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• SMAA, Pg. 25 General plan: The Project Site is designated as a Minor Resort <br /> Area by the General Plan, that designates this area as accommodating no more <br /> than 500 visitor units and providing both active and passive recreational <br /> opportunities commensurate with the scale of development. This is <br /> misinformation as the general cost of minor resort is less than 500,000 dollars. <br /> This development is estimated to have a cost of 200-350 million dollars; which, <br /> clearly exceeds a minor development; therefore, this is a major resort. <br /> The number of units far exceed the 500 units will include: existing colony 1, 76 <br /> units, colony 2, 63 units, Aspen 30 units, Village, 260 units and the 550 units on <br /> the Ninole-Punalu'u Supplemental Zone Map Section 25-8-28. The total unit <br /> between the completed plan is approximately, 979 units. This total amount of <br /> units makes this minor resort a major resort. <br /> • During the time of the first development over a 100 of cultural, historic and <br /> archeological site were destroyed since the project area first began to receive <br /> application approvals and the extent of harm to the cultural landscape and <br /> traditional and customary practices need to be explicitly discussed and <br /> monitored. The mitigation measures from 1988 were not applied due to neglect. <br /> As an example, DLNR,TMK: (3) 9-6-00: 002 were injured and altered during the <br /> course of land alteration activities on 26 June 2017 destruction occurred with <br /> removal of stacked wall which paralleled the shoreline at the wharf. Two <br /> separate piles of concrete rubble remain within the 40-foot set back area where <br /> the operator identified as Simon Vilaj of Hang Loose Tours had demolished two <br /> historical concrete structures. Should there be a storm type wave action piles of <br /> concrete rubble and soil may enter into the ocean. This destruction was <br /> conducted by the previous owner Roberts Hawaii who illegally grub the wharf <br /> area with intent to increase the boat ramp size for tours. This was conducted in <br /> the area of the Punalu'unui Heaiu and moehai pohaku the sacrificial stone. This <br /> was desecration of the historic sugar plantation warehouse structure. The SEIS <br /> will require inventory survey and monitoring the site activity to ensure no <br /> damage. <br /> • Social economic values have changed since rezoning and redistricting of this area <br /> since its first occurrence. For instance, Article XI did not exist, nor did Supreme <br /> Court rulings to protect public trust resources, traditional and customary rights. <br /> The C. Brewer Development contaminated our water wells from plantation and <br /> 9 <br />