COMMENT:  The Plan does not provide adequate protection of future well fields or groundwater quantity and quality in that it encourages more residential development directly “upstream” of existing or proposed well fields, does not provide adequate buffer zones “upstream” of existing or proposed well fields, and has provided no analysis of possible impacts of encouraging residential, industrial and commercial development “upstream” of existing and proposed well fields.  (Document 5-3)

C. STORMWATER MANAGEMENT
Page 85

COMMENT: The Stormwater Management Advisory Committee drafted an ordinance to implement the Stormwater Management Plan.  That ordinance was subsequently approved by the Planning Commission and reviewed and changed by the City Council.  The ordinance has sat on the shelf since that time.  If the City truly intends to adopt any implementing measures to deal with stormwater issues, the ordinance should be included in the Comprehensive Plan.  (See Document 11-1)

Suggested Language: Include the Stormwater Management Ordinance as part of the
Comprehensive Plan update.

D. PARKS, RECREATION AND OPEN SPACE
Pages 87-92

COMMENT: The Background section, at page 90, paragraph 2, indicates there is a Parks Capital Improvement Plan which was adopted by the City Council in 1998.  However, the list of Appendices shows only a Planning Report from 1987.  There is no Parks Capital Improvement Plan in this draft of the Plan.

COMMENT:  Page 92, Table 11-D2 - This table shows 1988 statistics. If the report in 1988 indicated deficiencies in neighborhood and linear parks, and a near term need in community parks.  Since there have been no new park lands added to the inventory, and Florence’s population has increased from 5,020 to 7,340 since that time, then an accurate assessment of Florence’s parkland needs would show increased deficiencies.

Suggested Language: Update the 1988 assessment of needs for parks, and revise the
comprehensive plan accordingly.

COMMENT:  Page 92 - The commentary discusses the elements of Part II of the Technical Report and Action Plan - but that plan was not adopted. Inclusion in the Comprehensive Plan of commentary about documents which were not adopted in the past, and are not being adopted during the periodic review, serve only to mislead and confuse.

Suggested Language: Delete this discussion from the Plan, or add language setting a time schedule for adoption of an appropriate Plan.

COMMENT:  The 1988 Comprehensive Plan included Recommendation 11. “A 20 year park system plan should be maintained and periodically updated to guide the enhancement and expansion of the Florence Parks System.”  In the 13 years since that Plan was adopted, the City has failed to follow up on that recommendation.  A Parks System Plan should be adopted and implemented as part of this periodic review.

Suggested Language: Parks, Recreation and Open Space, Policies 11.  A 20 year park system plan shall be maintained and periodically updated to guide the enhancement and expansion of the Florence Parks System before any parks improvements are implemented.

COMMENT: Page 91, paragraph 3 states that the projected 2020 population is 12,771.  This figure does not relate to any figures provided in the population projection Table P-2.

F. PUBLIC SAFETY
Pages 96-97

Comment: Policy 5 states that the Western Lane County Emergency Management Plan is included in Appendix 11.  The list of appendices does not list this document.

(Also See Specific Comments)

CHAPTER 12 - TRANSPORTATION
OAK STREET EXTENSION

COMMENT: The proposed transportation plan relies heavily on the extension of Oak Street north of 35th as an “minor arterial”, and south of 35th as a “collector”.

COMMENT: The City’s application to ODOT for grant money states that Oak Street between 21st and 37th will be a “full urban section including bike lanes and sidewalks.” (Document 12-14).    The Plan indicates the Oak Street extension north of 35th will be a “minor arterial, which is characterized by “A three lane roadway section.”  The minimum configuration for an arterial (Figure -1, Transportation System Plan, Proposed Street Standards) shows sidewalks and bike lanes on both sides of the street.  The City’s July
19, 2001 preliminary design calls for two 12-foot travel lanes, two 6-foot bike lanes, 5-foot sidewalks on both sides, with some sections being only 50 feet wide (Document 12-7).  The City is contemplating construction of sidewalks on only one side of the street.  These inconsistencies must be addressed. (Documents 12-7, 12-9, 12-13, 12-14, 12-17, 12-18)

COMMENT:   Document 12-3 offers an explanation for this obviously  ill-planned proposal.  The City and Oregon Department of Land Conservation and Development (DLCD) “made a deal” on October 14, 1997.  ODOT agreed to refrain from objecting to a city project, and in return the City agreed to extend Oak Street. (Documents 12-3 and 12-4)

“THE AGREEMENT ...DLCD Appeal: DLCD staff agreed that, pending approval from the
department, DLCD would not appeal a local decision to approve the re-designation, given that #2, above, occurs.”  (Note: The local decision dealt with development of the Fred Meyer store and the proposed Outlet Mall.)

