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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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supersede or otherwise affect the complaints that the complainants had earlier <br /> sent to the Appellee Planning Director. The letter on its face informs the <br /> Appellee Planning Director that the State Land Use Commission had recently <br /> rendered a declaratory order on the subject, nothing more (Part A.18, supra). <br /> 29. The Appellee Ford, et al.'s petition to the Appellee Board of <br /> Appeals (Dkt. 16, JEFS page 1, ROA 001-004), which is written on the county's <br /> pre-printed form (Revised April 2021), states: <br /> Nature of Appeal and Relief Requested <br /> On February 15, 2022, the Planning Director dismissed the <br /> Appellants' complaints ... because he believed that the use of the lot <br /> [Neal and Zanone's lot] for transient rental activity in the State Land Use <br /> (SLU) Agriculture District as well as in the County Agriculture Zoning <br /> District and County Agricultural Project District is a permitted use. 11 <br /> The Planning Director erred and the Appellants ask the Board of <br /> Appeals to reverse his decision. <br /> Statement of Error <br /> (1) ..... [T]he State Land Use Commission, acting under Section <br /> 205-5(b), HRS, recently held that transient rental activity of a lot that is <br /> located in the SLU Agriculture District is not a permitted use. 12 The <br /> Planning Director did not address the foregoing subjects in his decision. <br /> (2) ..... However, such activity [transient rental activity] is still <br /> subject to the provisions of Chapter 205, HRS and the State Land Use <br /> Commission's jurisdiction (see Point 1). <br /> (3) ..... Ordinance 97-133 requires the land in the Project <br /> District be used in conformance with Chapter 205, HRS and all <br /> applicable laws. <br /> The use of land that is located in these districts are covered by <br /> Chapter 25, Hawaii County Code (the Zoning Code) , in which the Hawaii <br /> County Council describes the kinds of uses that are allowed in a <br /> specific zoning district. <br /> 'Z See discussion in Part A.10, supra. Since the soil productivity <br /> rating for the Appellees Neal and Zanone's property is Class C, <br /> Section 205-5 (b) , Hawaii Revised Statutes directs the State Land Use <br /> Commission to "determine" the kind of activity that is "compatible" <br /> with the activities set forth in Section 205-2 (d) , Hawaii Revised <br /> Statutes. <br /> 11 <br />
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