19 <br />1 traffic impacts because the proposal did not require a TIA. Brief, p. 45. <br />2 However, the City properly found that the proposal would have only minimal <br />3 traffic impacts, because Oakleigh Lane has adequate capacity to safely <br />4 accommodate the traffic from the proposed PUD. <br />5 EC 9.8320(12) provides that: <br />6 "The proposed development shall have minimal off-site impacts, <br />7 including impacts such as traffic, noise, stormwater runoff and <br />8 environmental quality." <br />9 <br />10 The City found: <br />11 <br />12 "Traffic - Public Works staff confirm that the development will have <br />13 minimal off-site traffic impacts, as only 29 additional peak hour trips <br />14 will be generated by the development. Public Works staff state that <br />15 Oakleigh Lane currently provides for safe passage of two-way and <br />16 emergency vehicles. No street improvements are required of the <br />17 development, although right-of-way dedication and an Irrevocable <br />18 Petition are being required to enable future public improvements. <br />19 Pedestrian safety is further addressed at EC 9.8320(5)(b); those <br />20 findings are incorporated by reference. With regard to public <br />21 comments about the accident at the intersection of Oakleigh Lane and <br />22 River Road, this intersection is not in the City's inventory of <br />23 intersections with high crash ratings that would otherwise warrant <br />24 analysis to determine patterns that could be mitigated by infrastructure <br />25 improvements. As such, nothing further is required of the <br />26 development." Rec. 396. ER 62. <br />27 <br />28 The Hearings Official adopted these findings, and went on to find: <br />29 <br />30 "As an initial matter, the Hearings Official rejects Mr. Conte's <br />31 invitation to substitute the term `insignificant' for the term `minimal' <br />32 in EC 9.8320(12). I agree with the applicant, that if the City Council <br />33 had intended to impose a different standard it could have done so. <br />34 ORS 174.010. The Hearings Official agrees that requiring a PUD to <br />35 have minimal impacts is a very subjective standard that is difficult to <br />36 implement, but EC 9.8320(12) says what is says. <br />37 <br />