I error, petitioners challenge the adequacy of the factual base for including Area <br />2 8 under Goals 9 and 14.20 <br />3 As the Court of Appeals noted in Zimmerman v. LCDC, 274 Or App 512, <br />4 514, 361 P3d 619 (2015): <br />5 * * Goal 14 (Urbanization) requires a city to adopt and <br />6 maintain an urban growth boundary around its city limits "to <br />7 provide land for urban development needs and to identify and <br />8 separate urban and urbanizable land from rural land." OAR 660- <br />9 015-0000(14). Establishment and change of a UGB must be based <br />10 on a number of factors, including a "[d]emonstrated need for * * * <br />11 employment opportunities." Id. Under OAR 660-024-0040(5), in <br />12 turn, the determination of that need "must comply with the <br />13 applicable requirements of Goal 9 and OAR chapter 660, division <br />14 9, and must include a determination of the need for a short-term <br />15 supply of land for employment uses consistent with [OAR] 660- <br />16 009-0025." <br />17 Accordingly, a city estimates future employment to determine the need for <br />18 employment lands in order to comply with the applicable Goal 14 and 9 <br />19 requirements. <br />20 Here, respondents adopted a number of documents in support of their <br />21 decisions, including the economic lands component of the 2010 Coburg <br />22 Urbanization Study (2010 Study) (Record 308-634), the 2014 Regional <br />23 Economic Analysis (REA) (Record 635-666), and the 2014 Coburg <br />24 Urbanization Study Update (2014 Update) (Record 289-307). Respondents <br />25 explain that the 2010 Study documented the nature of industrial lands needed, <br />20 The ORS 197.298(1) priority scheme is not an issue under this assignment <br />of error. <br />Page 48 <br />