15 <br />1 "The development and existing street system do not warrant review <br />2 under this criterion, pursuant to the applicability criteria at EC 9.8670. <br />3 The applicant notes that the. development will generate roughly 15 PM <br />4 peak hour trips, which is well below the 100 trip threshold of these <br />5 standards. Further, staff has no concerns related to traffic safety <br />6 issues or poor service levels which result from this development. <br />7 The traffic generated by this site will not result in routine heavy truck <br />8 traffic." Rec. 1265 (Emphasis added). <br />9 The City relied on these staff findings in support of its determination that a TIA <br />10 was not warranted. Rec. 373-74. ER 39-40. The intervenor does not <br />11 acknowledge or challenge these findings. Accordingly, LUBA should also <br />12 deny his baseless fourth subassignment of error. <br />13 IE. The PUD is not an impediment to emergency response. <br />14 The intervenor argues under its fifth assignment of error that City failed to <br />15 make findings demonstrating that "configuration of Oakleigh Lane" would not <br />16 be an impediment to emergency response under EC 9.8320(6). However, the <br />17 applicable standard requires that: <br />18 "The PUD will not be a significant risk to public health and safety, <br />19 including but not limited to soil erosion, slope failure, stormwater of <br />20 flood hazard, or an impediment to emergency response." (Emphasis <br />21 added). <br />22 <br />23 Contrary to the intervenor's representations the City's findings specifically <br />24 address emergency response: <br />25 "With respect to the provision of emergency vehicle response, the <br />26 applicant states the proposed access on Oakleigh Lane and the <br />27 hammerhead turnaround within the development site is sufficient for <br />28 the proposed development. Referral comments from Public Works <br />29 staff indicate that this on-site turnaround must provide for emergency <br />30 vehicle access by being within a temporary emergency access <br />