I ASSIGNMENT OF ERROR (LHVQ <br />2 A. First Sub-Assignment of Error <br />3 LHVC argues that the hearings official mistakenly assumed that the <br />4 LHVC Sheet 9/2/15-04, submitted on September 2, 2015, was based on an <br />5 enlargement of the digital Metro Plan diagram rather than an enlargement of <br />6 the official paper 2004 Metro Plan diagram.4 Due to this mistake, LHVC <br />4 The hearings official's decision states, in relevant part: <br />"LHVC produced maps showing much more POS designated lands <br />by using a version of the Metro Plan diagram obtained from <br />LCOG that are depicted in Exhibits 1-5 [Sheets 9/2/15-01 through <br />-05] to their letter of September 2, 2015. LHVC also uses tax lots <br />for other properties, city limits, and additional streets to generate <br />what it argues are more accurate maps than the applicant. LHVC' <br />materials were prepared in part by a certified engineering <br />geologist, and the arguments are compelling. In fact, if the <br />question were where the boundary is most likely located using any <br />available information, I would likely agree with [LHVC]. In <br />determining the boundary, however, we are all bound by the 2004 <br />Metro Plan diagram. As staff s September 2, 2015 memorandum <br />explains, LHVC' used maps generated by LCOG from a digital <br />version that is different from the 2004 Metro Plan. Even though <br />the digitized version is likely more accurate than the 2004 Metro <br />Plan, even LCOG acknowledges that only the 2004 Metro Plan is <br />the official version of the diagram. Furthermore, city limits and <br />tax lots are not depicted on the 2004 Metro Plan diagram. So even <br />though LHVC' maps may be theoretically more accurate, they are <br />not more accurate for determining the boundary by using the 2004 <br />Metro Plan diagram." Record 148. <br />Page 19 <br />