PD RECOMMENDATION REPORT (PL-SMA-2021-000004)

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leading to the shoreline and other natural and cultural resources. Based on the preceding, the Director is recommending a condition of approval requiring that the existing public access plan be amended to include the public access facilities proposed in the Kumu Hou project area in order to create a comprehensive public access plan for the entire Waikoloa Beach Resort. Historic and Cultural Resources: Three (3) draft Archaeological Inventory Surveys (AIS) were completed by Haun & Associates for the entire 182.9-acre Kumu Hou project area(including "Areas B and C") in May 2021, August 2021 and October 2021 respectively. The most recent draft AIS identified a total of 14 sites with associated features, including nine (9) sites previously identified and five (5)newly identified sites. Of the 14, the draft AIS assesses three (3) sites as significant under Criterion"d" (information content) and Criterion"e" (cultural value). Based on the consultation with State Nd Ala Hele Trail & Access Program (Nd Ala Hele) and Ala Kahakai National Historic Trail Program (Ala Kahakai), the AIS recommends the development and adoption of a site preservation plan for three (3) sites located in project"Area B"with no further work or preservation recommended for the other 11 Sites. The sites recommended for preservation include Site 26871 (trail), Site 26873 (lava tube complex with multiple features), and a portion of Site 31230 (trail). The State Historic Preservation Division (SHPD) reviewed the August 2021 draft AIS and asked the applicant to incorporate the comments Nd Ala Hele and Ala Kahakai provided in a revised draft of the AIS,which they did. However, at the date of this writing SHPD has not responded to a request for comment on the October 2021 draft AIS. Based on the preceding, a condition of this approval will require the applicant to prepare and secure the Planning Director's and SHPD's approval of an archaeological preservation plan prior to commencing any land alteration activities. Furthermore, should archaeological features be discovered during construction, a condition of this approval will require the applicant to contact the State Department of Land and Natural Resources and secure their clearance prior to continuing with any development activities. A Native Hawaiian Traditional and Customary Practices Assessment report was submitted with the application. This assessment was designed to identify valued cultural, -6-