Florence Planning Commission
P.O. Box 340
Florence, Oregon 97439

RE: Resolution 01-01-09-04
          Annexation of 52,85 acres located west of Highway 101 commencing immediately north of the city limits Saubert, Merritt, Matthews, Sherman, Ryall, Higginson

Dear Commissioners:

Florence does not have sufficient water supplies

Attached are sections from an application from the City of Florence to the Oregon Water Resources Department for water permit for five new wells, received by the State on November 6, 2000.  That application clearly states:

     “B.  How long is the amount of water requested in this application expected to meet future needs?
     (City’s answer:) Water requested is not sufficient to meet future needs.  Water will be used to reduce water purchases from Heceta Water District during peak demand flows.”  (Form M, page 2)

The permit application indicates that the city intends to begin construction on May 1, 2001, and they expect water use will begin August 16, 2001.  But as of January 19, 2001, the City had not “officially” filed their water rights permit application.  According to staff at the Oregon Water Resources Department, the City was notified that their application was not being “filed”  because certain documents were missing from the application.   The permit application process cannot begin until the application is “filed”.  The City’s engineers optimistically ventured that the permit process would typically take from 270 to 300 days. (11/2/00 Brown and Caldwell letter).   The City’s schedule for the well field expansion shows they expect the Water Use Permit to be granted June 4, 2001.

Even if the City’s application was properly filed on January 20, it would be at least September or October before the permit could be issued, at best.  Oregon Department of Water Resources staff is less optimistic, indicating in a recent phone conversation that most applications take between a minimum of six months and two years - if there are no objections or appeals.  One application, which faced opposition by a community group, actually took nine years before a hearing was even held.

The City cannot award a construction contract until they receive the water rights permit.  If they do not receive the permit until October 2001, then the very earliest the new wells could be on line would be February 2002.  As  the application to the Water Resources Department (see attached map) indicates that the City plans to locate the new wells inside this property next to roads and houses, it is extremely likely that objections to the granting of the permit will be raised by environmental or other organizations, and this would further extend the time before full production could be expected.

And the planning commission should keep in mind, that these five new wells will not meet the
city’s current needs for water.  As the application states, they will only reduce the amount of water needed to be purchased from Heceta Water District.

Other Residential Lands Available
Although submitted in another annexation, the comments of the Florentine Estates Homeowners Association regarding no demonstrated need for additional single-family residences and inadequate water supply  apply to this request for annexation, as well.  I have therefore attached their statement to this letter.

Thank you,

Zane Ziemer, President

Attachments:
 11/2/00 Brown and Caldwell Letter to OWRD
 Form M, Request for Water (Received 11/6/00 at OWRD)
 Map showing well field location inside proposed annexation area
 1/3/01 Florentine Estates Homeowners Association Comments