Polk County Board of County Commissioners

Meeting Minutes - Final

May 07, 2024 Regular BoCC meeting

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CALL TO ORDER - 9:00 a.m. (BILL BRASWELL, CHAIR)

INVOCATION

Murphy Hanley, Polk County Fire Rescue Chaplain

PLEDGE OF ALLEGIANCE (BILL BRASWELL, CHAIR)

PRESENTATIONS and RECOGNITIONS

A.1. Lance Schmidt, Managing Principal of Office, Central Florida of

CliftonLarsonAllen, LLP will present the Annual Comprehensive Financial Audit

for the fiscal year ended September 30, 2023.

Minutes: Clerk and Comptroller Stacy Butterfield, CPA, said that Lance Schmidt,

CliftonLarsonAllen, LLP, will present the Annual Comprehensive Financial Audit for the

fiscal year ended September 30, 2023. She thanked Mr. Schmidt and his team, the

Board of County Commissioners, County Manager Bill Beasley, Deputy County

Manager Todd Bond and team, Comptroller Division Director Dee Dee Beaver and the

Comptroller Division. She said it takes coordination and she appreciates all the work.

She said this will also be available on the website.

Mr. Schmidt showed slides and gave an overview of the Annual Comprehensive

Financial Audit. He discussed the professional services performed. He said the

constitutional officers have a separate report and all of that is ultimately combined. He

said they issue 26 different reports and eight different financial statements. He

discussed the Independent Auditors' Report, the Single Audit Report, Independent

Auditors' Report on Internal Controls and the Management Letter. He thanked the

Board for the opportunity to provide these services.

REQUEST FROM THE GENERAL PUBLIC/AUDIENCE AND OPPORTUNITY TO BE

HEARD

C.1. Comments.

Minutes: Carolyn Williams said she is a member of PEACE-Elder Care. She discussed

families spending their entire savings on health care. She said services allowing them

to live independently is expensive. She discussed the difficulties with providing care.

She said one in five seniors live in poverty. She said that services have decreased. She

said in 2023 over 3,200 senior citizens were on a waiting list for community-based

services and 2,000 were on the list for in-home services. She asked for one of the

commissioners to meet with them to discuss PEACE.

Doretha Tillman said she is concerned with elder care for low income seniors. She

discussed her mother and having to care for her. She said it was difficult to care for her

and said she was constantly worried. She discussed being able to use the Adult Day

Care Center and said the services have stopped. She said seniors deserve to be cared

for. She said the county should not get out of the business of caring for seniors. She

asked one commissioner to take the lead and meet with PEACE.

Terry Hutchins said she is a member of PEACE. She asked a Board member to meet

with PEACE. She discussed the hardship with caring for her grandmother.

Christine Gyulavics-Reyes said she is a member of PEACE and said she is concerned

for the care for low-income seniors. She asked the Board to act and meet with them.

Reverend Lois Ann Sorensen said she is here for PEACE. She said they are

concerned about the care of seniors. She discussed the care that is needed for

seniors. She said many in the county do not have the resources.

Shanna Fox said she attended an event for PEACE and there were 1,000 constituents

there that care about this. She said they encourage them to meet with PEACE. She

said it is not the time to ignore this. She said 28% of the population must be a priority.

She said there are a lot of people who care. She asked for a commitment.

Jim Powers said he is the Chair of the Polk County REC. He said he is horrified by

what goes on in our election process. He said our voting is connected to the internet.

He said there are vulnerabilities with the voting systems and said we are completely

unprotected. He said we should stop using these systems. He said we can go to a

hand count of paper ballots and save money. He asked that a precinct level hand

count process be mandated.

Jessica Post said taxpayer money is being wasted on River Ranch Acres. She

discussed un-permitted structures. She discussed a cattleman and free-grazing the

cattle. She said to think about the money wasted on ten people and she said there are

42,000 people on the north and south side of River Ranch that need to be addressed

for the same thing. She said Code Enforcement asked to ignore the sheds, side yards

and un-permitted structures because they did not have enough manpower and it was

approved. She discussed Commissioner Wilson and him seeing the un-permitted

structures. She discussed Commissioner Combee and an article he wrote and she

commended Commissioner Combee for standing up for people.

