I DEVORE, J. <br />2 This case involves review of a decision of the Land Use Board of Appeals <br />3 (LUBA). In 2015, following urbanization studies and public hearings, the City of Coburg <br />4 and Lane County coadopted two ordinances to amend the city's urban growth boundary <br />5 (UGB) and to revise the city's transportation system plan. Respondents, Land Watch and <br />6 Kersten, appealed to LUBA, contending that the amended UGB was not supported by an <br />7 adequate factual basis and that the county did not comply with Oregon statutes, statewide <br />8 planning goals, and administrative rules.' LUBA remanded both ordinances because the <br />9 local findings were insufficient to satisfy ORS 197.298 and factors pertaining to Goals 9 <br />10 and 14. The city and county seek review of LUBA's order. Land Watch cross-petitions, <br />11 contending that the city used two mutually exclusive ways of calculating its employment- <br />12 based land need and that the city had "double-counted" future employment growth. We <br />13 affirm on the petition and cross-petition. <br />14 <br />I. BACKGROUND <br />15 A. Local Government Proceedings <br />16 In 2010, the City of Coburg conducted an urbanization study, as part of a <br />17 periodic review, to evaluate its land needs in light of future employment and residential <br />18 growth over a period of 20 years. See ORS 197.628 - 197.644 (periodic review <br />' Land Watch and Kersten are jointly represented by counsel and did not file <br />separate briefing. For ease of reference, throughout the opinion we refer to the parties <br />collectively as "Land Watch." <br />1 <br />