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COUNT IV <br /> (DECLARATION THAT COMP PLAN IS VOID FOR VAGUENESS) <br /> 33 . The plaintiffs reallege and reincorporate paragraphs 1 <br /> through 17 as though fully set forth herein . <br /> 34 . In order to determine whether the Land Development <br /> Regulations are consistent with the City' s Comprehensive Plan, <br /> it is necessary to understand and apply relevant textual <br /> provisions and terms of the Comprehensive Plan to the facts of <br /> this case . <br /> 35 . The plaintiffs believe that the plain meaning of the <br /> relevant portions of the Comprehensive Plan clearly demonstrate <br /> that the Land Development Regulations are inconsistent with the <br /> Comprehensive Plan. The City' s only conceivable explanation for <br /> the inconsistency has been to ascribe different and widely <br /> varying interpretations to those same provisions and terms . <br /> 36 . In the event that the Court finds that the City' s <br /> interpretations of the relevant sections of the Comprehensive <br /> Plan can be used to interpret the meaning of these terms, it is <br /> the plaintiffs' position that the terms are so vague, uncertain <br /> and ambiguous that they do not apprise either the applicant, <br /> affected parties , the government or the public of their intent, <br /> purpose and requirements . <br /> 32 The plaintiffs believe that sections of the <br /> Comprehensive Plan referenced in this count , to the extent they <br /> 12 <br /> SHUBIN & BASS, PA. <br />