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HomeMy WebLinkAboutItem 01 Proposed Regulations of Medical and-or Recreational Marijuana AGENDA ITEM SUMMARY Meeting Date: 3/7/2016 Meeting Type: Work Session Staff Contact/Dept.: Jim Donovan Staff Phone No: (541)726-3660 Estimated Time: 25 minutes S P R I N G F I E L D C I T Y C O U N C I L Council Goals: Promote and Enhance our Hometown Feel while Focusing on Livability and Environmental Quality ITEM TITLE: PROPOSED REGULATIONS OF MEDICAL AND/OR RECREATIONAL MARIJUANA ACTION REQUESTED: Council is requested to review and discuss the attached Proposed Springfield Development Code Amendments. ISSUE STATEMENT: Review and discuss proposed regulations that identify the zoning districts, the separation distance between certain uses and proposed marijuana businesses, and the site standards for the production and processing of marijuana and marijuana products as licensed by the Oregon Liquor Control Commission (OLCC) and the Oregon Health Authority (OHA). ATTACHMENTS: 1. Proposed Amendments to the Springfield Development Code Allowing Medical and Recreational Marijuana Facilities in Certain Zoning Districts 2. Map of Key Buffer Discussions DISCUSSION/ FINANCIAL IMPACT: In November 2015, the Council conducted a work session discussion regarding the potential appropriate regulation of recreational marijuana activities approved by voters as Measure 91 in November, 2014. This new law legalized the growth, sale, and use of marijuana for recreational purposes. The Council discussion focused on three major topics: Taxes, business licensing, and land use regulation. At the conclusion of the 11/9/15 work session, the Council directed staff to schedule work sessions of the Planning Commission to discuss the various options available in the Development Code to regulate the four activities subject to licensing by the OLCC: production, processing, wholesaling, and retailing. The Council did not indicate a preference for allowances or prohibitions; they wanted the Planning Commission to explore these topics and then provide the Council with options. The Council did indicate a concern that an overly aggressive site eligibility regulation based on separation between uses might make most sites unsuitable and therefore artificially limit the potential number of businesses. With this possible outcome in mind, the two Planning Commission work sessions conducted in December and the final work session in January included several maps displaying site availability for each license type. Largely due to the information provided by these maps, the Planning Commission has recommended various separation standards (all statutory setbacks are observed) that are included in the proposed Code going before the Planning Commission at public hearing on March 1, 2016. In summary, the proposed amendments allow retail businesses in two commercial zoning districts, and allow wholesaling, production and processing in three industrial zoning districts; these uses are prohibited in all other zones and anywhere outside the city limits. Where production and processing are proposed, these activities may either be indoors with mechanically controlled ventilation systems, or outdoors; on lots at least 5 or 10 acres in size depending on the size of the operation; and separated from any district allowing residential use by either 500 feet or 1,000 feet depending upon the size of the operation. PROPOSED SPRINGFIELD DEVELOPMENT CODE (SDC) AMENDMENTS TO ALLOW MEDICAL AND RECREATIONAL MARIJUANA FACILITIES IN CERTAIN ZONING DISTRICTS (3/1/16) This proposed action amends the following Sections of the Springfield Development Code: 1) Subsection 3.2-200 Residential Zoning Districts; Subsection 3.2-210 Schedule of Use Categories; Subsection 3.2-300. Commercial Zoning Districts; Subsection 3.2-310 Schedule of Uses Categories; Subsection 3.2-400 Industrial Zoning Districts; 3.2-410 Schedule of Use Categories; Subsection 3.2-415 Schedule of Campus Industrial Use Categories; Subsection 3.2-600 Mixed Use Zoning Districts; Subsection 3.2-610 Schedule of Use Categories; Subsection 3.4-200 Glenwood Riverfront Mixed Use Plan District; Subsection 3.4-255 Prohibited Uses; Subsection 4.7-177 Marijuana Uses; Subsection 6.1-110 Meaning of Specific Words and Terms. These amendments will allow medical and recreational marijuana retail sales in the Community Commercial and Major Retail Commercial Zoning Districts; will allow marijuana production, processing and wholesale sales in the Light Medium, Heavy and Special Heavy Industrial Zoning Districts; will establish Subsection 4.7-177 describing specific development standards for each licensed use in each affected zoning district; and will add definitions consistent with state statutes. I. The use tables of the Springfield Development Code are proposed to be amended as follows: 3.2-300 Commercial Zoning Districts Commentary. Marijuana retail sales are proposed to be permitted in the Community Commercial (CC) and Major Retail Commercial (MRC) Zoning Districts under Special Use standards as noted