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Appeal of RPC Vote Decision Findings.pdf - Humboldt County

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STATEMENT OF FACTS<br />

1) Jungo Land & Investments, Inc. ("Jungo") requested a five (5) year extension <strong>of</strong> the<br />

Conditional Use Permit (CUP), # UH-07-05, which was issued to Jungo Land & Investments,<br />

Inc. ("Jungo") by the Regional Planning Commission (<strong>RPC</strong>) on or about April 12, 2007. On<br />

February 11, 2010 the <strong>RPC</strong> granted Jungo a five (5) year extension <strong>of</strong> the CUP.<br />

2) Jungo argued that good cause exists for granting the extension due in substantial part<br />

because <strong>of</strong> citizen opposition to the landfill, lawsuits, political pressure from elected <strong>of</strong>ficials,<br />

and a slow regulatory permitting process. Jungo argued (unfortunately successfully) that it has<br />

been "prevented from timely obtaining the permits it needs to satisfu the condition <strong>of</strong> the CUP<br />

and to commence operation <strong>of</strong> the Jungo Landfill." Prevented! (Page 4 <strong>of</strong> January 19th, 2010<br />

letter <strong>of</strong> Frankovich, attached hereto and marked "Exhibit A").<br />

3) Appellants and other citizens requested that the <strong>RPC</strong> either deny the request <strong>of</strong><br />

Jungo, or grant the extension on condition that Jungo perform an environmental report or<br />

"environmental impact statement" or the like. The <strong>RPC</strong> granted the extension without any<br />

conditions. The <strong>RPC</strong> also granted the extension as Jungo stonewalled inquiry by a member <strong>of</strong><br />

the <strong>RPC</strong> about the water rights to be acquired by Jungo for the project.<br />

4) Among other open and unanswered questions by the <strong>RPC</strong>, Jim French, a former<br />

employee with the State <strong>of</strong> Nevada, reminded the <strong>RPC</strong> that no agency <strong>of</strong> State or local<br />

govemment has yet to analyze the impact the landfrll would have on wildlife in the area <strong>of</strong> the<br />

landfill.<br />

5) Ron Johnny, a member <strong>of</strong> the Summit Lake Paiute Indian Tribe, who is the Director<br />

<strong>of</strong> the Environmental Protection Department <strong>of</strong> the Summit Lake Paiute Tribe, argued that the<br />

landfrll would prevent and/or substantially interfere with Northern Paiute's ability to use the

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