30 <br />specific concerns about bicycle and pedestrian safety on Oakleigh Lane: <br />2 "Public Works staff indicates that the applicant's proposal is sufficient to <br />3 accommodate the turnaround, but not the area necessary to extend the <br />4 sidewalk along the south side of the turnaround, to separate pedestrians <br />5 from vehicles and provide a safe public walking surface for the residents of <br />6 the proposed development." Rec 39. And: <br />7 "Improving Oakleigh Lane to these [City] standards will allow for two-way <br />8 vehicular and bicycle traffic [and] will provide separation between vehicular <br />9 traffic and pedestrians Rec 41. (Emphasis added.) <br />10 Thus, the condition of EC 9.8670(2) is met, and a TIA is required. <br />11 The EPC simply relied on the Hearings Official's findings. Rec 9. The <br />12 Hearings Officials findings include patently incorrect statements, such as: <br />13 the strong assertion that an increase in ADT will result in traffic <br />14 accidents or actual danger to pedestrians and bicyclists is not supported by <br />15 evidence in the record. <br />16 <br />17 Contrary to Mr. Conte's assertion, Staff s position that there are no traffic <br />18 safety concerns associated with the proposal or Oakleigh Lane is some <br />19 evidence that a TIA under EC 9.8670(2) is not necessary. Public Works did <br />20 a lengthy and thorough analysis of traffic conditions that is largely repeated <br />21 in the Staff report. Neither Mr. Conte nor any other party submitted <br />22 evidence to the contrary, and that is what is required in order for Staff or the <br />23 Hearings Official to determine that EC 9.8670(2) might be implicated by <br />24 this application. " Rec 48-49. <br />25 The PWD conclusions, cited in opposition testimony below, provide <br />26 substantial, reliable and probative evidence of a documented City concern <br />27 about pedestrian and/or bicyclist safety. The PWD's "thorough analysis of <br />28 traffic conditions" relied upon as the primary evidence for the Hearings <br />29 Official's findings, in fact, concluded exactly the opposite of what the Hearings <br />