ER-27 <br />1 challenge to the city's conclusion that the PUD satisfies EC 9.8320(4)(b) is not <br />2 preserved for our review. <br />3 This portion of Neighbors' third assignment of error is denied. <br />4 E. Parking Area and Garbage Screening Standards (EC <br />5 9.642019.6205) <br />6 In their third assignment of error, Neighbors also argues that the garages <br />7 and parking areas "violate EC 9.6420 (parking area standards) by permitting <br />8 gravel surfacing, and EC 9.6205 regarding requirements for high screens and <br />9 full screen fencing adjacent to recycling and garbage areas." Neighbors' <br />10 Petition for Review 26. Meadows responds that neighbors are precluded under <br />11 Miles and ORS 197.825(2) from raising those issues. Neighbors has not <br />12 responded to Meadows' exhaustion waiver argument. We agree with Meadows <br />13 that the issues are not preserved for our review. <br />14 F. Minimal Off-Site Impacts (EC 9.8320(12)) <br />15 EC 9.8320(12) requires the city to determine that the PUD "shall have <br />16 minimal off-site impacts, including impacts such as traffic, noise, stormwater <br />17 runoff and environmental quality." The hearings officer concluded that traffic <br />18 impacts off-site would be minimal. The hearings officer relied on his <br />19 conclusions, based on peak vehicle trip estimates and traffic projections <br />20 provided by Meadows, that (1) a t raffic impact analysis (TIA) is not required <br />21 under EC 9.6870 because the PUD will not generate additional traffic above <br />22 the threshold required for a TIA, and (2) no level of service deficiencies would <br />23 occur based on new trips added to the area. The hearings officer rejected <br />24 opponents' arguments that the projected doubling of average daily trips over <br />25 current levels traffic impacts would have more than minimal impacts off-site. . <br />26 Record 397-99. <br />Page 27 <br />000076 <br />