LaurelRidge <br />Zone Change Application (Z 15-5) <br />Eugene Hearings Official - Remand Hearing - Rebuttal Period - Applicant Testimony <br />Page 10 of 10 <br />Again, GIS data is NOT accurate, the much-cited city limit lines west of the subject property are NOT <br />surveyed lines, and applicant drawing SA7.0 is NOT accurate, did NOT use the correct Metro Plan <br />diagram, and is NOT part of the zone change application. (By the way, in the world of surveying, GIS <br />means "Get It Surveyed.") <br />The city has NOT submitted any surveyed data of their own. LHVC has NOT submitted any surveyed <br />data of their own. Only the applicant has submitted survey data; data which accurately locates multiple <br />referents in relation to the subject property. <br />The city and LHVC have relied on tax lot maps and city limit lines, neither of which are on the Metro Plan <br />diagram and neither of which are surveyed information. <br />The only reliable data on the record which locates the subject property on the Metro Plan diagram is the <br />applicant's data, the applicant's Exhibit L, which was previously approved by the Hearings Official, and <br />upheld by the Planning Commission. As the applicant stated last week, the applicant believes that the <br />Hearings Official got it right the first time, that the applicant's Exhibit L, Adopted 2004 Metro Plan Map: <br />Rotated, dated 5-15-2015, revised 9-2-15, is the best representation of the subject property's location on <br />the Metro Plan diagram. The applicant believes that, with the additional documentation provided during <br />this remand hearing process, that the Hearings Official can reach the same conclusion. <br />This remand hearing is all about the boundary line between two land use designations. To date, with the <br />record now closed, neither the city nor LHVC have submitted a boundary line, nor a legal description of a <br />line. Only the applicant has done so. This is further evidence that the Hearings Official can approve the <br />applicant's zone change application, declaring Exhibit L as the correct alignment of the subject property <br />on the Metro Plan diagram. <br />This concludes the applicant's rebuttal testimony. In advance, thank you for your consideration of this <br />material. <br />Sincerely, <br />M. Sa~r& <br />Richard M. Satre, AICP, ASLA, CSI, Principal <br />Schirmer Satre Group <br />Enclosed: <br />Figure 1. Applicant-annotated Figure 1 from City of Eugene Memorandum to the Eugene Hearings <br />Official, dated September 28, 2016. <br />Figure 2. Applicant-annotated Figure 2 from the same memorandum. <br />Figure 3. Applicant-annotated Figure 3 from the same memorandum. <br />Figure 4. A to-scale full size plot from the actual CAD file used to generate Figure 2, showing the then- <br />consultant's GIS and LiDAR data in comparison with actual surveyed data. <br />Figure 5. Letter from Branch Engineering, Metro Plan LaurelRidge Zone Change (Z-15-5), dated October <br />5, 2016. <br />Figure 6. City of Eugene GIS Disclaimer. <br />Figure 7. Lane County Digital Product Disclaimer. <br />Figure 8. LCOG Disclaimer. <br />Figure 9. RLID Disclaimer. <br />Schirmer Satre Group • 375 West 4 'h Avenue, Suite 201, Eugene, OR 97401 . (541) 686-4540 <br />