I the statute but on its code as the basis for rejecting petitioner's CIR-CUP application. <br />2 Further, the city argues that its action is consistent with the statute. The problem with the <br />3 CIR-CUP application, the city contends, is not that it was incomplete, but that it requested <br />4 something the city could not consider: approval of a new CUP for a portion of a site already <br />5 subject to an approved CUP. In order to review that request, the city contends, petitioner <br />6 must file an application to modify the 1995 CUP in some way. The city agrees with <br />7 petitioner that the requisite modification could take a number of different forms, but argues <br />8 that it was in no position to inform the applicant "exactly what information was missing," as <br />9 ORS 227.178(2) requires. Under these circumstances, the city argues, rejecting the CIR- <br />10 CUP application was consistent with ORS 227.178(2). <br />11 Questions regarding what types of applications a development proposal requires are <br />12 often resolved at a pre-application conference. We are informed that the city has a voluntary <br />13 process for pre-application conferences, but petitioner did not request such a conference. <br />14 That point aside, the disagreement between the parties boils down a dispute over the <br />15 permissible range of responses under the city's code and applicable statutes, when the city <br />16 official who receives a permit application believes that development proposed in the <br />17 application requires an additional or a different type of application than the one submitted. <br />18 We disagree with the city that the city's code answers that question. The city may or may <br />19 not be correct that approval of the proposed development requires prior modification of the <br />20 1995 CUP pursuant to EC 9.718 and 9.772; however, neither of those code provisions <br />21 purport to authorize the city to reject a permit application for failure to seek such a <br />22 modification. <br />23 More importantly, we agree with petitioner that the city's summary rejection of the <br />24 permit application is inconsistent with ORS 227.178(3). That statutory provision is part of a <br />25 larger set of provisions beginning at ORS 227.160 prescribing standards for processing <br />26 permit applications. In relevant part, ORS 227.175 provides that the city must establish a <br />Page 9 <br />