APPROVE CONSENT AGENDA

D.1. Approve Consent Agenda.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

George Lindsey

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

COUNTY COMPTROLLER (STACY M. BUTTERFIELD, CPA)

E.1. Disbursements.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

E.2. Minutes of Regular Board meeting held on April 16, 2024.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Rick Wilson

Neil Combee

Lindsey, Braswell, Combee, Santiago, and Wilson

COUNTY MANAGER (BILL BEASLEY)

H.1. Request Board approve 1) Construction contract with Strickland Construction,

Inc. for the Polk County Sheriff’s Office Ridge District Station at Poinciana

project ($10,543,327.00 one-time expense), and 2) CIP amendment and budget

transfer in the amount of $2,310,849.00 from General Capital Improvement

Fund Reserves.

Minutes: County Manager Bill Beasley discussed the construction contract with

Strickland Construction, Inc., for the Polk County Sheriff's Office Ridge District Station

at Poinciana project, CIP amendment and budget transfer. He recommended approval.

Sheriff Grady Judd said it is his honor to be their Sheriff and he thanked the Board for

making public safety a top priority. He said over 100,000 people have moved here in

the last four years because of their remarkable leadership. He said the people of

Poinciana have asked for years for a police station. He said this will not be for just

Poinciana but it will be for that entire sector of the county. He said they are going to call

it the Ridge District at Poinciana if approved. He said it is the same district station that

the Board approved off of Dunson Road with a fleet maintenance bay for oil changes,

tire rotations and minor stuff. He said they can save money there and do it for less cost.

He said it is the right thing and right time because of the population explosion in the

northeast area. He said they are going to divide the northeast district.

Chair Braswell said we broke ground on this two years ago.

Commissioner Santiago said it was two years ago. She thanked them for moving

forward with this and said it is exactly what they need in this area. She said it is the

fastest growing area in our county and we need to make our citizens safe.

Commissioner Combee said the area deserves service and he is happy about this.

Sheriff Judd said two deputies were involved in a horrible violent situation. He said they

were patrolling Green and Duff Road and recently had a break-in at the concession

stand there. He said they had young gang bangers flipping handles. He said as a result

of checking out a vehicle there was a sovereign citizen who refused to cooperate. He

said after trying to deescalate the situation, he continued to argue and shot two

deputies; Deputy Craig Smith and Lieutenant Chad Anderson. He said they returned

fire and he will never pull a gun, shoot another person again and is graveyard dead. He

said he asked for this and they obliged. He said the deputies are home, alive and well

and are healing. He said they had tremendous support from the community, the Board

and the Sheriff's office.

Chair Braswell said we are always praying for all the deputies all the time.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Rick Wilson

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

H.2. Approve construction contract with Strickland Construction, Inc. for the

construction of a new roadway maintenance facility in Frostproof.

($4,410,000.00 one-time expense).

Minutes: County Manager Bill Beasley discussed the construction contract with

Strickland Construction, Inc., for the construction of a new roadway maintenance

facility in Frostproof. He recommended approval.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

George Lindsey

Lindsey, Braswell, Combee, Santiago, and Wilson

H.3. Approve construction contract with Crisdel Group, Inc. for the Fort Fraser Trail

Extension - Winter Lake Road to Glendale Street ($6,943,298.20 one-time

expense)

Minutes: County Manager Bill Beasley discussed the construction contract with Crisdel

Group, Inc., for the Fort Fraser Trail Extension - Winter Lake Road to Glendale Street.

He recommended approval.

Mr. Beasley said that 56% of the funding is state funded and the rest is county funded.

