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I and, thus, reducing the amount of buildable residential and commercial land located along the <br />2 street. 37 Or LUBA at 497 -498. In Home Builders Assoc. v. City of Eugene, 41 Or LUBA 370 <br />3 (2002), the City adopted natural resource setbacks that reduced its supply of buildable lands by <br />4 a quantifiable amount. In each of these cases, LUBA remanded back to the city, requiring that <br />5 the city calculate the acres that it had removed from its BLI. <br />6 In the cases above, as LUBA pointed out in Home Builders Assoc., 41 Or LUBA at 447, <br />7 the petitioner "made a facially plausible showing that the disputed provisions are likely to reduce <br />8 the supply of buildable lands." In the present case, however, Petitioners have made no such <br />9 showing. The PROS Plan does not rezone, redesignate, purchase or restrict the use of any <br />10 property. If, in following the guidance offered by the PROS Plan, the City takes such actions in <br />11 the future, the City will need to account for any reduction in the area's supply of residential land. <br />12 Petitioners complain that "`Parks' are an allowed use in every Residential zone in <br />13 Eugene." (Pet. Br. 36). Petitioners claim, without citation to any supporting evidence, that, in <br />14 adopting the PROS Plan, the City has made a decision to purchase residential land for parks <br />15 purposes without ever rezoning or redesignating that land, thus avoiding the need for Goal 10 <br />16 findings. (Pet. Br. 36). They state: "The PROS decision reflects the point in time when the <br />17 ultimate policy choice (between parks and housing) is made." (Pet. Br. 36). Petitioners do not <br />18 cite to anything in the PROS Plan that even discusses such activity, much less encourages or <br />19 requires it. <br />20 Petitioners also challenge the City's statements in its Goal 10 findings that the area's <br />21 residential BLI "assumed that 32 percent of residential land would be used for parks and other <br />22 nonresidential uses" and "that the jurisdictions did not count a total of 6,031 acres from the <br />23 overall total of buildable residential lands to ensure that, without counting those 6,031 acres set <br />24 aside for parks and other nonresidential uses, the area still could meet the demand for residential <br />25 lands." (Rec. 15, Pet. Br. 36). While the City does not agree with Petitioners' view of these <br />26 statements, there is no need to debate their points. These statements, showing that the City made <br />Pate 29 - BRIEF OF RESPONDENT <br />