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Under the third standard, proportionality, aresort development of, say, three hundred units may well generate a need for beach access across the land so developed because of the population increase, but whether such an access would need to be public, as opposed to "residents only" is Far less certain. 2. The Constitutional Standard Applied Following Nollan, many courts have struck down land development conditions for lack of nexus and/or proportionality. For example, in Art Piculell Group v. Clackamas County, 922 P.2d 1227 (Ore. App. 1996), an Oregon appeals court struck down a road dedication requirement fora 19- lot subdivision even though the county had demonstrated that the county needed the road: "We do not imply that a development cannot have impacts that could warrant improvement conditions that are system wide in scope. However...the determinative factor must be the relationship between the impacts of the development and the approval of the conditions, and not the extent of the public's need for road or other improvements that happen to exist at the time the particular development is approved." (at 1236) In Amoco Oil Co. v Village of Schaumburg, 661 N.E.2d 380 (Ill. App. Ct. 1995), the court struck down a road widening dedication, holding that the taking of 20% of Amoco's land for roadway widening purposes on the basis of a .4% increase in traffic caused by the proposed development "does not correspond with the slightest notions of rough proportionality." 661 N.E.2d at 391. Other examples: Schultz v. City of Grants Pass, 884 P.2d 569 (Ore.App. 1994), striking down a road dedication; Property Group, Inc. v. Planning & Zoning Com'n of the Town of Tolland, 628 A.2d 1277 (Conn. 1993) striking down road widening dedication; Lexington-Fayette Urban County Gov't v. Schneider, 849 S.W. 2d 557 (Ky. Ct. App. 1992), striking down bridge dedication requirement; Cobb v. Snohomish County, 829 P.2d 169 (Wash. Ct. App. 1991), striking down a road improvement fee; Dellinger v. City of Charlotte, 441 S.E.2d 626 (N.C. Ct. App. 1994) striking down a road dedication requirement; Castle Homes & Dev. v City of Brier, 882 P.2d 1172 (Wash. Ct. App. 1994) striking down aper-lot road impact fee. There are literally dozens of additional post-Nollan/Dolan cases striking down various impact fees and exactions for parks, schools, sewers, water and housing where government fails to meet the nexis and proportionality standards imposed by the U.S. Supreme Court. However, the foregoing analysis, which draws only upon road/access cases, should be sufficient to demonstrate the inadequate basis of the Draft General Plan in exacting free access to the beach ,let alone parking, as a condition for coastal resort development approval. There is no connection or nexus between such a coastal resort development and either public parking or beach access. Such a resort development does not drive the need for such parking and access. Moreover, even if it did, the requirement would sorely lack proportionality. The requirement is unconstitutional on its face. 13