06 Public Record Pages 1021-1272

I of land north of the UGB line as POS, and then to turn around in 1982 and 2 adopt the Laurel Hill Refinement Plan snap showing all lands immediately 3 north of the UGB line as LDR, if the city council intended to designate some 4 land north of the UGB as POS. Had that been the city's intent, petitioner 5 argues, it would have shown the POS designation north of the UGB line on the 6 refinement plan map. 7 The foregoing argument would be more persuasive if the relevant 8 question were whether the refinement plan conflicted with the 1980 Metro Plan 9 Diagram. The thin sliver of green color north of the UGB line depicted on the 10 hand-colored 1980 Metro Plan Diagram could easily be seen as an inadvertent 11 brushstroke. However, that argument is less forceful when applied to the 2004 12 Metro Plan Diagram, which is generated by a digital database and features 13 much crisper boundaries between plan designations compared to the 1980 or 14 1987 Metro Plan Diagrams. Moreover, the 2004 Metro Plan Diagram clearly 15 shows a large expanse of green color north of the UGB line, particularly where 16 the UGB line dips south before intersecting with the East 30`' Avenue right-of- 17 way. If the 1982 Laurel Hill Refinement Plan map can be understood as a 18 "policy choice" to designate LDR the area immediately north of the UGB line 19 wherever that line is ultimately located, as petitioners argue, then the 2004 20 Metro Plan Diagram can equally well be understood to reflect an subsequent 21 choice to change that "policy." 22 Finally, petitioners argue that the city's conclusion that the subject 23 property is split-designated LDR and POS presents the practical problem of 24 how to precisely determine the boundary between the two designations on the 25 subject property, based solely on the 2004 Metro Plan Diagram. According to 26 petitioners, there is no principled or empirical basis to determine precisely Page 19 Laurel Ridge Record (Z 15-5) Page 1057