44 <br />1 remedy the errors with regard to the criteria in EC 9.8320(5)(b), (6) and (11)(b). <br />2 SECOND ASSIGNMENT OF ERROR <br />3 The City erred in finding that the proposed PUD would have minimal <br />4 off-site impacts, as required by EC 9.8320(12). <br />5 Issue raised below. Appeal issues were raised below in testimony before the <br />6 Hearings Official (Rec 648, 881) and in the local appeal statement (Rec 332). <br />7 Standard of review. The standard of review is the same as stated under the <br />8 First Assignment of Error, which is incorporated here by reference. <br />9 Argument. The City erred in finding the PUD met the approval criterion: <br />10 EC 9.8320(12) The proposed development shall have minimal off-site <br />11 impacts, including impacts such as traffic, noise, stormwater runoff and <br />12 environmental quality. <br />13 With respect to traffic impacts, the EPC generally repeats elements in the <br />14 Hearings Official's findings. Rec 11. <br />15 Neither the EPC nor the Hearings Official provided a reasonable <br />16 explanation for how "minimal impacts" should be evaluated. While "minimal" <br />17 is admittedly subject to various interpretations, it must be given some <br />18 independent meaning and applied to the evidence in the record. <br />19 Nowhere does the Decision address the obvious fact that the PUD will <br />20 almost double daily vehicle trips and triple daily impacts from vehicle <br />21 pass-bys. Otherwise, the Decision provides no other scale on which to evaluate <br />