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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 />Goal 2. Petitioners seem to overlook the Goal 2 provisions that specifically contemplate that <br />"specific implementation measures" may be adopted separately from the plan." <br />3. LCDC Parks Planning Rule. <br />Regarding Petitioners' assertion that the LCDC local park planning rules require that <br />the PROS Plan include the project lists, as discussed in Section IV.E of this brief, OAR 660-034 - <br />0040(1)(a) applies to the City only if the City had chosen to adopt the PROS Plan as part of the <br />Metro Plan. Because the City did not adopt the PROS Plan as part of the Metro Plan, the City <br />was not required to identify the location and boundaries of planned local parks. <br />4. Metro Plan; Parks and Recreation Facilities Element. <br />Lastly, Petitioners argue that Policies H. l and H.2 of the Metro Plan "anticipate that the <br />PROS Plan will include an identification of what projects are needed in the future." 12 (Pet. Br. <br />31). No policy in the Metro Plan requires that the City adopt a project list as part of the City's <br />local parks plan. To the extent that the Metro Plan "anticipates" that a project list will be <br />included in the City's local parks plan (which it does not appear to do), anticipating such an <br />inclusion and requiring such an inclusion are not the same. <br />5. Conclusion. <br />For the reasons discussed above, the City was not required to include the project list in <br />the PROS Plan. LUBA should reject Petitioners' arguments to the contrary. <br />I. Response to Ninth Assignment of Error <br />A slam -dunk for the City. <br />Petitioners' brief does not assert a ninth assignment of error, thus, the City is clearly <br />entitled to a ruling in its favor. <br />"Though Petitioners do not refer to the Dundee case in this portion of their brief.. they argue in their <br />Jurisdiction blog that the Court of Appeal's decision in Dundee requires that the PROS Plan be more than just a <br />guiding document. (Pet. Br. 7 -8). In fact. the Dundee opinion says nothing as to the substantive elements that must <br />be in the PROS plan. <br />' support of their argument Petitioners. again.. reply on the incorrect version of the Parks and Recreation <br />Facilities Element of the Metro Plan. For the reasons set forth in section IV.B of this brief. LUBA should disregard <br />all arguments in Petitioners' brief that are supported by citations to Petitioners' Appendices 21 -25. <br />Page 26 - BRIEF OF RESPONDENT <br />