Eugene Hearing Official <br />November 3, 2015 <br />Page 5 <br />The plain language of this standard does not invite the crack that the Director read into it in <br />2004, or any crack for that matter. The language is pretty simple. It requires the buffer on the <br />perimeter adjacent to "surrounding properties." That would include private property, such as <br />adjacent private lots, and public property, such as streets. Surrounding is surrounding. <br />The dictionary definition of surrounding also does not allow the exception that the Director read <br />into it. See Webster's Third New MCI Dictionary (unabridged ed 2002) at 2302. "Surrounding <br />* * the circumstances, conditions, or objects by which one is surrounded." Applying this <br />standard as it is written would not permit any development of the property. The standard would <br />require the 30-foot buffer along West Amazon Drive, and that would preclude the private street <br />needed for access. <br />In summary, as LUBA explained in Horue Builders, this standard may not be applied consistent <br />with the statute because it does not allow development. <br />Sincerely, <br />O2 <br />Bill Kloos <br />