2026-01-05 Exhibit 06_Draft Cultural Impact Assessment and Ka Pa'akai Analysis

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MANAGEMENT SUMMARY Gina McGuire, PhD, prepared a Cultural Impact Assessment (CIA) and Ka Pa`akai Analysis for study area TMK: (3) 1-2-018:001 in Pu'ilima, Kaimu Ahupua`a, Puna District on Hawai`i Island. This CIA and Ka Pa`akai Analysis was designed to identify any valued historical, natural, and cultural resources or practices that may occur in the area, determine if the proposed project will affect the resources or practices, and offer mitigation recommendations for the project. The background research synthesizes traditional and historic accounts and land use history for the project area Kaimu Ahupua`a. The background study illustrated that this region is honored in `olelo no`eau, mo`olelo, and place names. As a result of this work, the cultural significance of the study site within Kaimu has been made clear. Kaimu has a long and sustained history of Kanaka `Oiwi (Native Hawaiian) subsistence,burials, and stewardship, with many of the same `ohana(families) persisting in ancestral homelands through present day. The area has seen many changes over the years,including dramatic geologic activity that filled in Kaimu Bay and displaced many long-term residents, increasing number of non-lineal descendant resident influx and subsequent development, and rapid coastal erosion and subsidence. Geologic activity has made remaining non-lava inundated, ancestral lands and coasts as highly valued kipuka,or refuges for cultural continuity for the Hawaiian people of the Kaimu and Kalapana areas. Following the Mahele land division and distribution act of 1848,no land commission awards(LCAs)were filed in Kaimu given its designation as crown lands. Hawaiian tenants continued to reside there through 1890. The Land Act of 1895 specified that government lands in rural areas be surveyed and granted(with cash payments)as homesteads to both Hawaiian and non-Hawaiian individuals to encourage rural farming. In Kaimu two areas were opened for homesteading,house lots at the shore of Kaimu Bay and agricultural lots in upland Ki`ula and Mokuhulu.Historic maps reveal the enduring rural character of Kaimu through the 10th century, the presence of the Kaipu`uelelu Cemetery site immediately upland of the study area, and the land grant(Gr. 8004)made to C.H. Will. Previous archaeological surveys revealed four Sites of Historic and Indigenous Preservation(SHIP)within the current study area(Spear 1992). These sites include SIHP 50-10-63-18525 and SIHP 50-10-63-18526 (agricultural and habitation mounds), SIHP 50- 10-62-18527 (historic boundary wall), and SIHP 50-10-62-18528 (a modified lava tube). Three of these sites, SHIP 50-10-63--18526, -18527, and -18528 were confirmed during the archaeological field inspection completed of the study area by Clark 2024. SHIP 50-10-63-18525 could not be re- located (Clark 2024). Other documented archaeological sites located within 1 km of the study area include the Kumaka`ula Heiau to the west,the Star of the Sea Church(SHIP 50-10-63-07380)to the north, and the Kaipuuelelu Cemetery (SHIP 50-10-63-02547), a site of about 8,000 burial mounds immediately upland of the study area. Community consultations were performed to obtain information about the cultural significance of the subject property and the surrounding area, as well as to address possible concerns of community members regarding the effects of proposed development on places of traditional importance and cultural practices. Interviews with six individuals knowledgeable about the project lands produced information on its rich cultural history. The Hawaiian families of Kaimu were (and continue to be) sustained by susbsistence-based livelihoods of fishing,gathering,and growing.There are many place names that hold meaning for Kaimu. Closest to the study area is the place name, Kalaehiamoe,the promontory of sleep or rest, potentially inidcating the link of the resting place of the ancestors interred at Kaipu`uelelu to the shoreline. Haleili was identified as the name of the pebble beach to the east of Kaimu Bay that fronts the study area.Kumaka`ula Heiau,located within 1 km of the study area is a spiritual site that remains following the lava flow that inundated Kaimu Bay. Mokuhulu, upland of the study area,is the home to the Hawaiian families who maintain kuleana,responsibility to the fishing and burial grounds of Pu'ilima,the name used by Hawaiian families for the study area.