TO:  City of Florence City Council
FR:  Nick Arnis, Region 2 ODOT
RE:  Comments for Planning Commission Hearing for City of Florence Draft Transportation System
Plan (TSP) (May 2000)

Thank you for the opportunity to respond to the Draft Transportation System Plan.  Please enter this memo and attached information for the public record.  The attachments are:
 

• June 15, 2000 memo from Nick Arnis, ODOT to Florence Planning Commission
• April 7, 2000 letter from ODOT and DLCD
• May 22, 2000 letter from Sandi Young

I have reviewed the Transportation System Plan (TSP) contained in the “Realization 2000" document sent to me July 31 from the City of Florence.  I found only slight modifications to the TSP based on the April letter and June memo from the Oregon Department of Transportation (ODOT).

I realize much work has taken place to adopt the TSP but as I clearly mentioned in previous
correspondence the TSP is not acceptable to ODOT in its current form.  Please refer to my letter and memo about specific ODOT concerns.

ODOT does not currently agree with the land use proposals in the North Commercial Area and Highway 101 impacts and proposed mitigation.  Please include Transportation Planning Rule findings (please address the 0060 section of the TPR) or justification in the TSP for improvements to Highway 101.  According to recent Lane Council of Governments (LCOG) model study of the proposed NCA, the volume to capacity (V/c) ratio reached levels over 1.0 on Highway 101 for the peak travel period.  The State Highway Plan standard for v/c on this portion of Highway 101 is 0.75.  In addition, please submit as part of the TSP a functional classification map of roadways in the City of Florence.

To avoid further delays and misunderstandings about ODOT intent and the City of Florence desires for the state highway system, I suggest the City postpone adoption of the TSP until ODOT and the City resolve differences.

TO:  City of Florence Planning Commission
FR:  Nick Arnis, Region 2 ODOT
RE:  Comments for Planning Commission Hearing for City of Florence Draft Transportation System Plan (TSP) (May 2000)

Thank you for the opportunity to respond to the Draft Transportation System Plan.  Please enter this memo and attached information for the public record.  The attachments are:
 

• April 7, 2000 letter from ODOT and DLCD
• May 22, 2000 letter from Sandi Young

My comments focus on postponing the TSP adoption, and specific issues and recommendations for the TSP.

Postponing the TSP Adoption
I realize that a lot of work by a citizen committee went into developing the draft TSP and it has taken many years to arrive at the adoption process, but unfortunately the TSP (May 2000) is not acceptable to ODOT at this time.  I request the City Planning Commission postpone recommending adoption of the draft TSP until ODOT and DLCD and the City discuss and attempt to resolve differences relating to the major land use changes proposed in the periodic review that affect the transportation system.  To avoid further misunderstandings and collaborate on issues and solutions, the City and ODOT should take time to discuss concerns and expectations before the TSP is submitted for state review.

Specific Issues and Recommendations
There are many aspects of the TSP that ODOT agrees with and supports.  For instance ideas for improved pedestrian crossings along Highway 101, the local parallel street system to Highway 101, and the need to focus on downtown improvements.  Also, there are many areas of the TSP that ODOT will not accept at this time.  Reasons and explanations for not accepting the TSP are given below.

The North Commercial Area Issue
One major issue for ODOT concerns the adequacy of the transportation system in relation to the proposed comprehensive plan changes in the North Commercial Area (NCA).  The NCA draft (3-23-00_ in the Florence Realization 2020 document and TSP executive summary propose widening Highway 101 to accommodate the proposed commercial expansion of the comprehensive plan.  At this time, ODOT does not agree with this expansion or the transportation improvements related to such an expansion.

Comprehensive land use changes from residential to commercial along Highway 101 will impact the highway and most likely reduce mobility operations and safety.  In addition, such land use changes in the NCA and proposed land use and transportation changes in the downtown must be coordinated and achieve consistency with the Oregon Highway Plan and the Transportation Planning Rule.

Given new policies in the Oregon Highway Plan and Oregon Transportation Commission (OTC) direction, ODOT is seeking better methods to manage and preserve the highway system.  Consequently, significant changes to the land use system that impact a state highway are highly scrutinized and must contain a level of analysis that justifies the land use changes.  To date, information in the TSP such as on page 9 of the draft under D. Highway 101-Other Improvements, #4 and on page 11, H. Signalization Improvements, #2 and #4 are not warranted given the lack of traffic analysis information in the TSP.  In addition, the TSP does not specify who is responsible for improvements on Highway 101.

