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I Unlike planning for its residential, commercial or industrial land needs, planning for a <br />2 city's recreational needs is largely a matter of local choice. The applicable statutes, Statewide <br />3 Planning Goals and administrative rules are not prescriptive as to the amount of park land that <br />4 a city must have to serve its population. LUBA has held that "While Goal 8 requires a city to <br />5 plan for recreational facilities consistent with availability of resources, nothing in Goal 8 requires <br />6 a city to fully fund identified recreational improvements, or ensure that those improvements are <br />7 available concurrently with projected growth." NWDA v. City of Portland, 47 Or LUBA 533 <br />8 (2004). This flexibility with respect to parks planning makes it acceptable for a city to adopt an <br />9 `aspirational' plan for parks planning and to make the choice to exclude that plan from its <br />10 comprehensive plan. In fact, the OARs that govern parks planning specifically allow cities to <br />11 adopt parks plans independently of their comprehensive plans.' <br />12 The Land Conservation and Development Department's (LCDC) rule pertaining to <br />13 planning for local parks provides, in part: <br />14 (1) Local park providers may prepare local park master plans, and local <br />governments may amend acknowledged comprehensive plans and zoning <br />15 ordinances pursuant to the requirements and procedures of ORS 197.610 through <br />197.625 in order to implement such local park plans.... If a local government <br />16 decides to adopt a local park plan as part of the local comprehensive plan, <br />the adoption shall include: <br />17 <br />(a) A plan map designation, as necessary, to indicate the location and <br />18 boundaries of the local park; and <br />19 (b) Appropriate zoning categories and map designations (a "local park" <br />zone or overlay zone is recommended), including objective land use and <br />20 siting review criteria, in order to authorize the existing and planned park <br />uses described in local park master plan. (App. 4, OAR 660 -034- <br />21 0040(1)) (emphasis added). <br />22 The above - quoted administrative rule is entirely permissive. The local park provider may adopt <br />23 a local master plan, the local government may amend the acknowledged comprehensive plan to <br />24 implement the local parks plan. Only if the local government adopts the local parks plan as part <br />25 <br />26 'As discussed previously in this brief. LCDC's Parks Planning Rule, which makes it clear that cities may <br />choose the manner in which they adopt parks plans, post -dates the City's 1989 adoption of the PROS Plan's <br />predecessor plan. <br />Page 1 � -BRIEF OF RESPONDENT <br />