AGENDA ITEM ST. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS

Transcription

1 1 AGENDA ITEM ST. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS Deadline for Submission - Wednesday 9 a.m. Thirteen Days Prior to BCC Meeting 10/3/2017 BCC MEETING DATE TO: Michael D. Wanchick, County Administrator DATE: August 20, 2017 FROM: Danielle Handy, AICP, Chief Planner PHONE: SUBJECT OR TITLE: AGENDA TYPE: DRI MOD Caballos del Mar (PGA Tour) Ex Parte Communications, Public Hearing, Resolution BACKGROUND INFORMATION: Request to amend the Development Order to consolidate the acreage and uses of the PGA Tour Property and the Annex Parcel in a unified Master Development Plan Map H, add a Land Use Equivalency Table, and extend buildout and completion dates. The Planning and Zoning Agency recommended approval of DRI MOD Caballos del Mar (PGA Tour) at the August 17th, 2017 hearing with a vote of 6-0. Please see staff report for additional details. 1. IS FUNDING REQUIRED? No 2. IF YES, INDICATE IF BUDGETED. No IF FUNDING IS REQUIRED, MANDATORY OMB REVIEW IS REQUIRED: INDICATE FUNDING SOURCE: SUGGESTED MOTION/RECOMMENDATION/ACTION: APPROVE: Motion to adopt Resolution DRI MOD Caballos del Mar (PGA Tour) based upon four (4) findings of fact. DENY: Motion to deny DRI MOD Caballos del Mar (PGA Tour) based upon four (4) findings of fact. For Administration Use Only: Legal: PS 9/6/2017 OMB: N/A Admin: DML 9/6/2017

2 Growth Management Department DIVISION REPORT Development of Regional Impact Modification DRI MOD Caballos del Mar (PGA Tour) To: Through: From: Board of County Commissioners Planning and Zoning Agency Danielle Handy, AICP, Chief Planner Date: August 30, 2017 Subject: Owner/Applicant: Authorized Rep.: DRI MOD Caballos del Mar (PGA Tour), request to amend the Development Order to consolidate the acreage and uses of the PGA Tour Property and the Annex Parcel in a unified Master Development Plan Map H, add a Land Use Equivalency Table, and extend buildout and completion dates. PGA Tour Inc. 112 PGA Tour Boulevard Ponte Vedra Beach, FL Phillip J. Mays RocaPoint Partners 3424 Peachtree Road, Suite 1140 Atlanta, Georgia Hearing date(s): Planning and Zoning Agency August 17, 2017 Board of County Commissioners September 19, 2017 Commissioner District: District 4 SUGGESTED MOTION/RECOMMENDATION/ACTION APPROVE: Motion to enact Resolution 2017-, DRI MOD Caballos del Mar (PGA Tour) based upon four (4) findings of fact. DENY: Motion to deny DRI MOD Caballos del Mar (PGA Tour) based upon four (4) findings of fact.

3 Page 2 DRI MOD Caballos del Mar (PGA Tour) MAP SERIES Location: The subject property is located west of A1A North and Palm Valley Road and south of PGA Tour Boulevard.

4 Page 3 DRI MOD Caballos del Mar (PGA Tour) Future Land Use: The subject property is designated Caballos del Mar DRI on the Future Land Use Map. Lands to the south and southeast are designated Commercial and Residential-B.

5 Page 4 DRI MOD Caballos del Mar (PGA Tour) Zoning District: The subject property is zoned Players Club Planned Unit Development (PUD) pursuant to Ordinance , as amended. The applicant filed a companion Major Modification to incorporate the proposed DRI amendments into the PUD. Adjacent properties are zoned PUD, Planned Special Development (PSD), Neighborhood Commercial (CN), and Open Rural (OR).

6 Page 5 DRI MOD Caballos del Mar (PGA Tour) Aerial Imagery: The subject property consists of acres. THE PLAYERS Stadium Course at TPC Sawgrass accounts for approximately acres, which includes the clubhouse, practice grounds, back practice grounds, and the 18-hole championship golf course. Approximately acres consist of lands utilized for parking during The PLAYERS Championship (TPC), wetlands, and lands that accommodate the Agronomic Operations Center (AOC). The remaining 1.8 acres are owned by St. Johns County and accommodate the Ponte Vedra Courthouse Annex and an Antenna Tower.

7 Page 6 DRI MOD Caballos del Mar (PGA Tour) BACKGROUND The Caballos del Mar Development of Regional Impact (DRI) was approved by the St. Johns County Board of County Commissioners in 1975, and has been modified at least twelve times since its inception. The DRI was most recently modified in 2014 via Resolution , which had the effect of combining vacant Tour-owned parcels, including Parcels 11, 12, 13, 34, 35, and a Commercial Parcel into one development parcel known as the Tour Parcel (Figures 1-2). The DRI modification also distributed the allowable uses on each individual parcel throughout the newly created Tour Parcel, including Commercial, Office, Patio Homes, Multi-Family, Single Family, and Special Use. Figure 1: Master Development Plan (Map H) prior to Resolution

8 Page 7 DRI MOD Caballos del Mar (PGA Tour) Figure 2: Master Development Plan (Map H) following Resolution APPLICATION SUMMARY The applicant is proposing to amend the Caballos del Mar Development of Regional Impact (DRI) in order to achieve the following changes: 1) Modification to the Master Development Plan Map H to combine the 1.8-acre St. Johns County Courthouse Annex site (the Annex Parcel ) with lands owned by the Tour (Figure 3). The proposed change will result in the relocation of the existing tower on the Annex Parcel to another location on the Tour Parcel, and the relocation of the Courthouse Annex building from the Annex Parcel to another site. 2) Consolidation of Tour-owned parcels (Tour and Golf Course Parcels) and the Annex Parcel, and their approved development rights, into one Master Development Plan Map H (Figure 3). Allowed uses on the Golf Course Parcel currently include TPC Golf Course, Clubhouse, and other ancillary golf course uses. By consolidating development rights throughout all of the Tour-owned properties, multi-family residential development would be allowed throughout the Golf Course Parcel as specified within the companion Major Modification application and summarized below. While the multi-family residential development could be located throughout the Tour Parcel, Annex Parcel, or Golf Course Parcel, commercial and office uses would only be allowed on the Tour Parcel and Annex Parcel. Staff anticipates changes to Figure 3 in order to replace the term Golf Course-Related Commercial and Office with Golf Related Uses, which is intended to address existing and future golf-related uses such as golf course, clubhouse and associated lawns, golfrelated commercial and office uses, maintenance and operations facilities, practice ranges, media center, starter s facilities, parking lots, unpaved parking areas, tournament facilities for THE PLAYERS, tournament hospitality facilities, office and commercial space associated with the uses allowed in this paragraph (by way of example but not limitation, offices for the Agronomic Operations Center, golf pro shop in the clubhouse), and other similar facilities.

