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Full Opinion
*700**434Intervenor-respondent Riverbend Landfill Co. seeks to expand its solid waste landfill in Yamhill County on land zoned for exclusive farm use (EFU). To obtain site design review and a floodplain development permit for the expansion, Riverbend had to meet what is sometimes known as the farm impacts test, set out in ORS 215.296. Subsection (1) of that statute precludes approval of a proposed nonfarm use when the use would "[f]orce a significant change" in accepted farm practices or "[s]ignificantly increase the cost" of those practices on surrounding agricultural lands. Subsection (2) provides that a permit applicant may meet the farm impacts test through the local government's imposition of conditions of approval.
Respondent Yamhill County has determined for a second time that, with conditions of approval, the landfill expansion will not create a significant change in accepted farm practices or significantly increase the cost of those practices on surrounding agricultural lands, thereby meeting the farm impacts test. But petitioners Stop the Dump Coalition, Willamette Valley Wineries Association, and Ramsey McPhillips and petitioner-intervenor Friends of Yamhill County (collectively, petitioners) contend that Riverbend's applications fail the farm impacts test, as it is correctly understood. In broad terms, the parties dispute what the farm impacts test measures and whether some of the conditions that the county imposed for approval are proper under ORS 215.296(2).
On review, petitioners take issue with both the latest order of the Land Use Board of Appeals (LUBA) in Stop the Dump Coalition v. Yamhill County , 74 Or. LUBA 1 (2016) (SDC II ), and the decision of the Court of Appeals upholding that order in Stop the Dump Coalition v. Yamhill County ,
**435This case requires us, for the first time, to interpret and apply the farm impacts test in ORS 215.296. Ultimately, we affirm in part and reverse in part the decision of the Court of Appeals and affirm in part, reverse in part, and remand the final opinion and order of the Land Use Board of Appeals.
I. FACTS AND PROCEDURAL HISTORY
A. The County's Reapproval of the Landfill Expansion
Riverbend owns and operates the Riverbend landfill sited on EFU-zoned land in Yamhill County. Stop the Dump Coalition v. Yamhill County , 72 Or. LUBA 341, 346 (2015) (SDC I ). The surrounding area contains EFU-zoned lands in various agricultural uses. Id . at 347. Because parts of its existing site are filling up, Riverbend sought to expand the landfill, including onto adjacent EFU-zoned land that it owns. Id . The expansion "would occupy land that qualifies as high-value farmland" and would "add 15 years of capacity to the landfill operation, which would otherwise reach full capacity in 2017."
A solid waste disposal facility is allowed as one of the 27 nonfarm uses that may be permitted on any EFU-zoned land, if approved by the local governing authority. See ORS 215.283(2)(k). Accordingly, Riverbend submitted applications to the county for a site design review under Yamhill County Zoning Ordinance 1101 and a floodplain development permit under Zoning Ordinance 901. In approving Riverbend's permit applications in 2015, the county imposed numerous conditions of approval on Riverbend and determined that, with Riverbend's adherence to those conditions, the farm impacts test was satisfied.
The county's 2015 approval led participants in the proceedings to file an appeal to LUBA. In that first appeal, LUBA agreed with the challengers that the county had incorrectly determined that the landfill expansion complied with the farm impacts test in *701ORS 215.296(1). LUBA concluded that the county's approach to determining compliance was flawed, both as to some individual impacts on surrounding farms and as to whether the cumulative effect of individual impacts met the farm impacts test. LUBA noted **436that the county had not articulated its understanding of "significant," and LUBA suggested that, based on the word's ordinary meaning, "significant" should be understood as a sizeable or important influence or effect. See SDC I , 72 Or. LUBA at 359 n. 12 (identifying a dictionary definition for the word "significant" as "having or likely to have influence or effect" and one for the antonym "insignificant" as "of little size or importance").
