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The Honorable Keith W. Ahue <br />Page 3 <br />December 8, 1993 <br />investment and its ability under law to continue to provide the Sig Island's <br />residents reliable power in a cost effective manner. <br />As we had indicated to both Mr. Paty and Mr. Masumoto in mid-1992, if HELCO <br />were to pursue the State Land Use and County rezoning approvals before <br />proceeding with the expansion of the Keahole Generating Station, this could <br />delay the project beyond 1995 and even for up to three or more years. Such a <br />delay would not be in the public's best interest. <br />2. HELCO'S :current Application for an amendment to the CDUP was made <br />f4Il wina _consultation with your predecessor, Sill Paty, in mid-1992, and in a <br />separate meeting with Harold Masumoto, Director of the Office of State <br />Planning, in mid-1992. <br />3. Since the CDUP amendment was accepted by DLNR in late 1992, HELLO has <br />relied on DLNR's September 25, 1992 "Notice of Acceptance," which states in <br />part that "The proposed use is a conditional use within the General Subzone of <br />the Conservation District according to Administrative Mules, Title 13, Chapter 2, <br />as amended ...." DLNR's staff report, dated January 21, 1993, to the Land <br />Board for the initial hearing on the CDUP amendment restates the <br />aforementioned finding. <br />DLNR's staff report, dated September 1988, and the acceptance of the CDUP <br />amendment HA -6/27188-487A, dated January 27, 1988, also makes an <br />identical finding. In September 1988, the Land Board approved the 1988 <br />CDUP amendment. HELCO has also relied on the direction provided in <br />DLNR's finding add the �Ldnd:Board'approval of the 1988 CDUP amendment in <br />pursuing tFe current amendment. <br />4. On the basis of the foregoing, the December 1992. Draft EIS, the June 1993 <br />Final EIS, and the July 1993 Revised Draft EIS contained the statement that the <br />expansion of the Keahole Generating Station "is consistent with ... the State's <br />land use classification.... " . <br />The comments in the fourth paragraph of your September letter were not <br />previously raised in DLNR's draft EIS comment letter, dated January 21, 1993, <br />or in either of DLNR's two July 1993 letters concerning the Final EIS (published <br />in June 1993). <br />DLNR staff also did not raise any; of the.. comments stated in the fourth <br />paragraph .of your `letter in any of their meetings with representatives of HELCO <br />acid/or CH2M t.4I1.L during -1992 and through September 1993. <br />