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HomeMy WebLinkAbout20140521.tiff RESOLUTION RE: APPROVE SITE SPECIFIC DEVELOPMENT PLAN AND USE BY SPECIAL REVIEW PERMIT, USR13-0054, FOR A MAJOR FACILITY OF A PUBLIC UTILITY (TWO (2) 115KV TRANSMISSION LINES EXTENDING APPROXIMATELY 24.7 MILES AND TWO (2) SUBSTATIONS - KEOTA AT THE WEST TERMINAL AND REDTAIL AT THE EAST TERMINAL) AND ONE (1) 250-FOOT TELECOMMUNICATION TOWER LOCATED AT THE KEOTA SUBSTATION IN THE A (AGRICULTURAL) ZONE DISTRICT-TRI-STATE GENERATION AND TRANSMISSION, INC. WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the Board of County Commissioners held a public hearing on the 26th day of February, 2014, at the hour of 10:00 a.m., in the Chambers of the Board, for the purpose of hearing the application of Tri-State Generation and Transmission, Inc., 1100 W. 116th Avenue, Westminster, CO 80233-0695, for a Site Specific Development Plan and Use by Special Review Permit, USR13-0054, for a Major Facility of a Public Utility (two (2) 115kV Transmission Lines extending approximately 24.7 miles and two (2) substations — Keota at the west terminal and Redtail at the east terminal) and one (1) 250-foot Telecommunication Tower located at the Keota Substation in the A (Agricultural) Zone District, on the following described real estate, being more particularly described as follows: The Pipeline Route commences at the Keota substation in Section 17 and enters Sections 16, 15, 14, 13, Township 9 North, Range 61 West; then into Sections 18, 17, 16, 15, 10, 3, 2, 1, Township 9 North, Range 60 West; then enters Sections 6, 5, 4, 3, 2, 1, Township 9 North, Range 59 West; then enters Sections 31, 32, 29, 20, 17 and terminates at the Redtail substation in Section 8, Township 10 North, Range 58 West of the 6th P.M., Weld County, Colorado WHEREAS, at said hearing, the applicant was present, represented by Selina Koler, and WHEREAS, Section 23-2-230 of the Weld County Code provides standards for review of said Use by Special Review Permit, and WHEREAS, the Board of County Commissioners heard all of the testimony and statements of those present, studied the request of the applicant and the recommendation of the Weld County Planning Commission and all of the exhibits and evidence presented in this matter and, having been fully informed, finds that this request shall be approved for the following reasons: 1. The submitted materials are in compliance with the application requirements of Section 21-3-330 of the Weld County Code. CC: CRPL, Pw;{-h_dOlPpr . 3-31 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 2 2. It is the opinion of the Board of County Commissioners that the applicant has shown compliance with Section 21-3-340.A of the Weld County Code as follows: A. Section 21-3-340.A.1 states: "The health, welfare and safety of the citizens of the County will be protected and served." The Design Standards (Section 23-2-240), Operation Standards (Section 23-2-250), Conditions of Approval, and Development Standards ensure that there are adequate provisions for the protection of the health, safety, and welfare of the inhabitants of the neighborhood and County. B. Section 21-3-340.A.2 states: "The natural and socio-economic environment of the County will be protected and enhanced." There are no significant prevalent natural hazards in the area that will affect, or be affected by, the project. Historically, the area has been dominated by dryland agricultural uses. C. Section 21-3-340.A.3 states: `All reasonable alternatives to the proposed action, including use of existing rights-of-way and joint use of rights-of-way wherever uses are compatible, have been adequately assessed and the proposed action is compatible with and represents the best interests of the people of the County and represents a fair and reasonable utilization of resources in the impact area." The transmission line corridor alternatives were evaluated to address the needs of the Project. 1) Scenario A -- Taking no action will result in no power delivery to our Members and their customers. The No Action Alternative does not meet the need of the Project. 2) Scenario B -- This alternative will involve the construction of approximately 24.7 miles of 115-kV transmission line between a new 345/115-kV Keota substation and the Redtail substation. Scenario B will provide the necessary power to supply oil and gas facilities in the area, as requested by Member customers. The preferred system scenario is Scenario B. Scenario B meets the Project's purpose and need, and provides a cost-effective, secure, and reliable source of power for Tri-State's Members, High West Energy and Morgan County REA, and their customers. The process used to identify alternative locations for the 115-kV transmission line began with delineating the general location for the substation sites, the location of the oil and gas facilities, interconnection considerations, and existing infrastructure. The locations of these features heavily influenced the area of consideration for the transmission line and substations. Four (4) potential routes from the proposed Keota substation to the Redtail substation were created based on an opportunity and constraints analysis that included, but was not limited to, the following criteria: Shortest length between the Keota substation and the Redtail substation: avoidance of 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 3 the Pawnee National Grasslands; avoidance of undisturbed and environmentally sensitive areas; existing linear corridors; property lines; buffers surrounding the Cedar Creek wind farm turbines; buffers surrounding existing oil and gas wells; buffers surrounding residences and buffer zones surrounding military infrastructure. 3) Alternatives -- Under all action alternatives, the Keota substation will be located adjacent to the existing 345-kV Laramie River to Story transmission line approximately one mile south of County Road (CR) 106 on CR 89. a) Alternative 1: The transmission line will then head north along the existing 230-kV Cedar Creek-Keenesburg transmission line and follow the route to the north and east until diverting south to the Redtail substation one mile west of County Road 127. Alternative 1 consolidates the disturbance with the existing transmission line. Less than one (1) mile of transmission line will be constructed outside an existing corridor, and no new landowners (that weren't impacted by the Cedar Creek lines) will be impacted. The line will be placed within 500 feet of two residences, and will cross four parcels (4 miles) currently encumbered by conservation easements held by the Colorado Cattleman's Agricultural Land Trust (CCALT). Alternative 1 is the longest alternative at 26.7 miles. b) Alternative 2: The transmission line will follow the existing Cedar Creek-Keenesburg line north and east out of the new Keota substation, but will divert from the existing line approximately 2.4 miles south of where the existing line turns due east. The line will then follow parcel boundaries for 2.15 miles where it will turn to the northeast to cross the Chalk Bluffs. It will then run north for approximately 0.6 mile before turning due east to CR 382. The line will then follow CRs 382 and 118 to the Redtail substation. Alternative 2 is the shortest with 22.5 miles of transmission line and avoids three parcels (2 miles) of land held in conservation easements, compared to Alternative 1. However, it creates 14.5 miles of disturbance outside the existing corridor (and crosses 18 new parcels), and comes within 500 feet of three residences. Additionally, it creates a new disturbance corridor across the Chalk Bluffs, approximately 2.3 miles south of the existing crossing. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 4 c) Alternative 3 follows the existing Cedar Creek-Keenesburg transmission line, except where it cuts through the wind farm at the Cedar Creek substation and then re-connects with the existing line near CR 382. The transmission line will follow parcel boundaries along the diversion as much as possible, but will be located approximately 600-800 feet north of the parcel boundaries for approximately 2.8 miles to avoid wind turbines. Alternative 3 will include 25.3 miles of transmission line and will impact nine parcels in conservation easements (5.9 miles). This alternative will create 5.2 miles of new disturbance outside the existing corridor, but will not come within 500 feet of residences. d) Alternative 4 occurs entirely outside of the existing Cedar Creek-Keenseburg transmission line corridor. It follows the parcel boundaries east out of the Keota substation for approximately one mile where it turns due north for one mile then back east for seven miles to the approximate alignment of the extension of CR 105. It then turns north for 1.25 miles, then east for approximately seven miles to the east side of CR 119. It then turns north for one mile to the north side of CR 110. It then turns east and north long property boundaries for approximately four (4) miles, then runs north for another three (3) miles and terminates at the Redtail substation site. Alternative 4 will include 24.7 miles of transmission line. It will cross 30 parcels, none of which have previously been impacted by a transmission line, but many of which are currently under oil and gas development. There will be no disturbance to any parcels currently held in conservation easements by the CCALT under Alternative 4. Additionally, the line will not come within 0.5 mile of any residences. Alternative 4 will not cross the Chalk Bluffs and will be located approximately two (2) miles to the south of the bluffs at its nearest location. Alternative 4 was selected as the preferred alternative after the following land use and natural resource features were taken into account: Avoidance of the Chalk Bluffs, Landowner input, Line distance, Conservation easements and Existing disturbance (oil and gas). 4) Public Outreach -- Tri-State mailed a letter to all landowners along the four proposed routes explaining the Project and the purpose that it will serve. The letter identified the purpose and location of 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 5 the proposed project, and requested permission to assess their properties. Recipients were provided with contact information and were invited to call Tri-State with comments or questions about the Project. Tri-State followed up with direct contact by phone or in person with the owner of each potentially affected property. Several owners of parcels that will be crossed by Alternative 1 requested that Tri-State select another route that was not across their land and/or not across Chalk Bluffs. In addition, several of the parcels crossed by Alternatives 1, 2 and 3 are encumbered by conservation easements held by CCALT. CCALT strongly opposed any route across its conservation easements. Tri-State also consulted with Colorado Parks and Wildlife (CPW) for the Project, who also preferred a route that did not cross the Chalk Bluffs. Tri-State did not receive any formal comment letters, or other negative feedback from landowners crossed by the Preferred Alternative. Tri-State received one electronic mail comment from a landowner adjacent to the Preferred Alternative, voicing his preference for the route across Chalk Bluffs and opposed to the Preferred Alternative. As the preferred route was identified, Tri-State staff reached out individually to the landowners whose property will be impacted by that route. Tri-State continues to work with those landowners to minimize and mitigate impacts to their properties. A second letter was mailed to all landowners previously contacted, informing them of the selection of a preferred route and the two alternatives, and again requested input. The new 24.7-mile transmission line will consist of approximately 222-296 structures, with the number of structures typical per mile listed as 9-12 poles. The structures will be a self weathering steel structure spaced approximately 400-600 feet apart. The poles will be between 60 and 100 feet in height from natural grade, with clearances over all roads and land forms listed at a minimum of 28 feet. The transmission line will have up to six conductors and an overhead optical ground wire. Transmission poles will be directly embedded in soil, except at changes in direction of the line. At these locations, the poles will be installed on reinforced concrete foundations, approximately 5-7 feet in diameter and 20-30 feet deep. There are no socio-economic constraints associated with the project. D. Section 21-3-340.A.4 states: "A satisfactory program to mitigate and minimize adverse impacts has been presented."The Colorado Division of Parks and Wildlife and the State Historical Society did not return a referral response, and the US Fish and Wildlife Service returned a referral dated January 13, 2014, indicating no concerns with the proposed development. The vicinity of the Project site is characterized by agricultural production, electric transmission, oil and gas production and storage, wind farms, as well as residential uses. Land to the north, south, east, and west of the Project area is part of unincorporated Weld County and is zoned 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 6 agricultural. The parcels that will be crossed by the line include agricultural property and oil and gas development. There are no residences that occur on parcels adjacent to the transmission line and none within 0.5 mile of the line. No residences occur on parcels adjacent to the substation, but one residence is within one mile of the Keota substation. There are multiple oil and gas wells and an existing transmission line on the properties as well. Further, the transmission corridor and substation sites are not situated within the boundaries of a 100-year or 500-year floodplain. Tri-State submitted an application with FAA and received a "Determination of No Hazard to Air Navigation" for the transmission line and communication tower. The surrounding vegetation communities can be characterized as disturbed grassland. Permanent removal of vegetation will occur at structure sites. Construction will occur primarily in an area that has been previously disturbed, and impacts to native vegetation communities are expected to be minimal. Most access will be overland in nature or along existing roads, and minimal vegetation will be disturbed from roads. The preferred alternative transmission line route will cross three named-drainages, Wild Horse Creek, Igo Creek, and North Pawnee Creek. The drainages will likely be spanned by the transmission line so no impacts will occur. Neither wetlands nor wetland vegetation was observed in association with the drainages. Additionally, no drainages or wetlands occur at either of the substation sites. If it is later determined that the drainages cannot be spanned and temporary impacts to wetlands will occur, Tri-State will notify the Army Corps of Engineers and construction will be authorized under a