2024-03-04 PL-SMA-2023-000046 Nohea Ka'awa Members of SMA2023-046 Working Group Opposition Testimony

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Pursuant to Planning Commission (PC) Rule 9-10(b)(5) & (11), and in order for the Planning Director to accurately evaluate whether the proposed action will have a substantial adverse effect, pursuant to PC Rule 94(e)(4), the Director shall require that SMA Use Permit Assessment and Use Permit applications include all of the information necessary to assess the proposed activity's impacts in the Special Management Area, including but not limited to: An assessment of impacts on hazard risk, including flooding, tsunami, and coastal erosion and/or sea level rise over the life of the development(PC Rule 9-10(h)(9)). Fire: Eight of eighteen fire hydrants are currently inoperable; many have rusted at the base and several have fallen over. With the annual fires encountered within Punalu`u and the confines of this SMA, we request that hydrants be repaired before other projects are initiated. From 2006 DEIS, the project area is located in an area susceptible to brush fires. Brush fires could easily spread onto the project site without adequate fire buffers on the project perimeter. The County Fire Department, Colony 1 Condo, and Punalu`u Mauka (Kalana Estates) residents have pushed to address these issues but in 4 years of black sands beach LLC ownership, these fire hydrants are still out of order. For first hand information on infrastructure issues please contact Jeff Silva who is a board member condo owner colony one, grade 4 licensed water distribution system operator, grade 1 system operator and resident of Punalu`u and works for the Hawaii County Fire Department in Pahala (808)345-8024. Flooding: Three of seven bridges were repaired in 2021 between Honu`apo and Pahala Hospital. The Punalu`u property includes coastal areas in zones AE and VE which represent areas with potential for coastal flooding. Mauka areas designated in zone X were determined to be outside of the 500-year floodplain. With the impacts that Rapid`Ohi`a Death is having within our Ka`u Forest Reserve (directly mauka of the property) and the dying off of our Kupuna trees, we can expect to see heavier flooding conditions and severe runoff with major debris at levels we have not encountered before. Four bridges have not been updated with repairs, three of which are located between Punalu`u and the newly-built emergency shelter in Pahala, we have reason to insist that repairs to the remaining bridges be completed prior to addressing the potential for any new development. Tsunami: The Federal Emergency Management Agency flood insurance rate map indicates areas of potential tsunami inundation on the coastal areas of the property. Due to its historic exposure to tsunami hazards, the risk of future tsunami inundation is significant in the coastal zone and must be addressed. Lava flows: The project area is within lava hazard zone 3, 3 with one posing the greatest hazard and 9 posing the least, indicating a moderate to severe hazard. . An active cinder cone sits within the proposed development area. This cinder cone is the arm of the southwest flank of Mauna Loa, which means that a future eruption could potentially begin from within this cinder cone. There is a reason why the adjacent lands to the northeast and southwest are undeveloped. We believe that any development in this area is subject to inundation by future flows, and without addressing evacuation routes and wildfire mitigation measures, no new developement should even be considered.