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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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(c) . . all lands with soil classified by the land study <br /> bureau's detailed land classification as overall (master) <br /> productivity rating class C, D, E, or U shall be restricted to <br /> the uses permitted for agriculture district as set forth in <br /> section 205-5 (b) . (emphasis added) <br /> to . Section 205-5(b), Hawaii Revised Statutes in turn states: <br /> (b) Within agricultural districts, uses compatible to the <br /> activities described in section 205-2 as determined by the [state <br /> land use] commission shall be permitted; provided that accessory <br /> agricultural uses and services described in sections 205-2 and <br /> 204-4.5 may be further defined by each county by zoning ordinance <br /> . . . (emphasis added) 4 <br /> Planning Director's "Closure Letters" <br /> 11. In February of 2022, the Appellee Planning Director sent <br /> identical "closure letters" to each of the complainants referred to in Part A. 4, <br /> supra, stating that: <br /> The Planning Department received your complaint alleging <br /> that the property located at 81-905 Makahiki Lane, Captain Cook <br /> is operating a Short-Term Vacation Rental ("STVR") , without <br /> approvals from the Planning Department ("PD") and that the parcel <br /> is located within an Agricultural Project District ("APD") . <br /> Based on the findings and the definitions provided above, <br /> we have determined that the parcel in question is not in viola- <br /> tion of the Hawaii County Zoning code, Chapter 25 or County <br /> Ordinance 97-133 . This case is now closed. (emphasis added) <br /> (Dkt. 16, JEFS page 60, ROA 060-109; Dkt. 19, JEFS 2, ROA 151-153; JEFS <br /> page 5, ROA 154-156, 157-159, 160-162; Dkt. 40, JEFS page 1, ROA 001-003; <br /> JEFS 65, ROA 065-093; Dkt. 41, JEFS page 1, ROA 094-114) <br /> 12. In his "closure letters," the Appellee Planning Director did <br /> not direct the complainants to the specific sections of published laws that <br /> declare transient accommodation activity to be a direct permitted use in the <br /> The process by which the State Land Use Commission is to make its <br /> "determination" is not clear, whether the commission is to make that <br /> "determination" by way of adjudication or by rule-making. See In Re <br /> Hawaiian Electric Company, Inc. , 81 Haw. 459, 465-467, 918 P.2d 561, <br /> 567-569 (1996) (distinction between rule-making and adjudication) . <br /> 5 <br />
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