below and detailed under Special Use Standards section. Marijuana retail sales are proposed to be prohibited in the Neighborhood Commercial (NC) and General Office Zoning Districts for the following reasons: 1) The NC (Neighborhood Commercial) Zoning District, while listed under “Commercial Districts”, is discussed under the Metro Plan Residential Designation where “neighborhood commercial services” are allowed as auxiliary uses. The SDC limits the NC Zoning District to not more than 3 acres in size consisting of a neighborhood market, hair salon, etc. serving the neighborhood and it is typically surrounded by residential zoning districts. The proposed separation and buffer restrictions proposed in Subsection 4.7-177 below either would be difficult to, or cannot be met. 2) The GO (General Office) Zoning District, which is considered a buffer between more intense commercial uses and residential uses does allow retail uses as a secondary use. However, retail uses are limited to no more than 10 percent of the gross floor area of the office building in which they are sited and are typically serving the primary office uses. If retail sales are to be buffered from residential districts, any separation standards would be virtually impossible to meet. For these reasons, staff proposes that marijuana retail outlets should not be permitted in the GO Zoning District. 3) After PC discussion of zoning principles and the lack of crime statistics to support safety concerns, state licensed commercial daycare businesses are not buffered in this proposal. Proposed text is underlined and highlighted in yellow. ATT1, Page 1 of 11 3.2-310 Schedule of Use Categories Commercial Districts Categories/Uses NC CC MRC GO Marijuana Business (Section 4.7-177) Marijuana Retail Outlet (Recreational or Medical) N S* S* N Note: S* refers to a use that is permitted subject to Special Use Standards, an asterisk denotes site plan review. ******************* Section 3.2-400 Industrial Zoning Districts Commentary. This section addresses several issues identified with production of marijuana, processing of marijuana products or wholesaling of marijuana. Staff research of other jurisdictions, state statutes and code structure leads to the proposal not to permit marijuana dispensaries or retail outlets within industrial zoning districts as a primary or secondary use. The LMI (Light Medium Industrial) and HI (Heavy Industrial Zoning) Districts do not permit retail uses as a primary use, which includes, but is not limited to: manufacturing; warehousing; and research, development and testing laboratories. While these zoning districts do allow secondary uses serving or related to the primary industrial uses, they are limited to those serving the employees of the primary industrial use. There are no secondary retail uses in these zoning districts. In addition, the SHI (Special Heavy Industrial) Zoning District is located outside of the Springfield city limits and is therefore not eligible for marijuana dispensaries, which are required to be located only within Springfield’s city limits due to the operational requirements contained in the Springfield Municipal Code Chapter 7. The Springfield Municipal Code does not apply outside of the city limits. 3.2-410 Schedule of Use Categories Industrial Districts Use Categories/Uses LMI HI SHI Marijuana Business (Special Use Standards Section 4.7-177) Production Facilities Indoor/Outdoor, Tier I-II Canopy Regulations- N S* S* Processing Facilities S* S* N Wholesale Facilities S* S* N Marijuana Retail Outlets or Sales, as a primary or secondary use. N N N Note: S* refers to a use that is permitted subject to Special Use Standards, an asterisk denotes site plan review. 3.2-415 Schedule of Campus Industrial Use Categories ATT1, Page 2 of 11 Commentary. While the CI (Campus Industrial) Zoning District does allow certain retail uses, these uses are also intended to be secondary to the permitted primary Campus Industrial uses. The purpose of these permitted secondary retail uses is to serve the employees of the CI Zoning District. A retail use will serve customers from all over the metropolitan area and, therefore, is not considered secondary to permitted primary uses specified in SDC Subsection 3.2-415. All other marijuana uses will not meet operational or other standards of the district. Staff proposes adding marijuana dispensaries to the CI prohibited use list: Prohibited Uses Marijuana Business N ****************** 3.4-200 Glenwood Riverfront Mixed-Use Plan District Commentary. Springfield has two sets of mixed-use zoning district. One applies to Glenwood Phase 1 only; the other to the rest of the City. This section addresses the Glenwood Riverfront Mixed-Use Plan Districts. All the zoning in Glenwood Riverfront Mixed-Use Plan District is either Employment Mixed-Use, Commercial Mixed-Use, Office Mixed-Use or Employment Mixed-Use. Any permitted primary uses in these zoning districts were limited to prevent conflicts with retail uses in downtown Springfield or other commercial areas and purposefully create a distinct business environment. Additionally, the purpose of permitted secondary retail uses in Glenwood is to serve either the residents or employees of a building, not the general public. Therefore, marijuana uses would not be allowed as a primary or secondary use in these zoning districts. 