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