33 <br />I EC 9.8320(5)(c) and require a TIA, based on the provision of EC 9.8670(2) <br />2 that requires a TIA for "identified locations where pedestrian and/or bicyclist <br />3 safety is a concern by the city that is documented." <br />4 Subassignment of Error I.E. The Decision failed to adequately evaluate <br />5 whether the PUD would be a significant risk to public safety as required <br />6 by EC 9.8320(6). <br />7 EC 9.8320(6) requires that the "PUD will not be a significant risk to public <br />8 safety, including but not limited to an impediment to emergency response." <br />9 The EPC simply relied on the Hearings Official's findings. Rec 10. The <br />10 Hearings Official did not directly evaluate emergency response and traffic <br />11 safety issues that were raised below, and instead relied on staff findings. Rec 50. <br />12 The staff findings (Rec 49-50) provide no analysis at all of the <br />13 configuration of Oakleigh Lane with respect to either public safety or <br />14 emergency response. Instead, the staff findings (and therefore the City's <br />15 Decision) rely on staff findings for EC 9.8320(5)(b) and (I 1)(b). <br />16 When findings for one criterion rely on findings for a separate criterion, <br />17 the decision must identify the specific findings for the referenced criterion that <br />18 are being relied upon and must explain how those findings ensure consistency <br />19 with the subject criterion. In this instance, neither the EPC, Hearings Official <br />20 nor the staff provided the required explanation for an adequate finding. <br />