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HomeMy WebLinkAbout20060946.tiff • . REUTZEL & ASSOCIATES, LLC ATTORNEYS AT LAW 9145 EAST KENYON AVENUE,SUITE 301 Land Use/Zoning DENVER,COLORADO 80237 Real Estate Telephone(303)694-1982 Annexations Fax(303)694-3831 Community Associations www.reutzelandassoc.com Oil and Gas Local Government JACK E.REUTZEL jack @reutzelandassoc.com July 29, 2005 Monica Mika, Director Weld County Planning and Zoning Department 918 10th Street Greeley, CO 80631 RE: Pioneer Comprehensive Plan Amendment Dear Monica: On behalf of my clients, HP Farms,LLC and Pioneer Communities, Inc., I am pleased to deliver the necessary application materials for a Comprehensive Plan Amendment (the "Amendment"). This Amendment seeks to establish a new urban area of approximately 4,236 acres (the "Pioneer Development Area" or"PDA") located generally at the intersection of WCR49 and WCR22. The change in land use designation for the PDA is supported through an application of existing Comprehensive Plan goals and policies to the PDA. The Amendment addresses (1) why the Comprehensive Plan is in need of amending and (2) the goals and policies of the Comprehensive Plan that support the Amendment. By applying the existing goals and policies, the Comprehensive Plan can accommodate this Amendment as presented with the inclusion of a new land use map in the Comprehensive Plan designating the PDA as an Urban Area. We have also included materials in our Application, (such as market study, fiscal analysis, preliminary traffic analysis, population estimates) which the County has traditionally required for amending the I-25 Mixed-Use Designation ("MUD") Area for additional support for the establishment of a new urban area. However, this Amendment stands on its own as an urban area. It is not an amendment to the existing MUD Area because that area is geographically separate and has a different set of variables to be addressed. The text and accompanying technical appendices and exhibits support the establishment of this new urban area that is in the best interest of the citizens of Weld County because the Amendment: • protects prime irrigated agricultural lands • promotes more efficient use of land and natural resources 2006-0946 Monica Mika, Director July 29, 2005 Page Two • utilizes existing transportation infrastructure • provides for modern regional water and sewer infrastructure and service • maintains Weld County water resources in Weld County • provides a population base that increases demands for employment opportunities and retail growth that will generate economic gain in this area and increase property values Please be advised that we have met and will continue to meet with interested organizations, groups and individuals about the Amendment and will supplement your files accordingly. My clients particularly appreciate the time you and other members of the County have spent to date in reviewing with us the procedural and timing requirements. We will also be vigilant in responding to County comments and referral comments and will supplement the Application accordingly. Enclosed with this Application is the first installment of our application fee of $25,000.00 in accordance with a separate agreement with the County. Finally, given the volume of material to be reviewed in connection with this Amendment request, I hereby waive the time deadlines for processing contained within Sec. 22-1-150 of the Comprehensive Plan and will work with you to determine a mutually satisfactory time schedule. Your offer of a late November Planning Commission date is appreciated and I commit our team to trying our best to meet the date. On behalf of my clients and the entire application team, I look forward to your review and in working with you in the months to come. Very Truly Yours RE r & ASSOCIA , LC By: �t ack E. -utzel ATTACHMENT F Correspondence REUTZEL & ASSOCIATES, "Lc ATTORNEYS AT LAW Land Use/Zoning Real Estate 9145 EAST KENYON AVENUE,SUITE 301 Annexations DENVER,COLORADO 80237 Community Associations Telephone(303)694-1982 Oil and Gas Fax(303)694-3831 Local Government wwwseutzelandassoacorn Corporate October 17, 2005 Ms. Michelle Martin, Planner Weld County Department of Planning Services North Office 918 10th Street Greeley, Colorado 80631 Re: Response to staff comments dated August 2005 for the Pioneer Comprehensive Plan Amendment land generally located in Sections 4,5,7,8,9,17,18, T2N, R64W Section 32 T3N, R64W, and Sections 1,2,11,12,13,14,15, T2N R6SW of the 6th PM, Weld County, Colorado (the "Property") • Dear Michelle; • This-letter is intended to accompany the revised Pioneer Comprehensive Plan Amendment which reflects modifications made to the text, appendices and maps as requested by the County in its initial review for a complete application of the Pioneer Comprehensive Plan Amendment. Below you will find answers to each question asked by the various County departments who participated in the initial round of review. Prior to that point by point review however I wanted to highlight some basic changes we have made to the Application based on major County comments and recent activities that have affected the Property. 1. All Property owned by the Applicant has now been included in the Application. Staff's initial review suggested that it was confusing to have the "Agricultural" designated property owned by the Applicant not being part of the Amendment while the Amendment still addressed proposed limitations and commitments relating to the agricultural zoned ground. In order to remove any confusion about the commitments made regarding the Agricultural designated property, we have included all property owned by the Applicant into the Amendment. 2. The Application no longer proposes a Neighborhood Center land use designation. The Neighborhood Center (Commercial/Mixed Use) designation has been deleted from this revision. The amount of commercial development proposed by the Applicant is 200,000 square feet at full build out. This level of commercial development can be accommodated under the County's Comprehensive Plan policy of allowing neighborhood scale commercial uses within "Residential" land use designations. By limiting the amount of commercial development we further the intent of the Amendment to encourage large-scale destination retail to develop in the existing towns and along the I-76 corridor. REUTZEL & ASSOCIATES,LLC • Pioneer Comp Plan Amendment Response ^ October 17, 2005 Page Two 3. The Application reflects a planned roadway connection to the Town of Keenesburg. In response to a request from the Town of Kennesburg (letter attached) and to strengthen the relationship between Pioneer and Keenesburg, the updated traffic study depicts a proposed connection from Pioneer to Keenesburg along the alignment of Weld County Road 22. The connection will facilitate access to I-76 for much of the eastern part of the Pioneer development. Additional benefits to Pioneer will be the improved operation of the Weld County Road 49 and Weld County Road 22 intersection. Keenesburg will benefit from this connection because it will emphasize the service and commercial opportunities around the Keenesburg intersection of 1-76. 4. The Application has been updated to reflect recent activities of Pioneer and Resource Colorado. Since the initial submission of this Application, the Applicant has submitted service plans for seven metropolitan districts. These seven districts are designed to plan, build and maintain infrastructure needed for development consistent with • this Application. References to the Pioneer Metropolitan Districts throughout the Application are to these districts. In late September, Resource Colorado Metropolitan district was granted conditional approval to become a designated management agency from the North Front Range Water Quality Planning Association. This step entitles Resource Colorado to begin the design and processing an application for the siting of a wastewater treatment plant. One of the conditions attached to the approval is the approval of this Amendment Application. The following specifically address staff statements: Planning Department Comments • The applicant needs to include Weld County Paramedic Services as a service provider. RESPONSE: The table in Chapter 1 Section 1-90 has been modified to include Weld County Paramedic Services as one of the Fire/Emergency Service providers. • The applicant needs to clearly identify the reason why the Comp. Plan is in need of a revision. RESPONSE: Section 1-40 Justification discusses the reason why the Comp. Plan is in need of revision. In addition we have summarized why the comp Plan requires an amendment in the opening paragraph of Chapter 1. We have also included a summary sheet with the executive summary that discusses Why, What and How of this amendment request. 2 REUTZEL & ASSOCIATES,LLC Pioneer Response October 17, 2005 Page Three • The applicant needs to define what areas will be affected by the amendment, throughout the maps and contents. RESPONSE: The area affected with this amendment includes the Property within the boundaries of the PDA. The actual boundaries are legally described in Appendix A and graphically represented in Exhibit 2 of this application. The property is generally described on other maps with a note referencing those exhibits. • It would help if some of the maps were clearly labeled including the roads and make sure the legends are accurate. RESPONSE:Additional detail including legends and roads have been added to the Exhibits. • Fire District Map shows a significant amount of Pioneer land that is not in a Fire District. The applicants must petition into a fire district. RESPONSE: The Service Plans for the Pioneer Metropolitan Districts include a fire service component. It is the intent of Pioneer to enter into inclusion agreements and or IGA's with existing Districts, as warranted, to deliver adequate service to accommodate urban development. More detailed discussion of this issue occurs in Section 2-20.03 of the Amendment. • What would be included in a neighborhood center? Types of employment and the number of jobs the development will create (page 1-8) RESPONSE: The commercial land use designation has been removed. The concept (consistent with Commercial Policy 22-2-170.3.3 of the Weld County Comp Plan) is that neighborhood services will be permitted within the residential land use designation of the Comprehensive Plan to provide neighborhood oriented businesses that will provide support goods and services for the residential neighborhoods. This will restrict the type and intensity of the commercial uses. Employment projections are discussed in Section 1-80.01 and Appendix C-3 of the Amendment. As discussed in the text the neighborhood convenience