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

     RE:  Draft Comprehensive Plan

Dear Commissioners:

Portions of the draft Comprehensive Plan has come to our attention as not being in the best interest of the Florence community, and failing to comply with Oregon Land Use Goals and Guidelines.

1.   We would propose that the zoning designation for the area north of Florence not be
approved at this time.  Our reasoning for this proposal is as follows:

     A.  The draft comprehensive plan does not comply with Oregon Land Use Goal 2,
     Land Use Planning, Part I, paragraph 3, in that it does not address:

      “All land use plans shall include identification of issues and problems, inventories and
     other factual information for each applicable statewide planning goal, evaluation of
     alternative courses of action and ultimate policy choices, taking into consideration
     social, economic, energy and environmental needs.”

Social Impacts not addressed: Degradation of the downtown if businesses do not relocate and
market pressure converts those lands to commercial/retail property.  Degradation of Florence’s attractiveness thus diminishing its small-town appeal for the tourist trade, as well as a home for retirees.

Economic Impacts not addressed: Degradation of Florence’s attractiveness thus diminishing its
small-town appeal for the tourist trade, as well as a home for retirees.  Increased costs to existing to taxpayers (many of whom are on fixed incomes) for road construction, traffic lights, police, stormwater removal, domestic water supply (more well fields needed).  Reduction in value of existing commercially zoned land due to over-saturation of the commercial land inventory.  Reduction of property values for those who live along Munsel Creek due to increased flooding and erosion.

Energy Impacts not addressed: Increased use of vehicles to reach commercial development in the northern end of Florence.  Increased use of electrical energy to maintain more commercial
development in the area.

Environmental Impacts not addressed: Stormwater runoff.  Degradation of Munsel Creek and
surrounding riparian areas and wetlands.  Inadequate water supply to accommodate large
commercial business.  Increase in auto exhaust pollution, stormwater runoff pollution, non-point source pollution, groundwater pollution.

     B.  The re-zoning proposal for the area north of Munsel Lake Road was not discussed
     during public meetings.  Details about stormwater, traffic flow, pedestrian and vehicle
     access have not been discussed by the planning bodies.

2.   The City has not prepared any implementation measures as suggested by Guideline A.  The City has identified the plan in a general manner, but it has not dealt with “the specific provisions for dealing with these issues” (Guideline A, paragraph 1).  The “various implementation measures which will be used to carry out the plan” (Guideline A. Paragraph 2) have not been considered.

3.   The City has not allowed sufficient time for at least two of the four provisions under Guideline A. paragraph 3:

     A.  Collection of necessary factual information.  The need for more commercial lands
     has not been verified.  It has not been determined how much land is actually needed for
     the three or four businesses that are being considered for relocation to the Limited
     Industrial/Commercial District.

     B.  Gradual refinement of the problems and issues and the alternative solutions and
     strategies for development.  There was very little discussion in the plan or supporting
     documents  regarding alternative solutions.  It has been stated that the industrial park
     lots are too small for industrial use, and being saved for “technical” industry.  The
     questions still remain: How much land will the businesses need for relocation?  Will
     there be a need for lot consolidation along Hwy. 101 to accommodate them?  If lot
     consolidation is needed on Hwy. 101, then why would lot consolidation not be feasible
     in the industrial park?  Is there any indication that the businesses have any interest in
     moving?  Plan policies and zoning codes are not currently worded to ensure that the
     objectives of attracting the heavy commercial uses to locate away from the downtown
     to spur redevelopment are met.  The free market will not accomplish this without clear
     and strong direction from the city.
 

4.   The need for more commercial and industrial land in the proposed “North Florence Commercial District”, “Limited Industrial/Commercial District”, and “Neighborhood Commercial Gateway District”, has not been justified.

5.   The proposal has not been adequately evaluated in terms of the transportation planning rule OAR 660-122-0060 provisions and whether the proposed land uses are consistent with the intended classification of the Highway.

