8 <br />1. Interpretation of EC 9.8320(5)2 <br />The City initially concluded that compliance with subsection (5) is <br />demonstrated by showing compliance with its individual components - <br />subsections (a), (b) and (c). LUBA Rec. 698.3 LfJBA agreed. Slip op. 31 <br />(LUBA Rec. 33). Petitioners do not really argue that LUBA erred in affirming <br />this particular interpretation. Rather, Petitioners attempt to provide their own <br />interpretation of how subsection (5) works, an interpretation that they prefer <br />over the City's interpretation and L UBA's decision. <br />Petitioners start out by explaining the grammatical structure of subsection <br />(5). They assert that subsection (5) is aimed at ensuring that the "PLI3 provides <br />safe and adequate transportation systems." Although not stated very clearly, <br />Petitioners seem to be arguing that subsections (a), (b) and (c) are not stand- <br />alone, independent standards or criteria. As Petitioners correctly point out, <br />subsection (b) does not identify any standards. Subsection (a), on the other <br />hand, does explicitly provide standards - those found at EC 9.6800-6875. <br />According to Petitioners, subsections (a) and (b) must be read together. They <br />argue that subsection (b) identifies elements of the transportation system, i. e., <br />2 The standard of review applicable here is outlined above at Section <br />II.A.1. <br />3 The planning commission decision provides: "The PC finds that the <br />HO was correct in his application of EC 9.8320(5), as being limited in scope to <br />compliance with the following: a) that EC 9.6800 through 9.6875 can be met, <br />b) that pedestrian, bicycle and transit circulation can be achieved, and c) that if <br />necessary a Traffic Impact Analysis (TIA) has been done and mitigation <br />provided." LUBA Rec. 698. <br />