19 <br />ER 143. In fact, public works staff determined that even though the <br />unimproved Oakleigh Lane "lacking curbs and gutters, storm drainage, <br />sidewalks, and street trees" it would provide adequate access for all modes of <br />travel until such time as the owners "elect to improve Oakleigh Lane to full <br />City standards." LUBA Rec. 1268. ER 146. Accordingly, the Public Works <br />staff clearly did not take the position that Oakleigh Lane must be improved as a <br />City street in order to be safe. <br />Second, the City's public works staff did not state or imply that Oakleigh <br />Lane must have a 45-foot right-of-way to be safe. In fact, City public works <br />staff provided findings in support of the half-street width dedication (22.5 feet) <br />east to the entry aisle of the PUD and a 13-foot right-of-way thereafter to <br />accommodate a future turn-around and bike path. LUBA Rec. 1257-58. <br />ER 135-36. Staff referred to the 45-foot right-of-way in arriving at the 22.5-foot <br />half-street dedication. However, Intervenors-Petitioners exaggerate when they <br />claim that staff found that Oakleigh Lane is unsafe without the 45-foot right-of- <br />way. The only, time staff mentions "risk" at all is where it indicates that "safe <br />vehicular, pedestrian and bicycle travel and emergency response and access will <br />be at risk if the 22.5 foot and 13 foot strips of right-of-way are not dedicated." <br />LUBA Rec. 1257. ER 135. Moreover, staff expressly found that it was <br />appropriate to defer an improvement of the dedication area, because "the <br />existing paved surface provides safe passage for two-way vehicular traffic, <br />bicycles, pedestrians and emergency vehicles, and since there is nothing to <br />