7 <br />1 dedicate the 22.5-foot right of way and the 13-foot bikepath connection. Rec. <br />2 409; ER 75. <br />3 Public works staff did not state or imply that Oakleigh Lane was unsafe <br />4 because it lacked a 45-foot right-of-way. In fact, the only reference to "risk" at <br />5 all is if the "22.5 foot and 13 foot strips of right-of-way are not dedicated." <br />6 Rec. 1257. Even then, as the Planning Commission found, public works staff <br />7 was only identifying "a future need for street improvements abutting the <br />8 property, rather than any immediate need, based on safety issues or otherwise, <br />9 associated with the proposed PUD." Rec. 9. ER 4. Accordingly, Oakleigh Lane <br />10 is not unsafe, and there is no basis to conclude that condition that public works <br />11 required is inadequate. <br />12 1B. The City's cul-de-sac and right-of-way standards do not establish <br />13 that the PUD is unsafe. <br />14 The intervenor argues that the PUD did not provide a "safe and adequate" <br />15 transportation system, based on alleged violations of cul-de-sac and right-of- <br />16 way standards. However, the City properly determined that the PUD was <br />17 eligible for an exception to cul-de-sac standards, and the right-of-way standards <br />18 themselves did not require immediate improvement of all of Oakleigh Lane. <br />19 A. Cul-de-Sac. <br />20 The intervenor takes issue with the cul-de-sac standards arguing that EC <br />21 9.6820(3) bars cul-de-sacs in excess of 400-feet, and that OMC was not eligible <br />22 for an exception to this standard. Brief, p. 17. However, EC 9.6820(5)(b) <br />