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Home My WebLink AboutPD Background Report (PL-SMA-2026-000087) -1- -1- BSiteM_SMA_2026 COUNTY OF HAWAIʻI PLANNING DEPARTMENT BACKGROUND REPORT DHL MAHI SITE M LLC & DHL MAHI PROPCO LLC AMENDMENT TO SPECIAL MANAGEMENT AREA USE PERMIT NO. 07-000019 (Amend SMA-07-019/ (PL-SMA-2026-000087) DHL MAHI SITE M, LLC and DHL MAHI PROPCO LLC have submitted an application requesting to amend Special Management Area (SMA) Use Permit No. 07-019 for a 10- year time extension to Condition No. 2 (Commence Construction); reduce the density of the Mauna Lani Site M master planned development from 1,207 Units (691 Residential & 516 Hotel) to 925 Units (551 Residential & 374 Hotel); remove proposed golf course and conference center use; increase preserved open space; and construct an emergency evacuation road. The project is situated within the Special Management Area and is located approximately 0.75 miles west of Queen Kaʻahumanu Highway, approximately 0.4 miles north of Mauna Lani Drive, Mauna Lani Resort, South Kohala, Hawai’i, TMKs: (3) 6-8-001:050; 052-055, (3) 6-8-022:010. APPLICANT’S REQUEST: 1. Request: DHL MAHI SITE M, LLC and DHL MAHI PROPCO LLC (collectively, the “Applicant”) request an amendment to Special Management Area (SMA) Use Permit No. 07-019 to modify the previously approved development program for “Site M” within the Mauna Lani Resort, located in South Kohala on TMK’s: (3) 6- 8-001:054 and (3) 6-8-022:010. The applicant requests the following specific changes to SMA 07-019: • Reduce the overall development intensity from 1,207 units to a total of 925 units, a 23.4% overall reduction. • Amend Condition No. 2 to authorize a ten (10)-year time extension to commence construction, with the extension period to begin upon approval of the amended permit. o 2 Construction of the proposed development shall be completed within ten (10) years from the effective date of -2- -2- this permit. The project shall be developed substantially as represented in the application.” • Amend the following conditions to remove the previously approved three-hole golf course from the project scope and convert those areas to landscaped open space. Accordingly, Condition Nos. 8 and 14 shall be amended, and condition No. 20 would need to be deleted. o 8. The applicant shall develop a three-fairway golf amenity or equivalent open landscaped area and use commercially reasonable efforts to use effluent water treated to the R-2 standard from the Mauna Lani Resort's wastewater treatment plant to irrigate the golf amenity or open landscaped area; provided, however, that the applicant's commitment to use the R-2 treated effluent shall be conditioned upon the operator of the wastewater treatment plant providing R-2 treated effluent of an acceptable quantity and quality so as to enable applicant to use such effluent within its subsurface drip irrigation system without incmring (sic) unreasonable expense or liability. o 14. A non-potable water source for golf course or equivalent open landscaped area irrigation shall be utilized. o 20. The applicant shall prepare an integrated golf course management plan (IGCMP) for the review and approval of the Planning Director. The IGCMP shall address the design, construction, maintenance and operation of the 3-hole golf course. The IGCMP shall contain specific best management practices for the 3-hole golf course. • Eliminate the previously approved 20,000-square-foot conference center on Parcel 3A from the project scope. • Pursuant to Condition No. 6 of SMA Use Permit No. 07-019 (shown below), the Applicant proposes to establish an emergency evacuation route road corridor intended to serve the Mauna Lani Resort area and the Puakō community. The proposed corridor would traverse portions of TMKs (3) 6-8-001:050, (3) 6-8-001:052, (3) 6-8-001:055 and (3).6-8- 001:049. Three (3) potential route alignments have been identified originating from the South Kohala Fire Station located on TMK (3) 6-8- -3- -3- 001:055. o 6. To the extent allowed by the applicable government agencies and Mauna Lani Service, Inc., applicant shall take commercially reasonable steps to enable its construction access road to also serve as an alternate emergency evacuation route for the Mauna Lani Resort and the Puako community; provided, however, that the applicant shall not be responsible for maintenance and/or control of the alternate emergency evacuation route. 2. Proposed Development: “Site M” encompasses approximately 150 acres situated within the SMA. The proposed amendment would modify the project’s residential and hotel components while retaining the existing parcel acreages. For the residential component, Parcel 1 would remain 7 acres and be reduced from 76 to 56 units, representing a 26.3 percent reduction, with a mix of stacked- flat and townhome units at a density of 8 dwelling units per acre. Parcel 2 would remain 12.8 acres and be reduced from 138 to 102 units, a 25.8 percent reduction, also consisting of stacked-flat and townhome units at 8 dwelling units per acre. Parcel 4 would remain 16.6 acres and be reduced from 180 to 133 townhome units, a 26.2 percent reduction, in two-story buildings at a density of 8 dwelling units per acre. Parcel 5 would remain 13 acres and be reduced from 141 to 104 units, a 26.2 percent reduction, with a mix of stacked-flat and townhome units at 8 dwelling units per acre. Parcel 6 would remain 22.3 acres with no change from the 2008 SMA approval, retaining 156 villa units in two-story buildings at a density of 6.9 dwelling units per acre. With respect to the hotel component, Parcel 3A would remain 16.4 acres and increase slightly from 266 to 270 rooms, a 1.5 percent increase, while retaining the previously approved four- story massing and 45-foot height limit. The conference center previously approved for Parcel 3A would be removed, the building footprint would be reduced by approximately 54 percent, and open space would increase by approximately 9 percent. The applicant now proposes a dual-branded hotel concept with shared amenities between Parcels 3A and 3B. Parcel 3B would remain 16.1 acres and be reduced from 250 to 104 rooms, representing a 58.4 -4- -4- percent reduction. In addition, the previously approved 100 bungalow buildings would be replaced with a single four-story hotel structure not to exceed 45 feet in height. The building footprint on Parcel 3B would be reduced by approximately 75 percent, with an approximately 10 percent increase in open space, and amenities would be shared with Parcel 3A. Further details can be found in Table 2 on page 12 of the application. 3. Reason for Request: The Applicant requests the subject amendment to reconfigure the approved hotel component by consolidating hotel accommodation into a single, multi-story structure in lieu of the previously approved dispersed, bungalow-style guest units. This is in addition to a previously approved second hotel which the applicant is not proposing any changes to at this time. The modification to the “Site M” master plan is intended to reduce the overall building footprint and associated site disturbance, thereby increasing landscaped and open space areas, reducing the extent of impervious surfaces, improving natural drainage patterns, and minimizing stormwater runoff within the project area. The proposed emergency evacuation route corridor is submitted in compliance with Condition No. 6 of SMA Use Permit No. 07-019 and is intended to enhance public safety by providing an additional means of egress for the Mauna Lani Resort area and the Puakō community. The requested amendments to permit conditions, including modifications to Conditions No. 8 and No. 14 and the deletion of Condition No. 20, reflect the removal of previously approved project components, specifically the three (3) hole golf course and the 20,000-square-foot conference center, which are no longer proposed as part of the development. 4. Project Objectives: Update to the 150-acre master plan and construction of an emergency evacuation route. 5. Cost/Time of Project: The estimated cost of the proposed improvements is approximately $500,000,000, or more, and therefore the proposed development is subject to Special Management Area (SMA) Use Permit review. The Applicant requests a modification to Condition No. 2 of SMA Permit No. 07-019, which -5- -5- establishes the project completion timeline. The original permit, along with subsequent administrative extensions, currently sets a completion deadline of September 4, 2028. The Applicant is requesting an amendment to Condition No. 2 of SMA Use Permit No. 07-019 to authorize a ten (10)-year time extension to commence construction, with the extension period to begin upon approval of the amended permit. 6. Supportive Information: The Applicant has submitted the attached in support of the request: (Planning Department Exhibit 1 – SMA Use Permit Application Packet dated January 30, 2026). 7. Landowner: DHL MAHI SITE M, LLC and DHL MAHI PROPCO LLC BACKGROUND INFORMATION a. 1968 – Land Use Commission Docket No. A68-175 for a State Land Use District Boundary amendment from Conservation to Urban for approximately 170 acres for a resort. 8. Mauna Lani Resort Development permits b. 1978 – SMA No. 2 was approved for the Mauna Lani Resort development; however, “Site M” is not included in this SMA permit. c. March 3, 1986 – Land Use Commission Docket No A84-583, State Land Use District Boundary amendment from Agricultural and Conservation to Urban for approximately 654 acres, which includes Site M. d. July 13, 1987 – Ordinance No. 87 73 for various changes of zones. “Site M” was included in this ordinance. e. March 7, 1995 - Ordinance No. 95 37 changed the district classifications from Multiple Family Residential (RM-4) and Open (O) to Open (O) and Multiple Family Residential (RM-4) for portions of TMKs (3) 6-8-022:010 and (3) 6-8- 001:054 for approximately 32.519 acres. f. August 17, 2000 – An administrative determination of a non-significant change of zone was granted for Tax Map Keys (3) 6-8-022:010 and (3) 6-8- 001:054. The purpose of this request was to facilitate an exchange of land uses by reallocating resort-designated acreage to accommodate a 49-lot -6- -6- residential subdivision, identified as the “49 Black Sand Beach” subdivision, located on the south side of the Mauna Lani Bay Hotel within the multiple- family residential zoning district of “Site M”. Both subject properties were previously included under Docket No. A54-583, as discussed above. Approval of the non-significant change of zone enabled the Mauna Lani Resort to preserve a designated future hotel site while maintaining compliance with Condition No. 5 of Docket No. A54-583, which requires that: “The Petitioner shall develop a full-service hotel on the Property in conjunction with the recreational and residential project to ensure employment opportunities.” g. May 22, 2007 - Administrative non-significant change of zone granted for TMK (3) 6-8-001:054 to amend the zoning for the 100.97-acre parcel. The property originally consisted of 45.797 acres zoned RM-4 and 55.101 acres of Open zoned districts. The action resulted in 45.696 acres zoned RM-4 and 55.101 acres of Open zoned lands. h. September 4, 2008 – SMA Use Permit No. 07-019 approved for the development of 691 residential units, 516 hotel rooms (consisting of 184 hotel room suites containing a total of 266 hotel rooms (keys) and an adjacent enclave of 100 self-contained family bungalows consisting of 250 rooms (keys), three (3) golf holes, and related support facilities within “Site M” of the Mauna Lani Resort. i. April 14, 2015 – 5-year administrative time extension granted for Condition No. 2 of SMA 07-019 until September 4, 2023 with a second 5-year administrative time extension from September 4, 2023 to September 4, 2028 to be automatically approved subject to the developer satisfying the following milestone: “The second 5-year administrative time extension to complete construction of the Project shall automatically be triggered upon the County of Hawai‘i’s issuance of all applicable permits for construction of the core infrastructure for the Project. This core infrastructure shall include at a minimum, improvements to Ho‘ohana Street fronting the Project to resort standards the electrical and utility service connections to the Project, and a -7- -7- north-bound left-turn lane packet from North Kaniku Drive into the main entrances to the Villages at Mauna Lani. The core infrastructure as defined herein shall not include any improvements to the Mauna Lani Resort project entry or intersection at Queen Ka’ahumanu Highway at Mauna Lani Drive.” j. January 26, 2023 – Grading permit No. PW.ENG2022-00248 was approved for the core infrastructure elements for “Site M” to comply with the aforementioned conditions. k. March 16, 2023 – Automatic second administrative time extension granted to comply with Condition No. 2 of SMA 07-019 from September 4, 2023, to September 4, 2028. l. October 3, 2024 – Compliance determination issued for the consolidation of the previously approved hotel bungalows on TMK (3) 6-8-022:010 into a four (4) story hotel consisting of 105 rooms (keys). The Planning Director determined the consolidation is in general compliance with SMA No. 07-019 and the existing entitlements for “Site M”. STATE AND COUNTY PLANS 9. State Land Use Designation: Site M is in the Urban District. The proposed road corridor is in the Urban and Agricultural Districts. 10. General Plan LUPAG MAP: Urban Expansion (ue) and Open. 11. County Zoning: (3) 6-8-001:054: Multiple-Family Residential 4,000-square feet (sf) (RM-4) & Open (O). (3) 6-8-022:010: Multiple-Family Residential 4,000-sf (RM-4) & Resort Hotel 1,250-sf (V-1.25). (3) 6-8-001:050: Agricultural 5-acre (A- 5a). (3) 6-8-001:052: Agricultural 5-acre (A-5a). 12. South Kohala Development Plan (PCDP): The South Kohala Community Development Plan was adopted by the Hawaiʻi County Council by Ordinance No. 08-159 on November 20, 2008. 13. Special Management Area (SMA): The project is located within the Special Management Area and therefore, the proposed development is subject to the SMA review. -8- -8- DESCRIPTION OF PROJECT AREAS AND SURROUNDING AREA 14. Subject Project Area: “Site M” is located within the Mauna Lani Resort, on approximately 150 acres. It is a master-planned community established in 1978 that includes a mix of resort, residential, and commercial land uses. The subject property is generally bound by the Mauna Lani North Golf Course and adjacent residential developments. The proposed Emergency Evacuation Road corridor encompasses an area of approximately 40 acres; however, upon final selection and alignment of a specific route, the actual area required for development of the evacuation roadway is anticipated to be substantially reduced. 15. Surrounding Land Zoning/Uses: The subject parcel and surrounding properties have mixed zoning districts including Agricultural five (5) acre (A-5a) and one (1) acre (A-1a) , Multiple-Family Residential 3,000, 4,000, 8,000 and 14,500 sf, (RM- 3, RM-4, RM-8 and RM-14.5), Commercial Village 10,000 sf (CV-10) and Residential Agricultural one (1) acre (RA-1a). Neighboring parcels are a mix of developed resort uses and undeveloped areas, with Cole Academy and various support facilities located along Ho‘ohana Street. Nearby amenities include the Fairmont Orchid, Hawai‘i, the Mauna Lani, Auberge Resorts Collection, and The Shops at Mauna Lani. Residential communities in the vicinity include The Fairways, Kulalani, and Ka Milo at Mauna Lani. Public amenities such as Holoholokai Beach Park and the Puakō Petroglyph Archaeological Park are located to the north. Lands east of “Site M”, along the proposed Emergency Evacuation Road corridor, are largely undeveloped, with the exception of the resort wastewater treatment plant and the South Kohala Fire Station. 16. Soil Type: The United States Department of Agriculture Natural Resources Conservation Service (NRCS) classified the soil underlying the proposed “Site M” and the Evacuation Route project areas as follows: 1. “SITE M”: TMK (3) 6-8-001:054 is classified as “336 – Puakō fine sandy loam, 0 to 6 percent slopes.” This soil consists of alluvium, is well-drained, and exhibits a medium runoff potential. It is characterized by a medial fine sandy loam surface layer and a very high available water capacity. TMK -9- -9- (3) 6-8-022:010 is classified as “10 – Lava flows, ʻaʻā, 2 to 20 percent slopes.” This soil type consists entirely of ʻaʻā lava, is excessively drained, and exhibits a very low runoff potential. 2. Emergency Evacuation Road Route: TMK (3) 6-8-001:050 is predominantly classified as “336 – Puakō fine sandy loam, 0 to 6 percent slopes,” consisting of alluvium, with well-drained conditions and a medium runoff potential. This soil is characterized by a medial fine sandy loam surface layer and a very high available water capacity. Portions of TMK (3) 6-8-001:052 are classified as “373 – Hapuna–Waikui–Lalamilo complex.” Within this complex, Hapuna soils exhibit a high runoff potential, while Waikui and Lalamilo soils exhibit low runoff potential. The soil in this area is generally well-drained and occurs on slopes of up to 20 percent. 17. Land Study Bureau's Detailed Land Classification System: The project site is listed as “E” (Very Poor). 18. Agricultural Lands of Importance to the State of Hawaiʻi (ALISH) System: A substantial portion of the area encompassing the proposed Emergency Evacuation Road route, specifically TMKs (3) 6-8-001:050 and (3) 6-8-001:052, is identified on the ALISH map as “Other Lands,” while the balance of the route area is designated as “0” (unclassified). 19. Flood Insurance Rate Map (FIRM): The entire project is located in Flood Zone X. 20. Flora/Fauna Resources: AECOS, Inc. prepared a Natural Resources Assessment in July 2025 to evaluate potential impacts to biological resources within “Site M.” The assessment included terrestrial surveys of flora and fauna using transects, avian point-count stations, and a mammalian review. The site is characterized as a disturbed, dry savannah landscape dominated by non-native vegetation. A total of 27 vascular plant species were documented, the majority of which are non-native. Three indigenous species—ʻilima (Sida fallax), ʻuhaloa (Waltheria indica), and alena (Boerhavia acutifolia)—were identified; however, no endemic or Polynesian-introduced (canoe) plants were observed. The vegetation -10- -10- reflects a low-diversity environment typical of previously disturbed areas in South Kohala. Wildlife resources are limited. Avian surveys recorded 14 species, predominantly introduced birds. One endemic species, the nēnē (Branta sandvicensis), was observed incidentally and is known to utilize nearby areas but not the project site. One indigenous species, the black-crowned night heron (Nycticorax nycticorax hoactli), was also recorded. No other native or listed bird species were identified. Mammalian presence is limited to feral goats, with indirect evidence suggesting the presence of other introduced species such as rodents and mongoose. Although the Hawaiian hoary bat (Lasiurus semotus), a listed endangered species, may transit the area, no suitable roosting habitat was identified within the site. The assessment concludes that the proposed project is not expected to result in significant impacts to biological resources. The site does not support rare, threatened, or endangered species and is characterized by previously disturbed, non-native habitat. 21. Archaeological Resources: “Site M” is located within the ahupua‘a of Waikōloa and lies adjacent to a petroglyph field listed on the National Register of Historic Places. A 2007 Archaeological Inventory Survey (AIS) identified eight archaeological sites containing 31 features, including pāhoehoe excavations, C- shaped alignments, abrader basins, and trail segments. Lava tube caves were inspected but not classified as sites due to the absence of cultural materials. All eight sites were determined to have informational value, with a recommendation of no further work, which was accepted by the State Historic Preservation Division (SHPD). A 2025 Literature Review and Field Inspection (LRFI) confirmed the presence and similar condition of all previously identified sites. Some features may be natural in origin but continue to be documented as historic resources. No new historic properties were identified. The proposed project incorporates recommendations of prior cultural studies, including preservation of the existing landscape. The design incorporates open space along the northern portion of the site to maintain access and provide a buffer to the adjacent Puakō Petroglyph Archaeological District. The applicant will continue to avoid impacts to -11- -11- known resources and preserve this buffer area. Emergency Evacuation Route: An Archaeological Field Inspection (AFI) conducted in December 2025 evaluated three potential alignments (Routes 1–3) for the proposed Emergency Evacuation Road within the 40-acre survey area. The inspection identified one previously documented historic property—a core- filled rock wall (Site 50-10-11-21975) associated with historic ranching—along with three additional, previously unrecorded segments. Due to prior disturbance, the likelihood of encountering additional buried resources was considered low. Route 1 would directly impact the wall and require further study and mitigation. Route 2 would utilize an existing breach but may still affect the resource if expanded. Route 3 would avoid the wall entirely. The AFI recommends selecting an alignment that avoids impacts to the historic wall to support a “no historic properties affected” determination from the State Historic Preservation Division. Routes 2 and 3 are identified as feasible avoidance options. The applicant concurs with these findings and will select a final alignment within the surveyed corridor that avoids impacts to the historic ranching wall and meets SHPD requirements. 22. Cultural/Historic Resources: In August 2025, ASM Affiliates prepared a Ka Paʻakai o Ka ʻĀina (KPA) analysis to evaluate the potential impacts of the proposed “Site M” development on traditional and customary Native Hawaiian rights. The KPA analysis determined that the 2007 Cultural Impact Assessment (CIA), which found no ongoing traditional practices in the area, was limited in scope and did not fully capture the site’s cultural significance. Consultation with cultural practitioners and lineal descendants in 2025 identified the area as part of a broader cultural landscape, noting the presence of unrecorded lava tubes, potential burials, ancestral trails, and wahi pana. The absence of previously documented sites was attributed in part to limited visibility due to dense vegetation. The KPA concludes that, although no active traditional gathering occurs on-site, the area retains cultural importance. Key recommendations include conducting comprehensive surveys, preserving cultural features in place, -12- -12- protecting traditional access routes, engaging Native Hawaiian stakeholders, and using traditional place names. The Applicant acknowledges these findings and commits to incorporating the KPA recommendations into project design and long- term stewardship to ensure culturally informed development of “Site M”. 23. Recreational/Scenic and Open Space Resources: The proposed project does not front the shoreline; however, adequate public shoreline access is available nearby within the Mauna Lani Resort, including Pauoa Bay, Makaiwa Bay, and Holoholokai Beach Park. Access is provided via resort pathways, hotel access routes, and a paved pedestrian trail connecting to Holoholokai Beach Park. Makaiwa Bay is accessible through designated walkways within the resort, while Holoholokai Beach Park, located approximately one-quarter mile north of Pauoa Bay, provides County-maintained facilities, parking, and direct shoreline access. All access points are readily reached from Queen Kaʻahumanu Highway via Mauna Lani Drive. No direct public mountain access is available from “Site M”. In the South Kohala region, upland access is typically provided through established trails, access roads, or State-managed lands outside the resort area. Public access within the Mauna Lani Resort is primarily oriented toward the shoreline. Vehicular access to “Site M” is provided by existing resort roadways, including North Kaniku Drive and Ho‘ohana Street, both of which connect to Mauna Lani Drive and Queen Kaʻahumanu Highway. The site is located approximately 0.75 miles west of the highway. North Kaniku Drive is a privately maintained, two-lane road serving the western portion of the site and is in good condition. Ho‘ohana Street, which serves the southern and eastern portions, is also a two-lane road but currently exhibits pavement deterioration. Condition No. 10 of SMA 07-019 requires improvements to Ho‘ohana Street and its intersection with North Kaniku Drive; no amendments to this condition is proposed. As the Applicant owns the property within the resort, legal access is established. Lastly, the proposed hotel is limited to a height of 45 feet, consistent with the maximum height permitted under the County of Hawai‘i Zoning Code, with the balance of the proposed development consisting of structures at lesser heights. As to potential view -13- -13- obstruction, the elevation of Queen Ka‘ahumanu Highway at a point perpendicular to “Site M” is approximately 180 feet, while the approximate elevation of the proposed development area, located about one-mile due west, is approximately 50 feet. In addition, directly makai of the highway is a berm with an elevation of approximately 188 feet, which blocks views to the coastline. 24. Coastal Hazards: The Proposed Project is not expected to be adversely affected by flood or tsunami hazards. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), the site is located within Flood Zone X, indicating a minimal risk of flooding, and the proposed development is not anticipated to increase flood risk to surrounding properties. Although the site falls within the County’s designated Extreme Tsunami Evacuation Zone defined as a major event, such as a magnitude 9.0 earthquake in Alaska, which may generate tsunami impacts extending further inland than the standard 100-year historic tsunami evacuation zones, its inland location approximately one mile from the shoreline makes tsunami impacts unlikely. Further, an analysis was conducted to evaluate the site’s exposure to a 3.2-foot sea level rise (SLR) scenario. The proposed project is located approximately one mile inland from the nearest shoreline and, due to its elevation, lies outside both the 3.2-foot and more extreme 6-foot SLR exposure areas. Mitigation measures will be incorporated to protect infrastructure and services. PUBLIC UTILITIES AND SERVICES 25. Vehicular Access: Mauna Lani “Site M” is readily accessible via existing internal private resort roadways, including North Kaniku Drive and Ho‘ohana Street, which connect to the regional roadway network. The site is located approximately 0.75 miles west of Queen Kaʻahumanu Highway and 0.4 miles north of Mauna Lani Drive. An Emergency Evacuation Road is proposed northeast of the “Site M” parcels, extending through TMKs (3) 6-8-001:050 and (3) 6-8-001:052 to provide a connection between “Site M”, Puakō and Queen Kaʻahumanu Highway. 26. Water: SMA Permit No. 07-019 identifies available potable water service from an existing 24-inch waterline on Ho‘ohana Street and a 12-inch waterline on North -14- -14- Kaniku Drive. The Department of Water Supply (DWS) states the water must be allocated from the tri-party agreement to secure potable water resources while utilizing non-potable sources for irrigation (Planning Department Exhibit 5 – Department of Water Supply). This tri-party agreement, executed on April 6, 2006, between Mauna Lani Service, Inc., Mauna Kea Properties, Inc., and the County of Hawai‘i Water Board, established a long-term potable water supply for the resort. Under the agreement, the resort funded and developed key infrastructure, including Parker Wells No. 3 and 4, which were dedicated to DWS. In return, the resort secured water allocation from the regional system, while also providing a public benefit through additional system capacity. The wells now operate as part of the DWS Lalamilo Water System. Pursuant to the agreement, all unused water unit allocations shall be returned to the ownership of the Department of Water Supply on May 26, 2029. The applicant is currently working with the Department of Water Supply to amend the agreement to provide for an extension of time. A July 2025 Water Use Study prepared by Akinaka & Associates, Ltd. confirms that sufficient potable water capacity exists to support full build-out of the Mauna Lani Resort. The resort has an average day allocation of 4.009 million gallons per day (MGD) (6.013 MGD maximum day), with current usage at 2.738 MGD. The proposed project is estimated to require 0.578 MGD (0.866 MGD maximum day), leaving a remaining surplus of approximately 0.693 MGD (1.040 MGD maximum day). Irrigation for the resort’s golf courses is supplied by a separate non-potable water system utilizing brackish water from on-site wells, consistent with the resort’s original development plan. 27. Wastewater: As established under SMA Permit No. 07-019, wastewater generated within “Site M” is proposed to be treated at the private wastewater treatment facility operated by Hawai‘i American Water Company (HAWC), which serves the Mauna Lani Resort. The original approval contemplated the construction of on-site sewer pump station(s) and force mains to convey flows to the existing treatment facility located mauka of the site. The existing wastewater treatment plant, located northeast of Site M, has a design peak capacity of -15- -15- approximately 1.1 million gallons per day (mgd), with current average flows of approximately 0.3 mgd, indicating available capacity. Treated effluent is reused for landscape irrigation, with future plans for additional disposal via an injection well. The proposed project is estimated to generate approximately 160,510 gallons per day of wastewater. Site M is within HAWC’s service area and will connect to the existing system, with a “will serve” commitment is anticipated at the appropriate stage of development. Development will include extension of off- site and on-site sewer infrastructure, including pump stations and force mains. Consultation with HAWC in August 2025 confirmed that facility upgrades, including filtration improvements, will be required to accommodate the additional demand. Based on available capacity, planned improvements, and system coordination, adequate wastewater infrastructure is available to serve the proposed project. 28. TRAFFIC: The applicant acknowledges and agrees to comply with the requirements set forth in Condition No. 10 of the original SMA approval. The recommendations associated with that condition were documented in a Traffic Impact Assessment Report (TIAR) prepared by Wilson Okamoto Corporation in February 2007. The applicant is not requesting any amendment to those requirements. The Hawai‘i Department of Transportation (HDOT) has indicated that these conditions must be satisfied, as reflected in (Planning Department Exhibit 6 – Hawai‘i Department of Transportation). With respect to the proposed emergency access corridor intended to address Condition No. 6, which requires the applicant to construct an emergency access road to serve the Mauna Lani Resort and Puako community, HDOT further commented that the applicant shall coordinate a meeting with the Highways Division, Hawai‘i District Office, to discuss the feasibility of the proposed emergency access connection to the state-owned Queen Ka‘ahumanu Highway. HDOT also noted that state highways are typically controlled-access facilities, as defined by Hawai‘i Revised Statutes § 264-61, under which owners or occupants of abutting lands, and other persons, have no right or easement of access, light, air, or view, or possess only -16- -16- a limited and controlled right of access. 29. Other Essential Utilities and Services: Electricity, telephone, and internet services are available to the site. AGENCIES' COMMENTS 30. State of Hawaii Department of Health: (Planning Department Exhibit 2 – February 6, 2026, Memo). 31. Department of Land and Natural Resources- Land Division: (Planning Department Exhibit 3 – February 23, 2026, Email). 32. State of Hawaii Office of Planning and Sustainable Development (OPSD): (Planning Department Exhibit 4 – March 4, 2026, Letter). 33. Department of Water Supply (DWS): (Planning Department Exhibit 5 – March 6, 2026, Letter). 34. State of Hawai‘i Department of Transportation (HDOT): (Planning Department Exhibit 6 – March 20, 2026, Letter). AGENCIES - NO RESPONSE 35. County Department of Public Works – Engineering, Traffic & Building Divisions; State Historic Preservation Division, County Department of Environmental Management, County Civil Defense, County Fire Dept., Department of Land and Natural Resources Division of Forestry and Wildlife. PUBLIC COMMENTS 36. Testimony from Jay M. Uyeda (Planning Department Exhibit 7 – March 30, 2026, Email). 37. Testimony from Robert Kildow (Planning Department Exhibit 8 – April 2, 2026, Email) 38. Testimony from Hawaii Hospitality Group (Planning Department Exhibit 9 – April 6, 2026, Email). 39. Testimony from Carl A. Carlson, Jr., (Planning Department Exhibit 10 – April 9, 2026, Email). 40. Testimony from Doug Clark, (Planning Department Exhibit 11 – April 8, 2026, Email). -17- -17- 41. Testimony from Elizabeth Brundt, (Planning Department Exhibit 12 – April 13, 2026, Email). 42. Testimony from Micah Kane, (Planning Department Exhibit 13 – April 14, 2026, Email). 43. Testimony from David and Alexis Colker, (Planning Department Exhibit 14 – April 14, 2026, Email). 44. Testimony from Sara and Allen Soltan, (Planning Department Exhibit 15 – April 16, 2026, Email). APPLICANT’S RESPONSE TO AGENCY COMMENTS 45. Response to DWS Comment (Planning Department Exhibit 16, – April 10, 2026, Letter) 46. Response to HDOT Comment (Planning Department Exhibit 17 – April 13, 2026, Letter) 47. Response to HDOT Comment (Planning Department Exhibit 18 – April 15, 2026, Letter) SPECIAL MANAGEMENT AREA USE PERMIT APPLICATION COUNTY OF HA WAil PLANNING DEPARTMENT (Type or legibly print the requested information) APPLICANT: OHL Mahi Site M C & D •-~ i Propco C APPLICANT'S SIGNATURE: ,:-~.-~ _..,,..,-: ___ DATE: ~,:,~m- ADDRESS: 235 Montgomery Street, Su,ite/f 1 :ref San Fransisco, CA 94104 LIST APPLICANT'S INTEREST IF NOT OWNER: ___________ _ LIST PRINCIPAL(S) INCLUDING NAMES OF MAIN OFFICERS: ______ _ PH0NE:(Bus.) fu&> .,..'$f??r(i) (Res.) _____ (Fax) ___ _ LANDOWNER(S): DHL Mahi Site LLC & HL Mahi Propco LLC LANDOWNER SIGNATURE(S):...,Z_d.r:,,d.~~~~~~~- LANDOWNER(S) ADDRESS: _________________ _ 235 Montgomery Street, Suite 1130 San Fransisco, CA 94104 REQUEST:Amendment to SMA Permit 07-019 Amendment to SMA Permit 07-019 TAX MA p KEY:<3) 6-8-001:054, (3) 6-8-022:010, (3) 6-8-001:050 & (3) 6-8-001:052 ZONING: RM-4, OPEN, V-1.25 &A-Sa SIZE OF PROPERTY OR AFFECTED AREA(S):_~_1_5_0_A_cr_e_s _______ _ AGENT: Wilson Okamoto Corporation ADDRESS: 1907 South Beretania Street! Suite 400 Honolulu! HI 96826 TELEPHONE:(Bus.) (808)946-2277 (Res.) (808)946-2277 (Fax)_(808)946-2277 Please indicate to whom original correspondence and copies should be sent. ORIGINAL: __ Je_ff_D_arr_o_w ______ COPIES: ________ _ Planning Dept. Exhibit 1 APPLICATION FOR AMENDMENT TO SPECIAL MANAGEMENT AREA USE PERMIT: SMA07-019 MaunaLani Waikoloa, South Kohala, Hawai'i Tax Map Keys: (3) 6-8-001 :054, (3) 6-8-022:01 0 (3) 6-8-001 :050 (por.) & (3) 6-8-001 :052 (por.) Applicant: DHL Mahi Site M, LLC 235 Montgomery Street, Suite 1130 San Francisco, CA94104 & DHL Mahi PropCo, LLC 235 Montgomery Street, Suite 1130 San Francisco, CA94104 Authorized Agent: Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400 Honolulu, Hawai'i 96826 January 2026 Contents MAUNALANI Amendment to SMA Permit 07-019 TABLE OF CONTENTS Page Project Components and Terminology .......................................................................................... 4 PROJECT SUMMARY ..................................................................................................................... 5 1. PROPOSED PROJECT DESCRIPTION ...................................................................................... 5 1.1 Proposed Project Background ....................................................................................... 5 1.2 Proposed Project Location ............................................................................................ 7 1.3 Proposed Amendments to Project ................................................................................. 9 1.4 Surrounding Uses ....................................................................................................... 16 1.4.1 Surrounding Landowners ........................................................................................ 17 1.5 Proposed Project Cost ................................................................................................ 17 1.6 Chapter 343, HRS Compliance ................................................................................... 17 2. EXISTING ENVIRONMENT, IMPACTS AND MITIGATION MEASURES ........................................ 18 2.1 Climate ...................................................................................................................... 18 2.2 Natural Hazards ......................................................................................................... 18 2.2.1 Flood and Tsunami Hazard ...................................................................................... 18 2.2.2 Sea Level Rise ............................................................................................................ 21 2.3 Geology, Topography and Soils .................................................................................... 21 2.4 Flora and Fauna .......................................................................................................... 25 2.5 Historic, Archeological and Cultural Resources ........................................................... 26 2.6 Traffic ......................................................................................................................... 29 2.7 Infrastructure ............................................................................................................. 29 2.7.1 Water ......................................................................................................................... 30 2.7.2 Electrical, Phone, Cable .......................................................................................... 31 2.7.3 Solid Waste and Sewage Disposal. .......................................................................... 31 2. 7 .4 Site Grading and Storm Drainage ............................................................................. 32 2.8 Public Access ............................................................................................................. 32 3. RELATION TO LAND USE PLANS AND POLICIES ................................................................... 34 3.1 State Land Use Districts ............................................................................................. 34 3.2 Coastal Zone Management Program (CZM) .................................................................. 36 3.3 Special Management Area Guidelines (SMA) ............................................................... 36 3.3.1 Compliance with SMA 07-019 Conditions ................................................................ 37 3.4 County Zoning ............................................................................................................ 38 3.5 Hawai'i County General Plan ....................................................................................... 40 Mauna Lani 2 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 3.6 South Kohala Community Development Plan .............................................................. 41 4. ALTERNATIVES TO PROPOSED PROJECT .............................................................................. 42 5. UNAVOIDABLE ENVIRONMENTAL IMPACTS .......................................................................... 42 5.1 Mitigation Measures .......................................................................................................... 42 LIST OF FIGURES Figure 1 :Proposed Project Location Map ....................................................................................... 8 Figure 2: 2007 SMA 07-019 Approved "Site M" Master Plan Map ................................................... 13 Figure 3: Proposed SMA Amendment "Site M" Master Plan Map ................................................... 14 Figure 4: Emergency Evacuation Road Corridor Map .................................................................... 15 Figure 5: Flood Insurance Rate Map ............................................................................................ 19 Figure 6: Tsunami Evacuation Map .............................................................................................. 20 Figure 7: Sea Level Rise Exposure Map ........................................................................................ 23 Figure 8: Soil Classification Map ................................................................................................. 24 Figure 9: State Land Use Map ...................................................................................................... 35 Figure 10: County of Hawai'i Zoning Map ..................................................................................... 39 LIST OF TABLES Table 1, Proposed Project Summary .............................................................................................. 5 Table 2, 2007 Approved"Site M" Master Plan & Proposed SMA Amendment "Site M" Master Plan Comparison ............................................................................................................................... 12 ATTACHMENTS Attachment A List of Surrounding Landowners Appendix A AppendixB AppendixC Appendix D Appendix E Appendix F AppendixG Appendix H Appendix I Mauna Lani APPENDICES Original SMA 07-019 Application Approval Letter 2015 Administrative Time Extension Letter from Planning Director 2023 SMAAutomatic Time Extension Approval Letter 2024 SMA Compliance Determination Letter for Hotel Redesign AECOS. Natural Resource Assessment ASM Affiliates. Archeological Literature Review and Field Inspection -"Site M" ASM Affiliates. Archeological Field Inspection -Emergency Access Road ASM Affiliates. Ka Pa'akai O Ka 'Aina Analysis Wilson Okamoto. Preliminary Engineering Report Amendment to SMA Permit 07-019 3 MAUNALANI Amendment to SMA Permit 07-019 Project Components and Terminology For clarity, the following key terms and components referenced throughout this application are defined below. • The Proposed Project: The Proposed Project encompasses both the "Site M" project area and the Emergency Access Road project area. These two distinct but related components are collectively referred to in this application as the Proposed Project. • "Site M": This is the primary component of the Proposed Project. It involves the master plan update for the main 150-acre "Site M" development area, which includes all proposed residential and hotel uses. "Site M" is located on Tax Map Keys (TM Ks) (3) 6-8-001 :054 and (3) 6-8-022:010. • Emergency Evacuation Road: This is a separate but related component of "Site M". This road is required under Condition 6 of the original SMA approval (SMA 07-019). This road is intended to provide emergency access / egress for the broader Mauna Lani Resort area. The conceptual planning for the proposed route is located on TM Ks (3) 6-8-001 :050 (por.) and (3) 6-8-001 :052 (por.). Mauna Lani 4 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 PROJECT SUMMARY Type of Document Amendment to Special Management Area Permit 07-019 Applicant and Recorded Fee DHL Mahi Site M, LLC & DHL Mahi Propco, LLC Owner Approving Agency County of Hawai'i Planning Department -West Hawai'i West Hawai'i Civic Center 74-5044 Ane Keohokalole Highway, Building E, 2nd Floor, Kailua-Kona, HI 96740 Agent Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400 Honolulu, Hawai'i 96826 Contact: Mr. Keola Cheng, (808) 946-2277 Carlsmith Ball LLP 121 Waianuenue Avenue Hilo, Hawai'i 96720 Contact: Katherine A. Garson, (808) 935-6644 & Steve S.C. Lim, (808) 523-2500 Tax Map Key(s) (3) 6-8-001 :054 and (3) 6-8-022:010 ("Site M"); (3) 6-8-001 :050 (por.) and (3) 6-8-001 :052 (por.) ("Emergency Evacuation Road") Land Area Approximately 150 Acres County of Hawai'i Zoning RM-4 OPEN V-1.25 A-Sa State Land Use Classification Urban Agriculture 2005 County General Plan "Land Resort, Urban Expansion, and Open Use Pattern Allocation Guide" County Community South Kohala Community Development Plan Development Plan Table 1, Proposed Project Summary 1. PROPOSED PROJECT DESCRIPTION 1.1 Proposed Project Background In 2007, Stanford Carr Development, LLC applied for a Special Management Area (SMA) Permit. The Hawai'i County Planning Commission approved the permit (SMA 07-019) in 2008, authorizing the development of "Mauna Lani Site M,'' an approximately 150-acre area within the Mauna Lani Resort. The approved master plan for "Site M" authorized the development of 1,207 units, consisting of 691 Mauna Lani 5 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 residential units and 516 hotel units (rooms). The master plan included residential development across six designated parcels and hotel development on two central parcels, combining traditional hotel accommodations with low-density bungalow units (See Appendix A for SMA 07-019 Approval letter). In addition, the approved master plan also incorporated a three-hole executive golf course, a conference center, swimming pools, tennis facilities, gardens, water features, outdoor function areas, landscaped open spaces, pedestrian walking paths, and 1,871 parking stalls, along with associated infrastructure improvements. The original SMA approval anticipated an 8-10-year period of phased development, with infrastructure to be constructed in conjunction with project scaling or building occupancy. The proposed development was found to be consistent with the Hawai'i County General Plan, and Hawai'i County Code Chapter 25 (Zoning), and was also found consistent with the objectives and policies of chapter 205A, HRS and the Planning Commission's SMA guidelines. SMA 07-019 was approved subject to 24 conditions of approval, compliance with which are discussed below. On April 14, 2015, the Planning Director granted an initial 5-year administrative time extension until September 4, 2023 to allow sufficient time to proceed, with a second 5-year administrative time extension to September 4, 2028 to be automatically approved upon issuance of permits for the development of core infrastructure (albeit, not including improvements to the Mauna Lani Resort entry or intersection at Queen Ka'ahumanu Highway and Mauna Lani Drive) (See Appendix B). On March 16, 2023, the automatic extension from September 4, 2023 to September 4, 2028 was granted by the Planning Director as DHL secured Grading Permit No. PW.ENG2022-00248 (See Appendix C for the Administrative Time Extension). On October 3, 2024, the Planning Director issued an SMA compliance determination letter regarding a pivot towards a then proposed dual-branded hotel concept. This plan involved changes to both hotel parcels, 3A and 3B, within "Site M". The determination addressed the proposal to consolidate the 100 previously approved hotel bungalows on Parcel 3B into a second 4-story hotel, while also redesigning the main hotel on the adjacent Parcel 3A. The letter confirmed that this entire dual- branded approach for both parcels was found to be in general compliance with the existing entitlements under SMA 07-019. (See Appendix D). The Applicant now proposes to amend SMA 07-019 by reducing the size from 1,207 units to 925 units, representing a 23.4 % reduction in overall density. This includes a decrease in hotel rooms from 516 rooms to 374 rooms (27% reduction) and a decrease in residential units from 691 residential units to Mauna Lani 6 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 551 residential units (20% reduction). As a result, the average density would drop from 8.9 dwelling units per acre to 6.2 dwelling units per acre (See Section 1.3 for further details). In addition to reducing the overall density, the proposed amendment also eliminates certain recreational and conference facilities and consolidates building footprints to increase landscaped open space. This amendment also addresses a separate but related component: the Emergency Evacuation Road, which is required under Condition 6 of SMA 07-019. 1.2 Proposed Project Location As previously mentioned, "Site M" is located within the Mauna Lani Resort, a master-planned resort community along the South Kohala coast of Hawai'i Island, which is situated makai (west) of Queen Ka'ahumanu Highway. Administratively, the Proposed Project lies within the ahupua'a of Waikoloa in the South Kohala District. Geographically, it is situated on the western slopes of Mauna Loa on the Kona side of the island. "Site M" is composed of two parcels, identified by Tax Map Keys (TM Ks) (3) 6- 8-001 :054 and (3) 6-8-022:010, which together encompass approximately 150-acres. The Emergency Evacuation Road is being conceptually planned to the east of the "Site M" parcels, extending through TM Ks (3) 6-8-001 :050 and (3) 6-8-001 :052, to connect "Site M' to Queen Ka'ahumanu Highway (See Figure 1). "Site M" is bordered to the southwest by North Kaniku Drive, and to the west by Holes 5 through 7 of the Mauna Lani North Golf Course, while also sharing this western boundary with the Villages at Mauna Lani residential condominiums. The remaining lands to the north and east of the Proposed Project are comprised of largely undeveloped lands. The Kulalani at Mauna Lani condominium and the Ka Milo at Mauna Lani condominium are both located in the near vicinity of the Proposed Project, or just west of the Mauna Lani North Golf Course golf holes that border the Proposed Project. Mauna Lani "Site M" is immediately accessible via existing internal resort roadways, including North Kaniku Drive and Ho'ohana Street, which connect to the broader regional roadway network. Mauna Lani "Site M" is located approximately 0. 75 miles west of Queen Ka'ahumanu Highway and 0.4 miles north of Mauna Lani Drive. Mauna Lani 7 Amendment to SMA Permit 07-019 FIGURE 1 -PROPOSED PROJECT LOCATION MAP Mauna Lani Resort ~•ll#ill'd3@1kl HIio Q Kamuela, Big Island, Hawai'i LEGEND --··---= Site M '--••-□ Parcels Emergency Evac Road Corridor Roads ft --==----c::===Feet ~ , 0 435 870 1,740 2,610 MAUNALANI Amendment to SMA Permit 07-019 1.3 Proposed Amendments to Project Maune Lani "Site M" The Applicant proposes to amend SMA 07-019 (See Figure 2 for Approved Mauna Lani "Site M" Master Plan from 2007). The subject amendment seeks to implement a revised master plan for Mauna Lani "Site M" that is intended to reduce the total Proposed Project unit count from 1,207 to 925 units-a 23.4% overall reduction-including a 27% reduction in hotel rooms (516 to 374), and a 20% reduction in residential units (691 to 551 ). The average density would decrease from 8.9 du/ac to 6.2 du/ac (See Figure 3 for Proposed SMAAmendment "Site M" Master Plan Map). Under this Proposed Project, key program elements approved in the original 2007 SMA application are proposed to be removed or modified. Specifically, the previously approved three-hole golf course would no longer be constructed; the area designated for these uses would remain as landscaped open space. The 20,000-square-foot conference center originally planned as part of the main hotel facility on Parcel 3A would also be removed. Hotel uses would be reconfigured to concentrate guest accommodations into fewer, consolidated structures rather than the combination of a single hotel building and multiple dispersed bungalows as approved of in 2008. This change reduces the total building footprint of the Proposed Project while allowing for increased landscaped and open space areas throughout the hotel parcels. By replacing the bungalows and their associated walkways with a more compact design, the total amount of hardscape is significantly reduced, which improves natural on-site drainage and minimizes stormwater runoff. The updated hotel program also introduces a dual-branded concept in which the two primary hotel buildings would share common amenities such as pools, dining areas, and fitness facilities. The dual-branded hotel concept, allowing the original 100 hotel bungalow plan at an approved height of 40 feet to be redesigned into a second 4-story hotel at 45 feet in height was previously found to be in compliance with the existing SMA permit via an SMA Compliance Determination issued by the Planning Director on October 3, 2024 (Appendix D). Overall, the modifications outlined in the Proposed Project adjust building placement and site coverage, reduce overall density, and reallocate certain land areas from built structures to open space, while retaining the resort-residential land use mix approved under the SMA 07-019. Component-specific changes requested in this Amendment to SMA 07-019 are as follows: Mauna Lani 9 Amendment to SMA Permit 07-019 Residential Component MAUNALANI Amendment to SMA Permit 07-019 • Parcel 1: Remains 7 acres; reduced from 76 to 56 units (26.3% reduction). Mix of stacked-flat1 and townhome2 units at 8 du/ac. • Parcel 2: Remains 12.8 acres; reduced from 138 to 102 units (25.8% reduction). Mix of stacked-flat and town home units at 8 du/ac. • Parcel 4: Remains 16.6 acres; reduced from 180 to 133 town home units (26.2% reduction) in two-story buildings, density 8 du/ac. • Parcel 5: Remains 13 acres; reduced from 141 to 104 units (26.2% reduction). Mix of stacked-flat and town home units at 8 du/ac. • Parcel 6: Remains 22.3 acres; no change from 2008 SMA approval-156 villa units in two-story buildings, density 6.9 du/ac. Hotel Component • Parcel 3A (Hotel): Remains 16.4 acres; increases slightly from 266 to 270 rooms (+1.5%), retaining four stories and the approved 45-foot height limit. Conference center removed. Building footprint reduced by 54%, with a 9% increase in open space. New dual-branded hotel concept to share amenities with Parcel 3B. • Parcel 3B (Hotel): Remains 16.1 acres; reduced from 250 to 104 rooms (58.4% reduction). Also, 100 bungalow buildings will be replaced with one four-story hotel (maximum 45 feet). Building footprint reduced by ~75%, with a 10% increase in open space. Amenities shared with Parcel 3A. The Proposed Project adjusts the distribution of residential, and hotel uses, reduces the overall density, eliminates certain recreational and conference facilities, and consolidates building footprints to increase landscaped open space within "Site M". Table 2 summarizes the numerical changes to each parcel, providing a direct comparison between the 2007 SMA approved master plan and the current Proposed Project. Emergency Evacuation Road Component Condition 6 of SMA 07-019 requires the Applicant, to the extent allowable by the applicable governmental agencies and private entities, to take commercially reasonable steps to construct an alternate Emergency Evacuation Road from the Mauna Lani Resort and the Puako community. The Applicant has initiated discussions with the County on the design of the Emergency Evacuation Road and this element is being included as part of the Proposed Project. The Emergency Evacuation Road is being evaluated using a corridor-based approach rather than a fixed alignment, extending from "Site M"to the regional road network at Queen Ka'ahumanu Highway. 