concurring in part and dissenting in part.
I concur in that part of the majority’s opinion which would deny CPO #7 standing in its representational capacity. I disagree with that part of the opinion which would deny CPO #7’s standing in its organizational capacity. I therefore dissent, noting at the outset that the Board of County Commissioners has not appealed. The intervenor challenged CPO #7’s standing only in its representational capacity.
The organization’s involvement in the zone change went beyond "a mere 'interest in the problem.’ ” See Sierra Club v. Morton, 405 US 727, 739, 92 S Ct 1361, 31 L Ed 2d 636 (1972). LCDC Goal 1, OAR 660-16-000 (Appendix A), requires every government subdivision having land use planning authority to establish a *84procedure for effective citizen participation. Under that goal, CPO #7 is one of 14 such organizations established by Washington County. Order 74-84 to implement the citizen involvement provisions of the Washington County Comprehensive Framework Plan. LCDC has approved the CPO program as complying with ORS 197.160(2) and Goal 1. The Washington County Community Development Ordinance establishes a formal procedure for certification of "neighborhood organizations” which, once certified, are thereafter entitled to party status in administrative hearings. Washington County Community Development Ordinance, section 2201-3.10. While it appears that no CPO has formally complied with the ordinance, the county has followed the practice of admitting CPO’s as parties in its land use proceedings. It did in this instance specifically.
Apparently CPO #7 has never organizationally gone beyond electing some officers and submitting their names and addresses to the county; further, it considers as members anyone, regardless of area of residence, who attends its meetings or whose name appears on its mailing list. The County Planning Department notifies the organization’s officers of all zone change and plan amendment applications affecting land within its boundaries and furnishes the organization with copies of staff reports. CPO #7 mails copies of its agenda for its monthly meetings and its newsletters to everyone on its mailing list. In this instance CPO #7 participated in the zone change proceedings before the County Planning Commission and before the Board. Thus it appears that CPO #7 is at least de jure a designated agency for insuring citizen participation in land use decisions in accordance with the overall state-wide scheme imposed by ORS ch 197.
In the petition for writ of review it was alleged: "CPO #7’s members have an interest in the integrity of the [Comprehensive Framework Plan] as it applies *85to the CPO #7 area as well as an interest in the quality of urban services available in the area, both of which interests are adversely affected by the Board’s action as hereinafter set forth.” The petition then alleged that the Board failed to follow the procedure applicable to the matter before it by failing to make certain specific findings,1 made a finding which was not supported by reliable, probative and substantial evidence2 and made an order based on findings not supported by reliable, probative and substantial evidence and improperly construed the applicable law in other particulars.3
*86The allegations of the petition assert that Washington County made a land use decision that substantially violated the applicable statutes, regulations and its own ordinances. The challenge is brought by an organization recognized by the county as a source of public input into the planning process, an input that is mandated by the LCDC goal. To shield a possibly unlawful decision from judicial review at the behest of an organization designated by the county to represent the public interest is incongruous indeed. To be sure, it is indefensible so long as the challenges are prima facie substantial and made in good faith. The county has not appeared to defend the integrity of its own decision-making process. The intervenor, whose interest is purely private, would have us deny review, because the organization has not made a showing of "some specific injury to the association or its members.” I would conclude that, given the nature of CPO #7, it has standing to assert it is injured because it has a substantial right to have the county comply with the statutes, regulations and its own ordinances. I am satisfied that CPO #7 has standing because, in the words of Sierra Club v. Morton, supra, 405 US at 740, review is being "sought in the hands of those who have a direct stake in the outcome.”
I would therefore reverse and remand this matter to the Board.
THORNTON, J., joins in this concurrence and dissent."(a) That granting the requested change is in the public interest;
"(b) That the public interest is best carried out by granting the requested change and that the public interest is best served by granting the requested change at this time;
"(c) That the requested change fully accords with the applicable map elements of the relevant CFP and also the goals and policies of the CFP;
"(d) That the factors listed in ORS 215.055 were consciously considered;
"(e) Respecting plaintiffs’ and the Board’s Planning Commission’s staffs contentions before the Board that the subject site does not meet criteria for conversion to urban use set forth in CFP, policy no. 24;
"(f) Respecting plaintiffs’ contentions before the Board that the requested change does not meet the criteria of CFP, policy no. 22, respecting affected road and school capacities and related urban services;
"(g) Respecting plaintiffs’ contentions before the Board that portions of the subject site are within the 100-year floodplain and therefore improperly designated 'urban’ or 'urban intermediate’ rather than 'natural resource’ in the CFP.”
" 'That there is an unequivocal public need for the zone change from RS-1 (surburban residential district) to RU-4 (low-density urban residential).’ ”
"(a) That granting the requested change is in the public interest;
"(b) That the public interest is best carried out by granting the requested change and that the public interest is best served by granting the requested change at this time;
"(c) That the requested change fully accords with the applicable map elements of the relevant CFP and also the goals and policies of the CFP;
"(d) That the factors listed in ORS 215.055 were consciously considered;
*86"(e) Respecting plaintiffs’ and the Board’s Planning Commission’s staff’s contentions before the Board that the subject site does not meet criteria for conversion to urban use set forth in CFP, policy no. 24;
"(f) Respecting plaintiffs’ contentions before the Board that the requested change does not meet the criteria of CFP, policy no. 22, respecting affected road and school capacities and related urban services;
"(g) Respecting plaintiffs’ contentions before the Board the portions of the subject site are within the 100-year floodplain and therefore improperly designated 'urban’ or 'urban intermediate’ rather than 'natural resource’ in the CFP.”