LaurelRidge Page 3 of 5 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Appeal Remand Hearing - Applicant Testimony <br />September 21, 2016 <br />zone change plan. The additional surveyed elements were added with respect to the <br />fixed lines of the subject property and the centerline of 30th Avenue. <br />The following are the modifications made to the original zone change plan: <br />a. The white text box in the lower right-hand corner was reduced so that all of <br />Bloomberg Park is visible. <br />b. The view-port (or window) of the plan was shifted eastward so that more area <br />around the green finger and Spring Blvd is visible. <br />C. The surveyor-located elements listed above were added. <br />2. Sheet ZC-4B - This is the same plan as the approved zone change plan, Exhibit L, with <br />the following modifications: <br />a.-c. Same as above. <br />d. The boundary linework was aligned with Tax Lot 301, the green finger. <br />3. Sheet ZC-4C - This is the same plan as the approved zone change plan, Exhibit L, with <br />the following modifications: <br />a.-c. Same as above. <br />d. The boundary linework was aligned with the centerline of Spring Blvd. <br />4. Sheet ZC-41D - This is the same plan as the approved zone change plan, Exhibit L, with <br />the following modifications: <br />a.-c. Same as above. <br />d. The boundary linework was aligned with Tax Lot 800, Bloomberg Park. <br />Results <br />The results are interesting. First, the additional referents previously cited (30th Avenue, <br />Spring Blvd and the green finger) were located and added to the updated plans. Additionally, <br />though not cited by LUBA, Bloomberg Park boundaries were located. And, for the purpose of <br />explaining the value of city limit lines, the east boundary of Tax Lot 500 (which is also a city <br />limit line) was added to the mix. <br />A page-by-page, side-by-side review of these four new plans shows, despite numerous <br />statements to the contrary, that using multiple referents does not necessarily result in a more <br />defensible alignment of the subject property on the Metro Plan diagram. No two referents <br />work completely, let alone the "...four referents... "that LUBA said could work. Here is how <br />they line up. <br />To describe the results, we labeled each of the referent lines with a capital letter. On each of <br />the four new plans, the letters A through I were used to label the referents for purposes of <br />discussion. These are as follows. <br />A. Centerline of 30th Avenue west segment. <br />B. Centerline of 30th Avenue middle segment. <br />C. Centerline of 30th Avenue east segment. <br />D. The Green Finger. <br />E. Centerline of Spring Boulevard. <br />F. Bloomberg Park west property line. <br />G. Bloomberg Park north property line. <br />H. Bloomberg Park east property line. <br />1. Tax Lot 500 east boundary. <br />What This Shows <br />There is no perfect alignment. <br />Schirmer Satre Group • 375 West 4'11 Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />