Fortunately, not really.
I don’t know whether that is now luck or bad luck. This constellation allows those involved to always point fingers at the others.
But as is often the case politically, the district office in Bavaria unfortunately usually sides with the municipality to avoid straining relations and does not replace the municipal consent.
You have tried to clarify. Your efforts were not rewarded. Then just turn the tables.
If the reference point in the extended driveway were assumed, there would only be a height difference of about 1m which one could reduce to the required value within the development plan with the maximum excavation, if one wants to avoid the legal route.
If no one tells you the reference point and there is a solution without an exemption, then plan in accordance with the development plan and make a clearance according to Art. 58 BayBO. LRA is out of the picture, it goes faster and is cheaper.
And then the staking is done by a dilettante like the city planners seem to be, and suddenly he has built in a height error that unfortunately no one notices.
I am always a fan of official channels. But if these are unjustifiably blocked because those responsible have realized they screwed up and are now hiding behind their institutional edifice, you just have to evade.
I once read the reasoning for the development plan. It’s a joke. Short and contradictory, apparently mostly copied from the equally flawed Part 1 of the development plan (Ctrl C - Ctrl V), no references to the height determinations. The legal basis is not specified exactly at this point in the ordinance text. A lawyer would IMHO tear the thing apart.
If your architect put a little effort into the reasoning for the exemption application, I don’t know with what arguments the municipality and LRA want to reject the application.
But what is the current status? Are the building application and exemption application with the LRA? Do they have the negative opinion from the municipality? Have you been advised to withdraw the application because otherwise it would be rejected with costs?