HomeMy WebLinkAbout991249.tiff .7.„..
Wn County Planning Dept.
r^ OCT 191998
CEt` D • .
. 7 U , U
„W A/4 ,yer> -e<< V'-t--,4:02 it/Le. `e+e-a.a.k...e_,
1/20,9-0 Etc., /,L,..- J 1.�fie. ra-a./ ci afreit�.J a- - €
�,.Lcfelc.e� tae.. .�r .atom ,e2-1-A- (/iY Cll.,/ Ca...a../ acv A-�-
A-e i Cam' -r- t-r) .elf -5( .5-C a `icic.,-C, ay at-ret. , -9M4"--e_.
,Ct ht-- 7' re 45 Q' l L/)mil G-, • - .-.d L"}._/ tint,.j -.-.'7r L7<�Ciet-4°
�/Llat9xY,C-. 4t..0G ,<i/,7C' !. . /LGu i __ ._-,2-‘2,2_, °-(..
,�Y 212..•_,
^ 5q
( rn"Z. !>-'z.� dm./ �L a" c 4L- .!'t -Attic J'- sQ C/z_> — ---< -
,jc.t-,;.-c.-i filar c4..i . ei ei-orC_. .efi- / .K..t�z� ..cLcrieti . _QJ
/z-v-e_, „t -C.,jc.e-'t_e__- eci-C-n-e_e_ 6 f a-r,-cc,1 -t .'c.." ab eltnt ≥a.1
/ �se(`a7�C_Gin 1,1 .01 t n c .f c-. 2%C ..at-721-e..e.-- CAC
O ie C ,.c.f�/ . -- a>. _ (/ti.t) GCJ(/'CLR c ,!y, �/ L t 22 --Inc
s�2-:L. ,a cam, . + �+c . t,d.� 1ea L�ts)-aJ z..2s>-� i? � era,r-ii
L7 0 !9/LCIA `/•-R cC- Cc. 2 t e 'r2C- ti C' L`` Cam." yeJJ Z-'z'
e • -r-tcc i t-lac., _ a /7 i c d �f .-mod et _LA € of.<.- i-z> : _
. f ' i7
_2471c c,�, a-!c —ant---y7'1..r L-c . � ry ,0-an-it, c<.a..,, /.
7G.e_a.� 1. SO 0 O-' ,--772-.c 41.¢...-, Cant.-j C. -t -ti ott c r c ma n t a,,
. W..eR t.1+`n�j Q C. a— L.tic C C- .f- � f� .4/,---6-°C)
e !c et Ca. . 4?2,-,_) ,t -7(:_.e a,>--c/l. 71-7U---4-e_.) c r .ca: of Le
Cc i 1/fl-t e_, Crt.-z.r 277a-k-e--= .,,I,C. �,.cd A., • `---
re
-h-Cre eC, 19 L°ar es.- o-t) r:72-2, it k-e, , 6,--4., ,C1rttaore-,.,oC.-1-.p,
r �`�"p�`. it, B-su-o- eat 1 ) e v' icy., �.t -c U '
( .0-a e-- „zzi-a -cc�2� -e c -tom./fl2, „&-- L4- t
.1Y72-tee Ft) "7,1--"Ac.e-- .�- -� ,a.c,..L'nr_�.j i%7/J�c_.C'.. . �j
W.Gdc;trec- '/ /�'7''� f..Gt�-O.J(t- )oC� .S of,Qa-.r.�.,� Zikecr.
C U
991249
Ct9t.i utlif inbi Vif it10J(-4/1
eEit- 1 I3)
a,'W Qp rte,-• is fa 8 t &-naO Q tc% ..ete oat-aJ - `-
7CC ,alder ee-' e re-al .N X4-9- Jn-m t/
fhea C22ti..c .L ,LAt -na. Cwt., a�
e--
jJ-L e�q�''r�¢�.�/e)� �O-c✓ yGzu /Lst nt ,S Qart.etfai
d)e d-
gP eliJ ee < e ipt r ` }c) 5ftc 4 �i�t+, ere
,�G,--2.e , /772,t-Ee� -t °-E'_p a- ?LIZ er,,e.aeL) r .,at ciitt,
c�-e-.)a 2,42_, . S�1 i ,, c nom, �'
�ELtc r�p�i� e2--rut
0adi fez) .in«-r zc, ' 2?ti e aJ .a..d
-7n_c.c.edt. ,QSL R.s .c&fcc, 2..L`` Z.e.a..� �" era cn ya.J
zp/�+-,Q,-�i . .14:.u,t� ,t �O-Orryie/�.�0
275 c_ G i Lert/cc . �) W . !Ct eC� �z [ C1ri� C.t-7Pee �"
,7-2 2-4-- 1///)dCy -C'�!L ylP� aJ --f:t t-rc c, , _ -O.e_, Cot f.
-it 7 .z-r l'7YLA�e� CA-ere-a,. 97G",t c u+-cam
YZrt 'cc—) A/t- .Ae.) oz2 �c c `r-tkeaJ) ( 4 r'
��. ( ).2€21J -72 't•C/ ���y{)r�
/-z tj_;rn-a-J, 5 2t�� nett) ,3 fl-G_'L.a_!'--ate 4 .tee,/"`
.Lt..n , ' .�yCea �L cy Cc-- OtaA-e. 2� c�, ¢.c2,
/ U
,ep- L//a� CCr;t�il } W-FG�/�LU� /tt/oc Cc__. y.4t e fie__,
S;34 6> .
771-0 r-ex.e Cpl, � C."'�"L-Le-(��n C'1� Rt.(U//1NLdJ GI-,J -�
gQ/ Y.-¢2 Ci;ci.e �7ZR'2-2i o-72'1-/Yir-iym
/ ya.Yc,4-)p42-dJ o.:72 L
Ac
K=3 Q .y `3 . . ou.7 5 �,c n-tr ari`t c c'-2c a_(70264-20
,en a-Z C z mu ;Doc 00-tin e-
i naft.e-rt &i Qan e L e c ,z c xe, . ,q e,
not,
�y/J/)j`p t Et c*y✓ (GP/'' ot.- eJe1z� -t use c R 2; /5-ei c
�eK�2e /2n/E,Cit c
Vi .
„bteia ,iAe-ccr•re--re-J.4Y e�} C C yfeac -,r8P7,..a'en.t"-
�ta !ecA „Ica. „fratee ,4 0Ccc ''Jy)itec--' an � , ccf,
�c -t!L 7-12- 'f cri c_e s_ .� yo C ¢Erc r C/�L� tiro r/2 —z� . •
U
Si Stec--
1
Weld County Planning Dept.
TO: DEPARTMENT OF PLANNING SERVICES
WELD COUNTY ADMINISTRATIVE OFFICES OCT 1 5 1998
1400 N. 17m AVE.
GREELEY,CO 80631 RECEIVED
CASE NUMBER: USR-1202
We would like to state our objection to the request for Scott Busker to put 4500 head of cattle on his dairy.
Reasons for this objection. 1. Health Reasons. Family members suffer from asthma,and allergies.
The dairy that exists now adds to these problems.
2. Envirmme1tally we are concerned about the ground water.
3. The flies. Our horse has had the virus from the flies.
4. The stench. We can no longer entertain outdoors,or do we enjoy
outdoor activities like we have in the past. We can't open windows day
or night.
5. Property value will drop.
We have lived on our property fir 19 years and have seen what these-dairies o an airicsdo tarea. We have made
^`
many improvements to our property and only feel that a bigger dairy will decrease our value of our home
and the surrounding area.
Please,Please do not pass this request.
Thank you,
Larry Ri eier and family.