9 Page 8 DRI MOD Caballos del Mar (PGA Tour) Figure 3: Proposed DRI Map H under DRI MOD Caballos del Mar (PGA Tour) 3) Amendment to the Development Order ( DO ) to add a Land Use Equivalency Table that will allow for the exchange of approved multi-family residential units to commercial (retail or office) square footage within parcels owned by the Tour and County (Exhibit C). Land Use Equivalency Tables, by design, provide the opportunity to convert entitlements through the establishment of conversion formulas to demonstrate no increase in traffic generation (i.e., traffic impact would be neutral). By incorporating a Land Use Equivalency Table into the DRI, the applicant would have the ability to convert the previously approved, vested multi-family residential development to commercial and/or office square footage. For example, under the proposed Land Use Equivalency Table, the conversion of the 684 multi-family residential dwelling units to office would result in a maximum of 259,783 square feet or a maximum of 136,390 square feet if converted to commercial. Alternatively, a conversion of the 684 multi-family residential units to office and commercial could be achieved so long as the conversion yielded no change in traffic generation. 4) Extend the termination, build-out, downzoning protection, and construction completion dates for development within the Tour and County- owned parcels subject to this application, in lieu of seeking certain gubernatorial and legislative extensions that have been granted. Commencement of development within the parcels subject to this application has occurred. Therefore, no extension to the commencement date is requested for such parcels.

10 Page 9 DRI MOD Caballos del Mar (PGA Tour) DEPARTMENTAL REVIEW This application was routed to all appropriate reviewing departments. Technical Division Review: All future site engineering, drainage and required infrastructure improvements will be reviewed pursuant to the established Development Review Process to ensure that the development has met all applicable local regulations and permitting requirements. No permits will be issued prior to compliance with all applicable regulations. Office of the County Attorney Review: Applicant must demonstrate that the proposed changes do not constitute a substantial deviation pursuant to section (19), F.S., which would require further review for regional impact. Afterwards, pursuant to section (11), the local government shall give notice and hold a public hearing on the application in the same manner as for a rezoning. Applicant then bears the initial burden of demonstrating with competent substantial evidence that the proposed change is a) consistent with the Goals, Objectives, and Policies of the Comprehensive Plan and b) complies with the procedural requirements of the Land Development Code. The Agency/Board may approve or deny the proposed request to amend the DRI if there is evidence that maintaining the existing DRI Development Order serves a legitimate public purpose on matters relating to local (not regional) issues. A legitimate public purpose for keeping the existing Development Order may include that the rezoning: produces an urban sprawl pattern of development; is spot zoning; produces an incompatibility or deviation from an established or developing logical and orderly development; produces significant adverse impact upon property values of the adjacent or nearby properties; or detracts from the character and quality of life in the neighborhood by creating excessive noise, lights, vibration, fumes, odors, dust, physical activities and other detrimental effects or nuisances Planning and Zoning Division Review: modification request can be found below. An analysis of each component of the DRI Acquisition of the Annex Parcel and relocation of existing tower: In coordination with County staff, the applicant has agreed to relocate the communication tower from the Annex Parcel to another portion of the Tour-site. In addition to relocating the tower structure, the tower is anticipated to be upgraded from a lattice structure to a monopole structure, and to be upgraded to increase the ability to withstand a Category 5 windstorm event as opposed to a Category 3 windstorm event. According to County staff, the existing tower provides communication services used by public safety agencies in the County. Further, the existing tower has one of the lowest wind storm ratings in the County compared to other towers used for intergovernmental communication system. With regard to the Ponte Vedra Courthouse Annex, the applicant has coordinated with the County s Real Estate Division, Fire Rescue, and the Office of the County Attorney to acquire the Annex Parcel and relocate services, which currently include a satellite office for the Property Appraiser and Tax Collector. County staff indicates that the Property Appraiser is the main user of the Annex Property, and that the relocated facilities will be nearby. County staff are advocating no interruption in services, and plans to review technical details of how the transition will occur to ensure no loss in service. Consolidation of the Tour-owned parcels and the Annex and their associated development rights: With regard to consolidating Tour-owned parcels and the Annex and their associated development rights, staff finds that the measures proposed with the Planned Unit Development should ensure consistent and compatible development. For instance, the

11 Page 10 DRI MOD Caballos del Mar (PGA Tour) applicant has stipulated within the Master Development Plan text the following standards: 1. A setback of 200 feet between multi-family residential units and existing platted single-family residential lots; 2. Requirement that all multi-family residential development proceed through the Incremental Master Development Plan or Small Adjustment process prior to obtaining construction plan approval; 3. Incorporation of compatibility standards for multi-family residential development in areas where non-compatible adjacent uses may exist, as provided within the Comprehensive Plan and Land Development Code, during staff review of aforementioned Incremental Master Development Plan or Small Adjustment applications; 4. Prohibition of multi-family residential development in playable areas of the 18-hole championship golf course (Stadium Course), defined as those areas that are inbounds for play. Existing Stadium Course must remain in a configuration that is substantially similar to its existing condition; 5. Establishment of a height zone map to limit previously height allowance of 100 feet to heights ranging between primarily 35 feet and 75 feet. It should be noted that there is a height allowance of 85 feet within the center of the golf course to accommodate the existing clubhouse facility; and, 6. Establishment of certain areas around the perimeter of the Golf Course parcel which prohibit multi-family development (see the areas noted in yellow on Proposed Master Development Plan Map of Golf Course Parcel). Addition of a Land Use Equivalency Table: The applicant is proposing to incorporate a Land Use Equivalency Table into the DRI. This table would allow the conversion of the 684 multi-family residential dwelling units into commercial (retail or office) square footage. The use of the Land Use Equivalency Table is limited to lands associated with this DRI modification and Major Modification request only. Additionally, the Land Use Equivalency Table does not allow for the conversion of commercial square footage to residential and does not provide for the conversion of office square footage to commercial square footage or vice-versa. Incorporation of extensions to termination, build-out, downzoning protection, and construction completion dates: Lastly, the applicant has incorporated the extension of termination, build-out, down-zoning protection and construction completion dates for lands subject to the DRI modification and Major Modification application. This request will memorialize gubernatorial and legislative extensions granted under Florida Statute. NORTHEAST FLORIDA REGIONAL COUNCIL The Chief Executive Officer of the Northeast Florida Regional Council (NEFRC), Brian Teeple, provided a memorandum on July 3, 2017 pertaining to the proposed changes to the DRI (Attachment 3). Mr. Teeple recommended that the Northeast Florida Regional Council Executive Committee approve the request based on consistency with the DRI Development Order Conditions, consistency with the numerical thresholds in F.S (19), and based on impacts to regional resources and facilities not previously reviewed. The Regional Council noted that the consolidation of all three parcels had two practical effects: a. Add the Courthouse Annex property into the DRI b. Designate the Golf Course as Mixed-use, which allows Golf Course, Multi-Family

