Laserfiche WebLink
October 26, 2009 <br />Page 2 <br />1. Loss of Industrial Lands; Consistency with Land Use Policies. The Proposal will lead to <br />additional loss of industrial lands in the City. The DSEIS identifies this loss of industrial land as <br />an "Unavoidable adverse impact" of Alternatives 1 and 2: <br />Loss of 63 acres of industrial land for future employment / industrial growth. No matter if <br />changes are made to land use regulations that could lead to improved employment <br />densities and more sustainable employment, loss of this land would mean less (prime) <br />land for industry and employment. <br />(DSEIS, page 2-27.) The DSEIS makes this conclusion based upon the findings of "South <br />Everett Industrial Land Analysis" prepared by Property Counselors and dated July 2009. <br />(Appendix C of the DSEIS.) ("Property Counselors' Report"). The Property Counselors' Report <br />concluded: <br />[T]here is almost no M-2 land available for expansion or new development. There is <br />approximately 17 year supply of M-1 land. The supply would not be adequate for a 20 <br />year planning horizon even without a market factor recognizing that most all [sic] lands <br />may not be available on the market or that the characteristics of the available land may <br />not precisely match the requirements of market demand. The M -M land supply would <br />meet the 20 year planning horizon need with a market factor of 25%. <br />(Property Counselors' Report, page 4.) <br />This is a startling conclusion, which, given that the Proposal will strip 63 acres of prime <br />industrial land from the City's precious and short supply, in and of itself should compel the City <br />to deny the requested action. To confirm this finding, Campbell commissioned another leading <br />local industrial lands economist, Matthew Gardner of Gardner Economics, to review the Property <br />Counselors' Report. Mr. Gardner agrees with the findings of the Property Counselors' Report: <br />Overall, we agree that the argument relative to current land supply as it pertains to a <br />twenty year planning horizon is appropriate, and it is clear that there is a significant <br />shortage of developable M-2 land. Additionally, assumptions as to potential demand <br />appear reasonable, although we have not confirmed or otherwise investigated the <br />accuracy of the data that was provided to Property Counselors by Colliers International. <br />(Gardner letter, page 2.) 1 have enclosed a copy of Mr. Gardner's review with this letter. <br />2. Need to Amend the City's Industrial Lands Policies for which the City has Conducted No <br />Environmental Review. The DSEIS reaches another dramatic conclusion based on the Property <br />Counselors' Report: <br />Absent a compelling reason to do otherwise, Everett's Industrial Lands Policies call for <br />protection and preservation of such upland industrial areas, and the employment base <br />they represent. If'this proposal is approved, affected Industrial Lands Policies will need <br />DWT 134989140 0009244.000016 <br />