8511 Weld County Road#116
Fort Luptm, CO 80621
r
Brett and Kathleen Cary
7772 WCR Lupton,CO 1 Ft. 80621 Weld County Planning Dept.
303-833-3935
Weld County Planning Department OCT2 0 1998
1400 N. 1716 Avenue
Greeley,CO 80631 RECEIVED
Re: Busker Dairy
Dear Sir or Madam:
We are neighbors of the Busker Dairy and we understand they have applied for a permit to allow
them to greatly expand their operation.There are approximately a dozen residences within'/mile of the
dairy,most have been here since long before the dairy. Many of us were without notice when the dairy
moved in. By and large we have adjusted to the comings and goings,however,we hope that their request
will be denied for the following reasons.
Traffic—Hay,feed,milk trucks,workers,compost/manure trucks,and assorted other business related trips,
all on dirt roads. The dust,the traffic noise and the amount of traffic are already many times worse than
before the dairy was there.
Noise—At all times of the day and night we can hear trucks and heavy equipment operating at the dairy,in
addition to the road traffic. The noise is constant,even h mile away.
Smell—The current odors coming off the dairy are at times unbearable. There are two towns,Frederick
and Firestone,down wind When we moved out here it was not to put up with these smells. Rather than
adding more cows,we would like to see that the dairy be required to take active steps to reduce the
offensive odors from the livestock they currently have.
Pests—Vermin and flies are a constant problem at the dairy,and they travel to the nearby properties. Our
fly problems have astronomically increased because of the daily. Amore proactive stance should be
required to limit the current problems rather than adding to them.
Property Values—Please stop to think about the impact that this request will have on so many people. For
most of us,our homes are our largest investment. Our one holding that we have hoped would grow in
value and provide us with the security all of us want. All of the surrounding homeowners would be
adversely affected,thousands and perhaps millions of dollars in value would be lost.This translates to a
great hardship for many. Doesn't the dairy's right to increased profits need to be limited by the financial
hardship it can cause others?
We hope that you will realize we can't ask for a special permit to maintain what we have built and
worked so hard for. It is your responsibility to weigh the value of one family's desire to grow rich against
the loss in value and an increasingly unpleasant environment to so many other families.The review process
the dairy is going through is in place to allow foreclose and thorough review of the consequences. We
believe it was also intended that more should be considered than just if the dairy has supplied the proper
paperwork to obtain their special use permit. We hope that serious attention will be paid to the many
surrounding homeowners. If it were possible for us to have applied for a special use permit to limit the
many detrimental effects upon our property caused by the dairy,we would have done so.
No hardship would be caused to the dairy by denying their request. We believe their right to grow
wealthy ends when it is coming directly out of the pockets of their neighbors. They are asking for uses
above and beyond the norm,which should not be granted lightly. We hope they won't be granted at all.
titly
pp
v r
v . Laitio,
/ October 30 , 1998
Weld County Planning Dept.
Weld County, . Colorado
Department of Planning Services NOV 0 2 1998
1400 North 17th Ave.
Greeley, Colorado 80631 RE V EI Y E D
Attn: Julie Chester, Planner V Y
Ref: Busker Dairy - USR It 1202
Dear Commissioners:
My husband and I have farmed at this location since 1983
and strongly object to the expansion of the Busker Dairy.
The dairy is on land that is not only extremely sandy but
has practically no slope since it was mechanically leveled
for more efficient irrigation. This makes for poor
drainage of the pens.
Busker Dairy has been a poor neighbor at best. The flies
this summer were so bad that on cool nights the white
/^ siding of our house would be covered with flies seeking
warmth.
There is all night pen cleaning with not only the constant
noise of the machinery but also the back-up beepers
sounding off .
The dairy uses the lagoon water to wash the barn alley and
the stench can be so nauseating we have to close windows
even on the nicest of evenings .
Where is the 80 acre parcel they propose to irrigate? The
headgates for irrigating his land have been removed and
irrigating with straight lagoon water can cause
overapplication and increased salinity. Uneven
distribution can increase pollution potential and
precipitation and evaporation must also be considered.
This is also a seasonal option due not only to crop
production but also freezing which limits or prevents
winter application. Julie assured me that the. applicants
representative, Tom Haren with Snvirostock, would provide
us with the expansion map. (Planning was unable to
duplicate the map with readable print) . I contacted Tom
on October 19th requesting this information and he assured
me he would send a copy and be glad to answer any
questions. We have yet to receive the information or hear
from Mr. Haren. This leaves us with more questions than
answers and bewilderment with the lack of cooperation.
page 2 of 2
Busker Dairy
USR #1202 application
The application states that the intent is to compost the
manure and remove from the property for sale. The
applicant has been composting manure for quite some time
and has been cited by the Health Department for "receiving
wastes other than those. generated on site". Scott
acknowledged only six loads when in fact there were
approximately 3 loads per hour for several weeks. We feel
the applicant has been less- then forthright in the past
and we question his. future actions based on past
experience. We need to take into account the increased
truck traffic removing this compost from the site. Our
experience has been that there is significant semi traffic
due to this composting practice. We would. also like the
compost to be turned more often to reduce maturity of fly
larvae Turning the compost several times per week would
significantly reduce the flies. This is the practice used
by MorningFresh Farms and makes for happy neighbors.
MorningFresh is located near Platteville and has composted
for years.
The Busker Dairy is within the "Smart Growth"
Inter-governmental Agreement planning area of the Town of
Firestone. This agreement was reached after long.
negotiation and discussion by the Weld County
Commissioners and the Town of Firestone. I hope the
intent of the agreement and the wishes of the Town of
Firestone are foremost in the consideration of this
application.
Sincerely,
Gilbert C. Evans Diana L. Evans
~7C- 19
Ft.Lupton,Lu CO 80621 . �l�Or
n fl
r
October 26, 1998
Weld County Planning Dept.
Dept. of Planning Services
Weld County Administrative Offices
1400 N. 17th Avenue OCT 3 0 1998
Greeley, CO 80631
Attention: Julie A. Chester, Planner RECEIVED
RE: Case Number USR-1202
To whom it may concern:
We strongly protest the granting of a permit to
Scott Busker for 4500 dairy cows east of and adjacent
to Weld County Road 17, south of Weld County Road 18 .
As the neighbor directly south of this area, we are
greatly concerned with the air, water, and land pollu-
tion from this large of a herd.
We feel this will reduce the value of our property,
greatly affect our quality of life, and make resale of
the property difficult.
We also feel that the immediate community as a
whole should be taken into consideration and that the
size of the dairy herd already near that location is
enough for this area. One man ' s gain should not be at
the expense of everyone else.
Sincerely,
Albert W. & Violet A. Betz
8179 Weld County Road 16
Ft. Lupton, CO 80621
r
October 28, 1998 Weld County Pl&!wiiq Dept
Weld County Dept. of Planning Services OCT 3 0 1998
1400 N. 17th Ave. RECEIVED
Greeley, Co. 8 30631
Attn: Julie Chester, Planner
Re : USR-1202 - Scott Busker
Dear Julie,
Scott Busker told me in 1994 that he intended to start a small
family dairy for him and his wife to operate. I approved of
that and signed his petition.
Now you inform me that he intends to have a herd of 4, 500 head. I
strongly object to that.
My husband and I moved here from our farm in Gfand Island, Nebraska
in 1972 when we retired. We farmed over 1,000 acres and had a
hog and beef operation. I believe the per acre/#of head limits
have been set by knowledgeable people for justified reasons . Even
with modern technology I don't think these limits should be exceeded.
My reasons for this belief are the potential of reducing the quality
of life for your neighbor farmer with flies, smell, dust and manure.
Also the potential of reducing the health and quality of environment
for the contained animals.