1 A single-level home that has another home located directly above or below it. 2 A multi-level home that shares one or more side walls with neighboring homes, but has no one living above or below it Mauna Lani 10 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 Multiple potential roadway alignments are feasible within this corridor; however, additional evaluation is being undertaken to ensure that the final alignment appropriately responds to site constraints, including cultural resources. Archaeological and engineering studies have been completed across the corridor to identify potential issues and to inform future design decisions, with the intent of providing a safe, reliable, and compliant emergency access and evacuation route for the community. The Emergency Evacuation Road corridor is located east of the "Site M" parcels and traverses predominantly fallow lands. The corridor runs adjacent to the South Kohala Fire Station and the wastewater treatment plant serving the broader Mauna Lani Resort area. The roadway is planned to connect directly to the fire station, enhancing emergency response access while also providing an alternate evacuation route. Archaeological field inspections conducted by ASM Affiliates identified a historic ranching wall within the vicinity of the corridor, intersecting portions of preliminary route options. In response, additional archaeological fieldwork was completed to document a wider corridor encompassing multiple potential alignments. This effort identified a pre-existing 12-meter- wide breach in the wall associated with an existing utility easement / access road as a potential crossing location. This may be one of the final road alignments selected for the permanent Emergency Evacuation Road. While the final roadway alignment has not yet been determined, it will be located within the surveyed corridor, allowing flexibility in final design while ensuring that historic resources are appropriately considered and protected (see Figure 4, Emergency Evacuation Road Corridor, showing historic ranching wall). Should final design activities indicate that the historic wall may be directly or indirectly affected, the applicant will coordinate with the State Historic Preservation Division (SHPD) in accordance with Hawai'i Revised Statutes (HRS) and obtain all necessary reviews and approvals prior to initiating any ground-disturbing activities. This process will ensure that any potential impacts to historic resources are appropriately addressed and mitigated through consultation with SHPD. Supplemental Studies Conducted to Support this Amendment Request In support of this Proposed Project requesting to Amend SMA 07-019, the Applicant: (1) updated the Natural Resource Assessment; (2) conducted an Archaeological Field Inspection and Literature Review; (3) conducted an Archaeological Field Inspection for the Emergency Evacuation Road; (4) conducted a Ka Pa'akai analysis; and (5) updated the Preliminary Engineering Report which supported the original approved SMA. Modification to Condition No. 2: Proposed Project Completion Timeline In addition to the site plan modifications, the Applicant requests a modification to Condition No. 2 of SMA Permit No. 07-019, which governs the timeline for the Proposed Project completion. The original permit and its subsequent administrative extensions (detailed in Appendices C and D) established a current completion deadline of September 4, 2028. The Applicant therefore requests a new ten-year period to complete construction, commencing from the effective date of this SMA Amendment Mauna Lani 11 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 approval. Granting a new ten-year period will ensure the orderly and successful completion of the Proposed Project as described in this amendment. Table 2: 2007 Approved SMA 07-019 "Site M" Master Plan & Proposed SMAAmendment "Site M" Master Plan Comparison % Parcel Acreage 2007 Approved Plan Proposed "Site M" Plan Change in Units 76 stacked-flat units; 2 stories; 56 stacked-flat & townhome 1 7.0 -26.3% max height 31 ft; 10.9 du/ac units; 2 stories; 8 du/ac 138 stacked-flat units; 2 102 stacked-flat & townhome 2 12.8 stories; max height 44 ft; 10.8 -25.8% du/ac units; 2 stories; 8 du/ac 266 hotel rooms; 3--4 stories; 270 hotel rooms; 4 stories; max 3A height 45 ft; no conference 16.4 max height 45 ft; attached +1.5% (Hotel) 20,000-sf conference center center; dual-branded concept; footprint -54%; open space +9% 250 hotel rooms in 100 104 hotel rooms in 1 four-story 3B building; max height 45 ft; shared 16.1 bungalow buildings; 1-2 -58.4% (Hotel) stories; max height 40 ft amenities w/3A; footprint -75%; open space +10% 4 16.6 180 townhome units; 3 stories; 10.8 du/ac 133 town home units; 2 stories; 8 du/ac -26.2% 141 townhome units; 2 stories; 104 stacked-flat & town home 5 13.0 -26.2% max height 35 ft; 10.8 du/ac units; 2 stories; 8 du/ac 6 22.3 156 villa units; 2 stories; max No change -156 villa units; 2 0% height 26 ft; 6.9 du/ac stories; 6.9 du/ac 104.2 ac 1,207 units total (691 925 units total (551 residential+ 374 hotel) at 6.2 du/ac; golf -23.4% Totals (residential/ residential+ 516 hotel) at 8 course and conference center total hotel du/ac; includes 3-hole golf removed; increased preserved units parcels) course & conference center open space Table 2, 2007 Approved"Site M" Master Plan & Proposed SMA Amendment "Site M" Master Plan Comparison Mauna Lani 12 Amendment to SMA Permit 07-019 Figure 2 -2007 SMA 07-019 Approved "Site M" Master Plan Map Mauna Lani Resort Parcel 1 ( Stacked Flats, 2 Stories, 76 Units, 7 Acres, 10.9 DU/AC I Parcel 2 ( Stacked Flats, 2 Stories, 138 Units, 12.8 Acres, 10.8 DU/AC) Parcel 3A ( Hotel Main Building, 3-4 Stories, 184 Units/ 266 Keys, 16.4 Acres, 11.2 DU/ AC) Parcel 3B ( Hotel Bungalows, 1 & 2 Stories, 100 Units/ 250 Keys, 16.1 Acres, 6.5 Keys/ AC) I" --, Parcel 4 L - -.J ( Townhomes, 2 Stories, 180 Units, 16.6 Acres, 10.8 DU/AC I .---, Parcel 5 L - -.J ( Townhomes, 2 Stories, 141 Units, 13.0 Acres, 10.8 DU/AC) Parcel 6 ( Villas, I Story, 156 Units, 22.3 Acres, 7.0 DU/AC) Kamuela, Big Island, Hawai'i TOTAL RESIDENTIAL UNITS TOTAL HOTEL UNITS Figure 3 -Proposed SMA Amendment "Site M" Master Plan Map Mauna Lani Resort ( Townhomes/ Stacked Flats, 56 Units, 7 Acres, 8 DU/AC) ( Townhomes/ Stacked Flats, 102.4 Units, 12.8 Acres, 8 DU/AC) ( Hotel Building 1, 4 Stories, 270 Units, 16.4 Acres, 16.2 Units/ AC) Parcel 3B ( Hotel Building 2, 4 Stories, 104 Units, 16.1 Acres, 6.5 Units/ AC) Parcel 4 ( Townhomes/ Stacked Flats, 132.8 Units, 16.6 Acres, 8 DU/ AC) Parcel 5 ( Townhomes/ Stacked Flats, 104 Units, 13.0 Acres, 8 DU/AC) Parcel 6 ( Villas, I Story, 156 Units, 22.3 Acres, 7.0 DU/AC) -OpenSpace 551 374 23% Kamuela, Big Island, Hawai'i TOTAL RESIDENTIAL UNITS TOTAL HOTEL UNITS TOTAL DENSITY REDUCTION FIGURE 4 -Emergency Evacuation Road Corridor Map Mauna Lani Resort PROJECT VICINllY Kamuela, Big Island, Hawai'i SIHP 50-10-11-21975 f: :i Emergency Evac Road Corridor () 0 120,000240,000 480,000 Feet 720,000 1.4 Surrounding Uses MAUNALANI Amendment to SMA Permit 07-019 "Site M" is located within the Mauna Lani Resort, a master-planned community established in 1978 that includes two major hotels, two 18-hole golf courses, and various residential and commercial areas. "Site M" is bordered to the west by Holes 5 through 7 of the Mauna Lani North Golf Course and The Villages at Mauna Lani residential community. The southwestern boundary is defined by North Kaniku Drive, while the southeastern boundary runs along Ho'ohana Street. Beyond Ho'ohana Street are largely vacant lands, except for the Cole Academy and several resort support facilities. The remaining lands to the north and east of "Site M" are undeveloped. "Site M" is directly accessible via the internal resort roadways of North Kaniku Drive and Ho'ohana Street and is located approximately 0.75 miles west of Queen Ka'ahumanu Highway. The two major resort hotels in the vicinity of the Proposed Project are the Fairmont Orchid, Hawai'i and the Mauna Lani, Auberge Resorts Collection, which was renovated in 2018. The Shops at Mauna Lani, a commercial center, is located approximately a quarter-mile southwest of the "Site M". Several other active residential communities are also in the near vicinity, including The Fairways at Mauna Lani, the 126-unit Kulalani at Mauna Lani, and the 136-unit Ka Milo at Mauna Lani, which are situated just west of the bordering golf course. A number of resort support and community facilities are situated along Ho'ohana Street, including a maintenance and service area, a privately operated wastewater treatment plant, a resort plant nursery, and the Mauna Lani Resort Association offices. The Seagull School at Mauna Lani, which was referenced in the original SMA 07-019 application, is no longer listed at this location and has transitioned to new locations on O'ahu, however, the Cole Academy at Mauna Lani, which offers preschool and daycare services, is currently operating at the former Seagull School location. Important public amenities in the Proposed Project vicinity include Holoholokai Beach Park and the Puako Petroglyph Archaeological Park, both of which are located north of "Site M" and remain open to the public. The land surrounding the proposed Emergency Evacuation Road route, located east of the "Site M" parcels, is characterized by predominantly fallow, undeveloped lands. Two key facilities are situated within this area: the resort's Wastewater Treatment Plant, operated by Hawai'i American Water Company, and the South Kohala Fire Station, which serves the broader community. Mauna Lani 16 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 1.4.1 Surrounding Landowners According to SMA guidelines, all owners and lessees of properties within 300 feet of the Proposed Project sites ("Site M" and Emergency Evacuation Road) are required to be notified of this application. Please see Attachment A for the list of all surrounding land owners and lessees. 1.5 Proposed Project Cost The original SMA 07-019 plan improvements and the current Proposed Project improvements have a valuation in excess of $750,000 and thus an amendment to the SMA 07-019, an SMA Major Permit, is required. 1.6 Chapter 343, HRS Compliance The decrease in density proposed in the Proposed Project does not trigger HRS 343 review3• 3 Note that an Environmental Impact Statement was accepted by the Land Use Commission on July 23, 1985 in support of the Land Use District Boundary Amendment from the Agricultural District to the Urban District in Docket No. A84-583. See https://files.Hawai'i.gov/dbedt/erp/EA EIS Archive/1985-06-DD-HA-FEIS-Mauna-Lani-Resort-Revised-Master-Plan.pdf Mauna Lani 17 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 2. EXISTING ENVIRONMENT, IMPACTS AND MITIGATION MEASURES 2.1 Climate The Proposed Project is located on the far western slopes of Mauna Loa, within the relatively dry climate of West Hawai'i. The climate can be characterized as mild sub-tropical, with a fairly constant temperature throughout the year. Average temperatures range from approximately 72°F in the coolest months to 77°F in the warmest months. This area receives a low amount of annual precipitation, averaging approximately seven to nine inches per year. The Proposed Project's location within this specific climate zone is a key factor influencing the types of vegetation and natural conditions found within the Proposed Project. 2.2 Natural Hazards 2.2.1 Flood and Tsunami Hazard The Proposed Project is not anticipated to have adverse effects from flood and tsunami hazards. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), the Proposed Project site is designated as Flood Zone X, an area of minimal flood hazard, and the proposed improvements are not expected to increase flooding risk to adjacent properties (See Figure 5). Its inland location, approximately one mile from the nearest shoreline, places it within the "Extreme Tsunami Evacuation Zone" according to Hawai'i County's Tsunami Evacuation Zone maps, but due to its distance from the shoreline, impacts are very unlikely (See Figure 6). Mauna Lani 18 Amendment to SMA Permit 07-019 FIGURE 5 -FLOOD INSURANCE RATE MAP Mauna Lani Resort PROJECT VICINllY \\-\\-\\' -\\-...... 1\-\\ ' \,,, ✓ .... , ;_, ....... ' -- ,, ,, Kamuela, Big Island, Hawai'i LEGEND Emergency Evac Road Corridor ---Roads Flood Zones AE ~ AO X Oo 435 870 1,740 Feet 2,610 FIGURE 6 -TSUNAMI EVACUATION ZONES Mauna Lani Resort PROJECT VICINllY Kamuela, Big Island, Hawai'i LEGEND -··-= : Site M 111-11.I Emergency Evac Road Corridor Evacuation Zone Extreme Evacuation Zone Safe Zone ft --===----===::::iFeet ~ , 0 435 870 1,740 2,610 2.2.2 Sea Level Rise MAUNALANI Amendment to SMA Permit 07-019 Sea level rise (SLR) is a significant long-term threat to the South Kohala coast, posing potential vulnerabilities to the region's economy and communities. A study by the UH Sea Level Center indicates that Hawai'i has approximately 15 years to prepare for the impacts of SLR, with a rapid increase in the number of flood days projected by the mid-2030s. The Hawai'i Sea Level Rise Vulnerability and Adaptation Report, last updated in 2022, provides the latest projections from an intergovernmental report led by NOAA. These models suggest that Hawai'i will experience SLR between 0.7 and 1.5 feet by 2050, and could see a range of 1.3 to 8 feet by the end of the century. The combination of rising sea levels with projections for stronger and more frequent El Nino events and tropical cyclones in the waters surrounding Hawai'i suggests an increasing vulnerability to coastal flooding and erosion. The State Climate Change Commission has issued guidance recommending a 3.2-foot SLR as a planning benchmark for critical infrastructure with long lifespans and low-risk tolerance. An analysis was conducted to determine the site's vulnerability to this 3.2-foot SLR scenario. The Proposed Project is located approximately one mile inland from the nearest coastline. Due to this significant distance and its elevation, the Proposed Project is located well outside of the 3.2-foot and even the more extreme 6-foot SLR exposure areas (See Figure 7). Consequently, the Proposed Project is not expected to be directly impacted by coastal inundation or chronic flooding associated with these SLR scenarios. However, there will be mitigation measures in place to protect its infrastructure and services and is expected to adapt to evolving climate change science, technology, and policies. 2.3 Geology, Topography and Soils The island of Hawai'i was formed by six volcanoes: Mahukona, Kohala, Mauna Kea, Hualalai, Mauna Loa, and Kilauea. The island's foundation consists of both pahoehoe and 'a'a lava flows. The Proposed Project, located on the Kona side of the island, was formed by volcanic activity from either Mauna Loa or Mauna Kea. The Proposed Project site has a relatively flat elevation gain and is situated approximately 7 feet above mean sea level (msl). According to the U.S. Department of Agriculture's Natural Resource Conservation Service (NRCS), the soil underlying the Proposed Project's site is classified as "310 Auwaiakeakua extremely cobbly silt loam, 2 to 10 percent slopes." This soil series is a well-drained aridisol with rapid permeability, meaning it does not typically produce significant runoff. Its full taxonomic class is "Clayey-skeletal, isotic, isohyperthermic, Typic Haplocambids." This soil is primarily used for recreational and wildlife habitats, and its natural vegetation is often composed of invasive species adapted to dry conditions. Regarding "Site M", In the northeast corner of parcel TMK (3) 6-8-001 :054, the soil is "336-Puako fine sandy loam, 0 to 6 percent slopes." This soil type consists of alluvium, is well-drained, and has Mauna Lani 21 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 a medium runoff class. It is characterized by a medial fine sandy loam surface layer and a very high available water supply. Finally, a small portion in the south portion of TMK (3) 6-8-022:010 is classified as "10-Lava flows, 'a'a, 2 to 20 percent slopes," which is composed entirely of 'a'a lava and is excessively drained with a very low runoff class In the eastern portion of the proposed Emergency Evacuation Road route, specifically on parcel TMK (3) 6-8-002:050, the predominant soil is "336-Puako fine sandy loam, 0 to 6 percent slopes." This soil type consists of alluvium, is well-drained, and has a medium runoff class. It is characterized by a medial fine sandy loam surface layer and a very high available water supply. As the road extends further east into the larger parcel TMK (3) 6-8-001 :052, it encounters the "373-Hapuna-Waikui- Lalamilo complex, 0 to 20 percent slopes," a unit composed of volcanic ash over 'a'a lava flows. Within this complex, the Hapuna soils have a high runoff class, while the Waikui and Lalamilo soils have a low runoff class. This area is well-drained and features slopes of up to 20 percent (See Figure 8). Development of the Proposed Project will require site grading and earthwork to prepare building pads, roadways, and landscaped areas. While these construction activities have the potential for short-term impacts such as soil erosion and dust, a comprehensive mitigation plan will be implemented to minimize these effects. All earthwork will be conducted in strict compliance with the County of Hawai'i's grading ordinance and State of Hawai'i Department of Health water quality standards. Best Management Practices (BMPs) will be implemented throughout all phases of construction, including the use of temporary silt fencing, on-site water sources for dust control, phasing of grading activities, and prompt stabilization of disturbed areas. Furthermore, as recommended in the Preliminary Engineering Report, a geotechnical engineer will be retained during construction to verify soil conditions and confirm the performance of drainage systems. With this combination of regulatory compliance, on-site BMPs, and professional oversight, any potential impacts to topography and soils will be appropriately managed, and no significant long-term adverse impacts are anticipated. Mauna Lani 22 Amendment to SMA Permit 07-019 FIGURE 7 -Sea Level Rise Exposure Scenario Map Mauna Lani Resort PROJECT VICINllY Kamuela, Big Island, Hawai'i LEGEND --··, II-_ Site M ··---Emergency Evac Road Corridor D 1.1 Foot Scenario D 2.0 Foot Scenario D 3.2 Foot Scenario ft --===----===Feet ~ , 0 435 870 1,740 2,610 FIGURE 8 -SOIL CLASSIFICATION MAP Mauna Lani Resort ..,tl3•li#itl14ilih1i Hilo Q ( I Soil Kamuela, Big Island, Hawai'i Emergency Evac Road Corridor LJ 10 310 □312 □316 □336 □352 373 ft --===----===::::iFeet ~ , 0 435 870 1,740 2,610 MAUNALANI Amendment to SMA Permit 07-019 2.4 Flora and Fauna Natural Resources Assessment for an SMA Permit Amendment for Mauna Lani, "Site M'~ South Kohala Island of Hawai'i ( See Appendix E for full report) AECOS, Inc. conducted a Natural Resources Assessment in July 2025 for "Site M" to evaluate potential impacts on floral and faunal resources. The study included a terrestrial flora and fauna survey using wandering transects, avian point-count stations, and a mammalian survey. "Site M" is characterized as a savannah environment dominated by non-native plant species. Flora A total of 27 vascular plant species were recorded during the most recent botanical survey. Of these, three were indigenous species-'ilima (Sida fallax), 'uhaloa (Waltheria indica), and alena (Boerhavia acutifolia)-which are widely distributed across coastal and dry lowland habitats in the Hawai'ian Islands. No endemic species or early Polynesian introductions (canoe plants) were observed within "Site M". The flora assemblage reflects a low-diversity, disturbed environment typical of similar developments in South Kohala. Fauna Faunal resources within "Site M" are limited, consistent with the altered and dry nature of the habitat. Avian surveys recorded 14 bird species, with the majority being introduced species such as African silverbill (Euodice cantans), Java sparrow (Lonchura oryzivora), and common myna (Acridotheres tristis). A single endemic species, the Hawai'ian goose or Nena (Branta sandvicensis), was observed incidentally and is known to utilize nearby golf course habitats but does not nest or forage within the Proposed Project's footprint. One indigenous species, the Black-crowned Night Heron (Nycticorax nycticorax hoactlt), was also observed. No other native or listed avian species were recorded. Mammals documented in "Site M" were limited to feral goats (Capra hircus), evidenced by tracks and scat distributed throughout "Site M". While not directly observed, it is likely that introduced mammalian predators such as rats (Rattus spp.), mice (Mus musculus), and small Indian mongoose (Herpestes javanicus) also use resources within and around "Site M". Although the Hawai'ian hoary bat (Lasiurus semotus)-a federally and state-listed endangered species-mayfly over the area, no suitable roosting trees were observed within the Proposed Project. Conclusion The Proposed Project is not anticipated to result in significant impacts to biological resources within "Site M". No rare, threatened, or endangered plant or animal species were found within "Site M", and the area is characterized by previously disturbed, non-native vegetation. With standard best practices in place, no adverse effects to native species or habitats are expected. Mauna Lani 25 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 2.5 Historic, Archeological and Cultural Resources In July and August 2025, ASM Affiliates completed several key studies for "Site M" and its associated Emergency Evacuation Road, including an Archaeological Literature Review and Field Inspection (LRFI) for "Site M", an Archeological Field Inspection for the Emergency Evacuation Road Corridor, and a Ka Pa'akai O Ka 'Aina (KPA) analysis for "Site M". The goal was to update the conditions of previously identified archaeological sites, assess potential impacts, and address valued cultural resources, practices, and beliefs. Archeological Literature Review and Field Inspection for the Proposed Mauna Lani "Site M" (See Appendix F for full report) "Site M" is within the ahupua'a of Waik6loa, and a petroglyph field, listed on the National Register of Historic Places, is located adjacent to the northern and western boundaries of the "Site M". A 2007 AIS identified eight archaeological sites (Sites 50-10-11-24425 through -24432). These sites contained a total of 31 features, including pahoehoe excavations, C-shaped structures, abrader basins, and trail segments. The caves documented in the 2007 AIS were inspected and did not contain cultural materials, so they were not classified as archaeological sites. The 2007 AIS determined all eight sites were significant for their informational value and recommended "no further work". This was accepted by the State Historic Preservation Division (SHPD) in July 2008. The 2025 LRFI included a targeted field inspection to re-evaluate the sites. All eight sites were re- identified and were found to be in a condition similar to their original descriptions. The inspection confirmed that some features, such as the C-shaped structures and trail segments, appeared more likely to be natural formations than constructed features, though they were still documented as historic resources. Conclusion The 2025 LRFI confirmed that no new historic properties were identified on the surface of "Site M". All eight archaeological sites identified in the original 2007 Archeological Inventory Survey (AIS) were found to be in similar condition. The State Historic Preservation Division (SHPD) previously concurred with the 2007 AIS and its recommendation of "no further work," a position that was reaffirmed in subsequent letters and approvals. The 2025 LRFI acknowledges that the "Site M" plan is consistent with recommendations from previous cultural studies, including the preservation of the existing landscape. The plan incorporates significant open space, particularly within the northern portion of the Proposed Project area, which maintains mauka-makai access routes and provides a protective buffer for the adjacent Puak6 Petroglyph Archaeological District Mauna Lani Amendment to SMA Permit 07-019 26 MAUNALANI Amendment to SMA Permit 07-019 The Applicant acknowledges the findings of the LRFI. In response to the study and the cultural landscape, the Proposed Project's design will seek to avoid impacts to the existing landscape and will maintain the open space along the northern portion of "Site M" to serve as a protective buffer for the adjacent Puak6 Petroglyph Archaeological District. Archeological Field Inspection of Proposed Mauna Lani "Site M" Emergency Access Road (See Appendix G for full report) An Archaeological Field Inspection (AFI) was conducted by ASM Affiliates in December 2025 to assess three potential alignments (Routes 1, 2, and 3) for the proposed Emergency Evacuation Road. The purpose of the AFI was to identify any historic properties within a 40-acre survey area and provide recommendations for the State Historic Preservation Division (SHPD) review process. The inspection identified one previously documented historic property crossing the proposed alignments: a historic, core-filled, rock wall (Site 50-10-11-21975), interpreted as a historic ranching wall. The AFI re-identified the main portion of the wall and also discovered three smaller, previously unrecorded segments of the wall south of the main section. The report notes that the survey area has been subject to substantial prior ground disturbance, and the likelihood of encountering other buried historic properties is considered extremely remote. The report evaluates the three proposed routes from a historic preservation standpoint: • Route 1: Directly crosses the historic wall, which would require, at a minimum, an Archaeological Inventory Survey (AIS) and potentially further mitigation like data recovery or monitoring. • Route 2: Utilizes an existing 12-meter-wide breach in the wall where a utility easement currently crosses. This route is the shortest and requires the least construction but may still have the potential to impact the wall where the easement is widened. • Route 3: Is a more circuitous route that completely avoids the historic wall by arcing to the south of it. Conclusion and Recommendation The December 2025 AFI concluded that one historic property, the ranching wall (Site 50-10- 11-21975) and its associated segments, is present within the project corridor. The report recommends selecting a roadway alignment that avoids impacts to the historic wall to achieve a "no historic properties affected" determination from SHPD. The study notes that utilizing the existing 12-meter-wide breach (Route 2) or selecting an alignment that completely circumvents the wall (Route 3) are both viable options for avoiding impact. The Applicant accepts the recommendations of the AFI and will use these findings to inform the final design of the Emergency Evacuation Road. While the final alignment has not yet been selected, it will be situated within the surveyed corridor to provide design flexibility. The Applicant is committed to selecting an alignment that avoids impacts to the historic ranching wall, with the goal of satisfying SHPD review requirements and ensuring that historic resources are appropriately protected. Mauna Lani 27 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 Ka Pa'akai O Ka 'Aina Analysis for the Proposed Mauna Lani "Site M" (See Appendix H for full report) In August 2025, ASM Affiliates conducted a Ka Pa'akai O Ka 'Aina (KPA) analysis to evaluate the potential impacts of the proposed "Site M" development on traditional and customary Native Hawai'ian rights. This analysis was undertaken to assist the planning commission in its duty to protect these rights by identifying valued cultural, historical, or natural resources; assessing how the Proposed Project within "Site M" would affect them; and determining feasible actions for their protection. The KPA builds upon the previous archaeological and cultural studies by incorporating historical-archival research and new community consultations. While a 2007 Cultural Impact Assessment (CIA) concluded there were no ongoing traditional practices within the "Site M" area, the 2025 KPA found this assessment to be incomplete. The KPA notes that the 2007 CIA's conclusion was based on limited consultation and focused on recent history, thereby not representing a full picture of the area's cultural history and practices. Consultations conducted in July and August 2025 with cultural stewards and lineal descendants provided a more layered understanding of the region as a significant cultural landscape. Interviewees emphasized that the area contains numerous uncharted lava tubes and potential burials, and that ancestral trails, wahi pana (storied places), and spiritual presence define the land. They noted that the absence of documented sites in some historical surveys was due to dense kiawe overgrowth that limited visibility, not a lack of cultural resources. Conclusion & Recommendations The KPA concludes that while no active traditional gathering is occurring on the property, the "Site M" area is part of a broader cultural landscape with historical resources and ancestral knowledge. The primary cultural concern is the potential for development to further detach the area from its cultural narratives and stewardship ethics. Based on extensive community consultation, the KPA provides several mitigation measures to reasonably protect Native Hawai'ian rights. Key recommendations include: • Conduct Thorough Surveys: Perform comprehensive cultural and archaeological surveys that are not limited by property lines or assumptions of irrelevance, recognizing that many features, especially subsurface caves and burials, may be undocumented. • Preserve Features In-Situ: Cultural sites such as ahu, burials, and petroglyphs should be left undisturbed and integrated into the Proposed Project design rather than relocated. Development should protect these living anchors of ancestral presence. • Protect Trail Systems and Access: Identify, map, and safeguard traditional trail systems to preserve mauka-makai access and cultural memory. • Engage the Community: Incorporate Native Hawai'ian perspectives into visitor and stakeholder engagement to bridge the gap between commercial interests and cultural integrity. • Use Traditional Place Names: Use full and traditional Hawai'ian place names to honor the identity, history, and mana of the landscape. Mauna Lani 28 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 The Applicant acknowledges the findings of the 2025 KPA analysis, which concludes that the Proposed Project's area is part of a broader cultural landscape rich with historical resources and ancestral knowledge. The Applicant agrees that the 2025 KPA provides a more complete understanding of the area's cultural significance than the 2007 CIA and commits to incorporating all recommendations and findings into the Proposed Project's design and long-term stewardship. The Applicant believes these commitments directly address the findings of the recent studies and establish a clear framework for the respectful and responsible development of "Site M". 2.6 Traffic Traffic impacts were thoroughly addressed in the original SMA 07-019 application. Certain mitigation measures based on the original plan were made conditions to SMA 07-019. The applicant is not requesting to amend those conditions, despite significantly reducing the density of the Proposed Project. This reduction in both residential and hotel components creates a less intensive impact overall, further lessening the traffic impacts that were originally mitigated for. The Traffic Impact Assessment Report (TIAR) was prepared by Wilson Okamoto Corporation in February 2007, which was submitted with the original SMA 07-019 application. This study used a Level of Service (LOS) analysis, a quantitative and qualitative measure of traffic operations, to evaluate both existing conditions and potential impacts of the development. The TIAR concluded that with specific recommended improvements, the Proposed Project's impact on traffic operations within the Mauna Lani Resort would be mitigated. The report specifically recommended providing adequate sight distance and turn-around areas for vehicles, installing an exclusive left-turn lane at the intersection of Mauna Lani Drive and Queen Ka'ahumanu Highway, and providing exclusive turn lanes and a traffic signal system at the intersection of North Kaniku Drive and Hoohana Street. The original approval letter also noted that the Department of Transportation recommended considering a grade-separated intersection to address cumulative impacts from other projects, and that the widening of Queen Ka'ahumanu Highway was a long-range plan not anticipated to occur in the near term. The approval included conditions requiring the necessary traffic mitigation measures as recommended by the TIAR and DOT. The Applicant is not requesting to amend these conditions and will comply with those conditions as the development proceeds. 2.7 Infrastructure A Preliminary Engineering Report (PER) was prepared by Wilson Okamoto Corporation and comprehensively updated in August 2025 to reflect the currently Proposed Project. The PER provides a detailed technical assessment of the infrastructure needs, including an analysis of existing conditions, projected demands, and proposed improvements for sanitary sewer, potable water, storm drainage, and roadway systems. The findings of the PER are referenced throughout the following sections, and the full report is included for detailed review (See Appendix I). Mauna Lani 29 Amendment to SMA Permit 07-019 2.7.1 Water MAUNALANI Amendment to SMA Permit 07-019 The SMA 07-019 approval states that water can be made available from an existing 24-inch waterline on Hoohana Street or a 12-inch waterline on North Kaniku Drive. The DWS required a breakdown of the estimated daily water needs for all uses. The original application noted a tri-party agreement to develop additional potable water sources and use a non-potable water source for golf course and open landscaped area irrigation. The resort's potable water allocation is secured by a tri-party agreement effective April 6, 2006, between Mauna Lani Service, Inc. (Mauna Lani Resort's predecessor), Mauna Kea Properties, Inc., and the County of Hawai'i Water Board. The agreement was established to provide Mauna Lani with a long-term, reliable water supply from the regional Department of Water Supply (DWS) system in exchange for the resort funding and developing significant public water infrastructure. Under the terms of this agreement, Mauna Lani Resort developed and constructed two new high- capacity wells, Parker Wells No. 3 and 4, along with associated storage and transmission mains, and subsequently dedicated this infrastructure to the DWS. This public-private partnership provided a direct benefit to the County and its ratepayers, as the DWS received a ten percent share of the water capacity from both new wells at no cost, adding valuable supply and resiliency to the regional system. These two wells now operate as part of the larger DWS Lalamilo Water System, which draws from the Waimea aquifer and is also sourced by Parker Wells No. 1 and 2 and the four Lalamilo wells (A, B, C, and D). A July 2025 Water Use Study was prepared by Akinaka & Associates, Ltd. to confirm that sufficient potable water is available for the full build-out of the Mauna Lani Resort (See Appendix B of the PER). The study analyzes the resort's water rights, which are defined in terms of Maximum Day Demand and Average Day Demand. Per DWS standards, the Maximum Day demand is calculated as 1.5 times the Average Day demand. The study confirms that under its tri-party agreement, the resort holds a total Maximum Day Use Allocation of 6.013 million gallons per day (MGD), which is equivalent to an Average Day Use Allocation of 4.009 MGD. A clear breakdown of this water budget is as follows: • Total Average Daily Allocation: 4.009 MGD • Current Average Daily Usage: 2. 738 MGD o Equivalent to a Maximum Day Use of 4.106 MGD • "Site M" Estimated Average Daily Usage: 0.578 MGD o Equivalent to a Maximum Day Use of 0.866 MGD • Remaining Surplus of Average Daily Use: 0.693 MGD o Equivalent to a Maximum Day Use of 1.040 MGD Mauna Lani Amendment to SMA Permit 07-019 30 MAUNALANI Amendment to SMA Permit 07-019 This analysis from the Preliminary Engineering Report and the updated Water Use Study confirms there is sufficient capacity for the Proposed Project, with a sizable surplus of over 1.0 MGD (Maximum Day) remaining. This surplus ensures the resort can meet its obligations without impacting the regional water supply, addressing a key concern for the community and regulatory bodies. The Mauna Lani Resort utilizes a separate water system for its golf course irrigation. The two 18-hole golf courses, the Mauna Lani North and South Courses, are irrigated with non-potable brackish water. This water is supplied by privately owned and operated on-site wells, which are not connected to the Department of Water Supply (DWS) potable water system. This practice is consistent with the original plan for the resort, which specified using non-potable sources for large-scale irrigation. By using a separate system for this purpose, the resort's potable water allocation is reserved for domestic and commercial uses. 2.7.2 Electrical, Phone, Cable The original SMA 07-019 Application noted that these services would be provided by HELCO, Hawai'ian Telcom, and Oceanic Cable via existing overhead lines along a service road. The approval letter did not specify details on these utilities. 2.7.3 Solid Waste and Sewage Disposal As established under the orignial SMA Permit 07-019, wastewater generated within "Site M" is intended to be treated at the private wastewater treatment facility owned and operated by Hawai'i American Water Company (HAWC), which serves the Mauna Lani Resort (MLR). The original SMA approval contemplated the development of on-site sewer pump station(s) and associated force main infrastructure to convey wastewater flows to the existing treatment facility located mauka of "Site M". Sanitary sewer service continues to be provided by MLR's private wastewater system operated by HAWC. The existing wastewater treatment facility is located just northeast of "Site M" on the mauka side of Ho'ohana Street and has a design peak treatment capacity of approximately 1.1 million gallons per day (mgd). Current average daily flows are approximately 0.3 mgd, indicating that substantial remaining capacity is available. Treated effluent is currently reused for nearby turf and landscape irrigation, and HAWC has also indicated plans for future installation of an injection well to supplement effluent disposal. Projected sanitary sewer demand for "Site M" is approximately 160,510 gallons per day, based on the Proposed Project program and applicable County demand factors. "Site M" is located within HAWC's established service area and will connect to the existing Mauna Lani wastewater system. A "will serve" commitment is anticipated at the appropriate stage of Mauna Lani 31 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 development. It is anticipated that a "dry" off-site sewer force main will be extended from the wastewater treatment facility to the eastern portion of "Site M". Mauna Lani will be responsible for constructing on-site sewer pump station(s) and associated force mains to connect to this off-site infrastructure. HAWC was consulted in August 2025 regarding system capacity and connection requirements. Based on this coordination, filtration improvements at the existing wastewater treatment facility will be required to accommodate the additional projected flows generated by the Proposed Project. Based on the available treatment capacity, planned infrastructure upgrades, and coordination with HAWC, adequate wastewater treatment and conveyance infrastructure is available to serve the proposed development under the SMA amendment. 2.7.4 Site Grading and Storm Drainage The Proposed Project's existing topography is characterized by mild slopes, with elevations ranging from approximately 80 feet above Mean Sea Level (MSL) in the southwest to 40 feet above MSL in the northern portion. According to the Preliminary Drainage Study, there are no defined natural drainage channels on the property; stormwater currently appears to flow to low spots and percolate into the ground (See Appendix C of the PER). There are no existing storm drainage systems in the immediate vicinity, and no surface water resources, such as streams or gulches, are located on or near the property. The SMA 07-019 Approval (Condition 9) requires that all development-generated runoff be disposed of entirely on-site. The 2025 Preliminary Drainage Study analyzes the impacts of the currently Proposed Project, calculating that peak runoff for a 10-year, 1-hour storm will increase from 114.32 cubic feet per second (cfs) under existing conditions to 172.06 cfs under proposed conditions. This represents an increase of approximately 57.74 cfs that must be managed on-site. To mitigate this increase and comply with the original permit condition, the Preliminary Drainage Report suggests an on-site drainage system consisting of 122 drywells to be placed to collect and retain the increased runoff. The current proposal represents a significant reduction in overall intensity compared to the 1,207-unit plan approved in 2008. By reducing the total number of units and eliminating the golf course and conference center, the new plan will create substantially less impervious surface and generate less total stormwater runoff than the previously approved project would have. In addition to these permanent improvements, the Proposed Project will also adhere to all original permit conditions for managing construction-phase runoff, including complying with Chapter 10 of the Hawai'i County Code for erosion and sediment control (Condition 15) and securing a National Pollutant Discharge Elimination System (NPDES) permit from the Department of Health as required by Hawai'i Administrative Rules, Chapter 11-55 (Condition 19). 2.8 Public Access Mauna Lani 32 Amendment to SMA Permit 07-019 Shoreline Access MAUNALANI Amendment to SMA Permit 07-019 The Proposed Project does not abut the shoreline. However, there are three notable shoreline areas located near Mauna Lani "Site M" that provide sufficient public shoreline access for users within the Mauna Lani Resort complex: Pauoa Bay, Makaiwa Bay, and Holoholokai Beach Park. Public shoreline access is available through hotel access routes or via a paved pedestrian trail connecting to Holoholokai Beach Park. Makaiwa Bay fronts the Mauna Lani Beach Club and the Kalahuipua'a fishponds. Public shoreline access is provided through designated walkways within the Mauna Lani property, linking resort roads and parking areas to the shoreline. Holoholokai Beach Park is a County-maintained public park located about one-quarter mile north of Pauoa Bay. It is accessible via Holoholokai Beach Park Road and offers direct shoreline access, picnic facilities, and coastal trails. All three shoreline access points are within the Mauna Lani Resort property and are easily reached from Queen Ka'ahumanu Highway via Mauna Lani Drive. Mountain Access There is no direct public mountain access from "Site M". Mountain access in the broader South Kohala region is generally obtained via established public trails, access roads, or State-managed lands outside of the Mauna Lani Resort boundary. The resort area itself is a developed coastal zone, and public access in the vicinity is focused on shoreline areas rather than upland or mountain trails. Road Access Access to the "Site M" is provided by the existing internal resort roadways of North Kaniku Drive and Hoohana Street. The primary access to the greater Mauna Lani Resort is from Queen Ka'ahumanu Highway via Mauna Lani Drive. The Proposed Project is approximately 0.75 miles west of Queen Ka'ahumanu Highway. North Kaniku Drive is a privately maintained, two-lane, two-way dead-end road that provides access to the western portion of the Proposed Project. The road has an asphaltic concrete paved surface, with paved shoulders and no curb or sidewalk. It is described as a well-maintained resort road with landscaped shoulders. Ho'ohana Street runs along the southern boundary of the Proposed Project and provides access to the eastern portions of the Proposed Project. It is also a two-lane, two-way dead-end service road that currently provides access to other resort facilities like a pre-school, maintenance facility, and private wastewater treatment plant. However, its pavement is in poor condition, showing signs of cracking and raveling. The original SMA 07-019 application, prepared in 2007, stated that Ho'ohana Street would be improved to serve as the main access roadway for the Proposed Project. Condition Mauna Lani 33 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 10 of SMA 07-019 provides for several improvements at the Ho'ohana Street intersection of North Kaniku Drive. The Applicant is not requesting an amendment to those conditions. As the Proposed Project is located within the Mauna Lani Resort and the applicant is the landowner, legal access rights are inherent to the property ownership. 3. RELATION TO LAND USE PLANS AND POLICIES 3.1 State Land Use Districts "Site M" is located within the State Land Use Urban District as designated by the Hawai'i State Land Use Commission in LUC Docket No. A84-583. This designation supports visitor-oriented accommodations, residential units within a resort context, recreational amenities, and associated infrastructure, consistent with the Proposed Project. While "Site M" is designated as Urban, the Emergency Evacuation Road is in the Agricultural district. The Urban designation for Mauna Lani "Site M" supports the existing resort and residential uses within the Mauna Lani Resort, while the Agricultural designation for the Emergency Evacuation Road is for open space and undeveloped buffers (See Figure 9). The planned uses are consistent with this land designation. Mauna Lani 34 Amendment to SMA Permit 07-019 FIGURE 9 -STATE LAND USE DISTRICT MAP Mauna Lani Resort ~•ll#ill'd3@1kl Hilo • Kamuela, Big Island, Hawai'i LEGEND --··, -_ Site M '··--Emergency Evac Road Corridor Land Use Designation -Agriculture -Conservation Urban ft --===----===::::iFeet ~ , 0 435 870 1,740 2,610 MAUNALANI Amendment to SMA Permit 07-019 3.2 Coastal Zone Management Program (CZM) The CZM Program's objectives and policies, as outlined in Chapter 205A, Hawai'i Revised Statutes, aim to manage coastal development by balancing economic needs with the preservation of natural and cultural resources. Chapter 205A sets forth objectives for the coastal zone, including the protection and preservation of coastal ecosystems, scenic and open space resources, and cultural and historic resources. The Proposed Project eliminates the previously approved three-hole golf course and increases the amount of land dedicated to open space, enhancing opportunities for passive recreation and maintaining visual openness within the resort area. Archaeological and cultural resource assessments are being updated to ensure that historic properties and Native Hawai'ian traditional and customary practices are identified and protected in accordance with HRS §6E and Ka Pa'akai o ka 'Aina requirements. The Proposed Project supports the objectives and polices of these programs by reducing the overall intensity within the Mauna Lani Resort area. The plan reduces the total unit count from 1,207 to 925 and lowers the average density from 8.9 to 6.2 dwelling units per acre. This reduction also involves eliminating the three-hole golf course and a conference center, which increases open space on "Site M". The original SMA approval letter found that the development would not have a discernible impact on water quality or the marine biotic community. The reduced scale of the Proposed Project is anticipated to have an even lesser impact. Additionally, the Proposed Project's inland location, approximately 2,700 to 3,200 feet from the shoreline, ensures no direct impacts to public shoreline access or recreational resources. The Proposed Project will not involve dredging or filling bays and will not obstruct public views toward the sea from the nearest state highway. The Emergency Evacuation Road will reduce hazards to life and property from coastal hazards by providing a secondary evacuation road from the Mauna Lani Resort Area. The Proposed Project is consistent with the CZM Program and guidelines. By reducing the density and increasing open space, the revised plan further protects the natural and cultural resources of the coastal zone while allowing for a resort-residential development that is compatible with the character of the Mauna Lani Resort. 3.3 Special Management Area Guidelines (SMA) The Proposed Project is consistent with the objectives and policies of Chapter 205A, Hawai'i Revised Statutes, and the Special Management Area (SMA) guidelines of the County of Hawai'i. "Site M" is located within the State Land Use Urban District and designated as Resort under the County's General Plan, with zoning that supports a mix of resort hotel, residential, and open space uses. The Proposed Project reduces overall density, increases open space, and maintains land uses that are compatible with the surrounding resort community, thereby helping to preserve and protect coastal zone resources while accommodating reasonable development. The SMA guidelines emphasize the need to avoid, minimize, and mitigate adverse environmental effects, and to ensure that coastal resources are not diminished for future generations. The revised Mauna Lani 36 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 plan reduces the intensity of development compared to the SMA 07-019 approval in 2008, which in turn reduces potential demands on coastal resources, potable water supply, wastewater infrastructure, and stormwater management systems. Stormwater will continue to be managed in accordance with County and State requirements, and the reduction in impervious surfaces associated with smaller building footprints will help maintain infiltration and reduce runoff. In addition, the SMA guidelines require consideration of public access to and along the shoreline, preservation of public views, and avoidance of impacts to coastal hazards. Although "Site M" is located inland of the shoreline, the proposed reduction in building massing, particularly in the hotel parcels, improves view plane protection from Queen Ka'ahumanu Highway and adjacent resort areas. The Proposed Project is also designed to comply with applicable building codes, including requirements for structural resilience in hazard-prone areas, thereby supporting public safety and hazard mitigation objectives. Overall, the Proposed Project advances the purposes of Chapter 205A and complies with the County's SMAguidelines by preserving more open space, reducing potential environmental impacts, ensuring cultural and historic resources are respected, and providing for a balanced resort- residential community within the coastal zone by reducing the overall density of what was in the original master plan. 3.3.1 Compliance with SMA 07-019 Conditions No areas of critical concern have been formally delineated by the Planning Director for the Proposed Project. SMA 07-019 and the subsequent environmental and archaeological reports concluded that the Proposed Project would not have any substantial adverse environmental or ecological effects that could not be mitigated. The current proposal, which reduces the density and footprint, is expected to be consistent with these previous findings. In addition, the Applicant acknowledges that it will comply with all conditions of approval and only requests modification to Condition 2 allow an extension of time for 10 years to commence construction, and deletion of Condition 20 as the golf course is being eliminated, in addition to further modifications to Conditions 8 and 14 to remove referenced of the former golf course element. Regarding the traffic improvements mandated under Condition 10, the Applicant is pleased to note that a key component has already been completed. The first requirement listed, "an exclusive left- turn lane on the eastbound approach of Mauna Lani Drive at the intersection with Queen Ka'ahumanu Highway," was constructed and is currently operational. The Applicant remains committed to implementing the remaining conditional improvements. With respect to Condition 17, compliance with the affordable housing conditions in LUC Docket No. A84-583, per Hawai'i County Council Resolution No. 350-87 Mauna Lani Resort, Inc., DHL's Mauna Lani 37 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 successor in interest, satisfied the affordable housing requirements up to a maximum of 1,450 additional hotel units and a maximum of 450 residential units. There are currently 2 hotels within the Mauna Lani Resort, the Fairmont Orchid, with approximately 542 rooms and suites and the Mauna Lani Auberge Resort Collection with 334 rooms, 36 suites, 5 residences and 1 estate. Thus there are roughly 915 existing hotel units, which leaves sufficient affordable housing credits to have previously satisfied the 374 hotel unit proposed in the Proposed Project. With respect to the residential units to be constructed in the RM-4 areas of the Proposed Project, the Applicant acknowledges that it will be subject to the 10% affordable housing requirement as contained in A84-583 to the extent that the present development within the Mauna Lani Resort area covered by A84-583 has exceeded the 450 residential units affordable housing credits previously granted. Therefore, despite the satisfaction of some of the affordable housing requirements contained in Condition 17 of SMA 07-019, that condition should remain and OHL is not asking that it be amended at this time. Condition 6 which provides: To the extent allowed by the applicable government agencies and Mauna Lani Service, Inc., applicant shall take commercially reasonable steps to enable its construction access road to also serve as an alternative emergency evacuation route for the Mauna Lani Resort and the Puako community; provided, however, that the applicant shall not be responsible for maintenance and/or control of the alternate emergency evacuation route. As noted above, Applicant has engaged in preliminary discussions with the County regarding the location of this Emergency Evacuation Road, and its preliminary location is as set forth in this Amendment. 3.4 County Zoning The Proposed Project includes areas zoned Multiple-Family Residential (RM-4) District, Open (0) District, Resort-Hotel (V-1.25) District, and agriculture (A-Sa) under the County of Hawai'i Zoning Code. Surrounding lands are zoned Agricultural (A-Sa) District, Multiple-Family Residential District (RM-4), Open (0) District, and Resort-Hotel (V-1.25) District (See Figure 10). The Proposed Project, as an amendment to an existing SMA permit, is consistent with these zoning requirements. The V-1.25 designation supports visitor-oriented accommodations, residential units, recreational amenities, and associated infrastructure, which is in line with the Proposed Project's resort-residential mix. The RM-4 designation permits higher-density multiple-family residential development, which is consistent with the resort-residential environment and subject to applicable building height, lot coverage, and open space standards. Portions of the Proposed Project zoned as "Open" are intended for open space preservation and recreational use, a purpose that is maintained and enhanced by the proposed changes. Mauna Lani 38 Amendment to SMA Permit 07-019 FIGURE 10 -COUNTY OF HAWAl'I ZONING MAP Mauna Lani Resort PROJECT VICINllY Kamuela, Big Island, Hawai'i LEGEND ~-111 I Site M •-11 ZONING Emergency Evac Road Corridor 1111 Roads 1111 A-Sa 1111 CV-10 -MCX-20 -OPEN -RM-3 -RM-4 1111 RM-8 1111 RS-10 1111 RS-20 [:==J V-1.25 n--==-----====:::iFeet ~ , 0 415 830 1,660 2,490 MAUNALANI Amendment to SMA Permit 07-019 3.5 Hawai'i County General Plan The Proposed Project remains consistent with the goals and policies of the Hawai'i County 2005 General Plan, in addition to the principles of the Hawai'i County 2045 General Plan (Draft), which is currently in a draft stage. This evaluation demonstrates a forward-looking approach to development, proactively aligning the Proposed Project with the County's vision for future growth. Under the Hawai'i County 2005 General Plan, the Proposed Project is designated Resort-Hotel (V- 1.25) and Multiple-Family Residential (RM-4). The V-1.25 designation supports resort hotel development at a scale consistent with the resort setting, allowing a mix of visitor accommodations, accessory resort facilities, and compatible uses. The RM-4 designation falls within the County's RM (Multiple-Family Residential) district, which utilizes density designations ranging from 0. 75 to 4.0 and upward in 0.5 increments. An RM-4 designation permits higher-density multiple-family residential development, consistent with a resort-residential environment, subject to applicable building height, lot coverage, and open space standards. Portions of the Proposed Project area are also zoned Open (0) for open space preservation and recreational use. Looking forward, the Proposed Project's changes are aligned with the Hawai'i County 2045 General Plan (Draft) visions and goals. This includes the goal of "Biological stewardship," as the amendment proposes reducing the total number of residential and hotel units, eliminating a three-hole golf course, and increasing open space. This reduction in overall development intensity and the consolidation of built areas, particularly in the hotel component, directly contributes to the preservation of land and the minimization of the ecological footprint. The commitment to maintaining open space supports the stewardship of natural resources within the resort community. The Proposed Project also demonstrates consistency with the Hawai'i County 2045 General Plan (Draft) principles related to "Climate change" and "Sustainable development". By reducing the overall density and building footprint, the amendment inherently conserves resources and reduces energy demands compared to the originally approved plan. The removal of the golf course and conference center and the shift toward more compact structures results in less land alteration and a smaller overall impact on the environment. This approach aligns with the goal of creating a more resilient community by promoting development that is less resource-intensive and more environmentally sensitive. Furthermore, the Proposed Project supports the draft plan's goal of fostering "Resilient communities and a thriving, diverse, and regenerative economy". "Site M" is located within an established master- planned resort community and continues to contribute to the economic vitality of the region. By modifying the master plan to a more sustainable and less dense form, the Proposed Project helps ensure the long-term viability and character of the resort. This balanced approach supports a regenerative economy by providing a mix of residential and visitor accommodations while demonstrating a commitment to responsible land use within the Mauna Lani Resort. The Proposed Project, therefore, not only conform to the existing General Plan but also proactively address the Mauna Lani 40 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 forward-looking principles of the Hawai'i County 2045 General Plan (Draft), ensuring long-term sustainability and positive contribution to the community. The Proposed Project is consistent with the Hawai'i County General Plan (2005) and the principles of the Hawai'i County 2045 General Plan (Draft). The Proposed Project's designations of V-1.25 Resort- Hotel, RM-4 Multiple-Family Residential, and Open (0) under the 2005 plan directly support the proposed mix of visitor accommodations, residential units, and open space. The amendment also aligns with the Hawai'i County 2045 General Plan (Draft) goals of "Biological stewardship," "Climate change," and "Sustainable development" by reducing density and consolidating the development footprint. This forward-looking approach ensures the long-term sustainability and positive contribution to the community. 