27 <br />1 The staff statement also depends entirely on the condition - "provided <br />2 the paved surface is not blocked by parked vehicles" - for the conclusion that <br />3 the paved surface of Oakleigh Lane would continue to adequately provide for <br />4 vehicle and pedestrian traffic, as well as for emergency vehicles and delivery <br />5 services. Yet in the very same paragraph, the staff statement makes clear that <br />6 the necessary condition cannot be ensured. Thus, this statement is in no way <br />7 reliable, probative and substantial, as required for adequate findings. <br />8 The Hearings Official also relied upon the applicant's claim that: <br />9 "the queuing effect of having a single travel lane along Oakleigh Lane is <br />10 likely to result in lower speeds and acceptably safe conditions for <br />11 pedestrians." Rec 47. <br />12 This assertion came from the applicant's attorney, not a traffic engineer or <br />13 anyone with any relevant expertise on this issue. Moreover, it was not based on <br />14 any evidence or analysis specific to Oakleigh Lane and doesn't even claim <br />15 anything stronger than that it is "likely" to result in safe conditions. To satisfy <br />16 EC 9.8320(5)(b), the applicant would have to provide substantial evidence that <br />17 the "queuing effect" would ensure safe conditions. <br />18 Furthermore, if the "queuing effect" were adequate to create safe <br />19 conditions, the PWD traffic engineers would presumably have relied on that <br />20 same effect and would not have found that Oakleigh Lane needed widening and <br />21 improvements to ensure safety. In fact, the full citation for the "queuing effect" <br />