commercial component may include but not limited to: service businesses, such as office; public facilities such as schools; civic uses such as places of worship; and parks. • Will there be residential above the commercial? RESPONSE: Not anticipated at this time. • The maps are not accurate they show an incorrect boundary for Pioneer. The maps have included exempted lands. RESPONSE:All lands owned by the Applicant have been included in the boundary. This includes the land that will remain in Ag. A note has been added to the maps that refer the user back to the legal description for the actual boundaries of the subject area of the Amendment. • How has the applicant identified the site influences, what are the references? The maps shall include referenced material. RESPONSE: Source references have been added to the site influence maps. • • REUTZEL & ASSOCIATES,LLC Pioneer Response October 17, 2005 Page Four • How will the open space (trails) within urban developments be connected to existing open space or defined as Ag on the maps. RESPONSE: A trail master plan has been included in the Appendix D illustrative materials. Further detail will be provided with the Sketch Plan submittal. • Need more information regarding the Ag university site? RESPONSE: The Ag university has been deleted from the map. This was never intended as a classroom facility. The concept was based on early discussions with Colorado State University to provide study opportunities on alternative and exploratory crop production and irrigation techniques. • How will the plan be amended in the future? What steps would someone take to amend this application? RESPONSE: Refer to 1-120 Future Amendments to Comprehensive Plan. SHERIFF • The Sheriff's office lacks the ability to absorb any additional service demand without the resources recommended in the multi-year plan provided to the Weld County Board of County Commissioners oras indicated by growth not considered at the time the plan was developed. Therefore the Sheriff's office will be requesting a L.E.A. to fund the additional resources required to properly serve the residents of these communities. RESPONSE: A draft resolution authorizing a LEA for the PDA is referred to in 2-20.02 of the Amendment and has been attached in Appendix G. • A permanent office / work space for the Sheriff's office to operate out of would provide the citizens with better service and enable the Sheriff's office to be more effective and efficient in the area. RESPONSE: Accommodations for service and ancillary facilities will be permitted and further refined with future entitlements. • Kenneth Poncelow, Commander of Weld County Sheriff's Office in his letter dated August 26 listed 8 issues / improvements for the Pioneer development. RESPONSE: All issues identified are reasonable recommendations and will be incorporated with Zoning and Subdivision applications, as appropriate. PUBLIC HEALTH AND ENVIRONMENT • Pg 1-7 Section 1-50 — The agricultural lands are included in the overall Property Boundary but the Department is confused as to whether these Ag. Lands will be preserved as such. RESPONSE: Agriculture has been included as a use category with the inclusion of the Ag land in the PDA. Previously we had not included the Ag land since it was already appropriately designated it was our position that it did not require an amendment. In order to clarify staff's concern Section 1-50.02 has been added. This section addresses techniques that can be imposed to appropriately limit and preserve the Ag use. REUTZEL & ASSOCIATES,LLC 4 Pioneer Response • October 17, 2005 Page Five • Pg 1-8 Section 1-50.01 - will Resource Colorado Water and Sanitation District serve the outlying, larger lots, through Metropolitan Districts, or will individual sewage disposal districts be allowed on these lots? RESPONSE: All uses within the residential land use category will utilize public water and public sewer provided by the Metropolitan Districts. • Pg 1-8 Section 1-50.02 states that the commercial development are not proposed as a regional component to draw traffic into the area as a destination. Is this a reasonable expectation? RESPONSE: Using the County's policy of encouraging only neighborhood services within the residential designated areas, we believe the regional commercial will locate in existing towns and along the frontage of the 1-76 corridor. • Tab F, pg 1 - request clarification / expansion on the "adequacy" of water to serve the area, i.e. anticipated years of availability, quality, etc. RESPONSE: Appendix F has been amended to address and clarify the adequacy of water appropriate to serve the area. • Exhibit 14 and Tabs H and I - Fire Districts - the Department is concerned that there appears to be areas of the Pioneer Development area that lie outside the boundary of any Fire Protection District (FPD). With the limited staffing of the Hudson FPD and Southeast FPD (mostly volunteer), the areas of each FPD, and the proposed density of development at full buildout, the Department is concerned with the level of service these districts are able to provide. Additionally, having multiple FPD's there could be some confusion as to jurisdictional boundaries and which agency will respond in an emergency. RESPONSE: Refer to discussion in 2-20.03 of the Amendment, the Service Plans for the Pioneer Metropolitan Districts have included a fire service component. In addition coordination through inclusion agreements or IGA's as warranted will be executed in order to deliver adequate service to accommodate urban development. ENGINEERING TRANSPORTATION COMMENTS • Section 1-90 Existing and Proposed Public Facilities and Services This section of the comp plan identifies Weld County Public Works as a provider of services - "Highways and Roads". The Public Works Department is not prepared to accept any responsibility for maintenance of highway, roads drainage facilities or other infrastructure improvements associated with this development. RESPONSE: The section is titled EXISTING and Proposed. Weld County is an existing service provider for the maintenance of the existing County roads in this area. The Applicant is aware of the County's position on maintenance of new infrastructure. 5 REUTZEL & ASSOCIATES,LLC Pioneer Response October 17, 2005 Page Six • Section 1-110 Transportation and Circulation The comp plan amendment states that the roadway system (i.e. WCR 49 and 22) will not need capacity improvements prior to the construction of 1,800 residential units. Public Works does not agree with this statement. Improvements to WCR 22 and 49 willl be required at the onset of the development. These will likely include shoulder widening, auxiliary lanes on WCR 49 and potential signalization. A more thorough, comprehensive investigation of the traffic impacts will need to be performed. RESPONSE: The transportation study has been revised accordingly. This will be further refined with the sketch plan and phasing submittals. • Public Works will require Pioneer Communities to provide a "master transportation plan" that shows the hierarchy of roads to be constructed, traffic capacities and timing of construction tied to the development phasing plan. The transportation master plan must also show how connections to existing county roads will be made and their respective impacts. RESPONSE: The Applicant is aware that a "master transportation plan"will be required. This master plan will be provided to the County for review at the time of Sketch Plan submittal. A Comprehensive Plan amendment is not the appropriate step for that detailed level of information. • Section 2-10 Urban Growth Nodes are Identified Areas of Potential Urban Growth A comparison is made between the Weld County Strategic Road system and the state highway system as potential justification of the "Urban Node" growth concept. While the strategic roads (WCR 49 & 22) are ultimately envisioned to be 4-lane roadways, they are not envisioned to "be designed to carry more traffic than many of the state classified roads." They are envisioned to provide intra-regional travel options between communities. Conversely, the state highway system is designed to provide inter- regional travel options across the state. It is Public Works' recommendation that the "Urban Node" concept for growth not be extended to include Strategic Roadways, many of which travel through very rural parts of Weld County. RESPONSE: The point we were trying to make is that the intersection of these two Strategic Roadways create a unique opportunity and have an effect on the surrounding land use. Weld County Strategic Roadways (WCR 22 and WCR 49) provide inter-regional travel options across the state similar to many roadways in the State Highway system. WCR 49 will provide connectivity from State Highway 14, north of Greeley, south ultimately to the Denver International Airport and WCR 22 will provide connectivity from Longmont to WCR 49. These will be four lane roadways and will carry more traffic than many of the two-lane state highways. The concept of urban growth node stems from the intersection of 2 or more roads that carry regional traffic. WCR 49 and WCR 22, as envisioned by Weld County clearly meet the objective test. Growth occurring at intersections of streets carrying regional traffic is a classic urban planning maxim and fits well with the Strategic Roadway model. fi 6 REUTZEL & ASSOCIATES,LLC • Pioneer Response - October 17, 2005 Page Seven • Section 2-20.5 Transportation This section alludes to the metropolitan district only providing maintenance for "certain" roadway improvements. Public Works will not accept maintenance for any improvements other than those completed on the already-existing system. RESPONSE: The Applicant understands Public Works position on maintaining new roads within the County. The funding of roadway improvements and maintenance will be determined at the time of subdivision plat. • Section 2-50.09 Transportation and Circulation (paragraph #3) This section discusses the metropolitan district's financial participation in both on and off-site road improvements. Public Works will require that all off-site road improvements needed due to the development will be paid for 100% by the metro- district and not a "pro-rata" share as mentioned in the discussion section. RESPONSE: The funding of roadway improvements and maintenance will be determined at the time of subdivision plat. • Both the comp plan amendment and the traffic study state "it is anticipated that this roadway (WCR 49 & 22) will be widened to a four or six-lane arterial roadway cross section with or without the traffic from the proposed Pioneer development." This statement is incorrect. The county's approach to strategic road improvements has been one in which we prioritize