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Proposed Finding of Fact Objections <br /> Planning Director's discussion of the Development Agreement was purportedly <br /> development agreement in the Order was "only background." <br /> only background, and was labeled as such. <br /> As set forth Oceanside's Petition for Appeal <br /> and its Consolidated Hearing Brief filed <br /> October 4, 2024 ("Hearing Brief'),pursuant <br /> to Rule 1 of the Office of the Mayor <br /> ("Mayor Rule l"), the Planning Department <br /> is the agency"responsible for the overall <br /> administration of the [Development] <br /> Agreement."See Mayor Rule 1-8. At the <br /> contested case hearing, the Planning <br /> Director confirmed during his testimony <br /> that, as part of carrying out its delegated <br /> responsibilities under Mayor Rule 1, the <br /> Planning Department interprets the <br /> provisions of development agreements and <br /> applies their requirements to facts. <br /> The Planning Director demonstrated that he <br /> possesses and can exercise this authority by <br /> interpreting the requirements of the <br /> Development Agreement in the Declaratory <br /> Order, while simultaneously and improperly <br /> refusing to respond to Oceanside's Requests <br /> related to the Development Agreement. The <br /> Planning Director erred by doing so. <br /> Oceanside further objects to Proposed FOF <br /> 12 on the grounds that it is vague and <br /> ambiguous as to what is meant by"correctly <br /> identified"questions related to the <br /> Development Agreement. <br /> Coupe Family's Response: This objection again goes beyond the scope of this proceeding <br /> because Oceanside is attempting to reargue the decision below whereas the Circuit Court <br /> only remanded for more details on the Board's decision. Coupe Family submits that any <br /> purported insufficiency would be remedied by incorporating Coupe Family's proposed <br /> edits as set forth below and in Exhibit A. <br /> 13. Planning Director [sic] discussion as to the Oceanside objects to Proposed FOF 13 on <br /> effect of a variance on existing law and the grounds that it is contrary to the <br /> authority of other county entities in his substantial evidence in the record and the <br /> Order-was not a sua s onte ruling. law. Section III B 3 c of the Declaratory <br /> 6 <br />