The findings also failed to address risks to migratory birds and wildlife. Large open water impoundments, including produced water ponds, are well-documented hazards for migratory birds and waterfowl. Yet the findings contain no assessment of bird use in the region, no analysis of how expanding from 2 to 5 ponds increases exposure risk, and no findings connecting wildlife impacts to land use compatibility or public welfare. Wildlife resources are central to this region's economy and cultural identity, and failing to evaluate those impacts is failing to address a core public welfare concern. I also want to address a closely related defect in the April 2nd approval.

The findings do not evaluate the economic and long-term public welfare risks that come from expanding this facility from 2 to 5 ponds. Section 813.4 does not limit the county's analysis to immediate operational impacts. Impact. It actually requires a forward-looking determination based on evidence that the approved use will not be detrimental to public welfare over time. The record shows that the existing business arrangement supporting the facility is nearing the end of its permit term.

The findings contain no analysis of renewal risk, market demand, or the realistic duration of use associated with expanding long-term produced water storage from 2 homes to 5. With a 200-acre wastewater footprint. This omission matters. Large industrial wastewater facilities are not easily reversible uses, particularly in rural areas. When drought- when throughput declines or contracts change, it is often the county and surrounding community that bear the long-term consequences in the form of stranded infrastructure, degraded land, and ongoing enforcement operations.

Approving a major expansion without addressing those foreseeable risks fails to satisfy the preventative public welfare standard imposed by the code. The economic risks also intersect directly with county capacity. A substantially larger facility increases the scope, frequency, and duration of county oversight related to liner integrity, leak detection systems, stormwater controls, odor management, and spill response. Yet the findings do not analyze whether those ongoing burdens are compatible with rural use. With rural service capacity or with the stated purpose of the A-5 Agricultural Zoning District, which is intended to preserve agricultural land rather than host long-term scale industrial wastewater operations.

Finally, none of these environmental and economic risks were evaluated cumulatively. The record shows that this facility operates in direct support of regional oil and gas development and alongside other energy-related uses in the same port- port- Even if individual facilities comply with separate regulatory regimes, land use compatibility analysis requires examining how these uses function together on the ground. For these reasons, Commission failed to meet specific evidence-based findings required to address the known risks inherent to large-scale produced water