27 <br />"consideration." ER p 32. In doing so, LUBA skipped the difficult questions <br />raised by this assignment of error. <br />A correct interpretation of EC 9.9320(5) requires all of its subsections to <br />be read in concert with each other. This begins with the text of the opening <br />provision of EC 9.8320(5): <br />"(5) The PUD provides safe and adequate transportation systems <br />through compliance with the following." <br />That text supports LUBA's conclusion that compliance with the subsections of <br />EC 9.8320(5) fulfills compliance with the entire provision, but it does not <br />explain how that compliance occurs or how the subsections work together to <br />achieve that result. That explanation requires an understanding of the <br />interconnected nature of the subsections. Each of the subsections has the same <br />grammatical construction- the subsections contain no verb or subject; instead <br />they consist solely of a predicate that contains a portion of the entire <br />requirement. <br />Subsection (a) identifies the standard that applies to the components of <br />the "safe and adequate transportation systems": <br />"(a) EC 9.6800 through EC 9.6875 Standards for Streets, Alleys, <br />and Other Public Ways (not subject to modifications set forth in <br />subsection (11) below)." <br />That provision does not identify what must meet the standards in EC 9.6800 - <br />OCTOBER 2014 <br />