the highest need and construct a two-lane facility. Any widening beyond this two-lane configuration will be done by development. We currently do not have any improvements planned on WCR 49 or 22 in our 10 year capital improvement plan. RESPONSE: This statement has been removed from the comp plan amendment and the traffic study. • LSC assumes that extra capacity in a roadway equals safe, efficient operation. Again, improvements to the WCR 49/22 intersection will be required at the onset of the development. RESPONSE: The transportation study has been revised and now acknowledges that improvements to the WCR 49/ WCR 22 intersection will be improved with the initial phase(s) of development. • Public Works does not agree with LSC's estimates for trip distribution. As shown in the comp plan projections, the largest amount of users will be commuters to the Denver- metro area. As such, the distribution should be in the following ranges (75% south on WCR 49, 15% north on WCR 49, 10% on WCR 22) RESPONSE: The transportation study has been revised and now shows the following distribution: 15percent to/from north WCR 49, 15 percent to/from the west on WCR 22, 45 percent to/from the west on 1-76, two percent to/from the east on 1-76, 20 percent to /from the south on WCR 49, and 15 percent to/from the proposed Keensburg Parkway. Although this differs from the distribution that Weld County recommended, 15 percent that was not routed to the south on WCR 49 was directed to the proposed Keensburg Parkway which also provides access to the south by way of 1-76 7 REUTZEL & ASSOCIATES,LLC Pioneer Response r-. October 17, 2005 Page Eight Storm Drainage Comments • Appendix F - Pioneer Water, Sewer and Stormwater Analysis (7-26-05) Public Works will require a multi-basin wide master-planning effort as mentioned in the comp plan amendment text. This effort should include a strong watershed approach to stormwater management component. Full developed condition flows for the 100-year design storm must be considered as well as 2,5,10 and 50 year events to determine levels of protection and provide for water quality analyses. RESPONSE: We acknowledge the need for a multi-basin wide planning effort and will comply with this request with Sketch Plan submittals. • Special consideration should be given to all identified floodplains within the development. Preferably, development should be highly discouraged from encroaching into the flood-fringe and floodplain. FEMA net-rise standards will be the standard measure. RESPONSE: This intent is to comply with future applications. A compliance statement has been incorporated in the Storm water section of Appendix F of this Amendment. • All master planning and stormwater design must follow Urban Drainage Criteria, latest version. RESPONSE: It is the intent that all storm water master planning and design will follow the latest version of the Urban Drainage Criteria. A compliance statement has been added to the Storm water section of Appendix F of this Amendment. WELD COUNTY GIS - DAN HUERTER Page 1-8 last sentence does not make sense with top of page 1-9 RESPONSE: Modified with revised Amendment. Table on page 1-24 does not list Weld County Paramedic Services RESPONSE: Table has been amended to include Weld County Paramedic Has CR 49 been designated as the "primary access to Denver International Airport from Greeley and Northern Colorado Page II-2 first paragraph. If so by whom? RESPONSE: The statement has been revised to state WCR 49 is one of the primary north south roadways. This is consistent with the Strategic Roadway Plan adopted by Weld County. Fire District Map shows a significant amount of Pioneer land that is not in a Fire District. Map page after I1-3. RESPONSE: The Service Plans for the Pioneer Metropolitan Districts include a fire service component. It is the intent of Pioneer to enter into inclusion agreements and or IGA's with existing Districts, as warranted, to deliver adequate service to accommodate urban development. More detailed discussion of this issue occurs in Section 2-20.03 of the Amendment. 8 REUTZEL & ASSOCIATES,LLC Pioneer Response October 17, 2005 Page Nine • Several maps do not show the correct County Boundaries i.e. the creation of Br000mfield County in 2001. RESPONSE: Exhibits have been modified. • Appendix C Exhibit 1-6 Average Daily Traffic Volume - Are the red, yellow and green colors for 2004? What would the colors be for 2020? RESPONSE: Amended on the exhibit. • Appendix C Exhibit 1-7 Planned, Under Construction and Completed Transportation Projects Map ID A - I'm not aware that the expansion of I-25 North of Highway 52 to Highway 119 had started.. or would be completed in 2006. All I know is that they haven't started construction as of 8/20/2005 RESPONSE: The "North Forty"Project of 1-25 stretches from CO 7 Jct. To Fort Collins. Construction on the first section, CO 7 to CO 119, has begun. Work on this stretch has commenced at CO 7 and I-25 and will move northward to CO 119 by 2008-2009. Appendix C Exhibit 1-10 Map of Key Migration Counties. Why Adams County instead of Denver County? (Also does not show Broomfield County) RESPONSE: Exhibit was added showing Denver County migration. Broomfield County was added to all exhibits. Appendix C Exhibit 1-12 Typo in legend "Norther Denver % Capture of Permits" RESPONSE: Corrected per comment. Appendix C Exhibit 1-14 The numbers presented are Total Population not Households...unless my definition of a household is incorrect. RESPONSE: Amended to show households. General Comment - Appendix C page 3 after the green sheet of paper - Impact on General Government Operations ... a 2.8% positive return is not significant. We have all seen projects miss their estimates by more than 2.8%. RESPONSE: The purpose was to show a positive return, whether it is significant was not the objective. This demonstrates that the development is capable of paying its own way. As such, the analysis is conservative and does not abuse the potential upside that would allow for an increased value to the fiscal benefit. Respectfully submitted REUTZEL & ASSOCIATES, LLC 9 TOWN OF KEENESBURG 140 SOUTH MAIN STREET P. O. BOX 312 KEENESBURG, CO. 80643 *en, �ounty 303-732-4281 FAX: 303-732-0599 CRt,lino e� SFP Ptce part, e September 27, 2005 � l' Z�Os Weld County Department of Planning CC) Monica Daniels-Mika 918 10`" Street Greeley, Co. 80631 The TOWN OF KEENESBURG is working to complete the update of our Comprehensive Plan. In recent meetings with Pioneer Communities and the TOWN OF KEENESBURG, discussion on traffic flows and the need for a collaborative transportation plan has evolved. The TOWN OF KEENESBURG recognizes the needs of its citizens and residents in southeast Weld County to have easy access to the County Seat in Greeley. Therefore, we would propose a parkway to the north of KEENESBURG, from exit 39 (1-76), to Weld County Road 22, and then west to Weld County Road 49. The proposed parkway will provide Pioneer Communities with additional access to 1-76, and improve the accessibility of area to the fire district. A cooperative effort by the TOWN OF KEENESBURG, Weld County and private developers is the best way to achieve this transportation goal. The TOWN OF KEENESBURG appreciates the time in the consideration of this cooperative transportation goal. Sincere /7' GAG£ rk D. Gray, May Cc: Pioneer Communities MEMORANDUM TO: Bill Cunningham, LCG September7, 2005 FROM: Don Warden, Director of Finance and Administration WIDcSUBJECT: Review of Pioneer Development Proposal COLORADO Attached is the market and fiscal section of the Pioneer Development Proposal. As Monica Mika and I have discussed with you Weld County would like you to review the proposal and give your comments on its accuracy and whether or not the data is reasonable for a project of this type. The areas we would want you to examine are: 1. Overall review of the market and fiscal impact data and your opinion of it. 2. Review the Market Opportunity Assessment (Appendix C) and give your opinion as to whether it is accurate and reasonable. This area is key since the assumptions and data appears to drive many of the conclusions as to the economic feasibility of this project. 3. Review fiscal impacts to the local jurisdictions. 4. Are the market values used reasonable regarding number of units, type, and value? Are the build out numbers reasonable? 5. Are the methodologies, such as the weighed per capita approach to revenue and expense projections, accurate and reasonable? 6. Your opinion on whether or not since the development will be in the unincorporated areas of the county will there be a disproportional impact on costs of county services rather than doing as they appear to have done and simply took a weighted per capita cost of all services for the total population? 7. They used 97,293 for the unincorporated population out of a total population of 217,850 in the county. The actual number for the unincorporated population is 42,477 out of a total county population of 209,909 per the State Demographer as of July, 2003. How does the correct number change their analysis? 8. They have used an assessment ratio of 9.12%for residential property for property tax revenues. With the Gallagher Amendment the assessment ratio for residential property keeps dropping. Has that factor been adequately accounted for in this analysis? 9. Weld County has a Home Rule Charter 5% property tax limitation that only allows the total property tax to increase only 5% over the previous year, unless the County Council authorizes an override to exceed the 5% or the voters authorize it. The result without the override in their analysis is that only 2% of total new growth is realized in a year with 3% inflation. This is just a factor that complicates any analysis of growth in Weld County. 10. Weld County recently adopted Metro District creation and review policies. How will those policies impact this proposal? I will email you a copy of the policies. 11. Will the countys impact fees for transportation and capital expansion be affected by this kind of concentration of growth over the proposed timeframe? Other than the obvious impact of the collection of the fees. 12. A development of this type will require a law enforcement authority for Sheriff's patrol services. Typically a seven mill levy is required to support the function. How will this impact the project? As you go through the analysis if you have questions please do not hesitate to contact me at 970-356-4000 Extension 4218. You have agreed to do this project on an hourly basis. If you need a signed engagement letter please send it to me and I will get it approved. pioneerreview Weld County Weld County Planning Department GREELEY OFFICE john 0. Cooke, ShenJ.f August 26, 2005 AUG 2 9 2005 Joy S McGee RECEIVED 9145 East Kenyon Avenue Suite 301 Denver, Colorado 80237-1823 Dear Ms. McGee, The sheriff's office will be recommending the following improvements for the Pioneer development: 1. The Sheriff's Office requests that builders and developers designate an area by the entrance of sub-divisions in which to place a shelter for school children awaiting the school bus. This area should also include a pull off for the school bus which enables it to safely load and unload children out of the roadway. 