LaurelRidge Page 5 of 10 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Remand Hearing - Rebuttal Period - Applicant Testimony <br />October 5. 2016 <br />Figure 9. RLID Disclaimer: <br />"RLID contains maps in a variety of forms. For example, maps appear on every <br />detailed property report (DPR) as well as on the comp sales report and in Lane <br />Maps. <br />The information on these maps was derived from digital databases in the <br />regional geographic information system (GIS). Where feasible, the GIS data on <br />which these maps are based is maintained and published in a timely fashion in <br />order to keep it in synch with the other data content in RLID. Care was taken in <br />the creation of these maps, but they are provided "as is". LCOG cannot accept <br />any responsibility for errors, omissions, or positional accuracy in the digital data <br />or the underlying records. Current designations (e.g., zoning) for specific parcels <br />should be confirmed with the appropriate jurisdictions. There are no warranties, <br />expressed or implied, accompanying these maps, however, notification of any <br />errors will be appreciated. " <br />In summary, staff's time and effort attempting to document the validity of using the city limits line <br />was not a wise decision. In the first figure, the city limits line is not a surveyed line. In the second <br />figure, there is nothing surveyed. In the third figure, the use of GIS data is very well documented <br />to not be reliable. <br />3. Using Multiple Referents. <br />Eugene staff define the process of using map referents as "The procedure used to bring data layers <br />into alignment via known ground location control points..." Staff further emphasizes plurality of <br />"control points"- that multiple referents could help in locating a map referent. The applicant doesn't <br />disagree. Multiple referents could help. However, the applicant points to two discrepancies in staff <br />assertions. <br />The first discrepancy is that the definition that staff utilizes is the reference to "known ground <br />location" control points. As has been documented, the much-cited city limit lines west of the <br />subject property are not surveyed lines. There is no known ground location of those lines. <br />They were traced over non-surveyed, "as-is", tax lot maps. Given this, any claim staff has <br />made, or will make, regarding the use of the city limit lines to assist in locating the subject <br />property on the Metro Plan diagram is in error. <br />The second discrepancy is the conflict between two statements in staffs narrative regarding <br />"accuracy." In the first statement, staff says that accurately registering a map image (i.e. <br />the Metro Plan diagram) to map data layers can only be accomplished by using multiple map <br />referents (or control points)." Staff then says that although multiple referents in this case do <br />not align it is still "...preferable to use multiple map referents even if they do not line up with <br />100% accuracy."So, what is staff saying? They profess the need for accuracy but if <br />accuracy is not possible, as it's not in this case, then something less than accurate is okay. <br />Can't have it both ways. They certainly did not make a case that multiple referents are better. <br />Applicant's Response to the LHVC Submittal, Dated September 28, 2016 <br />1. Applicant's Allegation 1: The LHVC Metro Plan Diagram vs. Applicant's True Copy. <br />In response to LHVC comments regarding the True Copy, see our statement above under <br />"Applicant's Response to the Eugene Planning Memorandum, Dated September 28, 2016, 1. Metro <br />Plan Used by LHVC." <br />Schirmer Satre Group 9 375 West 41h Avenue, Suite 201, Eugene, OR 97401 . (541) 686-4540 <br />