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2006-12-04_Memorandum_to_Petitioner_Opposition_to_Planning_Director_Motion_to_Dismiss_re_Herron_Whitehead
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2006-12-04_Memorandum_to_Petitioner_Opposition_to_Planning_Director_Motion_to_Dismiss_re_Herron_Whitehead
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AMY G SELF, replies to PETITIONERS' OPPOSITION TO THE PLANNING DIRECTOR'S <br /> MOTION TO DISMISS as follows <br /> I PETITIONERS' REQUEST FOR A DECLARATORY RULING BY THE BOARD <br /> OF APPEALS ON THE BASIS OF ZONING ESTOPPEL IS PREMATURE <br /> Petitioners claim that they have legal and equitable reasons for requesting a declaratory <br /> ruling based on the doctrine of equitable estoppel or zoning estoppel Although Petitioners infer <br /> that the Director has given Parker Ranch the"green light"to proceed with its project,Petitioners <br /> provide no evidence that the Director has given Parker Ranch official assurance that it may <br /> proceed without the need to comply with the conditions set forth in the Rezoning Ordinance <br /> No 96 1171 Instead, Petitioners provide their interpretation of condition M of the Rezoning <br /> Ordinance No 96 117 and certain documents obtained from the Planning Department's records <br /> regarding the development <br /> A The Director has given no assurance to Parker Ranch that it may proceed <br /> without complying with the conditions of Rezoning Ordinance No 96117 <br /> Contrary to Petitioners' allegations, there is no indication in the evidence provided by <br /> Petitioners or otherwise that the Director has taken any final discretionary action or given any <br /> official assurance on which Parker Ranch could rely to disregard the conditions of Rezoning <br /> Ordinance No 96 117 and in fact, the Director is without legal authority to do so The County <br /> Council is the only agency with authority to change the conditions of a rezoning ordinance <br /> Should Parker Ranch expend substantial money on planning its development with disregard to <br /> the conditions of Rezoning Ordinance No 96 117, it will do so at its own risk See County of <br /> Kauai v Pacific Standard Life Insurance Company et al, 65 Haw 318 at 330 (1982) (cited in <br /> Petitioners' Opposition to Planning Director's Motion to Dismiss) <br /> ' Ordinance No 96 117 was amended by Ordinance No 02 25 and should be referred to as such Condition M to <br /> which Petitioners refer did not change when Ordinance No 96 117 was amended <br /> 2 <br />
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