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Item Q55 CM ounty of onroe BOARD OF COUNTY COMMISSIONERS  Mayor Heather Carruthers, District 3 Mayor Pro Tem George Neugent, District 2 TheFloridaKeys Danny L. Kolhage, District 1 David Rice, District 4 Sylvia J. Murphy, District 5 County Commission Meeting May 18, 2016 Agenda Item Number: Q.5  Agenda Item Summary #1608 BULK ITEM: DEPARTMENT: No Planning/Environmental Resources TIME APPROXIMATE:STAFF CONTACT: Michael Roberts (305) 289-2502 3:00 P.M. PUBLIC HEARING AGENDA ITEM WORDING: An ordinance by the Monroe County Board of County Commissioners amending the Tier Overlay District Map designation from Tier I to Tier III for property owned by Longstock II, LLC, legally described as lots 1, 2, 3, 4 and 5, block 1; lots 1 through 18 block 2, Sam-N-Joe Subdivision Plat Book 3 Page 76 of the public records of Monroe County Florida and lots 1 through 9, block 3, Darios Subdivision Plat Book 3 Page 92 of the public records of Monroe County Florida; having real estate numbers 00300090-000000; 00300180- 000000; 00300590-000000 and 00300670-000000; providing for severability; providing for the repeal of inconsistent provisions; providing for the transmittal to the State Land Planning Agency and the Secretary of State; providing for amendment to the Tier Overlay District map and providing for an effective date. ITEM BACKGROUND: The requested Tier Overlay District map amendment is consistent with the adopted (5/18/2016) 00300090-000000; 00300180-000000; 00300590-000000 & 00300670-000000 from Tier I to Tier III. The parcels consists of a developed RV Campground historically containing 130 documented units, consisting of 125 transient units and 5 market rate units (Letter of Development Rights Determination dated 9/29/2014). The subject parcels are developed land outside existing deer corridors (HCP Figure 5.2) and do not meet the criteria for Tier I designation as provided in Policy 205.1.1, MCC §130-130 or the Habitat Conservation Plan. In addition, the subject parcels are not indicated to have significant deer utilization or distribution as depicted in Figures 2.1 and 2.4 of the HCP. The parcels are not within or adjacent to Lower Keys marsh rabbit habitat as depicted in Figure 2.2 of the HCP. On October 21, 2105 the U.S. Fish & Wildlife Service provided correspondence in which they supported the request to amend the Tier designation from Tier I to Tier III. 4EGOIX4K 5 At its regularly scheduled meeting on July 28, 2015, the Monroe County Development Review Committee reviewed the proposed amendment. The information provided in the staff report and Commission and Board of County Commissioners. At its regularly scheduled meeting on August 26, 2015, the Monroe County Planning Commission reviewed the proposed amendment. The information provided in the staff report and discussed at the County Commissioners. PREVIOUS RELEVANT BOCC ACTION: The LCP was completed in August 2004 adopted by the Board of County Commissioners on August 18, 2004 and is incorporated by reference into the Monroe County 2010 Comprehensive Plan by Policy 101.20.2(1). The LCP was amended in June 2009 (Ordinance 020-2009) to revise certain figures to depict only the lands covered by the HCP; to implement the ROGO requirements of the HCP; to define the number of dwelling units to be permitted over the life of the Incidental Take Permit (ITP), including the limitations on Tier I development; to establish certain control dates for development and mitigation; and to regulate the construction of fences and accessory structures. The Board of County Commissioners adopted Ordinance 022-2012 on September 21, 2012 to amend the Livable CommuniKeys Program Master Plan for Future Development of Big Pine Key and No Name Key , to amend the Tier designation on Figure 2.1 (Tier Map for Big Pine Key and No Name Key), and Table 2.7, Institutional Uses, for the Seacamp property from Tier I to Tier Ill, as directed by the Board of County Commissioners in Resolution 562-2003. The Board of County Commissioners transmitted the associated LCP Text amendment to this proposed map amendment to the State Land Planning Agency on October 21, 2015. CONTRACT/AGREEMENT CHANGES: N/A STAFF RECOMMENDATION: Staff