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ocean. To thus determine the status of the very inland waters would be very time consuming and beyond the scope of this study. There are several advantages and disadvantages of surface connection. Some advantages are that it is technically sound and can be implemented within the current regulatory and statutory framework with no modification to existing laws. Also it was the practice followed by the Hawaii County Planning Department and soon to be followed by the State. Finally, if controlling development for hazard mitigation purposes is important, using the surface connection method will identify risky areas that are vulnerable to future flooding, wave action and subsidence. The disadvantage of using surface connection is that it can lead to unusual results as seen for Figure 3-12. If surface connection is utilized, some discretion should be provided to the implementing agency, whether it is the county or the State. Also surface connection, while being the most conservative of the four options discussed in this report, may still not be conservative or restrictive enough. For example, tides higher than a 2.8 foot high tide can occur and cause greater problems than the tides used for certification purposes. The same can be said of storm or other very high wave events, which are excluded in the shoreline determination by definition, but in real life can cause significant hazard risk. Also there is the possibility of tides less than 2.8 MLLW accompanied by high non-storm waves causing much greater inundation than a 2.8 tide by itself. 3.4.2 Using the Transition to Gravity Flow rd In the review of the shoreline certification process by DLNR for the 23 Legislature, a report for improved administration of the shoreline certification process was submitted. This report was put together with the input of environmental groups (Sierra Club), business groups (Land Use Research Foundation), administrative organizations (DLNR, CZM – Office of Planning) and technical organizations (University of Hawaii – Geology Department & Sea Grant). In the report, the situation was recognized that the water position setting the shoreline should be based 14 on wave energy run-up and not gravity flow or funneling through narrow passages. A definition for run-up was proposed that would replace the “upper reach of the wash of the waves.” The proposed definition was: “run-up” means that the water position setting the shoreline must be derived exclusively by wave energy run-up and not aided by gravity or funneling through narrow passages. Where it is unclear to what extent the gravity flow played a part in the run-up, the transition from run-up to gravity flow shall be interpreted as shoreline (based on evidence, expert knowledge, and reasonable expectation). 14 DLNR report, proposed definition of runup on page 13 of the report. 33