Zoning and Land Development Code further specifies that accessory uses in CR-P District are limited to the following provided they occupy not more than 15 percent of the total site area. The applicant also has requested a text amendment to allow hotels as an accessory use for the purpose of clarifying the permitted uses in the Commercial Recreation category. Sec. 32-163 is excerpted below.
(a) Purpose and intent. The purpose and intent of the CR-P commercial recreational (passive) district is to provide suitable sites for commercial recreational attractions and facilities of a passive nature which require extensive land area and are recognized as being supportive of a tourist-oriented economy in areas consistent with the city's comprehensive land use plan.
(1) Commercial recreation uses, limited to golf courses.
(2) Accessory uses limited to the following, provided they occupy not more than a cumulative total of 15 percent of total site area:
b. Hotels, motels, restaurants, private clubs and cocktail lounges.
c. Parks, playgrounds and beaches.
e. Tennis, racquetball and handball courts.
For the purpose of this subsection, a hotel, motel, restaurant, private club, cocktail lounge, golf driving range, swimming pool, tennis, racquetball or handball court, park, playground and beach may be considered an accessory use to the main permitted golf course use, provided that those uses are incidental to and dependent upon the continued existence and operation of the main golf course use, even though uses may be more heavily utilized or realize substantially more income or profit than the main golf course use.
The proposed amendment is consistent with the intent and purpose of the Comprehensive Plan, and would not necessitate a change to Sec. 32-163 of the Zoning and Land Development Code.
COMMUNITY MEETING
The applicant held a community meeting on November 5, 2007 as required by City policy.
VII. REVIEW OF APPLICATION CRITERIA
Article VIII, Section 32-963 specifies the following criteria to be addressed in considering applications for rezoning and land use amendments:
(1) The relationship of the proposed amendment to the purposes and objectives of the City's Comprehensive Land Use Plan, when adopted, with appropriate consideration as to whether or not the proposed changes will further the purpose of this and other codes, regulations, and actions designed to implement said plan.
Not consistent. Staff finds that the proposed land use change is inconsistent with the following Comprehensive Plan policies:
Policy 1.3.4. B: High density residential developments should continue to be located with direct access onto major arteries.
Policy 1.5.3: Maintain a Commercial Recreation Category including Hallandale Beach major commercial recreation facilities, i.e., Gulfstream Race Track, Hollywood Dog Track and Diplomat Golf Course.. …Conversion of these facilities to other uses having increased impacts on public facilities will be contingent upon the new development’s ability to maintain adopted LOS Standards for affected public facilities.
Policy 1.12.2: The Growth Management Department shall evaluate impacts resulting from new developments to ensure that adequate facilities are either in place or planned so that Level of Service standards are not reduced.
Policy 1.10.1: The City shall maintain its highest intensities of land use along major transportation routes and encourage the clustering of parking area near major routes and transit stops.
(2) The proposed change would or would not be contrary to the established land use pattern.
Not consistent. The average proposed density of the amendment site is 11.24 du/ac. This number is calculated by dividing the number of proposed dwelling units by the acreage of the entire amendment site (93.5 acres). The net density, excluding the golf course parcel to remain, will be approximately 65 du/ac. This number is calculated by dividing the number of proposed dwelling units by the acreage of the four proposed residential pods within the amendment site (approximately 16 acres), as shown on Exhibit “B.” The proposed 65 du/ac net density is substantially higher than both the predominant 18 du/ac land use plan density of adjacent multiple-family properties and 5 du/ac density of adjacent single-family detached residences. The potential height of one or more high-rise buildings would pose a compatibility issue, as the majority of adjacent structures are low-rise in nature.
(3) The proposed change would or would not create an isolated district unrelated to adjacent and nearby districts.
Not consistent. High-rise residential towers are located approximately one-quarter mile to the east across the De Soto Waterway and one-quarter mile to the south. Mid-rise (approximately 6-8 stories) towers are located west of NE 14th Avenue. There is no precedent, however, for high-rise towers and a density of 65 du/ac (excluding golf course) within the core of the Diplomat Planning District east of NE 14th Avenue and west of Three Islands Boulevard. Staff finds that building height, location and massing may be equally relevant considerations as density, but cannot be adequately evaluated without the type of information provided during Major Development Review.
(4) The proposed change would or would not alter the population density pattern and thereby have an adverse impact upon public facilities such as school, utilities, and streets.
Not consistent. Impacts to public facilities and services are evaluated under “Interdepartmental Review Summary” and are of concern due to limitations on elementary school capacity, sanitary sewage treatment capacity, local roadway capacity, allowable Biscayne Aquifer withdrawal, lack of Floridian Aquifer wells, and present inability to treat the necessary quantities of brackish Floridian Aquifer water.