recommends adoption of the proposed tier amendment as the subject parcels do not meet the criteria for Tier I designation and are more appropriately designated Tier III in accordance with criteria of Section 130-130(d), the HCP and the LCP. DOCUMENTATION: Sea Horese RV Tier Overlay Map Ordinance Sea Horse Tier Ordinance Map Sea Horse Tier Overlay Map amendment Staff Report FINANCIAL IMPACT: Effective Date: Expiration Date: Total Dollar Value of Contract: 4EGOIX4K 5 Total Cost to County: Current Year Portion: Budgeted: Source of Funds: CPI: Indirect Costs: Estimated Ongoing Costs Not Included in above dollar amounts: Revenue Producing: If yes, amount: Grant: County Match : Insurance Required: Additional Details: REVIEWED BY: Mayte Santamaria Completed 04/27/2016 7:14 PM Steve Williams Completed 05/02/2016 9:56 AM Jaclyn Carnago Completed 05/03/2016 8:43 AM Christine Hurley Completed 05/03/2016 9:05 AM Michael Roberts Completed 05/03/2016 9:50 AM Mayte Santamaria Completed 05/03/2016 9:55 AM Kathy Peters Completed 05/03/2016 10:05 AM Board of County Commissioners Pending 05/18/2016 9:00 AM 4EGOIX4K %XXEGLQIRX7IE,SVIWI6:8MIV3ZIVPE]1ET3VHMRERGI 7IE,SVWI6:8MIV3ZIVPE](MWXVMGX1ET %XXEGLQIRX7IE,SVIWI6:8MIV3ZIVPE]1ET3VHMRERGI 7IE,SVWI6:8MIV3ZIVPE](MWXVMGX1ET %XXEGLQIRX7IE,SVIWI6:8MIV3ZIVPE]1ET3VHMRERGI 7IE,SVWI6:8MIV3ZIVPE](MWXVMGX1ET 5G MEMORANDUM MCP&ERD ONROE OUNTY LANNING NVIRONMENTAL ESOURCES EPARTMENT We strive to be caring, professional and fair  To: The Monroe County BOCC   Mayté Santamaria, Senior Director of Planning & Environmental Resources 7KURXJK From: Michael Roberts, Sr. Administrator, Environmental Resources Date: April 21, 2106 Subject: Request for an Amendment to the Tier Overlay District (Zoning)Map from Tier I to Tier III, Longstock II, LLC, Vacant Land, Big Pine Key, having real estate no. 00300090-000000; 00300180-000000; 00300590-000000 & 00300670- 000000 (File 2015-035) Meeting: May 18, 2016 1 2 IREQUEST 3 4 A request to amend the tier designation for Parcel # 00300090-000000; 00300180-000000; 5 00300590-000000 & 00300670-000000 from Tier I to Tier III. 6 7 8 Subject Parcels (outlined in blue) (2012) 9 10 2015-035 pg. 1 4EGOIX4K 5G 1 IIBACKGROUND INFORMATION & RELEVANT PRIOR COUNTY ACTIONS 2 Site Information 3 4 Address: 201 County Road, Big Pine Key 5 Legal Description: Lots 1, 2, 3, 4 and 5 Block 1; Lots 1 through 18 Block 2 Sam-N-Joe 6 Subdivision Plat Book 3 Page 76 of the Public Records of Monroe County Florida and 7 Lots 1 through 9, Block 3, Darios Subdivision Plat Book 3 Page 92 of the Public Records 8 of Monroe County Florida. 9 Real Estate (RE) Numbers: 00300090-000000; 00300180-000000; 00300590-000000 & 10 00300670-000000 11 Applicant: Longstock II, LLC 12 Size of Site: 3.93 acres 13 Land Use District(s): IS (North ½) and URM (South ½) 14 FLUM Designation: RM (North ½) and RH (South ½) 15 Tier Designation: I 16 Flood Zone: AE - 8 17 Existing Use: Sea Horse RV Campground 18 The parcel consists of a developed RV Campground containing 130 documented units, 19 consisting of 125 transient units and 5 market rate units (Letter of Development Rights 20 Determination dated 9/29/2014). 21 Existing Vegetation / Habitat: Scarified; Developed Land 22 Community Character of Immediate Vicinity: The surrounding community is a mix of dense 23 residential development interspersed with sparsely developed and undeveloped areas. The 24 adjacent land use (zoning) districts consist of IS, URM and SR land use districts. 25 26 On March 19, 2003 the Monroe County Board of County Commissioners (BOCC) 27 approved Resolution 119-2003 authorizing submittal of the Habitat Conservation Plan for 28 Key Deer and other protected species on Big Pine Key and No Name Key (HCP). 29 On December 17, 2003 the BOCC passed Resolution 562-2003 approving the Livable 30 Communikeys Master Plan (LCP) for Big Pine Key and No Name Key as the policy 31 document to direct growth and development of Big Pine Key and No Name Key. The 32 LCP implements the HCP as well as provides for the development needs of the 33 community. 34 The LCP was completed in August 2004 adopted by the Board of County Commissioners 35 on August 18, 2004 and is incorporated by reference into the Monroe County 2010 36 Comprehensive Plan by Policy 101.20.2(1). 