3.4-255 Prohibited Uses The following uses are similar in nature to other prohibited retail and industrial uses and shall be added to the list of prohibited uses within the Glenwood Riverfront Mixed-Use Plan District: Marijuana Business. Section 3.2-600 Mixed Use Zoning Districts Commentary. These mixed use zoning districts are distinct from Glenwood districts, and differ in permitted uses, notably residential uses are allowed under all three districts. Therefore it would be very difficult to regulate any separation between retail or any other marijuana uses and the desired residential uses. For these reasons staff recommends no marijuana uses be permitted in any mixed use district having a residential district. 3.2-610 Schedule of Use Categories ATT1, Page 3 of 11 Districts Categories/Uses MUC MUE MUR Marijuana Business Production, Processing, Wholesaling, Retail N N N ************* Section 3.2-200 Residential Zoning Districts Commentary. Marijuana businesses are prohibited in all standard residential districts by state statute, and verified for local compliance prior to the issuance of a license. This code section is intended to be consistent with those statutes. 3.2-210 Schedule of Use Categories Districts Categories/Uses LDR SLR MDR HDR Marijuana Business (4.7-177) Production, Processing, Wholesaling, Retail N N N N II. The following new Special Use Standards are proposed to be added to Code Section 4.7 as indicated by asterisk in the permitted use tables above: Section 4.7-177 Marijuana Uses Commentary. SDC 4.7-100 currently contains “special use” standards for a number of permitted uses in various zoning districts. These “special use” standards typically involve specific standards designed to control location or mitigate impacts of a use on surrounding properties. The following proposed Subsection provides specific standards for permitting marijuana uses consistent with statutory regulations, Springfield Municipal Code and as recommended or requested for consideration by City Council or the Planning Commission. A. l Marijuana Retail Outlets shall be: 1. Licensed or registered and operated in accordance with Oregon Revised Statutes and applicable Oregon Administrative Rules. 2. Licensed and regulated as specified in Chapter 7 of the Springfield Municipal Code; 3. Located on and take access from an arterial or collector street; and ATT1, Page 4 of 11 4. Fully contained in a permanent building in the Community Commercial or Major Retail Commercial Zoning Districts. 5. Prohibited in any district except CC and MRC. B. Where permitted by this Code, Marijuana Retail Outlets shall not be located: Commentary. The following section is designed to be consistent with state statutes and recommendations or requests for consideration by the Planning Commission or City Council. 1. At the same address as another licensed or registered marijuana business; 2. Within 1,000 feet of the real property comprising a public or private elementary, secondary or career school attended primarily by minors (“within 1,000 feet” means a straight line measurement in a radius extending for 1,000 feet or less in every direction from any point on the boundary line of the real property comprising an existing public or private elementary, secondary or career school primarily attended by minors); 3. Within 1,000 feet of another l Marijuana Retail Outlet (“within 1,000 feet” means a straight line measurement in a radius extending for 1,000 feet or less in every direction from any point on the boundary line of the real property compromising a retail outlet); Commentary. The following proposed standards are not listed in statute; the intent was to provide additional protection of children. See the Cole Memorandum1. Staff reviewed adopted or proposed medical marijuana dispensary zoning regulations from Ashland, Beaverton and Salem and found that they addressed parks, pre-schools and certified day care facilities. See Medical Marijuana Dispensaries – Other City Comparisons. Staff originally proposed 1,000 feet of separation between parks, pre-schools and certified day care centers. However, based upon input from the marijuana industry representatives (250 foot from parks) and the 100O foot buffer initially discussed, the 500 foot proposal represents a compromise of buffering. Pre- schools and day care facilities located in residential zoning districts will be addressed in the proposed residential setback locational standard below. 