has an inadequate driving surface" are synonymous. Moreover, there is no evidence in <br />the record establishing the alleged "adequacy" of the street to satisfy EC 9.6815(2)(f). <br />Photographs of Lombard Lane show significant deteriorations of the surface and <br />pavement distress, crumbling, and lack of drainage facilities. <br />Appellants incorporate by reference all arguments related to EC 9.6815(2)(f) <br />raised before the Hearings Official as if set forth here. <br />The Hearings Official misconstrued applicable law and made inadequate findings not <br />based on substantial evidence with regard to EC 9.5500(7), (13), and (14) <br />The Hearings Official's allegations of adequacy are generalized and do not <br />articulate or explain how it is feasible to comply with the articulation requirements. <br />Appellants incorporate by reference all arguments related to EC 9.5500(7), (13), <br />and (14) raised before the Hearings Official as if set forth here. <br />The Hearings Official misconstrued applicable law and made inadequate findings not <br />based on substantial evidence with regard to EC 9.5500(6) <br />The Hearings Official misconstrued applicable law and made findings not <br />supported by substantial evidence. Other than generalities, the applicant has not <br />demonstrated how the adjusted proposal will "create a vibrant street fagade with visual <br />detail" and "provide multiple entrances to buildings or yards." The notion that <br />"modulation, architectural articulation, and finished material selection" (which has not <br />been established at this point), exaggerated offset, and so forth do not equate to vibrancy <br />or create visual detail. Indeed, they have not even been established. Adjustment is not <br />warranted under EC 9.5500(6). <br />Appellants incorporate by reference all arguments related to EC 9.5500(6) raised <br />before the Hearings Official as if set forth here. <br />The Hearings Official misconstrued applicable law and made inadequate findings not <br />based on substantial evidence with regard to EC 9.6735(2) <br />The Hearings Official's findings are conclusory and are therefore not based on <br />substantial and are inadequate. <br />Appellants incorporate by reference all arguments related to EC 9.6735(2) raised <br />before the Hearings Official as if set forth here. <br />Incorporation of arguments by reference <br />Appellants incorporate by reference all arguments made by Sean T. Malone, <br />Greenlight Engineering, Rob Handy, Julie Hulme, H.M. Sustaita, Loren Schein, the City <br />Attorney, and LandWatch Lane County (including but not limited to the attached). <br />