9 <br />pedestrian, bicycle and transit elements, that must be evaluated for consistency <br />with the standards found in subsection (a) - the standards for streets, alleys and <br />other ways located in EC 9.6800 - 9.6875. <br />There are several problems with Petitioners' argument. First, this is a <br />novel interpretation that appears for the first time in Petitioners' brief before <br />this Court .4 As explained above, this Court's review function is to determine <br />whether LUBA erred in affirming the City's interpretation; the Court is not <br />reviewing Petitioners' desired interpretation of the relevant code provisions. <br />Second, that said, Petitioners' proposed interpretation might make more <br />sense if subsection (c) did not exist. Even Petitioners concede that the City's <br />interpretation is supported by the language of the provision. Petitioners' <br />Opening Brief 27. EC 9.8320(5) starts with a statement of the overarching <br />standard, "provision of safe and adequate transportation systems." That <br />standard is to be shown "through compliance with the following." Subsections <br />(a), (b) and (c) then provide three separate provisions that must be addressed in <br />order to demonstrate that EC 9.8320(5) is complied with. Petitioners' asserted <br />interpretation is just not supported by the structure of the code provision. The <br />City's interpretation is. <br />4 This Court is increasingly reluctant to address theories that are <br />presented for the first time on appeal. See Regency Centers, L.P. v. Washington <br />County, 265 Or App 49, 60-61, P3d (2014). <br />