Mr. Fred Wilson <br />September 2, 2015 <br />Page 3 <br />LHVC Sheet 9/2/15-04 <br />This map is a cropped enlargement of the section of the Metro Plan Diagram with the <br />Applicant's Sheet ZC-2 overlaid which was presented as LHVC 9/2/15/-03. Its similarity <br />with all the other sheets and Applicant's Sheet SA7.0 is again obvious. Moreover, it <br />should be pointed out that the enlargement results in some fuzziness of the Metro Plan <br />Diagram, which, for some reason is not present on the Applicant's maps (Sheets ZC-3 <br />and ZC-4). <br />LHVC Sheet 9/2/15/-05 <br />Although the applicant maintains in their testimony that tax lot maps are highly <br />inaccurate and unreliable, this map shows that the applicant's lot can be placed on the <br />Metro Plan Diagram using unmodified tax lot maps. Two maps were necessary for this <br />purpose, as the applicant's property is not in one piece on any of the tax lot maps that <br />also have the applicant's other referents. These tax lot maps have been scaled using <br />the applicant's scale from their Sheet ZC-3 (which forms the base) and lengths of <br />property lines as indicated on the tax lot maps. The resulting registration of the <br />centerline of 30th Avenue and Spring Boulevard is at least as good if not better than the <br />applicant's version (Sheet ZC-4). Also the boundaries of Bloomberg Park coincide with <br />the boundaries of TL 800 on the tax lot map. Moreover, the applicant's property from <br />the tax lot maps once again fits on the Metro Plan Diagram very similarly to all the other <br />maps presented here as attachments. <br />The quality of the registration achievable with just the tax lot maps should not be <br />surprising given the fact that LCOG indicates that these have the best control of all <br />layers in LCOG's GIS. This is due to the fact that these maps are based entirely on <br />field-surveyed data. <br />Other Considerations <br />Applicant's counsel maintained during the hearing that he had checked the Land Use <br />ORSs and had not found any requirements to present maps oriented to the State Plane <br />Coordinate System. This is because this requirement is in ORS 93.312, where it states <br />unequivocally: <br />(2) A description of land that contains coordinates associated with the position <br />of a point on a land boundary must: <br />(a) Use the Oregon Coordinate System; <br />(b) Use one specified zone and system for the entire description;... <br />Laurel Ridge Record (Z 15-5) Page 82 <br />