Citizens For Florence

Issues of
Interest
Comprehensive Plan Review
Public Comments

Our Goal: To improve the livability of Florence through public education and community involvement.

Public Comments

04/17/03 - 1000 Friends of Oregon

04/17/03 - People Against a Casino Town

03/25/03 - Arnold Buchman

02/07/02 - Alice & Howard Shapiro

02/07/02 - Craig Daniels

02/07/02 - Ronald Gerber & Debby Todd

02/06/02 - Bruce Mower

02/05/02 - Florentine Estates Home Owner's Association

01/25/02 - Kenneth and Leita Kent

01/19/02 - Kenneth Kent

08/30/00 - Debby Todd

08/03/00 - Florentine Estates Homeowners Association

05/31/00 - Howard Shapiro

04/17/03 - People Against a Casino Town (PACT)

Florence Planning Commission                            Lane County Planning Commission
250 Hwy 101                                                    125 East Eighth Avenue
Florence, Oregon 97439                                   Eugene, Oregon 97401

RE: Proposed Expansion of Florence Urban Growth Boundary
    Proposed Amendment to Florence Transportation Plan

Commissioners:

We Request This Hearing Be Continued
or
Second Hearing Be Held to Allow Testimony

     ■    Lack of Sufficient Notice

It was apparent at the public hearing that there was some confusion about which map was under consideration. For example, two maps were obtained from city hall on April 14. One map shows a triangular piece of property in the southwest corner as being proposed to be included in the UGB expansion. The second map shows that piece not inside the UGB boundary. Neither map was included in the staff report which was offered to the public prior to the hearing.

The notice in the newspaper did not contain a description of the land which was under consideration. It was not until the evening of the hearing that it became apparent that more land was under consideration than had previously been discussed by the Planning Commission and City Council. Testimony was offered that evening that persons living in the area proposed for inclusion in the UGB had not received notice that their property was being considered.   Unfortunately, the time for public testimony before the Planning Commission has passed, and many have not yet received notice that their land is to be
effected.

For these reasons, we are requesting the Planning Commission continue this hearing until all property owners in the affected area receive proper notice and sufficient time to comment on the City’s plans for their land.

     ■    Request Planning Commission Postpone Decision

There was testimony offered at the hearing about the pending lawsuit in Federal court regarding the Hatch Tract. Depending on the outcome of that lawsuit (to be decided in May), the Planning Commission will have a better idea of exactly what the full
implications of including the Tribal lands inside the UGB might be. The Tribes intend to build a casino on their land if they are successful in the lawsuit. If they are not successful, then the land will likely be developed as a commercial and/or residential
enterprise, as the primary purpose as stated by the Tribe is to provide income. Planning for expected development in that area would be an entirely different scenario if the court determines that no casino will be allowed. We think that a continuance of this hearing until after the Federal Magistrate has made his decision would be a wise, and cost effective, step.

     ■    Request for Second Public Hearing

There is a great amount of new information being made available to the Planning Commission. Apart from the public comments submitted, much of what the City is planning is going to require a considerable amount of time and city tax dollars to
implement. (See attached memorandum from Lane County Public Works.)

Based on this information, as well as public testimony provided, the Planning Commission may well consider re-configuring the UGB expansion. Should this occur, we are requesting the Planning Commission hold another public hearing at which the
public can offer comments on any “revised” UGB expansion.

Many of the Appendices to the Comprehensive Plan which were supposed to be included in the Planning Commission’s packet were “being revised”. It has become apparent that the public has not had opportunity to review these new revisions.

We also ask the Planning Commission to consider that the public has not been provided adequate notice of what will be the consequences to them, personally, if their land is placed inside the UGB. We have attached a list of questions which we believe would provide the public with some of the answers they need in order to consider the effects of this expansion.

     ■    Lane County Requirements

We are requesting the Planning Commission consider the information contained in the attached memorandum from Lane County to the City of Florence. The county requirements for the proposed UGB expansion appear to involve a rather lengthy (and
costly) process.

     ■    Revision of Florence Comprehensive Plan

The proposed UGB expansion may require amendment of the Florence Comprehensive Plan which was recently acknowledged by DLCD. In addition to those Plan sections mentioned in the county’s memorandum, we think the Planning Commission may need to consider amending the following sections, as well.

Air, Water and Land Resources Quality: Inclusion of land in a UGB presumes that the land will be changed from a rural to urban use. The City’s recently adopted Comprehensive Plan was based on a much smaller UGB expansion area, and does not
contain plans for dealing with the increase in air, water and land pollution which accompanies urban uses.

Economic Development: The impact on existing businesses, the Downtown Plan, and commercial land needs was based on a much smaller UGB expansion area. As the main reason for this expansion is to facilitate development of the area (providing city services), the City’s economic development plans may need to be revised.

Public Facilities and Services: This UGB expansion is much larger than that contemplated in the newly-approved Comprehensive Plan. The City’s plans for future needs for water, sewer, police, etc. may need to be amended, as the purpose for an Urban Growth Boundary is to help the City plan for eventual annexation into the City - and the expected demand for city services.

