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1988 RESPONSE TO SUFFICIENCY REVIEW COMMENTS ~ . AMENDED DEVELOPMENT of REGIONAL IMPACT APPLICATION for DEVELOPMENT APPROVAL for CHANGES to a PREVIOUSLY APPROVED DEVELOPMENT of REGIONAL IMPACT , .. '. .. ... ". ". II. ". II. M A L L ". ,,, City of Boynton Beach, Florida . .. RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION - .. - .. - Prepared For: Edward J. DeBartolo Corporation .. - .. - .,. Prepared By: - Greiner, Inc. .. ~ .. - November 1988 ... . - -' Greiner Greiner, Inc.. P,O, Box 31646 5601 Mariner Street Tampa. Florida 33630-3416 IB13) 286-1711 FAX: 18131 287-8591 C1519.00 November 22, 1988 Ms. L. Christine Beditz, DRI Coordinator Treasure Coast Regional Planning Council Post Office Box 1529 3228 S.W. Martin Downs Blvd., Suite 205 Palm City, Florida 34990 Reference: Response to Sufficiency Review Comments - Boynton Beach Mall Development of Regional Impact - Substantial Deviation Dear Ms. Beditz: In accordance with the requirements of Chapter 380.06, Florida Statutes, we are transmitting herewith our response to the Treasure Coast Regional Planning Council's Sufficiency Review Comments attached to Mr. Carey's letter of September 14, 1988. For the convenience of the reviewer, we have separated the response by review agency. A copy of each agency's comments is included and is immediately followed by answers to that agency's questions. I In accordance with Regional Planning Council policy, this response also includes revised pages where it was necessary to revise the Application text, tables or exhibits in response to agency review questions. The revised pages, exhibits and tables have been assembled in sets and punched for insertion in your ADA binders. Revised pages include: pages 18-4 and 18-7; the revised exhibits include Map G and Map J-I; the revised tables include Tables 31.1 through 31.21. A revised Exhibit B, which is an attachment to the City of Boynton Beach Annexation Agreement in the Appendix of the original Application, is also included. In addition to the above information, this submittal also includes revised or added transportation reference material which supports the information presented in the revised tables. This includes intersection capacity analyses for Old Boynton Road/Lawrence Road and Boynton Beach Boulevard/I-95. If you have any questions regarding any of the information included herewith, please do not hesitate to contact me. Sincerely, GREINER, INC. '-_ .I)/~ r -..... ~<<-- ~Vl..-~ Thomas A. Marsicano Associate Vice President T AM:sw Enclosures BOYNTON BEACH MALL TRANSMITT AL LIST RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Treasure Coast Regional Planning Council Ms. L. Christine Beditz DRI Coordinator Post Office Box 1529 3228 S.W. Martin Downs Boulevard Suite 205 Palm City, Florida 34990 (305) 286-3313 Ms. Lisa Smith DRI Coordinator Resource Control Department South Florida Water Management District Post Office Box 24680 West Palm Beach, Florida 33416 Department of Community Affairs Mr. Alto Thomas .. Bureau of State Planning 2740 Centerview Drive The Rhyne Building Tallahassee, Florida 32399 (904) 488-4925 Deparfment of Environmental Regulations Ms. Marion Y. Hedgepeth, MS. Environmental Specialist AND Mr. Bruce Offord, Air Permitting South Florida District Department of Environmental Regulation 1900 South Congress A venue - Suite A West Palm Beach, Florida 33406 (305) 964-9668 Department of Transportation Mr. Bruce Seiler, Planning Engineer Florida Department of Transportation District IV 780 S.W. 24th Street Fort Lauderdale, Florida 33315 (305) 522-4244 10 Copies Certified Mail Return Receipt Requested 5 Copies Certified Mail Return Receipt Requested I Copy Certified Mail Return Receipt Requested 2 Copies Certified mail Return Receipt Requested I Copy Certified Mail Return Receipt Requested BOYNTON BEACH MALL TRANSMITTAL LIST RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (continued) Department of Commerce (For non-residential DRI's only) , Ms. Wynelle Wilson Bureau of Economic Analysis Department of Commerce 107 W. Gaines Street Tallahassee, Florida 3230 I (904) 487-2568 Department of Natural Resources: Mr. William Howell Bureau of Biological and Interpretive Services Department of Natural Resources 3900 Commonwealth Boulevard Room 302 Tallahassee, Florida 32303 (904) 488-4892 Palm Beach County Health Department Dr. James P. Howell, Director Post Office Box 29 826 Evernia Street West Palm Beach, Florida 33402 (407) 820-3000 Palm Beach County Planning Ms. Roxanne Manning Palm Beach County 800 13th Street Palm Beach International Airport West Palm Beach, Florida 33406 Palm Beach County Ms. Teresa Cantrell Metropolitan Planning Organization Post Office Box 2429 160 Austrailian Avenue Building #2 (33406) Room 30 I Mr. Carmen Annunziato, City Planner City of Boy ton Beach 120 N.E. 2nd Avenue Post Office Box 310 Boy ton Beach, Florida 33425-0310 I Copy Certified Mail Return Receipt Requested I Copy Certified Mail Return Receipt Requested I Copy Certified Mail Return Receipt Requested 2 Copies Certified Mail Return Receipt Requested I Copy Certified Mail Return Receipt Requested 20 Copies Certified Mail Return Receipt Requested , , DETERMINATION OF INFORMATIONAL SUFFICIENCY FOR BOYNTON BEACH MALL DEVELOPMENT OF REGIONAL IMPACT SUBSTANTIAL DEVIATION APPLICATION FOR DEVELOPMENT APPROVAL Prepared by Treasure Coast Regional Planning Council Staff September 14, 1988 I. Boynton Beach Mall Development of Regional Impact Substantial Deviation Application for Development Approval (ADA) contains insufficient information for the Treasure Coast Regional Planning council to discharge its responsibilities under Subsection 380.06(12), Florida Statutes. II. The information listed below is requested. ouestion 12. PROJECT DESCRIPTION 1. The original Development Order for the Boynton Beach Mall issued by Palm Beach County (Resolution R-74-343) required the developer to "preserve the pine area located on the subject property." This pine area is on "parcel #7," which is the subject on the Annexation Agreement executed between the city of Boynton Beach and the developer on April 7-8, 1988. The preserve area is recognized by the Annexation Agreement. Exhibit A of the Agreement identifies the parcel as being 5.83 acres in size, and this is the figure used throughout the ADA. However, Exhibit B of the Agreement shows an area identified as Parcel 7 as being 6.92 acres in size. There is another notation indicating Canal Right-of-way as 2.36 acres. Is the specific acreage of Parcel 7 approximately 6.92 acres, of which 2.36 acres is Canal Right-of-way, leaving 4.56 acres of pine? Or is 6.92 acres of Parcel 7 the pine area, and 2.36 acres is Right-of-way, making the total acreage of Parcel 7 to be 9.28 acres? Please explain what the figures 5.83 acres, 6.92 acres, and 2.36 acres represent for Parcel 7. ouestion 13. AIR 1. Please respond to Question 13 (AIR) as provided in the ADA at the preapplication meeting (copy attached). If the modeling information is not included within the ADA and review process, it has previously been recommended for inclusion as a condition of the Development Order in order to address air quality concerns in Palm Beach county, which is designated as a nonattainment zone for ozone. Ouest ion 18. VEGETATION AND WILDLIFE 1. The application states that the pine flatwoods on site contain blue stem palmetto (Sabal minor), a species listed by the Florida Department of Agriculture and Consumer services as threatened. However, the habitat description provided in the ADA suggests that this plant may have been misidentified. Is this plant really the silver morph of the saw palmetto (Serenoa reDens)? ouestion 22. DRAINAGE 1. council requires a surface water management system that provides a level of treatment at least equivalent to that provided by retention or detention with filtration of the runoff from the three-year, one-hour storm event or of the first inch of runoff, whichever is greater. using these terms, what level of storm water treatment is currently being provided by the surface water management system on the mall site, and what level of treatment is proposed after the project is completed? 