COMMENT:    The creation of a North Commercial Node does not promote policies which will conserve energy.   Encouraging commercial development away from Downtown areas will encourage more and longer automobile trips for local residents.

COMMENT:    The Transportation System Plan encourages local traffic to travel on side streets such as Oak, as opposed to Kingwood, which will cause more gasoline usage because of the presence of numerous stop signs and school crossing areas (grade school, middle school, high school, community college). (Documents 12-6, 12-16)

COMMENT:  The proposed expansion of the Urban Growth Boundary discourages energy conservation.  The Plan encourages sprawl and strip development.  Both sprawl and strip development force consumers, employees and consumer goods producers to use fuel more, and increases the costs of municipal infrastructure more than urban in-filling.

CHAPTER 14 - URBANIZATION
Pages 183-186

COMMENT:   For those properties currently being served by the Heceta Water District, prior to annexation, the City must either (1) have an agreement with Heceta Water District or (2) have sufficient existing water system to serve the property.  Recommendation 4. is ambiguous about the timing of the agreement or the necessity of the City to have sufficient water supplies to serve the property before it is annexed.

Suggested Language: Page 184, Recommendation 4. Prior to annexation of properties which are located within the boundaries of Heceta Water District, [T]the City [and Heceta Water
District] must [negotiate] either (1) enter into an agreement for the provision of water following
annexation or (2) demonstrate the City has sufficient water supplies to serve the property.
The expected demand for water shall be calculated at a level to be expected if the property
is developed to the maximum level allowable under City zoning ordinances.

COMMENT:   Fire and rescue service levels should be sufficient to serve any proposed annexation prior to that annexation.

Suggested Language: Page 184, Recommendation 4. Prior to annexation of properties, the City must either (1) enter into an agreement with the Siuslaw Rural Fire Protection District for the provision of fire and rescue service following annexation.  The expected demand for fire and rescue service shall be calculated at a level to be expected if the property is developed to the maximum level allowable under City zoning ordinances.

COMMENT:    The Plan not consistent with the Urban Growth Boundary Task Issue Paper #2 in that there has been no demonstrated need for more residential lots near golf courses, and sufficient vacant land currently exists around existing golf courses within the city limits.

COMMENT:   There has been no analysis on how  many “golf course frontage lots” currently exist, much less how many  are needed to accommodate growth in the next 20 years.

COMMENT:   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.

COMMENT:    The Planning Commission version of the Comprehensive Plan contained the following statement: “While it may be desirable for Florence to conduct an ESEE analysis for its significant wetland resources in the future, staff has identified sufficient “buildable lands” within the existing UGB to meet the city’s residential, commercial and industrial land needs.”

COMMENT:    The Plan’s contentions about sewer lines outside city limits does not provide sufficient justification for expansion of the UGB in that OAR 660- 011-0060(3) does not prevent extensions of a sewer line through lands outside the UGB.

COMMENT:   Housing Needs - Even absent a review of the supporting data, the following statements (taken directly from the draft comprehensive plan presented to the Planning Commission) clearly illustrate that the proposal to make a “small adjustment” to the UGB (page 185) - consisting of 160 acres - complies with neither the State Land Use Goals, nor the City’s own Policies as stated in the draft.

-- “... a good supply of vacant lots and unbuilt phases of approved residential subdivisions exist within the city.” (5/5/2000 Draft, page 3)
-- “A good supply of vacant lots and still-to-be completed subdivisions also exist within  the current urbanizable lands.” (5/5/2000 Draft, page 3)
-- “... the analysis considered only single family development” (emphasis added)  (5/5/2000 Draft, page 3)
-- “... sufficient buildable land exists for the planning period without a need for major  adjustments to the UGB at this time.” (5/5/2000 Draft, page 3)
-- “In conclusion, the assessment resulted in a finding that the current UGB remains adequate for the following 20 year planning period.” (5/5/2000 Draft, page 3)
-- “Although the UGB is adequate for the 2000 - 2020 planning period ...” (5/5/2000 Draft, page 3)

COMMENT:   Employment - The City has not even hinted, much less provided a basis for the premise, that the proposed expansion of the UGB is in response to a need for employment opportunities.

