2026-6-26 APPELLANTS OBJECTIONS TO PROPOSED ORDER_v1.pdf

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18. Oe Oe Street, and surrounding neighborhood streets, are used by the public for overflow parking to access nearby beach parks. 19. The most direct route from Hilo, the origin of emergency services, to Appellant's residence does not utilize Oe Oe Street. The emergency evacuation route from Appellant's residence to safety does not utilize Oe Oe Street. Appellant may access nearby beach parks by using Oe Oe Street, and other neighborhood streets. By failing to address and enforce the Landowners' violations of the zoning code and other State laws at the SMA review stage, the Planning Director violated the Special Management Area policy for managing development: HRS §205A-2(c) (7)(A): "Use, implement, and enforce existing law effectively to the maximum extent possible in managing present and future coastal zone development." [page 4, #1.] Rohr objects on the grounds that Fact 18 assumes facts not in evidence and contradicts the Second Amended Petition allegations: On -street parking and egress issues at 14 Oeoe Street are directly traceable to the transient accommodation guests. The guests often arrive in large groups that drive in separate vehicles. The vehicles backing into 14 Oeoe Street or into the driveway cause cumulative impact and/or significant adverse effects on the surrounding community— blocking vehicles turning onto Oeoe Street from Kalaianaole Street, creating tsunami evacuation congestion, diminished fire protection and access to other emergency services; and unsafe conditions for bicyclists and pedestrians. [page 6.] Rohr objects on the grounds that Fact 19 contradicts the Second Amended Petition factual allegations that the Board must assume "as true and construe [them] in the light most favorable to [Rohr]", as follows: I rely on Oeoe Street to take my walks down to Leleiwi and Richardson's beaches, to access my driveway at 369 Nene Street, and to receive emergency services, including fire trucks that hook up to a fire 14