Nationwide Permit. Impacts to vegetation are expected to be minimal and impacts to wetlands and water resources are not expected to result from the Project. The native grassland and agriculture areas surrounding the transmission line are likely to support a variety of common wildlife such as pronghorn, coyote, fox, skunk, rabbits, and various birds. There is no designated critical wildlife habitat in the vicinity of the project. The area also supports habitat for various state-listed species, discussed in detail below. Tri-State is conducting an assessment of the area to identify suitable habitat, particularly for special status species. Additional surveys will be conducted in the spring, prior to construction, in areas identified as suitable habitat for state-listed species and for migratory birds. CPW recommended species-specific surveys for Plains Sharp-tailed Grouse leks, Mountain Plover, and Western Burrowing Owls (if prairie dog towns are found). If any nests for migratory birds or any state-listed species are found, appropriate construction timing limitations will be enforced, as feasible, according to CPW recommendations. Where timing limitations or setback cannot be applied due to timing constraints, other alternative mitigation measures will be considered and vetted with CPW. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 7 Project impacts to wildlife are expected to be minimal and limited to temporary disturbance from construction activities. The selection of the Preferred Alternative helped to eliminate potential disturbance to sensitive species found around the Chalk Bluffs. Efforts will be made so the contour of the land and natural drainage patterns along the right-of-way are not disturbed. If land contours and drainage patterns are disturbed, efforts will be made to restore any negative effects. Because Weld County has a semi-arid climate, revegetation can be difficult. As a result, disturbances to land surrounding the construction area will be minimized. All practical efforts will be made to re-establish native vegetation in the disturbed area. Tri-State will continue to coordinate with CPAW to develop appropriate mitigation measures that are compatible with Project goals and that will minimize impacts to wildlife along the transmission line and at the substations. To preclude avian electrocutions and minimize collision risk, Tri-State will incorporate Avian Protection Plan (APP) standards developed by the Avian Power Line Interaction Committee (APLIC 2006) and the APP guidelines (APLIC and U.S. Fish and Wildlife Service [USFWS] 2005) to protect birds on power lines, as well as NESC-specified electric conductor clearances. E. Section 21-3-340.A.5 states: "The nature and location or expansion of the facility complies with all applicable provisions of the master plan of this County, and other applicable regional, metropolitan, state and national plans." The transmission line alignment, substation and communication tower location is not within the three-mile referral area for a municipality or County. F. Section 21-3-340.A.6 states: "The nature and location or expansion of the facility does not unduly or unreasonably impact existing community services." The applicant states careful site planning will be developed with only a localized loss of agricultural land quality. Ground disturbance generally will be limited to an area of approximately 625 square feet around each pole (25 feet x 25 feet). The long-term presence of the existing 230-kV and 345-kV transmission lines and continued agricultural uses in the area provide an example of the complementary nature of the two uses. Approximately thirty (30) construction workers will be employed during the course of the approximately eight-month construction period. The maximum number of construction workers at any one time will be approximately thirty (30). 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 8 The Project will generate infrequent trips to the transmission line and substations during operation; the line will be inspected annually and occasionally for maintenance. No adverse effects on county roads are anticipated. Tri-State will work with the Weld County Department of Public Works to determine the appropriate access to the construction area. All mobile construction equipment will be certified to operate on Interstate highways. There may be short periods of time when traffic will be halted on CRs 89 and 118 to allow construction vehicles to enter and exit the construction area. No improvements to Weld County roads will be required. Given the relatively short construction schedule, the site will not generate significant demands on community services such as the school district. G. Section 21-3-340.A.7 states: "The nature and location or expansion of the facility will not create an expansion of the demand for government services beyond the reasonable capacity of the community or region to provide such services, as determined by the Board of County Commissioners." It is anticipated that the Project will have a negligible impact to the community of Grover, as there are no gas stations, restaurants, or hotels. The project may have a small beneficial impact to the local economy of Greeley and other small communities located between the Project area and metropolitan areas such as Cheyenne and Denver. Construction contractors, regardless of origin, will likely spend some money in Cheyenne or Greeley for fuel, food, or other supplies. During the construction period, the local economy may see a small influx of dollars and a small increase in sales tax revenue. The footprints of the proposed structures will be the only land removed from current use. Land between the transmission structures will remain available for farming, grazing, or other operations that do not interfere with safe and reliable operation of the transmission line. The Project area is located within District 1 of the Weld County Sheriffs Office and is within the jurisdiction of the Pawnee Fire Protection District. Public roads are maintained by the Weld County Department of Public Works. The nearest hospital is the North Colorado Medical Center, located in Greeley. None of these services are expected to be affected, unless emergency situations occur. There are no adverse socioeconomic impacts associated with the Project. The Project will not cause any residents or businesses to be displaced. The Project will generate additional tax revenue for Weld County. H. Section 21-3-340.A.8 states: "The facility site or expansion area is not in an area with general meteorological and climatological conditions which would unreasonably interfere with or obstruct normal operations and maintenance." The proposed site was selected because it does not affect the meteorological and climatological conditions. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 9 Section 21-3-340.A.9 states: "The nature and location of the facility or expansion will not adversely affect the water rights of any upstream, downstream or agricultural users, adjacent communities or other water users." The application states that the project will not impact hydrologic flow of either surface water or groundwater, nor will it affect groundwater recharge. Existing drainage patterns will be preserved. Permanent facilities will not be located in stream channels, appropriately sized culverts will be installed to maintain channel flow and morphology. The Project will have no impacts on vested water rights. Construction water and water to suppress dust during construction activities will be trucked into the site. J. Section 21-3-340.A.10 states: "Adequate water supplies are available for facility needs.Bottled water will be used during construction of the transmission line." K. Section 21-3-340.A.11 states: "The nature and location of the facility or expansion will not unduly interfere with existing easements, rights-of-way, other utilities, canals, mineral claims or roads." The applicants have negotiated land lease and easement agreements with property owners within the transmission line corridor. If any remaining agreements are required, these agreements will be obtained once the Weld County permitting processes are complete. L. Section 21-3-340.A.12 states: `Adequate electric, gas, telephone, water, sewage and other utilities exist or shall be developed to service the site." This is an unmanned facility consisting of one double circuit 115kV transmission line, two substations and one communications tower, therefore utility services are not required post construction. M. Section 21-3-340.A.13 states: "The nature and location for expansion of the facility will not unduly interfere with any significant wildlife habitat or adversely affect any endangered wildlife species, unique natural resource or historic landmark within the impact area." The Colorado Division of Parks and Wildlife and the State Historical Society did not return a referral response, and the US Fish and Wildlife Service returned a referral dated January 13, 2014, indicating no concerns with the project. The native grassland and agriculture areas surrounding the transmission line are likely to support a variety of common wildlife such as pronghorn, coyote, fox, skunk, rabbits, and various birds. There is no designated critical wildlife habitat in the vicinity of the project. The area also supports habitat for various state-listed species. Tri-State is conducting an assessment of the area to identify suitable habitat, particularly for special status species. Additional surveys will be conducted in the spring, prior to construction, in areas identified as suitable habitat for state-listed species and for migratory birds. CPW recommended species-specific surveys for Plains Sharp-tailed Grouse 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 10 leks, Mountain Plover, and Western Burrowing Owls (if prairie dog towns are found). If any nests for migratory birds or any state-listed species are found, appropriate construction timing limitations will be enforced, as feasible, according to CPW recommendations. Where timing limitations or setbacks cannot be applied due to timing constraints, other alternative mitigation measures will be considered and vetted with CPW. Project impacts to wildlife are expected to be minimal and limited to temporary disturbance from construction activities. The selection of the Preferred Alternative helped to eliminate potential disturbance to sensitive species found around the Chalk Bluffs. Impacts to wetlands and water resources will not occur from the Project. The Project will not impact hydrologic flow of surface water or groundwater, nor will it affect groundwater recharge. To preclude avian electrocutions and minimize collision risk, Tri-State will incorporate Avian Protection Plan (APP) standards developed by the Avian Power Line Interaction Committee (APLIC 2006) and the APP guidelines (APLIC and U.S. Fish and Wildlife Service [USFWS] 2005) to protect birds on power lines, as well as NESC-specified electric conductor clearances. Tri-State conducted a Class I Archaeological Database Search of the Project area, as well as a Class III Pedestrian Survey. Four prehistoric artifact scatters were located along the proposed transmission line and are eligible for listing on the National Register of Historic Places (NRHP). These sites will be spanned and avoided by the Project. There are no areas of geologic importance in the vicinity of the project. N. Section 21-3-340.A.14 states: "The nature and location or expansion of the facility, including expected growth and development related to the operation and provision of service, will not significantly deteriorate water or air quality in the impact area." Construction will last approximately seven to eight months. Construction activities associated with the proposed transmission line and substations will generate less than significant amounts of particulate matter from soil disturbances and diesel-powered equipment, and less than significant amounts of carbon monoxide and the precursor pollutants to ozone formation from tailpipe emissions. Any air pollutants generated will be widely dispersed across the Project area, short term in duration, and minimized by the small scale of construction operations for the substations, and excavating foundations and placing single pole transmission structures. Air pollutants also will be minimized through implementation of dust suppression and proper vehicle maintenance. Therefore, Project construction is not expected to contribute to the air quality status in the area. There will be no long-term air quality effects associated with routine operation and maintenance of the proposed transmission line and substations. Once construction activities have been completed, but before vegetation has been 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 11 re-established, some minor amount of additional dust could occur. The generation of dust will be monitored by Tri-State, and the appropriate action will be taken to control the dust and ensure that potential wind erosion is minimized. Weld County is an attainment area for all measured pollutants, including particulate matter smaller than 10 micrometers in diameter (PM10). No air emissions will result from operation of the transmission line or substations. There will be no direct impacts to water quality associated with regular operation or maintenance of the transmission line and substations. The Project will not create runoff in excess of historic levels and will not adversely affect drainage. There will be no alteration in the pattern or intensity of surface drainage as a result of construction or operation of the transmission line and substations. O. Section 21-3-340.A.15 states: "The geological and topographic features of the site are adequate for all construction, clearing, grading, drainage, vegetation and other needs of the facility construction or expansion."The vicinity of the Project site is characterized by agricultural uses, primarily farming and ranching. The surrounding vegetation communities can be characterized as disturbed grassland. Most access will be overland in nature or along existing roads, and minimal vegetation will be disturbed from roads. The geological and topographic features will be adequate for the transmission line corridor as the transmission corridor is relatively flat with slopes of 0-9% across the project site. Permanent removal of vegetation and agricultural crops will occur at structure sites. Construction will occur in an area that has been previously disturbed, and impacts to native vegetation communities are expected to be minimal. P. Section 21-3-340.A.16 states: "The existing water quality of affected state waters will not be degraded below state and federal standards or established baseline levels." There will be no direct impacts to water quality associated with the regular operation or maintenance of the transmission line. The existing water quality of affected state waters will not be degraded