12 Page 11 DRI MOD Caballos del Mar (PGA Tour) Residential, and Golf Course Related Commercial and Office. Mr. Teeple noted two concerns within the memorandum including two unsigned owner s authorization documents and general concerns regarding the lack of specificity within the development plan. Specifically, Mr. Teeple stated Additionally, the change in the land use designation for the Golf Course to Mixed-Use, without any specificity as to location of nongolf course uses, make meaningful analysis difficult. St. Johns County should await correction of these two issues prior to consideration of approval. Following the publishing of this memorandum, the applicant provided signed owner s authorization documents and revised application materials specifying a two-hundred (200) foot setback between multifamily residential units and existing platted single-family residential units and prohibiting multi-family residential units from being located within playable areas, defined as those areas that are in-bounds for play, of the 18-hole championship golf course (Stadium Course) in a configuration that is substantially similar to its existing condition. PLANNING AND ZONING AGENCY HEARING The Planning and Zoning Agency recommended approval of DRI MOD Caballos del Mar with a vote of 6-0 at the August 17, 2017 hearing based on four (4) findings of fact as provided in the staff report. Seven individuals spoke during the joint public input for the DRI Modification and Major Modification and cited concerns regarding the expansion of multifamily residential uses within the Golf Course Parcel, lighting of the practice facilities 2.5 hours prior to sunrise, lack of details depicted on the Master Development Plan Map, the request for a waiver to active recreation requirements, and how the term Golf-related is broad in nature in terms of describing allowable uses on the Golf Course Parcel. One member of the public expressed that the relocation and upgrage of the communication tower was a benefit to the County and that the incorporation of a Land Use Equivalency table could potentially increase commercial and/or office uses in the County to help balance the County s ad valorem tax base. Agency Member Koppenhafer questioned the term Golf Course-Related Commercial and Office uses to ensure that these uses were not intended to consist of shopping centers such as a Publix or McDonalds and to confirm that these uses instead capture golf-course related facilities. CORRESPONDENCE/PHONE CALLS Correspondence regarding the request is attached (Attachment 4). Phone calls in opposition to the request and of an information nature have been fielded by staff. RECOMMENDED ACTION NOTE: STAFF RECOMMENDATIONS ARE NON-BINDING. Staff recommends approval of DRI MOD Caballos del Mar (PGA Tour) subject to four (4) Findings of Fact. These findings are based on the application materials, consistency with applicable policies of the Comprehensive Plan, the Land Development Code requirements and other relevant information available to staff. Staff recommendations are non-binding. ATTACHMENTS 1. Documents to be Recorded 2. Application and Supporting Documents 3. Northeast Florida Regional Council Correspondence and Response 4. Correspondence

13 FINDINGS OF FACT DRIMOD Caballos del Mar (PGA Tour) APPROVE 1. This request was fully considered after public hearing pursuant to legal notice duly published as required by law. 2. The requested changes do not constitute a substantial deviation pursuant to the terms of Section (19) of the Florida Statutes. 3. The requested changes are compatible with the surrounding area and consistent with future development trends of the area. 4. The requested changes are consistent with and further the objectives of the 2025 Comprehensive Plan. DENY 1. This request was fully considered after public hearing pursuant to legal notice duly published as required by law. 2. The requested changes constitute a substantial deviation pursuant to the terms of Section (19), Florida Statutes. 3. The requested changes are not compatible with the surrounding area and not consistent with future development trends of the area. 4. The requested changes are inconsistent with and do not further the objectives of the 2025 Comprehensive Plan.

14 ATTACHMENT 1 DOCUMENTS TO BE RECORDED

15 RESOLUTION NO A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF ST. JOHNS, STATE OF FLORIDA, MODIFYING THE CABALLOS DEL MAR DEVELOPMENT OF REGIONAL IMPACT DEVELOPMENT ORDER, AS PREVIOUSLY APPROVED BY ST. JOHNS COUNTY ON JULY 8, 1975, AND AS PREVIOUSLY MODIFIED BY RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; RESOLUTION ; AND RESOLUTION ; FINDING THAT THE MODIFICATION DOES NOT CONSTITUTE A SUBSTANTIAL DEVIATION; PROVIDING FOR A SAVINGS CLAUSE; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, PGA Tour Inc., Tournament Players Association, Inc., Tournament Players Club at Sawgrass, Inc. and St. Johns County (collectively, Applicant ) has submitted a Notice of Proposed Change (DRIMOD ) (the DRI Modification Application ) to the Caballos del Mar Development of Regional Impact ( DRI ) dated May 30, 2017 (the Notification ) requesting modification to the Master Plan Map H (the Notice of Proposed Change ); and WHEREAS, the Applicant submits that the changes proposed in the DRI Modification Application does not constitute a substantial deviation pursuant to the terms of Section (19), Florida Statutes; and the Applicant has provided evidence that such changes do not constitute a substantial deviation under any provision of Section (19), of the Florida Statutes; and WHEREAS, the Northeast Florida Regional Council ( NEFRC ) reviewed the DRI Modification Application, as required by Section , Florida Statutes, and the DRI Modification Application recommends the NOPC does not constitute a substantial deviation; and WHEREAS, the St. Johns County Board of County Commissioners has duly noticed and held a public hearing as required by Section , Florida Statutes, and offered the public and all affected parties an opportunity to be heard and to present evidence; and WHEREAS, the Board of County Commissioners has reviewed the DRI Modification Application, the report and recommendation of the NEFRC, the recommendation of County Staff, and considered the evidence presented and whether the proposed modification constitutes a substantial deviation to the DRI requiring further DRI review at a public hearing held on September 19, 2017 after required notice. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of St. Johns County, Florida that: Section 1. The following facts and conclusions of law are established by clear and convincing evidence to support this Resolution: a. The requested changes to not constitute a substantial deviation pursuant to the terms of Section (19), Florida Statutes, consistent with the recommendation of approval by a July 3, 2017 memorandum by the Northeast Florida Regional Council.

