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declined nearly 50% from 2007 to 2008." "The current economic downturn is evident..." "Over half of <br />the new industrial space ... is slated for Pierce County". (p. 9). Therefore the potential supply of industrial <br />land in Southwest Everett could be much more than the twenty year planning horizon (and more than the <br />25 year supply of MM zoned land). <br />Whether the absorption rate will continue at historic levels (as assumed in this study) is a substantial <br />unknown, and this should be noted for decision -makers in the text of this SEIS. This is particularly <br />important given the widely divergent views regarding the time period necessary to recover from this most <br />recent recession. <br />It is also of note that the very great majority of industrial land development that did occur during the 1995 - <br />present time period has occurred in the area from Casino Road and to the north of Casino Road. This ' <br />Development Summary -Southwest Everett is well documented in Table 7, pp. 15-16 of appendix Cl. <br />Therefore, the absorption rate for industrial lands south of Casino Road would be substantially lower than <br />for the entire SW Everett study area addressed in Appx. C1. A map showing the location and distribution <br />of industrial land development during the time period analyzed in this document would be helpful to the <br />reader, and to decision -makers. <br />Finally, we support an appropriate revision to the policy language in the Comprehensive Plan that would <br />provide additional flexibility to decision -makers regarding conversion of industrial lands to other uses. <br />While a policy of discouraging the erosion of available industrial land, and maintaining the City's job base <br />is both reasonable and appropriate, under very limited circumstances such changes may be warranted. Such <br />decisions should be based upon site specific information, and the new policy language and criteria should <br />reflect that. We agree that "context" is an important consideration. (Apex. Cl, Recommendation 2). <br />Factors to be considered should include the properties suitability for industrial use, but should also include <br />the relationship and compatibility with adjacent land uses, whether the proposed change in designation <br />would be a logical extension of adjacent existing land use designations, and adjacent land use development <br />patterns. We could provide some draft policy language to that effect if desired, which would expand on, or <br />modify the draft recommendation in Appx. Cl, Recommendation 2. <br />Thank you for the opportunity to comment on this Draft SEIS. <br />Sincerely, <br />Robert A. Landles <br />For Earth Holdings, LLC <br />