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Further SMA approval should be deferred until issues of life and limb are rectified, such as <br /> water, fire hydrants, waste treatment. Assure access for traditional cultural practices, address <br /> shoreline changes and certification, crowd management and safety. If and when further SMA <br /> projects are approved, specific and enforceable conditions, timelines, required permits and <br /> mitigation measures must be provided in detail. <br /> Multiple SMA applications for a large multiphase project are inconsistent with planning policy <br /> and law. Some SMA projects remain incomplete after 2-20 years, and degree of completion of <br /> previously approved SMA(s) is not documented in the current application. <br /> 1: Proximity of proposed development to the shoreline. <br /> Shoreline certification (Waived by PD Zendo Kern in previous SMA) <br /> In this case the shoreline certification is fifty years old, and since that certification, sea level <br /> changes, earthquake, and shoreline subsidence, and climate change would indicate that the fifty <br /> year-old certification may be inaccurate. To site structures near the shoreline and near <br /> documented flood hazards without an understanding of the risks from storm surge and known <br /> changes to the extent of the black sand beach would be irresponsible. <br /> https : //dlnr.hawaii .gov/ld/files/2013/07/Chl3-222—Amend—Compil— <br /> Stand—Revl .pdf <br /> §13-222-11 Validity of certified shoreline . (a) <br /> Certification of the shoreline shall be valid for a <br /> period no longer than twelve months from the date of <br /> certification, <br /> Pursuant to Planning Commission (PC) Rule 9-10(b)(5) &(11), and in order for the Planning <br /> Director to accurately evaluate whether the proposed action will have a substantial adverse <br /> effect, pursuant to PC Rule 9-4(e)(4), the Director shall require that SMA Use Permit <br /> Assessment and Use Permit applications include all of the information necessary to assess the <br /> proposed activity's impacts in the Special Management Area, including but not limited to: <br /> An assessment of impacts on hazard risk, including flooding, tsunami, and coastal erosion <br /> and/or sea level rise over the life of the development(PC Rule 9-10(h)(9)); <br /> The 2006 DEIS notes: Flood: The property includes coastal areas in Zones AE and VE which <br /> represent areas with potential for coastal flooding. Mauka areas designated in Zone X were <br /> determined to be outside the 500-year floodplain. <br /> Hurricane: The Punalu'u coast is potentially susceptible to hazards from Pacific hurricanes <br /> generated off the Coast of Mexico. Based on historical tracks and computer simulations <br /> Hawaii County is at the greatest risk of impact from hurricanes (Hwang,page 43). Hurricane <br /> hazards include drainage from high winds in excess of 74 mph and flooding due to heavy <br /> D Ward Comments 2 <br />