Mr. Fred Wilson <br />September 16, 2015 <br />Page 13 <br />(b) The Tax Lot lines (data) that opponents put on the blowup of the Diagram in the <br />post-hearing submittal are not referenced to any data source. <br />(c) The LCOG Tax Lot GIS data layer, if that was used, consists of unsurveyed data <br />that are not shown to be registered to anything on the ground, including the site <br />survey. So, there is guesswork here in opponents fitting it to the Diagram The <br />applicant's licensed landscape architect, Richard Satre, AICP, ASLA, CSI, <br />explained it this way in the applicant's September 9 rebuttal evidence: <br />"As a licensed Landscape Architect, with 38 years experience, one who <br />utilizes tax lot maps on a regular basis, the applicant's land use consultant <br />can say with confidence that tax lot maps are notoriously not accurate. <br />When comparing one tax lot map to another tax lot map, as the opponents <br />did, yes, they should align. But when attempting to align a tax lot map <br />with an actual field-surveyed tax lot boundary survey, it is common for the <br />tax lot map to be inaccurate. A tax lot (map, illustration, drawing or <br />otherwise) is only accurate when based on field-surveyed data upon the <br />completion of a boundary survey or the recording of an approved property <br />partition or subdivision". <br />(d) The Assessor's Tax Lot maps, if that is what was used, do not reflect surveyed <br />information in this area, as there is no subdivision or partition plat filed. See <br />quote immediately above. So, there is guesswork here in opponents' fitting it to <br />the Diagram. <br />(8) Opponents have not suggested a boundary line that is reduced to a metes and bounds <br />legal description. They have not proposed a location between the boundaries of the <br />two proposed zoning districts. <br />VI. City of Eugene Staff recommend Approval. <br />(1) In their Zone Change Staff Report, City of Eugene staff recommended that the <br />Hearings Official approve the requested zone change. Staff found that the applicant's <br />proposal is consistent with applicable criteria. With particular attention to the <br />criterion regarding consistency with applicable provisions of the Metro Plan, <br />including the Metro Plan Diagram, staff summarized its review of the applicant's <br />proposal with the following statement: <br />II <br />staff believes the applicant's representation of the Metro Plan's Parks <br />and Open Space designation is reasonable considering the limited <br />precision that can be afforded by the relatively generalized Metro Plan <br />Diagram." <br />Laurel Ridge Record (Z 15-5) Page 60 <br />