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I not identify any parcels for future park acquisition. The PROS Plan does not impose any <br />2 restrictions on residential lands. Petitioners are incorrect in their assertion that the City was <br />3 required to somehow account for the PROS Plan's impacts on residential lands; there is nothing <br />4 to account for. <br />5 The City's Goal 10 findings provide: <br />6 Goal 10 requires that communities plan for and maintain an inventory of <br />buildable residential land for needed housing units. This resolution does not have <br />7 a direct impact on residential development opportunities. The PROS <br />Comprehensive Plan does not change the zoning, designation or allowed uses on <br />8 any properties. While the PROS Comprehensive Plan does include strategies to <br />provide a certain amount of park acreage per 1,000 residents and identifies the <br />9 need to acquire property for park use, it does not rezone any property for park <br />use. Thus, the PROS Comprehensive Plan has no effect on the inventories of <br />10 residential lands. Therefore, the resolution is consistent with Goal 10. <br />11 The City's findings nonetheless continue: <br />12 In ensuring an adequate supply of residential land in the 1999 Residential Lands <br />Study (this area's acknowledged Goal 10 inventory), the jurisdictions took into <br />13 account that numerous nonresidential uses, including parks, would locate on <br />residential land. Parks are specifically discussed in the 1999 Residential Lands <br />14 Study as a use that would need to be accommodated on residentially designated <br />lands. In determining the amount of land that would be needed to satisfy a 20- <br />15 year demand, the Study assumed that 32 percent of residential land would be used <br />for parks and other nonresidential uses. This is discussed on page 47 of the <br />16 Eugene- Springfield Metropolitan Area Residential Lands and Housing Study <br />Draft Supply and Demand Technical Analysis (adopted as findings by the City <br />17 in support of its 1999 action). The table on page 48 of that document, <br />summarizing the supply and demand analysis through the year 2015, show that <br />18 the jurisdictions did not count a total of 6,031 acres from the overall total of <br />buildable residential lands to ensure that, without counting those 6,031 acres set <br />19 aside for parks and other nonresidential uses, the area still could meet the demand <br />for residential lands. <br />20 <br />21 (Rec.15). <br />22 Petitioners, in support of their argument, cite to several cases, none of which is <br />23 comparable to this. In Opus Development Corp. v. City ofEugeiie, 28 Or LUBA 670 (1995), the <br />24 City changed the base zoning or overlay zoning applicable to specific numerous lots. In Volny <br />25 v. City of Bend, 37 Or LUBA 493 (2000), the City adopted a new classification for a particular <br />26 street, requiring a 100' minimum right -of -way where only 80' of right -of -way had been required <br />�J <br />li Page 2� - BRIEF OF RESPONDENT <br />