Attachment 2 <br />bicycle and pedestrian traffic that the PUD would generate and still provide a <br />safe and comfortable environment for pedestrians (including individuals in <br />wheelchairs or with other mobility limitations) using Oakleigh Lane to and <br />from River Road, as well as to and from the public bike/ped path along the <br />river. <br />The Decision failed to impose adequate condition(s) to ensure there would be <br />sufficient right-of-way, sidewalks and other improvements required for <br />consistency with this policy. <br />All statements related to pedestrian safety under Subassignments of Error <br />2.A, 2.B. 3.A, 4.B and10.A and the Fifth and Sixth Assignments of Error are <br />included herein by reference. <br />SUBASSIGNMENT OF ERROR 1.B <br />The Decision failed to address the following policy at all: <br />TransPlan Finance Policy #4: New Development (Metro Plan Policy F.36) <br />Require that new development pay for its capacity impact on the <br />transportation system. (Metro Plan III-F-13) <br />Evidence in the record clearly shows that Oakleigh Lane would have to be <br />widened and improved to accommodate the significant increase in vehicular, <br />bicycle and pedestrian traffic that the PUD would generate and still provide a <br />safe and efficient road for vehicles, including emergency response vehicles, <br />bicyclists, pedestrians and individuals in wheelchairs. <br />The Decision failed to impose adequate conditions to ensure there would be <br />sufficient right-of-way, sidewalks and other improvements in place at the <br />time the proposed development was occupied so as to be consistent with this <br />policy. <br />Approval of this PUD without such conditions would thereby cause the other <br />property owners along Oakleigh Lane to face potential condemnation and/or <br />large financial assessments to acquire the necessary right-of-way and <br />construct the required improvements. <br />All statements related to the necessary right-of-way and improvements under <br />Subassignments of Error 10.A, 10.B and 10.C and the Second, Third, Fourth <br />and Fifth Assignments of Error are included herein by reference. <br />Appeal Statement PDT 13-1 3 November 22, 2013 <br />PC Agenda - Page 9 <br />