PD RECOMMENDATION REPORT (PL-SMA-2021-000002)

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National Historic Trail Program (Ala Kahakai) for preservation measures for the portions of"Area A" of the Kumu Hou project that border the Ala Loa (Forerunner)trail. Based on consultation with the State Nd Ala Hele Trail & Access Program (Nd Ala Hele) and Ala Kahakai National Historic Trail Program (Ala Kahakai) the applicant has agreed to uphold further preservation agreements for a segment of the Ala Loa (Forerunner)trail, located outside of and adjacent to sub-area J2 of"Area A" of the proposed Kumu Hou project area. These agreements include removal of ironwood trees encroaching on the trail and within its existing 10-foot buffer, the removal of ironwood duff that blows onto the trail/buffer area, and the establishment of an additional 30-foot buffer and"vegetative transition"between the trail and any buildings that are proposed for sub-area J2 of"Area A." 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, historical, or natural resources in the project area and the extent to which traditional and customary native Hawaiian rights are practiced in the project area. The assessment also determined the extent to which those resources would be affected or impaired by the proposed project and any feasible actions to be taken to protect native Hawaiian rights if they are found to exist. The study concluded that, 1) given the distance from the shoreline, there would be no impacts to shoreline fishing and gathering; 2) there is a disagreement on the cultural, historical, and archaeological significance of the trails in the -6-