I absent a relevant consideration to the contrary should have been included <br />2 before Areas 1 and 6. <br />3 As part of McMinnville Step Two, a local government may consider Goal <br />4 14, Boundary Location Factor 3 "[c]omparative environmental, energy and <br />5 economic and social consequences" when determining if higher priority land <br />6 adequately accommodates identified land needs. Respondent relied in part on <br />7 Goal 14, Boundary Location Factor 3 to include portions of Areas 1 and 6, and <br />8 not include Area 7, based on "the environmental consequences of development <br />9 within the 100-year floodplain and impacts to mapped wetlands." Record 736- <br />10 37. <br />11 Petitioners argue: <br />12 * * There is no factual basis for this assertion. The findings <br />13 concede that, out of Area 7's 240 acres, only 23 acres are either <br />14 floodplain or wetland, and inspection of the City's mapping <br />15 reveals that area lies at the far north end, well away from the area <br />16 closest to the city center and most likely to be urbanized. <br />17 Furthermore, the findings do not explain why the consequences of <br />18 urbanizing Area 7 would be so severe that these areas would be <br />19 `inadequate' under ORS 197.298(1)." Petition for Review 19 <br />20 (record citations omitted). <br />21 We have not been able to locate a cognizable response to petitioners' <br />22 arguments concerning respondent's reliance on Goal 14, Boundary Location <br />23 Factor 3 environmental consequences to include portions of Areas 1 and 6 <br />24 while not including Area 7. This subassignment of error is sustained. <br />Page 29 <br />