2026-02-27 PL-BOA-2024-000104 Coupe Family's Response to 1250 Oceanside's Objections - Proposed Amended FOF-COL

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Proposed Conclusions of Law Objections rulings is circumscribed by PD Rule 3, and when the Planning Director acts outside of the boundaries of PD Rule 3, he commits clear error and acts without discretion, arbitrarily and capriciously, and in violation of the law. Coupe Family's Response: This COL is quoting PRPP Rule 3-1(a) directly. There is nothing in this COL that is mi scharacteri zing the nature and extent of the Planning Director's authority. It is unobjectionable. Oceanside objects to Proposed COL 5 on the 5. PRPP Rule 3-1(a) does not require the grounds that it appears completely unrelated Planning Director to answer all to this appeal. The Planning Director's questions posed in a petition once the failure and/or refusal to issue declaratory Planning Director decides to issue a rulings on certain questions is at issue in the declaratory ruling on a petition. The separate appeal under Case No. PL-BOA- Planning Director has discretion in the 2024-000105, which concerns Oceanside's manner and method in addressing Petition for Declaratory Ruling. It is questions posed for a declaratory ruling. therefore unclear what relevance, if any, the proposed finding that"PRPP Rule 3-1(a) does not require the Planning Director to answer all questions posed in a petition" has in this appeal. This appeal likewise does not concern"the manner and method"in which the Planning Director answered the questions posed in Coupe's Petitions for Declaratory Ruling; this appeal concerns numerous errors the Planning Director made in the Declaratory Order. Coupe Family's Response: This COL is relevant to this appeal to the extent that the Planning Director did determine that certain requests Coupe Family made were outside his authority and declined to exercise discretion to issue rulings on them. Further, this COL supplies the Board's interpretation of the rules in its examination of the Planning Director's Declaratory Order and is thus relevant. Like other Proposed FOFs and COLS 6. PRPP Rule 3-1(c)provides when the discussed supra, Proposed COL 6 appears Planning Director-shall respond to the completely unrelated to this appeal, and is request for a declaratory order. instead related to the issues raised by Oceanside in its separate appeal under Case No. PL-BOA-2024-000105, which concerns Oceanside's Petition for Declaratory Ruling. 12