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The other criteria is like unusual use. And the Department is saying, well, it’s unusual because <br />schools are not considered agricultural in nature. That’s true. The community is saying well, <br />you know, because of the magnitude of the request and its impacts, this unusual request should <br />be processed via the State Land Use Boundary amendment process and not the Special Permit <br />process. <br />Let’s look at the special permit criteria. The Department is saying, well, it’s a reasonable use <br />because schools are needed to support agricultural community. This is what the community is <br />saying, no, the proposed location is not needed to support an agricultural community because this <br />is an urban residential community, not an agricultural community. <br />The other criteria is that it would not adversely impact surrounding properties. Well, the <br />Department is saying, well, the adverse impacts are associated with traffic, noise, and visual. <br />And in terms of traffic, the TIAR states that the Level of Service, the LOS, to operate at <br />acceptable levels, would operate at acceptable levels with left turn lanes at Edita Street; and <br />don’t worry about the noise because they’ll provide landscaping. <br />Okay, in terms of like the traffic, well, at least like, as I mentioned, 70 percent of the community <br />now basically disagrees; and this is what they’re saying on traffic. They’re saying that, first of <br />all, the issue on the date of study, the study, in terms of the data collection, was done when the <br />school was nearing its end. Secondly, it was compiled on May 28, 2009, nearly 3 years from <br />submittal of application. The other thing is the level of standard is a standard based on, level of <br />service rather, it’s a standard based on waiting period for movements, which does not necessarily <br />translate to expected quality of life and, in turn, impact. <br />The significant traffic impacts, increase on Kaumana Drive and Edita Street, if you use the <br />“preferred alternative” data (which is the current plan of applicant) which is to use, the mauka <br />side will be kept open and the makai side would be all, you know, would be the project’s <br />development. They’re saying that the Project’s Traffic Generation during the a.m. peak, which is <br />7:00 to 8:00 a.m., would have about 187 movements on Kaumana Drive and Edita Street. If you <br />look at the existing a.m. peak right now at Kaumana Drive, you have 102 mauka bound on <br />Kaumana Drive, 219 on the makai bound, for a total of 321 movements on Kaumana Drive. <br />With the project upon build out, then that would represent about 58% increase over the existing <br />level. Let’s now turn only onto Edita Street which is going to be the most significantly impacted <br />area, street. The existing a.m. peak on Edita Street, you have like 13 inbound and 49 outbound <br />movements, for a total of 62 total movements. If you add 187 projected movements during the <br />a.m. peak, then you’ll have a total of 249, which represents 330% increase over the existing <br />level. <br />The other point I think the community is saying is that there’s no discussion of impacts to the <br />balance of Kaumana Drive, particularly between Ainako Avenue or at the start of where the <br />winding road begins to Edita Street, and also from Wilder Street, Wilder Road rather, down to <br />Edita Street. For example, there is like Terrace Drive, you know, because you’ll have lot of <br />traffic coming in, going mauka and makai bound on that. So, therefore, like in conclusion, <br />relative to traffic, the community is saying, first of all, the level of service is not really relevant <br />because it’s not, it relates to time delay. It has really little to do with the quality of life, the <br />perceived quality of life. And then the percentage of impact is more critical in establishing level <br /> 16 ATTACHMENT C <br /> <br /> <br />