<br />Hearings Official Decision (PDT 24-1; ST 24-3) 15 <br />through the review of this application. <br /> <br />However, while the Scenic Sites Working Paper itself may have formed the basis for the 1982 <br />acknowledged Goal 5 inventory, as described in the applicant’s attorney’s initial argument, the <br />acknowledgement itself required – and found -- that the acknowledgement was based on clear, <br />site-specific maps from those working papers. Specifically, as the applicant’s attorney quoted, <br />LCDC required that the Metro Plan “include a consolidated natural resource map or maps <br />which clearly define the location of sites where conflicting uses are prohibited or limited.” <br />(Emphasis added.) And, it determined that <br /> <br />“The Metro plan has been amended to include a consolidated natural resource map (Map <br />3, General Plan Technical Report.) In addition, very detailed site-specific maps of each <br />resource site are provided in the amended Natural Resource working paper. <br />Resources mapped include wetland vegetation, sand and gravel, significant <br />vegetation and wildlife area, and slopes.” <br /> <br />(Emphasis added.) “Map 3”, which the applicant’s attorney entered into the record during the <br />July 10, 2024 public hearing, is entitled “Metropolitan Area General Plan Background Report <br />Natural Resources & Airport Limitation Areas.” The City argues that this “Map 3” “is not <br />backed up with acknowledgement documents and in fact is contrary to what was acknowledged.” <br />However, as quoted above, while perhaps not the “very detailed site-specific maps” DLCD <br />referenced, this Map is labeled consistent with the acknowledgement finding. <br /> <br />Moreover, while rejecting the applicant’s “Map 3” as not being “backed up with <br />acknowledgement documents” and being “contrary to what was acknowledged”, the City relies <br />instead on an undated and unlabeled, very general map that appears to locate a significant swath <br />of the southern part of what is now in the City - as subject to whatever resource the map <br />generally references. It is clearly not the “very detailed site-specific maps of each resource” that <br />DLCD referenced in acknowledging the City’s mapping. <br /> <br />While the Scenic Sites Working Paper formed the basis for the Metro Plan Goal 5 <br />acknowledgement in 1982, without the site-specific map(s) referenced in the acknowledgement <br />documentation, which properties are subject to that acknowledgement cannot be determined. <br />The very high-level, very generalized, undated and unlabeled map the City identifies as H-2, <br />does not fit the description in the acknowledgement staff report of “a very detailed site-specific <br />map of each resource.” And, while the City may be correct that the Map 3 Metropolitan Area <br />General Plan Background Report Natural Features and Airport Limitations areas is not reflective <br />of what is shown on the maps referenced in the DLCD staff report, it is labeled, and has a title <br />that is consistent with the General Map referenced in that DLCD staff report. While, in <br />retrospect, the applicant now states that it is not “able to trace the pedigree of the H-3 map to any <br />verification of acknowledgement”, it is at least mentioned in the acknowledgement <br />documentation the applicant provided. Contrary to the applicant’s revised evaluation, it is better <br />evidence of what is acknowledged than is the City’s unlabeled and undated generalized depiction <br />of the entire southern portion of the City. <br /> <br />Without any site specific maps, which – according to the acknowledgement documentation the <br />Planning Commission Agenda Page 47 of 159