1 In a memorandum to all United States Attorneys dated August 29, 2013, James M. Cole, Deputy Attorney General distributed information on Guidance Regarding Marijuana Enforcement. The memorandum states in part: “…the Department (Justice Department) in recent years has focused its efforts on certain enforcement priorities that are particularly important to the federal government…. Preventing the distribution of marijuana to minors…. The Department’s guidance in this memorandum rests on tis expectation that states and local governments that have enacted [and/or are proposing to] laws authorizing marijuana-related conduct will implement strong and effective regulatory and enforcement systems that will address the threat those state laws could pose to public safety, public health, and other law enforcement interests….” The Oregon Legislature has adopted Medical Marijuana regulations enacted by Senate Bill 1531 (2014) which grants Springfield the authority to adopt ordinances within the city limits that impose reasonable regulations on the operation of medical marijuana facilities registered under ORS 475.314 that are consistent with the latest directive. ATT1, Page 5 of 11 4. Within 500 feet of parks where minors congregate (“within 500 feet” means a straight line measurement in a radius extending for 500 feet or less in every direction from any point on the boundary line of the real property compromising a l Marijuana Retail Outlet). Commentary. Setbacks from residential zoning districts. These standards are not listed in statute; the intent is to provide additional protection of children. This topic was initially discussed with City Council during review of regulations amending the Springfield Municipal Code to regulate licensing medical marijuana dispensaries in the City. A number of options were mentioned from 1,000 feet to 100 feet and possible distanced in between. Staff reviewed adopted, or soon to be adopted, medical marijuana dispensary zoning regulations from Ashland, Beaverton and Salem regarding setbacks from residential zoning districts. Staff found Ashland proposed a 200 foot setback, Salem proposed a 100 foot setback and Beaverton has no setback. Please note that when zoning was first applied along Main Street, commercial zoning included a 200 foot-wide swath that created a number of lots that were split zoned Community Commercial and residential. The linear pattern of Main Street also would prohibit the establishment of any medical marijuana dispensaries in this area if a 1,000 or even 200 foot setback was to be imposed. Staff prepared maps showing a proposed 50 foot and 100 foot setback from residential properties along Main Street and in other areas of Springfield where Community Commercial and Major Retail Commercial zoning occurs for review of Council and Planning Commission. Based upon input from Council, the Commission and initial feedback from marijuana industry representatives, a 50 foot setback was proposed. The 50 foot option should cover all residential pre-schools and day care facilities in the residential zoning districts and ensure that no retail outlet is located immediately adjacent to a residential zone. No separate setback for commercial day care facilities is proposed. 5. Within 50 feet of any residential zoning district (“within 50 feet” means a straight line measurement in a radius extending for 50 feet, including public right-of-way, in every direction from any point of the property containing a Marijuana Retail Outlet C. Additional Marijuana Retail Outlet Regulations. A Marijuana Retail Outlet shall: 1. Not have a drive-up window; 2. Not operate from any temporary facility in any zone. 3. Provide for secure disposal of marijuana remnants or by-products, which shall not be placed within the businesses exterior refuse containers. 4. Not include outdoor storage of merchandise, raw materials, or any other material associated with retail sales. 5. Preclude any use of products on site unless expressly exempted by state statute. 6. Not be allowed as a home occupation in any zone. Commentary: The following proposed Subsection provides specific standards for permitting production, processing or wholesale marijuana uses consistent with statutory regulations, Springfield Municipal Code and as recommended or requested for consideration by City Council or the Planning Commission. ATT1, Page 6 of 11 D. Industrial Uses Commentary: Discussions with the Planning Commission of characteristics related to production identified a need for reasonable operating and location conditions designed to mitigate olfactory impacts related to outdoor and indoor grow operations. The state defines two tiers of canopy sizes for indoor and outdoor grows under Production licenses: Indoor Production Outdoor Production Tier 1- Up to 5,000 square feet Tier 1- up to 20,000 square feet Tier II- 5001-10,000 square feet Tier II- 20,001-40,000 square feet Considering the potential olfactory impacts related to both indoor and outdoor production and other site design characteristics required for site plan and MDS approval the following special standards are proposed by staff for production within the Heavy Industrial District: Production Facilities 1. Indoor Production Facilities licensed by the State of Oregon as a Tier 1 operation shall be located within a permanent structure on a lot no smaller than 1 acre in size, shall not be located within 500 feet of any zoning