COMMENT:  The adopted Stormwater Management Plan contains no provisions for prevention of nonpoint  source pollution from entering the waters of the State.  To the contrary, it specifically plans for stormwater to be emptied into Munsel Creek, which is designated on the map as a “channel”.

COMMENT:  The expansion of the UGB will encourage more development, which will result in more stormwater runoff being directed to the stormwater system - i.e., Munsel Creek.  The draft Stormwater Management Plan has even designated Munsel Creek as a “channel”.  If too much runoff pollution is funneled into Munsel Creek, which empties into the Siuslaw River, it is to be expected that the State will require remedial action, at the Florence taxpayer’s expense.

COMMENT: The draft Stormwater Management Plan does not address the impact differences between commercial, industrial and residential zoning as it relates to nonpoint pollution of ground and surface water, and increased stormwater runoff which will effect Munsel Creek.  For example, a developed city block produces nine times as much stormwater runoff as does an undeveloped area because of the impervious surfaces involved.   Additionally, many of the flooding problem areas are directly “upstream” from city well fields.  If the city’s well field is contaminated from urban nonpoint pollution, a considerable
expense by the taxpayers would be necessary for clean-up, additional treatment facilities,  and/or relocation of the city wells. (See Document 5-3)

COMMENT: The Plan has not addressed the following impacts on the community: decreased air quality, decreased water quality, increased rates of natural resource consumption, lost open space and resource lands, lost visual and other amenity values, lost wildlife habitat, increased noise, lost mobility due to traffic congestion (delays and increased commute time), higher cost of housing,  higher cost of living, increased crime, lost sense of community, increased regulation (loss of  freedoms), costs to future generations which will result from the planned expansion of the UGB, creation of the North Florence Commercial Area, and creation of the LI/C zoning.

COMMENT: The Goal should be as indicated in the State Goals.

Suggested Language: Page 67, Goal - To maintain and improve the quality of the air, water and land resources of the City.

COMMENT:  The objective, as stated, does not comply with State goals and guidelines, in that it makes no reference to discharges from existing developments.

Suggested Language: Page 67, Objectives: To maintain and improve the quality of the air, water and land resources through control of waste and process discharges from present and future development.

(Also See Specific Comments)

COMMENT: The Housing Opportunities section  is inconsistent with the Land Use, Residential section in that it is based on existing housing, not existing residential zoning.

COMMENT: The provision of “opportunities and conditions” does not comply with the Statewide Goals. The purpose of the Statewide Goal for housing is to meet the housing needs of the citizens, not the needs of the developer for cheap, vacant land or development opportunities subsidized by the taxpayers.

COMMENT: There is no evidence which supports the conclusion that the city is “rapidly approaching buildout”.  The infamous “local builder” mentioned on page 80, paragraph 3 could just as likely have relocated to Veneta because there were no more dirt cheap vacant lots in previously developed subdivisions.  Likewise, the “increasing number” of building permit applications on marginal or scattered lots could be due to the fact that the economy is such that the financial resources needed for development of large subdivisions or PUDs is more difficult to come by.  It could also be due to the fact that the housing market in Florence is saturated. (See listing inventories table below)  As there is no current residential
lands analysis, it is impossible to determine what trends are being experienced by the area, or the reasons behind them.  (Document 10-2)  MLS Listing Inventory - Single Family Dwellings:
 

MLS Listing Inventory - Florence	July 1999	July 2000	July 2001
Single Family Dwellings	390	376	384

COMMENT:  The Plan is replete with language which infers that a “limited supply” of residential lands is justification for expansion of the UGB.  However, every city in the state has a “limited supply” of residential lands by virtue of their city limits boundary.  Absent a needs analysis, the City is trying to make decisions based in inaccurate or unsubstantiated  information. In fact, the Plan so states: “Before the City can take informed action to deal with the limited supply of residential lands, a new residential land use analysis must be completed.”  (Page 80, Background, paragraph 4)

(Also See Specific Comments)