21 <br />1 The intervenor takes issue with these findings arguing that the TIA addressed <br />2 traffic impacts to levels of service and traffic safety, but not other impacts <br />3 including "noise, headlight glare and dust that arise from traffic." Brief, p. 46. <br />4 However, the intervenor only raised the issues of noise and traffic safety below, <br />5 both of which were properly addressed by the City in the above findings. Rec. <br />6 332. Accordingly, this argument provides no basis for reversal or remand. <br />7 ORS 197.825(2). ' <br />8 The intervenor also faults the City for using Traffic Impact Analysis <br />9 (TIA) standards to evaluate the offsite traffic impacts of the PUD. Brief, p. 45. <br />10 However, the City's TIA review process is designed to evaluate the "traffic <br />11 impacts of...proposed development." EC 9.8650. The City reasonably relied on <br />12 the objective benchmarks set out in that process in interpreting the amorphous <br />13 standard of "minimal offsite impacts." See Northgreen Property LLC v. City of <br />14 Eugene, 65 Or LUBA 83, 92 (2012)(approving findings under EC 9.8320(13) <br />15 that relied on objective standards in the Eugene Code for siting <br />16 telecommunication facilities). Here, the PUD does not generate a third of the <br />17 100 peals hour trips required to even trigger the need for a study, and neighbors <br />18 identified no safety issues or impacts associated with the development.' <br />' The intervenor refers, again, to public works statements concerning the <br />dedication on the Oakleigh Lane property. Brief, p. 47-48. However, these <br />findings relate solely to the dedication area. Public works staff determined that <br />the PUD would have "minimal off-site traffic impacts." Rec. 1274. <br />