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In 2019 Sun Communities (Sun) proposed expanding an existing 475 unit manufactured home park in Stewartville, MN (population 6,000 +/-) by adding 300 new manufactured homes. This proposed expansion would have added about 15% to Stewartville’s existing size (as compared to 47 Degree North which would increase Cle Elum’s size by almost 100%).

Below are the links to the documents about the case.

Document 1

Document 2

Document 3

Document 4

Document 5

Document 6

47 Degrees North Project Information

The Bullfrog Flats property is approximately 1,100 acres located west of the Cle Elum Cemetery, north of the Washington State Horse Park, south of Suncadia, in the area bounded by Bullfrog Road, SR 903, and I-90. This property was incorporated into the city in 2002 and zoned/approved for an expansion of Cle Elum’s residential neighborhoods in an organic way, consistent with the city’s traditional architecture, over a period of 30 years once development started.  To date there has been no development on the site.

Sun Communities REIT[1] has proposed to change approvals and replace the traditional residential house development with a large manufactured home community/RV Resort, essentially functioning as a large private tourist resort.  The proposal would include:

• 707 Manufactured residential units (527 single-Family, 180 multi-family); All manufactured units to be purchased and owned by residents (some rentals) but all underlying land leased back to house owners.  None of the proposed manufactured homes are considered to meet criteria as affordable housing,
• 627 site RV Resort,
• All major resort amenities to remain private
• 25-acre future commercial development (not part of Sun Communities proposal, retained by Suncadia)

To put this project in perspective:

• The total population of Cle Elum/Roslyn/South Cle Elum is about 3,350.  Depending on its final approval, the Sun Communities project will add 1,490 to 1,650 more people plus 940 to 1,880 RV visitors per day, increasing the population of the three cities by 73% to 105%, depending on time of year.
• By itself the project would more than double the current size of Cle Elum and would be the largest development in the city’s history.

This near doubling of population will have huge impacts across the board on upper county public facilities and public services, including city facilities, county facilities, emergency/hospital services and schools[2].

• the police department will need to double in size (6 to 8 new officers, new equipment, new vehicles, new station expansion),
• emergency, fire, medical and hospital;/clinic services will need to approximately double (3 new full time professional fire fighters, 5 new EMT’s, 6 new paramedics, 2 new physicians, 5 APCs, 9 RNs),
• the school system will be 20%+ over capacity (12 new teachers, 4 to 5 new buses, additional classrooms),
• Traffic congestion will increase greatly on the major roads in the upper county. 16 separate intersections and associated roads will reach failing levels of service (total congestion) during peak periods after the project is fully built,
• County operated facilities and services, including the Cle Elum transfer station will need to be expanded. 

The developer is not proposing to actually build or expand any road or intersections outside of the Bullfrog Flats site, but rather asks to pay a “% share fee” to the city which would actually amount to a small percentage of the actual cost of what’s needed to expand al the congested roads.  And the developer has proposed to pay little, or even no, cost share for other needed capital facility expansions and budget shortfalls for Schools, emergency and hospital services, transfer station, etc. to accommodate the doubling of population.

The city commissioned fiscal studies on how the project would impact city and upper county budgets and how it would compare with the current approved land use plan.  The studies show that over time the taxes collected from the Sun Communities project will be far less than what would have been collected from the currently approved traditional neighborhood, and collected tax revenue would not be nearly enough to offset either the City’s increased cost for ongoing services (Police, Fire, Parks, Public Works) or the increased costs for schools, emergency services and other public services.  The studies are more or less silent on where the rest of the funding will come from, or who exactly will be responsible to actually build or expand the needed facilities, but the study strongly implies it will fall on the general public and upper county taxpayers[3].  If this project is approved as proposed, it’s quite clear the choice facing the upper county will be to suffer congested roadways, overcrowded schools, reduced police and emergency services, etc., OR, increase taxes to pay for what’s needed.    Without a doubt, if approved by the city as currently proposed the residents of the upper county will be subsidizing this project and taxes will go up.

Instead of a residential community of individually owned homes with roots and financial stakes in the City of Cle Elum and the upper county, the Sun Communities project is, and will continue to be, a large private business owned by a publically traded company headquartered in Michigan.  Sun Communities will retain ownership and control of all of the underlying land and all decision making on how to operate and manage the community will ultimately be subject to the approval of company headquarters.  And, as currently proposed, we the public will be subsidizing this private resort business.

Even though 47 Degrees North would be a small part of Sun Communities total holdings, it would constitute the largest manufactured home community and RV resort in Central Washington.  It’s likely it would be the largest of its kind outside the southwest, California, Texas and Florida.  A reasonable person could see this proposal for what it is, a very large experiment in a new type (for us) of wholly owned corporate resort community that no one in Kittitas County, or Central Washington, has experience with. The success, or failure, of this community, and whether it becomes a positive part of the community or a negative forever, will in large part be up to a huge publically traded corporate entity, or a future owner if they decide to sell, or the venture fails to meet their business objectives at some point.  There is no guarantee that the developer the city is dealing with now will be the entity the city will deal with 10 years from now.   A reasonable person should be skeptical that a publically traded corporate entity will place the needs and well-being of our community at the top of its list of business goals.

