8 <br />1 family dwellings generate 3,218 pass-bys per day, while the 29 proposed <br />2 dwelling units in the PUD would generate at least 6,065 pass-bys per day. <br />3 Thus, the PUD would cause traffic impacts, as measured by average daily <br />4 pass-bys, to almost triple (2.9 times) from 3,218 to 9,283. Rec 864-865. <br />5 <br />III. JURISDICTION <br />6 The PUD approval was a land use decision that applied Eugene Code's land <br />7 use regulations in a discretionary manner. ORS 197.015(10)(a)(A)(iii) <br />8 Accordingly, it is a land use decision subject to LUBA's jurisdiction. <br />9 <br />IV. ARGUMENT <br />10 FIRST ASSIGNMENT OF ERROR <br />11 The City erred in finding that the proposed PUD would provide safe <br />12 and adequate transportation systems through compliance with <br />13 standards for streets and other transportation system elements. <br />14 Issue raised below. The following appeal issues were raised below in <br />15 testimony before the Hearings Official (Rec 647-648, 860-861, 868-871) and in <br />16 the local appeal statement (Rec 320-3402) <br />17 Standard of review. LUBA must remand or reverse the application of a land <br />18 use regulation if the decision is not in compliance with applicable provisions of <br />2 EC 9.8320(5) at Rec 323, EC 9.8320(6) at Rec 328, EC 9.8320(11)(b) at <br />