APPLICATION FOR THE ESTABLISHMENT OF A FOREIGN-TRADE ZONE FOR TOWN OF LIMON, COLORADO Submitted By: Board of Trustees Town of Limon, Colorado July 23, 2014
APPLICATION
FOR THE ESTABLISHMENT OF A
FOREIGN-TRADE ZONE
FOR
TOWN OF LIMON, COLORADO
Submitted By:
Board of Trustees
Town of Limon, Colorado
July 23, 2014
Grantee Structure and Legal Authority
2. Legal Authority for Application
Please see Collective Attachment I, which is comprised of
A--copy of the State’s enabling legislation;
B—charter or organization papers showing the powers granted to Boards of
Trustees and sections that are pertinent to FTZs; and
C—certified copy of the Board of Trustees Resolution
3. Discuss the nature of the grantee organization (public or private; non-profit or
for-profit).
The proposed Grantee is a municipal corporation that has the legal status of a “town”
under the laws of Title 31 of the Revised Statutes of the State of Colorado. This
governmental entity is a body politic. The Grantee is governed by a mayor and a six
member Board of Trustees (the mayor and each Trustee are elected for four year terms)
with elections being held every two years by the qualified voters of the Town of Limon.
4. Summarize what you foresee as the operating structure of the zone and discuss
the financing plan (as applicable).
A summary of the operating structure of the zone and financing plan is: Zone status is
being sought under an Alternative Site Framework (ASF) format for some 2,000 acres to
be activated in the aggregate. As indicated above, this initial application has identified
two sites totaling approximately +- 421.46 acres. The proposed Grantee believes that the
flexibility offered by ASF is consistent with the flexibility which it intends to pursue in
its development efforts. The first two sites have been identified.
The proposed Grantee intends to offer FTZ status to qualified companies interested in
benefiting from the program. Each prospective user that meets the qualifications of the
zone schedule, upon the establishment of the zone and the development and promulgation
of the schedule, will operate independently. The proposed Grantee is committed to this
zone project on the basis of each individually activated site being operated by its
owner/operator. Each individual user will bear its own financial obligations required to
effectively operate its FTZ project.
Economic Justification
5. State the community’s1 overall economic and trade-related goals and strategies
in relation to those of the region and state, including a reference to the plan or
plans on which the goals are based and how they relate to the proposed zone. If
you have letters of support from local organizations, please include those letters
as an attachment (Attachment II).
Limon is known as the “Hub City.”
Limon, Colorado is located in the eastern section of Colorado, approximately 70
miles due east of Denver. Limon is located in Lincoln County which, along with the
Counties of Cheyenne, Elbert and Kit Carson, is included within the four-county area
referred to as the East Central Colorado Region (the Region). For many decades,
agriculture has been the main economic activity in Limon, the surrounding East Central
Colorado region and eastern Colorado in general. While agriculture continues to be a
major economic driver in Limon and Lincoln County, the transportation network is once
again a growing economic force in the community.
The Town of Limon is currently highly reliant upon the transportation system for its
primary source of revenue and jobs. The Town of Limon is home to two (2) major truck
stops and twenty (20) hotels and restaurants. Over 1.2 million trucks pass through Limon
annually. This translates to average per capita retail sales of $70,000.
1 Note that the economic data that are presented in this and other sections are derived from varying levels—the Town of Limon, Lincoln County, the East Central Region or other designations of the eastern half of Colorado (Eastern High Plains), and the state as a whole. Also note that no data is compiled or available for the geographic area that corresponds exactly to the proposed Service Area.
Location Quotients associated with this transportation system include
Accommodations and Food Services (2.5), Gas Stations (24.3) and Retail Trade (2.0) also
show the economic draw created by the transportation system.
Recently the Limon Retail Leakage Study, completed in January 2013 by Colorado
State University, Regional Economics Institute made this statement regarding the
implications of the current economy:
Clearly, Limon’s tax base is largely based on gas station related sales, with the
community able to fund much of their government activities through taxes
imposed on non-residents. Although this is a popular and effective strategy, it is
important to recognize that this ability may be influenced by recent national
policy developments. In particular, increased vehicle fuel efficiency standards
will likely eventually significantly reduce the overall demand for gasoline. This is
especially true if people do not respond to better fuel efficiency by driving more.
Thus, Limon’s gas stations may very well see fewer motorists stopping, meaning
not only lower fuel sales, but also reduced taxable sales of food, drink and
convenience goods.
This statement played into the decision of the Town and Lincoln County to work
together to diversify the economy by attracting other industry including manufacturing
and distribution which will be discussed in Section 5 of this application.
During the period 1970-2011, the Region has experienced a population growth of
78.8%. The region is projected to continue moderate growth through 2040 by the
Colorado State Demographer, as shown below.
Area resources including port facilities and transportation networks
The designation of “Hub City” describes the Town of Limon well. Throughout its
history, the economy of Lincoln County has relied upon its transportation system to
create and move its economy.
Colorado’s Front Range lies along the east slope of the Rocky Mountains and
includes the communities from Fort Collins on the north to Pueblo on the south.
Colorado’s major population centers are located along the Front Range. Front Range
cities such as Denver, Colorado Springs, Aurora, Lakewood, Thornton and Arvada are all
within an hour and twenty minute drive from Limon and Lincoln County.
The Town of Limon is approximately 60 minutes east of Denver on Interstate 70.
Highways traversing Limon are Interstate 70 and U.S. Highways 40/287 and 24.
Colorado State Highway 71 bisects Limon north to south connecting to Nebraska and
New Mexico. Colorado Highway 86, seven minutes west of Limon connects Interstate
70 to Elizabeth, Franktown, Castle Rock and Interstate 25. Twenty minutes to the south
of Limon on Highway 71 is the junction with Colorado State Highway 94, a route into
Colorado Springs. U.S. Highway 24 is the major route to Colorado Springs and
ultimately connects with the north and south Interstate 25. There are two railroads
servicing Limon: Union Pacific and the KYLE Railroad which is part of the Genesee &
Wyoming Railroad System.
Limon is positioned in the center of the Ports-to-Plains Corridor. This is a federally
designated High Priority Corridor on the National Highway System and the State of
Colorado’s primary freight corridor. See the map which shows the Ports-to-Plains
connections among the seaports and international border crossings served by the
Corridor, as well as the locations of FTZs including the proposed site at Limon,
Attachment VI. The corridor runs from the Port of Mazatlan in Mexico through Laredo,
Eagle Pass or Del Rio, Texas to Canada through Alberta and Saskatchewan. The
Colorado highways in the corridor, U.S. Highways 40/287 and I-70, and Colorado State
Highway 71, are a direct route from Mexico to Canada creating an international trade
corridor through North America’s Energy and Agricultural Heartland.
The Limon Municipal Airport is rated a B-1 airport. The runway is 4,700 feet with
24 hour lighting and part-time FBO availability. Denver International Airport is 77
minutes west of Limon and Colorado Springs Airport is 80 minutes to the southwest.
Strengths and weaknesses of the local economy as well as economic
imbalances and unemployment rates
As indicated above, the Town of Limon is heavily economically dependent upon gas
station retail sales. Lincoln County, as a whole, is seeing new economic growth in the
area of natural resources. In the past five (5) years, new development of both wind
resources and oil and gas development is bringing a new sector to the community.
Currently ranking second in the state with installed production capacity of 652 mw,
the wind capacity in Lincoln County is second to none. Three projects have been
developed, permitted, constructed and producing in the past three years.
Renewable Energy Systems developed the Cedar Point Wind Farm with 139 - 1.8 mw
Vestas turbines, two onsite project substations, one operations and maintenance building
and more than 40 miles of overhead transmission line. The Cedar Point Project is owned
by the Canadian company Enbridge under a power agreement with Xcel Energy. The
Cedar Point Wind Farm generates 252 megawatts of electricity.
NextEra Energy Resources developed the Limon I and Limon II Wind Energy Center
which came on line in late 2012. The 400 mw facility is comprised of twin 200-MW
projects and 125 GE 1.6 MW wind turbines. Located on more than 55,000 acres, a 45-
mile long, 345 kV transmission line connects the wind farms to the substation. Both these
projects also operate under a power agreement with Xcel Energy.
Limon III Wind Energy Center is currently being constructed with production
scheduled to begin in 2014. This will add an additional 200 MW bringing Lincoln
County to 852 MW of installed capacity.
Since 2008, there has been more oil development than at anytime in Lincoln County’s
history. Oil and gas property tax revenues have grown in the past 5 years from minimal
revenue to 35% of all county property tax revenue. That development is continuing to
grow. Through mid-October 2013, Lincoln County has 71 new permits approved this
year through the Colorado Oil and Gas Conservation Commission. Only three counties
in Colorado had more oil and gas permits granted. These permits are primarily
conventional, vertical wells.
The Colorado State Demography Office prepares an Economic Base Analysis for
each county in Colorado which evaluates the economy for a.) "direct basic" (DB), i.e.,
produce exports or derive their sales or income from other outside sources including
tourists or the Federal government, b.) "indirect basic" (IB), i.e., provide supplies or
business services to basic industries, and c.) non-basic, i.e,, worker-related local resident
services. Lincoln County shows total employment of all industries at 3,013, with direct
basic accounting for 2,020 of that employment. Employment of 994 is identified as
indirect basic and 201 non-basic. This results in a ratio of Total/Direct Basic of 1.49.
A significant concern about these results is that 19.22% of the direct employment is
based on Agriculture which, in terms of employment, is very flat in growth and is
affected by weather trends. Four of the past four years the county has been significantly
impacted by drought.
While it is encouraging to see the new sectors of wind, oil and gas, overall the
economy remains heavily dependent upon agriculture and the transportation service
sectors. Both of these latter sectors are heavily affected by weather and the overall
economy, respectively.
The local economy, as described above was summarized in Opportunities
Assessment, East Central Colorado Region, RUPRI Center for Rural Entrepreneurship in
the Comprehensive Economic Development Strategy of East Central Colorado
(Economic Development Administration). In that assessment two primary concerns are
being addressed by the establishment of a Foreign Trade Zone:
Personal income growth is weak and a primary area of concern. Real earnings are
flat. The share of income related to non-labor sources (such as Social Security) is
42% of total income. This suggests an aging population with relatively weak new
wealth creation.