2. council policy requires that post-development runoff volumes not exceed predevelopment runoff volumes for a storm event of three days duration and 25-year return frequency. In these terms, please indicate' what are the pre- and post-development runoff volumes for the entire project site. 3. The Drainage Map (Map G) does not show any outfall water control structures on the two southernmost retention ponds on the east side of the project site. Are there any water control structures on these ponds? If not, please describe where the water flows when these ponds overflow. III. Please respond to all items on the attached Information Adequacy statement from the South Florida Water Management District. Please respond to all items in the attached letters from: 1. Florida Department of Environmental Regulation 2. Palm Beach County Metropolitan Planning organization 3. Palm Beach County Office of the County Engineer 4. Palm Beach County Department of Environmental Resources Management IV. Please provide all information requested in II and III above on revised or new pages for the ADA. All revised or new pages should show the revision date. Provide a cover letter indicating where responses to each question within the text are provided and indicating the nature of the response. Attachments 13. Environment and Natural Resources: Air A. Complete Table 13-A. Please utilize methodology supplied by the Florida Department of Environmental Regulation in their Draft Interim Guidance for Evaluatin the Air Qualit 1m acts of Indirect ources 0 ar on onox e m1SS10n 0 es 1ma e y p ase an In parts per m1ll10n the one-hour and eight-hour carbon monoxide concentrations expected through buildout. Provide a map illustrating the carbon monoxide dispersion modeling study area and locate receptor stations. Modeling assumptions should consider State, federal and local government programmed link and intersection improvements with respect to project phasing. Please provide verification of any assumptions used in modeling which consider such programmed improvements. B. What steps will be taken to reduce emissions and to minimize adverse ai r quali ty impacts? Please specify structural or operational measures that will be implemented by development to minimize adverse air quality impacts. c. What steps will be taken to contain fugitive dust and asbestos particulates in the event demolition of existing on-site structures is proposed? o. Please specify what additional action will be taken, and by whom, if an exceedance(s) of air quality standards occurs as a result of development. _,'2 - '- '" o '" z o - ~ co: ~ z UJ u z o u UJ <:> - x o z i z o '"' co: < u ~ u UJ 6 a: ~ '" .. u '- '" o '" -.:l c: ... '" .. '" ... ~ c. < I M ... .. ~ .0 ... ~ '" .... ... -.:l o E E 0"".... u 0 '" u.... 0 ... c.-.:l ..~ o u.- ......'" '-.0 i:'.c ~ ...u... '" ... '" .. .. u "" "0 c:..... .- :3 "" c: 0 ~ -.:l .... "" ... c: ... .... ..0 .. "e Vl u~ u"e c: "".... '-c ... "" ",u5'" .... 0 0" 0 Vl .... .. V')vtV')~ U "" ~ .. .. "" cu<Uta.:.d: ... .... U '" c....QlU .... ... .. 0 _C"-lG 0 .... a: -J-<CCO ~ Vl - I" - >, u c: ... c. '" u u o '" .. ...~ .0 ..... -....~ .0 ~ ... ... '" .... ..... .. -.:l"e<ll c: ~ e ...>'" c.o", )(""'" UJ~< it TREASURE COAST REGIONAL PLANNING COUNCIL Resoonse to Ouest ion 12: Proiect Descriotion (Treasure Coast Rel!ional Planninl! Council) The original Development Order for the Boynton Beach Mall issued by Palm Beach County (Resolution R-74-343) required as Condition 9, that the pine area located on the subject property be preserved. The original Development Order, however, did not designate acreage of the pine area. The developer proposed to retain 3.41 acres of the original pine area and create .14 acres of additional pine area habit when the L-23 canal is culverted. The total pine area, upon completion of the project, will be 3.55 acres. Parcel 7, which is the subject of the annexation agreement, contains the pine area. Parcel 7, as described in "New Exhibit 'A'" of the agreement, is 5.83 acres. Exhibit "B" should show Parcel 7 as 5.83 acres as opposed to 6.92 acres. The reduction in acreage size from 6.92 to 5.83 acres is a result of R.O.W. dedication of Javert Street. The right-of-way dedication was also a condition of the original development order. The canal R.O.W. is designated in Exhibit "B" as 2.36 acres. The correct acreage for the maintained L-23 canal R.O.W. is 2.79 acres. A corrected Exhibit B (attached) is provided showing Parcel 7 as 5.83 acres and the L-23 canal R.O.W. as 2.79 acres. Resoonse to Ouestion 13: Environment and Natural Resources - Air (Treasure Coast Rel!ional Planninl! Council) At the pre-application meeting held at the Treasure Coast Regional Planning Council on March 8, 1988, it was discussed that the air quality question and associated modeling be included as a condition of the Development Order. The applicant subsequently requested that the air quality analysis be submitted for review as a part of the DR! process, once the transportation analysis was determined to be acceptable, i.e. no major revisions required. Based upon the sufficiency comments received to date, the air quality analysis will be provided subsequent the transportation analysis being determined sufficient or during the second sufficiency round, if required. The response to Question 13 will employ methodology in accordance with the Florida Department of Environmental Regulation's Draft Air Oualitv Imoact Guidelines. (January 1988). The Florida Department of Environmental Regulation (FDER) representative indicated at the pre-application meeting that only roadway links and intersections projected to operate at Level of Service E or F by buildout where improvement to restore their operation to LOS D or better have not been committed to will require modeling and assessment. However, it must be noted that the applicant does not necessarily agree that the results of this analysis are germane to this process since these rules have not properly been implemented (gone through rule making) by FDER, nor have they been properly adopted as a substitute for the air analysis currently required under DR! law, rules, and procedures. Resoonse to Ouestion 18: Vegetation and Wildlife (Treasure Coast Regional Planning Council It is our opinion, based on additional field reviews, literature search and consultation with the University of South Florida, that specimens identified as blue stem palmettos (Sabal minor) occurring on the project site are actually immature cabbage palms (Saba I oalmetto). This is based on field samples which indicate that the petioles are smooth (not armed with spines), the leaf blades have