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1 City, the PROS Plan does not require that the City employ such strategies at any particular time, <br />2 or at all. The Plan is a tool to be used as guidance as the City makes future choices about the <br />3 provision of parks. <br />4 2. Response. <br />5 a. The PROS Planning Period. <br />6 Petitioners argue that, because the planning horizon for the Metro Plan is 2015, the City <br />7 is outrightly prohibited from conducting any land use planning that considers what the area's <br />8 needs might be beyond the year 2015. (Pet. Br. 26, lines 5 -8). Although Petitioners cite the <br />9 Metro Plan as the basis for the alleged prohibition, Petitioners' brief is completely devoid of any <br />10 citation to a Metro Plan provision that supports their assertion. Respondents know of no such <br />11 provision. In fact, State laws and rules require local governments to adopt several different land <br />12 use plans that will have different planning periods. For example, the planning period for <br />13 purposes of adopting a Transportation System Plan is "the twenty -year period beginning with the <br />14 date of adoption of a TSP." OAR 660 -012- 000(18). For an area's residential lands planning, <br />15 it must plan for the 20 -year period that commences on the date initially scheduled for the <br />16 completion of the area's periodic review or legislative review. ORS 197.296. Still another 20- <br />17 year period will be considered when the jurisdiction plans for industrial lands. OAR 660 -009- <br />18 0025(2). Even if a jurisdiction adopts all of these plans and its comprehensive plan on the same <br />19 date, the plans will not share a planning period. <br />20 In another challenge filed by Petitioners against the City, LUBA addressed the same <br />21 argument that Petitioners repeat here. There, Petitioners argued that a Public Facilities Plan <br />22 violated Goal 2 because it had a planning horizon of 2025 as compared to the Metro Plan's <br />23 planning horizon of 2015. LUBA held that "Petitioners cite nothing in the statewide planning <br />24 goals that mandates that planning period for different planning considerations must in all cases <br />25 be identical. Without further argument from petitioners regarding why these different planning <br />26 periods constitute a conflict that amounts to a violation of Goal 2, we deny the second <br />Pag I S - BRIEF OF RESPONDENT <br />