Regionally Significant Industrial Area

Staff Analysis: Central Douglas Nomination

September 2012

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I. Executive Summary

The nomination is for three sites totaling 358 acres along I-5 in Central Douglas County.

Letters of support from the owners are provided for all three sites along with resolutions

of support from the cities of Roseburg and Sutherlin as well as Douglas County. The full

nomination as submitted by the Partnership for Economic Development in Douglas

County can be found at http://www.oregon4biz.com/The-Oregon-

Advantage/Sites/Industrial-Development/Industrial-

Areas/nominations/PartEcDevCentDouglas.pdf.

The three sites as a whole offer an attractive combination of industrial characteristics

including rail and highway access, utilities, readiness, zoning, site sizes, and neighboring

uses compatible with industrial development. Significant investments in rail and road

improvements as well as certification make the sites worthy of the protections afforded

by the Regionally Significant Industrial Area designation. All three sites are considered

to be on the market and are considered viable for a significant cross-section of statewide

recruitments.

With a labor force of 46,209 persons the Douglas County Regional labor force ranks

eighth in the State of Oregon and a clear majority of the region’s labor shed is within

commuting distance of all three sites.

It is appropriate to consider the sites as a group, as they offer a strong compliment of

highway served industrial options to the central Douglas County region.

The formal nomination by the Partnership for Economic Development in Douglas County

is considered factual and complete for consideration for designation by the Economic

Recovery Review Council (ERRC).

Evaluation

The best basis for nomination could be made on the basis of the following factors:

• The protection of community and state investments in infrastructure could be

made for all three sites. The best case for protection of investments in a

Site Name Jurisdiction Acres Ownership

Back Nine Roseburg 130 Back Nine Development

Stearns Lane Sutherlin 196 Alaska Sutherland Knolls Corporation

Sutherlin Industrial Park Sutherlin 32.3 Douglas County

Total 358.3

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combination of road and rail infrastructure are most pronounced at the Del Rio

Road site, which has had recent investments in both a rail spur and an

interchange. Local infrastructure investments and past certification of the

Sutherlin Industrial Park and Stearns lane also warrant protection.

• With their near interchange access and visibility, the Back Nine and the Sutherlin

location are the most likely to be under threat of conversion, though no actual

interest in by other uses has been expressed in the application or as part of the

staff analysis.

• As a whole, the sites offer a very competitive mix of options for a wide variety of

industrial and other traded sector users. All three sites have superior interstate

access; as mentioned the Back Nine offers intermodal transfer potential; gross

acreages ranging between 23 and 196 acres offer adequate choices for a broad

range of recruitments; and public and private ownership offers transactional

flexibility.

• Finally, all three sites are considered to be on the market and have ownership that

is supportive of the RSIA designation.

There are only a couple limitations or obstacles to the development of industrial and other

traded sector businesses on the nominated sites:

• Some minor transportation improvements could be required depending on the

traffic impact relating to any proposed development.

• The Sutherlin Industrial Park and the Stearns Lane site are in a community,

Sutherlin, which does not have an industrial pretreatment program. Industrial

developments on these sites requiring pretreatment would likely have to initiate a

process with the City of Sutherlin to develop such a program.

II. Statutory Requirements:

(2) “Regionally significant industrial area” means an area planned and zoned for

industrial use that: (a) Contains vacant sites, including brownfields, that are suitable

for the location of new industrial uses or the expansion of existing industrial uses and

that collectively can provide significant additional employment in the region;

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BUSINESS OREGON COMMENTS: All sites within this nomination area have been

reviewed by the Oregon Business Development Department. There are multiple vacant

sites including brownfields with NFAs that are appropriate for new industrial uses and

expansion for existing businesses. All of the sites are on the market and offer gross

acreages range between 32 and 197 acres. All of the sites have been previously certified

(Sutherlin Industrial, Stearns Lane) or are in the process of being certified (Back Nine).