3.6 South Kohala Community Development Plan The Proposed Project is consistent with the goals and policies of the South Kohala Community Development Plan (CDP). The CDP, adopted as an ordinance in 2008, serves to translate the broader Hawai'i County General Plan into specific actions for the South Kohala District . The CDP's vision is to honor economic viability and environmental responsibility, guided by a respect for cultural and natural resources. The Proposed project aligns with the CDP's key district-wide policies, particularly those related to preserving the community's sense of place, emergency preparedness, and environmental stewardship. The Proposed Project's design demonstrates consistency with the CDP's policy to "Preserve the Culture and Sense of Place of South Kohala Communities". By reducing the overall development density and increasing open space, the amendment helps maintain the visual character of the area. The elimination of the three-hole golf course and conference center and the consolidation of hotel structures further reduce the footprint, preserving more of the natural landscape. Furthermore, the amendment addresses the CDP's emphasis on "Emergency Preparedness". The plan for an alternate emergency evacuation route is a direct response to a key community concern and a specific policy in the CDP, which calls for the development of plans and programs for emergency routes . The Proposed Project, including the Emergency Evacuation Road will ensure a safe and reliable evacuation option is available for the resort and the nearby Puak6 community, which is particularly vulnerable to natural disasters like wildfires. Lastly, the Proposed Project aligns with the CDP's goal of "Environmental Stewardship and Sustainability". The Proposed Project's eduction in density and smaller building footprint contribute to a more sustainable form of development. The original SMA application addressed concerns about water quality and coastal ecosystems, and the current, less-intensive plan is expected to have an even more minimal impact. The Proposed Project's commitment to maintaining open space and its location away from the shoreline are also consistent with the CDP's principles of wise land management for future generations. Mauna Lani 41 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 4. ALTERNATIVES TO PROPOSED PROJECT No Action Alternative The No Action alternative is not considered to be a viable alternative for the Proposed Project. Under a No Action scenario, development of "Site M" could proceed in accordance with the development framework approved under SMA Permit 07-019 in 2007. The Proposed Project represents an alternative to that approval by modifying the previously approved master plan to reduce overall development intensity while maintaining consistency with the resort's long-term planning objectives. Alternative Design Concept While alternative design concepts are possible, the Proposed Project has been configured to reduce overall hotel and residential density from that approved in 2007 while remaining within the parameters of the existing SMA Permit. With respect to the Emergency Evacuation Road component, multiple potential roadway alignments may be feasible within the identified study corridor. Rather than selecting a single alignment at this time, the corridor approach allows for continued evaluation of alternative routes within the same area, informed by completed archaeological, environmental, and engineering studies. Any future roadway alignment would be located within the limits of the studied corridor and refined through subsequent design and permitting to ensure compliance with applicable requirements and the protection of identified resources. 5. UNAVOIDABLE ENVIRONMENTAL IMPACTS While significant adverse impacts are not anticipated, some temporary effects may occur during construction, such as minor soil erosion, increased sediment in storm drains, and short-term visual impacts from construction activities. Best management practices will be implemented to control erosion and sedimentation, and visual conditions are expected to return to pre-construction conditions once work is completed. Although the Proposed Project will occupy currently undeveloped land, it is zoned for resort and residential use, and the Proposed Project is consistent with these designations. With these measures in place, the Proposed Project is not expected to result in significant adverse environmental effects. 5.1 Mitigation Measures To minimize potential impacts of the Proposed Project, several mitigating measures are proposed, which are already included in the overarching Conditions of SMA 07-019, and will be implemented in the Proposed Project's design To protect water quality, the Prosed Project will implement best management practices (BMPs) to control runoff and soil erosion, such as minimizing the time of Mauna Lani 42 Amendment to SMA Permit 07-019 MAUNALANI Amendment to SMA Permit 07-019 exposure between construction and landscaping and using silt fences and sediment basins. Appropriate actions and mitigation measures will also be implemented, with coordination of the county, for stormwater runoff from construction activities should it exceed one acre. Any discharges will comply with applicable State Water Quality Standards. The Proposed Project's aesthetic impact will be mitigated by maintaining overarching views of both the makai and mauka view planes. The Proposed Project will aim to improve open space by introducing passive recreational features like walking paths and community gardens to enhance the area's natural beauty. To address wildfire risk, the Proposed Project will follow standards similar to other South Kohala developments, incorporating construction and final building safety standards that will not exacerbate current fire hazard conditions. The Proposed Project is also anticipated to incorporate mitigation measures to safeguard critical resources and infrastructure from sea level rise scenarios, even though the Proposed Project is not anticipated to be affected by the 3.2 ft SLR scenario. Based on the provided studies, key mitigation measures will be integrated into the Proposed Project's design and implementation. These measures will include physical site design modifications to protect historic properties and commitments to ongoing cultural stewardship as recommended in the KPA analysis. Mauna Lani 43 Amendment to SMA Permit 07-019 ATTACHMENTS ATTACHMENT A List of Surrounding Landowners I I APPENDICES APPENDIX A Original SMA 07-019 Application Approval Letter September 4, 2008 Steven S, C. Lim, Esq, Carlsmith Ball, LLP 121 W aianuenue A venue Hilo, HI 96720 Dear Mr. Lim: County of Hawai'i PLANNING COMMISSION Aupuni Center • IO I Pauahi Street, Suite 3 • Hilo, Hawai 'i 96720 Phone (808) 961-8288 • Fax (808) 961-8742 Special Management Area Use Permit Application (SMA 07-000019) Request: 691 Residential Units, 516 Hotel Units (Consisting of 184 Hotel Room Suites Containing a Total of 266 Keys with an Adjacent Enclave of 100 Self-Contained Bungalows Containing a Total of 250 Keys), 3 Golf Holes and Related Support Facilities Applicant: Stanford Carr Development, LLC Tax Map Key: 6-8-1 :54/6-8-22: 10 The Planning Commission at its duly held public hearing on August 22, 2008, voted to approve the above-referenced request to allow the development of 691 residential units, 516 hotel units ( consisting of 184 hotel room suites containing a total of 266 keys with an adjacent enclave of 100 self-contained family bungalows containing a total of 250 keys), 3 golf holes, and related support facilities within the Mauna Lani Resort The property involved is located makai of the Queen Kaahumanu Highway, within the existing Mauna Lani Resort, Kalahuipuaa, Anaehoomalu and Waikoloa, South Kohala, Hawaii. Approval of this request is based on the following: The purpose of Chapter 205A, Hawaii Revised Statutes (HRS), and Special Management Area Rules and Regulations of the County of Hawaii, is to preserve, protect, and where possible, to restore the natural resources of the coastal zone areas. Therefore, special controls on development within an area along the shoreline are necessary to avoid permanent loss of valuable resources and the foreclosure of management options. The proposed development will not have any significant adverse environmental or ecological effect, except as such adverse effect is minimized to the extent practicable and clearly outweighed by public health, safety, or compelling public interest. Such adverse Hawai'i County is an Equal Opportunity Provider and Employer - 1-) ?nnR Steven S. C. Lim, Esq. Page 2 effect shall include, but not be limited to, the potential cumulative impact of individual developments, each one of which taken in itself might not have a substantial adverse effect and elimination of planning options. The applicant is requesting a Special Management Area Use Permit to allow the development of a portion of the Mauna Lani Resort (MLR) located adjacent to the Francis H. Ii Brown North Golf Course. This area includes MLR master plan sites M-1, M-2, M- 3 and T ("Site M") and encompasses approximately 150 acres. The applicant proposes to develop Site M with a mix of for-sale residential dwellings and hotel units. Site M is identified by two tax map key numbers and includes 691 residential units on approximately 71.6 acres: TMK: 6-8-22: 10 (49.066 acres) • a four-story 184-room (266 keys) hotel (16.4 acres) • 100 units (250 keys) in one-and two-story self-contained family bungalows on approximately 32.5 acres (16.1 acres) • 203 multiple-family residential units (16.6 acres) • multiple swimming pools, gardens, water features, walking paths, outdoor function areas and a 3-hole golf course TMK: 6-8-1: 54 (100.797 acres) • 430 multiple-family residential units (33.7 acres) • 58 single-family residential units (21.3 acres) Necessary infrastructure and landscaping, as well as 1,871 parking stalls, are also proposed. Residential structures will be one to three stories, and the hotel will be a maximum of 45 feet in height. The entire project will be developed over an 8 to 10 year period at a cost of $400 million. The proposed project will not create significant adverse impacts upon nearby and adjacent properties since the area has been developed with condominiums, single family residences, and other urban uses. The project site is bounded by Hoohana Street to the southeast, North Kaniku Drive to the southwest, a golf course to the west, and undeveloped, vacant lands to the west and north. The lands surrounding the project area are zoned Agricultural 5-acre (A-5a), Multiple-Family Residential 4,000 square feet (RM- 4) and Open (0). The Mauna Lani Bay Resort and Bungalows is located approximately one mile to the west and the Fairmont Orchid is located approximately .6 miles to the northwest. The Shops at Mauna Lani is located .25 mile southwest of the project site. Surrounding uses in the mauka direction along Hoohana Street include the Seagull School at Mauna Lani, resort maintenance and service area, a wastewater treatment plant, and Steven S. C. Lim, Esq. Page 3 resort plant nursery. Surrounding uses makai of the site include the Francis H. Ii Brown north golf course and residential developments including The Villages at Mauna Lani, The Fairways at Mauna Lani and Kulalani. Holoholokai Beach Park and the Puako Petroglyph Archaeological Park are located north of the project site. The project should not adversely affect views to and along the shoreline due to the project area's distance integration of the sloping property with the proposed structures. As the proposed development is similar in character to the surrounding area, the visual impact to the surrounding areas will not be significant. While the project will not have a direct impact upon coastal recreational resources, review of developments within the Special Management Area must also consider the cumulative impacts of such developments upon these resources. The proposed development will not substantially affect scenic vistas or viewplanes of nearby residents nor have an adverse impact on coastal recreational or visual resources to the shoreline and coastal ecosystems. The project site is located makai of the Queen Kaahumanu Highway within the Mauna Lani Resort Development and will not restrict access to coastal recreational resources along the shoreline nor will it restrict existing visual viewplanes from the highway. The view plane from the shoreline towards the site will not be impacted as lands makai of the project site are currently improved with approximately 900 hotel units, 1,200 single-family and multiple-family residential units, two 18-hole golf courses, shopping centers and public parks. A visual analysis depicting the proposed hotel as it would appear from the Queen Kaahumanu Highway indicates that the structure will not be visibly obtrusive, and will be designed to be compatible with the existing surrounding structures. Air quality in the area is predominantly affected by emissions from natural and vehicular sources. Both short-term air and noise quality impacts associated with the construction of the proposed improvements are expected during construction, especially during grubbing and grading activities. These impacts can be mitigated through the utilization of best management practices. The project is not anticipated to result in cumulative impacts, as it involves the expansion of an existing master planned resort area. Therefore, no significant long-term air and noise quality impacts are anticipated. There are no surface water resources in the vicinity of the project site. However, coastal waters off the Mauna Lani Resort area are classified as Class AA. As the coastal area is heavily utilized for recreational purposes, a study of the nearshore environment concluded that the proposed project should not change the water quality or the marine biotic community structure of the offshore area. Impacts to water quality that may occur during construction can be mitigated by applying best management practices such as minimizing open grading activities and cleaning paved surfaces of mud and silt. A National Pollutant Discharge Elimination System Permit (NPDES) for storm water runoff associated with construction activity will be secured from the Department of Health. For Steven S. C. Lim, Esq. Page4 the development of the three-hole golf course, best management practices will be employed in the application of fertilizers and pesticides to minimize groundwater impacts. The proposed project is consistent with the objectives and policies as provided by Chapter 205A, HRS, and Special Management Area guidelines contained in Rule No. 9 of the Planning Commission Rules of Practice and Procedure. According to the Department of Water Supply (DWS), water can be made available from an existing 24- inch waterline within Hoohana Street or from an existing 12-inch waterline within North Kaniku Drive, both fronting the project site. The DWS requires a breakdown of the estimated daily water requirements for all uses other than residential and irrigation such as swimming pools, water features and other amenities, as well as a breakdown of the amount of potable and non-potable water to be used for irrigation. Wastewater from the project will be treated by the private plant owned by Hawaii American Water. An on-site sewer pump station and force main will be developed to convey wastewater flows to the treatment plant located mauka of the project site. The Department of Environmental Management provided no comments with respect to wastewater disposal. Any potential runoff or discharge that could reach ocean waters can be handled by on-site improvements consistent with the requirements of the Department of Public Works. Any impacts from soil erosion and runoff during site preparation and construction phases can be adequately mitigated through compliance with existing regulations and proper construction practices. Air emissions generated during the construction phase for the proposed project can be mitigated by existing construction regulations. With these precautionary measures in place, the proposed development is not anticipated to have any substantial adverse effects upon nearby coastal resources or the surrounding environment. Conditions of approval will be included relating to wastewater, solid waste and public safety to ensure that impacts on coastal resources are minimized. A study titled An Inventory Survey for Site Min Mauna Lani: Investigation into Resource Exploitation Patterns in the Lower Elevations of the Kaniku Flow in Waikoloa Ahupuaa, South Kohala District, Hawaii Island, Hawaii (TMK: 3-6-8-1:54 and 3-6-8- 22:10) was prepared by Thomas R. Wolforth and Shannon Huber of Scientific Consultant Services, Inc. in February, 2007. Eight archaeological sites discovered on the two parcels were evaluated as significant under Criterion D, "must have yielded or may be likely to yield, information important in prehistory or history", with no further work required for recommended treatment. The February2007 report has yet to be approved by the DLNR- HPD. By letter dated April 4, 2007, the applicant has requested a letter of "no effect" from the DLNR-HPD. Steven S. C. Lim, Esq. Page 5 A study titled A Survey of Botanical, Avian and Terrestrial Mammalian Species for Mauna Lani Site "M" Special Management Area Permit Application, South Kohala District, Island of Hawaii was prepared by Rana Productions, Ltd., in September 13, 2006. No plant or avian species cmTently listed as endangered, threatened, or proposed for listing.under either the federal or the State of Hawaii's endangered species programs were recorded within or near the project site. There is no evidence of any traditional and customary Native Hawaiian rights being practiced on the site. The proposed project is a part of the Mauna Lani Resort development, which has been master planned and developed over the past three decades. The property is not proximate to the shoreline and will not be impacted by coastal hazard and beach erosion. No scenic or open space resources to the shoreline or coastal view plane or coastal ecosystem will be negatively impacted by the proposed action, as the area makai of the project site is currently developed with hotels, residences and commercial establishments. The residential structures will be low-rise developments ranging from one to three stories and the proposed hotel will not exceed 45-feet in height. The proposed development is consistent with the County General Plan and the Zoning Code. The General Plan Land Use Pattern Allocation Guide (LUPAG) Map establishes the basic urban and non-urban form for areas within the County. The project site is designated Resort Node, Urban Expansion and Open on the LUPAG map. Resort areas include uses such as hotels, condominium-hotels and supporting services. Thus, the proposed development would be consistent with the LUPAG Map designation. This proposed development would complement, among others, the goals, policies and standards of the Land Use and Economic elements of the General Plan. The project will be in harmony with the character of the surrounding area and result in an intensity of land utilization no higher than as permitted or as otherwise specified for the district in which this development is proposed. Access to the project site is from the Queen Kaahumanu Highway, a state-owned highway, to Mauna Lani Drive and North Kaniku Drive and Hoohana Street. North Kaniku Drive, which provides access to the western portion of the project site, is a private two-lane, two-way dead-end road servicing local resort traffic, with paved shoulders and no curb, gutter or sidewalk and landscaped shoulders. Hoohana Street, located along the southern boundary of the project site, provides access to the eastern portion of the project site. Hoohana Street is a two-lane, two-way dead-end service road that provides access to Seagull School, the Mauna Lani Resort maintenance facility, Mauna Lani Resort wastewater treatment plant and other resort support facilities. Steven S. C. Lim, Esq. Page 6 A traffic study titled Traffic Impact Report for the Mauna Lani Site M Development dated February 2007 was prepared by Wilson Okamoto Corporation and included as Appendix H in the application. In summary, the study recommended the following: 1. Provide adequate site distance for motorists to safely enter and exit the project driveways/roadways. 2. Provide adequate tum-around area for delivery and refuse vehicles to maneuver within the project site to avoid vehicle reversing maneuvers onto adjacent streets. 3. Provide sufficient driveway/roadway width to accommodate safe vehicle ingress and egress. 4. Provide an exclusive left-turn Jane on the eastbound approach of Mauna Lani Drive at the intersection with Queen Kaahumanu Highway. 5. Provide exclusive left-tum and right-tum lanes on the westbound approach of Hoohana Street at the intersection with North Kaniku Drive. 6. Provide an exclusive right-turn lane on the northbound approach of North Kaniku Drive at the intersection with Hoohana Street. 7. Install a traffic signal system at the intersection of North Kaniku Drive with Hoohana Street to improve projected traffic conditions. The TIAR utilizes the concept of Level of Service (LOS) to evaluate existing traffic conditions and potential impacts. LOS is a quantitative and qualitative assessment of traffic operations. Levels of service are defined by LOS "A" through "F", with LOS "A" representing ideal traffic conditions and LOS "F" unacceptable or potentially congested traffic conditions. (Refer to page 32 in the application and the TIAR in Appendix H for additional information on the LOS with and without the project) The study concluded that "the provision of exclusive turning lanes and the installation of a traffic signal system at the intersection of North Kaniku Drive and Hoohana Street should mitigate the impact of the proposed development on traffic operations with the Mauna Lani Resort." The Police Department recommends that the Planning Department and applicant consider the development of a fully grade-separated intersection in the Mauna Lani development from the Queen Kaahumanu Highway. The Department of Public Works provided no specific comments on traffic issues. The Department of Transpmtation (DOT) has recommended that traffic mitigation measures and highway intersection improvements, including signalization, should be provided to address the cumulative impact from the existing and on-going reso1t construction projects, as well as to participate in and contribute to regional transportation improvements. The DOT recommends that a "grade-separated intersection/interchange and lateral or frontal roadways, similar to those presented in our conceptual master plan for Queen Kaahurnanu Highway, should be considered along with accommodations to be provided by the landowner/master developer (e.g., reservation of land, space for road right-of-way, or other maintaining of available open land) for such facilities." According to the DOT, widening of the Queen Kaahumanu Highway in the Steven S. C. Lim, Esq. Page 7 area is a "long-range plan and not anticipated to occur in the upcoming years." Conditions of approval will be included to provide the necessary traffic mitigation measures as stated in the application and recommended by the TIAR and DOT. The portion of the Mauna Lani development covered by LUC Docket No. A84- 583 has affordable housing conditions resulting from both the LUC Decision and Order and subsequent county rezoning ordinances. Mauna Lani had constructed affordable housing units in the past; specifically Mauna Lani has completed the development of 243 affordable housing units, 200 at Lailani, 19 at Noelani I, and 24 at Noelani II, and in Council Resolution No. 350-87, the Council determined how these should be credited against future development within the A84-583 area. In essence, the Council determined that these past affordable housing developments would serve to satisfy the requirements for Mauna Lani's plans within the A84-583 area, up to 1,450 hotel units and a maximum of 450 resort residential units. Since that time, between 462 and 472 resort residential units have been developed within the A84-583 area and 550 hotel units for the Ritz- Carlton Hotel. Thus, the applicant will have to provide additional affordable housing for the further development of residential units in the A84-583 area, unless the Council modifies Resolution No. 350-87 so that some of the hotel credits which still are available are shifted to the residential units. This is more fully discussed in the Planning Director's letter dated April 27, 2007 identified as Exhibit 3. That letter estimated the number of residential units in the A84-583 area at 510, but upon subsequent analysis, the County and Mauna Lani agreed that the actual number was between 462 and 472. (It was difficult to determine an exact number because some of the buildings straddle the A84- 583 area and the area that was reclassified earlier.) The Planning Department does not have any record of LUC action relating to the affordable housing requirements covered under A84-583. The units created may satisfy the 10% affordable housing requirement for 2,430 reso11 residential units as stipulated under Condition No. 1 of the docket. As there is no record of any LUC action pertaining to the release of the affordable housing requirement, Mauna Lani is in the process of preparing a submittal to the LUC requesting release from the requirement. Once the matter has been reviewed and cleared by the LUC, Mauna Lani will work to reconcile the number of units in the then-development scenario for Mauna Lani Resort as reflected in Council Resolution 350 87. [n view of the recent Hawaii State Supreme Court's "PASH" and "Ka Pa' akai 0 Ka 'Aina" decisions, the issue relative to native Hawaiian gathering and fishing rights must be addressed. These rights must be addressed in terms of the cultural, historical, and natural resources and the associated traditional and customary practices of the site. Investigation of valued resources: The following studies were submitted for the Planning Commission's review: Steven S. C. Lim, Esq. Page 8 • An Inventory Survey for Site Min Mauna Lani: Investigation into Resource Exploitation Patterns in the Lower Elevations of the Kaniku Flow in Waikoloa Ahupuaa, SouthKohala District, Hawaii Island, Hawaii (TMK: 3-6-8-1:54 and 3-6- 8-22:10) was prepared by Thomas R. Wolforth and Shannon Huber of Scientific Consultant Services, Inc. in February, 2007. • A Survey of Botanical, Avian and Terrestrial Mammalian Species for Mauna Lani Site "M" Special Management Area Permit Application, South Kohala District, Island of Hawaii was prepared by Rana Productions, Ltd., in September 13, 2006 • A cultural impact study by Thomas R. W olforth dated February 2007. The valuable cultural, historical, and natural resources found in the area: Eight archaeological sites discovered on the two parcels were evaluated as significant under Criterion D, "must have yielded or may be likely to yield, information important in prehistory or history", with no further work required for recommended treatment. By letter dated April 4, 2007, the applicant has requested a letter of "no effect" from the SHPD. Possible adverse effects or impairment of valued resources: The project will require site grading and grubbing, and construction of various improvements such as roadways, buildings and a 3-hole golf course. These activities will cause changes to the vegetation types which presently exist on the project site. Native vegetation may be destroyed by ground alteration. Changes in species composition will be introduced through landscaping and natural processes, perhaps resulting in a loss of some native plants. However, these plants are found in similar habitats throughout the general area and continue to grow within the natural lava. There is no evidence that the flora in the area are particularly desired or used for cultural practices. The project will also alter the existing fauna on the site. The clearing and landscaping of large areas will create non-native habitat areas. Existing on-site species will be dislocated as part of the project development. However, no plant or avian species currently listed as endangered, threatened, or proposed for listing under either the federal or the State of Hawaii's endangered species programs were recorded within or near the project site. Feasible actions to protect native Hawaiian rights: The project site is located makai of the Queen Kaahumanu Highway, approximately 2,700 to 3,200 feet from the shoreline, and will not be impacted by coastal hazard and beach erosion. The existing public access to the shoreline is provided via North Kaniku Drive to Holoholokai Beach Park, and will continue to be provided. No gathering is taking place in the project area. Thus, to the extent to which traditional and customary native Hawaiian rights are Steven S. C. Lim, Esq. Page 9 exercised, the proposed action will not affect traditional Hawaiian rights; therefore, no action is necessary to protect these rights. Based on the above findings, it is determined that the proposed development and related improvements will not have any substantial adverse impacts on the surrounding area, nor will its approval be contrary to the objectives and policies of Chapter 205A, HRS, relating to Coastal Zone Management and Rule No. 9 of the Planning Commission relating to the Special Management Area. Approval of this request is subject to the following conditions. 1. The applicant, its successor or assigns shall be responsible for complying with all stated conditions of approval of this permit. 2. Construction of the proposed development shall be completed within ten ( 10) years from the effective date of this permit. The project shall be developed substantially as represented in the application. 3. The applicant shall develop the property to a density not to exceed 691 residential units and 284 hotel units ( consisting of a maximum of 516 keys), and uses accessory thereto. 4. Prior to construction, the applicant, successors or assigns shall secure Final Plan Approval for the proposed improvements from the Planning Director in accordance with Section 25-2-70, Chapter 25 (Zoning Code), Hawaii County Code. Plans shall identify all proposed structures, access roadways and parking stalls and other improvements associated with the proposed development. Landscaping shall also be indicated on the plans for the purpose of mitigating any adverse noise or visual impacts to adjacent properties in accordance with the requirements of Planning Department's Rule No. 17 (Landscaping Requirements). 5. Construction of single-family homes by individual lot owners or master developer are covered by this approval and do not require subsequent Special Management Area Use permits. 6. To the extent allowed by the applicable government agencies and Mauna Lani Service, Inc., applicant sha11 take commercially reasonable steps to enable its constrnction access road to also serve as an alternate emergency evacuation route for the Mauna Lani Resort and the Puako community; provided, however, that the applicant shall not be responsible for maintenance and/or control of the alternate emergency evacuation route. Steven S. C. Lim, Esq. Page 10 7. To mitigate potential interference with view planes from the Queen Kaahumanu Highway, the proposed hotel shall be limited to a height of 45 feet, measured according to Chapter 25, Hawaii County Code. 8. The applicant shall develop a three-fairway golf amenity or equivalent open landscaped area and use commercially reasonable efforts to use effluent water treated to the R-2 standard from the Mauna Lani Resort's wastewater treatment plant to irrigate the golf amenity or open landscaped area; provided, however, that the applicant's commitment to use the R-2 treated effluent shall be conditioned upon the operator of the wastewater treatment plant providing R-2 treated effluent of an acceptable quantity and quality so as to enable applicant to use such effluent within its subsurface drip irrigation system without incurring unreasonable expense or liability. 9. All development-generated runoff shall be disposed of on-site and shall not be directed toward any adjacent properties. 10. The applicant shall provide, at a minimum, the following improvements, meeting with the approval of the Department of Transportation and/or the Department of Public Works, whichever agency is applicable: • an exclusive left-tum lane on the eastbound approach of Mauna Lani Drive at the intersection with Queen Kaahumanu Highway. • an exclusive left-tum and right-tum lanes on the westbound approach of Hoohana Street at the intersection with North Kaniku Drive. • an exclusive right-tum lane on the northbound approach of North Kaniku Drive at the intersection with Hoohana Street. • install a traffic signal system at the intersection of North Kaniku Drive with Hoohana Street. 11. A drainage study shall be prepared by a licensed civil engineer and submitted to the Department of Public Works prior to the issuance of Final Plan Approval. If required, the drainage improvements shall be constructed, meeting with the approval of the Department of Public Works, prior to receipt of a Certificate of Occupancy. 12. Wastewater from the project shall be treated by the private plant owned by Hawaii American Water. 13. The applicant shall develop and implement a groundwater and nearshore water quality monitoring program for review and approval by the Planning Director. The location and extent of water quality monitoring shall be established by a Steven S. C. Lim, Esq. Page 11 monitoring plan meeting with the approval of the Planning Director, but shall generally encompass ocean areas which may be affected by the development, including waters fronting the northeast portion of the Mauna Lani Resort and the southern end of Puako Beach Road. 14. A non-potable water source for golf course or equivalent open landscaped area irrigation shall be utilized. 15. All earthwork and grading shall conform to Chapter 10, Erosion and Sediment Control of the Hawaii County Code. 16. A Solid Waste Management Plan shall be submitted to the Department of Environmental Management for review and approval prior to the issuance of a Certificate of Occupancy. 17. To comply with LUC Docket No. A84-583 and to ensure that the Goals and Policies of the Housing Element of the General Plan are implemented, the applicant shall comply with the requirements of the applicable zoning ordinances, Council resolutions and LUC requirements. This requirement shall be approved by the Administrator of the Office of Housing and Community Development prior to the issuance of a Certificate of Occupancy for any residential development. 18. During construction, best management practices shall be utilized to minimize the potential of both fugitive dust and runoff sedimentation. Such best management practices shall be in compliance with construction industry standards and practices utilized during construction projects in the State of Hawaii. 19. The applicant shall comply with Chapter 11-55, Water Pollution Control, Hawaii Administrative Rules, Department of Health, which requires an NPDES permit for certain construction activity. 20. The applicant shall prepare an integrated golf course management plan (IGCMP) for the review and approval of the Planning Director. The IGCMP shall address the design, construction, maintenance and operation of the 3-hole golf course. The IGCMP shall contain specific best management practices for the 3-hole golf course. Steven S. C. Lim, Esq. Page 12 21. Should any undiscovered remains of historic sites, such as rock walls, terraces, platforms, marine shell concentrations or human burials be encountered, work in the immediate area shall cease and the Department of Land and Natural Resources-Historic Preservation Division (DLNR-HPD) shall be immediately notified. Subsequent work shall proceed upon an archaeological clearance from the DLNR-HPD when it finds that sufficient mitigation measures have been taken. 22. The applicant shall comply with all applicable County, State and Federal laws, rules, regulations and requirements. 23. An annual progress report shall be submitted to the Planning Director prior to the anniversary date of this permit. The report shall include, but not be limited to, the status of the development and the extent to which the conditions of approval are being satisfied. This condition shall remain in effect until all of the conditions of approval have been satisfied and the Planning Director acknowledges that further reports are not required. 24. An initial extension of time for the performance of conditions within this permit may be granted by the Planning Director upon the following circumstances: A. The non-performance is the result of conditions that could not have been foreseen or are beyond the control of the applicant, successors or assigns, and that are not the result of their fault or negligence. B. Granting of the time extension would not be contrary to the General Plan or Zoning Code. C. Granting of the time extension would not be contrary to the original reasons for the granting of this permit. D. The time extension granted shall be for a period not to exceed the period originally granted for performance (i.e., a condition to be performed within one year may be extended for up to one additional year). E. If the applicant should require an additional extension of time, the Planning Department shall submit the applicant's request to the Planning Commission for appropriate action. Should any of the conditions not be met or substantially complied with in a timely fashion, the Planning Director may initiate procedures to revoke the permit. Steven S. C. Lim, Esq. Page 13 This approval does not, however, sanction the specific plans submitted with the application as they may be subject to change given specific code and regulatory requirements of the affected agencies. Should you have any questions, please contact Norman Hayashi of the Planning Department at 961-8288. Sincerely, 4~6~ Rodney Wtanabe, Chairman Planning Commission Lstanfordcarrsma07-0000 l 9PC cc: Department of Public Works Department of Water Supply County Real Property Tax Division Planning Department -Kona Department of Land and Natural Resources/HPD DOT-Highways, Honolulu Ms. Alice Kawaha Zoning Inspector-Kana Plan Approval Section Ivan Torigoe, Esq. Amy Self, Esq. Roy Vitousek, Esq. Jerry M. Hiatt, Esq. APPENDIXB 2015 Administrative Time Extension Letter from Planning Director William P. Kenoi Mayor West Hawai'i Office 74-5044 Ane Keohokalole Hwy Kailua-Kona, Hawai'i 96740 Phone(808)323-4770 Fax (808) 327-3563 April 14, 2015 REC1' APR I 0 201! Steven S. C. Lim, Esq. Carlsmith Ball, LLP POBox686 Hilo, HI 96721-0686 Dear Mr. Lim: County of Hawai 'i PLANNING DEPARTMENT Special Management Area Permit No. 07-000019 (SMA 07-19) Successor Applicant: Site M Associates, LLC Duane Kanuha Director Bobby Command Deputy Director East Hawai'i Office IOI Pauahi Street, Suite 3 Hilo, Hawai'i 96720 Phone (808)961-8288 Fax (808) 961-8742 Subject: Request for Administrative Time Extension and 2008-2014 Annual Progress Reports Tax Map Key: 6-8-001:054 and 6-8-022:010 This letter is in response to your letters dated August 27, 2014 and March 19, 2015 containing an annual progress report and requesting an administrative time extension to comply with Condition 2 ( complete construction) of SMA Permit No. 07-19. Please accept our apology for not providing a timely response. The annual progress report satisfies Condition 23 of the permit. Please submit the next report on or before September 4, 2015. Condition No. 2 requires that within ten years from the effective date of the permit the applicant complete construction of the proposed development. Condition No. 24 allows for an administrative time extension for a period of time not to exceed what was originally granted. Based on the reasons in your letters, we will grant an initial 5-year administrative time extension until September 4, 2023 to allow the project sufficient time to proceed, with a second 5-year administrative time extension from September 4, 2023 to September 4, 2028 automatically approved subject to the developer satisfying the following milestone: "The second 5-year administrative time extension to complete construction of the Project shall automatically be triggered upon the County of Hawai 'i's issuance of all applicable permits for construction of the core infrastructure for the Project. This core infrastructure shall include at a minimum, improvements to Ho 'ohana Street fronting the Project to resort standards, the electrical and utility service connections to the Project, and a north-bound left-turn lane pocket from North Kaniku Drive into the main entrance to the Villages at Mauna Lani. The core infrastructure as defined herein shall not include any improvements to the Mauna Lani Resort project entry or intersection at Queen Ka 'ahumanu Highway and Mauna Lani Drive. " We would also like to inform you that the Planning Department has determined that the subject property is subject to the maximum hotel and residential unit limit set for the Mauna Lani Resort. Maximum unit www.cohplanningdept.com Hawai ·; County is an Equal Opportunity Provider and Employer planning@co.hawaii.hi.us Steven S. C. Lim, Esq. Carlsmith Ball, LLP Page2 April 14, 2015 counts of 3,000 hotel rooms and 3,182 residential units were established for the 778-5-acre resort on March 15, 1978 with an amendment to SMA Permit No. 2 and on August 10, 1978 with Rezone Ordinance 380. In 1984, Mauna Lani Resort, Inc. applied to reclassify 654 adjacent acres from Agricultural and Conservation to Urban in order to expand the resort development. The Land Use Commission's Decision and Order approving the reclassification (Docket No. A84-583) was based on representations that the "Proposal for Development" would "increase the size of the existing 778.5-acre Mauna Lani Resort Urban District to approximately 1,432 acres to provide additional recreational opportunities and visual amenities and to develop the existing Mauna Lani Resort at a lower density ( emphasis added). Page 5 of the Docket states "Petitioner does not propose to increase the number of hotel, resort condominium and residential units allowed by the current master plan. The existing County of Hawai'i zoning for the 778.5-acre Urban District allows the Petitioner to develop 3,000 hotel rooms and 3,182 residential units, shopping and entertainment activities and recreational facilities." SMA Permit No. 07-000019 was issued on September 4, 2008 to allow the development of 284 hotel units ( consisting of a maximum of 516 keys; which we understand is equivalent to 516 hotel rooms) and 691 residential units on the approximately 150-acre subject property, which is a portion of the 654 acres that was subject to the 1984 reclassification action. In hindsight it may have been more appropriate to amend SMA Permit No. 2 to include the subject property rather than issue a separate SMA Permit. Either way, it is clear that all previous entitlements issued for the Mauna Lani Resort were to allow a maximum of 3,000 hotel rooms and 3,182 residential units within the 1,432 acre resort area currently located in the State Land Use Urban District. If you disagree with this determination please notify the Planning Department as soon as possible and provide information to support your position of disagreement. If you have any questions, please feel free to contact Daryn Arai at (808) 961-8142 or Maija Jackson at (808) 961-8159. Planning Director MJJ:klt P:\wpwin60\Maija\Letters\ TER\LLim-AdminTER-SMA07-I 9 .doc cc w/ letter (electronic): Planning Dept. -Kana Office cc w/letter: Cades Shutte LLP, Mr. Roy A Vitousek IIT Villages at Mauna Lani Association of Apartment Owners Mauna Lani Resort Association State Land Use Commission APPENDIXC 2023 SMAAutomatic Time Extension Approval Mitchell D. Roth Jayor Lee E. Lord Ma11ogi11g Dircc1or We t Hawai'i Of-Ii c 74-5044 Ane Keohok51ole llwy Kailua-Kona, Hawai'i 96740 Phonc(808)323-4770 Fax (808) 327-3563 March 16, 2023 Steven S. . Lim, Esq. arlsm ith Ball LLP P. 0 . Box 686 Hilo, Hl 96721-0686 Dear Mr. Lim: County ofHawai'i PLA I G DEP RTME T Special Management Area Permit o.07-000019 ( M 07-19) Applicant: ubject: TMK's: (PL-I T-2023-004318) OHL Mahi OpCo, LLC Request for 2nd Admini trative Time Extension {Condition 2) (3) 6-8-001:054 and (3) 6-8-022:010 Zendo Kem Direc1or Jeffrey W. Darrow Deputy Dlreclor Ea·t HawAi'i Office IO I Pauahi treel, uite 3 Hilo, Hawai'i 96720 Phone (808) 961-8288 F~x (808 I 961-8742 This letter is in response to your letter dated January 26, 2023 requesting an automatic second administrati e time extension to comply with Condition 2 (complete construction) of SMA Penn it No. 07-19. ondition o. 2 requires that within ten years from the ffective date of the permit the applicant complete construction of the propos d development. Condition No. 24 allows for an administrative time extension for a period of time not to exceed what was originally granted. On April 14, 2015 the Planning Department approved of a 5-year administrative time extension until September 4 2023 to allow the project sufficient time to proceed with a second 5-year administrative time extension from eptember 4 2023 to S ptem ber 4 2028 automatically approved subject to the developer satisfying the following milestone: "Th e second 5-year administrative time extension to complete consm,ction of the Project shall automatically be triggered upon the County of Hawai 'i • • issuan e of all applicable permit: for construction of the core infrastructure for the Project. This core infrastructure shall include at a minimum, improvement; to Ho 'ohana Sh·eet .fronting the Project to re ·ort landard , th e electrical and utility ervice connection 10 the Project. and a north- bound left-turn lane pocket from orth Kanilai Drive into the main entrance to the Villages www.planning.hawaiicountv.eov Hmm/·; Co,111(1• is 011 £qua/ OpJ1or11111/n• Pro .. ider and £111plover planninC?@hnwaiicounlv.gov ( l Steven S.C. Lim, Esq. Carlsmith Ball, LLP March 16, 2023 Page 2 at Mauna Lani. The core irifrastructure as defined herein shall not include any improvements to the Mauna Lani Resort project entry or intersection at Queen Ka 'ahumanu Highway and Mauna Lani Drive. " Based on information provided the Applicant (DHL Mahi OpCo, LLC) has successfully secured Grading Permit No. PW.ENG2022-00248 (dated 01/26/23) for the core infrastructure elements for the Site M Project to comply with the aforementioned condition. Therefore, the Planning Department will grant the automatic second 5-year administrative time extension from September 4, 2023 to September 4, 2028, to comply with Condition No. 2 by completing construction of the proposed development. Please be informed, should you need an additional extension of time your request and reasons shall be forwarded to the Planning Commission. A public hearing will be held by the Planning Commission. If you have any questions, please feel free to contact Alex Roy at (808) 961-8140 or via email at alex.roy@hawaiicounty.gov Sincerely, zendo Kem Zenda Kern (Mar 16, 2023 13:06 HST) ZENDOKERN Planning Director AJR:mads P\wpwin60\czm\letters\2023\pl-int-2023-0043 ! 8 _site_m_ 2nd _ter.doc APPENDIXD 2024 SMA Compliance Determination Letters for Hotel Redesign Mitchell D. Roth Mayor Deanna S. Sako Managing Director West Hawai 'i Office 74-5044 Ane Keohokfilole Hwy Kailua-Kona, Hawai'i 96740 Phone (808) 323-4770 Fax (808) 327-3563 October 3, 2024 Katherine A. Garson, Esq. Carlsmith Ball LLP P.O. Box686 Hilo, HI 96721-0686 Dear Ms. Garson: County of Hawai'i PLANNING DEPARTMENT Zendo Kem Director Jeffrey W. Darrow Deputy Director East Hawai 'i Office 101 Pauahi Street, Suite 3 Hilo, Hawai'i 96720 Phone (808) 961-8288 Fax (808) 961-8742 Subject: Request for SMA Compliance Determination (Updated Hotel Concept) Response to Letter Dated September 13, 2024 Special Management Area (SMA) Major Use Permit No. 07-000019 (SMA 07-19) Project: Site M Mauna Lani Applicant: DHL Mahi Site M LLC Tax Map Key No.: (3) 6-8-001:054 and (3) 6-8-022:010 (collectively Site M) This is in response to your letter dated September 13, 2024, requesting for an administrative review and written determination from the Planning Department on DHL's proposal to consolidate the hotel bungalow plan, originally planned for a portion of TMK: (3) 6-8-022:010 ("Parcel 10") under SMA 07-19, into a second 4-story hotel structure. DHL is proposing to convert the 100 hotel bungalows (250 keys) originally planned for Parcel 3B into another similar, but significantly smaller, 4-story hotel comprised of 105 hotel keys, which would result in a more functional and modem design intended to attract and retain a broader range of guests. SMA 07-19 proposed hotel uses, which consisted of2 distinct hotel offerings within Parcel 10, namely a single 4-story 184-unit hotel structure consisting of 266 hotel keys located in planning area "Parcel 3A", and 100 hotel bungalows ranging 1 to 2 stories in height, representing the remaining 250 hotel keys (516 total hotel units/ keys) proposed within planning area "Parcel 3B". The construction of a smaller main hotel on Parcel 3A and the addition of a second hotel within Parcel 3B appears to result in fewer overall impacts, including visual impacts, upon the affected land area and the SMA than the original hotel and bungalow concept approved under SMA 07-19. After review of the proposal, along with all of the proposed layout and visual comparisons, the Planning Department has determined that the proposed dual-branded hotel concept, which proposes to redesign the main hotel while also allowing a consolidation of the original 100 hotel bungalows plan into a second 4-story hotel at 45 feet in height, is in general compliance with SMA 07-19 and the existing entitlements for Site M. www .planning.hawaiicounty.gov Hawai'i County is an Equal Opportunity Provider and Employer planning@hawaiicounty.gov Katherine A. Garson, Esq. Carlsmith Ball LLP Page2 October 3, 2024 We appreciate the clarity, and the detailed plans submitted along with the request. If you have any questions, please feel free to contact me a (808) 961-8125. Sincerely, ZeJtdo Ket Jt Zendo Kern (Oct 4, 2024 08:54 HST) ZENDOKERN Planning Director APPENDIXE AECOS. Natural Resources Assessment for an SMA Permit Amendment for Muna Lani, Site "M", South Kohala Island of Hawaii AECOSNo. 1891 Natural resources assessment for an SMA permit amendment for Mauna Lani, Site "M", south Kohala Island of Hawai'i AECOSinc. 45-939 Kamehameha Highway Suite 104 Kane'ohe, Hawai'i 96744 July 17, 2025 Natural resources assessment for an SMA permit amendment for Mauna Lani, Site "M", south Kohala Island of Hawai'i July 17, 2025 DRAFT Gioconda Lopez, Reginald E. David, and Flor Muciiio AECOSinc. 45-939 Kamehameha Highway, Suite 104 Kane'ohe, Hawari 96744 Phone: (808) 937-0124 Email: gioconda@aecos.com Introduction AECOS No. 1891 The Mauna Lani Resort is proposing to amend an existing Special Management Area (SMA) Permit to reduce a previously approved resort density on an approximately 150-ac piece of land comprising two TMKs: (3) 6-8-022:010 and (3) 6-8-001:054 (Figure 1). Wilson Okamoto Corporation contracted AECOS Inc. to conduct a brief terrestrial flora and fauna survey in the subject to supplement existing information. This report presents our findings of the field survey.1 Site Description The project area is located within the greater Mauna Lani Resort Development in South Kohala on the Island of Hawai'i. The project is bound on the southeast side by Hoohana Street and on the west by existing development and a golf course. To the north and east are undeveloped lands with a mixed terrain of 'a'ii. and pii.hoehoe lava flows (Figure 1). 1 This report was prepared for Wilson Okamoto Corporation and is intended to become part of the public record by incorporation into an EA for the subject project. AECOS Inc. [File: 1891.docx] Page 11 Natural Resources Assessment. Figure 1. Survey area ( outlined in red) and (inset) location on the Island of Hawai'i. Survey Methods Botanical Survey MAUNA LANI, HAWAI'I AECOS botanist Gioconda Lopez and biologist Flor Mucino surveyed the site on May 22, 2025 using wandering transects to cover the Project area. Species were identified as they were encountered. Any plant not immediately recognized during the survey was photographed and/or a representative feature (fruit, flower, branch) collected for later identification at the laboratory. Species names follow Manual of the Flowering Plants of Hawai'i (Wagner, Herbst, & Sohmer, 1990; Wagner & Herbst, 1999) for native and naturalized flowering plants. More recent name changes for naturalized plant species follow Imada (2019). AECOS Inc. [File: 1891.docx] Page 12 Natural Resources Assessment. MAUNA LANI, HAWAI'I Terrestrial Vertebrates Surveys Avian Survey An avian survey was conducted by Reginald David on the morning of May 27, 2025. Ten avian point-count station were established approximately equidistant from each other across the survey area. A single six-minute count was conducted at each of the count stations. Birds were identified by visual observations aided by Leica 8 X 42 binoculars, and by listening for vocalizations. Weather conditions were ideal with unlimited visibility, no precipitation, and winds between 3 and 10 kilometers per hour. The avian phylogenetic order and nomenclature used in this report follows the AOU Check-List of North and Middle American Birds 2024 (Chesser et al., 2024) and the 65th supplement to the checklist (Chesser et al., 2024). Mammalian Survey A list was made of mammals encountered during the survey. Indicators of mammalian presence, such as tracks, scat, and other animal sign were noted. Mammalian phylogenetic order and nomenclature follow Mammal Species of the World (Wilson and Reeder, 2005). Results Vegetation The vegetation present in the project area is savannah dominated by fountain grass (Cenchrus setaceus), patches ofbuffelgrass (Cenchrus ciliaris), and Bermuda grass (Cynodon dactylon) with kiawe trees (Prosopis pallida; cover photo). The roadside verge supports ruderal weeds. Flora A botanical listing (flora) with approximate relative abundance for all plant taxa recorded is presented in Table 1. Entries are arranged alphabetically under family names and include scientific name, common name, status (i.e., native or non-native; see key at end of table), and a relative abundance value within the survey area. "Status" reflects the state-wide distribution of the species. Abundance is provided only for species observed in the May 2025 survey. The other species listed with a "-" in the abundance column were reported as present in previous surveys of the same area (David and Guinther, 2006) or vicinity, but AECOS Inc. [File: 1891.docx] Page 13 Natural Resources Assessment. MAUNA LANI, HA WAI 'r Table 1. Flora listing for the Mauna Lani, Site M and adjacent areas. Species listed by family Common Name Status Abundance Notes PTERIDOPHYTES -FERNS & FERN ALLIES NEPHROLEPIDACEAE Nephrolepis multifl.ora (Roxb.) sword fern Nat <1 (1)> Jarrett ex Morton OPHIOGLOSSACEAE Ophioglossum polyphyllum A. Braun pololei Ind <1 (2) > FLOWERING PLANTS -MONOCOTS AMARYLLIDACEAE Unknown Amaryllidaceae Orn p <2> ARECACEAE Cocos nucifera L. niu, coconut palm Pol < 1(1)> Livistona chinensis (Jacq.) R. Br. Chinese fan palm Orn <1 (1)> CYPERACEAE Kyllinga nemoralis (Forst.) Dandy ex kili'o'opu Nat <1 (1)> Hutch. & Daiz. Pycreus polystachyos (Rottb.) P. Ind < 1 (1)> Beauv. POACEAE Aristida adscensionis L. sixweek threeawn Nat 0 <1 (1)(2)(3)> Cenchrus ciliaris L. buffelgrass Nat C <1 (1)(2)(3)> Cenchrus setaceus (Forssk.) Morrone fountain grass Nat AA <1 (1)(2)(3)> Chloris barbata (L.) Sw. swollen finger grass Nat 0 <1 (2)> Cynodon dactylon (L.) Pers. Bermuda grass Nat <1 (1)(3)> Digitera setigera Roth itchy crabgrass Ind? <1 (2)> Eleusine indica (L.) Gaertn. beach wiregrass Nat < 1 (2)> Eragrostis cilianensis (All.) Link stinkgrass Nat R <1 (1)(2)(3)> Eragrostis amabilis (L.) Wight & Japaneselovegrass Nat u <1 (2)> Arnott Heteropogon contortus (L.) P. Beauv. pili Ind? <1 (2)> ex Roem. & Schult. Panicum torridum Gaud. kakonakona End <1 (2)> Melinus repens (Willd.) Zizka Natal redtop Nat <1 (1)(3)> Setaria verticillata (L.) P. Beauv. bristly foxtail Nat <1 (1)> AECOS Inc. [File: 1891.docx] Page 14 Natural Resources Assessment. MAUNA LANI, HAWAI'I Table 1 ( continued). Species listed by family Common Name Status Abundance Notes FLOWERING PLANTS -EUDICOTS AIZOACEAE Carpobrotus sp. ice plant Orn p <2> AMARANTHACEAE Alternanthera pungens Kunth khaki weed Nat u Amaranthus viridis L. slender amaranth Nat <1 (1)> Amaranthus spinosus L. spiny amaranth Nat u <1 (1)(2)> Atriplex semibaccata R. Br. Australian saltbush Nat 0 <1 (1)> Chenopodium album L. lamb's quarters Nat <1 (1)> Chenopodium ambrosioides L. Mexican tea Nat <1 (1)> Chenopodium murale L. lamb's quarters Nat u <1 (1)(2)(3)> Dysphania carinata (R.Br.) Mosyakin Nat u <1 (2)> &Clemants APOCYNACEAE Calotropis procera (Aiton) W.T.Aiton crownflower Om u <1 (3)> Cascabela thevetia (L.) Lippold be-still tree Nat <1 (1)> Plumeria obtusa L. Singapore plumeria Orn <1 (1)> Plumeria rubra L. frangipani Orn <1 (1)> ASCLEPED IACEAE Calotropis gigantean (L.) W. T. Aiton crown flower Orn <1 (1)> ASTERACEAE Ageratum conyzoides L. maile hohono Nat <1 (1) (2)> Bf dens cynapiifolia Kunth Spanish needle Nat <1 (2)> Bidens pilosa L. ki Nat <1 (2)> Bidenssp. beggar's tick Nat <1 (3)> Conyza canadensis (L.) Cronq. horseweed Nat u Emilia fosbergii Nicolson pualele Nat <1 (2)> Hypochloris radicata L. hairy cat's ear Nat <1 (2)> Pluchea carolinensis (Jacq.) G. Don Nat <1 (1)(2)(3)> Pluchea xfosbergii Cooperr. & Galang Nat <1 (1)(3)> Pluchea indica (L.) Less. Indian fleabane Nat <1 (1)(3)> Richardia tingitana (L.) Roth Nat <1 (2)> Senecio madagascariensis Poir. Nat <1 (1)> Sonchus oleraceus L. sow thistle Nat <1 (1)(2)> Tridax procumbens L. coat buttons Nat <1 (1)(2)(3)> Verbesina encelioides (Cav.) Benth. & golden crownbeard Nat 0 <1 (1)(3)> Hook. BRASSICACEAE Lepidium virginicum L. Nat <1 (1)(2)> CAPPARACEAE Cleome gynandra L. wild spider flower Nat <1 (1)(2)(3)> AECOS Inc. [File: 1891.docx] Page 15 Natural Resources Assessment. MAUNA LANI, HAWAI'I Table 1 ( continued). Species listed by family Common Name Status Abundance Notes CASUARINACEAE Casuarina equisetifolia L. ironwood Nat <1 (1)> CONVOLVULACEAE Merremia aegyptia (L.) Urb. hairy merremia Nat <1 (1)(2)(3)> CU CURB IT ACEAE Cucumis dipsaceus Ehrenb. Ex Spach. teasel gourd Nat R <1 (1)(2)(3)> Momordica charantia L. balsam pear Nat <1 (1)> EUPHORBIACEAE Euphorbia hirta (L.) Millsp. garden spurge Nat u <1 (1)(2)(3)> Euphorbia hypersifolia (L.) Millsp. graceful spurge Nat <1 (1)> Euphorbia prostrata (Aiton) Small prostrate spurge Nat u <1 (1)> FABACEAE Albizia lebbeck (L.) Benth. siris tree Nat <1 (1)> Erythrina sp. Orn <1 (1)> Leucaena leucocephala (Lam.) deWit koa haole Nat <1 (1)> Macroptilium lathyroides (L.) Urb. cow pea Nat <1 (1)> Prosopis pallida (Humb. & Bompl. ex kiawe Nat C <1 (1)(2)(3)> Willd.) GOODINACEAE Scaevola taccada (Gaertn.) Roxb. naupaka Ind <1 (3)> MALVACEAE Abutilon grandifolium (Willd.) Sweet hairy abutilon Nat <1 (1)> Hibiscus tiliaceus L. hau Ind <1 (1)> Malva parvif1.ora L. cheese weed Nat <1 (2)> SidafallaxWalp. 