4467 Comp Plan Amdmt 2830 Pine WayOrdinance No. 2018-4467
An Ordinance of the City of Sanford, Florida amending
the City of Sanford Comprehensive Plan, as previously
amended; providing for amendment of the Future Land
Use Map of the Future Land Use Element of the City of
Sanford Comprehensive Plan relative to certain real
property, approximately 9.76 acres (Tax Parcel
Identification Number 17-20-31-300-001B-0000),
addressed as 2830 Pine Way, and described in this
Ordinance from SE (Suburban Estates) to LDR-SF (Low
Density Residential - Single Family); providing for
legislative findings and intent; providing for assignment
of the land use designation for the property; providing
for severability; providing for ratification of prior acts of
the City; providing for conflicts; providing for
codification and directions to the Code codifier and
providing for an effective date.
Whereas, the real property which is the subject of this Ordinance is
approximately 9.76 acres in size and is located at 2830 Pine Way; and
Whereas, the real property which is the subject of this Ordinance is located
on the north side of Pine Way approximately 661 feet west of Sipes Avenue
immediately east of the Wyndham Preserve Subdivision; and
Whereas, the real property which is the subject of this Ordinance, and the
pertinent applications therefor, currently has been assigned the SE (Suburban Estates)
land use designation; and
Whereas, the property owner of the property which is the subject of this
Ordinance is Brisson Investments LLC whose managing members are Sadique Jaffer,
Ashu Luthra and Rob Zlatkiss; and
Whereas the applicant is Kim Fischer, P.E., of Cycorp Engineering Inc.; and
Whereas, a Citizen Awareness and Participation Plan (CAPP) meeting the
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requirements of the City has been submitted to the City and that process included a
meeting held on April 13, 2017 all of which was accomplished by Ms. Kim Fischer, P.E.,
and a CAPP report was drafted and provided to the City; and
Whereas, the City of Sanford's Planning and Zoning Commission, as the
City's local planning agency, held a public hearing on June 7, 2018 to consider
amending the Future Land Use Map of the Future Land Use Element of the City of
Sanford Comprehensive Plan and recommended approval of the proposed Future Land
Use Map amendment to the Comprehensive Plan for the subject property as requested
by the property owner; and
Whereas, Section 163.3187, Florida Statutes, relates to the amendment of
adopted local government comprehensive plans and sets forth certain requirements
relating to small scale amendments and which are related to proposed small scale
development activities and provides, among other things, that such amendments may
be approved without regard to statutory limits on the frequency of consideration of
amendments to the City of Sanford Comprehensive Plan; and
Whereas, the City of Sanford has complied with all requirements and
procedures of Florida law in processing this amendment to the City of Sanford
Comprehensive Plan including, but not limited to, Section 163.3187, Florida Statutes.
Now, therefore, be in enacted by the People of the City of Sanford, Florida:
Section 1. Legislative findings and intent.
(a). The City Commission of the City of Sanford hereby adopts and
incorporates into this Ordinance the City staff report and City Commission agenda
memorandum relating to the application relating to the proposed amendment to the City
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of Sanford Comprehensive Plan pertaining to the subject property.
(b). The City of Sanford has complied with all requirements and procedures of
Florida law in processing and advertising this Ordinance.
(c). This Ordinance is internally consistent with the goals, objectives and
policies of the Comprehensive Plan of the City of Sanford and the proposed
Comprehensive Plan amendment does not trigger any urban indicators and adoption of
this amendment will discourage the proliferation of urban sprawl within the City of
Sanford.
(d). Public services are available to the real property which is the subject of
this Ordinance.
(e). The proposed development of the real property which is the subject of this
Ordinance is planned to be a single family residential subdivision.
(f). The exhibits to this Ordinance are incorporated herein as if fully set forth
herein verbatim.
Section 2. Amendment to Future Land Use Map.
(a). The Future Land Use Plan Element of the Comprehensive Plan of the City
of Sanford and the City's Future Land Use Map is hereby amended by changing the
land use designation from SE (Suburban Estates) to LDR-SF (Low Density Residential -
Single Family) with regard to the real property which is the subject of this Ordinance as
set forth herein.
(b). The property which is the subject of this Comprehensive Plan amendment
is described as follows:
The Southwest 1/4 of the Southeast 1/4 of the Northeast 1/4, Section 17,
Township 20 South, Range 31 East, Seminole County, Florida.