I raffle a large vegetable garden to suppliment my income. The flies
this summer were not only a nuisance but I feel they contributed to
my higher than normal spoilage rate. There were days I entered my
produce shed and could hardly see my boxed tomatoes for the flies
setting on the produce.
This expanded dairy operation not only has the potential of reducing my
property value but of also reducing my garden income. Please deny
this application.
Sincerely,
Ci v Js
Irene Schutt
7707 WCR #19
Ft. Lupton, Co. 80621
(303) 833-2208
Weld County Planning Dept.
OCT 191998
October 15, 1998 RECEIVED
Department of Planning Services
1400 N 17'"Avenue
Greeley,CO 80631
TO:Weld County Commissioners.
RE:Case#USR- 1202
Name: Scott Busker
For:request to increase present dairy herd from present level to 4500 head.
The following is written in protest to the request of Scott Busker for dairy herds increase. I would like the
commissioners to take a good look at the monster you have already created by allowing this dairy farm to
even exist.
The health problems that have been caused by this dairy are unbelievable. Our fly problem is so great that
on Sunday, September 27, 1998 I was not able to leave my residence because of the heavy concentration of
flies on my exit doors. I was forced to use Diazion by spray to remove the flies from our doors. The
commissioners I am sure know what the health problems caused by the flies do to the people,especially to
/ the elderly in the area,which we have in this section.The odor from this dairy is so great that we are unable
to leave our windows open at night.
Also,I believe you need to check on violations by the Busker Dairy,with the Weld County Health
Department for the addition of turkey by-products to his manure piles,this was stopped by the county.
As a resident of this area for 1 l years and long before you approved the dairy I believe his request for
enlargement of the daisy is not warranted. All the neighbors in the section agree with this statement.
We also know that if this is approved Darrell Bearson has told neighbors that he will request the same herd
increase. This will make those residents who live on WCR 19 within 500 foot of two dairies with a
possible herd total of 9000 to 10,000 cows.
Please consider the neighbors'problems and deny this request.
Sincerely,cyarle5,eea-d
B.Heaton
7625 WCR 19
Ft.Lupton CO 80621
Tel.#303-659-6857—home
Tel#303-438-5530—office
Fax#303-438-2197
N0Y 16 '9B 11:54AM P.1
Department of Planning Services
Weld County Administrative Offices
1400 N. 17th Avenue
Greeley, Colorado 80831
Re: Case Number USR-1202
To Whom It May Concern:
Our name Is Justin and Deborah Westmoreland and our property Is on the north border
of the dairy owned by Scott Busker. We have concerns regarding the*pension
proposal of the dairy. First and foremost, the expansion Itself is not a problem. Scott
Busker makes his living in the dairy business and we do not wish to make his livelyhood
any more difficult than it already Is. The concern lies within the management of the
lagoons. When we grit normal amounts of minted' and or snow, the existing lagoons)
run over and down the barrow ditch washing out our drive on County Rood 17. Flow will
they control this? As with any expansion in any industry, there will be more waste,
traffic, noise, dust and in this particular industry, more smell and files. It will also
diminish our property value_ Other concerns include but are not limited to how they will
manage the excess manure and what kind of fencing will be used to contain the
livestock.
If this proposal is allowed, we would like to gee a few stipulations the dairy must follow.
We would like a buffer zone of at least 250 feet between our property line and the dairy
and Its lagoons, with birms and landscaping in this space. We believe this will help
control the noise and some of the dust from not only the dairy itself but also from the
compost piles and when the panel are being damned. We would also Hite to know If the
County is planning on paving Roads 17 and 18 since this expansion will obviously bring
more traffic and tractorftraliors. The tract rltrallors have a tendency to turn dirt roads
into washboards, as you well know, and the grader only comes once a week.
We hope you will keep our interests in mind when considering this proposal.
ay,
Justin and Deborah Westmoreland
p( 41498 40 C4ia)asz-1312.
r^
11/16/98 10:54 TX/RX N0.3343 P.001 ■
c:45:1Taktaca..44:,..
-
November 6, 1998
Weld County Planning Dept.
NOV 0 91998
RECEIVED
Ms . Julie Chester, Planner
Weld County Department of Planning Services
1400 North 17th Avenue
Greeley, Colorado 80631
Re : Case Number USR 1202
Busker Dairy Expansion
Dear Julie:
In response to your letter of September 24, 1998 concerning Mr.
Busker' s request for a Use by Special Review Permit, Bataa Oil, Inc.
(Bataa) would like to make you aware of its rights pursuant to an
Oil and Gas Lease recorded in Book 629 at Reception No . 1550984 by
and between Martin T . Hart and Nadine M. Hart and Energy Minerals
Corporation. Bataa currently operates three oil and gas wells on
the subject property; the Cleveland #3, Cleveland #2 and Cleveland
#7 . The Cleveland #2 and Cleveland #7 wells located south of the
proposed pen area and compost area will require a 150 foot radius
reserved for workover operations . In addition to the operations of
these three wells, Bataa operates the Cleveland #1 and Cleveland #8
wells that are located on the adjacent property just north of the
subject property. The Cleveland #1 and Cleveland #8 wells produce
to a production facility on the subject property located just west
of the proposed pond. In reviewing the Busker Dairy Map, it appears
the flowlines for both the Cleveland #1 and Cleveland #8 wells
traverse the northwest area of the proposed expansion where the pond
and manure storage compost area are planned.
Bataa objects to Mr. Busker' s request for expansion of the
dairy operations where it interferes with Bataa' s current
facilities . Bataa requests that the pond be relocated in an area
away from the flowlines and that an area consisting of a 150 foot
radius be reserved surrounding Bataa' s wells located on the subject
property.
y A.any
5801 WEST 11TH STREET, SUITE 300 • GREELEY, COLORADO 80634 • PHONE(970) 336-100
r- Page 2
Busker Dairy Expansion
November 6, 1998
Any construction activities, excavating, digging, or trenching
must be closely coordinated with Bataa so that flowlines traversing
the property will not be damaged or encroached upon. In addition,
Bataa must be allowed to maintain its access roads, surface
equipment areas and subsurface flowlines for each well . Bataa from
time to time may be required to perform workover operations on the
wells that could create a great deal of noise for any livestock
located nearby. This could directly impact Mr. Busker' s dairy
operations and may result in loss milk production that Bataa will
not be responsible for any related damage or losses .
Bataa must be able to continue its operations on the subject
property in a safe and efficient manner. We wish to avoid future
loss or damage to both parties . If you have any questions or
comments, please give us a call .
r Very truly yours,
BATAA OIL, INC.
(L29
Coll4en Nealy
Land Manager
cc: Tom Haren
r-
I l
OUTLINE OF REASONS FOR DENIAL OF BUSKER DAIRY USR
I. Introduction.
A. The County is considering a use-by-special-review for the expansion of an existing
dairy operation to include 4,500 head of dairy cows or 6,600 animal units.
1. This is a very large operation with impacts more like an industrial processing
facility versus a fanning/agricultural-type operation.
B. The U.S.D.A. and E.P.A. recently published a draft Unified National Strategy for
Animal Feeding Operations("Unified Strategy"). The document published by these
agencies states that operations with 1,000 animal units are considered to be large
operations(see Section 2.1 of National Strategy).
1. 85% of the farms with livestock in the United States have fewer than 250
animal units. Large operations with high animal units are definitely a minority
within the farming and agricultural industry.
2. From 1978 to 1992, the average size based on animal units of dairies in the
United States increased by 93%.
a. But still only about 15% of those dairies have more than 250 animal
units.
3. As part of the Draft Unified Strategy,the U.S.D.A. and E.P.A. cited reports
from various states.
a. In the 22 states that categorized impacts from specific types of
agriculture, animal operations were identified as impacting about
35,000 river miles.
