2010/05/26 Council Agenda Packet

October 23, 2009 Allan Giffen Director of Planning and Community Development and SEPA Responsible Official City of Everett 2930 Wetmore Ave., Suite 8-A Everett, WA 98201 Dear Mr. Giffen, The comments below are provided on behalf of Earth Holdings, LLC including several property owners of industrially designated land, and are in response to the request for comments on the Draft Supplemental Environmental Impact Statement (DSEIS) for CEMEX Materials, including the technical appendices to the DSEIS. The information regarding the amount of industrial land and industrial land availability, appears substantially different in previous environmental analysis from that in Appendix C 1 (South Everett Industrial Lands Analysis) of this DSEIS. It may be that the differences are due to smaller sub -areas being analyzed in this document. However, some explanation of the different land acreages should be provided to assist the reader in understanding the new analysis. For example, the prior EIS for the Comprehensive Plan, under Industry, states: "The Everett Planning Area has a large inventory of undeveloped industrially zoned land. Of the approximate 5,398 acres of industrially zoned land (26.5% of the total net land area), only 54 percent, or approximately 2900 acres, is presently developed... However, much of the inventory of vacant industrial land is affected by environmental constraints, reducing the amount of vacant and developable industrial land to approximately 1,437 acres... Most of the vacant and developable industrial land is located in the southwest Everett/Paine Field area, where few constraints to development exist... Another large industrially zoned aggregates mining area has a short remaining life expectancy and is expected to be reclaimed for industrial use." (Land Use Element, Background Information, A.2.e., existing conditions, emphasis added). . _... However, Appendix C 1 (South Everett Industrial Lands Analysis) of this DSEIS in Table 10 (p. 24) shows only 458.6 total acres of available developable industrial land in the Southwest Everett area. - The acreage numbers for developable industrial land seem substantially divergent, and some explanation or reconciliation of the analysis should be provided. Both the text of the SEIS and Technical Appendix Cl, should be revised to accurately state the findings included in the Everett Industrial Lands Policy Economic Analysis. Appendix Cl, p.4, shows a 25 year supply of remaining MM zoned land (under the 1995 -present average annual absorption rates). Likewise, . the information on page 24, as well as Table 11, p. 25 (Comparison of Industrial Supply and Demand) show a 25 year supply of MM land remaining. Conclusion 5 of the study, however, states that "the existing supply of developable industrial zoned lands ; are less than the amounts necessary for even a twenty year planning horizon." The following language should be added to the beginning of Conclusion 5: "With the exception of MM industrial zoned land which has a 25 year supply,..." This information should also be reflected in the body of the text of the SEIS. Since the absorption rates and industrial land supply are assumed to be an important factor regarding industrial policies, it should be noted in the text of the SEIS that the absorption rates are based upon the historical absorption rate from 1995 -present. The study assumes that the average annual absorption of industrial land will remain the same as that during the 1995 -present period. We believe this is an optimistic projection, since parts of this period were characterized by unusually high levels of economic growth and development, and also in light of other specific information in this study which documents the more recent significant downturn in economic and development activity. E.g. "The absorption of industrial land