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Section 3. Implementing Administrative Actions. The City Manager,
or designee, is hereby authorized to implement the provisions of this Ordinance as
deemed appropriate and warranted.
Section 4. Ratification Of Prior Actions. The prior actions of the City
Commission and its agencies in enacting and causing amendments to the
Comprehensive Plan of the City of Sanford, as well as the implementation thereof, are
hereby ratified and affirmed.
Section 5. Severability. If any section, sentence, phrase, word, or
portion of this Ordinance proves to be invalid, unlawful or unconstitutional, it shall not
be held to impair the validity or effect of any other action or part of this Ordinance.
Section 6. Conflicts. All ordinances or parts of ordinances in conflict
herewith are hereby repealed.
Section 7. Codification/Instructions to Code Codifier. It is the intention of
the City Commission of the City of Sanford, Florida, and it is hereby ordained that the
provisions of this Ordinance shall become and be made a part of the codified version of
the City of Sanford Comprehensive Plan and/or the Code of Ordinances of the City of
Sanford, Florida in terms of amending the Future Land Use Map of the City.
Section 8. Effective Date. The small scale Comprehensive Plan
amendment set forth herein shall not become effective, in accordance with Section
163.3187(5)(c), Florida Statutes, until 31 days after the enactment of this Ordinance. If
challenged within 30 days after enactment, the small scale amendment set forth in this
Ordinance shall not become effective until the State land planning agency or the
Administration Commission, respectively, issues a final order determining that the
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subject small scale amendment is in compliance with controlling State law; provided,
however, that this Ordinance shall not take effect until the annexation ordinance
annexing the property that is the subject of this Ordinance is final.
Passed and adopted this 10th day of December, 2018.
City Commission f the City of
Sanford, Florida
Attest:
6wl 0 i g1l Y' 1,
Traci Houchin, City Clerk -t4f-U
CD
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Approved as to form and legality:
William L. Colbert, Esquire
City Attorney
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FLORIDA
CITY COMMISSION MEMORANDUM 18255
DECEMBER 1 O, 2a 1 8
WS RM
Item No. s"%'%� - I
TO: Honorable Mayor and Members of the City Commission
PREPARED BY: Jordan Smith, AICD, PP — Senior Planner
Traci Houchin, City Clerk
SUBMITTED BY: Norton N. Bonaparte, Jr., City Manager
SUBJECT: Future Land Use Amendment request to ange 9.76 acres at 2830 Pine
Way from SE, Suburban Estates to LD SF, Low Density Residential —
Single Family
STRATEGIC PRIORITIES:
❑ Unify Downtown & the Waterfront
❑ Promote the City's Distinct Culture
® Update Regulatory Framework
❑ Redevelop and Revitalize Disadvantaged Communities
SYNOPSIS:
A request to amend the future land use designation from SE, Suburban Estates to LDR-SF, Low
Density Residential — Single Family for 9.76 acres with a project address of 2830 Pine Way has
been received.
The property owner is Brisson Inv., LLC. The applicant is Kim Fischer, P.E. of Cycorp
Engineering Inc. who was responsible for completing the required CAPP meeting.
The Affidavit of Ownership and Designation of Agent form is attached and additional information
is available in order to ensure that all potential conflicts of interest are capable of being discerned.
FFISCALISTAFFFING STATEMENT:
The parcel shown on the attached map, owned by Brisson Inv., LLC includes the following
improvements per the Seminole County Property Appraiser:
Parcel Number
Location Improvements
17-20-31-300-001B-00002830
Pine Way One single family structure
and two barn/shed
Based on the 2017 tax roll of Seminole County, the total assessed value for the 9.76 acres is
$423,420. The tax bill for the property in 2017 totaled $6,178.58. Changing the future land use of
the property to Low Density Residential — Single Family will have an impact on public facilities
and services.
BACKGROUND:
The applicant is requesting to amend 9.76 acres, future land use designation of Suburban Estates,
SE to Low Density Residential — Single Family, LDR-SF for the development of a single-family
subdivision. The site is located on the north side of Pine Way approximately 661 feet west of Sipes
Avenue immediately east of Wyndham Preserve. The access for the project is planned to connect
through Wyndham Preserve, currently under construction, creating a second phase to the project.