4. U.S.D.A. and E.P.A. in the Unified Strategy indicate that animal feeding
operations pose a number of risks to water quality and public health because
of the animal manure and waste water they generate.
a. Manure and waste water from animal feeding operations have the
potential to contribute pollutants such as nitrogen and phosphorus,
sediment pathogens, heavy metals, hormones, antibiotics, and
ammonia to the environment.
b. Other reports discuss the public health hazards associated with E. coli
/1 from cow manure.
Outline of Reasons for Denial
December 15, 1998
Page 2
5. In Section 3.3 of the Unified National Strategy associated with manure
handling and storage,the U.S.D.A.and E.P.A suggest that"dry manure such
as that produced in certain poultry and beef operations, should be stored in
production buildings, storage facilities or otherwise covered to prevent
precipitation from coming into direct contact with the manure."
6. Section 4.4, identifying priorities for the regulatory program and the Unified
Strategy, states:
Large facilities(those with greater than 1,000 animal
units) produce quantities of manure that are a risk to
water quality and public health whether the facilities
are well-managed or not because the amount of
manure is so large, a spill while handling manure or a
breach of a storage system can release large quantities
of manure and waste water into the environment,
causing catastrophic water quality impacts and
threatening public health. Land application of large
volumes of waste requires very careful planning to
avoid water quality and public health impacts.
7. This same report within Section 4.4 suggests that the aggregate water quality
impacts on a watershed scale should be evaluated by the states when
permitting confined animal feeding operations. The U.S.D.A.and E.P.A. are
recognizing the aggregate effect on water quality of the continued approval
of confined animal feeding operations. Additionally,these agencies state that
site-specific water quality impacts should be analyzed.
C. Recently, a dairy operator was sentenced to a jail term for clean-water violations. A
news release distributed by E.P.A.'s Western Region Media Relations Office states,
"This case reflects the growing national problem of how to handle millions of gallons
of liquid and solid animal waste from factory-like farms. These farms contain
thousands of pigs, cows, chickens, and turkeys that are confined on small plots of
land."
D. An article written for Industry News, a publication printed by the Marketing and
Technology Group for the meat and poultry industries, states that according to the
E.P.A., dairy cows produce between 70 and 120 gallons of waste a day("Jail Term
for Clean Water Violators Signals Get Tough Stance on Livestock Producers," 330,
1998).
n Outline of Reasons for Denial
December 15, 1998
Page 3
II. Posting and Publication was Incomplete and Inaccurate.
A. Weld County Zoning Ordinance Section 24.2.4 requires that a sign be posted for at
least ten days prior to the Planning Commission hearing.
1. The sign posted at the entrance of the existing Busker Dairy operation was
posted on November 6, 1998.
2. The sign was removed until after a meeting at the Town of Firestone on
November 12, 1998.
3. The sign was again posted on the morning of November 13, 1998.
4. The public hearing was scheduled for November 17, 1998, and continued on
that date.
5. The posting for this use-by-special-review as required by the Weld County
Zoning Ordinance has mit been complied with.
B. The sign that was posted at the entrance of the current Busker Dairy operation was
inadequate.
1. Section 24.2.2.4.5 requires that the sign indicate the size of the parcel of land
under consideration.
2. The sign posted at the property indicates only 125 acres are subject to this
application.
3. But the dairy operation is proposing the use of an additional 80 acres
"adjacent to the dairy facility" for purposes of waste water disposal.
4. The total acreage in this application is 205 acres.
5. Where are the additional 80 acres referenced in the application? Was it
posted? Why didn't the posting at the dairy indicate 205 acres are subject to
this application?
6. The posted sign was incomplete and inaccurate.
C. The legal notice published in the Platteville Herald is incomplete and inaccurate.
Outline of Reasons for Denial
December 15, 1998
Page 4
1. The size of the parcel under consideration was indicated as 125 acres in the
publication.
2. The actual size of the parcel under consideration in this application is 205
acres.
III. The USR Application is Incomplete.
A. The Planning Commission hearing is premature because the application is incomplete.
1. An applicant for use-by-special-review must demonstrate compliance with
certain design standards"in the application" (Section 24.5.1).
a. One of the considerations is whether adequate sewer services are
available to the site to serve the uses permitted. There will be
numerous residential structures placed on the site, and there is no
sewer service available to the site. Also, the response from the Soil
Conservation District indicates there are severe limitations as a result
e., of the soils on the property, putting in question the acceptability of
numerous individual septic systems on the site.
b. Section 24.5.1.3 indicates that if soil conditions on the site present
moderate or severe limitations to the construction of the facilities
proposed for the site,the applicant must demonstrate how limitations
can and will be mitigated. The applicant has not demonstrated how
these soil conditions and the limitations therefrom will be mitigated.
This is evidenced by the fact that the Planning staff is placing a
condition on approval that, prior to recording the plat, the applicant
demonstrate how the waste water retention facilities will be
constructed in order to comply with Confined Animal Feeding
Operation regulations. This information should have been provided
in the application allowing the public an opportunity to comment on
the applicants' proposed means of complying with the regulations.
2. Additionally, the application needed to include supporting documents
pursuant to Section 24.7.
a. The applicant was required to provide information regarding the
proximity of the proposed use to residential structures; the size of
stockpile storage or waste areas to be utilized;proposed landscaping
Outline of Reasons for Denial
December 15, 1998
Page 5
plans; a statement delineating the need for the proposed use; as well
as a vicinity map. This information was not provided.
b. None of the maps within the Planning staff's file contain the following
information associated with the vicinity map required under 24.7.4.4:
(1) The general classifications and distributions of soils over the
parcel under consideration. Soil classification names and
agricultural capability classifications must be noted in the
legend of the vicinity map. The applicant has not submitted
the information.
(2) Locations and names of all roads,irrigation ditches,and water
features. The vicinity map does not include all of this
information.
(3) The location of all residences within a half-mile radius. The
vicinity map does not show the location of residences as
,e,,, required.
c. The applicant was also required to submit a plot plan in the use-by-
special-review application pursuant to Section 24.7.4.5. A plot plan
was prepared by Powers Elevation Company, Inc., and last amended
September of 1998. The plot plan provided by the applicant is missing
the following required information.
(1) No public rights of way of record are identified. The utility
easements or rights of way for telephone,gas, electric,water,
and sewer lines are not shown on the plat.
(2) The location of areas of moderate or severe soil limitations as
defined by the soil conservation service is not indicated on the
plot plan.
(3) The location, amount, size, and type of any proposed
landscaping, fencing, walls, berms, or other screening are not
shown on the plot plan.
(4) The plot plan is devoid of complete traffic circulation and
parking areas showing the locations and size of said features.
r-.
Outline of Reasons for Denial
December 15, 1998
Page 6
(5) The inadequacy of the plot plan provided by the applicant is
demonstrated by the conditions of approval recommended by
the Department ofPlanning Services(please see items 2.A.(3)
and(4)and 2.G. as well as 2.7.1 and 2.7.2).
(6) The plot plan should have been amended prior to the
completion of the application and the presentation to the
Planning Commission in order to give the public the ability to
comment on the specific details of the applicant's plot plan.
d. Finally, the applicant was also required to provide supporting
documents pursuant to Section 24.7.5 of the Zoning Ordinance.
(1) Section 24.7.5.5 requires that a soil report of the site prepared
by the Soil Conservation Service or a soils engineer or
scientist be provided. Additionally, where a report indicates
moderate or severe soil limitations, the applicant must detail
the methods to be employed to mitigate the limitations.