6.   Major plan amendments such as these must be coordinated with Oregon Department of
Transportation and Department of Land Conservation and Development.  Goal 2, Guideline A. 4. States: “Sufficient time has not been given for identification and resolution of possible conflicts with plans of affected governmental units”.

7.   The plan does not comply with Goal 2.G., “Implementation guidelines should relate primarily to the process of carrying out the goals once they have been incorporated into the plans.  Techniques to carry out the goals and plans should be considered during the preparation of the plan.”  There is no language which will ensure that the objectives of attracting the heavy commercial uses to locate away from the downtown to spur redevelopment are met.

8.   Re: extension of Spruce Street.  Although contained in the plan, it is common knowledge that the City does not intend to extend Spruce Street north to Munsel Lake Road.  There are no plans for sidewalks, bike lanes, etc. on the street that is planned to connect between Spruce Street and Munsel Lake Road, so it will not be a “full service” street to ease congestion on Hwy. 101.  See attached letter to ODOT re: Oak Street extension from CFF.  The same arguments apply to the proposed Spruce Street extension.

9.   Re: It is common knowledge (and stated in public meeting by city representatives) that the
proposed 18th Street extension contained in the Transportation System Plan will not be carried out, and was placed in the comprehensive plan for the exclusive reason of justifying the Urban Growth Boundary expansion at Ocean Dune Golf Links.

10.  The draft does not contain the necessary elements for a Transportation System Plan such as roadway, bicycle, pedestrian and transit mode plans, needs analysis, project locations, cost and jurisdiction responsibilities, model results, model assumptions for population and employment growth in each transportation analysis zone.

11.  The draft does not comply with Goal 9, Guideline A, 2., 4, 5.  Re-zoning and encouragement of commercial growth along Hwy. 101 directly controverts the goals and needs of the Florence “downtown” area.

12.  Encouraging strip development north along Hwy. 101 is not in the best social and economic interest of the residents of Florence.

13.  Encouraging strip development north along Hwy. 101 will directly, detrimentally effect the
Downtown Development Plan, which supports redevelopment and expansion of existing businesses.

14.  Development north of Munsel Lake Road should not be allowed until all necessary infrastructure and public facilities (roads, sewer, water supply, etc.) is in place.  Language such as: “Adequate public facilities and streets to serve proposed development must be assured prior to development.” should be included in the comprehensive plan.

15.  The draft plan does not address the city’s inability to provide sufficient water for more
commercial or residential growth.  The current supplementation provided by Heceta Water District is restricted to 1 million gallons per day, except with express annual written permission of one individual.  While the permission has been granted in the past, there is no guarantee that permission will be granted in the future.  If permission is denied in the future, the City will be limited to the 1 million gallon per day supply from Heceta Water District, absent considerable expense and upgrading of the City’s existing water supply system, which is not addressed in the comprehensive plan.

16.  The Stormwater Management Plan, which is referred to as thought it were a completed, and implementable, project is still in preliminary draft stages.  Any re-zoning based upon the premise that the Stormwater Management Plan, as drafted and unadopted, will address future stormwater runoff issues of the property should be deleted.  Any plans dealing with the area north of Munsel Lake Road should be delayed until after acceptance and implementation of a Stormwater Management Plan which deals with this area - which the current draft does not.

17.  The Transportation System Plan must be based on the planned land uses, population and
employment distributions, not on existing data.  The proposed land use changes must be considered, and findings must be made which demonstrate that the proposed changes are consistent with the TSP.

18.  The public was not given 30 days to review the Transportation System Plan, as provided by law.  The plan was not available to the public until May 25, 2000.  The public hearing on the TSP is scheduled for June 15, 2000.

The above comments are based on a preliminary review of the draft comprehensive plan.  We will submit further comments at subsequent public hearings.  Attached are the following, which are incorporated in this testimony: (1) 5/22/00 letter from myself to Oregon Department of
Transportation, (2) 4/7/00 letter from Oregon Department of Land Conservation and Development to Sandi Young, Planning Director, City of Florence.

(signed)
Zane Ziemer
President