Citizen Requests to the City Of Cle Elum

• We request that the City carefully consider the pros and cons of turning over a large part of its Urban Growth Area and housing stock, with a future population equal to the size of the existing city, to a large out of state business corporate entity whose interests will surely be different than the city’s interests over time; to create a private resort community that is out of character with the upper county cities.  On many levels this is the wrong project for this site, for the City and the upper county.  We request that the City deny the proposed major amendment and retain the existing approval.

If the City determines to move forward with this project we request that the City:

• Condition the project in a strong legally enforceable way so that there are NO financial impacts to existing upper county residents; so that higher taxes aren’t needed; so the residents of the upper county aren’t required to subsidize a private business venture
• Provide legal mechanisms so the Sun Communities project pays for all special district (non-city) financial Impacts and funding shortfalls (schools, waste, transportation).

• Redesign the project so it’s oriented toward the City of Cle Elum, and city services, and not primarily towards Bull Frog Road and upper valley residents.  Currently the project is designed so that for practical purposes it’s actually closer to Roslyn than Cle Elum. This should be reversed to make it an integral part of the city.
• Include a large, thick Buffer along Bullfrog Rd to obscure all view of the project from Bullfrog Road.  None of the project should be visible from Bullfrog Road.  This is what Suncadia was required to do, and it was effective.
• Include a new road connecting the project directly to the City of Cle Elum Commercial center so the development is more connected to the City center and new residents don’t have to drive outside the project to get to city services.

• Infrastructure and concurrency – Condition the project so that infrastructure is built when it’s needed and not after the project is built out and the developer is finished with little or no incentive to participate.
• Make the project responsible for funding/constructing any infrastructure needed to support it, or if the city were to accept some, or all, of the responsibility (“% share” method), the project should be required to wait until the city actually builds the infrastructure that’s needed (concurrency).
• Condition the project with a concurrency agreement/phasing plan so that development is only allowed to proceed in phases as infrastructure is fully funded/constructed.
• The study of impacts for this project is largely based on modeling and assumptions from other regions which may not be accurate for this development in our unique location.  The progress of the project should be tied to a monitoring plan as part of concurrency.  No model is 100% accurate.  If the project has more impacts than assumed by the models, more mitigation (more funding) should be required in future phases to make up for shortfalls

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[1] Real Estate Investment Trust – Sun Communities owns and operates over 300 manufactured home communities and RV resorts located in 29 states throughout the US and Canada. Sun has been listed on the New York Stock Exchange since 1993 under the symbol: SUI.  Sun Communities is headquartered in Southfield, MI.

[2] All statistics below are estimates from the city’s environmental studies

[3] Draft SEIS, Appendix K, Page 45, ECONorthwest Memo 9/9/20: to meet shortfalls…”….Consistent with typical municipal budgeting practices, the city could impose new taxes or fees to balance its budget or seek to change levels of public services to meet available revenues, or a combination of both approaches…..”

47 Degrees North suggested comment letter/Email to the City of Cle Elum.

• Email addresses for Cle Elum planning department and elected officials are provided at the bottom, use these to email the letter.
• Don’t forget to put “47 Degrees North Major Amendment” in the subject line of your email or letter and your name and address at the bottom.

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City of Cle Elum – Mayor, City Council members, Planning Department,

Re: 47 Degrees North Major Amendment proposal

I am writing to provide the city with my very strong concerns about the Sun Communities 47° North proposal for the Bullfrog flats property.  The proposed manufactured home / RV community:

    – is not in character with the City of Ce Elum or the upper valley (a fundamental requirement of the current zoning for the property),
   – would create a new and separate private tourist resort and not a natural extension of city neighborhoods as originally envisioned/required by city zoning and current approvals,
    – is in its entirety a private business not a neighborhood (no lots will be created or sold, all spots will be leased, and the project will be private), wholly owned by a large out-of-state publically traded corporation who’s fiduciary duty is to its shareholders,
    – provides no significant benefits to upper valley residents and tax payers, but
    – will create serious and significant impacts on roads, police, fire, schools, emergency services, hospitals and other public services that can’t (or won’t) be fully mitigated by the developer, and therefore,
    – will create extensive traffic congestion and gridlock conditions and an overall reduction in levels of service of upper county services which will require public expenditures and increased upper county taxes to pay for, essentially a subsidy for a private business,
    – Denial of the Sun Communities proposal would not take away or reduce underlying property rights.  The original underlying zoning approval would still allow development of this site, just not as a private resort/manufactured home community.

For all of these reasons, and others, I implore the City to DENY this proposed major amendment and retain the current approved land use for the property.

Respectfully,

______________

Name

___________________

Address

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Email Addresses:

Emailed comments must go to:

planning@cityofcleelum.com


You should also copy the Mayor and city councilmembers with your emailed comments at the addresses below:

jmcgowan@cleelum.gov
jglondo@cleelum.gov
kratliff@cleelum.gov
bwilliams@cleelum.gov
mholz@cleelum.gov
sharper@cleelum.gov
mlundh@cleelum.gov
rweaver@cleelum.gov

If you prefer a mailed letter:  letters may be mailed to: City of Cle Elum, Attention: Planning Department/47 Degrees North, 119 West First Street, Cle Elum, WA 98922.

Summary:

Attached is a copy of a letter sent to the City of Cle Elum from the City of Roslyn detailing their deep concern about the project.

Attached is a copy of the letter from Clay Myers, Kittitas County Sheriff.