(5) Existing district boundaries are illogically drawn in relation to existing conditions on the property proposed for change.
Not consistent. Existing district boundaries are not illogically drawn in relation to existing conditions on the amendment site.
(6) Changed or changing conditions make the passage of the proposed amendment necessary.
Not consistent. The application states that the proposed amendment is necessary to accommodate the City’s future projected population. South Florida has experienced steady construction of residential units over the last two decades, which is projected to continue. However, the location of residential development has shifted from strictly suburban growth in western areas to renewed interest in infill development and residential and mixed-use redevelopment throughout Broward County. For this reason, the City’s population is expected to grow to more than 53,000 residents by the year 2030, and the City has seen a surge in residential projects.
Due to the county-wide change in the spatial pattern of residential growth, the application is correct in stating that conditions have changed. However, the amendment is not necessary to accommodate the City’s projected population. The City’s 2030 population growth is projected to occur gradually over the next 22 years. The amendment, combined with other recently approved and planned residential projects, would achieve nearly 50 percent of that projected growth in just a few years.
Strategic, coordinated and well-planned redevelopment distributed throughout the City—but not necessarily concentrated in very large projects such as the proposed amendment—will ensure the City can accommodate its projected population. Such redevelopment will occur throughout the City, consistent with sustainable development practices, in areas designated for same upon adoption of the Citywide Master Plan and implementing amendments to the Comprehensive Plan and Future Land Use Plan Map. Therefore, at this time, the passing of the proposed amendment is not necessary.
(7) Substantial reasons exist why the property cannot be used in accordance with the adopted land use plan and/or the existing zoning.
Not consistent. The amendment site is a golf course and country club with a hotel and accessory marina. The golf course, spa and country club serve the guests of the Diplomat Hotel on Hollywood Beach, among others. The applicant has not indicated that the land use plan designation impedes the present use of the amendment site, or other permitted passive recreation uses. In fact, the proposed expansion of the hotel on the property from 60 rooms to 349 rooms will be in furtherance of the uses permitted under the current land use plan and zoning classifications.
(8) Whether or not the change is out of scale with the needs of the neighborhood.
Not consistent. The proposed change is substantially out of scale with the needs of the neighborhood.
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VIII. STAFF FINDINGS
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Application #34-07-PA for amendment to the Future Land Use Plan Map and Application #33-07-TC was analyzed with due consideration to several germane planning issues, as follows:
1. Amount, location and character of growth.
4. Impact on public facilities and services (see also review criterion 4). The amendment will have a substantial impact on potable water, sanitary sewer, transportation and public school facilities.
a. SFWMD has prohibited additional withdrawals from the Biscayne Aquifer, which is the main water supply for all of South Florida. The City must develop new wells to access the Floridian Aquifer in order to supply the potable water needs of new development, and must build capacity for treating the more brackish water of this source. None of the infrastructure is yet in place, and has not been funded, and final water allocation from SFWMD has not been determined as of yet.
b. The amendment will utilize approximately 34 percent of the remaining sewage treatment capacity allocated to the City via the Large User Agreement with Hollywood, leaving only enough capacity to accommodate approximately 686 additional residential units or an equivalent amount of commercial development. Therefore, future diverse residential and/or commercial development may potentially be precluded due to lack of sanitary sewage treatment capacity.
e. City has adequate park acreage to accommodate the proposed amendment at this time, but will need to reevaluate in the coming years whether the acreage will be sufficient beyond the 10-year planning horizon. However, the amendment will create a demand for almost 6 acres of additional parks from the City’s inventory.
5. Criteria for review of proposed plan amendments. The amendment application does not satisfy the criteria for consideration of plan amendments.
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IX. STAFF RECOMMENDATIONS
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Based upon the aforementioned findings of facts, staff recommends the following:
Staff recommends that Application #34-07-PA for amendment of the Future Land Use Plan Map be denied.
Accordingly, staff also recommends denial of Application #33-07-TC(A) for amendment of the text of the Future Land Use Element to create dashed-line areas.
Application #33-07-TC(B) for amendment of the Future Land Use Plan text, to allow hotels, motels and similar lodging as an ancillary use in the Commercial Recreation category, is consistent with the intent and purpose of the Commercial Recreation category, and staff recommends approval.
IX. PLANNING AND ZONING BOARD RECOMMENDATION______________
Suggested Motions:
1. I move to deny application #34-07-PA based upon staff recommendation.
2. I move to deny application #33-07-TC for amendment to the text of the Future Land Use Element to create dashed-line areas based upon staff recommendation.