DLCD COMMENTS: All three sites are planned and zoned for industrial use. The Del

Rio Back Nine site is zoned M-3 Heavy Industrial by Douglas County and is designated

Industrial on the Roseburg urban area comprehensive plan map. The M-3 zone permits a

wide range of industrial uses outright (i.e., without a showing that the use complies with

criteria). A short list of industrial uses (e.g., wrecking yards, slaughterhouses) require

compatibility review through a conditional use permit process. The uses permitted in the

M-3 zone include, by reference, those permitted in the M-1 and M-2 zones. Permitted

uses are predominantly consistent with the definition of “industrial use” in ORS 197.722.

The M-1 zone allows: builder supplies including retail sales of lumber, agricultural

supplies and machinery sales room; mobile home and recreational vehicle sales; and

veterinary clinics. The M-3 zone permits “one mobile home or watchman’s quarters in

conjunction with a use listed in this article.”

The Sutherlin Industrial Park and Stearns Lane sites are each designated M-2 General

Industrial by the city of Sutherlin on the comprehensive plan/zoning map. This zone

permits these uses outright: light manufacturing; warehouse and distribution; vehicle

wrecking yards, offices incidental to industrial use, and “government facilities (e.g.,

public safety, utilities, school district bus facilities, public work yards, and similar

facilities).” Heavy manufacturing, assembly and processing of raw materials are

permitted subject to compatibility review through a conditional use permit process. The

M-2 zone also allows caretaker residence, park and open space, and vocational school

uses outright.

DEQ COMMENTS: This area is currently in attainment for all air pollutants. However, if

a new facility emits at a rate greater than a significant emission rate, as defined in rule, it

would need to conduct an air quality analysis in order to demonstrate ambient air quality

will remain in compliance with federal standards. This analysis would have to consider

competing sources that are located within the same geographical area.

Sub-Area 1. Back Nine, This property was occupied by the former Roseburg Forest

Products Winchester Mill. The property is listed as Site #4441 in DEQ’s Environmental

Cleanup Site Inventory (ECSI) database and includes tax lots 300, 500 and 800. In

2005, DEQ made a No Further Action (NFA) determination that applies exclusively to

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the former log pond on tax lot 500 based upon soil data. In 2006, based upon review of

soil and groundwater data provided in the Independent Cleanup Program report, DEQ

made a Conditional NFA determination for the site. DEQ determined that soil

contamination on the site appears to pose no unacceptable risks to people or the

environment under current and future industrial land use conditions. However,

groundwater contamination could pose an unacceptable risk if used for drinking water,

and DEQ required that an Easement & Equitable Servitude (E&ES) prohibiting indoor

uses of groundwater from the site. As long as the conditions in the E&ES are met, no

further action is required. The E&ES was recorded with Douglas County in 2006.

The Roseburg Urban Sanitary Authority has adequate capacity and capability (pre-

treatment program) to provide sewage service to this property. Several routes for line

extension to reach the property have been identified.

Sub-Area 2. Sutherlin Industrial Park, Two ECSI files pertain to this property. ECSI Site

#560 (tax lots 303 and 303) received an NFA determination from DEQ in 1994 for the

cleanup of petroleum products associated with underground tanks. ECSI Site #4575

includes tax lots 303, 304, 100, 101 and Section 30 TL 801. In 2007, DEQ reviewed a

Supplemental Phase II Environmental Site Assessment report and determined that

cleanup was required to address elevated arsenic concentration in soil at the Sutherlin

Industrial Park II site. However, more recent data from other investigations indicates that

the background concentration of arsenic may be naturally high in soils in this area.

Additional investigation is warranted at this site to determine whether a remedial action is

necessary for any part of the site. Anything over background levels would be considered

for remedial action if there is anticipated exposure for workers at the site. If needed, a

remedial action might involve measures such as capping, consolidation and capping, off-

site removal or some combination of these.

The City of Sutherlin can provide sewage service to this property. Sutherlin has treatment

capacity, but no industrial pretreatment program. So, if the proposal is for a categorical

industry, Sutherlin would need to establish a program. Typically, the City could ask the

industry to pay for the cost of the industrial pretreatment program.