The applicant is proposing up to 34 dwelling units at a density of 3.48 units per net buildable acre.
Per the State's Growth Policy Act (Chapter 163 F.S.), any plan amendment shall discourage the
proliferation of urban sprawl. In order to determine that a plan amendment does not constitute
urban sprawl, the amendment must be analyzed as to whether it incorporates a development pattern
or urban form that achieves four or more of the following eight criteria:
1. Directs growth and development to areas of the community in a manner that does not
adversely impact natural resources;
2. Promotes the efficient and cost effective provision or extension of public infrastructure and
services;
3. Promotes walkable and connected communities and provides for compact development and
a mix of uses at densities and intensities that support a range of housing choices and a
multimodal transportation system;
4. Promotes conservation of water and energy;
5. Preserves agricultural areas and activities;
6. Preserves open space and natural lands and provides for public open space and recreation
needs;
7. Creates a balance of land uses based on demands of residential population for the
nonresidential needs of an area; and,
8. Provides uses, densities and intensities of use and urban form that would remediate an
existing or planned sprawl development pattern or provides for an innovative development
pattern such as transit oriented development or new towns.
The two subdivisions to the west of the site include Wyndham Preserve, a 248 lot subdivision on
60.43 acres with a density of 4.1 dwelling units per acre and Kensington Reserve, a 375 lot
subdivision on 128.59 acres with a density of 2.9 dwelling units per acre. Both are single family
subdivisions with Future Land Use designation of LDR-SF. Development within LDR-SF shall
include existing stable single family areas as well as those areas for future low density residential
single family with the goal of providing sufficient land area to meet projected single family
housing needs. The remainder of the properties adjacent to and in the vicinity surrounding the
property are within unincorporated Seminole County and have a Future Land Use designation of
SE, Suburban Estates. Objectives and Policies of the Comprehensive Plan that are relevant to this
application are listed below:
Future Land Use Element
Objective 1-1.1: Implement the Future land Use Map Series. The maximum density for the LDR-
SF future land use is 6 dwelling units per acre. The proposed amendment is not in conflict with
the density as the project is proposing 3.48 dwelling units.
Land Use Designations
Map Symbol
Density/Intensiiy (Max)
Low Density Residential —
Single Family
LDR-SF
6 du/acre
Objective 1-1.2: Allocate Residential Use. The future Land Use Map shall allocate residential
density based on the following considerations:
- Past and projected population, housing tends and characteristics;
- Provision and maintenance of quality residential enviromnental
- The need to plan for smooth transition in residential densities; and
- Provision and maintenance of traffic circulation and multiple -family improvements
The proposed amendment appears consistent with objective 1-1.2 as there are new approved
subdivisions immediately to the west being under construction.
Transportation Element
Objective 2-1.2: Coordinate Land Uses and Transportation. The City shall coordinate the
transportation system with the Future Land Use Map Series and ensure that existing and proposed
population densities, housing and employment patterns, land uses, and all other short and long
tern development plans are consistent with the city transportation system and services.
Infrastructure Element
GOAL 4-1: PROVIDE ADEQUATE PUBLIC FACILITIES. ENSURE AVAILABILITY
AND PROVISION OF ADEQUATE PUBLIC FACILITIES INCLUDING POTABLE WATER,
SANITARY SEWER, SOLID WASTE, STORMWATER DRAINAGE, AND AQUIFER
RECHARGE IN A MANNER WHICH PROTECTS INVESTMENTS IN EXISTING
FACILITIES, CONTINUES TO SERVE EXISTING RESIDENTS AND SUPPORTS
ORDERLY, COMPACT GROWTH.
Objective 4-1.1: Ensure Available Public Facilities, Maximize Use of Existing Public
Facilities, and Prevent Urban Sprawl. The City shall require that proposed land uses be
adequately served by public facilities, including water, wastewater, storm water management, solid
waste disposal and hazardous waste management. The subdivision and site plan review processes
shall provide a unified system for maximizing use of existing public facilities and for coordinating
the efficient location, timing, phasing, and scale of public and private development.
The proposed development is located within Planning Area 4 of the 2015 City of Sanford/Seminole
County Joint Planning Agreement (JPA). An east -west alignment established by Eaglewood Trail
shall serve as a dividing line for residential density within Planning Area 4. Properties to the north
of this line shall develop at a maximum of 3.5 units per net buildable acre and properties lying
south of this line and north of Pine Way shall develop at a maximum of 2.5 units per net buildable
acre. The subject property is located south of Eaglewood Trail and north of Pine Way and
therefore, per the 2015 JPA, shall develop at a maximum of 2.5 units per net buildable acre which
would yield approximately 24 dwelling units.
The proposed amendment is consistent with the City of Sanford Comprehensive Plan, however, it
is not consistent with the 2015 JPA between Seminole County and the City of Sanford.
On May 3, 2018, the Planning and Zoning Commission recommended the City Commission
approve a Future Land Use Amendment request to change 9.76 acres located at 2830 Pine Way
from SE, Suburban Estates to LDRSF, Low Density Residential Single Family.
On June 25, 2018 the first reading of Ordinance 4467 was continued to the August 13, 2018 City
Commission meeting to allow the applicant time to address issues/concerns relating to the rezone.
On August 13, 2018 the City Commission approved the first reading of Ordinance No. 4467 to
change the Future Land Use of 9.76 acres located at 2830 Pine Way from SE, Suburban Estates to
LDR-SF, Low Density Residential Single Family.
On August 27, 2018 second reading of Ordinance No. 4467 to change the Future Land Use of 9.76
acres located at 2830 Pine Way from SE, Suburban Estates to LDR-SF, Low Density Residential -
Single Family was continued to the November 12, 2018 City Commission Meeting per the request
of the applicant to continue to address the concerns of the proposed pool.
On November 12, 2018 second reading of Ordinance No. 4467 to change the Future Land Use of
9.76 acres located at 2830 Pine Way from SE, Suburban Estates to LDR-SF, Low Density
Residential -Single Family was continued to the December 10, 2018 City Commission Meeting per
the request of the applicant.
LEGAL REVIEW:
The City Attorney has reviewed the staff report and has noted the following:
This matter is not a quasi-judicial matter as amendments to local government comprehensive plans
are legislative in nature. That being said, if a proposal to amend the City Comprehensive Plan is
to be recommended for denial, it would be appropriate to state the particular reason for such a
recommendation to be considered by the City Commission - such as the proposal is internally
inconsistent with a goal, objective or policy of the Comprehensive Plan or inconsistent with
controlling State law or the like.
RECOMMENDATION:
Staff finds that the small scale amendment is consistent with the Comprehensive Plan. It has been
determined that the City has available capacity to serve the increased demand on available water
and sewer.
The Planning and Zoning Commission voted the City Commission approve this policy matter after
conducting a public hearing and determining that the proposed land use change is consistent with
the goals, objectives and policies of the City's Comprehensive Plan and the State's Growth Policy
Act.
Additional comments or recommendations may be presented by staff at the meeting.
SUGGESTED MOTION:
"I move to adopt the second reading of Ordinance No. 4467 to change the future land use map of
the Sanford Comprehensive Plan for approximately 9.76 acres with a project address of 2830 Pine
Way from SE, Suburban Estates to LDR-SF, Low Density Residential — Single Family."
Attachments: Project Information Sheet
Future Land Use Amendment Map
Aerial Map
Affidavits of Ownership and Designation of Agent
Written Explanation/Justification
Ordinance No. 4467
PROJECT INFORMATION -- 2830 PINE WAY
COMPREHENSIVE PLAN AMENDMENT
Requested Action: A Comprehensive Plan Amendment to change the future land use map designation
for 9.76 acres from SE, Suburban Estates to LDR-SF, Low Density Residential —
Single Family
Proposed Use: Single Family Residential
Project Address: 2830 Pine Way
Current Future Land Use SE, Suburban Estates
Proposed Future Land Use LDR-SF, Low Density Residential — Single Family
Current Zoning: AG, Agriculture
Proposed Zoning: PD, Planned Development
Current Land Use: Residential
Legal Description: SW 1/4 of SE 1/4 of NE 1/4, SEC 17, TWP 20S, RGE 31E, Seminole County,
Florida
Tax Parcel Number:
17-20-31-300-00113-0000
Site Area:
9.76 Acres
Property Owners:
Brisson Inv., LLC
27 N. Summerlin Avenue
Orlando, Florida 32801
Applicant/Agent:
Kim Fischer, P.E.
