I <br />TABLE OF CONTENTS <br />I. STANDING I <br />II. STATEMENT OF THE CASE <br />I <br />A. Nature of the Decision and Relief Sought 1 <br />B. Summary of Arguments <br />C. Summary of Material Facts <br />III. JURISDICTION <br />IV. ARGUMENT <br />FIRST ASSIGNMENT OF ERROR <br />1 <br />3 <br />8 <br />8 <br />8 <br />The City erred in finding that the proposed PUD would provide <br />safe and adequate transportation systems through compliance with <br />standards for streets and other transportation system elements. <br />Subassignment of Error LA 14 <br />The City did not adopt a condition of approval that would <br />ensure the 45-foot right-of-way adjacent to the proposed <br />development's access point that the City's findings required. <br />Subassignment of Error LB 16 <br />The Decision did not properly apply adopted street <br />standards to Oakleigh Lane, as required by EC 9.8320(5)(a), <br />EC 9.6820(4) and EC 9.6870. <br />Subassignment of Error 1.C 22 <br />The Decision did not properly evaluate the requirements of <br />EC 9.8320(5)(b) with respect to Oakleigh Lane. <br />