Mr. Fred Wilson <br />September 16, 2015 <br />Page 8 <br />(6) The UGB line shown on the Metro Plan Diagram is generalized. <br />Unlike 301h Avenue, which is a physical referent, and the north arrow, which is <br />precise, the UGB is generalized. <br />The text of the Metro Plan explains that the UGB shown on the Diagram is <br />generalized and is to be fixed at the time of annexation. See Metro Plan at II-G-4: <br />"The UGB is tax lot-specific where it is coterminous with city limits, where it has <br />been determined through the annexation process, and where it falls on the outside <br />edge of existing or planned rights-of-way. In other places, the UGB is determined <br />on a case-by-case basis through interpretation of the Metro Plan Plan Boundaries <br />Map in this Metro Plan and the following factors (see Metro Plan Plan <br />Boundaries Map Key)." <br />The actual location of the UGB with respect to this parcel did in fact get fixed at the <br />time the property was annexed in 2007. It was reduced to a metes and bounds line. <br />See annexation map showing UGB, Boundary Commission Final Order, C EU 07-37 <br />(Oct. 4, 2007), submitted at Exhibit E. <br />As a result of the above, the UGB line shown on the Metro Plan Diagram does not <br />show the actual location of the UGB. LUBA agreed its depiction on the Diagram was <br />adequate to show that some part of the property is planned POS. However, it has no <br />utility in locating the metes and bounds of the plan boundary. <br />(7) We have rendered the line between the two Metro Plan designations and <br />proposed zoning districts as a metes and bounds description. <br />Only the applicant provided a metes and bounds description of the LDR/POS plan <br />boundary line. The applicant is OK, of course, with the city surveyor verifying the <br />legal description, as requested by staff. <br />IV. Summary of Applicant's methodology to locate the boundary line. <br />The contending positions on drawing the line organized into two camps during the hearing <br />process - the opponents, who argued for rotating the Metro Plan Diagram to correct for the 2004 <br />compass rose - and the applicant, who argued that would be a mistake. Here we outline the steps <br />we took to locate a metes and bounds boundary line under each competing methodology. <br />(1) Assuming that the Diagram page is oriented N/S: <br />(a) Start with first generation copy of the Metro Plan Diagram from the original 2004 <br />ordinance, as discussed above. See Exhibit C. <br />Laurel Ridge Record (Z 15-5) Page 55 <br />