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effect on the environment, the Director shall consider every <br />phase of a proposed action and expected consequences, either <br />primary or secondary, or the cumulative as well as the short or <br />long term effect of the proposal. The Director should bear in <br />mind that in most instances, the following factors of a <br />proposal, although not limited to same, may constitute a <br />significant adverse effect on the environment when the <br />proposed use, activity or operation: <br />4) significantly affects the economic or social welfare <br />and activities of the community, County or State; <br />5) involves significant secondary impacts, such as <br />population changes and effects on public facilities; <br />6) in itself has no significant adverse effect but <br />cumulatively has considerable adverse effect upon <br />the environment or involves a commitment for larger <br />actions; <br />10) is contrary to the objectives and policies of the <br />Coastal Zone Management Program and the Special <br />Management Area Guidelines of Chapter 205A, HRS. <br />The applicant admits that he is not willing to provide a public access <br />easement for the existing trail to the beach. The applicant admits that the <br />subdivision without a shoreline access easement is inconsistent with the HCDP <br />(which cites to SMA guideline, HRS section 205A-26) (Application page 17). SMM <br />23-54 is clearly invalid under HRS section 205A-26(2)(C) because it is inconsistent <br />with the Community Plan and the zoning. <br />The SMA minor permit 23-54 is based on the misconception that all of the <br />conservation land is located within proposed Lot 1 when there is a 2002 SLU <br />Boundary Interpretation, included here, that establishes a three hundred foot deep <br />SLU conservation district within proposed Lots 1, 3, and 4. <br />3 <br />APPELLANT EXHIBIT 4, pg. 3 of 5 <br />