1614 White Dove Drive
Winter Springs, Florida 32708
Phone: 407.405.7819
Email: kim@cycorpengineers.com
CAPP Meeting: The applicant held a CAPP meeting on Thursday, April 13, 2017
Commission District: District 1 — Commissioner Art Woodruff
COMPREHENSIVE PLAN COMPLIANCE REVIEW
Planning staff has reviewed the request and has determined the use and proposed improvements to be consistent with
the Goals, Objectives and Policies of the Comprehensive Plan.
Current Future Land Use: SE, Suburban Estates
Proposed Future Land Use LDR-SF, Low Density Residential — Single Family
Existing Land Use: Single Family Residential
Surrounding Uses and Zoning:
Uses
North Single Family Residential
South Single Family Residential
East Single Family Residential
West Wyndham Preserve (246 DU
residential community)
CONCURRENCY
Zoning
A-1, Agriculture (County)
A-1, Agriculture (County)
A-1, Agriculture (County)
PD, Planned Development (City)
Concurrency is a finding that public facilities and services necessary to support a proposed development are
available, or will be made available, concurrent with the impacts of the development. An assessment will be made
at the development review stage.
LOS Standard Facility Capacity"
*
Potable Water: 144 gal/capita/day 9.02 MGD (CUP Capacity)
Sanitary Sewer: 132 gal/capita/day 9.3 MGD
Solid Waste: 2.46 lbs/capita/day 21.5 million tons
The proposed overall demand of the project will be determined at the time of Engineering Plan Review.
The City's Utility Department tracks water and wastewater capacities for all projects once a Florida Department of
Environmental Protection (FDEP) permit has been obtained. The available capacity for a proposed project is verified
but will not be reserved until a FDEP permit is obtained. Below is a breakdown provided by the City of Sanford
Utility Department for current usage within the City:
Potable Water** Sanitary Sewer**
Recorded 3 -month Average daily flow: - 6.73 MGD
Recorded 12 -month Average daily flow: 7.504 MGD -
Projects with FDEP permits (not in service): 0.806 MGD 0.624 MGD
** As provided by the City of Sanford's Utility Department. (CUP — Consumptive Use Permit)
TADevelopment Review\03-Land Development\2018\2830 Pine Way - PD Rezone SFR\Comp Plan\Project Info Sheet - 2830 Pine Way2,doc
City of Sanford Comprehensive Plan Amendment
Site: 2830 Pine Way
Parcel No: 17-20-31-300-00113-0000
Proposed Future Land Use: LDRSF - Low Density
Single Family Residential
9.76 Acres
Legend
Existing Land Use
Mobile Home
Public Use
Vacant
Agriculture
Single Family Residential
Multi -Family Residential
Future Land Use
20
Low Density Res. Single Family
Resource Protec t ion
Suburban Estates
Existing Land Use
City of Sanford Department of Planning & Development Services, April 2018
April 2018
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AFFIDAVIT OF OWNERSHIP AND DESIGNATION OF AGENT
Please use additional sheets as needed. If any additional sheets are attached to this document, please sign here and note below:
1. Ownership
1, Robert Zatkiss , hereby attest to ownership of the property described below.
Tax Parcel Number(s): 17-20-31-300-0018-0000
-Address Cif property: 2830-Pine-WaySanI`Grd,,FL 3281-9
for which this rezonelcomp plan/annexadon/engineering application is submitted to the City of Sanford.
II. Designation of Applicant's Agent (leave blank If not applicable)
As the owner/applicant of the above designated property for which this affidavit is submitted, I designate the below named individual
as my agent in all matters pertaining. to the application process. In authorizing the agent named below to represent me, or my
company, I attest that the application is made in good faith and that all information contalqed in the application is accurate and
complete to the best of my personal knowledge.
Applicant's Agent (Print): Kim Fischer
Agent Address: 1614 White Dove Drive, Winter Springs, FL 32708
Email: kim@cycorpengineers.com
Ill. Notice to Owner
Signature:
Phone: 407-405-7819 Fax:
A. AM changes in Ownership and/or Applicant's Agent prior to final action of the City shall require a new affidavit. If ownership
changes, the new owner assumes all obligations related to the filing application process.
B. If the Owner intends for the authority of the Applicant's Agent to be limited in any manner, please indicate the limitations(s)
below. (i.e.: limited to obtaining a certificate of concurrency; limited to obtaining a land use compliance certificate, etc.)