district allowing residential use, and shall provide a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line. 2. Indoor Production Facilities licensed by the State of Oregon as a Tier II operation shall be located within a permanent structure on a lot no smaller than 5 acres in size, shall not be located within 1000 feet of any zoning district allowing residential use, and shall provide a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line. 3. Outdoor Production Facilities licensed by the State of Oregon as a Tier I operation shall be located on a lot no smaller than 5 acres in size, shall not be located within 1000 feet of any zoning district allowing residential use, and shall be screened or secured in accordance with state statutes and this code for outdoor storage. Any structure on site used for production purposes shall provide a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line. 4. Outdoor Production Facilities licensed by the State of Oregon as a Tier II operation shall be located on a lot no smaller than 10 acres in size, shall not be located within 1000 feet of any zoning district allowing residential use and shall be screened or secured in accordance with state statutes and this code for outdoor storage. Any structure on site used for production purposes shall provide a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line. ATT1, Page 7 of 11 Commentary: Discussions with the Planning Commission of the known characteristics related to processing identified a need for reasonable operating conditions designed to mitigate impacts related to the most intense processing operations, notably extraction with butane or other chemicals. Processing Facilities 1. Processing Facilities performing testing, including marijuana testing laboratories, processing, or manufacture of edibles or concentrates shall be located within LMI or HI Districts and be completely enclosed within a permanent structure provide with a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line. 2. Processing Facilities processing cannabinoid extracts shall be located within HI Districts, shall be located 500 feet from any district allowing residential use and be completely enclosed within a permanent structure provide with a controlled exhaust system with filters designed to significantly reduce or eliminate odors at the property line and shall be subject to Type II Site Plan Review. 3. Licensed or registered and operated in accordance with Oregon Revised Statutes and applicable Oregon Administrative Rules. 4. Licensed and regulated as specified in Chapter 7 of the Springfield Municipal Code; 5. Located on and take access from an arterial or collector street; and Commentary: Discussions with the Planning Commission of the known characteristics related to production identified a need for reasonable operating conditions designed to mitigate olfactory impacts related to outdoor and indoor grow operations. Wholesale Facilities 1. Licensed or registered and operated in accordance with Oregon Revised Statutes and applicable Oregon Administrative Rules. 2. Licensed and regulated as specified in Chapter 7 of the Springfield Municipal Code. 3. Located on and take access from an arterial or collector street. 4. Within 50 feet of any residential zoning district (“within 50 feet” means a straight line measurement in a radius extending for 50 feet, including public right-of-way, in every direction from any point of the property containing a Marijuana Retail Outlet. 5. No retail sales shall be permitted from any wholesale marijuana distribution facility. 6. No outdoor storage of any marijuana items shall occur at a wholesale marijuana distribution facility. ATT1, Page 8 of 11 Commentary. The intent of the Subsection below is to not penalize existing marijuana dispensaries that have been: 1) approved prior to these proposed amendments; or 2) if a school, park or another protected use locates within a proposed locational standard area after a marijuana business has been approved under these proposed regulations. E. The siting of a future school, daycare or park use that affects a licensed marijuana business existing at the time of the siting, shall not make the existing marijuana business in violation of the locational standards specified in this Code, nor shall it be grounds to refuse to renew a license. F. In the event that a licensed or registered marijuana business is existing on [INSERT EFFECTIVE DATE OF ORDINANCE HERE], that existing use is allowed to continue as approved. In the event a marijuana business is unoccupied, discontinued or unlicensed for 6 months or more after the above date, it shall be subject to the non-conforming use standards of Section 5.8-100 of this code. Commentary. In addition to meeting the proposed locational standards, establishment of marijuana businesses will require the following applicable planning review process. All marijuana businesses are required to be located on properties annexed to the City of Springfield to allow enforcement and licensing as prescribed by the Springfield Municipal Code, and all businesses permitted under this code are considered urban uses and are not permitted in the UF/10 Overlay District. G. Planning Review. 