HomeMy WebLinkAbout2.0 Staff Report BOCC 10.2.89• •
BOCC 10/2/89
PROJECT INFORMATION AND STAFF COMMENTS
REQUEST:
APPLICANT:
LOCATION:
SITE DATA:
WATER:
SEWER:
ACCESS:
EXISTING ZONING:
ADJACENT ZONING:
Exemption from the Definition of
Subdivision
Charles & Vicki Grumley
A tract of land situated in
Sections 5 & 6, T7S, R87W; located
approximately 10 miles northwest of
Carbondale off County Rd. 121.
The site consists of a 252 acre
tract.
Individual wells
Individual Sewage Disposal Systems
Proposed access drive off County
Rd. 121.
A/R/RD
A/R/RD & P.U.D.
I. RELATIONSHIP 1.rO THE COMPREHENSIVE PLAN
The proposed lot is located in District F,
Environmental Constraints as designated
Management District Map.
II. DESCRIPTION OF THE PROPOSAL
Rural Areas with Severe
on the Comprehensive Plan
A. Site Description: The site is located in a rural portion of the
County with adjacent land uses primarily single family
residential, agricultural, and open space. Slopes on the site
are moderate with the majority used for agricultural/grazing
purposes. Improvements include one single family dwelling and
several barns and accessory buildings.
B. Project Description: The applicant proposes to divide the 252
acre parcel into two tracts of 6 acres and 246 acres in size with
the larger tract containing all existing improvements. (See
attached map I page r ) •
C. History: Deeds submitted by· the applicant establish that the
overall tract has not been subdivided since January 1, 1973.
III.MAJOR ISSUES AND CONCERNS
1. The applicant has represented that an additional well permit for
the 6 acre tract has been applied for with the State Division of
Water Resources. Documentation of their issuance of a well
permit should be required.
2. Soil Conservation Service information on the site indicates that
the soils are poorly suited to homesite development due to
shrink-swell potential, low strength, and slow permeability.
3. Approval by the County Road and Bridge Department is required for
any new access point off C.R. 121 and may require improvements
including culverting.
-/-
• •
4. The applicant is petitioning to include the proposed site in the
Carbondale Rural Fire Protection District. Documentation of
acceptance into the district should be provided or plat notes
included indicating that the location is outside of any fire
protection district.
IV. SUGGESTING FINDINGS
1. That proper posting and public notice was provided as required by
law for the meeting before the Board of County Commissioners.
2. That the meeting before the Board of County Commissioners was
extensive and complete, that all pertinent facts, matters and
issues were submitted, and that all interested parties were heard
at that meeting.
3. That for the above stated and
exemption is in the best interest
convenience, order, prosperity and
Garfield County.
other reasons, the proposed
of the health, safety, morals,
welfare of the citizens of
V. RECOMMENDATION
APPROVAL, with the following conditions:
1. That the following plat notes be included on the Exemption Plat:
A. That engineered foundations and individual sewage disposal
systems may be required.
B. That this 6 acre lot is being subdivided out of the Vicki
Grumley and Charles Grumley property as described in Book
749, Pages 676-678, as recorded in the Garfield County Clerk
and Recorder's office.
2. That the applicant submit evidence of a domestic water source for
the proposed 6 acre tract, consisting of an additional well
permit, or other verification acceptable to the Board of County
Commissioners.
3. That the applicant submit $200 per lot in School Impact Fees for
the creation of one new lot.
4. That the applicant shall submit an approved driveway access
permit from the Garfield County Road and Bridge Department for
the 6 acre lot, or a letter stating that permit would be issued
at a future date.
5. That the applicant submit documentation of acceptance of the site
into the Carbondale Rural Fire Protection District.
6. That all representations of the applicant, either within the
application or stated at the meeting before the Board of County
Commissioners, shall be considered conditions of approval.
r I I )
-,2 -
November 16, 1989
To the Board of County Commissioners,
This is a letter of formal protest against the Subdivision Exemption
requested by Charles and Vicki Grumley.
The Petitioners are asking to be allowed to divide a 252 acre tract
into two tracts of approximately 246 acres and 6 acres.
of adjacent property, adamantly oppose such exemptions.
that only 35 acre or larger tracts be approved.
