21 <br />1 <br />z ER-8. LUBA's and the City's decision simply ignores the plain meaning of the <br />3 terms within the definition of "street" and "parking drive." A "street" is a private <br />4 way that allows for access to additional lots or parcels, and that is exactly what has <br />5 occurred here through the adjustment. Again, as noted above, the City has found a <br />6 troublesome issue in its code, and the remedy for the City is to amend its code <br />7 rather than creating an unworkable interpretation that inserts what has been omitted <br />8 and omits what has been inserted. See ORS 174.010. Therefore, because the City <br />9 and LUBA failed to give any effect to the phrase "to provide ingress or egress for <br />1o vehicular traffic to one or more lots or parcels," LUBA's decision is incorrect and <br />11 unlawful in substance. <br />12 IV. Conclusion <br />13 For the reasons set forth above, Petitioners request that this Court reverse <br />14 LUBA's Order and Opinion and, if necessary, remand the matter to LUBA for <br />15 further proceedings. <br />16 s/ Sean Malone Dated: April 17, 2019 <br />17 Sean Malone OSB No. 084060 <br />18 Attorney at Law <br />19 259 E. 5th Ave., Suite 200-G <br />20 Eugene, OR 97401 <br />21 (303) 859-0403 <br />zz seanmalone8(? <br />,hotmail.com <br />23 <br />24 s/ Charles W. Woodward, IV Dated: April 17, 2019 <br />25 Charles W. Woodward, IV <br />