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2026-5-27 ROHR EXHIBIT 4_v1.pdf
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2026-5-27 ROHR EXHIBIT 4_v1.pdf
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2026-5-27 ROHR EXHIBIT 4_v1.pdf
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Under HCC Chapter 34 Public Access, even a two -lot subdivision of parcel <br />118, on top of a previous four lot subdivision, reaches the six lots or more limit in <br />the definition of "Subdivision" requiring an easement for public access to the <br />shoreline at Papaikou Landing beach which is used by the public for recreation. <br />("Subdivision" for the purpose of this chapter, means any improved or unimproved <br />land or lands divided or proposed to be divided for the purpose of disposition into six <br />or more lots or parcels.)(Public Access Code, Section 34-3(a)(15)). <br />Even if the applicant comes back with a different subdivision plan, a SMA <br />minor permit would be invalid considering the possible damage to the resources of <br />the SMA from earth disturbing activities and eco-tourism and film industry <br />activities on the beach that the applicant erroneously believes is privately owned. <br />("The Director shall consider every phase of a proposed action and expected <br />consequences, either primary or secondary, or the cumulative as well as the short or <br />long term effect of the proposal.")(PC Rule 9-10(h) Criteria of Significant Adverse <br />Effect). <br />The Planning Department is statutorily mandated to give effect to the <br />policies, objectives and guidelines of the Coastal Zone Management Act (CZMA), <br />reading HRS § 205A-2 and §205A-26 in conjunction with the Planning <br />Commission's Rules of Practice and Procedure and Hawaii County Code Chapter 34 <br />Public Access, as well as in the context of the entire CZMA. <br />0 <br />APPELLANT EXHIBIT 4, pg. 4 of 5 <br />
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