We, the owners
It is our position
The upper Cattle Creek -Coulter Creek area is inhabited soley by
stockmen operating well established working cattle ranches. Because
these ranches are large, undivided, and adjoining properties are fenced
unobtrusively, the valley view is continuous, unobstructed, and pleasing.
All residences and outbuildings lie on the natural perimeter of this
beautiful valley. Wildlife roam unhampered through the meadows and
surrounding oak brush. Each ranch is able to bear the burden of the large
deer and elk populations equally, because of unrestricted access to and
through all ranches. New dwellings and development will disturb the current
foraging paths. Any disturbance to the movement and grazing patterns of the
large herds will destroy the tenuous balance established among the ranches.
If a ranch, because of new development, is not proportionately sharing
in the pasturage of wildlife, adjacent ranches will be inundated by
displaced herds. Overgrazing of neighboring ranches· will result in spring
and fall. Winter haystacks will be consumed, at great economic loss to the
rancher, and therefore the county.
If land is to be divided in this area, it must be done in tracts of
35 acres or more. Large tracts help preserve the natural openess necessary
to insure free movement of wildlife. This is especially imperative as
wildlife is continually forced into our area due to growth in Spring Valley,
Cattle Creek, and Missouri Heights. Latg~1tr~cts will preserve the
wildlife access and grazing balance between ranches better than small
restrictive parcel:·~
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Water \~V' (
We are concerned .about the severely limited water supply. If an
exemption is made, and a small tract is allowed, how will the water
allotment be determined?
Every rancher in the area will attest to the critical water situation.
Many ranches are operating with under 40% of their alloted water, and are
barely able to harvest a hay crop. Not only is the surface water inadequate,
but our underground wells periodically run dry.
If land is to be subdivided, it must be done with the water interests
of all residences and ranches in mind. Additional strain of use on
underground water will severely affect most local ranches. Three of the
four large ranches in the valley depend on springs for partial water supply
and cattle watering areas. If these springs run dry, because of depletion of
the aquifer by newly drilled wells, cattle will have no watering holes.
Cattlemen will be forced out of business. We feel that the surrounding
ranchers and residents should not be forced into this jeopardous position
by one party wishing subdivision exemption.
Hunters
Ranches provide taxes, but this is not all. Irrigated ranches keep wildlife
herds healthy and large. If the water table lowers because of new development,
ranches will be without springs and watering holes. Wildlife populations
will diminish. Our county will no longer be able to induce hun~ers and their
money. A ranch out of business, because of loss of water, means a lot of
people in town are out of business also.
We feel that this area will not support many more water wells. The
proposed subdivision land has never been irrigated, It has no legitimate ·
water right. A manipulated water right, which would be necessary for the
parcel, should not be allowed to stand.
Traffic
We are distressed about the future traffic increase we foresee. It may
be argued that a 6 acre tract would not create a traffic problem. This is
true. The concern is that if the county exempts one 6 °2or~ 0 tca¢t,1 it ·~ill .~in
the future be more likely to give its permission to subdivide the remaining
246 acres into small parcels. The possible forty-two 6 acre homesights would
JP> add a lot of residential and construction crew traffic. ~
Neither County Road 115 or Cattle Creek Road can handle continuous,
high speed traffic. County Road 115 is winding, du$ty, and covered with
loose gravel. Traffic churns up dust and generates washboard conditions.
Additional county maintenance would be costly.
Winter traffic here is slow and dangerous. Residents are cautious and
thankful for the sparse traffic on icy, hazardous roads. Winter is a
favorite time of year because few cars ven t ure by. This means fewer
trespassers intruding on private land.
Trespassers
Ranches with wildlife and scenic beau t y will always draw those who wish
to trespass. This is a major problem to our ranch which has outstanding
views and animal life~ Great energy and time is spent in locating and
informing these people that they need to leave the private land. We
believe that more residents in the area me an more of a trespassing problem
for us and our neighbors. Liability is a major concern. What if they fall
off our cliff, or a bull runs them down? Trespassers and cattle ranches
do not mix!
One Other Concern
If this land is being exempted from the regular 35 acre requirement because
the proposed buyers can't afford a bigger plot, what kind of building can
they afford to put on the land? We don't want shabby houses or outbuildings,
trailer homes, or businesses up here. We believe all land in the area should
be subject to the same requirements, that of 35 acre minimum divisions.
In the past, the Planning Office and County Commissioners have shortsightedly
approved overgrowth of the Cattle Creek. The damage there is irreversible.