Commissioner Lindsey said the Holloway family donated the easement for this. He said

Orlando Health acquired some of the property and agreed to honor the commitment

Mr. Holloway made.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

George Lindsey

Rick Wilson

Lindsey, Braswell, Combee, Santiago, and Wilson

H.4. Approve Local Agency Program (LAP) Supplemental Agreement with the Florida

Department of Transportation (FDOT) to fund the construction phase of the

Inwood Elementary School sidewalk improvement project, CIP Amendment,

Resolution and budget amendment. ($554,455.00 one-time revenue)

Minutes: County Manager Bill Beasley discussed the Local Agency Program

Supplemental Agreement with the Florida Department of Transportation to fund the

construction phase of the Inwood Elementary School sidewalk improvement project,

CIP Amendment, Resolution and budget amendment. He recommended approval.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

George Lindsey

Lindsey, Braswell, Combee, Santiago, and Wilson

H.5. Approve the contract with Central Florida Health Care, Inc. (CFHC) for the

proposed purchase and renovation of a new community health center in

Mulberry. (Total amount not to exceed $4,000,000)

Minutes: County Manager Bill Beasley discussed the contract with Central Florida

Health Care, Inc., for the proposed purchase and renovation of a new community

health center in Mulberry. He recommended approval.

Commissioner Lindsey said this is the former PenFed Credit Union building in

Mulberry. He said it is a great addition to the community and is a great facility.

Mr. Beasley recognized Ann Claussen with Central Florida Health Care, Inc., for being

here.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Martha Santiago

Neil Combee

Lindsey, Braswell, Combee, Santiago, and Wilson

H.6. Approve the contract with Winter Haven Hospital, Inc. d/b/a Center for

Behavioral Health (WHCBH) for the proposed renovations, equipment and

supplies. (Total amount not to exceed $408,966)

Minutes: County Manager Bill Beasley discussed the contract with Winter Haven

Hospital, Inc. d/b/a Center for Behavioral Health for the proposed renovations,

equipment and supplies. He recommended approval.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

COMMISSIONER DISTRICT 1 (GEORGE LINDSEY)

I.1.

Appoint Susan L. Smith as a member of the Housing Finance Authority for the

remainder of the four-year term ending January 22, 2025.

RESULT:

MOVER:

APPROVED

George Lindsey

Rick Wilson

SECONDER:

Lindsey, Braswell, Combee, Santiago, and Wilson

AYE:

I.2.

Commissioner Lindsey Comments.

Minutes: Commissioner Lindsey said he would like to discuss the equestrian facility.

He said we have struggled with it for an extended period of time with Fort Meade. He

said now Bartow has expressed interest in moving forward and have done preliminary

planning. He said that the discussion on Friday was to abandon the Bartow efforts and

instruct staff to proceed with the county doing this on our own with the funds

designated for that purpose. He said before we take that vote he would like Mr. Herr

and his team to make a presentation on what they propose for this facility on how they

will finance, operate, and maintain it.

Commissioner Wilson said he knows Bartow's ideas and what they want to do with this.

He said for Bartow it is not possible to finance their dream of this equestrian center. He

said he wanted to have someone run it, take care of it and keep the county out of it

because the county has other projects going on. He said the vision of what he would

like to see is an agricultural equestrian linked facility for our Youth Fair and our place

on Highway 17 that is out of room. He said he does not think people are looking upon

millions and millions of dollars and everybody gets off track to what he would like to

see. He said everybody looks at this as a money making opportunity and the cities

would not want to be involved in it if they did not think it was a big grandiose deal to

make money. He said he admires their thinking on what could be done. He said he

sees a $150 million project. He said funding this was how we could help. He said we

have the ground and personnel, and lets build what we got. He said our Youth Fair and

equestrian center can be a part of it. He said he sat down with Mike Herr and said we

need to move quick and that was over a year ago.

Commissioner Combee said he does not object to having Mr. Herr come and make a

presentation and he supports the idea so we are all on the same page. He said that he

agrees with Commissioner Wilson that if it is going to get done it is going to be on us.

He said he does not want to slow down what Commissioner Wilson wants to do. He

said we are not going to build a world equestrian center whether it is us alone or us

with a city. He said it has been a long time getting nothing done.

Commissioner Santiago said her concern was when they dealt with Fort Meade they

just kept pushing us forward and forward and it turned out that the city was not able to

afford it. She said she does not want to see the same thing happening to Bartow. She

said they can make their presentation. She said she does not want to wait again as we

did with Fort Meade. She said the faster we go the better it is and she does not want

this to drag out anymore.