below state and federal standards or established baseline levels by the project. Q. Section 21-3-340.A.17 states: "The proposed project will not have a significantly adverse net effect on the capacities or functioning of streams, lakes and reservoirs in the impact area, nor on the permeability, volume, recharge capability and depth of aquifers in the impact area."According to the application, construction and maintenance of the transmission line will not measurably impact surface water or groundwater quality. Additionally, there will be no long-term impacts to surface water or 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 12 groundwater hydrology as a result of construction or operation of the transmission line. The Project will not impact hydrologic flow of either surface water or groundwater, nor will it affect groundwater recharge. Further, subsurface drainage will not be impacted by the proposed transmission line. There will be no direct impacts to water quality associated with regular operation or maintenance of the transmission line. Project construction will not create runoff in excess of previous site levels and will not change existing topography or adversely affect drainage. There will be no alteration in the pattern or intensity of surface drainage as a result of construction or operation of the transmission line facility. Therefore, a Drainage Report is not required. A range of measures ensuring the Project does not impact water quality will be implemented prior to construction, including a Storm Water Permit for Construction Activities which will be acquired from the Colorado Department of Public Health and Environment. R. Section 21-3-340.A.18 states: "The benefits of the proposed developments outweigh the losses of any natural resources or reduction of productivity of agricultural lands as a result of the proposed development" The majority of the site consists of agricultural uses, primarily farming and ranching. The facility will have limited impact on agricultural lands within the transmission line corridor project site and minimal impact on future land use. Permanent facilities upon completion will only cover approximately 168 acres. S. Section 21-3-340.A.19 states: "The applicant has obtained or will obtain all property rights, permits and approvals necessary for the proposed project, including surface, mineral and water rights and easements for drainage, disposal, utilities, access, etc." If the applicant has not obtained all necessary property rights, permits and approvals, the Board may, at its discretion, grant the permit conditioned upon completion of the acquisition of such rights prior to issuance of a zoning or building permit by the County. The application indicates that individual land lease agreements have been obtained or will be acquired between Tri-State and the affected property owners. The applicant has obtained or will obtain all property rights, permits and approvals necessary for the proposed project, including surface, mineral and water rights and easements for drainage, disposal, utilities, access, et cetera, with approval by the Board of County Commissioners. T. Section 21-3-340.A.20 states: "The proposed project (nonlinear facilities) will not present an unreasonable risk of exposure to or release of toxic or hazardous substances within the impact area." The determination of effects of the project shall include the following considerations: 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 13 1) The means by which outdoor storage facilities for fuel, raw materials, equipment and related items are adequately enclosed by a fence or wall. 2) The likelihood of hazardous materials or wastes being moved off the site by natural causes or forces. 3) Containment of inflammable or explosive liquids, solids or gases. There will be temporary storage of construction materials at the proposed Project site. Construction, operation, and maintenance activities will comply with all applicable federal, state, and local laws and regulations regarding the use of hazardous substances. The only hazardous chemicals anticipated to be used on site are those found in diesel fuel, gasoline, coolant (ethylene glycol), and lubricants in machinery. Hazardous materials will not be drained onto the ground or into streams or drainage areas. In its contract with the construction contractor, Tri- State will specify that it will hold a required pre-construction meeting with the contractor to ensure that all applicable laws and Tri-State's procedures will be followed. Enclosed containment will be provided for all trash. All construction waste, including trash and litter, garbage, other solid waste, petroleum products, and other potentially hazardous materials will be removed to a disposal facility authorized to accept such materials. The Health Department is requiring that a waste handling plan be submitted as a condition of approval. U. Section 21-3-340.A.21 states: "The scope and nature of the proposed project will not unnecessarily duplicate existing services within the County." The scope and nature of the proposed project will not unnecessarily duplicate existing services within the county. The proposed transmission line will address a specific demand for electricity for Noble Energy's Keota Gas Plant (USR13-0013) and Whiting Petroleum's Redtail Gas Plant (USR13-0016) thereby enabling these two facilities to meet their long term air attainment requirements. Further, there is a vast development potential for oil and gas in this region, and this development is very dynamic and evolving. Several different companies have indicated sizeable potential electrical loads in the area beyond what is currently being considered. The applicant believes this line will serve the additional electrical loads in the area and will provide for future reliability needs and operational flexibility under transmission contingencies, increasing the reliability to the loads in the area. V. Section 21-3-340.A.22 states: "If the purpose and need for the proposed project are to meet the needs of an increasing population within the County, the area and community development plans and population trends demonstrate clearly a need for such development."The purpose of 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 14 the double circuit 115kV transmission line is to provide Noble Energy's Keota Gas Plant (USR13-0013) and Whiting Petroleum's Redtail Gas Plant (USR13-0016) with electric service that is reliable and operates efficiently while helping to ensure an adequate and dependable supply of electrical power to meet the needs of for future development. POSSIBLE ISSUES SUMMARIZED FROM APPLICATION MATERIALS FOR THE 250-FOOT COMMUNICATION TOWER Narrative: The purpose for this communications system build-out is to provide a high speed geographically diverse digital communication link between the Tri-State operations control center computers located at Westminster, Colorado, and Frederick, Colorado, with the proposed Keota 345kV and Redtail 115kV substations. Requirements are to communicate with the Supervisory Control and Data Acquisition (SCADA) equipment, transmission line relay protection equipment, with the substation revenue metering equipment, the FERC mandated security systems for a bulk power substation, and voice communications for the safety of the maintenance personnel working around the energized equipment. The proposed Keota Communications facility will be located approximately 1,070 feet west of CR 89 on the proposed