10 <br />The City and LUBA read subsection (b) to "require safe and adequate <br />pedestrian, bicycle and transit circulation both within the PUD" and `as well as <br />to adjacent and nearby residential areas, transit stops * * Slip op. 32 <br />(LUBA Rec. 34). It is the "safe and adequate" standard in the introductory <br />language of EC 9.8320(5) that gives meaning to subsection (b), not, as <br />Petitioners suggest, the standards found in subsection (a). That is the <br />interpretation that the City adopted, and LUBA did not err in affirming it. <br />Petitioners also complain that LUBA dismissed Petitioners' safety <br />concerns by noting that the street width standard in EC 9.6870 (incorporated by <br />reference by EC 9.8320(5)(a)) applies only to dedicated streets.5 Petitioners' <br />Opening Brief 34. They seem to think that LUBA was confusing or conflating <br />the dedication issue with the safety issue, and that by concluding that only <br />dedicated right-of-ways had to comply with the street width standards, the City <br />was entirely avoiding addressing safety. Petitioners' Opening Brief 34-35. <br />LUBA's determination that the standard in EC 9.6870 only applied to <br />dedicated streets was based entirely on the language of the provision, EC <br />9.6870, which provides: <br />"Unless an alternative width is approved through use of other <br />procedures in this code, the right-of-way width and paving width <br />of streets and alleys dedicated shall conform to those designated on <br />5 LUBA held: "In addition, the EC 9.6870 requirements for right of way <br />widths apply to `dedicated' streets. It does not require Meadows to dedicate <br />right of way on land that it does not own or to improve land it does not own." <br />Slip op. 31 (LUBA Rec. 33). <br />