Affidavit of Mayre FlowersNA! J'J`I� r�� �, c[eel of D{Sirlc Court
ay Deputy
AFFIANT BEING FIRST DULY SWORN, DEPOSES AND SAYS:
1. MAYRE FLOWERS IS EXECUTIVE DIRECTOR OF CITIZENS FOR A
BETTER FLATHEAD, A NON PROFIT EDUCATIONAL, ORGANIZATION
ESTABLISHED IN 1992 IN FLATHEAD COUNTY. DURING THIS TIME
CITIZENS FOR A BETTER FLATHEAD (CFBF) HAS ACTIVELY ENCOURAGED
CITIZEN PARTICIPATION IN NUMEROUS LAND USE AND 'TRANSPORTATION
ISSUES IN OUR COUNTY. WE HAVE SOUGHT TO PROVIDE THE PUBLIC
UP-TO-DATE INFORMATION ON DEVELOPMENT PROPOSALS FROM A
VARIETY OF SOURCES SO AS TO ENCOURAGE INFORMED CITIZENS
PARTICIPATION. CFBF'S HAS DEVELOPED EXPERTISE IN PLANNING AND
GROWTH ISSUES IN BOTH THE COURSE OF OUR ON GOING WORK AND
RESEARCH AND IN THE EXPERIENCE AND RELEVANT TRAINING OUR
STAFF AND BOARD BRING TO THIS WORK.
2. CFBF HAS HAD STAFF, BOARD, OR MEMBER REPRESENTATION AT
ALMOST ALL, IF NOT ALL PUBLIC HEARINGS AND MEETINGS ON THIS
PROPOSED NEIGHBORHOOD PLAN AND MOU.. WE HAVE ALSO PROVIDED
TESTIMONY BEFORE THE LAND BOARD. AT THESE MEETING WE HAVE
REPEATEDLY RAISED ISSUES AND ALTERNATIVES THAT WE FELT SHOULD
BE CONSIDERED IN THE DEVELOPMENT OF THIS PLAN. OUR
ORGANIZATION AS WELL AS CONCERNED MEMBERS HAVE SUBMITTED
COMMENTS AT PUBLIC HEARINGS THAT ARE OF PUBLIC RECORD. WE
HAVE FEATURED ARTICLES IN OUR NEWSLETTER TO FURTHER INFORM
THE PUBLIC ABOUT THIS NEIGHBORHOOD PLAN AND MOU PROPOSAL.
3. CFBF HAS CONSISTENTLY RAISED CONCERNS THAT THE
NEIGHBORHOOD PLAN MAY HAVE SIGNIFICANT IMPACTS ON GROWTH
PATTERNS, TRANSPORTATION, AIR QUALITY, LOCAL TAXES,
INFRASTRUCTURE DEMANDS, DOWNTOWN BUSINESSES AND THE
STAINABILITY OF COMMERCIAL EXPANSION IN THE COUNTY AND A
VARIETY OF OTHER QUALITY OF LIFE ISSUES IN FLATHEAD COUNTY.
FOR EXAMPLE DNRC HAS CONSISTANTLY STATED THAT LEASING OF
RESIDENTIAL LOTS IS A BAD IDEA FOR THE STATE,GIVEN ITS
EXPERIENCE WITH LOT OWNERS IN THE PAST DECADE. YET THE
NEIGHBORHOOD PLAN ADOPTS A STRATEGY THAT INCLUDES THE
OPPORTUNITY FOR RESIDENTIAL LEASES. IT IGNORS, DESPITE OUR
INPUT, CONSIDERATION OF COLLABORATIVE STRATEGIES BETWEEN
STATE AGENCIES AND LOCAL GOVERNMENT THAT MIGHT IDENTIFY
AFFORDABLE HOUSING OPPORTUNITIES THROUGH A SWAP OR
EXCHANGE.IN ANOTHER AREA, THE TYPES OF DEVELOPMENT PERMITED
IN THE NEIGHBORHOOD PLAN AS WELL AS THE LEASE STRUCTURES MAY
IMPACT OTHER LOCAL BUSINESSES IN OTHER PARTS OF KALISPELL.THE
POTENTIAL FOR LARGE SCALE COMMERCIAL RETAIL DEVELOPMENT AND
THE KNOWN FUTURE DEVELOPMMNT OF A BY-PASS FOR KALISPELL THAT
IS DESIGNATIED TO RUN THROUGH THE PROPERTY MAY COMBINE TO
HAVE A DRASTIC EFFECT.ON TRAFFIC ON THE NORTH END OF TOWN,
YET NONE OF THESE IMPACTS HAVE EVER BEEN ASSESED.
WE HAVE ALSO RAISED QUESTIONS ABOUT THE VIABILITY OF THE
PROPOSED DEVELOPMENT AS A VIABLE INVESTMENT STRATEGY FOR THE
STATE AND SUGGESTED THAT OTHER ALTERNATIVES BE CONSIDERED. WE
HAVE URGED MORE DEPTHFUL ANALYSIS OF THE BENEFITS AND
IMPACTS/COSTS TO THE LOCAL COMMUNITY AND THE STATE AS CALLED
FOR IN 77-1-601. THESE IMPACTS HAVE NEVER BEEN ANALYZED.
4. CFBF HAS REQUESTED.THAT ALTERNATIVES TO THE NEIGHBROHOOD
PLAN BE CONSIDERED RANGING FROM SIGNIFICANT ALTERNATIVES THAT
MIGHT INCLUDE SALE OR EXCHANGE OF LAND TO MORE MODERATE
ALTERNATIVES THAT INCLUDE CHANGES TO THE PERMITTED USES,
STANDARDS .FOR THE QUALITY OF PERMITTED DEVELOPMENT AND
CHANGES TO THE PROPOSED PHASING OF DEVELOPMENT. WE HAVE ALSO
CALLED FOR EVALUATION OF ECONOMIC IMPACTS INCLUDING
EVALUATION OF ECONOMIC IMPACTS OF DIFFERENT APPRAISAL
PROCESSES, LEASING TERMS AND DIFFERENT PERMITTED USES. THE
DEPARTMENT HAS NEVER COMPARED THE COSTS, BENEFITS AND IMPACTS
OF ANY ALTERNATIVE WITH THE NEIGHBORHOOD PLAN.
5. MY ORGANIZATION RELIED ON DNRC'S REPRESENTATIONS THAT IT
WOULD DO MEPA ON THE NEIGHBORHOOD PLAN AND THAT MANY OF THESE
ISSUES WOULD BE IDENTIFIED IN THE SCOPING PROCESSES ALONG
WITH OTHERS TO INSURE A COMPREHENSIVE REVIEW OF THESE ISSUES.
ADDITIONALLY, BECAUSE THE DEPARTMENT PROPOSES TO DO MEPA ONLY
ON INDIVIDUAL PROPOSALS, THE PUBLIC WILL NEVER HAVE AN
OPPORTUNITY TO COMPARE THE NEIGHBORHOOD PLAN WITH THESE OTHER
ALTERNATIVES, OR TO UNDERSTAND THE IMPACTS OF ADOPTING THE
NEIGHBORHOOD PLAN.
FURTHER AFFIANT SAYETH NAUGHT.
DATE AND SIGN
STATE OF MONTANA ) `
ss.
COUNTY OF LEWIS AND CLARK )
On this day ofC LQk , 2000 before me the
undersigned Notary Public, personally appeared
known to me to be the person whose name is subscribed.to the
within instrument, and acknowledged to me that he executed
the same.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed
my official seal the day and year first above written.
NOTARY PUBLIC for/the State of Montana
Residing at -m-i�l Montana.
My commission expires: q---� ?-c)c/