General Recommendations on the Draft TSP
Please insert before the table of contents:  "The inclusion of proposed projects and actions in this plan does not obligate or imply obligations of funds by any jurisdiction for project level planning or construction.  However, the inclusion of proposed projects and actions does serve as an opportunity for the projects to be included, if appropriate, in documents such as the State Transportation Improvement Program (STIP).  Such inclusion i(s) not automatic.  It is incumbent on the state, county, city and general public to take action to encourage and support inclusion into the STIP at the appropriate time.  Projects included in the STIP are required to have funds available so the numbers of projects that can be included are constrained by funding levels."

Please include all maps and graphics pertinent to the TSP.  The May 2000 draft is missing maps that should depict:

• Need analysis and deficiencies maps for roads, bikes, and pedestrians.
• Crash data map for sites along Highway 101 and 126.
• Map showing current and future volume to capacity ratios.
• Maps showing functional classifications of roadways.
• Maps showing current and future mode plans for the roadway, bike, transit and pedestrian systems.  Please indicate bike lands the entire length of Highway 101.
• Figures showing road classification cross-sections.
• A projects table for each mode must be included that includes priority, cost, description, and responsibility.

 

 
 
 
 
 

Comments on the Executive Summary

Page 7. Project Summary - Please indicate costs and responsibility for project implementation for all projects.

1. Highway 101/126 Enhancement Program - How is the enhancement program different than the downtown development planning ideas?  Parking on Highway 126 (Highway 101 to East Gateway) must be acceptable to ODOT before this is adopted in the plan.

3. Siuslaw River Bridge/Highway 101 - Where is the installation of trees and irrigation along Highway 101 and who is responsible for this project?

5. Quince Street Improvements - Please provide justification as far as operations, capacity or safety at this intersection that then calls for a project.

Page 8. North Florence Transportation Planning Area - The local parallel street system is encouraged along Highway 101.

Page 9. Highway 101-Other Improvements - Highway classification proposals 2, 3 and 4 need more clarification with ODOT in relation to the Oregon Highway Plan classification policies.  For instance, what is meant by transition areas and mainstreet character?

In item #4, Highway 101 between 42nd and 46th, there needs to be a greater analysis for this project idea in relation to the proposed land sue changes in the NCA.  At this time, ODOT does not support this project.

Page 11. H. Signalization Improvements - What is the need for these signals?  Is there any traffic analysis such as twenty-year volume to capacity ratios that justify these signals?  ODOT is particularly concerned with the signal ideas at Heceta Beach Road and 46th along Highway 101.

Page 19.  Chapter Two, Goals and Policies - Goal 2. Does the City propose a level of service standard?

Page 31.  Highway 101-Other Improvements - ODOT does not accept the justification for a 5 or 7 lane section on Highway 101 in the North Florence Transportation Planning Area.  The City must explain why this widening is needed, the cost, the description and who is responsible for the project.

The last statement in the fourth paragraph, "Its character is not consistent with City policies ..." should be a concern for ODOT and the City and all the more reason for greater coordination -- the TSP must be consistent with the Oregon Highway Plan.
 

April 7, 2000

Sandi Young, Planning Director
City of Florence
P.O. Box 340
Florence, Oregon 97439

Dear Sandi:

Thank you for providing the Oregon Department of Transportation (ODOT) and the Oregon Department of Land Conservation and Development (DLCD) an opportunity to comment on the proposed plan and zone map amendments along the Highway 101 corridor from Munsel Lake Road to Heceta Beach Road.  This proposal would redesignate a significant amount of land from residential use to commercial and industrial use.  In addition, there has been a proposal to rezone the “wrecking yard” on Munsel Lake Road near Highway 101 to commercial use.

Based on the information received, ODOT Region 2 Planning and the DLCD do not support the proposed amendments.  The need for more commercial and industrial land has not been justified. The proposal is not consistent with policies in the city's comprehensive plan.  The proposal has not been adequately evaluated in terms of the transportation planning rule OAR 660-12-0060 provisions and whether the proposed land uses are consistent with the intended classification of the Highway. Also, major plan amendments such as these must be coordinated with ODOT and DLCD  as described in the transportation planning rule under 660-12-0015 “Preparation and Coordination of Transportation System Plans.”

