September 28, 2016 <br />Eugene Hearings Official Received <br />c/o City of Eugene r <br />Planning and Development Department <br />Planning Division SEP 2 8 2016 <br />99 West 10th Avenue <br />Eugene, OR 97401 City of Eugene <br />Re: LaurelRidge Zone Change (City File Z 15-5) Planning Division <br />Remand Hearing - Open Record Period - Applicant Testimony <br />Dear Eugene Hearings Official, <br />We are submitting this as the applicant's open record testimony. <br />Additional Referents <br />At the remand hearing last week on September 21, 2016, the applicant submitted testimony and evidence <br />as suggested by LUBA and addressed additional referents. As documented that evening, the applicant <br />surveyed the location of three additional referents to add to its original referent - the 30th Avenue <br />centerline. The three additional referents were the tax lot associated with what is being referred to as the <br />green finger, the centerline of Spring Blvd, and Bloomberg Park. These four referents are locationally <br />diverse in regards to the subject property. The green finger tax is located to the west-northwest, the <br />centerline of Spring Blvd is located to the west-southwest, the 301h Avenue centerline is located to the <br />west-southwest and south, and Bloomberg Park is located to the south-southeast. <br />As was documented, no two sets of referents can be utilized to accurately locate the subject property on <br />the Metro Plan diagram. That is because the Metro Plan diagram is not a measured drawing. It is not <br />based on surveyed data. It is a drawing carried forward from its genesis in the late 1970s, well before the <br />development of today's digital drawing construction abilities. It is not inaccurate to say that the Metro <br />Plan diagram is a cartoon. <br />Given that, the applicant stated that evening that additional referents have been considered, and that <br />having more referents did not provide more accuracy. The strongest, best, nearest and longest referent, <br />the 30th Avenue centerline, is still the best referent to use. <br />LHVC Sheet 912/15-04 <br />Another of LUBA's findings discussed the need to adequately consider LHVC Sheet 9/2/15-04. This <br />occurred at last week's hearing. The Hearings Official discussed his consideration of the diagram from <br />the prior approval of this zone change application a year ago. The Hearings Official asked a number of <br />questions regarding the diagram. LHVC representatives discussed sheet 9/2/15-04 in detail. <br />The hearing closed with LHVC stating that their Sheet 9/2/15-04 is the most accurate and best alignment <br />of the subject property on the Metro Plan diagram and should be the alignment that the Hearings Official <br />should select. <br />Given that, the applicant decided to take a look at Sheet 9/2/15-04 and Sheet 9/2/15-05. <br />Here is what we found. <br />A. A COMPARISON OF LHVC 9/2/15-05 AND ACTUAL SURVEYED DATA <br />The information below lists the inconsistencies on map LHVC 9/2/15-05 which pm~ <br />opponents assert justifies the fact that tax lot maps, not found anywhere on the Metro <br />Plan, can be used to accurately locate the subject property with respect to the Metro <br />Plan. FN <br />+ LANDSCAPE ARCHITECTS + <br />375 West 4th, Suite 201, Eugene, OR 97401 SCHIRMER <br />PLANNERS - LANDSCAPE ARCHITECTS ENVIRONMENTAL SPECIALISTS Phone: 541.686.4540 Fax: 541.686.4577 - <br />www.schirmersatre.com <br />