I runs north-south through the center of the proposed development. And a bike path runs <br />2 northwest-southeast along the eastern edge of the proposed development. One circulation <br />3 area, which is essentially straight except for a small offshoot, runs east-west between <br />4 River Road and Lombard Street. The other circulation area, which is horseshoe-shaped, <br />5 connects to Lombard Street at two points and runs through the part of the complex that is <br />6 east of Lombard Street. Thus, both internal parking circulation areas permit through <br />7 traffic, in that it would be physically possible for a motor vehicle to enter the complex <br />8 from River Road and exit on Lombard Street (or vice versa) using the first parking area, <br />9 or to enter the eastern half of the complex from one place on Lombard Street and exit at a <br />10 different place on Lombard Street using the second parking area. <br />11 With that picture in mind, we turn to the Eugene Code. Under the code, <br />12 "parking drives" are a type of "driveway." EC 9.5500(11)(b). "Driveways" (in general) <br />13 and "parking drives" (in particular) "are private roadways for projects or portions of <br />14 projects not served by streets." EC 9.5500(11)(b). All "driveways" are to be designed to <br />15 "provide vehicular access to parking and dwelling units," but they "do not provide <br />16 primary pedestrian access to units," and they "are intended to be used primarily for <br />17 vehicular circulation and dwelling access and should be visually distinct from streets." <br />18 EC 9.5500(11)(b)(1). "Parking drives" are "driveways lined with * * * parking spaces, <br />19 garages, or any combination thereof along a significant portion of their length." EC <br />20 9.5500(11)(b)(2). For multi-family residential developments larger than 20 units, parking <br />21 drives are to be designed "so as to permit no through-motor vehicle movements." Id. <br />14 <br />