The position of our two agencies on this issue is not new.  In a May 21, 1997 letter to John Theilacker, City of Florence, ODOT stated: “At a minimum, ODOT will seek policies in the TSP that clearly and fairly plan for growth along Highway 101 based on current comprehensive plan designations.  A policy should indicate that Highway 101 and Munsel Lake Rd. be the northern  terminus for the existing comprehensive plan commercial designations along the highway.  Any future amendments to the adopted comprehensive plan will be judged by ODOT according to this policy, the TPR and City of Florence land use plans.”

ODOT, DLCD and the City of Florence must agree about the functional classification of Highway 101 in the downtown and northern areas.  It is not in the interests of the two state agencies to support the designation of additional commercial and industrial land uses along Highway 101 while planning for and attempting to implement the TGM downtown plans along Highway 101.  Both  agencies desire an open dialogue about the role and function of Highway 101 and 126 in relation to the downtown plan and ideas for the northern area near the Munsel Lake Rd./Hwy 101 and the Heceta Beach Rd./Hwy 101 intersections.

Land Use Issues

Many of the comments below are the same as those contained in our letter to John Theilacker dated July 18, 1997.  Although the specific properties involved are different, the issues are very similar. If the city has amended its plan or supporting information since that time and would like to submit additional information, we will be happy to review it and revise our comments as appropriate.

1.  Need

The draft findings on commercial and industrial lands which were compiled in periodic review do not justify a need for this additional commercial and industrial land.  No additional information was provided showing the current plan and zoning designations for the area or the amount of land proposed to be redesignated and rezoned to “North Florence Commercial District”, “Limited Industrial/Commercial District”, and “Neighborhood Commercial Gateway District.”

Commercial use.  Based on our review of the city's analysis of commercial lands, there is no need for additional commercial land (Issue Paper #1, Commercial and Industrial Land Uses, February 11,  1997, pages 10 through 15).  The factor of 0.453 acres of commercial land need per person is  based on the existing commercially zoned land and the 1995 population.  However, a considerable amount of the land in commercial zones is occupied by other uses: government, institutions, residential or vacant.  The future need for commercial land should be based on the actual amount of land now in commercial use.  Based on this assumption, the need would be as follows:
 

Land need:
Land in commercial use (UGB) - 167 acres
1995 population - 7,590
Commercial acres per person - 0.22
2015 population @ 2.3% - 11,961
Needed commercial land - 263 acres
Additional land needed - 96 acres

Land supply:
Land zoned for commercial use - 361 acres
Vacant land zoned (includes 17 acre rezoning) - 90 acres
Land with other uses - 102 acres

The analysis above shows that enough land is already zoned (361 acres) to meet the future commercial need (263 acres) although only 90 acres is both zoned commercial and vacant.
However, considering only vacant land, the net deficit would be only 6 acres.  It would be inconsistent to allow land to remain in commercial zoning but assume that none of that land will convert over time to commercial use.  Another source of commercial land is the conversion of existing residences in commercial zones to retail shops or professional offices.  Based on the above,
there is no need to zone additional land for commercial use.

Commercial/Industrial use.  The city's issue paper on industrial lands states on page 22 that “the current amount of industrially zoned land is more than adequate for the 20-year planning period.” Based on this information, there is no need to zone land north of Munsel Lake Road for industrial uses.  In addition, the proposed Limited Industrial/Commercial District consists substantially of uses that should be locate din a commercial zone; these are: retail building supply, retail plant nurseries, and professional offices.  It is likely that the other uses, construction contractors and truck and equipment repair, could also be located in one of the city's commercial or industrial zones.

2.  Consistency with the Florence Comprehensive Plan

This proposal would be a major change in the policies and assumptions underlying the plan in regard to the pattern of commercial uses, and therefore, it is not consistent with applicable provisions of the Florence Comprehensive Plan.

North Florence Shopping Area.  The Florence Comprehensive Plan states (pages 53-54): Future development in the north area of Florence is expected to generate a need for an additional shopping area ...”

This proposal goes far beyond what was contemplated in the Florence Comprehensive Plan.  The north area of Florence already has two planned shopping centers, one at Munsel lake Road and one at Heceta Beach Road.  The current proposal would fill in the land between the two centers, creating a single strip of commercial and some industrial uses.

Linear Development Patter.  The city has a policy that prohibits further linear or strip commercial development (Economic Element, policy 6).  The proposed plan amendment would violate this policy by extending the commercial strip along Highway 101.

