and the Breen finger. LHVC's Diagram certainly appears to match upvery well with the length of <br />East _ 0'h Avenue and the city limit lines around Spring Boulevard and the Teen finger. <br />The applicant argues that the city limit lines on the LHVC Diagram should not be used <br />because the city limit lines are not on the Nletro Plan Diagram and the city limit lines nn LHVC's <br />survey map were generated by tax lot and CIS information that is inherently inaccurate. <br />"The GIS data, notably county tax lot data and the city limits line. are not precise in the <br />real world. By definition these data sets are all approximations. Every source of CIS data <br />that was used by the City or the opponents is a database that comes with substantially the <br />same disclaimer about limitations on its accuracy and use. <br />"The inherent limitations of the GIS data and shortcomings in the opponents' and staffs <br />use of GIS data are now well documented in the Record." Applicant's Final Legal <br />Argument s. <br />While I am sympathetic to the applicant's argument that the city limit lines may not be <br />perfectly accurate, LUBA clearly does not agree: <br />"bVhile the cit limits line is not depicted on the enlarged Metro Plan diagram. neither is <br />the centerline of East ;0th Avenue on which Environ-Metal exclusively relies. Birth the <br />city limits and center line are surveyed. and there is no dispute that the depiction of their <br />location and relationship on the survey map is accurate. Both the centerline and the city <br />limit line bear close physical relationships to features depicted on tile 2004 Metro Plan <br />dia,rant * * Like the western curve of East ,Olh .Avenue, the city limits line is posi[ioned <br />at various angles to the portion of East =0th Avenue that Envircm-Metal relies upon as its <br />sole referent. and thus the city limits line matchup acts as an additional referent to check <br />the accuracy of Environ-Nfetal's preferred location of the match between the survey map <br />and the enlarged Metro Plan diagram." Laurel Hill I4r//ev Chiaeiis. Slip Op 37-38. <br />Although the applicant argues that the city limit lines are inaccurate. the September ?S, <br />2016 staff memo explains that staff conducted measurements to test the accuracy of the LHVC <br />Diagram city limit lilies and that staff concurs with LHVC's depiction of city limits.'' The <br />applicant argues that the measurements are faulty, largely for the same reasons that discussed <br />above that tax lot data and GIS data are unreliable. Even if that is true. LUBA held that the city <br />limit lines should be used as referents and staff validated those city limit lines. As far as I can tell, <br />the city limit lines are accurate. <br />" LUBA stated that the city limit lines are surveyed. While the city limits that birder the suhjeet property' are surveyed. <br />the applicant ar_ues that the other ciuY limit lines are not surveyed and werejust traced onto a sureey map from another <br />map. LI.IBA explained that there is no dispute that the city limit lines are accurate. Even if LUBA had notdeterntined <br />that the city limit lines were accurate. LI IBA still tiwnd that the CILV limit lines act "as an additional reterent to check <br />the accuracy' of the ;lpplicant s Diagram. <br />Hearings Official Decision (Z 15-5 Remand) Page 11 <br />