The economy is relatively specialized and dependent upon production agriculture,
the I-70 transportation corridor and government (both local and prison). There is
moderate economic instability due to net income swings in production agriculture.
Key recommendations made in the assessment include:
Making income improvements a primary focus for the County’s development
Increasing core or basic economic activity
Increasing value from existing production agriculture and the I-70 transportation
corridor offer some opportunities for both increasing incomes and economic
activity.
Opportunity for warehousing and wholesale development due to the County’s
location on I-70 and the proximity to Denver Metro region and Colorado Springs
region.
Lincoln County’s current unemployment rate is 4.9%. Historical unemployment
since 1990 is shown below.
This rate and the chart do not, however, provide a complete picture of the
unemployment situation in Lincoln County. Within Lincoln County, 5.7% of the labor
force has “multiple job holding,” i.e., people are working at two or more jobs. The
multiple job holding rate is projected to grow to 6.0% by 2015. Looking at the larger
East Central Region, the 2013 unemployment rate is 6.1% with a multiple job holding
rate of 6.5%.
Combined with the multiple job holding rate is educational attainment. The
American Community Survey, U.S. Census indicates that for the population over age 25
in Lincoln County that over 82% are high school graduates and 15.6% have a bachelor’s
degree or better. The educational attainment in the overall region is similar.
Lincoln County, the East Central Region and eastern Colorado experience a
significant underemployment on an individual and a collective basis.
Current and projected levels of foreign trade
Freight Analysis Framework (FAF) from the U.S. DOT, Federal Highway
Administration, Office of Freight Management and Operations, indicates foreign trade
exports from Colorado will grow 327% in value and 335% by weight by 2040. Import
values are projected to grow 199% in value and 111% in weight in the same period.
Foreign DestinationTotal M$ in
2002Total M$ in
2011% Change2002 2011
Total M$ in2040
% Change2011 2040
Canada $1,546 $2,258 46% $9,386 316%Mexico $447 $1,230 175% $4,974 304%Rest of Americas $75 $118 56% $528 348%Europe $510 $4,686 819% $21,325 355%Africa $22 $22 1% $150 576%SW & Central Asia $51 $110 117% $507 362%Eastern Asia $410 $1,434 249% $5,271 267%SE Asia & Oceania $99 $214 116% $906 323%Total $3,161 $10,072 219% $43,046 327%
Foreign DestinationTotal KTons
in 2002Total KTons
in 2011% Change2002 2011
Total KTonsin 2040
% Change2011 2040
Canada 351 1,032 194% 4,674 353%Mexico 244 331 36% 1,346 307%Rest of Americas 28 27 1% 191 599%Europe 73 249 243% 2,008 707%Africa 11 75 576% 797 958%SW & Central Asia 23 52 125% 324 528%Eastern Asia 466 1,227 163% 3,872 216%SE Asia & Oceania 73 136 87% 396 191%Total 1,267 3,129 147% 13,609 335%
Export Flows Value All Commodities
Export Flows Weight All Commodities
Exports to Europe are projected to grow by 355% to over $21 billion by 2040.
Eastern Asia will also remain a significant market of over $5.2 billion by 2040. Canada
and Mexico will continue to be important markets. Colorado’s exports are projected to
reach over $43 billion with every region experiencing gains for 267-567 percent by 2040.
ForeignDestination
Total M$ in2002
Total M$ in2011
% Change2002 2011
Total M$ in2040
% Change2011 2040
Canada $1,552 $6,572 323% $16,249 147%Mexico $436 $1,086 149% $4,096 277%Rest of Americas $128 $197 54% $577 192%Europe $1,004 $1,691 68% $6,169 265%Africa $14 $56 301% $164 195%SW & Central Asia $84 $277 228% $903 226%Eastern Asia $1,649 $2,404 46% $8,593 257%SE Asia & Oceania $442 $941 113% $2,801 198%Total $5,309 $13,223 149% $39,552 199%
ForeignDestination
Total KTonsin 2002
Total KTonsin 2011
% Change2002 2011
Total KTonsin 2040
% Change2011 2040
Canada 2,407 6,471 169% 11,858 83%Mexico 100 158 57% 587 271%Rest of Americas 166 321 93% 815 154%Europe 386 293 24% 869 196%Africa 25 200 704% 441 121%SW & Central Asia 75 326 337% 826 153%Eastern Asia 457 643 41% 2,211 244%SE Asia & Oceania 163 289 77% 770 167%Total 3,778 8,702 130% 18,377 111%
Import Flows Value All Commodities
Import Flows Weight All Commodities
Outside of Canada and Mexico, leading importers to Colorado are Eastern Asia,
Europe and SW and Central Asia. On a weight basis, imports from Europe (at 196
percent (196%) and Eastern Asia (at 244 percent (244%) are projected to grow the
greatest.
Colorado is a destination state. With over $13 billion of current total imports
projected to grow to over $39 billion by 2040, imports are an important part of
Colorado’s economy. This leads to the question of how these imports contribute to the
jobs and employment in the state and locally in the community and service area. The
development of additional manufacturing, assembly and distribution with a Foreign
Trade Zone should stimulate more opportunities as well as benefit the export market in
Colorado.
Transportation and logistics costs for the exports are dependent upon efficient usage
of transportation resources. Empty resources, i.e., trucks, containers, etc. created by
imports result in lower freight costs for exports.
Specific opportunities in Colorado associated with Vestas, a Danish-based Wind
Energy Manufacturer that has located in three Colorado communities across the Colorado
Front Range and Aero Electric located in the Denver area were considered by the
community and region. Vestas’ FTZ subzone operations were recently granted activated
status by Denver five (5) years after their initial approval. Suppliers to Vestas and Aero
Electric are potential users of this proposed zone.
Dominant sectors in terms of percentage of employment/income
Looking regionally at the Key Industry Clusters identified by the state of Colorado,
the East Central Region is led in terms of employment by Food and Agriculture (38.2
percent), Financial Services (10.5 percent) and Transportation and Logistics (9.3
percent). Energy and Natural Resources (6.4 percent) and Advanced Manufacturing (5.3
percent) certainly present sectors of opportunity for the Foreign Trade Zone.
KIN 2012 EmpLevel Job Chg
10 12Avg Annual
Growth 10 12Level Job Chg
02 12Avg Annual
Growth 02 12Food & Agriculture 4,251 164 2.0% 420 1.0%Financial Services 1,166 86 3.8% 489 5.4%Transportation & Logistics 1,038 34 1.6% 132 1.2%Infrastructure Engineering 875 52 3.0% 81 1.0%Energy & Natural Resources 760 102 7.2% 86 1.2%Health & Wellness 709 50 3.7% 145 2.3%Tourism & Outdoor Recreation 680 2 0.1% 76 1.2%Advanced Manufacturing 598 17 1.4% 117 2.2%Creative Industries 572 7 0.6% 101 1.9%Technology & Information 252 9 1.8% 23 0.9%Defense 110 1 0.5% 5 0.4%Electronics 40 4 5.2% 19 6.4%Bioscience 36 8 9.4% 9 2.9%Aerospace 33 5 8.7% 5 1.4%Grand Total 11,120 475 2.2% 1,433 1.4%
The highest annual growth rate from 2010 to 2012 was Energy and Natural
Resources. The chart below shows the importance of developing industry beyond Food
and Agriculture with an average wage of $24,003. The Foreign Trade Zone would
provide the community and Region with significantly larger economic benefits with
greater average wages in Energy and Natural Resources ($50,376), Advanced
Manufacturing ($40,539), and Transportation and Logistics ($43,723).
Location Quotients certainly indicate opportunities in each of these sectors.
KIN2012Wage
2012 Est Emp/Est 2012 LQ 2001 LQ
Food & Agriculture $24,033 106 40 1.8 1.8Financial Services $37,585 61 19 1.1 0.9Transportation & Logistics $43,723 97 11 1.0 1.1Infrastructure Engineering $37,819 86 10 1.0 1.1Energy & Natural Resources $50,376 67 11 0.4 0.4Health & Wellness $25,871 55 13 0.4 0.4Tourism & Outdoor Recreation $18,587 37 19 0.7 0.3Advanced Manufacturing $40,539 43 14 0.1 0.2Creative Industries $21,090 41 14 0.3 0.2Technology & Information $44,555 46 5 0.2 0.2Defense $32,771 NA NA 0.5 0.5Electronics $74,862 6 7 0.1 0.0Bioscience $57,183 9 4 0.0 0.0Aerospace $51,046 4 8 0.1 0.0Grand Total $31,621 657 17 0.5 0.4
6. Describe the economic profile of the community and discuss the following:
Dominant sectors in terms of employment or income
Area strengths and weaknesses
Unemployment rates
Area foreign trade statistics
This response is in addition to the data provided in response to questions 5 and 7.
The community’s and Service Area’s economic development strategy is guided by three
documents: (i) Lincoln County Economic Development Strategic Plan, (ii) East Central
Colorado Comprehensive Economic Development Strategy (for the region consisting of
Lincoln, Elbert, Cheyenne and Kit Carson counties) and (iii) Colorado Blueprint
Summaries for the Proposed Service Area. Asterisks (*) will denote areas where this
proposed zone project will interact with these strategies.
Lincoln County Economic Development Strategic Plan identifies the following
goals:
Create and promote programs that retain, create, and promote jobs for both
existing and new businesses in Lincoln County*
Develop and expand local businesses and recruit new business to Lincoln
County*
Strive for economic diversity*
Encourage the development of infrastructure for business and industrial
recruitment*
Increase tourism development efforts
Ensure stable, long term funding for Lincoln County Economic Development
East Central Colorado Comprehensive Economic Development Strategy (CEDS)
identifies the following goals:
Attract People*
Plan for Energy Opportunities*
Capitalize on Heritage and Recreational Resources
Plan and Be Ready for Transportation Corridors Development*
Offer Technical Assistance
Strengthen/Expand Existing Businesses*
Attract Recruit New Businesses*
Colorado Blueprint Summaries
The Blueprint has given Colorado a framework to
build a comprehensive economic development plan that
aligns existing efforts and identifies opportunities
for growth and focused investments.
Implementation of the Colorado Blueprint will
depend on the three-dimensional alignment of
State, Regions and Industry Clusters in a way that
focuses people, ideas and resources on our greatest
opportunities for success.