'ilima Ind u <1 (1)(2)(3)> Sida rhombifolia L. Cuba jute Nat <1 (1)> Waltheria indica L. 'uhaloa Ind 0 (1) (2)<6> MOLLUGINACEAE Mollugo cerviana (L.) Ser. threadstem Nat C <1 (1)(2)(3)> carpetweed NYCTAGINACEAE Boerhavia acutifolia (Choisy) J.W. alena Ind C <1 (1)(2)(3)> Moore Bougainvillea spectabilis Willd. bougainvillea Orn C <1 (1)> PORTULACEAE Portulaca oleracea L. pigweed Nat <1 (1)(2)(3)> Portulaca pilosa L. Nat <1 (1)(2)(3)> SAPINDACEAE Cardiospermum cf.. halicacabum L. poniu Nat? <1 (3)> SCROPHULARIACEAE Bacopa monnieri (L.) Wettst. 'ae'ae Ind <1 (1)> AECOS Inc. [File: 1891.docx] Page 16 Natural Resources Assessment. MAUNA LANI, HAWAI'I Table 1 ( continued). Species listed by family Common Name Status Abundance Notes SOLANACEAE Capsicum cf. annuum L. red pepper Orn <1 (1)> Solanum lycopersicum var. cerasiforme (Dunal.) Spooner, G. cherry tomato Anderson, & Jansen Nat R <1 (1)(3)> <1 (1)> Nicotiana glauca R.C. Graham tree tobacco Nat Unknown Unknown flowering plant 0 Legend to Table 1 STATUS = distributional status for the Hawaiian Islands: End = endemic; native and unique to the Hawaiian Islands. Ind = indigenous; native to Hawaii, but not unique to the Hawaiian Islands. Pol= early Polynesian introduction (before 1778). Nat= naturalized, exotic, plant introduced to the Hawaiian Islands since the arrival of Cook Expedition in 1778, and well-established outside of cultivation. Orn = A cultivated plant; a species not thought to be naturalized in Hawai'i. ABUNDANCE= occurrence ratings for plant species observed in May 2025: R-Rare U-Uncommon 0 -Occasional C-Common A-Abundant not observed in 2025 survey seen in only one or two locations. seen at most in several locations. seen with some regularity. observed numerous times during the survey. found in large numbers; may be locally dominant. abundant and dominant; defining vegetation type. AA-Very abundant p-Present plant intentionally cultivated for decorative or food-related purposes. Abundance not determined. NOTES: <1> Recorded in report by David and Guinther (2006) as: (1) from general area by AECOS Consultants (2004) and/or (2) by Char (1989) from the scrub vegetation type at Mauna Lani Marina site, and/or (3) as present by David and Guinther (2006). <2> Plant a juvenile or lacking flowers or fruit; identification therefore uncertain. not seen in the May 2025 survey. That report included species from two other earlier reports (Char, 1989; AECOS Consultants, 2004) as indicated in the "Notes" column of the table. AECOS Inc. [File: 1891.docx] Page 17 Natural Resources Assessment. MAUNA LANI, HAWAI'I In May 2025 we recorded 27 species of vascular plants, all of them angiosperms (flowering plants). Three species (11 %) are native indigenous plants (Ind; native but also distributed elsewhere in the Pacific. No endemic species (native uniquely to the Hawaiian Islands) or early Polynesian introductions ( so-called "canoe plants") were recorded. The remaining 24 species (89%) are plants introduced to the Hawaiian Islands after 1778, comprising 21 naturalized species (Nat; i.e., grow naturally in the wild), and three ornamentals (Orn). The indigenous species found during the present survey are: 'ilima (Sida fallax), 'uhaloa (Waltheria indica) and alena (Boerhavia acutifolia ). These species are relatively common across the Hawaiian Islands, especially in the coastal strand. Avian Fauna A total of 468 individual birds of 14 species, representing 11 separate families, were recorded during the May 2025 station counts (Table 2). An additional species: Hawaiian Goose-or Nene (Branta sandvicensis) was recorded as an incidental observation by the botanical team. Nene are an endemic species listed as threatened under federal endangered species statutes and as endangered under State of Hawaii statutes (HDLNR 1998, 2015; USFWS; nd-b). One other species Black-crowned Night Heron (Nycticorax nycticorax hoacth) is an indigenous resident breeding species. The remaining 13 species recorded are established alien species. Table 2. Avian species detected Mauna Lani Resort, Site M, May 2025. Common Name Hawaiian Goose Gray Francolin Black Francolin Spotted Dove Zebra Dove Mourning Dove AECOS Inc. [File: 1891.docx] S. ecies ORDER FAMILY ANSERIFORMES ANATIDAE -Ducks, Geese & Swans Anserinae -Geese & Swans Branta sandvicensis PHASIANIDAE -Pheasants & Partridges Phasianinae -Pheasants & Allies Ortygornis pondicerianus Francolinus francolinus COLUMBIFORMES COLUMBIDAE -Pigeons & Doves Streptopelia chinensis Geopelia striata Zenaida macroura Status RA ET A A A A A 1-2 2.30 0.90 0.50 2.40 1.70 Page 18 Natural Resources Assessment. MAUNA LANI, HAWAI'I Table 2 ( continued). Common Name ORDER FAMILY Status RA Black-crowned Night Heron Warbling White-eye Northern Mockingbird Common Myna African Silverhill Java Sparrow House Finch Northern Cardinal S ecies PELECANIFORMES ARDEIDAE -Herons, Bitterns & Allies Nycticorax nycticorax hoactli PASSERIFORMES ZOSTEROPIDAE -White-eyes Zosterops japonicus MIMIDAE -Mockingbirds & Thrashers Mimus polyglottos STURNIDAE -Starlings Acridotheres tristis ESTRILDIDAE -Estrildid Finches Euodice cantans Lonchura oryzivora FRINGILLIDAE -Fringilline and Carduline Finches & Allies Carduelinae -Carduline Finches and Hawaiian Honeycreepers Haemorhous mexicanus CARDINALIDAE -Cardinals & Allies Cardinalis cardinalis THRAUPIDAE -Tanagers Thraupinae -Core Tanagers _Sa_ff_r_o_n_F_in_c_h ______ Sica/is jlaveola Key to Table 2. Status: A = Alien introduced species. IR A A A A A A A A ET= Endemic Threatened species, listed under both federal and State of Hawaii ESA statutes. IR= Indigenous resident species, native but not unique to the Hawaiian Islands. RA: Relative abundance is the number of birds recorded by the number of count stations (10). 0.40 0.20 0.80 13.40 25.90 5.10 1.40 0.80 1.00 Avian diversity and densities observed during the survey are consistent with the xeric alien dominated habitat present at this elevation on the Island of Hawai'i. One species, the African Silverhill (Euodice cantans), accounted for 55% of the total number of birds recorded. AECOS Inc. [File: 1891.docx] Page 19 Natural Resources Assessment. MAUNA LANI, HAWAI'I Mammalian Fauna The only mammalian species recorded during the course of the survey was feral goat (Capra hircus). Goat scat, tracks, paths, and other sign, were encountered across the entire survey site. Discussion and Recommendations Recommendations are partly based on U.S. Fish and Wildlife Service, Animal Avoidance and Minimization Measures (USFWS-PIFWO). Implementation of the recommendations (provided below as bulleted items) by the project contractor will minimize impacts to listed species to the maximum extent practicable. Floral Resources Although scattered and sparse, occurrences of native flora are present within the Project area. These species are all common and their respective populations are abundant outside of the Project area. Only 27 species of plants were recorded from the Site M area. A survey of the same area in 2006 (David & Guinther, 2006) recorded 27 species, with 14 common to both surveys. Such a difference is probably not unusual considering that 15 of the species in the recent survey were rated as rare or uncommon in abundance; 21 were so listed in the 2006 survey. Species that are rare or uncommon are easily missed and occur in populations that may be poorly established, appearing and disappearing in the landscape from year to year. The large total number of species listed (81) indicates the surveys from which most of the species were recorded included habitats different from those present in the Site M area. No plants proposed or listed as threatened or endangered species as set forth in the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543; USFWS, nd-a; HDLNR, 1998) were seen during this survey. For plants, state listing follows the federal listing (HDLNR, 1998). Avian Resources One native endemic listed species, Nene, and one indigenous resident species Black-crowned Night Heron were recorded. The remaining 13 avian species detected during this survey are non-native introduced species naturalized in the Hawaiian Islands. AECOS Inc. [File: 1891.docx] Page 110 Natural Resources Assessment. MAUNA LANI, HAWAI'I Nene and Waterbirds Suitable nesting or foraging habitat does not exist in the Project area for Nene, which are, however, using resources on the adjacent golf course and other golf courses in the Kohala area. Water features that could support either of the two extant listed species, Hawaiian Coot (Fulica aim) and Black-necked Stilt (Himantopus mexicanus knudseni), are absent from the Site "M" area. The development of the site will not result in deleterious impacts to Nene, coot, or stilt. Seabirds ESA-listed night-flying seabirds in Hawai'i include Hawaiian Petrel (Pterodroma sandwichensis), Newell's Shearwater (Puffinus newelh), and Band-rumped Storm- Petrel (Hydrobates castro). On the Island of Hawai'i these three species nest in upland mountainous habitat. In the summer and fall, night-flying seabirds ( especially fledglings) transiting to the sea from inland locations can become disoriented by exterior lighting. When disoriented, seabirds may collide with man-made structures or the ground. If not killed outright, dazed or injured birds are targets of opportunity for feral mammals (Podolsky et al., 1998; Ainley et al., 2001; Day et al., 2003). The primary cause of mortality in listed species is predation by alien mammalian species at the nesting colonies (USFWS, 1983; Ainley et al., 2001). Collision with man-made structures is considered the second most significant cause of mortality of these seabirds in Hawai'i. No suitable nesting habitat for seabird species occurs in the project area, or vicinity. • The project can minimize or avoid risks to protected night-flying seabirds by not conducting night-time construction and ensure that all outdoor lighting is fully shielded (Night sky compliant). Mammalian Resources It is probable that one or more of the four Muridae found on the Island-roofrat (Rattus rattus), brown rat (Rattus norvegicus), Polynesian rat (Rattus exulans hawaiiensis), and European house mouse (Mus musculus domesticus) as well as small Indian mongoose (Herpestes javanicus) use resources on and within the general project area on a seasonal basis. These introduced mammals are deleterious to native ecosystems and native faunal species. It is possible that the endangered Hawaiian bat (Lasiurus semotus) over-fly's the project area. This bat species is solitary and rare but with a widespread distribution on Hawai'i. However, Hawaiian hoary bats use multiple roosts within AECOS Inc. [File: 1891.docx] Page 111 Natural Resources Assessment. MAUNA LANI, HAWAI'I a home territory (Bonaccorso, 2015), so the disturbance associated with removal of any particular tree would be minimal. An exception might be during the pupping season if a female bat carrying a pup or an unattended pup is in a tree being felled, these individuals could be unable to flee the tree. With that said, currently there are no suitable roosting trees for this species on the property. • Potential adverse impacts to Hawaiian hoary bat can be avoided or minimized by not clearing woody vegetation taller than 4.6 m (15 ft) between June 1 and September 15, the bat pupping season. Other Resources of Potential Concern Critical Habitat No federally delineated Critical Habitat for any species occurs within the project area (USFWS, nd-b). There is no equivalent designation under State of Hawai'i endangered species statutes. AECOS Inc. [File: 1891.docx] Page 112 Natural Resources Assessment. MAUNA LANI, HAWAI'I References Cited AECOS Consultants. 2004. Unpublished botanical results from a DERP-FUDS survey ofWaikoloa Sector 17 for USA Environmental. Ainley, D. G, R. Podolsky, L. Deforest, G. Spencer, and N. Nur. 2001. The Status and Population Trends of the Newell's Shearwater on Kaua'i: Insights from Modeling, in: Scott, J. M, S. Conant, and C. Van Riper III (editors) Evolution, Ecology, Conservation, and Management of Hawaiian Birds: A Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper's Ornithological Society, Allen Press, Lawrence, Kansas. Pp. 108-123. Bonaccorso, F. J., C. M. Todd, AC. Miles, and P. M. Gorresen. 2015. Foraging range movements of the endangered Hawaiian hoary bat, Lasiurus cinereus semotus. ]. ofMammology, 96:64-71. Char, W. P. 1989. Botanical Survey, Mauna Lani Marina, Mauna Lani Resort, Island of Hawai'i. Prep. for Belt Collins & Assoc., Honolulu. Char & Associates. Chesser, R. T., S. M. Billerman, K. J. Burns, C. Cicero, J. L. Dunn, B.E. Hernandez- Bafios, R. A Jimenez, Oscar Johnson, A W. Kratter, N. A Mason, P. C. Rassmusen, and J. V. Remsen Jr. 2024. Check-list of North American Birds. American Ornithological Society. Available online at URL: http://checklistaou.org/taxa; last retrieved March 17, 2025. Chesser, R. T., S. M. Billerman, K. J. Burns, C. Cicero, J. L. Dunn, B.E. Hernandez- Bafios, R. A Jimenez, 0. Johnson, A W. Kratter, N. A Mason, P. C. Rassmusen. 2024. Sixty-fifth Supplement to the American Ornithological Society's Check-list of North American Birds. Ornithology, Volume 141, 1- 21. David, R. E. 2023. Unpublished field notes -Hawai'i 1980 -2023. David. R. E., and E. B. Guinther. 2006. A Survey of Botanical, Avian and Terrestrial Mammalian Species for Mauna Lani Site "M" Special Management Area Permit Application, South Kohala District, Island of Hawai'i. Prep. for R. M. Towill Corp. 13 pp. Day, R. H., B. Cooper, and T. C. Telfer. 2003. Decline of Townsend's (Newell's Shearwaters (Puffin us auricularis newelli) on Kauai, Hawaii. The Auk, 120: 669-679. AECOS Inc. [File: 1891.docx] Page 113 Natural Resources Assessment. MAUNA LANI, HAWAI'I Hawaii Department of Land and Natural Resources (HDLNR). 1998. Indigenous Wildlife, Endangered And Threatened Wildlife And Plants, And Introduced Wild Birds. Department of Land and Natural Resources. State of Hawaii. Administrative Rule §13-134-1 through §13-134-10, dated March 02, 1998. Hawaii Department of Land and Natural Resources (HDLNR). 2015. Hawai'i Administrative Rules, Title 13, Department of Land and Natural Resources, Subtitle 5 Forestry and Wildlife, Part 2 Wildlife, Chapter 124, Indigenous Wildlife, Endangered and Threatened Wildlife, Injurious Wildlife, Introduced Wild Birds, and Introduced Wildlife. February 27, 2015. 16 pp. Imada, C. T. 2019. Hawaiian Naturalized Vascular Plants Checklist (February 2019 update). Bishop Museum Tech. Rept. 69. 209 pp. Podolsky, R., D. G. Ainley, G. Spencer, L. de Forest, and N. Nur. 1998. Mortality of Newell's Shearwaters Caused by Collisions with Urban Structures on Kaua'i. Colonial Waterbirds, 21: 20-34. U.S. Fish & Wildlife Service (USFWS). 1983. Hawaiian Dark-Rumped Petrel & Newell's Manx Shearwater Recovery Plan. USFWS, Portland, Oregon. February 1983. U.S. Fish & Wildlife Service (USFWS) Undated website (n.d.-a). Endangered Species. Available online at URL: https://www.fws.gov/endangered/; Last visited on April 4, 2025 and Environmental Conservation Online System (ECOS), online at URL: https://ecos.fws.gov/ecp/species-reports; last retrieved October 30, 2020. U.S. Fish and Wildlife Service (USFWS). Undated website (n.d.-b). Available online at URL: https://ecos.fws.gov /ecp/report/table/critical-habitat.html; last retrieved April 21, 2025. U.S. Fish & Wildlife Service-Pacific Islands Fish and Wildlife Office (USFWS- PIFWO). 2023. FINAL Avoidance and Minimization Measures (AMMs). Available online at URL: https://www.fws.gov/media/animal-avoidance-and- minimization-measures-may-2023-0; last retrieved March 17, 2025. Wagner, W. L., D. R. Herbst, and S. H. Sohmer. 1990. Manual of the Flowering Plants of Hawai'i: Volume I and II. Bishop Museum Special Publication 83. University of Hawai'i Press. 1853 pp. AECOS Inc. [File: 1891.docx] Page 114 Natural Resources Assessment. MAUNA LANI, HAWAI'I Wagner, W. L. and D.R. Herbst. 1999. Supplement to the Manual of the flowering plants of Hawai'i, pp. 1855-1918. In: Wagner, W. L., D. R. Herbst, and S. H. Sohmer, Manual of the flowering plants of Hawai'i. Revised edition. 2 vols. University of Hawaii Press and B.P. Bishop Museum. Wilson, D. E., and D. M. Reeder (editors), 2005. Mammal species of the world: a taxonomic and geographic reference. 3rd edition. 2 vols. John Hopkins University Press. Baltimore, Maryland. 2142 pp. AECOS Inc. [File: 1891.docx] Page 115 APPENDIXF ASM Affiliates. Archeological Literature Review and Field Inspection for the proposed Mauna Lani Site M AFFILIATES _.a\.rchaeology Hfa:tory Amhropology Architecmral H.i~iory September 3, 2025 Keala Cheng Wilson Okamoto Corp. 1907 S. Beretania St., Suite 400 Honolulu, HI 96826 Email: Subject: Dear Keala: via email Archaeological Literature Review and Field Inspection for the Proposed Mauna Lani Site M Development, TMKs: (3) 6-8-001:054 and 6-8-022:010, Waikoloa Ahupua'a, South Kohala, Hawai 'i Island. As requested by Wilson Okamoto Corp., on behalf ofDHL Mahi Site M, LLC (DHL; the landowner), ASM Affiliates (ASM) conducted an archaeological literature review and field inspection (LRFI) in support of an amendment to the Special Management Area (SMA) permit (SMA 07-019) for the proposed Mauna Lani Site M Project, TMK parcels (3) 6-8-001 :054 and 6-8-022:010, located in the ahupua'a ofWaikoloa, South Kohala District, Island of Hawai'i (Figures 1 through 3). The Site M development would encompass approximately 150 acres and proposes building a mix of hotel and residential dwellings with accompanying amenities. The purpose of this LRFI is to provide an update on the current conditions of the archaeological sites previously identified within Site M during the archaeological inventory survey (AIS) completed by Wolforth and Huber (2007), and provide information and recommendations to assist with the Department of Land and Natural Resources-State Historic Preservation Division (DLNR-SHPD) with their Hawai'i Revised Statutes (HRS) Chapter 6E-42 review of the amended permit application. This letter report presents a description of the proposed project and the project area, provides a brief culture-historical background for the Waikoloa Ahupua'a, a summary of previous archaeological studies conducted within and adjacent to the project area, and concludes with a description of the methods and results of the current field inspection, a discussion of the results, and a recommended effect determination for the proposed project. Description of the Proposed Project and Project Area In 2007, the Hawai'i County Planning Commission approved SMA Use Permit No. 07-000019 for the development of Site M, a 150-acre area within the Mauna Lani Resort. The proposed project included 1,207 units, consisting of 691 residential units and 516 hotel units, a three-hole golf course, a conference center, swimming pools, landscaped open spaces and water features, and 1,871 parking stalls, along with associated infrastructure. DHL proposes amending the SMA Use Permit to reduce the total unit count from 1,207 to 925 units (an approximate 23% overall reduction), including a 27% reduction in hotel rooms (516 to 374), and a 20% reduction in residential units (691 to 551). The revised plan also eliminates the three-hole golf course, which will remain as open space, and removes the conference center (see Figure 3). The Site M Project area is bordered to the west by N. Kaniku Drive and the Mauna Lani North golf course, to the south by Ho'ohana St, to the east by an undeveloped parcel, and to the north by an access road and the Puak6 petroglyph field (Figures 4 through 10). Much of the project area has experienced prior ground disturbance as evidenced by the presence of bulldozer tracks throughout the site and numerous areas that have been excavated, presumably for geotechnical investigations (Figure 11 ). The unmodified ground surface within the project area consists primarily of 'a'a and exposed pahoehoe bedrock terrain from the Kanimoe flow, a Mauna Loa flow originating between 4,000-5,000 years B.P. (Figure 12; USGS 2024). Soils within the project area are mainly classified as belonging to the Auwaiakeakua soil complex, and consist of extremely loamy cobbly silt loam on 2 to 10 percent slopes; however, the northwestern comer of Site M consists of Puak6 fine silty loam on Oto 6 percent slopes, while the southwestern-most sliver consists 820 Mililani Street, Suite 700, Honol'ulu, Hawaii 96813 (808) 439-8089 Fax: (808) 439-8087 507 A East Lanikaula Street, Hilo, Hawaii 96720 (808) 969-6066 Fax.: (808) 443-0065 www.asmafflliates.com September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page2 of43 of 'a'a lava flows on 2 to 20 percent slopes (Figure 13; Soil Survey Staff 2022). Vegetation found scattered within the project area includes buffelgrass (Cenchrus ciliaris), kiawe trees (Prosopis pallida), and a few scattered koa haole (Leucaena leucocephala). Literature Review Proiect Area Background The current project area is situated within the ahupua'a ofWaikoloa, which can be translated to either 'duck water' or 'water pulling far' in reference to the cold northeast Waikoloa winds (Pukui et al. 1974). Maly and Maly (2002) suggest that referencing the place name of Waikoloa could be in honor of a wind goddess as told by Kamakau ( 1991 ), who states that Lonopele called upon the cold, northern winds to sink the priest Pa'ao's canoes. One of these winds was Waikoloa, the sister of Kanakanaka, a semi-divine figure in the mo'olelo of the region (Kamakau 1991 :5 in Maly and Maly 2002:12). Another mo'olelo relates to the dominant lava flows in this area of Waikoloa: Kanimoe, which has been translated as "prostrate sound", and Kanikii, as ''upright sound" (Pukui et al. 1974:85; Wolforth and Huber 2007:6). Kanikii and Kanimoe, two mo'o (water-spirits with lizard bodies) would take the form of beautiful women and live in the large coastal fishpond ofWainanali'i in Pu'uanahulu. When a lava flow covered the pond, Kanikii and Kanimoe were turned into stone; their bodies remaining in the middle of the 'a'a, lying side by side in the lava flows now known by these names (Maly 2000). Archaeological evidence indicates that the Hawaiian settlement of the kona (leeward) coastal area was well underway by A.D. 1200 with major population expansion occurring between A.D. 1500-1700 (Cordy 2000; Dunn and Rosendahl 1992; Kirch 1979). The abundant anchialine ponds and easy access to the rich pelagic and benthic marine resources in this area led to the growth and expansion of these Hawaiian settlements by the early A.D. 1700s (Handy and Handy 1991 ). From the time of conquest, Kamehameha I bestowed land to warriors and chiefs who gave him support with the understanding that the lands could be revoked by the king at any time. In the beginning of the 19th century, Kamehameha I bequeathed the lands ofWaikoloa to Isaac Davis and John Young (McElroy et al. 2016). During the post-contact period (after 1778), the ever-growing population of Westerners in the Hawaiian Islands necessitated socioeconomic and demographic changes that led to the establishment of a Euro-American style ofland ownership, which was carried out in the Great Mahele. Waikoloa was deemed Crown land of which Isaac Davis received a large portion (Royal Patent Number 5671). George Hii'eu, the only surviving son oflsaac Davis, received a portion of Waikoloa (LCA 8521-B:1) in 1865. Post-Mahele, Waikoloa was sometimes referred to as "Waikoloa Nui" and "Waikoloa Iki", differentiating between the Crown land and Davis' land, respectively. The Crown land portion later became known as Lalamilo and Davis' portion, Waikoloa. The coastal lands of 'Anaeho'omalu and Kalahuipua'a were retained by the Crown as 'ili kupono (Maly 2000). During the first part of the A.D. 1900s, nearby Puako became the site of a short-lived sugar plantation. Subsequent to this, Puako and portions of coastal Waikoloa became Parker Ranch feed lots for cattle (Maly 1999; Puako Historical Society 2000). While ranching and sugar plantations expanded in the general area during the early 20th century, the current project area remained relatively unchanged beyond cattle grazing until the expansion of the highway and development of the coastal hotels. Much of the makai Parker Ranch lands in this area were sold to various entities during the 1960s. Conversely, the neighboring lands to the south of the project area were purchased by Francis Hyde I'i Brown in the 1930s. During his ownership, Brown restored the ponds at Kalahuipua'a, built rudimentary roads and planted many of the of palms that are now part of the Resort. In 1970, construction of the section of Queen Ka'ahumanu Highway from Hapuna to 'Anaeho'omalu Bay began, opening up the area for further resort development. In 1972, Orchid Island Resorts acquired the fee title to Brown's 175 acres and an additional 3,025 acres from Signal Properties (former Parker Ranch land) to create the 3,200-acre Mauna Lani Resort (Wolforth 2007). In 1972, re-zoning of the land was applied for and by 1980, construction began on the 3,200-acre property (Hawaii Tribune-Herald 1980). In 1985, September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page3 of43 Mauna Lani Resort, Inc. received SMA approval for the entire Resort Complex (Land Use Commission Docket No. A84-583). Archaeological Background Since the initial acquisition by Orchid Island Resorts in 1972, much of the Mauna Lani Resort, including the lands adjacent to the current project area, have been developed. As such, a series of archaeological studies have been conducted as part of the historic preservation review process for the various development activities within the larger Resort area (Figure 14). An AIS of Site M was conducted in 2007 (Wolforth and Huber 2007), during which several historic properties were identified. To better understand the broader context in which the historic properties located within Site M are situated, a review of prior archaeological studies conducted within and adjacent to the Site M parcel was conducted; this review expands upon the previous studies discussed in Wolforth and Huber (2007). Additionally, historic documents, maps and aerial photographs were also assessed. More than 3,000 individual petroglyphs were initially documented by the Bishop Museum in 1964 (Smart 1964) between the Puako Beach Lots and Ho'ohana Street. In 1982, the petroglyph field was listed in the Hawai'i Register of Historic Places (HRHP; Tomonari-Tuggle 1982) and subsequently in the National Register of Historic Places (NRHP) in April of 1983. This site, designated as "The Puako Petroglyph Archaeological District" (Site 50-10-11-04 713 ), is described as one of the largest and oldest petroglyph fields of its kind in the Hawaiian Islands (Dunn and Rosendahl 1992; Lee and Stasack 1999). This petroglyph park is located adjacent to the northern and western boundaries of the current project area. Between 1973 and 1975, prior to the development of the Mauna Lani Resort, the Bishop Museum also conducted a series of archaeological investigations within an approximately 3,841-acre area that covered the coastal portions of the ahupua'a of Kalahuipua'a, Waikoloa, and Lalamilo and included the current project area (Kirch 1979). That study, which encompassed all of the lands situated between Puako Beach Drive, the Queen Ka'ahumanu Highway right-of-way, and the southern end of the Waikoloa Resort Property, identified 179 archaeological sites containing a total of 449 features. The documented features included petroglyphs, fishponds, trails, C-shaped structures, U-shaped structures, L-shaped structures, shelter caves, burial caves, storage caves, modified sinks, abrader manufacturing areas, papamu, walls, circular structures, enclosures, platforms, and midden deposits (Kirch 1979). Most of the sites were identified within the coastal portion of the survey area and were interpreted as being associated with the extraction of marine resources from the Kalahuipua'a fishponds and other nearby anchialine ponds. The entirety of the current project area was included within the Kirch (1979) survey area, but no sites were reported within Site M. In 1989, Paul H. Rosendahl, Ph.D., Inc. (PHRI) conducted an AIS (Jensen 1989) of a 156-acre project area across multiple parcels for the development of additional holes for the Resort's north and south golf courses. The survey area for the additional North course holes is adjacent to the southern portion of the current project area (see Figure 14). Nine archaeological sites containing 18 component features were identified. Formal feature types that comprised the sites included caves, C-shape walls, trails, cairns, quarried crevices and blisters, abrader basins with associated modified scoriaceous pahoehoe, and light midden scatters. Functional site types included temporary habitations, markers, transportation features, and quarry/production areas related to the manufacture of abraders. One site, Site 50-10-11-11265 (previously identified by Kirch 1975 as Site E2-31) consisted of four C-shaped shelter features, two petroglyphs and an estimated 175 abrader basins. This site is located outside of the southwestern portion of the current project area. No further work was recommended for Site 50-10-11-11265. Scientific Consultant Services (SCS) conducted an AIS (Burgett et al. 1999) of a 22.5-acre portion of TMK parcels (3) 6-8-022:001 and 005 (Parcel K), which became the Fairways at Mauna Lani Subdivision. As a result of that study, 39 features were documented in four clusters that were designated as separate sites (Sites 50-10-11-21362, -21363, -21364, and -21365). The sites included abrader basins and pahoehoe excavations, as well as small temporary shelters, rock mounds, and small openings used to store items. Burgett et al. (1999) investigated several crevices and cave openings within the Fairways at Mauna Lani September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page4 of43 project area but did not find any evidence of long lava tubes or extensive use of the small blisters or tube opemngs. Rosendahl (2000) conducted an AIS of a 450-acre portion of TMK (3) 6-8-001 :022, just northwest of the current project area. As a result of the survey, 14 sites containing 30 features were identified. The sites included walls, mounds, marine shell concentrations, a possible cart path, and a modified outcrop with cultural deposits, and three complexes with enclosures, overhangs, and ranching and sugarcane features. Based on the findings of the project, no further archaeological work was recommended for any of the sites. In 2003, SCS began conducting archaeological monitoring for the construction of the Fairways at Mauna Lani subdivision (Wolforth 2006). During the geotechnical boring, technicians exposed a concealed cave containing human skeletal remains. SCS inspected the cave and documented it as Feature 14 of Site 50-10- 10-21364. A burial treatment plan (Wolforth 2003) was subsequently prepared for the cave and archaeological monitoring continued until the end of ground disturbance. No additional archaeological sites or features were identified. In 2004, CSC (Wolforth 2005) conducted an AIS of the 56-acre Brookfield Homes Development. Twelve archaeological sites, including abrader basins, pahoehoe excavations, a pavement, trails, and a modified lava ball, were identified. All sites were significant under Criterion 'd' and no further work was recommended of any of the identified sites. Wolforth and Huber (2007) cited the inventory of feature types at the Parcel Kand Brookfield Homes project areas as indicators for the Site M project, based on similar terrain and proximity (Burgett et al. 1999; Wolforth 2005). Abrader basins and small caves were the most common feature types. The small blister areas contained scant artifacts, suggesting sporadic use and likely functioned as short temporary shelter during makai-mauka resource procurement (Wolforth and Huber 2007:31). The aforementioned archaeological studies indicate that features in this area of Hawai 'i Island tended to occur in higher concentrations and exhibited greater functional diversity closer to the coast. As was the case in nearby parcels, activities occurring within the current project area typically included resource extraction and processing, as indicated by the presence of pahoehoe and 'a'a excavations, and abrader basins. Temporary habitations such as C-shapes and small shelter caves were interspersed across the landscape with trails that were utilized to access resources and mauka destinations likely occurring over the flatter, smoother pahoehoe landscape. Archaeological Inventory Survey of Site M In 2007, SCS conducted an AIS of Site M, comprising roughly 150 acres within the Mauna Lani Resort development area across TMKs: (3) 6-8-001:054 and 6-8-022:010 (Wolforth and Huber 2007). The fieldwork for the AIS, which included a surface survey of the entire project area with fieldworkers spaced at 20-meter intervals followed by detailed site documentation and subsurface testing at selected features, was conducted between November 8 and December 17, 2004, under the direction of Robert L Spear, Ph.D. (SCS Principal Investigator). During the fieldwork Global Positioning System (GPS) coordinate data in Universal Traverse Mercator (UTM) units were taken for the features and metal site tags displaying temporary site numbers, date, field crew recorder, and SCS project number (514), were placed at every site (Wolforth and Huber 2007:32). As a result of the AIS, eight archaeological sites containing a total of 31 features were documented and assigned Statewide Inventory of Historic Places (SIHP) site designations (Sites 50-10-11-24425 to 50-10- 11-24432). The documented sites included pahoehoe excavations, C-shaped structures, abrader basins, and a resource extraction complex (Table 1 and Figure 15). Three features at two of the sites were subject to subsurface testing (Site 24426 Feature 1 and Site 24432 Features 2 and 7), but only a single waterwom pebble was recovered from one of the tested features (Site 24432 Feature 2). Due to its proximity to the Puako Petroglyph Archaeological District (Site 4713), the northern portion of the project area was inspected closely for petroglyphs on three different occasions. No petroglyphs were September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 5 of43 observed within the project area. In addition to the 8 sites assigned SIHP site designations, SCS also investigated 6 cave openings within the Site M project area (Sites T-1, T-2, T-4, T-5, T-6 and T-7; see Figure 15) by traveling through all passageways until they became 30 centimeters wide or high, precluding further passage. According to Wolforth and Huber (2007:32): Each cave was mapped, and in one case, a test excavation was conducted within the cave soils. No cultural material was observed in any cave, or in the excavated area. Consequently, these caves were not interpreted as archaeological sites. A photograph and plan view of each cave [ was prepared] to document that these potential cultural resources were fully inspected. In summarizing the findings of the AIS, Wolforth and Huber (2007:74-75) write: Site density closer to the ocean reinforces the model for the area that habitation took place along the shoreline. The expectation is that people living near the sea would travel inland to perform certain activities. Based on the study area data, these activities include extraction and processing of basalt material, as expressed at the pahoehoe excavation, abrader basin, modified lava ball, and 'a 'a excavation sites. Trails connect temporary habitations, in the form of small shelter caves, pavings, and platforms, to the resource extraction areas. While the pahoehoe covers most of the Study Area, resource extraction within the pahoehoe is concentrated in one area, and not spread out. This is demonstrated by the high density of abrader basins in the western third of the project area, and the complete lack of such features in the eastern two thirds where pahoehoe, the substrate for abrader basins, is abundant. In other words, the presence of good abrader basin substrate does not mean that abrader basins will be made there. Consequently, the location of abrader basins are determined by factors other than material availability. And that factor appears to be relative proximity to the habitation near the ocean. The 'a 'a terrain is situated further inland. Two types of archaeological features are present only within the 'a 'a modified lava balls, and 'a 'a excavations. This correlation probably means that the 'a 'a terrain supplied a particular kind of resource that was retrieved in a particular kind of way. What makes that particular resource sought after is not known at this time. It may be the porosity of the basalt, or it may be the particular color that was desired. One speculation is that the 'a 'a here is lighter and can provide the appropriate weight for net sinkers: heavy enough to sink the net, but light enough to carry when many are attached to a net. The way of obtaining this resource was by opening up lava balls, and scraping out the 'a 'a from the sides of slopes ( 'a 'a excavations). With regards to the documented trail sites, they write: If there is a positive correlation between trail visibility and intensity of travel over that trail (Wolforth and Wilson 2004), then it appears that the trail in the western portion of the project area was used most often near Feature 2 of Site 24432, and near the marker Feature 11 at Site 24432. The lack of distinct trail in association with the portion of Site 24432 where the resource extraction features are located, is interpreted as indicating that people moved over the resource extraction area in an unrestricted fashion. In other words, the trail leads people to the resource extraction area, but once people get to the fringe of that area, they fan out over the landscape to perform extraction wherever they desire. Consequently, there is no one single pathway that is used, and a restricted trail does not develop, or was not created . . . . The three trail segments in the eastern portion of the project area (Site 24427) may be associated with travel to and from the petroglyphs in nearby Site 4713 [the Puako Petroglyph Field]. The three trail segments are restricted trail pieces of a larger unrestricted September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 6 of 43 pathway. A large cairn north beyond the project area is in alignment with the three trail segments, suggesting that it is another part of the larger trail pathway. (W olforth and Huber 2007:75-76) Wolforth and Huber (2007:77) evaluated all eight of the documented sites as significant under Hawai'i Administrative Rules (HAR) § 13-284-6 Criterion 'd' for the information that they contained relative to the prehistory of the region and recommended a treatment of"no further work" for all sites (see Table 1). They conclude the AIS by stating that: Upon acceptance of these recommendations by SHPD, development may proceed across the entire project area without any additional archaeological measures. While the methods used and reported on in this inventory survey are appropriate for the kinds of terrain and expected archaeological and cultural sites for this project, there is always the possibility that such sites were not identified during that process. Hawai'i Administrative Rules §13- 280 governs the procedures to be conducted should undocumented archaeological and cultural sites be encountered during the development process. An initial draft of the AIS report for Site M was submitted to the DLNR-SHPD for review in 2005. A letter requesting revisions to the draft report was sent to SCS by the DLNR-SHPD on April 20, 2006, and a revised draft of the AIS report was submitted to the DLNR-SHPD for review in February of 2007. That draft of the report was accepted as final by the DLNR-SHPD in a later dated July 13, 2008 (Log No: 2007.0569; Doc No: 0807MD22; Appendix A). In that letter the DLNR-SHPD concurred with significance assessments for the sites and agreed that the documentation presented in the AIS was sufficient to warrant a treatment of "no further work" for all sites. Table 1. Significance and Recommended Treatments reproduced from Wolforth and Huber (2007:77). State Architectural Fllllction. Significance Recommended Site features Criterion Treatment -24425 Piihoehoe Resource extraction D No further excavations work -24426 Modifie<l Temporary :habitation D No further outcrop work -24427 Trail segments Travel D No further work -24428 C-shaped Temporary habitation D Nolbrlher structure work -24429 C-shaped Temporary habitation D No further structure work -24430 A brade.r basins Tool manufacture D No further work -24431 Abrader basins Tool manufacture D No.further work -24432 Complex Resource extraC'tion D No further work I In December of 2007, SCS also completed a draft of a Cultural Impact Assessment (CIA) for the proposed development of Site M (W olforth 2007). The CIA concluded that: Based on the archaeological work, research into the history of the area, and interviews, there are not Traditional Cultural Properties or ongoing Cultural Practices within the project area that area tied to the land. For instance, there are no resources that are gathered within the area, no recreational or transportational activities that take place there, no agricultural activities, no ceremonies practiced there, and no burials present. There broader September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page? of43 context of the Mauna Lani area does provide the setting for an unusual kind of cultural practice, however, one that probably has not been considered before, but one that is germane to the culture of this island and state: this is the "Resort Culture ofMauna Lani". (Wolforth 2007:25) Wolforth (2007:26) goes on to describe the Resort Culture ofMauna Lani as follows: ... the commercial setting of the area that has come to be known as Mauna Lani has, at its core, a set of practices and beliefs that are founded in the earliest days of commercial development there, and can still be observed in a variety of manifestations. The suite of developments in the Mauna Lani region (those areas connected to one another by the roads that lead the single road that intersects Queen Ka'ahumanu Highway) share a common corporate history. That history is passed on by word of mouth, and is a source of self- esteem and honor for many of the employees that work in the wide variety of jobs ... . . . The presence of a "commercial culture" at Mauna Lani is evident in the continued retelling of the origin of the Mauna Lani Resort, and emphasized by the production of the written version of those stories. The culture is expressed in the way that cultural resources are incorporated into the design and layout of the resort area, and the continued maintenance of those resources. The CIA goes on to conclude that: There are no Traditional Cultural Properties at Site M. There are no preservation archaeology sites at Site M. The only cultural practice at Site M is the practice of commercial development of resort property. This is a relatively new practice, but one that is significant in 20th century land use that is intimately tied to the way that modem people identify with, understand, interpret, and affect ancient culture. Decentralization of the Mauna Lani development, and lack of opportunities for new participants in that culture to share, interact with, or otherwise obtain information about, the origin, history, and ongoing activities that make up that resort culture, contributes to the demise of that resort culture. Knowledge of such things as how certain resort components came to be as they are, historical trajectories that might influence current and future design, current issues with native Hawaiians, how historical resources have been dealt with in the past successfully or not, is not being shared with the newcomers to the property. The development of the Site M property for resort use contributes to the way that the resort culture evolves at Mauna Lani. Those actions may be conducted without knowledge of the resort culture at Mauna Lani, however. The lack of articulation with the resort culture at Mauna Lani can be considered a negative impact to the continuation of the resort culture at Mauna Lani. To mitigate impacts to this commercial cultural practice, it is recommended that the developer create a program that is designed to introduce current and future developers to the commercial culture at Mauna Lani of which they are now participating in ... . . . The objective in disseminating information about the resort culture at Mauna Lani is not necessarily to promote a particular paradigm, or to insist that only certain ways of conducting commercial activity are permitted. The objective is to facilitate the continuation of this particular resort culture, which can be seen as a growing and evolving activity that deals with development issues that pertain to Mauna Lani. Those issues have an origin, a history, and a current trajectory that is not being shared with newcomers to that culture and practice. The synthesis of available information, and the dissemination of that information at appropriate venues will mitigate the impacts to the resort culture at Mauna Lani. (Wolforth 2007:27) September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 8 of43 To effectively facilitate the continuation of the Mauna Lani Resort Culture as part of the development of Site M, the CIA recommended that: (1) the publication and dissemination of the written version of the oral histories presented as an appendix to the CIA occur; (2) a list of other relevant reading materials be produced; (3) a 30-minute DVD presentation on the history of the commercial culture at Mauna Lani be prepared; (4) opportunities for developers to interact with the Mauna Lani cultural specialists be provided; and (5) venues to appropriately disseminate the Mauna Lani Resort Culture information in ways that are valuable to current and future developing entities be created (Wolforth 2007:27). Both the AIS and the CIA prepared by SCS (Wolforth 2007; Wolforth and Huber 2007) were used to inform an SMA permit application (SMA 07-000019) for proposed hotel, residential, and golf course development within the Site M project area that was submitted to the County of Hawai'i (CoH) Planning Commission for review and approval in 2008. The SMA permit application for Site M (SMA 07-000019) was approved by the Planning Commission in a letter dated September 4, 2008. Subsequently, in a letter dated September 10, 2008, the DLNR-SHPD reviewed the SMA permit application for Site M (LOG NO: 2008.4079; DOC NO: 0809TD17) and reaffirmed that they concurred with the significance assessments presented in the Wolforth and Huber (2007) AIS report, and ''with the findings of the report that no further archaeological data collection was needed as a mitigation measure" ( see Appendix A). Most recently, in a letter dated October 5, 2015, the DLNR-SHPD reviewed and approved a grading permit for TMK: (3) 6-8-001:054, encompassing the northern 100 acres of Site M (Log No: 2015.03240; Doc No: 1510SN02), stating that: The parcel has been subject to a previous SMA review by our office and it has been determined that the mitigation for the proposed project has been completed (Log No. 2008.4079, Doc. No. 0809TD17). Therefore, based on current information, SHPD's determination is no historic properties affected. Issuance of the permit for the grubbing activities may proceed. (see Appendix A) Archaeological Field Inspection: Methods and Results On May 28, 2025, S. Steele D. Jaques, M.A. (ASM Principal Investigator), Matthew R. Clark, M.A., and David King, M.Sc., conducted a targeted archaeological field inspection of Site M that included the location and reassessment of the archaeological sites and associated features previously identified by Wolforth and Huber (2007). The field investigation began in the northeastern portion of the project area and terminated at the southern end of Site M. Between sites, investigators spread out to survey a greater area, but no systematic survey was conducted. When a site and its component features were reidentified, they were checked against the original site and feature descriptions and photographs, and updated GPS positions were collected using BOS Arrow 100 Global Navigation Satellite System (GNSS) receivers (set to the NAD 83 Zone 5 North) connected to handheld tablet computers running ESRI's Field Maps application (Figure 16). Updated photographs and brief descriptions were taken using the Field Maps and Solocator applications on the handheld tablet computers. Several of the caves documented by Wolforth and Huber (2007) were also revisited. As a result of the targeted survey, all sites and features documented by Wolforth and Huber (2007) were reidentified and found to be in similar conditions to those described in the original descriptions in the 2007 AIS (for a more detailed description and photographic documentation of present site conditions, see Appendix B). No new historic properties were identified on the surface of the project area. Based on the current field inspection, Wolforth and Huber (2007) adequately identified all historic properties within Site M. In fact, some of the sites that were identified as historic properties during the 2007 AIS were barely discernable as such; some sites and/or features (such as Features 1 and 3 of Site 24426, Sites 24427-24429, and Features 1, 12, and 14 of Site 24432) appeared more likely to be natural formations rather than historic properties. Portions of the areas inspected during the current fieldwork were observed to have been subjected to prior mechanical disturbance, including bulldozer scarring, pathways, and tracks and geotechnical excavations. It appears some of the disturbance had occurred subsequent to the AIS conducted by Wolforth and Huber September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 9 of 43 (2007). None of these disturbances impacted sites. The depth of the disturbances, combined with the nature of the lava substrates within Site M, suggests that the likelihood of encountering any intact subsurface historic properties is also very low. Summary and Recommendations As a result of the targeted survey, no additional historic properties were identified on the surface of the project area. All sites and component features identified by Wolforth and Huber (2007) were extant and in similar conditions to those originally described in the 2007 AIS. Based on review of the AIS and the CIA prepared by SCS (Wolforth 2007; Wolforth and Huber 2007), the SMA permit application for the proposed hotel, residential, and golf course development within Site M (SMA 07-000019) was approved by the Planning Commission in a letter dated September 4, 2008, and subsequently, in a letter dated September 10, 2008 (LOG NO: 2008.4079; DOC NO: 0809TD17), the DLNR-SHPD reaffirmed that they concurred with the significance assessments presented in Wolforth and Huber (2007) AIS report, and "with the findings of the report that no further archaeological data collection was needed as a mitigation measure" (see Appendix A). Most recently, in a letter dated October 5, 2015, the DLNR-SHPD reviewed and approved a grading permit for TMK: (3) 6-8-001:054, encompassing the northern 100 acres of Site M (Log No: 2015.03240; Doc No: 1510SN02; see Appendix A). Therefore, we do not believe that the DLNR-SHPD will require any additional documentation or mitigation as part of the SMA permit extension application. To facilitate the continuation of the Mauna Lani Resort Culture as part of the development of Site M, the CIA recommendation included: (1) the publication and dissemination of a written version of the collected oral histories; (2) the presentation of a list of other relevant reading materials; (3) the production of a 30- minute film on the history of commercial culture at Mauna Lani; ( 4) opportunities for developers to interact with the Mauna Lani cultural specialists; and (5) venues to appropriately disseminate the Mauna Lani Resort Culture information in ways that are valuable to current and future developing entities (Wolforth 2007:27). Wolforth (2007:26) further states, "The development of Mauna Lani incorporates the conflicts inherit in a large-scale development: that of the destruction that comes with construction. Brown, Gotoh and Rockefeller worked together to provide a leadership core that held preservation of cultural and natural features in high regard. The result is evident in the way that the Puak6 Petroglyph National Register of Historic Places district is regarded and handled, the King's Trail is maintained, the fishponds are dealt with, and the Eva Parker Woods cottage is kept as a vital part of the place." The current Site M development plan has considered the recommendations proposed by Wolforth (2007), including preservation and perpetuation of the existing landscape. The plan incorporates open spaces, most significantly within the northern portion of the proposed project area, thus maintaining mauka/makai access routes, as well as connections to historic sites such as the adjacent Puak6 Petroglyph Archaeological District (Site 4713) and potentially Sites 24426 and 24427, which are located within the open spaces shown in the current development plan (see Figure 17). Should you have any questions or concerns, please feel free to contact me directly. Sincerely, S. Steele D. Jaques, M.A. Senior Archaeologist, ASM Hilo September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 10 of43 References Cited Burgett, B., L. McGerty, and R. L. Spear 1999 An Archaeological Inventory Survey of a 22.5 Acre Parcel (Parcel K) in the Ahupua'a of Waikoloa, South Kohala District, Island of Hawai'i (TMK 6-8-22:01,05). Scientific Consultant Services, Inc. Project Number 129-2. Final. Revised July 1999. Prepared for Mauna Lani Resort, Honolulu. Cordy,R. 2000 Exalted Sits the Chief, The Ancient History of Hawai 'i Island. Mutual Publishing, Honolulu. Dunn, A. E. and P. H. Rosendahl 1992 Phased Archaeological Inventory Survey, Puako Beach Road Extension Corridor, Land of Lalamilo, South Kohala District, Island of Hawaii. Paul H. Rosendahl, Ph.D., Inc. 975- 050592. Prepared for Paniau Partners, Hilo, HI. Hawaii Tribune-Herald 1980 Ground Broken. Hawaii Tribune-Herald [Hilo, Hawaii]. October 29, 1980: 1. Electronic document, https:/ /www.newspapers.com. Jensen, P. 1989 Archaeological Inventory Survey, Mauna Lani Resort New Golf Course, Lands of Kalahuipuaa and Waikoloa, South Kohala District, Island of Hawaii. Paul H. Rosendahl, Ph.D., Inc. 469-120988. Prepared for Mauna Lani Resort, Inc., Hilo, HI. Kamakau, S. M. 1991 Tales and Traditions of the People of Old, Na Mo 'olelo aka Po 'e Kahiko. Bishop Museum Press, Honolulu. Kirch, P. V. 1979 Marine Exploitation in Prehistoric Hawaii: Archaeological Investigations at Kalahuipua'a, Hawai'i Island. Pacific Anthropological Records No. 29. Department of Anthropology, B.P. Bishop Museum, Honolulu. Lee, G. and E. Stasack 1999 Spirit of Place: Petroglyphs of Hawai'i. Easter Island Foundation, Los Osos, California. Maly, K. 1999 Nii Ala Hele Ma Kai O Kohala Hema (The Coastal Trails of South Kohala): Archival- Historical Documentary Research, Oral History-Consultation Study and Limited Site Preservation Plan Kawaihae-'Anaeho'omalu Trail Section: Lands ofKawaihae 2nd, 'Quli, Liiliimilo, Waikoloa, Puako, Waimii, Kaliihuipua'a, and 'Anaeho'omalu; District of Kohala, Island ofHawai 'i (TMK Overview Sheets: 6-2, 6-8 & 6-9). Kumu Pono Associates Report HiAla-l 7K (043099). Prepared for State Division of Forestry and Wildlife, Nii Ala Hele Program Manager (Hawai 'i Island), Hilo, HI. 2000 A Historical Overview: Ka 'iii 'Aina of 'Anaeho 'omalu Ma Waimea, Kohala Hema (The Land of 'Anaeho 'omalu, at Waimea, South Kohala) Island of Hawai'i (TMK: 6-9-07: 15). Maly, K. and 0. Maly 2002 He Wahi Mo'olelo No Ka •Aina A Me Nii 'Ohana O Waiki'i Ma Waikoloa (Kalana 0 Waimea, Kohala), A Me Ka •Aina Mauna: A Collection of Traditions and Historical Accounts of the Lands and Families of Waiki'i at Waikoloa (Waimea Region, South Kohala), and the Mountain Lands, Island of Hawai 'i (TMK Overview Sheet 6-7-01 ). Kumu September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 11 of43 Pono Associates, LLC Report HiWaikii61-111202. Prepared for Waiki'i Ranch Homeowner's Association, Kamuela, HI. McElroy, W. K., L. Brandt, and C. Hitt 2016 FINAL-Ethno-Historical Study of the Kalahuipua'a Fishponds, Waikoloa Ahupua'a, South Kohala District, Island of Hawai'i, TMK: (3) 6-8-022:006 (por.), :015 (por.), :048, and :061. Keala Pono Archaeological Consulting, LLC. Revised 2016. Prepared for Group 70 International, Honolulu. Puako Historical Society 2000 Puako An Affectionate History. Creative Connections Publishing, Vancouver, B.C. Pukui, M. K., S. H. Elbert, and E. Mo'okini 1974 Place Names of Hawaii. Revised and Expanded ed. University of Hawaii Press, Honolulu. Rosendahl, P. H. 2000 Archaeological Inventory Survey of TMK 6-8-01:22, Land of Waikoloa, South Kohala District, Island of Hawai'i. Paul H. Rosendahl, Ph.D., Inc. 2017-072000. Revised 2000. Prepared for White Sand Beach LP, Tinguely Development, Hilo, HI. Smart, C. 1964 A Report of Excavations on Site H22, Puako, Hawaii Island. Revised 1964. Prepared for B.P. Bishop Museum, Honolulu. Soil Survey Staff (United States Department of Agriculture, Natural Resources Conservation Service) 2022 Official Soil Series Descriptions. Electronic document, https://soilseries. sc.egov. usda. gov/ osdlist.aspx. Tomonari-Tuggle, M.