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

     RE:  Comments on Proposed Comprehensive Plan Update - Goal 14: Urbanization

Commissioners:

The draft comprehensive plan does not comply with Oregon State Land Use Goal 14: Urbanization.

Goal 14 states: “Urban growth boundaries shall be established to identify and separate
urbanizable land from rural land.  Establishment and change of the boundaries shall be
based upon considerations of the following factors:”

     1.   Demonstrated need to accommodate long-range urban population growth
requirements consistent with LCDC goals

Even absent a review of the supporting data, the following statements (taken directly from the draft comprehensive plan) clearly illustrate that the proposal to make a “small adjustment” to the UGB - 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)

     2.   Need for housing, employment opportunities, and livability

Need for Housing:  The same comments as listed in 1 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)

In addition, regarding the proposed expansion of the UGB, 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.

Need for Employment Opportunities:  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.

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

A close review of the supporting data, at least that which has been provided for public review, (Periodic Review Work Task #1 Urban Growth Boundary Study) reveals all manner of number manipulation:

      a.  The report which has been provided to the public as “Appendix 14" is a June 30,
     1997 Draft, is not a finalized, adopted, accepted document, and is incomplete as an
     attachment mentioned is not attached.

      b.  Population data is based on a 1995 Center for Population and Census estimate.

      c.  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 5-year
     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.

     3.   Orderly and economic provision for public facilities and services

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.

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.

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)

The City does not have a sufficient domestic water supply to accommodate more. The amount of water which they can purchase from Heceta Water District is limited by an easement restriction. Without permission, Heceta Water District cannot convey more than 1 million gallons per day across the easement.  The City has received temporary permission to exceed the 1 million gallon per day limitation.  (See attached 4/26/00 letter from Aaron U. Jones)  That temporary permission provides that Heceta Water District cannot convey more than 1.4 to 1.6 million gallons per day for the next two years across the pipeline which delivers water to the City.  This limitation is not just for the City’s usage of water, but includes water which is to be used by Heceta Water District.  That means that the City’s ability to supplement its water supply through purchase from Heceta Water District will be limited to the difference between what the District uses and 1.4 to 1.6 million gallons per day for at least two years, and possibly longer without considerable upgrading of the City’s existing water delivery system.

After the two years’ permission expires, the City’s ability to supplement its dunal well water supply will be limited to the difference between what the District uses and 1 million gallons per day  - unless one property owner gives their consent.  Although the District is planning on building a new water treatment plant, there limitation on the easement will stay in place, and are no immediate plans to change the current delivery system to the City.

While the city claims to have goals of becoming self-sufficient on dunal wells, this goal has
remained unfulfilled for over 50 years.  Current plans for development of additional well fields on federal lands are speculative, at best.  If the City is either unable to obtain permission to exceed the 1 million gallon per day limit, and/or the carrying capacity of  its present  infrastructure is not increased, the City’s ability to provide water to its residents will be limited to that which it can produce with dunal wells plus 1 million gallons per day from Heceta Water District.   These circumstances, plus past experience with dunal wells - and the unfulfilled expectations of long term increased capacity - have not been adequately considered, nor accurately reported.

The City does not have an adequate stormwater runoff management plan.  The draft plan that does exist does not deal with the proposed expansion area at all.  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 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.

     4.   Maximum efficiency of land uses within and on the fringe of the existing urban area

The draft states, “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)  The proposed expansion of the UGB does not make maximum efficiency of land within and on the fringe of the existing urban area.  The same comments as for 1., 2. and 3. above apply.

In the case of a change of a boundary, a governing body ... shall follow the procedures and
requirements as set forth in the Land Use Planning goal (Goal 2) for goal exceptions.

The Draft plan does not comply with Goal 2, as outlined in our previous letter dated June 1, 2000.

Conversion of urbanizable land to urban uses shall be based on consideration of:

     1.   Orderly, economic provision for public facilities and services

As addressed above.

     2.   Availability of sufficient land for various uses to insure choices in the market place

There has been no inventory of existing residential golf course frontage lots, therefore the availability of sufficient residential golf course frontage lots cannot be determined.

     3.   LCDC goals or the acknowledged comprehensive plan

The draft plan complies with neither LCDC goals, nor any existing acknowledged comprehensive plan.

     4.   Encouragement of development within urban areas before conversion of urbanizable
     areas.

As stated above, the City has admitted that there is sufficient undeveloped land within the UGB, and there is no need to expand the UGB.

Guidelines:  Land and uses developed on the land shall be managed and controlled so as to
maximize the conservation of all forms of energy, based upon sound economic principles.

The draft Transportation Systems Plan, which is an integral part of the rationale for expansion of the UGB, does not comply with this Goal, as we will detail in future testimony.  The Draft states that “... the public right of way gained for an east-west street ...” would be an added benefit.  Munsel Lake Road already provides an east-west street through the proposed expansion to Hwy. 101.

Claims that an “alternative connector between Highway 101 and Munsel Lake Road” is “much needed” should be viewed with scepticism.

Thank you,

(signed)
Zane Ziemer
President

Attachment: 4/26/00 letter from Aaron U. Jones