Sub-Area 3. Stearns Lane This property is undeveloped. DEQ reviewed the site in 2005

in response to an OECDD site certification request. An August 2000 Phase I ESA and an

updated September 2005 Phase I ESA were reviewed. Documentation of removal of

asbestos-containing shingles from Tax Lot 100 is included in the 2005 report. The report

noted the ‘small orchard’ on a 1943 aerial photo was a single line of four trees. Based on

this information, no further inquiry into possible pesticide usage was required. DEQ

memo dated November 2, 2005 addressed to Bev Thacker concludes a No Further Action

status for Tax Lots 100, 900, 1500 and 1600. The site is listed as ECSI #4533. DEQ’s

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NFA does not apply to Tax Lot 1200, where a recognized environmental condition was

identified and recommended for further assessment. However, DEQ understood that this

tax lot 1200 was not being considered for Industrial Lands Certification at that time.

DEQ also recommends that the uncapped well on the northeast portion of Tax Lot 100 be

properly capped or abandoned in accordance with Oregon Water Resources Department

guidelines.

The City of Sutherlin can provide sewage service to this property. Sutherlin has treatment

capacity, but no industrial pretreatment program. So, if the proposal is for a categorical

industry, Sutherlin would need to establish a program. Typically, the City could ask the

industry to pay for the cost of the industrial pretreatment program.

In a letter associated with the site certification application, dated November 18, 2005,

MAP Engineering, Inc. proposes a STEP system with on-site treatment and disposal.

However, DEQ cannot permit this type of private system if city sewer service is both

‘legally and physically available’. The City would determine legal availability and DEQ

would work with the City to determine physical availability. State rules and laws

prohibit DEQ from issuing an onsite system permit when sewer is available (OAR 340-

071-0160(4)(f) and ORS 454.655(4)).

DSL COMMENTS: Back Nine Site: Removal-fill permit 33676-RF was issued in 2006

authorizing approximately 42 acres of wetland impact and 51 acres of waters (log pond)

impact. An approximately 10-acre on-site mitigation area has been established. The

remaining mitigation obligation is fulfilled off-site. All wetlands/waters on within this

RSIA have been permitted for development excepting the designated 10-acre wetland

mitigation area.

Sutherlin Industrial Park: No removal-fill permit history within this RSIA. A wetland

delineation for this RSIA was approved in 2001 and renewed in 2007 documenting

approximately 11 acres of wetland. The delineation is expired. Future projects within

this RSIA will require wetland delineation. Future projects will likely qualify for a

removal-fill permit waiver as part of DEQ-approved remedial action (OAR 141-085-

0595). An off-site conceptual mitigation plan has been reviewed and acknowledged by

DSL through the industrial site certification program.

Stearns Lane: No removal-fill permit history within this RSIA. Two wetland

delineations were approved for this RSIA in 2004 documenting at total of approximately

10 acres of wetland and 0.5 acres of seasonal streams. The delineations are expired.

Future projects within this RSIA will require wetland delineation. Future projects may

incur substantial removal-fill permitting requirements.

III. Statutory Requirements (continued):

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(2) (b) Has site characteristics that give the area significant competitive

advantages that are difficult or impossible to replicate in the region;

BUSINESS OREGON COMMENTS:Within Douglas County there are only five other

industrial sites at least 15 acres in size listed for sale or lease on the ExpandInOregon

industrial site data base. Three of these sites lack municipal infrastructure, one is heavily

impacted by wetlands and the third is located at the coast in a different market.

The primary attributes that are difficult to replication on the Back Nine site include a rail

spur, location on an interchange that is undergoing a substantial improvement, and

ownership committed to industrial development on the site. The Sutherlin Industrial Park

offers adjacency to the freeway, ready to go utilities, recent development successes on

adjacent parcels, and certification of a portion of the site. The Stearns Lane site offers the

potential for a large campus-like setting and superior internet and power thresholds.