Regional Partnerships
Central Plains (Lincoln, Elbert, Cheyenne, Kit Carson)
Develop strategies and programs to promote and support agricultural
producers and businesses*
Create additional opportunities for heritage tourism and recreation
Market the strong cooperative spirit among the communities that results in
numerous partnerships… “doing together what we cannot do alone”*
Support additional opportunities involving all energy production and the
continued development of various transportation corridors*
Support strategies and collaborations in order to maintain a competitive and
innovative workforce*
Northeast Colorado Region (Morgan, Logan, Sedgwick, Phillips, Yuma,
Washington) will focus on:
Marketing programs*
Telecommunications
Improving access to capital
Agriculture*
Tourism
Southeast Business Retention and Expansion Alliance (SEBREA) (Crowley,
Kiowa, Prowers, Otero, Baca, Bent) is a support partnership to assist in
strengthening the economy of southeast Colorado through the
Retention of jobs*
Expansion and attraction of businesses*
Providing resources to thrive in today’s changing business environment
regionally, nationally, and globally*
Industry Clusters (Key Industry Network)
Each of the fourteen (14) clusters will consist of groups of related businesses and
organizations within an industry whose collective excellence, collaboration and
knowledge-base provide a sustainable competitive advantage. Strong clusters will
translate directly into tangible benefits for businesses, citizens and educational
institutions by allowing related businesses to (i) have shared access to suppliers, services,
resources, technology and workforce and (ii) work together to reduce barriers to growth
and achieve new economies of scale, distribution and supply channels and, ultimately,
increased profitability. Overall, a higher level of focus on Colorado’s key clusters will
help identify opportunities for growth, and foster an environment for job creation.
Advanced Manufacturing*
Aerospace*
Bioscience*
Creative Industries
Defense & Homeland Security
Electronics*
Energy & Natural Resources*
Financial Services
Food & Agriculture*
Health & Wellness
Infrastructure Engineering*
Technology & Information
Tourism & Outdoor Recreation
Transportation & Logistics*
This proposed Service Area addresses the goals, objectives, and plans of the
immediate community (Town of Limon), the wider Service Area and the state of
Colorado as a whole. Historically, the focus of economic development in all three areas
has been on the export of goods, primarily agriculture, and transportation of goods.
Natural resources development, through renewable energy and oil and gas, has expanded
opportunities, as previously described. The proposed Service Area comes from a new
recognition of the local, regional and state role in a global economy and the imports,
along with direct foreign investment, can and should play in our economies. Indeed, we
observe that the mere process of preparing and filing this application has already
increased interest in the community and the proposed Service Area.
Many recent Request for Proposal’s (“RFP’s”) from prospective investors require
that a community or site has obtained, or is willing to apply for, Foreign Trade Zone
status as a condition of considering a location in the community. In other words, if a
community does not have FTZ sites, some companies will not even entertain a reply to an
RFP.
The site(s) for this FTZ designation do not present any adverse impact on the
environment. Big Sandy has not been used as a feedlot, its only previous use, for the past
fourteen years so it is virtually a Greenfield site; the Airport site is in fact a Greenfield
site. We anticipate neither air emissions nor the creation of any hazardous waste
materials. Each of the sites is environmentally friendly with little population in these
areas, yet the sites have excellent access to major roads with utilities in close proximity.
The use of FTZ procedures will not significantly change the physical aspects of any
existing or proposed operations on these identified sites for the simple fact that there are
no existing or other proposed operations for the sites.
Industries that we have targeted for recruitment include warehousing and distribution
and manufacturing and assembly. Today, most industries recognize the importance of
global connections – often seeking customers and/or sourcing parts and raw materials
from around the world. A Foreign Trade Zone, along with other incentive programs, will
draw industry to the Limon region, enabling us to increase jobs and create a more diverse
economy.
Demographic Information—See Attachment V for data that will show the nature of the
immediate six-county Service Area as evidenced by housing, income, education, racial
background of residents and other measurements.
7. State the role and objective of the proposed zone and discuss the anticipated
economic impact, direct and indirect, of the zone, including references to public
costs and benefits, employment and U.S. international trade.
The economic impact of the zone project will encompass a number of different
segments of the economy of Limon and Lincoln County, including direct and indirect job
creation, increased tax revenues and greater payrolls.
The economic impact to businesses making use of the zone will come in the form of
various zone benefits, including:
Duty deferral
Duty elimination for re-exported goods and scrap
Merchandise processing fee savings due to weekly entry
Duty reduction through inverted tariffs for those zone users who might seek and
obtain manufacturing authority
The combination of these benefits provides a wide range of potential benefits to
prospective importers interested in locating to Limon and Lincoln County. The potential
beneficiaries of a new zone may be divided into two categories, the General Purpose
Zone and Subzone Users.
The expected Zone Users would initially come from the following industry
categories:
Warehousing/Distribution
Given its location, the grantee of the proposed FTZ anticipates users will be
importing various types of products and storing them in inventory prior to their use in
manufacturing or for sale.
Manufacturing
There are some companies who are actively considering Subzone/usage driven site
status for their facilities should they locate in Limon and Lincoln County. From their
perspective, such status is a potential benefit that will increase their competitive
advantage in United States and overseas markets.
8. Describe the need for zone services in your community. If the CBP port of entry
(which you will identify in response to Question 10 below) is already served by
one or more foreign-trade zone(s), explain why the existing zone(s) will not
adequately serve the “convenience of commerce” (needs of potential users). Cite
evidence to support all assertions.
See letters of support in Attachment II.
As described more fully in the preceding discussions, the economy of the Town of
Limon and Lincoln County has heavily depended on both agriculture and on
transportation and retail sales to support their operations in the past.
The political leadership in the Town of Limon and in Lincoln County has been
focused on the need for job creation and diversification.
As has been shown over the past several years with what has been termed “the global
economic crisis,” the economy is indeed global. Just consider the impact of the euro
zone financial crisis on the U.S. economy. Indications are that manufacturing is “re-
shoring” (coming back to the US) in many industries because of the low dollar and
uncertainty in many other countries. Also, it has been our experience that many
international companies consider a location in the U.S. to be highly desired.
Other communities within the United States are able to offer FTZs and for us to
remain competitive, create jobs, and restructure and improve our economy, we need to be
able to offer the same opportunity here in site selection contests. One of the projects on
which we are currently working is only considering sites that can provide FTZ services,
so without this designation, we will be immediately eliminated from the site search.
Since we are still a small economy in a rural area with a relatively small population,
providing every possible advantage we can to prospects gives us a chance to compete
with larger, more developed areas.
The support for establishing this FTZ and Service Area is significant. Congressional
support is demonstrated by a joint letter from U.S. Senators Mark Udall and Michael
Bennet and U.S. Representative Cory Gardner. Colorado Governor John Hickenlooper
provided a letter of support. The Colorado Office of Economic Development and
International Trade has provided a written letter of support. County Commissioners in
five (5) of the six (6) counties included in the Service Area took the time to provide
letters or resolutions of support. Additionally seven (7) local economic development
organizations as well as businesses, education interests and others provided letters of
support. The largely rural area is excited about the potential that this FTZ would provide.
The CBP port of entry is Denver. The port of Denver is currently served by two
existing foreign trade zone sites.2
Because there are existing zone sites serving the Port of Denver, we must address the
fact that the customs laws recite that “[e]ach port of entry is entitled to at least one FTZ
and that zones in addition to those to which a port of entry is entitled shall be authorized
only if…existing or authorized zones will not adequately serve the convenience of
commerce.”3
In regard to this issue of the “convenience of commerce” neither of these existing
zones will serve the needs of the prospective users of the proposed zone.
The Foreign Trade Zones Board enunciated a four factor test in examining
“convenience of commerce” questions.4 These factors, and the way in which they arise
in this Application, are as follows:
2 There are two separate zones: (1) Denver--General Purpose Zone 123, grantee City and County of Denver and (2) Colorado Springs-- General Purpose Zone 112, grantee Colorado Springs Foreign Trade-Zone, Inc. a private corporation.
3 19 USC § 81b (b).
4 This was upon remand in the case of Miami Free Zone Corp. v. United States, 945 F. Supp. 273, 20 CIT 1297 (CIT 1996).
Factor 1: Level of international trade in the port of entry area and demand for
international trade, including FTZ services there
Trade data for the Denver Customs Service Area (CSA)5
The Freight Analysis Framework (FAF3) was used to summarize the historical and
future international imports into the Denver Customs Service Area. Data for value in
millions of U.S. dollars is provided from a base of 2007, the latest data in 2011 and
projected data to 2025 and 2040.
Denver CustomsService Area Imports
Total M$in 2007
Total M$in 2011
Total M$in 2015
Total M$in 2020
Total M$in 2025
Total M$in 2030
Total M$in 2035
Total M$in 2040
Truck $557 $764 $969 $1,262 $1,600 $1,966 $2,317 $2,743Rail $2 $3 $4 $5 $7 $9 $10 $13Air (include truck air) $5 $7 $9 $11 $14 $17 $20 $24Multiple modes & mail $0 $0 $0 $0 $0 $0 $0 $0Pipeline $84 $118 $135 $159 $199 $247 $302 $364Other and unknown $182 $173 $218 $295 $393 $507 $603 $720Total Imports $831 $1,065 $1,335 $1,733 $2,213 $2,746 $3,252 $3,864% Change per period 28% 25% 30% 28% 24% 18% 19%% Change 2011 to 2025 108%% Change 2011 to 2040 263%
Currently the Denver CSA imported slightly under $1.1 billion in goods through all
modes in 2011. A significant majority (72%) of those imports enter the Denver CSA by
truck. Additionally, the summary indicates that the overall increase between 2011 and
2025 is projected to be more than double the existing level of imports at 108%. By 2040
the increase projected from 2011 is projected to be 263%. The proposed FTZ provides an
alternative to the pattern of trucks entering the Denver CSA at an increasing rate and
adding to the current congestion and air quality issues that Denver continues to address.
5 Freight Analysis Framework (FAF), Center for Transportation Analysis in the Oak Ridge National Laboratory under funding from the Federal Highway Administration.