The owner of the real property associated with this application or procureffient activity Is a (check one)
a Individual a Corporation a Land Trust o Partnership a Limited Liability Company
a Other (describe):
1. List all natural persons who have an ownership interest In the property, which Is the subject matter of this petition, by name and
address.
2. For each corporation, list the name, address, and title of each officer the name and address of each director of the corporation;
and the name and address of each shareholder who owns two percent (2%) or more of the stock of the corporation. Shareholders
need not be disclosed if a corporation's stock are traded publicly on any national stock exchange.
3. In the case of a trust, list the name and address of each trustee and the name and address of the beneficiaries of the trust and the
percentage of interest of each beneficiary. If any trustee or beneficiary of a trust is a corporation, please provide the Information
required in paragraph 2 above.
Name of Trust:
4. For partnerships, including limited partnerships, list the name and address of each principal in -the partnership,, including -general
or limited partners. If any partner is a corporation, please provide the information required in paragraph 2 above.
1
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5. For each limited liability company, list the name, address, and title of each manager or managing member, and the name and
address of each additional member with two percent (2%) or more membership interest. If any member with two percent (20/6) or
more membership interest, manager, or managing member is a corporation, trust or partnership, please provide the information
required in paragraphs 2. 3 and/or 4 above.
Name of LLC- American Land Inv of Pine Way LLC
6. In the circumstances of a contract for purchase, list the name and address of each contract purchaser. If the purchaser is a
corporation, trust, partnership, or LLC, provide -
the information required for those entities in paragraphs 2, 3. 4 and/or 5 above.
.41
Name of Purchaser �MM�Wnv, XC e, W
4� Date of Contract:
NAME TITLEIOFFICEITRUSTEE ADDRESS
OR BENEFICIARY
% OF
INTEREST
27 N Summerlin Orlando, FL 32801
100
(Use additional sheets for more space.)
7. As to any type of owner referred to above, a change of ownership occurring subsequent to the execution of this document, shall be
disclosed in writing to the City prior to any action being taken by the City as to the matter relative to which this document pertains.
8. 1 affirm that the above representations are true and are based, upon my personal- knowledge andbeliet after alt reasonable inquiry. r
understand that any failure to make mandated disclosures is grounds for the subject rezone, future land use amendment special
exception, or variance involved with this Application to become void or for the submission for a procurement activity to be non-
responsive. I car* that I am legally authorized to execute this Affidavit and to bind the Applicant or Vendor to the disclosures
herein.
STATE OF FLORIDA
COUNTY OF_��%A
Sworn to (or affirmed} and subscribed before me by
on this ZJ day of 20
Signature of Notary Public
Personally Known 11 OR Produced Identification
Type of Identification Produced
Mdavit of Ownan;Np - January 2015
, Aw
Owner;gent, Applicant Signature
` Print, , 'Type'br Stamp Name of Notary Public
2
F�
INEERING.
NC 1614 White Dove Dr. Winter Springs, FL 32708 Phone: 407-405-7819
TO: City of Sanford
300 N. Park Avenue
Sanford, FL 32771-1244
407-688-5147
FROM: Kim Hall Fischer
SUBJECT: Pine Way Subdivision
Comprehensive Plan Amendment and
Rezoning Petition
DATE: October 12, 2017
We are submitting application for a Small Scale Comprehensive Plan Amendment concurrently
with a Rezoning Petition. The subject property is currently zoned for Agricultural with a future
land use of suburban estates. The, proposed amendment would be to Low Density Residential
with a zoning classification of PD. The subject property is proposing lot sizes similar to the
Wyndham Preserve to the west. Access would be through Wyndham Preserve and thus would
be a separate phase to Wyndham Preserve. The subject property is consistent with the State
Comprehensive Plan and the Growth Policy Act.
The surrounding area is either vacant, single family residential or churches. We feel the area
along Pine Way can support additional growth of residential properties. This amendment will
not significantly alter acceptable existing land use patterns or adversely affect the livability of
the area or the health and safety of the residents.
Water and sewer are currently available through Wyndham Preserve and extensions were
anticipated and stubs constructed to service this parcel.
The proposed development of 49 -single family -homes will bring an added benefit to the area
and to the growth of the entire City.