PL-REZ-2022-000033 NA ALA HELE COMMENTS 12.14.2022

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NA ALA HELE Hawaii Trail & Access System Ref: H03:21, H09:02 Holualoa December 14, 2022 TO: Christian Kay, Planner County of Hawai'i Planning Department U FROM: Jackson Bauer,Trails and Access Specialist V Na Ala Hele Trails and Access Program, DOFAW, DLNR SUBJECT: Change of Zone Ordinance No. 02-131, applicant Kona Three,TMKs (3) 7-6-021:016 and :017 Holualoa, North Kona, Island and County of Hawai'i. The Na Ala Hele Trails and Access Program within the Division of Forestry and Wildlife, Department of Land and Natural Resources, thanks you for the opportunity to comment on the subject Change of Zone.This area was a main population center for pre-contact Hawaiian society and thus contains many important wahi pana and archaeological sites, including trails. As the project proposal has the potential to impact several historic features, including trails, as well as impact public access, our recommendations are as follows: Mauka-Makai Trails: The Holulaloa ahupua'a was a main population center for pre-contact Hawaiian society. Extensive agricultural field systems are present above and within the subject area. Extensive mauka-makai trails were known to connect these agricultural fields with the coastal villages and fisheries, many of which were continued to be used well into the 20'century (See testimony from Goro Inaba, Exhibit A).The community has also shown strong support in preserving these historic trail alignments and public accesses (see petition, Exhibit B). Several maps from the early 20'century,when stitched together, show continuous trails from the coast up to the Mamalahoa Highway and the uplands. (See Exhibits C, D). One of these trails also follows the existing rock wall features that partly formed boundaries of LCA 3660.These double rock walls form a narrow corridor that is consistent with similar trail attributes in the area (for example,Judd Trail).The archeological reports in this area are very detailed and extensive, however, little research was conducted on the known trails and alignments. An important site just below the project area and between this network of trails is the Kealakowa'a Heiau complex. As its name suggests (along with historical accounts and histories), this was an important site in relation to the canoe carving and the hauling of canoes on these mauka-makai trails (Ke ala= "the trail", ko wa'a="for canoes"). Division of Forestry and Wildlife Department of Land and Natural Resources 19 E.Kawili Street,Hilo,HI 96720