I We do not foreclose that possibility that circumstances in irrevocably <br />2 committed lands could pose such challenges to development of multi-family <br />3 housing that the city could find and justify a decision that multi-family housing <br />4 cannot "be reasonably accommodated" on such exception lands. But <br />5 generalized concerns about parcelization complicating site acquisition or <br />6 property owner opposition to multi-family housing fall far short of making the <br />7 demonstration required under ORS 197.298(3)(a) that "specific types of <br />8 identified land needs cannot be reasonably accommodated on higher priority <br />9 lands." <br />10 This subassignment of error is sustained. <br />11 D. Error to Include Area 6 Farmland to Site East-West Bypass <br />12 Area 6 is exclusive farm use zoned land composed of Class I and II soils. <br />13 There is no dispute that Van Duyn Street, which provides access to downtown <br />14 Coburg, is experiencing congestion at two intersections west of the city. See <br />15 Appendix 3. Petitioners argue respondent improperly relied on ORS <br />16 197.298(3)(c) to include the lower part of Area 6 to allow construction of the <br />17 east-west bypass to resolve access problems associated with this traffic <br />18 congestion.19 Under ORS 197.298(3)(c), lower priority land may be included <br />19 within the UGB ahead of higher priority land if "[m]aximum efficiency of land <br />19 Respondents at one point proposed to include a larger part of Area 6, but <br />when faced with opposition settled on the smaller portion of Area 6, primarily <br />to allow construction of the east-west bypass. <br />Page 42 <br />