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r <br />E <br />Attorney Vitunac noted for the record that Mr. Lappeman is <br />reading from his own position at the lower level, and, therefore, <br />is not presenting new evidence here. The fact that it is in the <br />Appeal_ of Decision doesn't mean it is true. <br />Director Boling advised that Section 23.2 (a)(10) <br />specifically adds a requirement that acreages and boundaries be <br />identified. <br />Commissioner Eggert pointed out that we would have to <br />quadruple our staff if everything that was submitted was reviewed <br />before it was ready to be reviewed. It would be an impossible <br />thing, and that is one of the reasons why such rigid requirements <br />were set. <br />Director Boling stressed that staff is just saying that we <br />need that information at the actual time of review, and Mr. <br />Lappeman asked if staff has that information at the present time. <br />Director Boling believed that what was submitted on October <br />30th would have been complete enough to route it for review under <br />the old LDRs, but it missed the deadline of October 10th. Staff <br />sent a letter out on October 1st and we didn't hear again until <br />October 30th. <br />Mr. Lappeman stressed that three quarters of the submittal <br />was correct, and just because one item wasn't doesn't mean that <br />the whole application wasn't in by that date. He felt that too <br />much importance is being placed on the tail end of this matter. <br />Commissioner Scurlock likened it to your income tax where it <br />is not considered filed until you sign it. <br />Chairman Bird felt there has been acknowledgment that a <br />certain amount of the application was in and was sufficient to <br />start the review; however, certain important aspects were <br />missing, and the package wasn't complete and the review could not <br />start. In his opinion, Mr. Lappeman has not overturned the <br />position of staff that the submittal does need to be in a certain <br />complete form in order for them to start the process and trigger <br />that starting date. Further, the engineers were notified that it <br />wasn't complete and we didn't get their response by the October <br />10th deadline. <br />Mr. Lappeman stated that it was difficult for him to accept <br />or acknowledge that after such a thorough and important survey, <br />the submittal is regarded as not good enough. In his opinion, <br />this presentation is quite unique. <br />Commissioner Scurlock felt that the real answer here is that <br />all this information now can be put in proper form and <br />resubmitted for review under the new LDRs, but Mr. Lappeman <br />stressed that with the new submittal he wouldn't be grandfathered <br />26 <br />