COMMENT:   Livability -  “Increased opportunities for residential golf course frontage lots” can hardly be equated to increasing the livability of Florence, except perhaps for a small handful of developers.

COMMENT:   A close review of the supporting data (Periodic Review Work Task #1 Urban Growth Boundary Study, June 30, 1997) reveals evidence of data manipulation:

-- Population data is based on a 1995 Center for Population and Census estimate, not current data.
-- The “Comparison of Population Growth Rates” compares apples to oranges.  It compares a 10-year growth rate of 7.0%, a 10-year growth rate of 1.6%, and a  growth rate of 3.7%, and not only comes to the conclusion that the three periods are comparable, but that a 3% growth rate should be used for the periodic review.  This is faulty science, at best, and manipulation at worst.

COMMENT:    Although mentioned numerous times in the draft, there is no evidence that on-site sewage systems inside the UGB  are “failing”.   (5/5/2000 Draft, page 2)  The fact that there is a high seasonal water table in the UGB does not necessarily mean the systems are failing.  Surely, if they were failing, the County and/or would initiate enforcement actions.  If the City is actually aware of any “failing” systems, they should be reported to the County for corrective actions.

COMMENT:    The proposed expansion of the UGB to include 160 acres will address none of the purported “failing septic system” problems.  The draft does not state that there are “failing” septic systems on any of the 160 acres proposed for inclusion.  The draft states “At some point, these private systems will fail ...”    (5/5/2000 Draft, page 2)  That statement could be made for every acre in Lane County which is not currently served by municipal sewer services.  It is hardly justification for expansion of a UGB when no need can be shown.

COMMENT:   It is curious that the City is not proposing to expand the city limits to take care of “Lots in the area of the far northwest part of the UGB are smaller, and are developed with small, older vacation cottages, many of which have older, failing on-site sewage disposal systems.” (5/5/2000 Draft, page 2) - while trying to justify the expansion in this northeast area because, “At some point, these private systems will fail, requiring public sewer service to reduce a public health hazard and potential contamination of Munsel Lake.”   (5/5/2000 Draft, page 4)

COMMENT:    Stormwater runoff from the proposed expansion area could drastically effect residents inside the UGB, and development (which would require filling of the wetlands) of this area will have negative impacts on surrounding City residents, as well as all Florence taxpayers who will have to pay for the resultant stormwater management problems.  The adopted Stormwater Management Plan does not apply to the areas proposed to be included in the UGB, and the City’s ability to regulate stormwater runoff in areas which are outside the city limits is severely limited.

COMMENT:   The cost to the existing residents of Florence of expansion of the UGB in the proposed area has not been adequately addressed.  The cost of increased demand on existing schools, police, water, sewer, city administration, local street development, stormwater runoff management, and health care facilities has not been considered. (Document 14-7)

COMMENT:    The proposed expansion of the UGB does not make maximum efficiency of land within and on the fringe of the existing urban area.  A comment from the 5/5/2000 draft: “In addition, unplatted and under-utilized lands, primarily found in the urbanizable area of the current UGB, add to the inventory of vacant lands.” (5/5/2000 Draft, page 3) .

COMMENT:    Many elements of the plan rely on the implementation of the Stormwater Management Plan in the UGB, but the Plan cannot be enforced outside the city limits.  Key areas of stormwater management concern lie outside the city, but within the UGB.  For example,  the area directly north of Munsel Lake Road (outside the city, but inside the UGB) is the source of much of the stormwater runoff flooding in Florentine Estates (inside the city).   Many of the provisions for commercial and residential development in this area rely heavily on the assumption that the Stormwater Management Plan will solve the winter flooding problems – an assumption which could cost the property owners and the taxpayers because of lawsuits against the city for allowing and encouraging development in an area known to be hazardous due to stormwater runoff flooding.

(Also See Specific Comments)