16 b. The changes requested in the DRI Modification Application are consistent with the Land Development Code of St. Johns County, as amended. c. The changes requested in the DRI Modification Application are consistent with and further the objective of the St. Johns County Comprehensive Plan Section 2. The legal description of the property within the Caballos del Mar DRI is attached as Exhibit A to this Resolution. Section 3. The Caballos del Mar DRI Master Plan H is hereby modified by approval of the following specified changes: a. Revise Map H included as Exhibit B to add 1.8-acre County Annex Parcel to the DRI and allow all development rights allocated to the Tour Parcel, Golf Course Parcel and County Annex Parcel to be constructed within the three parcels, as combined, and subject to the uses depicted on Map H. Section 4. The Caballos del Mar DRI Development Order is hereby modified by approving Exhibit C, Land Use Equivalency Table, attached and incorporated to this Resolution, and applicable only to the property subject to this Resolution and described in Exhibit A. Section 5. Except as modified by this Resolution, the existing Caballos del Mar DRI Development Order shall remain in full force and effect. Section 6. A certified copy of this Resolution, complete with all exhibits, shall be rendered by St. Johns County within ten (10) days of its adoption by certified mail, return receipt requested to the Developer, the Florida Department of Economic Opportunity, and the Northeast Florida Regional Council. Section 7. This Resolution shall become effective immediately upon adoption. PASSED AND ADOPTED by the Board of County Commissioners of St. Johns County, Florida, this day of, ATTEST: Hunter S. Conrad, Clerk By: Deputy Clerk BOARD OF COUNTY COMMISSIONERS OF ST. JOHNS COUNTY, FLORIDA By: James K. Johns, Chair

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21 EXHIBIT B Map H Black & White Version

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26 EXHIBIT C Land Use Equivalency Table

27 EXHIBIT "C" CABALLOS DEL MAR DRI - DRI DO AMENDMENT TOUR, GOLF COURSE AND ANNEX PARCELS LAND USE EQUIVALENCY TABLE USE OF THE LAND USE EQUIVALENCY TABLE The Applicant may increase or decrease the amount of a particular land use within the Tour, Golf Course or Annex Parcels portion of the DRI without filing a notice of proposed change, provided that: (a) Such changes are consistent with the Land Use Equivalency Table set forth below. The Land Use Equivalency Table specifies the rate at which Residential Condo/Townhouse uses may be exchanged for Office or Commercial/Retail uses. The Land Use Equivalency Table allows for conversion of all or a portion of the TOUR's 684 vested Residential units. (b) At any time of election of a land use conversion under the Land Use Equivalency Table, the Applicant shall notify, in writing, St. Johns County, the Department of Economic Opportunity ( DEO ), and the Northeast Florida Regional Council ( NEFRC ) of the election at least 30 days in advance of the change. Use of the Land Use Equivalency Table will be reported on an individual and cumulative basis in the project biennial report. Any Notice of Proposed Change ( NOPC ) filed shall incorporate all changes made pursuant to the Land Use Exchange Table prior to the filing of such NOPC. So long as the conversion is consistent with the criteria contained in the Land Use Equivalency Table and no change is made to the Master Development Plan, Map H, no additional DRI approvals shall be required for the conversion. LAND USE EQUIVALENCY TABLE* Commercial / TO: Office (KSF) Retail FROM: (KSF) (KSF) Residential Condo / Townhouse (DU) *The Land Use Equivalency Table only allows conversion from Residential Condo / Townhouse dwelling units to either Office or Commercial/Retail uses. Land Use Residential Condo / Townhouse (DU) Office (KSF) Commercial / Retail (KSF) Net New PM Peak Hour External Trips Quantity of Rate Units (DU or KSF) (trip/unit) Example: Convert 100 DU of Residential to Commercial / Retail 100 x = Residential Dwelling Units is equivalent to KSF Commercial / Retail Convert 100 DU of Residential to Office 100 x = Residential Dwelling Units is equivalent to KSF Office MAXIMUM INCREASES/DECREASES Land Use Maximum Decrease in Residential Units via Conversion (DU's) Maximum Increase in Office Use via Conversion (SF) Maximum Increase in Commerical/Retail Use via Conversion (SF) Quantity , ,390 August 14, 2017

28 EXHIBIT "C" CABALLOS DEL MAR DRI - DRI DO AMENDMENT TOUR, GOLF COURSE AND ANNEX PARCELS LAND USE EQUIVALENCY TABLE PM Peak Hour Trip Generation Estimation Method Gross PM Pk Percentage of Pass-By Average PM Pk Hour ITE Code Land Use Quantity Unit (Rate or Equation) 1 Hour Trip Ends New Trips 2 Trips (vph) Net New Trips (vph) 230 Residential Condo / Townhouse 684 DU's T = 0.52(X) % Office KSF T = 1.49(X) % Commercial / Retail KSF T = 3.71(X) % , ,393 *The Land Use Equivalency Table only allows conversion from residential condo / townhouse dwelling units to either office or commercial/retail uses. Notes: 1 ITE Trip Generation Manual, 9th Edition 2 St. Johns County P.M. Peak Hour Trip Rate and Percent New Trips Data August 14, 2017

