Planning board pauses comprehensive-plan EAR review, asks staff to return with clarified legal citations and edits

The Town of Orange Park Planning & Zoning Board on Jan. 9 received a detailed briefing on the statutorily required Evaluation and Appraisal Review (EAR) of the town’s comprehensive plan and voted to continue consideration so staff and the consultant can supply clearer citations and revise draft language.

Tony Robbins, the consultant working with the town, told the board the Community Planning Act requires jurisdictions to evaluate their comprehensive plans roughly every seven years and to transmit the EAR to the Florida Department of Commerce for agency review. Robbins described proposed updates that include population and household projection changes, a residential density bonus policy, codifying the town’s Complete Streets program into the plan, and minor map updates.

Robbins said the draft also incorporates a property-rights element the council adopted in 2022 and clarified that mixed-use designations could be made available more broadly across the town rather than only in target areas. He said changes driven by state law since the plan was last adopted in 2018 were summarized in his cover memo and would be forwarded to state reviewers if the council transmits the EAR.

Board members and members of the public asked detailed questions about multiple items: the exact statutory changes Robbins cited, how a residential-density bonus would operate, definitions for floor-area ratio and development orders, and how mixed-use and zero-lot/clustered development ideas would interface with existing land-development regulations. Board member Johnson pressed for clearer identification of which requirements are mandatory state changes and which are discretionary local policies; Robbins and staff said they would provide explicit references.

Public commenters urged the board to review “shall” language where it appears and to ensure the EAR does not lock the town into policies that residents would not support. Susanna Thompson emphasized that wording such as “shall” carries legal weight; Robbins responded that the comprehensive plan is an umbrella policy document and that many implementation details belong in the town’s land-development regulations.

After extensive discussion and a request from several board members for clearer statutory citations, map labeling, and editorial corrections (for example, updating references from compact fluorescent bulbs to LEDs and clarifying a sidewalk designation along River Road), the board voted to continue action on the EAR to the Feb. 13 meeting so staff can present a redlined draft that highlights state-mandated requirements and the other requested edits. The board recorded the continuation without objection.

Robbins and staff said the next step — if the council approves transmittal — is for staff to send the EAR to the Florida Department of Commerce, which will circulate it to state reviewing agencies (for example, DOT, DEP and the water-management district) for formal objections, recommendations or comments. Robbins said agencies typically return comments in 30–60 days; the council would consider any state comments and could adopt a revised plan later in the year.

Board members asked for an educational workshop or segment at a future meeting to walk through the plan’s structure and explain how the comprehensive plan interacts with the town’s land-development regulations. Robbins and staff agreed to prepare the statutory citations, a redline of changes since the 2018 adoption, definitions for key planning terms, and targeted map-label corrections for the board’s next meeting.