Commissioner Lindsey said he shares that concern but he does not have the benefit of

Commissioner Wilson's conversation with Mike and his team. He said he was not a fan

of this to begin with. He said it goes back ten years and a few more weeks is not going

to make a difference. He said we may come back to what Commissioner Wilson has

described but he would like to hear the alternative. He said as a courtesy he would like

to hear the plan.

Chair Braswell said they will move forward and the City of Bartow can make a

presentation at the next agenda review.

Commissioner Lindsey said they are showing what the $6.3 million can do and provide.

Upon question, County Manager Bill Beasley said parks are a core service that we

provide that the citizens want whether active leagues or passive parks. He said it is part

of the tools that the public expects and they do not make money.

Commissioner Wilson said we have $6.5 million set aside for this. He said what Bartow

has envisioned in this project is multiple millions of dollars. He said they do not have a

clue how they will do this and they have no money. He said all we are doing is waiting

and pushing this down the road.

Commissioner Combee said he does not know how we plan to go forward on

evaluating the property and what $6.5 million will do for it. He said somebody can start

that process.

Chair Braswell said Keith Tate is working up a basic plan.

Commissioner Lindsey said he wants to discuss the action of Mr. Schmidt as a

member of the Planning Commission and going outside the parameters of protocols as

a planning commissioner. He said it was a bad act on his behalf, shows a lack of

respect for the protocol and how things are structured. He said regardless of the merits

of the issue it was the manner in which it was brought forward. He discussed him being

asked to resign or have a remedial training session with the County Attorney's office.

He said he obviously missed something and for him to not be allowed to participate

until he completes that remedial training.

Motion: At a minimum Mr. Schmidt will be required to take remedial training with the

County Attorney's office, he missed something in the protocol lesson, before he is

allowed to go back to sitting on the Board; motion dies for lack of second.

COMMISSIONER DISTRICT 2 (RICK WILSON)

J.1. Commissioner Wilson Comments.

Minutes: Commissioner Wilson discussed Bone Valley and said this past weekend we

had the ribbon cutting for the bridge that is connecting the two properties from Bone

Valley South to Bone Valley North. He said people need to go out and look that it is

unbelievable. He said Bone Valley South has been growing and he discussed the

growth of the ATV market. He said it has turned out to be very populated with people

coming to ride their ATVs. He said it is a safe place to go and they have a lot of room to

grow with the north side. He thanked the past commissioners that started this and he

thanked the commissioners now for supporting this. He said the admissions has

doubled. He said this has turned out great and will be a premier motor cross track. He

said for everyone to go out, and that they have rentals there.

COMMISSIONER DISTRICT 4 (MARTHA SANTIAGO)

K.1. Commissioner Santiago Comments.

Minutes: Commissioner Santiago asked about the elderly care discussion and said it

brought her to all the programs we do through indigent health care. She asked in what

ways are the elderly cared for and she said she wants to know what is being done on

that.

Joy Johnson, Indigent Health Care, said they are putting together a team for

explorations on unmet needs, a gap analysis in the community with the elderly

population, and some of the needs going on that has come to their attention. She said

if there is an opportunity to align the use of these dollars to help meet some of those

needs they want to pursue those. She said they have a plan and will mobilize it soon.

Commissioner Santiago said the comments that were made were they wanted to meet

with one of us here and she wants to know what is going on with the programs and how

it is helping out.

Ms. Johnson said she will also be meeting with them.

COMMISSIONER DISTRICT 5 (NEIL COMBEE)

L.1. Appoint Adam Bass as an alternate member of the Polk County Planning

Commission for the remainder of the three-year term, May 7, 2024 to July 1,

2026.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

L.2. Commissioner Combee Comments.