Transportation: Aside from the need to revise the Transportation Systems Plan to include plans for this level of UGB expansion and growth, the City may need to revise plans for providing access to this area - as it will eventually become annexed into the city. The current plans call for extension of 18th Street from Hwy 101 to North Fork Road. The City needs to plan for improvements (widening, sidewalks, stop lights and turn lanes on Hwy 101, etc.) to 18th Street to meet the expected increase in traffic through those residential neighborhoods. Understanding the potential for a casino raises the issue of
access from the north from Hwy 101. Munsel Lake Road would appear to be the major route to and from a casino, and Munsel Lake Road is primarily residential 25-30 mpg. Revisions to the TSP are thus dependent on the use of the Hatch Tract, be it commercial or residential.

For these reasons, we are requesting the Planning Commission not act hastily in making their recommendation to the City Council. Decisions to be made about this proposed UGB expansion, given the potential Hatch Tract use, will have major impacts on our City’s ability to plan for our future.

Respectfully,

Chair
PACT Steering Committee

Attached:      Lane County Memorandum
                    PACT Questions for Planning Commission

03/25/03 - Arnold Buchman

March 25, 2003

Lane County Planning Commission

125 E. 8^thStreet

Eugene, OR 97401

Florence Planning Commission

City Hall

250 Highway 101

Florence, OR 97439

Tribal bargaining for Florence sewer/water services to facilitate development of a gaming casino on the Hatch Tract has added urgency to the city’s heretofore desultory consideration of Urban Growth Boundary (UGB) expansion. Citizen concern prompted by the proposed project, in turn, has served to focus public attention on the rationale presented in support of UGB expansion.

City staff say homes in the expansion area suffer from failing septic systems and poor-quality water. This without any evidence or testimony from supposedly affected landowners supporting the allegation. Staff also cite golf course plans for 100 additional residential units on its property. Sewer and water service might indeed promote the proposed housing. But, state urbanization policy (Goal 14) limits UGB expansion to satisfying demonstrated population growth requirements. Even at the generous 3% growth rate projected by the city, the additional housing units are contrary to Oregon’s anti-sprawl policy.

Coupled with the Tribes’ ultimatum to expand the UGB by June 30 “or else we’ll provide our own sewer and water”, the sudden push for expansion, notwithstanding the deficiencies of the process, suggests that an expansion decision may have more to do with the Tribes’ imprecise offer of an additional police officer and 60 FEC rentals than failing septic systems and poor-quality water.

Oregon land use laws envision full, open, public consideration of the economic and social consequences of a boundary enlargement. That principle falls victim if this “rush to judgment” to facilitate a casino is permitted.

Arnold E. Buchman
Florence

2/7/02 - Alice & Howard Shapiro

Director
Department of Land Conservation and Development
635 Capitol Street, N.E., #200
Salem, Oregon 97310

Regarding: City of Florence Comprehensive Plan Update

Dear Sir:

We have reviewed the comments, objections and suggested changes that were submitted to your office by Citizens For Florence on January 28, 2002. We would like to adopt the Objection filed by Citizens For Florence as our own. We agree with their objections, and the changes they proposed would adequately address our concerns.

We also specifically object to the City's last-minute inclusion of a change in the Urban Growth Boundary, consisting of over 160 acres. The first time the public was made aware of this decision was during a City Council work session, at which the Public was not allowed to participate or comment, and long after the Council had officially closed the comment period. The first time this information was available to the public in written form was late afternoon of January 8, 2002. The City Council adopted the changes only six days later (on January 14), again without any opportunity for public comment. The decision to expand the UGB, as stated in the Comprehensive Plan, is solely to accommodate development of a proposed Indian casino. We believe the City's decision is procedurally deficient, at the very least, and the UGB should not be expanded.

We would like to receive a copy of your report on the Comprehensive Plan changes, and the objections submitted, when it becomes available.

Sincerely,

Alice Shapiro
Howard Shapiro
P.O. Box 2651
Florence, OR 97439

2/7/02 - Craig Daniels

Director of Staff
Department of Land Conservation and Development
635 Capitol Street, NE, #200
Salem, Oregon 97310

Regarding: City of Florence Comprehensive Plan Update

Dear Person,

I lived in the City of Florence until December of 2001 - having followed and participated in local issues since 1991. While no longer a resident, please accept the validity of my opinions on the basis of that background.

In particular: I've long despaired of the Florence "done deal" style of political decision making in City Hall - in which it too often seemed the very purpose was to avoid public information and testimony - or to make it impotent.

The City's recent move to expand their urban growth boundary (by 160 acres!) - as a not-for-discussion / hearing after-thought to our extensive planning and review process is what prompts my post-departure comment.

I wholeheartedly endorse objections filed with you by the "Citizens For Florence" on January 28, 2002.

The State of Oregon should either insist on the elements of its meeting / hearing laws being observed - or officially retire them as having become a cynical charade and posturing at observing democratic process.

