21 <br />LUBA correctly affirmed the City's findings that the proposed PUD <br />conforms to the transportation standards at EC 9.8320(5). Eugene Code section <br />9.8320(5) states: <br />"(5) The PUD provides safe and adequate transportation <br />systems through compliance with the following: <br />(a) EC 9.6800 through EC 9.6875 Standards for Streets, Alleys, <br />and Other Public Ways (not subject to modifications set <br />forth in. subsection (11) below). <br />(b) Pedestrian, bicycle and transit circulation, including related <br />facilities, as needed among buildings and related uses on the <br />development site, as well as to adjacent and nearby <br />residential areas, transit stops, neighborhood activity <br />centers, office parks, and industrial parks, provided the city <br />makes findings to demonstrate consistency with <br />constitutional requirements. "Nearby" means uses with 1/4 <br />mile that can reasonably be expected to be used by <br />pedestrians, and uses within 2 miles that can reasonably be <br />expected to be used by bicyclists. <br />(c) The provisions of the Traffic Impact Analysis Review of EC <br />9.8650 through 9.8680 where applicable." <br />(Emphasis added). As the City Hearings Official explained, the highlighted <br />language: <br />"demonstrates that the provision is limited by its own words to <br />a requirement showing. three things: a) that EC 9.6800 through <br />9.6875 can be . met, b) that pedestrian, bicycle and transit <br />circulation can be achieved, and c) that if necessary a Traffic <br />Impact Analysis has been done and mitigation provided. In <br />other words, the adopted provisions of EC 9.8320(5) assume <br />that if those three criteria can be met, a `safe and adequate <br />transportation system' will result." <br />Rec. 370. ER 81. The Eugene Planning Commission expressly affirmed this <br />interpretation stating "the HO was correct in his application of EC 9.8320(5), as <br />being, limited in scope to compliance with the following: a) that EC 9.6800 <br />