(a) The only soil report found in the Planning staff's file as
ofNovember 13, 1998,consisted of photocopies from
the Soil Survey of Weld County, Colorado's Southern
Part prepared by the United States Department of
Agriculture Soil Conservation Service. Exhibit 36 in
the P.C.packet shows that even though the Longmont
Soil Conservation District has identified the soils
existing on the site,the appropriate sections of the Soil
Survey describing those soils are not provided. Other
soils are described in the Planning Commission packet.
i) Staff provides information regarding Nunn
loam soils and Nunn clay loam. Those soils
are not identified by the Longmont Soil
Conservation District.
ii) Staff provides information regarding (47)
Olney fine sandy loam, but not (44) Olney
soils, which is identified by the Soil
Conservation District. Finally,(72)Vona soils
�., Outline of Reasons for Denial
December 15, 1998
Page 7
are identified by the Soil District, but no
information regarding said soil is provided in
your packet.
(b) Review soils information section of this outline.
IV. Soils Information.
A. Excerpt from October 15, 1998,letter from the Longmont Soil Conservation District:
The soils on the site are (44 and 47) Olney, (72) Vona, and (51)
Otero. These are all loamy sands or sandy loans. They all have
severe limitations for sewage lagoons because of seepage. There
are plans for septic systems on the property and the Vona soil has a
severe limitation, with the other soils having moderate limitations.
The (47) Olney and the (51) are prime farmland when irrigated
(emphasis added).
B. Excerpt from Soil Survey: Weld County, Colorado, Southern Part, p. 31 regarding
"44--Olney loamy sand":
This soil has good potential for urban development. The only limiting
feature is the moderately rapid permeability in the substratum,which
causes a hazard of ground water contamination from sewage lagoons
(emphasis added).
C. Excerpt from Soil Survey: Weld County, Colorado, Southern Part, p. 32 regarding
"47--Olney fine sandy loam":
This soil has good potential for urban and recreational development.
The only limiting feature is the moderately rapid permeability in the
substratum, which causes a hazard of ground water contamination
from sewage lagoons(emphasis added).
D. Excerpt from Soil Survey: Weld County, Colorado, Southern Part, p. 35 regarding
"51--Otero sandy loam":
This soil has excellent potential for urban and recreational
development. The only limiting feature is the moderately rapid
permeability in the substratum,which causes a hazard of ground water
r^ contamination from sewage lagoons(emphasis added).
�., Outline of Reasons for Denial
December 15, 1998
Page 8
E. Excerpt from Soil Survey: Weld County, Colorado, Southern Part, p. 47 regarding
"72--Vona loamy sand":
This soil has good potential for urban and recreational development.
. . . The chief limiting soil feature is the rapid permeability in the
substratum, which causes g hazard of ground water contamination
from sewage lagoons(emphasis added).
F. It is not appropriate to locate the large sewage lagoons and numerous septic systems
proposed by the applicant in an area that has severe soil limitations for sewage
lagoons.
V. Analysis of the Planning Staff Recommendation.
A. The staff has found that the submitted materials are in compliance with the application
requirements of Section 24.7 of the Weld County Zoning Ordinance as amended.(See
written comments regarding incomplete application.)
B. Section 24.3:
1. The Planning staff finds that Section 24.3.1.1 has been met, which requires
that the proposal be consistent with the Weld County Comprehensive Plan.
(Please see Analysis of Comprehensive Plan Policies.)
2. The Planning staff indicates that the proposal is consistent with the intent of
the district in which the use is located. The use found within the proposal is
not permitted within the agricultural zone district unless the County Planning
Commission and Board of County Commissioners find that a use-by-special-
review is appropriate under the criteria expressed in the Zoning Ordinance.
The applicant has the burden to prove that his application is appropriate and
his enlarged use is compatible with the area.
3. The Planning staff finds that Section 24.3.1.3 is met and that the uses are
compatible with the existing surrounding land uses. The Planning
Commission should note the opposition to this proposal by the surrounding
property owners and their indication to the Planning Commission that the
proposed use is not compatible with the existing surrounding land uses. The
staff has correctly identified that another dairy is located within a half-mile of
the current applicant's dairy. The owner of the second dairy has indicated
that if Mr. Busker is successful with this application, he will also apply for a
Ir' use-by-special-review permit. Therefore,unless the County denies the second
Outline of Reasons for Denial
December 15, 1998
Page 9
permit,the County will be approving over 9,000 head of dairy cows within a
half-mile of the surrounding property owners.
4. The staff finds that Section 24.3.1.4 has been satisfied and that the uses
permitted under this USR will be compatible with future development of the
surrounding area as projected by the Comprehensive Plan and Master Plan of
Firestone. The Town of Firestone has commented in its referral that the
proposal is not consistent with Firestone's comprehensive plan. Additionally,
the Town of Firestone has commented that the proposal is not consistent with
the Baseline Development Standards created as a part of the
intergovernmental agreement involving Firestone and Weld County. Finally,
the Town ofFirestone also indicates that the approval of this USR will violate
the express terms of the intergovernmental agreement involving Firestone and
Weld County. The Planning staff tries to minimize the Town of Firestone's
opposition by stating that suitable mitigation measures to be imposed by the
County will eliminate or adequately mitigate adverse consequences. The
County's staff has not expressed any conditions of approval or development
standards that are in addition to the minimal regulatory requirements for this
�. use. None of the conditions or development standards go to mitigating the
adverse consequences resulting from this USR application. All of the
conditions of approval and development standards simply go to compliance
with state and federal regulations.
5. This proposal does not lie within any "overlay" districts, but this proposal
does lie within the urban growth boundary for the Town of Firestone, which
is controlled by an intergovernmental agreement. This effectively created an
overlay district for the area.
6. Although the Planning staff finds that Section 24.3.1.6 is satisfied, the staff
does not express how the applicant will be conserving prime agricultural land
in the locational decision for the proposed use. Prime agricultural land will
be taken out of farm production and used for waste water lagoons, manure
stockpiles, and composting facilities as well as stock pens if the USR is
approved.
7. The staff finds that Section 24.3.1.7 has been satisfied by the applicant. The
staff believes that the conditions of approval and development standards
ensure the protection of the health, safety, and welfare of the inhabitants of
the neighborhood and the County. As stated above, the conditions of
approval and development standards are simply an expression of the minimal
regulatory requirements for this operation. The regulatory requirements are
Outline of Reasons for Denial
December 15, 1998
Page 10
not site specific, and neither the applicant nor the staff has addressed site-
specific considerations for the protection of the health, safety, and welfare of
the inhabitants of the neighborhood and the County. Because this is a site-
specific review process, the applicant should be required to provide site-
specific information regarding local hydrology, soils conditions, and other
information so that the County staff and the public in general can evaluate and
comment on the proposal as it specifically relates to this subject parcel.
a. Remember the Soil Conservation District letter and Soils Survey
information. This is the only site specific information provided.
C. Analysis of Conditions of Approval:
1. The staff indicates the conditions of approval must be met within thirty days
of approval by the Board of County Commissioners. The conditions reflect
items that are more appropriate for the application stage in order to give the
public an opportunity to comment on the same.
2. The staff establishes a condition that prior to recording the plat,the applicant
must meet the requirements of 2a through 2k including the subrequirements
1 through 7 found in 2a. In order for the public to provide adequate comment
regarding the applicant's proposal,the items found in Conditions 2a through
2k should be addressed in very specific detail as a part of the application and
not subsequent to the public's opportunity to comment. The applicant has
simply indicated that he will comply with regulations, and the staff is simply
requiring that the applicant comply with regulations. There is no specific
discussion with regard to how the applicant will comply with the Confined
Animal Feeding Operations Regulations,the Air Quality Control Commission
Regulations, and Water Quality Control Commission Regulations on this
specific site given the particular soil conditions evidencing severe limitations
and other site-specific considerations. Items such as a dust abatement plan,
fly control plan, odor control plan, etc. should be submitted prior to the
approval of this permit so the public will have an opportunity to comment on
the same. The staff is effectively shifting a substantial portion of the
application process to a post-public hearing consideration by the staff only.
The fact that the staff is requiring a dust abatement plan,fly control plan,odor
control plan, and also a manure and waste water plan"prior to recording the
final plat" indicates the application materials submitted by the applicant
attempting to address these issues are inadequate at this time.
Outline of Reasons for Denial
Pas
December 15, 1998
Page 11
D. Comments Regarding Staff Development Standards for the Busker Dairy:
1. Standard 4: Shouldn't the Health Department specifically define manners of
disposal of liquid and solid waste that will protect against surface and
groundwater contamination from this site?
2. Standard 11: The staff indicates the surface beneath the manure storage areas
shall be of materials which are protective of state waters. Shouldn't the staff
indicate specifically what these materials should be and how these materials
should be maintained in order to protect the state waters?
3. The staff has not addressed the baseline development standards found within
the intergovernmental agreement with the Town of Firestone.
4. The staff references certain sections of the Zoning Ordinance for purposes of
evaluating compliance with the approval conditions in the future. The County
staff should specifically itemize the requirements found within the subject
Zoning Ordinance sections so that in the future, if and when the Ordinance is
amended,there is no confusion with regard to the obligations of the applicant
if this USR is approved.
VI. Analysis of Comprehensive Plan.
A. Page 2-2 of the Comprehensive Plan states, "It is important that Weld County
representatives and officials recognize their role in reducing the conflicts between
agricultural uses and residential, commercial, and industrial uses."
1. The approval of the applicant's use-by-special-review permit does not reduce
the potential for conflicts in this area. The approval of the use-by-special-
review permit will increase the level of conflicts between agricultural uses and
residential, commercial, and industrial uses.
B. A. Policy 2 states that agricultural businesses and industries will be encouraged to
locate in areas that minimize the removal of prime agricultural land from production.
1. The Soil Conservation District has found prime agricultural land exists on the
site. The approval of this use-by-special-review permit will remove prime
agricultural land from production.
Outline of Reasons for Denial
("' December 15, 1998
Page 12
2. The USR proposal also allows numerous residential units to be located on the
property. There are enough residential units to be considered "urban-scale
residential development" under the Zoning Code and Comprehensive Plan.
The location of this urban-scale residential development is within a very
intense, industrial-like, agricultural use.
C. Page 3-3 of the Comprehensive Plan recognizes that when growth at the
municipality/county level is not coordinated, problems such as incompatible adjacent
land uses and inconsistent engineering standards occur.
1. Approval of this USR is not consistent with coordinated planning since it is
within Firestone's Urban Growth Boundary,and Firestone has determined the
proposal is incompatible with its master plan.
D. The first sentence of page 3-2 states, "When a municipality and the County enter into
an urban growth boundary agreement, the County agrees to abide by the
municipality's vision for future development in the area."
1. The proposed project is within the Firestone urban growth boundary, and an
existing agreement with regard to the future development of the area is in
place. Firestone believes this proposal violates both its comprehensive plan
as well as the intergovernmental agreement.
2. Paragraph 4.3(g) of the IGA states, "To the extent legally possibly pursuant
to the Plan and the County's land use regulations as described in Section 3.2,
the County will deny proposals for Non-Urban Development in the Urban
Growth Area."
a. In order to comply with the urban growth boundary provisions in the
comprehensive plan,the County must comply with Paragraph 4.3(g)
of the intergovernmental agreement with Firestone.
E. UGB.Goal 1 states that Weld County will assist each municipality in establishing an
intergovernmental urban growth boundary agreement.
1. Weld County has encouraged Firestone,Frederick, and Dacono to enter into
an agreement regarding the urban growth boundary for each municipality,and
the approval of this application will "fly in the face of' the previously
approved intergovernmental agreements with these municipalities.
r
Outline of Reasons for Denial
December 15, 1998
Page 13
F. UGB.Goal 2 states that the "County will concentrate urban development in or
adjacent to existing municipalities. . . and maintain urban growth boundary areas that
provide an official designation between future urban and non-urban uses."
1. This project is within an urban growth boundary area that provides an official
designation between future urban and non-urban uses. The proposed USR
creates a non-urban use in an area designated for urban uses.
G. UGB.Goal 3 states that the County and municipalities should coordinate land use
planning in urban growth boundary areas, including development policies and
standards, etc.
1. The County and Firestone should coordinate the land use planning for this
property. The County and Firestone have developed policies and standards
under which any development within the urban growth boundary must
comply. It appears the County has not considered those standards in
evaluating the appropriateness of the specific proposal put forth by the
applicant.
H. The Comprehensive Plan does not support the approval of this application. The
Planning staff has only cited one goal and one policy within the Comprehensive Plan
that supports the approval of this application. Contrary to those two provisions,there
are numerous other provisions that indicate this proposal should be denied.
1. See 2.a. of staffs reasons for recommending approval.
r-
Deeebt15.InvmAroN\ooaMENTOU .wenT
December 19.1991
Weld County, Colorado
USR #1202
Busker Dairy
December 1998
Weld County Planning Commission
Dear Sirs & Madams :
Please find attached a compilation of Actual Property Value
of all the homes of surrounding property owners in the immediate
area of the Busker Dairy expansion. The owners-of the properties
pictured are strongly opposed to this expansion.
To recap I would like to note that all of these records were obtained
from the Weld County Assessors office.
Total actual value of all Total Actual Property
surrounding property owners Value, 1998 Type
listed on applicants 9/28/98
"Certificate of Mailing" : $1, 798,456 8 agricultural
4 residential
Total actual value of all
surrounding property owners
NOT listed of Cert. of Mailing: $ 268, 631 2 agricultural
Total actual value of surrounding
property owners opposed to usr 1202
and in immediate area of dairy: $ 351,426 4 agricultural
Grand total "Total Value" of
opposed owners : $2418, 549 14 agricultural
4 residential
_Properties in this report are only owners who have made their
objections known by letter to planning and/or attendance to this
meetinr or the previous two meetings cancelled 11/17/98 & 12/1/98.
Typically properties located near a confined feeding operation of
this intensity loose 30% of the property value. That loss would
be $725, 565. 00. Can county justify this loss for these owners?
Respectfully Submitted, Gilbert & Diana Evans
7987 Weld County Rd. #19
Ft. Lupton, Co. 80621
(303) 833-4720
SURROUNDING PROPERTY INNERS AND/OR
SUBSURFACE ESTATESANTEREST OWNERS
Scott Busker
USR-1202 Total Actual Property
!� Value, 1998 Tyne
Gilbert and Dianna Evans
79871MCR 19 883, 275 Agricultural
Ft Lupton,CO 80621
EH and Elva Marino
8800 WCR 18 $293 , 348 Residential
Ft Lupton,CO 80621
Bud and Joyce Hunziker
' 7073 WCR 19 $207 , 172 Agricultural
Ft Lupton,CO 80621
•
Phillip Camenisch
10504 WCR 7 Unknown if opposed Agricultural
Longmont,CO 80501
David Mallory
7549 WCR 16 $112 , 124 Agricultural
Ft Lupton, CO 80821
Deborah and Justin Westmoreland
7812 WCR 17 $74, 620 Agricultural
Ft. Lupton, CO 80621
Big Sky Venture,LLC
24WC 17 Willmer, Wil
Ft Lupton, CO 80621 $109 , 750 Agricultural
e Albert and Violet Betz
8179 WCR 16 $196 ,426 Residential
Ft Lupton,CO 80621
Wayne and Mary Lockwbod
8275 WCR 16 $187 , 383 Residential
Ft. Lupton, CO 80621
445V1 R15 8243 , 248 Residential
8445 WCR 16
FL Lupton, CO 80621
Joseph and Virginia Heaton
7825 WCR 19 $193,474 Agricultural
Ft Lupton,CO 80621
. Irene Schutt
770 WCR 19
FL Lupton,CO 80621 $97 , 636 Agricultural
HS Resources, Inc.