-J. 1982 An Archaeological Reconnaissance Survey of a Parcel Adjoining the Puako Petroglyph Fields, Puako, Hawai'i. Revised 1982. Prepared for Waimea Hawaiian Civic Club and Mauna Lani Resort. USGS 2024 Wolforth, T. R. 2003 Geologic Map of the Northwest Flank ofMauna Loa Volcano, Island ofHawai'i, Hawaii, p. https://pubs.usgs.gov/sim/2932/e/sim2932e sheet2931.pdf. Burial Treatment Plan for Inadvertent Discovery of Human Remains at the Fairways of Mauna Lani, Waikoloa, South Kohala, Hawai 'i Island. Scientific Consultant Services, Inc. Report 411.1. Prepared for Stanford Carr Development, LLC. 2005 An Inventory Survey Report for the Brookfield Homes Development: Investigation into Patterns of Resource Expoloitation of the Lower Elevations of the Kanikii Flow in Waikoloa Ahupua'a, South Kohala, Hawai'i Island, Hawai'i, [TMK: 3-6-8-22:7 and 41]. Scientific Consultant Services, Inc. Project 471-2. Prepared for Brookfield Homes Hawai 'i, Inc., and SCD ML II, LLC, Managed by Stanford Carr Development, LLC, Honolulu. 2006 Monitoring Construction at the Fairways of Mauna Lani TMK (3) 6-8-022:5. Scientific Consultant Services, Inc. Report 456.1. Revised March, 2006. Prepared for Stanford Carr Development, LLC. 2007 A Cultural Impact Assessment for Site M in Mauna Lani: Waikoloa Ahupua'a, South Kohala District, Hawai'i Island, Hawai'i [TMK: 3-6-8-1: 54 and 3-6-8-22: 10]. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 12 of 43 Wolforth, T. R. and S. Huber 2007 An Inventory Survey for Site M in Mauna Lani: Investigation into Resource Exploitation Patterns in the Lower Elevations of the K.anikii Flow in Waikoloa Ahupua'a, South Kohala District, Hawai'i Island, Hawai'i, [TMK: 3-6-8-1:54 and 3-6-8-22:10]. Scientific Consultant Services, Inc. 514-2. Prepared for Stanford Carr Development, LLC, Honolulu. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 13 of 43 Figures N A D Project Are~ 0 0 300 Km I I ~ -+----+--- g ~t-,,,,..,.,-,--,- <• 199000 0 C E :woooo Figure 1. Project area location. A 201000 N A :!03000 ~0-1000 :!05000 September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 14 of 43 N A c:J Project Area Hawai'i County Parcels Figure 2. Project area location. N A !'..-!Ctl.'11. 450 900 N w w ....i ~ .i:i, ., ... 0 ,., Q ~ :il $I ~ r-~ -Cl ii ~ ~ c= z ~ V, V, ..... 0 ~ r-:,;, g; Cl ~ :;j ~ C: z ~ t.)W'/OOG"t "nayrn'sa~95i~t•RIYI.J 9f,lll"d I :nt/oo 11 'o::r..o.-o·n '1:111111 'l!Ot 's~:1~s fUWD'fllM01J S: fll3Ject (3v/na1'ra.ny9"gJ '""'111na: 'J~:IP~l1i /n\llOlflMIIJ.I t' p;ued Figure 3. Conceptual plan for the proposed Mauna Lani Site M. development. l:no/q!vn S'91~H,W'J~J 1$1!111n\'OI. •w~st'l.l~!Pl!"IIPJOH) 8£fil:I.Ji!d bt/st!.."'fl l"!lt 'n.ay i,·91 '11!un Oll •~OISt°lJU!Pf.n81aJ.1>Jf) llf P>J•d l ~Jn<J, "A.ow rzt 'nivn not "q-it PaJPIIIS /n 11111\fWMl.l) Z 1-':>JBd IW/nCJt'AnYl'•~n gs-'~U p~lrg/U~J) l l•>J•d ON3931 [ 0 D September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 16 of 43 I I // Figure 4. Southern boundary of Site M along Ho'ohana St, view to the southwest. Figure 5. Eastern boundary of Site M., view to the east. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 17 of43 Figure 6. Boundary of Site M along the North golf course, view to the northeast. Figure 7. Western boundary of Site M along N. Kaniku Street, view to the south. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 18 of 43 Figure 8. Overview of the southern portion of Site M, view to the east. Figure 9. Overview of the northern portion of Site M, view to the south. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 19 of 43 Figure 10. Access road along the northern boundary of Site M, view to the east. Figure 11. Example of bulldozer disturbance within Site M, view to the southeast. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 20 of 43 N A Kapunlau Point D Project Arca 0 0.75 Kilometers 1.5 Figure 12. Geology within the project area. [::J'Project Area IO • Lava flows, ·a· a. 2 lo 20 percent slopes 20 -Beaches. 0 10 6 percent slopes 310 -Am\·ai.:ikealn1:i extremely cobbly silt loam. 2 ro 10 percent slopes 312 -li'l\·a flows-Auwaiakeak"\la co111plex. 2 to 20 perce.111 slopes 316 -LaYa tlows-Kiholo complex. 2 to 20 percent slopes 336 -Punko fine sandy torim. 0 to 6 pen:e.111 slopes 352 -Lava nows-NanuJ...1.1 complex. 2 to 20 percen1 slopes 373 -Hapuua-W,1il,.,,.1i-Lalam.ilo complex, 0 ro 20 percent slopes \V -\Va1er AFFILIATES AFFILIATES 150 Mrtcrs 300 Sm! SttrVC) Staff.1\'atuml Rc-.ourccs (\i11s..:-rvatm11 S1..•r\icc, Cn1lt:l St:.ih:~ Department ofAgm:ultun: S111l Surn-~ Gt>og.raplm: {S~L-RGOJ DatabJ::.c A\'mlnblc-onlwe ,11 h11ps:11::;dmclutaac:cess.sc.1:go\.l1Sda.gov . .,\ci.:cs~t;>d6·27 2025 Figure 13. Soils within the project area. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 21 of 43 0 no/a, 300 Km I I N A c::J Pn~jccL Arca LJ Burgett et. al 1999 LJ Jensen 1989 c::J Kirchl979 Wolforth 2005 ~ \Vol forth and Huber 2007 LJ Rosendahl 2000 r.-.i Puoko Petroglyph ~ Archaeological Dis.trier .. . .,.. ------AFFILIATES HAWAII COUNTY 400 APRX; 4845U \'1:.mn.il.ani l.iyout. lnvestig;:itions Figure 14. Previous Archaeology in the vicinity ofMauna Lani Mauna Lani Site M. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 22 of 43 LU 0 0 0 ..-0 g N N 400: 0 ~ 800 Px = Pahoehoe excavation M □ = ModWe□ ou lcrop Cs = C-Stlape Ao = Abrader 1Jasi11 g .(Q 0 ~ V = non sile cave \ = Tra tl segmeoL T# = Tempornry # ti#, ## = SIHP 0 0 .. ~ --- --------24437 J 200 meters c:f7=compl!?.x Figure 15. Site Distribution within Mauna Lani Site M from Wolforth and Huber (2007). Note that Site 24437 should read as 24427. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 23 of 43 N A 0 c:] Pn~jcct Arca -Site Boundary Figure 16. Site Distribution from the current study. N A September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 24 of 43 0 300 Km I I I f f N A c:J Project Area -Site Boundary /',lctcn; 2-10 Figure 17. Site Distribution within the proposed Mauna Lani Site M conceptual plan. AFFILIATES September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 25 of 43 Appendix A LJNDA!l..lKGLE ~r..Or'JU1Wt1,U •~.:-~ l . ' ~ ... -~ ST ATE OF HA WAil U.llli H. THlE-L'EN -~gf~~~T\RAL.~~ ~OJiii ..... ,~Mil.II~ RUi5EU. l'~ IliWI f11.§.UiPt.rT'f llU(' MWJIIIAK,\ CQl".,IW~'"TQl~Wl,l!C! ---=-11111,'J?>KiMDQ:~IUCQl,n:N DEPARTMENT OF LAND AND NATURAL RESOURCF.S STATEHJSTORICPRESERVAT!ON Dl\l'IS,ION July 13, 2008 Robert Spears, Ph.D Scientific Consultant Services, Inc. 711 Kapiolani Blvd., Suite 975 Honollllu, In 96813 601 !<k\!.OKILA OO!JliVA.RD,R00'.\1 55:i KAl'OI.E'.1, tlA W Al1 96707 SUJUEC.: Chapter •6E-42 Historic Preservaticm lteview - -"'--~l;f..M!Qtip.l'ilfoID~-.w.'AGliMPl'I OOMUJilVA'IXN #04!i-00.IST.-J. L>J(_'D5, ca:.m:Jt'i,",ltnl.v.'Cl'~Olllal~ ~ JltlllS'n!YolOID-1,1,'RJJU:fil IDS~•~A.'Jl.QNI ~w.t13W-'1>il.e!B.'II!! CONMt:!:50'1! """' ~,J.J.K.S LOG NO: 2007 .0:569 DOC NO: 0807MD22 Archaeology ~cb.aeologial h!v(!Jltory Survey of a 150-acr-e area with eight (8) new sit~ Waikoloa Ahupua • a, Sou.th Kohala District, Island of Hawaf i TMK: (3) 6-8--001:054 ud (3) 6-8-022:010 This le:tter reviews the revised report ~bmitted lo us in F¢bn!ary 2007 (Woiforth and Huber 2007; An lnvenlory Survey far Site M in Mauna Lani: lnvestigacion imo Resource Exploitation Patterns in the Lower Elevations of the Kaniku Flow in Waikofoa Ahup!/Q 'a, S0111h Koh.ala Distric(, Hawai 'i Island, ffm,w;i'i. /TMK: 3·6-li·l:54 and 3·6-8·22:IOJ; SCS Report 514-2). We apologize for the dclay m our reply. The survey idartilled eight (S) Sitell al this locat~oo (Sites 2442.5 [Pahoehoe e,wavatioosl), 24426 [modified outcrop], 24427 [trail segment], 24428 and 24429 C-shaptd structures], 24430 and 24431 [abrader basins]. and 24432 [ccmplex]). All are consid.ered sigptificant under criterion 'd' .md we concur wilh this assessment. We also concur with your ~ecomrnendation that your work documentmg these fo111r Silts is sufficient and no farthe, wo,k is required. Tbt raport is therefore aa;:epted pursuant to §13-276 of the Hawaii Administrative Rules. If you have: any qmtstions about this letter please oontact Morgan Davis at ou. Hawaii Island office at (808) 981-2979 Aloha, !Jigitally signed by ?'L .. t} ~,,/4.,...NancyA.McMahon 1 ~ Dat~; 2008.07.13 • 1 16:54:44 -10'00' Nancy McMah.on, Archaeology and Historic Preservation Manager State Historic Presesva.tiQn Divi~ion September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 26 of 43 LOIDA LINCI.E lllJVEJ.},1)J;,(11H!l'N"Ji.ll STATEOFHAWAH DEPARTMENT OF LA!'fl!) AM), NATURAL RESOURCES STATE HISTORIC PRllS.ERVAilO:N DTVISJON 601 KAMO:K!l..A BOIJLEVARD.ROOM 555 September 10, 2008 Christopher Yuen,, Planning Director Attn: Rodney Watanabe County of Hawaii Planning Department IOI Pammi Street, Suite 3 Hilo, Hawai'i 96720-4224 • Dear Mr. Yuen: KAPOLEl, HAWAII %707 SUB.JECT: Chapte.-6E4l 1Ilsto.-k Pl"fl5e.-v.dion Review - '-"UMH.ffl)D.l!N ............ ~OFW'O~~n,-.u.~ ~IDMll·Ott •.-.TD~tag:w...:w~ ,!1-U$5.ELL V. 'rSWI ,Wl'~ l'IIC',K,i.'W.IJl~jtli, l!Elt1T'Ytllm:J1!Jl.",'{,1.'ll!JI "']Ull.Tl!:~ IKli'ini+:IAMtl«!A:M IIECJ1.l.f'all ,Kl!P'.lJ i;ir~~ OiM..~CW•'im.~~ iXl!Wb'A1'itltNlO~T.-J.~S ~'l,·,li.~',l,,h"1)~~ ~G ~Zl1YNa:1.-n.Dl.ml lu.noa:;~WA_Tmtl v.a::ic::c.A"'lftmMm<~~1~JJ[w .....,, JV,0::11'.IAD LOG NO: 2008 .4079 DOC 0: 0809TDI 7 Archaeology Special l\1anagem.ent Area Pernt.lt Application ,(SMA 07..(100019) fo.-Hotel, Residential .and Gelf Course Devefopm.ent (Stanford Carr Develapmeot, LLC) Waiko)ea Ahupua'a, South Kohal11 Dbtrict, h1aod of Hawai'i IMK: {3) 6;-8,J: 54 and 6-8-22: 10 Thank you for providing Lis a copy of the Hawai'i County Planning Coromi~sion letter to Steven S :C. Lim, Esq. dated September 4, 2008, which approves the subject MA. pennit application. We would like ro clarify information presented in the letter regarding: historic preservation (eview of this project The fifth pllir.lgrapb on page 4 of ili.e letter states ihat the archaeological inventory survey report for th_is project (\Volforth and Huber 2007) has not yet b«n. approved by the DLNR-HPD-The sul\>ject repon has been reviewed by our office and was approved in July 2008 (log No. 2007.0569, Doc o. 0807MD22). Th~ inventory survey for this project identified eight hisl:oric properties, all of which were detennmed to be significant under HAR criterion "d'', for information value. We co.ncwred \.\1th these assessments and with the findings of I.he report that DO further archaeological data c-0lkction was needed as. a mitigation ineasuce. We believe that no hlstorit properties will be affected by this proposed activity bec.iuse: D Previous grubbing/grading has altered the land D An .accepted archaei;ilogical inventory survey (AIS) found no historic properties [:El SHPD previo1;1sly reviewed this project and mitigation has been completed In the event that historic resources, including hl!l11'.Wl skeletal remains, lava tubes, and lava blis,tersJbubbles are identified dwing the construction activities, a]l work should cease m the immediate vicinity of fue find, the find should be protected from additional disturbance, and lhe State Historic Preservation Divisi.on, Hawaii Wand Sc:ction, should be e-0ntacted immediately at (808) 981-2979 , Pl.ease contact Theresa K.. Donhaim at (808) 981-2979 if you have .my questions or conccms regarding lhls letter. Aloha, -~t?;?J!~ak- Nancy McMahon, Deputy SHPO/State Al:chaeoJogist And Historic Preservadon Manager State Historic Preservation Division September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 27 of 43 fM.\'1fl -tGt: <llW'lj~~~.,,il\}1 STATE OFHAWAl1 DEPAR'fl\lE ;J Of LAND AND ArtJIRAL RESOURCES October 5, 20 l 5 Dueno Kenul>e, Pl;uming Dirccwr ,Cc,unty offfirweii lO I Pauahi Stree1 S·uite 3 : Hilo, H.l 96 720 (p;la1:U1inSIIDhawaiicou.!1ty.sm·) o~ar Mr. Kanuha: STATE HIS'roruCT-!l.E:!iERVATION DfV.ISION KAKUH!HEWA El!JILDIING 601 KAMOKJLA BL \ID, S'H 555 KM-'OLE:I, IIAWAII %?01 SUBJECT; Chapter 6,E-42 Hiislork rreserv111.ion Review Coull1l' of lhlwa.i' i Grubbing Perm ii for Site M /\511ociates Wtiko!Cla A upmil'a, South Ko.bala District,Jsland or lbwai'I TMK; (J J 6·8--00 I :t54 :5-Ul.L\"NE D.CA.U .,., .. .,.""" IICWJJ~Of"LJ.M)AKtl>l>l.11..'bU.ll5CIUlC!J ~04-A.tla-ADGUID:~ JU'llif'I' T.,PE'J[fliON ct~co.£C11ll:-W.d1:ll LOG NO: 2.015.03240 DOC NO: l.5IOSN02 Archaeology Th.is grading p,ermil application W1IS rccei,vcd by our Hilo offrcc on Scptomb,cr 2, 201S, on behalfofthe lend owner Si1e M A.s~i•tc5, v,i11 $~for,;! C~rr-The 11ppl iCIIJ'\t :proposes gn,bbi ng oftl'.le entit'(l I 00. 7'J7-aae l)ateel, A reviev.· of,our records indicet"'1 lhet there has been 11□ archaeological invemory SllTlley (AIS) conr1p,lc:t~ for this parcel. The rcp,o.rt was rcvf~wed ancl accepted by SHPD in Jul)',2008 (Log o, 2007.0S-69, Doc. No. OS07MD22). The sillVe)I identified two historic propenies wilillin lhe aforeitu:ntioned parcel; a piihoehoe·ei.:cavation pit (Site 24426) 1111d a lrail segment (S ite 24427). TnClie sites were assessed a~ being slg,nif'iea~t under Hawllii Adm i r1is1rn1ivc Rutcs (HAR)§ 13-2!6-4, criterion "d~ !IB,;I rwommcnded for no furmer work. Tiie parcel has been subjecr to a previous SMA review by our offic,, and it hes been determined toot the mitigation for the proposed project has been completed (Log No .. 2008.4079, Doc. No, 0309TDI 7}. Therdare, based an current information, SHl>O'~ decerminaM.□ is no historic proptrti.es 11rT\!ded. I u11nee or fll.e permil for libt grubbing adiviti.es ma,, r1rotced. ' • , In lhe unlikely event lhat historic pmpmie,; su:cl:i es lava tube Op<'rtings, conoontrations of artifacts, stru.ct11u-al remains or· !luman skeletal remains are found d,uti ng oonslrnction .retivilies plei!1$c . .:,case worl< in the i mmcdiale vicinicy oftlie tind, prole:ct die findl from additional di~u.rbance, and contact the Slate Histqr(c Preservation Di11ision al (&08} 933-7651. Aloha, ~.....,.,.A .~ Susan A. Lebc,, PhD Archaeology Branch Chief cc. Site M Associates, I.LC l lOO Alakea SI. Suire 27•>1 Hooolulu, HI 96813 Attn. SmnfoJd Carr Pa:ul Mat~1,1da Group 70 lntematf:o.nar ~25 Be1hel Street Fiftb Floo UollOIUIU, H1 96813 September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 28 of 43 AppendixB Summaries of the original site descriptions for the historic properties located within Site M are presented below (Wolforth and Huber 2007), followed by an assessment of their current condition based on the recent field inspection. Site 50-10-11-24425: Pahoehoe Excavations Wolforth and Huber (2007:33) describe Site 24425 as: Site 24425 is a collection of four features over a 17.0 m by 8.0 m area ... The site is on a flat pahoehoe area, and has two pahoehoe filled cavities (Features 1 and 2) and two pahoehoe excavations (Feature 3 and 4). Feature 1 is small cobbles (less than 10 cm in diameter) filling a small area about 80 cm in diameter. Feature 2 is another small area (about 1.0 m by 0.5 m) of small cobbles that appear to fill and level a portion of the outcrop. Feature 3 is a pahoehoe excavation 57 cm long and 30 cm high prior to removal of the pahoehoe cobbles ... Feature 4 is another pahoehoe excavation about 70 cm in diameter. During the current field inspection, Feature 3 was re-identified, and new GPS locational mapping was conducted (Figure B 1 ). This Feature appeared unchanged from the description and photographic evidence presented by Wolforth and Huber (2007). Figure Bl. Site 24425, Feature 3. View to the south. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page29 of43 Site 50-10-11-24426: Modified Outcrop Site 24426 was originally described by Wolforth and Huber (2007:37-42) as: ... several features within a 10.0 m by 10.0 m area near the eastern boundary of the project area . . . on a 3 .0 m high hill ... There is one particularly prominent natural vertical lava formation on the hill. Cultural modifications are small, scattered about, and are not distinct from the natural outcrops. These cultural modifications were grouped into three features in this analysis. Feature 1 is at the western base of the hill ... There are four culturally used areas: two small pavings, a modified lava blister, and an overhang. The northern paving is 1.0 m by 0.4 m with small cobbles and pebbles. Some of these paving stones are purple, an indication that the surfaces of the stones have been roughed up or otherwise modified. There is an approximately 40 cm by 30 cm abraded surface next to the northern paving. The southern paving is the same size as the northern one, but is less distinctive. The overhang opening is on the western face of the vertical outcrop. The opening is approximately 1.5 m by 0.8 m. There are three small chambers in the interior, with a maximum penetration into the outcrop of 50 cm. All of these chambers are too small for people to enter. A burned piece of wood that appeared to have been placed there was observed within the chamber. Feature 2 is a modified pahoehoe outcrop at the southern boundary of the site. Several cobbles are stacked 70 cm high over a 1. 7 m by 1.2 m base. Feature 3 is a natural vertical. .. outcrop with cobbles apparently stacked over a 2.0-m wide area on the sloping terrain at the northern edge of the outcrop. The function of this site is unclear, but probably related to travel through the area, as opposed to being a place of destination. This natural outcrop with an overhang was modified with pavings and stacking rocks. Some activity resulted in the abraded surface. The tall vertical outcrop probably served as a marker. People passing through the area may have used it as a guide for a pathway. The cultural modifications suggest that people probably stopped at this area for temporary shelter. A single unit within Feature 1 was excavated during the 2007 AIS. No cultural material was observed. All three features were relocated during the current field investigation and appeared to be in similar condition as described in the original site description (Figures B2 through B5). New GPS locational mapping was conducted, and documentary photographs of each feature were captured. Vegetation are the site appeared to be altered slightly, buffel grass was more sparsely distributed and there was an absence ofkiawe trees in the vicinity of the site (when compared to the documentary photographs in the 2007 AIS). This could have been due to a brush fire that occurred between the original and current investigations. Of note, inspection of Features 1 and 3 during the current field inspection indicated that these features appeared more likely to be natural formations rather than historic properties. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 30 of 43 Figure B2. Site 24426, view to the northeast. Figure B3. Site 24426, Feature 1. View to the north. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 31 of 43 Figure B4. Site 24426, Feature 2. View to the west. I Figure B5. Site 24426, Feature 3. View to the southwest. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 32 of 43 Site 50-10-11-24427: Trail Segments Site 24427 was designated by Wolforth and Huber (2007:42-47) as: ... three restricted trail segments in the eastern portion of the project area. Although they do not connect, they are roughly oriented in the same direction, suggesting that they could be part of one pathway. Feature 1 is the northernmost segment, and is approximately 7.0 m long and 2.0 m wide ... Large and small 'a 'a cobbles identify the trail path, and there was a small, possibly stacked group of rocks along the segment. .. Informal probes were made in the trail pathway and at the stacked group, and no cultural materials were observed. Feature 2 is a paved area within an otherwise natural cobble area. This segment is approximately 3.0 m long and 1.0 m wide ... The eastern edge of the probable trail appears to have a low curb. Feature 3 is an approximately 4. 7 m by 1.0 m linear paved area on the ridge of a hilltop ... The paving is small to medium cobbles. Some of the paving stones appear to have been turned over ( or moved), and others are purple, suggesting a roughening of their outer surfaces. These trail segments are restricted trail types on undulating bedrock in the eastern portion of the project area. That area is dominated by smooth pahoehoe. Unrestricted trails probably were situated throughout this area, but those are not identifiable on the ground surface. Portions of trails situated over rougher terrain were modified by creating smoother, paved areas, and these restricted trail styles are observable on the ground surface as the three features of this trail site. All three features (Figures B6 through B8) were relocated during the current field inspection; however, these features appear to be formed by natural deposition rather than possible trail segments as the deposition of 'a'a in these areas is non-distinct from the surrounding landscape. Features 1 and 3 appear consistent to the descriptions and documentary photographs presented in the 2007 AIS but the central portion of Feature 2 appears to have been disturbed sometime after 2007 (see Figure B7). Photographs and updated GPS points were taken at each feature during the current field inspection. Figure B6. Site 24427, Feature 1. View to the east. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 33 of 43 Figure B7. Site 24427, possible Feature 2. View to the north. Figure B8. Site 24427, Feature 3. View to the southeast. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 34 of 43 Site 50-10-11-24428: C-Shaped Structure Site 24428 has been classified by Wolforth and Huber (2007:47) as: ... three features over a 7.0 m by 4.0 m area on top a hill in the southwest, grassy and rolling pahoehoe portion of the project area ... Feature 1 is a medium to large cobble stacking in a curved C-shaped structure 2.2 m long by 1.1 m wide, and 80 cm high. Feature 2 is a small (0.8 m by 1.0 m) 'a 'a paving. Feature 3 is several flat pahoehoe stones arranged as an apparent pathway on the slope. The function of this small group of features is probably related to their positioning on the 4.0-m high hilltop. There is a grand 360 degree vista from this location. The sparse modifications, and lack of material remains suggests that temporary shelter may have been taken here by people passing through. There is no potential for subsurface deposits; most of the ground surface is bedrock. The C-shaped structure (Figure B9) was relocated during the current field inspection and appears to be in similar condition as was described by Wolforth and Huber (2007). Updated photographs and GPS locational data were acquired during the recent field inspection. While it's possible this location was utilized as temporary habitation, the features appear more likely to have been natural formations than constructions. Figure B9. Site 24428, Feature 1. View to the southeast. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 35 of 43 Site 50-10-11-24429: C-Shaped Structure Wolforth and Huber (2007:47) designated Site 24429 as: ... an 8.1 m by 2.8 m, and 60 cm high C-shaped structure ... There are two small areas of fill creating level areas on the bedrock and stacking. The fill is small cobbles ( < 10 cm) with some purple (roughened) surfaces. This is probably a temporary shelter associated with activities that took place at nearby sites. There is no potential for subsurface deposits; most of the ground surface is bedrock. The C-shaped structure (Figure B 10) was relocated and appears to be in similar condition as was described by Wolforth and Huber (2007). While it's possible this location was utilized as temporary habitation, the feature appears more likely to have been formed naturally than constructed. Figure B 10. Site 24429, view to the north. Site 50-10-11-24430: Abrader Basins Wolforth and Huber (2007:47) described Site 23330 as: ... three abrader basins ... Each abraded area ... is shallow and amorphous (Figure 26), suggesting that these areas were used for only a short period. They are situated on the smoothest natural surfaces available in the vicinity. There are some darker areas on the smooth pahoehoe that might represent the very earliest stages of abrasion, but they are too indistinct to declare them abrader basin features. These features were reidentified and photographed during the current field inspection and new GPS positional data was captured at each feature (Figures Bl 1 and B12). The features appear unaltered from the state in which they were described above. Interestingly, though three features were recorded as part of Site 24430, this area of Site M is replete with abrader basins. During the recent field inspection, numerous additional abrader basins were observed in close proximity to the three features that comprise Site 24430. It is unclear why the other abrader basins were not discussed or included as part of the site during the 2007 AIS. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 36 of 43 Figure B 11. Site 24430, Features 1 and 2, view to the north. Figure B12. Site 24430, Feature 3. View to the west. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 37 of 43 Site 50-10-11-24431: Abrader Basins Wolforth and Huber (2007:52) describe Site 24431 as: ... three abrader basins on a pahoehoe prominence surrounded by 'a 'a ... There are slight grooves in the basins ... A small portion of the surface of the pahoehoe has been removed, possibly as a test of the lava content below the surface. The large pahoehoe prominence (Figure B13) was relocated and appears to be in similar condition as was described by Wolforth and Huber (2007). Updated photographs and GPS locational data were acquired during the recent field inspection. Figure B13. Site 24431, view to the west. Site 50-10-11-24432: Site Complex Site 24432 is described as comprised of, "15 features situated over 400.0 m by 100.0 m area in the Kanikii 'a 'a located in the southwest portion of the project area" (Wolforth and Huber 2007:54). The site and component features were revisited during the current field inspection (Figures B 14and B 15). The condition of the features were reassessed and updated GPS data and documentary photographs were captured. An update on each of the features, or grouping of features, are provided below the original feature descriptions from the 2007 AIS. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 38 of 43 Figure B 14. Overview of the northern portion of Site 24432. View to the east. Figure B 15. Overview of the southern portion of Site 24432 with Feature 9 in the background. View to the south. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page39 of43 Feature 1 is described by Wolforth and Huber (2007) as a restricted trail network in the 'a'ii The trail is distinguished from the surrounding natural lava flow by the purple color of the "paving" stones in the pathway (Figure 30). The trail cobbles are small, from 1 cm to 15 cm, with the mode size approximately 10 cm. The purple color may be the result of roughening of the cobble surface (Wolforth and Wilson 2004). Trail edges blend into natural lava, and it is difficult to discern the pathway in many places, but the average width of the trail pathway is approximately 50 cm. Even with a close up view, the trail can be difficult to see (Figure 31), but the presence of the purple (altered) rocks in a linear orientation over a long area does attest to their representing a trail, and not a natural phenomenon. The trail is well-defined in the west portion of the site near Feature 2. Purple paving stones are 4 cm to 15 cm and the pathway is fairly level. Larger cobbles, from 30 cm to 60 cm, are in the pathway near Feature 2, and these look like stepping stones. The trail is less distinct to the north and east of Feature 2. There is no distinct trail in the central portion of the site. This area corresponds to the concentration of pahoehoe excavation and 'a' a excavation features ... Further to the east, the trail is more distinct, especially in the area near Feature 11, a trail marker. To the west of Feature 11 there are purple cobbles in the pathway, and larger flat slabs that appear to be stepping stones. The pathway is well defined to the east of Feature 11 ( see Figure 30), but becomes indistinct with proximity to the grassy, pahoehoe flow. A bulldozer two-track path passes near the trail (Wolforth and Huber 2007:54-56). The 24432 Site map generated by Wolforth and Huber (2007) was utilized during the recent field inspection to discern the trail system; however, as stated above, much of what was designated as a trail appeared consistent with the surrounding landscape. Given the number of features in this area, it is likely that a trail or network of trails were utilized to access the pahoehoe and 'a'a excavations and abrader basins, but no clear system was apparent during the current study. Features 2, 7, and 8 are listed as platforms (Wolforth and Huber 2007): Feature 2 is a two tiered sunken platform ... A natural depression has been modified with stacked and faced lining that create segregated spaces within a roughly rectangular 3 .8 m by 2.1 m space. The northern area is the largest component, and the paved floor of this area is 60 cm below the outer edge of the feature ... The southern division is smaller, and the floor is not level. A majority of the cobbles used in construction and found associated with the feature are the overturned and roughened purple cobbles similar to those in the trail pathway (Wolforth and Huber 2007:57). Feature 7 is a 7.3 m by 4.0 m platform situated in a small canyon-like area between two ridges ... The eastern edge abuts the sloping hillside, and the western edge is approximately 50 centimeter above ground level. Small cobbles less than 15 cm in diameter pave most of the surface of the feature (Wolforth and Huber 2007:61). There is a pahoehoe slab set on its edge within a small platform situated next to trail Feature 1 ... The 20-cm high platform is about 1.5 m diameter and is paved with purple cobbles. The western edge is faced. The thin slab protrudes 46 cm above the platform (W olforth and Huber 2007:67). All three platform features (Features 2, 7 and 11) were subjected to excavation during the 2007 AIS (Wolforth and Huber 2007). Test unit(s) were placed in each of the features; with the exception of a single waterworn stone found at Feature 2, no cultural material was observed and cultural modifications to the platforms appeared slight. During the current field investigation, the platforms were relocated and appeared to be in similar condition to the post-excavation state as described in Wolforth and Huber (2007). September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 40 of 43 Several pahoehoe (Features 3, 4, 5, and 6) and 'a'a excavations (Features 8, 9, 10, 14, and 15) were recorded as features throughout the Site 24432 complex: There are four pahoehoe excavations in the western portion of the site near Feature 2 ... These are relatively deep pahoehoe excavations ... Rocks taken from the features have been turned over and placed, or left, around the rim of the features (Wolforth and Huber 2007:61). There are five places in the 'a'a where cavities have been created ... These are unlike pahoehoe excavations that are on relatively level ground, and have blocky rocks turned over around the rim of the excavated areas. In contrast, these excavations in the 'a'a are oriented vertically, and are situated on the sides of relatively steep slopes. They are characterized by clearly bashed areas in the slope side, and debris fields are relatively small pieces of a 'a (less than 10 cm) downslope from the excavated area. The excavated areas range from barely perceptible to distinct... Along each of the five 'a'a excavation areas, there is a range from vague to distinct manifestations. These feature areas appear to represent extraction of a sought after resource: porous, gravely 'a'a. There is olivine in this source, and perhaps this is a source of scoriaceous abrader material common in fishing related sites along the nearby coast (Kirch 1979). Alternatively, or in addition, this light weight, porous 'a 'a might have been used as net sinker material, supplying enough weight to sink the net, but not so heavy as to preclude carrying and use (Hiroa 1957:344; Wolforth and Huber 2007:64). The pahoehoe and 'a'a excavations were relocated during the current study and were observed to be unaltered from the state in which they were described above (see Figures B15 and B16). Figure B16. Site 24432, Feature 14. View to the south. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 41 of 43 Wolforth and Huber (2007) recorded Feature 12 is a modified cave entrance: ... Trail Feature 1 is nearby. The opening is a vertical shaft that is about 30 cm diameter. The surface of the cave has been built up and modified. Attempts were made to enter the cave, however it was impassable to humans. A visual inspection of the cave interior revealed that it was very small and continued on only 2.0 min each direction before constriction to less than 30 cm. No cultural materials were recovered. Although no cultural material was observed, the modifications at the opening indicate that some cultural activity once took place here. How that activity related to the nearby trail is unclear. Items may have been stored, and perhaps temporarily sealed within, this small cave (Wolforth and Huber 2007:69). Feature 12 was reidentified and reassessed and updated GPS data and documentary photographs were captured (Figure B 17). The condition and surrounding landscape appeared consistent to the description provided in Wolforth and Huber (2007). Figure Bl 7. Site 24432, Feature 12. View to the east. Feature 13 is a C-shaped structure are the eastern end of Site 24432: ... a 2.5 m long, 1.0 m wide, and 60 cm high c-shaped structure ... at the east end of the site. The feature is situated on smooth pahoehoe outcrop ... There are no artifacts and no soil deposits directly associated with this feature. A small portion of this feature was deconstructed to check to see if there was a crevice that was covered by the construction. None was observed; the feature was built entirely on the smooth pahoehoe bedrock (Wolforth and Huber 2007:70). September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 42 of 43 Feature 13 was reidentified and reassessed and updated GPS data and documentary photographs were captured (Figure B 18). The condition and surrounding landscape appeared consistent to the description provided in Wolforth and Huber (2007). Figure B18. Site 24432, Feature 13. View to the east. Caves Wolforth and Huber (2007:32) observed six cave openings around the project area. Every cave opening was inspected by traveling through all passageways until they became 30 centimeters wide or high, precluding further passage. Each cave was mapped, and in one case, a test excavation was conducted within the cave soils. No cultural material was observed in any cave, or in the excavated area. Consequently, these caves were not interpreted as archaeological sites. Figure B19 presents an example of one of the cave openings (T-2) recorded by Wolforth and Huber (2007). The cave openings were relocated and reinspected during the current field investigation and the original findings were confirmed; no cultural material of any kind was located within the mouths of the cave openings. The current investigators did not travel through the caves to a depth of 30 centimeters. September 3, 2025 ASM Affiliates-Mauna Lani Site M LRFI Page 43 of 43 Figure B19. Example ofa non-site cave (T-2) within the proposed project area, view to the west. APPENDIXG ASM Affiliates. Archeological Field Inspection of Proposed Mauna Lani Site M Emergency Access Road AFFILIATES _.a\.rchaeology Hfa:tory Amhropology Architecmral H.i~iory December 30, 2025 Keala Cheng Wilson Okamoto Corp. 1907 S. Beretania St., Suite 400 Honolulu, HI 96826 Email: Subject: Dear Keala: via email An Archaeological Field Inspection of Proposed Alignments for a Mauna Lani Site M Emergency/Construction Access Road across portions of TMKs: (3) 6-8-001:050, 052, 053, and 055, Waikoloa Ahupua'a, South Kohala, Island ofHawai'i. As requested by Wilson Okamoto Corp. on behalf of DHL Mahi Propco LLC (the landowner), ASM Affiliates (ASM) conducted an archaeological field inspection (AFI) of three proposed alignments (routes) for a Mauna Lani Site M Emergency/Construction Access Road across portions of Tax Map Keys (TMKs): (3) 6-8-001: 050, 052, 053, and 055 in Waikoloa Ahupua'a, South Kohala District, Island of Hawai'i (Figures 1 through 3). The proposed roadway would extend from Ho'ohana Street (TMK: (3) 6-8-001 :053) within the Mauna Lani Resort, across portions of TMKs: (3) 6-8-001:050 and 052, to Queen Ka'ahumanu Highway in the vicinity of the South Kohala Fire Station, which is located adjacent to the highway right- of-way on TMK: (3) 6-8-001 :055 (Figures 4 through 6). The purpose of the proposed roadway is to provide an additional emergency access/evacuation route for the resort area in the event one is needed, as well as to provide easier access for construction equipment to Site M within the Mauna Lani Resort. This AFI was conducted to determine if any historic properties are present within or nearby the proposed roadway routes and to provide recommendations regarding the Hawai'i Revised Statutes (HRS) Chapter 6E historic preservation review process of Department of Land and Natural Resources-State Historic Preservation Division (DLNR-SHPD) as it relates to permitting for the proposed project. The archaeological survey area for the field inspection covered a larger area than the construction of the proposed roadway will ultimately require, encompassing a total area of roughly 40 acres (see Figure 6). The wider survey was undertaken in an effort to identify any potential archaeological concerns or constraints that could limit the feasibility of the alternative routes under consideration, and to provide recommendations regarding which route(s) may be preferable from a historic preservation standpoint. This letter report provides a description of the proposed project and the project area, presents a summary of prior archaeological work conducted in the vicinity of the project area, describes the methods and results of the field inspections, and provides historic preservation review recommendations for the planning of the proposed roadway. Description of the Proposed Project and Project Area The proposed project consists of the construction of anapproximately 4-meter (12-foot)-wide roadway and between Ho'ohana Street and Queen Ka'ahumanu Highway within Waikoloa Ahupua'a, South Kohala District, Island of Hawai'i (see Figures 1 through 6). Three alternative alignments are currently under consideration. The length of the road varies between proposed routes; Routes 1 and 2 are more direct and roughly the same length, approximately 976-meter (3,200-foot)-long, and 938-meter (3,080-foot)-long, respectively, while Route 3 is longer and more circuitous, approximately 1260-meter (4,130-foot)-long. The project area is situated south of the town of Puak6 and northeast of the Mauna Lani Resort, roughly 1.93 kilometers (1.2 miles) inland from the coast at Paniau Bay. The proposed roadway will extend from an elevation of approximately 17 meters (55 feet) above mean sea level (amsl) at Ho'ohana Street to an 820 Mililani Street, Suite 700, Honol'ulu, Hawaii 96813 (808) 439-8089 Fax: (808) 439-8087 507 A East Lanikaula Street, Hilo, Hawaii 96720 (808) 969-6066 Fax.: (808) 443-0065 www.asmafflliates.com December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page2 of24 elevation of approximately 40 meters (170 feet) amsl near Queen Ka'ahumanu Highway. Geologically, the makai (western) portion of the project area is situated on mixed 'a'a and pahoehoe lava flows ofKa'u Basalt (labeled "Qkly" in Figure 7) that originated from Mauna Loa 3,000 to 5,000 years before present (B.P.) (Sherrod et al. 2007). This Mauna Loa flow is referred to on more recent geological maps prepared by (Trusdell and Lockwood 2024) as the "Kanimoe flow." The mauka (eastern) portion of the project area is situated on two different flows; the northeastern portion is situated on a much older substrate (labeled "Qhm" in Figure 7) consisting of weathered 'a'a lava flows of the Hamakua Volcanics series that originated from Mauna Kea 64,000 to 300,000 years B.P., while the southeastern portion is situated on newer, less- weathered 'a'a lava flows of the Laupahoehoe Volcanics series that originated from Mauna Kea 11,000 to 64,000-years B.P. (labeled "Ql" in Figure 7; Sherrod et al. 2007). Soils that have developed on the Kanimoe lava flow are classified as Puako fine sandy loam (labeled "336" in Figure 8), while those that have developed on the older Mauna Kea lava flow are classified as belonging to the Hapuna-Waikui-Lalamilo complex (labeled "373" in Figure 8; Soil Survey Staff2024). The more recent 'a'a flow in the southeastern portion of the project area is classified as Lava flows-Nanuku Complex (labeled "352" in Figure 8). Vegetation within the project area consists of a secondary growth of fire resistant plant species limited primarily to buffelgrass (Cenchrus ciliaris) and kiawe trees (Neltuma pallida) with a few isolated coconut palms ( Cocos nucifera; Figures 9 and 10). This vegetation is indicative of prior ground disturbance, and the presence of burned tree stumps indicates that the area has burned in recent years. The lands surrounding the entire project area have experienced substantial prior ground disturbance as exhibited by the presence of bulldozer tracks on bedrock surfaces, bulldozed roads, push piles of both plant material and rock/soil material, and dumped piles of construction materials found throughout (Figures 11 and 12). Much of this ground disturbance appears to have occurred during the 1990s to early 2000s when the Mauna Lani Resort and the existing wastewater treatment plant (WWTP), holding ponds (Figure 13), and fire station (Figure 14) located along the southern edge of the project area were built, however some disturbance could be related to wild fire suppression activities which, based on the number of burned trees within the project area (Figure 15), have occurred relatively recently. Several existing gravel and dirt roads, portions of which will be incorporated into the proposed Mauna Lani Site M Emergency/Construction Access Road, currently cross the project area. The most well-maintained of these roads are associated with an existing easement for overhead electrical lines and a waterline that runs along the southern edge of the archaeological survey area for the proposed project (Figure 16). Prior Archaeological Research Conducted in the Vicinity of the Project Area Prior archaeological research in the vicinity of the current project area has occurred primarily in conjunction with proposed development projects in an effort to satisfy historic preservation review. Portions of the current project area were included in archaeological studies conducted during the 1970s as part of the development of Queen Ka'ahumanu Highway and the Mauna Lani Resort (Ching 1971; Kirch 1979; Rosendahl 1972). Those studies included large areas ofland and recorded hundreds of archaeological sites but did not report any findings within the current project area. Subsequent studies of smaller parcels within the Mauna Lani Resort property (within the area surveyed by Kirch 1979) have shown that many archaeological sites were not documented as part of those early studies, especially at inland locations. The early research conducted by the Bishop Museum focused largely on the coastal portions of the development area where the most substantial sites related to Hawaiian land use were once located. More recent archaeological studies conducted adjacent to the current project area have identified historic properties at proximate inland areas, but have also demonstrated that the sites in this area tend to be more widely scattered across the landscape (than they are at the coast), and that the site types are largely related to travel through the area and the extraction of locally available lithic resources. Recent studies (see below) have also noted the prevalence of prior ground disturbance in the vicinity of the current project area, and in some cases have attributed the lack of identifiable archaeological sites in the area to that prior disturbance. Archaeological studies in the vicinity of the current project area began with the surface survey of Section III of the Kailua-Kawaihae road corridor conducted by Ching (1971). This survey, conducted prior to the construction of Ka'ahumanu Highway (Highway 19), extended south from Lalamilo Ahupua'a to December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page3 of24 Hamanamana Ahupua'a (in the district of North Kona), and included a strip ofland within TMK: (3) 6-8- 001 :055 of the current project area (the South Kohala Fire Station Parcel). Ching (1971) identified numerous features within the Waikoloa portion of the road survey corridor that were individually assigned Statewide Inventory of Historic Places (SIHP) site numbers. The documented features included linear shelters, hunting blinds, enclosures, ahu (cairn), retaining walls, and platforms. No detailed recording of these features was conducted as part of the Ching (1971) surface survey, but brief descriptions of some of the features were presented in table form in that report. None of the features documented by Ching (1971) were located within the current project area. Following the completion of the Ching (1971) surface survey, the Bishop Museum (Rosendahl 1972) undertook archaeological salvage excavations at selected sites within the final alignment of the Kailua- Kawaihae road corridor. During the salvage work, Rosendahl (1972) investigated 26 features within Waikoloa Ahupua'a in the vicinity of the current project area including 11 that were previously recorded by Ching (1971) and 15 that were newly identified (and assigned individual SIHP site numbers) during the salvage work. The features investigated by Rosendahl (1972), who assigned new feature types to some of the previously recorded features, included C-shaped shelters, cairns, hunting blinds, walls, a retaining wall, a water-diversion wall, a platform, a possible water diversion wall, and a surface midden with a stone alignment. None of the features documented by Rosendahl (1972) were located within the current project area. Between 1973 and 197 5, prior to the development of the Mauna Lani Resort, the Bishop Museum conducted a series of archaeological investigations within an approximately 3,841-acre area that covered the coastal portions of the ahupua'a of Kalahuipua'a, Waikoloa, and Lalamilo and included the current project area (Kirch 1979). That study, which encompassed all of the lands situated between Puako Beach Drive, the Queen Ka'ahumanu Highway right-of-way, and the southern end of the Waikoloa Resort Property, identified 179 archaeological sites containing a total of 449 features. The documented features included petroglyphs, fishponds, trails, C-shaped structures, U-shaped structures, L-shaped structures, shelter caves, burial caves, storage caves, modified sinks, abrader manufacturing areas, papamu, walls, circular structures, enclosures, platforms, and midden deposits (Kirch 1979). Most of the sites were identified within the coastal portion of the survey area and were interpreted as being associated with the extraction of marine resources from the Kalahuipua 'a fishponds and other nearby anchialine ponds. The entirety of the current project area was included within the Kirch (1979) survey area, but no sites were reported in the vicinity of the currently proposed road alignment. In 2000, prior to the construction a brackish water storage lagoon at the existing Mauna Lani WWTP, Paul H. Rosendahl, Ph.D., Inc. (PHRI) conducted an archaeological field inspection of an area adjacent to the southern edge of the current project area within TMK: (3) 6-8-001 :049 (Rosendahl 2000a). The field inspection covered approximately 5 acres, but no archaeological or historic features of any kind were identified. The letter report noted that, " ... virtually the entire area appeared to have been disturbed by grubbing and ripping at some point in the past, as evidenced by the visible bulldozer scraping and deep scarring of the exposed rock outcroppings." (Rosendahl 2000a:4). The report also noted former irrigation debris and trash were common within the area. Also in 2000, PHRI conducted an archaeological inventory survey (AIS) of a 450-acre portion of TMK: (3) 6-8-001:022 situated to the northwest of the current project area on the opposite side of Ho'ohana Street (Rosendahl 2000b). That survey identified a total of 14 sites with 30 component features including walls, mounds, marine shell concentrations, enclosures, overhangs, a possible cart path, a modified outcrop, and a complex of historic features related to the historic use of the area for commercial sugarcane cultivation and ranching. While the majority of the documented sites and features were situated well to the north of the current project area, one historic wall documented by Rosendahl (2000b) as Site 50-10-11-21975 is shown on the project site maps as extending south from TMK: (3) 6-8-001:022, across Ho'ohana Street, into the current project area. That wall, described by Rosendahl (2000b) as being stacked and core-filled, was interpreted as a historic ranching wall constructed by Parker Ranch to restrict the movement of cattle. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page4 of24 In 2007 Scientific Consulting Services (SCS) conducted an AIS for Site M of the Mauna Lani Resort (TMKs: (3) 6-8-001:054 and 6-8-022:010), encompassing approximately 150 acres located directly to the southwest of the current project area on the opposite side of Ho'ohana Street (Wolforth and Huber 2007). As a result of the survey, eight archaeological sites were identified with feature types that included abrader basins, pahoehoe excavations, caves, platforms, trails, modified outcrops and 'a'a excavations. None of the documented sites were located within close proximity to the current project area. Archaeological Field Inspection: Methods and Results On May 28, 2025, Matthew R. Clark, M.A. (ASM Principal Investigator), S. Steele D. Jaques, M.A. (Senior Archaeologist), and David King, M.Sc., conducted an archaeological field inspection for the proposed project that covered the initial 25-acre archaeological survey area (to include Routes 1 and 2; see Figure 1). The field inspection included a 100% surface survey of the area with the surveyors walking east-west pedestrian transects (spaced at no more than IO-meter intervals) from Ho'ohana Street to Queen Ka'ahumanu Highway and back following the route of the proposed access road. It was found that the route of the proposed roadway generally follows a network of existing gravel roads between Ho'ohana Street to Queen Ka'ahumanu Highway, and that most of the surveyed area had been subject to prior mechanical disturbance. Evidence of this prior disturbance, including bulldozer tracks and scarring, gravel roadways, berms, piles of pushed plant and soil materials, and piles of dumped construction materials, was widespread throughout the survey area, especially within the makai portion corresponding to the younger Mauna Loa lava flows (see Figures 9 and 10). The prior ground disturbance was less evident on the older Mauna Kea lava flows in the mauka portion of the project area near the existing South Kohala Fire Station. In this area, roughly 150 meters makai of the Queen Ka'ahumanu Highway right-of-way, a historic, core-filled, rock wall transects the project area (Figure 17). The wall, which was previously documented to the northwest of the current project area by Rosendahl (2000b) as Site 50-10-11-21975, was the only historic property identified as a result of the archaeological field inspection. Only the northernmost portion of the wall (roughly 1 kilometer in length) was previously documented by Rosendahl (2000b ). Site 50-10-11-21975 crosses the archaeological survey area in a northeasterly-southwesterly direction. The wall is situated entirely within TMK: (3) 6-8-001:052. It begins within the younger of the Mauna Loa 'a'a flows (Figure 18) and extends northwest for a total distance of 1.8 miles (2.85 kilometers) before terminating at the edge of Kamakoa Gulch inland of Puako Bay (Rosendahl 2000b ). The southernmost portion of the wall inspected during the initial field inspection (roughly 350 meters in length) is in good condition, and has similar dimensions to what was previously documented by Rosendahl (2000b) with wall heights ranging from 1 to 1.3 meters and wall widths averaging 70 centimeters (Figures 19 and 20). Minor wall collapse was noted along the portion of Site 50-10-11-21975 within the survey area, along with one major breach (roughly 12 meters in length) where the existing utility easement crosses it approximately 55 meters makai of the existing fire station (Figures 21 and 22). Two other openings in the wall were noted to the north of the survey area where Site 50-10-11-21975 crosses two small drainages (see Figure 17). As discussed by Rosendahl (2000b) the Site 50-10-11-2197 5 wall was likely built during the late nineteenth or early twentieth century by Parker Ranch or the Puako Sugar Plantation to restrict the movement of cattle. The wall was previously assessed as significant under Criterion 'd' for its information potential (Rosendahl 2000b). Subsequent to the May 28, 2025, field inspection, the client requested ASM conduct an additional field inspection of a 15-acre area of TMK (3) 6-8-001 :052, south of the fire station between the Wastewater Treatment Plant and Queen Ka'ahumanu Highway. On November 11, 2025, Matthew R. Clark, M.A., and S. Steele D. Jaques, M.A., conducted an archaeological field inspection for the proposed project that covered the additional 15-acre archaeological survey area (to include Route 3; see Figure 6). The field inspection included a 100% surface survey of the area with the surveyors walking east-west pedestrian transects (spaced at no more than IO-meter intervals). The area consisted of steep, jagged Mauna Loa 'a'a flows (Figures 23 through 25). Approximately 45 meters south of the main section of wall Site 50-10-11- 21975, three small sections of Site 50-10-11-21975 were observed extending into the rocky outcrop (Figures 26 through 28); the northernmost was approximately 11-meters-long, the second, situated December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 5 of24 approximately 6-meters south of the first, was 5.5-meters-long, and the southernmost section, located approximately 5.5-meters from the second section, was approximately 3.5-meters-long (see Figure 17). No other evidence of the wall or any other historic properties were observed within this section of the proposed project area. Summary and Recommendations As a result of the current field inspection, one previously documented historic property (Site 50-10-11- 21975, a historic ranching wall) was identified within the proposed project area (see Figure 17). The presence of this historic wall within the proposed Route 1 roadway alignment means that the DLNR-SHPD will require ( at a minimum) the preparation of an AIS meeting the standards of Hawai 'i Administrative Rules (HAR) §13-276 as part of the HRS Chapter 6E historic preservation review of permitting for the proposed project. The AIS will need to cover the entire alignment of the roadway and provide detailed documentation of the section of the wall Site 50-10-11-21975 that will be breached by the proposed construction activities. It will also need to include an updated significance assessment and treatment recommendation for the site, so that an appropriate effect determination for the project can be formulated. While it is likely that additional documentation of the site presented in the AIS (and the DLNR-SHPD review and acceptance of the AIS report) will complete the historic preservation review process for the project, it is possible that DLNR-SHPD will request that additional mitigation occur at Site 50-10-11-21975 prior to allowing the wall to be breached. The additional mitigation could take the form of archaeological preservation, archaeological data recovery, or archaeological monitoring. Alternatively, if the eastern section of the proposed roadway could be re-routed to utilize the existing 12- meter (roughly 40-foot)-wide breach in the wall where the existing utility easement crosses it makai of the South Kohala Fire Station (Route 2; see Figure 17), and the wall could be left in place "as is" on either side of the breach, then this field inspection report would likely satisfy the HRS Chapter 6E historic preservation review requirements of the DLNR-SHPD, since no historic properties would be affected by the proposed project. Similarly, if the eastern section of the proposed roadway could entirely circumvent the wall by arcing around to the south (Route 3), and since no historic properties would be affected by this alignment, then this report would likely satisfy the HRS Chapter 6E review requirements of the DLNR-SHPD. Based on the results of the field inspections, we recommend Route 2 or Route 3. Route 2 is the shortest and, given that the majority of the route follows the existing 7.6-meter (25-foot)-wide utility easement, would require the least amount of construction. However, the widening of the easement to accommodate a 12-meter (40-foot)-wide access road has the potential to impact Site 50-10-11-21975 on either side of the existing 12-meter (roughly 40-foot)-wide breach in the wall where it crosses the easement makai of the South Kohala Fire Station. If any potential impacts to the wall in this location can be avoided, Route 2 is recommended. If impacts to the wall in this location cannot be avoided, Route 3 is recommended. Though Route 3 is more circuitous and would entail new construction in an undeveloped section of TMK parcel 052, the proposed alignment of Route 3 avoids Site 50-10-11-21975. In sum, avoiding impacts to the wall would negate the need for additional archaeological documentation of Site 50-10-11-21975 and the project would receive an effect determination of "no historic properties affected" since no other sites or features were identified anywhere else within the archaeological survey area for the proposed roadway, and the likelihood of encountering buried historic properties is extremely remote given the shallow soil in the area and the extent of prior ground disturbance that has occurred. Should you have any questions or concerns, please feel free to contact me directly. Sincerely, ~~ Matthew R. Clark, M.A. Principal Investigator, Director ASM Hilo December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page6 of24 References Cited Ching, F. K. W. 1971 The Archaeology of South Kohala and North Kona: From the ahupua'a ofLalamilo to the ahupua'a ofHamanamana., Surface Survey Kailua-Kawaihae Road Corridor (Section III). Hawaii State Archaeological Journal. Department of Land and Natural Resources, Division of Parks, Outdoor Recreation and Historic Sites, State of Hawaii 71-1. Revised September 1971. Kirch, P. V. 1979 Marine Exploitation in Prehistoric Hawaii: Archaeological Investigations at Kalahuipua'a, Hawai'i Island. Pacific Anthropological Records No. 29. Department of Anthropology, B.P. Bishop Museum, Honolulu. Rosendahl, P. H. 1972 Archaeological Salvage of the Hapuna-Anaehoomalu Section of the Kailua-Kawaihae Road (Queen Kahumanu Highway), Island of Hawaii. Departmental Report Series. Department of Anthropology 72-5. Revised 1972. B. P. Bishop Museum. 2000a Archaeological Field Inspection Brackish Water Storage Lagoon Site Manua Lani Resort. Land ofWaikoloa, South Kohala. 2000b Archaeological Inventory Survey of TMK 6-8-01:22, Land of Waikoloa, South Kohala District, Island of Hawai'i. Paul H. Rosendahl, Ph.D., Inc. 2017-072000. Revised 2000. Prepared for White Sand Beach LP, Tinguely Development, Hilo, HI. Sherrod, D.R., J.M. Sinton, S. E. Watkins, and K. M. Brunt 2007 Geologic Map of the State of Hawai 'i. U.S. Department of the Interior, U.S. Geological Survey. Open-File Report 2007-1089. Electronic document, http://pubs.usgs.gov/of/2007/1089, accessed Apr 27, 2018. Soil Survey Staff (United States Department of Agriculture, Natural Resources Conservation Service) 2024 Web Soil Survey. Electronic document, http://websoilsurvey.nrcs.usda.gov. Trusdell, F. A., and J.P. Lockwood 2024 Geologic Map of the Northwest Flank of Mauna Loa Volcano, Island of Hawai 'i, Hawaii. United States Geological Survey. U.S. Geological Survey Scientific Investigations Map 2932-E. Wolforth, T. R., and S. Huber 2007 An Inventory Survey for Site M in Mauna Lani: Investigation into Resource Exploitation Patterns in the Lower Elevations of the Kanikii Flow in Waikoloa Ahupua'a, South Kohala District, Hawai 'i Island, Hawai 'i, [TMK: 3-6-8-1 :54 and 3-6-8-22: 10]. Scientific Consultant Services, Inc. 514-2. Prepared for Stanford Carr Development, LLC, Honolulu. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 7 of24 Figures Figure 1. Proposed project plans for Route 1. <( ..-w a::: :::i (!) u::: z "' 0 ~ ~ 1 I--CJ) I w CI: 1 u: :5 4l ..: I ; 0 ~ "' :,: -I--c:, ::0 ~ 0 CJ) 0 gJ ..: l'! 0 ·u CI: -,: CJ) >-CJ) Q:: w 1§ u u " ..: 0 z ~ 0 "' F ~ u ::, ~ CI: I--i;, CJ) ,; z 0 :s Q ~ >-u Cl z :i: w <!> CI: w :::; w 0 w (.{) 0 "-0 CI: "- December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 8 of24 Figure 2. Proposed project plans for Route 2. <( z " ~Q ~ w!;;: 1 0::: f- ::i ~ "' (.!) Q; ~ u:: ~ 1 <Ii' <( -1 :c 0 ~ " :c ~ f-::, 0 I:' 'J? oi 0 ~ <( 0 a:: ~ U) en w ~ u u <( z 0 .= u ::, a:: f-U) z 0 ~ u z w (!) a:: w ::;; w D w CJ) 0 0.. 0 a:: 0.. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 9 of24 Figure 3. Proposed project plans for Route 3. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 10 of24 201000 20:!000 N A Area of Detail 0 203000 2()4000 lr----'._,'---1~-ii---/----;,'-ll--j'--,,-"----+-~ .... ,_,_.. 1l •-r "' -r -_, ~l --_G ( C ) "' ;. F-~J---\-----.--------..-£---+----'c------""'--------r=----~~-_,_----/------,,,<-------'----;eeew---+--+=-----'-"',.-=~,,L----+-f--1 ., \ ... s ~~ _ __,,--t :w1000 2021)0{) 203000 20-WOO Figure 4. Survey area location. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 11 of24 N A I lawui'i County Parcels LJ An.:ha~ologic,d !iurvey ar~.i N A )JO -----AFFILIATES Figure 5. Aerial map showing TMK parcels in the vicinity of the survey area. Parcel numbers are proceeded by TMK plat map (3) 6-8-001. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 12 of24 ,G Area of Detail Figure 6. Google Map aerial imagery showing the location of the proposed roadway routes and the archaeological survey area. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 13 of24 Qkly D Archaeological survey area Qhm 64,000-300,000 yr Hamakua Volcanics Qkl y 3,000-5,000 yr Kau Basalt QI 11,000-64,000 yr Laupahoehoe Vo lcanics Sherrod, D.R .. Sinton. J.\f. Watkins. S.f, and On.mt. K.\-1.. 2007, Gcolog1c Map of the State ofllawai"1. US Geological Sm...-cy Open-file Report 2007-1089. f(\ p., 8 plates. scale~ I 100.000 and I :250.000. with GJS database. Acce-.~cd 12, 16 20:25 Figure 7. Lava flows within the project area. c:::::J Archaeological survey area IO -Lava flows. ·a· a. 2 to 20 percent slopes 310 -Auwaiakeakua extremely cobbly silt loam. 2 to 10 percent slopes 336 -Puako fine sandy loam. 0 to 6 percent slopes 352 -Lava llows-Nanuku complex. 2 to 20 pcrccnl slopes 373 -Hapuna-Waib1i-Lalamilo complex. 0 to 20 percent slopes Qtim N A -=-a ~1ctcrs 0 100 200 N A ~ti.ktcrs 0 50 ICXI Soil <.;uJ\.!!Y St.,ff :\l,111md R1.":-\lU1\:!!' ( (11h.:n:i1mn S.:nu:i.: Lnif.:d St;it.;.., D.:p,1ttmcn1 ol ,\gmulnir.:-'oil Sun·..:~ Cn:~,grnphic tS~llRCJO) l);itaha,;,e_ \\·ailahle online ;it http<:: ~111da1aa.cce<:<:.<:c,egov.u<:da.g.o,· '\ccessed 12 16 ~1125 Figure 8. Soils of the project area. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 14 of24 Figure 9. Vegetation in the makai portion of the project area, view to the east. Figure 10. Vegetation in mauka portion of project area, view to the northwest. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 15 of24 Figure 11. Bulldozer push pile and dumped construction materials, view to the southwest. Figure 12. Large rubble pile, view to the east. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 16 of24 Figure 13. Existing holding pond at the Mauna Lani WWTP, view to the west. Figure 14. Existing South Kohala Fire Station, view to the east. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 17 of24 Figure 15. Burned coconut pahns within the project area, view to the northeast. Figure 16. Power line/water line easement road, view to the west. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 18 of24 A C::J l\rch:i.:nlogical survey arcl CJ 1tou1.:J Figure 17. Aerial view showing the location of Site 21975, the proposed location of the new roadway, and the utility easement and existing breach in the wall. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 19 of24 Figure 18. Southern end of Site 21975, view to the southwest. Figure 19. Site 21975, view to the north. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 20 of24 Figure 20. Site 21975, view to the southeast. • Figure 21. Existing breach where utility easement crosses Site 21975, view to the north. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 21 of24 Figure 22. Existing breach where utility easement crosses Site 21975, view to the east. Figure 23. Example of the landscape within the southern portion of the project area, view to the southwest. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 22 of24 Figure 24. Terrain within the southern portion of the project area, view to the southeast. Figure 25. Landscape within the southern portion of the project area, view to the northwest. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 23 of24 Figure 26. Extension of Site 21975, south of the fire station, view to the southeast. Figure 27. Southernmost segment of Site 21975, view to the south. December 30, 2025 ASM Affiliates-Mauna Lani Site M Access Road FI Page 24 of24 Figure 28. Southern extensions of Site 21975, view to the southeast. APPENDIXH ASM Affiliates. Ka Pa'akai O Ka 'Aina Analysis for the Proposed Mauna Lani Site M -----AFFILIATES September 5, 2025 Keola Cheng Wilson Okamoto Corp. 1907 S. Beretania St., Suite 400 Honolulu, HI 96826 Email: Subject: via email Ka Pa'akai O Ka 'Aina Analysis for the Proposed Mauna Lani Site M Development, TMKs (3) 6-8-001:054 and 6-8-022:010, Waikoloa Ahupua'a, South Kohala, Hawai'i Island. Aloha e Keola: At the request of Wilson Okamoto Corporation, on behalf of DHL Mahi Site M, LLC (the landowner), ASM Affiliates (ASM) conducted a Ka Pa'akai O Ka 'Aina (KPA) for Tax Map Key (TMK) parcels (3) 6- 8-001 :054 and 6-8-022:010 within the ahupua'a of Waikoloa in the District of Kohala on the Island of Hawai 'i (Figures 1 and 2). The Proposed Mauna Lani Resort (MLR) Site M Development (referred to hereafter as both the "petition area" and "project area," or "PA") encompasses approximately 150 acres and would include both a hotel and residential dwellings, with accompanying amenities (Figure 3). The Site M Project area is bordered to the west by N. Kaniku Drive and the Mauna Lani North golf course, to the south by Ho'ohana St, to the east by an undeveloped parcel, and to the north by an access road and the Puako petroglyph field (Figures 4 through 10). ASM is preparing this analysis to evaluate the potential impacts of the proposed development on traditional and customary Native Hawaiian rights and to assist the planning commission in upholding the State's obligation to reasonably protect customarily and traditionally exercised rights of Native Hawaiians. Information compiled in this KP A analysis can be utilized as a guide toward responsible land stewardship and the perpetuation of the cultural values, practices, and knowledge associated with Waikoloa Ahupua'a and, in the broader context, South Kohala. In Ka Pa 'akai O Ka 'Aina v. Land Use Commission (2000), the Hawai 'i Supreme Court recognized that the State has an obligation to protect Hawaiian traditional and customary practices to the extent feasible, and that the proponent of an action must show sufficient evidence that these types of practices are protected, if they exist in the location in question. This three-part analytical framework was created by the Court "to help ensure the enforcement of traditional and customary Native Hawaiian rights while reasonably accommodating competing private development interests." To effectuate the State's (and its agencies') constitutional responsibility to protect Native Hawaiian customary and traditional practices while reasonably accommodating competing private interests, the framework addresses the following: 1) the identity and scope of "valued cultural, historical, or natural resources" in the petition area, including the extent to which traditional and customary Native Hawaiian rights are exercised in the petition area 2) the extent to which those resources-including traditional and customary Native Hawaiian rights-will be affected or impaired by the proposed action; and Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 2 of42 3) the feasible action, if any, to be taken by the Land Use Commission to reasonably protect Native Hawaiian rights if they are found to exist. To provide a context within which to assess the potential impact of the proposed action on traditional and customary practices, a brief culture-historical background for the ahupua'a ofWaikoloa is first presented, followed by a description of the consultation methodology and results of the consultation process. The final section of this analysis includes an assessment the findings from the background research and consultation process using the three-part Ka Pa'akai o ka 'Aina analytical framework outlined above. A BRIEF CULTURE-HISTORICAL BACKGROUND FOR THE MAUNA LANI RESORT SITE M DEVELOPMENT In an effort to identify any valued cultural, historical, or natural resources, and to assess the extent to which traditional and customary rights are, or have been, exercised in the PA (the first part of the analytical framework), this section presents a summary of historical-archival information concerning Waikoloa Ahupua'a and, where applicable, the broader regional areas including the moku (district) ofKohala Hema (South Kohala). The lands known today as Waikoloa are part of a deeply layered landscape shaped by traditional land tenure, environmental phenomena, and ancestral knowledge-all of which inform the presence and continuity of traditional and customary Native Hawaiian practices. There remains some variation in the classification of Waikoloa as a land unit. While Soehren (2010) identifies it as an ahupua'a, 1865 boundary testimonies presented by Kanehailua clarify that Waikoloa was historically considered an 'ili kiipono of Waimea (Jensen 1989: 15). Waimea itself is not a conventional ahupua'a or moku, but rather a kalana or 'okana-a complex land unit described by Maly and Maly (2002) as a subdistrict smaller than a moku yet comprising multiple land sections that contributed to its overall productivity and cultural wealth. Among the lands historically associated with the kalana of Waimea are Waikoloa, Laliimilo, 'Ouli, Wai'aka, Puako, 'Anaeho'omalu, Kanakanaka, Ala 'Ohi'a, Paulama, Pu'ukalani (Pukalani), andPu'ukapu (Maly and Maly 2002:6). Directly to the west ofWaikoloa lies Lahuipua'a, translated as "family of pigs," which is likewise recognized as an 'ili 'aina of Waimea (Soehren 2010; Jensen 1989:12). Together, these lands form an interconnected region that stretches from mauka agricultural zones to coastal fisheries. Handy (1940) described this South Kohala coastline as once dotted with fishing communities and sandy bays- such as those at 'Anaeho'omalu, Waialua, Honoka'ope, Kalahuipua'a, and Pauoa-where small-scale cultivation, especially of sweet potato in the black cinder, likely supported a subsistence-based lifestyle during the rainy season. The name Waikoloa-interpreted as "duck water" or ''water pulling far" (Pukui et al. 1974:223)-is also associated with the winds of the region. Mo'olelo recorded by Karnak.au (1991) tell of the priest Lonopele summoning the cold northern wind to sink the canoes of Pa'ao; one of these winds was named Waikoloa (Karnak.au 1991:5). According to Maly and Maly (2002:12), this wind later becomes a wind goddess, an embodiment of natural power rooted in the identity of place. Additional winds of Waikoloa mentioned in the ka'ao (legend) ofKamiki and Maka'iole include Kuehulepo, which scatters dust, and three canoe-sailing winds: Haehae, Naulu, and Ho'olua (Maly and Maly 2002:24). These chants serve not only as oral histories but also as place-name references, anchoring the identity of the region in ancestral knowledge systems. Geologically, the PA is located northeast of the Kalahuipua'a fishpond and sits on an older, weathered pahoehoe flow belonging to the prehistoric Ka'u volcanic series deriving from Mauna Loa (Kirch 1979:8). It is not situated on the more recent Kanikii 'a'a flow, which lies to the south and serves as the natural boundary separating Kalahuipua'a from 'Anaeho'omalu. The following section presents the wahi pana, or storied places, within and around the PA. Many of the place names and mo'olelo that follow are drawn from the ka'ao ofKamiki and Maka'iole, which serve as a traditional framework for understanding the regional landscape. In addition to oral traditions, this analysis references previous studies, archival records, and mo'olelo documented or interpreted by cultural historians Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 3 of42 and scholars including, J.W.H.I. Kihe, Pomander, Kamakau, Maly, Kimura, McElroy, Jensen, and Barrere, whose collective work helps preserve and illuminate the ancestral significance of South Kohala. Lalamilo & Puako Named for the young chiefLalamilo, this area carries the legacy of deep familial ties, in-depth knowledge, and sacred traditions that center on the ocean. Lalamilo was the grandson ofKanakanaka, a master lawai'a hI'ahi (deep-sea tuna lure fisherman), and Piliamo'o, a powerful priestess. Kanakanaka's sister was the wind goddess, Waikoloa. Lalamilo's mother, Ne'ula, a fishing goddess, introduced him to Puako, a chiefess with a great desire for he'e (octopus). Puako was the daughter of Wa'awa'a and Anahulu, and sister of 'Anaeho'omalu. The two fell in love along the South Kohala coast, where their story is still rooted in the names and winds of the land. After a moment of mistrust, Lalamilo discovered a sacred leho ( cowry lure) imbued with the spirit of Ha'aluea, a supernatural octopus being. This lure brought him great abundance but only through sacred rituals and devotion to his ancestral akua (god). The names Lalamilo, Puako, and Ne'ula now live on in the land, wind, and sea---etched in place names and preserved in the proverb, "The salt-gathering place ofNe'ula, where the Kii'ula (akua of fishermen) rests and the salt is laid by the wind Kuehulepo" (Maly and Maly 2002:22-24). Kamakanui'aha'ilono And Lonopiiha Kamakanui'aha'ilono (Kamaka), a divine healer and youngest sibling of the gods Kii, Kane, Lono, Kanaloa, and Kamakaokiikoa'e, was born to Kama'oa and Hinaikamalama. Gifted with healing powers, he traveled across the Hawaiian Islands, helping people in need-one of which was Chief Lono, who became known as Lonopiiha ("swollen Lono") after an injury with an '6'6 (digging stick). Afterward, the chief joined Kamaka on his healing journey through Puna, Hilo, Hamakua, Waimea, Puako, and finally Kalahuipua'a. At Kalahuipua'a, Kamaka encountered Kolea-nui-a-Hina in the form of a kolea (golden plover) with a rainbow path, a relative of Kamaka. The three-Kamaka, Lonopiiha, and Koleanui-traveled together to Kohala to see Kamanuiohua. When they needed herbs, Lonopiiha was sent to gather them at Puako. He uprooted all the herbs, leaving none behind, which angered Lonoikoleamoku, who then refused to enter Kamaka's house and placed a carved image at the doorway, declaring he would not return until he went back to Kahiki (a spiritual homeland). After Lonoikoleamoku departed, Kamaka and Lonopiiha's journey continued to 'A.wini, where Kamaka taught Lonopiiha how to make medicines (McElroy et al. 2016:10- 11). 'Umi-a-Lnoa The waters of Kalahuipua'a were a favored fishing spot of 'Umi-a-Lnoa, the unifier of Hawai'i Island. According to the historian Samuel Kamakau, 'Umi was a skilled and dedicated fisherman, earning the title "Pu'ipu'i aka lawai'a" (a stalwart fisherman). Aku fishing was his favorite occupation, and it often took him to the beaches from Kalahuipua'a to Makaula, where he also pursued 'ahi and kala. 'Umi was often joined by famed fishermen-such as Pae and Kahuna-and all the chiefs of his kingdom (Kamakau 1961:19-20). Pele In a legend shared by Larry Kimura (1968) in Kapalaoa Homestead Life, the area of Kapalaoa is tied to a story of Pele. Appearing as an elder woman with a cane, Pele asked residents for some salted fish or even just the gills or scales. She was denied, being told "Na ke ali'i no na mea a pau loa!" ("Everything is for the chief!"). Offended, Pele turned to Manna Loa, later coming back as her lava form to destroy the royal family and those who refused her. Chief Pohakuloa and Chiefess Kuaiwa fled but were overtaken by the lava and turned into large stones still visible today. As Kuaiwa ran, her niho palaoa (whale-tooth pendant) fell and was covered by lava, too; a semicircle stone seen at low tide marks the spot, giving the area its name, Kapalaoa. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page4 of42 Kapuaokalaulani, also known as Kaipukai, fled carrying her food, calabash. Her stone form includes a shallow cave symbolizing this calabash, explaining her name. Another stone, Meko, lies just below the ocean's surface; tradition says women once wove mats in a cave beneath it. A nearby shark hole, Ka Lii o ka 'Ehu, was believed to be guarded by a protective shark spirit, shielding swimmers and fishers between Kapalaoa and Keawewai in South Kohala (Kimura in Jensen 1989:12, 14). Lonoikamakahiki Ahualono Along the boundary between Kohala and Kona, the sixteenth century ali'i of Hawai'i Island, Lonoikamakahiki, erected a boundary marker known as Ahu-a-Lono. During a visit to Kaua'i, he was abandoned by his followers but formed a close friendship with Kapaihi-a-Hilina, who later accompanied him back to Hawai'i and became his closest advisor. However, envious chiefs deceived Lono with false accusations against Kapaihi. While at Kahalu'u in Kona, Lono, believing the lies, rejected Kapaihi, who then departed back to Kaua'i. Lono soon regretted his actions and set out to fmd his lost friend. Barrera (1971) writes: As Lonoikamakahiki set out to find his friend, Kapaihiahilina has already arrived at 'Anaeho'omalu. Shortly after, Lono followed and upon arrival, he saw Kapihiahilina sitting on the beach as the canoes were being brought ashore. When they reunited, Lonoikamakahiki established a covenant of reconciliation and loyalty between them. To honor and seal this bond, they built an ahu pohaku ( temple of stones) as a sacred place for offering prayer and oaths to Lonoikamakahiki's god (Pomander 1916-1917:360-362; Barrera in Jensen 1989:14). Kanaloakua 'ana In one mo'olelo told by Pomander (1996), Lonoikamakahiki faces a rebellion led by his older brother, Kanaloakua'ana, who attempts to seize control of Hawai'i Island. The confrontation begins at 'Anaeho'omalu and continues at Wailea, "not far from Wainanali'i, where in those days a watercourse appears to have been flowing" (Pomander 1996:120-121 in Maly and Maly 2002:12). The conflict moves north to Kauna'oa and then to Nakikiaianihau, where the rebellion is finally ended with the help of reinforcements from Kohala and Hamakua. Peace is eventually restored between the brothers, and they later fight alongside one another in future battles. Kamalalawalu -The Battle at Waimea One such battle arises when Kamalalawalu, the chief of Maui, seeks to invade Hawai 'i Island. After spying missions falsely reported Hawai'i Island as undefended, Kamalalawalu launched an invasion, landing in Kohala and capturing Kanaloakua'ana (Kamakau 1961:56). The brutality was immense: "The eyes of Kanaloakuaana were gouged out by the Maui forces, the eye sockets pierced by darts, and he was then killed, the eyes of Kanaloakuaana being tatued. Because of this action on the part of Kamalalawalu's men the landing place for the canoes at Puako was called Kamakahiwa, and to this day is known by that name and may ever remain so to the end of this race" (Pomander 1916:342). The Maui army advanced toward Kawaihae and Puako, but most locals had already fled to Waimea. Two elder men-secretly loyal to Lonoikamakahiki-guided Kamalalawalu mauka, advising him to dismantle all his canoes and settle at Hokii'ula. As the Maui army reached Waimea and looked back toward the coast, they saw, ''the lava bed ofKanikii and all the land up to Hu'ehu'e was covered with men" (Maly and Maly 2002:58). The land appeared red, not from lava, but from the sheer mass of warriors poised for battle. Kona forces stretched from Pu'upa to Haleapala, Ka'ii and Puna from Holoholokii to Waikoloa, Hilo and Hamakua from Mahiki to Pu'ukanikanihia, and Kohala from Momoualoa to Waihaka. The old men falsely claimed it was dust lifted by the 'Olaniu wind, masking the truth: warriors from every district had encircled Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 5 of42 the Maui forces, signaling an imminent and overwhelming counterattack (Maly and Maly 2002:58). Realizing his disadvantage, Kamalalawalu proposed peace. But Lonoikamakahiki, still grieved by the cruel fate dealt to his brother, rejected the offer, choosing battle over forgiveness. 'Anaeho'omalu and Kalahuipua'a Precontact Coastal areas experienced settlements prior to inland areas, usually by single extended families. Along the coastal areas near the PA, 'Anaeho'omalu experienced human settlement between AD 900-1000, and Kalahuipua'a between AD 1100-1200. "For both areas, population gradually increased, achieving a maximum permanent population at 'Anaeho'omalu of between 35-50 persons, and between 100-150 at Kalahuipua'a. Early occupation at Kalahuipua'a was "marked by exclusive use of shelter cave sites" (Jensen 1989:8). Around 1650, the populations in the area began to decrease for several reasons: "competitions for arable land or other resources had led to significant internal stress; and/or there was an increase in open conflict and competition during the two to three centuries preceding European contact." Anehoomalu and Kalahuipuaa, compared to surrounding lands, are oasis-like, and in prehistoric times they were valuable for fishing, aquaculture, and other shoreline activities. Both ili include small strips of sand beach backed by brackish-water anchialine ponds that sustain a variety of marine life (Jensen 1989:12). The presence of scoriaceous pahoehoe in the area provided a material well suited for abrading and shaping tasks, supporting evidence of quarrying and abrader manufacture. Quarry and workshop activities taking place within the caves likely began around AD 1400, with the evidence of volcanic glass dating between AD 1700 and AD 1800 (Jensen 1989:11). According to GIS data provided by both the State and the Office of Hawaiian Affairs, there are numerous wahi pana in the PA vicinity. Wahi pana near MLR Site M identified in the Kipuka Database include 'Auwaiakeakua, Kanikii lava flow (southeast of PA), Lae O Puili (west of PA), Manoku fishpond (in Lahuipua'a), Papakonani Boat Landing (in Lahuipua'a), Puako Keamuku Trail, Waiakumalae Point and Waipuhi Fishpond (at coast in Lahuipua'a; (OHA 2018). Other place names in the PA vicinity were identified on a historic map of the Waimea ahupua'a from 1866 (Figure 11). These include Waima, Ke'eke'e, Nakui'elua, Lalo, Kalolo gulch, Kalahuipua'a, and Kepani. Ali'i Fishponds ofKohala Hema Keawenui Landing was the location that Kamehameha I would land to access his small village in this area (behind a small cove northeast ofLahuipua'a Pond). When Kamehameha gifted the 'aina of Waikoloa to Isaac Davis, that grant did not encompass 'Anaeho'omalu and Kalahuipua'a with their valuable fishponds (Hammon 1981 in Jensen 1989:15). Lahuipua'a Pond belonged to Kamehameha I, and the fish from the pond would be brought to him in Kohala by one of his runners (Jensen 1989:15). Because the ponds were designated for the ali 'i, it is possible that habitation in the areas surrounding the fishponds were limited to those who cared for the ponds. This is supported by Barrera (1971 ), who stated that " ... utilization of adjacent land units may have differed quite radically ... for example, the upper Lalamilo area contains nearly 3,500 features, while Waikoloa, separated from Lalamilo by a stone wall, contains only 240 features (Barrera 1971:3 in Jensen 1989:15). Further, Apple and Kikuchi (1975) conducted an evaluation of ancient Hawaiian fishponds for the National Park Service to identify ponds most worthy of historical preservation. Out of 56 fishponds listed throughout the Hawaiian Islands, Lahuipua' a Pond at Kalahuipua'a was ranked the second most important (Costa-Pierce 1987). Petroglyphs The Kalahuipua'a and Puako region is distinguished by the presence of some of the largest and most significant petroglyph fields in Hawai 'i. Extensive concentrations of carvings-particularly at Paniau and Kaeo-depict humans and other forms with remarkable density and technical skill, suggesting these sites were focal points of cultural activity in the precontact and early historic periods. Documented through Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 6 of42 successive Bishop Museum surveys beginning in the 1960s and 1970s, and reinforced by later studies, these fields are widely recognized as holding the highest level of preservation value (W olforth and Huber 2007). Collectively, they provide enduring testimony to the cultural and historical depth of the landscape and frame the region as one of exceptional significance within the Hawaiian Islands. Wolforth and Huber (2007:14) note: "Sometime in the prehistoric past, the native Hawaiians created one of the most elaborate fields of petroglyphs form the entire island chain just north on the project area (Lee and Stasack 1999). There are several petroglyph loci in the Puako region, but the largest, and nearest to the project area, is that referred to as Kaeo 1. Kaeo 1 is nearly 2,200 m 2 of petroglyphs, mostly in human form, on pahoehoe. The emphasis on human forms, the sheer quantity, and the technical application suggests that "some singular activity was focused at Kaeo 1" (Lee and Stasack 1999:15). Just what that activity was remains speculative at this time". During his 1930 survey, Reinecke writes (1930:30-31): As Stokes and Baker mentions, there is a great variety of forms; the surrounding rings are of various shapes; the human figures of some variety of forms; while there are several other forms (beside the vast multitude of rings), some of which appear in my photographs. There must be thousands of individual petroglyphs. The predominant features is the rings, single or several concentric together, with or without a small hole in the center. These may be records of tris, or sexual in nature; I am much inclined to think the latter ... which is identical with a Marquesan carving shown me by Dr. Hands ... There were several names, initials, and dates in the locality, but I saw no ships or other modem-appearing figures, such as the "horse" at Lae Mano. In several places the pahoehoe had been worn to a depth of several inches, say two to five, by the carving of petroglyph on petroglyph, so that the surface presented the appearance of a shallow bowl. In at least one place a shallow basin has been worn into the pahoehoe. (I believe it is at Kapalaoa that I saw what was apparently a little basin formed by the erasure of a petroglyph side by side with another petroglyph.). This area deserves careful study and photographing. {Mr. Baron Y. Goto of Puako Ranch, Kawaihae, or any of his family, or any of the Hind family, would no doubt cooperate willingly in providing transportation and guidance to this area, and to the area mentioned near Puako by Dr. Baker in Thrums Annual for 1920, pp. 49-52.) Early Historic Accounts Early historic accounts of Kohala Hema area primarily concern Kawaihae, to the north of the PA. When Captain James Cook first arrived in 1779, he and his men went ashore at Kawaihae, looking for fresh water. No water was to be found, and Cook describes Kohala to be the same as Ka'ii: .. .is not only by far the worst part of the Island, but as barren waste looking a country as can be conceived to exist in the Neighborhood of a fine one, & this owing to the ravages of a Volcano ... horrid & dismal at this part of the Island appears, yet there are many villages intersperse, & it struck us as being more populous than the part of Opoona which joins Koa [Ka'ii]. There are houses built even on ruins [lava] we have describ'd. Fishing is a principal occupation with the inhabitants (Beaglehole 1967:607). Captain George Vancouver, who sailed with Cook in 1779, returned to Kawaihae in 1793 and 1794. He mentioned South Kohala appearing unpopulated. When Louis Claude de Saulses de Freycinet stopped at Kawaihae as part of his voyage around the world in 1819, he was greeted by Liholiho, Kamehameha II, at Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 7 of42 Pu 'u Kohola Heiau. His companion, Jacques Arago recorded his observations along the way, describing the South Kohala district thusly: Not a tree nor a bush, not a single stripe of verdure, not a beast nor a bird, and scarcely an insect give life to this desolate scene ... the whole coast is indented with crooked and deep ravines, and broken into little cones and petty eminences, once the crates of volcanoes long extinguished. Immense deposits oflava, which the waves break over with violence; massy rock, suspended like arches, from the precipices between which dart the rays of a burning sun; half-formed paths, which makes us shudder as we tread them, and which at intervals are lost on the rocky shore, or in the distance, which we dare not attempt to reach; such are the terrific objects, which in this inhospitable country shock our view, and depress our imagination. The misery of the people is to be deplored, who are frequently obliged rapidly to traverse these frightful deserts, without finding a small spring, or a single rivulet, in which they may repose from their fatigues (Arago 1823:88 in Maly and Maly 2002:29) Mahele 'Aina of 1848 In the beginning of the nineteenth century, Kamehameha I bequeathed the lands ofWaikoloa to Isaac Davis and John Young (McElroy et al. 2016). By the mid-nineteenth century, the ever-growing population of Westerners in the Hawaiian Islands forced socioeconomic and demographic changes that promoted the establishment of a different style ofland ownership, resulting in the Mahele 'Aina of 1848 and the Kuleana Act of 1850. The lands in the PA vicinity were distributed as follows. Waikoloa was deemed Crown land, of which Isaac Davis received a large portion (Royal Patent Number 5671). George Hii'eu, the only surviving son of Isaac Davis, received a portion of Waikoloa (Land Commission Award 8521-B:1) in 1865. Post-Mahele, Waikoloa was sometimes referred to as "Waikoloa Nui" and "Waikoloa Iki," differentiating between the Crown land and Davis' land, respectively. The Crown land portion later became known as Lalamilo and Davis' portion, Waikoloa. The coastal lands of 'Anaeho'omalu and Kalahuipua'a were retained by the Crown as 'ili kiipono (Maly 2000). Numerous Kuleana were awarded within Waikoloa and Waimea; however, nothing is within the PA. Nearby, along the coast, is an award for 359 acres to Kalama, H. (Land Commission Award 4452:3) for the 'ili 'aina ofKalahuipua'a or Lahuipua'a in Waimea,justwest of the PA (OHA 2018). When Kalama passed in 1870, the 'aina ofKalahuipua'a was inherited by her uncle, Kanaina. Upon the death ofKanaina seven years later, the courts awarded the lands to 25 heirs. Unable to agree on its division, a commissioner was appointed by the courts and the lands were sold with the proceeds going to the Estate of Charles Kanaina (Jensen 1989:15). During Boundary Commission Testimony on August 14, 1873, George Kaukuna, who moved to Kapalaoa in 1863 and had since lived in Kiholo, testified before the boundary commission that the government road marked the boundary between Waikoloa and Kalahuipua'a. " ... Thence along the land ofWaikaloa to Kepani a puu hoomahu [a resting place; a rock outcropping, mound or hill], there are two piles of stones there, and the road cuts through the hill. From this point you can see the trees on the shore of Kalahuipuaa. Thence along the land ofWaimea kai towards Kohala hills, to a place called Milokukahi; a grove of Milo trees, where the boundary turns makai ... " (McElroy et al. 2016:26-27). Nauhau, who was born at Lalamilo, mauka of Puako and lived at 'Anaeho'omalu and Kalahuipua'a also provided testimony that day, stating the boundary between Kalahuipua'a and Waikoloa is the same as that testified by Kaukuna. Nineteenth and Early Twentieth Centuries As Wolforth (2007) describes, "Hawai'i changed rapidly and dramatically after the death of Kamehameha in 1819. Populations moved from traditional homelands and decreased due to the introduction of alien diseases, and new concepts of economy and ownership." During the latter half of the nineteenth century, Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 8 of42 the landscape across Waikoloa/Waimea/Kohala was transformed by the introduction and growth of commercial agriculture and ranching throughout the district. Following Samuel Parker's (grandson of John Palmer Parker, the founder of Parker Ranch) 1882 purchase of 'Anaeho'omalu and Kalahuipua'a, the lands were used by Parker Ranch employees for recreation and fishing, with the ponds supplying fish for the ranch's lii'au (Jensen 1989:16). By 1901, much of the lands within the PA vicinity were classified as "Grazing Lands" (Figure 12). In 1903, under the direction of A. W. Carter, Parker Ranch purchased Waikoloa (Maly and Maly 2002:iii). Kalahuipua'a was later purchased by Francis 'l'I Brown (1932-1936), who oversaw pond maintenance and whose name was later given to the golf course constructed by MLR more than 50 years later. The ponds in the area were also utilized to restock the Kaloko Pond between the late 1930s to early 1940s (Jensen 1989:16). Despite damage from the 1946 and 1960 tsunamis, and temporary restoration by Parker Ranch, the ponds fell into disuse following the retirement of the last kia'i loko (guard of fishpond) in 1965 or 1966 (Jensen 1989:16). A 1954 aerial photograph (Figure 13) illustrates the coastal landscape during this period, showing the extent of grazing and land use along the shoreline prior to resort development. In 1880, George Bowser traveled from Puako to Kalahuipua' a along the coast before turning inland to make his way toward Kiholo. The documentation of his trip and the views he saw are presented in his publication The Hawaiian Kingdom Statistical and Commercial Directory and Tourists Guide (Bowser 1880). Bowser describes the area thusly: From Puako to Kalahuipuaa is about four miles. The traveler cannot mistake the road in this district, as the paths are always plainly marked. The road to Kalahuipuaa is along the sea beach and is in good order. A few shrubs are growing along the route, but on my left I had nothing but a sea of lava. At this place there are several waterholes into small groves of cocoanut trees. There is a splendid view from here of the south side of the Island of Maui, which is something short of thirty miles away, in a crow line. On the road to this place we passed over the scene of the lava flow of 1859, one of the grandest that has ever been seen in Hawaii. Here the lava is turned and twisted in all directions. This stream of lava reached the sea from its source on the north flank of Maunaloa (about thirty miles distant in a straight line) in the incredibly short space of three days. One of the pieces of mischief it did was to destroy a splendid fish pond and its contents. There is still a pool of water left to market place where this fish pond used to be. From Kalahuipuaa to Kiholo my next halting place the road leaves the sea beach and turns inland in a southerly directions. On the way we saw a great lava flow of 1801, which burst out from the base of Mauna Hualalai, not more than six miles from the sea. There is nothing to be seen all the way but lava; lava to right of you, lava to left of you, lava ahead of you, lava behind you, and lava beneath you; the road for a dozen miles or more is composed of nothing but clinkers of every size ... (Bowser 1880:547-548) Menzies (1920) describes the Waimea, South Kohala area on his way inland towards the Waimea plains: I travelled a few miles back, attended by these two natives through the most barren, scorching country I have ever walked over, composed of scorious dregs and black porous rocks, interspersed with dreary caverns and deep ravines, evidently indicating the volcanic revolution which the country at no very distant period had undergone. The herbs and grasses which the soil produced in the rain seasons were now mostly in a shriveled state, thinly scattered and by no means sufficient to cover the surface from the sun's powerful heat, so that I met with very few plants in flower this excursion. A little higher up ... than I had time to penetrate, I saw in the verge of the woods several fine plantations, and my guides took great pains to inform me that the inland country was very fertile and numerously inhabited. Indeed, I could readily believe the truth of these assertions, from the Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 9 of42 number of people I met loaded with the produce of their plantations and bringing it down to the water side to market ... (Menzies 1920:56) In 1930, Reinecke surveyed coastal sites from the Kona/Ka'ii boundary to Kawaihae, passing near the PA. The following introduce his observations: Site 145-At Honokaope Bay, white sand drifted among the a-a; a few kiawe; no pool as on the map. There is, however, the pool in the a-a a little north, with potable brackish water. One shelter between it and the sea. A third of the distance toward Kalahuipuaa is a shelter on the path. Site 146-A few shelters where the path descends from the a-a to the masonry breakwater of the chief pond at Kalahuipuaa. From here the growth of kiawe along the shore is so dense that it was useless to attempt any survey of sites unless one had a base near; nor is it likely that a painstaking search would reveal much. Site 147-The area ofpetroglyphs on the pahoehoe about three-quarters of a mile N.E. of Anehoomalu, S. Kohala, by the trail and mostly on Anehoomalu land. This area is well described by Stokes in the Bishop Museum Occasional Papers for 1909, and is mentioned by Dr. Albert S. Baker in Thrum's Annual for 1919, pp. 131 ft. Both men, not having exact maps, mislocated the area, the former putting it between the branches of 1856 flow, the latter in Puu Anahulu land. Construction of the section of Queen Ka'ahumanu Highway from Hapuna to 'Anaeho'omalu Bay began in 1970, opening up the area for further resort development. In 1972, Orchid Island Resorts acquired the fee title to Brown's 175 acres and an additional 3,025 acres from Signal Properties (former Parker Ranch Land) to create the 3,200-acre Mauna Lani Resort (Wolforth 2007). In 1972, the resort applied for re-zoning of the land, and, by 1980, construction began on the 3,200-acre property (Hawaii Tribune-Herald 1980). In 1985, Mauna Lani Resort, Inc. received special management area approval for the entire Resort Complex (Land Use Commission Docket No. A84-583). Previous Archaeology Since the initial acquisition by Orchid Island Resorts in 1972, much of the Mauna Lani Resort, including the lands adjacent to the current project area, have been developed. As such, a series of archaeological studies have been conducted as part of the historic preservation review process for the various development activities within the larger Resort area (Figure 14). To better understand the broader context in which the historic properties located within Site M are situated, a brief review of prior archaeological studies conducted within and adjacent to the Site M parcel is presented. More than 3,000 individual petroglyphs were initially documented by the Bishop Museum in 1964 (Smart 1964) between the Puako Beach Lots and Ho'ohana Street. In 1982, the petroglyph field was listed in the Hawai'i Register of Historic Places (Tomonari-Tuggle 1982) and subsequently in the National Register of Historic Places in April of 1983. This site, designated as "The Puako Petroglyph Archaeological District," was assigned a Statewide Inventory of Historic Places number (SIHP Site 50-10-11-04713), is described as one of the largest and oldest petroglyph fields of its kind in the Hawaiian Islands (Dunn and Rosendahl 1992; Lee and Stasack 1999). This petroglyph park is located adjacent to the northern and western boundaries of the current project area. Between 1973 and 197 5, prior to the development of the MLR, the Bishop Museum also conducted a series of archaeological investigations within an approximately 3,841-acre area that covered the coastal portions of the ahupua'a of Kalahuipua'a, Waikoloa, and Lalfunilo and included the current project area (Kirch 1979). That study, which encompassed all of the lands situated between Puako Beach Drive, the Queen Ka'ahumanu Highway right-of-way, and the southern end of the Waikoloa Resort Property, identified 179 Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 10 of42 archaeological sites containing a total of 449 features. The documented features included petroglyphs, :fishponds, trails, C-shaped structures, U-shaped structures, L-shaped structures, shelter caves, burial caves, storage caves, modified sinks, abrader manufacturing areas, papamii, walls, circular structures, enclosures, platforms, and midden deposits (Kirch 1979). Most of the sites were identified within the coastal portion of the survey area and were interpreted as being associated with the extraction of marine resources from the Kalahuipua'a :fishponds and other nearby anchialine ponds. The entirety of the current project area was included within the Kirch (1979) survey area, but no sites were reported within Site M (Figure 15). Since then, a series of archaeological investigations within the Mauna Lani Property have been carried out, including the north and south golf courses (Jensen 1989); Parcel K, known as the Fairways at Mauna Lani (Burgett et al. 1999; Wolforth 2006); and the Brookfield Homes Development (Wolforth 2005). During geotechnical boring in the Brookfield Homes Development, technicians exposed a concealed cave containing human skeletal remains. A burial treatment plan (Wolforth 2003) was subsequently prepared for the cave. Wolforth and Huber (2007) cited the inventory of feature types at the these locations (caves, C- shape walls, trails, cairns, quarried crevices and blisters, abrader basins with associated modified scoriaceous pahoehoe, and light midden scatters) as indicators for the Site M project, based on similar terrain and proximity (Burgett et al. 1999; Jensen 1989; Wolforth 2005). Abrader basins and small caves were the most common feature types. The small blister areas contained scant artifacts, suggesting sporadic use and likely functioned as short temporary shelter during makai-mauka resource procurement (Wolforth and Huber 2007:31). Additionally, (Rosendahl 2000) conducted an archaeological inventory survey of a 450-acre portion of TMK (3) 6-8-001:022, just northwest of the current PA (see Figure 14). As a result of the survey, 14 sites including walls, mounds, marine shell concentrations, a possible cart path, and a modified outcrop with cultural deposits, and three complexes with enclosures, overhangs, and ranching and sugarcane features. In 2007, Scientific Consulting Services (SCS) conducted an archaeological inventory survey (AIS) of Site M (W olforth and Huber 2007). As a result of the AIS, eight archaeological sites containing a total of 31 features were documented and assigned SIHP designations (Sites 50-10-11-24425 to 50-10-11-24432; Figures 16 through 18). The documented sites included pahoehoe excavations, C-shaped structures, abrader basins, and a resource extraction complex (see Figure 16). Due to its proximity to the Puako Petroglyph Archaeological District, the northern portion of the project area was inspected closely for petroglyphs on three different occasions. No petroglyphs were observed within the PA. In addition to the eight sites assigned SIHP site designations, SCS also investigated six cave openings within the Site M PA; no cultural material was observed in any cave (Figure 19). No further work was recommended for any of the sites. In line with other previous archaeological assessments in the vicinity, Wolforth and Huber (2007) noted disturbance associated with Site M. These construction impacts coupled with evidence of relatively recent wildfires have further scarred the landscape, potentially impacting historical surface deposits (Figures 20 through 22). Most recently, ASM (Jaques, in draft) conducted an LRFI of Site M to provide an update on the current conditions of the archaeological sites previously identified within property during the AIS completed by Wolforth and Huber (2007) and to provide information and recommendations to assist the Department of Land and Natural Resources-State Historic Preservation Division (DLNR-SHPD) with their Hawai'i Revised Statutes Chapter 6E-42 review of the amended permit application (see Figure 16). As a result of the targeted survey, no additional historic properties were identified on the surface of the project area. All sites and component features identified by Wolforth and Huber (2007) were extant and in similar conditions to those originally described in the 2007 AIS. Based on their :findings, Jaques (in draft) recommended the following suggestions for consideration. If the northern boundaries of the PA are to remain undeveloped (as depicted on the current development plan overlaid by the site distribution map; Figure 23), Site -24426 would remain preserved in its current state. This undeveloped section of the PA could also function as an open, mauka/makai access corridor, while Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 11 of42 dually serving as buffer and access route to the adjacent Puako Petroglyph Archaeological District (Site - 4713). As a portion of Site -24427 appears to be located within the proposed golf course, it is recommended that consideration be given to avoiding this site during construction of the golf course. Several of the sites are also located within or nearby planned landscaping areas. Further consideration could be given to preserving these sites within these landscaped areas. Lastly, as Site 24432 (in the southeastern portion of Site M) is the most extensive historic property with the greatest density of features within the proposed project area, it is recommended that consideration be given to preserving or avoiding this site. Cultural Impact Study of Site M In December of 2007, SCS completed a draft of a Cultural Impact Assessment (CIA) for the proposed development of Site M (Wolforth 2007). The CIA concluded: Based on the archaeological work, research into the history of the area, and interviews, there are not Traditional Cultural Properties or ongoing Cultural Practices within the project area that area tied to the land. For instance, there are no resources that are gathered within the area, no recreational or transportational activities that take place there, no agricultural activities, no ceremonies practiced there, and no burials present. There broader context of the Mauna Lani area does provide the setting for an unusual kind of cultural practice, however, one that probably has not been considered before, but one that is germane to the culture of this island and state: this is the Resort Culture of Mauna Lani. (Wolforth 2007:25) Wolforth (2007:26) goes on to describe the Resort Culture ofMauna Lani as follows: ... the commercial setting of the area that has come to be known as Mauna Lani has, at its core, a set of practices and beliefs that are founded in the earliest days of commercial development there, and can still be observed in a variety of manifestations. The suite of developments in the Mauna Lani region (those areas connected to one another by the roads that lead the single road that intersects Queen Ka' ahumanu Highway) share a common corporate history. That history is passed on by word of mouth, and is a source of self- esteem and honor for many of the employees that work in the wide variety of jobs ... . . . The presence of a "commercial culture" at Mauna Lani is evident in the continued retelling of the origin of the Mauna Lani Resort, and emphasized by the production of the written version of those stories. The culture is expressed in the way that cultural resources are incorporated into the design and layout of the resort area, and the continued maintenance of those resources. The CIA concludes: There are no Traditional Cultural Properties at Site M. There are no preservation archaeology sites at Site M. The only cultural practice at Site M is the practice of commercial development of resort property. This is a relatively new practice, but one that is significant in 20th century land use that is intimately tied to the way that modem people identify with, understand, interpret, and affect ancient culture. Decentralization of the Mauna Lani development, and lack of opportunities for new participants in that culture to share, interact with, or otherwise obtain information about, the origin, history, and ongoing activities that make up that resort culture, contributes to the demise of that resort culture. Knowledge of such things as how certain resort components came to be as they are, historical trajectories that might influence current and future design, current issues with native Hawaiians, how historical resources have been dealt with in the past successfully or not, is not being shared with the newcomers to the property. