measure from on a tax lot line necessarily changes the measurement. Regardless of that <br />basic shortcoming, once again, the applicant is simply attempting to use a single referent <br />- 30th Avenue, not the many referents that the applicant used and that LUBA suggested - <br />and the applicant fails to harmonize the various referents to come to a reasonable, <br />accurate conclusion. <br />The applicant repeatedly alleges that LHVC 9/2/15-04 and -05 maps represent the <br />"incorrect" Metro Plan. The letter from the City staff dated September 28, 2016, <br />unequivocally refutes this worn out allegation. City staff stated: <br />"City of Eugene staff keep paper copies of the official 11x17 Metro Plan diagram <br />for everyday use - at the request of LHVC, staff scanned this paper copy on a <br />Fujitsu FI-5750C scanner and sent the digital file to LHVC. This high quality <br />scanner is able to produce images with an optical resolution of 600 dots per inch <br />(DPI), which is why the Metro Plan diagram image on Sheet 9/2/15-04 appears to <br />be quite clear." <br />As such, the applicant's allegation of the "incorrect" map falls on deaf ears. <br />As to the applicant's repeated assertions that the City limits cannot be used, that <br />issue has been laid to rest by LUBA in its most recent opinion.I City staff also agrees <br />with this position, and, at the September 21 hearing, the Hearings Official appeared to <br />agree. <br />The applicant essentially alleges that all maps - including tax lot maps and LHVC <br />maps are incredible - and that only its own maps can be trusted. For example, in alleging <br />that map LHVC 9/2/16-05 is faulty, the applicant attacks all tax lot maps: it "actually <br />proves that tax lot maps are inherently fallible and not accurate." This is broad-brushed <br />statement, in and of itself, is incredulous. <br />The applicant then presents unsubstantiated arguments about raster and vector, <br />but the reality is that the applicant is using the blurriest image of all for its map. City <br />Indeed, LUBA ultimately agreed with LHVC stating: <br />"while not depicted on the enlarged Metro Plan diagram, the city limits line in this <br />area is a surveyed line that can be accurately located along the boundaries of two <br />features that are depicted on the enlarged Metro Plan diagram: Spring Boulevard <br />and the so-called `green finger.' According to undisputed testimony in the record, <br />the city limits is located along the eastern boundary of Spring Boulevard, and <br />borders the eastern and northern boundary of a portion of the green finger, the <br />base of which forms an `L' shape." <br />LHVC v. City of Eugene, Or LUBA , (LUBA No. 2015-092/091, March 11, 2016) <br />slip op 35. <br />z <br />