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(10) is contrary to the objectives and policies of the Coastal Zone <br /> Management Program and the Special Management Area Guidelines <br /> of Chapter 205A, HRS. <br /> "Special Management Area Use Permit" means an action by the authority <br /> authorizing development ...which may have a substantial adverse environmental or <br /> ecological effect, taking into account potential cumulative effects." §205A-22 <br /> Definitions. <br /> "Special management area use permit" procedures under Planning Commission <br /> Rule 9-4(u) definitions and Rule 9-11 are required as a matter of law. <br /> Dated: Hilo, Hawaii, November 7, 2025. <br /> Respectfully submitted, <br /> RcriLv- <br /> CLAUDIA ROHR, <br /> Plaintiff Pro Se <br /> 8 <br />