a midrib in the basal portion, and leaf segments are filamentose. Attached are revised pages 18-4 and 18-7, for inclusion in the Amended ADA for the Boynton Beach Mall DR!. 2 ResDonse to Ouestions 22: Public Facilities Drainal!e (Treasure Coast Rel!ional Planninl! Council) 1. In accordance with South Florida Water Management District water quality treatment criteria, the existing surface water management system at the Boynton Beach Mall is designed to detain the runoff from a three-year one hour storm event. This level of treatment is equivalent to that provided by a retention or detention system with filtration. Based on unpublished data obtained by the South Florida Water Management District as part of an ongoing water quality study at the mall, the following treatment efficiencies were measured for storm events which occurred in 1986. Also listed are the average pollutant removal efficiencies for retention systems as presented in Table 5-1 of the draft final Report "An Assessment of Stormwater Management Programs" prepared by Camp Dresser and McKee in 1985. As noted below, the existing stormwater system is providing a level of treatment which is equivalent to what would be expected from a retention or detention with filtration system. Average Pollutant Measured Pollutant Removal Err. Pollutant Removal. 9/6/86 10115/86 1216/86 Total Suspended Solids (TSS) 90% 98% 94% 97% Total Phosphorus 90% 95% 56% 76% Total Dissolved Phosphorus 90% NA NA NA Total Nitrogen 90% NA NA NA Total Kjeldahl Nitrogen NA 84% 18% 43% Nitrite NA 97% 17% 83% NA - Not Available . CDM Report 3 The same level of water quality treatment will be provided after the project is completed. 2. As stated in the ADA, the post development peak discharge for the expansion area will be limited to 62.6 CSM which is the current allowable discharge rate for areas within the C-16 canal basin. Pre versus post development runoff volumes for the entire project site for a 25-year, 72-hour storm event area as follows: Pre-Development Runoff Volume = 107 Acre-feet Post-Development Runoff Volume = 104 Acre-feet 3. The two southernmost retention ponds on the east side of the project are connected with existing culverts. Both ponds are within the east drainage basin and outfall is through the existing east basin control structure to the C-16 canal (see attached revised Map G). 4 Jonn R. Wodralka. Executive Director Tilford C. Cr.... Deputy Executive Director ~.- .----.-.--. r:'f;' ? ~ IN REPLY REFER TO: ]i .... SEP 15 1988 - Via Purolator Courier September 14, 1988 T;::,._ 1 ~~ -".~; ~:~:::!:Al rl,;........J ~C:;~.JfL L. Christine 8editz, DRI Coordinator Treasure Coast Regional Planning Council 3228 SW Martin Downs Boulevard, Suite 205 Palm City, FL 33490 Dear Ms. Bejitz: au.. Subject: Boynton Beach Mall SFWMD DRI No. 88-289 First Sufficiency Review District staff have reviewed the Application for Development Approval the Boynton Beach Mall Development of Regional Impact, and determined following areas require additional information and/or clarification: Question 22: Public Facilities: Drainage 1. Commercial projects are required by the District to provide dry pretreatment. How will dry pretreatment be provided for the Sears retail store and automotive repair facilities additions to the Boynton Beach Mall? to amend that the If dry pretreatment cannot be provided, what provisions can be made in order to ensure that runoff from areas where hazardous materials are used and stored will not enter the surface water management system? 2. The applicant has proposed 1500 linear feet of 60" diameter culvert to replace the relocated section of the Lake Worth Drainage District's L-23 canal. How was the size of the culvert derived? How were potential off-site and upstream impacts considered? Were impacts to unpermitted drainage systems evaluated? 3. Please provide documentation from the Lake Worth Drainage District that demonstrates their knowledge and acceptance of the relocation of a section of L- 23 and the replacement of same with 1500 linear feet of culvert, as described in the Application for Development Approval. Nancy H. Aoen Chairman. Plantation J.D. York Vice Chairman - Palm City Nathaniel P Reed Hobe Souna Oscar M. Corbin, Jr Fl. Myers Arsenio Mihan MiamI Fritz Stein Belle Glade James F Gamer Ft Myers Mike Stout Windermere Doran A. Jason Key Biscayne L. Christine Beditz September 14, 1988 Page 2 If you have any Questions regarding the review of the Boynton Beach Mall DR!, Program Manager. South Florida Water Management District's please contact Lisa Smith, DR! Review Sincerely, >f~L~~ Supervising Professional Land Development Review Resource Control Department SJL/lsc cc: Thomas A. Marsicano . . ~~ ,,-~....~ +~~\ !~,..\ : ,- ,I~\ ~ 1'/., <<'(51 Q "11,.~ '--' ..' 9,:1,.: ~/ ~)i;W . ~ 41 '....<4rr 01 ~o..~ Florida Department of Environmental Regulation Southeast Districtel900 S. Congress Ave.. Suite AeWest Palm Beach. Flond2 33..06e..0"'.960+-9608 Bob M2rtinc::z, Governor Dale lWachtmann. Secretary John She:arer. AsSISClnt Sccrcary Scon Benvon. Deputv :\sslSlam SC'crearr September 6,l988 Ms. L. Christine Beditz Treasure Coast Regional Planning Council 3228 S.W. Martin Downs Blvd., Suite 205 P.O. Box l529 Palm City, Florida 33490 Subject: Boynton Beach Mall-Amended ADA _:--ttt":t', . 'y , , ... ..-'" , . ~.... "" I ..j , ..- Dear Christine: I have reviewed the Amended Appliication for Development Approval (dated August l5, 1988) referenced above and have the following comments: l. Public Facilities: Drainage. The relocation and culverting of Lake Worth Drainage District Canal L-23 will require a DER Dredge and Fill Permit. In the review of your Dredge and Fill Permit Application, the Department will examine the loss of habitat and possible water quality degradation. I would suggest that you apply for the application concurrently with your proposed amendment changes. If you have any further questions regarding the Department's comments, please feel free to call me at (407)964-9668 or SUNCOM #22l-5005. Sincerely, ....--..... Marion Y. Hedgepeth I DRI Coordinator MYH:mh:88 cc: South Florida Water Management District, Lisa Smith Thomas A. Marsicano, Greiner, Inc. Rob Robbins, Palm Beach County, DERM SOUTH FLORIDA WATER MANAGEMENT DISTRICT & FLORIDA DEPARTMENT OF ENVIRONMENT AL REGULATION Resoonse to Ouestion 22: Public Facilities: Drainage (South Florida Water Management District) 1. Dry pre-treatment is not included as a part of the storm water management system serving the Boynton Beach Mall. In accordance with the District's Basis of Review, assurances will be provided to ensure that hazardous materials do not enter ,the surface water management system. As stated in the ADA, the Sears automotive facility will incorporate above ground storage facilities to temporarily store waste oils, and surface impoundment area to store batteries. Waste oils and spent batteries will be removed periodically by a licensed private contractor for recycling. 2. The proposed culvert enclosure was sized to pass the design flow for this reach of the L-23 canal without increasing headwater stages at Javert Street. The calculations are included with the Surface Water Management Permit modification which was submitted to the District on September 27, 1988. 