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2024-12-03 1250 Oceanside LLC Objection to Proposed FOF, COL, D&O (PL-BOA-2024-000105)
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2024-12-03 1250 Oceanside LLC Objection to Proposed FOF, COL, D&O (PL-BOA-2024-000105)
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Road must be dedicated to the County. See Video of Hearing starting at 1:41:55 (direct <br /> examination); id. starting at 2:12:55 (cross examination by Interveor's counsel). <br /> SUA SPONTE RULINGS REGARDING VARIANCES <br /> 50. When questioned about the section of the Declaratory Order entitled <br /> "Applicability of a Variance," the Planning Director was unable to identify which Requests from <br /> Oceanside the section was responding to. See Video of Hearing starting at 2:00:15. For <br /> example, when questioned about his statements in the Declaratory Order that a variance under <br /> HCC ch. 23 cannot amend an existing ordinance,2 the Planning Director was not able to identify <br /> which Request from Oceanside his statements were responding to. See Video of Hearing starting <br /> at 2:03:15. <br /> 51. On cross examination by Intervenor's counsel, the Planning Director testified that <br /> it was Intervenor's (and not Oceanside's)Petitions for Declaratory Ruling filed in Planning <br /> Department Docket No. 24-0001 that asked the Planning Director to issue declaratory rulings on <br /> whether a variance under HCC ch. 23 can amend an existing ordinance.3 See Video of Hearing <br /> starting at 2:12:20. <br /> 52. The BOA finds that the Planning Director's statements in the section of the <br /> Declaratory Order entitled"Applicability of a Variance"were not made in response to any of the <br /> Requests submitted in Oceanside's Petition for Declaratory Ruling. <br /> b. Oceanside's Supplemental Conclusions of Law. <br /> In addition to its objections to the Planning Director's Proposed COLs set forth above, <br /> Oceanside hereby submits the following Supplemental COLs: <br /> 2 See, e.g., Exhibit 1 at 12 ("Because such a variance only excuses performance under Chapter <br /> 23, Variance 10-027 cannot and does not effect an amendment of an existing ordinance."). <br /> 3 The Planning Director's Declaratory Order on Intervenor's own Petitions for Declaratory <br /> Ruling is the subject of the separate appeal in BOA Docket No. 24-000104. <br /> 19 <br /> 4897-0598-6819.1.00DBS 1-00001 <br />
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