We believe that the city's policy prohibits such strip development and instead authorizes centers/nodes, much like the existing Old Town and Downtown areas.  These areas have: (1) depth away from the highway; (2) a variety of street connections to surrounding areas other than the highway; (3) a mix of uses; (4) supporting uses on surrounding properties.

Transportation Issues

1.  Consistency of Proposed Land Uses with the Transportation System

The Transportation Planning Rule (TPR) requires planned land uses to be consistent with the function, capacity, and performance standards of transportation facilities.  OAR 660-012-0060.  We understand the amendments to the city's comprehensive plan in the vicinity of the North Florence Transportation Planning Area are being proposed in conjunction with the update of the city's Transportation System Plan (TSP).  However, it is our understanding that the underlying assumptions of the TSP, such as planned land uses and population and employment distributions, were based upon the existing planned land uses, not the amendments being proposed at this time. The transportation analysis should consider the affects of the proposed land use changes and include findings demonstrating the proposed land uses are consistent with the planned transportation system.

2.  Plan for Local Streets and Access Management

The TPR includes requirements for local street and access management plans for comprehensive plan amendments which include designation of two or more acres of land for commercial uses, where the proposed amendment would significantly affect a transportation facility, and where the local government has not adopted a TSP or local street plan which complies with OAR 660-012-0020(2)(b).  The proposed amendment appears to meet these criteria and, therefore, the amendment must include the adoption of a local street plan, access management plan, and future street plan.  OAR 660-012-0060(6).  By planning for the extension of some local streets such as Oak and Spruce and by including some access management requirements, the proposed TSP and zoning districts address these requirements to a certain extent.  However, we do not believe the plan and zoning requirements are detailed enough to constitute the local street and access management plan required by the TPR.

3.  Consistency with the Oregon Highway Plan

The Oregon Highway Plan (OHP) requires local governments and ODOT to reach agreement on the application of specific highway designations (i.e., Commercial Center, Urban Business Area) to guide land use planning and development standards (Action 1B.7).  The purpose of this requirement is to identify the planned function of the facility and to ensure that the design of the facility and adjacent land uses are consistent with this function.  From the information presented, it is unclear exactly what highway designations the city intends to apply to the segment of Highway 101 in North Florence and whether or not the proposed improvements and development standards are consistent with this designation.  For example, p. 6 of the TSP Executive Summary states that Highway 101 in the North Florence Planning Area “is planned for at least a 5-lane section, and eventually a 7-lane section.”  This language is vague and ambiguous.  Similarly, p. 5 of the TSP Executive Summary refers to a second signalized intersection at 46th Street that may not be consistent with the function of the highway or the signal spacing standards contained in the OHP.  In addition, the draft zoning code for the Limited Industrial/Commercial District states that “access to Highway shall be via combined driveways” without any explanation as to whether such standards are consistent with ODOT’s access management standards or whether access via local streets should be provided in lieu of direct access to Hwy. 101.  Considering the area proposed for the Limited Industria/Commercial District has been subdivided to include many narrow parcels that front on Hwy. 101, we believe the proposed access standards would result in multiple driveway access points which would be detrimental to the function of the highway.

4.  Implementation of Proposed Transportation Improvements

The proposed TSP includes several transportation improvements that we support, such as the extension of Oak and Spruce Streets and the extensions of Munsel Lake Road to the west and Heceta Beach Road to the east.  We are concerned that these improvements may not be  implemented in a timely fashion, as necessary to support the planned land uses.  For example, the final draft text for the North Commercial Area states that additional right-of-way will need to be obtained concurrent with the development of abutting properties but that additional planning and preliminary engineering plans are necessary to determine the ultimate alignments and right-of-way needs.  The text goes on to state that “(w)ithout the plans, there is no way to determine what lands should be dedicated.”  Similarly, the text states that the east-west connector to the south of the Fred Meyer site cannot be constructed until the Community Baptist Church is relocated and redeveloped.  In addition, the plan calls for the extension of Heceta Beach Road and for parcels in the  Neighborhood Commercial Gateway District to gain access via an internal street network.  However, the zoning code states that “(u)ntil such access is available, businesses shall be permitted temporary access to Highway 101, but must share a common access with an abutting property.”

While we agree that shared access can be beneficial, this plan and code language to not provide enough assurance that the necessary transportation facilities will be installed concurrent with development.  In addition, once development occurs and make use of “temporary” accesses to Hwy. 101, it is unlikely there will be an impetus for development in the area to provide the necessary transportation facilities and change their access points.

