2 <br />1 D. Timeliness of the Appeal <br />z ORS 197.850(3) requires the filing of a petition for review of a LUBA order <br />3 within 21 days of the date that LUBA mails or delivers LUBA's order. In this <br />4 case, LUBA mailed its order on March 6, 2019, LUBA Rec-6; ER-1, and <br />5 Petitioners filed the Petition for Review with this court on March 27, 2019, LUBA <br />6 Rec-3. Petitioners' appeal is therefore timely. <br />7 E. Question Presented <br />s 1. Did the Eugene Planning Commission's interpretation <br />9 (affirmed by LUBA) give effect to the express text and context <br />10 of EC 9.2751(1)(b) and 9.275 1 (1)(c)(1) to correctly interpret <br />11 the "net density" calculation when the interpretation renders <br />12 specific terms and phrases in the code superfluous? <br />13 F. Summary of Arguments <br />14 1. First Assignment of Error <br />15 The LUBA and the City misconstrued the Eugene Code, because the City <br />16 failed to exclude areas from the "net density" calculation, pursuant to EC <br />17 9.2751(1)(b) and 9.2751(1)(c)(1). Based on the plain text and context of EC <br />18 9.2751(1)(b), the leasing office and maintenance shed are not in actual residential <br />19 use or reserved for the exclusive use of the residents. The plain meaning and <br />20 context of the terms "actual" and "exclusive" allow only a reading that excludes <br />