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2026-02-05 Kellberg's Pre-Hearing Brief (PL-BOA-205-000124)
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2026-02-05 Kellberg's Pre-Hearing Brief (PL-BOA-205-000124)
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purported lots moving forward. It is indisputable that the subdivided lots presently do not conform <br /> to several sections of the zoning and subdivision codes(e.g.,HCC §25-5-74 states,"The minimum <br /> building site area in the A district shall be five acres." Three lots are smaller than three acres). <br /> Regardless of the finality of the subdivision's approval, how and to what extent do such non- <br /> conformities affect the lots' future uses, and to what extent must the lots be brought into <br /> compliance? 1 The approval implies one answer, while the County Code mandates the opposite. <br /> Pursuant to the County Code and Planning Department Rules, only the Planning Director can <br /> reconcile the two. <br /> II. FACTUAL BACKGROUND <br /> SUB 05-00064 (the "Subdivision") concerned a 48.47 acre parcel and a non-contiguous <br /> .699 acre parcel identified prior to SUB 05-00064 as TMK 3-2-002-035, all of which is in the <br /> agricultural district and zoned A-20a. On June 2, 2004, the Planning Director issued a <br /> determination of pre-existing lots on the 48.47 acre parcel and stated that there were only two legal <br /> 1 "Duties of county officers. (a) The building official shall enforce any provisions of this <br /> chapter relative to building construction and occupancy. (b) The director shall enforce all other <br /> provisions of this chapter pertaining to land use. (c) All law enforcement officers of the County <br /> shall enforce all the provisions of this chapter." HCC § 25-2-1 (emphasis added). <br /> "Issuance of permits or licenses in conformance with chapter. All departments, officials, and <br /> public employees authorized to issue permits or licenses shall conform to the provisions of this <br /> chapter and no permit or license for any use, building, or other purpose shall be issued where the <br /> license or permit would be in conflict with the provisions of this chapter. Any permit or license, if <br /> issued in conflict with the provisions of this chapter, shall be void."Id. § 25-2-2 (emphasis added). <br /> "Violations. Any approval or permit issued pursuant to the provisions of this chapter shall comply <br /> with all applicable requirements of this chapter. Failure to comply with conditions imposed as part <br /> of any approval or permit, including variances from the provisions of this chapter, shall constitute <br /> a violation of this chapter."Id. § 25-2-30 (emphasis added). <br /> 3 <br />
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