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Jeff Darrow <br /> November 21,2025 <br /> Page 2 <br /> Additionally,no use,land alteration or vertical construction will be permitted within the 40-foot shoreline setback area <br /> as established by a shoreline survey ofthe subject property certified by the Board of Land and Natural Resources on <br /> March 29,2023. <br /> The H1CRIS submittal data and materials indicate that the proposed project area has been included as part ofprevious <br /> archaeological studies (Spear 1992, Doc. No. 9 o2ks2 ; and Clark 2024, Doc. No. 2 9J o7) that resulted in the <br /> identification of historic properties. Per the submitted construction plans, none of the previously identified historic <br /> properties are located within the current permit area. SHPD received additional information subsequent to the initial <br /> submittal (Submission Nos. 2025PR010 1.003 and 2 2 PRolo l.00 ) that indicates that the proposed project area <br /> has been previously disturbed. SHPD previously reviewed an SMA permit (Permit # PL- MA-2o2 -0000 3 [see <br /> above for previous project scope description]; HICRIS IS Project No. 202 PR00930; Doc. No. 2 09J 07) in which <br /> SHPD reviewed a field inspection letter report (Clark 2024) and made a then-project effect determination of"No <br /> historic properties affected."The submitted CIA report(McGuire,October 2025)indicates that the coastline of Kaimu <br /> was a significant area to pre-contact and post-contact communities linked to traditional cultural practices. Moreover, <br /> interviews contained therein also indicate that a concern of the area is the potential for encountering subsurface <br /> deposits within the project area given the existing cemetery across the street from the subject parcel and the <br /> preservation of a coastal trail that that has not been identified by the previous studies(Spear 1992;and Clark 2024). <br /> Per correspondence(Joshua Gastilo ISHPD] to Jackson Bauer [DLNR DOFAW]; see HICRIS IS submittal materials), <br /> the trail alignment referred to in the CIA report(McGuire,October 2025)correlates with the existing highway corridor. <br /> While the proponent has previously indicated that the ground surface ofthe proposed project area is a result ofa 1960s <br /> lava flow;available data and the submitted field inspection letter report(Clark 2024)specifically indicates the that the <br /> project parcel lies atop a"Puna basalt flow that erupted between 400 and 750 years before present(BP)forming much <br /> of the central and southern part of the parcel; a younger Puna basalt flow of'ea lava dating to 200-400 years BP <br /> creating the northeastern edge;and a more recent pahoehoe flow that occurred between 1986 and 1992 present at the <br /> coast."The portion of the youngest flow(between 1986 and 1992)located in the project parcel is outside of the current <br /> project area.Moreover,the subject project area may lie within a previously disturbed area that that may have removed <br /> any surface features;however,any ground altering activity has the potential to impact subsurface features beneath the <br /> existing surface flow, including burials. Additionally,the portion ofthe lava flow on which the project is proposed is <br /> comprised of`a`a►lava.Due to the nature of`a` lava,potential exists for any unidentified historic properties,including <br /> human skeletal remains/burials to have fallen into the cracks and crevices and to have been deposited in subsurface <br /> contexts. <br /> Based on the information provided and the sensitivity of the area,SHPD has insufficient information to determine the <br /> potential for the project to adversely impact significant subsurface historic properties, including human skeletal <br /> remains:`burials.Therefore,SHPD requests that archaeological monitoring be conducted for identification purposes <br /> during all ground disturbing activities to adequately identify any archaeological historic properties present and, if <br /> identified,to determine potential impacts to them,and to ensure that appropriate mitigation is implemented. <br /> SHPD looks forward to receiving for review and acceptance an archaeological monitoring plan(AMP) meeting the <br /> requirements of HAIL §13-279-4 prior to permit issuance. Please submit the requested AMP and associated filing <br /> review fee to HICRIS Project No.202 PR010 l in response to our HICR1S 1 request. <br /> SHPD will notify the County of Hawaii Planning Department when the AMP has been reviewed and accepted,and <br /> the permit issuance process may continue. <br /> Please contact Traven Apiki at traven.apiki@hawaii.gov,hawaii.gov for any questions regarding burials and Joshua Gastilo at <br /> Joshua.gastilo@hawaii.gov_ for any questions regarding archaeological resources or concerns regarding this letter. <br /> Aloha, <br /> "-lerjrb <br /> Jessica L.Puff <br /> Administrator,State Historic Preservation Division <br /> Deputy State Historic Preservation Officer <br />