1. Industrial uses proposed for sites within the nominated area include:

• Sustainable building products

• Flat glass manufacturing

• Glass container manufacturing

• Warehousing and distribution

• Data farms (Stearns Lane)

These proposed uses were identified in the Douglas County Economic Development

Road Map, Chabin Concepts, 2010

IV. Statutory Requirements (continued):

(2) (c) Has superior access to transportation and freight infrastructure,

including, but not limited to, rail, port, airport, multimodal freight or

transshipment facilities, and other major transportation facilities or routes; and

BUSINESS OREGON COMMENTS: All sites within the nomination have superior

access to Interstate 5. The Back Nine industrial site has a combination of rail and

highway service that is difficult to replicate and even harder to develop..

ODOT COMMENTS: Back Nine: The Back Nine site is included in the Roseburg urban

area and located west of Interstate 5 (I-5) and north of Del Rio Road. The site has access

to I-5 at the Del Rio Road interchange, which is currently being reconstructed. The

reconstruction efforts have anticipated industrial level of development within the Back

Nine and therefore should provide a good level of access between I-5 and the site. OR 99

is located just east of I-5 and runs parallel to I-5 in this area and can provide additional

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north/south route options if needed. The Back Nine also has access to rail facilities. In

fact the CORP rail line is at the north edge of the site. Additionally through the

ConnectOregon program, significant investments have been made in this location

providing ample switching and loading capacity that can serve the industrial area.

Airport service is in close proximity as the Roseburg airport is only located a few miles

south of the site. The Roseburg airport provides some limited freight opportunities. For

larger freight needs, the Eugene airport is located approximately 65 miles north of the

site. The Roseburg area is served by transit. While transit options may be limited in the

area today, it may be possible to work with the transit provider to increase service if

developed along with the potential of increased service to Umpqua Community College

campus which is located just a mile or so east of I-5 in this area.

Stearns: The site has direct access to OR 138 in Sutherlin. The site is accessed through

an at grade un-signalized intersection. Improvements to this intersection will likely be

needed to accommodate industrial scale development. OR 138 connects to I-5 just a few

miles to the west of the site. The I-5 interchange was recently reconstructed and should

provide very good access to I-5. In addition, the Stearns Lane site does have a local road

access connection to I-5 at the south Oakland interchange. This interchange would likely

only serve as a secondary access to the site as the interchange is not designed for

significant levels of traffic and both directions onto the interstate are located on

significant grades which would affect truck traffic. However a secondary access is

desirable if problems were to occur at the primary interchange connection. The port of

Coos Bay provides access to marine freight shipping options. The Stearns Lane site does

not have direct site access to rail, however, access to the CORP line at the Back Nine

development site. As the Back Nine site has very good access to rail, as part of the

approval process, the ERRC may want to encourage the Back Nine site to develop good

rail/truck transfer facilities on site to assist the sites contained in this application as well

as other industrial opportunities within the greater area. Air service again is provided

through the Roseburg Airport approximately 12 miles to the south or Eugene Airport

approximately 60 miles to the north.

Sutherlin Industrial Park: The site is located in the urban growth boundary of Sutherlin in

close proximity to I-5. The site has two potential access locations to I-5. Both Exit’s 135

and 136 provide access to the site and I-5. The interchange at MP 136 is the primary

interchange to the City of Sutherlin and was recently reconstructed providing improved

capacity and access to I-5. Access to I-5 at this interchange requires utilizing several city

and county owned facilities. The site also has access to the interchange at MP 135. This

interchange is a more rural design type of interchange and would likely provide a

secondary access to I-5. The site also has access to OR 99 which is located just to the

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west of the site. OR 99 would provide an alternate north/south travel option to I-5. Rail

and air access are the same as the Stearns Lane site.

All three sites would have access to the Port of Coos Bay/North Bend via rail (CORP)

and truck using OR 138/OR 38 or OR 42 located south of Roseburg. Additionally,

ODOT has completed Interchange Area Management Plans at Interchange 136

(Sutherlin) and Interchange 129 Del Rio Road, and each plan has anticipated

development of the identified industrial sites contained in this application.

V. Statutory Requirements (continued):

(2) (d) Is located in close proximity to major labor markets.