Leading Imports toDenver CSA by Truck
Total M$in 2011
Total M$in 2025
Total M$in 2040
%Change2011 to
20401 Machinery $262 $603 $1,104 322%2 Precision instruments $89 $193 $319 259%3 Basic chemicals $87 $168 $282 224%4 Electronics $85 $179 $291 243%5 Mixed freight $57 $95 $138 142%6 Misc. mfg. prods. $48 $101 $183 282%7 Textiles/leather $25 $47 $79 209%8 Live animals/fish $22 $36 $48 115%9 Chemical products $17 $41 $76 338%
10 Motorized vehicles $15 $25 $34 131%
Above is a listing of the top ten commodities being imported into the Denver CSA by
truck. Each category is projected to more than double by 2040 with Machinery and
Chemical Products exceeding three times the current value.
Until the September, 2013 activation of the Vestas Nacelles America sites (Subzone
#123E), FTZ activities associated with the Denver FTZ #123 were principally limited to
the jet fuel operations at Denver International Airport. The Colorado Springs FTZ has
had no FTZ activity to date.
The following data are derived from Appendices to the 74th Annual Report of the
Foreign-Trade Zones Board for calendar year 2012. This Annual Report was published
in October, 2013.
Appendix C—Top 25 States—FTZ Activity, 2012
Warehouse/Distribution Activity:
Imports (Merchandise received)—Colorado ranks 21st
Exports—Colorado ranks 16th
Appendix D—Movement of Merchandise By State, 2012
1. FTZ 123
Foreign status—100% oil/petroleum
Shipments—imports US $1-5 billion, exports $75-100 million
2. FTZ 112—no reported zone activity
The Eastern Colorado Mobility Study, undertaken by the Colorado Department of
Transportation looked at the projected growth of inbound and outbound commodity flows
by truck and rail between 1998 and 2025 with a breakdown between the counties
comprising the Colorado Front Range and those in the Eastern Plains Region, the latter
including many of the counties identified as being within the primary Service Area of this
application. While this study did not differentiate between domestic and international
trade, it speaks to the anticipated growths of cargo traffic within the State.
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Beginning from a larger base, the Front Range was projected to grow by 115%
overall. Inbound growth was projected to grow by 103 percent. Outbound projected to
grow by 131 percent.
Cargo traffic movement in the Eastern Plains counties, identified as the primary
Service Area in this application, were projected to increase by 89 percent by 2015.
Consequentially, while the outbound movement was projected to increase 67 percent, the
inbound movement was projected to keep pace with the Front Range rate increasing by
113 percent. The opportunity for a Foreign Trade Zone would be an important tool in
realizing this projection and to diversify the commodities.
Factor 2: Need for FTZ Services within the Community
The major reason for a need for FTZ services within the Town of Limon is that
several of the companies with whom the Town has spoken, and to whom it has exerted
direct efforts to locate their operations within the Town and Lincoln County, have made
an FTZ status a key issue in their site selection process.
Naturally, we will continue to search for potential users. We have every expectation
that we will attract new companies with our FTZ potential. We must emphasize that,
from the potential Grantee’s perspective, even if we were only able to attract companies
that created some new well-paying, permanent jobs by means of the zone status, we
would still consider the project a tremendous success. It will have signaled a shift away
from the retail sector upon which we have been relying.
Neither of the other general purpose zones are local to the proposed zone sites or to
the land that the Town plans to offer prospective users. Denver and Colorado Springs are
both remote and the Town of Limon displays a need for FTZ services within and for its
own community and within and for the Service Area. Further to this point, it is apparent
that the grantee of FTZ 123, the city and county of Denver, is committed to and focused
upon serving the interests of Denver and not those of the Town, Lincoln County or any of
the other jurisdictions which make up the Service Area. That having been said, we are
advised that FTZ 123 is generally supportive of this application, as noted in our Factor 4
response, below.
Beyond this point, it is clear that the Town of Limon and Lincoln County have their
own deep-rooted challenges and have set their own goals in meeting those challenges by
winning projects and in attracting new companies, creating a more diversified economic
base and offering employment opportunities to its citizens. The grantees of each of the
existing general purpose zones have the same and competing economic goals for the
development of their own respective areas, if they are public organizations or, if they are
private companies, have a profit motive to see that the land they own is utilized. The
Town of Limon’s interest is not in serving the needs of other communities or their
citizens, nor in making a profit on the zone operation. Instead, the goal of the officials
of the Town of Limon and Lincoln County is in providing a service that meets the needs
of their citizens and, by extension, the needs of the citizens of the wider Service Area
that would be served by FTZ designation.
Those development efforts and the public interests of those citizens are not at all
served by the existence of other general purpose zones in view of these separate interests
of the Town of Limon and Lincoln County and the other communities in the eastern part
of the state. If the “public interest” criterion which plays such a key, indeed a decisive
role in the review of FTZ applications, is applied from the perspective of the Town of
Limon and of Lincoln County and the other counties in the proposed Service Area and,
on a larger basis, the State of Colorado, then it is clear that this Application merits your
attention and fulfills that public interest criterion.
Factor 3: Competitive Effect of the proposed zone
This Application does not present “a rob Peter to pay Paul” application in the sense
that, in order to demonstrate a need for zone status, the proposed Grantee is luring away
or hoping to lure away zone users from any of the existing zone sites. This is not a “zero
sum” game in that any positive zone activity in the Town and the wider Service Area will
come at the expense of lowered zone activity elsewhere.
Indeed, at no time has the potential Grantee marketed or even approached a company
that is a user at any of the other zones with a view toward suggesting that the user should
relocate. The potential Grantee has no plans to actively market to any of those other
companies either to relocate to its zone sites or to sponsor any Subzones within the
jurisdictions covered by these other zones. Indeed, the point is that the driving forces that
may convince a company to locate within the potential zone sites we seek, such as the
characteristics of the available land, potential employee base, transportation network and
other infrastructure factors, will usually be such that their confluence will be unique to
our site. In short, the reason why a company will come to the potential zone sites will
dictate that it will not go to one of the existing zone sites.
We submit that it is on the basis of these facts that the State’s Office of Economic
Development and International Trade (OEDIT) and Colorado’s Governor have viewed
this application as congruent with the State’s overall economic development efforts. The
Colorado Department of Labor and Employment, which has a state-centric focus, has also
expressed its strong support for this application and sees no tension created by a
successful effort on this present application.
As indicated earlier in this application, Colorado is a destination state for
manufactured goods and other products. This situation creates a transportation imbalance
with more trucks and containers carrying goods and products into Colorado than
available goods and products moving out of Colorado. Empty trucks and containers
increase consumer costs and add to the cost of doing business. The FTZ proposed in this
application could be significant in adding to the manufacturing and assembly base within
Colorado and would improve the utilization of the transportation system in Colorado.
Factor 4: Support from State and Local Officials
This Application has received overwhelming support from affected cities, regional
economic development bodies and the OEDIT and the Department of Labor and
Employment of the State of Colorado. The Congressional delegation comprised of the
U.S. Congressman representing Lincoln County and the majority of eastern Colorado
making up the Service Area, Cory Gardner, the two United States Senators representing
the State of Colorado, and the Governor of Colorado have all joined in unanimous
support of this Application. It is fair to say that few other zone applications have
demonstrated this both wide and deep level of public official support.
Importantly, the State has conferred with responsible officials of both of the grantees
of the other existent zones, Denver and Colorado Springs. We have been advised that
those grantees have expressed that they have no opposition to this application and,
moreover, can see the rationale for making the application for this separate zone in
eastern Colorado.
In summary, we submit that, on the basis of all of the foregoing information in this
subsection, the present Application has fully met the convenience of commerce
requirement. There is no currently existing zone site that can support the needs of the
Town of Limon and Lincoln County and the other counties comprising the Service Area
and of the companies who are potential zone users who are considering locating to that
geographic locale.
9. Provide specific expressions of interest from proposed zone users. Please include
those letters as Attachment III.
At this time, there are no persons who have committed to act as zone users due to the
fact that the proposed zone is in its early stages of development.
Proposed Zone Structure and Description
10. Indicate the CBP port of entry for the proposed zone.
The CBP port of entry is Denver.
11. Describe the counties or other distinguishable legal jurisdictions that make up
the proposed service area. In the Service Area Correspondence attachment
(Attachment IV), please include documentation of support from each county in
your proposed Service Area. Provide letters from local jurisdictions in using the
standard format for service area letters provided at:
http://ia.ita.doc.gov/ftzpage/majorexp.html.
The applicant is requesting the establishment of a new zone with a Service Area in
order to serve the public interest in the Town of Limon and in communities (i) in the
following Counties in their entireties: Adams, Arapahoe and Morgan and (ii) in portions
of the following Counties (as further delineated within Attachment V, Service Area
Boundary Description and Map): Lincoln, Elbert and Washington. See letters in
Attachment IV, including letter from Town of Limon.
12. In a “General Maps” attachment (Attachment V), please provide the following:
a. (optional) a map of the proposed service area with proposed boundaries
outlined in red;
b. (required) if your proposed service area includes any partial
jurisdictions, prove a map clearly showing in red the line dividing the
portions of the jurisdictions inside and outside the Service Area; and
c. (required) one or more maps showing the proposed sites in a regional
context. All documents must be legible and letter-sized (8 1/2" X 11").
See Attachment V, Service Area Boundary Description and Map.
Proposed Magnet Sites and Site Selection Criteria
Questions 13 through 17 apply only if you are proposing one or more Magnet
sites:
13. Provide the following information in the table provided below for each Magnet
site: the site number; the county or other legal jurisdiction in which the site is
located (which must correspond to the county or legal jurisdictions listed for
question 11); a basic description of the site and its address; and the site’s
acreage.
SiteType
(Magnet/ Usage)
Site#
County / Legal
Jurisdiction
Name of Site and Address Acreage within site boundaries
SiteActivation
Limit
Magnet 1 Town of Limon
Big Sandy 1055 Immel St., Limon, CO 80828
141.16+/- N/A
Magnet 2 Town of Limon
East Airport 21650 State Highway 40/287, Limon, CO 80828
280.3 +/- N/A
Total (sum site activation limits) N/AReserve (2,000 less sum of activation limits) N/A
14. Describe in detail the grantee's process for selecting each site for which Magnet
designation is proposed. Discuss the criteria applied in that process and how
those criteria relate to the local economic development plans. Indicate the public
entities involved in the site-selection process.
The Town of Limon has been actively engaged in the economic development process
for approximately twenty-three (23) years. In 1990, the Town’s direction was initially
changed following an F3 tornado that destroyed a significant portion of its historical
downtown. A major economic revitalization followed including the active development
of facilities in the downtown areas including a new town hall, library, senior center and
medical center. These activity centers, along with development of new downtown
streetscape, strengthened the downtown area. That area has become the business service
area of the community.
In 1997, both the Town of Limon and Lincoln County became active members of the
Ports-to-Plains Alliance. For the past eight years, the Town of Limon has provided a
staff member to the Ports-to-Plains Alliance. The Ports-to-Plains Alliance provided a
catalyst to see the value of global trade to the local area as well as the Service Area
Region.
The next step in the progression was the creation of Lincoln County Economic
Development Corporation, Inc (LCEDC) in 2000. This 501(c)(3) corporation is a public-
private partnership committed to expanding and retaining the economy across Lincoln
County. Public investors in this organization include Lincoln County and every
municipality within the county including Limon, Hugo, Arriba and Genoa. Additional
information can be found at www.lincolncountyed.org. Following a lengthy community
outreach to reestablish its strategic plan in 2013, LCEDC’s budget for 2014 is the largest
in its history.
As indicated in Section 5 above, the Town of Limon and Lincoln County are active
participants at regional and statewide levels. The Assistant Town Manager in Limon
serves on the Board of Directors of the Economic Development Council of Colorado.
More specifically, the process of selecting the magnet sites included a county-wide
outreach through LCEDC. Interest in the proposed FTZ came from all areas of the
county, but two publicly owned sites became clearly the top opportunities. Both these
sites are owned by the Town of Limon. As described in Section 5 above, the Big Sandy
site has been lying vacant for the past fourteen years and East Airport site is completely
greenfield.
As the two sites were evaluated the following strengths were identified for each site:
Big Sandy
Location: Good connection to Highway 71 to accommodate the movement of
freight.
Utilities: Good ability to extend utilities including water, sewer, electricity,
natural gas and telecommunications infrastructure from existing locations.
Environment: Adequate land for development will still leave significant open
space and riparian areas untouched.
Other: Public ownership allows negotiation on public incentives to be part of
the discussion with potential users. Development adds the property to tax
rolls. Can be subdivided to the specific needs of users.
East Airport
Location: Adjacent to Interstate 70 and U.S. 40/287 (Ports-to-Plains) and
direct access to the Limon Municipal Airport.
Utilities: Good ability to extend utilities including water, sewer, electricity,
natural gas and telecommunications infrastructure from existing locations.
Environmental: Complete greenfield site with only current use as grassland
for cattle grazing.
Other: Public ownership allows negotiation on public incentives to be part of
the discussion with potential users. Development adds the property to tax
rolls. Can be subdivided to the specific needs of users.
15. Explain in detail why each proposed Magnet site is needed to provide FTZ
services to your community(ies). Address the degree to which each site may
duplicate types of facilities at other proposed sites.
The two magnet sites, while located geographically common, each provide separate
opportunities for interested parties. The East Airport site provides direct access to the
general aviation available at Limon Municipal Airport. The Big Sandy site would be the
select location for a company looking for a location with significant open space from an
environmental viewpoint. The Big Sandy site includes riparian areas in the Big Sandy
Creek along the north and east boundaries.
16. The default sunset period for each designated Magnet site in a zone is five years.
A proposed grantee is allowed to request a waiver of the sunset limit for one
Magnet site. If you would like to request a waiver of the sunset limit for one of
your Magnet sites, indicate the site number and describe in detail why this site
was chosen for the waiver request. Key considerations would be the publicly
owned nature of a site and public processes leading to the site’s selection.
The Town of Limon would like to request a waiver of the sunset limit for Site #1, the
Big Sandy Site. This site is one of two publicly owned sites in the proposed foreign trade
zone. We anticipate that the full development of the Big Sandy Site may take a number
of years due to funding. Therefore, this site may require a more extended timeframe to
meet our strategic goals. The Limon Board of Trustees, the public body governing the
use of the site, agrees that to meet our strategic goals may require a longer period of time.
The fact that the Town of Limon owns and controls the use of the property places this
property in a more advantageous position than privately owned property due to previous
infrastructure planning and construction and a more narrowly targeted industry group.
17. If you believe that a sunset period of longer than five years is justified for one or
more specific Magnet sites, provide separately for each such site a detailed
description of the specific circumstances that you believe justify a sunset period
of longer than five years for the site in question.
A sunset period of greater than five years is justified for the East Airport site for
reasons similar to those noted in point 15 regarding the Big Sandy site. As a publicly
owned property, we are being realistic in thinking that it will take some time to attract
potential users.
Proposed Subzone/Usage-Driven sites (if applicable)
Question 18 only applies if you are proposing one or more Subzone/Usage-Driven sites:
18. Using the table provided below, outline your zone describing the proposed
Subzones or usage-driven sites, if applicable, with site type, site identification,
which county or other legal jurisdiction (which must correspond to the county or
legal jurisdictions listed for Question 10) they are located in, basic description of
site and address, and the acreage.
Not applicable
Other Requirements
19. CBP Automated Systems Requirements: For the proposed new sites, do you
commit to working with Customs and Border Protection, as appropriate, to meet
current and future CBP automated-systems requirements (such as ACE) and to
meet any CBP security requirements related to activation?
Yes, the proposed Grantee makes that commitment.
20. Please state that the applicant is aware that FTZ status would not exempt any
site or party (e.g. operators or users) from any Federal, state or local
environmental requirements.
The applicant is aware that FTZ status would not create any site or party exemptions
from any Federal, state or local environmental requirements.
General Attachments
I. Legal Authority to Apply (see Question 2)
II. Support from Local Organizations (see Question 7)
III. Support from Local Jurisdictions (see Question 9)
IV. General Maps (see Question 10)
V. Demographic Information
VI. Ports-to-Plains Map
VII. Site-Specific Documents
PART TWO: SITE-SPECIFIC INFORMATION FOR MAGNET SITE 2(Big Sandy)
This section should be filled out separately for each magnet site. Attach any
documents needed for Questions M13 and M14 (and M15, if applicable) directly behind
the copy of this section for each site.
M1. Indicate the site’s distinct identifying number: Magnet Site No. 1. This distinct
identifying number must tie to your table for Question 13 in Part One of this
application.
M2. List the site’s address, including the jurisdiction in which the site falls (town,
city, county).
1055 Immel St., Limon, Lincoln County, CO 80828
M3. Indicate the site’s proposed acreage:
141.16 +/- acres
M4. Explain if the site is within the boundaries of the CBP port of entry (as listed
in Question 9 in Part One of the application). If not, indicate how many miles
the site is from the outer limits of the CBP port of entry. If the site is beyond
60 miles from the outer limits of the CBP port of entry, provide the driving
time from the outer limits of the port of entry to the site.
The closest CBP port of entry is Denver. The site is not within the boundaries of the
CBP port of entry. The site is 84.6 miles from the outer limits of the CBP port of entry:
from port boundary. The driving time from the outer limits of the port of entry to the site
is 74 minutes.
M5. Indicate the type of site (port, industrial park, warehouse complex) and its
current zoning. (Note: Sites with inappropriate zoning – such as agricultural,
retail, or residential – should not be included in an FTZ application.)
The site is currently zoned as a Commercial (C-1) Zone District by the Town of
Limon.
The Commercial Zone District (C-1) was developed and approved by the Board of
Trustees of the Town of Limon specifically to meet the needs of a potential FTZ.
Allowed Uses-By-Right:
Places for the conduct of mixed
commercial and industrial uses,
including, but not limited to, the
following:
assembling and light
manufacturing plants
electronic, electrical,
communication equipment
manufacturing/assembly
warehouse and distribution
facilities
manufacturing, assembly, and
distribution of secondary and
basic goods
truck terminals and loading areas
oil and gas drilling service
operation and storage areas
commercial storage areas and
warehouses used to store or
distribute goods and
commodities
commercial storage (indoor)
processing plants
emergency response facilities
public safety facilities
utility service facility
utility generation facilities
greater than or equal to 50
megawatts of power
Allowed Conditional Uses:
manufacturing (food)
manufacturing (machinery)
manufacturing (metal)
manufacturing (non-metallic
mineral)
manufacturing (textile)
manufacturing (wood product)
carpentry and woodworking
shops
food and beverage processing
plants
food lockers
recreational vehicle storage lots
crop dusting and associated
chemical storage and airstrips
aircraft related recreational
activities
water tanks, water and sewer
treatment facilities, utility
substations, and regulator station
communication facilities
exceeding the height limit
Allowed Special Review Uses:
manufacturing (oil and gas)
outdoor commercial storage
areas
commercial and general aviation
airports and heliports
concrete, asphalt and mortar
batching plants
temporary batch plants
warehouse (flammable materials)
aircraft related commercial
facilities
major facility of a public utility
Allowed Accessory Uses:
airplane hangars
The Commercial Zone District designation, because of its allowed uses being
compatible with the goals of recruiting new business development in manufacturing and
distribution, will make the property marketing simpler and make the land development
process more streamlined.
M6. Describe the proposed site’s:
existing and planned buildings (including square footage)
existing and planned activities
whether the site is master planned
projected timetable for construction and activation
possibilities and plans for future expansion of the site.
This site is not part of a master plan. There are no existing or planned buildings. The
site is ready for development, but with today’s economy, completion of the buildings to
house industries to use FTZ will not take place until there is a company who has agreed
to locate there and needs a facility. We are actively marketing this site to industrial
prospects and have had several visits by companies, but no decisions at this time.
Presently there are no applications for construction approvals or timeline for CBP
activation.
M7. List the companies that currently occupy the site:
None.
M8. Briefly describe the transportation infrastructure serving the site, including its
ties to the broader regional/national transportation system:
This site connects to Colorado Highway 71 within 1000 feet of the property and is
only 0.4 mile to the intersection of Highway 71 and U.S. 24/40/287 and only 1.6 miles to
Interstate 70 going west and 1.9 miles east. Interstate 70 connects to west to Denver and
east to Kansas City. U.S. Highway 24 connects to Colorado Springs. Colorado Highway
71 north is part of the Ports-to-Plains Corridor, identified as a High Priority Corridor on
the National Highway System called Heartland Expressway. U.S. 40/287 connects south
into Texas markets. The entire Ports-to-Plains Corridor connects internationally to
Mexico and Canada.
