LaurelRidge Page 5 of 5 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Remand Hearing - Open Record Period - Applicant Testimony <br />September 28, 2016 <br />We submitted a metes and bounds description that corresponds to the line that separates the two <br />land use designations. It was included in the applicant's open record submittal from last year's <br />hearing process regarding this zone change application. See Exhibit O, dated 8-31-15. <br />Of the three primary findings put forth in the LUBA decision, the applicant has provided testimony and <br />evidence regarding each of them. We have demonstrated that additional, multiple referents can be <br />considered but do not necessarily lead to a better conclusion. We have demonstrated that tax lot maps, <br />even though they are not on the Metro Plan, may be considered by some but that the maps are <br />inaccurate and should not be used. The city limits line, as suggested by LUBA, could be considered and <br />yet the only way to locate that line on a map is to use tax lot maps which are demonstrated to be <br />inaccurate. The city limits line is not found on the Metro Plan. We have demonstrated that additional <br />consideration can be given to LHVC Sheet 9/2/15-04, but that it is not an accurate representation of the <br />subject property on the Metro Plan. <br />In the end, the applicant believes that the Hearings Official got it right the first time, that the applicant's <br />Exhibit L, Adopted 2004 Metro Plan Map: Rotated, dated 5-15-2015, revised 9-2-15, is the best <br />representation of the subject property's location on the Metro Plan diagram. The applicant believes that, <br />with the additional documentation provided during this remand hearing process, that the Hearings Official <br />can reach the same conclusion. <br />This concludes the applicant's open record testimony. In advance, thank you for your consideration of <br />this material. <br />Sincerely, <br />R~t~d, M. Safr& <br />Richard M. Satre, AICP, ASLA, CSI, Principal <br />Schirmer Satre Group <br />Enclosed: <br />ZC-4E. LHVC Sheet 9/2/15-05 with Subject Property and Surveyed Referents Added <br />ZC-4F. LHVC Sheet 9/2/15-04 Scaled to Graphic Scale <br />ZC-4G. LHVC Sheet 9/2/15-04 Scaled to Match North Property Line <br />Exhibit O - Zone Boundary Legal Description for Metro Plan Rotated <br />Schirmer Satre Group • 375 West 4th Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />