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J. Response to Tenth Assignment of Error <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 />The City's adoption of the PROS Plan is consistent with Statewide Planning Goal <br />10. '3 <br />Petitioners' tenth assignment of error is based on the false premise that the PROS Plan <br />removes land from the area's residential lands inventory. There is no basis for Petitioners' <br />reliance on such a premise. Petitioners cite to Table B -1, Rec 135, in support of their assertion. <br />That table, discussed above in the City's Response to Petitioners' Assignment of Error Six, is <br />included in the Plan's Appendix B: "Existing Resources." As discussed above, the table lists <br />seven different types of park facilities and shows the ratio at which parks are provided for in <br />other communities and in Eugene in terms of acres per 1,000 people. The table also sets out <br />"Proposed Standards" for Eugene with respect to each type of park and shows how many acres <br />of each type of park land would be needed to meet the proposed standard if serving a projected <br />2025 population of 210,900. Nothing in the PROS Plan requires the City to meet the "Proposed <br />Standards" or even adopts the proposed standards as anything more than a proposal. <br />The standard proposed for Eugene in the table is an overall standard of 20 acres of park <br />land per 1,000 population. The table shows that, if the City chooses to impose upon itself the <br />proposed standard, by 2025, the City would need to have an additional 1,316.04 acres of park <br />land. 15 However, the City did not choose to impose upon itself the standard proposed in the <br />PROS Plan and adopted the entire plan as a guiding, but not controlling, document. (Rec. 10). <br />The PROS Plan does not identify any areas to be rezoned or redesignated for park use and it does <br />13 Petitioners' stated assignment of error at Pet. Br. 31, lines 14 -18 also asserts that the City violated "the <br />Needed Housing Statutes (ORS 197.307 et seq)" and "failed to make a decision reflecting ultimate policy choices <br />and an adequate factual basis and findings." However, Petitioners fail to develop any argument with respect to these <br />assertions in the text of their argument. <br />14 The table shows that the average standard for 45 Oregon cities surveyed is 21.62 acres of park land /1,000 <br />population. <br />"Petitioners incorrectly state that "the PROS Plan calls for an additional 1,623 acres of land being put into <br />park use." (Pet. Br. 31, lines 20 -21) (emphasis added). Even if the City had adopted the standard proposed in the <br />PROS Plan (20 acres per 1.000 people), the City would not need that many acres above its current inventory of park <br />land. Petitioners repeat this error at Pet. Br. 36. <br />Pave 27 - BRIEF OF RESPONDENT <br />