In general, we do not believe the comprehensive plan amendments to allow more intensive uses in the North Florence area should be approved until and unless the alignment of necessary streets is known and the facilities can be provided concurrent with development and in a manner that is consistent with ODOT’s access management standards.  A greater level of detail is necessary  to identify the alignments for local street connections, where private driveways will or will not be allowed, and how the necessary improvements will be constructed.  For example, perhaps any comprehensive plan changes should be conditioned upon the formation of a local improvement district (LID) or other implementing mechanism to assure the facilities will be provided as development occurs.

5.  General Comments about the Transportation System Plan (TSP)

We have two over-riding concerns about the coordination of these proposals with the TSP.  The time line for adoption may be too short and the City and state agencies must better coordinate their goals and policies for the Highway.  Given comprehensive plan amendments and other ideas proposed by the City of Florence in the Periodic Review and the TSP, it appears that an August adoption before the Council is unlikely.  Please be aware that Lane County must also adopt the TSP.  The practice is to hold joint sessions with Lane County for Planning Commission  recommendation and elected official adoption.

State agencies and the City must better coordinate the proposed periodic review tasks and the City TSP.  ODOT is very concerned about the magnitude and scope of the proposed comprehensive plan amendments for the northern area of Highway 101.  For this reason, we request the opportunity to review a complete preliminary draft of the transportation system plan.  This draft should include all elements for a TSP as described by the transportation planning rule such as roadway, bicycle, pedestrian and transit mode plans which includes needs analysis, project locations, cost and jurisdiction responsibilities.  In addition, please include the model results and model assumptions for population and employment growth in each transportation analysis zone.  A preliminary TSP review would allow ODOT and DLCD to make comments and suggest revisions before a draft is circulated for review by the planning commission and public.

6.  Specific Comments on the TSP Executive Summary

Please include the executive summary as well as all figures as part of the preliminary draft TSP
which we have requested, above.  We will want to review on the full TSP draft in order to comment more fully on these proposed changes in use adjacent to the highway.  Some initial comments on the executive summary are attached to this letter for your information.

Thank you again for providing our two agencies an opportunity to comment on these proposals. These preliminary comments are based on the (partial) information which is available to date.  We may have additional comments as more information about these issues develops.  Please do not hesitate to call either of us to discuss these issues further.

Sincerely,

(Signed)
Jim Hinman, DLCD Urban Division
Nick Arnis, ODOT Region 2 Planning

Attachment: Specific Comments on the TSP Executive Summary

cc:    Kent Howe, Lane County Planning Department
        Larry Ward, LCOG

Distribution: Russo, Perry, Jacobson (DLCD); Johnson, deTar (ODOT Region 2)

Attachment: Specific Comments on the TSP Executive Summary

Page 2. Highway 101/126 Enhancement Program - Please delete "would" in the second sentence with "could".  Is this a City program?

Page 3.  Safety Awareness - What is the safety hazard?  How will a sign improve the safety?

Page 3.  Stewardship - Who will manage traffic and how, or how will managing traffic preserve the bridge?  The bridge will reach capacity, is this the solution?

Page 4.  Highway 126/Quince Street intersection - Must see the figure.  Figure must be consistent with ODOT project.

Page 4. Quince Street Improvements - Please delete "Preliminary Engineering should include investigation of a roundabout" or state that a preliminary engineering study will consider alternatives for the intersection.

Page 4.  Highway 101 Pedestrian Crossing Pilot Program - Please provide figure.  There still needs to be an agreed design concept between ODOT and the City, which will be created during another TGM grant.  Please mention that another study will determine a specific design concept.

Page 5.  North Florence Transportation Planning Area - ODOT must review the proposed land use amendments and road project map before making any comments.

Page 5.  Oak Street North Extension - There will not be a signalized intersection at 46th street.  This is consistent with the ODOT decision about access to the Fred Meyer site.  Signalized intersection at Heceta Beach Road is not "required" as suggested in the last paragraph, please delete.

Page 6. Highway 101 - Other Improvements - ODOT and the City must determine the classification of Highway 101.  Please indicate the need for a 5 lane cross-section and eventually a 7 lane cross section.

Page 7. Third Paragraph - Please identify the section of Highway 101 that is not consistent with City policies and identify the policies and why there is not consistency.  The TSP must be consistent with the Oregon Highway Plan.

Page 7.  Last Paragraph - Who should improve Highway 101 from 42nd to 46th? Are the improvements needed in relation to proposed comprehensive plan amendments?