People have been allowed to build in flood and slide areas of the creek.
Landcuts for roads and residences have significantly filled the stream channel
with erosional debri s . After each rainstorm, publicly financed County Roadcrews
are required to spend a day cleaning rock and mudslide material off the
Cattle Creek Road. This is a waste of limited County resources.
At the mouth of that scenic creek, and automotive junk yard was approved.
Who gets to pay for the cleanup of oil an d antifreeze leaks making way to the
creek and County water supply? We know these atrocities were approved in past
terms, and it is there that we place the blame. The present commissioners,
we believe, are wiser and won't fall into the short sighted economic blinders
their predecessors fell victim to.
Summary of Reasons for Objection
1. The beauty and continuity of the valley could be adversely affected.
2. Wildlife grazing patterns could be al t ered, forcing the surrounding
ranches to bear the economic brunt of displaced herds.
3. Small parcels are more likely to disrupt wildlife grazing patterns than
the larger 35 acre tracts.
4. The water supply is already severely s trained. The proposed parcel has
no legitimate right to water. If well water is granted, it would impact
the water table and economy of neighboring ranches.
5. Ranches out of business translate into fewer hunters and less money to
the county.
6. Water pollution is possible, depending upon the care of the new
residents, and their construction crews.
7. Traffic load and accidents will increase on what we believe should remain
a remote gravel road.
B. Increased residents and traffic mean more of a trespassing and liability
problem for local ranchers.
9. Does the small size of the parcel imp l y financial inability to construct
a nice building?
10. All land should be subject to the same requirement of 35 acre parcels.
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POST OFFICE BOX 1714• ASPF.N,CT>l.OR@(HO: ·5·7SG5
• • JAMES D. PETERSON
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POST OFFICE BOX 1714 •ASPEN, COLO
NOV 2 0 1989
GAK fltLl)
COUNTY COMMISSIONERS
To the Board of County Commissioners,
•
November 16, 1989
This is a letter of formal protest against the Subdivision Exemption
requested by Charles and Vicki Grumley.
The Petitioners are asking to be allowed to divide a 252 acre tract
into two tracts of approximately 246 acres and 6 acres. We, the owners
of adjacent property, adamantly oppose such exemptions. It is our position
that only 35 acre or larger tracts be app r oved.
The upper Cattle Creek -Coulter Creek area is inhabited soley by
stockmen operating well established working cattle ranches. Because
these ranches are large, undivided, and ad j oining properties are fenced
unobtrusively, the valley view is continuous, unobstructed, and pleasing.
All residences and outbuildings lie on the natural perimeter of this
beautiful valley. Wildlife roam unhampered through the meadows and
surrounding oak brush. Each ranch is able to bear the burden of the large
deer and elk populations equally, because of unrestricted access to and
through all ranches. New dwellings and development wi ll disturb the current
foraging paths. Any disturbance to the movement and grazing patterns of the
large herds will destroy the tenuous balance established among the ranches.
If a ranch, because of new development, is not proportionately sharing
in the pasturage of wildlife, adjacent ranches will be inundated by
displaced herds. Overgrazing of neighbor i ng ranches will result in spring
and fall. Winter haystacks will be consumed, at great economic loss to the
rancher, and therefore the county.
If land is to be divided in this area, it must be done in tracts of
35 acres or more. Large tracts help preserve the natural openess necessary
to insure free movement of wildlife. This is especial ly imperative as
wildlife is continually forced into our area due to growth in Spring Valley,
Cattle Creek, and Missouri Heights. Large \tracts wi l l preserve the
wildlife access and grazing balance between ranches better than small
restrictive parcels.
• •
Water
We are concerned about the severely limited water supply. If an
exemp~ion is made, and a small tract is allowed, how will the water
allotment be determined?
Every rancher in the area will attest to the critical water situation.
Many ranches are operating with under 40% of their alloted water, and are
barely able to harvest a hay crop. Not on l y is the surface water inadequate,
but our underground wells periodically run dry.
If land is to be subdivided, it must be done with the water interests
of all residences and ranches in mind. Additional strain of use on
underground water will severely affect most local ranches. Three of the
four large ranches in the valley depend on springs for partial water supply
and cattle watering areas. If these springs run dry, because of depletion of
the aquifer by newly drilled wells, cattle will have no watering holes.