LUBA directed the county, on remand, to reconsider evidence with respect to a variety of specific impacts, including (1) impacts of litter on the McPhillips farm, (2) impacts of nuisance birds on nearby farms, (3) impacts on pheasant-raising operations on the McPhillips farm, and (4) odor and visual impacts of the landfill expansion, including on farm stands and direct farm sales on nearby farms. Id. at 361-62, 367-76. In addition, LUBA directed the county to determine "whether Riverbend has demonstrated that the cumulative impacts of the proposed use will not force a significant change in, or significantly increase the cost of, accepted farm practices on surrounding lands." Id. at 377.
On remand, the county reopened the record and accepted additional evidence and arguments. SDC II , 74 Or. LUBA at 6. Petitioners and their members have interests in nearby agricultural land and opposed the county's reapproval of Riverbend's applications. Ramsey McPhillips, the individual petitioner, has a farm adjacent to and downwind of the landfill. Id. McPhillips has a hay operation and raises pheasants and other poultry on his farm. Id. at 6-7, 28.
In 2016, the county commissioners again approved Riverbend's applications for site design review and a floodplain development permit. Id. at 6. In support, the county issued new findings (including Findings 26-34, regarding litter on the McPhillips farm; 51-78, regarding nuisance birds; and 94-96 and 99-110, regarding landfill noise, odor, and visual impact) and modified findings in its 2015 order (including Findings 136-41 pertaining to cumulative impacts).
As before, the county's reapproval depended in part on imposing conditions of approval on Riverbend under ORS 215.296(2). Two of those conditions related to the impact **437of litter on the McPhillips farm, requiring Riverbend to install an additional litter fence and to provide or pay for litter patrols, consisting of Riverbend employees, McPhillips employees, or third parties (at McPhillips's election) walking the farm and picking up plastic bags and other trash during periods immediately before harvesting the hay field. SDC II , 74 Or. LUBA at 9, 11-15. In addition, two conditions related to nuisance birds generally: Riverbend would have to increase falconry activities during winter months and to contract with the United States Department of Agriculture "to provide adaptive management bird control measures applicable to landfills." Id. at 20. The county imposed two additional conditions to address the impact of nuisance birds on the Frease farm (which has a large hazelnut orchard, a small cherry orchard, and a small berry operation), requiring "Riverbend [to] purchase the entire crop of cherries and berries" from the farm, "at a market price that is adjusted each year." Id. at 23. Riverbend was also required to address the effects of the falconry program on the pheasant and poultry operation on the McPhillips farm by paying for the cost of netting to protect those birds from falcons. Id. at 28-29. The county determined that the conditions of approval would ameliorate significant individual impacts of the expansion of the landfill.
The county also determined that the cumulative impacts of the expansion were not significant, because the farms that would experience multiple impacts represented "only 10 percent of the acreage in the [farm] study area" and "only a 'relatively small portion of the landscape.' " 74 Or. LUBA at 36 (quotation omitted). Relying on that broad-gauge view of cumulative impacts and without evaluating multiple impacts farm by farm, the county found that the proposed expansion will not force a significant change in accepted farm practices or significantly increase the *702cost of those practices on surrounding farm lands, after Riverbend satisfies conditions of approval. Id. at 36-37.
B. Petitioners' Appeal of the County's Reapproval to LUBA
In their appeal to LUBA of the county's reapproval of the expansion, all petitioners except Friends of Yamhill County (FYC) assigned error to the county's findings **438concerning the effects of litter on haying and of nuisance birds on grass seed farming, two individual impacts on farm practices. Id. at 6. FYC argued that the county had incorrectly determined the facts concerning other individual impacts on surrounding lands. Focusing on fruit and nut farms, pheasant and poultry operations, and livestock, FYC also raised the impacts of nuisance birds. Additionally, FYC argued that the sight of the landfill expansion would depress prices at vineyards and wineries and that the odor from the expansion would adversely affect direct farm sales and farm stands. FYC also challenged some of the conditions that the county had imposed on Riverbend.