37 The LCP was amended in June 2009 (Ordinance 020-2009) to revise certain figures to 38 depict only the lands covered by the HCP; to implement the ROGO requirements of the 39 HCP; to define the number of dwelling units to be permitted over the life of the Incidental 40 Take Permit (ITP), including the limitations on Tier I development; to establish certain 41 control dates for development and mitigation; and to regulate the construction of fences 42 and accessory structures. 2015-035 pg. 2 4EGOIX4K 5G 1 The Board of County Commissioners adopted Ordinance 022-2012 on September 21, 2 2012 to amend the Livable CommuniKeys Program Master Plan for Future 3 Development of Big Pine Key and No Name Key , to amend the Tier designation on 4 Figure 2.1 (Tier Map for Big Pine Key and No Name Key), and Table 2.7, Institutional 5 Uses, for the Seacamp property from Tier I to Tier Ill, as directed by the Board of 6 County Commissioners in Resolution 562-2003. 7 8 The Board of County Commissioners adopted Ordinance 022-2012 on September 21, 9 2012 to amend the Livable CommuniKeys Program Master Plan for Future 10 Development of Big Pine Key and No Name Key , to amend the Tier designation on 11 Figure 2.1 (Tier Map for Big Pine Key and No Name Key), and Table 2.7, Institutional 12 Uses, for the Seacamp property from Tier I to Tier Ill, as directed by the Board of 13 County Commissioners in Resolution 562-2003. 14 15 The Board of County Commissioners transmitted the associated LCP Text amendment to 16 this proposed map amendment to the State Land Planning Agency on October 21, 2015. 17 DRC Review 18 19 At its regularly scheduled meeting on July 28, 2015, the Monroe County Development 20 Review Committee reviewed the proposed amendment. The information provided in the staff 21 approval to 22 the Planning Commission and Board of County Commissioners. 23 PC Review 24 25 At its regularly scheduled meeting on August 26, 2015, the Monroe County Planning 26 Commission reviewed the proposed amendment. The information provided in the staff report 27 and discussed at the meeting supports the decision to recommend 28 approval to the Board of County Commissioners. 29 30 31 IIIPROPOSED AMENDMENT 32 33 Request to -000000; 00300180-000000; 34 00300590-000000 & 00300670-000000 from Tier I to Tier III (Exhibit I) 35 36 2015-035 pg. 3 4EGOIX4K 5G 1 2 3 4 5 6 2015-035 pg. 4 4EGOIX4K 5G Review of Amendment 1 2 3 The Tier Maps for Big Pine Key and No Name Key has been developed based on relative 4 wildlife habitat quality as defined in the Habitat Conservation Plan (HCP). Monroe County 5 developed the Tier Maps pursuant to county-wide Smart Growth Initiatives adopted in Goal 6 105 of the Comprehensive Plan and Strategy 1.1 of the LCP. 7 8 9 operates under the assumption that avoiding and minimizing impacts to Key deer habitat, will 10 also provide direct protection to both populations and habitats of other terrestrial species. In 11 the development of the HCP, the ecology and population dynamics of the Key deer was 12 studied for three years and a Population Viability Analysis (PVA) model, including a spatial 13 component, was produced to evaluate the impacts of development scenarios on the Key deer 14 population. Based on the Key deer studies done for the HCP and the resulting spatial model, 15 16 deer habitat. Tier 3 lands are the lowest quality Key deer habitat. Most of the parcels in Tiers 17 2 and 3 are interspersed among developed parcels and among canals. These areas provide 18 19 20 er are wide ranging and utilize virtually all available habitat 21 22 indicate the utilization or distribution of Key deer, during the 3 year study period, within or 23 adjacent to the subject properties but it is not as significant as other locations. (Pg. 20 Habitat 24 Conservation Plan). 2015-035 pg. 5 4EGOIX4K 5G Approximate location of subject parcels 1 2 3 Figure 2.2 of the HCP provides the Lower Keys marsh rabbit habitat, as identified by the 4 U.S. Fish and Wildlife Service. This figure displays the Lower Keys marsh rabbit habitat on 5 Big Pine Key and No Name Key (Faulhaber 2003) based on the most recent data on its 6 distribution within the covered area (Figure 2.2). Figure 2.2 does not indicate Lower Keys 7 marsh rabbit habitat within or adjacent to the subject properties. (Pg. 23 Habitat Conservation 8 Plan). 