driveways and private streets, but the requirement is for a "system," not just on-site circulation. <br />Thus, an "adequate transportation system" must reasonably include at least some vehicular <br />connection to the City street network. <br />And because the system must be "safe and adequate," all of the private and at least some <br />of the public streets that are essential components of that system must themselves be safe and <br />adequate - both for the proposed PUD residents and for other members of the public who use <br />these streets.18 <br />The present case is as simple as it gets - there's only a single, dead-end public street that <br />provides the PUD with its essential connection to the City street network - Oakleigh Lane. <br />The three subsections then provide the scope and standards by which to determine what <br />is safe and adequate. The first subsection provides standards for the minimum rights-of-way, <br />paving widths and other improvements. It's that simple. To say that compliance with the <br />standards under EC 9.8320(5)(a), such as minimum right-of-way widths, can be ignored for <br />most of the one public street that is essential to the "transportation system" for PUD residents <br />would be contrary to what EC 9.8320(5) explicitly requires, and an impermissible omission of <br />what's in the code. Similarly, to say that compliance with required paving widths and other <br />improvements for this essential public street can be deferred to some indefinite date would also <br />negate the explicit intent and language of EC 9.8320(5).19 <br />A correct interpretation of EC 9.8320(5) also requires that all of its subsections be read in <br />concert with each other and harmonized. Each of the subsections has the same grammatical <br />construction - the subsections contain no verb or subject; instead they consist solely of a <br />predicate that contains a portion of the entire requirement. <br />As already observed, subsection (a) identifies the standards that apply to the essential <br />components of a safe and adequate transportation system. However, that subsection alone <br />doesn't identify exactly what must meet the standards in EC 9.6800 - 9.6875, so the subsection <br />cannot sensibly be applied in isolation. Instead, these standards obviously apply to the object <br />identified in the opening portion, i.e., the transportation system that would serve the PUD <br />residents. <br />Subsection (b) uses the same grammatical structure as subsection (a) and identifies three <br />additional modes of transportation system facilities - those that enable circulation of <br />pedestrians, bicyclists and transit around the site and to and from nearby areas. EC 9.8320(5) <br />obviously assumes that an "adequate" transportation system would include facilities for <br />vehicular circulation, and the purpose of subsection (b) is to ensure that these additional modes <br />are also supported by the transportation system. Section (b) also requires that the explicit scope <br />of connectivity for the three modes must extend beyond the development site; in this case, even <br />18 This doesn't mean, as the Hearings Official tried to imply that "all nearby streets had to meet City standards." The Hearings <br />Official set up a ridiculous straw man that avoided the more limited, but essential requirement in this case. <br />19 Of course, specific provisions of the standards found in EC 9.6800 through EC 9.6875 may allow exceptions or deferrals, but <br />allowing an applicant to exercise such provisions isn't the same as allowing noncompliance with EC 9.6800 through EC 9.6875. <br />Similarly, possible modifications to the standards, as set forth in subsection EC 9.8320(11), are explicitly allowed; but these were <br />not the basis of the Hearings Official's findings. 0 <br />Trautman Appeal Testimony PDT 13-1 Page 23 July 27, 2015 <br />215 <br />