3. Lake Worth Drainage District approval of the canal relocation and enclosure will be obtained prior to construction. L.W.D.D. staff has conceptually reviewed and concurred with the use of a 60 inch diameter RCP culvert. Resoonse to Ouestion 22: Public Facilities: Drainage (Florida Deoartment of Environmental Regulation Letter) A dredge/fill application for the relocation and filling of the L-23 Canal was submitted to the Department on August 18, 1988. 5 METROPOLITAN PLANNING ORGANIZATION OF PALM BEACH COUNTY '60 Australian Avenue. SUIte 301. West Palm Beach, Flonda 33406 Tel (305) 684-41 70 September 12, 1988 ~-_.~ ---~-------~.:-.'\ ); - "EP 1 ',' ""'8 ;:; _ J i.::id Ms. L. Christine Beditz,DRI Coordinator Treasure Coast Regional Planning Council P. O. Box 1529 Palm City, Fl 34990 T' .~ "~~.::.1~1. h_. r-...~.l'.""" 101... ...i,,,,,iL Subject: Boynton Beach Mall Development of Regional Impact Substantial Deviaiton Dear Chris: The staff of the Metropolitan Planning Organization has reviewed the amended Development of Regional Impact Application for Development Approval for the Boynton Beach Mall and offers the following comments for your consideration. MaDs J-2 and J-3 Map J-2, 1988 Average Annual PM Peak Hour Traffic Volumes, should include all links that are significantly impacted by the development. For instance, Mil itary Trail between Old Boynton West Road and Hypoluxo Road is significantly impacted by the Boynton Mall (between 5 and 11 percent) and should therefore be i ncl uded in the analysi s. General Comments Palm Beach County and the MPO accept the Ci rcul ar 212 as the standard procedure for analyzing intersection capacity. It is suggested that the Region's recommendations for development approval include those improvements required to maintain Level of Service C based on the Circular 212 analysis. I trust these comments will be helpful to you. Sincerely Yours, , I Teresa P. Cantrell Senior Planner cc: S. Shannon C. Walker P Q. Boll. 2429, West Palm Beach, Flonda 33402-2429 METROPOLITAN PLANNING ORGANIZATION OF PALM BEACH COUNTY Map J-2, 1988 Average Annual PM Peak Hour Traffic Volumes, should include all links that are significantly impacted by the development. For instance, Military Trail between Old Boynton West Road and Hypoluxo Road is significantly impacted by the Boynton Mall (between 5 and 11 percent) and should therefore be included in the analysis. Map J-2 includes existing mall traffic, passer-by traffic, and background traffic, for the average annual condition, at the Mall Access Points. Map J-I depicts the regional significant studied roadways, which does include Military Trail between Old Boynton West Road and Hypoluxo Road. This link is identified as links MI and M2 in all applicable analysis tables. Palm Beach County and the MPO accept the Circular 212 as the standard procedure for analyzing Intersection Capacity. It is suggested that the region's recommendations for development approval include those improvements required to maintain Level Of Service C based on the Circular 212 Analysis. Greiner maintains that the analysis techniques set forth in the 1985 Highway Capacity Manual are appropriate. These procedures are now the accepted standard for design and review of improvements for all state and federal projects. They are also reported to be the basis of roadway capacity criteria published by TCRPC for use in DRI analysis. Board of County Commissioners Carol :\. Roberts, Chair Carol J. Elmquist, Vice Chairman Karen T. ~ larcus Dorothy Wilken Jim Watt County Admiaistratol Jan Winters Ms. L. Christine Beditz DRI Coordinator Treasure Coast Regional Planning Council 3228 S.W. Martin Downs Blvd. Suite 205 - P.O. Box 1529 Palm City, Florida 34990 SUBJECT: BOYNTON BEACH MALL DRI SUBSTANTIAL DEVIATION Department of Eugineerin~ and Public Works H.. F.. Kah1crt County Engineer r- '-''-<;-,~'''''~'.j~' ' _..:01'" . I ~, r., . ..- ,... r. S;p ~. 3. 1~8~ ",;~\ Tr-' ..... ....-~...T ""~""...,,, r.l.~...,:.....::' ,,-, ... ...__~J..u... "L '. I'""...;>H i ....i'.~.-4.. v"........., Dear Ms. Beditz: The Palm Beach County Traffic Division has reviewed the substantial deviation application for development approval (ADA) for Boynton Beach Mall and would like to submit the following comments for your consideration: Table 31.1 & 31.2 1. The source for the "Total ADT" volumes shown in these tables is cited as "Palm Beach County.. These volumes do not, however, correspond to any published by the County for either the 1987 or the 1987-88 year. No 1988 year ADTs have yet been published. 2. The diamond interchange critical movement analysis program should be used to analyze the I-95/Boynton Beach Blvd. intersection. 3. How was "mall peak hour volume" derived for each existing roadway 1 ink? 4. "Daily capacity. should be shown at LOS 'C., not LOS 'E' and .peak hour capacity" at LOS 'D', not LOS 'E'. This will allow for direct comparison with accepted Treasure Coast Regional Planning Council (TCRPC) standards. 5. Lawrence Road (Boynton Beach Bl vd. to Lantana Rd.) is on the County's Thoroughfare Plan and should be considered in the analysis. Also, the section of Old Boynton Road between Congress Ave. and Boynton Beach Blvd. should be considered since it acts as a collector road and provides a short cut to the Mall from 1-95. 6. Some of the existing peak hour link volumes which were factored from turning movements appear low when compared with adjacent road segments and with County data on file. For example, the following links all show peak hour volumes that are only about 6% or less of daily vol umes (rather than something closer to the 9% average experienced throughout Palm Beach County): "An Equal Opportunity. Affirmative Action Employer" BOX 2429 WEST PALM BEACH, flORIDA 33402-2429 (407) 684-4000 page 2 Congress Ave. (south of Golf Rd.) Military Trail (south of Boynton Beach Blvd.) Boynton Beach Blvd. (west of Military Trail) Boynton Beach Blvd. (Military Trail to Winchester Park Blvd.) Boynton Beach Blvd. (Old Boynton Rd. to 1-95) Woolbright Rd. (Congress Ave. to 1-95) Table 31.7 7. What turn lane improvement is recommended by the Circular 212 Method for the "eastbound" movement at the Congress and Old Boynton intersection? Table 31.9 8. The roadway annual growth rates in this table are incorrectly calculated because the historical AOTs shown do not represent a one- year growth period. What is shown as the "1988 AOT" in the table is, in fact, the 1987-88 AOT and represents only 6 months growth from the "1987 AOT". The consultant therefore needs to double all of the growth rate percentages shown in order to derive growth for a 12-month period. It would be preferable, however, to consider a longer historical time period as a more accurate (minimizing the impact of unusual yearly fluctuations) basis upon which to derive growth rates. The County requires that a 3 year time period be considered in significant project traffic studies done pursuant to Ordinance 87- 18 (Traffic Performance Standards). In any event, the consultant will need to rework Table 31.9 and change Tables 31.5 and 31.6 accordingly. MaD J-S 9. It does not seem realistic for a "Regional Mall" of this size to draw only 17.8" of its traffic from 1-95. In fact, the rapidity with which traffic disperses on this map appears to be more characteristic of a neighborhood or community shopping center than a regional mall. The application of the NCHRP Report #187 gravity model distribution technique should be adjusted in recognition of the type of shopping trip attraction that a "regional mall" represents and in consideration of the market areas of competing regi ona 1 malls. Table 31-13 10. The "mall expansion traffic" of LOS 'C'" column should be changed to "mall expansion traffic" of LOS '0'" for the peak hour because LOS '0' is the TCRPC peak hour standard. page 3 Your transmittal of this report for our comments is appreciated. Please do not hesitate to contact me if you have any questions. Sincerely, OFFICE 0 THE COU~f ENGINEER ~/1 -/;/ L.