M9. Explain how the site will accommodate multiple companies’ use.
The site is open to any businesses that need significant acreage, or support activities
by these businesses site under public utility principles (under uniform rates and
conditions).
M10. Briefly describe the physical security measures that will be used for the
proposed site in order to meet CBP requirements.
The site will be fenced with controlled access.
M11. Confirm that FTZ designation or the use of FTZ procedures is not a
requirement or a precondition for future activity or construction at the site.
Confirmed; FTZ designation is not a pre-condition.
M12. List the owner(s). (If the site is not owned by the applicant, then provide a
“Site Ownership” attachment with a letter of concurrence from the property
owner(s).)
The site is owned by the Town of Limon.
M13. A clear and detailed site map showing existing and planned structures. The
site boundaries must be outlined clearly in red. Note that if streets or similar
landmarks are not legible on the site map, you will also need to provide a
detailed street map with the proposed site’s boundaries in red. Any map
should be no larger than letter-sized (8 ½” x 11”) and clearly labeled, with
legends provided for any markings.
See Attachment VIII.
M14. Signed letters of intent to use the proposed FTZ site in question on letterhead
from firms considered prime prospects for use of the site.
Given that this application proposes the Town’s publicly owned land as one of two
magnet sites for a new FTZ under the ASF in a county unserved by another FTZ, we
believe it is justifiable to waive the ordinary need for letters of interest and intent.
M15. If your state (such as TX, KY, AZ) has one or more taxes for which
collections will be affected by the proposed FTZ designation of the new site,
please attach all of the following:
a) An explanation of the specific local taxes that will be affected;
b) A stand-alone letter (in other words, a letter separate from the application
letter) that:
Lists all of the affected parties;
Includes a statement below the list certifying that this is a complete list of
all parties that would be affected by this particular request; and,
Is signed by an official of the grantee organization.
c) Correspondence from all of the affected parties (such as a local school board)
indicating their concurrence (or non-objection) regarding the proposed FTZ
designation.
Not Applicable.
PART TWO: SITE-SPECIFIC INFORMATION FOR MAGNET SITE 2(East Airport)
This section should be filled out separately for each magnet site. Attach any
documents needed for Questions M13 and M14 (and M15, if applicable) directly behind
the copy of this section for each site.
PART II: MAGNET SITE JUSTIFICATION: SITE 2 (East Airport)
This section should be filled out separately for each site.
M2. Indicate the site’s distinct identifying number: Magnet Site No. 2. This distinct
identifying number must tie to your table for Question 13 in Part One of this
application.
M2. List the site’s address, including the jurisdiction in which the site falls (town,
city, county).
21650 State Highway 40/287, Limon, Lincoln County, CO 80828
M3. Indicate the site’s proposed acreage:
280.3 +/- acres
M4. Explain if the site is within the boundaries of the CBP port of entry (as listed
in Question 9 in Part One of the application). If not, indicate how many miles
the site is from the outer limits of the CBP port of entry. If the site is beyond
60 miles from the outer limits of the CBP port of entry, provide the driving
time from the outer limits of the port of entry to the site.
The closest CBP port of entry is Denver. The site is not within the boundaries of the
CBP port of entry. The site is 85.0 miles from the outer limits of the CBP port of entry:
from port boundary. The driving time from the outer limits of the port of entry to the site
is 75 minutes.
M5. Indicate the type of site (port, industrial park, warehouse complex) and its
current zoning. (Note: Sites with inappropriate zoning – such as agricultural,
retail, or residential – should not be included in an FTZ application.)
The site is currently zoned as a Commercial (C-1) Zone District by the Town of
Limon.
The Commercial Zone District (C-1) was developed and approved by the Board of
Trustees of the Town of Limon specifically to meet the needs of a potential FTZ.
Allowed Uses-By-Right:
Places for the conduct of mixed
commercial and industrial uses,
including, but not limited to, the
following:
assembling and light
manufacturing plants
electronic, electrical,
communication equipment
manufacturing/assembly
warehouse and distribution
facilities
manufacturing, assembly, and
distribution of secondary and
basic goods
truck terminals and loading areas
oil and gas drilling service
operation and storage areas
commercial storage areas and
warehouses used to store or
distribute goods and
commodities
commercial storage (indoor)
processing plants
emergency response facilities
public safety facilities
utility service facility
utility generation facilities
greater than or equal to 50
megawatts of power
Allowed Conditional Uses:
manufacturing (food)
manufacturing (machinery)
manufacturing (metal)
manufacturing (non-metallic
mineral)
manufacturing (textile)
manufacturing (wood product)
carpentry and woodworking
shops
food and beverage processing
plants
food lockers
recreational vehicle storage lots
crop dusting and associated
chemical storage and airstrips
aircraft related recreational
activities
water tanks, water and sewer
treatment facilities, utility
substations, and regulator station
communication facilities
exceeding the height limit
Allowed Special Review Uses:
manufacturing (oil and gas)
outdoor commercial storage
areas
commercial and general aviation
airports and heliports
concrete, asphalt and mortar
batching plants
temporary batch plants
warehouse (flammable materials)
aircraft related commercial
facilities
major facility of a public utility
Allowed Accessory Uses:
airplane hangars
The Commercial Zone District designation, because of its allowed uses being
compatible with the goals of recruiting new business development in manufacturing and
distribution, will make the property marketing simpler and make the land development
process more streamlined.
M6. Describe the proposed site’s:
existing and planned buildings (including square footage)
existing and planned activities
whether the site is master planned
projected timetable for construction and activation
possibilities and plans for future expansion of the site.
This site is not part of a master plan. There are no existing or planned buildings. The
site is ready for development, but with today’s economy, completion of the buildings to
house industries to use FTZ will not take place until there is a company who has agreed
to locate there and needs a facility. We are actively marketing this site to industrial
prospects and have had several visits by companies, but no decisions at this time.
Presently there are no applications for construction approvals or timeline for CBP
activation.
M7. List the companies that currently occupy the site:
None.
M8. Briefly describe the transportation infrastructure serving the site, including its
ties to the broader regional/national transportation system:
This site is adjacent to Interstate 70 and U.S. 40/287 (Ports-to-Plains Corridor) and
direct access to the Limon Municipal Airport. Interstate 70 connects to west to Denver
and east to Kansas City. U.S. Highway 24, in 2.3 miles, connects to Colorado Springs.
Colorado Highway 71 north is part of the Ports-to-Plains Corridor, identified as a High
Priority Corridor on the National Highway System called Heartland Expressway. U.S.
40/287 connects south into Texas markets. The entire Ports-to-Plains Corridor connects
internationally to Mexico and Canada.
M9. Explain how the site will accommodate multiple companies’ use.
The site is open to any businesses that need significant acreage, or support activities
by these businesses site under public utility principles (under uniform rates and
conditions).
M10. Briefly describe the physical security measures that will be used for the
proposed site in order to meet CBP requirements.
The site will be fenced with controlled access.
M11. Confirm that FTZ designation or the use of FTZ procedures is not a
requirement or a precondition for future activity or construction at the site.
Confirmed; FTZ designation is not a pre-condition.
M12. List the owner(s). (If the site is not owned by the applicant, then provide a
“Site Ownership” attachment with a letter of concurrence from the property
owner(s).)
The site is owned by the Town of Limon.
M13. A clear and detailed site map showing existing and planned structures. The
site boundaries must be outlined clearly in red. Note that if streets or similar
landmarks are not legible on the site map, you will also need to provide a
detailed street map with the proposed site’s boundaries in red. Any map
should be no larger than letter-sized (8 ½” x 11”) and clearly labeled, with
legends provided for any markings.
See Attachment VIII.
M14. Signed letters of intent to use the proposed FTZ site in question on letterhead
from firms considered prime prospects for use of the site.
Given that this application proposes the Town’s publicly owned land as one of two
magnet sites for a new FTZ under the ASF in a county unserved by another FTZ, we
believe it is justifiable to waive the ordinary need for letters of interest and intent.
M15. If your state (such as TX, KY, AZ) has one or more taxes for which collections
will be affected by the proposed FTZ designation of the new site, please
attach all of the following:
a) An explanation of the specific local taxes that will be affected;
b) A stand-alone letter (in other words, a letter separate from the application
letter) that:
Lists all of the affected parties;
Includes a statement below the list certifying that this is a complete list of
all parties that would be affected by this particular request; and,
Is signed by an official of the grantee organization.
c) Correspondence from all of the affected parties (such as a local school board)
indicating their concurrence (or non-objection) regarding the proposed FTZ
designation.
Not Applicable.
