This case raises the question of whether a local agency issuing a development permit has discretion to delegate authority to the planning department to determine whether a modification of the approved permit is minor (i.e., in substantial compliance with the approved permit) or requires an amendment to the permit with public notice and hearing.  CSAC’s brief argues that such delegation is common and permissible, and that removing such discretion would unnecessarily bog down the planning process.  The brief was drafted by Johannah Hartley in the Santa Barbara County Counsel’s Office.