2026-01-05 Exhibit 10_SHPD Comments

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Jeff Darrow November 21,2025 Page 2 Additionally,no use,land alteration or vertical construction will be permitted within the 40-foot shoreline setback area as established by a shoreline survey of the subject property certified by the Board of Land and.Natural Resources on March 29,2023. The HICRIS submittal data and materials indicate that the proposed project area has been included as part of previous archaeological studies (Spear 1992, Doc. No. 9302ks25; and Clark 2024, Doc. No. 2409JG07) that resulted in the identification of historic properties. Per the submitted construction plans, none of the previously identified historic properties are located within the current permit area. SHPD received additional information subsequent to the initial submittal (Submission Nos. 2025PR01081.003 and 2025PR01081.004) that indicates that the proposed project area has been previously disturbed. SHPD previously reviewed an SMA permit (Permit # PL-SMA-2024-000063 [see above for previous project scope description]; HICRIS Project No. 2024PR00930; Doc. No. 2409JG07) in which SHPD reviewed a field inspection letter report (Clark 2024) and made a then-project effect determination of"No historic properties affected."The submitted CIA report(McGuire,October 2025)indicates that the coastline of Kaimu was a significant area to pre-contact and post-contact communities linked to traditional cultural practices.Moreover, interviews contained therein also indicate that a concern of the area is the potential for encountering subsurface deposits within the project area given the existing cemetery across the street from the subject parcel and the preservation of a coastal trail that that has not been identified by the previous studies(Spear 1992; and Clark 2024). Per correspondence (Joshua Gastilo [SHPD] to Jackson Bauer [DLNR DOFAW]; see HICRIS submittal materials), the trail alignment referred to in the CIA report(McGuire,October 2025)correlates with the existing highway corridor. While the proponent has previously indicated that the ground surface of the proposed project area is a result of a 1960s lava flow;available data and the submitted field inspection letter report(Clark 2024)specifically indicates the that the project parcel lies atop a"Puna basalt flow that erupted between 400 and 750 years before present(BP)forming much of the central and southern part of the parcel; a younger Puna basalt flow of'al lava dating to 200-400 years BP creating the northeastern edge;and a more recent pahoehoe flow that occurred between 1986 and 1992 present at the coast."The portion of the youngest flow(between 1986 and 1992)located in the project parcel is outside of the current project area.Moreover,the subject project area may lie within a previously disturbed area that that may have removed any surface features;however,any ground altering activity has the potential to impact subsurface features beneath the existing surface flow,including burials.Additionally,the portion of the lava flow on which the project is proposed is comprised of`a`a lava.Due to the nature of'al lava,potential exists for any unidentified historic properties,including human skeletal remains/burials to have fallen into the cracks and crevices and to have been deposited in subsurface contexts. Based on the information provided and the sensitivity of the area,SHPD has insufficient information to determine the potential for the project to adversely impact significant subsurface historic properties, including human skeletal remains/burials. Therefore, SHPD requests that archaeological monitoring be conducted for identification purposes during all ground disturbing activities to adequately identify any archaeological historic properties present and, if identified,to determine potential impacts to them,and to ensure that appropriate mitigation is implemented. SHPD looks forward to receiving for review and acceptance an archaeological monitoring plan(AMP) meeting the requirements of HAR §13-279-4 prior to permit issuance. Please submit the requested AMP and associated filing review fee to HICRIS Project No.2025PR01081 in response to our HICRIS request. SHPD will notify the County of Hawaii Planning Department when the AMP has been reviewed and accepted, and the permit issuance process may continue. Please contact Traven Apiki at traven.apikighawaii.gov for any questions regarding burials and Joshua Gastilo at Joshua.gastiloga.hawaii.gov for any questions regarding archaeological resources or concerns regarding this letter. Aloha, —/Of)6-7) Jessica L.Puff Administrator, State Historic Preservation Division Deputy State Historic Preservation Officer