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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />of the local comprehensive plan must the local parks plan include a plan map designation (as <br />necessary), appropriate zoning categories and map designations. <br />3. Conclusion. <br />The City did not adopt the PROS Plan as part of the Metro Plan. (Rec. 10). Thus, <br />pursuant to OAR 660 - 034 - 0040(1), the City was not required to include the elements delineated <br />in OAR 660 - 034- 0040(1)(a) & (b). Accordingly, LUBA should deny Petitioners' fifth <br />assignment of error. <br />F. Response to Sixth Assignment of Error <br />The planning period and the population projections used in the PROS plan do not <br />violate Statewide Planning Goal 2 or the Metro Plan. <br />1. Background. <br />a. Population Projections and Planning Period for the Metro Plan. <br />The Metro Plan is a regional plan which considers the planning needs for the Cities of <br />Eugene, Springfield and portions of Lane County. Metro Plan, I -1. The Metro Plan plans for <br />growth in the Metro Area through 2015. Because it is a regional plan, population projections in <br />the Metro Plan pertain to the entire Metro Plan area. With respect to population projection, the <br />Metro Plan provides: <br />The Plan is intended to designate a sufficient amount of urbanizable land to <br />accommodate the need for further urban expansion, taking into account the <br />growth policy of the area to accommodate a population of 293,700. The <br />population projection range for the Residential Land Use and Housing Element <br />is 291,700 to 311,100. The expected population for the year 2015 is 301,400. <br />Metro Plan, I -1.' <br />"Petitioners stated that" [tjhe acknowledged population projection for the entire Metro area for the planning <br />period. as stated in the Metro Plan at I -1, is 286,000 for the year 2015." (Pet. Br. 26, lines 12 -13). Petitioners are <br />quoting from language in the latest update to the Metro Plan that, at the time the City adopted the PROS Plan, was <br />caught up in the court system after being challenged by Petitioners, themselves. As explained above, the <br />determination that the PROS Plan is consistent with the Metro Plan is properly based upon the Metro Plan provisions <br />that were in place at the time the PROS Plan was adopted. See Section IV.B. above. <br />Pace 16 - BRIEF OF RESPONDENT <br />