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3/6/24, 12:06 PM Unite Here!Local 5 v.City and Cty.of Honolulu,231 P.3d 423-Haw: Supreme Court 2010-Google Scholar <br /> the plaintiffs'contentions,to wit:(1)whether the plaintiffs'claims are time-barred by the applicable statute of limitations and(2)whether the Environmental Council exceeded <br /> its statutory authority in promulgating the administrative rules regarding SEISs. <br /> A. Statute of Limitations <br /> As previously indicated,the circuit court ruled that Kuilima's first motion for summary judgment based on statute of limitations grounds,which was joined in by the County,was <br /> 445 moot in light of its grant of summary judgment in favor of the defendants.Although the statute of limitations ground was reasserted on appeal before the*445 ICA,neither the <br /> ICA majority nor the dissent addressed this threshold issue.In response to the plaintiffs'application,Kuilima again argues that the plaintiffs'claims are untimely because the <br /> plaintiffs'complaint was filed more than 120 days after"the[p]roject started or allegedly restarted'and when[the plaintiffs]knew or reasonably should have known of the <br /> alleged change in the timing of the[p]roject or the'new circumstances or evidence."'Alternatively,Kuilima argues that the plaintiffs'claims are time-barred because:(1)the <br /> plaintiffs filed the complaint more than thirty days"after[the plaintiffs]had actual knowledge of the DPP's determination that a[]SEIS was not required";and(2)the plaintiffs <br /> filed the complaint"mare than sixty days after[the plaintiffs]had actual knowledge of the DPP's determination that a[]SEIS was not required." <br /> HEPA does not provide limitation periods for actions specifically related to supplemental assessments.However,it appears undisputed,based on the arguments of the parties, <br /> that the limitation periods applicable to EISs are the same for SEISs.Such treatment is seemingly supported by the administrative rules promulgated to further the purpose of <br /> HEPA that generally subject EISs and SEISs to some of the same procedural requirements.See HAIR§11-200-28(indicating that the contents of a SEIS"shall be the same as <br /> required by this chapter for the EIS");HAIR§11-200-29(listing certain procedural requirements,including filing public notices,distribution,and acceptance procedures,and <br /> indicating that such procedures"shall be the same for the supplemental statement as is prescribed by this chapter for an EIS").Thus,pursuant to HRS§343-7,the statute of <br /> limitations for actions related to an EIS—and,consequently,a SEIS—is as follows: <br /> (a)Any judicial proceeding,the subject of which is the lack of[an environmental]assessment required under section 343-5,[Supp.2005I16I]shall be initiated <br /> within one hundred twenty days of the agency's decision to carry out or approve the action,or,if a proposed action is undertaken without a formal determination <br /> by the agency that a statement is or is not required,a judicial proceeding shall be instituted within one hundred twenty days after the proposed action is started.... <br /> (b)Any judicial proceeding,the subject of which is the determination that a statement is required for a proposed action,shall be initiated within sixty days after the <br /> public has been informed of such determination pursuant to[HRS]section 343-3[(Supp.2005)(pertaining to public records and notice)].Any judicial proceeding, <br /> the subject of which is the determination that a statement is not required for a proposed action,shall be initiated within thirty days after the public has been <br /> informed of such determination pursuant to section 343-3.... <br /> (c)Any judicial proceeding,the subject of which is the acceptance of an[EIS]required under section 343-5,shall be initiated within sixty days after the public has <br /> been informed pursuant to section 343-3 of the acceptance of such statement. <br /> (Emphases added.)Inasmuch as the issue here is the DPP's determination that an environmental assessment was not required,subsection(c)above,relating to judicial <br /> proceedings involving"the acceptance of an EIS,"clearly does not apply. <br /> On the other hand,subsection(b)'s limitation period applies to those judicial proceedings related to whether a statement is or is not required and is,thus,seemingly applicable. <br /> For circumstances where the determination involves a statement that is not required,as here,judicial proceedings"shall be initiated within thirty days after the public has been <br /> informed of such determination pursuant to[HRS]section 