Respectfully,

Craig Daniels

2/7/02 - Ron Gerber & Debby Todd

Director
Department of Land Conservation and Development
635 Capitol Street, N.E., #200
Salem, Oregon 97310

Regarding: City of Florence Comprehensive Plan Update

Dear Sir:

We participated in the City’s periodic review by submitting written testimony to the Florence
City Council on November 6, 2001 (attached). We have also carefully reviewed the
comments, objections and suggested changes which were submitted to your office by the
Citizens For Florence group on January 28, 2002. We would like to adopt the objection
filed by Citizens For Florence, as though fully set forth herein, as we agree with their
objections, and believe the changes they proposed would adequately address our
concerns.

We would also specifically like to object to the City’s last-minute inclusion of a change in
the Urban Growth Boundary, consisting of over 160 acres. The first time the public was
made aware of this decision was during a City Council work session, at which the public
was not allowed to participate or comment, and long after the Council had officially closed
the comment period. The first time this information was available in written form to the
public was late in the afternoon of January 8, 2002. The City Council then adopted the
changes only six days later (on January 14) again without any opportunity for public
comment. The decision to expand the UGB, as stated in the Comprehensive Plan, is solely
to accommodate development of a proposed Indian casino. We believe the City’s decision
is procedurally deficient, at the very least, and the UBG should not be expanded.

We would like to receive a copy of your report on the Comprehensive Plan changes, and
the objections submitted, when it becomes available.

Thank you,

Ron Gerber
Debby Todd

2/6/02 - Central Oregon Coast Board of Realtors

2/6/02

Jim Hinman
DLCD Periodic Review Specialist
635 Capitol Street NE, Suite 150
Salem, Or. 97301

Re: Objection to the City of Florence Periodic Review Work Task Decision

Dear Mr. Hinman,

We are the Central Oregon Coast Board of Realtors, consisting of approximately 85 members serving the public's real estate needs in the Florence area and are members of the Oregon Association of Realtors and the National Association of Realtors. Thank you for allowing us the opportunity to submit our objections.

Members of the Central Oregon Coast Board of Realtors have been involved in the City of Florence's Comprehensive Plan update process since 1996 by testifying at CAC meetings and participating in the complete RDI Visioning process. In addition, we have testified orally at the Planning Commission level and both orally and in writing before the City Council on 8/30/00 and 11/06/01. Additionally, I have participated and testified as an individual in all of the above. The Central Oregon Coast Board of Realtors has the following objections.

Objection #1: Zone change without due process.
The CAC made many suggested changes in their deliberations that were passed on to the Planning Commission and then to the Council in an effort to better distribute commercial development. One such change was the rezoning of a 22 acre parcel North of Munsel lake Road and East of Highway 101 known as the "Seifert Property". In order ot take some of the pressure off of what is referred to as "Strip Development" it was felt that an expansion of commercial land to the East along Munsel lake Road would help meet that need. The old existing zone was Mobile Home District, and through a lengthy planning process was changed to a large development Commercial District. This parcel remained in the proposed new Commercial designation through the planning commission hearings and approval and finally through the City Council hearings. After the hearings, the City Council held work sessions in which the subject of the commercial area east of Highway 101 was brought up. In a matter of a few minutes, the entire 22 acres was arbitrarily changed to Industrial without public input or landowner notification. We believe this is a violation of City and State Code.

Solution: We still believe that the CAC and the Planning Commission were correct to recommend commercial to the east and away from the highway to relieve pressure for the need of commercial lands. We would advocate that at least a portion of the western 1/2 of the 20 acres be added as Commercial and the balance of the eastern portion remaining Industrial subject to input from the owner.

Objection #2: A planned and critical UGB change was left out.
The CAC made two suggested changes in the UGB in their deliberations that were passed on to the Planning Commission and then to the Council. One of these changes was an effort to address potential sewer problems on the west end of Munsel Lake where there is dense housing and septic fields as close as 50' from the lake and many have no replacement areas. Some have already failed. This was also changed after the public comment was closed by the Council at a later work session. Ironically the only opposition to this area being included in the UGB was from the Rod and Gun Club who was represented by Bruce Mower who also is our Lane County Sanitarian. This area will need public sewers in the near future and should be included in the 20 year planning for the city.

Solution: Extend the UGB in this critical need area with the exclusion of the Rod and Gun Club property and the property to the north.

Objection #3: This plan does not include legitimate buildable lands inventories.
The City admits that the 20 year buildable land inventories have not been done. State law and your 1995 Periodic Review Work Order requires these Inventories accompany the approved plan update by the city for residential and commercial lands. The City states in it's notice to the public of Periodic Review Work Task Decision, that it has "adopted as a part of Appendices 2 and 14" a "buildable lands analysis, and analysis of residential, commercial and industrial land needs," This reference is to a minimal analysis done by City Planner, John Th(e)ilacker in 1996 to support the City's position in recommending a zone change on a 17 acre parcel from residential to commercial and is not a 20 year buildable lands inventory as is required by law. To our knowledge, the law does not allow for a partial analysis, nor does it allow for one after the fact.

