I officer's decision, and that it erred in accepting and relying on new evidence relating to those <br />2 appeal issues in contravention of EC 9.7655(2). <br />3 West Creels responds that the issues that it raised in its appeal statement regarding the <br />4 Matthews Slope Map were raised before the hearings officer at Record 498 and that the <br />5 planning commission did not err in correctly concluding that West Creek had raised the <br />6 issues below. West Creek argues that the planning commission correctly interpreted EC <br />7 9.7655(3) as allowing the planning commission to consider West Creek's additional <br />8 arguments related to issues that were properly raised below. Finally, West Creels responds <br />9 that the planning commission correctly concluded that, except for the material that the <br />10 planning commission struck as new "evidence," no new evidence was included in West <br />11 Creek's submissions. <br />12 We agree with West Creek. First, Southeast Neighbors' arguments in the first <br />13 subassignment of error conflate the "issues" that it alleges were not raised with the more <br />14 detailed arguments on the issues that West Creek made to the planning commission. The <br />15 planning commission interpreted the requirement in EC 9.7655(3) that an "issue" have been <br />16 raised not to require that an appealing party must have raised all arguments in connection <br />17 with that issue in order to make those arguments to the planning commission. Southeast <br />18 Neighbors does not challenge that interpretation or otherwise explain why it is not correct. <br />19 Gage v. City of Portlafzd, 133 Or App 346, 349-50, 891 P2d 1331 (1995). <br />20 Second, Southeast Neighbors does not identify in the petition for review with any <br />21 specificity the `'new evidence" that it alleges was introduced before the planning <br />22 commission.7 The planning commission adopted detailed findings that identify the evidence <br />23 it determined was "new evidence" contained in West Creek's and Southeast <br />7 The petition for review refers to a chart at Record 328-29, but that chart does not identify with any <br />specificity new "evidence" that Southeast Neighbors believes was introduced. Southeast Neighbors' Petition for <br />Review 26. <br />Page 13 <br />