2. The costs of lawsuit shall be borne by the Plaintiff.

A. On July 2018, the Plaintiff filed an application for permission to engage in solar power generation business with the alteration of the form and quality of the instant application site and installation of structures in the area of 20,402 square meters among 22,305 square meters of forest land B in Gangwon-gun, Gangwon-do (hereinafter “instant application site”).

B. On December 19, 2018, the Defendant rejected the Plaintiff’s application on the following grounds based on the result of deliberation by the Crossing Planning Committee.

(hereinafter referred to as “instant disposition”). - Each entry in Gap’s 1, 3, 4, and 5 evidence (including each number; hereinafter the same shall apply) in the project site and its surrounding area, which includes the area of landslide 1-2 with acute slope in the project site, and the ground is weak, and there is a concern about the occurrence of disaster and damage to the project site and its surrounding area (hereinafter referred to as “grounds for Disposition 1”) - There is no dispute over the ground for recognition - 【A ground for disposition 2’s view on the neighboring road and the view of surrounding environment or landscape (hereinafter referred to as “grounds for Disposition 2”). The purport of the whole

2. The Plaintiff’s assertion on the following grounds is against the principle of proportionality, the principle of self-regulation, the principle of protection of trust, the principle of excessive prohibition, and the principle of equality, and thus, it is unlawful as it deviates from and abused discretion.

On November 7, 2018, the defendant examined whether the plaintiff's business satisfies the criteria for permission for conversion of mountainous district, and notified the deposit of expenses for forest replacement resources and restoration expenses on the premise of permission for conversion of mountainous district.

This is not likely to cause disaster, such as soil erosion and collapse, in the application form of this case, and it is recognized that the defendant has minimized damage to mountainous landscape and forest.

B. According to the prior examination of factors influencing disasters submitted by the Plaintiff, even if the area of the first-class and second-class landslide was partially included in the instant application area, it is not a middle-class radius, but a private surface stability exists even after cutting and filling up the ground, and there is a high level of soil erosion due to the high level of administration, so there is little possibility of landslide.

C. The Plaintiff