ER-42 <br />1 is not supported by substantial evidence in the record. Conte Petition for <br />2 Review 30-32. According to Conte, the city's public works staff's analysis <br />3 provides substantial evidence of "a documented concern" about pedestrian and <br />4 bicycle safety. However, similar to our conclusion above, we agree with <br />5 respondents that the public works staff's comments simply do not say what <br />6 Conte argues they say. 14 The city's conclusion that a TIA. is not required under <br />7 EC 9.8760(2) is supported by substantial evidence in the record. ORS <br />8 197.835(9)(a)(C). <br />9 Cons first assignment of error is denied. Neighbors' fourth <br />10 assignment of error is denied. <br />11 The city's decision is remanded. <br />14 The city's public works staff's comments provide, in relevant part: <br />"The development and existing street system do not warrant <br />review under [EC 9.8320(5)(c)], pursuant to the applicability <br />criteria at EC 9.8670. The applicant notes that the development <br />will generate roughly 15 pm peak hour trips, which is well below <br />the 100 trip threshold of these standards. Further, staff has no <br />concerns related to traffic safety issues or poor service levels <br />which result from this development. * * Record 1265. <br />Page 42 <br />000091 <br />