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I H. Response to Eighth Assignment of Error <br />2 The City is not required to adopt the park facilities project list as part of the PROS <br />3 Plan by state statutes, Goal 2, the LCDC Park Planning Rule, or the Metro Plan. <br />4 In this assignment of error, Petitioners set out four bases for their argument that LUBA <br />5 is required to remand the PROS Plan based on that Plan's omission of "an identification of park <br />6 facilities needed for the planning period." (Pet. Br. 29, lines 5 -6). None of the bases provided <br />7 by Petitioners imposes such an obligation. <br />8 Petitioners argue that the City erred when it removed from the PROS Plan a project list <br />9 that was included in early drafts of the PROS Plan. During the revision process, and prior to <br />10 submitting the PROS Plan to the City's Planning Commission for review and comment, City <br />11 Staff did remove from the PROS Plan the projects list and the priority tables. (Rec. 920). The <br />12 project lists and priority tables were made a part of a separate document ( "the PROS Project and <br />13 Priorities Plan ") that was presented to the Council for adoption by resolution. (Rec. 191). The <br />14 PROS Project and Priorities Plan identifies, prioritizes, and estimates costs of proposed actions <br />15 for parks, open space and recreation facilities, programs, and services. (Rec. 801). The PROS <br />16 Project and Priorities Plan includes tables listing proposed capital and non- capital projects <br />17 priorities for parks, open space and recreation facilities, programs, and services, maps of existing <br />18 and proposed parks and open space resources, organized by geographic planning area, and <br />19 estimates of costs of capital and non - capital projects. (Rec. 801). Removing these items from <br />20 the PROS Plan was in keeping with the City's adoption of the PROS Plan as a purely aspiration <br />21 document. <br />22 1. Comprehensive Plan. <br />23 In support of their argument that the City was required to include the project lists in the <br />24 PROS Plan, Petitioners refer back to their Jurisdiction blog and rely on the state statutory <br />25 definition of "comprehensive plan." (Pet. Br. 30). Petitioners argue that the definition of <br />26 "comprehensive plan" imposes the requirement that the PROS Plan include "an identification <br />Page 24 - BRIEF OF RESPONDENT <br />