Solution: DLCD should order the City to complete the buildable lands inventory for commercial and residential lands, as stated in your 1995 Work Order, as part of the City's current Periodic Review. DLCD should provide the city with a grant for funding said work.

Respectfully yours,

Dale A. Saari
Chair, Government Affairs
Central Oregon Coast Board of Realtors

2/6/02 - Bruce Mower

Jim Hinman
DLCD Periodic Review Specialist
635 Capitol Street NE, Suite 150
Salem, OR 97301

RE: Florence City Comprehensive Plan Review

Dear Mr. Hinman,

I would like to take this opportunity to voice my opposition to Florence City's final version of their Comprehensive Plan adopted by the City Council on January 14, 2002. Specifically, I object to the findings and recommendations for Chapter 14, URBANIZATION, and the proposed extension of the Urban Growth Boundary to include the North Fork Siuslaw Road properties and the property identified as the "Hatch Tract" just west of the North Fork Road. My objections are as follows:

Lack of Citizen Involvement

Chapter 1 of the Comprehensive Plan has stated goals/objectives/policies that require citizen involvement in the planning process. These objectives were completely ignored with the inclusion of the North Fork Road properties and the "Hatch Tract" into the Urban Growth Boundary. The original proposed extensions of the Urban Growth Boundary that were brought to public hearings were the extension by Munsel Lake and the Ocean Dunes Golf Course as shown in exhibit #1. The UGB extensions in these two areas were the only proposed extensions that were subject to public input during the public hearing process. It was after the final hearing on November 6, 2001 that the inclusion of these North Fork Properties and the "Hatch Tract" were included into the UGB expansion. Specifically these properties were addressed by the city Council at Comprehensive Plan work sessions in mid-December. Although persons were present at this work session, there was no public testimony allowed at the work session. This last minute unilateral action by the City Council circumvented any opportunity for public comment on these UGB expansions. The "Hatch Tract" is owned by the Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians and has been proposed for the construction of a casino complex. The City Council's assertion that "it is to the City benefit to include this major urban scale facility within the UGB" (page 191) is made without any public comment or debate on the merits of having such a development within the UGB.

Lack of Justification

The City has not conducted a residential land analysis to justify the expansion of the Urban Growth Boundary. State Planning Goal 14 has several factors that must be addressed in order to change the City's UGB. There must be a demonstration, supported by substantial evidence, that there is a "need" to enlarge the UGB. On page 12 of the City's Urban Growth Boundary Study and Report (exhibit #2) it specifically states that residential demand does not require amendment of the UGB. Additionally the City has not completed a residential land use analysis to demonstrate any need for enlargement of the UGB. The City's assertion that they "intend" to prepare this analysis after the 2020 Comprehensive Plan (page 190, exhibit #3) does not and cannot substitute for a properly conducted analysis. Please note that the Lane County Planning Department also recognized this lack of demonstration of need concerning UGB expansions in their letter dated July 27, 2000 to Florence City Planning Department (exhibit #4).

The City has also asserted that the inclusion of the homes along the North Fork Road into the UGB is to alleviate water or sewer problems. They provide no data or analysis to support this conclusion. As the issuance of well drilling permits resides with the Oregon Department of Water Resources, and sewage system permits with the Lane County Land Management Division, the City has no means of actually tracking or making an analysis of problems with water or sewage disposal in this area. In fact, an analysis of the Lane County Land Management permit records for dwellings along the North Fork Road show that there is no extreme failure rate for septic systems in this area. The data displayed in exhibit 6 table clearly shows that there has been no unusual frequency of septic system repair for dwellings along the North Fork Road. The data in exhibit #5 would indicate that on the average a septic system in this area would have to be repaired about every 25-30 years. This low failure rate does not justify the need for City service and the expansion of the UGB into this area.

Lack of Orderly Expansion of Services

The City has stated that lots in other areas, already within the UGB, have problems with failing sewage systems (page 189). If this is in fact the case, the City should concentrate its efforts in expanding municipal sewers into this area before adding new areas (with undocumented sewage problems) into the UGB.

In conclusion, I believe it is evident that the City has failed to provide any justification under the State Planning Goals to support the increased Urban Growth Boundary proposed in their Comprehensive Plan. I hereby request that your office reject their proposed Boundary expansions.

Sincerely,
Bruce Mower
cc: Florence Community Development Dept.

Editor's Note: Minor typographical errors contained in the original letter have been corrected in this reproduction.

Link to: Exhibit 5

2/5/02 - Florentine Estates Home Owner's Association

Director
Department of Land Conservation and Development
635 Capitol Street, N.E.., #200
Salem, Oregon 97310

RE: Objections - City of Florence Comprehensive Plan Periodic Review

Dear Sir:

Enclosed are the objections that the Florentine Estates Homeowners' Association Board of Directors is submitting to your office.

