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I provisions of the Eugene Code, 1971. While the PROS Comprehensive Plan <br />will take the place of the 1989 Eugene Parks and Recreation Plan, it will not <br />2 be a refinement to the Metro Plan. Instead, the PROS Comprehensive Plan <br />will be a stand -alone plan serving as an aspirational and guiding document <br />3 for the City as it conducts long -range planning for parks, recreation and <br />open space. (Rec. 10, emphasis added). <br />4 <br />5 Further, findin "D" of the ordinance repealing the 1989 Parks and Recreation Plan (Ordinance <br />6 No. 20362) states: <br />7 By separate Resolution, the City Council is adopting the Parks, Recreation and <br />Open Space Comprehensive Plan ( "PROS Comprehensive Plan ") to provide <br />8 long -range direction for future strategies and actions to improve parks, provide <br />recreation opportunities, and protect natural resource values. The PROS <br />9 Comprehensive Plan will not be a refinement to the Metro Plan, but will be <br />a stand -alone plan serving as an aspirational and guiding document for the <br />10 City as it conducts long -range planning for parks, recreation and open <br />space. (Rec. 145, emphasis added). <br />11 <br />12 Petitioners attempt to create ambiguity where there is none. Based on the above - quoted <br />13 findings from the resolution adopting the PROS Plan and the ordinance repealing the 1989 Parks <br />14 and Recreation Plan, the City made it very clear that the PROS Plan was not being adopted as <br />15 a refinement to the Metro Plan. Rather, the City made it clear that it was adopting the PROS <br />16 Plan as a "stand -alone plan serving as an aspirational and guiding document for the City as it <br />17 conducts long -range planning for parks, recreation and open space." (Rec. 10). By adopting the <br />18 PROS Plan as a stand - alone, aspirational, long -range planning document (and not as a refinement <br />19 plan) the City made it very clear that it was not adopting the PROS Plan as an "element" of the <br />20 Metro Plan. <br />21 Regarding Petitioners' argument that it is unclear whether or not the PROS Plan is a <br />22 "land use plan," Petitioners' argument is insufficiently developed. The City followed the <br />23 procedures for making a legislative land use decision. Petitioners fail to identify any error in the <br />24 City's process for making a legislative land use decision. It appears that Petitioners are attaching <br />25 some unexplained significance to the term "land use plan." (Pet. Br. 15 -16). Petitioners are, <br />26 again, attempting to create confusion when there is none. <br />Page 7 -BRIEF OF RESPONDENT <br />