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count for the main garden shall become one of the worlds largest. Regarding traffic, she claims that there will be no discernable increase in traffic on Highway 19 and says nothing of the traffic impacts on Leopolino Road and the Old Mamalahoa Highway. As we will explain in a minute, the traffic impacts will be significant. On the matter of inclusion of the 300 acres, she resists by stating that future ideas for the 300 acres are extremely germinal and there are no plans for development as acquisition has not been consummated. The reality, the garden has already done extensive development of these lands and they contain the waterfalls that are currently the main attraction of the garden. Regarding the CZM review, she does not recognize that the CZM and SMA are two different regulatory systems and does not indicate that they will do an assessment in relation to the CZM objectives. The State Division of Forestry and Wildlife expressed concerns in a letter dated March 20, 2004, you mentioned that earlier. They state that the ornamental industry has contributed to the introduction of invasive plants to Hawaii. The World Garden and particularly its sales of nurseryitemscanonlyincreasethechanceofmoreinvasiveweedintroductions.Thegarden states that it wants to some day have over 30,000 species!! And I think, I mean, Rene you had a good idea about asking some other environmental groups about what could be the impacts. As we mentioned before, the Planning Directors recommendation has flaws. The Planning Directors recommendation is misleading. It states that there has been no objection from the community. In fact, the community was not consulted and only a handful of the local residents were notified. The Directors recommendation also states that the land is unsuited for the uses permitted in this district. How could land that is growing hundreds of kinds of plants be unsuited for agricultural use? We were looking at the gardens website last week and the gardens director, Lanny Neel, says on the website, Doing business in Hawaii certainly has the same goals as on the mainland (make money, network and make things happen). The garden has mainland investors who want to see a return on their investment. Maybe they should have invested in a garden like Nani Mau that does receive tour buses, has a restaurant and gift shop, and most importantly is located in an urban area or close to one. The website also says that several long time employees are no longer with the garden and the new director has been here less than a year. Check it out. The World Botanical Garden should have requested the Special Permit before starting the garden and investing time and money. If you go to the garden today youll see a sign with an artists rendering of their new visitors center and words indicating that this is the site where it will be even though they still dont have the Special Permit to build it. Also, according to their application they still have not officially acquired some of the lands that they are developing. It seems the garden has the cart before the horse. The traffic study they had prepared is flawed. Read it, its hard, its tough reading. Page 2, Section B- Purposes and Objective of the Study - #1. Provide supporting documentation for the Application for Special Permit. This is clearly and admittedly biased. Section C says that the objective of the project was to attract visitors from the background stream along Hawaii Belt Road. This doesnt make sense because they are proposing to transport visitors in tour buses and have 1200 visitors. I mean you dont pull that many people from the background stream and not have any new traffic. 25EXHIBIT C