- Allan A. Ennis, P.E. Development Review Engineer AAE:te cc: Randy Whitfield, P.E., Director, Palm Beach County MPO Carmen Annunziato, AICP, Planning Director, City of Boynton Beach file: SID - DeBartolo Mall DEPARTMENT OF ENGINEERING AND PUBLIC WORKS OF PALM BEACH COUNTY Table 31.1 & 31.2 1. The source for the "Total ADT" volumes shown ,in these tables is cited as "Palm Beach County". These volumes do not, however, correspond to any published by the County for either the 1987 or the 1987-88 year. No 1988 year ADTs have yet been published. The reviewer is correct. The counts were provided by the Palm Beach County MPO, and simply indicated as Palm Beach County Counts. A copy of these counts are appended. Tables 31.1 and 31.2 have been revised accordingly. The ADT counts were adjusted upwards where appropriate due to the fact that 1988 counts reportedly covered only the first half of the year. 2. The diamond interchange critical movement analysis program should be used to analyze the I-95/Boynton Beach Blvd. intersection. Tables 31.3, 31.4, 31.7, 31.8, 31.15, and 31.16 have been revised to reflect the reanalization of the signalized intersection sf Boynton Beach Boulevard and 1-95 as a diamond interchange. 3. How was "mall peak hour volume" derived for each existing roadway link? Existing "Mall Peak Hour Volume" was derived based on existing mall driveway turning movement counts appropriately adjusted for season variation to correspond with existing roadway counts and the gravity model developed using procedures outlined in the National Cooperative Highway Research Program (NCHRP) Report #187 - "Quick Response Urban Travel Estimation Techniques." 4. "Daily capacity" should be shown at LOS "C", not LOS "E" and "peak hour capacity" at LOS "D", not LOS "E". This will allow for direct comparison with accepted Treasure Coast Regional Planning Council (TCRPC) standards. Tables 31.1, 31.2, 31.5, 31.6, 31.10, 31.13, 31.14, and 31.17 have been changed to reflect the change in "Daily Capacity", shown at a LOS "C" service volume, for the average annual condition and at a LOS "D" service volume for the peak season condition, and the change in "Peak Hour Capacity" to a LOS "D" service volume for both average annual and peak season conditions. 5. Lawrence Road (Boynton Beach Blvd. to Lantana Rd.) is on the County's Thoroughfare Plan and should be considered in the analysis. Also, the section of Old Boynton Road between Congress Ave. and Boynton Beach Blvd. should be considered since it acts as a collector road and provides a short cut to the Mall from 1-95. Map J-I and Tables 31.1, 31.2, 31.3, 31.4, 31.5, 31.6, 31.7, 31.8, 31.10, 31.13, 31.14,31.15, 31.16,31.18 31.19, 31.20, and 31.21 have been revised to include Lawrence Road. The section of Old Boynton Road between Congress A venue and Boynton Beach Boulevard, is not a regionally significant roadway (not on the County's thorough fare plan) therefore, the most conservative distribution of project traffic was through the intersection of Boynton Beach Boulevard and Congress A venue. 6. Some of the existing peak hour link volumes which were factored from turning movements appear low when compared with adjacent road segments and with County data on file. For example, the following links all show peak hour volumes that are only about 6% or less of daily volumes (rather than something closer to the 9% average experienced throughout Palm Beach County): [C-81 - Congress Ave. (south of Golf Rd.) (M-4) - Military Trail (south of Boynton Beach Blvd.) [B-II - Boynton Beach Blvd. (west of Military Trail) [B-2) - Boynton Beach Blvd. (Military Trail to Winchester Park Blvd.) [B-51 - Boynton Beach Blvd. (Old Boynton Rd. to 1-95) [W-l) - Woolbright Rd. (Congress Ave. to 1-95) 2 In addressing this comment, the reviewer is first directed to the comment where roadway link identifiers (C-S, M-4, etc) have been added. It is important to note that, with the exception of link B5, ill of the roadway links listed fall outside of the study of this analysis. On a regional level, project traffic on links C-8, M-4, B-1, B-2 and w- I account for less than 5% of the applicable existing level of service service volumes for both the daily and peak hour conditions during the average annual and peak season analysis analysis periods. The same situation exists when the City of Boynton Beach local criteria is examined, i.e. Palm Beach County 1% threshold. These links were provided solely on an informational basis to identify the limits of the analysis area. However, the relationship between the daily traffic volumes reported and the peak hour traffic volumes counted are provided below. In addition, the a copy of the daily traffic counts used in this analysis, as supplied by the Palm Beach County MPO, is appended. Addressing the links in order, the link C-8 daily volume was obtained from the nearest count station (5602-2), located immediately north of Lake Ida Road, approximately 2-1/2 miles south of Golf Road. As a result, directly determining a "K" based on a illustrative AOT is not appropriate in this case. The M-4 link daily volume was based on an appropriately located county count station (5608-2). However counts at this location have varied significantly up and down over the last five years ('83-11510, '84-12092, '85-17007, '86-14991P and '87-21012). This variation suggests that the count data obtain over the last few years may not be reliable. Assuming the data from 1983 to 1986 is valid and projecting 1988 daily volume based on this growth rate would yield a daily volume of roughly 16,500 and a "K" of 8.0%. 3 Along New Boynton Beach Boulevard three locations warrant review and comment. Link B-1 daily volumes were based on county station 5611-1 where the exact location of the station west of Military Trail is not known and traffic count data has significantly varied up and down over a three year period from 8,924 to 13,040, with no growth indicated over the past two years. However, to present a conservative analysis a growth rate was assumed and an artificially high existing volume was reported. This process lead to a low "K" when the inflated daily volume is used to derive the "K", again direct comparison of daily and peak hour traffic is cautioned at this location. Due to the significantly negative growth identified by county counts at stations 5613-1, the daily volume used for link B-2 was the same as that used for link B-3 (5601-2). It must be recognized that this is more than likely a higher daily volume than would normally be expect along link B-2 and thus results in the low "K" when directly applied. Link B-5 presents perhaps the most interesting contradiction in daily count volumes. The peak hour volumes taken by Greiner at 1-95 and Old Boynton West Road and the Congress Avenue count obtained from the county were compared to determine if significantly different peak hour volumes were indicated. The counts compared extremely well. However, the county counts at stations 5301-2 (B-6), 5201-2 (B-5) and 5615-1 (B-4) indicate significant higher traffic at location B-5, the middle link, and rather consistent volumes at B-6 and B-4. If it is assumed that the higher volume along link B-5 is attributable to the presence of Old Boynton West Road, than the resulting "K" for this road is four to five percent when the unexplained link B-5 daily traffic volume increase (10,000 to 13,000) is assigned to Old Boynton West Road. Given the questionable nature of the B-5 daily traffic volume, caution is again 4 recommended when calculating a "K" and determining it to be low when upstream and downstream peak hour volumes are comparable and there corresponding "K" are within an acceptable range. Finally, the link W-I daily volume was obtained from a count station (5205-2) located immediately west of 1.95 and at a distance of approximately one mile east of Congress A venue. It appears unreasonable to evaluate a peak hour volume ("K") based on a daily traffic count which may not accurately reflect the actual daily traffic volume where the peak hour traffic count was conducted. 