LUBA rejected petitioners' challenge, determining that the county reasonably had concluded that, with the conditions imposed on Riverbend, litter and nuisance birds due to the landfill expansion would not cause significant changes in accepted farm practices for haying and grass seed farming and in the costs of those practices. Id . at 15, 23, 25. LUBA also rejected FYC's arguments concerning individual impacts on various grounds. Id . at 25-35. Ultimately, applying its understanding of "significant" as articulated in SDC I , LUBA affirmed the county's conclusion that, after Riverbend implemented the required conditions imposed by the county, each individual impact of the landfill expansion on surrounding properties-that is, each individual impact to an accepted farm practice or its cost at each farm or agricultural operation-would not be significant.
But LUBA agreed with FYC that the county had employed an improper legal test to analyze the cumulative impacts of the landfill's expansion on the farms that experienced multiple, but less than significant, individual impacts. Id. at 35-37. LUBA observed that the county's approach to finding that those multiple impacts would not be cumulatively significant was to consider whether the farms that would experience multiple impacts were a small proportion of the surrounding lands. Id. at 36. Based on the ordinary meaning of the statutory terms "significant" and "insignificant" in ORS 215.296(1) and on Von Lubken v. Hood River County ,
Thus, LUBA understood the farm impacts test to require a farm-by-farm analysis. Specifically, LUBA concluded that, to determine the significance of changes in or costs of farm practices, the county must consider both the significance of an individual impact and the significance of cumulative impacts of the landfill expansion, as conditioned by the county, on a farm-by-farm basis. Id.
LUBA also concluded that the county's factual findings regarding its cumulative impacts analysis were "inadequate and not supported by substantial evidence." Id. at 35. Because the county had failed to consider whether, cumulatively, individual impacts of the landfill expansion on each farm would amount to a significant change in, or increased cost of, farm practices for that farm, LUBA remanded the matter to the county. LUBA instructed the county to determine whether "individual insignificant impacts, some of which may be additive and some which may not be, are cumulatively significant with respect to each farm that alleged multiple impacts to their farm practices." Id. at 37.
C. The Court of Appeals Decision
Both petitioners and respondents sought judicial review of LUBA's order. The Court *703of Appeals construed both subsections of ORS 215.296 and affirmed LUBA's order. However, in construing ORS 215.296(1), the court formulated the farm impacts test differently than LUBA had, both as to individual impacts of the proposed landfill expansion and as to cumulative impacts of the expansion.
For a significant change or cost increase, the Court of Appeals focused on whether the impact of the landfill expansion "affects the preservation of agricultural land for productive use." SDC III ,
As for conditions of approval that the county had imposed, petitioners had two basic objections. First, they contended that, in some instances, the county's conditions were not "clear and objective[,]" as required by ORS 215.296(2). Second, petitioners contended that some conditions were improper as significant changes to accepted farm practices in their own right, particularly the condition for litter patrols on the McPhillips farm, at Riverbend's expense, and the condition requiring Riverbend to pay for the entire crop of berries and cherries on the Frease farm, which would be rendered unmarketable by nuisance birds.
As to petitioners' first contention, the Court of Appeals concluded that a clear and objective condition will "provide adequate guidance as to its performance and non-discretionary enforcement."
II. ANALYSIS
A. Farmland Protection in Oregon's Land Use System
We allowed petitioners' petition for review to address the requirements of the farm impacts test and whether the conditions that the county imposed in this case were statutorily permitted. In addition to briefing from the parties, the court has received briefs on what the farm impacts test requires from amicus curiae State of Oregon, through its Department of Agriculture and Department of Land Conservation and Development (DLCD); amicus curiae 1000 Friends of Oregon; and amicus curiae Oregon Farm Bureau Federation.
