I decision should have applied the definition of "adjacent land" at OAR 660- <br />2 024-0060(4), which provides: <br />3 "In determining alternative land for evaluation under ORS <br />4 197.298, `land adjacent to the UGB' is not limited to those lots or <br />5 parcels that abut the UGB, but also includes land within the <br />6 vicinity of the UGB that has a reasonable potential to satisfy the <br />7 identified need deficiency." <br />8 Respondents do not respond to the argument. The response brief merely <br />9 touches on adjacency as one of the reasons "one portion of study area 5" was <br />10 excluded, in part due to being "separated by approximately one half mile from <br />11 Coburg and only marginally connected to the rest of study area 5 across a <br />12 heavily traveled road." Respondents' Brief 38. Although respondents do not <br />13 cite to it, we understand the primary finding on adjacency to be at Record 747, <br />14 which appears to conclude that North Area 5 and South Area 5 are not adjacent <br />15 to the UGB, but does not address OAR 660-024-0060(4). <br />16 OAR Chapter 660, Division 24, is LCDC's administrative rule <br />17 concerning urban growth boundaries and is, at the very least, relevant context <br />18 regarding the meaning of the word "adjacent" in ORS 197.298(1). More to the <br />19 point, in contrast to respondents' argument that area 5 is not "adjacent" to the <br />20 existing UGB, the findings seem to indicate that all eleven study areas were <br />21 considered "adjacent" for purposes of the UGB amendment: "Map 11 of the <br />22 2010 Urbanization Study shows `built upon and developed' exception areas * * <br />23 * and natural resource areas * * * located adjacent to the Coburg Urban <br />24 Growth Boundary." Record 728 (emphasis added). See Record 1441 (showing <br />Page 25 <br />