I as the 1995 CUP, or (2) provide a basis to conclude under EC 9.8110(2) that the proposed <br />2 modification will result in insignificant impacts on adjoining properties. Intervenors contend that <br />3 petitioners bear the burden of demonstrating compliance with EC 9.8110(2), and that petitioners <br />4 failed to submit any evidence or even focused argument that the city's tree cutting ordinances <br />5 provide the same protections as the 75-foot vegetative buffer required by the 1995 CUP. <br />6 We agree with intervenors that petitioners did not adequately raise the issue that they fault <br />7 the hearings officer for failing to address. The testimony petitioners cite to is not directed at <br />8 EC 9.8110(2) and at best presents an argument that the city's tree cutting ordinance will ensure that <br />9 any tree removal that occurs will be consistent with the city's tree cutting ordinance. See n 5. That <br />10 argument falls far short of alerting the hearings officer that petitioners believe the city's tree cutting <br />11 ordinance requires evaluation of impacts to adjoining .,properties, and further offers protection <br />12 equivalent to the vegetative buffer imposed by the 1995 CUP, for purposes of complying with <br />13 EC 9.8110(2). Petitioners do not argue they raised any issue below regarding whether the city's <br />14 stormwater regulations are sufficient to protect adjoining properties against increased runoff that <br />15 might result from loss of the vegetative buffer, for purposes of EC 9.8110(2). Having failed to raise <br />16 these issues below, petitioners' argument that the hearings officer erred in failing to address them <br />17 does not provide a basis for reversal or remand. <br />18 C. Modifications to Access and Utilities <br />19 Having rejected the proposed modification to remove Zone 6 from the 1995 CUP footprint, <br />20 the hearings officer proceeded also to reject the proposed modification to the 1995 CUP to allow <br />21 fixture development in Zone 6 to access and use roads and utilities within the remaining CUP area.' <br />6 The hearings officer's decision states, in relevant part: <br />"Likewise, the applicant has proposed changes to access and utility installation, yet has not <br />provided any evaluation as to how the change in access or installation could impact the <br />surrounding properties or the use of the site. While any change may be insignificant, without <br />that evaluation, and a statement of the purpose of the changes, that evaluation cannot be <br />made." Record 14. <br />Page 14 <br />