Cattlemen will be forced out of business. We feel that the surrounding
ranchers and residents should not be forced into this jeopardous position
by one party wishing subdivision exemption.
Hunters
Ranches provide taxes, but this is not all. Irrigated ranches keep wildlife
herds healthy and large. If the water table lowers because of new development,
ranches will be without springs and watering holes. Wildlife populations
will diminish. Our county will no longer be able to induce hun~ers and their
money. A ranch out of business, because of loss of water, means a lot of
people in town are out of business also.
We feel that this area will not support many more water wells. The
proposed subdivision land has never been irrigated, It has no legitimate
water right. A manipulated water right, which would be necessary for the
parcel, should not be allowed to stand.
Traffic
We are distressed about the future traffic increase we foresee. It may
be argued that a 6 acre tract would not create a traffic problem. This is
true. The concern is that if the county exempts on~ 6 ·sorp .t~a¢t,i it ·~ill .~in
the future be more likely to give its permission to subdivide the remaining
246 acres into small parcels. The possible forty-two 6 acre homesights would
add a lot of residential and construction crew traffic.
•• •
Neither County Road 115 or Cattle Creek Road can handle continuous,
high speed traffic. County Road 115 is winding, dusty, and covered with
loose gravel. ;Traffic churns up dust and generates washboard conditions.
Additional county maintenance would be costly.
Winter traffic here is slow and dangerous. Residents are cautious and
thankful for the sparse traffic on icy, hazardous roads. Winter is a
favorite time of year because few cars venture by. This means fewer
trespassers intruding on private land.
Trespassers
Ranches with wildlife and scenic beau t y will always draw those who wish
to trespass. This is a major problem to our ranch which has outstanding
views and animal life. Great energy and time is spent in locating and
informing these people that they need to leave the private land. We
believe that more residents in the area mean more of a trespassing problem
for us and our neighbors. Liability is a major concern. What if they fall
off our cliff, or a bull runs them down? Trespassers and cattle ranches
do not mix!
One Other Concern
If this land is being exempted from the regular 35 acre requirement because
the proposed buyers can't afford a bigger plot, what kind of building can
they afford to put on the land? We don't want shabby houses or outbuildings,
trailer homes, or businesses up here. We believe all land in the area should
be subject to the same requirements, that of 35 acre minimum divisions.
In the past, the Planning Office and County Commissioners have shortsightedly
approved overgrowth of the Cattle Creek. The damage there is irreversible.
People have been allowed to build in flood and slide areas of the creek.
Landcuts for roads and residences have significantly filled the stream channel
with erosional debris. After each rainstorm, publicly financed County Roadcrews
are required to spend a day cleaning rock and mudslide material off the
Cattle Creek Road. This is a waste of limited County resources.
At the mouth of that scenic creek, and automotive junk yard was approved.
Who gets to pay for the cleanup of oil and antifreeze leaks making way to the
creek and County water supply? We know these atrocities were approved in past
• • terms, and it is there that we place the blame. The present commissioners,
we believe, are wiser and won't fall into the short sighted economic blinders
their predecessors fell victim to.
Summary of Reason s for Objection
1. The beauty and continuity of the valley could be adversely affected.
2. Wildlife grazing patterns could be altered, forcing the surrounding
ranches to bear the economic brunt of displaced herds.
3. Small parcels are more likely to disrupt wildlife grazing patterns than
the larger 35 acre tracts.
4. The water supply is already severely s t rained. The proposed parcel has
no legitimate right to water. If well water is granted, it would impact
the water table and economy of neighbo r ing ranches.
5. Ranches out of business translate into fewer hunters and less money to
the county.
6. Water pollution is possible, depending upon the care of the new
residents, and their construction crews.
7. Traffic load and accidents will increase on what we believe should remain
a remote gravel road.
B. Increased residents and traffic mean more of a trespassing and liability
problem fer local ranchers.
9. Does the small size of the parcel imply financial inability to construct
a nice building?
10. All land should be subject to the same requirement of 35 acre parcels.
• •
EXHIBIT A
Lots 3 (22 acres), 5 (32.10), 6 (13.20), 9 (37.0), 10 (Net 10.84)
(Less schoolhouse parcel), ll (25.lG), SEl/4 NWl/4, Section 51
Lot '1. (Net 60.42 Ac.) lying South of a line drawn trom the SW
corner of Lot 12 to the SE corner of Lot 2, Lot 9
(ll.86 Ac.) S1ction 61
252.58 Acres more or less.
All in Township 7 South, Range 87 West o! the Sixth Principal
Meridian in Gar!ield County, Colorado, tog1th1r with all wattr
and ditch rights.
