I "When planning for and regulating development, local governments shall <br />2 consider the need for protection of open spaces, including those characterized <br />3 by significant vegetation and wildlife. Means of protecting open space include <br />4 but are not limited to outright acquisition, conservation easements, planned <br />5 unit development ordinances, streamside protection ordinances, open space <br />6 tax deferrals, donations to the public, and performance zoning. ,2 <br />7 The hearings officer found: <br />8 "This policy seems to provide both broad direction to the local government for <br />9 long-term planning, and direction when regulating development; however, the <br />10 `means of protecting open space' include only long-term planning strategies, <br />11 not anything that is related to a specific development proposal." Record 219. <br />12 The planning commission agreed with the hearings officer and adopted additional findings: <br />13 "The Planning Commission concludes that Metro Plan policies C.21, EA and <br />14 E.6 are not independent, mandatory approval criteria in this instance. In <br />15 regards to Policy E.4, the Hearings Official correctly found the policy to <br />16 provide broad direction and, as applied to a PUD and CUP, the policy is <br />17 implemented by numerous criteria, including EC 9.8320(3), (4), (8), (12) (13) <br />18 and EC 9.8090(2) and (3). The Hearings Official correctly explains the proper <br />19 use of this and other Metro Plan policies in his decision, also specifically <br />20 noting that several of the other relevant policies are implemented by other <br />21 approval criteria for the applications. To the extent the policies are relevant or <br />22 could be interpreted as part of the approval criteria in this instance, the <br />23 Planning Commission has considered them and finds that the intent of the <br />24 policies are met based on the Hearings Official's decision and the additional <br />25 findings * * * elsewhere in this Final Order." Record 16. <br />26 We review the city's interpretation of its comprehensive plan and land use regulations <br />27 to determine whether it is correct. Gage v. City of Portland, 133 Or App 346, 349-50, 891 <br />28 P2d 1331 (1995). In Bothman v. City of Eugene, 51 Or LUBA 426 (2006), we concluded <br />29 that even where the local code includes a requirement that the comprehensive plan be <br />30 considered in approving a land use permit application, plan policies that plainly direct the <br />31 city to undertake planning efforts do not operate as decisional standards that apply on a case- <br />32 by-case basis when approving individual development proposals. We agree with the city's <br />33 interpretation of the Metro Plan that Policy C-21 is such a policy. Policy C-21 directs the <br />z We set out the text of Policy E-4 and discuss that policy separately later in this opinion. <br />Page 4 <br />