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which states that there can be problems with mulching attaching insects. Increased insects are a concern for Adelman's farming operations located directly across from the Subject Property. Analyzing whether a nonfarm operation is "essential to the practice of agriculture" is paramount even when the operation primarily or exclusively supplies to farms. See City of Sandy v. Clackamas County, LUBA No. 94-104 at 9-10 (1994) (stating that connection must be "closer to the `essential practice of agriculture"' to be valid). While there is no single test for what is "essential" to the practice of agriculture, the case law gives examples of what is sufficiently "essential" pursuant to Oregon's land use framework. It is not sufficient if the commercial activity's products or services are frequently used — or even indispensable — to farming. The relevant question is whether the commercial activity is something particularly unique to farm users and farm use practices. As stated in City of Sandy, "the Oregon Court of Appeals had little difficulty concluding a hop warehouse that would store hops grown by many hops growers, and sell string and burlap used in hop production, qualified as a commercial activity in conjunction with farm use." Id. at 9. String and burlap are not exclusively used in hop production, but was approved as part of the commercial activity in conjunction with farm use because it is essential to the production of hops. However, in the hops case, all of the warehouses purchases and sales were to commercial hop growers. While farmers must eat and farm equipment frequently operates on gasoline, that is not sufficient to make grocery stores or gas stations commercial activities in conjunction with farm use. The connection must be closer to the 'essential practice of agriculture. Id. at 9. The Oregon Land Use Board of Appeals (LUBA) has emphasized the necessity of a direct and substantial relationship between the proposed use and existing farm practices. In Friends of Maf-ion County v. Marion County and Jones, Seasons at Red Oak Farm, LUBA 2021-089 (2022), LUBA determined that a program aimed at inspiring youth to pursue agricultural careers did not meet the criteria set forth in MCC 17.136.060(D)(4). LUBA concluded that the connection between participating in the program and future agricultural employment was "too remote and speculative," and thus did not qualify as providing products or services essential to agriculture. This interpretation underscores that for a conditional use to be approved under MCC 17.136.060(D)(4), Applicant must demonstrate a clear, immediate, and beneficial impact on agricultural practices. The inquiry demanded by caselaw is that indirect support, even if beneficial, does not satisfy the criterion. The Affidavits submitted by Applicant establish that Applicant does not charge for the mulch. Although Applicant states that the supply of mulch to the cattle farmers and blueberry farmers is "essential to the aforementioned farm operations" (October 31, 2024 Submission, Exhibit G), the farm operators state that the mulch is "significant" to the cattle operations, and without the mulch, alternative practices would need to be taken. (Exhibit H). The supply of mulch is "valued through the cattle ranch and farming communities." CU 24-028 - ORDER Klopfenstein Page 14 Page 19 of 26