The city adopted its Goal 5 resource maps, and regardless of their accuracy, those maps are the city's <br />definitive statement as to the areas to be protected. The Picullel Group v. City of Eugene, _ Or LUBA <br />- (LUBA No. 2007-213, March 13, 2008), slip op 13-14 (The Picullel Group)(geographic boundaries <br />of the city's Goal 5 resource sites cannot be "refined" based on site-by-site empirical evaluations.) <br />Therefore, the question of whether those maps are or are not accurate is not relevant to this matter, <br />which requires the application of /WR conservation area provisions to the areas depicted as resource <br />sites on those maps. Again, if the applicant seeks to demonstrate that the Goal 5 resource maps are <br />inaccurate, the applicant must follow the process set out in EC 9.4960, or request a map amendment <br />under the city's Type IV procedures. <br />Turning to the question of whether the Goal 5 Resource Plan maps can be scaled to identify the <br />riparian resource on this site, the hearings official agrees with the applicant that, however the resource <br />designation is applied to the site, interpretations of ambiguous boundaries of the resource area should <br />include the features that define the resource. I t Thus, where there is a question whether the boundaries <br />of a resource site does or does not include the resource to be protected, the decision maker should try <br />to resolve the ambiguity in favor of inclusion. However, the hearings official disagrees with the <br />applicant that the sole defining criterion for this riparian corridor is the presence or absence of natural <br />vegetation. The plan identified the site as appropriate for protection because it includes undeveloped <br />natural areas on a 3.6-acre site, is adjacent to a riparian corridor, and is located within the 100-year <br />floodplain.12 The western portion of the site is "natural" in the sense that it has not been developed <br />with infrastructure, although the ditch has been moved and deepened over time.13 The staff's map <br />Goal 5 Plan, the east-west dimension of the Goal 5 Site is 4/5 (160 feet) of the north-south dimension of the <br />resource on the subject site The resource extends along the west property'boundary, which is 200 feet long The <br />resource is "U"-shaped within this area, with the points of the legs of the "U" oriented to the south property line <br />The bottom of the U extends south of the north property line approximately 1/5 (40 feet) of the total north south <br />dimension. The southwest U-leg is slightly narrower than the southeast U-leg, and spans approximately % (40 <br />feet) of the east-west dimension of the south portion of the resource, with the area between the two legs <br />comprising less than %2 (80 feet) of the total width <br />"On the easternmost side of the /WR Site, the boundary clearly does not extend beyond the conservation setback <br />For the north, west, and east boundary of Lot 5, the boundary markedly extends landward from /WR setback <br />mapped by the applicant The /WR Site boundary also appears to extend landward from the conservation setback <br />on Lot 6, but the extent is less clear in the absence ofa precise delineation of the /WR conservation area, as <br />described above " <br />The hearings official also disagrees with the applicant's synopsis of the Cl 07-3 decision There, two questions were <br />asked and answered (1) whether the Goal 5 Resource maps can be "interpreted" through a site-specific identification of the <br />resource and (2) whether it is possible to have a "gap" between the resource site and the conservation setback that is <br />intended to protect the resource The first question was answered in the negative, was appealed to LUBA in The Picullel <br />Group, and as noted above, was affirmed by the Board The second question was also appealed, but LUBA declined to <br />address it, concluding that it was not necessary to resolve that point, because of other errors in the hearings official's <br />application of the "top of bank" methodology While the hearings official conceded in Cl 07-3 that the application of the <br />Goal 5 Resource Plan maps to individual sites is problematic, she did not conclude that it is therefore impossible or <br />unnecessary to identify the resource site by using the Goal 5 Resource Plan maps <br />12 According to the applicant's site plan, all or part of proposed lots 4 through 9 are located within a "flood hazard" area <br />designated as Zone A on the applicable Flood Insurance Rate Map The flood hazard area does not include the drainage <br />area located along the western boundary of the site. <br />13 The hearings official realizes that this interpretation of "natural" may be at odds with her interpretation of "natural <br />conditions" in her remand decision in The Picullel Group However, there the question was whether "natural conditions" <br />prevailed for the purposes of identifying the "top of bank" on the property Here, the use of the phrase "undeveloped <br />natural areas" connotes a broader definition of "natural." See Webster's Third New Int'l Dictionary, (2002 ed ) 1506 <br />("natural" is defined as "13 a : planted or growing by itself : not cultivated or introduced artificially * * * b : existing in or <br />produced by nature * * * : not artificial (as in form or construction) * * * <br />Alder Woods PUD (PDT 07-5 & SDR 08-2) Page 13 <br />Laurel Ridge Record (Z 15-5) Page 1141 <br />