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

kipp@parkerag.com

PORTS-TO-PLAINS ALLIANCE5401 N MLK BLVD. #395

LUBBOCK, TX 79403 806-775-2338

MICHAEL.REEVES@PORTSTOPLAINS.COM

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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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