The Florentine Estates Homeowners' Association Board of Directors participated in the City's periodic review by submitting written testimony, as well as oral testimony at the Planning Commissoin level and at the City Council hearing level. The testimony submitted is attached.

Also attached are our objections to the varoius sections of the comprehensive plan adopted under the relevant work tasks.

Our comments cover Goal 2, Land Use; Goal 11, Utilities and Facilities; and Goal 14, Urbanization.

In addition we wish to object to the City Council's arbitrarty decision to expand the UGB to include certain lands to accommodate a proposed Indian casino, as well as other neighboring parcels, without any public hearing, review or input. We would appreciate knowing as soon as possible if this action must be appealed directly to LUBA, as opposed to being contained in these objections.

Thank you for taking the time to review our concerns about the City's proposed Comprehensive Plan.

Nola Fran Xavier, President

cc: City of Florence

Link to: Specific Comments

1/25/02 - Kenneth & Leita Kent

Jim Hinman
DLCD Periodic Review Specialist
635 Capitol Street NE
Suite 150
Salem, OR 97301

Subject: 17 Acre Development, Florence, OR.

Dear Sir

If my memory serves me correctly, this is my second effort to your offices regarding this issue, although I do not recall if you were the person who was the recipient of the last mailing.

Rather than repeat the whole litany, I beg your indulgence by enclosing "some" of the former correspondence, as well as our latest efforts. We remain very concerned regarding the proposed Arlie & Co. project, and how they will provide the required safeguards to shield our residents from the various forms of pollution that will surely occur, as well as the flooding problem which will be exacerbated with the removal of the natural growth which exists at present within the 17 acre parcel. Regarding the flooding, there is a locally executed video tape which documents this condition. You really should see this epic prior to any deliberation which must follow.

As you may know, Florence has a persistent wind condition which prevails, usually from the ocean, southwest or northwest. At night you can hear the surf ... that is nice, but during the day we are treated to all the traffic noise from Highway 101. This will most certainly be amplified when the tree/ground cover is removed, and the protective hill is leveled. Not good for the 100 or so families who live directly adjacent to the parcel.

We would appreciate your input on this problem. Frankly, we feel that we and many others are being ignored regarding this potential problem.

Most sincerely,

Kenneth & Leita Kent
467 Sherwood Loop
Florence, OR 97439

1/19/02 - Kenneth Kent

January 19, 2002
To: Editor, Siuslaw News

Recent issues of the Siuslaw News have reported, with front page coverage, the potential problems indigenous to the proposed Indian casino. I for one can understand the many concerns and issues which could develop due to the addition of such a business venture to the economy of Florence. As well as the impact on a moral level. However, I fail to see the difference between this potential development and the 17-acre parcel located at Highway 101 and Munsel Lake Road.

The city of Florence, in all its infinite wisdom, has seen fit to diminish the lifestyle and property investment of approximately 100 families by rezoning the adjacent 17-acre parcel from residential to commercial. A property which is now owned by that infamous Eugene development company. Guess who that may be?

I fail to see what the city of Florence will achieve by ruining the retirement lifestyle of Florentine's Senior Community. (I capitalize that title on purpose.) I, for one, am extremely upset and disappointed in our city officials who, apparently, do not care about us and seem to be motivated by commercialism, rather than the quality of life here in our small city. Oh! I forgot, none of them live next to the proposed "big box development." None of them will have to experience the various forms of pollution that will be generated by the new commercial zone.

Kenneth Kent, Florence

8/30/00 - Debby Todd

Growth. No Growth. The mere mention of the topic at social gatherings makes people
uncomfortable. Everyone is afraid they'll offend their friends if their opinions differ - so no one is openly discussing the issue. Local governments all over the state are making decisions based on emotion, rhetoric, and darn good sales pitches, with little thought to the magnitude of their decisions. And planning departments are no better. They're afraid to tell the public the real facts - many a planner has lost her job because she tried to tell a group of developers that it would be cheaper to the city in the long run to just buy a piece of property and turn it into a park.

Right now, the City of Florence is contemplating a $20 million decision, and they don't even
realize it. Its not that Florence is particularly bad, or irresponsible, or even unusual - it's just that no one has told them how much things will cost. This same story has unfolded in city after city throughout the state. The characters may be different, but the numbers remain pretty much the same.

The city of Florence is proposing to add another 173.87 acres to its Urban Growth Boundary - that's the line drawn outside the city limits which is expected to fill in and become part of the city within the next 20 years. You would think that would be a good thing: more people equals more taxes paid, equals more money to pay for government services. And you would expect that the property taxes are set at a level that would ensure that everyone was paying his own way - that any increase in government services would be offset by the increased taxes.