29 END OF RECORDED DOCUMENTS SECTION

30 ATTACHMENT 2 APPLICATION AND SUPPORTING DOCUMENTS

31 FORM DEO-BCP-PROPCHANGE-1 Rule 73C , FAC. Effective (Renumbered ) STATE OF FLORIDA DEPARTMENT OF ECONOMIC OPPORTUNITY DIVISION OF COMMUNITY PLANNING & DEVELOPMENT The Caldwell Building, MSC East Madison Street Tallahassee, Florida NOTIFICATION OF A PROPOSED CHANGE TO A PREVIOUSLY APPROVED DEVELOPMENT OF REGIONAL IMPACT (DRI) SUBSECTION (19), FLORIDA STATUTES Subsection (19), Florida Statutes, requires that submittal of a proposed change to a previously approved DRI be made to the local government, the regional planning agency, and the state land planning agency according to this form. 1. I, William J. Schilling Jr., the undersigned owner/authorized representative of PGA Tour, Inc., Tournament Players Association., Inc., Tournament Players Club at Sawgrass Inc. and St. Johns County, hereby give notice of a proposed change to a previously approved Development of Regional Impact in accordance with Subsection (19), Florida Statutes. In support thereof, I submit the following information concerning the Caballos del Mar DRI development, which information is true and correct to the best of my knowledge. I have submitted today, under separate cover, copies of this completed notification to St. Johns County, Florida, to the Northeast Florida Regional Council, and to the Bureau of Community Planning, Department of Economic Opportunity. Date Signature William J. Schilling, Jr., P.E., Authorized Agent for: PGA Tour, Inc., Tournament Players Association., Inc., Tournament Players Club at Sawgrass Inc., St. Johns County

32 2. Applicant (name, address, phone). PGA Tour, Inc. 112 PGA Tour Blvd. Ponte Vedra Beach, Fl Tournament Players Association. Inc. 110 PGA Tour Boulevard Ponte Vedra Beach, Fl Tournament Players Club at Sawgrass Inc. 110 PGA Tour Boulevard Ponte Vedra Beach, Fl St. Johns County 500 San Sebastian View Saint Augustine, Fl Authorized Agent (name, address, phone). William J. Schilling Jr. Kimley-Horn and Associates, Inc Gran Bay Parkway West Suite 2350 Jacksonville, Florida (904) Location (City, County, Township/Range/Section) of approved DRI and proposed change. St. Johns County, Florida 5. Provide a complete description of the proposed change. Include any proposed changes to the plan of development, phasing, additional lands, commencement date, build-out date, development order conditions and requirements, or to the representations contained in either the development order or the Application for Development Approval. This application for Non-Substantial Deviation to the Caballos del Mar Development of Regional Impact ( DRI ) is submitted by PGA Tour, Inc. and Tournament Players Association., Inc., and Tournament Players Club at Sawgrass, Inc. (collectively, the Tour ) and St. Johns County (the County ) to request modification of the Master Development Plan Map (Map H) for certain lands owned by the Tour and the County located within the Players Club Planned Unit Development ( PUD ) portion of the 2

33 Caballos del Mar DRI. The proposed revision to the Master Development Plan include the following: 1. Modifies the Master Development Plan Map H to combine the 1.8-acre St. Johns County Courthouse Annex site (the Annex Parcel ) with lands owned by the Tour and described as the Tour Parcel, as depicted in Exhibits B-4A and B-4B. 2. Consolidates Tour owned parcels (Tour and Golf Course parcels) and the Annex Parcel, and their approved development rights, into one Master Development Plan Map H. 3. Amends the Development Order ( DO ) to add a Land Use Equivalency Table that will allow for the exchange of approved multi-family residential units to commercial (retail or office) square footage within parcels owned by the Tour and County. The proposed Land Use Equivalency Table is added to the DO as an exhibit and is attached to this application as Exhibit C. 4. Extends the termination, build-out, downzoning protection, and construction completion dates for development within the Tour and County-owned parcels subject to this application, in lieu of seeking certain gubernatorial and legislative extensions that have been granted. Commencement of development within the parcels subject to this application has occurred. Therefore, no extension to the commencement date is requested for such parcels. This DRI DO amendment will result in no change to the approved land uses, acreage or densities/intensities within the combined parcels and will not result in a substantial deviation pursuant to the provisions of Subsection (19)(b), Florida Statutes. The Caballos del Mar Development of Regional Impact (DRI) was approved by the St. Johns County Board of County Commissioners on July 8, Minor changes to the DRI were approved in December 1978; May 1980; October 1980; and June A restated Development of Regional Impact Order was approved by St. Johns County Resolution on April 26, Additional modifications were approved by St. Johns County Resolution dated July 26, 1983; a Resolution approved March 13, 1984; Resolution approved May 22, 1984; Resolution approved November 20, 1984; Resolution approved September 24, 1985; Resolution dated November 25, 1986; Resolution approved September 13, 1988; Resolution approved March 12, 2002; Resolution approved October 30, 2007; and Resolution approved November 4, The DRI Development Order as modified by all prior modifications is referred to herein as the Development Order or DO. Indicate such changes on the project master site plan, supplementing with other detailed maps, as appropriate. Additional information may be requested by the 3

34 Department or any reviewing agency to clarify the nature of the change or the resulting impacts. The changes to the project Master Development Plan Map ( Map H ) are shown on the proposed DRI Master Development Plan Map H attached to this application as Exhibit B- 4A and B-4B. The proposed changes to Map H include the following: A. Combines the 1.8-acre Annex Parcel with the Tour-owned Tour Parcel. B. Consolidating Tour-owned parcels (Tour and Golf Course parcels) and the Annex Parcel and their approved development rights into one Master Development Plan Map H. 6. Complete the attached Substantial Deviation Determination Chart for all land use types approved in the development. If no change is proposed or has occurred, indicate no change. The completed Substantial Deviation Determination Chart is attached. 7. List all the dates and resolution numbers (or other appropriate identification numbers) of all modifications or amendments to the originally approved DRI development order that have been adopted by the local government, and provide a brief description of the previous changes (i.e., any information not already addressed in the Substantial Deviation Determination Chart). Has there been a change in local government jurisdiction for any portion of the development since the last approval or development order was issued? If so, has the annexing local government adopted a new DRI development order for the project? April 26, 1983 Resolution July 26, 1983 Resolution May 22, 1984 Resolution November 20, 1984 Resolution April 16, 1985 Resolution September 24, 1985 Resolution November 25, 1986 Resolution September 13, 1988 Resolution November 8, 1994 Resolution March 13, 2002 Resolution October 30, 2007 Resolution November 4, 2014 Resolution There has not been a change in local government jurisdiction for any portion of the development since the last approval or development order was issued. 4

35 8. Describe any lands purchased or optioned within 1/4 mile of the original DRI site subsequent to the original approval or issuance of the DRI development order. Identify such land, its size, intended use, and adjacent non-project land uses within ½ mile on a project master site plan or other map. No lands have been purchased by The Tour within ¼ mile of the DRI as originally approved. 9. Indicate if the proposed change is less than 40% (cumulatively with other previous changes) of any of the criteria listed in Paragraph (19)(b), Florida Statutes. Do you believe this notification of change proposes a change which meets the criteria of Subparagraph (19)(e)2., F.S. YES NO X The proposed change should be determined to be a non-substantial deviation to the previously-approved Caballos del Mar DRI, as amended, because there are no changes in the approved uses, density/intensity, or increase in traffic generation, or any other modification that would create the reasonable likelihood of additional regional impact. 10. Does the proposed change result in a change to the buildout date or any phasing date of the project? If so, indicate the proposed new buildout or phasing dates. Concurrent with the Notice of Proposed Change approved in 2014, via Resolution , the Board of County Commissioners approved a major modification to the Players Club PUD (St. Johns County Ordinance ) for the Tour Parcel, requiring construction commencement to occur within 20 years and construction completion to occur within 25 years of the date of approval of the PUD major modification. Construction on the Tour Parcel commenced in Therefore, the commencement requirement for the PUD has been met. As part of this application and the companion PUD major modification application, the Tour and County propose a similar approach of a 25-year time-frame for the DRI termination, build-out, downzoning protection and construction completion dates for development within the Tour, Golf Course and Annex parcels. Accordingly, a maximum of 25 years from the date of the Board of County Commissioners approval of the subject application will be allowed for construction completion within the Tour and County parcels subject to this application. This approach and associated time extension are being sought in lieu of the gubernatorial and legislative extensions that are available to the applicants by law. Nothing stated herein would prevent the Tour or County from seeking gubernatorial and legislative extensions for the subject parcels that are granted subsequent to the Board of County Commissioners approval of the subject applications. 5

36 11. Will the proposed change require an amendment to the local government comprehensive plan? No, the proposed changes to the DRI do not require an amendment to the St. Johns County 2025 Comprehensive Plan. Provide the following for incorporation into such an amended development order, pursuant to Subsections (15), F.S., and , Florida Administrative Code: Not applicable. 12. An updated master site plan or other map of the development portraying and distinguishing the proposed changes to the previously approved DRI or development order conditions. The changes to the project Master Development Plan ( Map H ) are shown on the proposed DRI Map H attached to this application as Exhibit B-4A and B-4B. The proposed changes to Map H include the following: A. Combines the 1.8-acre Annex Parcel with the Tour-owned Tour Parcel. B. Consolidates Tour-owned parcels (Tour and Golf Course parcels) and the Annex Parcel and their approved uses into one Master Development Plan Map H. 13. Pursuant to Subsection (19)(f), F.S., include the precise language that is being proposed to be deleted or added as an amendment to the development order. This language should address and quantify: a. All proposed specific changes to the nature, phasing, and build-out date of the development; to development order conditions and requirements; to commitments and representations in the Application for Development Approval; to the acreage attributable to each described proposed change of land use, open space, areas for preservation, green belts; to structures or to other improvements including locations, square footage, number of units; and other major characteristics or components of the proposed change; Development within the Tour, Golf Course and Annex parcels shall occur in a single phase, which has already commenced. Build-out of the single development phase shall be allowed to occur up to 25 years from the date of approval of this application. The proposed DRI Map H combines all existing development rights within the 6

37 Tour, Golf Course and Annex parcels and allows such uses to be located within the combined parcels, with certain limitations set for the companion PUD zoning ordinance. A Land Use Equivalency Table is being added to the DO for the Tour and County parcels to allow the conversion of the existing 684 Residential Condo/Townhouse development rights to Office and Commercial/Retail space. b. An updated legal description of the property, if any project acreage is/has been added or deleted to the previously approved plan of development; Updated legal descriptions have been included in this application as Exhibit A. c. A proposed amended development order deadline for commencing physical development of the proposed changes, if applicable; Not applicable as the project has already commenced. d. A proposed amended development order termination date that reasonably reflects the time required to complete the development; Construction within the Tour, Golf Course and Annex parcels shall be completed in accordance with the applicable expiration date(s) of construction approvals, which may be extended upon County staff approval consistent with applicable provisions of the Land Development Code, but in no case shall completion extend beyond 25 years from the date of approval of this application. e. A proposed amended development order date until which the local government agrees that the changes to the DRI shall not be subject to downzoning, unit density reduction, or intensity reduction, if applicable; and Changes to the Tour, Golf Course and Annex parcels within the DRI shall not be subject to down-zoning, unit density reduction or intensity reduction for a period of 25 years from the Board of County Commissioners approval of the subject application, as specified above. f. Proposed amended development order specifications for the annual report, including the date of submission, contents, and parties to whom the report is submitted as specified in Subsection 73C (7), F.A.C. Not applicable. 7

38 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. SUBSTANTIAL DEVIATION DETERMINATION CHART TYPE OF LAND USE CHANGE CATEGORY PROPOSED PLAN Attraction/Recreation # Parking Spaces NO CHANGE # Spectators NO CHANGE # Seats NO CHANGE Site locational changes NO CHANGE Acreage, including drainage, ROW, easements, etc. NO CHANGE External Vehicle Trips NO CHANGE D.O. Conditions NO CHANGE ADA Representations NO CHANGE Airports Runway (length) NOT APPLICABLE Runway (strength) Terminal (gross square feet) # Parking Spaces # Gates Apron Area (gross square feet) Site locational changes Airport Acreage, including drainage, ROW, easements, etc. ORIGINAL PLAN PREVIOUS D.O. CHANGE & DATE OF CHANGE

