PDF Page 11 <br />LaurelRidge Appeal Statement <br />September 27, 2013 <br />Page 4 <br />The rules stated by the Court of Appeals in Knutson for how to read the two plans together <br />remain valid today for this property. The relevant language from the Metro Plan has not <br />changed. <br />The following excerpts from the Metro Plan were relied upon by LUBA and the Court of <br />Appeals in Knutson and remain verbatim in the Metro Plan today: <br />The Metro Plan Diagram is a graphic depiction of. (a) the broad allocation of <br />projected land use needs in the metropolitan area; and (b) goals, objectives, and <br />policies embodied in the text of the Metro Plan. [Current Plan at I-5; 2002 version <br />at I-4] <br />and <br />In addition, it is important to recognize that the written text of the Metro Plan <br />takes precedence ovdr the Metro Plan Diagram where apparent conflicts or <br />inconsistencies exist. The Metro Plan Diagram is a generalized map which is <br />intended to graphically reflect the broad goals, objectives, and policies. As such, it <br />cannot be used independently from or take precedence over the written portion of <br />the IvIetro Plan. [Current Plan at 1-5; 2002 version at I-5] <br />and <br />The Metro Plan is the basic guiding land use policy document, but it is not the <br />only such document. As indicated in the Purpose section, above, the Metro Plan is <br />a framework plan, and it is important that it be supplemented by more detailed , <br />refinement plans, programs, and policies. * * * * <br />Refinements to the Metro Plan can include: * * (c) neighborhood plans or <br />special area studies that address those issues that are unique to a specific <br />geographical area. In all cases, the Metro Plan is the guiding document, and <br />refinement plans and policies must be consistent with the Metro Plan. Should <br />inconsistencies occur, the Metro Plan is the prevailing policy document. <br />[Current Plan at I-6; 2002 version at I-5] <br />and <br />The Metro Plan Diagram is a generalized map and graphic expression of the <br />goals, objectives, and recommendations found elsewhere in the Metro Plan. <br />* * Finally, the Metro Plan Diagram is drawn at a metropolitan scale, <br />necessitating supplementary planning on a local level. [Currrent Plan at II-G-1; <br />2002 version at II-E-1] <br />73 <br />