2. Either mail distribution within sub-divisions or a central drop off location within sub- --- divisions should be developed so that residents do not have to cross a county road to obtain their mail. 3. A permanent sign should be placed at the entrance to subdivisions detailing the name of the sub-divisions, address, and a graphical presentation of the roadways within subdivisions. There should be a plan developed to maintain these signs. 4. If the roadways within sub-divisions are not maintained or adopted by the county, individuals purchasing property in these sub-divisions should be notified that the Sheriffs Office will have limited traffic enforcement powers. 5. A plan should be developed to maintain roadways within sub-divisions especially during inclement weather conditions for emergency vehicles. 6. The Sheriffs Office is very supportive of homeowner funded homeowner's associations. These associations provide a contact for the Sheriffs Office and a means of maintaining common areas. 7. If there are oil or gas production facilities within sub-divisions, they need to be fenced off in order to mitigate the potential for tampering. These facilities are known Yp create an, attratvge.nuispnce for Young;people, ,Tapering pot Drily,creates a ., Lift, Lt! J fe ,�i7e U �!Y/it-L!. Ilit,,,r(t/f e•Ilu i,rU.t� _ ( fit'::( cR i,_o../i? InaC(2;.:!/.1' ; ?N Y.O /C Main Office, Greeley Fort Lupton Sub Station Southwest Complex North Jail Complex 1950"O" Street 330 Park Avenue 4209 WCR 24 'h 2110"0" Street Greeley, CO 80631 Fort Lupton,CO 80621 Longmont CO 80504 Greeley. CO 80631 Phone(970)3564015 Phone(303)857-2465 Phone(720)652-4215 Phone(970)3564015 x3922 significant danger to safety but also of environmental damage with extensive mitigation and clean-up costs. 8. The names of all streets within sub-divisions should be presented to the Sheriffs Office for approval. This will eliminate duplication of street names within the county. The Sheriffs Office lacks the ability to absorb any additional service demand without the resources recommended in the multi-year plan provided to the Weld County Board of County Commissioners or as indicated by growth not considered at the time the plan was developed. There for the Sheriffs Office will be requesting a L.E.A. to fund the additional resources required to properly serve the residents of these communities. A permanent office/ work space for the sheriffs office to operate out of would provide the citizens with better service and enable the sheriffs office to be more effective and efficient in the area. It was a pleasure to meet with all of you. I look forward to assisting you with this project. Sincerely, hz_ Kenneth E. Poncelow, Commander "...to provide an environment designed to maintain and enhance the general health, welfare, and sa;%tv of the people of Wei(' County. Main Office, Greeley Fort Lupton Sub Station Southwest Complex North Jail Complex 1950"O" Street 330 Park Avenue 4209 WCR 24 % 2110"O" Street Greeley,CO 80631 Fort Lupton, CO 80621 Longmont. CO 80504 Greeley,CO 80631 Phone(970)356-4015 Phone(303)857-2465 Phone(720) 652-4215 Phone(970)356-4015 x3922 Fax(970)304-6467 Fax(303) 857-3027 Fax(720) 652-4217 Fax(970) 304-6461 Page 1 of 1 Michelle Martin From: Dan Huerter Sent: Monday, August 22, 2005 10:55 AM To: Michelle Martin Subject: FYI - Pioneer Comments Michelle, Just some quick comments about the Pioneer Comp. Plan Amendment. These may be very nit-picky and inappropriate. Pagel-8 last sentence does not make sense with top of page 1-9 Table on page 1-24 does not list Weld County Paramedic Services Has CR 49 been designated as the "primary access to Denver International Airport from Greeley and Northern Colorado" Page 11-2 first paragraph. If so by whom? Fire District Map shows a significant amount of Pioneer land that is not in a Fire District. Map page after 11-3 Several maps do not show the correct County Boundaries i.e..e. the creation of Broomfield County in 2001. Appendix C Exhibit 1-6 Average Daily Traffic Volume -Are the red yellow and green colors for 2004? What would the colors be for 2020" Appendix C Exhibit 1-7 Planned, Under Construction and Completed Transportation Projects - Map ID A- I'm not aware that the expansion of 1-25 North of Highway 52 to Highway 119 had started...or would be completed in 2006. All I know is that they haven't started construction as of 8/20/2005 Appendix C Exhibit 1-10 Map of Key Migration Counties..Why Adams County instead of Denver County? (Also does not show Broomfield County Appendix C Exhibit 1-12 Typo in legend "Norther Denver % Capture of Permits" Appendix C Exhibit 1-14 The numbers presented are Total Population not Households...Unless my definition of a household is incorrect. General Comment -Appendix C page 3 after the green sheet of paper- Impact on General Government Operations... a 2.8% positive return is not significant. We have all seen projects miss their estimates by more than 2.8%. Dan Huerter Systems Consulting Senior Analyst Weld County GIS 1400 N 17th Avenue Greeley, Colorado 80631 (970)356-4000 x2521 (970) 304-6434 (Fax) dhuerter@co.weld.co.us 08/22/2005 PUBLIC WORKS DEPARTMENT 1111 H STREET P.O.BOX 758 GREELEY, CO 80632 WEBSITE: WWW.CO.WELD.CO.US PHONE (970) 356-4000,EXT. 3750 FAX: (970)304-6497 MEMORANDUM DATE: August 15, 2005 TO: Monica Mika—Planning Director FROM: Keith Meyer, P.E.—Engineering Manager CC: Kim Ogle—Planning Manager Peter Schei, P.E. -Senior Engineer Donald Carroll —Engineering Administrator Frank Hempen, P.E. —Public Works Director file RE: Pioneer Communities Comprehensive Plan Amendment—July 29, 2005 he Public Works Department has reviewed the above referenced comprehensive plan amendment and offer the following comments. Comments made during the comp plan amendment process may not be all-inclusive. Other issues may arise during the subsequent submittal phases that may supersede comments provided herein. • Public Works received the following document to review: Pioneer Communities, Inc., Weld County Comprehensive Plan Amendment(July 29. 2005). Transportation Comments • Section 1-90 Existing and Proposed Public Facilities and Services. This section of the comp plan identifies Weld County Public Works as a provider of services— "Highways and Roads". The Public Works Depai tuient is not prepared to accept any responsibility for maintenance of highways,roads, drainage facilities or other infrastructure improvements associated with this development. • Section 1-110 Transportation and Circulation The comp plan amendment states that the roadway system(i.e. WCR 49 and 22) will not need capacity improvements prior to the construction of 1.800 residential units. Public Works does not agree with this statement. Improvements to WCR 22 and 49 will be required at the onset of the development. These will likely include shoulder widening, auxiliary lanes on WCR 49 and potential signalization. A more thorough, comprehensive investigation of the traffic impacts will need to be performed. • Public Works will require Pioneer Communities to provide a "master transportation plan" that shows the hierarchy of roads to be constructed, traffic capacities and timing of construction tied to the development phasing plan. The transportation master plan must also show how connections to existing county roads will be made and their respective impacts. !h., rur.:-:dn: �cL ra oa , _ a� rd. . .; ,., c ' dca � � P9t_ I of 2 • Section 2-10 Urban Growth Nodes are Identified Areas of Potential Urban Growth A comparison is made between the Weld County Strategic Road system and the state highway system as potential justification for the "Urban Node" growth concept. While the strategic roads (WCR 49 &22) are ultimately envisioned to be 4-lane roadways, they are not envisioned to "be designed to cony more traffic than many of the state classified roads. " They are envisioned to provide intra-regional travel options between communities. Conversely, the state highway system is designed to provide inter-regional travel options across the state. It is Public Works' recommendation that the"Urban Node" concept for growth not be extended to include Strategic Roadways, many of which travel through very rural parts of Weld County. • Section 2-20.5 Transportation This section alludes to the metropolitan district only providing maintenance for "certain"roadway improvements. Public Works will not accept maintenance for any improvements other than those completed on the already-existing system. • Section 2-50.09 Transportation and Circulation(paragraph#3) This section discusses the metropolitan district's financial participation in both on and off-site road improvements. Public Works will require that all off-site road improvements, needed due to the development, will be paid for 100% by the metro-district and not a"pro-rata" share as mentioned in the discussion section. • Both the comp-plan amendment and the traffic study state "it is anticipated that this roadway(WCR 49&22) will be widened to a four or six-lane arterial roadway cross section with or without the traffic from the proposed Pioneer development. " This statement is incorrect. The county's approach to strategic road improvements has been one in which we prioritize the highest need and construct a two-lane facility. Any widening beyond this two-lane configuration will be done by development. We currently do not have any improvements planned on WCR 49 or 22 in our 10-year capital improvement plan. • LSC assumes that extra capacity in a roadway equals safe, efficient operation. Again, improvements to the WCR 49/22 intersection will be required at the onset of the development. • Public Works does not agree with LSC's estimates for trip distribution. As shown in the comp-plan projections, the largest amount of users will be commuters to the Denver-metro area. As such, the distribution should be in following ranges(75% south on WCR 49, 15%north on WCR 49, 10% west on WCR 22). Storm Drainage Comments • Appendix F—Pioneer Water, Sewer. and Stormwater Analysis(7-26-05) Public Works will require a multi-basin wide master-planning effort as mentioned in the comp-plan amendment text. This effort should include a strong watershed approach to stormwater management component. Full developed condition flows for the 100-yr design storm must be considered as well as 2, 5, 10 and 50 year events to determine levels of protection and provide for water quality analyses. • Special consideration should be given to all identified floodplains within the development. Preferably, development should be highly discouraged from encroaching into the flood-fringe and floodplain. FEMA net- rise standards will be the standard measure. • All master planning and stormwater design must follow Urban Drainage Criteria, latest version. Recommendation he Public Works Department is not providing a formal recommendation of acceptance or denial of the comprehensive •an amendment. However, we have provided comments for applicant and inter-departmental use. : '3 91::^'. .1.1,1 JCW ..Ic9 ora`1 (ilt..11., i.jai ,i.O� . 