In conclusion, even assuming that (1) the city`s 20-year land need estimate of 4,956 acres <br />[R. at 39, 43, 152, 1054, 1058, 1167] is correct, and (2) the city does not need to adopt <br />any additional efficiency measures to accommodate housing need within the existing <br />UGB, its appears that the city could meet all of its 20-year land needs within adjacent <br />exception tands.64 <br />Aggregatim t?f L(wds foi~ AJtelwatives Analpsis. A second general problem with the <br />locational analysis is that large areas grouped for evaluation do not have similar <br />circumstances as required by OAR 660-024-0060(6). The analysis: <br />• Aggregates all parcels in the study area and then applied the same "threshold <br />suitability criteria" for all Lit-ban land needs; <br />• Did not separate resource parcels by soil capability before applying site need <br />criteria: <br />• Did not map or describe the resource parcels in the study area by soil capability. <br />• Classified resource lands by current use, which is not a valid "common <br />circumstance" under Goal 14, ORS 197.298, and OAR 660-024-0060; <br />• Segregated exception parcels with potential scenic or natural resources from other <br />exception parcels, without any Goal 5 inventory and regulatory protection <br />program as a basis for doing so; <br />• Groupcd together exception and resource parcels into UGB alternative scenarios <br />based, in part, on cost to extend sewer lines, instead of following the methodology <br />for selecting parcels to include in Goal 14, ORS 197.298 and OAR 660-024-0060, <br />• Segregated exception parcels into two different groups-parcels zoned Urban <br />Area Reserve and all other exception parcels when all exception parcels are the <br />same priority and must be treated alike under ORS 197.298(I)(b). <br />As a restilt, the analysis does not comply with the OAR 660-024-0050(5) requirement to <br />apply appropriate plan designations and zoning to the expansion area. This rule states: <br />When land is added to the UGB, the local government must assign appropriate <br />urban plan designations to the added land, consistent with the need determination. <br />Tile local government must also apply appropriate zoning to the added land <br />consistent with the plan designation, or may maintain the land as urbanizable land <br />either by rcfciinhi q the zonii g that was assigned prior to inclusion in the boundary <br />of by applying other interim zoning that mcl1F7 airs the 1cmXs j)otentlai fol' <br />pica neci u7'bon cieveloj)mew mail the il/1ul is rezone'ci for the pionned urbc F4 uses. <br />The requirements of ORS 197.296 regarding planning and zoning also apply <br />when local governments specified in that statute add land to the UGB. [emphasis <br />added] <br />6s 'I he findings provide that only 5,733 acres of the adjacent exception lands ill the study area are <br />"suitable." and only 5,434 acres are both "suitable and available." [lt. at 159, 175-176, 1174, 1190-91] <br />Bend UGB Order 001775 123 of 156 January 8, 2010 <br />