This afternoon I met with GMD4 board in executive session and after 2-1/2hrs they decided the industrial permit will be issued on the basis of no provisions being included in the LEMA allocations to say it can't be done.
Not going to lie, I've spent the last 2 weeks prepping for what I knew might not be possible in a IGUCA (Intensive groundwater unit control area). It took the Lawyer setting in to explain they could not help but allow my request because the language was not written in to the LEMA program.
I got it, it's mine permanently but will never be granted again in a LEMA district.
I got lucky but it's done.