I within the south hills suitable as recreational parks[.]" Record 13. The <br />2 planning commission also adopted the hearings official's alternative findings <br />3 that the PUD is consistent with at least one of the purposes of the Ridgeline <br />4 Park section. <br />5 On appeal, the Neighbors first challenge the hearings official's primary <br />6 finding that the subject property is not in an area "recommended for <br />7 preservation."10 According to the Neighbors, the above-quoted SHS language <br />8 itself constitutes an express designation that "all vacant property above an <br />9 elevation of 901 [feet] be preserved from an intensive level of development," <br />10 and therefore the portions of the subject property above 901 feet in elevation are <br />11 "recommended for preservation." The Neighbors cite a LUBA opinion, <br />12 Highland Condominium Assoc. v. City of Eugene, 37 Or LUBA 13, 34 (1999), <br />13 and legislative history of the SHS, to support their argument that the SHS is <br />14 intended to preserve land above 901 feet in elevation, with the two exceptions <br />15 listed, for a variety of purposes, e.g., visual impacts, not limited to recreational <br />16 or park use. The Neighbors note that the hearings official does not identify <br />10 The Neighbors focus their arguments mostly on EC 9.9630(1), which <br />codifies the above-quoted language from the SHS Ridgeline Park section in a <br />code provision that applies refinement plan policies specifically to <br />"subdivisions, partitions, and site review." EC 9.9500. The city argues that <br />nothing in the EC codifies or applies the SHS Ridgeline Park section language <br />with respect to a tentative PUD application. However, the city agrees with the <br />Neighbors that the SHS policies apply directly to a tentative PUD application, <br />pursuant to EC 9.8320(2). <br />Page 27 <br />