Mr. Fred Wilson <br />September 16, 2015 <br />Page 11 <br />Metro Plan GIS layer "...is not the adopted official diagram." Second, as staff also <br />said, there is "...no documentation regarding the methodology employed by LCOG;" <br />and, "...lacking an explanation of the exact methodology presents a problem when <br />trying to defend it." <br />(2) Opponents' September 2 post-hearing submittal went in several directions, none of <br />which is sound. <br />(a) First, opponents focused on the apparent 2-degree rotation of the adopted 2004 <br />diagram. They showed (on their two maps LHVC Sheet 9/2/15-01 and LHVC <br />Sheet 9/2/15-02) that if one rotates the subject property's boundary survey <br />compared to the Metro Plan diagram or rotates the Metro Plan diagram compared <br />to the boundary survey, that the results are the same. The Opponents then took <br />the applicant's boundary survey and superimposed it onto a scanned copy of the <br />adopted 2004 Metro Plan diagram (which they obtained from city staff). This was <br />their map LHVC Sheet 9/2/15-03. As the adopted Metro Plan Diagram is <br />published as a scale of 1" = 7000', the opponents cropped their Sheet 9/2/15-03 <br />and scaled it up to a size where the subject property was then visible on the Metro <br />Plan diagram. This was their map LHVC Sheet 9/2/15-04. <br />In all four of these sheets, the opponents located the applicant's subject property <br />on the Metro Plan Diagram by using the 30th Avenue centerline and the nearby <br />city limits line. Rotating the subject property in regards to the Metro Plan <br />diagram and rotating the Metro Plan diagram in regards to the subject property <br />both result in more POS area on the property. Using the city limits line to align <br />the subject property with the Metro Plan diagram results in even more POS on the <br />property. <br />The fundamental weakness with this is using the city limit lines. City limits are <br />not on the adopted Metro Plan diagram. <br />(b) With the last sheet in their September 2nd submittal, the opponents went in a <br />different direction. They dropped the use of the applicant's boundary survey and <br />created this fifth sheet using tax lot maps. They used two tax lot maps (obtained <br />from LCOG GIS, which city staff already said wasn't competent data) and <br />overlaid an excerpt from the Metro Plan diagram. They state that the maps align <br />with each other (i.e., fit against each other). They state that the Metro Plan <br />diagram aligns with the tax lot maps. <br />The weakness in this fifth map from the opponents is three-fold. First, they did <br />not use the subject property's boundary survey, which accurately locates the <br />property in relation to 30th Avenue. Second, they used GIS data again. Third, <br />they used tax lot maps, which are not on the Metro Plan diagram and cannot be <br />used. <br />Laurel Ridge Record (Z 15-5) Page 58 <br />