Minutes: Commissioner Combee said that the county attorney needs to prepare a

memo for all of us and the Planning Commission (PC) about what is protocol, what the

parameters are, what they may and may not say, what are those boundaries, the

difference between legislative action and quasi-judicial action and a clear distinction

between those two. He said he did not question Mr. Bass, he had an interest in serving,

and someone said he would do a good job so he put him on here to get appointed. He

said he does not have an agreement on what he will or won't say or what he likes or

doesn't like. He said it is important and he will defend Mike Schmidt because it is a

legislative issue. He said it would be just like us sitting up here with something coming

before us that we don't like that we are sworn to silence and can't say anything about it

and that obviously is not the case. He said if it is the case he wants them to put it in

black and white.

County Attorney Randy Mink said in lieu of doing a memo we have a huge training that

we do for the PC and he would like to send it to them so they can see what the training

covers.

Commissioner Combee says he wants a memo from Mr. Mink that says here is what is

quasi-judicial for the Board of County Commissioners and Planning Commissioners

because they are basically operating in our stead.

Mr. Mink said he said he can do a memo and he wants them to see the training that

they do.

Commissioner Combee said there are five members of this Board and they are

required by law to notice public hearings. He said the idea that you would announce a

public hearing seems like a service. He said if he does not like something he has the

right if it is legislative to say he does not like it at the grocery store, barber shop, church

or wherever. He said we need something concise and an executive summary for

people who are not going to go through training and have no interest of being a

member of the PC or this Board.

Commissioner Combee said he could not make it out to Bone Valley and he wanted to

go and see what the county staff had accomplished. He said when the north side is

done it will be spectacular. He said he does not look back a lot on decisions he made

and he did not have to make one on this because it was in the early stages. He said

Randy Wilkinson was the one who kept wanting to build this. He said he is happy to

hear it when they look at the situation with Rancho Bonito being disorderly and out of

control. He said he would like to see it expanded even more.

COMMISSIONER DISTRICT 3 (BILL BRASWELL, CHAIR)

M.1. Chair Braswell Comments.

Minutes: Chair Braswell said we still have six people showing up at the Planning

Commission (PC).

County Attorney Randy Mink said the ordinance dictates how many are on the PC. He

said they want to come back to the Board on adopting a policy on the steps if the PC

members do not show up.

Chair Braswell said this is a hugely important job that involves tens of millions of dollars

of development monies whether it is spent or not. He said these guys deserve a

well-trained well-versed group.

Commissioner Lindsey suggested requiring the alternates to attend.

County Manager Bill Beasley said they are discussing increasing the amount of

alternates and requiring alternates at every PC meeting.

Commissioner Wilson said he understands what everyone is saying. He said we have a

hard enough time getting them to come now and you hammer them in taking more

courses. He asked what are you gonna do if they don't show up.

Mr. Mink said they want to come back with suggestions on what the Board wants them

to do.

Commissioner Combee said the Water Cooperative has four members and it is the

same three who come. He said the staff emails, calls and lets them know that they

need them there.

Mr. Mink said they are looking at the alternates being on call and having an alternate

designated to be there.

Land Development Director Ben Ziskal said when they find out a regular member

cannot be there, they make phone calls to the alternates and the alternate often has

prior engagements. He said they receive phone calls or emails that morning that they

cannot be there.

Commissioner Santiago said talking to people in public is one thing and she said the

FaceBook post is wrong and they should address it. She said it is not appropriate. She

said talking to someone on a personal basis is not what this is about.

Commissioner Combee said he wants Mr. Mink to address what is out of bounds or

outside the law.

LAY BOARD APPOINTMENTS

N.1. Appoint Le Rue “Skip” Stellfox to the Tohopekaliga Water Authority (TWA)

Board of Supervisors for the remainder of a vacated term and a new 1-year term

ending September 30, 2025.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Rick Wilson

George Lindsey

Lindsey, Braswell, Combee, Santiago, and Wilson

EXPEDITED HEARINGS PURSUANT TO RESOLUTION NO. 2022-089

Minutes: County Attorney Randy Mink reminded the audience of the procedures for

expedited hearings and public hearings and swore in those who plan to speak.

P.3. Public Hearing to consider adoption of an ordinance amending Polk County

Ordinance 2022-029, the Polk County Local Provider Participation Fund

Ordinance (no fiscal impact).

