Mitchell Hartman, editor of the magazine Oregon Business, offered a pithy comment on Measure 37 in his December 2004 column, which is akin to my views on why the measure passed. Mr. Hartman wrote, "[The passage of Measure 37] clearly expresses a frustration with land use rules and the government agents who enforce them. The easiest way to turn a landowner against planning is for some government bureaucrat to say 'no' repeatedly to a legitimate and seemingly harmless improvement -- stopping someone from building a shed next to their streamside home in Lake Oswego, or banning a Yamhill County farm family from building a house for their kids to live in."