substation property approximately 740 feet northeast of the Laramie River Station 345kV (LRS 345) line structure 203 and near to the proposed Keota 345kV substation also under review here. Tri-State operates a high-speed fiber and microwave communications network across its four-state service territory. The back-bone system consists of several SONET self-healing geographical diverse rings to provide protection against fiber cuts, microwave propagation outages, and equipment failures. Three of those rings currently traverse the southern portion of Weld County using six of the approximately 400 locations that make up the Tri-State network. To meet the protection requirements for a high reliability multi-channel communications system, a new standalone facility complete with a communications tower will be required on the substation property for the expressed purpose of providing multi-channel communications for Keota and the Redtail substations. In order to meet regulatory compliance, system reliability and safety, the existing system will be modified to extend the route diversity communication route to Keota. The installation and commissioning of this communication system is proposed to be completed in the 3rd Quarter of 2014 to allow for the substation to be placed in-service. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 15 To meet Tri-State's long term communication needs, the facility will be developed to handle microwave, fiber, multiple address polling radio (MAS) and mobile radio system needs for this area. Existing Tower Co-Location Analysis: As per FERC / NERC and Weld County requirement, Tri-State considered eleven of the existing Tri-State I partner facilities and found only three locations that meet the path requirements. The Tri-State partner facility, Weldona, owned by Western Area Power Administration (WAPA) and the partner facility, Point of Rocks, operated by Basin Electric (Weld CUP-37) were selected based on Tri-State's path I site selection criteria. To meet the County Code requirement to examine other existing structures in Weld County not associated with Tri-State, another 16 locations were identified and considered for collocation or as intermediate repeater sites to lower the required Keota tower height using the GIS map supplied by Weld County and research done using the FAA and FCC Antenna Registration System databases. Only one site, Noble Energy (Weld USR-13-0013) was found to be possibly close enough to be considered in lieu of a facility build. Three additional sites were identified and evaluated as possible intermediate repeater sites. Eleven additional facilities were looked at for possible collocation as required by Weld County. Noble Energy, USR 13-0013, was contacted about collocation at their site approximately 1,900 feet away on the adjacent property to see if a new site build at the substation could be avoided. It was determined that their tower as designed and permitted will not be able to support Tri-State's antenna requirements. This removed any option of avoiding a communications site build along with a communications tower at the Keota Substation. The three sites, USR-974, USR-1750 and CUP-42 reviewed as intermediate repeater locations for the Point of Rocks path were eliminated based a decrease in system reliability and will not eliminate the site build at the Keota Substation. The use of additional radio paths will require addition FCC transmit frequency pairs to be available in an area that is already very congested. Conclusions: 1) There is not any existing nearby communications facilities that will defer constructing a new communications facility with a tower to serve the proposed Keota Substation. 2) The 250-foot structure at Keota will allow Tri-State to meet Federal requirements for relay protection of a critical substation by providing geographical route diversity paths to Point of Rocks and Weldona. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 16 3) The reduction in system reliability by adding additional collocation sites and equipment does not outweigh the minimal cost savings of reduction in tower height. The criteria for review of this Special Review Permit is listed in Section 23-2-230 of the Weld County Code. 1. The submitted materials are in compliance with the application requirements of Section 23-2-260 of the Weld County Code. 2. It is the opinion of the Board of County Commissioners that the applicant has shown compliance with Section 23-2-230 of the Weld County Code as follows: A. Section 23-2-230.B.1 -- The proposed use is consistent with Chapter 22 and any other applicable code provisions or ordinance in effect. 1) Section 22-2-20.1 (A.Goal 9) states: "Reduce potential conflicts between varying land uses in the conversion of traditional agricultural lands to other land uses." This is a proposed lattice construction 250-foot communication tower with an equipment shelter. No additional structures/improvements are proposed to occur on-site and it is an unmanned facility. This communication tower and the land are owned by Tri-State Generation and Transmission and is located at the proposed Keota 115kV Substation site. Based on the analysis of potential co-location tower sites, the applicant indicates there will be a net increase in towers with the construction of the proposed 250-foot communication tower. The applicant has submitted a Decommissioning plan, and states ". . . there are no plans to decommission the proposed Keota Substation and the associated communication tower. The communications facility would only be dismantled and removed if the substation facility located on the property was removed in the future. Further, Tri-State Generation and Transmission Association is agreeable to making the proposed tower available for co-location with such entities as government agencies, public safety operations, utilities and some non-profit organizations that are judged capable of meeting Tri- State's security requirements. We do not co-locate with "for profit" entities in the majority of cases but will review all applications for co-location on a non-discriminatory basis. Any tower space that is not in use or reserved for future use by Tri-State will be available for co-location. Acceptable co-locators can occupy the unused portion of the tower as long as space is available and the use is within the tower's structural limits. Tri-State currently has sharing agreements with Western Area Power Administration, Basin Electric, Xcel Energy, the State of Colorado, and others to use tower and building space at our sites." 