COMMENT: No standards have been developed for the amount, distribution and type of open spaces needed, contrary to Goal 5 Planning Guidelines.

COMMENT:  The Plan has not adequately addressed:
     1.   The impact on Munsel Creek from the proposed Stormwater Management Plan in terms of water quality and quantity;
     2.   Recent application for water rights which Water Resources Department has determined will effect the levels in Munsel Creek; or
     3.   The proposal by the City (to Water Resources Department) to pump water into Munsel Creek during the fall should also be addressed.

COMMENT:  Information should be added which details that the wetlands inventories were conducted following a “drought” period when rainfall averaged 65" (according to the City Wetland Report).  The 1999  annual rainfall was 102".   The following rainfall information, from the Oregon Climate Service (and National Weather Service) should be included in the comprehensive plan to illustrate the significant rainfall differences which can occur during a 20-year planning period.
 

A. WETLANDS
Page 42

COMMENT: The wetlands inventory is certainly not complete, and actual on the ground inventories should be conducted prior to approval of any development projects.  Many areas which would be defined as “wetlands” were missed in the inventory because property owners would not give permission to inventory their land.  Those properties were “inventoried” by flying over the area in a plane - not a very reliable method of determining the existence of wetlands.

COMMENT: Over time, and often as a direct result of development, wetland areas change - disappearing in some places, appearing in others.  There should be a provision in the Plan for a periodic updating of wetland inventories.

COMMENT: All too often in the past, homes and businesses have suffered from stormwater runoff flooding caused by development of an “upstream” property.  Often the offending property was previously a stormwater retention area, and during development, re-routing of the natural stormwater drainage was allowed.

Suggested Language: Page 43, Policy 3 - No significant wetland shall be drained or altered by
re-routing of natural drainage ways or from groundwater drawdown except for that which might occur as part of a natural or catastrophic event.

C. GROUNDWATER
Page 47

COMMENT:   The Plan has not adequately addressed protection of the North Florence Dunal Aquifer in that it offers only minimal protection in discrete areas around proposed well sites, and ignores warnings contained in the Periodic Review Work Task #1 Urban Growth Boundary Study  about contamination of the aquifer.  For example, the City, at one time, had proposed locating a well field in the dunal area known as Cannery Dune.  Then it allowed development of the Fred Meyer retail complex, complete with injection well type stormwater system and gasoline storage tanks.  This development will in all likelihood preclude
municipal well development in the dunes due west, because of the direction of the groundwater flow.  The City’s current proposed location for a new wellfield, north of the existing field, may conflict in the future with the heavy residential use proposed in the properties to be annexed and the UGB expansion area.  This lack of planning will ultimately cost the residents of Florence in decreased drinking water quality and/or increased cost for treatment of that water. See map of groundwater flow in North Florence Dunal Aquifer Document 5-3.

H. SCENIC RESOURCES/VISUAL QUALITY
Page 61

COMMENT: Lane County has a number of acres of open space located within or near the City, and these lands should be included in the City’s planning, the Cannery Dune being the most visible from Hwy 101 (See Document 5-2)
Suggested Language: Page 61, Objectives - 5. To work with county, state and federal agencies to provide for the continuation of scenic resources on their lands.

COMMENT:  If the City is to retain scenic view land (detailed on Map 5H-2) as “public”, then access by the public should be provided, and retained. The areas referred to are the northwest corner of the Pacific View Industrial Park and an area near the water tower at the end of Kingwood Street.

Suggested Language: Page 62, Policies - 3. The City shall retain ownership of City owned lands outside platted subdivisions, which provide scenic viewpoints.  These lands are shown on Map 5-H2.  The City shall restrict development in these two areas, as necessary, in order to provide for access by the public to the scenic viewpoints.  This shall include, at a minimum, retention of an area for vehicle parking and an area for the public to use the viewpoint.

I. HISTORIC RESOURCES
Page 65

COMMENT: Although a list of historic buildings is included, there are no protecting these structures from destruction.  The Planning Commission recognized this issue in their draft, where they stated: “Proposed demolition of a historic structure can be problematic if there is no buyer who wishes to maintain the structure as an historic structure or if the structure is proposed to be demolished to allow another use.  Cities with Historic Districts have a process in their codes for dealing with these situations.”

Suggested Language: Page 65, Policies - 5.  The City shall prepare a plan for
retention/rehabilitation of historic buildings included on the List of Historic Buildings,
including funding resources for implementation of the plan.

(Also See Specific Comments)