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sites" on the largest proposed parcel; this potential archeological site straddles <br />the easement area, and the largest proposed parcel, and is just south of the <br />proposed access from Pomaika'i Street. <br />There are three separate letters (dated 2/25/2022, 8/5/2022, and 10/31/2022) <br />discussing the request by the State Historic Preservation Division (SHPD) to <br />prepare an Archeological Inventory Survey (AIS). In its February 2022 letter, <br />SHPD states that the AIS does not meet the standards for this document as <br />identified in the Hawaii Administrative Record (HAR) Section 13-267. In this <br />letter, SHPD asks for a field investigation (FI) to be prepared and reviewed by <br />SHPD. In the August 5, 2022 letter from SHPD, it discusses the FI it received <br />and reviewed; the FI also indicates that an AIS is required. There is language in <br />this letter that states that SHPD does not have, "sufficient information to <br />determine the potential of the proposed project to impact historic properties" <br />pursuant to HAR 13-284_ It's in the October 31, 2022 letter from SHPD to the <br />County of Hawaii that the AIS would not be required now at the entitlement <br />phase, and would be required at the building permit phase of the process. <br />Here's direct quote from the Findings section of this October 31, 2022 letter: <br />"SHPD personnel observed potential terraces and a platform that were not <br />previously identified. Thus, it is likely that the current project parcel may contain <br />more sites/features that have yet to be identified". <br />Based on the information in these letters, and this discussion with SHPD, it <br />seems contrary to the process that both the state and County of Hawaii <br />Planning Department have routinely used to not require the AIS now. <br />Pushing out the AIS until the building permit phase also denies <br />the public and interested parties to review this report. If the AIS is allowed to be <br />conducted later, how can the public review this report? How can the public <br />review the Field Investigation (FI) that has been prepared and submitted to <br />SHPD in May 2022? <br />Any updated cultural survey and/or archeological report prepared to specifically <br />address this potential site of archeological sites should also address: 1) access <br />from Pomaika'i Street to the site and proximity to the potential archeological <br />sites which are shown on Figure 3 of the 1987 Archeological Report that is <br />included in the Background Report for this proposal; 2) what impact might occur <br />from the installation of water meters for the potential lots; 3) the additional <br />"necessary water improvements" from the Department of Water Supply; and 4) <br />an exhibit that shows the possible locations of home sites for all three lots. This <br />level of review would add to the discussion of this proposal, and is the type of <br />work that should be performed for ALL development proposals that would <br />intend to build on lands with known (and to be known) cultural artifacts. <br />Lastly, there are highlighted areas (by the applicant/proponent?) on page 214 of <br />the background report for the 1987 Archeological Survey; these two phrases - <br />"Preservation of the agricultural features is therefore not recommended", and <br />2 of 6 <br />