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I C. Response to Third Assignment of Error <br />2 The Metro Plan does not mandate that the PROS Plan be adopted as a refinement <br />plan. Adopting the PROS Plan as a stand -alone internal guidance document is <br />3 consistent with the Metro Plan and does not amount to a de facto amendment to the <br />Metro Plan. <br />4 <br />5 Petitioners' third assignment of error asserts that the Metro Plan requires that the City <br />6 adopt the PROS Plan as a refinement to the Metro Plan and that, by not adopting the PROS Plan <br />7 as a refinement plan, the City effectuated a "de facto" amendment to the Metro Plan. Petitioners <br />8 are incorrect. <br />9 1. Adoption of the PROS Plan as a Stand -Alone Document. <br />10 The City did not adopt the PROS Plan as a refinement to the Metro Plan. (Rec. 10). Due <br />11 to the PROS Plan's aspirational nature, the City adopted the PROS Plan as a stand -alone plan <br />12 to serve as a guiding document for the City as it conducts long -range planning for parks, <br />13 recreation and open space. (Rec. 10). <br />14 Petitioners assert that "there is no such thing as a `stand -alone plan' in the framework of <br />15 the Metro Plan." (Pet. Br. 19). Petitioners argue that if the City wants to adopt any plan that <br />16 relates to a Metro Plan policy it must adopt that plan as a refinement to the Metro Plan. (Pet. Br. <br />17 19). In support of this assertion, Petitioners refer back to their Jurisdiction bloc which sets forth <br />18 the "framework" of the Metro Plan. (Pet. Br. 19, 9 -10). Petitioners' assertion that the Metro <br />19 Plan requires that the PROS Plan be adopted as a refinement to the Metro Plan is not supported <br />20 by the text of the Metro Plan and is, simply, incorrect. <br />21 While the Metro Plan allows for the adoption of refinement plans, its does not mandate <br />22 that every document that relates to a Metro Plan policy, such as the PROS Plan, be adopted as <br />23 a refinement to the Metro Plan. In fact, the Metro Plan specifically states that, while it is the <br />24 basic guiding land use document, it is important "that it be supplemented by more detailed <br />25 refinement plans, programs, and policies." (Pet. Br. 9). Clearly, the Metro Plan anticipates that <br />26 the Metro jurisdictions will supplement the Metro Plan with documents that are not refinement <br />Pane 11 - BRIEF OF RESPONDENT <br />