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to, Paragraph 6 and Sub-Paragraphs a, b and c, which talk about the identity and scope of <br />these valued resources, the extent to which they’re affected or impaired, and the feasible <br />action, if any, to be taken. And as I mentioned in an earlier case this morning, these are <br />requirements which were put into your SMA rules in January, I believe it was <br />st <br />January 21 of 2006; and these came and they were passed by this Commission. And <br />they were inserted in there as a result of two very important, three very important legal <br />actions that were taken. And one of them was the PASH decision regarding traditional <br />and customary gathering rights, I believe you know about this. <br />No. 3 was Act 50 passed by the Legislature relating to the cultural impact assessments. <br />And, No. 4, from which Act 50 partially emanated was the Ka Pa‘akai case. Both Ka <br />Pa‘akai and the PASH cases were adjudicated by the Hawai`i State Supreme Court. And <br />in those particular cases, there were certain requirements that the court mandated be part <br />of certain applications. And, indeed, the preamble to your current rules, Rule 9, Section <br />1, Purpose, takes that into consideration; and, so, I won’t refer to the numbers, you can <br />look at them yourself. <br />While Mr. Fuke and I, who know each other quite well and are friends, I think I regard <br />Mr. Fuke as a friend, may disagree on this, I want to caution you that the current <br />application for an SMA Management Area Permit does not fulfill the law, not even by a <br />long shot. And if you pass this, whether today, next month, two months, and you do not <br />have a Cultural Resource Management Plan, No. 1, which is required by law, by the <br />County law, and if you do not have a cultural impact assessment which is required by <br />your Rule 9, which emanates from the State law and also Supreme Court decisions, you’ll <br />be in deep trouble for this. <br />And let me tell you what the scope of the work for this assessment must contain, and I’m <br />going to put it on the record, and I’m reading this verbatim, are the OEQC guidelines that <br />were referred to earlier. I’m sorry, Mr. Chairman, I’m taking more than three minutes, <br />but it’s very important for you to know this, ‘cause there are new Commissioners here <br />who might not be aware of it. <br />In order to constitute appropriate, I’m not quoting yet, to constitute an appropriate <br />assessment, the scope of work for the assessment has to include, and now I quote, <br />“(1) identify and consult with individuals and organizations with expertise concerning the <br />types of cultural resources, practices and beliefs found within the broad geographical <br />area,” this has not been done, “e.g., district or ahupua`a.” “(2) identify and consult with <br />individuals and organizations with knowledge of the area potentially affected by the <br />proposed action”, this has not been done. “(3) receive information from or conduct <br />ethnographic interviews and oral histories with persons having knowledge of the <br />potentially affected area,” that has not been done. “(4) conduct ethnographic, historical, <br />anthropological, sociological, and other culturally related documentary research”, some <br />of that has been done for this area related to other projects but it has not been <br />incorporated nor has been considered, in my estimation, in the report before you. And <br />“(5) identify and describe cultural resources, practices and beliefs located within the <br />potentially affected area”, not been done. Some, there has been some identification of the <br />EXHIBIT C <br />14 <br /> <br />