Also described in the tax records or Garfield County as tollowai
5-7-87
Section 5, Lots 3 (22 acres), 5 (32.10 acres), 6 (13.20 acres), 9
(J7acres),
Lot 10 (10.84 acres), Lot 11 (25.16 acres), SE NW.
6-7-87
Section 6, Lot 9 (ll.86 acr••), Section 6, Lot l (Net 60.42
acres) lying
South of a line drawn from th• SW corner or Lot 12 to SE corner
of Lot 2.
Book 0192, Page 0212:
Book 0655, Page 0987:
Book 0659, Page 0601;
Book 0668, Page 0264.
consisting or 252.58 acre• more or leas a/k/a The Home Place,
together with any and all ditch and water rights,
County of Garfield, State ot Colorado.
ROY ROMER
Governor • •
OFFICE OF THE STATE ENGINEER
DIVISION OF WATER RESOURCES
Mr. Glenn Hartmann
1313 Sherman Street-Room 818
Denver, Colorado 80203
(303) 866-3581
January 11, 1990
Garfield County Planning Department
109 8th Street, Suite 303
Glenwood Springs , CO 81601
Dear Mr. Hartmann:
Re: Grumley Exemption
Sec. 5, T7S, R87W
JERIS A. DANIELSON
State Enginee r
We have reviewed the above referenced proposal to separate 6 acres from a
252 acre tract. The proposed 6 acres would be used as a residential tract and
the applicant is seeking a well .
We could make a household-use-only well available for the 6-acre tract.
Use of this well for lawn and garden would be prohibited. If these
limitations are acceptable to the applicant, we can recommend approval. We
ask for a plat note or covenant to reflect the limitation on the use of the
we 11.
We consider this to be a one-time exemption and thus would be opposed to
any future separations of the 246-acre tract of less than 35 acres.
JRH/JCM/clf:7473I
cc: Orlyn Bell, Division Engineer
Bruce DeBrine
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Sincerely,
~1r1izdl
James R. Hall, P.E.
Supervising Water Resources Engineer
• GARFIELD COUNTY
DEPARTMENT OF BUILDING SANITATION AND PLANNING
December 13, 1989
Colorado Division of Water Resources
1313 Sherman St., Room 818
Denver, CO 80203
Attn: Jim McDanold
Dear Jim:
Enclosed for your review and comment are three applications for exemption
from the definition of subdivision that are pending with Garfield County.
conditionally
approval. The
the Board of
The Grumley request has been
Division of Water Resources
scheduled for meetings before
December, 1989 and January, 1990.
approved subject to the
other two requests are
County Commissioners in
Your cooperation in reviewing these applications is appreciated. Please
contact our office if you require additional information or if we can be
of assistance in your review process.
Sincerely,
~~~~~
Glenn Hartmann { .,b'J•~.t)
Planner
GH/emh
encl.
109 8TH STREET, SUITE 303 945-8212 I 625-5571 GLENWOOD SPRINGS, COLORADO 81601
RECO~OED AT g 3 E-
~EC. '4 4<w>15
0 1 CLOCK /i .M. /-3o -<lo
~ILDRED ALSDCRF, CO.llilTY CLE~X
GARFI=LD COUNTY, C~ADO BOOK •771_ P!GE921
DISTRICT COURT, COUNTY OF GARF IE LD, STATE OF COLORADO
Civil Action No. 4582
ORDER POR INCLUSION
IN RE THE ORGANIZATION OF THE CARBONDALE AND RURAL FIRE
PROTECTION DISTRICT
This matter having come before the Court pursuant to the
provisions of Colorado Revised Statutes 32-l-402(l)(e), as
amended, and the Court being fully advised of the premises
enters the following findings of fact:
1. The Carbondale and Rural Fire Pro tee ti on District
adopted a Resolution approving inclusion of real property on
December 13, 1989.
2. One hundred percent (100%) of the fee owners of the
real property to be included petitioned the District for
inclusion.
3. The provisions of the statutes of the State of
Colorado, more particularly the requirements of Article 1 of
Title 32, have been complied with.
