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HomeMy WebLinkAbout2025-10-29 Appellants Supplemental Exhibit List Claudia Rohr 369 Nene St. Hilo, HI 96720 (808)640-5976 crohr4@gmail.com Appellant, pro se BEFORE THE BOARD OF APPEALS COUNTY OF HAWAII STATE OF HAWAII CLAUDIA ROHR, No. PL-BOA-2025-000119 Appellant, APPELLANT'S SUPPLEMENTAL vs. EXHIBIT LIST; DECLARATION OF CLAUDIA ROHR; JEFFREY DARROW, PLANNING CERTIFICATE OF SERVICE DIRECTOR; RICHARD STANDKE; DEBORAH STANDKE, Appellees APPELLANT'S SUPPLEMENTAL EXHIBIT LIST The Appellant CLAUDIA ROHR, ("Rohr") submits her Supplemental Exhibit list for the hearing set for November 14, 2025. Exhibit No. Description 1 Memo No. 2024-10 Building Permit Rejection Process 2 SMA Short Form Assessment No. 2025-SFA-000433 3 Director of Public Works ROA PL-BOA-2025-0000121, Document#2, building plans with approval stamps from Planning Department dated 1/13/2025: "2025-SFA-000433. Approved for proposed alterations and additions to existing dwelling." 1 4 SMA Assessment Application No. PL-SAA-2025-000280 5 PL-SAA-2025-000280 Comments from Claudia Rohr 6 PL-SAA-2025-000280 Exemption Determination Letter 7 Letter Complaint and Complaint Form dated June 30, 2025 8 Photographs in support of Complaint dated June 30, 2025 9 Lilikoi House Booking Policies highlighted 10 Booking Confirmation Lilikoi and Orchid Houses highlighted 11 STVR-19-359757 application 12 SLH2O24_Act17, amending HRS § 46-4. 13 Hawaii County Code (HCC) Chapter 25, Article 1, Article 2, Article 4, And Article 5, Relating To Short-Term Vacation Rentals. 14 County of Hawaii Planning Department, Rules of Practice and Procedure, Rule 23. 15 HRS §205A-1 16 HRS §205A-22 17 HRS §205A-26 18 County of Hawai'i Planning Commission Rules of Practice and Procedure, Rule 9. 19 Claudia Rohr's April 14, 2025 Letter to WPC and LPC re: Unnumbered Agenda Item, Planning Director's SMA Report for March SMA exemption for No. PL-SAA-2025-000280, TMK (3)2-1-018-013, 14 Oeoe St.,Hilo, HI 96720; and 6 attachments. See, bookmarks. 20. Copy of Aluli v. Lewin, 73 Haw. 56, 828 P.2d 802, (1992). 21. Copies of photographs I personally took at three of Richard Standke's side-by-side STVRs. 2 DECLARATION OF CLAUDIA ROHR [in lieu of Affidavit] I, CLAUDIA ROHR, do declare that the following information is truthful to the best of my knowledge and understanding as follows: 1. That Exhibit 1 is true copy of"Memo No. 2024-10 Building Permit Rejection Process" received from the Planning Department in response to an information request on a UIPA form. 2. That Exhibit 2 is a true copy of SMA Short Form Assessment No. 2025-SFA- 000433 that I received from the Building Division of Public Works in response to an information request on a UIPA form. 3. That Exhibit 3 is a true and readable copy of"Director of Public Works ROA PL-BOA-2025-0000121, Document#2", building plans with approval stamps from the Planning Department dated 1/13/2025: "2025-SFA-000433. Approved for proposed alterations and additions to existing dwelling", that was emailed to me by the Director of Public Works' counsel, Sinclair Salas Ferguson 4. That Exhibit 4 is a true copy of SMA Assessment Application No. PL-SAA- 2025-000280 received from the Planning Department in response to an information request on a UIPA form. 5. That Exhibit 5 is a true copy of Comments on PL-SAA-2025-000280 from Claudia Rohr provided to the Planning Department by email on April 8 and 9, 2025. 6. That Exhibit 6 is a true copy of PL-SAA-2025-000280 Exemption Determination Letter I downloaded from EPIC. 7. That Exhibit 7 is a true copy of the Letter Complaint filed with the Planning Department on June 30, 2025. 