ER-40 <br />1 north is a taking of the property to the north without just compensation as <br />2 required by the Fifth Amendment to. the U.S. Constitution. <br />3 Respondents respond, and we agree, that the street connection study is <br />4 substantial evidence in support of the city's decision to grant an exception to <br />5 the street connectivity standard at EC 9.6815(2)(d), and a reasonable person <br />6 would rely on it to grant the exception. Respondents also respond, and we <br />7 agree, that the street connection study's depiction of the property to the north in <br />8 the possible future hammerhead turnaround is not a taking of the property to <br />9 the north and does not require the property to the north to dedicate any land. <br />10 C. EC 9.8320(5)(c) (TIA Requirements) <br />11 EC 9.8320(5)(c) requires the city to determine that "the PUD provides <br />12 safe and adequate transportation systems through compliance with [t]he <br />13 provisions of the Traffic Impact Analysis Review of EC 9.8650 through 9.8680 <br />14 where applicable and 9.8650 through 9.8680." EC 9.8670 specifies the <br />15 circumstances when a TIA is required, which include, as relevant here: <br />16 "Applicability. Traffic Impact Analysis Review is required when <br />17 one of the conditions in subsections (1) - (4) of this section exist <br />18 <br />19 <br />20 "(2) The increased traffic resulting from the development will <br />21 contribute to traffic problems in the area based on current <br />22 accident rates, traffic volumes or speeds that warrant action <br />23 under the city's traffic calming program, and identified <br />24 locations where pedestrian and/or bicyclist safety is- a <br />25 concern by the city that is documented. * * <br />26 The hearings officer concluded that the increased traffic generated by the PUD <br />27 will not contribute to traffic problems in the area, considering the factors set' <br />28 out in EC 9.8670(2). Record 374-75. The hearings officer relied on the <br />Page 40. <br />000089 <br />