2024-12-03 1250 Oceanside LLC Objection to Proposed FOF, COL, D&O (PL-BOA-2024-000104)

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Extension in 2012 satisfied the Ordinances as they relate to the Mauka Haleki`i Extension. See Video of Hearing starting at 2:06:50 (testifying that"The dedication of that Mauka Halekii did satisfy the dedication requirements for that section of the road for the Ordinances, yes."). 31. The Planning Director testified that the Declaratory Order does not qualify or limit the effect and validity of either the 2012 dedication of the Mauka Haleki`i Extension to the County, or Oceanside's satisfaction of the Ordinances as they relate to the Mauka Haleki`i Extension. See Video of Hearing starting at 2:07:20 (testifying that his determination was not qualified). MAKAI HALEKI`I EXTENSION AND CONNECT ROAD 32. The Planning Director testified that DPW, and not the Planning Department,has the jurisdiction to determine whether a roadway can be accepted for dedication. See Video of Hearing at 2:09:25. 33. The Planning Director testified that the Declaratory Order does not make any findings, conclusions, or determinations as to whether the Makai Haleki`i Extension and Connector Road can be dedicated in their current condition. See Video of Hearing at 2:10:10. 34. The Planning Director testified that Ordinance No. 96-8 does not set a deadline, date certain, or development milestone by which the Makai Haleki`i Extension and Connector Road must be dedicated to the County. See Video of Hearing starting at 1:41:55 (direct examination); id. starting at 2:12:55 (cross examination by Interveor's counsel). b. Oceanside's Supplemental Conclusions of Law. In addition to its objections to the Planning Director's Proposed COLs set forth above, Oceanside hereby submits the following Supplemental COLs: 1. The above Findings of Fact, to the extent they constitute Conclusions of Law, are 14 4860-2001-2538.2.051730-00058