1�- J u.ndyn, _..IT1f0C 1 i,i-U5iipC Par.2 of To Michelle Martin Re: Pioneer Communities Comprehensive Plan Amendment—July 29, 2005 The Department of Planning Services has reviewed the above reference comprehensive plan amendment and offers the following comments. These comments are intended to review the adequacy of the application as it pertains to the "planning aspects", and are not intended to address the contextual information of the overall application. GENERAL COMMENTS - The primary concern regarding this application centers around what lands are included in the application, and which ones are excluded. At times, in the applicant identifies (A) agricultural lands as open space and preservation areas, and other times these areas are excluded from the study area. Not only is this confusion, but I question how to apply the goals and policies as listed by the applicant to these areas. Either these areas are control within the study area or they are not. - On the Maps located between Exhibit 4-17 a blue line is used to delineate the study area including the A (Agricultural) lands. This blue line is not labeled. What is this blue line? Why does this not follow section lines? - On Maps Exhibits 10 and 11 the legend does not include a black defined area. - On Maps Exhibits 12 and 13 blue line is not defined - On Map 14 No fire district is identified. The applicants must petition into a fire district. . - On Map Exhibit 16 all IGA boundaries should be listed - On Map Exhibit 17, support information for citation should be included - Alta Survey... Uses for Neighborhood Center are not defined. What is the FAR or sq feet of area available to commercial uses, and what are these uses likely to be. This information is include in the existing MUD model, and needs to be included here. - The breakdown of uses is not consistent between the maps and information in the text. For example the Conceptual Master land shows pictures of trails but these are not delineated. The commercial area is not broken down. The rural street are not listed, but pictorially shown without sidewalks. There is a reference to a "Main Street" and center town site, but this information is not included in the Conceptual Map. - It appears that some of the schools are located in the (A) agricultural areas, these needs to be clarified. - Why are the agricultural areas identified as preservation or open space area outside the study area? What are the exact acreages of land located with the study are identified as open space? - The Conceptual Master Plan needs to be revised to list the same amount of information on the current MUD map, i.e. definition of uses, transit corridors, trails. - ECONOMIC ANALYSIS—Weld County will forward this information to an independent consultant for review. Recommendation The Department of Planning Services is not providing a formal acceptance of this plan at this time. The Department of Planning Services finds that the above information substantial enough to deem this an incomplete application. • Jul 20 05 11 : 35a Cheryl Jesser 303-732-0599 p, 1 • Town of Keenesburg Incorporated July, 1919 140 S. Main Street, P.O. Box 312 • Keenesburg, Colorado 80643 303-732-4281 • July 18, 2005 • Attn: Connie O'Neill North Front Range Water Quality Planning Association Civic Center • . 500 E. 3f°Street Loveland, Colo. 80537 RE: Areawide Water Quality Management Plan Amendment for Resource Colorado Water and Sanitation Metropolitan District Dear Ms. O'Neill: The Town of Keenesburg has received and reviewed the referral package for the proposed �' Areawide Water Quality Management Plan Amendment for the Resource Colorado Water and Sanitation Metropolitan District. . In accordance with recent discussion with representatives of Resource Colorado, the Town of Keenesburg has an interest in the possibility of regionalized wastewater treatment and is interested in the ultimate siting of Resource Colorado's wastewater treatment facility for future service considerations. Accordingly, the Town of Keenesburg has no objection to Resource Colorado being designated as a responsible Management and Operating Agency for the new sewer service area delineated in the amendment application, as long as additional land within the general area remains open to consideration for future wastewater service. . If you have any questions, please contact me. Sincerely, Mark D. Gray, Mayor**Stnifi—, • • ATTACHMENT G water report TIMOTHY R. BUCHANAN, P.C. ATTORNEYS AT LAW 7703 RALSTON ROAD ARVADA,COLORADO 80002 • TELEPHONE: (303)431-9141 FACSIMILE:(800)803-6648 EMAIL: trbpertrbpc.com WEBSITE:www.trbpc.com TIMOTHY R.BUCHANAN ALAN E.CURTIS trbra)trbpc.com aecna,trbpc.com HEATHER A.WARREN,LL.M. hawnagbpc.com KARA GODBEHERE GOOD WIN IN kggaaltrbpc.com December 2, 2005 Mr. Brad Simons, P.E. Gateway American Properties, LLC 9145 E. Kenyon Avenue, Suite 200 Denver, Colorado 80237 Re: Lost Creek Designated Ground Water r Dear Mr. Simons: In accordance with your request, we have prepared the following discussion regarding the sustainability of the alluvial ground water supplies within the Prospect Valley area located within the Lost Creek Designated Ground Water Basin (the "Lost Creek Basin"). 1. THE LOST CREEK BASIN The Lost Creek Basin is located north and east of the Denver metropolitan area. A map depicting the location of the Lost Creek Basin is attached as Exhibit A. The Lost Creek Basin was designated by the Colorado Ground Water Commission in 1967, and generally consists of an area consisting of approximately 420 square miles. In general, the boundaries of Lost Creek Basin consist of the drainage area of Lost Creek,which is an intermittent stream that infrequently carries water on the surface. A portion of the rainfall and snowfall that occurs within the drainage area percolates through the overlying soil into the alluvial aquifer underlying the Lost Creek drainage area. The alluvial aquifer ranges from the ground surface to approximately Two Hundred(200)feet below the ground surface. The northern end of the Lost Creek Basin is also traversed in part by the Denver-Hudson Canal and laterals off the canal, which are owned and operated by the Henrylyn Irrigation District, and used to deliver water to farms within the Lost Creek Basin. A portion of the water delivered into the Lost Creek Basin by Henrylyn Irrigation District is also stored in Prospect Reservoir,Olds Reservoir and Lord Reservoir. Carriage of water in the Denver-Hudson Canal and laterals, as well Mr. Brad Simons, P.E. December 2, 2005 Page 2 as the reservoirs, results in leakage of water into the alluvial aquifer underlying the Lost Creek drainage area. Water use within the Lost Creek Basin occurs by two methods: (1) wells pumping water from the alluvial aquifer, and (2) water delivered within the Lost Creek Basin by the Henrylyn Irrigation District. The first wells were constructed in the Lost Creek Basin in the 1930's, and as of 1967, there were approximately Two Hundred and Thirty-Eight (238) high capacity wells withdrawing water from the alluvium of the Lost Creek Basin. Based on the information that we have reviewed and as discussed below, the alluvial aquifer of the Lost Creek Basin has been a consistent, reliable water supply source. At the time the Lost Creek Basin was designated,it was estimated that the quantity of water stored in the alluvial aquifer was approximately One Million, Three Hundred Thousand acre feet (1,3000,000). See"Summary of Conclusions"at pages 4-6 of"Ground Water Resources of the Lost Creek Drainage Basin"(the"Lost Creek Basin Creation Report")by Nelson,Haley,Patterson, and Quirk,Inc.,June, 1967,attached as Exhibit B. The estimated annual rate of recharge of the alluvial aquifer from a combination of precipitation percolation and leakage from the Henrylyn Irrigation District facilities was approximately of Forty-Four Thousand acre feet(44,000),as of April of 1967. The estimated average annual use of ground water from the Alluvial Aquifer at the time of the Lost Creek Basin creation was approximately Forty Thousand acre feet per year (40,000), of which an estimated Twelve Thousand acre feet per year(12,000) would return to the alluvial aquifer. Id. Since the 1950's,the United States Geological Survey and the Colorado State Engineer have measured the water levels in the alluvial aquifer of the Lost Creek Designated Basin. See"Ground Water Levels in the Lost Creek Designated Ground Water Basin," State of Colorado, Division of Natural Resources,Division of Water Resources,February 2005,attached as Exhibit C(the"Ground Water Levels Report"). The Ground Water Levels Report indicates that the water levels in the Lost Creek Basin have been stable or increasing since the mid 1970's. However, the water levels in the alluvial aquifer fluctuate from year to year. A series of wells within the Lost Creek Basin are illustrative of the stability of the water levels in the alluvial aquifer. The wells are designated as wells GS-1 through GS-6 in the Ground Water Levels Report, with well GS-1 located in the northern end of the basin and the well numbering continuing south to well GS-6 located in the southernmost end of the basin,at a location in the vicinity of southernmost well owned by PV Water Holdings LLC. The locations of wells GS- I through GS-6 are indicated on the map included within the Ground Water Levels Report. • In order to illustrate the water levels over the time period from 1995 to 2005, the following chart illustrates for each of the wells GS-1 through GS-6 the (1) ground surface elevation, (2) the average annual water level elevation, (3)the maximum water level elevation, and(4)the minimum water level elevation. As noted above, since well GS-6 is in the southern portion of the Lost Creek Basin, the well has the highest ground surface elevation, and well GS-1 has the lowest ground Mr. Brad Simons, P.E. December 2, Page2005 3 surface elevation. Except for well GS-6, each of the water levels maintain the same approximate depth to water from the ground surface elevation of each of the wells. The chart further indicates that although the water levels fluctuate between the maximum water level elevation and the minimum water level elevation, the range of fluctuation is very narrow. The stable nature of the water levels in the alluvial aquifer indicates that the recharge of the aquifer and the well pumping are in approximate balance, and evidence that the alluvial aquifer is a reliable water supply. Lost Creek Designated Basin Average Water Levels 1995-2005 5100 .