3. I move to approve application #33-07-TC for amendment to the text of the Future Land Use Element to allow hotels, motels and similar lodging ancillary to the primary commercial recreation use based upon staff recommendation.
EXHIBIT “A”
PUBLIC FACILITIES AND SERVICES IMPACT ANALYSIS
Parks and Recreation
- Inventory: 165 acres (58 acres of parkland, 107 acres are waterways)
- LOS Standard: 3 acres/1,000
- 2006 LOS (34,622 population): 103.9 acres needed
- Additional parks demand generated by the proposed amendment: almost 6 acres
- Projected 2030 LOS (54,321 population): 162.93 acres needed (without the amendment)
Potable Water
- Average daily demand is 6.54 mgd.
- SFWMD intends to limit withdrawal to 6.2 from the Biscayne Aquifer.
- Committed demand for approved but unoccupied projects is approximately .50 mgd.
- The amendment will create .385 mgd of additional demand, for a total of demand of 1.22 mgd in excess of the amount of water that the City anticipates it will be allowed to withdraw from the Biscayne Aquifer.
- Treatment capacity: 8.0 mgd, with a 15 mgd expansion planned.
The South Florida Water Management District (SFWMD) determines how much untreated ground water the City can withdraw from its Biscayne Aquifer wells each year. SFWMD does so through issuance of consumptive use permits, which specify maximum withdrawal on an average and peak daily basis. The permit has expired and is currently under review by SFWMD. As such, the City is operating without a valid permit. The situation is similar across South Florida as the SFWMD and local governments grapple with water supply limitations.
SFWMD has prohibited most cities, including Hallandale Beach, from using the Biscayne Aquifer to meet the water needs of future growth. In fact, SFWMD is requiring a reduction in Biscayne Aquifer withdrawal and requiring potable water suppliers to find and fund alternative water supply sources and treatment.
Hallandale Beach is pursuing the development of wells to tap the deeper and more brackish Floridian Aquifer. The Floridian Aquifer is a more expensive source of water because deeper wells have to be drilled to reach it, and because treating brackish water requires different, and more expensive technology than treating fresh waster from the Biscayne Aquifer. Additionally, the technology used to treat brackish water is less efficient, meaning that for each gallon of post-treatment potable water produced from the Floridian Aquifer, more than one gallon of pretreated raw water is required.
The City Engineer has estimated the cost of pursuing Floridian Aquifer wells to be approximately $42 million dollars. Also, it is not known at this time to what extent the Floridian Aquifer can support the region’s future growth.
Sanitary Sewer
- City of Hollywood treats sanitary sewage from Hallandale Beach.
- City of Hollywood has a total 48.75 mgd plant capacity and 43.54 mgd flow. No planned expansions at this time.
- Hallandale Beach is allocated 7.85 mgd average annual daily flow
- Actual average daily demand from Hallandale Beach: 6.798 mgd
- Committed flow for approved but unbuilt Hallandale Beach projects: 0.453 mgd
- Diplomat amendment project demand: 0.359 mgd
- Remaining Capacity : 0.240 mgd (enough for 686 SFR)
Schools
The amendment would impact the following schools as indicated:
- Hallandale Elementary School: 44 students (overcrowded at 111% of capacity based upon multi-track year-round calendar)
- Gulfstream Middle School: 8 students (under capacity)
- Hallandale High School: 12 students (under capacity)
Transportation
Hallandale Beach, like all of eastern Broward County, is located within a Transit-Oriented Concurrency Area. Within this area, developers make one-time payments to Broward County based upon the traffic they would generate, but the money is used to improve and operate mass transit service.
Nonetheless, transportation impact, particularly on collector and local streets is a valid and important consideration when evaluating proposed plan amendments. Accordingly, the applicant submitted a traffic impact yielding the results on the following page.
| 2005 LOS | Without Amendment | With Amendment |
2012 LOS | 2030 LOS | 2012 LOS | 2030 LOS |
Diplomat Parkway | N. of Amendment | C C | C C | C C | C C | C C |
S. of Amendment |
Atlantic Shores Blvd. | E. of Amendment | D D | D D | C C | C C | C C |
W. of Amendment |
NE 14th Avenue | N. of Atlantic Shores Blvd. | C
D | D
D | F
F | F
F | F
F |
S. of Atlantic Shores Blvd. |
E. Hallandale Beach Blvd. | E. of Diplomat Parkway | D
F | D
F | D
F | D
F | D
F |
West of Diplomat Parkway |
W. Hallandale Beach Blvd. | (I-95 to US-1) | E | F | F | F | F |
CommercialRecreation Irregular (11.24du/ac) Residential
Dashed linearea