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 17 B. Section 23-2-230.B.2 -- The proposed use is consistent with the intent of the A (Agricultural) Zone District. Section 23-3-40.L allows for Telecommunication Antenna Tower as a Use by Special Review in the A (Agricultural) Zone District. C. Section 23-2-230.8.3 -- The uses which will be permitted will be compatible with the existing surrounding land uses. The proposed tower site is located on an 80-acre parcel zoned Agriculture and utilized for grazing of livestock. Lands to the north, south and west are utilized for dryland agriculture, including livestock grazing. Land to the east is the new Noble Energy Keota Gas Plant, USR13-0013, also located on an 80-acre parcel. There are no residential structures in the immediate area, but one residence is within one (1) mile north of the Keota substation. In general the property is located in an area where the topography consists of wide expanses of relatively flat topography covered in native vegetation. Staff has not received any correspondence in favor or against this request from adjacent property owners. D. Section 23-2-230.B.4 -- The uses which will be permitted will be compatible with future development of the surrounding area, as permitted by the existing zoning, and with the future development, as projected by Chapter 22 of the Weld County Code and any other applicable code provisions or ordinances in effect, or the adopted Master Plans of affected municipalities. The tower site is not located within the three-mile referral area of a municipality or a County. The tower location, as proposed, will meet all setback and offset distances from all property lines equal to the height of the tower or greater. E. Section 23-2-230.6.5 — The application complies with Chapter 23, Article V, of the Weld County Code, if the proposal is located within any Overlay District Area identified by maps officially adopted by the County. The subject property is not located within the Geological Overlay District or the Flood Hazard Overlay District. Building Permits issued on the lot will be required to adhere to the fee structure of the County-Wide Road Impact Fee, County Facility Fee and Drainage Impact Fee Programs. F. Section 23-2-230.B.6 -- The applicant has demonstrated a diligent effort to conserve prime agricultural land in the locational decision for the proposed use. The proposed site is designated as "High Potential Dry Cropland — Prime if they Become Irrigated" and "Other Land" per the 1979 Soil Conservation Service Important Farmlands of Weld County Map. The site will be utilized for dryland agriculture on areas not fenced for the Keota substation and tower location site. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 18 G. Section 23-2-230.B.7 -- The Design Standards (Section 23-2-240, Weld County Code), Operation Standards (Section 23-2-250, Weld County Code), Conditions of Approval and Development Standards ensure that there are adequate provisions for the protection of the health, safety, and welfare of the inhabitants of the neighborhood and County. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the application of Tri-State Generation and Transmission, Inc., for a Site Specific Development Plan and Use by Special Review Permit, USR13-0054, for a Major Facility of a Public Utility (two (2) 115kV Transmission Lines extending approximately 24.7 miles and two (2) substations — Keota at the west terminal and Redtail at the east terminal) and one (1) 250-foot Telecommunication Tower located at the Keota Substation in the A (Agricultural) Zone District, on the parcel of land described above be, and hereby is, granted subject to the following conditions: 1. Prior to recording the plat: A. The applicant shall address the requirements of the Department of Public Works, as stated in the referral dated December 11, 2013. B. A copy of the signed and recorded construction and post-construction lease agreements, or other acceptable authorization from property owners, shall be submitted to the Department of Planning Services. C. The applicant shall provide documentation that Lot A of RECX13-0117 has been vacated out of the USR-1723 associated with the BP Energy North America, LP, Cedar Creek II Wind Farm and that the partial vacation plat has been recorded per Board of County Commissioner Resolution dated January 27, 2014. D. The plat shall be amended to delineate the following: 1) All sheets of the plat shall be labeled USR13-0054. 2) The plat shall be prepared in accordance with Section 23-2-260.D of the Weld County Code. 3) The attached Development Standards. 4) The final location of the permanent 100-foot transmission line easement with dimension of permanent right-of-way, property ownership, parcel number, all easements of record, and all physical encumbrances. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRNASMISSION, INC. PAGE 19 5) The applicant shall delineate all approved access roads will be created off CR 89 and CR 118 for the Keota and Redtail substations respectively. Tri-State has submitted Access Road Permit Applications (AP13-00358 and AP13-00372) and will comply with all County design standards. 6) CRs 89, 97, 103, 107, 119, 110, and 118 are designated on the Weld County Road Classification Plan as local gravel roads, which require 60 feet of right-of-way at full buildout. The applicant shall verify the existing right-of-way and the documents creating the right-of-way and this information shall be noted on the plat. All setbacks shall be measured from the edge of future right-of-way. These roads are maintained by Weld County. 7) CR 390 is designated on the Weld County Road Classification Plan as a collector road, which requires 80 feet of right-of-way at full buildout. There is presently 60 feet of right-of-way. An additional 10 feet shall be delineated on the plat as future CR 390 right-of-way. All setbacks shall be measured from the edge of future right-of-way. The applicant shall verify the existing right-of-way and the documents creating the right-of-way and this information shall be noted on the plat. This road is maintained by Weld County. 8) The "Fall Zone" location for the 250-foot in height Communication Tower. 2. One month prior to construction activities: A. The applicant shall contact the Permitting/Inspection agent for Weld County Department of Public Works, for a Right-of-Way Permit for any work that may be required in the right-of-way. A Special Transport Permit will be required for any oversized or overweight vehicles that may access the site and may also be obtained through the same office. B. A vehicle tracking pad will be required at all crossings to keep from tracking mud or debris onto Weld County roads, and at both substation locations. C. The applicant shall submit evidence of an Air Pollution Emission Notice (APEN) application from the Air Pollution Control Division, Colorado Department of Public Health and Environment. Alternately, the applicant can provide evidence from the APCD that they are not subject to these requirements. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRNASMISSION, INC. PAGE 20 3. Upon completion of Condition of Approval #1 and #2 above, the applicant shall submit an electronic version (.pdf), or three (3) paper copies, of the plat to the Weld County Department of Planning Services for preliminary approval. The plat shall be prepared in accordance with the requirements of Section 23-2-260.D of the Weld County Code. Upon approval of the plat, the applicant shall submit a Mylar plat, along with all other documentation required as Conditions of Approval. The Mylar plat and additional requirements shall be submitted within one hundred twenty (120) days from the date of the Board of County Commissioners Resolution. The Mylar plat shall be recorded in the office of the Weld County Clerk and Recorder by the Department of Planning Services. The applicant shall be responsible for paying the recording fee. 4. In accordance with Weld County Code Ordinance #2012-3, approved April 30, 2012, should the plat not be recorded within the required one hundred twenty (120) days from the date of the Board of County Commissioners Resolution, a $50.00 recording continuance charge shall added for each additional three (3) month period. 