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Applicantʻs Memorandum in Opposition to First Amended Petition
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2024-05-06 Windward Special Meeting
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(PL-CCH-2024-024) 'Iewe Hanau O Ka 'Aina
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Applicantʻs Memorandum in Opposition to First Amended Petition
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5/2/2024 3:33:41 PM
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5/3/2024 12:00:58 PM
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Document Date
5/1/2024
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Letter from Daryn Arai- Applicantʻs Response
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III. ARGUMENT <br /> A. By Petitioner's very own admission,their concerns are NOT clearly <br /> distinguishable from that of the general public. <br /> At the very beginning of Petitioner's appended narrative attached to their petition, <br /> Petitioner states, "'Iewe Hanau o Ka 'Aina is an unincorporated hui of Ka'u residents who desire <br /> to protect the cultural practices,natural resources, and stunning beauty of Punalu'u. The <br /> protection of iwi and honu are of great importance." <br /> No doubt these values of the protection of cultural practices,natural resources, and <br /> beauty of the 'aina are shared with the general public who call Hawaii their home. In fact,the <br /> State of Hawaii has legislated laws which reflect these values, including the protection of iwi <br /> and the honu. <br /> Recognizing their positions may not be distinguishable from the general public and that <br /> they will lack standing, Petitioner then argue that the term "clearly distinguishable from that of <br /> the general public"has been misinterpreted by lawyers and suggest to this Commission that"all <br /> that needs to be shown is that 'Iewe Hanau o Ka 'Aina and its members would be adversely <br /> affected by the proposed project." <br /> This is a fatal admission by Petitioner. Petitioner's activities in "walk(ing) along the <br /> Punalu'u coastline, swim(ming) at Punalu'u Beach, observ(ing)marine life,provid(ing) <br /> stewardship of the land, work(ing)to protect the honu that live in the area, gather(ing)marine <br /> life, and participat(ing)in cultural protocol"will in fact be enhanced by this project, as it <br /> dedicates 30 acres of shoreline to conservation and will manage the entire shoreline frontage of <br /> the project site to ensure that these special coastal resources can continue to be shared by all <br /> without undue degradation. In sum, the approval of the proposed SMA essentially guarantees <br /> -5- <br /> 3302522x2 <br />
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