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POSITION STATEMENT ON PETITION TO INTERVENE IN GENERAL PETITION <br /> FOR APPEAL OF DECISION BY PLANNING DIRECTOR,DATED JULY 3, 2024 <br /> Pursuant to Rule 2-7 of the County of Hawai`i ("County")Board of Appeals ("BOA") <br /> Rules of Practice and Procedure, 1250 Oceanside, LLC ("Oceanside"), by and through its <br /> attorneys, Carlsmith Ball LLP, files this Position Statement in response to the Petition to <br /> Intervene in General Petition for Appeal of Decision by Planning Director("Petition") filed by <br /> C & J Coupe Family Limited Partnership ("Coupe") on July 3, 2024. <br /> I. INTRODUCTION <br /> Given the context and history behind the present appeal, Oceanside does not generally <br /> oppose Coupe's request to intervene. However, Oceanside files this Position Statement to object <br /> to and correct the many mischaracterizations and misrepresentations in Coupe's Petition. <br /> II. BACKGROUND <br /> The background and procedural history behind this appeal is set forth in detail in <br /> Oceanside's General Petition for Appeal of Decision of the Planning Director, filed May 28, <br /> 2024. The following only provides the information necessary to respond to Coupe's Petition. <br /> Oceanside is the current developer of the master-planned residential community known <br /> as Hokuli`a("Hokuli`a") located on the Kona Coast in Kealakekua, Hawai`i. Hokuli`a is being <br /> developed pursuant to a number entitlements issued by the County, including rezoning <br /> Ordinance No. 96-7 ("Ordinance No. 96-7") and rezoning Ordinance No. 96-8 ("Ordinance <br /> No. 96-8"; together, the "Ordinances"). The Ordinances, as well as other entitlements, were <br /> later incorporated into a Development Agreement, dated April 20, 1998 (the"Development <br /> Agreement"), between the County and Oceanside's predecessor-in-interest. <br /> Relevant to this appeal, the Ordinances required the construction of the following <br /> roadways: <br /> 4885-9189-8831.1.051730- 000581 <br />