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1 The City did not err by looking beyond its boundaries in considering the City's future <br />2 parks and recreation needs. Further, the City properly coordinated with Lane County regarding <br />3 the adoption of the PROS Plan. <br />4 C. Summary of Material Facts <br />5 The Petitioners' "Summary of Facts" are a gross mischaracterization of the facts as they <br />6 relate to the City's adoption of the PROS Plan. While Petitioners' Summary of Facts does <br />7 contain some correct factual assertions, because of the manner in which Petitioners characterize <br />8 those facts, the City rejects the Petitioners' Summary of Facts in its entirety and, instead, offers <br />9 the following. <br />10 In 2002, the City's Mayor's Advisory Committee (MAC) on the PROS Plan began <br />11 regular meetings to discuss the value of parks, recreation and open space. (Rec. 1668 - 1669). <br />12 Throughout 2002, 2003 and 2004, the MAC worked to, among other things, identify community <br />13 park and recreation needs. (Rec. 1192- 1668). During this time, a number of focus groups were <br />14 convened to offer their input on the park and recreation needs of their groups. For example, the <br />15 City sought input from the Multi - Cultural Focus Group and the Recreation and Service Provider <br />16 Focus Group. (Rec. 1522. 1485). Also during this time the City embarked on an extensive pubic <br />17 outreach process that reached over 3,000 community members using various strategies, including <br />18 a survey of City households. a youth questionnaire, and a speakers' bureau. (Rec. 920). In <br />19 November, 2003, City staff provided the City Council with an update of the status of the PROS <br />20 Plan, the public involvement undertaken to develop the Plan, and the findings that the City staff <br />21 and the MAC had made based on that public involvement. (Rec. 1272- 1297). <br />22 In December, 2004, the MAC convened for a final time to give feedback to City staff <br />23 regarding the November, 2004, draft PROS Plan. (Rec. 1192- 1207). The November, 2004 draft <br />24 of the PROS Plan: 1) identified the core values that the City holds in common in relation to the <br />25 provision of parks, recreation programs and open space; 2) set forth a vision of the future; 3) <br />26 established a mission to communicate the approach that staff will take in conducting the business <br />Page ? - BRIEF OF RESPONDENT <br />