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 12 of42 The development of the Site M property for resort use contributes to the way that the resort culture evolves at Mauna Lani. Those actions may be conducted without knowledge of the resort culture at Mauna Lani, however. The lack of articulation with the resort culture at Mauna Lani can be considered a negative impact to the continuation of the resort culture at Mauna Lani. To mitigate impacts to this commercial cultural practice, it is recommended that the developer create a program that is designed to introduce current and future developers to the commercial culture at Mauna Lani of which they are now participating in ... . . . The objective in disseminating information about the resort culture at Mauna Lani is not necessarily to promote a particular paradigm, or to insist that only certain ways of conducting commercial activity are permitted. The objective is to facilitate the continuation of this particular resort culture, which can be seen as a growing and evolving activity that deals with development issues that pertain to Mauna Lani. Those issues have an origin, a history, and a current trajectory that is not being shared with newcomers to that culture and practice. The synthesis of available information, and the dissemination of that information at appropriate venues will mitigate the impacts to the resort culture at Mauna Lani. (Wolforth 2007:27) To effectively facilitate the continuation of the Mauna Lani Resort Culture as part of the development of Site M, the CIA recommended that (1) the publication and dissemination of the written version of the oral histories presented as an appendix to the CIA occur, (2) a list of other relevant reading materials be produced, (3) a 30-minute DVD presentation on the history of the commercial culture at Mauna Lani be prepared, (4) opportunities for developers to interact with the Mauna Lani cultural specialists be provided, and (5) venues to appropriately disseminate the Mauna Lani Resort Culture information in ways that are valuable to current and future developing entities be created (Wolforth 2007:27). These conclusions were reached, in large part, based on consultation with a few individuals that have ties to, or have been longtime residents of the area, including Daniel Akaka, Jr., and Kenneth Francis Brown. However, the majority of the individuals interviewed were involved in the acquisition of, or early development efforts associated with the MLR, many of whom were non-residents ofHawai'i (from either Japan or the mainland U.S.) and who had little to no prior knowledge of the area until their involvement with the MLR. While these interviews are unique in that they capture the vision, design, subsequent development, and early life at a major resort property on along the Kohala coastline, these interviews and the conclusions reached by Wolforth (2007) are based on recent history (post-statehood) and while insightful and detailed in building a picture of a facet of the modem identity of this area, they are incomplete; they do not, by any means, represent a full picture of the cultural history and practices associated with this area (full interviews can be referenced in Appendix A of the 2007 CIA). CONSULTATION Consultation for the current Ka Pa'akai O Ka '.Aina analysis involved gathering oral histories and conducting interviews with various community members in an effort to further document individuals' historical connections to place, as well as acknowledge the visions communities have for wahi pana of Waikoloa Ahupua'a. Generating detailed stories about people and places helps to ensure that this knowledge and these connections are transferred to future generations. In conducting interviews with kiipuna who have longstanding ties to Waikoloa and the larger Kohala Hema, we have tried to capture some personal histories, stories of the landscape, and mo'olelo associated with this area. The interviews conducted for this analysis are summarized below. Puako-Kalahuipua'a Cultural Stewards On July 24, 2025, ASM Cultural Specialist, U'i Kiiali 'i, conducted two in-person consultations at the MLR with two longtime cultural stewards who have been intimately tied to the Puako and Kalahuipua'a region since before resort development (names have been withheld until acceptance of the consultation Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 13 of42 summaries). Recognized today as trusted advisors for the area, they continue to carry forth knowledge, guardianship, and advocacy for the integrity of place. They noted that Keawenui Landing had once been the site of Kamehameha the Great's kauhale (campsite), and that Puako and Kalahuipua'a served as gathering places for ali'i as far back as the time of 'Umi. Trails once crisscrossed this makai landscape, visible today through the extensive petroglyph fields that testify to the time and presence invested there. As one consultant explained: "You had to spend time in an area to create a petroglyph. It takes time. Habitat caves and petroglyphs, we know people spent time here." The area contains numerous lava tubes, many uncharted, with burials extending both makai and mauka. A burial cave makai of the PA, on the way to Paniau, was described as holding a wooden casket and many 'iwi, including possibly ali'i and 'ohana associated with Puako descendants. Another burial cave was recalled at Holoholokai, along the "Fire Road." The consultants emphasized the mauka-makai connection of these lava tubes: "If you have tubes makai, they gotta come from somewhere. There's a mauka source." The interviewees reflected on the 1973 and 1975 Bishop Museum surveys ofMLR's 3,200 acres; of the documented 40 caves, nine contained burials. Other tubes were likely used as shelters or storage, and some containing fishhooks. It was noted that not all findings were published; information was withheld at the time, possibly to protect sites from being damaged or looted. The recommendation today is clear: surveys should be thorough and fully documented to preserve the integrity of the cultural record. Overgrowth of kiawe over the last 50 years has likely obscured sites, while fire has also posed threats. About 15-20 years ago, fire crews called upon these cultural stewards to guide them, preventing damage to sensitive places. In one instance, a fire truck driver stoppped instinctively just before running over petroglyphs-an example of intuition protecting wahi pana. The consultants also recalled their time in the 1970s Hawaiian cultural studies program at the University of Hawai'i, where they and their peers composed mele to honor wahi pana at Kalahuipua'a and Ka'iipiilehu. These mele were featured through Ka Leo Hawai 'i, and that practice evolved into Twilight at Kalahuipua 'a, commemorated for nearly three decades. Stories of trails and night marchers also surfaced. The old Brown cottage once sat directly on a mauka- makai trail, and was said to be crossed by night marchers through the middle room. The old cowboys would playfully test newcomers by placing them in the room aligned with the marchers' path. Mauka trails such as Pu'u Ku'ainiho extended makai, underscoring the interconnectedness of mauna (mountain) and kai (ocean). The consultants highlighted examples of displacement and disregard for cultural integrity during resort development. At the Fairmont, an ahu was dismantled and rebuilt in a new location to make way for construction, undermining its original significance. That ahu marked Kamilokiikahi (the lone standing milo ), a place-name later shortened to "Kamilo" by the resort. The milo itself had once grown a Hila (branch) pointing directly toward Lalamilo---literally meaning "milo tree branch"-a detail indicating the precision of cultural placement. They felt very strongly that ahu should not have been moved and the full name should have been used, as traditional names are purposeful. Finally, the mo'olelo of Pualenalena, the dog, was shared. Known for stealing 'awa for his master and ultimately redeeming himself by retrieving the stolen pii (conch shell) from the menehune, Pualenalena's story ties Waipi'o Valley to Puako. The pii, Kihapii chipped during the chase, remains preserved today at Bishop Museum-a tangible reminder of the enduring connection between story and place. Together, the recollections of these cultural advisors paint layered imagery ofPuako and Kalahuipua'a with burials, trails, petroglyphs, wahi pana, and spiritual presence. They are landscapes that once gathered ali 'i and communities and that continue to demand kuleana, respect, and protection. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 14 of42 Dr. Patrick Von Kirch ASM Cultural Specialist, U'i Kiiali'i, also conducted a phone consultation with Dr. Patrick Von Kirch on August 7, 2025. The following summary reflects his recollections and sentiments regarding his early work in the Kalahuipua'a and Puako regions. Dr. Patrick V. Kirch received his PhD in 1975 and was soon hired by Bishop Museum, where he worked until 1984. At the time, Kirch had already been involved in projects with Bishop Museum which then functioned as Hawai'i's largest Cultural Resource Management organization. The 1973 survey conducted by the Museum encompassed a broad area of the Kalahuipua'a/Puako region, while the 1975 survey work concentrated around the fishponds, which were slated for hotel development. Kirch remembered the pahoehoe landscape of the project area as "bare lava ... hot, super hot." The fishponds stood out as the heart of the region. He recalled them as Francis 'I'i Brown's private retreat, maintaining exclusive control as an ali'i decendant who inherited the property through John Papa 'I'i. According to Kirch, Kalahuipua'a was essentially a private reserve in the early twentieth century, where maka'ainana were not welcomed unless specifically invited. This seclusion meant that the Bishop Museum team had little contact with local communities or cultural practitioners during their fieldwork. Instead, their interactions were limited to a land caretaker associated with the Browns. Unlike other projects where kiipuna taught him protocols, this survey was conducted in relative isolation by a small team of archaeologists. Despite these circumstances, certain discoveries left lasting impressions. Near the ponds, the team investigated a collapsed lava tube that revealed petroglyphs and evidence of prior habitation. Deep within its narrow chambers, they uncovered a cache of 16 wooden shark-fishing hooks, an extraordinary find Kirch describes as unique in his career. He interpreted them as belonging to a specialist fisherman who never returned to reclaim his tools. In another lava tube nearby, the team documented at least 29 burials, including one individual interred in a wooden canoe hull. Out ofrespect, the 'iwi were left undisturbed; the site was blessed by Reverend Leon Sterling, and the entrance was sealed. Kirch recalled this with reverence, describing it as one of the most distinctive sites from the project. Within the parcels that today form part of MLR, Kirch remembered the kiawe overgrowth as so dense that it hindered survey efforts: "It was the densest kiawe I'd ever seen." While some sites were recorded, he alluded to the possibility that additional cultural features may have been present but obscured beneath the thickets. His own strongest memories, however, remained tied to the fishponds, which he described as the focal point of both the cultural landscape and his field experience. Kirch has only returned once to Kalahuipua'a since the 1970s during the preparation of his and his wife's book, Legacy of the Landscape (1993). He expressed sadness at what he saw, recalling how the once tranquil fishponds and coconut groves had been overtaken by paved roads, parking lots, and hotels: "I remember the place when it was still what it was-beautiful ponds, coconut palms, peaceful and tranquil...! don't want to see it like that. I want to remember it the way it was." When asked about assessing cultural significance in such a heavily modified place, Kirch admitted he had little to offer: "I think that place is so modified. I really dont have an answer for you on that." Kirch's reflections emphasized the integrated nature of Kalahuipua'a's cultural and natural systems. He described the fishponds and anchialine pools as part of a larger ecological and cultural web, explaining that changes mauka-such as golf course irrigation-could alter the delicate freshwater flows that sustained the ponds. He also emphasized that makai sites like Kalahuipua'a and 'Anaeho'omalu were resource-rich oases once connected to mauka farming systems in an integrated regional network. The lava tubes and shelters near the ponds contained deep midden deposits, evidence of centuries of habitation linked to intensive fishing. He further noted the makai trail system, including straightened trails across the Kanikii flow, which were constructed in the early nineteenth century using prison labor under laws enforced by Ka'ahumanu and later Kina 'u. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 15 of42 ANALYSIS AND MITIGATIVE MEASURES This section of the report provides an analysis within the three-part Ka Pa'akai O Ka 'Aina framework. Part 1: Identify whether any valued Cultural, Historical, or Natural Resources are present within the petition area, and identify the extent to which Traditional and Customary Native Hawaiian Rights are exercised The culture-historical background, in conjunction with previous archaeological surveys, cultural impact assessments, and the mana' o shared by interviewees regarding this area of Waikoloa Ahupua' a indicates that most precontact sites within or in close proximity to the PA were resource acquisition sites, where resources were gathered, temporarily processed, or transported to support fishing and other marine-based activities. The trails used by early Hawaiians in these areas were likely unrestricted trails over pahoehoe sections of lava, and which enabled Hawaiians to travel between mauka and makai destinations to access diverse resources, including fresh water, plant materials, and coastal fish and shellfish. Limited agriculture occurred in this area. Beginning in the early twentieth century, the area was used as grazing land for cattle, which further altered the historic landscape. The area is also connected to traditional mo'olelo regarding the two dominant lava flows, Kanimoe and Kanikii. While the cultural landscape referred to in the consultations above has been described and is understood by its physical features, "the Hawaiian cultural perspective adds a non-physical dimension to the cultural landscape, and the landscape becomes imbued with cultural meaning and value ... " Hawaiians also distinguished between wao kanaka (zone or region of man) from wao akua (zone or region of deities). Further, the landscape is animated with mana (spiritual energy): "Acts of the past that occurred in the area -people worked and prayed everyday-strengthened the mana of the place. So it's still there" (Fielder 2011:25). The project area and its surrounding landscape contain a range of valued resources with cultural, historical, and natural significance. These resources are deeply interwoven, with historical use informing cultural identity and natural features enabling traditional practice. While categorized below for clarity, these domains are not mutually exclusive. Historical Resources Numerous archaeological and historical features have been identified in the Puako-Kalahuipua'a region and its coastal corridor, underscoring the long-standing human presence and traditional land use patterns. Site types recorded in the coastal portions of Puako consist of caves (lava tubes), petroglyphs, cairns, trails, rock and cave shelters, refuge caves, burials, a holua slide, and features associated with both temporary and permanent habitation, including house platforms, overhangs, terraces, modified outcrops, paved areas, U- and C-shaped enclosures, sinkholes, walls, and rubble excavation areas. Coastal and inland (mauka/makai) trail networks documented throughout Kohala Hema were most likely used for coastal travel between ahupua'a and to facilitate resource extraction and exchange between the coastal areas and the upland agricultural fields. The absence or minimal presence of agricultural features in this coastal zone suggests an occupational emphasis on the extraction of marine resources (Rechtman 2014). Prior archaeological inventory surveys conducted within the footprint of the current PA and the PA vicinity indicate that numerous historic properties related to traditional Hawaiian cultural practices and customary native rights exist within this area (see Figure 14). Wolforth and Huber (2007:30-31) hypothesized that peripheral evidence would likely indicate the presence of significant resources within the PA: Three parcels to the west of Site M provide insight into types and distributions of archaeological resources that can be expected within Site M (Jensen 1989; Burgett et al. 1998; Wolforth and Wilson 2004). The sites to the west of the Site M project are dominated Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 16 of42 by abrader basins. An unquantified "extensive area of abrader basins" (Jensen 1989:32) ... The inventory offeature types at the Parcel K project area (Burgett et al. 1999) and Brookfield Homes project area (Wolforth and Wilson 2004) are indicators of what to expect in the Site M project based on the proximity of the two projects and the continuity of terrain. There are many abrader basins on the project. There are also a considerable number of small caves. These are not tubes. Rather, they are small blister areas with openings to the surface. The documented sites identified by Wolforth and Huber (2007) included pahoehoe excavations, C-shaped structures, abrader basins, and a complex. Kirch explains the scoriaceous lava of the PA was extensively used for abraders, and literally thousands of man-made depressions in the pahoehoe are the result of abrader manufacture (1979:8-9). Trails were the arteries connecting coastal and inland settlements, facilitating resource acquisition and communication and trade between communities. It is likely, given the landscape of the PA, that trail systems would have been categorized as unrestricted trails: These flows are smooth, light brown, ropey pahoehoe with a relatively level surface. This surface facilitated walking. There are no large crevices, and no need to create filled-in stone pathways. This surface does not show any alteration due to trampling, however. Consequently, there is no identifiable pathway on these older flows. Unlike the Restricted Trails on the Kanukii flow, the lack of visible pathway on the surface precludes the ability to interpret the intensity of use on the Unrestricted Trails (Wolforth 2007:19). Cultural Resources In his 2007 cultural assessment of Site M, Thomas Wolforth characterized the area as having limited cultural significance, framing it as peripheral to the more notable and concentrated traditional activities found along the shoreline and in petroglyph fields beyond the PA boundaries. Although Site M contains evidence of past uses such as abrader basins, quarries, temporary shelters, and minor trail segments, these features are presented as indicators of sporadic or marginal precontact occupation. Wolforth (2007) further notes the absence of ongoing cultural practices such as subsistence gathering, religious ceremonies, or recreation within the area today, without addressing how changes in land access or historical development patterns may have contributed to that absence. Though it may appear that cultural practices are no longer actively occurring in the PA, this perception is rooted not in a lack of historical or cultural significance of the area, but rather in the impacts of past land use and socioeconomic changes. The introduction of cattle, the sandalwood trade, and widespread ranching activities during the nineteenth century displaced many kanaka from their traditional kuleana, leading to the erosion of subsistence agricultural systems and community life. Testimonies from the early twentieth century describe significant environmental degradation that further undermined the viability of traditional practices. By the early 1900s, very few hoa 'aina remained in the Lalamilo area (Haun et al. 2002:96). Historical records and testimonies affirm that neighboring Lalamilo was once a densely populated and actively cultivated region. It likely supported major endeavors, such as agricultural expansion by the Waimea chiefs to sustain large armies and chiefly retinues-most notably, the construction of Pu'ukohola Heiau, which required a vast quantity of laborers. The subsequent decline of these communities was accelerated by foreign commercial interests centered at Kawaihae, which further disrupted cultural continuity. Moreover, some cultural knowledge bearers today continue to honor their traditions through silence, choosing not to share specific practices publicly. Their restraint is not a sign of absence, but rather a reflection of respect for ancestral protocols. In time, as trust and safety are restored, these voices may re- emerge to reaffirm the enduring cultural connection to this land (Haun et al. 2002:96). Within Bishop Museum surveys of the Kalahuipua'a region in the 1970s, researchers documented two of the largest and best-known petroglyph fields in the Hawaiian Islands: Paniau and Kaeo. The Paniau Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 17 of42 complex contains roughly 3,000 individual carvings. Kaeo 1, spans nearly 2,200 square meters of piihoehoe and contains thousands of carvings, the majority depicting human figures. The scale, density, and craftsmanship of the images suggest the site was the focus of distinctive and significant cultural activity (Lee and Stasack 1999: 15 in Wolforth and Huber 2007). Viewed through both artistic and anthropological perspectives, these petroglyphs offer enduring testimony to Hawaiian life in the precontact and early historic periods, their scale indicating the importance of this area (Kirch 1979: 17). Also identified in a 1973 survey was a shelter cave interpreted as a kuahu, or shrine. At its heart rests a raised platform, bearing an upright, waterwom cobble shaped by the hands of time and tide. In precontact Hawai'i, such stones served as tangible embodiments of 'aumakua-family or local guardian spirits- connecting people to their ancestral lineage and the land itself. Shrines like this have been found throughout the islands, each a sacred marker of devotion and identity (Kirch 1979: 17). The idea of a more contemporary form of social paradigm at Site M, the development of resort culture, was introduced by Wolforth (2007). The concept of resort culture at Mauna Lani refers to the practice of commercial development that began with the property's acquisition by Francis H. I'i Brown in 1932 (Wolforth 2007). While not a traditional cultural practice by any means, this form ofland use has become a defining aspect of the area's modem identity. As such, it may serve-if intentionally structured-as a platform for engaging visitors and new stakeholders with the history, cultural narratives, and indigenous concerns tied to the landscape. Natural Resources The PA is presently undeveloped but portions of Site M appear to have been grubbed in the past, which has left much of it relatively open and sparsely vegetated (see Figures 20 and 21). The unmodified ground surface within the project area consists primarily of 'a'a and exposed piihoehoe bedrock terrain from the Kanimoe flow, a Mauna Loa eruption dating between 4,000--5,000 years B.P. This same flow is in the mo'olelo of Kanikii and Kanimoe, which recounts how Pele's forces surged through this coast, leaving behind the distinctive piihoehoe and 'a'a that still define the landscape. Kanikii and Kanimoe, two mo'o (water-spirits with lizard bodies), would take the form of beautiful women and live in the large coastal fishpond of Wainanali'i in Pu'uanahulu. When a lava flow covered the pond, Kanikii and Kanimoe were turned into stone, their bodies remaining in the middle of the 'a'a, lying side by side in the lava flows now known by these names (Maly 2000). The wealth of mo' olelo associated with these two flows indicates their significance in defining this area. While no freshwater resources exist within the PA, four principal fishponds lie on the grounds of MLR: Kaliihuipua'a, Waipuhi, Hopeaia, and Manoku. At Kaliihuipua'a, fish species like mullet and awa were raised and fattened within the ponds specifically for the ali'i; these particular fishponds belonged to Kamehameha the Great. The integrity of coastal resources such as loko i'a depends on the stewardship of inland areas, as the freshwater springs feeding these ponds originate far from the shoreline. Within the PA, vegetation is limited but includes scattered grasses, scrub, and a few tree species: kiawe (Prosopis pallida), niu (Cocos nucifera), milo (Thespesia populnea), and koa haole (Leucaena leucocephala; see Figures 4 through 10). In the broader coastal Puako area, additional species can be found, including pohuehue (Ipomoea pes-caprae), naupaka (Scaevola), and two important plants, noni (Morinda citrifolia) and hala (Pandanus odoratissimus), that hold enduring value for their combined economic, cultural, and ecological roles. Mo'olelo such as those of Kamakanui'aha'ilono and Lonopiiha, along with practitioner testimony, affirm that the makai vegetation that did grow here (including certain salt-tolerant and drought-adapted species) was of cultural and medicinal significance, particularly for la'au lapa'au. Over time, competing land uses have further reduced vegetative presence, limiting gathering opportunities. With attentive stewardship, however, some of these culturally important species could potentially be restored to the area. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 18 of42 Archaeological excavations within cave shelters in the PA vicinity have yielded an exceptional preservation of plant material, providing insight into the vegetation that once thrived in the area and its traditional uses. Species identified from these excavations include niu, which remains common along the shoreline today, and ipu (Kirch 1979:140-144). In traditional Hawai'i, the ipu was intentionally cultivated for a range of purposes. Smaller, thin-walled ipu served as receptacles for water and food, and when fashioned into rattles, their rain-like sound became an essential accompaniment to hula. Larger, thicker-walled ipu were used for storing kapa (tapa cloth) and other goods and were used for drums in hula. Both forms remain integral to hula today, continuing their role as foundational implements in Hawaiian cultural practice. The white flesh of immature ipu could be eaten, and certain varieties with a bitter pulp were specifically set aside for medicinal uses (Pukui and Elbert 1986). The presence of kukui (candlenut) suggests use for both illumination and food preparation, as it was traditionally mixed with fish and seaweed (Kirch 1979: 140-144). In Hawaiian tradition, the kukui tree holds both practical and symbolic significance. Its soft, workable wood was shaped into canoe components, while gum from its bark was used to paint kapa. The outer coats of its nuts, as well as its roots, provided a rich black dye. Fishermen seeking uhu (parrotfish) sometimes chewed the nuts and released them into the ocean to help still the waters. Polished kukui nuts are strung into lei, and its silvery-green leaves and delicate white blossoms are also fashioned into adornments. Beyond these physical uses, kukui is regarded in Hawai'i as a symbol and activator of enlightenment-its light, both literal and metaphorical (Pukui and Elbert 1986). Hala and 'awa (Piper methysticum) were also found, pointing to their roles in both ceremonial and daily life (Kirch 1979:140-144). Hala has long been valued in Hawaiian culture for its versatility. The tender tips of its young aerial roots were used medicinally. It's tough yet flexible lau hala (leaves) were, and continue to be, expertly plaited into a range of durable items: floor and sleeping mats, baskets, fans, and special sandals for traversing lava. The brilliantly colored keys of the 'ahui hala (hala fruit) are used as brushes and to make lei, adding visual richness to ceremonial adornment (Kent 1986). 'Awa has been a crucial component of ceremonies and festivals as a valued source of a narcotic drink and medicine for hundreds, if not thousands, of years. Particles of its root mixed with water produce a drink worthy of offering to the akua. Cordage or bundle wrapping found was likely accomplished using leaf material from lii'I (ti leaf) and 'awapuhi (ginger)-plants associated with food preparation, medicine, and ritual (Kirch 1979:140-144). 'Ilima (Sida fa/lax), identified from floral remains, remains dominant in the Kalahuipua'a landscape and was known for its ornamental use, especially in lei. 'Ilima is also a mild laxative for keiki. Other material such as pili (Heteropogon contortus), used in traditional thatching, and seeds of milo, a species prevalent around the fishpond, further emphasize the functional relationship between native vegetation and the daily lives of the region's early inhabitants. The presence of these plants within shelters and habitation areas reflects both the adaptability of traditional practices and the ecological knowledge required to thrive in such an environment. These findings not only highlight the range of plant-based resources historically available but also affirm the cultural ingenuity in utilizing local and imported flora to sustain life and ceremony within this storied coastal landscape. Part 2: Identify the extent to which those resources and rights will be affected or impaired by the proposed action The Proposed Manna Lani Site M Development Project will result in the creation of new hotel and residential units and associated amenities across the majority of the two subject parcels. Based on the cultural, historical, and natural resources identified above, and the scope of the proposed development, the following is anticipated: Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 19 of42 The trail system(s) throughout the project area that were utilized to access resources were unrestricted, and therefore, undefined. As such, the current proposed action does not appear to have a direct impact on these undefined trails. While there is no clear existing mauk:a-makai trail throughout the PA, it is important that the proposed development activities do not impact or restrict mauk:a-makai access or impede view planes in the construction of new facilities. No resource acquisition is actively occurring with the project area; therefore, the proposed action would have no direct impact on this practice. Numerous uncharted caves and subsurface features exist throughout the region. These caves are not always visible on the surface or recorded in prior surveys, and several have been discovered inadvertently during excavation. Therefore, while unlikely, there is a risk of impacting undocumented subsurface features, especially given the historic record of burials in lava tubes nearby. While other parts of Waikoloa Ahupua'a are known for extensive agricultural complexes, no surface agricultural features have been identified in the PA Thus, the authors do not anticipate any impact to traditional agricultural practices or any associated agricultural features. The ecological state of the parcels is currently degraded, with invasive species dominating much of the area. Therefore, the authors do not anticipate any significant impact of the proposed action on existing flora. The proposed development does have the potential to directly impact the natural resources of the area by increasing usage of freshwater, an already scarce resource. Freshwater flows and subterranean hydrology are part of interconnected systems that sustain the land and the people. Impacts to any part of this system, whether physical alteration, contamination, or diversion, all have cascading effects that extend beyond the immediate footprint of development. While no visible cultural practices are currently exercised within the proposed PA, this absence is not evidence of lack of significance. The primary cultural concern with additional development is further detachment from cultural narratives and stewardship ethics. The more contemporary practice of resort culture introduced by Wolforth (2007), while not a traditional cultural practice, has become a defining aspect of the area's modem identity. The proposed action will not negatively impact this practice. Part 3: Specify any mitigative actions to be taken to reasonably protect Native Hawaiian rights if they are found to exist. To reasonably protect Native Hawaiian rights associated with the proposed action and to uphold the kuleana of cultural stewardship, incorporation of the following considerations into planning, implementation, and mitigation phases is recommended. ASM engaged in consultation with community members who maintain deep and long-standing pilina with the region, whether through ancestral lineage, generational residence, cultural practice, or sustained engagement. These discussions were centered on the cultural, historic, and environmental implications of both historical and proposed developments. Participants raised mana'o rooted in intimate, lived knowledge of the land. The following themes emerged consistently across conversations and offer crucial guidance for respectful planning and long-term stewardship: 1. Conduct thorough and inclusive cultural and archaeological surveying During consultations, interviewees recalled the archaeological surveys of 1970s, noting that the dense kiawe forest in the PA at the time severely limited visibility and access. This view is supported by Reinecke's (1930:30) earlier observation of the area: "here the growth ofkiawe along the shore is so dense that it was useless to attempt any survey of sites unless one had a base near." This overgrowth had prevented a complete assessment of the land, leaving portions unexplored. Interviewees stressed that the absence of documented sites from those earlier surveys should not be misinterpreted as proof that none existed. Furthermore, each consultation conducted yielded the concurrence among all members that not all findings from the 1973 and 1975 surveys were included in the final reports. Given the concentration of significant Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 20 of42 features, such as caves, trails, petroglyphs, and burials, identified in immediate surrounding areas, they maintain it is possible that similar undiscovered sites remain within the PA boundaries. Community members emphasized the critical importance of acknowledging that numerous uncharted caves and subsurface features exist throughout the region. To assume otherwise is to disregard both the physical evidence of the broader cultural landscape and the lived expertise of those who know this place intimately. They stressed that, as these caves are not always visible on the surface or recorded in prior surveys, several have been discovered inadvertently during excavation, often when it is too late to avoid disturbance or irreversible damage. Such features can contain a range of historical and cultural resources, including ancestral burials, evidence of habitation, and material deposits that speak to centuries of land use and stewardship. The presence of these undocumented subterranean spaces amplifies the need for heightened caution, early consultation with knowledgeable community members, and proactive site assessment prior to any ground disturbance. Recognizing the likelihood of encountering these concealed historical resources is foundational to protecting the integrity of the cultural landscape and honoring the responsibility to preserve what remains unseen but not forgotten. In sum, community members stressed the need for cultural and archaeological surveys that are truly comprehensive, not limited by artificial boundaries, ease of access, jurisdictional constraints, or assumptions of irrelevance. Cultural landscapes do not conform to modem property lines. Meaningful survey efforts must account for the broader historical and cultural context in which practices and features exist. Importantly, cultural sites often extend beyond what is immediately visible or formally documented This includes inaccessible or marginal areas such as old trail alignments, agricultural remnants, ahu (shrines), or view plane connections. To survey with integrity is to see with cultural eyes-to recognize that the land still speaks, even in places where its voice has been buried, obscured, or overlooked. Anything less risks missing not only physical features, but the living memory embedded in place. 2. A void relocation or disturbance of significant cultural and archaeological features The message from the community was firm and unwavering: cultural sites are to be left in situ, undisturbed, and intact. Development should protect and incorporate the presence of ahu, burials, petroglyphs, and other wahi pana. These are not remnants of a distant past but living anchors of ancestral presence-sites of memory, identity, and spiritual continuity. Cultural sites are not negotiable. They should not be viewed as inconveniences to be relocated or reinterpreted. They are fixed truths in the landscape, deserving of protection and reverence. To disturb them is to sever a thread in the fabric of generational memory. Stewardship demands more than avoidance; it requires humility, accountability, and the recognition that in these storied places, we are not the first nor the last. Any development that compromises their presence undermines both cultural survival and community trust. Protection of these resources is not just a recommendation; it is a responsibility. 3. Identify, document, and preserve traditional trail systems The importance of trail systems was repeatedly emphasized. Trails are not merely physical corridors but are imbued with cultural memory. Traditional trails are not simply remnants of travel; they are imprints of ancestral movement etched into the land through generations. Historically, these ala hele connected not just places, but people, purpose, and ceremony. They were routes of fishermen, farmers, messengers, ali'i, and kia'i; the paths to kuahu, gathering grounds, neighboring ahupua'a, and distant heiau. These paths record knowledge, relationships, and responsibility. Their cultural value has not diminished over time. Even when overgrown, faint, or obscured by modem development, these pathways remain part of the living landscape and deserve recognition and protection. Knowing where they are, including those partially buried or seasonal in nature, is vital to maintaining the cultural integrity of the broader region of which it lies. They must be identified, mapped, and safeguarded; not blocked, severed, or repurposed in ways that erase their historical and cultural functions. To preserve trails is to preserve access, not only to place, but to lineage, memory, and kuleana. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 21 of42 Portions of the project area, particularly the northern boundaries of Site M which lie outside of the proposed development area, if left undeveloped could serve as preserved open space; this would ensure that view planes are maintained while also providing unobstructed mauka-makai access throughout the property. 4. Recognize the kuleana of all parties involved A particularly resonant point raised during consultation was the shared kuleana among all stakeholders, community members, landowners, developers, and government agencies-to act with respect, humility, and cultural awareness. As one participant stated, "Our kuleana is to make you aware that you have kuleana. Your kuleana is to be respectful. There are forces out there we cannot control who will do what they need to do to make things pono." This sentiment reflects both a spiritual and pragmatic understanding: actions taken without care or consent may have consequences beyond the immediate or visible. Respecting cultural protocol is part of sustaining collective well-being. Spiritual accountability exists alongside regulatory compliance. 5. Use full and traditional place names The use of full, traditional Hawaiian place names is essential to honoring the identity and mana of the landscape. Abbreviated, anglicized, or commercialized versions strip a place of its mo'olelo and sever the historical continuity embedded in language. Members expressed that correct naming is not merely a matter of pronunciation or signage: it's cultural stewardship. Hawaiian place names encode history, genealogy, ecological relationships, and spatial memory-they are not arbitrary. Preserving and using them in their entirety is integral to telling their story. 6. Community Engagement The development at Site M may-if intentionally structured---can serve as more than a backdrop for hospitality, and further, as a platform for engaging visitors and stakeholders with the history, cultural narratives, and indigenous concerns tied to the landscape. Responsible action would include the intentional incorporation of Native Hawaiian perspectives and knowledge into all aspects of visitor and stakeholder engagement. Without sustained and deliberate efforts to center these perspectives, the development risks perpetuating a selective or superficial portrayal of the area's culture under the guise of tourism. Currently, there is a notable gap in how knowledge related to the cultural and historical dimensions of Mauna Lani is shared. Those involved in the ongoing development of the area may not always operate with a clear understanding of the site's cultural context-such as the origins of certain resort features, past successes or failures in cultural resource management, or existing Native Hawaiian perspectives. This lack of continuity risks further detaching commercial activity from the foundational history of the area. Although some argue that the continuation of resort culture could be used to preserve and communicate knowledge, this outcome is not guaranteed. Without deliberate effort to document, synthesize, and share relevant cultural information, commercial development is more likely to obscure rather than illuminate the region's heritage. To address this, it has been suggested that developers implement educational programs aimed at orienting staff, visitors, and developers to the specific history and cultural landscape of Mauna Lani. Whether such initiatives can meaningfully bridge the gap between commercial interests and cultural integrity remains uncertain; however, these initiatives may offer a starting point for mitigating the erasure or oversimplification of Hawai'i's past within resort spaces. The goal is to honor rather than rewrite Hawai'i's cultural heritage. 7. Responsible Management of Ecological and Freshwater Resources The existing lands consist of introduced species of buffelgrass, kiawe trees, and koa haole that have smothered the landscape. Reforestation of indigenous and dryland natives such as koaia, iliahi, milo, mamane, a'ali'i, pilo, alahe'e, wiliwili, etc. can re-establish a beneficial ecosystem. Additionally, native Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 22 of42 aquatic plants such as 'ae'ae ahuawa, makaloa, and uki for bio-filtration and sediment control could aid restoration efforts. Thoughtful replanting of culturally significant or native species within the green spaces of the development could support traditional practices, including plant gathering and cultural healing. Maintaining the undeveloped areas within and around the proposed development footprint would also help protect nearby resources, such as Site -24426 and the adjacent Puako Petroglyph Archaeological District (Site -4713), ensuring that opportunities for the exercise of traditional rights are maintained. Four principal fishponds lie on the grounds ofMLR: Kalahuipua'a, Waipuhi, Hopeaia, and Manoku with three smaller ones: Kahinawao, Waipuhi Iki, and Milokiikahi. The number of ponds, water-filled caves, and crevasses between Pauoa Bay and the edge of the Kanikii flow exceeds 20 (Clark 2002: 149; Kirch 1979:9). The integrity of these freshwater and coastal resources, such as loko i'a, depends on the stewardship of inland areas. In the cultural framework, the health of the 'aina is measured holistically, and the protection of interconnected resources is essential to the survival of both the natural ecosystem and the cultural practices it supports. Freshwater flows, native vegetation, and subterranean hydrology are all part of the same interconnected system that sustains both the land and the people. Impacts to any part of this system, whether physical alteration, contamination, or diversion, all have cascading effects that extend beyond the immediate footprint of development. As Kirch explained: The 'aina is a complex web and if you start changing parts of it, you lose the integrity. The whole thing is integrated. Think of those ponds. The water that's coming in them, its fresh water flowing in from underground onto the lava and becomes brackish as it mixes in the ponds, which is the ideal habitat for mullet and other fish. But when you start changing the area inland, putting golf courses on them and what not, who knows now. It would be interesting to know what the ecology of those ponds is like now because they're irrigating that right into the water. The water that was coming in is not the same kind of water. 8. Mindful Building Practices Mindful building practices that focus on minimizing surface and subsurface ground disturbance will help to lessen any potential impacts to cultural landscape, aligning with the Hawaiian values of kuleana and stewardship of the 'aina. This includes placing height restrictions on buildings to ensure view planes are maintained and prevent obscuring any traditional landmarks or locations that are utilized as locational references from both on land and at sea. 9. Fire Safety Initiatives Recognizing fire risk, planned initiatives to mitigate potential risk can include onsite reservoirs (to be used for water drops and firefighting), irrigated areas to provide fire breaks, onsite water trucks equipped with water cannons, and the utilization of resistant building materials. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 23 of42 References Apple, R. and W. Kikuchi 1975 Ancient Hawaii Shore Zone Fishponds: An Evaluation of Survivors For Historical Preservation. Revised 1975. Prepared for Office of the State Director, National Park Service, United States Department of the Interior, Honolulu. Barrera, W., Jr. 1971 Anaehoomalu: A Hawaiian Oasis. Preliminary Report of Salvage Research in South Kohala, Hawaii. Pacific Anthropological Records 15. Department of Anthropology, B.P. Bishop Museum, Honolulu. Beaglehole, J. (editor) 1967 The Journals of Captain James Cook on His Voyages of Discovery. The Hakluyt Society, London. Bowser, G. 1880 Hawaiian Kingdom Statistical and Commercial Directory and Tourists' Guide George Bowswer & Co., Honolulu and San Francisco, CA. Electronic document, http://ulukau.org/elib/co11ect/polk1880/index/assoc/D0.dir/book.pdf, accessed October 8, 2021. Burgett, B., L. McGerty, and R. L. Spear 1999 An Archaeological Inventory Survey of a 22.5 Acre Parcel (Parcel K) in the Ahupua'a of Waikoloa, South Kohala District, Island of Hawai'i (TMK 6-8-22:01,05). Scientific Consultant Services, Inc. Project Number 129-2. Final. Revised July 1999. Prepared for Mauna Lani Resort, Honolulu. Clark, J. R. K. 2002 Costa-Pierce, B. Hawai'i Place Names: Shores, Beaches, and Swf Sites. University of Hawai'i Press, Honolulu. 1987 Aquaculture in Ancient Hawaii. BioScience 37 (5):320-331. Dunn, A. E. and P. H. Rosendahl 1992 Phased Archaeological Inventory Survey, Puako Beach Road Extension Corridor, Land of Lalamilo, South Kohala District, Island of Hawaii. Paul H. Rosendahl, Ph.D., Inc. 975- 050592. Prepared for Paniau Partners, Hilo, HI. Fielder, B. A. 2011 Pomander, A. Cultural Impact Assessment (CIA) for 'Ouli II in South Kohala Island of Hawai'i (TMK (3) 6-2-001:050 and 051). Pacific Legacy, Inc. Prepared for Belt Collins Hawai'i Ltd. 1916-1917 Fornander Collection of Hawaiian Antiquities and Folk-lore. Memoirs of the Bernice Pauahi Bishop Museum, vol. N. Bishop Museum Press, Honolulu. 1996 Ancient History of the Hawaiian People, vol. IL Mutual Publishing, Australia. Handy, E. S. C. 1940 The Hawaiian Planter. Bernice P. Bishop Museum Bulletin No. 126. Published by the Museum, Honolulu. Haun, A. E., D. Henry, and K McGuire 2002 Archaeological Inventory Survey DHHL Residential Development at Lalamilo South Kohala District, Island ofHawai' (TMK: 6-6-01: 10, 54, & 77, and TMK: 6-6-04:12-17). Haun & Associates. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 24 of42 Hawaii Tribune-Herald 1980 Ground Broken. Hawaii Tribune-Herald [Hilo, Hawaii]. October 29, 1980: 1. Electronic document, https:/ /www .newspapers.com. Jensen, P. 1989 Archaeological Inventory Survey, Mauna Lani Cove Project Area, Mauna Lani Resort, Lands of Kalahuipuaa and Waikoloa, South Kohala District, Island of Hawaii. Paul H. Rosendahl, Ph.D., Inc. 588-060589. Prepared for Belt, Collins & Associates, Hilo, HI. Kamakau, S. M. 1961 Ruling Chiefs of Hawaii. Kamehameha Schools Press, Honolulu. 1991 Tales and Traditions of the People of Old, Na Mo 'olelo aka Po 'e Kahiko. Bishop Museum Press, Honolulu. Kent,H. W. 1986 Kimura, L. K. 1968 Kirch, P. V. Treasury of Hawaiian Words in One Hundred and One Categories. Masonic Public Library of Hawaii, Honolulu. Kapalaoa Homestead Life. Unpublished Manuscript. 1979 Marine Exploitation in Prehistoric Hawaii: Archaeological Investigations at Kalahuipua'a, Hawai'i Island. Pacific Anthropological Records No. 29. Department of Anthropology, B.P. Bishop Museum, Honolulu. Lee, G. and E. Stasack 1999 Spirit of Place: Petroglyphs ofHawai'i. Easter Island Foundation, Los Osos, California. Maly, K. 2000 A Historical Overview: Ka 'iii 'Aina of 'Anaeho 'omalu Ma Waimea, Kohala Hema (The Land of 'Anaeho 'omalu, at Waimea, South Kohala) Island of Hawai 'i (TMK: 6-9-07: 15). Maly, K. and 0. Maly 2002 He Wahi Mo'olelo No Ka 'Aina A Me Na 'Ohana O Waiki'i Ma Waikoloa (Kalana 0 Waimea, Kohala), A Me Ka 'Aina Mauna: A Collection of Traditions and Historical Accounts of the Lands and Families of Waiki'i at Waikoloa (Waimea Region, South Kohala), and the Mountain Lands, Island ofHawai'i (TMK Overview Sheet 6-7-01). Kumu Pono Associates, LLC Report HiWaikii61-111202. Prepared for Waiki'i Ranch Homeowner's Association, Kamuela, HI. McElroy, W. K., L. Brandt, and C. Hitt 2016 FINAL-Ethno-Historical Study of the Kalahuipua'a Fishponds, Waikoloa Ahupua'a, South Kohala District, Island of Hawai'i, TMK: (3) 6-8-022:006 (por.), :015 (por.), :048, and :061. Keala Pono Archaeological Consulting, LLC. Revised 2016. Prepared for Group 70 International, Honolulu. Menzies, A. 1920 Hawaii Nei, 128 Years Ago. Honolulu, T.H., Honolulu. Office of Hawaiian Affairs 2018 Kipuka Database. Electronic document, http://kipukadatabase.com/kipuka. Pukui, M. K. and S. H. Elbert 1986 Hawaiian Dictionary: Hawaiian-English, English-Hawaiian. Revised and english ed. University of Hawaii Press, Honolulu. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 25 of42 Pukui, M. K., S. H. Elbert, and E. Mo'okini 1974 Place Names of Hawaii. Revised and Expanded ed. University of Hawaii Press, Honolulu. Rechtman, R. B. 2014 An Archaeological Assessment Survey of a Newly Created 16,661 Square Foot Parcel (TMK: (3) 6-9-002:031, Llilamilo Ahupua'a, South Kohala District, Island of Hawai'i. ASM Affiliates Project Number 22020. Final Version. Revised April 2014. Prepared for Lisa Treadwell, Hilo, HI. Reinecke, J. 1930 Survey of West Hawaiian Sites: From Kailua, Kona, to Kalahuipuaa, Kohala. Department of Anthropology, B.P. Bishop Museum, Honolulu. 1930. Rosendahl, P. H. 2000 Archaeological Inventory Survey of TMK 6-8-01:22, Land of Waikoloa, South Kohala District, Island of Hawai'i. Paul H. Rosendahl, Ph.D., Inc. 2017-072000. Revised 2000. Prepared for White Sand Beach LP, Tinguely Development, Hilo, HI. Smart, C. 1964 Soehren, L. 2010 A Report of Excavations on Site H22, Puako, Hawaii Island. Revised 1964. Prepared for B.P. Bishop Museum, Honolulu. Hawaiian Place Names. Ulukau: The Hawaiian Electronic Library. Electronic document, http://ulukau.org/cgi-bin/hpn?, accessed September 14, 2016. Tomonari-Tuggle, M.-J. 1982 An Archaeological Reconnaissance Survey of a Parcel Adjoining the Puako Petroglyph Fields, Puako, Hawai'i. Revised 1982. Prepared for Waimea Hawaiian Civic Club and Mauna Lani Resort. Wolforth, T. 2003 Burial Treatment Plan for Inadvertent Discovery of Human Remains at the Fairways of Mauna Lani, Waikoloa, South Kohala, Hawai 'i Island. Scientific Consultant Services, Inc. Report 411.1. Prepared for Stanford Carr Development, LLC. 2006 Monitoring Construction at the Fairways of Mauna Lani TMK (3) 6-8-022:5. Scientific Consultant Services, Inc. Report 456.1. Revised March, 2006. Prepared for Stanford Carr Development, LLC. Wolforth, T. R. 2005 An Inventory Survey Report for the Brookfield Homes Development: Investigation into Patterns of Resource Expoloitation of the Lower Elevations of the Kaniku Flow in Waikoloa Ahupua'a, South Kohala, Hawai'i Island, Hawai'i, [TMK: 3-6-8-22:7 and 41]. Scientific Consultant Services, Inc. Project 471-2. Prepared for Brookfield Homes Hawai 'i, Inc., and SCD ML II, LLC, Managed by Stanford Carr Development, LLC, Honolulu. 2007 A Cultural Impact Assessment for Site M in Mauna Lani: Waikoloa Ahupua'a, South Kohala District, Hawai'i Island, Hawai'i [TMK: 3-6-8-1: 54 and 3-6-8-22: 10]. Wolforth, T. R. and S. Huber 2007 An Inventory Survey for Site M in Mauna Lani: Investigation into Resource Exploitation Patterns in the Lower Elevations of the Kaniku Flow in Waikoloa Ahupua'a, South Kohala District, Hawai'i Island, Hawai'i, [TMK: 3-6-8-1:54 and 3-6-8-22:10]. Scientific Consultant Services, Inc. 514-2. Prepared for Stanford Carr Development, LLC, Honolulu. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 26 of42 Figures 0 300 Km I I ~ +----+---- 199000 0 N A c:J Project Aren C E A :woooo '.::01000 Figure 1. Project area location. N A ,'vlcters "" ~03000 AFFILIATES ~0-1000 :!05000 Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 27 of42 N A c:J Project Area Hawai'i County Parcels 0 Figure 2. Project area location. N A N w w -...I ~ .i::., ~o 0 ~~ ~ :! c:, :t fi~ ~ :! C: z ~ ... Vi u, 1,-1, cl :il i i5 5! ~ C: :;;: ~ l.:n,/oon 'sanvrn~~~'J.....-;l~l 9 F'>Jed I Jw/oo s~g.aya-n•q1u11 t1lt's+ai;l~S{f,aWo1.jV-i_J s ldllJl!'d b•Joat•m,.,,.-g,t'slfwnnn '1i•1:tP~•ts/~"lf"M"il t,, p:.!J~d bvl~!'ln ~t"R.a-.1·tt'Q,in~t- •n~is t '1' 1 .. ftlllil p:i,<>ff; I 11£1""-"'d b,:fs1~0 ?'!tT~~t•9,:'11_1wnoll 'nJJG1St'tlu!Pf"lll1\0H) VfP:JJl>d (::,wJna,'1:my.-z1'Slfu.n YlQJ's}"H p~qs /H--,.-1) Z(.llilllfd bv/na 1 'nJJV L 'Qf"l1 ,s•n•1:1paip~p:>~il llill:>Jl!:d ON:1931 Figure 3. Conceptual plan for the proposed Mauna Lani Site M. development (map derived from client). ~ o? "' [ r '"O ~ I>' I>' (JQ (1) '"O N I>' 00 pi' 0 [ Hi .i,.. ~ N I>' '< "' tn· 8' .... ),,-z f D t""' :::,0 ~-t ► ~ g -(1) _S;:: ~ 0 =::r' e:.. J>' ~ ~ e: . .... ,1,, ~ Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 29 of42 I I // Figure 4. Southern boundary of Site M along Ho'ohana St, view to the southwest. Figure 5. Eastern boundary of Site M., view to the east. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 30 of42 Figure 6. Boundary of Site M along the Mauna Lani North golf course, view to the northeast. Figure 7. Western boundary of Site M along N. Kaniku Street, view to the south. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 31 of42 Figure 8. Overview of the southern portion of Site M, view to the east. Figure 9. Overview of the northern portion of Site M, view to the south. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 32 of42 Figure 10. Access road along the northern boundary of Site M, view to the east. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 33 of42 n C: d WAIMEA SOUTH kOUA LA 11.JJ J1;;1 n \. .S.,.,,.,1 JU( Jiu p u " . N 0 T Figure 11. Registered map 712 (1866). ,..,.. . 0 . ·. 0 A H u L u X 0 - ,._ 4 ► . I 1 ~1'"' I. ~ ~ ✓ ► 'Q -1, ),- 0 Q '1,. .... r~" •" l. ... "-·~ " ... :, A,r;; ~ h-4-t ..... !I: " .-.c.,, .... .f':_, __ < < .. . ,,. .... ,,,_ • i: .. • _1. .. - < < 0 --,.. ..... •-I: ;,:•-- ~ .,, ...... f,_\. ...., ... N A Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 34 of42 0 .... 300 Krn N A c:J Projcd Area Pa.ti.i:Ja. K~wa.,w,i 11on,1;KQ,,u"e Ba,. ,'11 .......... loA! .. m.-(U.1<, Ka.•11.av N A :u K1lomcrcrs AFFILIATES D Public Lands. [7 Homll'ls\~a,(l Se:Ulean,nt Tre.ctB-. • ...J □ C Approxi'.mato .'\.rea of Grazipg Lattds. A.pproXlma.te Area oi Pint:11.pple Lwids, Appro:iiimat& Area. uf Su!(al· PlaDrn.tions., Appro,.irn.ate Are1,. cf Forec-11 Landi! n~t in He.serve,. School8, PO!.t Offlet.-s. Figure 12. Section of J.M. Donn's (1901) map, "specially prepared for Governor's Annual Report, Illustrating Conditions as of June 30, 1906" (approximate location of the project area in red). Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 35 of42 Figure 13. Historic aerial imagery of the PA vicinity (1954). Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 36 of42 0 no/a, 300 Km I I N A c::J Pn~jccL Arca LJ Burgett et. al 1999 LJ Jensen 1989 c::J Kirchl979 Wolforth 2005 ~ \Vol forth and Huber 2007 LJ Rosendahl 2000 r.-.i Puoko Petroglyph ~ Archaeological Dis.trier .. . .,.. ------AFFILIATES HAWAII COUNTY 400 APRX; 4845U \'1:.mn.il.ani l.iyout. lnvestig;:itions Figure 14. Previous Archaeology in the vicinity ofMauna Lani Mauna Lani Site M. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 37 of 42 IR / N "' J9 fQ '3 ., lll )0 i;EAM;.rUOUIA 66 61 60 511 f lg. 10. LOCATION MAP OF SITES jM KAl.AHU I U 'A (El ) A~D WAI KOLOA (E2). Figure 15. Kirch 1979 Location Map of Sites in Kalahuipua'a and Waikoloa. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 38 of 42 N c:] Pn~jcct Arca A -Site Boundary 0 N A Figure 16. Site Distribution from the recent LRFI study (Jaques, in draft). Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 39 of42 Figure 17. Site 24432, Feature 13 -C-Shaped Structure. View to the east. Figure 18. Site 24430 -Abrader Basins, Features 1 and 2, view to the north. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 40 of42 Figure 19. Example of a non-site cave (T-2) within the proposed project area, view to the west. Figure 20. Example of bulldozer disturbance within Site M, view to the southeast. