other is 30th Avenue. According to staff, the intersection of these two reference points resolves <br />any question of whether at least some portion of the subject property is designated Parks and <br />Open Space.' <br />As to the necessity for referring to the Laurel Hill Plan, staff concluded that the plan did not <br />provide any more detailed information about the location of the Parks and Open Space <br />designation on the subject property. Staff concluded that, "[a]t best, reliance on the older, non <br />parcel specific refinement plan diagram as suggested by the applicant would create an <br />inconsistency and therefore conflict between the two diagrams. In that case, the Metro Plan <br />diagram controls over the refinement plan designation in accordance with EC 9.8865(2)." <br />Opposition's Position <br />At the August 28, 2013 public hearing, opponents of these applications agreed with staff <br />on the Parks and Open Space designation of the subject property. The opponents argued that <br />without magnification of any kind the Metro Plan Diagram clearly shows that some portion of the <br />subject property is designated Parks and Open Space adjacent to the UGB. In support of this <br />argument the opponents submitted an August 28, 2013 letter from attorney Sean Malone. Mr. <br />Malone generally agrees with staff's position and made the following additional arguments: <br />The methodology set forth in Knutson is only triggered when there is an ambiguity in the <br />Metro Plan Diagram. The facts in Knutson are distinguishable because there were no clear <br />referents between two Metro Plan designations. Here, physical referents exist on the <br />Metro Plan Diagram which resolves any ambiguity which precludes a reference to the <br />Laurel Hill Plan. <br />• The Laurel Hill Plan is inconsistent with the Metro Plan and Metro Plan Diagram because it <br />shows no Parks and Open Space designation for the subject property whereas the Metro <br />Plan Diagram shows both Low Density Residential and Parks and Open Space designation <br />for the subject property. <br />• The Laurel Hill Plan conflicts with both the Metro Plan Diagram and the Metro Plan text <br />and policies that inform the Parks and Open Space designation - particularly for the South <br />Hills ridgeline which runs through the subject property. <br />Mr. Malone's overall conclusion is that the Metro Plan Diagram shows a Parks and Open Space <br />At the August 28, 2013 hearing, and in the applicant's written comments, it was alleged that staffs conclusions <br />about the location of the Parks and Open Space designation were based on a "blown up" or otherwise magnified <br />view of the Metro Plan Diagram. The applicant assigned error to that approach stating that the Metro Plan <br />Diagram is only valid at the "11 x 17" scale. While the Hearings Official agrees with the applicant that the "11 x 17" <br />diagram is the only appropriate scale upon which to make Metro Plan designation decisions, the record is sufficient <br />to show that is what staff did, and that review of other versions of the Metro Plan Diagram in the course of <br />reviewing the application materials was supplemental to staffs consideration of the official "11 x 17" Metro Plan <br />Diagram. <br />Hearings Official Decision Z 12-2, PDT 12-2, TIA 12-6, SDR 12-5 7 <br />Laurel Ridge Record (Z 15-5) Page 1027 <br />