-. .,.. ,......... oso soon 4950 0 w 4900 , WL4:Va1.i aW 4850 � . t i t F R ��G _ T 4 6600 i .. o-. a� r 4]50 t ....,� } t 4700 .. GS-6 GS-5 GS-4 GS-3 GS-2 GS- USGS Well Designation Surtace Elevation- �Hrerage Water Lerel- n._µazmum Water Lewl--,c mum Water Lerel—0— 2. ADMINISTRATION OF LOST CREEK BASIN GROUND WATER The Colorado Ground Water Commission is empowered to determine rights to use the water supplies in the Lost Creek Basin, and the State.Engineer's office administers the water rights on behalf of the Colorado Ground Water Commisson. Section 37-90-110, 111, C.R.S. The Ground Water Commission has promulgated Rules and Regulations for the Management and Control of Designated Ground Water,2 CCR 410-1 ("the Designated Basin Rules"). Through the Designated Basin Rules,the Ground Water Commission has established terms and conditions for implementing the statutory requirements for administration of Designated Ground Water. The Lost Creek Ground Water Management District is also authorized to regulate the use, control, and conservation of the ground water within the District pursuant to Section 37-90-130, C.R.S., and has promulgated rules for the use, control and conservation of ground water in the District. The rules promulgated by the Lost Creek Ground Water Management District affect and limit the use of water rights located in the Lost Creek Basin. r Mr. Brad Simons, P.E. December 2, 2005 Page 4 With respect to the administratrion by the Ground Water Commission and the Lost Creek Ground Water Management District,there are two types of water within the Lost Creek Designated Basin: (1)water within the"alluvial aquifer,"see,Designated Basin Rule 5.2.5,and(2)water within the "Denver Basin Bedrock Aquifers," see, Designated Basin Rule 5.3. The wells owned by PV Water Holdings LLC have all been drilled into the alluvial aquifer, and therefore we have not included a discussion of the Denver Basin Bedrock Aquifers. As discussed above,the water in the alluvial aquifer is primarily located within approximately the first Two Hundred (200) feet below the ground surface and a portion of the water is depleted and recharged on an annual basis. The Designated Basin Rules specifically state that the"alluvial aquifer within the Lost Creek Designated Ground Water Basin area south of the line between Township 2 North and Township 3 North is determined to be overappropriated and, therefore, no new large capacity well permits shall be granted in this area unless a replacement plan is approved by the Commission..."Designated Basin Rule 5.2.5.2. The well water rights owned by PV Water Holdings LLC are all located south of the "appropriation boundary," and, as a result,no new high capacity wells will be allowed in this area unless a Commission-approved replacement plan is in place. This is a good indication of the future reliability of the ground water resources in this area, because there will be no new appropriations of ground water granted for large capacity wells. The only method under Colorado law by which new large capacity wells could be obtained in the area south of the"appropriation boundary"is through a"replacement plan"approved pursuant to the Designated Basin Rules. See Designated Basin Rule 5.2.5.2, A"replacement plan" is defined as: A detailed program to increase the supply of water available for beneficial use in a designated basin or portion thereof by the development of new or alternate means or points of diversion,by a pooling of water resources,by water exchange projects,by providing substitute supplies of water,by the development of new sources of water, or by any other appropriate means. Designated Basin Rule 4.2.2.3. In order for the Ground Water Commission to approve a replacement plan it will be necessary for additional water supplies to be delivered to the Lost Creek Basin to "replace" the depletions caused by a new well. As of this date, the Ground Water Commission has not approved any replacement plans within the Lost Creek Basin. Each well owned by PV Water Holdings LLC has also been assigned a"priority date." The significance of the priority date is that in the event of a shortage of water in the Lost Creek Basin, the wells with the earliest priority dates will be allowed to pump,but wells with junior priority dates may be curtailed. The exact administration of the priority dates is uncertain because neither the Ground Water Commission nor the Ground Water Management District has ever administered the operation of the wells based on priority dates. Table A-1 of the Lost Creek Basin Creation Report, attached as Exhibit D,illustrates that many of the wells in use in the Lost Creek Basin prior to 1950 are now owned by PV Water Holdings LLC. Therefore, in the event of administration of wells Mr. Brad Simons, P.E. December 2, 2005 Page 5 within the Lost Creek Basin on the basis of priority dates,the wells owned by PV Water Holdings LLC would be among the last to be curtailed. Another factor to be considered is that as a result of the change of the water rights owned by PV Water Holdings LLC,the future annual withdrawal of water from the alluvial aquifer of the Lost Creek Basin will be reduced. Pursuant to the terms and conditions of (1) Findings of Fact, Conclusions of Law,Judgment and Decree of the Court entered by the Adams County District Court on May 10, 2004 in Case No. 98CV1727, and recorded on June 22, 2004 as Reception No. 20040622000516130 of the books and records of the Adams County Clerk and Recorder, and recorded on June 22,2004 as Reception No. 3191505 of the books and records of the Weld County Clerk and Recorder, and (2) Findings of Fact, Conclusions of Law, Judgment and Decree of the Court entered by the Adams County District Court on June 1, 2004 in Case No. 99CV0097, and recorded on June 22, 2004 as Reception No. 20040622000516120 of the books and records of the Adams County Clerk and Recorder, and recorded on June 22, 2004 as Reception No. 3191504 of the books and records of the Weld County Clerk and Recorder,the water rights owned by PV Water Holdings LLC were changed from irrigation use to other uses,including municipal uses. Pursuant to the Designated Basin Rules,the amount of water that may be withdrawn from the alluvial aquifer associated with the water rights owned by PV Water Holdings LLC was reduced. The following chart illustrates the original permitted appropriation for each of the wells and the average annual historical depletions for each of the wells after the change of the water rights: Parcel No. Well Permitted Average Annual Permit Appropriation Historical Depletions Nos. (acre-feet) (acre-feet) A-1 464-FP 220 51.9 467-FP 180 63.4 • A-2 8533-FP 280 84.0 8534-FP 200 81.5 8535-FP 320 96.9 C 31518-FP 640 124.3 31519-FP 400 117.5 31520- 560 173.1 FP D 12123-FP 415 163.1 Mr. Brad Simons, P.E. December 2, 2005 Page 6 Parcel No. Well Permitted Average Annual Permit Appropriation Historical Depletions Nos. (acre-feet) (acre-feet) 12124-FP 385 106.4 F 31526-FP 350 144.4 31527-FP 350 139.1 G 31595-FP 400 163.5 H 1771-FP 200 83.2 1772-FP 200 125.3 1773-FP 200 79.9 1774-FP 200 27.8 I-1 31612-FP 200 65.4 1-2 31652-FP 267 139.6 31653-FP 266 98.0 31654-FP 267 116.8 1-3 31536-FP 200 84.6 I-4 1730-FP 200 92.0 1731-FP 200 82.2 J 8873-FP 250 58.3 8874-FP 300 79.1 9321-FP 250 61.7 L-1 31542-FP 558 193.3 L-2 14860-FP 200 74.3 31643-FP 200 111.3 M 31640-FP 400 297.2 Mr. Brad Simons, P.E. December 2, 2005 Page 7 Parcel No. Well Permitted Average Annual Permit Appropriation Historical Depletions Nos. (acre-feet) (acre-feet) N-1 14861-FP 325 46.8 14862-FP 325 194.3 14863-FP 325 136.0 N-2 6419-FP 800 347.2 6420-FP 250 160.4 9175-FP 800 301.4 14856-FP 100 0 14857-FP 275 0 TOTAL 12,458 4,565.2 The average annual historical depletion constitutes the new limit on average annual withdrawals by the wells owned by PV Water Holdings LLC. Hence, the potential annual diversions from the alluvial aquifer have been reduced by approximately Seven Thousand Nine Hundred (7,900) acre feet. The ground water levels in the alluvial aquifer in the Lost Creek Basin have been stable for many years. Based on the information that we have reviewed, the evidence indicates that the alluvial aquifer will continue to be a reliable, stable water supply source in the future. Please feel free to contact me with any comments or questions regarding this matter. Sincerely, TIMOTHY R. BUCHANAN, P.C. Timothy R. Buchanan trb:hg Exhibit A to Letter re: Lost Creek —• Designated Ground Water I GREELEY WELD CO. MORGAN CO. H I 1. 1. r � N4 \ RIVER — Z ROGGE N' ti's :L'%�t'. fl^IAL:11.":; i' c 112 KEENESSURG Vt'"5...3.i- -J' co HUDSON `. ', o f L'i6 fr 7 sy t f. U m .o/ pi s tl VALLEY H $ 0 1 i i v+ . V ehi: (' w JEFFFEORSON ' �'`i Y n41 7:i °it' a kii J' s ioY - MORGAN CO �o '4 �. ,x - . ADAMS CO i oU 11 a I / f DENVER I . i .:�: BENNETT Ii US. HWY N0. 287 '` '^:C:'r;}Y a. V.S. HWY. / �4 NO. 36 ADAMS CO l� i ??:?'}ii'=:jXt. ARAPAHOE CO. Air H N H le RS 11 C 12 2 \ o 0 2 O w LI <'-''• NELSON-HALEY-PATTERSON AND QUIRK, INC. LOST CREEK DRAINAGE AREA ENGINEERING CONSULTANTS WELD - ADAMS - ARAPAHOE COUNTIES GREELEY, COLORADO - -‘ COLORADO ., -.7.0P.4.4.--c- / • Exhibit B to Letter re: Lost Creek Designated Ground Water 00, SUMMARY OF CONCLUSIONS The proposed Lost Creek Ground Water Basin is described as the surface drainage area of Lost Creek south of Township 4 North, seven sections in Township 4 North, Range 62 West, and six sections in Township 4 North, Range 63 West. Water-bearing geological members of formations in the proposed Ground Water Basin are: 1. Lost Creek Alluvium. 