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TMK (3)2-1-018-013, within 210 feet of my property boundary, without requiring a <br /> completed and signed SMA use permit assessment application under the <br /> requirements of Planning Commission Rules 9-4(u) and 9-10 Assessments. <br /> The guests staying at this location often arrive in large groupsl'1 that drive in <br /> separate cars that causes significant adverse effects on the surrounding <br /> community—blocking vehicles turning onto Oeoe Street from Kalaianaole Street <br /> creating safety issues, tsunami evacuation congestion, diminished fire protection <br /> and access to other emergency services, and unsafe conditions for bicyclists and <br /> pedestrians. Adding a total of 444-SF of cover lanai and an enclosed stairway to <br /> make it easier to run up and down, will expand the capacity to hold gatherings and <br /> parties on premises already illegally used as a four-bedroom short-term vacation <br /> rental. The additional development will draw even more on-street parking and <br /> increase the number of vehicles stacked in the driveway and backing out onto Oeoe <br /> St., which may have a substantial adverse environmental or ecological effect, taking <br /> into account potential cumulative and secondary effects under HRS §205A-22 and <br /> the definition of"Special management area use permit." <br /> A SMA use permit is required not only for the project exempted under No. <br /> PL-SAA-2025-000280, but for the 2025 NUC renewal application because the <br /> "change in the density or intensity of use of land" created by the nonconforming use <br /> certification of the addition of two bedrooms does not have a SMA permit. Under <br /> the standard of review outlined in Planning Commission Rules of Practice and <br /> Procedure, Rule 9-10 Assessment, part (h), Criteria of Significant Adverse Effect, a <br /> 6 <br /> APPELLANT EXHIBIT 19, pg. 6 of 41 <br />