47 <br />defensible analysis for the EC 9.8320(12) criterion. <br />2 Further, both the EPC and the Hearings official failed to consider PWD's <br />3 conclusion that "safe vehicular, pedestrian and bicycle travel and emergency <br />4 response and access will be at risk" with the additional traffic, if Oakleigh Lane <br />5 is not widened and improved. No reasonable person would conclude that <br />6 placing drivers, pedestrians and bicyclists on Oakleigh Lane at significant risk, <br />7 as the PWD analysis concludes, is only a "minimal" offsite impact.9 <br />8 In summary, the Decision did not explain a reasonable standard for <br />9 "minimal offsite impact" with respect to traffic and failed to address the <br />10 substantial evidence in the record that the traffic generated by PUD residents <br />11 would have greater than minimal offsite impacts. Consequently, there were not <br />12 adequate findings to conclude the PUD is consistent with EC 9.8320(12). <br />13 The decision must be remanded for the City to provide a reasonable <br />14 interpretation that gives independent meaning to "minimal impacts," and to <br />15 adequately evaluate the potential impacts for noise, headlight glare, dust and <br />9 Even if approval criteria identified under the First Assignment of Error were <br />found not to apply to Oakleigh Lane between the development site and River <br />Road, the safety implications demonstrated in the discussion supra are rele- <br />vant to impacts on all residents and other users along all of Oakleigh Lane. <br />Also, future ROW dedications cannot be relied upon to keep safety <br />problems "minimal," because dedication of a 45-foot right-of-way would then <br />cause a huge negative impact on Oakleigh Lane property owners. Rec 648. <br />