(#2 above) “ 2. The City staff agreed to pursue an amendment to the text of the Florence
Comprehensive Plan at the time the City Council takes action on the Comprehensive Plan map
amendment for the factory outlet mall site.  The text amendment would be to add a  policy to the effect that the City shall plan a connected local street network parallel to Highway 101 ...  to prevent all traffic from accessing Highway 101 at a single location; ... Extension of Oak and Spruce Streets will be considered as alternatives to achieve these objectives.”  (See Document 12-3)

This is hardly an adequate basis for transportation planning.  This type of “planning” is counter productive, fllies in the face of public participation goals, and weakens our local economy  through expenditure of tax moneys on inefficient, unproductive and wasteful projects.

COMMENT: Planning for use of Kingwood Street, instead of extension of Oak Street would: provide more commercial land for future growth, provide an incentive for the sale of all that, city-owned land on Kingwood, reduce our tax burden through the sale of the city-owned land,  eliminate the need to extend Oak Street (estimated at $3.57 million for just a portion); eliminate the need to pay for new storm sewer system on Oak Street to serve the north Florence area; protect our children from increased traffic in front of their schools; allow locals to shop locally, without having to fight tourist traffic on Hwy 10; enhance the livability of Florence. (Document 12-10)

OAK STREET 15TH TO 21ST

COMMENT: Oak Street, between 21st and 35th, runs in front of every school in Florence.  It is already evidencing too much traffic, and the community is trying to add more stop signs and slow traffic down even more.  (See Documents 12-5, 12-6, 12-10, 12-16)

COMMENT: The Plan calls for extension of Oak Street from 15th to 21st.  This extension would destroy a well-used pedestrian and bicycle path which runs the length of Miller Park, the most popular park in Florence.   It is common knowledge in the community that the City has no intention of actually doing this, and that the only reason this is in the Plan is to placate ODOT. (Documents 12-10, 12-15, 12-18)

18TH STREET EXTENSION

COMMENT:  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.

COMMENT:   The Plan does not address the probability that commercial truck deliveries will be using North Fork Siuslaw Road/Munsel Creek Road as access to the North Commercial Node - and the resulting impact on the residential area all along Munsel Creek Road.

SPRUCE STREET EXTENSION

COMMENT:   There are two crucial elements of the proposed Transportation Plan - Oak and Spruce Streets running parallel to Highway 101 in order to direct local traffic off the State highway.  However, there is no map and only vague explanation of just how the City intends to extend Spruce Street from it’s present terminus at the south edge of Florentine Estates north to Munsel Creek Road.

COMMENT:   There are comments (page 30) that  “No land for street right-of-way will be required of Florentine Estates to the east.”  Logic would lead one to conclude that the 17-acre parcel to the west would bear the full responsibility of providing land for the continuation of Spruce Street north to Munsel Lake Road.  The Transportation Plan designates Spruce Street south of Munsel Lake Road as a “Collector”. (Page 152)  Collectors are characterized by two or three lanes, sidewalks on both sides of the street, signalization of intersections with other collectors and arterials, if warranted.  But the Plan (page 30) states that “a full urban section will not be required,” and that “an internal, public connection” will be constructed instead of a City street, with the sole design requirement of “shall be designed to carry 2-way
traffic safely through the site.”

TRANSPORTATION PLAN
Page 101

COMMENT:   The City Council is contemplating major changes in the Downtown Plan as it relates to Highway 101 pedestrian amenities.  If the Council makes changes in the Comprehensive Plan, then the Transportation Plan must be changed as well.

COMMENT:   ODOT, on numerous occasions, has indicated its desire to maintain the State Highway 101 as part of the state transportation system, not for use as “Main Street” Florence.  The Transportation Plan contemplates no less than six new signalization projects on Highway 101 during the planning period. See CFF’s list of Planned Signalizations, Document 12-1.

I. PORT OF SIUSLAW WATER RELATED
Pages 109 and 143

COMMENT:   The Plan does not provide information on the City’s level of involvement in the Port’s artificial reef project, and yet it is included as a priority in the Transportation Plan.  This should be clarified or deleted from the Plan.

(Also See Specific Comments)