I. STATEMENT OF THE CASE <br />Respondent ("the City") accepts Petitioners' Paul Conte and Simon <br />Trautman's ("Petitioners") Statement of the Case, except as set forth below. <br />A. Questions Presented on Appeal <br />1. Did LUBA err in affirming the City's interpretation of Eugene <br />Code (EC) 9.8320(5) or (6)? <br />2. Did LUBA misunderstand and/or misapply its standard of review <br />when it concluded that the City's determination that Oakleigh Lane would be <br />safe was supported by substantial evidence? <br />B. Summary of Arguments <br />Petitioners' main contention is that the increase in traffic to be generated <br />by the proposed development will cause Oakleigh Lane, the sole access to and <br />from the development, to be unsafe. They rely upon that assertion to support <br />their theory that Oakleigh Lane must be fully improved to city standards prior <br />to approving the construction of the PUD. LUBA, however, concluded that the <br />City's determination that Oakleigh Lane would be safe was supported by <br />substantial evidence. This Court can only disturb that conclusion if it <br />determines that LUBA misapplied or misunderstood its standard of review. <br />C. Statement of Material Facts <br />The City accepts Petitioners' Statement of Material Facts as set forth at <br />Petitioners' Opening Brief, 4-6. The City takes no position with regard to <br />