LaurelRidge Page 7 of 10 <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Remand Hearing - Rebuttal Period - Applicant Testimony <br />October 5, 2016 <br />Mr. Malone then reminds everyone that LUBA directed the Hearings Official to consider the city <br />limits lines. As stated above, a key word here is "consider." LUBA directed the HO to consider <br />the city limits. LUBA did not mandate that the city limits lines be used. As has been stated <br />repeatedly, and demonstrated conclusively, the city limit lines west of the subject property, those <br />which are the subject of this discussion between all parties on the record, are NOT surveyed <br />lines. They are lines traced from tax lot maps which were obtained as GIS data from other <br />sources, including the city and LCOG. GIS data is not accurate. The city limits were not <br />surveyed. They cannot be used. <br />C. The applicant's new maps (ZC-4A through D) are not responsive to LUBA's remand. <br />Mr. Malone then states that the goal is accuracy, not perfection. In response, if one wants <br />accuracy, then one must rely on actual surveyed data. Not GIS data, not traced linework, but <br />actual, verified, documented surveyed data. The applicant is the only party on the record which <br />has submitted surveyed data. The subject property boundary has been surveyed. The location <br />of all of the cited referents have been surveyed. <br />D. LHVC's prior submitted map and newly submitted map are the most accurate maps before the <br />Hearing Official. <br />The applicant has previously documented, in great detail, how the LHVC Sheet 9/2/15-04 is NOT <br />accurate. This documentation was included in the applicant's open record submittal dated <br />September 28, 2016. For convenience, a portion of that testimony is repeated here. (Refer to the <br />applicant's open record submittal, dated September 28, 2016, for the full text.) <br />Excerpt from Applicant's Open Record Submittal, dated September 28, 2016: <br />B. A COMPARISON OF LHVC 912/15-04 AND ACTUAL SURVEYED DATA <br />This document lists the inconsistencies on the map LHVC 912115-04 which opponents assert is the <br />more accurate location of the boundary between the two land use designations. <br />LHVC 912115-04 (what makes up this original exhibit) <br />• Adopted 2004 Metro Plan scanned by the City of Eugene from a book they have in the office <br />that contains the Metro Plan (not scanned from the original document kept on file at the city <br />recorder's office). <br />• Schirmer Satre Groups ZC-2 (dated 5-15-2015). <br />Note: We have no direct knowledge of the methodology used to assemble this sheet however <br />what we do know is LHVC did not have access to an ACAD version of the surveyed line work. <br />They would have had to make a copy of the line work from the paper or PDF plans submitted <br />initially which necessarily makes the data a raster images (pixelated, less clear). <br />This non-A CAD (pixelated /raster) version would then have to be merged with the scan of the <br />Metro Plan. <br />The inherent accuracies in that methodology are evident when taking a close look at this sheet. <br />2. What We Found (letters on drawing correspond to the following comments) <br />Drawing ZC-4F <br />• When the drawing is scaled so that the bar scale in the lower right comer of the title block is <br />at exactly 1 "=200' then other lines within the drawing are not accurate. <br />Graphic Scale: 1 " = 200' <br />Schirmer Satre Group • 375 West 4 'h Avenue, Suite 201, Eugene, OR 97401 • (541) 686-4540 <br />