Florence Planning Commission
City of Florence
P.O. Box 340
Florence, Oregon 97439

     RE:  Comments on Proposed Comprehensive Plan Update

Commissioners:

The draft comprehensive plan does not comply with Oregon State Land Use Goal 5: Natural
Resources, Scenic and Historical Areas, and Open Spaces.

The following portion of the comprehensive plan should be changed as follows.  (Additions in bold, deletions in [italics].)
 

NATURAL RESOURCES A. Wetlands: Policies  2.   Disturbance of significant wetlands for land development activities shall be prohibited within the Florence UGB with the following exceptions: [a.    Variances to FCC Title 10, Chapter 7 as provided for therein] [c. pre-existing lots which have been rendered unbuildable by application of the special development standards in FCC Title 10, Chapter 7, Water Resources Overlay.] 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. 4.   [Adopt “safe-harbor standard process provisions ...apply to all land use actions and building activities.” ]

The draft comprehensive plan states: “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.”

If this statement is accurate, then there should be no development allowed on significant wetlands, and the comprehensive plan and city codes should so state.
 

1.   As the City’s buildable lands begin to fill in and prior to moving the UGB limit outward, the City shall [should consider] conduct [ing] an analysis of the economic, social, environmental, and energy (ESEE) consequences that could result from a decision to allow, limit, or prohibit a conflicting use for each of the locally identified [significant] wetlands.  [From this analysis, lessor quality wetlands may be found eligible for partial or full development.]  2.   The City shall [should] coordinate with the Oregon Division ... 3.   The City shall [should] consider formal wetland delineation reports approved by the Oregon Division of State Lands ...

The very fact that certain wetlands are labeled “significant” is a clear indication that they are very important to our environment, essential eco-systems, and our aquifer from which we obtain our drinking water.  We should not short-change our future by taking the quick and easy route with the “safe-harbor” standards.  If we allow development on wetland areas without full and complete (as possible) knowledge of the consequences of those actions, we are gambling with our children’s futures.  For example, if a development contaminates the aquifer, we could lose our primary source of drinking water.  That could have a devastating effect on our economy, our way of life, our very future in Florence.

Wetlands do more than provide habitat for frogs and birds.  They act as catch basins for stormwater runoff.   One consequence of filling wetlands is “downstream” flooding from stormwater runoff. If the City chooses the “quick and easy” option for enforcing development standards, the City could very well be setting itself up for lawsuits from property owners who happen to own property “downstream” from the filled wetlands.

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.
 

Background Information 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.

 

Year	Rainfall (inches)	Year	Rainfall (inches)
1980	69	1990	73
1981	82	1991	58
1982	82	1992	58
1983	96	1993	67
1984	80	1994	67
1985	51	1995	110
1986	70	1996	120
1987	68	1997	87
1988	65	1998	107
1989	61	1999	102

Thank you,

(signed)
Zane Ziemer, President