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effect on the environment, the Director shall consider every <br /> phase of a proposed action and expected consequences, either <br /> primary or secondary, or the cumulative as well as the short or <br /> long term effect of the proposal. The Director should bear in <br /> mind that in most instances, the following factors of a <br /> proposal, although not limited to same, may constitute a <br /> significant adverse effect on the environment when the <br /> proposed use, activity or operation: <br /> 4) significantly affects the economic or social welfare <br /> and activities of the community, County or State; <br /> 5) involves significant secondary impacts, such as <br /> population changes and effects on public facilities; <br /> 6) in itself has no significant adverse effect but <br /> cumulatively has considerable adverse effect upon <br /> the environment or involves a commitment for larger <br /> actions; <br /> 10) is contrary to the objectives and policies of the <br /> Coastal Zone Management Program and the Special <br /> Management Area Guidelines of Chapter 205A, HRS. <br /> The applicant admits that he is not willing to provide a public access <br /> easement for the existing trail to the beach. The applicant admits that the <br /> subdivision without a shoreline access easement is inconsistent with the HCDP <br /> (which cites to SMA guideline, HRS section 205A-26) (Application page 17). SMM <br /> 23-54 is clearly invalid under HRS section 205A-26(2)(C) because it is inconsistent <br /> with the Community Plan and the zoning. <br /> The SMA minor permit 23-54 is based on the misconception that all of the <br /> conservation land is located within proposed Lot 1 when there is a 2002 SLU <br /> Boundary Interpretation, included here, that establishes a three hundred foot deep <br /> SLU conservation district within proposed Lots 1, 3, and 4. <br /> 3 <br />