comply with the standards incorporated into EC 9.8320(5)(a). That conclusion is supported by <br />the Staff Report and should be affirmed by the HO. <br />(5) The PUD provides safe and adequate transportation systems through compliance <br />with the following: <br />(b) Pedestrian, bicycle and transit circulation, including related facilities, as <br />needed among buildings and related uses on the development site, as well as to <br />adjacent and nearby residential areas, transit stops, neighborhood activity centers, <br />office parks, and industrial parks, provided the city makes findings to demonstrate <br />consistency with constitutional requirements. "Nearby" means uses within 1/4 mile <br />that can reasonably be expected to be used by pedestrians, and uses within 2 miles <br />that can reasonably be expected to be used by bicyclists. <br />1. The Staff Report at 29 and 30 explain why the application complies with this standard. The <br />HO should endorse the findings in the Staff Report. <br />2. Opponents question whether enough facilities are being provided for pedestrians and cyclists. <br />However, this is a subjective standard. It comes with the "as needed" qualifier, which invites <br />argument. Here the HO should endorse the Staff Report finings. <br />(5) The PUD provides safe and adequate transportation systems through compliance <br />with the following: <br />(c) The provisions of the Traffic Impact Analysis Review of EC 9.8650 through <br />9.8680 where applicable. <br />1. The HO has previously determined that the TIA provisions of the code do not apply when the <br />applicant invokes the Needed Housing Statute because the trigger and the standards for a TIA in <br />the code are not clear and objective. See our March 5 Hearing Letter at 2 and supporting <br />Hearing Exhibit A. Therefore, this standard does not apply. <br />2. The Staff Report at 30 concludes that the triggers in the code for a TIA are not met and <br />explains why. The HO should adopt the findings of the staff on this issue. <br />3. Opponents take great issue with the city conclusion that no TIA is needed. They also stress <br />that the TIA that was done and submitted by the applicant's engineer is not competent. This is <br />the opinion of the opponents' engineer Mr. Massoud Saberian P.E. <br />We refer the HO to the March 21 Technical Memorandum from Damien Gilbert P.E., which is <br />Hearing Exhibit B attached to the Schirmer Satre letter of March 21. He addresses the criticisms <br />of the opponents' engineer in detail. He notes, in summary: <br />APP C - Final Argument 4.6.2018 <br />