Not so, says Eben Fodor in his 1998 statistical analysis of the cost to communities in Oregon.
Fodor’s analysis shows a net cost to existing residents of $33,260 per new home. Florence's year 2020 population projections use a figure of 2.04 people per home, and 4.84 homes per acre. The total number of new homes that could be expected in the 173.87 acres would be 841.5. Under current city rates, each home could be expected to pay about $3,950 in systems enlargement fees, which would leave a net cost of $29,310 per home. Based on Fodor’s statewide figures, the total cost of increasing the size of the city by 173.87 acres - $24.6 million. Now, I'm not a statistical wizard, but I thought that seemed a bit much. So I tried adjusting the figures to more fully reflect the small community where I live, Florence, population 6,865.

Most newcomers to Florence are retired. Half of the proposed expansion is around a golf course. The other half is already developed, and their kids are in Florence's schools anyway. So there probably would be less impact on the schools - discounting the $11,809 allocated to school costs by 50% equals $5,904.

Sewer system costs are a whole other matter here in Florence. We've just built a new sewer plant designed to take care of 12,000 people. The cost for that improvement was spread out over 20 years and some of that cost will be paid by newcomers through systems enlargement fees. Unfortunately, those fees seldom, if ever, cover the whole cost of the enlargement necessitated by new growth. No discount to the $1,660 allotted to sewer system costs.

Next comes costs of building new roads to serve the new areas - $4,430. One-half of the 173 acres is already served by a small, two lane County road. If that area of Florence is brought into the city, it will be the city's responsibility to upgrade the road to accommodate the increase in growth. The other half of the acreage will require new roads to access. More people in the other one-half to be developed will also mean wider roads, new curbs, drainage, lighting, signage and traffic signals inside the city. No discount there.

Now on to water services - $2,729 per house. Right now, Florence is holding its own during the summer. About one-third of its water is purchased from a neighboring water district. The City is planning to build a new water well system, which is projected to cost $12 million over the next 20 years - in order to accommodate new growth. No discount there.

Parks - $2,915 per house. Our parks are projected to be insufficient for the size of our
community by the year 2020. The argument could be made that those retired folks don’t use the parks all that much, and maybe we’ll be able to get by with the existing parks we have - especially considering there are so many state and federal forest lands in the area. Deduct that cost from the estimate.

Stormwater Drainage - $483. Most of the land proposed for inclusion is in the northeast area of Florence - an area that is infamous for its stormwater flooding problems. The city is working on a city-wide stormwater management system. You can bet that’s going to be a big item in the city’s budget, and 173 more acres would be adding to the problems. $483 seems reasonable.

Expanded library and fire protection facilities - $441 and $298. The library is in pretty good shape right now, but again, the increased retirement population can be expected to put more of a strain on services than do working families, so that seems to be a legitimate cost. Fire protection services have been delegated to the rural fire department, but an increase in the city’s share of the service area will no doubt be reflected in an increase in service rates to the City. No discounts there.

Last, but not least, electric power and distribution costs - $8,494. Since the local public utility district takes care of that, it would be very simple to just ignore the costs. But each rate payer living in the city will be paying their share of the net costs associated with the PUD’s additional equipment needed to serve more people. Without the city encouraging more houses in the 173 acres, the existing power facilities would be sufficient to serve existing city rate payers. No discount.

That leaves us with a locally-adjusted cost to the taxpayers of Florence of $24,439 per house. This figure does not take into account that about half the acreage already has houses on it, so there would be only about one-half of the normal systems enlargement fees going into the city coffers.
.
Net cost to existing taxpayers of adding 173 acres to the city: $20,553,199. My calculator was already heated up, so I went one step further: The 6,865 people now living in Florence can each expect to pay about $2,993 more for the same (or more likely less) city services that they now receive.

One comment often comes up in conversation - "all those new people will also be paying city
property taxes, so they really will be paying their fair share". The only problem with that statement is that property taxes only pay for “operation and maintenance” of existing government services, including increased staffing needed, etc. The $20.5 million cost to the residents of Florence only deals with “capital” costs - like adding another wing to the library, buying another fire truck, or adding another well to produce drinking water.

Bottom line - local governments need to check out their own bottom line before they expand city boundaries.

(Signed)
Debby Todd

8/3/00 - Florentine Home Owners

Florentine Home Owners Association

August 3, 2000

TO: Florence City Council
FROM: Florentine Home Owners Association
RE: Proposed Changes in the Comprehensive Plan

Our specific concern is the proposed rezoning in the NCA of the 17-acre parcel that fronts along Highway 101 on the east and abuts Florentine Estates. Our 428 lot owners, representing about 750 voters (or 17% of the voting population), purchased their property and built their homes with the understanding that his parcel was zoned for single-family residences and would remain residential. In fact, it was understood by many that this area would be a possible annexation to Florentine. Four of our streets in the north end of the development are dead ends, not cul de sacs, that appear to have been planned as entrances into the area when developed.

We have 17 residences with an average value of $150,000 that will be directly, adversely impacted by the proposed zoning changes, with another 96 residences that will be substantially impacted and many more that will be somewhat impacted. Those 17 directly impacted homes generate an annual property tax of in excess of $21,000 and represent a value in excess of $2.5 million. When you add in the 96 additional substantially impacted homes, that property tax base increases to $140,000 and property values increase to over $18 million. If you add in those additional homes that will have some impact, the numbers go way up.

