I <br />1. STANDING <br />2 Intervenor-Petitioners ("Conte") has standing under ORS 197.830(2) and (7) <br />3 because on several occasions, including October 9, 2013, Conte submitted <br />4 written testimony to the City of Eugene Hearings Official in opposition to the <br />5 proposed PUD (City Exhibit PH-49 at Rec 1308); and Conte filed a timely <br />6 Motion to Intervene, which LUBA granted in their Order dated May 1, 2014. <br />7 II. STATEMENT OF THE CASE <br />8 A. NATURE OF THE DECISION AND RELIEF SOUGHT <br />9 The decision under appeal is that land use decision of Respondent ("City") <br />10 entitled "Final Order of the Eugene Planning Commission on Appeal: <br />11 Oakleigh Meadows Cohousing PUD (PDT 13-1)," which became final on <br />12 December 16, 2013, and which approved a Planned Unit Development for a <br />13 proposed condominium development at the terminus of Oakleigh Lane. <br />14 Conte seeks relief by way of a remand with instructions to the City to <br />15 correct the errors enumerated in this appeal by providing adequate findings and <br />16 conditions of approval to ensure the proposed PUD development meets all of <br />17 the City's PUD approval criteria, or the application is denied. <br />18 B. SUMMARY OF ARGUMENTS <br />19 FIRST ASSIGNMENT OF ERROR <br />20 Decision erred in finding that the proposed PUD would provide safe and <br />