NOW, THEREFORE, it ls ordered by the Court that the
real property situate in the County of Garfield, State of
Colorado, described on Exhibit "A" attached hereto and
incorporated herein, be hereby included in the Carbondale and
Rural Fire Protection District, whose address is 300
Meadowood, Carbondale, Colorado 81623.
IT IS FURTHER ORDERED by the Court that after the date
of its inclusion in the Carbondale and Rural ~ire Protection
District, the above-described real property shall be subject
to a 11 the taxes and charges imposed by the Carbondale and
Rural Fire Protect i on District and shall be liable for its
proportionate share of existing bonded indebtedness of the
Carbondale and Rural Fire Protection District, but it shall
not be liable for any taxes or charges levied or assessed
prior to its inclusion in the Carbondale and Rural Fire
Protection District.
IT IS FURTHER ORDERED by the Court that the real prop-
erty described above shall be liable for-its propor-tionate
share of annual operation and maintenance charges and the
cost of facilities of the Carbondale and Rural Fire
Protection District and taxes, rates, fees, tolls, or charges
shall be certified and levied or assessed therefor.
-1-
• • BOOK 771. P!.Gf. 922
IT IS FURTHER ORDERED by the Court that the change or
boundaries or the Carbondale and Rural Fire Protection
District shall not impair nor affect its organization, nor
shall it affect, impair, or discharge any contract,
obligation, lien, or change of boundaries not having been
made.
IT IS FURTHER ORDERED by the Court that this Order shall
be filed in accordance with the provisions of Colorado
Revised Statutes 32-1-105, as amended.
c;/k ~
Dated this ....r:::_ day of 04Muol , 19.'Jn_.
BY THE OURT
File No. CAR-1-62
SD7/86
CERTIFICATE OF MAILING
I Certify that a copy of
Foregoing was mailed to all
Counse~-~t CJ. This 9J6 /. 69Err 190
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BOO~ '771 P!GE923
A Tract of land situate in Section 5, being a part of Lots 9
and 10, Township 7 South, Range 87 West of the 6th Pr-incipal., Meridia~. being more particularly descr-ibed as follows:
Beginning at a point from which the S.W. corner of Section s.
Township 7 South. Range 07 West of the 6th Principal Meridian b~ars s. 38°17'04" W. 1,808.99 feet;
thence N. 89°44'49" E .• along the Northerly line of Cattle
Creek Ranch P.U.D., Filing One, also being the Southerly line
of Lots 9 and 10, 680.00 feet;
thence N. 00°15'11" W. 420.00 feet;
thence s. 89°44'49" H. 605.36 feet to a point on the Easterly
right of way l ~ne of County Road 121 (Coulter Creek Road)
thence Southerily along the Easterly right of way line of said
road the following courses and distances:
S.· 00°00'08". E.
S. 02°05'30" E.
s. 19°46'40" w.
containing 6.00 acres
State of Colorado
.. .
43.50 feet;
158.36 feet and
232.19 feet to the Point of Beginning,
more or less, all in the County of Garfield.
....
E X H I B I T "A"
Crumley Property
• •
ROY ROMER
Governor
Mr. Glenn Hartmann
• •
OFFICE OF THE STATE ENGINEER
DIVIS I ON OF WATER RESOURCES
1313 Sherman Street-Room 818
Denver, Colorado 80203
(303) 866-3581
January 11, 1990
Garfield County Planning Department
109 8th Street, Suite 303
Glenwood Springs, CO 81601
Dear Mr. Hartmann:
Re: Grumley Exemption
Sec. 5, T7S, R87W
JERIS A. DANIELSON
State Engineer
We have reviewed the above referenced proposal to separate 6 acres from a
252 acre tract. The propose d 6 acres would be used as a res i dential tract and
the applicant is seeking a well.
We could make a household-use-only well available for the 6-acre tract.
Use of this well for lawn and garden would be prohibited. If these
limitations are acceptable to the applicant, we can recommend approval. We
ask for a plat note or covenant to reflect the limitation on the use of the
well.
We consider this to be a one-time exemption and thus would be opposed to
any future separations of the 246-acre tract of less than 35 acres.
JRH/JCM/clf:7473I
cc: Orlyn Bell, Division Engineer
Bruce DeBrine
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Sincerely,
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James R. Hall, P.E.
Supervising Water Resources Engineer