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I plans. Further, the Metro Plan contains numerous policies directing the Metro jurisdictions to <br />2 undertake certain actions, including the adoption of specific strategies, plans and policies. For <br />3 example, Section III -A -11, policy A.26, states: "Pursue strategies that encourage rehabilitation <br />4 of existing housing and neighborhoods." Pursuant to Petitioners' logic, the City could not adopt <br />5 a strategy for rehabilitating existing housing unless it has adopted as a- refinement to the Metro <br />6 Plan. This conclusion belies common sense. <br />7 While the Metro Plan's Parks and Recreation Facilities Element anticipates that the local <br />8 jurisdictions will adopt local parks and recreation plans, the Metro Plan does not require that the <br />9 local parks plan be adopted as a refinement plan. Specifically, Policy 2 states: "Local parks and <br />10 recreation plans and analyses shall be prepared by each jurisdiction and coordinated on a <br />11 metropolitan level." (App. 8). While the City could have adopted the PROS Plan as a <br />12 refinement to the Metro Plan, it was not required to do so. Petitioners cite to no provision in the <br />13 Metro Plan that mandates that a document adopted with the intent of fulfilling a Metro Plan <br />14 policy must be adopted as a refinement plan, and the City could find none. <br />15 2. The City Did Not Effectuate a De Facto Amendment to the Metro Plan. <br />16 Regarding Petitioners' assertion that the City's act of adopting the PROS Plan as a stand - <br />17 alone document amounts to a do facto amendment of the Metro Plan because the Metro Plan <br />18 does not recognize "stand alone" documents, Petitioners are, again, incorrect. As discussed <br />19 above, the Metro Plan allows refinement plans, it does not mandate refinement plans. There is <br />20 nothing in the Metro Plan that prohibits the City, or any Metro jurisdiction from adopting along - <br />21 range planning document that also fulfills one of the Metro Plan policies. <br />22 3. Conclusion. <br />23 The City was not required by the Metro Plan to adopt the PROS Plan as a refinement <br />24 plan. LUBA should deny Petitioners' third assignment of error. <br />25 <br />26 <br />Pagc 12 - BRIEF OF RESPONDENT <br />