Page 3, LHVC Response re Z15-5, September 9, 2015 <br />relevant error being that the applicant's maps significantly reduce that portion of their property which is <br />designated POS on the 2004 Metro Plan Diagram. <br />Credibility <br />The applicant's spokespersons repeatedly went out of their way to tell the story of how they had obtained a <br />paper copy of the original 2004 ordinance that adopted the current version of the Metro Plan, and how they <br />had used a scanned version of the map therein as the basis for their work. In his letter of September 2, Mr. <br />Sartre now admits this was untrue. This same letter starts with an apology for repeatedly misrepresenting the <br />rotation of the two map layers. Additionally, their most recent versions of ZC-4 deliberately omit the city <br />limits because it would successfully show the misalignment of the two layers. It is also worth noting that while <br />new maps have been submitted since the hearing, the application narrative,including for instance the acreage <br />calculation, is apparently the same. <br />These three misrepresentations, and the internal inconsistency between the maps and the narrative, whether <br />intentional or otherwise, fatally undermine the applicant's credibility. There is no reason to believe that the <br />September 2, 2015 submission by the applicant is any more reliable than previous submissions. The only <br />remedy at this point is to have a neutral agency, such as LCOG, position the subject property at the correct <br />location on the Metro Plan Diagram. <br />Conclusion <br />Laurel Hill Valley Citizens asks the Hearings Official to deny Z15-5 because it fails to comply with EC 9.8865(1). <br />Respectfully submitted, <br />Jan Wostmann <br />Co-Chair, Laurel Hill Valley Citizens <br />2645 Riverview St. <br />Eugene, OR 97403 <br />LaurelHilNalleyCitizens@gmail.com 2480 Laurel Hill Drive 9 Eugene, OR 97403 . www.lhvc.org <br />