9 10 11 12 13 14 15 16 17 Approximate location 18 of subject parcels 19 20 21 22 23 2015-035 pg. 6 4EGOIX4K 5G 1 Lastly, Figure 2.4 depicts the 6 grid layers used to generate the weighting factor for the final 2 carrying capacity grid. The deer corridor deer density, house density and distance from US1 3 parameters reflect low utilization of the subject properties by Key deer. 4 5 6 7 8 9 For the Big Pine Key and No Name Key planning area the Tier Maps are intended to be 10 based upon habitat sensitivity identified in the HCP, primarily as represented on the weighted 11 Harvest Grid Map (Figure 2.5 of the HCP, below). 12 2015-035 pg. 7 4EGOIX4K 5G Approx. Location of Subject Parcels 1 2 Harvest Grid Map (Figure 2.5 of the HCP) 3 (darker shades = higher value for deer) 4 5 6 The subject parcels are developed land outside existing deer corridors (HCP Figure 5.2, 7 below) and do not meet the criteria for Tier I designation as provided in Policy 205.1.1, MCC 8 §130-130 or the Habitat Conservation Plan, as noted below: 9 10 11 HCP Figure 5.2 Key deer corridor across Sands Subdivision 12 2015-035 pg. 8 4EGOIX4K 5G 1 2 Sands corridor with subject parcels in blue 3 4 The HCP describes the habitat description and associated H values that should be reflected in 5 the Tier designation. These descriptions are provided in Table 2.7 (below). 6 Table 2.7 (HCP pg. 43) Tier classification system (vacant privately-owned lands) 7 Tier Description Lands where all or a significant portion of the land area is characterized as environmentally sensitive and important for the continued viability of HCP covered species (mean H per -3 1 10x10 meter cell = 0.259 x 10). These lands are high quality Key deer habitat, generally representing large contiguous patches of native vegetation that provide habitat for other protected species as well. Scattered lots and fragments of environmentally sensitive lands that may be found in platted -3 subdivisions (mean H per 10 x10 meter cell = 0.183 x 10). A large number of these lots are 2 located on canals and are of minimal value to the Key deer and other protected species because the canal presents a barrier to dispersal. Scattered lots within already heavily developed areas that provide little habitat value to the -3 Key deer and other protected species (mean H per 10x10 meter cell = 0.168 x 10). Some of 3 the undeveloped lots in this Tier are located between existing developed commercial lots within the US-1 corridor or are located on canals. 8 9 The proposed amendment is consistent with the above Tier descriptions. The site is -3 10 developed and the mean H value per 10 x 10 meter cell is 0.000182 (0.182 x 10). 11 12 13 2015-035 pg. 9 4EGOIX4K 5G 1 2 Sea Horse RV Park RE # H Area (square feet) (10m X 10m) 00300090-000000 0.0044 26,910 0.00017491 00300180-000000 0.0148 96,048 0.00016538 00300590-000000 0.0084 42,435 0.00021257 00300670-000000 0.0015 5,589 0.00029043 3 4 5 subject parcel contains no native habitat and supports 130 lawfully established units. The 6 amount of H impact for this type of development is based on traffic generation because 7 vehicle collisions with Key deer are the most important human-related cause of mortality for 8 the Key deer (HCP page 41). Based on the average daily trip assumptions in the HCP (9.5 9 ADT/unit), the 130 units developed on the site generate 1,235 average daily trips (ADT). 10 11 The subject parcels lie partially within the IS land use district (north ½) and partially within 12 the URM land use district (south ½). The corresponding FLUM designations are Residential 13 Medium (RM) on the north and Residential High (RH) on the south. There is no change 14 15 platted, the four parcels consisted of 32 platted lots. 16 SR 60 IS 61 SC 1' URM 6, SR 60 Land Use District Map Future Land Use Map (FLUM) 17 18 19 2015-035 pg. 10 4EGOIX4K 5G Consistency of the proposed amendment with the provisions and intent of the Monroe 1 County Land Development Code: 2 3 Staff has determined that the proposed tier overlay district (zoning) map amendment is 4 not inconsistent with the provisions and intent of Section 130-130 of