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to implement the vision established by the Comprehensive Plan. <br /> Subsequent to their initial enactment, these Land Development <br /> Regulations have been amended on at least two (2) occasions . <br /> The Land Development Regulations, althouah they may also have <br /> been applied by Sunny Isles Beach so as to meet the definition <br /> cf "development order" under §163 . 3164 (7) , are a 'land <br /> development regulation" as set forth at §163 .3213 (2) (b) , <br /> 10 . The Land Development Regulations, as initially enacted <br /> and as amended, are inconsistent with the City' s Comprehensive <br /> Plan for the reasons set forth below: <br /> • By completely failinc to notify and solicit comments <br /> from the Town of Golden Beach with respect to the Land <br /> Development Regulations, which are comprehensive in <br /> scope and which dramatically affect the quality of life <br /> in Golden Beach, and which further affect real property <br /> within 500 feet of the boundaries of the Town of Golden <br /> Beach and the City of Sunny Isles Beach, the <br /> Intergovernmental Coordination Element of the City's <br /> Comp Plan has been violated, specifically Objective 4 ; <br /> • By failing to properly consider the incompatibility of <br /> its Land Development Regulations with the as-built <br /> character of Golden Beach, and by ignoring the impact of <br /> the project on the citizens of Golden Beach, the <br /> approved LDRs contravene the Interaovernmental <br /> Coordination Element cf the Comprehensive Plan in all <br /> material aspects; <br /> • Through its attempt to vest rights in numerous high- <br /> density projects, both unbuilt and built, which were <br /> illegally approved through the City' s administrative <br /> site plan review procedures, the LDRs violate the above- <br /> referenced Intergovernmental Coordination Element; <br /> • The LDR' s "FAR bonus" L <br /> s s stem' + <br /> Y reliance on a monetary <br /> contribution in consideration for increased floor area <br /> ratio (as opposed to onsite design solutions) fails to <br /> "encourage adequate and efficient <br /> provision <br /> of . . . expanded on-site landscaped open space, increased <br /> view corridors and additional public cross access <br /> SHUBIN &4 BASS, P.A. <br />