ATTACHMENT I – LEGAL AUTHORITY FOR APPLICATION
A--Certified Copy of the State’s Enabling Legislation
B—Charter or Organization Papers Showing the Powers Granted to Boards of Trustees and Sections Pertinent to FTZs
C—Certified Copy of the Board of Trustees Resolution
�
�
November�25,�2013���Mr.�Andrew�McGilvary,�Executive�Secretary�Foreign�Trade�Zones�Board�U.S.�Department�of�Commerce�1401�Constitution�Avenue,�NW,�Room�2111�Washington,�DC��20230���Re:��Limon/Lincoln�County�Application�to�Establish�a�Foreign�Trade�Zone�Grant�of�Authority�under�the�
Alternative�Site�Framework���Dear�Mr.�McGilvary:���Adams�County�Economic�Development�supports�Limon/Lincoln�County’s�application�to�Establish�a�Foreign�Trade�Zone�Grant�of�Authority�under�the�Alternative�Site�Framework�in�eastern�Colorado.�Additionally,�Adams�County�would�like�to�be�included�in�the�service�area�of�the�proposed�new�Foreign�Trade�Zone.��The�Application�to�Establish�a�Foreign�Trade�Zone�Grant�of�Authority�would�support�and�enhance�our�local,�regional�and�state�plans�for�economic�development�–�helping�to�retain�and�attract�primary�jobs�and�capital�investment�–�in�an�area�that�is�underserved�by�existing�foreign�trade�zones.��This�application�is�being�made�after�careful�and�extensive�evaluation�undertaken�by�the�Town�of�Limon�on�behalf�of�Limon,�Lincoln�County�and�the�other�counties�comprising�the�proposed�Service�Area.��The�project�meets�goals�of�the�region�in�attracting�and�retaining�U.S.�based�economic�activity.��The�State�of�Colorado�would�welcome�new�opportunities�in�eastern�Colorado�to�encourage�international�investment�and�promote�import/export�activities.��We�thank�you�for�your�thoughtful�review�and�consideration�of�the�application�and�ask�for�your�approval.��The�entire�eastern�Colorado�region�will�benefit�from�the�creation�of�new�economic�opportunities�and�primary�jobs.��Sincerely,�
�Barry�Gore�President/CEO��
ATTACHMENT II - SUPPORT FROM LOCAL ORGANIZATIONS
November 12, 2013
Mr. Andrew McGilvary Executive Secretary Foreign-Trade Zones Board U.S. Department of Commerce 1401 Constitution Avenue, NW, Rm 2111 Washington, DC 20230
RE: Limon/Lincoln County Application to Establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework
Dear Mr. McGilvary:
As the owner of several businesses located in the Limon/Lincoln County area of Colorado, I would like to add my whole-hearted support for Limon/Lincoln County’s application to establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework in eastern Colorado. I encourage your favorable determination of this proposal.
Our enterprises include transportation; commercial, industrial and agricultural real estate; agricultural production; and environmental services for customers located throughout the Rocky Mountain West. The institution of the Foreign Trade Zone in this region will be a complementary factor to many existing businesses in our locale, perhaps including my own. I believe this will lead to the creation or expansion of many other businesses, too. The creation of the FTZ will allow the entire region of eastern Colorado to participate more directly in this world-wide economy in which we operate today.
There are many favorable qualities that currently exist in this area that will benefit the proposed FTZ. Limon & Lincoln County are at the heart of the eastern Colorado region. We are home to a large, new and growing wind energy business. We have also been the benefactor of new and substantial oil and natural gas energy developments in the area. Community wise, local citizens have recently approved the funding and building of three brand new K-12 school facilities in Limon, Hugo and nearby Simla. Of course, production agriculture serves as the traditional economic foundation of the region.
As for transportation, the possibilities are very favorable. Limon is known as the “Hub City of the Plains,” complete with an interstate highway and 6 other primary state highways. There are two railroad lines that serve this area, as well as a great “jet-capable” municipal airport. Further, the close proximity to Denver and the entire Front Range area of Colorado spells great economic opportunities for many businesses serving a wide range of industries. (And by way of reference, it is a four hour drive to Cheyenne, WY and approx 5 hours to Albuquerque, NM.)
Perhaps most importantly, The Town of Limon is served by uncommon leaders who are forward thinking, creative and hard working. This FTZ application, in and of itself, is proof positive of my assertion. As a local businessman, I can assure you that these folks are quite capable of completing any and all responsibilities associated with this proposal, both now and into the future.
Indeed, the creation of the proposed FTZ would be an ideal fit for this community and the citizens of the entire region. I can share that community support for this application is at an
incredibly high level. It is my estimation that this community will serve as a great home for the FTZ and that a mutually symbiotic relationship between the two will undoubtedly be created.
Thank you for your consideration. I would be pleased to visit with you if such a need should arise. We look forward to welcoming you to our community as the process allows.
Warmest regards,
KIPP PARKER, OWNER / MANAGER
Parker Ag Services, LLC AWS Dredge, LLC West Park Transport, LLC Western Resources Group, LLC Parker Farms
O) 719-775-9870 F) 719-775-9871 C) 719-740-9870
PORTS-TO-PLAINS ALLIANCE5401 N MLK BLVD. #395
LUBBOCK, TX 79403 806-775-2338
PPPPPPPORORTORTORORTORTORORTORTRRTSSSS-TTOTOTO-PPPLAILAILAILAINS NS N AAAALLLLILILIIIILLIIILLL AANNNNNNCNCNCNCNCNNNCNNNNNCNNNN EEEEEEE5454544010100 NNNN MLMLMLKKK BBBLVDVDLVLVD..... ##3#3333333#33333333333959555595999
LLLUBBUBBUBBBOCKOCKOOCK, TXTTXXXXXXX 77779999944444404044444044004 333333380808080808880666---77777777777777777775555--222233333333332333333838883883338833388
MICMMICMIMMICCCCCCHAEL.REEREEEEEEVEVESVV SSS@@@@@@@@@@PORPORPORPORPORTSTTSTTSTTSTTSTSTOOPLLLO LLLOPPOPLLLLPOPPPPLAINAAINNNNSSS...CCCOCOOMOMOMCOCCCC MMC
5401 N. MLK Blvd. #395 ~ Lubbock, TX 79403 ~ p 806 775-2338 ~ f 806 775-3981 ~ www.portstoplains.com
October 29, 2013
Mr. Andrew McGilvaryExecutive SecretaryForeign-Trade Zones BoardU.S. Department of Commerce1401 Constitution Avenue, NW, Rm 2111Washington, DC 20230
Re: Limon/Lincoln County Application to Establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework
Dear Mr. McGilvary:
We would like to add the support of the Ports-to-Plains Alliance for Limon/Lincoln County’s application to establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework in eastern Colorado.
The Ports-to-Plains Alliance is a grassroots alliance of over 170 communities and businesses in a region extended from Texas to Montana and North Dakota including Colorado whose mission is to advocate for a robust transportation infrastructure to promote economic security and prosperity throughout North America's energy and agricultural heartland. Colorado’s international imports are projected to grow from its current over $13 billion by 199% to over $39 billion by 2040. Both Limon and Lincoln County are active members of the Ports-to-Plains Alliance and have demonstrated a strong understanding of the importance of trade to their local, regional and national economies.
The Application to Establish a Foreign Trade Zone Grant of Authority would support and enhance local, regional and state plans for economic development and job retention and creation in an area that is underserved by existing foreign trade zones.
This application is being made after careful and extensive evaluation undertaken by the Town of Limon on behalf of Limon, Lincoln County and the other counties comprising the proposed Service Area. The project meets goals of the region in attracting and retaining U.S. based economic activity. It is also confirmed that such development in eastern Colorado would be welcomed by the State of Colorado and easily integrated with the state’s existing programs for inviting inward international investment and for promoting exports from the state.
We look forward to your thoughtful consideration as you review and consider approval of this application. We thank you in advance for enabling this service area to access this important economic development tool. We will use it to result in the betterment of the entire region by creating new economic opportunities and jobs in eastern Colorado.
Sincerely yours,
Michael ReevesPresident
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
Mr. Andrew McGilvary Executive SecretaryForeign-Trade Zones BoardU.S. Department of Commerce 1401 Constitution Avenue, NW, Rm 2111 Washington, DC 20230
Re: Limon/Lincoln County Application to Establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework
Dear Mr. McGilvary:
The State of Colorado, through the Colorado Office of Economic Development and International Trade, supports the Town of Limon/Lincoln County application to Establish a Foreign Trade Zone Grant of Authority under the Alternative Site Framework in eastern Colorado.
This application is being submitted after an evaluation by the Town of Limon, Lincoln County and the other counties comprising the proposed Service Area. These counties are included in the Ports-to-Plains Alliance region, a growing economic transportation corridor that connects North America through 10 U.S. states and into Canada and Mexico. The proposed Zone District lies at the very center of this corridor that consists of four High Priority Corridors on the National Highway System, a designation included in the Moving Ahead for Progress in the 21st Century (MAP-21) approved by the U.S. Congress. Additional connections to the east and west are created by numerous highways including Interstate 70, Interstate 76 and U.S. Highway 50.
The establishment of a Foreign Trade Zone in eastern Colorado serves a region that is seeing significant business opportunities, especially in the energy sector. The Colorado Office of Economic Development and International Trade (OEDIT) works closely with international firms looking to establish or expand business operations in the United States. For example, Enbridge, a Canada-based company, is already doing business in Lincoln County.
The state of Colorado looks forward to your thoughtful consideration as you review and approve this application. Thank you in advance for enabling this service area to access this important economic development tool.
Sincerely,
Kenneth W. Lund Executive Director
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT III -- SUPPORT FROM LOCAL JURISDICTIONS
ATTACHMENT IV – GENERAL MAPS
Proposed Service Area
Complete Boundary
The service area boundaries are the following boundary:
Starting at the southwest corner of Adams County proceeding north along the entire western border of Adams County, then proceeding east along northern border of Adams County to its intersection with Morgan County border;
then proceeding north along the western border of Morgan County, then proceeding east along the northern border of Morgan County, then proceeding south along the eastern border of Morgan County to its intersection with the northern border of Washington County;
then proceeding east along the northern border of Washington County to Colorado Highway 63, then proceeding south along Colorado Highway 63 to the northern border of the Town of Akron, then proceeding along the border of the Town of Akron to the southern intersection with Colorado Highway 63 including all the Town of Akron, then proceeding south along Colorado Highway 63 to its intersection with the southern border of Washington County, then proceeding west along the southern border of Washington County to Colorado Highway 63;
then proceeding south along Colorado Highway 63 in Lincoln County to Interstate 70 including the entire border of the Town of Arriba, then proceeding south along Colorado Highway 63 to its intersection with Lincoln County Road 2W, then proceeding west along Lincoln County Road 2W to its intersection with U.S. Highway 40/287, then proceeding northwest along U.S. Highway 40/287 to the border of the Town of Hugo, including the entirety of the Town of Hugo, then proceeding south from the border of the Town of Hugo along Lincoln County Road 109 to its intersection with Lincoln County Road 2W, then proceeding west along Lincoln County Road 2W to its intersection with Colorado Highway 71, then proceeding south along Colorado Highway 71 to its intersection with Lincoln County Road 2X, then west along Lincoln County Road 2X to its intersection with the border of Lincoln County;
then proceeding west from the border of Elbert County line along Elbert County Road 34 to its intersection with Elbert County Road 137, then proceeding north along Elbert County Road 137 to its intersection with Elbert County Road 38, then proceeding west along Elbert County Road 38 to the Elbert County line, then proceeding north along the western border of Elbert County to its intersection with the border of Arapahoe County;
then proceeding west along the southern border of Arapahoe County to its southwest corner, then proceeding along the western border of Arapahoe County to the point of beginning.
Arapahoe�County
Morgan County
Washington�County
Adams County
Elbert County
Lincoln�County
Magnet Sites Regional Context
Magnet Site #1 – Big Sandy Local Context
Magnet Site #1 – Big Sandy Site Map -- Aerial
Magnet Site #1 – Big Sandy Site Map – Base
Magnet Site #2 – East Airport Local Context
Magnet Site #2 – East Airport Site Map -- Aerial
Magnet Site #2 – East Airport Site Map – Base
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341
26.1
646
49.5
224
17.2
715.
438
2.9
139
10.6
796.
045
034
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412.
99El
bert
8,38
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719
80.2
2,74
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949
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753.
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619
406
65.6
138
22.3
355
57.4
113
18.3
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49
1.5
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816
2.6
213
34.4
200
32.3
2.24
2.82
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Car
son
3,03
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64.4
849
27.9
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24.
784
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1,21
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orga
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7,20
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tero
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ips
1,81
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ers
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wick
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ashi
ngto
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1,29
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623.
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95Yu
ma
3,95
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430
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2.7
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931
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120
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Serv
ice
Are
a43
6,43
229
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433.
00
Hus
band
-wife
fa
mily
with
ow
n ch
ildre
n un
der 1
8 ye
ars
Mal
e ho
useh
olde
r, n
o wi
fe
pres
ent
Mal
e ho
useh
olde
r, no
wife
pr
esen
t with
ow
n ch
ildre
n un
der 1
8
Fem
ale
hous
ehol
der,
no h
usba
nd
pres
ent
Fem
ale
hous
ehol
der,
no h
usba
nd
pres
ent w
ith
own
child
ren
unde
r 18
Non
fam
ily h
ouse
hold
s
Tota
lH
ouse
hold
er
livin
g al
one
Fam
ily h
ouse
hold
s (fa
mili
es)
Tota
l
With
own
ch
ildre
n un
der 1
8 ye
ars
Hus
band
-wife
fa
mily
Ave
rage
ho
useh
old
size
Ave
rage
fa
mily
si
ze
Hou
sing
Occ
upan
cy
Hou
sing
Occ
upan
cyPr
ofile
of G
ener
al P
opul
atio
n C
hara
cter
istic
s: 2
010
2010
Dem
ogra
phic
Pro
file
Dat
a
Hom
eown
er
vaca
ncy
rate
(p
erce
nt)
Ren
tal
vaca
ncy
rate
(p
erce
nt)
Num
ber
Num
ber
%N
umbe
r%
Num
ber
%N
umbe
r%
Num
ber
%N
umbe
r%
Num
ber
%N
umbe
r%
Col
orad
o2,
212,
898
1,97
2,86
889
.224
0,03
010
.857
,644
2.6
3,05
80.
132
,673
1.5
5,41
80.
210
1,96
54.
639
,272
1.8
2.5
7.8
Ada
ms
163,
136
153,
764
94.3
9,37
25.
74,
083
2.5
188
0.1
2,30
91.
430
20.
235
30.
22,
137
1.3
2.2
7.2
Ara
paho
e23
8,30
122
4,01
194
.014
,290
6.0
6,41
92.
729
00.
13,
203
1.3
475
0.2
844
0.4
3,05
91.
32.
27.
4B
aca
2,24
81,
685
75.0
563
25.0
662.
91
0.0
180.
89
0.4
492.
242
018
.71.
412
.6B
ent
2,24
21,
832
81.7
410
18.3
964.
310
0.4
281.
227
1.2
331.
521
69.
62.
213
.4C
rowl
ey1,
559
1,30
683
.825
316
.230
1.9
00.
033
2.1
201.
324
1.5
146
9.4
3.4
7.4
Elbe
rt8,
939
8,38
093
.755
96.
356
0.6
120.
118
32.
031
0.3
720.
820
52.
32.
45.
3K
iowa
805
619
76.9
186
23.1
263.
21
0.1
121.
511
1.4
263.
211
013
.72.
712
.0K
it C
arso
n3,
527
3,03
886
.148
913
.910
83.
14
0.1
391.
124
0.7
451.
326
97.
61.
810
.9Li
ncol
n2,
420
1,94
880
.547
219
.597
4.0
20.
148
2.0
130.
550
2.1
262
10.8
3.5
12.9
Loga
n8,
981
8,04
789
.693
410
.430
03.
38
0.1
134
1.5
220.
292
1.0
378
4.2
2.4
10.4
Mor
gan
11,4
9010
,294
89.6
1,19
610
.434
73.
021
0.2
179
1.6
330.
326
92.
334
73.
02.
68.
7O
tero
8,96
97,
729
86.2
1,24
013
.833
13.
712
0.1
138
1.5
740.
865
0.7
620
6.9
2.6
10.8
Phill
ips
2,08
71,
819
87.2
268
12.8
502.
43
0.1
321.
58
0.4
401.
913
56.
52.
48.
8Pr
ower
s5,
942
4,93
583
.11,
007
16.9
307
5.2
130.
298
1.6
540.
969
1.2
466
7.8
2.9
15.5
Sedg
wick
1,41
51,
093
77.2
322
22.8
825.
82
0.1
201.
47
0.5
473.
316
411
.62.
520
.3W
ashi
ngto
n2,
434
1,98
081
.345
418
.799
4.1
30.
136
1.5
341.
445
1.8
237
9.7
2.4
15.2
Yum
a4,
466
3,95
288
.551
411
.585
1.9
100.
246
1.0
350.
877
1.7
261
5.8
1.7
6.3
Serv
ice
Are
a46
8,96
143
6,43
293
.132
,529
6.9
12,5
823.
258
00.
16,
556
1.5
1,17
90.
72,
200
1.6
9,43
27.
72.
410
.9
Cou
nty
Tota
l ho
usin
g un
itsO
ccup
ied
hous
ing
units
Vac
ant h
ousi
ng
units
Vac
ant h
ousi
ng u
nits
For r
ent
Ren
ted,
not
oc
cupi
edFo
r sal
e on
lySo
ld, n
ot
occu
pied
For
seas
onal
, re
crea
tiona
l, or
occ
asio
nal
All
othe
r va
cant
s
Hou
sing
Ten
ure
Hou
sing
Ten
ure
Prof
ile o
f Gen
eral
Pop
ulat
ion
Cha
ract
eris
tics:
201
020
10 D
emog
raph
ic P
rofil
e D
ata
Num
ber
Num
ber
%N
umbe
r%
Col
orad
o1,
972,
868
1,29
3,10
065
.52.
5767
9,76
834
.52.
34
Ada
ms
153,
764
101,
041
65.7
2.87
52,7
2334
.32.
80A
rapa
hoe
224,
011
143,
520
64.1
2.60
80,4
9135
.92.
42B
aca
1,68
51,
227
72.8
2.22
458
27.2
2.14
Ben
t1,
832
1,22
466
.82.
3160
833
.22.
41C
rowl
ey1,
306
930
71.2
2.36
376
28.8
2.51
Elbe
rt8,
380
7,38
288
.12.
7499
811
.92.
81K
iowa
619
429
69.3
2.24
190
30.7
2.23
Kit
Car
son
3,03
82,
160
71.1
2.39
878
28.9
2.32
Linc
oln
1,94
81,
297
66.6
2.32
651
33.4
2.19
Loga
n8,
047
5,46
067
.92.
392,
587
32.1
2.22
Mor
gan
10,2
946,
691
65.0
2.72
3,60
335
.02.
61O
tero
7,72
95,
019
64.9
2.42
2,71
035
.12.
31Ph
illip
s1,
819
1,30
671
.82.
4651
328
.22.
27Pr
ower
s4,
935
3,27
966
.42.
541,
656
33.6
2.36
Sedg
wick
1,09
377
370
.72.
1932
029
.32.
04W
ashi
ngto
n1,
980
1,43
172
.32.
3054
927
.72.
44Yu
ma
3,95
22,
688
68.0
2.47
1,26
432
.02.
53Se
rvic
e A
rea
436,
432
285,
857
65.5
2.44
150,
575
34.5
2.39
Cou
nty
Tota
l
Ren
ter-
occu
pied
hou
sing
O
wner
-occ
upie
d ho
usin
g un
itsO
ccup
ied
hous
ing
units
Ave
rage
ho
useh
old
size
of
rent
er-
occu
pied
un
its
Ave
rage
ho
useh
old
size
of
owne
r-oc
cupi
ed
units
Tota
l
Med
ian
Hou
seho
ld In
com
e
Med
ian
Hou
seho
ld In
com
ePr
ofile
of G
ener
al P
opul
atio
n C
hara
cter
istic
s: 2
010
2010
Dem
ogra
phic
Pro
file
Dat
a
Inco
me
Col
orad
o$5
6,08
9
Ada
ms
$56,
089
Ara
paho
e$5
9,93
7B
aca
$37,
111
Ben
t$3
5,66
7C
rowl
ey$4
0,63
6El
bert
$79,
367
Kio
wa$4
1,54
2K
it C
arso
n$4
3,19
4Li
ncol
n$4
3,37
5Lo
gan
$42,
324
Mor
gan
$42,
792
Ote
ro$3
1,24
6Ph
illip
s$4
4,71
7Pr
ower
s$3
4,51
3Se
dgwi
ck$3
6,79
7W
ashi
ngto
n$4
3,94
5Yu
ma
$44,
991
Serv
ice
Are
a$4
4,60
3
Attachment VI – Port-to-Plains Map
ATTACHMENT VII - SITE-SPECI IC C MENTS
Magnet Site o. 1 ig Sandy
Approved evelopment lan
Magnet Site o. 1 ig Sandy
Resolution o. 14 04 16 Approval of evelopment lan
Magnet Site o. 1 ig Sandy
rdinance o. 72 oning for ig Sandy Addition
Magnet Site o. 2 East Airport
Approved evelopment lan
Magnet Site o. 2 East Airport
Resolution o. 14 04 17 Approval of evelopment lan
Magnet Site o. 2 East Airport
rdinance o. 73 oning for ig Sandy Addition