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2026-02-27 PL-BOA-2024-000105 Coupe Family's Response to 1250 Oceanside's Objections - Proposed Amended FOF-COL
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2026-02-27 PL-BOA-2024-000105 Coupe Family's Response to 1250 Oceanside's Objections - Proposed Amended FOF-COL
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Proposed Conclusions of Law Objections <br /> Coupe Family's Response: This objection again attempts to reargue the matters before the <br /> Planning Director and is thus beyond the scope of this proceeding. This COL contains the <br /> Board's reasoning for its decision. To that end, it is both relevant and unobjectionable. <br /> 12. The Planning Director correctly In response to Proposed COL 12, <br /> identified issues and questions outside Oceanside incorporates by reference its <br /> the Planning Director's jurisdiction and objections to Proposed COLS 4-7 and 10- <br /> discretion. 11, supra. As set forth in Oceanside's <br /> Petition for Appeal and Hearing Brief, the <br /> Planning Director erred by, inter alia, <br /> refusing to: (a) answer four of Oceanside's <br /> Requests on the grounds that they <br /> concerned the Development Agreement; <br /> and (b) answer seven of Oceanside's <br /> Requests on the grounds that they <br /> purportedly sought to review or affirm <br /> prior Planning Department actions. <br /> Coupe Family's Response: This objection again attempts to reargue the matters before the <br /> Planning Director and is thus beyond the scope of this proceeding. This COL contains the <br /> Board's reasoning for its decision. To that end, it is both relevant and unobjectionable. <br /> 13.Planning Director was not required to In response to Proposed COL 13, <br /> inform the Appellant of their [sic] Oceanside incorporates by reference its <br /> compliance obligations under Ord. 96-7 objections to Proposed COLS 4-7 and 10- <br /> and Ord. 96-8, or provide the specific 12, supra. <br /> information sought by Appellant. <br /> Oceanside also objects to Proposed COL <br /> 13 as being contrary to the law. Petitions <br /> for declaratory rulings are "meant to <br /> provide a means of seeking a determination <br /> of whether and in what way some statute, <br /> agency rule, or order, applies to the factual <br /> situation raised by an interested person." <br /> CARD, 114 Haw. at 196-97, 159 P.3d at <br /> 155-56. In other-words, petitions for <br /> declaratory ruling are specifically intended <br /> to provide interested persons a means to <br /> obtain an agency's official position on the <br /> petitioner's "obligations" as it relates to <br /> matters within the agency's jurisdiction. <br /> 24 <br />
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