We are concerned that our owners are not being given adequate consideration concerning the
potential for many problems relating to noise, lights, odors, pollution, stormwater, blowing sand, operating times, trash collection, and loading and unloading of goods that will occur during any construction and the operation of a large retail facility in our back yard.

The proposed draft of the Land Use, Policies, #1 states that “Designation and location of land uses shall be made based on an analysis of documented need for land uses of various types, physical suitability of the lands for the uses proposed, adequacy of existing or planned public facilities and the existing or planned transportation network to serve the proposed land use, and potential impacts on environmental, economic, energy and social factors.” It also states “The North Commercial Area (NCA) has been established to address recent interest in regional commercial development where opportunities exist for large single parcels, or consolidation of vacant parcels.” Does “recent interest” constitute “Documented need for land uses”? What we don’t see is adequate proposals that address protection for the existing developments based on the “potential impacts” that this document admits exist.

In the Background information provided in the document it addresses the fact that “Florence is
growing in population, primarily those individuals 65 years of age and older and is growing faster than Lane County ...” That’s us: the 65 years and older people you are talking about. One of the reasons “Florence continues to survive economically as an ideal retirement spot” is because of Florentine and the economic stability we bring to this community. Now that we are here, and have purchased property and built homes, we feel that we should be given adequate consideration regarding protecting our property values and quality of life. Most of us have moved here to escape the nose, traffic and related problems that seem to be a part of life in larger communities. We moved here because Florence offered a different lifestyle.

In the Residential section of the plan, it states as the goal: “To create residential living environments that satisfy a wide variety of local and regional population needs and desires and which add long-term community value.” That is just what we feel has happened her e in Florentine, and now we see that the changes being proposed will have exactly the opposite effect of taking away from our “long-term community value”. It would seem that the stated goal and proposal for rezoning the NCA are at odds with each other.

It also lists as number 1. under Policies: “The City shall encourage the use of residential planned unit developments,” and under number 5., it says “Residential living areas shall not be located in areas subject to high concentrations of vehicular traffic, noise, odors, glare or natural hazards.” If the object is to encourage PUDs, then after they are there, why make zoning changes that have adverse impact on them? This plan will certainly increase our exposure to traffic, noise, odors, glare and natural hazards. Number 6. says that “Existing and proposed residential areas shall be protected from encroachment of land uses with characteristics that are distinctly incompatible with a residential environment.”

We are an “existing” residential area. Where is the protection from all of the increased exposure? What the plan says is that “Where the NCA abuts residentially planned or developed land (that is Florentine Estates) effective undisturbed or landscaped buffers shall be incorporated into commercial or other non-residential development plans, as well as the use of attractive barriers or walls.” Do any of us really believe that a landscaped buffer of 35' and a 6' fence or block wall will keep out the nosie, glare, blowing sand or stormwater? And even that is assuming that the developer doesn’t apply for and receive a “reduction of the required setback” that the Planning Commission resolution No. 00-6-27-50 allows with “the construction of a minimum 6' solid, decorative concrete and/or block wall”. And, what good is a 6' wall when the same resolution also allows “a greater height up to a maximum of 50' may be permitted by conditional use of the Planning Commission finds that the structure is in compliance with current life safety codes.”

The plan acknowledges that “Some residential subdivision both inside city limits and within
urbanizable lands which were developed prior to 1995 have experienced infrastructure problems, stormwater deficiencies, slope failures, flooding due to high groundwater tables and invasive weed infestations.” It says an objective is to insure a more consistent application of development standards to avoid these problems. We certainly have stormwater deficiencies and flooding due to high groundwater tables. We have well documented these problems and have test wells in operation. A large retail development will certainly have a very direct impact on the already existing problem. Covering over large amounts of land only means the water has to go somewhere else, and we are the “else”. Florentine is the existing, single family residential subdivision that abuts the NCA and we are the ones to be impacted. We are not a “hypothetical subdivision”, we are people, homeowners, taxpayers, volunteers, citizens and voters of Florence. We are here now, today, and hopefully tomorrow and we want our concerns acknowledged and addressed within the planning process in a way that provides adequate protection for the quality of life we have established and for the value of properties we have worked so hard to obtain.

We are not opposed to growth and to new developments. They are necessary to provide the jobs and services that a community needs. We are, however, very concerned that in planning and providing for growth and new developments, that the existing developments are not forgotten, overlooked, ignored, or abused by the very people that we have elected to represent us. Please give careful consideration to exactly what this proposed change would do to Florentine Estates and its residents.

Respectfully,

(Signed)
Nola Xavier, President, Board of Directors

5/3/00 - Howard Shapiro

Howard H. Shapiro
P.O. Box 2651
Florence, OR 97439

The City of Florence
Periodic Review Comments

May 31, 2000

In reviewing your draft plan for the UGB study, we find it necessary to make a few pertinent
observations pertaining to the proposal to include the areas adjacent to Ocean Dunes Golf Course and Munsel Lake into the UGB of the City of Florence.

