1 2. Petitioners' Findings Challenges <br />2 Respondents' brief includes 35 pages in which respondents attempt to <br />3 explain why they believe the challenged decision properly applied the three- <br />4 step analysis required under the Court of Appeals' McMinnville decision. But <br />5 respondents' brief makes almost no attempt to acknowledge and directly <br />6 address petitioners' challenges to a number of respondent's findings. Because <br />7 our task on review is to determine the merits of petitioners' challenges to those <br />8 findings, that failure on respondents' part complicates our resolution of this <br />9 part of petitioners' second assignment of error. While the subassignments of <br />10 error that we discuss separately below are technically sub-subassignments of <br />11 error under petitioners' second subassignment of error, we refer to them as <br />12 subassignments of error to avoid the awkward phrase sub-subassignment of <br />13 error. <br />14 a. Adjacent to the UGB (North Area 5; South Area 5) <br />15 Area 5 contains 97 acres of exception lands. As we have already <br />16 explained, the highest priority areas in candidate areas identified by the city are <br />17 exception lands. Under ORS 197.298 those exception lands must be "adjacent <br />18 to an urban growth boundary[.]" One of the reasons respondents gave for not <br />19 including North Area 5 and South Area 5 in the UGB is that North Area 5 and <br />20 South Area 5 are not "adjacent" to the urban growth boundary. Respondents <br />21 relied on a dictionary definition of "adjacent," but petitioners argue that the <br />Page 24 <br />