1000 Friends of Oregon v. Land Conservation and Development Commission

Petitioners seek judicial review of an order of the Land Conservation and Development Commission (LCDC) approving the City of Woodburns amendment of its urban growth boundary (UGB) to include an additional 409 acres for industrial uses. Petitioners myriad contentions on review pertain to two basic issues. First, did the city include more industrial land in its UGB than was necessary to accommodate its needs over the 20-year planning period in violation of Statewide Land Use Planning Goals 9 and 14? Second, assuming that there was a need for the additional industrial land, should the city have selected different properties for inclusion in the UGB pursuant to ORS 197.298 and the locational factors in Goal 14? For reasons that we will explain, we conclude that the LCDCs order is inadequate for judicial review with respect to its treatment of the first of those two issues, and, accordingly, reverse and remand the order for reconsideration, which, in turn, obviates the need to address the second issue.