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I that was made by resolution instead of ordinance and, even if the City was required to adopt the <br />2 PROS Plan by ordnance, adoption by resolution was harmless error. The City's response does <br />3 not raise any new matters; rather, the City merely responds to Petitioners' two - sentence argument <br />4 that is extremely lacking in detail and specificity. <br />5 LUBA has previously held that when a reply brief merely expands on an earlier <br />6 assignment of error, the reply brief will not be allowed. See Oien v. City of Beaverton, 46 Or <br />7 LUBA 109 (2003) (denying a motion to file a reply brief because the reply brief appeared to be <br />8 simply an embellishment of the petitioner's assignments of error). In this instance, Section A <br />9 of Petitioners' Reply Brief is merely an embellishment on Petitioners' two - sentence assignment <br />10 of error. Petitioners should not be permitted to capitalize on their earlier failure to provide <br />11 sufficient detail and legal argument in support of their assignment of error by being allow to file <br />12 a reply brief on the grounds that the City's response raises new issues. As such, the City requests <br />13 that LUBA deny Petitioners' request to file a reply brief pertaining to Petitioners' Fourth <br />14 Assignment of Error. <br />15 B. The effective date of "housekeeping amendments" postdated the City's adoption of <br />the PROS Plan. <br />16 <br />17 In their Petition for Review, Petitioners, at times, rely on language from a set of <br />amendments to the Metro Plan often referred to as "the housekeeping amendments." It is notable <br />18 <br />19 that Petitioners only rely on the Metro Plan housekeeping amendments when they perceive that <br />20 the amendments favor them. When Petitioners prefer the Metro Plan before the housekeeping <br />amendments, they quote that earlier version.' <br />21 <br />In their Reply Brief, Petitioners argue that the "housekeeping amendments" to the Metro <br />22 <br />Plan were in effect when the City adopted the Parks Recreation and Open Space Comprehensive <br />23 <br />Plan ( "PROS Plan ") that is the subject of this LUBA appeal. They also seem to believe that the <br />24 <br />25 <br />26 For example, on page, on page 38 of Petitioners' brief, they quote a portion of the Metro Plan that was <br />substantially amended in the housekeeping process, but Petitioners do not include those amendments for purposes <br />of that argument. <br />I <br />Page 2 - CITY'S RESPONSE TO PETITIONERS' MOTION AND PROPOSED REPLY BRIEF <br />