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YEH: I do. <br />SUILLIVAN: I do. <br />WATANABE: And I don’t know which one of you would like to start, Mr. Yeh, but, <br />obviously, before you start your testimony, please full name and address for the record. <br />YEH: Yeah, I’ll go ahead and start first. My name is Thomas Yeh, attorney <br />representing the applicant, Katherine Sullivan, who is present here today. My business address <br />is 85 West Lanikaula Street, Hilo, Hawaii. And, first of all, I wanted to thank you all for taking <br />another day out of your busy schedule to show up, because it’s not easy attending one day, full <br />day, let alone two. So thank you for that. <br />It is kind of hard sitting there listening cause it’s not like a point, counter point situation. But I <br />did try to take some notes. And, first of all, just for the record today, those points that were <br />measured I think it was 29 feet and 43 feet from the front property line that we looked at. <br />Second of all, with respect to the first question, were improvements approved prior to November <br />of 2006 by the Planning Department in absence of the certified shoreline in the Kapoho area, the <br />answer clearly yes. And what we did is we submitted first of all with our May 2008 submittal <br />several letters. There’s one Attachment B which is dated March 8, 2005. Now this is in the <br />Kapoho Beach Lots area which is just north of the Vacationland area. And similar issue there, <br />this happened to be my client at the time, John and Sandy Barsell, and basically they were asking <br />for a request for approval of a dwelling on property which abutted the shoreline. And if you take <br />a look at the second page of this exhibit, it’s interesting because we’ve been talking about a 2.8 <br />foot tide and in this letter Planning Department agreed to accept the topo survey that showed <br />elevations referencing the appropriate low tide datum. It had nothing to do with a high tide. <br />WATANABE: I’m sorry, Mr. Yeh. I saw a 4-d. <br />YEH: Well, this would be our Attachment B in our May 5, 2008 submittal. And <br />if you take a look at, it’s a March 8, 2005 letter from the Planning Department agreeing, and this <br />is page 2 at the top of the page, agreeing to accept the topo, well, “by our letter dated August 30, <br />2004, agreed to accept a topographical survey map that shows elevations referenced to the <br />appropriate low tide datum of the subject area in lieu of a Certified Shoreline Survey.” So it’s <br />pretty clear that that was done in that particular case. <br />We represented another client who had been cited for certain violations for renovations of an <br />existing dwelling that happened to be next to the Mayor’s house in Vacationland on the makai <br />side of Wai Opae Road. And in that one there, that’s our Exhibit D to the same transmittal, <br />second page, the 20-foot shoreline setback and the 20-foot shoreline, which we’ll get into a little <br />bit later, applies when you have a lot that was created prior to the shoreline setback law. And as <br />we know, and part of the submittals that we provided you today, was that the Kapoho <br />Vacationland Subdivision was created in 1962, well prior to the shoreline setback law. The rule <br />that we provided to you, which is the Planning Department rule, says that when you have less <br />than 50 percent buildable area remaining after application of shoreline setbacks, building <br />setbacks, then you’re dealing with a 20-foot setback. So we look at page 2 of this letter to me, <br />June 29, 2006, now this is when the Sullivans submitted or had their first survey done, page 2 <br />says “The 20-foot shoreline setback will be measured from the innermost inland projection of the <br />11 <br /> <br />