Minutes: County Attorney Randy Mink discussed the ordinance amending Polk County

Ordinance 2022-029, the Polk County Local Provider Participation Fund Ordinance. He

recommended approval.

The Chair opened a public hearing; no one spoke.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Neil Combee

George Lindsey

Lindsey, Braswell, Combee, Santiago, and Wilson

O.1. Public Hearing (LDCPAL-2023-11 US 27 NR SAP ECX) (Transmittal Hearing) to

consider the adoption of a Large-Scale Comprehensive Plan Amendment to

change the Future Land Use designation on 29.69+/- acres from Professional

Institution-X (PIX) to Employment Center-X (ECX) and to amend Policy

2.131-Q4, M, c (a) to delete the new driveway access prohibition to US 27 within

the Transit Supportive Development Area (TSDA), Transit Corridor and Transit

Center of the Transit Centers and Corridors Overlay. (No Fiscal Impact)

Minutes: Land Development Director Ben Ziskal discussed the proposed text

amendment. He said that the Planning Commission and staff recommend approval. He

said this is a transmittal hearing.

Upon question, Mr. Ziskal said not having a driveway in the TSDA was to limit driveway

connections and have the driveways connect to the existing east/west roads.

The Chair opened a public hearing; no one spoke.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

George Lindsey

Martha Santiago

Lindsey, Braswell, Combee, Santiago, and Wilson

O.2. Public Hearing (LDCT-2024-3 Recreational Camping LDC Text Amendment)

(First Reading) to consider the adoption of a County-initiated request to modify

Conditional Use criteria for Recreational Camping and RV Parks (No Fiscal

Impact).

Minutes: Land Development Director Ben Ziskal reviewed the proposed text

amendment. He said that the Planning Commission and staff recommend approval. He

said that this is the first reading.

The Chair opened a public hearing; no one spoke.

O.3. Public Hearing (LDCT-2024-4 Streets & Pedestrian Safety Text Amendment)

(First Reading) to add EV Charging Stations as accessory uses and require 20

MPH speed limits signs on Level 2 plans for residential subdivisions with public

roads. (No Fiscal Impact).

Minutes: Land Development Director Ben Ziskal reviewed the proposed text

amendment. He said that the Planning Commission and staff recommend approval. He

said that this is the first reading.

Commissioner Lindsey said on a recent trip there was a charging station and the

business decided to put the charging station on an adjacent piece property and get its

own address. He said the general public could Google that address and make use of

those facilities.

Upon question, Mr. Ziskal said this text amendment considers the charging station as

an accessory to the primary use. He said they could look at how they could allow for a

stand-alone use. He said he is not aware of a free standing charging station.

The Chair opened a public hearing; no one spoke.

O.4. Public Hearing (LDCT-2024-5 Boat Ramps Amendment) (First Reading) to allow

administrative approval of Boat Ramps to be open 24 Hours in Recreation Open

Space (ROS) land use districts (No Fiscal Impact).

Minutes: Land Development Director Ben Ziskal reviewed the proposed text

amendment. He said that the Planning Commission and staff recommend approval. He

said that this is the first reading.

The Chair opened a public hearing; no one spoke.

PUBLIC HEARINGS

P.1. Public Hearing (LDCU-2024-4 North Lakeland Brownfield Designation)

(Adoption Hearing) to consider the designation of a 22.5-acre site as a

Brownfield. (No Fiscal Impact)

Minutes: Mark Bennett, Land Development, showed slides and reviewed the North

Lakeland Brownfield Designation. He discussed the location of the site and said the

request is to designate 22.5 acres as Brownfield.

The Chair opened a public hearing; no one spoke.

RESULT:

MOVER:

SECONDER:

AYE:

APPROVED

Rick Wilson

Neil Combee

Lindsey, Braswell, Combee, Santiago, and Wilson

P.2. Public Hearing (LDCPAL-2023-12 Green Swamp Density CPA Text)

(Transmittal Hearing) to change SECTION 2.132-D RURAL SPECIAL

PROTECTION AREA (RURAL-SPA) and modifications of POLICY 2.132-D4