1 * * Adding a large residential area west of [the Van <br />2 Duyn/Coburg Road North] intersection without mitigation would <br />3 cause a significant and early failure of the intersection." <br />4 Respondents' Brief 42-43 (footnote omitted). <br />5 The above is not responsive to petitioners' argument. If there is a <br />6 response to that argument in the decision, respondents have not pointed it out <br />7 to us. Respondent cannot propose the east-west bypass, acknowledge that <br />8 North Area 5 traffic impacts would be addressed by the bypass, and then rely <br />9 on the lack of an existing east-west bypass to reject North Area 5 as <br />10 "inadequate to accommodate" residential land needs under ORS 197.298(1). <br />11 This subassignment of error is sustained. <br />12 L Cost of Water and Sewer (North Area 5) <br />13 Respondents determined that exclusion of Area 5 was warranted because <br />14 "[t]he exception area properties are unlikely to be available for residential <br />15 development within the time needed because the initial high cost of extending <br />16 infrastructure would disproportionally impact early development, thus <br />17 discouraging or delaying any development." Record 749. <br />18 Respondent relied on the high cost of the extension of water and sewer <br />19 service as a basis to exclude North Area 5. In doing so, it is not entirely clear <br />20 whether respondent was invoking Goal 14 Boundary Location Factor 2 <br />21 "[o]rderly and economic provision of public facilities and services" to find <br />22 Area 5 is "inadequate to accommodate" residential land needs under ORS <br />23 197.298(1), or was relying on Goal 14 Boundary Location Factor 3 <br />24 (Comparative environmental, energy, economic and social consequences[.]" <br />Page 36 <br />