Applicant's Final Argument - Laserfiche WebLink

Eugene Hearings Official October 12, 2016 Page 5 (b) The survey data are precise in the real world. Only the applicant has submitted survey data. Survey data are now available for the boundaries of the subject property and the following real world features tied to the subject property: Centerline of E. 301h Ave.; the centerline of Spring Blvd.; the boundaries of TL 301 - the green finger; the east boundary of TL 500; and the west, north and east boundaries of TL 800 - Bloomberg Park. All these data are shown on a single survey map by Branch Engineering, submitted at the hearing. The Applicant's September 21 hearing submittal also included four large sheets, each fitting the survey of the subject property to one of four surveyed referents - the center line of 301h Ave., the green finger, Spring Blvd, and Bloomberg Park. Survey data are available for only one proposed location of the plan boundary line. That is the line proposed by the applicant and approved in the previous decision. (c) The GIS data, notably county tax lot data and the city limits line, are not precise in the real world. By definition these data sets are all approximations. Every source of GIS data that was used by the City or the opponents is a database that comes with substantially the same disclaimer about limitations on its accuracy and use. See verbatim disclaimers, quoted in the Schirmer Satre October 5 letter, from the City, the County, LCOG, and RLID. LCOG says: "The relative accuracy and absolute accuracy of this product are not guaranteed * * * The County says about its tax lot maps: "Current configurations and/or designations for specific parcels should always be confirmed with the appropriate jurisdiction(s)." The City says: "the maps and data are dynamic and in a constant state of maintenance, correction and revision. Any maps and associated data for access do not represent a survey." The inherent limitations of the GIS data and shortcomings in the opponents' and staff's use of GIS data are now well documented in the Record. See especially the Schirmer Satre September 28 open record submittal, and the Schirmer Satre October 5 rebuttal evidence. 4. Discussion. The Hearings Official must choose a methodology to locate the boundary line, and then he must actually locate the line. Choosing a methodology: The applicant's methodology uses all survey data for referents on the Diagram. The opponents use only imprecise GIS data for referents on the Diagram and other stuff not on the Diagram. Neither methodology allows simultaneous matching of multiple referents on the Metro Plan Diagram to the subject property. The Applicant showed this for the surveyed referents in its