39 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. SUBSTANTIAL DEVIATION DETERMINATION CHART Airports (cont.) # External Vehicle Trips D.O. Conditions ADA representations Hospitals # Beds NOT APPLICABLE # Parking Spaces Building (gross square feet) Site locational changes Acreage, including drainage, ROW, easements, etc. External Vehicle Trips D.O. conditions ADA representations Industrial Acreage, including drainage, ROW, easements, etc. # Parking spaces Building (gross square feet) # Employees chemical storage (barrels and pounds) Site locational changes NOT APPLICABLE

40 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. SUBSTANTIAL DEVIATION DETERMINATION CHART Industrial (cont.) # External vehicle trips D.O. Conditions ADA representations Mining Operations Acreage mined (year) NOT APPLICABLE Water withdrawal (gal/day) Size of mine (acres), including drainage, ROW, easements, etc. Site locational changes # External vehicle trips D.O. Conditions ADA representations Office Acreage, including drainage, ROW, easements, etc. NO CHANGE Building (gross square feet) Increases in building area will be allowed via a simultaneous decrease in multi-family residential units via the Land Use Equivalency Table.

41 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. Petroleum/Chemical Storage SUBSTANTIAL DEVIATION DETERMINATION CHART # Parking Spaces NO CHANGE # Employees NO CHANGE Site locational changes County Owned Annex Parcel will be combined with the Tour owned Tour Parcel and Golf Course Parcel. # External vehicle trips NO CHANGE D.O. Conditions NO CHANGE ADA representations NO CHANGE Storage Capacity (barrels and/or pounds) NOT APPLICABLE Distance to Navigable Waters (feet) Site locations changes Facility Acreage, including drainage, ROW, easements, ect. # External vehicle trips D.O. Conditions ADA representations Ports (Marinas) # Boats, wet storage NOT APPLICABLE # Boats, dry storage

42 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. Ports (Marinas) (cont.) Dredge and fill (cu. yds.) Petroleum storage (gals.) Site locational changes SUBSTANTIAL DEVIATION DETERMINATION CHART Port Acreage, including drainage, ROW, easements, etc. # External vehicle trips D.O. Conditions ADA representations Residential # Dwelling units Decreases in dwelling units will be allowed to provide for simultaneous increases in commercial (retail or office) building area via the Land Use Equivalency Table. Type of dwelling units NO CHANGE # of lots NO CHANGE Acreage, including drainage, ROW, easements, etc. NO CHANGE

43 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. SUBSTANTIAL DEVIATION DETERMINATION CHART Residential (cont.) Site locational changes County owned Annex Parcel will be combined with the Tour owned Tour Parcel and Golf Course Parcel. # External vehicle trips NO CHANGE D.O. Conditions NO CHANGE Wholesale, Retail, Service Acreage, including drainage, ROW, easements, etc. NO CHANGE Floor Space (gross square feet) Increases in building area will be allowed via a simultaneous decrease in multi-family residential units via the Land Use Equivalency Table. # Parking Spaces NO CHANGE # Employees NO CHANGE

44 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. Wholesale, Retail, Service +(cont.) SUBSTANTIAL DEVIATION DETERMINATION CHART Site locational changes County owned Annex Parcel will be combined with the Tour owned Tour Parcel and Golf Course Parcel. # External vehicle trips NO CHANGE D.O. Conditions NO CHANGE ADA representations NO CHANGE Hotel/Motel # Rental Units NO CHANGE Floor space (gross square feet) # Parking Places # Employees Site locational changes Acreage, including drainage, ROW, easements, etc. # External vehicle trips D.O. Conditions ADA representations R.V. Park Acreage, including drainage, ROW, easements, etc. NOT APPLICABLE

45 Note: If a response is to be more than one sentence, attach a detailed description of each proposed change and copies of the proposed modified site plan drawings. The Bureau may request additional information from the developer or his agent. SUBSTANTIAL DEVIATION DETERMINATION CHART R.V. Park (cont.) # Parking Spaces Buildings (gross square feet) # Employees Site locational changes # External vehicle trips D.O. conditions Open Space (All natural and vegetated nonimpervious surfaces) Preservation, Buffer or Special Protection Areas Preservation (cont.) ADA representations Acreage NO CHANGE Site locational changes Type of open space D.O. Conditions ADA representations Acreage NO CHANGE Site locational changes Development of site proposed D.O. Conditions ADA representations

46 ATTACHMENT 3 Northeast Florida Regional Council Correspondence and Response

47 MEMORANDUM DATE: JULY 3, 2017 TO: FROM: RE: NORTHEAST FLORIDA REGIONAL COUNCIL EXECUTIVE COMMITTEE BRIAN TEEPLE, CHIEF EXECUTIVE OFFICER CABALLOS DEL MAR DEVELOPMENT OF REGIONAL IMPACT NOTICE OF PROPOSED CHANGE (TOUR) The applicant, PGA Tour Inc., Tournament Players Association, Inc., and Tournament Players Club at Sawgrass, Inc. (collectively the Tour ), proposes to make changes to the Master Development Plan (Map H) for the Players Club Planned Unit Development (PUD) portion of the Caballos del Mar DRI. This PUD was originally approved, along with companion modifications to the DRI, in 1999 and subsequently amended in The proposed changes include the following: 1. Modification of Map H to combine the 1.8 acre St. Johns County Courthouse Annex site with lands owned by the Tour as part of the DRI. 2. Consolidation of Tour owned parcels (Tour and Golf Course Parcels) and the Annex parcel and their approved uses into Map H. The practical effect of this proposal is to: a. Add the Courthouse Annex property into the DRI, pending a proposed land swap with the County. b. Predesignate the Golf Course as Mixed-use with the allowable uses of Golf Course, Multi-Family Residential, and Golf Course Related Commercial and Office. It is the NEFRC s understanding this is being proposed to provide for the development of multi-family dwelling units in unspecified non-golf course portions of this parcel. 3. Addition of a new Land Use Equivalency Table that provides for the exchange of approved multifamily residential units and commercial (office and retail). 4. Extension of the termination, build-out, downzoning protection and construction completion dates for development that is the subject of this NOPC. This extension is proposed to be a period of 25 years upon approval of amended DO for this proposal. Recommendation Staff respectfully recommends the Northeast Florida Regional Council Executive Committee approve this staff report.

