I That is, Land Watch contends that the projected land need was inflated, because both <br />2 "Scenario A safe harbor and the add-on 'regional' Scenario B 1 land need determinations <br />3 identified 20+ acre parcel sizes as a necessary special site characteristic for industrial <br />4 land." <br />In its response brief to LUBA, the city and county contended that Land <br />6 Watch had misunderstood "the basis behind" the REA. They proposed a different <br />7 understanding of the calculations: <br />8 "[T]he REA * * * recognizes that an EOA based simply on anticipated <br />9 economic growth derived strictly from expected population growth does <br />10 not capture all the types of economic growth that can and will normally <br />11 occur in a region. A regional analysis is based on the fact that there are <br />12 types of industries that will seek to locate substantial facilities in a region <br />13 and that have a tremendous flexibility as to where they can locate. Once <br />14 the decision is made to locate in a region, the employers are opportunistic <br />15 shoppers, seeking immediately available properties and will turn their <br />16 attentions elsewhere if, for example, assembly of smaller parcels or major <br />17 land use procedures need to occur before development can happen. See, <br />18 R.753 (discussing approach of large-site industrial regional employers)." <br />19 The city and county asserted that the REA did not double-count projected employment <br />20 growth, because the REA considered "additional large site employers that might <br />21 otherwise locate somewhere else on the west coast but may locate in Coburg if the <br />22 conditions are right." (Underscoring in original.) Therefore, they maintained, the REA <br />23 did not reuse the same subset of employment-based need, but rather included additional <br />24 regional need that had not already been included in the EOA calculation. <br />25 LUBA reviewed for substantial evidence and concluded that Land Watch <br />26 failed to demonstrate that there had been a "double-counting of large-lot industrial jobs." <br />17 <br />