5. The Department of Planning Services respectfully requests a digital copy of this Use by Special Review, as appropriate. Acceptable CAD formats are .dwg, .dxf, and .dgn (Microstation); acceptable GIS formats are ArcView shapefiles or ArcGIS Personal GeoDataBase (MDB). The preferred format for Images is .tif (Group 4). (Group 6 is not acceptable). This digital file may be sent to maps@co.weld.co.us. 6. The Use by Special Review activity shall not occur, nor shall any building or electrical permits be issued on the property, until the Use by Special Review plat is ready to be recorded in the office of the Weld County Clerk and Recorder. 2014-0521 PL2257 SPECIAL REVIEW PERMIT (USR13-0054) - TRI-STATE GENERATION AND TRNASMISSION, INC. PAGE 21 The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 26th day of February, A.D., 2014. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: I� � ' �1� Do}�glas ftademac e �1` Fesr, air Weld County Clerk to the Board ♦�'�+� n n ' *y rbara Kirkmeyer, •ro-Tem BY: a�• J '0. -(-j i I .� _ ( — , De Clerk to the Boa � � p an P. Conway A D A M: a .# I) 1 .1L-J Mike Fr n Co n y Attorney i liam F. Garcia Date of signature: 1 L4 2014-0521 PL2257 SITE SPECIFIC DEVELOPMENT PLAN USE BY SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS TRI-STATE GENERATION AND TRANSMISSION, INC. USR13-0054 1. A Site Specific Development Plan and Use by Special Review Permit, USR13-0054, is for a Major Facility of a Public Utility (two (2) 115kV Transmission Lines extending approximately 24.7 miles and two (2) substations — Keota at the west terminal and Redtail at the east terminal) and one (1) 250-foot Telecommunication Tower located at the Keota Substation in the A (Agricultural) Zone District, subject to the Development Standards stated hereon. 2. Approval of this plan may create a vested property right pursuant to Section 23-8-10 of the Weld County Code. 3. A vehicle tracking pad will be required at all crossings to keep from tracking mud or debris on to Weld County roads, and at both substation locations. 4 There shall be no parking or staging on Weld County Roads. The applicant shall utilize the private easements or rights-of-way. 5. The contractor will utilize the Keota/Redtail substation sites for its base of operations with no new proposed staging or lay-down yards. A 100-foot private right-of-way (easement) will be used for the transmission line. 6. A Right-of-Way Permit will be required at each County Road crossing, along with approved signing details. The applicant shall work with the Weld County Public Works Utility Coordinator. 7. Should noxious weeds exist on the property, or become established as a result of the proposed development, the applicant/landowner shall be responsible for controlling the noxious weeds, pursuant to Section 15-1-180 of the Weld County Code. 8. All parking and vehicle storage shall be provided on site; parking shall not be permitted within any public right-of-way. 9. Since more than one (1) acre is to be disturbed (Keota/Redtail), a Weld County Grading Permit will be required prior to the start of construction. 10. Building Permits maybe required, per Section 29-3-10 of the Weld County Code. Currently, the following have been adopted by Weld County: 2012 International Codes, 2006 International Energy Code, and 2011 National Electrical Code. A Building Permit Application must be completed and two (2) complete sets of engineered plans bearing the wet stamp of a Colorado registered architect or engineer must be submitted for review. A Geotechnical Engineering Report performed by a Colorado registered engineer shall be required or an Open Hole Inspection. 2014-0521 PL2257 DEVELOPMENT STANDARDS (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 2 11. At both substation locations, the historical flow patterns and runoff amounts will be maintained on-site. 12. All liquid and solid wastes (as defined in the Solid Wastes Disposal Sites and Facilities Act, Section 30-20-100.5, C.R.S.) shall be stored and removed for final disposal in a manner that protects against surface and groundwater contamination. 13. No permanent disposal of wastes shall be permitted at this site. This is not meant to include those wastes specifically excluded from the definition of a solid waste in the Solid Wastes Disposal Sites and Facilities Act, Section 30-20-100.5, C.R.S. 14. Waste materials shall be handled, stored, and disposed of in a manner that controls fugitive dust, fugitive particulate emissions, blowing debris, and other potential nuisance conditions. The facility shall operate in accordance with the approved Waste Handling Plan, at all times. 15. Fugitive dust and fugitive particulate emissions shall be controlled along the construction route. The facility shall operate in accordance with the approved Dust Abatement Plan, at all times. 16. Adequate toilet facilities (portable toilets) and hand washing units shall be provided during construction of the project. 17. Environmental Protection Measures for Construction Projects, as identified in Appendix B of the application, shall be adhered to by Tri-State Generation and Transmission and successors. 18. This facility shall adhere to the maximum permissible noise levels allowed in the Non-Specified Zone, as delineated in Section 14-9-30 of the Weld County Code. 19. The operation shall comply with all applicable rules and regulations of the state and federal agencies and the Weld County Code. 20. Co-location of another antenna by other service providers shall be allowed for such entities as government agencies, public safety operations, utilities and some non-profit organizations, provided they are judged capable of meeting security requirements, space is available, they do not interfere with public safety communications, and are within the tower's structural limits. 21. Upon termination of the use of the communication antenna tower, the equipment shelter, antenna structure, and associated equipment shall be removed and the premises restored to its original condition according to the approved Decommissioning Plan. 22. Building Permits issued on the proposed lots will be required to adhere to the fee structure of the County-Wide Road Impact Fee Program. 2014-0521 PL2257 DEVELOPMENT STANDARDS (USR13-0054) - TRI-STATE GENERATION AND TRANSMISSION, INC. PAGE 3 23. Building Permits issued on the proposed lots, will be required to adhere to the fee structure of the County Facility Fee and Drainage Impact Fee Programs. 24. The property owner or operator shall be responsible for complying with the Design Standards of Section 23-2-240, Weld County Code. 25. The property owner or operator shall be responsible for complying with the Operation Standards of Section 23-2-250, Weld County Code. 26. Necessary personnel from the Weld County Departments of Planning Services, Public Works, and Public Health and Environment shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Conditions of Approval and Development Standards stated herein and all applicable Weld County regulations. 27. The Use by Special Review area shall be limited to the plans shown hereon and governed by the foregoing standards and all applicable Weld County regulations. Substantial changes from the plans or Development Standards, as shown or stated, shall require the approval of an amendment of the Permit by the Weld County Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. 28. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the Permit by the Board of County Commissioners. 29. The Weld County Right to Farm Statement, as it appears in Section 22-2-20.J.2 of the Weld County Code, shall be placed on the plat and recognized at all times. 2014-0521 PL2257 Hello