23 <br />the time the PUD is developed, and not other pre-existing streets in the area. <br />Accordingly, LUBA's interpretation of this provision is reasonable and correct, <br />and should be affirmed. <br />Intervenors-Petitioners also argue that EC 9.8320(5)(a) should, apply to <br />off-site streets because EC 9.8320(5)(b) may apply to facilities for off-site <br />pedestrian, bicycle and transit circulation. However, the two are separate <br />standards that address different aspects of the project. EC 9.8320(5)(a) ensures <br />that streets, alleys and other public ways within the PUD meet minimum City <br />standards prior to acceptance. EC 9.8320(5)(b) by contrast ensures <br />"[p]edestrian, bicycle and transit circulation" by requiring "related facilities, as <br />needed" between buildings and uses on the development site, and for uses <br />"nearby" where the City can meet the requisite constitutional requirements. <br />The mere mention of off-site facilities in EC 9.8320(5)(b) does not <br />require that all streets serving the PUD must meet the current standards for the <br />City streets under EC 9.8320(5)(a). To the contrary, the express reference to <br />"nearby" uses in EC 9.8320(5)(b) - including the clear definition of "nearby" <br />uses and the reference to constitutional restrictions - means that EC <br />9.8320(5)(a) does not apply to "nearby" streets. EC 9.8320(5)(a) does not refer <br />to or define "nearby" streets or impose similar constitutional restrictions, and <br />the standards in EC 9.8320(5)(a) could not be applied to "nearby" streets <br />without rewriting that provision. Again, the Intervenors-Petitioner fail to <br />