the Monroe County 5 Land Development Code. 6 7 Sec. 130-130. Tier Overlay District 8 9 (a) Purpose. The purpose of the tier overlay district is to designate geographical areas 10 outside of the mainland of the county, excluding the Ocean Reef planned development, 11 into tiers to assign ROGO and NROGO points, determine the amount of clearing of 12 upland native vegetation that may be permitted, and prioritize lands for public 13 acquisition. The tier boundaries are to be depicted on the tier overlay district map. Lands 14 on Big Pine Key and No Name Key shall be delineated as tier I, II, or III. Lands in the 15 remainder of the unincorporated county, excluding the Ocean Reef planned development, 16 shall be delineated as tier I, III, and III-A (special protection area). 17 18 (b) Tier boundaries. Tier boundaries shall follow property lines wherever possible, 19 except where a parcel line or distinct geographical feature, such as a canal or roadway, 20 may be more appropriate. 21 22 (c) Tier boundary criteria, excluding Big Pine Key and No Name Key. The tier 23 boundaries are designated using aerial photography, data from the Florida Keys Carrying 24 Capacity Study, the endangered species maps, property and permitting information and 25 field evaluation. The following criteria, at a minimum, are used to evaluate upland 26 habitats and designate boundaries between different tier overlays: 27 28 (1) Tier I boundaries shall be delineated to include one or more of the following 29 criteria and shall be designated tier I: 30 a. Vacant lands which can be restored to connect upland native habitat 31 patches and reduce further fragmentation of upland native habitat. 32 b. Lands required to provide an undeveloped buffer, up to 500 feet in 33 depth, if indicated as appropriate by special species studies, between 34 natural areas and development to reduce secondary impacts. Canals or 35 roadways, depending on width, may form a boundary that removes the 36 need for the buffer or reduces its depth. 37 c. Lands designated for acquisition by public agencies for conservation 38 and natural resource protection. 39 d. Known locations of threatened and endangered species, as defined in 40 section 101-1, identified on the threatened and endangered plant and 41 animal maps or the Florida Keys Carrying Capacity Study maps, or 42 identified in on-site surveys. 43 e. Conservation, native area, sparsely settled, and offshore island land use 44 districts. 45 f. Areas with minimal existing development and infrastructure. 46 2015-035 pg. 11 4EGOIX4K 5G 1 (d) Big Pine Key and No Name Key tier boundary criteria. The tier boundaries shall be 2 designated using the Big Pine Key and No Name Key Habitat Conservation Plan (2005) 3 and the adopted community master plan for Big Pine Key and No Name Key. 4 The parcels in question are developed land outside existing deer corridors (HCP 5 Figure 5.2, below) and do not meet the criteria for Tier I designation as provided in 6 MCC §130-130 or the Habitat Conservation Plan. In addition, the subject parcels 7 are not indicated to have significant deer utilization or distribution as depicted in 8 Figures 2.1 and 2.4 of the HCP. The parcels are not within or adjacent to Lower 9 Keys marsh rabbit habitat as depicted in Figure 2.2 of the HCP. 10 11 12 13 14 Figure 5.2 Key deer corridor across Sands Subdivision 15 16 2015-035 pg. 12 4EGOIX4K 5G 1 2 Sands Corridor with Subject Parcels in blue. 3 Consistency of the proposed amendment with the Principles for Guiding Development in 4 the Florida Keys Area of Critical State Concern pursuant to F.S. Chapter 380.0552(7). 5 6 7 For the purposes of reviewing consistency of the Land Development Code or any 8 amendments to the Code with the principles for guiding development and any amendments to 9 the principles, the principles shall be construed as a whole and no specific provision shall be 10 construed or applied in isolation from the other provisions. 11 12 (a) To strengthen local government capabilities for managing land use and development 13 so that local government is able to achieve these objectives without the continuation of 14 the area of critical state concern designation. 