343-3."HRS§343-7(b).HRS§343-3 provides in relevant part: <br /> 446 (a)All statements,environmental assessments,and other documents prepared under this chapter shall be made available*446 for inspection by the public during <br /> established office hours. <br /> (b)The[OEQC]shall inform the public of notices filed by agencies[(e.g.,the DPP)]of the availability of environmental assessments for review and comments,of <br /> determinations that statements are required or not required,of the availability of statements for review and comments,and of the acceptance or nonacceptance of <br /> statements. <br /> (Emphases added.)With respect to"notices filed by agencies"referred to above,HAIR§§11-200-11.1(relating to"Notice of Determination for Draft Environmental <br /> Assessments")and 11-200-11.2(relating to"Notice of Determination for Final Environmental Assessments"),which are nearly identical,provide in relevant part that, <br /> if the...approving agency[(here,the DPP)]anticipates that the proposed action is not likely to have a significant effect,it shall issue a notice of determination <br /> which shall be an anticipated negative declaration[I17!]subject to the public review provisions of section 11-200-9.1[(setting forth procedures for public review and <br /> comment in negative declaration determination situations)].The...approving agency shall also file such notice with the[OEQC]as early as possible after the <br /> determination is made/.] <br /> HAIR§11-200-11.1 (emphases added)J18]A review of the record reveals no evidence demonstrating that the DPP filed a notice of its determination that a SEIS was not <br /> required with the OEQC,and Kuilima fails to identify any such evidence.Inasmuch as the requisite notice was not provided,there is no date from which to measure the thirty <br /> day limitation prescribed by HRS§343-3(b).Consequently,we conclude subsection(b)is inapplicable under these circumstances. <br /> Kuilima,however,in attempting to convince this court that subsection(b)applies,essentially contends that the plaintiffs'actual knowledge may substitute for the public notice <br /> and argues(in a footnote)that,"[i]n cases where formal publication does not occur,the statute of limitations runs from the date of actual knowledge."'(Citing HRS§91-2 <br /> (1993),I191)Specifically,Kuilima points to various instances when"[m]embers of KNSC[allegedly]admitted to having actual knowledge,"'including,interalia,(1)Shafer's <br /> receipt of DPP's January 19,2006 response letter,indicating that a SEIS was not required,(2)KNSC director Gilbert Riviere's attendance at the February 9,2006 Koolau Loa <br /> Neighborhood Board Meeting when the DPP's February 8,2006 letter was allegedly read aloud,and(3)"at the very latest,"KNSC members'attendance at a March 15,2006 <br /> Sunset Neighborhood Board meeting when Gill allegedly reported DPP's response. <br /> Kuilima's citation to the general provision set forth in HRS§91-2,quoted supra at note 19,and its conclusory statement that,absent formal publication,the statute of <br /> 447 limitations runs from actual notice is unpersuasive.As discussed above,the statute of limitations set forth in HRS§343-7(b)specifically provides that judicial proceedings*447 <br /> "shall be initiated within thirty days after the public has been informed of such determination pursuant to section 343-3."In turn,section 343-3 mandates the OEQC to inform <br /> the public of the DPP's negative declaration upon receipt of such notification from the DPP.See Chock v.Gov't Employees Ins.Co.,103 Hawaii 263,269,81 P.3d 1178,1184 <br /> .(2003)(recognizing that"where there is a plainly irreconcilable'conflict between a general and a specific statute concerning the same subject matter,the specific will be <br /> favored").Thus,given the plain and unambiguous statutory language,coupled with the related administrative rules discussed above,actual knowledge cannot be"substitute[d] <br /> for public notice."Consequently,Kuilima's argument lacks merit. <br /> Finally,with respect to HRS§343-7(a),the period of limitation begins to run upon"the agency's decision to carry out or approve the action,"or,"if a proposed action is <br /> undertaken without a formal determination by the agency that a statement is or is not required,"then the judicial proceeding must be brought 120 days"after the proposed <br /> action is started."In the instant case,although the subdivision application was part of the larger action(i.e.,the project),the specific"action"for statute of limitation purposes <br /> https://scholar.google.com/scholar_case?case=4308700817237546533&q=unite+here+local+5&hl=en&as_sdt=2006 11/17 <br />