2. Sands of the Laramie and Fox Hills formations. The proposed boundary of the Lost Creek Alluvium is the line of zero- saturated thickness of the Alluvium and the proposed boundary of the Basin where the saturated thickness is greater than zero. • The proposed horizontal boundary of the sands of the Laramie and Fox Hills formations is congruent with the proposed boundary of the Basin. The vertical boundaries are the bottom of the Fox Hills sands and the top of the Laramie sands. The estimated quantity of water stored in the Lost Creek Alluvium within the Basin is 1,300,000 acre feet. The estimated quantity of water stored in the sands of the Laramie and Fox Hills formations within the proposed Ground Water Basin is 3,000,000 acre feet, of which an estimated 22,000 acre feet are recoverable. The estimated annual rate of recharge to the Lost Creek Alluvium within the proposed Basin is 44,000 acre feet. The estimated annual rate of recharge to the sands of the Laramie and Fox L Hills formations within the proposed Basin is 1,000 acre feet. The estimated use of ground water from the Lost Creek Alluvium within the proposed Basin is 40,000 acre feet per year, of which an estimated 12,000 acre feet returns to the Alluvium. An estimated1,000 acre feet - 4 - of water from the sands of the Laramie and Fox Hills formations within the proposed Basin are used each year. • The estimated projected use of ground water within the proposed Basin in the succeeding fifty years at ten year intervals is as follows: Year Lost Creek Alluvium Laramie-Fox .Hills Sands 1967 46,000 Acre Feet 1,000 Acre Feet 1977 49,000 Acre Feet 1,500 Acre Feet 1987 48,000 Acre Feet 2,000 Acre Feet 1997 47,000 Acre Feet 2,500 Acre Feet 2007 45,000 Acre Feet 3,000 Acre Feet 2017 43,000 Acre Feet 4,000 Acre Feet Tables A-I, A-II, and A-III of Appendix A list the users of ground water for irrigation purposes who have been withdrawing water since prior to January 1, 1950; started using irrigation wells after January 1, 1950; and for whom no date of first use has been determined. The estimated annual quantity of water withdrawn by each user and the year in which the user began to withdraw water, where determined, are shown on the Tables. Maps which clearly show all lands included in the boundaries of the • proposed Designated Ground Water Basin, together with a written description thereof, are included in this engineering report. Ground water in the Lost Creek Alluvium and in the sands of the Laramie and Fox Hills formations within the proposed Designated Ground Water Basin is not adjacent to a continuously flowing natural stream, and ground water withdrawals have constituted the principal water usage in the Basin for more than fifteen years preceding January 1, 1965. - 5 - We recommend that the Colorado Ground Water Commission designate the Lost Creek Basin, as described in this report, as a Ground Water Basin so Ground Water Management Districts can be established to properly manage and fully utilize the water resources within the Basin. g _ Exhibit C to Letter re: Lost Creek Designated Ground Water • GROUND WATER LEVELS in the LOST CREEK DESIGNATED GROUND WATER BASIN February 2005 a 11 11Ir 1 � 1 • WATER RESOURCES DEPARTMENT OF NATURAL RESOURCES by Michael P Schaubs STATE OF COLORADO DEPARTMENT OF NATURAL RESOURCES DIVISION OF WATER RESOURCES Bill Owen Russell George Governor Director Hal D.Simpson Dave McElhaney State Engineer Project Manager LOST CREEK DESIGNATED GROUND WATER BASIN 2005 This report represents the results of water level measurements of wells in the Lost Creek Designated Basin made during the month of February 2005. The project was done in cooperation with the Lost Creek Ground Water Management District and local well owners. Funding for this project was supplied in part from well permit fees collected and managed by the Office of the State Engineer as a result of the passage of Senate Bill 200 during the 1987 legislative session. Twenty of the twenty-one monitoring wells in the basin were measured. These wells are all part of an observation network that has been measured for many years. Records for one well dates back to the 1930's, however, observations for many of the wells didn't start until the 1950's and 1960's. All of the measured wells indicate water level declines over the previous year. The average decline for the past year was 1.76 feet. This compares to an average decline of 0.81 feet for the previous year. The average decrease for the last five-year period was 1.33 feet per year, and for the last ten-year period, a decline of 0.51 feet per year. Overall, the water level trend for the basin had been stable or increasing since the mid 1970's, but has generally reversed sharply around 2000 due to below normal precipitation of the past several years. Generally, north of Interstate-76, the water levels are within 20 feet of the surface and with ground water in few wells within five feet of the surface. Between Highway 52 and Interstate 76, water levels are between 25 feet and 45 feet of the surface. Water levels south of Highway 52 range from 45 feet to over 110 feet below the ground surface. Tabular data are presented for each well for the previous 10 years. Graphical data are presented for the entire period of record. Information concerning bedrock wells for the Denver Basin Aquifers will generally be available in June of each year and can be obtained from the Office of the State Engineer. 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I O LThl I `© Up n I —I t F— I J ♦ r r '1 \IIt" - Pit 1 i I .y1I 7 1 ej I ` — ' I C —• �I `y i ) I N,1 qtrs."; Wlad.3 4� t. .- ..r7, r 7 _._ I r 3 0 3 6 9 12 Miles N Lost Creek District Monitoring Well Locations ATTACHMENT H LELAND CONSULTING GROUP Independent Financial Review PIONEER DEVELOPMENT MARKET/FISCAL REVIEW Memorandum TO: Don Warden Director of Finance and Administration Weld County FROM: Bill Cunningham Anne Ricker DATE: 30 January 2006 SUBJECT: Market/Fiscal Review of Pioneer Development Submittal Project Number: J3026 This memorandum summarizes the market and fiscal reviews completed for the proposed Pioneer development(the Development)in southern Weld County (the County). This review included analyses of the Development with regard to: • Absorption and buildout of land uses; • Market values by land use type; • Fiscal impacts to the County(operating revenues and expenditures); and • Impacts on area schools. Each of these analyses is summarized in the following paragraphs. Development Absorption The Pioneer Development envisions a mix of single family detached,single family attached,and multifamily residential uses,with supporting grocery store-anchored retail space. The projected buildout of this development program is twenty years. The market absorption analysis provided by RCLCo estimates absorption based on a "top-down" analysis of growth in the"extended" Denver region,the northeast Denver metro area, the I-76 Corridor,Southern Weld County and finally, the project itself. This "market capture" methodology for estimating absorption at the project level is reasonable, given the availability of data and the size and scope of the proposed development. The biggest challenge in estimating absorption for a project such as this is in attempting to forecast regional growth trends and how they might be influenced by the project itself. • Real Estate Strategists. ruurte.lelmidmnsiIttmg.com Page 7 al LELAND CONSULTING GROUP U While growth in the Denver region is certainly moving to the northeast and in the direction of the proposed Development, there is substantial competition for future growth from a number of areas in this quadrant of the region, e.g., the I-25 Corridor (Westminster,Broomfield,Thornton,Southwest Weld County),the E-470 Corridor (Commerce City, Brighton,Aurora),and the I-76 Corridor (Brighton,Commerce City). A number of large-scale,master-planned communities are developing in these areas, capturing a significant share of the short-and mid-term market. The Pioneer development is at a competitive disadvantage compared to these projects, due to its more remote location. Due to these competitive influences,particularly in the next decade, it is estimated that the Pioneer development will be more affected by growth in Weld County,rather than in the extended Denver region. Therefore,in order to evaluate the reasonableness of the absorption forecast, project estimates were compared to projected growth in Weld County over the twenty-year buildout period. Table 1 summarizes the projected absorption of housing units within the Development over the next 20 years,compared to growth in Weld County and the"extended" Denver region(defined as the Denver-Boulder metro area plus Weld County). TABLE 1 PIONEER DEVELOPMENT SUBMITTAL MARKET ABSORPTION REVIEW Figures Growth Indicator/Area 2005 2015 2025 2005-2015 2015-2025 2005-2025 Population Denver Region 2,625,600 3,054,000 3,526,400 428,400 472,400 900,800 Weld County 223,300 303,600 413,300 80,300 109,700 190,000 Denver Region Extended 2,848,900 3,357,600 3,939,700 508,700 582,100 1,090,800 Households Denver Region 1,103,100 1,286,500 1,553,500 183,400 267.000 450,400 Weld County 82,700 112.500 156,000 29,800 43,500 73,300 Denver Region Extended 1,185,800 1.399,000 1,709,500 213,200 310,500 523,700 Pioneer Development Housing Units 0 2,904 10,000 2,904 7,096 10,000 Market Share Weld County '..! 0.0% 2.6% =6.4% '.9:7% 16-3°% 13.6% Denver.Region Extended 0.0% 0.2% 0.6% ".1.4% '.. 2:3% 1.9% Households in Price Ranges Weld County(Ownership) 53,100 Weld County(Rental) 13,600 Pioneer Development Housing Units(Ownership) 9,000 Housing Units(Rental) 1,000 Market Share of Growth Weld County(Ownership) . 16,9% Weld County(Rental) 'i 7.4% Source:Pioneer Companies, Inc.;Colorado State Demographer;and Leland Consulting Group. As shown in Table 1,projected absorption of the Development's residential units would require a market capture rate of 9.7% of Weld County growth between 2005 and 2015, 16.3% of County growth between 2015 and 2025, or an overall 13.6% of County growth over the twenty-year buildout period. • Real Estate Strategists, a ww.lelandconsniting.coin Rage 2 of 7 LELAND CONSULTING GROUP U Table 2 summarizes a further analysis of residential growth by expected income category (which translates to supportable home price and apartment rent). As shown, this reduces the potential"pool" of new households from 73,300 to approximately 66,700 over the twenty-year analysis period. Of this total,approximately 53,100 are estimated to be ownership units and 13,600 are estimated to be rental units. As shown in Table 1, this increases the required project market capture rate to approximately 17% for ownership units and 7% for rental units. These rates appear to be high, again based on the level of competition in northeast metro Denver and southern Weld County. TABLE 2 PIONEER DEVELOPMENT SUBMITTAL RESIDENTIAL DEMAND BY PRICE POINT Trade Area Demand from New Households(2005-2025) Current HHs Est Net Annual Income in Income New HHs Total Range(2005 Approx. Approx.Home Bracket by Income '.rc. P::f Total Ownership dollars) Rent Range Price Range (2005) Bracket Total Units Rcne c:. Rental Units Units up to$I5K up to$375 up to$50K 8% 2% 1,466 1,393 73 $15-25K $375-$625 $50 to$85K 8% 7% 5,131 £5s 4,361 770 $25-35K $625-$875 $85 to$120K 9% 11% 8,063 ,O 4,438 3,628 $35-50K $875-$1,000 $120 to$175K 15% 17% ,12,1&1 . 3738 6723 $50-75K $1,000♦ $175 to$250K 24% 25% ' 18,325 { 3,865 . 