LaurelRidge Page 4 of 5 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Appeal Remand Hearing - Applicant Testimony <br />September 21, 2016 <br />• No magic location where everything aligns. <br />• It illustrates what we already know, that the Metro Plan diagram is an imperfect <br />representation of reality. It is a cartoon. <br />• It was created in the day before there were computers, GIS, AutoCAD or anything <br />digital. <br />• The Metro Plan diagram includes some information. <br />• It includes land use designations (naturally), as well as some roadways, rail lines and <br />water features. <br />• It does not include topography, tax lots or city limit lines. <br />• Nonetheless, the applicant sought out the location of those things (referents) which <br />have been cited in the record as being of potential help in locating the subject property <br />on the Metro Plan diagram. <br />• The applicant accurately located the 30th Avenue centerline, the Spring Blvd centerline, <br />the green finger and Bloomberg Park in relation to the subject property. <br />• Using those, we present various potential locations of the subject property on the <br />diagram. <br />• None of them is perfect. None of them varies by much. <br />The Applicant's Recommendation <br />We have submitted maps that show 9 referents with surveyed segments. <br />We have displayed these 9 segments on the Metro Plan diagram in four different hard copy <br />maps. <br />Those maps show that it is not possible to register all of the surveyed referents to the Metro <br />Plan diagram. That is because the Metro Plan diagram is, by definition, generalized. It has <br />some qualities of a cartoon. <br />This supports a basic proposition: Using more referents is not necessarily helpful in fitting the <br />Metro Plan diagram accurately to a site. That is the situation here. <br />The Hearings Official nevertheless faces the task of fitting the diagram to the site. <br />We suggest the approach that relies on a second proposition stated by the HO in his decision <br />-one that was left intact by LUBA. That is the proposition that referents that are closest to <br />the subject property are generally more reliable than using referents that are more remote. <br />The two referents that are closest to the subject property are referents B and C regarding the <br />30th Avenue centerline. Referent segment B provides East-West control for fitting. Referent <br />C provides North-South control for fitting. The use of these two referents is reflected in Map <br />ZC-4A. This is the same as the decision of the HO remanded by LUBA. <br />III. In Closing. <br />1. The applicant believes that is has presented sufficient multiple referent documentation as to <br />the location of the subject property on the Metro Plan diagram. <br />2. We believe that the Hearings Official has sufficient information to make findings as to the <br />subject property's location, and thus location of the two land use designations, on the subject <br />property. <br />Schirmer Satre Group • 375 West 4" Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />