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Home My WebLink About11-14-2021 Applicant Response to Various DLNR Division Agency Comments PB,R H AWA l 1 November 14, 2021 ASSOCIN.lwES, INC. Mr. Zendo Kern, Director IC STAN NDI rNC:.AN,ASV.��A P a,1&bat,G,,Rra,.'mm Planning Department Idl.rSSE I,A.1.(.IWNG,FAS1 A,I.wD E "A6'B D+C', COUNTY OF HAWAII tl"``�N vdvw,'"'°°""°"'�' 101 Pauahi Street, Suite 3 A INC ENT SI oIG UNI Hilo, HI 96720 'loo ti r k n r P ar sal m/Amu al,W GRAN I I h6lRAKANI.,h.ttl+l.l-ED".14PBD+4:: ,�r,r�, V, P"a+rlakne/1rr,.at,ped SUBJECT: 2°d ROUND OF STATE AND COUNTY AGENCY COMMENTS KI Nil Nil KAMl A UM F1.H A1"BID+C AND RESPONSES TO MULTIPLE PERMIT APPLICATIONS FOR KUMU HOU AT WAIKOLOA M"ONI SCI NNgiLL,AIG::ID f+rP,ucq and CA1.tlFCULLISON A101 Applications: Special Management Area Use Applications PL-SMA-2021-000001 I'mmrINd (±182.9 acres), 000002 (±38.6 acres), 000003 (±7.3 acres), and 000004 0136.9 acres), CtlIG"1ri�WASi WITTEN,8lh+ll..lh h(u Au a, )a�(�r,w Change of Zone Applications PL-REZ-2021-000004 and 000005 W CRANK R RAT`J1D1.l,hSO.A Applicant: Waikoloa Land Company RA'LF7v1ON DT IHGA,A.SLA TMKs: (3) 6-9-008:013 (por.), 021, 022, 025, 027 (por.), 028 (por.), 029 (por.), Ak;,>'l aa-P^rdda;Prat 031 (por.), and 033 MARC`IllMATS'U,ASL.aA Location: 'Anaeho'omalu, South Kohala District, Hawaii .Artsrn,wh,Pderaa-ip(U I a AC H NG iDG'D,Nf,LF11:Y PAPa � r D lePaaa,lPDrxa Dear Director Kern: ANN Nil KI KO HOUM.00; Phil) Polyo l"wo``lr Thank you for forwarding the recently received comments from various divisions of the R.A AAA,` °"'"a State Department of Land and natural Resources (DLNR) and from the County t iaLftr ak as �¢a'raaF axty P:^ftrrr,unee MIG:AF M01111 N,ASL.^A,LFED'All Department of Water Supply regarding the above-noted applications for Kumu Hou at ....... ' '�,z� Waikoloa(the Applications). NA1IIA1,11:RAZ() ;,,,I�'caa Asra:rs rcraa.I This letter is submitted on behalf of the project Applicant, Waikoloa Land Company G;P2.k.G[llf9 NCd A11,A O.tl;Stl','17"C�.A,g6"fCSw AA Ba ,<�l ar-��a, (WLC). It presents a summary of the comments received from these two agencies, and tl,; I]): MLA Applicant Waikoloa Land Company's responses to these comments. A.......ffi, ° STATE DEPARTMENT OF LAND AND NATURAL RESOURCES til"lJ:NA RNNCJ� I,yrcr�oIevk Several divisions of DLNR responded to their agency's recent solicitation of NIO:71..ESAWANSG-DN comments on the Applications. Comments received and the Applicant's A.wu'l we responses to each are as follows: WO I Honduh,1h I "'"`" "mlv ° • Division of Aquatic Resources (October 29, 2021) had no comments. Etlirriinsl pl rx Ptlu ;nl"i ieflS i1D;1 :n Fl'vsa h�rahn q,uP4J Llwwi6P.+'.a:oil hrTYrt w.t r,aa r r c p�,:Ce•nl p�ry y^ee P1,, NNI\G, . LAND CAP -ARCIIq l I,cl URt; - IiAA'pRClX\1A .N I' V0DlG"; I NT 11 1IfM1,1^ 1 V'l;RN1A I 'I1N6 • GR AP I I C 1)I1,IG Mr. Zendo Kern SUBJECT: 2nd ROUND OF STATE AND COUNTY AGENCY COMMENTS AND RESPONSES TO MULTIPLE PERMIT APPLICATIONS FOR KUMU HOU AT WAIKOLOA November 14, 2021 Page 2 • Engineering Division (October 29, 2021) noted that rules and regulation of the National Flood insurance Program (NFIP) are in effect when development falls within a Special Flood Hazard Area, and notes that flood zones subject to NFIP are identified on FEMA's Flood Insurance Rate Maps (FIRM). Response: According to data obtained from the County of Hawaii and ESRI base maps, the Kumu Hou project area is rated Zone X, or an area of minimal flood risk. • Commission on Water Resource Management (CWRM) (November 3, 2021) recommends the following: o The project should be incorporated into the County's Water Use and Development Plan. Response: If entitled, the Applicant will coordinate with the County DWS to ensure Kumu Hou's incorporation into this plan. o Water efficient fixtures and water efficient practices should be implemented throughout the development. o Response: The Applications identify numerous water efficient practices that the Applicant is committed to. Draft conditions recommended by the Planning Department provide further guidance in these respects. o Best management practices (BMPs) should be employed for stormwater management. Response: Kumu Hou will employ BMPs for stormwater management. o Alternative water sources should be employed wherever practicable. Response: Kumu Hou's landscape irrigation is planned to be sourced exclusively from brackish water drawn from the `Anaeho`omalu Aquifer. Owing to the repurposing of nine golf fairways and the project's generation of additional high quality recycled water,Kumu Hou is expected to result in the overall Waikoloa Beach Resort requiring less of this water resource in the future than it does presently. In addition, the Applicant is exploring various landscape solutions within Waikoloa Beach Resort but outside of Kumu Hou to help mitigate the project's impacts on the area's fresh water resources. o Participation in the Hawaii Green Business Program is suggested. Response: The Applicant will consider participation in this program. o Landscape irrigation BMPs endorsed by the Landscape Industry Council of Hawaii should be employed. Response: Kumu Hou is planned to incorporate several such BMPs. As noted, the Applicant is exploring the feasibility of extending such practices throughout the Resort. o Approvals shall be conditioned upon review by the State Department of Health (DOH) regarding the potential for ground or surface water degradation/contamination. Response: The Applicant will coordinate with DOH regarding such review. o The project should consider using reclaimed water for its non-potable water needs, such as irrigation. Mr. Zendo Kern SUBJECT: PUBLIC COMMENTS AND RESPONSES TO MULTIPLE PERMIT APPLICATIONS FOR KUMU HOU AT WAIKOLOA November 14, 2021 Page 3 Response: Waikoloa Beach Resort already processes wastewater to R-1 standards and uses this resource to irrigate its golf courses. Kumu Hou will both increase the available quantity of such R-1 recycled water and reduce the acreage of golf fairways needing irrigation. o Well construction and pump installation permit(s) are required before commencement of any well construction work, or ground water development, respectively. Response: Kumu Hou will obtain all such necessary permits in a timely manner. o Any wells located on or adjacent to the project that are not planned to be used and which will be affected by the new construction should be properly abandoned and sealed. Response: At this time, there are no wells located on or adjacent to Kumu Hou that are expected to no longer be needed. o Consultation with the region's (moku) Aha Moku Council should be undertaken to determine whether the planned development of a new brackish water irrigation system will affect traditional and cultural practices in the project area. Response: An assessment of Native Hawaiian traditional and cultural practices was undertaken during the initial planning for Kumu Hou, and that study was presented as Appendix 5 to the Applications (TCP Hawaii, LLC). The Applicant will also consult with the Aha Moku Council prior to finalization of plans for the proposed new brackish water irrigation system. • Office of Conservation & Coastal Lands (October 22, 2021) had no comments. • Land Division—Hawai`i District(October 28, 2021) had no comments. • Division of Forestry & Wildlife (DOFAW) (November 9, 2021)— • , 2021)—o DOFAW notes that several State listed waterbirds,the Hawaiian Hawk(`Io), the Hawaiian Hoary Bat (`Ope `ape `a), the Blackburn's Sphinx Moth have the potential to occur in the vicinity of the project area. Response: The Applicant acknowledges the potential presence of these and other species of interest and will observe the protocols noted in the DOFAW's letter, including those related to artificial lighting. Many of these recommendations were also presented in the biological study as Appendix 3 to the Applications (Geometrician Associates, LLC). o DOFAW recommends minimizing the movement of plant or soil material between worksites and consulting with the Big Island Invasive Species Committee in the planning, design, and construction of Kumu Hou. Response: The Applicant appreciates this guidance and will pursue these recommendations. o DOFAW recommends the use of native plant species for landscaping as appropriate and avoidance of planting invasive species. Response: The Applicant will follow this guidance. Mr. Zendo Kern SUBJECT: PUBLIC COMMENTS AND RESPONSES TO MULTIPLE PERMIT APPLICATIONS FOR KUMU HOU AT WAIKOLOA November 14, 2021 Page 4 COUNTY DEPARTMENT OF WATER SUPPLY The DWS notes that pursuant to Section 23-84 of the Hawaii County Code,the following minimum requirements must be complied with for subdivision approvals: • Provide a water system designed to deliver water at adequate pressure and volume in accordance with Water System Standards; • Submit construction plans for review and approval by the DWS; • Pay the appropriate fee to cover DWS' plan review, testing, and inspection of the water system. Response: The Applicant will meet these minimum requirements. Additionally, the Applicant appreciates DWS' concerns for the sustainable yield of the Waimea Aquifer System and understands that CWRM and/or other agency actions could limit the availability of water from this source in the future. SUMMARY The Applicant remains committed to stewarding the natural, cultural, and social resources of Waikoloa Beach Resort, while following governing County, State, and Federal laws, rules, and regulations. Please be in touch should you have any questions or concerns about the comments and responses summarized herein. Sincerely, Tom Schnell, AICP Principal cc Mr. Scott Head, Waikoloa Land Company Mr. Sidney Fuke, Sidney Fuke Planning Consultants