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I repeals the 1989 plan; and, 2) a resolution that adopts the PROS Comprehensive Plan as a stand <br />2 alone internal document, i.e., not as a refinement to the Metro Plan." (Rec. 1076 - 1077). <br />3 On February 13, 2006, the City passed Resolution No. 4858 adopting the PROS Plan as <br />4 a stand -alone aspirational document. (Rec. 10). That same night, the City passed Ordinance No. <br />5 20362, repealing the 1989 Parks and Recreation Plan and the corresponding provisions included <br />6 in the City's land use code. (Rec. 144). This appeal followed. <br />7 III. JURISDICTION <br />8 The City accepts Petitioners' assertion that LUBA has jurisdiction to review the City's <br />9 passage of Resolution No. 4858 adopting the PROS Plan. See ORS 197.015(10). (Pet. Br. 13, <br />10 lines 21 -25). <br />11 Petitioners' Jurisdiction section includes 10 pages of factual and legal assertions that do <br />12 not relate to their jurisdictional argument. (Pet. Br. 5 -15). To the extent that Petitioners' <br />13 individual assignments of error reference back to arguments and assertions in Petitioners' <br />14 Jurisdiction blog, the City addresses them within its response to the specific assignments of error. <br />15 IV. RESPONSES TO ASSIGNMENTS OF ERROR <br />i <br />16 A. Response to First Assignment of Error <br />17 The City clearly adopted the PROS Plan as a stand -alone internal guidance <br />document and not as a refinement plan. The City's adoption of the PROS Plan is <br />18 supported by adequate findings and facts. <br />19 Petitioners' first assignment of error urges LUBA to remand the PROS Plan because they <br />20 claim the City was unclear as to whether the City intended the PROS Plan to be an "element" <br />21 of the Metro Plan and because the City's findings in support of the PROS Plan are conflicting. <br />22 Petitioners are incorrect on both counts. <br />23 1. The Citv's Intent is Clear. <br />24 Finding "C" of the resolution adopting the PROS Plan (Resolution No. 485 8) states: <br />25 Portions of the current Eugene Parks and Recreation Plan were adopted by <br />Resolution No. 4127 on July 10, 1989 as a refinement to the Eugene - Springfield <br />26 Metropolitan Area General Plan (Metro Plan). By separate Ordinance the City <br />is repealing the 1989 Eugene Parks and Recreation Plan and the corresponding <br />Page 6 - BRIEF OF RESPONDENT <br />