14 <br />Laurel Dill Valley Citizens <br />Co-Chairs <br />Gunnar Schlieder <br />Jan Wostmann <br />Secretary <br />Stephanie Midkiff <br />Treasurer <br />Betty Hemmingsen <br />Executive <br />Committee <br />Adam Jones <br />Bill Blix <br />Betty Hemmingsen <br />Betty Hosokawa <br />Deborah Kelly <br />Kathleen Frazer <br />Kaye Downey <br />Mitch Hider <br />Natalie Whitson <br />Paul Crum <br />Seamus Corbett <br />Sheryl Kelly <br />Susan Ratzlaff <br />September 9, 2015 <br />Mr. Fred Wilson, Eugene Hearings Official <br />c/o Eugene Planning Department <br />99 West 10th Ave. <br />Eugene OR 97401 <br />Re: Response to September 2, 2015 submission by applicant for Laurel Ridge Z15-5 <br />Dear Mr. Wilson: <br />This final argument from LHVC contains no new evidence and introduces no new <br />issues. It is one of two letters summarizing the LHVC position with regard to Z15-5, <br />and relies on evidence in the public record as of 9/2/2015. <br />There is really only one issue in contention that blocks the approval of Z15-5, that <br />is compliance with approval criteria EC 9.8865(1): The proposed zone change is <br />consistent with applicable provisions of the Metro Plan. <br />It is our assertion that the applicant has not met their burden of proof in claiming <br />that either of the two most recent maps of their property in relation to the Metro <br />Plan Diagram is accurate. Exhibit L: ZC-4: Adopted 2004 Metro Plan Map Rotated, <br />is perhaps slightly closer to reality than their previous versions, while Exhibit M: <br />ZC-4: Adopted 2004 Metro Plan Map Not Rotated, is unchanged from previous <br />versions and has all the inaccuracies highlighted by LHVC in previous testimony. <br />Even Exhibit L is still too far removed from know facts in the record to be a basis <br />for approval. <br />Our argument has a number of facets, they are: <br />All layers in any map must be rotated to the same interpretation of North. <br />More than one referent must be used to accurately align the layers on the <br />applicant's maps. <br />3. LHVC has presented maps that show the correct registration of the subject <br />property onto the Metro Plan Diagram, and these maps all show a substantially <br />larger POS designated area than the latest maps presented by the applicant. <br />4. Given the repeated misrepresentation of their methodology by the <br />applicant, their latest submission cannot be trusted and is incomplete. <br />We will detail each of these points below. <br />LaurelHillValleyCitizens@gmail.com 2480 Laurel Hill Drive 9 Eugene, OR 97403 . www.lhvc.org <br />