23 <br />the configuration, condition and projected use along its entire length. <br />2 The uses on River Road are less than 1/4 mile from the development site, <br />3 and Oakleigh Lane provides the only direct route to/from River Road for <br />4 pedestrians and bicyclists from the PUD and residences on Oakleigh Lane. The <br />5 EPC failed to actually evaluate whether Oakleigh Lane would provide a "safe <br />6 and adequate" pedestrian and bicycle route to River Road. The Decision states: <br />7 "The constitutional findings address a future need for street improvements <br />8 abutting the property, rather than any immediate need, based on safety <br />9 issues or otherwise, associated with the proposed PUD. The [E]PC <br />10 concludes that no additional right-of-way dedication or street improvements <br />11 are necessary to meet the approval criteria. Based on these findings, the <br />12 pedestrian, bicycle and transit circulation requirements of EC 9.8320(5)(b) <br />13 are met." Rec 9. <br />14 Because EC 9.8320(5)(b) addresses bike/ped connections to nearby areas, the <br />15 scope of this approval criteria cannot be limited to "street improvements <br />16 abutting the property." Instead the standard must necessarily encompass the <br />17 entire length of Oakleigb Lane from the development site to River Road. <br />18 The Hearings Official based his findings on the following interpretation: <br />19 "The language of EC 9.8320(5) states: `[t]he PUD provides safe and <br />20 adequate transportation systems through compliance with the following:' <br />21 The underlined section demonstrates that the provision is limited by its own <br />22 words to a requirement showing three things: * * * b) that pedestrian, bicycle <br />23 and transit circulation can be achieved, * * Rec 44. <br />24 This interpretation impermissibly omits the code requirement that "safe and <br />25 adequate" pedestrian, bicycle and transit circulation can be achieved, and the <br />