In its order, LUBA agreed with some of Land Watch's contentions. LUBA <br />2 observed that the county's brief "neither acknowledg[ed] nor directly respond[ed] to" <br />3 Land Watch's arguments on a number of issues. LUBA concluded, among other things, <br />4 that there was no substantial evidence for the exclusion of Areas 5 and 7 because the city <br />5 and county had not properly applied the three-step process outlined in McMinnville, 244 <br />6 Or App at 239. LUBA ruled that the city and county had not satisfied the requirements <br />7 under ORS 197.298 and under the Goal 14 factors. That is, the city and county did not <br />8 properly justify their decision to exclude areas of inferior agricultural quality while <br />9 including better agricultural lands within an expanded UGB. <br />10 With regard to Land Watch's argument that the city had "double-counted" <br />11 its employment-based forecast in the REA, LUBA concluded that the "OAR 660-024- <br />12 0040(9)(a) safe harbor does not preclude taking into account additional demand for <br />13 employment land that may be generated by regional forces that may have little or nothing <br />14 to do with the city's population growth. * * * [T]he Goal 9 rule, OAR 660-009-0015 (1) <br />15 and (2) expressly permit such considerations." LUBA also concluded that Land Watch <br />16 had had "the burden of demonstrating error," and that Land Watch had "failed to <br />not make a clear challenge involving the calculation of "Scenario A." Land Watch states, <br />for example, that the city "should have stopped * * * with its 'Scenario A' safe harbor <br />jobs forecast and corresponding land need." <br />° That argument was based upon employment forecasts as presented in tables within <br />the REA. Land Watch argued that the "324 jobs in Scenario A are an already-counted <br />subset of Coburg's large-lot job capture--and they cannot be counted a second time as <br />part of Scenario B." (Emphasis in original; boldface omitted.) <br />10 <br />