1999 Broadway, Suite 3600 Subsurface interest only, Unknown if opposed.
Denver,CO 80202
BataaOil, Inc. Subsurface interest only, letter in planning file
2500 W.29th Streetopposing expansion of Busker Dairy
CC CO806 808311 Greeley,
CERTIFICATE OF MAILING
I hereby certify that t have placed a true and correct copy of the surrounding property owners and owners and
lessees of minerals in accordance with the notification requirements of Weld County in Case Number USR-
1202,in the United States Mall, postage prepaid First Class Mail�byy letter ass addressed on the attached list
this 28th day of September, 1998. /
Weld County USR--1202
Busker Dairy
Surrounding property owners NOT notified with "Certificate of Mailing",
Total Actual Property
Richmeier, Lawrence & Kim Value, 1998 Type
8511 WCR #16
Ft. $126 , 352 Agricultural
Lupton, Co. 80621
Black, John D. & Susan C.
8076 WCR #18 $142, 279 Agricultural
Ft. Lupton, Co . 80621
Surrounding property owners opposed to expansion and in immediate
area of dairy (I.E. across road and/or adjacent to dairy. ) Their
opposition has been voiced via letter to Planning and/or attendance
to todays or--.previously delayed hearings about this matter.
Total Actual Property
Goetzinger, J.J. & Betty J. Value, 1998 Type
7128 WCR. #19
Ft. Lupton, Co. 80621 $43, 527 Agricultural
Wilson, Richard L. or Elizabeth
6707 WCR #19 $159, 339 Agricultural
Ft. Lupton, Co . 80621
Cary, Brett R. & Kathleen
7772 WCR #16 $51, 290 Agricultural
�- Ft. Lupton, Co. 80621
Spurling Thomas E. III & Diana
6648 WCR #19 $97, 306 Agricultural
Ft. Lupton, Co. 80621
RECAP
Total actual value of owners opposed and
on Certificate of Mailing: $1, 798,456
Total actual value of opposed surrounding
property owners NOT on "Certificate of Mailing": $268, 631
Sub-total Surrounding property
owners opposed to expansion: $2, 067 ,087
Additional Adjacent opposed owners
total actual value : $351 ,426
Grand Total Actual Value of surrounding
property owners opposed to expansion: $2 ,418, 549 1998 Value
Attachments : Weld County Assessors printout of
individual properties reviewed here: 20 pages
Pictures of many properties included
with the assessments . Gil & Diana. Evans
Respectfully submitted: 7987 WCR #L9
Ft . Lupton. Co
S¢ t
(1
Ili
0
• 0
1
m W 4 4 0 0 4 4 4 4 4 4 4 0 4 4 4 4 0 4 4 `: A
7
ea T N
Li
w 4
(0 •l•1 Ll o
• N A l
el el r 0 el N N b P CO T O el a 0) •D n r m r` w 0 0
O N N m el en el en en en el a • • 3 3 • • a to 7 1-1 .°„
Ul at 00000 00000000000 000 yl 0) '0
y,( 0 0 0 0 0 0 0 00 0 0 0 0 0 00 0 0 0 :a
'ill
i 000 000 0000000000 00,8 N 7 .y. C
w (Ui co CO CO CO CO 03 CO a a 0a CO CO Om 0 0 00 Om m "' C WOW N m
le N N N N N N N N N N N N N N N N Nei 0 7
E W HHHeielelnelelrelel . ri .iea 0 Nco K1 4-i
N a m n en el m m m m n m m en n m@ n n .-1
m� 44 C C .
(0 N rl wo r i el el ea el ea el el el .-1 W l.11 .-1 el el N ro w 01
I,VN w O E
(0 0 0 w N
(!i V O N l•l 0 O N.S.' 0 p Ul 0.
0i1 >+ N l-I N 7 L•rl C .C N U l•1 P. 7 0 ti
0.0 CO ri u .n ro w al u a -lW •el m .+ N
ri •( 7 0 +l N V N m > •ri 7 rl N m m >
r-1 N„ cn .a 303 (n w �,w Z.-. as 3 m G N
(d al W W W W W W W W W CO CO 3 a W W W W W W 0 0 'O
CO m m a CO CO m CO m m m m 0 m ON m m m 0 m
(44 e 0 r n a W co m m o et r m W r to el N r co a m 3 T 0- N
HIV N N N N N m en o 0 m m en a a ei el 0 00 O yl k al w Iv
V en m m m en m � en en \o W • a W W 0 ei el co H
O �4 a a a e a :II a a a o o n n o 0 o el el el .l H w al w v1
.,1 N it YI N Y1 m m t;1; O O O O el el N .i e1 ei e1 N 7 r{
J-1 UI m' K m W W w' c4 w' C (L W g W C4 W W aC a rice
a 0) M
OM Z u m z S x .-,, 0 N O 0 m m O
l-1 - 3 W V comm• O O Z W m N.l Co W• v N a L W O
.i '4', C Z uy l.1 (Uit 0 n N U V rl � Z 3 0 -' C 03 .H T
w (OS W r W • a a u V Nee O N > m 1.1
}l •rl to m ME. W ZZ • m W W W W +l U N oat nl
7.73 pas nF a On � - W h3m0OK x NN u C •rl a e-1
I .
w w '" W N W - ooFHelll-luOOO mm V Nei C N .
CVrl Umn CO a0n00 Fal >. 0 3N3N N •C N N 7
U L w -- tmvo UUUaZ Za4 Para u mm H 2 C A L a
•rl �..' r ti U 3 U' 0 0 X w� >. N ry N 0
ll.l •.-, raw 3 m 0 W W 0 W W 4 U' O ., rl ZZ
W to 0 3 W W m m W m C. W W o: N 0. --
N co m 0 0, m r m co el F F O T 3 C
N m 0 m r r V t0 F of P 0. 0.
cc?,
V W m r W W r X 44 . W W wed - •0 N
O mrvr W m W W W •rvJE r r — . rmm 0. 0 0 0.
co•41Q1 N le m P N N H LOW N ' N N
a r W N N r.,;)
m0100, 0 • COi t
• 1-°S) a 3 N U to m m to N u N N r 01 rl el .$ C 4
W VI >4 N CO N N m JC 1 . W N
N C m W N N N N a la
`..43
m NW
W W N r'l 0 CO V
QQ ry iii mry m as W NNN tamC .el rl �•l N t
CO (p m r m ry a W W a m Z N • a al u 7 N
� - a to N 3 Z Z W N N W CO 3 N F F 7
N a n 3 • W N N Z m • a 0) w 0. al
el r
co 0. 3 amNa3 a W m a a N W Rl NmZS N m u
Cl) • N W W 3 N N 3 W m WNW W C
(0 O ry N W m W a m Z Z Z z a 3 0 E • X X vi 3 m >
�•w . smoteCI N F W FE. F FZNN 0. 0. 0) 041 0i 333 W m al N ,C 1
A• D) 010.al F w w 0. w H Z a ea Z ZOO a •el M N CI)
Zam W 4a V 4. m4w U ₹z4m OZw' m 0 > •r4 U) el
to to W W to W V N N a a m m in a • 4 40
7 , N C
a
ei el e. H el ei el rl el el H e1 el H el .4 H H 0 w L ,C r
. a • a a a • • 3 • a a 'WV . ell a a F F E m u 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
4) N N N N N N N N N N N N N N N N N N of ..l ml w N
ml 7 o al -0
rl 7 u m
O v w m u m
W 0+ •la u p N u
a a' u V N w m
✓ r r r r r r r r r r r r r r r r r r r 7 N 0 u m
W W W W W W W W W W W W W W W W W W W W m P. 0. N N
,a !el
d VI m 0) el T
N ..-I > rl w
0 N N N N N N ea N N N N N N N N N N N N el �" N •.'l N
W P00000000000000000000 El Ei •m 3 >
IC c
le 0
c y
V
Co ry m m m m cm m m m m m w m m m m o w m m - —. .