1. When the proposed marijuana business is a change of use in an existing building, Minimum Development Standards (MDS) as specified in Section 5.15-100 will apply. 2. When the proposed marijuana business is to be located in a new building, Site Plan Review standards as specified in Section 5.17-100 will apply. 3. MDS or Site Plan Review approval by the Director will require, in addition to any other conditions of approval, a copy of the state license or registration and a copy of the City of Springfield marijuana business license pursuant to Chapter 7 of the Springfield Municipal Code. These documents shall be required prior to occupancy. 4. All marijuana businesses allowed under this code shall occur on properties inside city limits. Commentary. The statutory definitions of medical and recreational uses consistent with Chapter 7 of the Springfield Municipal Code will be inserted prior to public review. Section 6.1-110 Meaning of Specific Words and Terms Cannabinoid means any of the chemical compounds that are the active constituents of marijuana. Cannabinoid concentrate means a substance obtained by separating cannabinoids from marijuana by: (a) A mechanical extraction process; or (b) A chemical extraction process using a nonhydrocarbon-based or other solvent, such as water, vegetable glycerin, vegetable oils, animal fats, isopropyl alcohol or ethanol. ATT1, Page 9 of 11 Cannabinoid edible means food or potable liquid into which a cannabinoid concentrate, cannabinoid extract or dried marijuana leaves or flowers have been incorporated. Cannabinoid extract means a substance obtained by separating cannabinoids from marijuana by: (a) A chemical extraction process using a hydrocarbon-based solvent, such as butane, hexane or propane; (b) A chemical extraction process using the hydrocarbon-based solvent carbon dioxide, if the process uses heat or pressure; or (c) Any other process identified by the commission, in consultation with the authority, by rule. Cannabinoid product means a cannabinoid edible and any other product intended for human consumption or use, including a product intended to be applied to the skin or hair that contains cannabinoids or dried marijuana leaves or flowers. Cultivation or cultivate means: all phases of growth of marijuana from seed to harvest. Marijuana means the plant Cannabis family Cannabaceae, any part of the plant of the Cannabis family Cannabaceae and the seeds of the plant Cannabis family Cannabaceae. “Marijuana” does not include industrial hemp, as defined in ORS 571.300. Marijuana business means any person or entity appropriately licensed by the Oregon Health Authority or the Oregon Liquor Control Commission that sells, produces, cultivates, grows, wholesales, processes, researches, develops or tests medical marijuana or recreational adult use marijuana within the City of Springfield. Marijuana grow sites means a specific location registered by the Oregon Health Authority and used by the grower to produce marijuana for medical use by a specific patient. Marijuana items means marijuana, cannabinoid products, cannabinoid concentrates and cannabinoid extracts. Marijuana processing means the preparing, compounding, testing or conversion of marijuana into cannabinoid products, cannabinoid concentrates, and cannabinoid extracts for medical or recreational purposes. Marijuana production means the manufacture, planting, cultivation, growing, or harvesting of marijuana as licensed by the Oregon Liquor Control Commission or Oregon Health Authority. Marijuana retailer means a person or entity licensed by the Oregon Liquor Control Commission or Oregon Health Authority to sell marijuana items to a consumer in this state. Marijuana Retail Outlet means a business location that sells marijuana items to a consumer or patient. Marijuana testing laboratory means a laboratory that tests marijuana items for producer, processor, wholesaler or retail outlets. Marijuana wholesaler means a person or entity that purchases marijuana items in this state for resale to a person other than a consumer. Medical marijuana dispensary means a medical marijuana facility or entity registered with the Oregon Health Authority under ORS 475.300. ATT1, Page 10 of 11 Recreational marijuana means any marijuana intended for recreational use which meets all requirements for recreational marijuana contained in this chapter, Oregon state law, and any other applicable law. School means a building where individuals gather to receive educational instruction, either public or private, except as otherwise specifically defined in this code. School does not include a child care facility as defined in this Chapter. NOTE: This package of specific code amendment language is supported by the accompanying Staff Report and Findings document containing findings and conclusions in compliance with the standards of the Springfield Development Code for proposed amendments. ATT1, Page 11 of 11 ATT2, Page 1 of 1