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public facility plan shall list the title of the project and describe each public facility project in terms of the type of facility, service area, and facility capacity." (OAR 660-011-0020) "The governing body Of the city or county responsible for development of the public facility plan shall adopt the plan as a supporting document to the jurisdiction's comprehensive plan and shall also adopt as part of the comprehensive plan: a) The list of public facility project titles, excluding (if the jurisdiction so chooses) the descriptions or specifications of those projects." (Oar 660-011-0045) On page 3 and 4 of Appendix B (Attachment 1), the new narrative under Wastewater System Condition Assessment and the new Table 16a respond specifically to these requirements of the rule. It should be noted that the Metro Plan text, at page III-G-2, is very clear regarding the reach of the PFSP: "The project lists and maps in the Public Facilities and Services Plan are adopted as part of the Metro Plan. Information in the Public Facilities and Services Plan on project phasing and costs, and decisions on timing and financing of projects are not part of the Metro Plan and are controlled solely by the capital improvement programming and budget processes of individual service providers." Examples of this protocol are in the record of the Planning Commissions (Attachment 3) at Documents #13 and #14. The proposed inclusion of a separate amendment process for the PFSP includes the requirements of OAR 660-011-0045 Adoption and Amendment Procedures for Public Facility Plans and maintains the categories of Type I and Type II amendments as those classes of amendments are distinguished in Chapter IV of the Metro Plan and in the development ordinances of Springfield, Eugene and Lane County. The purpose of the PFSP having its own amendment process is twofold: 1) recOgnition that the Metro Plan amendment process is a better fit with broad-based comprehensive planning issues than it is with specialty plans; and 2) the State law makes a distinction between the requirements for post-acknowledgment plan amendments (PAPA's) and some changes to a community's public facilities plans; these distinctions should be observed locally. Amendments to Chapter III, Section G of the Metro Plan are included in this proposal and are intended to address the internal consistency criteria required of Metro Plan amendments: "Adoption of the amendment must not make the Metro Plan internally inconsistent." (Springfield Code 7.070(3) (b)) This question of consistency exists because of the relationship between functional plans (PFSP) and the Metro Plan text: "All refinement and functional plans must be consistent with the Metropolitan Plan, and should inconsistencies occur, the Metropolitan Plan is the prevailing policy document." (Chapter IV, page IV-4, Metro Plan) For these reasons, the Metro Plan text is proposed to be amended to recognize the new maps, the existence of the treatment facilities and collection systems, and the definition of "primary collection system" and "treatment facilities system." In the interests of furthering internal consistency, a single new policy is proposed for inclusion in Chapter III, Section G of the Metro Plan, and reads as follows: "Wastewater conveyance and treatment shall be provided to meet the needs of projected growth inside the UGB that are capable of complying with regulatory requirements governing beneficial reuse [or discharge] l of effluent and beneficial reuse or disposal of residuals." This language makes a deliberate connection between the Metro Plan and the amendments to the Wastewater System Condition Assessment of the PFSP, and responds to the specific requirements of OAR 660-011-0020(2). Planning Commission Action and Public Testimony The Planning Commissions of Springfield, Eugene and Lane County conducted a joint public hearing on these proposed amendments on April 20, 2004. Written and oral testimony was provided by the Eugene Chamber of Commerce and the Lane County Home Builders. The latter group requested an extension of the written record until 5:00 p.m. on Friday, May 7, 2004. As a result of this record extension request, the Planning Commissions scheduled deliberation dates in the third and fourth weeks of May. The staff's written response to the testimony submitted at the public hearing was distributed to the Planning Commissions a Week before their respective deliberation dates. A written response to the Home Builders I The staff report Appendices Aa and Ab inadvertently omitted "or discharge" from the text of new Policy G.9, however the DLCD Notice of Proposed Amendment did include this language (See Attachment 1).