the proposed conservation setback is consistent with the setback methodology set out in EC 9.4920. If; <br />as here, the applicant disagrees with the city's identification of the resource site and "top of bank," the <br />applicant has the burden of showing why the resource area is misidentified and. correspondingly, <br />explain why the proposal meets the applicant's view of the standard.9 <br />B. Ambiguity in the City's Goal 5 Resource Plan maps <br />The city's adopted Goal 5 maps are an amalgamation of aerial orthophotos overlain with tax map lines. <br />The parties dispute the reliability of those adopted maps. The applicant argues that the maps <br />themselves do not accurately depict the resource and its relation to property boundaries, or to the <br />extent they identify a resource site within the boundaries of the subject property, the resource site <br />boundaries are invariably skewed to include more area than is needed to protect the resource. The <br />applicant argues that for smaller'sites, the maps must be interpreted to include only those features that <br />have been identified as worthy`of protection under the Goal 5 Resource Plan. To do otherwise, the <br />applicant argues, conflicts with plan policies that permit development outside of the conservation <br />areas, consistent with the applicable zoning designation. <br />The applicant analogizes the Goal 5 maps in this case to ambiguities in plait maps generally, and <br />argues that the maps themselves must be interpreted consistently with related plan text. Carlson v. City <br />of Eugene, 3 Or LUBA 175 (1981) (ambiguities in the Metro Plan land use diagram may be resolved <br />by-reliance on more site specific provisions in the applicable refinement plan); Knutson Family LLC v. <br />City of Eugene, 48 Or LUBA 399, aff'd 200 Or App 292, 114 P3d 1150 (2005) (ambiguities in <br />refinement plan and Metro Plan designations should be resolved to give effect to both) and Lofgren v. <br />Jackson County, _ Or LUBA _ (LUBA No. 2007-061, October 4, 2007) slip op 21 (plan map <br />designation criteria provides relevant context for resolving mapping ambiguity.) <br />The applicant describes the method used by staff to scale the Goal 5 resource maps as "slapping" a <br />ruler on a map without regard to the resource to be protected, and argues that this approach to <br />identification of the resource boundaries was "debunked" in prior decisions. See May 14, 2008 letter <br />from Bill Kloos to Anne Corcoran Briggs, page 3, referring to The Picullel Group decisions and the <br />hearings official decision in CI 07-3. <br />The city responds that the Goal 5 resource maps, while less site specific than the applicant desires, are <br />clear enough to identify the resource on the site. Staff argues that while it may be true that some of the <br />resource plan maps includes more than just the small area that encompasses the protected resource, the <br />larger area is consistent with Goal 5 Resource Plan`provisions and Willakenzie Area Plan Resource <br />Policy 1, which are intended to protect all of resource attributes to the maximum extent feasible. Staff <br />also argues that while the scaled version of the resource area described in the May 6, 2008 staff report <br />and depicted as Exhibit B to its July 14, 2008 memorandum are not exact in every detail, they <br />reasonably approximate the boundaries of the resource site. 10 <br />9 The applicant may provide its own version of the /WR resource site, based on its own scaling of the Goal 5 maps, or the <br />applicant may assert that the resource site was mis-mapped. EC 9.4960 includes provisions addressing /WR mapping <br />errors. The hearings official realizes and agrees with the applicant that adjustments to the conservation setback or resource <br />site boundaries are unlikely to be approved under the very limited approval standard set out in the code, nevertheless, EC <br />9 4960 is one avenue to adjust the boundaries, a plan map amendment is another <br />10 The May 6, 2008 staff report at pages 12-13 states, in relevant part <br />"With respect to the adopted Goal 5 Maps, the dimensions and shape of the /WR site in relation to the dimensions <br />of the subject property facilitate scaling the /WR Site on the subject property, and ameliorate any challenges that <br />are otherwise presented by the laree scale of the Goal 5 Plan maps and the size of the resource As shown on the <br />Alder Woods PUD (PDT 07-5 & SDR 08-2) <br />Lturel Ridge Record (Z 15-5) <br />Page 12 <br />Page 1140 <br />