7. Table 31.7 - What turn lane improvement is recommended by the Circular 212 Method for the "eastbound" movement at the Congress and Old Boynton intersection? Table 31.7 has been revised to show an eastbound left turn lane improvement at Old Boynton Road and Congress Avenue, based on the Circular 212 procedure. 8. Table 31.9 - The roadway annual growth rates in this table are incorrectly calculated because the historical ADTS shown do not represent a one-year growth period. What is shown as the "1988 ADT" in the table is, in fact, the 1987-8g ADT and represents only 6 months growth for a I2-month period. It would be preferable, however, to consider a longer historical time period as a more accurate (minimizing the impact of unusual yearly fluctuations) basis upon which to derive growth rates. The County requires that a 3 year time period be considered In significant project traffic studies done pursuant to Ordinance 87-18 (Traffic Performance Standards). In any event, the consultant will need to rework Table 31.9 and change Tables 31-5 and 31-6 accordingly. Table 31.9 shows the roadway growth rate for the background traffic. Where appropriate 1988 base counts were increased to reflect a full years growth, prior to projecting future year growth based on these volumes. These rates were derived using 1987 and 1988 mid-year counts. Although these growth rates may only represent 5 six months growth, the actual growth rate used on our studied roadways is actual much high, due to the addition of 'Other Projects' traffic to the background traffic. The following table provide an example of the actual background growth used on Congress Avenue and Boynton Beach Boulevard. ACTUAL GROWTH RATES USED 1988 Background 1989 Background PM Peak Hour Volume PM Peak Hour Volume Percent Increase Average Peak Average Peak Average Peak Link Annual Season Annual Season Annual Season C3 2,779 2,864 3,599 3,642 29.5 27.2 C4 2,883 2,983 3,665 3,770 27.1 26.4 C5 2,750 2,837 3,582 3,676 30.2 29.6 B3 2,028 2,085 2,243 2,305 10.6 10.6 B4 2,277 2,426 2,743 2,846 20.4 17.4 B5 2,386 2,553 2,747 2,924 15.1 14.5 The following table shows the historic (1985 to 1987) Florida Department of Transportation AADT counts. FDOT HISTORICAL AADT COUNTS FDOT Percent Growth Count Station LocationI 1985 1986 1987 Per Year 285 Boynton Beach Blvd. N/A 29,077 27,384 Negative East of Congress Ave. 58 Boynton Beach Blvd. N/A 17,826 16,615 Negative East of Military Trail 2,196 1-95 North of 80,816 85,975 99,491 11.5 Boynton Beach Blvd. 2,195 1-95 South of 80,529 113,113 107,534 16.8 Boynton Beach Blvd. I No count locations on Congress Avenue within the study area. 6 As shown in the above table Boynton Beach Boulevard shows no growth, and we used an actual growth rate of approximately 15 percent. 9. Man J-5 - It does not seem realistic for a "Regional Mall" of this size to draw only 17.8% of its traffic from 1-95. In fact, the rapidity with which traffic disperses on this map appears to be more characteristic of a neighborhood or community shopping center than a regional mall. The application of the NCHRP Report #187 gravity model distribution technique should be adjusted in recognition of the type of shopping trip attraction that a "regional mall" represents and in consideration of the market areas of competing regional malls. A copy of the gravity model was included in the transportation appendix which accompanied the ADA. The model accurately represents the Boynton Beach Mall market area as delineated by the applicant. The market area, or primary trade area as it is more typically referred to in the retail industry, is influenced by a number of factors such as population density, average household income, travel time, distance, and competitive centers. The competitive centers which directly influence the trade area of this mall include: Palm Beach Mall; Town Center of Boca Raton; and Worth Avenue. The trade area is also influenced to some extent by the abundance of community and neighborhood shopping opportunities within the general area. The gravity model was also ground truthed based on the actual directions of approach and departure of existing project traffic at each of the mall access points. As a result, the gravity model accurately reflects the trade area, the presence of competitive and alternative shopping opportunities in the area and relies on the actual approach and departure patterns of mall patron at each of the project access points. 10. Table 31-13 - The "mall expansion traffic % of LOS "e" column should be changed to "mall expansion traffic % of LOS "D" for the peak hour because LOS "D" is the TCRPC peak hour standard. Please refer to footnote #6 of Table 31.13 a indicated. The LOS "C" column referred to in the reviewer's question was provided at the request of the City of Boynton Beach 7 to ensure that the study area included all roadway links applicable under the Palm Beach County Transportation Impact Fee Ordinance study criteria. The column has no bearing on the TCRPC criteria or DRI review process. The regional (TCRPC) study area is based on 5% of the appropriate LOS service volume for the overall project, while impact fee criteria applies only to the mall expansion and in this case a differing LOS standard at a 1% threshold. 8 Board, of County Commissioners County Administrator Join \\'inters Carol :\. Roberts, Chair Carol J. Elmquist, Vice Chairman Karen T. ~Iarcus Dorothv \\iilken Jim Watt Department of Environmental Resources Management September 12, 1988 [,,'?,''??1~~ ~ :" .' ~~ ~~ -~ \' r . f\' :~.' '1 '.... SEP 14 1988 Mr. Daniel M. Cary, Executive Director Treasure Coast Regional Planning Council 3228 S.W. Martin Downs Boulevard Suite 205, P.O. Box 1529 Palm City, Florida 34990 Tl"",,,.~-= ~""T "1'~1!l".L ~'"'........ ,....~.oi ft.... All rj.ri.~~~.J ~~~iima.