2024-03-06 PL-SMA-2023-000046 Megan Lamson Testimony

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this SMA request, a new current shoreline and environmental surveys should be conducted before concluding that there will indeed be no adverse impacts to our native wildlife and habitats. We disagree with the Planning Department's recommendation to proceed with this SMA application, saying there will be no substantive environmental and ecological effects, and that no environmental assessment or impact statement is needed. We have already noted (in our 2021 letter about an SMA minor application on this same propoerty) that the past environmental impact statements (from 1998 and 2006 respectively) are both outdated and incomplete. We also appreciate that the Applicant landowner has paid for an updated archeological and flora survey, but the full impacts from this cumulative proposed development will negatively effect coastal and marine ecosystems, and these items have not yet been addressed. Hawai'i Wildlife Fund shares our four key concerns about this proposal: First, Policy 28 in the Ka'u Community Development Plan states that, "On lots that are of least partially within the Special Management Area in the Ko'u CDP Planning Area, establish shoreline setbacks of the earliest stages of the land use planning and development process of o minimum of 1,320 feet(1/4-mile) ...". The proposed location of the 8,000 sq ft, 2.5 story fish market, retail space, and restaurant is located around 200 feet from the coastline, in an area with no existing infrastructure, and as such is not in alignment with this important Ka'u CDP Policy. Second, the SMA application references documents (including a 1988 FEIS and a 2006 Draft EIS) which are not only outdated, but were (in the case of the 2006 DEIS) a major source of conflict in the community, and lacks in sound scientific data collection methodology. See attached for the comment letter drafted to the COH Planning Department from 18 years ago by our current President and Hawaii Program Director. In it, Megan highlights the inadequacies of the 2006 DEIS for then proposed "Sea Mountain" development like them performing a "qualitative survey' of marine resources at Punalu'u because weather and conditions did not allow for researchers to enter the ocean. In summary, both then and now, the shoreline at Punalu'u remains an ecologically sensitive area, home to basking threatened honu (green turtles), nesting endangered honu'ea (hawksbill turtles), resting and hauled out endangered ilioholoikauaua (Hawaiian monk seals), foraging and roosting habitat for 'ope'ape'a (Hawaiian hoary bats) in addition to numerous coastal ponds, tidepools, and nearshore coral reefs with their countless native inhabitants. Other endangered invertebrates that are known from this region include protected species like nalo meli maoli (yellow- faced bees), pulelehua (Blackburn's sphinx moth), pinao (Orange-black damselfly), plus one of the few remaining populations of endangered loulu palms (Pritchordio moideniono). Third, the proposed location of the Welness Center is on lowland dry shrubland, which in itself is a threatened ecosystem type. Past surveys had recognized alahe'e and 'a'ali'i plants in this 9-acre section of the property. We mahalo the Applicant landowner for updating the flora surveys for the area since their 2021 application, and hope that any developments in this "Area 4" that are approved fall outside this ecosystem type or can be mitigated for. We also recommend that any planned landscaping conducted in the entire development include only plants that are both native (endemic, indigenous) to Hawai'i or are canoe plants like niu, noni, 'auhuhu, and are also plants that are able to live in more arid, dry climates so that extra water is not expelled for irrigation. www.wildAaw411 Arp