as far out as River Road. Again, EC 9.8320(5) assumes an "adequate" transportation system <br />would also include off-site facilities to allow PUD residents to safely connect by car or other <br />vehicle with the City's street system, which is found at the intersection with River Road. It <br />would be inconsistent and unreasonable to interpret EC 9.8320(5) as requiring an "adequate <br />transportation" system to provide connectivity beyond the site for pedestrians and bicyclists <br />and yet not require adequate and safe connectivity for vehicle use. <br />Consistent with the broad opening portion of EC 9.8320(5), subsection (b) relies on <br />compliance with the standards referenced in subsection (a). More specifically, standards for <br />pedestrian and bicycle facilities are found in EC 9.6835 Public Accessways, and transit facilities <br />are covered in several of the sections referenced by EC 9.8320(5)(a). There is no need to repeat <br />the reference to these code sections when the three subsections are interpreted as working <br />together to ensure the requirement in the opening portion of EC 9.8320(5).. <br />• <br />Finally, subsection (c) adds the additional requirement for a detailed Traffic Impact <br />Analysis (TIA) where traffic volume or special conditions justify a more extensive analysis and <br />potential mitigations to ensure the transportation system is safe and adequate. Importantly, <br />when;a TIA is triggered, subsection (b) ensures that the TIA. addresses pedestrian, bicycle and <br />transit levels of service (LOS) and safety, as well as vehicular LOS and safety. Again, it would <br />be unreasonable to interpret subsection (c) as allowing a TIA that didn't fully evaluate <br />pedestrian, bicycle and transit levels of service and safety - but that is exactly what the <br />Hearings Official's interpretation would do by treating the subsections of EC 9.8320(5) in <br />isolation. <br />The only way to read EC 9.8320(5) and give effect to all portions of this approval <br />criterion is to find that overall, this criterion requires safe and adequate transportation systems. <br />Subsection (a) states the specific applicable standards, subsection (b) enumerates several <br />transportation modes in addition to vehicular use where those standards apply, and subsection <br />(c) applies an additional level of analysis to all four modes (vehicular, pedestrian, bicycle and <br />transit). <br />There's explicit context in Eugene Code that supports the plain language interpretation <br />of EC';9.8320(5), subsection EC 9.8320(5)(a) and the referenced street standards in EC 9.6870. The <br />purpose of EC 9.6870 is set forth in EC 9.6800 and states: <br />"[s]ections 9.6800 through 9.6875 establish standards for the dedication, design and <br />location of public ways to address the purpose of this land use code contained in <br />EC 9.0020 Purpose." <br />• <br />The referenced code at EC 9.0020 Purpose states: <br />"The purpose of the land use code is to protect and promote the health, safe and <br />general welfare of the public * * (Emphasis added) <br />By the reference to EC 9.0020 Purpose, EC 9.6800 establishes that the purpose of EC 9.6800 <br />through EC 9.6875 is to "establish standards for the dedication, design and location of public <br />ways to" "protect and, promote the health, safety, and general welfare of the public." <br />Trautman Appeal Testimony PDT 13-1 Page 24 <br />July 27, 2015 <br />216 <br />