COMMENT: The introduction states: “The most significant changes are contained in the following chapters of the Plan: ...”  Not mentioned is the major adjustment to the UGB in the Urbanization section, wherein the UGB is to be expanded by over 280 acres.

COMMENT:  The Plan fails to indicate exactly which growth rate is being used to determine the need for expansion of the Urban Growth Boundary, need for more Commercial, Industrial or Residential lands, or other planning purposes.  The individual sections contained in the plan fail to indicate which growth rate is used as a basis for the respective analyses.  The  appendices, which are in many instances used as the factual basis for the conclusions reached, contain inconsistent population data and growth projections.  The illustrated range of 2.5% to 3.5% may seem a minor distinction.  However, given the relatively small population of Florence, 7,340, the range of possible new residents in the area by 2020 is equal to over one-
third of our current population. One specific projected growth rate should be used consistently throughout the planning document.

Suggested Language: Similar language to that contained in the Transportation Plan (page 113)
should be added.

COMMENT:  CFF offers as supporting documentation for their testimony - Document 2-7.

COMMENT:   Retain definition for Objectives, and include in each section of Plan.  The City Council deleted the definition for Objectives which the Planning Commission had recommended.  The following language is that previously  approved by the Planning Commission.

Suggested Language: Page 4, Definitions: Objectives - Specific ends or targets which would aid in achieving the Goals.  Objectives also describe more specific directions in which the City
wishes to progress.

COMMENT: CFF has requested that funding of citizen involvement be given the priority due a Policy Statement.  The public, during this period review process, experienced numerous instances of obstruction to their participation, as illustrated in Document 1-1, CFF’s List of Missing Documents.   Many documents were either incomplete, unavailable, or simply did not yet exist while the public was trying to undertake review of the Draft Comprehensive Plan at the Planning Commission level.  Even after the Plan had been approved by the Planning Commission, and public forums and hearings were being held before the City Council, numerous sections and supporting documents were not available or did not yet exist.  The first
public forum was held May 4, 2000.  Not until October 2001 were all components of the Plan available for review.  This is does not make for adequate citizen involvement.  The City appears to have provided insufficient funding to the planning department to allow them to provide for an effective public participation component in the Comprehensive Plan  review process.  CFF is therefore requesting the City include public participation as a major component in their funding priorities, and ensure that funding is adequate for future actions.

(Also See Specific Comments)

COMMENT:  A specific growth rate should not be a Policy.  Growth rates should be based on the most current data available, not a fixed number, in order to provide the greatest flexibility for future planning processes.

Suggested Language: Page 11,  Policy 6 -  The City shall conduct an internal at least once very three years to assess capacity of sewer, water and stormwater systems including three-year projections of additional consumption using [a 3%] an appropriate growth rate.

COMMENT: The City does not have the authority to bring “owners” into conformance with standards. The City does have authority to bring buildings and structures into conformance with standards.

Suggested Language: Page 11, Recommendations - 5 - ... The City should have the option of
condemning, or eliminating eliminated through strict enforcement of the appropriate codes, those buildings and structures which cannot [, or whose owners will not,] be brought into conformance with standards, or whose owners will not or cannot bring them into conformance with standards.

COMMENT: According to the Real Estate Research Corporation “Emerging Trends in Real Estate” in 1999, “In reality, the most stable investment markets - the ones that have staying power and hold value - also have growth controls, either government-enacted or enforced by natural geographic boundaries ...  Developers reflexively loathe the regional growth boundaries set by Portland, Oregon, but admit the laws have led to a thriving downtown center as well as a healthy metropolitan area.  On a more micro level, cities and suburbs that set aside parks and thoughtfully zone residential areas to integrate with commercial and retail districts are more likely to thrive over the long term than towns with ‘anything goes’ zoning boards.”

RESIDENTIAL
Pages 13-18

COMMENT:  The City states, as partial  justification for the expansion of the UGB and addition of 160 acres of Residential land, “Not all lands designated Residential on this map are necessarily buildable.”  Given the existence of Munsel Creek running through the town, and the extent of significant wetlands in the area, it can be assumed that much of this these lands are considered unbuildable due to wetland or riparian setback constraints.  However, in Chapter 5, Riparian Areas, the Plan effectively removes all restrictions to building for any pre-existing lot. (Page 46, Exception 4.c.) Im riparian areas.  Likewise, Chapter 5, Wetlands, Recommendations, provides for partial or full development of “lesser quality wetlands” after an ESEE analysis.  Any inventory of “buildable” land should consider these situations. (Page 43, Recommendation 1.)

COMMENT:  Need for Housing:  The same comments as listed in above apply in this consideration - the City, in it’s own document, has admitted there is no need for more housing which cannot be met within the current UGB.   The underlying basis for their calculations (Appendix 14) even states: “... if all projected growth can be accommodated on single family lots within the current UGB, then the UGB should be adequate to accommodate the projected growth for the planning period.”  This statement came after an explanation of exactly how they had tried to manipulated the numbers by excluding “wetlands” (which can be, and are regularly, filled for development), “lands over 15% slope (which can be, and are regularly, leveled for development), and an arbitrary figure of 20% for “roads, utilities, etc. (Appendix 14, page 10) It should also be noted that it is stated that the January 7 version of the Plan is based on calculations contained in Appendix 14, the plan shows a lower population expectation by 2020 (see page 7, Projected Population ) than the October 3, 2001 draft which was also based on Appendix 14) - yet the UGB has been expanded rather than downsized, and proposed zoning changes have not been revised.

INDUSTRIAL
Page 26 - 28

COMMENT:  The Plan designates 79.57 acres of Lane County land as “public”.  (See Industrial Lands Inventory) The correct designation is Limited Industrial.

COMMENT:  The proposed Service Industrial District consists substantially of uses that should be located in a commercial zone.

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

COMMENT:  The City has suggested that industrial uses on the Port property are inappropriate due to the proximity to homes and that the oceanview lots would be more suitable for high-tech industry.  This is misleading.  Much of the property is not on high ground and is removed from residential areas, making most of the 40 acres ideally suited for industrial use.

LAND USE PLAN - NORTH COMMERCIAL NODE
Page 28

COMMENT: The zoning designation for the area north of Florence should  not be approved at this time.  Our reasoning for this proposal is as follows:

1.  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. Degradation of neighboring subdivisions (i.e., Florentine Estates) due to intrusion by noise, wind, traffic, light, and other non-residential area type activities.

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 an increase in the commercial land inventory.  Reduction of property values for those who live along Munsel Creek due to increased flooding and erosion. Reduction in property values for those who own existing commercially zoned land inside city limits due to a dilution of the commercial lands inventory.

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, a significant salmon habitat, 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.

2.  The re-zoning proposal for the area north of Munsel Lake Road was not discussed during public meetings.  Details about the cost of assumption of responsibility for Munsel Lake Road, stormwater, traffic flow, pedestrian and vehicle access have not been discussed in public meetings.

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

(Also See Specific Comments)