14,660 '^ $75-100K $1,000+ $250 to$350K 15% 15% .10,995 g.'"'-> 1100 9 896 $100-150K $1,000+ $350 to$500K 15% 15% "10,995 'a^ 550 10,445 $150K and up $1,000+ $500K and up 6% 8% X5,864 T'fi 117 5,747 Totals 100% 100% 73,300 " 19,359 53,941 Source:ESRI-BIS, Colorado Division of Local Governments, U.S. Census,and Leland Consulting Group Development Market Values The estimates of development market value and resulting property tax revenues prepared by RCLCo for the proposed Development utilized the following assumptions: • Residential Units(all): $250,000 • Retail(per square foot): $120 • Residential assessment rate: 9.12% • Commercial assessment rate: 29% Despite the fact that the proposed residential mix for the Development was estimated at 80% single family detached,10% single family attached, and 10% multifamily,no attempt was made to differentiate residential units by product type and expected market value. For the purposes of this review,the following values were used: • Residential(single family detached): $250,000 • Residential(single family attached): $200,000 • Residential(multifamily): $75,000 • Retail(per square foot): $120 • Real Estate Strategists, wevw.lelandmnsulling.com Page 3 of 7 LELAND CONSULTING GROUP LThe land values projected for the Development appeared to be reasonable. In addition to refinements in residential market values,a lower residential assessment rate of 7.96% was used to reflect current property tax conditions. In fact,the statewide residential assessment rate has gradually declined over the last ten to twenty years,so it is likely to decline further over the analysis period. An updated County mill levy rate (for 2005) was also used in the review analysis. Fiscal Impacts to County (Revenues and Expenditures) The fiscal impact analysis provided by RCLCo estimated County operating revenues and expenditures associated with the Development's buildout over twenty years. These revenue and expenditure estimates were prepared based on a per capita methodology, which takes current County budget figures and projects into the future on a proportional per capita basis. This is an accepted methodology for fiscal impact analyses, particularly for a project of this size at an early planning level. As development programs are refined and more detail is provided related to phasing,product types,and potential residents, more"realistic" revenue and expenditure impacts can be determined. Ideally,an analysis of department-by-department impacts and the best determinants for those impacts(such as"miles of street maintained" for public works or"number of police calls per capita" for public safety)would be completed with input from department heads. Additionally,a capacity analysis should be completed to account for unusual, or one- time service impacts (such as the purchase of a fire engine or the hiring of new personnel) associated with the Development. The methodology used in the fiscal impact analysis,as noted,is probably appropriate for this level of planning,but should be refined as the Development moves through the approval process. With regard to the revenue and expenditure assumptions used in the RCLCo analysis, the assumption that was adjusted or modified the most was the calculation for per capita revenues and expenditures. The RCLCo analysis based per capita estimates on a population figure for unincorporated Weld County of 108,054(97,293 residents and 11,291 employees). The population figure for unincorporated Weld County in 2004 was 42,857,far below the figure used in the RCLCo analysis. Adjusting for 2005 figures,the review analysis used an unincorporated population figure of 44,100 and an estimated employment figure of 12,300 (proportionally the same as was used in the RCLCo analysis)for a total per capita figure of 56,400 for calculation purposes. Because this figure is nearly one-half of the figure used in the RCLCo analysis,estimates of per capita costs and revenues will be significantly higher. In addition to the change in unincorporated population,adjustments were made to the Development's projected population. Based on current household sizes in Weld County, for both ownership and rental housing units,upward adjustments were made to household size figures by housing product type. The changes in these fiscal impact assumptions are summarized in Table 3. • Real Estate Strategists. imnzo.lelandeonsulting.eom Page 4 of LELAND CONSULTING GROUP L TABLE 3 PIONEER DEVELOPMENT SUBMITTAL COMPARISON OF FISCAL IMPACT ASSUMPTIONS Indicator RCLCo Analysis Review Analysis Household Size(SFD) 2.8 3.0 Household Size(SFA) 2.1 2.5 Household Size(MF) 1.8 2.0 Project Population 26,269 28,500 Per Capita Calculator 108,584 56,400 . Per Capita Revenues* $84 $250 Per Capita Expenditures '8255 $496 *Does not include property tax revenues. The highlighted assumptions have the most profound impact on the estimates of revenues and expenditures associated with the Development. In fact, these changes in assumptions result in a fiscal deficit at buildout,rather than a fiscal surplus as indicated in the RCLCo analysis. Table 4 summarizes the annual revenue and expenditure impacts from the Development at buildout. TABLE 4 PIONEER DEVELOPMENT SUBMITTAL ANNUAL FISCAL IMPACTS @ BUILDOUT Indicator 30-Yr Buildout Estimated New Development Units/Sq Ft Single Family Detached 8,000 Single Family Attached 1,000 Multi-Family 1,000 Retail 200,000 Estimated Annual Revenues by Type: Property Tax $2,350,625 Other Revenues* $7,322,525 Total New Annual Revenues to County: $9,673,150 Estimated Annual Operating Expenses by Department: General Government $5,678,626 Public Safety $7,634,688 Public Works $423,756 Culture& Recreation $27,301 Health &Welfare $338,179 Economic Assistance/Miscellaneous $923,531 Total'NewAnnualService Costs to County: .$15,026,081 Total Net Annual County Surplus(Deficit). ($5,352,932) "Includes Franchise Tax,Fines,Charges for Services, Permits/Fees,and Miscellaneous Revenues. Source:Weld County;Pioneer Companies,Inc.;and Leland Consulting Group. • Real Estate Strategists, azww.tetandmnsniting.coin Page5 of 7 LELAND CONSULTING GROUP U School Impacts The methodology to estimate pupil yields,facility needs and potential property tax revenues available for school construction is reasonable for this level of project planning. However, the results of the analysis,which project approximately$175 million in property tax revenues to be available for school construction,will be negatively affected by the changes in assumptions discussed in this review,namely: • Slower absorption of development based on lower market capture rates • Slightly lower market values for residential product types • Lower assessment rate for residential development The result is a likely lower revenue stream available for school construction and a wider gap in funding for the proposed Capital Facility Foundation. Conclusions Based on the analyses summarized above,the following conclusions were drawn: • The estimated absorption rate for the Development is aggressive, given the level of competition in the northeast Denver and southern Weld County markets,and the required project market capture rates. • Adjusting for the"pool" of home buyers and renters potentially available to the Development,the required market capture rates are even higher. • While the Development's proposed mix of residential unit types- 80% single family detached, 10% single family attached and 10% multifamily-will no doubt respond to prevailing market conditions,it appears to be too heavily weighted toward the single family detached market. The project's ultimate success will depend on the variety of housing products with which it can penetrate different market niches. • The absorption of the project's commercial space is appropriately tied to residential absorption. Any fluctuations in this residential absorption will have an impact,whether positively or negatively,on the development of commercial space within the Development. At buildout,the residential development planned would likely support a greater amount of commercial development, depending on its type and location. • It is estimated that the Development's buildout would more likely occur over a 30 to 35-year period,rather than the 20-year buildout projected. • Residential and retail market values estimated for the Development appeared to be reasonable,however,a further refinement was necessary to account for different residential product types (single family vs. multifamily). The residential assessment rate was also lowered to approximately 8% to reflect the historical downward trend in this rate. • While the"per capita" methodology for determining fiscal impacts from the Development is probably appropriate for this level of planning,analyses of department-by-department impacts and a capacity analysis should be completed to account for unusual, or one-time service impacts associated with the Development. • Real Estate Strategists, www.lelandnnrsdting.rom Page F of7 • LELAND CONSULTING GROUP L • The change in assumptions that had the most profound impact on the analysis was the per capita multiplier figure(identified as the population-both residents and employees-of unincorporated Weld County). Because the review analysis used a per capita multiplier that was nearly one-half of that used by RCLCo, the resulting per capita revenues and expenditures were nearly doubled. • The changes in assumptions outlined above resulted in a fiscal deficit,rather than a fiscal surplus,for the Development at buildout. • While the methodology used to calculate potential school impacts (pupil yield, facility needs,costs and revenues for school construction) is reasonable,the changes in assumptions discussed earlier in the review analysis will likely result in lower revenues being available for school construction and a larger deficit in capital facility construction. • The adjustments in assumptions also result in lower tax revenues to other jurisdictions,e.g.,Weld Library,AIMS Junior College,etc.,as well as any potential special districts. • Finally, it should be noted that the estimates of property tax revenues are significantly affected by assumptions for inflation. The RCLCo assumed 4% annual growth in revenue,which, over a 30-year analysis period,has a substantial compounding effect. In addition,because property is assessed every other year,the true impacts of that increase in revenue are not realized every year. This compounding impact,without accounting for the County's reassessment process,will likely overstate revenues in a long-term forecast. If you have any questions regarding the analysis herein,please do not hesitate to call us at 303.458.5800. • Real Estate Strategists. wani deia zdco zsultfag.coni Page 7 of Hello