22 <br />through 9.6875 can be met, b) that pedestrian, bicycle and transit circulation can <br />be achieved, and c) that if necessary a Traffic Impact Analysis (TIA) has been <br />done and mitigation provided." LUBA Rec. 8. ER 45. <br />On appeal, Intervenors-Petitioners challenge this interpretation but fail to <br />identify any error in the decision. In interpreting ,a local ordinance, the Court of <br />Appeals follows the same "steps of statutory interpretation articulated in PGE." <br />Wal-Mart Stores v. City of Oregon City, 204 Or App 359, 365, 129 P3d 702 rev <br />den 341 Or 80, 136 1`3d1123 (2006). Here, the City's interpretation clearly <br />comports with the plain language of the EC 9.8320(5) that provides an <br />application must demonstrate that it has safe and adequate transportation <br />systems "through compliance" with the three subsections. Even the Intervenors- <br />Petitioners concede that the "text supports LUBA's conclusion that compliance <br />with the subsections of EC 9.8320(5) fulfills compliance with the entire <br />provision." Opening Brief, p. 27. <br />In fact, it is unclear what error the Intervenors-Petitioners are alleging in <br />LUBA's interpretation. They appear to assert that LUBA erred by holding that <br />the standards for Streets, Alleys and Other Public Ways only applied to <br />facilities in the PUD. However, as LUBA found, "[t]he plain language of EC <br />9.8320(5) requires the city to determine that `the PUD' meets the standards in <br />(a)" and not "all streets serving the PUD. Rec. 33. ER 31. This is an <br />unremarkable distinction in light of the fact that only the new streets, alleys and <br />ways inside the PUD would be required to conform to the current standards at <br />