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CENTER FOR BIOLOGICAL DIVERSITY'S PETITION FOR STANDING IN A CONTESTED CASE <br /> HEARING <br /> Appendix B <br /> A. The Center interests in this matter are clearly distinguishable from that of the general <br /> public. <br /> The Center for Biological Diversity (the "Center") is a nonprofit corporation dedicated to the <br /> preservation of biodiversity, native species, and ecosystems. The Hawai'i Program focuses <br /> specifically on conserving ecosystems and seeks to ensure that imperiled species are properly <br /> protected from destructive practices across our pae 'aina. Through science, policy, and <br /> environmental law, the Center is actively involved in species and habitat protection issues <br /> throughout Hawai'i, including efforts related to Hawai'i's imperiled plant and animal species, <br /> such as the endangered hawksbill and threatened green sea turtles, and effective <br /> implementation of Federal, State, and County laws. The Center's members have legally <br /> protected interests in the survival and recovery of endangered and threatened species and the <br /> habitats they depend on. The Center's members derive scientific, recreational, cultural, <br /> religious, conservation, spiritual, subsistence, educational, and aesthetic benefits from the <br /> myriad of native plants' and animals' existence in the wild of Punalu'u. <br /> The Center has members with direct interests in the species, habitat, and environment at <br /> Punalu'u that will be injured by the proposed development. Article XI, Section 9 of the Hawaii <br /> Constitution (1978), states: "Each person has the right to a clean and healthful environment, as <br /> defined by laws relating to environmental quality, including control of pollution and <br /> conservation, protection and enhancement of natural resources. Any person may enforce this <br /> right against any party, public or private, through appropriate legal proceedings . . " The <br />