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also made their recommended edits to it, and that was in Communication No. 2018-15. So from
<br />there, the Planning Department, specifically the Long Range Division of the Planning Department,
<br />picked up those edits, reviewed them as one package.
<br />
<br />And after reviewing, reviewing those previous edits, the Planning Department made some
<br />determinations, which was that other amendments were needed for the Plan in order to resolve
<br />concurrency issues, account for due diligence for resource impact mitigation for road corridors, to
<br />address Actions that attempted to amend Hawai‘i County Codes, to address policies that were
<br />inconsistent with Hawai‘i County Codes or attempts to innovate codes, and to address policy
<br />amendments that are interrelated to policies in other sections. That last part, in other words, was
<br />making sure that we weren’t changing “shall”s and “should”s in isolation of other sections of the
<br />CDP.
<br />
<br />So what we did see is that just changing “shall”s to “should”s didn’t work in the overall scheme of
<br />the Plan itself. So, after, after our review we created a new scope of work, and the new scope of
<br />work was to review the “shall”s and the “should”s to make sure we were okay with them, and just
<br />to note that some of the “should”s, we reverted back to “shall.” Two, “Edit narratives where
<br />required”: This was important because sometimes the narrative before the actual policy set up the
<br />policy, so if you change – and just to go back, the first editions of the amendments, we were only
<br />looking at “shall”s and “should”s – if you didn’t change the narrative prior to that, you could again
<br />run into inconsistencies. The other part of the scope was to ensure that amendments structurally
<br />worked with inter-related policies; checking policies against Hawai‘i County Codes, and
<br />sometimes we had to go a little bit further and check with Hawai‘i Revised Statutes. The other
<br />part of the first edition of the drafts before we got it, the draft edits, was that it didn’t address the
<br />Actions, and so some of the Actions actually says that this policy, the Action, automatically
<br />amends the Code; so, that wasn’t addressed and we had to address that as well. And the last part
<br />was to adjust statements that tried to innovate; so, again, not totally, when we say “innovate,”
<br />mostly coming down to process where you see they are trying to create new processes in terms of
<br />permitting.
<br />
<br />To the left is an example. So, we took every Policy along with their Action, so to the left the
<br />illustration there is just to show that every Policy was broken down in this manner. The next
<br />column to the right of the Policy is tracking who made amendments, and then, because this is
<br />crossing many people’s desk, showing who’s recommending the change and if the change is
<br />approved or not. And I know that’s a little bit more detail, but we wanted to show this because
<br />every Policy and every Action was vetted. Also, when we got comments in from other agencies,
<br />we did the same thing; we vetted each one.
<br />
<br />So, some of the challenges to this process was that we were working, we started off with multiple
<br />drafts, and multiple drafts come with multiple perspectives and inputs, but we took them all in.
<br />The other big challenge was that for us to determine how much change was necessary, and
<br />especially because from the beginning of this process, the Department determined that this was not
<br />going to be a comprehensive review. In other words, this wasn’t going to be the point in time
<br />where we are going to update the entire CDP; this was meant to address issues arising from the
<br />Missler case. So, we are looking to make the least amount of changes as possible and, again, not
<br />intended it to be a comprehensive review. We initiated, we also did this in consultation with other
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<br />EXHIBIT B
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