increase trips over the 750 trip threshold. Moreover, as the Hearings Official <br />found, the increased traffic will actually create a safer environment for <br />pedestrians by reducing vehicle travel speeds, and there is no evidence of any <br />safety risk associated with increased vehicle traffic: <br />"Although the Hearings Official understands the neighbor's concerns <br />about increased numbers of vehicles using Oakleigh Lane, the strong <br />assertion that an increase in ADT will result in traffic accidents or actual <br />danger to pedestrians and bicyclists is not supported by evidence in the <br />record. Assertion is not evidence, and neither is an explanation of <br />inductive reasoning. Therefore, the Hearings Official cannot substitute <br />the neighbor's very strongly held opinions that more cars will necessarily <br />decrease traffic safety for actual evidence. Anecdotal instances of unsafe <br />traffic conditions are also not enough to trigger a TIA." HO Decision, p. 28. <br />Accordingly, the appellant's assumption that Oakleigh Lane is inadequate to <br />safely accommodate new trips is without basis in the evidence. <br />In the absence of this evidence, the appellant attempts to twist staff <br />findings justifying the road and turnaround dedication to argue that "[i]f <br />dedication is required to adequately protect the public interest on site, it should <br />also be required offsite." However, this fundamentally misconstrues both the <br />findings and the law. As the Hearings Official explained the dedication <br />requirements at EC 9.8320(5) only apply to the property that is subject to the <br />application. HO Decision, p. 25. In that light, staff's findings (and the underlying <br />Public Works comments) justifying the exaction have no applicability to any <br />other portion of Oakleigh Lane, because the findings are only talking about the <br />subject property's frontage. Id. at 27. As such, the appellant has provided no <br />basis for requiring any additional widening or dedication of Oakleigh Lane. <br />C. TIA <br />The appellant also urges that the Hearings Official erred by not requiring <br />a Traffic Impact Analysis. However, as is clearly set forth in the Hearings <br />Official's decision, none of the triggers for a TIA under EC 9.8670 were applicable <br />to the Tentative PUD: The applicant argues that EC 9.8670(2) provides a b asis for <br />a TIA. However, that provision is only triggered where: <br />"The increased traffic resulting from the development will contribute to <br />traffic problems in the area based on current accident rates, traffic <br />volumes or speeds that warrant action under the city's traffic calming <br />program, and identified locations where pedestrian and/ or bicyclist safety <br />is a concern by the city that is documented." <br />The City has no documented pedestrian or bicycle safety concerns on Oakleigh <br />Lane. The applicant points to staff findings concerning the exaction. However, <br />the referenced findings document no concerns regarding pedestrian safety, but <br />instead state that a larger dedication is required in front of the proposed PUD to <br />bring the street up to current standards. This is not documented concern <br />5 <br />239 <br />