3 8. That Exhibit 8 is a true copy of photographs taken February 26, 2024 in support of my Letter Complaint filed June 30, 2030, TMK 3-2-1-18-13, 14 Oeoe Street, Hilo, Hawaii. 9. That Exhibit 9 is a true copy of the online advertisement for the Lilikoi House that I printed on 4/12/2025 from the owners' website. I highlighted it in yellow to show the extra sleeping areas (beyond four bedrooms) that are advertised. 10. That Exhibit 10 is a true copy of the Booking Confirmation that I printed on 4/12/2025 from the owners' website when I booked the Lilikoi House and the Orchid House together. I highlighted it in yellow to show my notes that the reservation was for a reunion of 12 of my husband's fraternity brothers arriving in separate cars. 11. That Exhibit 11 is a true copy of the Standkes' STVR-19-359757 application I received in response to a UIPA request to the Planning Department. Page 10 shows that the Planning Department issued a non-conforming use certificate even though no parking plan was submitted. 12. That Exhibit 12 is a true copy of Act 17 (S.B. NO. 2919); HRS §46-4 County zoning, and HRS §237D-1 Definitions, printed from the Hawaii Legislature's website. I highlighted the pertinent sections in yellow. 13. That Exhibit 13 is a true copy of the Zoning Code, Chapter 25, printed from the County of Hawaii's website on 7/20/2025. 14. That Exhibit 14 is a true copy of the Planning Department's Rules of Practice and Procedures, Rule 23 - SHORT-TERM VACATION RENTALS, printed from the County of Hawaii's/Planning Department's website. I highlighted pertinent parts in yellow. 15. That Exhibit 15 is a true copy of HRS Section 205A-1, printed from the Hawaii Legislature's website. I highlighted the pertinent section in yellow. 4 16. That Exhibit 16 is a true copy of HRS Section 205A-22, printed from the Hawaii Legislature's website. I highlighted the pertinent section in yellow. 17. That Exhibit 17 is a true copy of HRS Section 205A-26, printed from the Hawaii Legislature's website. I highlighted the pertinent section in yellow. 18. That Exhibit 18 is a true copy of the Planning Commission Rules of Practice and Procedure, printed from the Hawaii Legislature's website. I highlighted some of the pertinent section in yellow. 19. That Exhibit 19 is a true copy of Claudia Rohr's April 14, 2025 Letter to WPC and LPC re: Unnumbered Agenda Item, Planning Director's SMA Report for March SMA exemption for No. PL-SAA-2025-000280, TMK (3)2-1-018-013, 14 Oeoe St.,Hilo, HI 96720; and 6 attachments. See, bookmarks. 20. That Exhibit 20 is a true copy of a Hawaii Supreme Court opinion- Aluli v. Lewin, 73 Haw. 56, 828 P.2d 802, (1992), printed from Justia's website. Administrative agencies must adopt rules that govern their discretionary decisions, at 803. 21. That Exhibit 21 contains true copies of photographs I personally took at three of Richard Standke's side-by-side STVRs. That I do declare under penalty of law of perjury that the foregoing is true and correct. Dated: Hilo, Hawaii, October 29, 2025. Respectfully submitted, ti4t4A1A, CLAUDIA ROHR, Plaintiff Pro Se 5 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and accurate copy of the foregoing documents were served upon the following parties shown below, via electronic mail service on October 20, 2025. 1. Planning Director Jeffrey Darrow Jeff.Darrow@hawaiicounty.gov 2. JEAN CAMPBELL, jeank.campbell@hawaiicounty.gov Deputy Corporation Counsel Attorney for the Planning Director 3. SYLVIA WAN, SylviaA.Wanghawaiicounty.gov Deputy Corporation Counsel For the Board of Appeals 4. Board of Appeals boardofappeals@hawaiicounty.gov 5. RICHARD AND DEBORAH STANDKE richard.standkeggmail.com DATED: Hilo, Hawaii, October 29, 2025. CLAUDIA ROHR, Plaintiff Pro Se 6