The city and county (lid, generally, attempt to avoid land planned as agricultural land. <br />However, the present findings and record do not justify (at this point) any significant <br />inclusion of agricUltural lands in the UGB expansion area. The city has begun to make an <br />adequate showing that expansion onto some agricultural lands to the east may be <br />necessary to provide public services to higher priority lands (ORS 197.298(3)(c) [R. at <br />1183-1 186], but given the Uncertainty concerning the amount of land needed, the director <br />cannot determine that the city has made the showing required by the statute at this time. <br />There also are several, technical, problems with the submittal. The record does not <br />include a map or description of all resource parcels in the study area, as required by OAR <br />660-024-0060(6). The boundary location analysis map shows only those parcels <br />determined to be "suitable" because they met all of the city's threshold suitability criteria. <br />[R. at 165, 1180, Figure V-4] The department has prepared a map showing the zoning of <br />lands in the study area as Figure 2, Using GIS data from Deschutes County. <br />The record does not include a map or description of all exception parcels in the study <br />area, which is required by OAR 660-024-0060(6). But see Figure 3 on the following <br />page, prepared by the department based on the county's official zoning traps. The <br />boundary location analysis map in the record shows o«ly those exception parcels that are <br />determined "suitable" because they met all of the "threshold suitability criteria." [R. at <br />164, 1179 - Figure V-3] The city removed all other exception parcels from the study area <br />prior to the boundary location analysis, using the "threshold suitability criteria" that <br />appears to be developed after the completed need analysis. Other exception lands are not <br />part of the need analysis in the record. [R. at 47-48,153-160, 1062-63, 1168-75] <br />Suitabilitj% As described above, in order to eliminate lands from consideration for <br />inclusion in a UGB expansion, they either must be found to be generally unsuitable based <br />on the criteria in OAR 660, division 8 ("buildable" lands for housing) or division 9 <br />("suitable and available lands" for employment), or (if the lands are being added for a <br />specific identified land need) the suitability criteria must be based on the applicable needs <br />analysis (HNA or FOA). In addition, lands in a study area may be unsuitable for one <br />need, and suitable for another (for example, suitable for single family liousing, but <br />unsuitable for a medical center). The Underlying housing and employment needs analyses <br />establish a generalized housing need mainly for single family housing, as well as <br />general commercial uses. and do not identify why these general uses can't be met (at least <br />in part) on adjacent exception lands identified as unsuitable. As shown in Figure 2, there <br />is a substantial amount of exception land to adjacent to the southern boundary of the city. <br />The city's analysis of these lands is addressed in more detail, below. <br />The city's application of site criteria to till planned urban uses before the study area <br />parcels were divided into the ORS 197.298(1) priorities was overbroad. This step <br />prematurely rejected many parcels that are suitable for one or more of the city's future <br />land needs before those parcels could be analyzed Under' OAR 660-24-0060 and ORS <br />197.298. The city improperly "refined and reduced the size of the study area for the 20- <br />year UGB expansion (2028) in an iterative fashion." [R. at 152, 1167] <br />Bend UGB Order 001775 116 of 156 January 8, 2010 <br />