- ._~ Dear Mr. Cary: The Palm Beach County Department of Environmental Resources Management (ERM) has reviewed the substantial deviation Application for Development Approval (ADA) for the Boynton Beach Mall Development of Regional Impact (DRI). We have no objection to the modification of the mall to allow the construction of an additional anchor department store. However, we do oppose the proposed reduction of the pine flatwoods preserve, located in the northwest corner of the site, to accommodate the additional parking estimated by the applicant to be needed for the operation of the new store. We believe that a parking garage could be constructed to provide the necessary number of parking spaces without the destruction of a significant portion of the pine preserve. Previous Palm Beach County Actions Related to the Proposed Project In our previous letter to you on this project, dated April 14, 1988, we stated our position that the pine flatwoods tract should be preserved, as required in the original development order issued by the Palm Beach County Board of County Commissioners (Development Order Resolution No. R-074-343, issued on Hay 7, 1974). We further noted that previous plans for the mall proposed by the applicant indicated the potential for construction of a parking garage, and recommended that this option be investigated as part of the substantial deviation review process. Residents of the Pine Acres subdivision, which is located immediately west of the mall and the pine preserve, appeared before the Board of County Commissioners on May 10, 1988 to express their concerns regarding the possible loss of the preserve. At that time, members of the Board expressed their support for continued preservation of the preserve and stated their intent to support the requirements for the preservation of the pine tract in the County's review of the ADA. Therefore, we wish to reaffirm our continued support for the preservation of the entire pine flatwoods tract in its present location. Potential for Settinq of a Precedent Allowing the destruction of a portion of the preserve at the Boynton Beach Mall site could set a precedent for the loss of portions or all of future 3111 SOUTH DIXIE HWY" SUITE 146 WEST PAL.\! IlE,~CH, HORIDA 33+05 (407) 820.40 II SUNCO.\t 245.4011 Hr. Daniel H. Cary Page 2 September 12, 1988 preserves set aside as conditions for the approval of future ORIs, if the developers or owners decide they need more space for other uses. Unless such conditions are adhered to in perpetuity, such areas are not truly preserved. Effects of the Proposed Reduction of the Pine Flatwoods Preserve According to the information presented in Table 12.2 of the ADA, 42% of the existing pine flatwoods area would be removed to permit the relocation and cUlverting of Canal L-23 and the development of additional parking spaces. The removal of this portion of the existing pine flatwoods ecosystem would result in the loss of that amount of habitat for the species of wildlife that presently live, feed, or breed on the site. The disturbance caused by the removal of the vegetation and the relocation of the canal also could result in the elimination of some of these species permanently from the site, because there is no adjacent area from which replacement animals can repopulate the amount of the preserve remaining. The disturbance of the soil structure and composition of the area to be cleared could prevent some species of plants or animals from repopulating the site, because some of the soil- or plant-related conditions or factors they require as part of their environment might no longer be present. The value of the remaining habitat for wildlife would be reduced because of the decrease in the total size of the preserve. It also is likely that the vegetation remaining would function less efficiently as a visual screen and buffer to reduce the noise and visual impacts on the Pine Acres subdivision than the present preserve, due to the reduction in the width of the buffer area, and thus the density of the vegetative community. Additionally, the disturbance and subsequent replanting activities could favor the invasion of the disturbed area by nonnative species. Although 2.42 acres of the present pine flatwood area would be developed, only 0.l4 acres would be replanted with pine trees. This is approximately 5.8% of the area lost, or a 0.06-1.0 mitigation ratio -- a very low rate. Projects that involve mitigation for habitat loss typically provide. at a minimum, one acre of replacement habitat for every acre of existing habitat destroyed or degraded. The shrubs, grasses, and herbs, which constitute a significant portion of the vegetation on the site and provide food and other habitat needs for wildlife, would not be replaced. Although it is stated in the ADA that three pine trees would be replanted for everyone lost, the increased number of trees does not compensate for the lost acreage of habitat, and in fact may not be desirable because of the density of the planting and the likely even- age status of the trees to be used. The species diversity of the site (number of species present and variety of types of species) and the structural diversity of the plant community would be reduced. The loss of this diversity would reduce the value of the site for wildlife. Any additional vegetation to be planted to the east of the relocated canal probably would function more as landscaping for the parking area than as habitat or a food source for the animals of the pine preserve or a visual buffer to the residential subdivision. Landscaping is not replacement of lost habitat. Mr. Daniel M. Cary Page 3 September 12, 1988 The variety of ages of trees also could be reduced. Animals need trees and plants of different ages at different times of the year for feeding, breeding, nesting, etc. Dead trees (known as snags) are a natural part of the pine flatwoods ecosystem; they provide perching, nesting, and denning sites for a variety of animal species, as well as habitat for insects that are an important food source for many species. Species that require snags may no longer be able to use the site. Use of Nonnative Landscape Plants The significant deviation application indicates that the right-of-way along Javert Street, on the western border of the pine preserve, would be planted with pong am (Ponqamia pinnata) trees, a species not native to Florida. This landscaping activity is not desirable if a natural preserve area is to be maintained. It would reduce the residents' view of the native vegetation and is likely to facilitate the introduction of other nonnative plants and animals. If the pine flatwoods area is intended to be a preservation area for native vegetation and wildlife habitat, nonnative species such as pongam should not be planted on the site. Also, some authorities state that pongam seeds are poisonous if consumed; therefore, it would be advisable not to use this species where the seeds would be accessible to small children. such as adjacent to a single-family residential subdivision. Problems Due to Lack of Adequate Site Maintenance It is noted in the significant deviation that the pine flatwood area has been used as an illegal dump, apparently for a number of years, and that debris and waste ranging from trash and tree trimmings to an auto.obile chassis is present. Regardless of the extent of the pine preserve, this material should be removed by the owners or operators of the mall, and the area checked periodically to ensure that it is being maintained in a state conducive to the preservation of the habitat value of the natural ecosystem. It should not be degraded in quality through use as a waste disposal site. Ecoloqical Value of the Pine Preserve Although the pine preserve has not been identified as a high-quality native ecosystem in the Inventory of Native Ecosystems being conducted by consultants for Palm Beach County, it is one of the last remaining tracts of pine flatwoods in the central and south-central