I among other things, noise and smell from industrial operations. Petitioner also <br />2 cites to the Coburg zoning code setback provision for industrial sites abutting <br />3 residential districts, arguing that the new residential zone will result in <br />4 "existing, protected Goal 9 resources [having] to change to accommodate the <br />5 new residential development" due to the future imposition of a 25-foot setback <br />6 from residential parcels. Petition for Review 12. <br />7 Respondents consider petitioners' argument to be that new residential <br />8 development would require the NIA to modify its operations and accommodate <br />9 residential development, resulting in a failure of a Goal 9 resource. <br />10 Respondents argue that the portion of the NIA that is adjacent to the UGB <br />11 residential expansion is already built out and "no growth is possible within the <br />12 area of alleged concern." That appears to be the case. See Appendix 2. <br />13 In any event, based on our disposition of the first assignment of error, we <br />14 disagree with petitioners that paragraph 4 of Goal 9 applies to protect the <br />15 Coburg NIA in the manner petitioner argues. <br />16 This subassignment of error is denied. <br />17 B. The UGB Amendment Is Inconsistent With The ORS 197.298 <br />18 Priority Scheme <br />19 As we explain in more detail below, ORS 197.298 establishes priorities <br />20 for the types of lands that may be included in the UGB. Under the priority <br />21 scheme, exception lands must generally be included in the UGB before <br />22 agricultural lands. Exception lands are lands outside the existing UGB, for <br />23 which a committed exception to Goal 3 has been approved, to permit those <br />Page 15 <br />