I "Turning to Petitioners' arguments here, the City's original <br />2 demonstrated need for one or two 20-plus acre sites is a population <br />3 based industrial land need for target industrial uses that have <br />4 certain parcel size requirements. Its purpose is to replace the land <br />5 lost to local businesses use of those site types and to provide <br />6 similar types of sites to meet future local needs. However, REA is <br />7 looking at additional large site employers that might otherwise <br />8 locate somewhere else on the west coast but may locate in Coburg <br />9 if the conditions are right. In that respect, the regional opportunity <br />10 does not draw from the normal population growth within the cities <br />11 of Coburg, or even Eugene or Springfield. The regional need does <br />12 not already include the normal need for similar types of uses that <br />13 are based on population or employment projections as Petitioners' <br />14 arguments contend; regional need is in addition to the local need. <br />15 Thus the number of jobs that may be created by a regional <br />16 opportunity are not already included in the initial EOA analysis - <br />17 there is no double counting." Intervenor-Respondent's Brief 40.25 <br />18 We are not sure we fully understand either petitioners' or intervenor's <br />19 arguments on this point. Petitioners have the burden of demonstrating error. <br />20 We conclude petitioners have failed to demonstrate that respondents <br />21 improperly double-counted large-lot industrial jobs. <br />22 This subassignment of error is denied. <br />23 E. Failure to Consider Rezoning Surplus Commercial Land <br />24 Already Inside the UGB <br />25 Petitioners' next subassignment of error is seven lines long, but bolstered <br />26 by additional arguments in a footnote. We reject the footnote arguments as <br />27 insufficiently developed to merit review. Petitioners' complaint appears to be <br />25 Intervenor also points out that petitioners misread REA's Scenario B 1 to <br />assume Coburg "will capture 463 large-lot jobs," whereas the REA actually <br />indicates a regional need for 463 acres. <br />Page 61 <br />