I It is not entirely clear to us that respondent's legal theory for including <br />2 Lower Area 6 was because it is needed for multi-family housing that cannot <br />3 reasonably be accommodated on exception land. But respondents do not <br />4 dispute the point, so we assume that is the case. <br />5 Petitioners make a number of arguments. First, petitioners contend that <br />6 30 of the 47 acres in Area 6 have been designated for low density housing, not <br />7 multi-family housing. So at most, a need for land that can reasonably <br />8 accommodate multi-family housing could only justify 17 of those 47 acres. <br />9 Second, petitioners contend the city has not adequately explained why the <br />10 entire need for multi-family housing cannot be accommodated inside the <br />11 existing UGB, by rezoning some land now designated for low density housing <br />12 if necessary. Third, while the city cites a need to site multi-family housing <br />13 away from "the Coburg Historic District or any developed neighborhoods," <br />14 petitioners contend there is no evidence to support that assertion. Finally, <br />15 petitioners challenge respondents' findings that the need to aggregate smaller <br />16 parcels in the North and South Area 5 and landowner opposition to multi- <br />17 family development means those exception lands cannot reasonably <br />18 accommodate multi-family housing, arguing those observations are not <br />19 sufficient to establish that multi-family housing "cannot be reasonably <br />20 accommodated" in those exception areas. <br />21 In its response brief, respondents do not point to any findings in the <br />22 decision that respond to the issues raised under this subassignment of error. <br />Page 41 <br />