N N N N N 01 N N N N N N N N N N N N N N Am
Ei
ii ell 41
°ii. i o c` t' jtntt ii, pi i
tkitill
it SII I'll
nass
ii ktyi
4 :y ��
it I i. I , , .
l ' .
1111 1 �v
o
3 t, y1
1i11a1, s
b r: E
II hE! T i o iPr
I i
, id :,,.
7 „ , ,,
,.
I'
Iit , _ ..1
1 1
3li l 1 '; �, 11
if i o� E • I
l■
i .ii
L i, I 1 1311113! # - ' j 1: 1 1311311;
1 ii
i
dj
la LI.4i
� ilSifi tirrd. �, ti , ,
i
ii 1
-:L1 it � '1
',iii 1f i I 13111111 • i I ` ` 1311133;
14 i is I
III
l ig i - 1 . ,
if
jam■}1 � it
i A5II
4 ' I31 jilt CD
I
I , lu- i ii
Jo L
!. l 13131113 II
ILii . 1 1311111►
4 , 1 .14,
+
ii, # and;. .�" 'Mai,,
i
egg lic sr,. i Ott
k.$ t , ki.i !I •A. ,. : 1 i` i ��
i Jinni; 1 } I6y
t
'�`" to'
1JJfi
'„ t. � r4
VI , i j
a
j , Jilai .` j a WWII
i + A8 C
ICI I1 - _ft
I i I i - 1,73.L.: Itc.c,
i I !
It, ! _ I ii!?Iiit ellI1
iiii• l
i�°!9+( a Y if 3�ii f
if 11/4 tii
'it `+16141 � ., +
!IIp d1
r:::17,iiiEl
''%i11 ii1°liir t� i lit
331?liii
HIM 1=
i :16666 IakniF * i
Si I 6 {+
IL
i �7 qPt El
11 II I i
u
! }1
; t 33111ii1 I, III I Wind
/ tee/, gftP.sc/ pye
ts- e /
AA-07E- 2,
t /f
pfo�� _ .r� �', o n..ife ,elaese- .,."74-7 .Ace 7z-
/ / o• y�4 / o ,%�
j
es-
71.4-7z z< ����
7- f, � � ���� � s
.i#'-�� LL /yam/ 2a‘��/
-4/. _ - -
1i2- /n �%P 5W t/99V.
/9 -
11 e
� _2'yr /77
fi.12d fir t/le-z _ O�%7iG� - r7�G- 4,745-ea -
1
/ellea2
/h .7-
V
/ I e e �i�� /12
,fr" 7/2 j/
_5
J! / l -A% /A'e s≤,-ere i�`s //
r' -e-s- o -
ae #/) is -
719
e
I : �� , /' mss4/7 e
Q1 /-tr4 4,5 ecr,r rt
Ti' %/2"y
7L
9'S , 117,7‘7G r/avrit`ezzren<
[i
I5/`i%q lie 4"ge ` X/,rte
v /1 kitj ,
�r�rL�s Z4- _-!2Zd X7',1 - cf,e z
i
(0,A7/),'-'. - - , i< 47,,4eiK---,40:--tr, de__ ,ftd ' e 3
Qt.-
, > e n 1„di-eirZ DST,___________,egf,a2z9 ASS .
,/r . s
/
fig P ,el /ti`i j 5y cS lef271
77/,s 575 r ' /s '1e& / 4a
- . St/77 ."freelcit- fr,die/y71,et° , -7. a,
41/7 / % ,Sf /I. T/rc _
f e/.. erne e e'-IG (�&//
/ fit .f
• 7/ . -- - T • • • /
je �e le f1 .
. •
7 • -9° va the it p7I'
7 5-
lire e_ • _,Ite . c _ - 5
Pg4 ,5 b c 6
GJ_ al_e_i_s//_I '" /�/cO /7,,Pr ireZ
/
G G 27
Pete V
np /p /etS71- 0i e Sc S,
E
Ujr 7t riff 74/9r
G '
'K pn tvz' Jl .,
t easey r /e //, zz eir
ail_,7 - ' ≥ter :. 74
e_ l
i dint. mein
ri--- „A-,5 --,2 ,-)/7a 44- / lc----, '
s •_d_________a/ nre___________
in#. e - c'♦ b ,s
ii7!7,-� s /74 f-7
. I : . e-,---
f Lit(/ , . ce. /5 ! J , e
II
%a' h elf Y� - Grl' , 'Memo
,
I
77 e
,I Y
- i A , z , -
S. \'l :i " e-; i r 4,,- �� _�V
2ff'7�G �or�
l ' 24. flues
(i /n2
���G/ �o
5-1
`e' . ix /7O` : /� /i-, / 1 /iii I—
C d's / e'
r h e ____4i/2O, _ - - X--341
dpcn-v�' /�'71;4-
ro yJ% 2 l 7
o 0`1y sir 4 . . e.r ?4r
o,
ii e/r7: 4 i� /-/1� o /
/l E414/ i / -t % 1- - J --t-
i ! A ,- e �� 6,1'i�r�
cat& 4e�ao � _ _�'� � -
_A - G'_ eCS 1I c r terdirat
- `� -. f f/1�z��G£�_
f''
li'' 1 Ps _A/1j et--
(/l9j, Jc4fl4 s/ d'4 / /¼.� 4 D/1 e
i `?` h1/2
r
if r 1 4 _fir___,A, e i /s_i -nit, 27 _
//A e "h G i e e n a i -""e, ,y 4
- -:. %7" e/�`s yr- • �, -
ill
7 -412/Y
!I1 pi--rsir /`>> �-
�� • �. �.
ill ,IG1:v .tom/ IA> t is,' p',..,/e/' I In l i°f s 2- r - " rs
.-, _ g 'J`-,4 / f/L-
J
1 ' .3//� ` -
/i` / fi ' c /-
1 _
`•- •� aai��i���/
o
HI
' '
!II tcc4 ,al / tvAr .1 -re/, ,
L' -
th "p / 6.t , / 1 . / ,. <- ` • �.—
,e-- t
SZ`L---- /5
J` nr1
G , 4 z�Gd/reS
p , _________
; _._ 7
ii
r^ / /e si,ew ,z-L-----n,
fin • . , z
4 i v
n ,- Z 77 e -, '
9" is er 7-afr / /.�si'ercc
r/.e►�e ��z ( "This /.5 zic
li An -7/' ,b 1 ' . 7/
�ti me- e c%%
ii ` S
K..---- / / i t 4
h 7 e // t, / / �1
r. jil Ile /7/ h e LGtr . —P S
1 e y/ -ys7.d .6,9.,7 ` c .rky.xi /s
I (f/1. . ex/57 h,- n/-4-7/ viers/, ewes
j'' d.1// ho" icf fi AC2 7/`S,---
off- /
5G&/7 ,6/ Itss ;4.- /
t "J fl7-7/ 1/e/ #.b�e t Ze 6/ r ,# -,
!I �D�/I ne1G "eve JCr ,4 9//t'
w ,z y( -
FA--A-; =
te- !1
it --
I
f---
Exhibits 47 , V- 1 ,V-2 , W, AA, BB , FF
are oversized maps and cannot be
reproduced at the Clerk to the Boards
office.
Hello