because the decision does not require the neighbors to "dedicate a portion of <br />their property to the widening of the right-of-way or paved surface of Oakleigh <br />Lane." HO Decision, p. 25. The appellant does not acknowledge or challenge this <br />finding in its appeal. In any case, where as here, a Hearings Official addresses <br />the substance of arguments that were advanced by the opponents below, he <br />cannot be faulted for not citing to the policies directly. Ettro v. City of Warrenton, <br />53 Or LUBA 485, 492 (2007). <br />Accordingly, the appellant has failed to identify any error in the Hearings <br />Official's decision and this assignment should be denied. <br />2. The Appellant Fails to Identify Any Error in Hearings Official's <br />Findings Under EC 9.8320(5)(a)-(c) Concerning Safe and Adequate <br />Transportation Facilities. <br />The appellant assigns as error the Hearings Officials' findings under <br />Eugene Code section 9.8320(5)(a)-(c), arguing that the OMC's street connectivity <br />study was inadequate to establish an exemption for an additional street <br />connection, that Oakleigh Lane has to be widened along its entire length in order <br />to avoid increased risks from increased traffic, and that a TIA was required but <br />not performed. The appellant has failed to identify any error in the Hearing's <br />Official's decision with regard to these issues and this appeal item should be <br />denied. <br />A. Street Connectivity and Turnarounds <br />The appellant takes issue with exceptions to street connectivity and to the <br />cul-de-sac requirements approved by the Hearings Official, arguing that <br />Oakleigh Lane cannot adequately serve a single undeveloped property (Tax Lot <br />200). However, EC 9.6815(2)(g)(1)(b) provides that: <br />"In the context of a Type II or Type III land use decision, the city shall <br />grant an exception to the standards in subsections (2)(b), (c) or (d) if the <br />applicant demonstrates that any proposed exceptions are consistent with <br />either subsection 1. Or 2. below: <br />(1) The applicant has provided to the city, at his or her expense, a local <br />street connection study that demonstrates: <br />b. How undeveloped or partially developed properties within a quarter <br />mile can be adequately served by alternative street layouts." (Emphasis <br />added) <br />As the Hearing Official notes, the applicant did provide at its sole expense a <br />connectivity study prepared by a licensed traffic engineer demonstrating how <br />Tax Lot 200 can be adequately served by an alternative street layout. HO Decision, <br />p. 25. What's more, the Eugene Public Works Department concurred in this <br />connectivity study and recommended that the exception be granted. Id. at 18-19. <br />Accordingly, the Hearings Official properly approved this exception. <br />3 <br />237 <br />