15 (b) To protect shoreline and marine resources, including mangroves, coral reef 16 formations, seagrass beds, wetlands, fish and wildlife, and their habitat. 17 (c) To protect upland resources, tropical biological communities, freshwater wetlands, 18 native tropical vegetation (for example, hardwood hammocks and pinelands), dune ridges 19 and beaches, wildlife, and their habitat. 20 (d) To ensure the maximum well-being of the Florida Keys and its citizens through sound 21 economic development. 22 (e) To limit the adverse impacts of development on the quality of water throughout the 23 Florida Keys. 24 (f) To enhance natural scenic resources, promote the aesthetic benefits of the natural 25 environment, and ensure that development is compatible with the unique historic 26 character of the Florida Keys. 2015-035 pg. 13 4EGOIX4K 5G 1 (g) To protect the historical heritage of the Florida Keys. 2 (h) To protect the value, efficiency, cost-effectiveness, and amortized life of existing and 3 proposed major public investments, including: 4 1. The Florida Keys Aqueduct and water supply facilities; 5 2. Sewage collection and disposal facilities; 6 3. Solid waste collection and disposal facilities; 7 4. Key West Naval Air Station and other military facilities; 8 5. Transportation facilities; 9 6. Federal parks, wildlife refuges, and marine sanctuaries; 10 7. State parks, recreation facilities, aquatic preserves, and other publicly owned 11 properties; 12 8. City electric service and the Florida Keys Electric Co-op; and 13 9. Other utilities, as appropriate. 14 (i) To limit the adverse impacts of public investments on the environmental resources of 15 the Florida Keys. 16 (j) To make available adequate affordable housing for all sectors of the population of the 17 Florida Keys. 18 (k) To provide adequate alternatives for the protection of public safety and welfare in the 19 event of a natural or manmade disaster and for a post disaster reconstruction plan. 20 (l) To protect the public health, safety, and welfare of the citizens of the Florida Keys and 21 maintain the Florida Keys as a unique Florida resource. 22 Staff finds the proposed amendment consistent with the Principles for Guiding 23 Development as a whole and is not inconsistent with any one principle. 24 25 26 In accordance with MCC §102-158(d)(5)., the BOCC may consider the adoption of an 27 ordinance enacting the proposed change based on one or more of the following factors: 28 29 30 1.Changed projections (e.g., regarding public service needs) from those on which the text 31 or boundary was based; NA 32 33 34 2.Changed assumptions (e.g., regarding demographic trends); NA 35 36 37 3.Data errors, including errors in mapping, vegetative types and natural features described 38 in Volume 1 of the Year 2010 Comprehensive Plan; Based on the Tier designation criteria in Sec. 130-130 (Tier Overlay District), the 39 HCP, the LCP and the Comprehensive Plan, the subject parcels do not meet the 40 specified criteria for Tier I designation. The property does not contain native 41 habitats (pinelands, hammock or wetlands) and has been developed with 130 units. 42 The parcel does not contain habitat for Key deer and is outside of established deer 43 corridors. 44 2015-035 pg. 14 4EGOIX4K 5G 1 4.New issues; NA 2 3 4 5.Recognition of a need for additional detail or comprehensiveness; or NA 5 6 7 6.Data updates; NA 8 9 10 7.Impact on Community Character: 11 The subject parcels have been developed with 130 units and supports little or no 12 native habitat. Staff has determined that the proposed amendment to the Tier 13 designation will not have an adverse impact on community characterThe Tier 14 . Overlay District designation is utilized to implement and score ROGO applications, 15 to steer growth and to establish clearing limits. The Tier designation will not impact 16 community character. 17 18 19 IVRECOMMENDATION 20 Staff recommends approval of the proposed amendment as the parcels do not meet the 21 criteria for Tier I designation and is more appropriately designated Tier III in 22 accordance with criteria of Section 130-130(d), the HCP and the LCP. 23 2015-035 pg. 15 4EGOIX4K 5G EXHIBIT I 1 TIER OVERLAY DISTRICT MAP AMENDMENT 2 3 PROPOSED TIER OVERLAY DISTRICT DESIGNATION 4 2015-035 pg. 16 4EGOIX4K