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

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I. Rohr's General Objections. Appellant's Objections To The Proposed Conclusions Of Law Appellant submits her formal objections to the Proposed Conclusion of Law regarding standing. Specifically, Appellant objects to the conclusion that she "failed to plead sufficient, non -speculative facts to establish that she is an aggrieved person pursuant to BOA Rule 8-2." A. Appellant's Objections To The Proposed Factual Findings The Proposed Order Fails to Acknowledge the Ultimate Fact: The Planning Director's conduct that is the cause of Rohr's threatened injury -in -fact from hazardous road conditions on Oeoe St. is his issuance of a SMA exemption without a condition for off-street parking on the building plans that STVRs are required to construct. The Proposed Order Erred By Ignoring Specific Factual Injuries: The Director's proposed Order, like the Motion to Dismiss, fails to acknowledge that because Rohr relies on Oeoe Street to take her walks down to Leleiwi and Richardson's beaches, to access her driveway at 369 Nene Street, and to receive emergency services, including fire trucks that hook up to a fire hydrant on the corner of Oeoe Street and Kalanianaole Street, Rohr will suffer an actual or threatened injury -in -fact from hazardous road conditions on Oeoe St. directly traceable to STVR guests backing out of the driveway at 14 Oeoe St for lack of off-street parking. It follows that the injuries to Rohr's interests can be remedied with a condition on an exemption determination to add off-street parking to the standards that STVRs are legally required to construct to the building plans.