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2026-05-08 COH-Planning Director Amended Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119).pdf
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2026-05-08 COH-Planning Director Amended Motion to Dismiss for Lack of Standing (PL-BOA-2025-000119).pdf
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Standing also requires that the injury be within the "zone of interests" protected or <br />regulated by the relevant statute. Life of the Land, 63 Haw. at 173, 623 P.2d at 439. The <br />Director's determination was made pursuant to Hawaii Revised Statutes Chapter 205A, which <br />focuses on: <br />1. protecting shoreline environmental resources; and <br />2. ensuring public access to the shoreline. <br />See, e.g., Haw. Rev. Stat. § 205A-2. <br />Appellant's complaints regarding traffic, short-term vacation rentals, and non -conforming <br />structures are irrelevant to SMA resource protection. Because these factors cannot legally form <br />the basis of an SMA determination, the Board cannot grant the relief Appellant seeks. An injury <br />that cannot be redressed by a favorable decision is fatal to standing. See Kia'i Wai O Wai'ale'ale <br />u Bd. OfLand and Nat. Res., 157 Hawaii 303, 317, 576 P.3d 816, 831 (2025). <br />D. Appellant's Procedural Non -Compliance <br />Standing requirements ensure that the legal system is not weaponized to delay legitimate <br />property improvements. Mr. Standke's project has been stalled for over a year due to Appellant's <br />unsupported claims and failure to comply with the BOA Rules. Appellant has caused undue <br />delay by her failure to comply not only with BOA Rules 8-2 but also 8-11(d) requiring notice to <br />surrounding property owners. <br />IV. CONCLUSION <br />Appellant has failed to allege a specific, non -conjectural injury related to SMA criteria. <br />Without standing, this Board lacks the jurisdiction to hear the appeal. The Director respectfully <br />requests the Board dismiss the appeal in its entirety. <br />M <br />
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