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 Coupe Family's Response: This COL may be revised for clarity in the manner proposed by Coupe Family below and as shown in Exhibit A. Oceanside objects to Proposed COL 10 on 10.The Planning Director correctly the grounds that it is contrary to the identified issues and questions outside substantial evidence in the record and the the Planning Director's jurisdiction and law. in the Declaratory Order, the Planning discretion. Director exceeded his authority and jurisdiction by, inter alia,ruling that the Makai Haleki`i Extension and Connector Road have not been constructed as required under Ordinance No. 96-7 and Ordinance No. 96-8. Coupe Family's Response: This objection again attempts to reargue the matters before the Planning Director and is thus beyond the scope of this proceeding. This COL contains the Board's reasoning for its decision. To that end, it is both relevant and unobjectionable. Like other Proposed FOFs and COLS 11.The Order sufficiently addressed the discussed supra, Proposed COL 11 appears questions raised by the Appellant even completely unrelated to this appeal, and though the Order did not reflect the instead is related to issues raised by specifics desired by the Appellant. Oceanside in its separate appeal under Case No. PL-BOA-2024-000105, which concerns Oceanside's Petition for Declaratory Ruling. Specifically, the Declaratory Order at issue in this appeal did not address "the questions raised by the Appellant" (i.e., Oceanside). Those "questions"were raised by Coupe, not Oceanside. Oceanside further objects to Proposed COL 11 on the grounds that it misstates the grounds for Oceanside's appeal of the Declaratory Order. As the Circuit Court found in its Remand Order, Oceanside's appeal to the BOA "did not only concern the Declaratory Order lacking `the level of clarity desired by' Oceanside." See Exhibit A at 25-26, ¶29. 14