I that the tree sample survey used by the city was inadequate under CDC 9.1011. Petitioners raised <br />2 specific issues under CDC 9.1011; however, we are not cited to any place in the record where <br />3 issues were raised under CDC 6.0323(B)(2)(a). <br />4 Petitioners argue that because the staff report addressed CDC 6.0323(B)(2)(a), that is <br />5 sufficient to avoid waiver under ORS 197.763(3) and 197.835(3). We disagree. The staff report <br />6 did not raise any cognizable "issue" under CDC 6.0323(B)(2)(a), and certainly not the issue that <br />7 petitioners raise under this assignment of error. To avoid waiver, the issue must be "raised and <br />8 accompanied by statements or evidence sufficient to afford the governing body, planning <br />9 commission, hearings body or hearings officer, and the parties an adequate opportunity to respond" <br />10 to the issue. ORS 197.763(1). A finding in a staff report that a criterion is satisfied is insufficient to <br />11 "raise" an "issue" with respect to that criterion, for purposes of ORS 197.763(1) and 197.835(3). <br />12 No party to the proceedings below would understand from the staff report that an issue has been <br />13 raised regarding compliance with CDC 6.0323(13)(2)(a). <br />14 We also understand petitioners to argue that raising an issue under CDC 9.1011 is sufficient <br />15 to raise the same issue under CDC 6.0323(B)(2)(a). Again, we disagree. While CDC 9.1011 and <br />16 CDC 6.0323(B)(2)(a) impose nearly identical requirements, raising an issue under one code <br />17 provision does nothing to apprise the decision maker and other parties that petitioners wish to raise <br />18 the same issue under a separate, unidentified code provision.6 <br />19 The fourth assignment of error is denied. <br />20 The city's decision is remanded. <br />"Issues shall be limited to those raised by any participant before the local hearings body as <br />provided by ORS 197.195 or 197.763, whichever is applicable." <br />6 As a practical matter, however, the survey that the city must require on remand under CDC 9.1011 will <br />almost certainly include the information required by CDC 6.0323(B)(2)(a). <br />Page 14 <br />