LaurelRidge Page 4 of 5 <br />Zone Change Application - Hearings Official - Public Hearing - Applicant Testimony <br />August 26, 2015 <br />b. Those sheets were generated very early in the previous process. <br />C. They were not generated as the basis for a zone change application, or any land use <br />application for that matter. <br />d. They were generated as part of an initial data-gathering task. <br />e. They were to serve as the basis for a preliminary, conceptual site design exercise. <br />f. There was no single source of data utilized. There was no alignment, no registration, <br />and no precise methodology. <br />g. Referring to it as the basis for Metro Plan diagram interpretation is contrary to its <br />purpose. <br />2. Page 3, second paragraph, references a 2014 position by City of Eugene parks staff <br />indicating that there is about 40 acres in POS on the subject site. <br />a. What methodology did they use to arrive at that figure? <br />b. Where is the documentation of that meeting and of their statement? <br />C. What diagram could they have possibly used? <br />3. Page 3, last paragraph, says it is likely the applicant used a digital copy of the Metro Plan <br />diagram to scale up. <br />a. No, we didn't. <br />b. A digital copy is not the official diagram. <br />C. We used a paper copy of the official adopted 2004 diagram. <br />4. Page 4 includes language about using the Oregon State Plane Coordinate System. It <br />includes narrative stating that the Metro Plan diagram appears to be rotated, that the north <br />arrow is similarly rotated, and that this requires significant work-arounds. This may be true. <br />But it does not matter. As LUBA declared, the adopted 2004 Metro Plan diagram is the <br />diagram. It is the one which must be used. <br />a. We used the official, adopted, paper copy 2004 Metro Plan diagram. We scaled it up to <br />a scale matching the subject property's boundary survey and aligned the two. We did <br />not use digital. We did not stretch. We did not rotate. <br />b. Question: If the Metro Plan diagram is rotated, does that mean that every zone change <br />that used the diagram, since the diagram's inception in 1982, might be based on a <br />rotation? And might be in error? <br />Page 5, last paragraph, includes a statement that the applicant's 301h Avenue centerline is <br />less than perfect; that the alignment of the centerline falls apart further away from the subject <br />property. Let's clarify that: <br />a. The center line is very exact. It is a drawing of the legal centerline of 301h Avenue. It <br />was located in relation to the subject property's boundary survey. <br />b. But, yes, the further afield one goes from the subject property, the more the centerline <br />is challenging to align with the diagram. We looked at that. The question became, "Do <br />we align the subject property in the immediate vicinity of the property or do we look at <br />roadways or intersections further away?" If 30th and Spring Blvd mattered, why not 30th <br />and 1-5? Why not River Road and Beltline? Or 581h and Main Street in Springfield? <br />C. The point is, that a segment of 30th Avenue is immediately adjacent to the subject <br />property's west boundary. And since our task is to locate the subject property in <br />relation to 301h Avenue, nothing could be more accurate than aligning with 30th Avenue <br />where it is immediately adjacent. <br />6. Page 6, first paragraph, begins with an assertion that the applicant "...has moved the tax lot, <br />city limits, UGB and road centerline layers..." Here, too, we need to be clear: <br />a. The applicant has not 'moved' anything. We were not working with a digital plan. We <br />were not working with layers. <br />Schirmer Satre Group • 375 West 4 m Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />