Mr. Erik Berg-Johansen <br />August 14, 2015 <br />Page 9 <br />Recommendation <br />It is recommended to deny Zone Change Application 15-005 on the following grounds: <br />The application fails to meet the following Approval Criteria: <br />9.8865(l) The proposed change is consistent with the applicable provisions of the <br />Metro Plan... <br />As indicated in the decisions of every entity from the City of Eugene to the Court of Appeals, the <br />Metro Plan Diagram is applicable to this zone change. The applicant's overlay of the tax lot onto <br />the Metro Plan Diagram as presented in the site maps accompanying the application is erroneous <br />in several ways. The layers have been rotated to different references (Oregon State Plane <br />Coordinate System Grid North for the Metro Plan Zoning Designation Diagram and True North for <br />everything else). <br />Moreover, in the western portion of the property, the applicant has inadvertently moved the tax lot <br />layer 179 feet NW relative to the position where LCOG's maps indicate the tax lot should fall on the <br />Metro Plan Diagram. In the eastern portion this offset is compounded by the rotation error. This <br />offset is insupportable when tighter constraints are placed on the relationship between the Metro <br />Plan Diagram by use of appropriate referents outside the immediate vicinity of the tax lot. The <br />applicant has arbitrarily chosen to limit their referents to a single, curving line in the immediate <br />vicinity of the tax lot and to the North Arrow (apparently without consideration of the fact that North <br />can be relative in a cartographic sense). <br />Therefore, the applicant's maps and application are not consistent with the provisions of the Metro <br />Plan. <br />If you have any questions regarding this matter, please do not hesitate to contact me at (541) 729- <br />4271. <br />Respectfully submitted, <br />Gunnar Schlieder, Ph.D., CEG <br />Co-Chair, Laurel Hill Valley Citizens <br />Att: Bill Clingman's response to inquiry regarding overlay <br />of the GIS system. <br />onto Tax lot layer <br />Expires 12/31/2015 <br />