Attachment B <br />1 whether the proposed zoning of the subject property is consistent with the <br />2 Metro Plan diagram. <br />3 In general, the evidence submitted below attempted to follow LUBA's <br />4 suggested approach, by first creating a map (which we refer to as a survey <br />5 map), at a scale of 1 inch equals 200 feet that depicts the subject property lines, <br />6 the urban growth boundary, city limits and the 3 0th Avenue centerline. The 3 0th <br />7 Avenue centerline is located based on data from the Lane County Surveyor's <br />8 Office. The property boundary, city limits and urban growth boundary are <br />9 based on surveys. We understand the parties to agree that the subject property <br />10 lines, the urban growth boundary, city limits and the 30th Avenue center line <br />11 are accurately depicted in relation to each other. <br />12 Next, the Metro Plan diagram is enlarged and scaled to 1 inch equals 200 <br />13 feet (the enlarged Metro Plan diagram). The parties initially used the digital <br />14 version of the Metro Plan diagram. However, as explained below, the parties <br />1.5 later shifted to using enlarged scans of the official paper 2004 Metro Plan <br />16 diagram.' <br />1 What we refer to as the "digital version" of the Metro Plan diagram is one <br />or more maps generated by a digital database maintained by the Lane County <br />Council of Governments (LCOG). All parties agree that maps generated from <br />the LCOG database are not officially adopted maps, and that the paper 2004 <br />Metro Plan diagram is the relevant Metro Plan diagram for purposes of EC <br />9.8865(1). However, at oral argument, Lim JC and Environ-Metal agreed that <br />there are no substantive differences relevant in this appeal between the features <br />depicted on the enlarged maps in the record based on the digital version of the <br />Metro Plan diagram and those based on the paper 2004 Metro Plan diagram. <br />Page 6 <br />HO Agenda - Page 11 <br />