|
LaurelRidge Page 2 of 5
<br />Zone Change Application - Hearings Official - Public Hearing - Applicant Testimony
<br />August 26, 2015
<br />e. 30th Avenue was there in 1982. It's a constructed, physical object. It hasn't
<br />changed.
<br />f. Thus, we obtained a drawing of the legal centerline from the project's surveyor,
<br />with the centerline located in relation to the subject property's boundary survey.
<br />• NOTE: we're talking here in terms of "boundary survey", not "tax lot."
<br />• The subject property's boundary was measured and surveyed, confirmed and
<br />located, in the field (and aligned with the metes and bounds description of the
<br />UGB where the UGB is adjacent to the subject property).
<br />• We all know that tax lots, which are not on the Metro Plan diagram by the way,
<br />are famously not accurate. They are, more often than not, mere
<br />"representations." Metes and bounds can be scribed into legal descriptions,
<br />from which a boundary survey can be generated. That's what we did.
<br />• So, keep in mind, throughout our application, our methodology, exhibits and
<br />testimony, we're talking about the subject property's boundary survey, not tax
<br />lot. The work we did here is very accurate.
<br />g. Okay, so, doing this, we knew where the subject property was in relation to 30th
<br />Avenue's centerline.
<br />h. Then, using the Metro Plan diagram, at the same scale as the subject property, we
<br />aligned the 30th Avenue centerline with the black line on the Metro Plan diagram.
<br />i. With that, we knew where Referent #1, 301h Avenue, was in relation to the subject
<br />property.
<br />Referent #2 - North Arrow: Staff states that the North Arrow is not a physical
<br />referent. They are correct. But it is a very important, and useful, referent. Why? Well:
<br />a. We're required to use the Metro Plan diagram. The diagram has a north arrow.
<br />b. We're to align the Metro Plan diagram with the subject property. The subject
<br />property survey was generated in relation to north. (As are all surveys... metes and
<br />bounds...northings and southings...etc).
<br />c. What other way could we possibly align these two data sources but to do so in
<br />relation to the compass? To skew one would be to skew the results.
<br />d. We did not do that. We kept both the diagram and the survey oriented in the same
<br />direction. We now have an accurate, honest representation of the diagram and the
<br />subject property in relation to each other.
<br />Referent #3 - The UGB: Here are things that are true about the UGB.
<br />a. Just like the north arrow, the UGB is not a physical referent. You can't go out there
<br />in the field and see it. You can't point to it and say "There it is over yonder." It
<br />does not exist that way. Thus, the UGB is not physical.
<br />b. Unlike 301h Avenue, which is a physical referent, and the north arrow, which is
<br />precise, the UGB is generalized. Indeed, when scaling up the Metro Plan diagram,
<br />one discovers that the graphic symbol depicting the UGB is a series of wavy, free-
<br />hand parallel lines. (See applicant's Exhibit G, Sheet ZC-3.) A line which scales
<br />some 250 feet wide. Thus, the UGB is imprecise.
<br />c. Furthermore, with the subject property's annexation in 2007, the UGB, as it borders
<br />the subject property, was reduced to a precise metes and bounds description. This
<br />metes and bounds UGB does not match the Metro Plan diagram UGB. Thus, the
<br />UGB is not accurate.
<br />d. Nonetheless, we do agree that the UGB can be a useful referent. It is useful in
<br />terms of generally documenting that, yes, there is some amount of POS north of
<br />the UGB.
<br />Schirmer Satre Group • 375 West 41h Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540
<br />
|