HomeMy WebLinkAboutApplicant Reponse 9-9-15September 9, 2015
Eugene Hearings Official
C/o City of Eugene
Planning and Development Department
Planning Division
99 West 10th Avenue
Eugene, OR 97401
Re: LaurelRidge Zone Change (City File Z 15-5)
Applicant's Post-Hearing Testimony
Dear Eugene Hearings Official,
Please accept this letter as applicant's additional testimony for the submittal period closing on September
9, 2015. We are responding to new evidence submitted by the Laurel Hill Valley Citizens (LHVC) on
September 2, 2015.
In the LHVC explanation regarding their illustration titled "LHVC Sheet 9/2/15-05" we would like to point
out the following:
1. LHVC did not use the subject property's boundary survey. It should be no surprise that the tax lot
maps align with each other. After all, LHVC is aligning one tax lot map with another tax lot map.
Again, the challenge before us isn't to align tax lot maps, it is to align the Metro Plan diagram with
the subject property and there is no better way to do that than using a boundary survey of the
subject property.
2. LHVC did not document the source of the tax lot maps, nor their methodology in creating Sheet
9/2/15-05.
3. LHVC asserts that tax lot maps are based entirely on field-surveyed data. As a licensed
Landscape Architect, with 38 years experience, one who utilizes tax lot maps on a regular basis, I
can say with confidence that tax lot maps are notoriously not accurate. When comparing one tax
lot map to another tax lot map, as LHVC did here, yes, they should align. But when attempting to
align a tax lot map with an actual field-surveyed tax lot boundary survey, it is common for the tax
lot map to be inaccurate. A tax lot (map, illustration, drawing or otherwise) is only accurate when
based on field-surveyed data upon the completion of a boundary survey or the recording of an
approved property partition or subdivision.
4. Tax lot maps used here may be aligned with the Metro Plan Diagram but there is no evidence
that they are aligned with the real-world location of the subject property.
5. And again, tax lot maps are not part of the adopted Metro Plan Diagram and cannot be used as a
referent.
In advance, thank you for your consideration of this material.
Sincerely,
2 is cw& M. Satrel
Richard M. Satre, AICP, ASLA, CSI
Principal, Schirmer Satre Group
375 West 4th, Suite 201, Eugene, OR 97401
PLANNERS ' LANDSCAPE ARCHITECTS ENVIRONMENTAL SPECIALISTS Phone: 541.686.4540 Fax: 541.686.4577
www, scliirmersaire.com
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