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

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The interviewees described rich cultural practices,archaeological sites,and the vibrant landscape of mo`olelo in the surrounding area. They shared the rich connection between Mokuhulu and the Pu'ilima study area. Each of the interviewees recalls being taken by kupuna to engage in fishing and/or marine provisioning practices along the oceanfront of the project area and surrounding coastline. Traditional burial practices for iwi kupuna at Kaipu'uelelu remain within living memory and in continued practice today. Many treasured memories of this area and time spent there with their elders and ancestors were shared by the interviewees. The interviewees established a clear connection between the Kaipu'uelelu burial ground across the street and the study area,with a variety of relationships between the upland area and the coastline established. These include the feeding of the kupuna trees and fishing grounds of Pu'ilima from ancestors'bodies and spirits, leina for these ancestors, and kinolau-based communication from ancestors (e.g. `opihi ko`ele). The many kaona associated with the place names of Kalaehiamoe,Kaipu'uelelu,Pu'ilima,and Makena suggest a site of great mana,of healing practices, and as a place for ancestors to rest in slumber. Cultural practices within the project area include aukai and pikai(cleansing and rinsing after burial practices) and gathering and fishing grounds for a variety of species including plants for medicinal uses (ko`oko`olau, `uhaloa, and `ohi`a) and weaving (lauhala), fish (ulua, aholehole, enenue, po`opa`a, moi, menpachi, aweoweo, kole, and pao`o), limu: limu (general) and limu kohu, and invertebrates (`opihi, lobsters, and `a`ama crab). This stretch of coastline is used for `ohi`a-pole based ulua fishing. Howard Konanui spoke of brackish pools where families from Mokuhulu would wash and dry clothes. The most archaeologically significant site near the project area includes the Kaipu'uelelu Cemetery, immediately upland of the project area. The interviewees recall many ancestors who are buried there,including family that they have laid to rest there. The proposed project may negatively affect cultural resources and practices including destruction of a storied gravesite, diminishing fishing and cultural access, and altering one of the few remaining ancestral stretches of coastline in Kaimu. Of immediate concern is the harm that has already been done to the historic coastal trail that connects the study area to the neighboring `a`a coast to the east and to upland Mokuhulu and to agricultural and habitation mound, SHIP 50-10-63-18525. Concerns include gating of the property(already discouraging public access),introduction of invasive species, destruction of the ancestral milo and noni grove that was on the property,and disrespect to the many Hawaiian ancestors buried in immediately surrounding lands. Concerns include the impact of increased human waste into the porous lava rock of the study area through the proposed septic system(s) into groundwater and marine gathering grounds that lineal descendants depend on. Historic sites that have and may be affected include SHIP 50-10-63-18525, -18526, -18527, and - 18528. Interviewee concerns include: • The study area is part of a cultural and burial complex that has ancestrally, is actively, and will continue to serve as a site of great significance for the Native Hawaiian communities of Pu'ilima,Kalaehiamoe,Kaipu'uelelu, and Makena. • Any building or construction that occurs within the project area will obstruct the leina(jumping off point for spirits). • The project area is known to be home to the burial site of ancestor Makapo Kaho`okaulana. • Development will place waste into the ground which will affect the limu,intertidal zone, and fish that lineal descendants depend on to sustain subsistence-based livelihoods. • There are few stretches of coastline in Kalapana that have ancestral milo groves like the ones within the project area that have been harmed by recent land clearing.