32 <br />1 "Under EC 9.8670(2), it is implied that a TIA and associated mitigation <br />2 measures do not need to be considered unless there is evidence of <br />3 "problems" caused by accident rates, traffic volumes or speed." Ibid. <br />4 The Hearings Official completely neglected to consider the last part of the <br />5 EC 9.8670(2) text, which also triggers a TIA: * * identified locations where <br />6 pedestrian and/or bicyclist safety is a concern by the city that is documented." <br />7 The Hearings Officials omission was impermissible under the ORS 174.010 <br />8 requirement to not "omit what has been inserted." <br />9 In summary, the Hearings Official never even evaluated the relevant <br />10 TIA-triggering condition in EC 9.8670(2), and he ignored substantial and <br />11 probative evidence that the "trigger" condition was met in this case. As a result <br />12 the City erroneously failed to require the necessary TIA. <br />13 It bears noting that a TIA would have provided location-specific data and <br />14 analysis, including current and projected volumes of vehicle, pedestrian and <br />15 bicycle traffic, and the interactions among these modes of travel. Thus, a TIA <br />16 analysis would have provided the probative evidence required to conclude <br />17 whether or not widening of, and/or improvements to, Oakleigh Lane were <br />18 necessary to be consistent with the traffic and safety-related approval criteria. <br />19 The Hearings Official erred by not requiring the TIA, and then he relied on <br />20 erroneous findings to conclude no widening or improvements were necessary. <br />21 The decision must be remanded for the City to properly evaluate <br />