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TORKILDSON KATZ <br /> A Law Corporation <br /> LINCOLN S. T. ASHIDA 4478-0 <br /> 120 Pauahi Street, Suite 312 <br /> Hilo, HI 96720 <br /> Telephone: (808) 961-0406 <br /> Facsimile: (808) 961-3815 <br /> Attorneys for Applicant <br /> BLACK SAND BEACH LLC <br /> BEFORE THE WINDWARD PLANNING COMMISSION <br /> COUNTY OF HAWAI'I <br /> STATE OF HAWAI'I <br /> In the Matter of: PL-CCH-2024-000023 <br /> Development of a Residential and APPLICANT BLACK SAND BEACH <br /> Commercial Community Consisting of LLC'S MEMORANDUM IN OPPOSITION <br /> Approximately 225 Residential and Short TO THE CENTER FOR BIOLOGICAL <br /> Stay Units,Village and Wellness Center, DIVERSITY'S PETITION FOR <br /> Retail Uses, Rehabilitation of Golf Courses, STANDING IN A CONTESTED CASE <br /> and Dedication of a Portion of Coastline as a HEARING; CERTIFICATE OF SERVICE <br /> Conservation Area <br /> Hearing Date: May 6, 2024 <br /> Hearing Time: 9:00 a.m. <br /> APPLICANT BLACK SAND BEACH LLC'S MEMORANDUM IN OPPOSITION TO <br /> THE CENTER FOR BIOLGICAL DIVERSITY'S PETITION FOR STANDING IN <br /> CONTESTED CASE HEARING <br /> Applicant BLACK SAND BEACH LLC ("Applicant") by and through their undersigned <br /> counsel, hereby submits the following Memorandum in Opposition to the CENTER FOR <br /> BIOLOGICAL DIVERSITY'S ("CBD") Petition for Standing in a Contested Case Hearing. <br /> L BACKGROUND <br /> "Black Sand Beach LLC has done tremendous things for our community. Giving a local <br /> nonprofit 3 acres of land and 2 greenhouses to garden through the pandemic...donated <br /> cattle to help feed the community. They have donated to the hospital as well as Naalehu <br /> Elementary School. <br /> "I say if not Black Sand Beach LLC,then who? No other company that has come to <br /> Ka`u ever thought about the community and their needs. They want to help preserve the <br />