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June 26, 2015
RICHARD M. SATRE
SCHIRMER SATRE GROUP
375 WEST 4T" AVENUE, SUITE 201
EUGENE, OR 97401
RE: Completeness Review for Laurel Ridge Zone Change (Z 15-5)
On May 27, 2015, you submitted a Zone Change application for the Laurel Ridge property (Tax Lots
701 & 703 of Assessor's Map 18-03-10-00). The Planning Division has assigned a file number (Z 15-5)
and I will serve as the lead City staff person reviewing the application.
As you know, the first step in the application process is the "Completeness Review Step." For further
information about this step, refer to the document enclosed titled, "Land Use Application -
Completeness Review Step." Also enclosed is a document titled, "Incomplete Land Use Application -
180 Day Completeness Review Process." To help ensure City staff know how to proceed with your
application, please sign and return this form.
Regarding your application, City staff reviewed the application and determined that it is incomplete.
Below are comments from the Planning Department that help to identify the missing or otherwise
incomplete materials as they relate to the Zone Change Approval Criteria:
1. EC 9.8865(1) - Please expand the discussion of all potentially relevant Metro Plan policies,
including those that address the protection of open spaces and natural areas (e.g. Policy
C.21).
Methodology/UGB - In the 2012 Laurel Ridge Hearings Official Decision (Z 12-2), the
Official states that "...the UGB and 30th Avenue are sufficient reference points upon which
to locate the subject property" (page 8). Please further explain the applicant's position as
to the use of the UGB as a referent, in light of the Hearings Official's clear statement noted
above. If the applicant believes the UGB as shown on the Metro Plan diagram is not an
appropriate referent, please clarify that reasoning in more detail (i.e. why the applicant
disagrees with the Hearings Official, staff and opponents use of the UGB as a referent in
the prior case), and why it is included on plan sheet ZC-4 (Diagram on Subject Prop.). The
applicant should also provide an explanation of its position in light of LUBA's extensive
discussion about the UGB as a sufficient reference point.
City of Eugene . 99 W 10th Ave. • Eugene, OR 97401 . 541-682-5481 . 541-682-5572 Fax
www.eugene-or.gov/planning
Methodology/North Arrow - Exhibit F states that the 30th Avenue, the UGB and the
Diagram's north arrow "...were referred to by staff as 'Referents."' Staff does not recall
advising the applicant to rely on the north arrow or how, nor does the Hearings Official or
LUBA appear to use it in his analysis of the prior case. Please further explain how the
applicant has used the north arrow as a referent, and how the correct mapping orientation
(i.e. true north) is maintained through the process of overlaying the Metro Plan diagram
with surveyed data (e.g. 30th Avenue, the UGB, and the subject tax lots).
4. Transportation Planning Rule - Please address the existence (or lack thereof) of the Parks
and Open Space (POS) comprehensive plan designation at the time the TSP was adopted,
and how this relates to the requested TPR exemption.
Previous Site Analysis Map - A map similar to the current plan sheet ZC-4 (Diagram on
Subject Prop.) was included as Attachment B in the 2012 Hearings Official packet for the
Laurel Ridge PUD. This graphic, labeled as sheet SA7.0 and named "Site Analysis: Land Use
and Infrastructure," depicts a larger area of Parks and Open Space (POS) zoning on the
subject property than is currently proposed.
Please describe why this map differs from the current sheet ZC-4. If this discrepancy
relates directly to a difference in the methodology used to define the POS boundary,
please explain the method (i.e. referents) used to generate the 2012 version as compared
to the current request.
6. On page 6 of the submitted narrative, please note that the correct Metro Plan Diagram
Ordinance No. is "20319."
If you have any questions about this completeness review, please contact me at (541) 682-5437 or
via e-mail at: erik.bergPci.eugene.or.us
Sincerely,
Erik Berg-Johansen
Assistant Planner
Enclosures: Land Use Application - Completeness Review Step;
Incomplete Land Use Application -180 Day Completeness Review Process
CC: Environ-Metal Properties, LLC