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Statement of Reasons for Appeal Appellants preserve the following issues for appeal and incorporate all issues and arguments raised before the Hearings Official as if set forth here in full, including both written and oral testimony. The Hearings Official misconstrued applicable law and made findings not based on substantial evidence with regard to EC 9.88.15(1). 9.8815(1) requires that "[t]o the greatest possible degree, the development will provide the maximum possible landscaped area, open space, or vegetation between the activity and the river." Here, the proposal provides a 100-foot setback from the river, but only a 70-foot setback from the property line. The problem is that the applicant has not provided any evidence to demonstrate that the proposed setback is the greatest possible. Indeed, the Hearings Official concedes that "[t]he applicant's response under this criterion does not provide much information...." The Hearings Official then engages in a "theoretical" reduction to absurdity by arguing that the applicant could have no development at all under the standard. Such a justification has little meaningful effect under the applicable provision. The standard requires a "balancing of factors," and, here, there is simply no balancing. The applicant is developing the property to the greatest degree possible, not providing the maximum possible landscaped area, open space, or vegetation between the activity and the river. In short, there is nothing in the record to demonstrate that the applicant has balanced any factors in complying with this standard - only that the applicant has developed the property to the maximum degree possible. There is simply nothing to demonstrate that the applicant has placed the development "as far away as possible," and the Hearings Official's failure to balance any factors misconstrues applicable law. Appellants incorporate by reference all arguments related to EC 9.8815(1) raised before the Hearings Official as if set forth here. The Hearings Official misconstrued applicable law and made findings not based on substantial evidence with regard to EC 9.8815(2). EC 9.8815(2) provides that "[t]o the greatest possible degree, necessary and adequate public access will be provided along the Willamette River by appropriate legal means." Here, the applicant provides no means to access the river for the public or the residents of the development. The proposed development includes a fence that would actually restrict access to the greenway. The notion that the existing bike path provides the necessary access is mistaken because the bike path is not part of the application or development. The standard requires that the proposed development provide access - to the greatest possible degree - to the River. Here, no access is provided to any degree. The fact that there is access along the river by means other than the subject property is 1