Petitioner ʻIewe Hanau O Ka Ainaʻs Reply in Support of its First Amended Petition

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equipment and must be upgraded to safely dispose of sewage generated by current demand. Aqua Engineers called for replacing the entire wastewater treatment facility. Exhibit A at 12. Yet, in its SMA application to the planning commission, Black Sands, LLC indicates that it is not planning any repair or improvements to the wastewater treatment plant. See Application at pages 17-18. On page 18, it declares, "No expansion of the existing sewer system or the wastewater treatment plant is proposed."' If granted intervention, `Iewe Hanau o Ka `Rina will demonstrate that the proposed project violates HRS chapters 6E, 343, 195D, 226, and 205A. It will also show that the impacts of this project are significant, that the project is inconsistent with the objectives and polices of coastal zone management as well as the general plan. Dated: Honolulu, Hawaii, May 2, 2024. /s/David Kimo Frankel Attorney for `Iewe Hanau o Ka `Rina i Please note that Black Sands, LLC says that repair and maintenance of the wastewater treatment facility is imperative. But the treatment plant's owner, whose agent is Black Sands Beach, LLC, is already legally obligated to maintain and repair the plant pursuant to HAR § 11- 62-06(d). This development cannot be used an excuse to correct problems that are already required to addressed. 3