1. As stated on page 3 of your urbanization and Land Use study dated 5/5/2000, in referring to residential lands, “... Although the UGB is adequate for the 2000-2020 periods ...” you then proceed to attempt to justify why we should include these two additional residential areas in our UGB for the new Comp. Plan. If we have enough residentially zoned land, we have no need to add additional lands.

2. One of the reasons given on page 4 for including the Munsel lake area is that a sewer main must be run through the County land. We would like to know why the sewer main couldn’t be run along any one of the streets that the city already controls and maintains. It can connect with the highway 101 connector at any point along the highway.

3. The plan also states that some of the lots are developed with septic systems and that if they fail they may pollute the lake. If the city is truly interested in maintaining the purity of the lake why isn’t the whole of Munsel Lake included into the proposed UGB extension to be eventually sewered? There are many houses all around the lake that are on septic systems and they may also fail. Won’t their sewage pollute the lake?

4. It is also stated that Lane County would like to have the city maintain all of Munsel Lake Road. Of course they would, I’m sure that they would like to see us maintain all of their roads, if possible. It’s cheaper for them! We don’t think that the already overburdened Florence taxpayers would like to pay for the additional expense of maintaining a road that the county already maintains out of their broader tax base.

5. Paragraph 3 on page 4 addresses the 80-acre Ocean Dunes “adjustment”. It states that part of Ocean Dunes Golf Course lies in the city and part is out of the UGB in Lane County, and that the developer must satisfy both the city and county regulatory procedures and priorities. This is misleading and not entirely accurate. If a developer or individual builds a house in the city, he satisfies the city codes, and if he builds in the county, he satisfies the county codes. Why should we change our UGB to make it easier for a developer to build? We don’t think it is fair for the taxpayers to be asked to support the infrastructure necessary if this area is included in the UGB and the city decides to annex it. The golf course developer knew that the project was split between the county and city when he decided to develop the golf course. It is questionable that the developing golf course frontage houses and condominiums will substantially increase the recreational opportunities of the golf course. It will increase the monetary value of the property and will generate some taxes but probably not enough to justify the expense of the eventual annexation that the city plans. It is, however, possible that fairway frontage condominiums may diminish the playability of the course. We don’t think that the case flow of the golf course should be the concern of the city, since ti is not a municipal course but a private one, and the money generated form green fees, etc. doesn’t go into the city coffers but back into the running of the private course and into profits of the owners and not into the city budget.

From the looks of the course, it doesn’t look as though water is a problem. The greens and fairways look well watered and maintained regardless of where the water is coming from. We all get our water form the same aquifer, so whether they get their water from Heceta Water District, the city or a well, should not be a consideration in placing this area into the UGB.

5. If the supply of land around golf courses is limited as stated on page 19 of the City of Florence Periodic Review Urban Growth Boundary Study and Amendment, why are there so many vacant buildable lots around Sandpines golf course, which is already in the city limits? The real estate inventory in Florence is already inordinately large. It would seem to be prudent and to the benefit of most of the citizens of Florence to wait until the demand begins to catch up with the supply of real estate before encouraging more speculative building. The study also broaches the idea of the necessity of building yet another golf course to take care of this mythological need for golf course residential properties. It is quite rare for a city the size of Florence to even have one golf course, let along three. There are plenty of golf course properties in Florence for development. All the developer has to do is go to the correct permitting agency for approval.

6. The same page also states that the city has designated Munsel lake Road as a minor arterial in its draft TSP. This is a highly inappropriate designation for this narrow residential, dangerously curvy road. Between the golf course and North Fork Road, unless Lake Road has a 25 mph speed limit because of the residential properties that come down to the edge of the road. There are no shoulders or sidewalks and there are often small children playing at the roadside. We shudder to think of what could happen when semi-trailer delivery trucks begin to use the road with a delivery deadline to meet. Farther to the west the road has been somewhat straightened and the speed limit around the curves is now 20 mpg. This could create a dangerous hazard for truck traffic and the additional traffic that would come from a minor arterial designation. The city’s plan to use Munsel Lake Road as a minor arterial to service Fred Meyer and the “northern commercial node” is seriously flawed and dangerous for the people that live in that area. We can’t agree that it is worth endangering lives and committing the taxpayers of Florence to the expense of the necessary road improvements to put the two areas that are cited into the UGB for the purpose of creating a dangerous road to service the “northern commercial node” and Fred Meyer.

(Signed)
Howard H. Shapiro

Maps	CFF Comments	ODOT Comments	DLCD Comments	Public Comments

Citizens For Florence
P.O. Box 1212
Florence, Oregon 97439

E-mail Address: citizensforflorence@yahoo.com

Copyright © 1998-2002 Citizens For Florence. Users may download information from this web site for personal use only. Unauthorized copying or distribution of this site or any of its contents without the express permission of the author is expressly forbidden.