BUSINESS OREGON COMMENTS: The Central Douglas County area consists of three

locations, one in Wilbur and two in Sutherlin, all of which are located in Region 6,

Douglas County. According to Longitudinal Employer-Household Dynamics data from

the U.S. Census Bureau, Region 6 had 35,245 employed workers in 2010. There were

30,594 employed workers living within a 25 mile radius of the Central Douglas County

area in 2010, which represented 87 percent of Region 6’s employed workforce. The

Central Douglas County area includes well over half of the region’s workforce, and is

located in close proximity to the major labor market of the region.

BUSINESS OREGON BUSINESS DEVELOPOMENT OFFICER: In addition to the

labor market information included with nomination materials, Roseburg area employers

describe a labor shed that extends South to Grants Pass (Josephine), and North to the

Cottage Grove area (Lane) and West to Coos County. In June 2012, the civilian labor

force in Douglas County was 46, 012 individuals with 5,510 individuals unemployed.

VI. ERRC Adopted Policy:

A. The ERRC intends to designate a variety of RSIAs determined to have the

most potential for rapid job creation across the state.

BUSINESS OREGON COMMENTS: The sites represented in this nomination have the

superior potential for rapid job creation within the SW region; and, because of their size,

highway and rail access, readiness, and services (water, sewer, power), are among the

sites with the best potential within rural Oregon

VII. ERRC Adopted Policy (continued)

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B. For each nominated RSIA, ERRC will consider information regarding the

purpose of the designation, whether one, two or all the following:

a. Preservation

i. Protection from land use conversion to other than industrial

zone

ii. Assurance of compatible neighboring and uses

iii. Preservation of assets for best industrial use e.g.

transportation access, utilities, site characteristics

BUSINESS OREGON COMMENTS: There is a substantial public investment in

infrastructure connected to the Back Nine site and the Sutherlin Industrial Park Site

including:

a. Connect Oregon Grant (Back Nine rail yard)

b. County and ODOT highway funds (Back Nine interchange, Sutherlin access rd.).

c. Wetland delineation and mitigation (Sutherlin Industrial Park).

d. Municipal water and sewer (Sutherlin Industrial Park)

ODOT COMMENTS: All three sites within this proposed area are quality industrial sites

and have gone through the industrial certification program with Business Oregon. None

of the sites will likely have significant pressure to convert from industrial, however,

given the close proximity to the interstate and the recent infrastructure investment in the

interchange at Del Rio Road, there is always that possibility. The investment recently

made in the interchange as well as the CORP rail facilities around the Back Nine site,

make this site a high priority area to protect for industrial uses. Likewise the other two

sites within this area, all can work very well together to ensure significant industrial

development growth potential is retained for the area. Given the transportation assets in

the area, the proximity to the community college in the area and the general labor markets

of the immediate area, designation could help provide assurances that industrial

opportunities will exist on these sites well into the future.

VIII. ERRC Adopted Policy (continued) b. Investment

i. Implementing a strategy of improvements for priority locations

ii. Targeting job growth in an area

BUSINESS OREGON COMMENTS: The targeting of job growth and investment at

these sites is wholly appropriate given the state and local investments in infrastructure,

transportation, and industrial site readiness.

IV. ERRC Adopted Policy (continued)

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c. Marketing Advantage

i. Assuring attention for certified sites

ii. Complimenting cooperation and partnership of local and state

government

BUSINESS OREGON COMMENTS: Stearns Lane and the Sutherlin Industrial park sites

are “shovel ready” certified sites. A majority of the documentation for certification of the

Back 9 site has been submitted to Business Oregon.

RST COMMENTS: Development of the Back Nine has been a priority project of the

Regional Solutions Team since 2003. The site was nominated as an “Opportunity Site” in

2003. This process predated the Current certified site designation program. Projects have

included:

1. Wetland mitigation

2. Freeway Interchange and site access alignment

3. Construction of the rail yard

near WilburDouglas County, Oregon

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4 Parcel Total Acreage 32.28 ac

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22.55 acres

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Sutherlin Industrial ParkDouglas County, Oregon

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