LaurelRidge Page 6 of 10 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Remand Hearing - Rebuttal Period - Applicant Testimony <br />October 5. 2016 <br />In response to LHVC comments regarding pixels, please refer to the enclosed letter from Branch <br />Engineering, dated October 5, 2016. <br />In response to LHVC comments regarding the 1,200 dpi resolution of their copy of the Metro Plan <br />diagram, please note that staff says that the resolution was 600 dpi. <br />2. Applicant's Allegation 2: It is Impossible to Use More Than One Referent at a Time. <br />LHVC presented two arguments under the heading "Applicant's Allegation 2: It is Impossible to Use <br />More Than One Referent at a Time." The first is in regards to what was used and how they created <br />the diagrams in their September 28, 2016 submittal. The second is in regards to how the various <br />referents can, or cannot, align. The applicant addresses both of these arguments below. <br />A. LHVC's Maps Included with their September 28, 2016 Submittal. <br />LHVC used a scan of a copy of a PDF of the surveyor's map. They then overlaid that onto a scan <br />of a copy of a PDF of the applicant's map. They then "adjusted" that overlay by changing the <br />scale and rotation, creating a diagram another generation removed from the original. They then <br />added another scan of a copy of a PDF onto this new drawing, moved that new layer around, <br />creating another diagram another generation removed from the original. Really? So how <br />accurate is this? Scans? PDFs? Adjusting, scaling and rotating? Ever see the movie <br />'Multiplicity?' Everyone knows that a copy of a copy is not as sharp as the original. Successive <br />generations result in distortion and degradation. <br />B. How the Various Referents Do, or Do Not, Align. <br />After scanning, overlaying, scaling and rotating, LHVC stated that there is no perfect alignment. <br />(Gosh, that's just what the applicant said.) LHVC then stated, just as staff said, that if you can't <br />have accuracy, then it's okay to settle for something less. <br />3. Letter from Jan Wostmann. <br />The stated purpose of Jan Wostmann's September 28, 2016, letter is to get on the record a city staff <br />estimate of the POS acreage. As stated in the letter, the city used GIS data. It is fine that this <br />acreage calculation is now on the record. But it is irrelevant. It is irrelevant, first, because it has been <br />demonstrated that GIS data is not accurate and, second, because acreage is not a criterion for zone <br />change approval. <br />4. Letter from Sean Malone. <br />There were six sections to Mr. Malone's letter. Each is addressed (as A through F) below. <br />A. The applicant is incorrect to continue to allege that LHVC map 9/2115-04 is based on the <br />electronic version. <br />Mr. Malone's letter opens with a series of statements regarding the Metro Plan diagram used in <br />LHVC Sheet 9/2/15-04. See the applicant's statement above under "Applicant's Response to the <br />Eugene Planning Memorandum, Dated September 28, 2016, 1. Metro Plan Used by LHVC." <br />B. LUBA directed that the Hearing Official to consider the city limits, Spring Boulevard, and the <br />"green finger." <br />Schirmer Satre Group • 375 West 4th Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />