I of that "safe harbor" rule was unlawful in substance. Second, we consider LUBA's ruling <br />2 that there was substantial evidence supporting the city's employment forecast--that is, the <br />3 issue of so-called "double-counting" of large-lot industrial jobs. <br />4 1. OAR 660-024-0040(9) (a) <br />5 LUBA ruled that the OAR 660-024-0040(9)(a) "safe harbor" does not <br />6 preclude a city from considering additional demand for employment land, when <br />7 completing an "employment forecast." As we will explain, we conclude that the ruling <br />8 was not unlawful in substance. <br />9 Goal 9 provides that urban planning in comprehensive plans must <br />10 "[i]nclude an analysis of the community's economic patterns, potentialities, strengths, and <br />11 deficiencies as they relate to state and national trends." OAR 660-015-0000(9); see also <br />12 ORS 197.712(2) (codification of Goal 9 requirements for urban comprehensive plans). <br />13 Several other administrative rules direct and focus the analysis under that Goal 9 <br />14 requirement. At issue here is the city's application of the "safe harbor" provision, OAR <br />15 660-024-0040(9), which provides, in part: <br />16 "The following safe harbors may be applied by a local government <br />17 to determine its employment needs for purposes of a UGB amendment <br />18 under this rule, Goal 9, OAR chapter 660, division 9, Goal 14 and, if <br />19 applicable, ORS 197.296. <br />20 "(a) A local government may estimate that the current number of <br />21 jobs in the urban area will grow during the 20-year planning period at a <br />22 rate equal to either: <br />23 "(A) The county or regional job growth rate provided in the most <br />24 recent forecast published by the Oregon Employment Department; or <br />13 <br />