HomeMy WebLinkAbout2019-11-06 Letter to Bob Wessels re EIS for Town of Aina Le'a -.0-4-4„:11',./;‘••
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25 Aupuni Street,Suite 2603 • Hilo,Hawaii 96720 • (808)961-8211 • Fax(808)961-6553
KONA: 74-5044 Ane Keohokalole Hwy.,Bldg.C • Kailua-Kona,Hawaii 96740
(808)323-4444 • Fax(808)323-4440
November 6, 2019
Mr. Bob Wessels
Aina Le'a, Inc.
P.O. Box 385050
Waikoloa, HI 96738-5041
Re: October 2019 Preparation Notice for an Environmental Impact Statement
Project: Town of Aina Le'a
TMK: (3) 6-8-001:025, 036, 038, 039 and 069
Dear Messrs. Wessel and Bernstein and Ms. Valenzuela,
This follows our meeting of October 14, 2019. Thank you for sharing with me Aina Lea
Inc.'s proposed Lulana Gardens project and the desire to construct affordable housing in this
County.
I encourage Aina Lea, Inc. to work with the Planning Department to produce a final
environmental impact statement ("EIS")which the Planning Department can legally accept in
order to allow the Lulana Gardens project to proceed.
I also encourage Aina Lea Inc, to review the law and the history of its predecessor's
previous meetings with, and submittals to, the Planning Department because the representations
made to me at our meeting on October 14, 2019, appear to be incorrect:.
• Lulana Gardens Project is not exempt from environmental review: The assertion that
affordable housing projects are exempt from environmental review under Hawaii State
law is not correct. While there is an exemption from environmental reviews for certain
affordable housing projects under the new Hawaii Administrative Rules, your project
does not appear to meet the requirements for that exemption.
• There is not a valid accepted Final EIS for the Lulana Gardens Project: In 2010, the
Planning Department previously accepted a final EIS for a larger project that differs from
the present proposal for Lulana Gardens. As you know, in 2013 the Circuit Court of the
Third Circuit found that the Planning Department should not have accepted that statement
because it did not take a hard look at whether the project covered by the 2010 EIS was a
segment of a larger project or also whether there were cumulative impacts which were
not fully analyzed.
o The plaintiff in the court case challenged the sufficiency of the 2010 EIS, noting
that it only covered approximately 1,092 acres of property, while the 2007 EIS
County of Hawaii is an Equal Opportunity Provider and Employer.
Mr. Bob Wessels
Aina Le'a, Inc.
November 6, 2019
Page 2
Preparation Notice had described a project on approximately 3,000 acres of
property.
o Aina Lea, Inc.'s predecessor in interest acquired the 1,092 acres of property in
2009, but had a joint development agreement with the prior owner for the full
3,000 acres of property which allowed for those parties to cooperate in developing
infrastructure to be used by the full 3,000 acres of property.
o The projects covered by the 2007 EIS Preparation Notice, the 2010 EIS, and the
Joint Development Agreement all proposed an action which triggers
environmental review under Hawaii law: the development or construction of a
wastewater treatment unit serving more than fifty single-family dwellings.
o I understand that the Lulana Gardens project also presently proposes the
development or construction of a wastewater treatment unit serving more than
fifty single-family dwellings.
• The Planning Department's efforts: Contrary to what was stated at our meeting, the
Planning Department has conferred via telephone and in-person to meet with agents,
consultants, and/or representatives of Aina Lea Inc. and its predecessors on numerous
occasions. Planning Department files reveal nine (9) letters that the Planning Department
has written to Aina Lea in this regard from 2015 to 2019.
According to the Planning Department, as articulated to Aina Lea in its letter to Dennis
M. Lombardi, Esq., dated March 5, 2019, the clearest and most efficient way for Aina Lea, Inc.
to proceed with its project (or any phase of the project) is to complete the environmental review
process according to law given the length of time which has passed between publication of the
EIS Preparation Notice for a project on 3,000 acres in 2007, and the ensuing changes in scope
and intensity of the proposed project on 1,092 acres as contemplated in 2010.
I encourage Aina Lea, Inc. to work with the Planning Department to produce a final EIS
which the Planning Department can legally accept in order to allow the Lulana Gardens project
to proceed and help provide our citizens with more affordable housing options.
Sime el
Harry Kim
MAYOR
County of Hawaii is an Equal Opportunity Provider and Employer.