All amici emphasize that this case raises questions that must be considered in light of the importance of farmland protection in Oregon. In its brief, the state notes that, as of the beginning of 2017, Oregon had over 35,000 farms and ranches-96 percent family-owned-and that those farms and ranches accounted for $5 billion in sales and 10.9 percent of the state's total exports. And 1000 Friends of Oregon explains in its brief that its own 2013 report on agriculture in Oregon concludes that both urban and rural jobs *704depend on agriculture. It also states that changes for individual farms can have ripple effects: "[L]oss of productive capacity from individual farms and associated land converted to other uses translates into loss of demand for inputs, services, equipment, processing, and related activities."
Agricultural lands are an important part of Oregon's statewide land use system. See generally Edward Sullivan & Ronald Eber, The Long and Winding Road: Farmland Protection in Oregon 1961-2009 , 18 San Joaquin Agric. L. Rev. 1 (2009) (describing the history of Oregon's tax and land use policies to protect agricultural land and farming). Before turning to the analysis of ORS 215.296, we provide a brief overview of farmland protection's place in the state's land use system.
The legislature's primary statement of agricultural land use policy is contained in ORS 215.243, which has **442remained unchanged since its enactment as part of Oregon's statewide land use planning system in 1973:
"The Legislative Assembly finds and declares that:
"(1) Open land used for agricultural use is an efficient means of conserving natural resources that constitute an important physical, social, aesthetic and economic asset to all of the people of this state, whether living in rural, urban or metropolitan areas of the state.
"(2) The preservation of a maximum amount of the limited supply of agricultural land is necessary to the conservation of the state's economic resources and the preservation of such land in large blocks is necessary in maintaining the agricultural economy of the state and for the assurance of adequate, healthful and nutritious food for the people of this state and nation.
"(3) Expansion of urban development into rural areas is a matter of public concern because of the unnecessary increases in costs of community services, conflicts between farm and urban activities and the loss of open space and natural beauty around urban centers occurring as the result of such expansion.
"(4) Exclusive farm use zoning as provided by law, substantially limits alternatives to the use of rural land and, with the importance of rural lands to the public, justifies incentives and privileges offered to encourage owners of rural lands to hold such lands in exclusive farm use zones."
Thus, the legislature has declared that preservation of agricultural land, particularly in large blocks, is an important statewide policy and that limitations on urban expansion into, and alternative uses of, agricultural and forest lands are necessary and a matter of statewide concern. The legislature's policy for dwellings on farm and forest lands, set out in another statute, similarly seeks to "[l]imit the future division of and the siting of dwellings upon the state's more productive resource land." ORS 215.700.
Those policy statements are part of a detailed set of statutes concerning agricultural land use generally, including such matters as EFU zoning, soils assessments, rural land maps, dwellings on agricultural land, land divisions, and other uses permitted on agricultural land. See **443ORS 215.203 - 215.337 ; ORS 215.700 - 215.799. The farm impacts statute at issue is located within the agricultural lands statutes.
The legislature directed the state's Land Conservation and Development Commission "to implement Oregon statutes by adopting land use planning goals that set out broad objectives for land use planning in Oregon." Wetherell v. Douglas County ,
Goal 3 first became effective on January 25, 1975. There have been several amended versions since, taking effect in 1983, 1988, 1993, and 1994. As amended, Goal 3 provides in part:
"To preserve and maintain agricultural lands.
*705"Agricultural lands shall be preserved and maintained for farm use, consistent with existing and future needs for agricultural products, forest and open space and with the state's agricultural land use policy expressed in ORS 215.243 and 215.700.
"USES
"Counties may authorize farm uses and those nonfarm uses defined by commission rule that will not have significant adverse effects on accepted farm or forest practices.
"IMPLEMENTATION
"Zoning applied to agricultural land shall limit uses which can have significant adverse effects on agricultural and forest land, farm and forest uses or accepted farming or forest practices. Counties shall establish minimum sizes for new lots or parcels in each agricultural land designation. The minimum parcel size established for farm uses in farmland zones shall be consistent with applicable statutes. ***
**444"* * * * *
"GUIDELINES
"* * * * *
"B. IMPLEMENTATION
"1. Non-farm uses permitted within farm use zones under ORS 215.213(2) and (3) and 215.283(2) and (3) should be minimized to allow for maximum agricultural productivity."
