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• The proposed development could impede access to shoreline areas traditionally used by Native <br /> Hawaiians, in violation of Article XII, Section 7 of the Hawaii State Constitution and Ka <br /> Pa`akai o Ka `Aina precedent set by the Hawaii Supreme Court. <br /> Without adequate study and protection of Native Hawaiian rights and customary access, the project <br /> must not proceed. <br /> With the proposed construction just steps from the shoreline, this project is highly vulnerable to sea <br /> level rise, storm surge, and coastal erosion. The State of Hawaii and Hawaii County both recognize <br /> the increasing threat of climate change, and shoreline development such as this is inconsistent with <br /> future resilience and hazard mitigation goals. <br /> Approving this development could: <br /> • Set a dangerous precedent for further risky shoreline development; <br /> • Create future liability for the County and State due to property damage or public safety threats; <br /> • Disregard the recommendations of the Sea Level Rise Vulnerability and Adaptation Report <br /> (2017), which discourages new shoreline-intensive development. <br /> The growing trend of luxury, large-scale homes in shoreline areas of Kona contributes to the <br /> gentrification and displacement of local families, as well as environmental degradation. The <br /> proposed residence, with multiple bathrooms, garages, and spa facilities, is not aligned with local <br /> housing needs or sustainable land use planning. <br /> Further, there is no evidence that the applicant has addressed the cumulative impacts of such <br /> development on: <br /> • Water demand; <br /> • Wastewater disposal; <br /> • Emergency services access; <br /> • Community character and cultural landscape. <br /> It is unclear whether neighboring residents, local cultural practitioners, and the broader community <br /> have been adequately informed or given a fair opportunity to voice concerns. Public participation is a <br /> key mandate under HRS §205A-26, and the process must not proceed without meaningful community <br /> engagement and transparency. <br /> Based on the concerns outlined above, I strongly urge the Hawaii County Planning Department and <br /> Commission to deny the SMA Use Permit application (PL-SMA-2025-000076)by David Ebenal. The <br /> proposed development poses significant environmental, cultural, and community risks, and does <br /> not align with the goals and policies of Hawai`'s coastal zone management framework. <br /> Mahalo, <br /> Cindy Freitas <br />