sections of the county. Therefore, it provides valuable habitat for wildlife because of the scarcity of this type of habitat in the county. The Florida Natural Areas Inventory has ranked this ecosystem as vulnerable to extinction, both statewide and globally, because of the relatively small amount that remains. \ Kr. Daniel M. Cary Page 4 September 12, 1988 Recommendations for Conditioning of the Development Approval The significant deviation application does not consider alternatives to the removal of a portion of the pine preserve. such as the provision of the required parking elsewhere on the mall site. One alternative that should be considered is the construction of a parking garage, preferably in a portion of the mall site away from the preserve, so that the noise and other impacts associated with the garage would not adversely affect the preserve and its component species. We recommend that the development approval be conditioned to require the preservation of the existing pine flatwoods preserve in perpetuity, the maintenance of the preserve to prevent waste-related problems, and the construction of a parking garage. Thank you for the opportunity to comment on the ADA. ~athleen Brennan of my staff at (407) 820-4011 if you regarding our comments. Please contact me or have any questions Sincere~y yours~, 1 (0 II c 6 . . ( / ~!:i,-t\""(.'-1' C'- v.-~u...~ Richard E. Walesky, Director cr Environmental Resources Management cc: Commissioner Karen Marcus Commissioner Carol Roberts Commissioner Carol Elmquist Commissioner Dorothy Wilken Commissioner James Watt Jan Winters. County Administrator Sam Shannon. Assistant County Administrator Ms. Rebecca Martin. Pine Acres Dr. Frederick Cichocki, Coalition for Wilderness Islands RESPONSE TO PALM BEACH COUNTY DEPARTMENT OF ENVIRONMENTAL RESOURCES MANAGEMENT LETTER TO TREASURE COAST REGIONAL PLANNING COUNCIL SEPTEMBER 12, 1988 Previous Palm Beach Countv Actions Related to the Pro Dosed Proiect The original D.O. Condition referencing the pine flatwood area states that the developer "preserve the pine area located on the subject property," not that it be designated or dedicated as a preserve. This area was zoned CG-General Commercial along with the balance of the property. The proposed plan retains 3.41:t acres or 58% of Parcel 7 which includes the "pine area" referred to in the original D.O. The precise acreage of the pine flatwood area located within the 5,83 acre area (Parcel 7) has not been determined. Residents of the Pine Acres subdivision have appeared before the City Council on April 5, 1988 and at a neighborhood meeting conducted by the Applicant on November 10, 1988, to express their concerns of the subject area and adjacent canal. The Applicant will attempt to incorporate their concerns and suggestions as much as possible in a revised native landscape buffer plan. A list of those residents of the Pine Acres subdivision and other interested City or County residents who attended the recent neighborhood meeting is included in this response. The Applicant requests that a list of those Pine Acre residents attending the Board of County Commissioners on May 10, 1988 be provided for inclusion in the Sufficiency Response. Potential for Setting of a Precedent The pine flatwood area was not indicated as a high quality native ecosystem by the Inventory of Native Ecosystems for Palm Beach County nor has it been designated as a conservation area or area of significant environmental concern by either the City of Boynton Beach Comprehensive Plan or the Palm Beach County Land Use Map. Parcel 7 has remained as designated in the County Land Use Plan as Medium to Medium High Residential with a zoning designation of General Commercial. The Applicant is proposing that the remaining area of Parcel 7 be designated as a recreational area in accordance with the recommendation of the City of Boynton Beach's Comprehensive Plan 1986 Technical Report. The removal of a portion of the pine flatwood area does not set a precedent for the loss of all or future areas which are dedicated preserve areas by definition of their environmental significance since it was never actually dedicated as a "preserve" or conservation area. The retention of 58% of Parcel 7, which includes the pine flatwood area, is in excess of current TCRPC policy requiring the retention of 25% of native upland habitat. Effects of the Prooosed Reduction of the Pine Flatwoods Preserve The replanting of the .14 acres in pine habitat community is a result of the culverting of the L-23 canal. The Applicant concurs that the reduction of the pine area will result in a similar reduction in habitat. However, the loss of habitat should not greatly influence the current existing species' diversity of the site and structural diversity of the community. There is no reason to speculate that species located in that portion of the site lost will not migrate to the remaining adjacent habitats. 2 The removal of exotic species which has become established in approximately I acre of the 5.83 acre parcel is required by the Treasure Coast Regional Planning Council. The subsequent replanting of native upland habitat is anticipated to enhance and increase that portion of the pine flatwood area lost as a result of the invasive exotic monoculture community. The re-vegetation of this area and proposed replanting activities, coupled with an environmentally sensitive maintenance program should prevent the re-invasion of the disturbed area by exotic species, as well as prevent the continued invasion of exotic species into the existing pine area. All portions of the pine area are to be maintained in a natural state including the retention of dead trees (snags) and brush material. Use of Non-native Landscaoe Plants The proposed landscape buffer along the Javert Street right-of-way will be revised to incorporate native species typical of pine flatwoods. Additional consideration has been directed towards those species which are attractive to wildlife. Problems Due to Lack of Adeouate Site Maintenance The proposed landscape and buffer plan for the pine flatwood area will insure that the area is not continually used as a convenient and illegal dumping ground. The plan which will include fencing of the subject site will enable the area to be restored and maintained in a more natural condition. 3 Ecoloeical Value of the Pine Preserve The proposed landscape buffer plan and maintenance program, the restoration of the pine area lost due to exotic species, the prevention of exotic species invasion further into the pine area, and the cessation of illegal and potentially hazardous dumping activities will benefit the community in terms of neighborhood enhancement and will restore a degraded natural system. 4 BOYNTON BEACH MALL PROPOSED EXPANSION NEIGHBORHOOD MEETING NOVEMBER 10, 1988 Virginia Driscoll Greiner, Inc. Tom Marsicano Greiner, Inc. Dick Greco DeBartolo Corp. Ken and Joan Herndon 3513 Lothair Ave. Stella Rossi 625 Whisperings Pine Rd., Boynton Bch. Janet Hofmeister 3593 Kitely Ave., Boynton Bch. Mike Houbill and Jim Kerstin 3606 Kitely Ave., Boynton Bch. Nicky Hartless 3603 Oberon Ave., Boynton Bch. Jim Houbrick 3600 Kitely Ave., Boynton Bch. Mary McCullough 3545 Oberon Ave., Boynton Bch. Robert Pendleton 3546 Oberon Ave., Boynton Bch. Joanne Davis Florida Native Plant Society (Palm Beach Chapter) 4060 Westview Ave. Lake Worth, FL Steve Farnsworth 7080 Hypoluxo Farms Rd., Lake Worth