Miami Dade County Community Forum

Friday, September 17, 2010

Krome Avenue: Letter from the UEL's past - October 2002.

Sent to the DCA and Miami Herald:


If widening roads made them safer, South Florida would be one of the safest places to drive on the planet. Unfortunately, adding lanes adds danger, by encouraging the most reckless drivers to set the speed. This fact hasn't stopped a group of development interests in the Redland from pushing to four-lane Krome Avenue, ostensibly in the desire to make the road safer.

The Florida Department of Transportation's own statistics show that the opposite will be the case. When Alligator Alley was widened from two lanes to four, adding a substantial grassy median, the road became much more dangerous. From 1992 to 1997, traffic increased 7%, yet deaths shot up 600%. FDOT's figures show that Alligator Alley is not an isolated case. Throughout the state, two-lane highways are consistently safer than four lane highways.

Yet it is true that Krome Avenue is badly in need of improvement. The road has been the scene of several horrible accidents. That's why FDOT initiated the Krome Avenue Action Plan, a sensible consensus plan developed in 1998 with the participation of farmers, residents and commercial interests along the avenue. That plan calls for a new median, wider lanes and shoulders, and new turning lanes and lighting at critical intersections. It also calls for enforcement of speed limits, which only makes sense: reducing vehicle speed is the single most critical factor in decreasing traffic deaths.

The main difference between the consensus plan and the developers' plan is the addition of two extra lanes. Since the extra lanes would only make the road more dangerous, why add them?

It's an old story that upzoning and development follow road-widening. The story has a one-word name: Sprawl. The state Department of Community Affairs (DCA) has consistently opposed the widening of Krome, because it's outside of the county's Urban Development Boundary (UDB), and because the widening would have an adverse impact on the Comprehensive Everglades Restoration Plan.

In a July 15th letter we received via a public records request, the state Department of Environmental Protection stated their objections this way: "The County has not provided data to support its proposed four-laning of Krome Avenue."

The DCA has presented two official objections to the widening, which reference over a dozen violations of both the Florida Statutes and the Florida Administrative Code. The first objection states that road improvements must be prioritized for areas within the UDB. The second objection deals with the sensitive environmental resources in the area of the road widening, including wetlands and wellfields.

[see below for exact text of objections]

In its attempt to answer the DCA's objections, the county has assured the state that commercial sprawl will be controlled in the wake of the widening--although residential sprawl will not be directly addressed. And tellingly, neither the county nor anyone else has answered the concerns that widening Krome will cause a greater number of fatal accidents, not fewer.

The Urban Environment League opposes the four-laning of Krome Avenue, and supports the consensus plan that can truly make the road safer. South Florida's urban and natural environment both benefit from careful planning that advocates sustainable urban form over sprawl.
A safer two-lane Krome Avenue will preserve the precious agricultural and natural character that exists at the edge of the developed county.

Let's make Krome Avenue safer for strawberry fields, U-pick stands and wetlands--and safer as well for those of us who will be driving on Krome to get to them.

Thank you for your time,

The Urban Environment League


DCA Objection No. 1: Inconsistency with FLUE and
TE Policies and Guidelines:
The amendment does not demonstrate consistency
with CDMP FLUE Policy 2B.
Policy 2B states "Priority in the provision of
services and facilities and
the allocation of financial resources for services
and fucilities in
Miami-Dade County shall be given first to serve
the area within the Urban
Development Boundary (0DB) of the Land Use Plan
(LUP) map. Second priority
shall support the staged development of the Urban
Expansion Area (UEA).
Urban services and facilities which support or
encourage urban development
in Agriculture and Open Land areas shall be
avoided, except for those
improvements necessary to protect public health
and safety and which service
the localized needs of these non-urban areas." The
analysis submitted with
the amendment does not explain why four laning is
necessary to correct
public safety problems or why the previous 1999
Action Plan recommended
improvements would not adequately address the
safety problems. Furthermore,
the supporting analysis does not demonstrate the
proposed four-lane roadway
would serve only localized needs of the non-urban
areas. Rather, if it were
four-laned, Krome Avenue would serve as a regional
facility providing access
beyond the local area. Transportation Element (TB)
Policy 4C reinforces
these provisions, stating that roadways shall
avoid environmental protection
designated areas.

The amendment does not demonstrate consistency
with FLUE Policy 8F which
requires the County to "consider consistency with
the Goals, Objectives and
Policies of all Elements, other timely issues, and
in particular the extent
to which the proposal, if approved, would enhance
or degrade environmental
resources, features or systems (e.g., Everglades
and wellfields) of County
significance." It is clearly stated in the
Agriculture land use category
that in order to protect the agricultural
industry, facilities that support
or encourage urban development are not allowed in
the area. In the absence
of other controlling growth management and land
use policies, the widening
of the segment would support or encourage urban
development in the area that
is outside the UDB.

[Rules 9J-S.005(2)(a), (5) &(8)(J);
9J-5.006(5)(g)2.; 5..; J-5.006(5)(h),
(i)9, (j)6 &19, Florida Administrative Code,
(FAC), and Chapter 163.3 177
(6)(a)-(g), (8) & (l0)(e), Florida Statutes, (F.S)

DCA Objection No.2: The County is proposing new
FLUB Policy 3F as a
safeguard to preserve and protect the
environmental and natural resources,
wellfields, and agricultural lands outside the
UDB. The policy does not
provide predictable and meaningful guidelines to
demonstrate how the
policies will accomplish these outcomes or
expectations and ensure internal
consistency with FLUE Policy 3F and the
Agriculture and Open Land

[Rules: 9J-S.00S(2)(a), (5), (6) & (8)(j),
9J-5.006(5)(g)2., 5.;
9J-5.006(5)(h), (i)(, (j)6 & !9;
(3-5.019(3)(d)(i), F.A..C., and Chapter
163.3177(6)(a) รณ (g), (8) & (10)(e), F.S.]

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