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<br /> 'Q- ®lIII YSO lYO[w rm uut <br /> P.K.O. <br /> <br /> <br /> Regulations) and the National Register, Bulletin 15 and 38. <br /> <br /> <br /> In any decision-making process there must be an established criteria to <br /> <br /> IDENTIFY, ASSESS and EVALUATE culturalhristorical resources; second, all relevant <br /> <br /> facts must have been gathered; and lastly, based upon the facts so gathered which <br /> <br /> have been deemed to be relevant in the case, made a finding that no adverse impacts <br /> exist and that the decision is consistent with the laws of this state. <br /> <br /> <br /> <br /> It has been the coalitions' position before the State Land Use Commission and <br /> <br /> the Hawaii County Planning Commision that absent such established crtteria or <br /> decision-making mechanisms, it would be extremely difficult, if not impossible to make <br /> <br /> a fair and accurate decision whether all traditional culturallhistorical properties have in <br /> <br /> fact been identified and of the traditional cuiturallhistodc properties so identified, <br /> <br /> whether they can be legitimately regarded as such. <br /> <br /> <br /> That absent such published rules for evaluating and documenting traditional <br /> <br /> cultursOlstoric properties, the agency has no guidelines to follow in order for It to <br /> <br /> make a fair determination, fair to all parties, of whether a particular cultural/historic <br /> property is significant enough to preserve, or if not significant, can be destroyed after <br /> <br /> first having retained data by photographs and field notes or other forms of recovery <br /> <br /> and retention. <br /> <br /> <br /> It is the coalition's position that such a methodology can be established. <br /> <br /> Lacking specific evaluation and assessment guidelines, identification and assessment <br /> <br /> of what is "culturally significant is left to the persuasion of the developer. It would be <br /> <br /> much more cost effective and sensible to start the process now and eliminate the <br /> need for future development delays stemming from Intervenor Petitions and contested <br />