11-14-2021 Applicant Response to Various DLNR Division Agency Comments

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Mr. Zendo Kern SUBJECT: 2nd ROUND OF STATE AND COUNTY AGENCY COMMENTS AND RESPONSES TO MULTIPLE PERMIT APPLICATIONS FOR KUMU HOU AT WAIKOLOA November 14, 2021 Page 2 • Engineering Division (October 29, 2021) noted that rules and regulation of the National Flood insurance Program (NFIP) are in effect when development falls within a Special Flood Hazard Area, and notes that flood zones subject to NFIP are identified on FEMA's Flood Insurance Rate Maps (FIRM). Response: According to data obtained from the County of Hawaii and ESRI base maps, the Kumu Hou project area is rated Zone X, or an area of minimal flood risk. • Commission on Water Resource Management (CWRM) (November 3, 2021) recommends the following: o The project should be incorporated into the County's Water Use and Development Plan. Response: If entitled, the Applicant will coordinate with the County DWS to ensure Kumu Hou's incorporation into this plan. o Water efficient fixtures and water efficient practices should be implemented throughout the development. o Response: The Applications identify numerous water efficient practices that the Applicant is committed to. Draft conditions recommended by the Planning Department provide further guidance in these respects. o Best management practices (BMPs) should be employed for stormwater management. Response: Kumu Hou will employ BMPs for stormwater management. o Alternative water sources should be employed wherever practicable. Response: Kumu Hou's landscape irrigation is planned to be sourced exclusively from brackish water drawn from the `Anaeho`omalu Aquifer. Owing to the repurposing of nine golf fairways and the project's generation of additional high quality recycled water,Kumu Hou is expected to result in the overall Waikoloa Beach Resort requiring less of this water resource in the future than it does presently. In addition, the Applicant is exploring various landscape solutions within Waikoloa Beach Resort but outside of Kumu Hou to help mitigate the project's impacts on the area's fresh water resources. o Participation in the Hawaii Green Business Program is suggested. Response: The Applicant will consider participation in this program. o Landscape irrigation BMPs endorsed by the Landscape Industry Council of Hawaii should be employed. Response: Kumu Hou is planned to incorporate several such BMPs. As noted, the Applicant is exploring the feasibility of extending such practices throughout the Resort. o Approvals shall be conditioned upon review by the State Department of Health (DOH) regarding the potential for ground or surface water degradation/contamination. Response: The Applicant will coordinate with DOH regarding such review. o The project should consider using reclaimed water for its non-potable water needs, such as irrigation.