48 Northeast Florida Regional Council Review of Caballos del Mar Development of Regional Impact Tour Notice of Proposed Change Background The Caballos del Mar Development of Regional Impact (DRI) (n/k/a Players Club and Marsh Landing) was one of the first DRIs approved in Northeast Florida. It was originally developed by Fletcher Land Corporation and was approved by St. Johns County on July 8, 1975 and has been modified 18 times since. When the DRI was approved in 1975, it included development rights for 8,296 residential dwelling units, acres of commercial uses, acres of recreation, acres of community support, acres of resort villas, and acres of roads, creeks and preserve (Attachment 1). In 1978, the DRI's density and uses were modified to include a total of 8,200 residential dwelling units; acres of commercial uses; 1, acres of active and passive recreational; acres of community support; and acres of miscellaneous uses. In 1993 St. Johns County Amended and Restated the Caballos del Mar Development Order (DO) by approving Resolution No which cites "the presently approved total of 7,576 DU's." The DRI's development entitlements were allocated between two separate Planned Unit Developments (PUDs), Marsh Landing and Players Club. Over time, the development of the PUD lands has yielded a much lower density and intensity than allocated to them in their respective PUD ordinances, as amended. Proposed Change The applicant, PGA Tour Inc., Tournament Players Association, Inc., and Tournament Players Club at Sawgrass, Inc. (collectively the Tour ), proposes to make changes to the Master Development Plan (Map H) for the Players Club PUD portion of the Caballos del Mar DRI. This PUD was originally approved, along with companion modifications to the DRI, in 1999 and subsequently amended in The proposed changes include the following: 1. Modification of Map H to combine the 1.8 acre St. Johns County Courthouse Annex site with lands owned by the Tour as part of the DRI. It was noted during the review that the Owners Authorization Form for St. Johns County was unsigned. 2. Consolidation of Tour owned parcels (Tour and Golf Course Parcels) and the Annex parcel and their approved uses into Map H (Attachment 2). The practical effect of this proposal is to: a. Add the Courthouse Annex property into the DRI, pending a proposed land swap with the County. b. Predesignate the Golf Course as Mixed use with the allowable uses of Golf Course, Multi Family Residential, and Golf Course Related Commercial and Office. It is the NEFRC s understanding

49 this is being proposed to provide for the development of multi family dwelling units in unspecified non golf course portions of this parcel. Again, it was noted that the Owners Authorization Form for the Tournament Players Club at Sawgrass, Inc. was also unsigned. 3. Addition of a new Land Use Equivalency Table (Attachment 3) that provides for the exchange of approved multi family residential units and commercial (office and retail). Land use equivalency tables are frequently found in modern DRIs to allow for some flexibility in land use while making any such exchange external trip neutral. 4. Extension of the termination, build out, downzoning protection and construction completion dates for development that is the subject of this NOPC. This extension is proposed to be a period of 25 years upon approval of amended DO for this proposal. Review There are three review standards that are applicable to proposed changes in DRIs: 1. Consistency with the DRI s Development Order Conditions. 2. Consistency with the numerical thresholds in Subsection (19), Florida Statutes. 3. Impacts to Regional resources and facilities not previously reviewed. Consistency with the DRI s Development Order Conditions The proposed change does not violate any condition in the Caballos del Mar Development Order and therefore additional mitigation is not recommended under this review standard. Consistency with the numerical thresholds in Subsection (19), Florida Statutes This proposed change does not exceed the thresholds established in Subsection (19)(b)8., Florida Statutes. Impacts to Regional resources and facilities not previously reviewed Since the proposed development does not exceed the approved amount of development in the Caballos del Mar DRI there are no impacts to regional resources or facilities that were not previously reviewed. No additional mitigation is recommended under this review standard. Observations/Recommendations As noted above, there are two unsigned Owners Affidavit Forms contained in the NOPC. Additionally, the change in the land use designation for the Golf Course to Mixed use, without any specificity as to location of non golf course uses, make meaningful analysis difficult. St. Johns County should await correction of these two issues prior to consideration of approval.

50 Attachment 1 Caballos del Mar Tour DRI NOPC

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52 Attachment 2 Caballos del Mar Tour DRI NOPC

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54 Attachment 3 Caballos del Mar Tour DRI NOPC

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56 July 20, 2017 Brian Teeple, AICP Northeast Florida Regional Council 100 Festival Park Avenue Jacksonville, FL Re: Caballos Del Mar DRI Application for NOPC (Non-Substantial Deviation) Dear Mr. Teeple, Thank you for your thorough review of the Caballos Del Mar Development of Regional Impact Notice of Proposed Change (PGA Tour) and subsequent July 3 rd Memorandum to the Northeast Florida Regional Council Executive Committee. We appreciate your time and effort in meeting with the project team as well as the Executive Committee and would like to take this opportunity to respond to your Observations/Recommendations. In your memorandum, you correctly recognized the fact that there are two unsigned Owners Affidavit Forms in the NOPC application. This has been remedied in that these two forms have now been signed appropriately by St. John County and PGA Tour and are enclosed with this letter. Your other observation identified the lack of specificity as to location of nongolf course uses within the NOPC boundaries. In response, the project team has continued to work with the County in developing an exhibit for use in the PUD Major Modification application that would set a two hundred-foot setback from single family lot lines and one hundred-feet from other golf course lot lines for any use other than golf course or golfrelated commercial and office. The Tour has also specified in the PUD text that multi-family units will only be located within areas of the Golf Course Parcel that are not currently used for golf play. Should you have any questions, please feel free to contact me at (904) or bill.schilling@kimley-horn.com. kimley-horn.com Gran Bay Parkway West, Suite 2350, Jacksonville, FL

57 Page 2 Sincerely, KIMLEY-HORN AND ASSOCIATES, INC. William J. Schilling, Jr., P.E. Senior Vice President Enclosures cc: Jim Triola Phillip J. Mays Matt Phillips Ellen Avery-Smith Mark Shelton kimley-horn.com Gran Bay Parkway West, Suite 2350, Jacksonville, FL

58 ATTACHMENT 4 CORRESPONDENCE

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