Goal 3: Agricultural Lands , Oregon Department of Land Conservation and Development, https://www.oregon.gov/lcd/OP/Pages/Goal-3.aspx (last visited Feb. 21, 2019). Thus, by its terms, Goal 3 both (1) promotes preservation of agricultural land for "farm use" and "maximum agricultural productivity" and (2) limits nonfarm uses of agricultural lands to those "that will not have significant adverse effects" on accepted farming or forest practices.
B. The Farm Impacts Test: ORS 215.296(1)
In broad terms, the parties have two disparate views of how the farm impacts test works. Riverbend and the county defend the Court of Appeals decision. In their view, to determine the significance of changes or cost increases on a single farm or multiple farms caused by a proposed nonfarm use, the local government must take a global view and consider whether the changes rise to the level of causing certain large-scale effects in the surrounding lands, especially a decrease in the supply of agricultural land. Petitioners, on the other hand, see the test operating in granular terms, farm by farm and farm practice by farm practice. They contend that the text of ORS 215.296 indicates that the farm impacts test requires (1) the applicant to properly identify the surrounding lands, the farms on those lands, the accepted farm practices on each farm, and the impacts of the proposed nonfarm use on each farm practice; (2) the local government to determine whether the proposed **445nonfarm use will force a "significant" change to, or cost increase in, an accepted farm practice, as that term is ordinarily used; and (3) if there is a significant change, the local government to determine whether the applicant has demonstrated that, with conditions of approval imposed pursuant to subsection (2) of the statute, the nonfarm use meets the test. As we will explain, we agree with petitioners that the legislature intended the farm impacts test to apply on a farm-by-farm and farm practice-by-farm practice basis and intended to use the ordinary meaning of "significant" and "significantly" in ORS 215.296(1), not a specialized meaning tied to the supply of agricultural land, supply of food, or farm profitability.
1. Significance of an individual impact
We begin with how a local government must determine whether an individual impact on an accepted farm practice or its cost is significant under ORS 215.296(1). On review, petitioners contend that the Court of Appeals drew an erroneous conclusion about what the legislature intended in ORS 215.296(1) by "significant" changes. See SDC III ,
Riverbend and the county primarily respond that, although petitioners are urging that the case presents a legal question about the meaning of the term "significant," this case turns on the sufficiency of facts in the record instead. That is because they view the significance of changes to farm practices or of cost increases as a fact question for the county. Thus, Riverbend and the county argue, when a local government determines that an applicant has satisfied the farm impacts test, LUBA must defer to the local government's decision whenever the record would permit that finding. They also argue that the Court of Appeals was correct about what constitutes a significant change or cost increase and that the county properly applied that standard.
**446As a preliminary matter, we disagree that the issue on review is, at its core, a fact question. Although the question whether a proposed nonfarm use meets the farm impacts test ultimately depends in part on the facts, that question also depends on whether the local government applies the correct test supplied by ORS 215.296(1). And how a "significant" change or cost increase in farm or forest practices is determined is a question of law. That question-and the nature of such a legal standard-requires us to construe ORS 215.296(1).
We begin that task by examining the text and context of ORS 215.296(1), with the goal of determining legislative intent. State v. Gaines ,
"A use allowed under ORS 215.213(2) or (11) [uses permitted in EFU zones in marginal lands counties] or 215.283(2) or (4) [uses permitted in EFU zones in nonmarginal lands counties] may be approved only where the local governing body or its designee finds that the use will not:
"(a) Force a significant change in accepted farm or forest practices on surrounding lands devoted to farm or forest use; or
"(b) Significantly increase the cost of accepted farm or forest practices on surrounding lands devoted to farm or forest use."
