The Florida Department of Transportation (FDOT) has completed its review of the privately initiated Large Scale Plan Amendment (CPA 25-06ESR). This proposal covers approximately 4,900 acres in the East County area, located east of US 17. In a formal transmittal comments letter to the County, FDOT determined that the amendment may have a "significant adverse impact to transportation resources or facilities of state importance".
FDOT has explicitly requested that the entire amendment package be revised to reflect only the currently approved maximum development rights.
The Limits: The project must be restricted to 6,000 dwelling units, 500,000 sq. ft. of commercial use, and 1,000,000 sq. ft. of regional economic development.
The Warning: FDOT stated that any reference to increasing these maximums must be removed, noting that if they are not, the attached traffic study will be considered "no longer applicable".
Where to find this: See Technical Assistance #1 on Pages 1 and 2.
The state agency found that the Traffic Impact Statement (TIS) provided for the project was fundamentally flawed and must be revised.
Outdated Forecasts: The developer failed to use the required 2050 forecast in their methodology.
Wrong Tables: The study did not use the correct Level of Service (LOS) tables or the proper "Context Classification" for the area.
Ignored Impacts: FDOT noted there was "no coordination or mitigation identified" for the potential impacts on US 17 (Duncan Road), which is a Strategic Intermodal System (SIS) facility.
Where to find this: See Technical Assistance #2 on Page 2.
State law requires that public facilities, like roads, be available concurrently with the impacts of new development.
No Plan Provided: FDOT stated that as proposed, there were no concurrency plans or coordination with FDOT District One.
Required Action: The developer and County staff must coordinate to identify concurrency needs based on the proposed development’s impacts.
Where to find this: See Technical Assistance #3 on Page 2.
Comments Letter from FDOT January 9, 2026
Analysis by David Northcutt, Certified Analytics Professional, presented to Charlotte County.
What is Strategic Intermodal System (SIS)?
In the context of the Florida Department of Transportation (FDOT) report, the Strategic Intermodal System (SIS) is Florida’s high-priority network of transportation facilities that are considered critical to the state's economy and mobility.
Think of an SIS facility as a "Tier 1" roadway or hub that the state prioritizes above all others for funding, maintenance, and safety.
In their comments, FDOT explicitly identifies US 17 (Duncan Road) as an SIS facility. This is significant for several reasons:
Highest State Priority: Because US 17 is part of the SIS, the state has a "compelling interest" in protecting its traffic flow. FDOT is legally required to ensure that new developments do not degrade the performance of these specific roads.
Stricter Standards: SIS facilities have much more stringent "Level of Service" (LOS) standards than local roads. If a development makes an SIS road too congested, the state can effectively block the project until a mitigation plan (like widening the road or adding signals) is funded and approved.
Inter-regional Importance: SIS facilities are intended to move people and goods across long distances (between counties and states) rather than just local neighborhood traffic. FDOT's concern is that the RSAOD development will turn this high-speed "state workhorse" into a congested local street.