ORS 215.296(1).
Some of the terms used in ORS 215.296(1) are statutorily defined. An "accepted farming practice" is defined in ORS 215.203(2)(c) as a "mode of operation" that is "necessary for the operation of such farms to obtain a profit in money" and that is "utilized in conjunction with farm use." "Farm use" is also defined, and it is undisputed that surrounding lands are devoted to farm use.
**447But ORS 215.296(1) also contains key undefined phrases: specifically, when the nonfarm use will "[f]orce a significant change" in accepted farm or forest practices "on surrounding lands" or when it will "[s]ignificantly increase the cost" of those accepted farm or forest practices. In large part, the dispute boils down to what the legislature intended by using those phrases and whether "significant" and "significantly" were intended to have their ordinary meaning or another, specialized meaning.
*707We start with the ordinary meaning of "significant" and "significantly." As petitioners note, the court regularly presumes that the legislature intended to give undefined words in a statute their ordinary meanings. See, e.g. , Hodges v. Oak Tree Realtors, Inc. ,
As used in ORS 215.296(1) to modify a "change in accepted farm or forest practices on surrounding lands," the ordinary meaning of "significant" indicates that the change has, or is likely to have, an important influence or effect on the farm or forest practices "on surrounding lands." Similarly, the ordinary meaning of "significantly" with respect to an increase in the cost of accepted farm or forest practices appears to mean to increase the cost in a significant manner, that is, in an influential and important way. See Webster's at 2116 (defining "significantly" as "in a significant manner *** : to a significant degree").
**448Petitioners further argue that the phrase "farm or forest practices on surrounding lands" refers to each individual farm or forest practice on all surrounding lands; therefore, the significance of changes is considered as to each farm or forest practice. LUBA accepted that reading of ORS 215.296(1). See SDC I , 72 Or. LUBA at 359 n. 12 (whether a change or cost increase in farm practices is significant is determined on an individual basis and not by reference to a group of farm practices on surrounding lands). Petitioners also note that nowhere in ORS 215.296(1) does the text refer to the supply of agricultural land or the provision of food, factors that the Court of Appeals used to determine the significance of changes to farm practices and to the cost of those practices.
In urging us to conclude that the legislature instead intended a "significant" change or cost increase to have a specific impact, namely, one that results in a reduction in agricultural land in the surrounding area, Riverbend and the county primarily rely on context, but they partly ground their argument in the text of ORS 215.296(1). Their textual argument focuses on the prepositional phrase "change *** on surrounding lands." As Riverbend and the county understand it, that phrase requires a local government to view the significance of a change to a farm or forest practice by looking to its effect on surrounding lands. According to Riverbend and the county, a change is not "significant" under ORS 215.296(1) if the nonfarm use does not affect the supply of agricultural land in the surrounding area, even if the nonfarm use may force a change to an accepted farm practice that matters to a farmer. Although petitioners' reading of the statute is more consistent with our typical approach of relying on the ordinary meaning of undefined terms in a statute, Riverbend and the county's reading of the text is at least a possible one.
We next examine the context of ORS 215.296(1) to help us construe those disputed phrases. As noted earlier, the legislature has adopted a statutory agricultural land use policy set out in ORS 215.243. Context includes related statutory policy provisions. See TriMet v. Amalgamated Transit Union Local 757 ,
**449(reviewing as context overarching policy of public meetings law). Because state and local land use laws must be consistent with the statewide land use goals, Goal 3 is also relevant context. See, e.g. , Wetherell ,
The Court of Appeals considered two statutory provisions in its contextual analysis. First, it appears that the Court of Appeals relied on the legislature's concern for preservation of "a maximum amount of the limited supply of agricultural land" as stated in *708ORS 215.243(2) to conclude that the legislature intended "significant" changes in farm practices or their costs to be those that result in a reduction in the amount of agricultural land in the area. See SDC III ,