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 41 of 42 Figure 21. Example of bulldozer disturbance within Site M, view to the southwest. Figure 22. Burnt coconut grove within Site M, view to the northeast. Ka Pa 'akai Analysis for Mauna Lani Site M, Kohala, Hawai 'i Page 42 of42 0 300 Km I I I N A CJ Project Arca Sitt.' Boundary Figure 23. Site Distribution within the proposed Mauna Lani Site M conceptual plan. AFFILIATES APPENDIX I Wilson Okamoto. Preliminary Engineering Report for Mauna Lani Site M Preliminary Engineering Report Mauna Lani Site "M" Waimea, Hawaii TMK: 6-8-022:010 and 6-8-001 :054 Prepared For: DHL Mahi OpCo, LLC 235 Montgomery Street, Suite 1130 San Francisco, CA 94104 Prepared By: Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400 Honolulu, Hawaii 96826 woe Job No. 10704-01 February 2007 (Revised August 2025) Mauna Lani Site "M" Preliminary Engineering Report TABLE OF CONTENTS EXECUTIVE SUMMMARY ....................................................................................... iii 1. Introduction .................................................................................................... 1-1 2. Sanitary Sewer System ................................................................................. 2-1 2.1 Background ............................................................................................ 2-1 2.2 Existing Conditions ................................................................................. 2-1 2.3 Projected Demands ................................................................................ 2-1 2.4 Proposed Improvements ......................................................................... 2-3 3. Potable Water System ................................................................................... 3-1 3.1 Background ............................................................................................ 3-1 3.2 Existing Conditions ................................................................................. 3-2 3.3 Projected Demands ................................................................................ 3-2 3.4 Proposed Improvements ......................................................................... 3-2 4. Site Grading, Flooding, and Storm Drainage System ................................. 4-1 4.1 Background ............................................................................................ 4-1 4.2 Existing Conditions ................................................................................. 4-1 4.3 Project Demands .................................................................................... 4-1 4.4 Proposed Improvements ......................................................................... 4-4 5. Parking and Roadway System ...................................................................... 5-1 5.1 Background ............................................................................................ 5-1 5.2 Existing Conditions ................................................................................. 5-1 5.3 Project Demands .................................................................................... 5-1 5.4 Proposed Improvements ......................................................................... 5-1 6. Other Utilities ................................................................................................. 6-1 6.1 FuelSystems .......................................................................................... 6-1 APPENDICES Preliminary Engineering Report i Mauna Lani Site "M" Preliminary Engineering Report FIGURES Page Figure 1-1 .... Vicinity Map ...................................................................................... 1-2 Figure 1-2A .. Tax Map Key .................................................................................... 1-3 Figure 1-28 .. Tax Map Key .................................................................................... 1-4 Figure 2-1 .... Existing Sanitary Sewer System ....................................................... 2-2 Figure 2-2 .... Conceptual Sanitary Sewer System ................................................. 2-4 Figure 3-1 .... Existing Water System ..................................................................... 3-2 Figure 3-2 .... Conceptual Water System ................................................................ 3-4 Figure 4-1 .... Topographic Map .............................................................................. 4-2 Figure 4-2 .... Flood Insurance Rate Map ............................................................... 4-3 Figure 5-1 .... Existing Roadway System ................................................................ 5-2 Figure 5-2 .... Conceptual Roadway System .......................................................... 5-3 APPENDICES Appendix A Proposed Sewage Design Flow Calculations Sewer Info Request Letter submitted August 13, 2025 HAWC Response received August 22, 2025 Appendix B Proposed Potable Water Demands Calculations Water Info Request submitted August 13, 2025 Appendix C Preliminary Drainage Study Preliminary Engineering Report ii Mauna Lani Site "M" Preliminary Engineering Report EXECUTIVE SUMMARY In 2007, a preliminary engineering assessment of the proposed Mauna Lani Site "M" development was conducted to: (1) review the site infrastructure and utilities systems, (2) determine project demands (3) identify possible constraints, and (4) describe proposed improvements to sanitary sewer, potable water, storm drainage, parking, roadway, electrical, telephone, cable, and data communications systems. This 2025 version is updated with the current values, information, and goals. Sewer: Based on the anticipated additional sewage flows of approximately 160,510 gallons per day, the private sewage treatment plant servicing the Mauna Lani Resort (MLR) will require improvements to increase the facility's filtration capacity. Anticipated improvements include an on-site underground gravity sewer collection system, sewage pump station(s), sewer force main, and the extension of the sewer force main to the sewage treatment facility. Water: Potable, irrigation, and fire protection water service will be available from the municipal water system operated by the County of Hawaii's Department of Water Supply (DWS). Based on the expected water demand of approximately 577,600 gallons per day for the residential and hotel units, DWS' municipal has adequate capacity. Potable water service and fire protection lateral connections for each parcel will be made to either the existing 12-or 24-inch water main in North Kaniku Drive and Ho'ohana Street located along the eastern boundary of the Site "M" project site, respectively. The new connections will likely include new combination domestic and fire protection meters and backflow prevention devices. Options for irrigation water source include potable water connection to the DWS system, connection to MLR's brackish water system, installation of a new brackish water well, and use of treated effluent from the MLR wastewater treatment facility. Connection to DWS' system will require separate service lateral connections and meters for each parcel. Site Grading. Flooding. and Storm Drainage System: Existing topography within the project is characterized by mild slopes. Site elevations range from 80 feet above Mean Sea Level, on the southwest corner near North Kaniku Street, to 40 feet above Mean Sea Level on the northern end of the project site. Drainage can be accommodated through underground drain lines and catch basins, connected to drywalls, retention basins, or injection wells. Preliminary Engineering Report iii Mauna Lani Site "M" Preliminary Engineering Report Parking and Roadway System: The proposed access to the project site is proposed along Ho'ohana Street and North Kaniku Street adjacent to the project. Approximately 1,871 parking stalls will be provided by at-grade parking lots and covered parking garages. Preliminary Engineering Report iv Mauna Lani Site "M" Preliminary Engineering Report 1. INTRODUCTION This report presents the preliminary engineering assessment of the project's infrastructure and utility systems. The objective of the report is to review existing infrastructure systems, determine project demands, identify possible constraints based on the projected demands, and describe proposed improvements related to sanitary sewer, potable water, storm drainage, and parking systems. The proposed improvements are subject to change based on refinement of plans and availability of more detailed information. OHL Mahi OpCo, LLC ("OHL Mahi") intends to develop a 149.9-acre property located within the northeast boundary of the MLR area, in South Kohala on Hawaii island. The project site is bounded by the Mauna Lani North Golf Course to the west, Ho'ohana Street to east, North Kaniku Street to the south and undeveloped land to the north. See Figure 1-1, Vicinity and Location Map. The project site is located by TM Ks (3)6-8-022: 010 and (3)6-8-001: 054. See Figures 1-2A and 1-28. The project area is divided into 7 development parcels that are anticipated to consist of 551 for-sale residential units, 374 hotel rooms, and associated amenities, such as recreation areas, pools, landscaped gardens, water features, and at-grade parking lots. Preliminary Engineering Report 1-1 PROJECT VICINITY ISLAND OF HAWAII • o Pahi H, KfJel ,e Papakona oot L~ndin N~13/1k11 ( , .. t::i MAUNA LANI SITE M fl_ / ,,-~□□-!!!!~15 ~~i!)!!!!!!!!!!!!!!!!~~$.~iiiiiiiicii, ~t , VICINITY AND LOCATION MAP FIGURE 1-1 7000,f Slf/'w1,~"-INp 155:.l'V'Jr 11/;, ' Cio,231_,,:..-., ,·~----,. <c8.B51A c. / MAl<AIWA ) ~A~ . ~.,:;·. ~er• F,f,' 1,..r:i· •,, ~~ .. ~ i>- ('3 t.. .15 5",f. S 2 A~._.,. ~b, G.,~'J'. /'='LA 1" ol 1 • --------~• .. -'77•• "'e Af<.t::.1/. t,s/"IT ,•e," c15,6<.P<,,r coUl2". NO,e-rH ,eet;,oie1' 3 ,, ~a f}O No, 5~Z. ae~ Ae. ('? ' , ,r/ (o,~ f<~i~ "Si:x~~ ·~~fl z,Al5 ,_. '-I -.... I q;"". '-I 0 " ~~ -:v. 'z' ".) ·> ~~ ~ ~ I I 0 NORTH Not to Scale Mauna Lani Site "M" 2. SANITARY SEWER SYSTEM 2.1 Background Preliminary Engineering Report MLR's private wastewater, system operated and maintained by Hawaii American Water Company ("HAWC"), provides sanitary sewer service to the project area. 2.2 Existing Conditions Wastewater from the MLR area is treated at the private wastewater treatment facility operated by HAWC located just northeast of the project site on the mauka side of Ho'ohana Street. The wastewater treatment facility has a design peak capacity of approximately 1.1 million gallons per day (mgd). Presently, the facility treats about 0.3 mgd of wastewater on an average daily basis. All the wastewater effluent is pumped to nearby turf and landscaping operations for use as irrigation. HAWC has mentioned their plans to install an injection well for effluent disposal. The sanitary sewage system in the vicinity of the project site consists of the wastewater treatment facility located to the east and an existing 18-inch sewer force main located along Ho'ohana Street adjacent to the southern boundary of the project. An existing 16-inch sewer force main that crosses the southwestern corner of the project site conveys sewer flows from other developments within the MLR to the wastewater treatment plant. Due to the age of the line, it is our understanding that HAWC is currently planning to replace the existing 16-inch force main crossing through the project site. See Figure 2-1, Existing Sanitary Sewer System. 2.3 Projected Demands Sanitary sewer volumes for the project were derived using the project's program and County demand factors. An average sanitary sewer volume of 160,510 gallons per day is projected for the development. See Appendix A. Preliminary Engineering Report 2-1 ---- Nerth -------.. __ ~--------------- ---------- -------- -------- Fairways at Mauna Lani ~ MALINA LANI SITE M GRAPHIC SCALE: EXISTING SANITARY SEWER SYSTEM 200' 100' 0 200' SCALE: ---- \ \ \ \ \ ""' 1"•400' \ \ \ \ \ \ \ FIGURE 2-1 Mauna Lani Site "M" Preliminary Engineering Report 2.4 Proposed Improvements Our understanding is that the project site is within the MLR wastewater treatment facility's service territory and will be able to connect to the treatment plant. According to the Purchase and Sales Agreement (PSA) dated September 23, 2004, the seller will provide a "will serve" letter at closing. It is also our understanding that MLR, at their own cost, will extend a "dry" off-site sewer force main line from the wastewater treatment plant to the eastern most corner of the project site. The project will be responsible for constructing on-site sewer pump stations and force mains to the connection point of the dry off-site sewer force main installed by MLR. The on-site sewer pump stations need to have the capacity to pump the sewage flows from the sewer pump station to the sewer treatment plant. The on-site sewer pump station(s) will likely consist of an underground wet well with a minimum duplex grinder pump system, level switches distribution vault, and associated piping. An above grade structure will house the motor controls, visual and audio alarms, and standby power. The exterior footprint of the on-site sewer pump station(s) should be designed to provide paved vehicle access for maintenance of the facility. The final layout of the sewer pump station(s) will be determined during the design phase of the project. For planning purposes, a 3,000 to 5,000 square foot area could be used for a basic on-site sewer pump station(s). Factors such as existing terrain, separation from buildings, landscaping buffers may increase the required area for the on-site sewer pump station(s). Other site improvements will consist of an underground gravity sewer collection system located throughout the project site to convey sewage flows from the various site structures to the sewage pump station(s). Line sizes will be determined during the design phase of the project. See Figure 2-2, Conceptual Sanitary Sewer System. HAWC was consulted in August 2025 to determine appropriate connections based on existing facility capacities and preliminary development plans. Per HAWC, the project will be required to improve the existing plant's filtration capacities based on the anticipated sewage flow quantities being added. See Appendix B. Preliminary Engineering Report 2-3 Fa1rwavs at Mauna Lan1 Villages at Mauna Lani ---- -----~------------ ------------- /-------------\ / \ : "--/ , __ , \ / \ / KA MILO \ : '\ I , ' : \ ', ,..,../ I ' ----' ,__ \ \ ,_,, --------------------------------------------------"--\ KULALANI at MAUNA LANI EXISTlNG FORCE MAIN EASEMENT NEW SEWER MANHOLE, TYP \ \ EXISTING 6" / "',. "< -----~c:_~---./ EXISTING 18" FORCE MAIN MALINA LANI SITE M /PROPERTY ---1,. __ LINE, TYP ------ ~ ~ ~ NEW SEWER ~")"" PUMP STATION /'>v) EXIST SEWER_____// • TREATMEOT PLAOT CONCEPTUAL SANITARY SEWER SYSTEM -------- --- NEW SEWER MANHOLE, TYP ----- GRAPHIC SCALE: • 200' 100' 0 200' SCALE: LEGEND EXISTING SEWERLINE NEW SEWERLINE NEW SEWER MANHOLE FIGURE ""' 2-2 1"•400' Mauna Lani Site "M" Preliminary Engineering Report 3. POTABLE WATER SYSTEM In July 2025, Akinaka & Associates, Ltd. ("Akinaka") prepared a report that analyzed MLR's existing potable water source and use and provided the proposed development's anticipated additional water demands. See Appendix B. 3.1 Existing Conditions DWS supplies water to the project site area via 12-and 24-inch mains located along North Kaniku Drive and Ho'ohana Street, respectively. No off-site fire hydrants are located along either North Kaniku Drive or Ho'ohana Street. See Figure 3-1, Existing Water System. Per Akinaka's analysis, it is our understanding that DWS, Mauna Kea Properties, Inc. (MKP), and Mauna Lani Service, Inc. (MLS) have a tri party agreement in place that developed an additional potable water source at DWS' Lalamilo System. According to the agreement dated April 6, 2006, MLS was responsible for developing Parker Wells Nos. 3 and 4 and connecting those wells to DWS' Lalamilo System. In doing so, MLS has agreed to assign certain portions of the water from Parker Well No. 3 and 4 as follows: Parker Well No. 3 10% to DWS 20%to MKP 70%to MLS Parker Well No. 4 10% to DWS 90% to MLS The tri-party agreement and development of the additional potable water source provides MLR with a maximum daily water allocation of 6.013 million gallons per day (MGD). Based on DWS' Water System Standards, the maximum daily demand for Hawaii Island is 1.5 times the average daily demand. As a result, MLR's average daily demand is 4.009 MGD. According to Akinaka's report, MLR's current average daily water usage is approximately 2.738 MGD. MLS also has a brackish water system in the vicinity of the project that provides irrigation water to the golf course. Preliminary Engineering Report 3-1 Fairways at Mauna Lani Villages at Mauna Lani I I -<::/ ""I '-I ---- KULALANI at MAUNA LANI EXISTING 2-4" WATERLINE MALINA LANI SITE M EXISTING WATER SYSTEM ---------- ---------- FIGURE GRAPHIC SCALE: 200' 100' 0 200' ""' 3-1 SCALE: 1"•400' Mauna Lani Site "M" Preliminary Engineering Report 3.2 Projected Demands Potable water demands for the project site were determined by Akinaka. An average daily water demand of 577,600 gpd is anticipated to be added by the project. Line sizes will be determined during the design phase of the project. 3.3 Proposed Improvements The proposed water system improvements will consist of new water service lateral connections for each development areas to either the 12-inch and 24-inch water mains located in North Kaniku Drive and Ho'ohana Street respectively. See Figure 3-2, Conceptual Water System. The fire protection water service lateral for the project will consist of a double check detector assembly with concrete vault and waterline extending to the various buildings. The need for a fire pump for any multi-level building will need to be determined during the design phase of the project. The site fire protection system will consist of waterlines extending around the new buildings with fire hydrants spaced at 250-foot intervals. Although there are several options in providing non-potable irrigation water to the site, it is not anticipated that these sources will satisfy all the future irrigation needs for the project. Therefore, it is anticipated that potable water lateral connections to the DWS will be required to service portions of the proposed project. DWS will require separate lateral connections and water metering of the irrigation water. DWS was consulted in August 2025. An inquiry request was provided as part of efforts to determine appropriate connections based on existing facility capacities and preliminary development plans. Preliminary Engineering Report 3-3 Fairways at Mauna Lani Villages at Mauna Lani ,I;, ,,,,-<- "' --3:: ✓ Queen ,-nontJ f(oofrtJ Hig/lWOY ---- / _____________ \ / \ : "--/ , __ , \ / \ / KA MILO \ : '\ I , ' : \ ', ,..,../ I ' -' ,__ \ :~:N~Z" \ ---------------------------------------------------\ \ KULALANI at MAUNA LANI \ /-----.................. -------------' --------~---./,, .................. ........._ _______ _ 0 NEW COMBINED DOMESTIC AND FIRE WATER METER CONNECTION TO EXISTING WATERLINE, TYPICAL EXISTING 24" WATERLINE / -- MALINA LANI SITE M /PROPERTY ---& ...... LINE, TYP ------ CONCEPTUAL WATER SYSTEM ---------- ---------- NEW COMBINED DOMESTIC AND FIRE WATER METER CONNECTION TO EXISTING WATERLINE, TYPICAL GRAPHIC SCALE: 200' 100' 0 200' SCALE: LEGEND EXISTING WATERLINE NEW WATERLINE FIGURE ""' 3-2 1"•400' Mauna Lani Site "M" Preliminary Engineering Report 4. SITE GRADING, FLOODING, AND STORM DRAINAGE SYSTEM 4.1 Background Review of the site grading, flooding, and storm drainage system is based on the topographic survey map prepared by R.M. Towill Corporation. See Figure 4-1, Topographic Map. 4.2 Existing Conditions The proposed project area is located along the west coast of the island of Hawaii in Mauna Lani Resort area. Based on a topographic survey map provided, existing topography within the project is characterized by mild slopes. Site elevations range from 80 feet above Mean Sea Level, on the southwest corner near North Kaniku Drive, to 40 feet above Mean Sea Level on the northern end of the project site. Based on the topographic survey map provided, there are no definable natural storm drainage flow patterns within the project site or any pattern showing offsite flows entering the project site. There are also no existing storm drainage systems in the vicinity of the project site. The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel 155166 0303F revised September 29, 2017, shows that the project site is within Zone "X", defined by the FIRM map as "areas determined outside of 500-year flood plain." See Figure 4-2, Flood Insurance Rate Map. More information on the existing conditions is contained in the Preliminary Drainage Study. See Appendix C. 4.3 Project Demands Storm drainage volumes for the project were derived using the conceptual site plans and generalized simulation of projected volumes for similar developments. Line sizes, inlet locations, drywell requirements and detention/retention requirements will be determined during the design phase of the project. Based on the Conceptual Layout Plan the estimated storm drainage volumes for a 10-year, one-hour rainfall event are 114.32 cubic feet per second (cfs) and 172.06 cfs, for existing and proposed conditions, respectively. See Appendix C. Preliminary Engineering Report 4-1 / 't ,I; (I Fairwa~ at Mauna Lani Villages at Mauna "~. " fo,,....., ~ ~66n ~n'lan QKa~i~aY H19 11 ------ ----- ----- I --r [PROPERTY '<- LINE, TYP t -0 -----\ ------ \ \ KA MJLO Co( J 1 -------~-- ----------------_ _____I \ KULALANI ato~UNA LANI " ~ " \ Mouna Resorts (Fne Pl~ Phos~s 1B21) {Of J-6 MALINA LANI SITE M TOPOGRAPHIC MAP io1 0 FIGURE GRAPHIC SCALE: 200' 100' 0 200' ""' 4-1 SCALE: 1"■400' FIRM FLOOD INSURANCE RATE MAP HAWAII cou.,rv, HAWAII PANEL 303 OF 1975 iSEE f/Af' INDEX FD~ FIRl.4 rA~EL LAYOUT'. ,:,;,;JNl1,11>1::,; MAP NUMB 155166030 PTEMBER 29, 20 .!.illt::!Q_ m PROJECT LOCATION ZONE VE ZONE AE N ZONE X ~ Not to Scale FIGURE 4-2 FLOOD INSURANCE RATE MAP MAUNA LANI SITE M WAIMEA, HAWAII Mauna Lani Site "M" Preliminary Engineering Report 4.4 Proposed Improvements Since there currently is no existing storm drainage system in the vicinity of the project site to dispose of surface flows, all increases in storm runoff resulting from the development will be required to be retained on-site. The on-site drainage system will likely consist of drywells and/or detention basins located at low spots at various locations throughout the project site. Depending on the type of development proposed, use of an underground storm drainage system consisting of drain lines and drain inlets may be required to collect and convey storm drainage runoff to the drywells and/or detention basins. The actual number of drywells and size of detention basins will be determined during the design phase of the project. A geotechnical engineer should be retained during the construction phase of the project to verify percolation results of the drywells to confirm discharge capacities. Should deep drywells be required, an Underground Injection Well Permit will need to be obtained. The proposed project will be required to retain all increases in storm water runoff volumes for a 10-year 1-hour storm created by the development. The proposed on- site storm drainage system is likely to consist of a combination of drain inlets, storm drain manholes, underground piping, both wet and dry open retention basins and drywell systems. More information on the proposed conditions is contained in the Preliminary Drainage Study. See Appendix C. Preliminary Engineering Report 4-4 Mauna Lani Site "M" 5. PARKING AND ROADWAY SYSTEM 5.1 Background Preliminary Engineering Report The review of the parking and roadway system is based on the review of the conceptual site plans. A separate Traffic Impact Analysis Report (TIAR) has been prepared for the project. This section will concentrate on on-site related parking and roadway system issues. The TIAR will assess the need for specific off-site roadway and traffic improvements that may be necessary to support the proposed project. 5.2 Existing Conditions Access to the western portion of the project site is provided via North Kaniku Drive, a privately maintained two-lane, two-way dead-end road servicing local resort traffic. North Kaniku Drive consists of an asphaltic concrete paved road section with paved shoulders and no curb, gutter, or sidewalk. North Kaniku Drive is a well-maintained resort road with landscaped shoulders. Ho'ohana Street, located along the southern boundary of the project site, provides an alternative access to the eastern portions of the project site. Ho'ohana Street is a two-lane, two-way, dead-end service road that provides access to MLR's wastewater treatment plant and other MLR support facilities. Ho'ohana Street's pavement is showing signs of failure with considerable cracking and raveling evident. See Figure 5-1, Existing Roadway System. 5.3 Project Demands The current site plan provides a total of 1,871 parking stalls, 871 of which will be covered stalls with the remainder uncovered. See Figure 5-2, Conceptual Roadway System. 5.4 Proposed Improvements The internal roadway system for the proposed project will be connected to both Ho'ohana Street and North Kaniku Drive. It is anticipated that Ho'ohana Street fronting the project site will be upgraded to resort standards. Improvements include road widening, roadway resurfacing, re- striping, street lighting, landscaping, and undergrounding of the overhead electrical and communication lines on the project side of Ho'ohana Street. Preliminary Engineering Report 5-1 Fairways at Mauna Lani EXISTING-----~.a North KM#a, Om, Villages at Mauna Lani KULALANI at MALINA LANI EXISTING Ho'oham, Stn,et MAUNA LANI SITE M EXISTING ROADWAY SYSTEM ----- ~ --------------------- FIGURE GRAPHIC SCALE: 200' 100' 0 200' <OD' 5-1 SCALE: 1"•400' Fairways at Mauna Lani CONNECT TO EXIST ROADWAY, TYPICAL Villages at Mauna Lani KULALANI at MAUNA LANI PROPOSED ROADWAY, TYPICAL EXISTING Ho'ohanaS~t TO BE UPGRADED MAUNA LANI SITE M /PROPERTY ---!,.. __ LINE, TYP ------ CONCEPTUAL ROADWAY SYSTEM CONNECT TO EXISTING ROADWAY, TYPICAL ----- --------------------- FIGURE GRAPHIC SCALE: 200' 100' 0 200' <OD' 5-2 SCALE: 1"•400' Mauna Lani Site "M" Preliminary Engineering Report Other anticipated off-site roadway improvements include the following: 1. Exclusive left-turn and right-turn on the westbound approach of Ho'ohana Street at the intersection with North Kaniku Drive. 2. Exclusive right-turn lane on the northbound approach of North Kaniku Drive at the intersection with Ho'ohana Street. 3. North-bound left-turn pocket from North Kaniku Drive into the main entrance to the Villages of Mauna Lani. 4. Signalization of the North Kaniku Drive and Ho'ohana Street intersection. 5. Exclusive left-turn lane on the eastbound approach of Mauna Lani Drive at the intersection with Queen Kaahumanu Highway. Preliminary Engineering Report 5-4 Mauna Lani Site "M" 6. OTHER UTILITIES 6.1 Fuel Systems Preliminary Engineering Report If gas ranges or tiki torches are incorporated into the design of the project, on-site fuel storage tanks will be required. Sizing and locations of the various fuel tanks will be determined during the design phase of the project. Preliminary Engineering Report 6-1 Mauna Lani Site "M" Preliminary Engineering Report APPENDICES Preliminary Engineering Report Mauna Lani Site "M" APPENDIX A Proposed Sewage Design Flow Calculations Assumptions: Average Daily Wastewater Flow (ADWF)1. 2.8 persons per apartment 2 persons per hotel unit 70 gallons per day per person (GPDPP) Average Daily Wastewater Flow (ADWF) Parcel Building Type Units/Rooms Persons 1 Stacked Flats 56 Units 157 & Townhomes 2 Stacked Flats 102 Units 286 & Townhomes 3A Hotel Building 270 Rooms 540 38 Hotel 104 Rooms 208 Bungalows 4 Town homes 133 Units 373 5 Stacked Flats 104 Units 292 & Townhomes 6 1-Story Villas 156 Units 437 Total 925 2,293 Preliminary Engineering Report GPDPP ADWF 70 10,990 70 20,020 70 37,800 70 14,560 70 26,110 70 20,440 70 30,590 160,510 The total Average Daily Wastewater Flow for the project will be approximately 160,510 gallons per day. Sewer info request submitted August 13, 2025 HAWC response received August 22. 2025 1 City and County of Honolulu, Wastewater System Design Standards, Volume 2 dated July 2017. Preliminary Engineering Report A-1 rq WILSON OKAMOTO 1111 C O R P O R A T I O N _ ..... ti@·MM¥WMhiiM◄UMifi41 August 12, 2025 Mr. Matthew Lasecki Hawaii American Water Company 6700 Kalanianaole Hwy Ste 206 Honolulu, HI, 96825 Subject: Mauna Lani Site "M" -HA WC Sewer Adequacy Request TMKs: 6-8-022:010 and 6-8-001:054 Dear Mr. Lasecki: Wilson Okamoto Corporation ("WOC") is requesting the Hawaii American Water Company's ("HA WC") assistance to determine adequacy of the existing wastewater treatment facilities serving the Mauna Lani Resort properties, for the development of new residential and hotel units on parcels located in TMKs 6-8-022:010 and 6-8-001:054. See Figures 1-1, 1-2A and 1-2B enclosed. It is WOC's understanding that HAWC currently operates and maintains the Mauna Lani Resort's ("MLR") private wastewater treatment facility consisting of two aerated lagoons, which treats approximately 0.3 mgd on an average daily basis and has a design peak capacity of approximately 1.1 million gallons per day (mgd). Furthermore, based on previous due diligence efforts by others, WOC's understanding is that HAWC has future plans to develop injection wells for effluent disposal. The proposed Site "M" development is anticipated to add 162,330 gpd on an average daily basis per County demand standards. See below for anticipated programming and the resulting anticipated additional sanitary sewer demand calculations: Parcel Building Type Units/Keys Persons* GPDPP** 1 Stacked Flats, Townhomes 56 157 70 2 Stacked Flats, Townhomes 102 286 70 3A Hotel Building 270 756 70 3B Hotel Bungalows 104 292 70 4 Townhomes 133 373 70 5 Stacked Flats, Townhomes 104 292 70 6 1-Story Villas 58 163 70 Total 827 2,319 * 2.8 persons assumed per residential unit, 2 persons assumed per hotel unit. ** Demand in gallons per person per day (GPDPD), per County standards ADWF 10,990 20,020 52,920 20,440 26,110 20,440 11,410 162,330 1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277 Letter to Ms. Robyn Matsumoto August 12, 2025 Page2 Lastly, WOC is requesting any record drawings/as-builts of the existing wastewater treatment facilities that may be available to share. Any available information or feedback that can be provided will be used in the project planning and design process to minimize potential conflicts during construction. Feel free to call or email me at require additional information. ~ Brett Kuamoo, P.E. Senior Project Manager Enclosures: Figure 1-1 Project Vicinity and Location Map Figure 1-2A Tax Map Key Figure 1-2B Tax Map Key should you have any questions or 1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii• 96826 • (808) 946-2277 Brooks Martinez From: Sent: To: Cc: Subject: Brooks Matthew E Lasecki < Matthew.Lasecki@amwater.com > Friday, August 22, 2025 3:56 AM Brooks Martinez Brett Kuamoo; Michael Fujita RE: Kana Wastewater Inquiry At a minimum your project would require improvements to the filtration capacity that is prior to our effluent wells. Your project total flow is almost a 50% increase to our daily flows. I have sent my feedback to our local General Manager who has also been in discussions with other potential project connections. I expect he (Lee Mansfield) will be responding to you. We are regulated by the HPUC, and our tariffs which include how development costs are handled are available on our company web site, link below. In essence though all development costs are the responsibility of the developer. https://www.amwater.com/hiaw/Customer-Service-Billing/Your-Waste-Water-Rates/ Matt Lasecki, PE Hl&CAAmerican Water C: 916-275-4740 From: Brooks Martinez > Sent: Thursday, August 21, 2025 11:52 AM To: Matthew E Lasecki <Matthew.Lasecki@amwater.com> Cc: Brett Kuamoo >; Michael Fujita Subject: FW: Kana Wastewater Inquiry Hi Matthew, > Hope you're having a good week so far. WOC wanted to respectfully follow up: has American Water received and/or had an opportunity yet, to review the attached inquiry? Thank you, Brooks Brooks Anthony Martinez Civil Engineer AWR.SON-~ 1111 C O R P O R A T I O N iiiih%HfW8iiiihi&iiHiiiHI 1907 South Beretania Street, Suite 400 Honolulu, Hawaii 96826 T (808) 946-2277 W http://www.wilsonokamoto.com This message contains information that might be confidential and privileged. Unless you are the addressee or are authorized by the sender, you may not use, copy or disclose the information contained in this message. If you have received this message in error, please delete it and advise the sender. 1 From: Brooks Martinez Sent: Wednesday, August 13, 2025 1:49 PM To: Matthew.Lasecki@amwater.com Cc: Brett Kuamoo Subject: RE: Kana Wastewater Inquiry Hi Matthew, > Appreciate your reaching out, and patience with my response. The project in question, Mauna Lani Site "M," consists of new residential/hotel units to be located on currently undeveloped land within the Mauna Lani resort area. Believe a call is not needed at this time, as the project is in the planning and preliminary design stages only. Thank you for confirming that American Water currently owns and operates wastewater facilities in the area. On behalf of our client, Wilson Okamoto Corporation is providing the attached sanitary sewer service availability request letter, for HAWC's review and advisement. Feel free to reach out if any further info or discussion is needed. Thank you, Brooks Brooks Anthony Martinez Civil Engineer AWR.SON-OK»iOro -C O R P O R A T I O N iiiih%hfW8iiii\iiW%iiiiiii 1907 South Beretania Street, Suite 400 Honolulu, Hawaii 96826 T (808) 946-2277 W http://www.wilsonokamoto.com This message contains information that might be confidential and privileged. Unless you are the addressee or are authorized by the sender, you may not use, copy or disclose the information contained in this message. If you have received this message in error, please delete it and advise the sender. From: Matthew E Lasecki <Matthew.Lasecki@amwater.com> Sent: Tuesday, August 5, 2025 7:04 AM To: Brooks Martinez > Subject: Kana Wastewater Inquiry Brooks I received your inquiry through our web site. American Water currently owns and operates wastewater facilities in Waimea and at the Mauna Lani resort. Please let me know what your questions are. Depending on how far along you are on your project I may suggest a conference call also including others at our company. Matt Lasecki, PE Hl&CAAmerican Water C: 916-275-4740 2 Mauna Lani Site "M" Preliminary Engineering Report APPENDIX B Proposed Potable Water Demands Calculations (Prepared by Akinaka & Associates) Water info request letter submitted August 13, 2025 Preliminary Engineering Report B-1 MAUNA LANI RESORT Kamuela, Hawaii WATER USE STUDY Prepared For: ~ PROSPECT HI LL 235 Montgomery Street, Suite 1130 San Francisco, California 94104 1100 Alakea Street, Suite 1800 Honolulu, Hawaii 96813 November 2017 Revised July 2025 DRAFT WATER USE STUDY For MAUNA LANI RESORT Kamuela, Hawaii Prepared For: Prospect Hill Group LLC 235 Montgomery Street, Suite 1130 San Francisco, California 94104 Prepared By: Akinaka & Associates, Ltd. 1100 Alakea Street, Suite 1800 Honolulu, Hawaii 96813 Version: July 2025 Draft Table of Contents 1. EXECUTIVE SUMMARY ..................................................................................................................... 1 2. INTRODUCTION ................................................................................................................................ 5 2.1. Purpose and Scope of the Water Use Study ..................................................................................... 5 3. EXISTING COUNTY DEPARTMENT OF WATER SUPPLY REGIONAL SYSTEM .................................... 5 3.1. Aquifers, Wells, Water Distribution System ..................................................................................... 5 4. EXISTING WATER USE ....................................................................................................................... 7 4.1. Tri-party Agreement with Department of Water Supply for Parker Ranch Wells No. 3 and 4 ........ 7 4.2. Existing Water Use ............................................................................................................................ 8 4.3. Existing Water Use by Property ........................................................................................................ 9 5. HAWAII COUNTY DEPARTMENT OF WATER SUPPLY POTABLE WATER SYSTEM PLANNING STANDARDS ................................................................................................................................... 14 6. PROPOSED WATER USE ANALYSIS AND SUMMARY ..................................................................... 14 7. REFERENCES .................................................................................................................................... 19 EXHIBITS 1. Vicinity Map 2. Location Map 3. Regional Water System Map 4. Mauna Lani Water Usage -Akinaka/PHG Estimates Updated 2025 APPENDICES A. County of Hawaii, Department of Water Supply-Water Rates B. Water System Standards Consumption Tables C. Memorandum for Mauna Lani Resort's Present Water Use of the Department of Water Supply's Lalamilo System Relative to its Allocation from the System by Tom Nance Water Resource Engineering dated March 20, 2017 D. Agreement-Tri Party, Parker Well Nos. 3 & 4, Water Board of the County of Hawaii, Mauna Lani Service, Inc, Mauna Kea Properties, Inc. E. Amendment of Agreement Regarding Parker Wells Nos. 3 & 4 dated April 7, 2008 F. Assignment of Water Allocation dated June 2009 G. Mauna Lani Property Photos Mauna Lani Resort -Water Use Study 1. EXECUTIVE SUMMARY Purpose and Scope of the Water Use Study The scope of this study is to determine with reasonableness, whether or not there will be enough potable water available to the properties and facilities in Mauna Lani Resort, herein referred to as "Mauna Lani", upon full build out. To do so, there are two basic types of potable water use that must be measured: 1) the water use of existing properties and facilities and 2) the potential water use of currently unbuilt properties. To determine the water use of existing properties and facilities, the water uses provided in the Tom Nance Water Resource Engineering memo were compared with water meter readings provided by the County of Hawaii, Department of Water Supply (DWS). Based on the water use of various projects within the resort and a field survey conducted on March 27, 2017 to tour many of the unbuilt properties, reasonable estimates of potential future uses were determined for the currently unbuilt properties. The water meter readings have been updated to the current 12-month average based on data provided by DWS between November 2023 to 2024. The amount of single family and multi-family units built since the original 2017 report have been provided by the Mauna Lani ownership. Existing Water Use The DWS provides potable water to Mauna Lani. Mauna Lani is a party to an executed tri- party agreement between Mauna Lani, Mauna Kea Properties and DWS. This agreement became effective on April 6, 2006. The tri-party agreement provides Mauna Lani with a potable water allocation of 6.013 million gallons per day (MGD} of maximum daily water usage. This is the total amount of water that DWS will supply to all built and unbuilt properties and facilities within Mauna Lani. Manua Lani Resort -Water Use Study The tri-party agreement expresses water allocation in terms of maximum day use. According to the DWS' Water System Standards, the maximum daily demand for Hawaii Island is 1.5 times the average daily demand, to account for variability in water use. As a result, Mauna Lani has an average day demand of 4.009 MGD, which equates to a maximum day use of 6.013 MGD at the 1.5x factor. As calculated by Akinaka based on independent research and DWS meter readings and files, the current average day water usage by existing properties and facilities within Mauna Lani is 2.738 MGD, which is equivalent to a maximum day use of 4.106 MGD. This level of water use is similar to the 2017 water study findings of 2.755 MGD and 4.132 MGD respectively. The updated water use is still in line with the use approximately displayed on the Tom Nance Water Resource Engineering memo, and was independently corroborated and supplemented by research of DWS meter readings and files. The existing potable water use is based on a twelve month moving average of DWS meter readings from November 2023 to November 2024. The water use and number of built & unbuilt units in this report has been updated to reflect the construction and build-out that has occurred since the original 2017 report and tour. Existing usage was calculated separately for single-family, multi- family, hotel and other types of developments. Based on the DWS allocation of 6.013 MGD maximum day usage and existing use of 4.106 MGD average day usage by existing properties and facilities, there is 1.907 MGD of water allocation available for unbuilt properties and facilities at Mauna Lani, as shown in Table 1. Table 1. Water Available for Unbuilt Properties Allocation From DWS Less: Presently Built Usage Available for Unbuilt Avg Day DWS Max Day Water Use Multiplier Water Use 4,008,667 2,737,551 1,271,115 1.Sx 1.Sx 1.Sx 6,013,000 4,106,327 1,906,673 Manua Lani Resort -Water Use Study Proposed Water Use Analysis and Summary The DWS Water System Standards' Domestic Consumption Guidelines (Table 100-18} for Resort, Single Family, and Multi-Family Residential zoning designations use average daily demand of 400 GPD/unit. The total average day estimated water use for the currently unbuilt properties and facilities is 577,600 gallons per day (GPD}, which is equivalent to a maximum day use of 866,400 GPD. This leaves an average day use of 693,515 GPD (or a maximum day use of 1.040 MGD} available for the construction of Site M and the Undeveloped Golf Course as shown in Table 2: Table 2: Water Available for Unbuilt Properties Not Controlled by Buyer Avg Day DWS Max Day Water Water Use Multiplier Use Allocation From DWS 4,008,667 1.Sx 6,013,000 Less: Presently Built Usage 2,737,551 1.Sx 4,106,327 Available for Unbuilt 1,271,115 1.Sx 1,906,673 Less: Unbuilt Estimated Usage 577,600 1.Sx 866,400 Available for Remaining Unbuilt 693,515 1.Sx 1,040,273 Existing water using units (hotel, commercial, single and multi-family) at Mauna Lani have an average day use of 2.738 MGD. The unbuilt units that could eventually come online would account for an additional average day water usage of 577,600 GPD. This means that current and potential average day water use at Mauna Lani equals 3.315 MGD, which leaves a surplus of average day water use of 693,515 GPD for additional buffer. Given 1) ProspectHill Group's ownership of Site M and its ability to control the level of development, and 2) the necessity to obtain water allocation from ProspectHill Group, the current lack of water allocation, entitlements and buildable zoning on the Undeveloped Golf Course, ProspectHill Group has the ability to control any excess water usage beyond the DWS allocation. Manua Lani Resort -Water Use Study The tri-party water agreement states that all unused water allocations will revert back to the DWS after a period of 20 years from dedication of Parker Wells No. 3 & 4, which occurred on May 26, 2009. Any unused allocations will revert back to DWS on May 26, 2029. Construction of the remaining developments should be completed prior to this date, or ProspectHill Group should request an extension with DWS, to maximize development. Manua Lani Resort -Water Use Study 2. INTRODUCTION 2.1. Purpose and Scope of the Water Use Study The scope of this study is to determine with reasonableness, whether or not there will be enough potable water available to the properties and facilities in Mauna Lani Resort, herein referred to as "Mauna Lani", upon full build out. To determine the water use of existing properties and facilities, the water uses provided in the Tom Nance Water Resource Engineering memo were compared with water meter readings provided by the County of Hawaii, Department of Water Supply {DWS). Updated DWS water meter readings taken between November 2023 and November 2024 were used to determine the current water use. Based on the water use of various projects within the resort and a field survey conducted on March 27, 2017 to tour many of the unbuilt properties, reasonable estimates of potential future uses were determined for the currently unbuilt properties. The water use and number of built & unbuilt units in this report has been updated to reflect the construction and build-out that has occurred since the original 2017 report and tour. The purpose of this study is to: • provide interpretation of the existing tri-party water agreement dated April 6, 2006, • establish reasonable water usage rates for the existing development, • use the DWS WSS Domestic Consumption Guidelines to determine the water usage for the remaining unbuilt units within Mauna Lani, and • identify constraints between the existing and proposed water use versus water allocation per the tri-party agreement. 3. EXISTING COUNTY DEPARTMENT OF WATER SUPPLY REGIONAL SYSTEM 3.1. Aquifers, Wells, Water Distribution System The Mauna Lani area properties are serviced by two aquifers, Anaehoomalu and Waimea. s I Manua Lani Resort -Water Use Study The Anaehoomalu [80701] Aquifer System Area is within the Northwest Mauna Loa Aquifer Sector Area. It extends from the summit of Mauna Loa, northwest to the western shores of Anaehoomalu, and spans three districts, capturing the southern coastal portion of the South Kohala District, the northeastern portion of the North Kona District and the southern portion of the Hamakua District. Average rainfall ranges from 10 inches along the coast to 45 inches in the low-lying areas between Mauna Kea and Mauna Loa. The current sustainable yield is 30 MGD. According to the State of Hawaii, Commission on Water Resource Management (CWRM) database, there are 19 production wells in the sector, including 11 irrigation, 1 industrial, and 7 other. The Waimea [80301] Aquifer System Area is within the West Mauna Kea Aquifer Section Area. Its boundaries extend from the saddle area between Mauna Kea and Mauna Loa to Waimea and along the western shores at Kawaihae to Puako, capturing most of the South Koh ala district and the western portion of the Hamakua district. Average annual rainfall ranges from nine inches along the coast to nearly 50 inches; however, most of the sector receives less than 30 inches, making this sector area one of the driest on the island. The current sustainable yield is 24 MGD. According to the CWRM database, there are 30 production wells in the sector area, including 15 municipal, 11 irrigation, 2 industrial, 2 other. There are also seven wells drilled and categorized as "unused." Water from the Waimea aquifer is delivered to the Manua Lani area properties by the distribution system owned and operated by the County of Hawaii, Department of Water Supply (DWS). The DWS water system is sourced with eight wells in two nearby well fields: Lalamilo Wells A, B, C and D, and Parker Wells 1, 2, 3 and 4. The wells feed into existing water storage tanks at elevation 1103' and is piped down the access road with a pressure reducing station (PRV) at elevation 770' and water storage tanks at elevation 610' and elevation 319'. At Queen Kaahumanu Highway, a 24" waterline transmits water to the south along Hoohana Street towards the Mauna Lani area properties. Manua Lani Resort -Water Use Study Water from the Anaehoomalu aquifer is used mainly for irrigation purposes. There is limited information available regarding the irrigation system, so details of usage and distribution are unknown. There is an existing irrigation water agreement which is explained in Section 4.2. 4. EXISTING WATER USE 4.1. Tri-party Agreement with Department of Water Supply for Parker Ranch Wells No. 3 and 4 Mauna Lani is party to an executed tri-party water service agreement with the DWS and Mauna Kea Properties (MKP) for development of Parker Wells No. 3 and 4, herein referred to as "Wells No. 3 and 4". In exchange for developing Wells No. 3 and 4 and the associated storage and transmission mains, Mauna Lani was allocated a maximum day water use of 6.013 million gallons per day (MGD) from the Lalamilo Water System. This is the total amount of water that DWS will supply to all built and unbuilt properties and facilities within Mauna Lani. The tri-party agreement, effective April 6, 2006, outlines the following conditions: • Water allocation is based on maximum day use. Maximum day use is defined as 1.5 times the 12-month moving average (12-MAV) of DWS' metered readings. • Water allocation from the capacity of Well No. 3 is as follows: o Ten (10) percent -DWS o Seventy (70) percent -Mauna Lani o Twenty (20) percent -MKP • Water allocation from the capacity of Well No. 4 is as follows: o Ten (10) percent -DWS o Ninety (90) percent -Mauna Lani • Water allocations to Mauna Lani and MKP are reserved for a period of 20 years from dedication of Wells No. 3 and 4. After the 20 year period, ending on May 26, 2029, unused allocations are reverted back to DWS. Unused allocations do not include Manua Lani Resort -Water Use Study those situations where a development has been constructed, a service lateral to the development has been installed, and the allocation to service a particular parcel within the development is available. • Water use will be paid for in accordance with the prevailing rate schedule • Mauna Lani and MKP shall install separate meters for irrigation use on parcels developed after execution of the water agreement • Prevailing facilities charges will apply for maximum day use in excess of 6.013 MGD. The tri-party agreement expresses water allocation in terms of maximum day use. According to the DWS' Water System Standards (WSS), the maximum daily demand for Hawaii Island is 1.5 times the average daily demand, to account for variability in water use. As a result, Mauna Lani has an average day demand of 4.009 MGD (6.013 MGD/1.5 factor). 4.2. Existing Water Use 12-Month Moving Average As outlined in the tri-party agreement, the water allocation is based on the 12-MAV of DWS' metered readings. To determine the existing water use for some of the Mauna Lani projects, the 12-MAV was calculated for each individual property, using the procedure below. Please note that when DWS meter readings were not readily available, existing water use was taken from Table 1 of Appendix C (Tom Nance Water Resource Engineering memorandum dated March 20, 2017). • DWS meter readings were obtained for November 2023 to November 2024. Meter readings were provided on an average day use. • The average day use was multiplied by the number of days in the billing period to obtain a total water use. • Since meter readings do not follow complete calendar months (i.e. 1/15/24 to s I 3/17 /24), the readings were prorated as necessary. The total water use reflects the number of days for which data was available for. Manua Lani Resort -Water Use Study • The total water use between the November 2023 and November 2024 was added together to provide the total water use within a 12-month period. • The total water use within the 12-month period was averaged over the number of days to obtain an average day water use. • A factor of 1.5 was used to calculate the maximum day use 12 -MAV (gallons/day) Total water use between Novmeber 2023 to November 2024 (gallons) Number of days within the meter reading period (days) 4.3. Existing Water Use by Property Mauna Lani consists of a collection of hotels, private resort and luxury homes, townhouses, condominiums, and resort accommodations, including restaurants and golf courses. Based on the 12-MAV, Mauna Lani has an average day potable water use of 2,737,551 gallons per day (GPD), or a maximum day use of 4,106,327 GPD after the 1.Sx multiple. This water use is inclusive of potable water that is used for the maintenance of onsite amenities including landscaping, water features, private and community pools and community areas. As a resort area, properties use vast amounts of water for irrigation to maintain the lush appearance of the onsite landscaping. The following sections detail the water use of each property within Mauna Lani based on the number of existing units and the presence of onsite amenities. This total water use does not include brackish water use and water used for the irrigation of the two Francis l'I Brown North and South Golf Courses. ProspectHill Group (current owner of Mauna Lani) states that the golf courses are irrigated with brackish water. Brackish water is provided by onsite wells owned and operated by MLRO, who also owns and operates the golf courses. Although the MLRA receives brackish water from MLRO, it is not known where, within Mauna Lani, the brackish water is being used based on the information provided. Should the availability of brackish water become scare, alternative sources to replace brackish water will need to be explored. Manua Lani Resort -Water Use Study Hotels There are two hotels located in Mauna Lani: Mauna Lani Hotel and Fairmont Orchid. Both hotels are luxury resorts with onsite pools, spas, restaurants and bars. The total average day water use for both hotels is 487,558 GPO. Table 1. Hotel Existing Water Use Hotel Number of Percent Existing Average Maximum Existing Constructed Amenities on Day Water Day Rooms Site Use (GPD) Water Use (GPD) Mauna Lani 341 100% Pool, water 181,301 271,952 Hotel features, landscaping, 5 restaurants /bars Fairmont Orchid 540 100% Pool, spa, water 306,257 459,386 features, landscaping, 5 resta u rants/bars Total 881 487,558 731,337 Multi Family There are eleven multi-family communities within Mauna Lani. Properties within these developments range from condominium units to single family detached dwellings, with the majority of the developments averaging a unit size of 0.14 to 0.23 acres. Lots within Ke Kailani and the Islands at Mauna Lani average a lot size of 0.41 acres and 0.36 acres respectively. All of these developments offer community pools and hot tub facilities. For the developments that are not fully constructed, the vacant lots are bare with no landscaping, and thus minimal irrigation use. The total average day water use for 839 units within these eleven communities is 833,865 GPO. 10 I Manua Lani Resort -Water Use Study Table 2. Multi Family Existing Water Use Property Number of Percent Existing Average Maximum Existing Constructed Amenities Day Water Day Units* Use (GPD) Water Use (GPD) Mauna Lani 80MF 100% 2 community 76,948 115,422 Terrace condominium pools, hot tub, units sauna, shower facilities, landscaping Mauna Lani 116 MF 100% Restaurant, 93,467 140,201 Point condominium community pool, units sauna, hot tub, landscaping The Islands at 46 MF 100% Community pool, 71,291 106,937 Mauna Lani condominium hot tub, units landscaping, landscaping Villages at 130 MF 100% Freshwater 115,585 173,377 Mauna Lani townhouse community pool, units hot tub, private pool, landscaping Ke Kailani 4 duplex units, 20% Community pool 20,267 30,401 unoccupied (The Grotto), recreation area and spa (Hana Pono Park), landscaping Golf Villas at 87 MF 100% Community pool, 74,793 112,189 Mauna Lani condominium spa, landscaping units The Fairways 126 MF 100% Community Pool, 111,375 167,063 at Mauna Lani townhouse hot tub, units landscaping Kulalani 106 MF 84% Shares a 45,228 67,842 townhouse community pool units, and recreation unoccupied area with Ka Milo, landscaping Ka Milo 37 SF units 73% Shares a 174,499 261,748 100 duplex community pool units and recreation area with Kulalani, landscaping, private pool/spa Manua Lani Resort -Water Use Study Palm Villas 44MF 100% Community Pool, 35,898 53,848 townhouse hot tub, units landscaping Nohea Phase 0,vacantland 0% Landscaping, will 14,514 21,771 2 share community pool with Nohea Phase 1 Total 839 units 833,865 1,250,798 *MF stands for multi-family homes Single Family There are nine single family, private resort communities within Mauna Lani. 49 Black Sand Beach, Ke Kailani, Nohea Phase 1, Pauoa Beach and Nomura Hawaii Village offer community pool and spa facilities. Many private land owners in each of these communities have also elected to construct their own private pools and hot tubs. 49 Black Sand Beach, Ke Kailani, Pauoa Beach and Nomura Village are high end properties and as such, have larger lots with extensive landscaping to promote a resort like atmosphere. The total average day water use for the 187 single family units within these communities is 1,169,859 GPD. Table 3. Single Family Existing Water Use Property Number of Percent Amenities Average Maximum Existing Constructed Day Water Day Units* Use (GPD) Water Use (GPD) 49 Black Sand 42 SF 88% Community pool, 349,554 524,331 Beach spa, landscaping, private pool Ke Kailani 8 SF 21% Community pool 131,166 196,749 (The Grotto), recreation area and spa (Hana Pono Park), private pool/spa, landscaping The Estates 19 SF 100% Private pool, 40,769 61,154 landscaping Champion 27 SF 82% Private pool, hot 111,762 167,644 Ridge tub, landscaping Manua Lani Resort -Water Use Study Nohea Phase 1 7 SF, 23% unoccupied Cape 12 SF 86% Pauoa Beach 41 SF 93% Laule'a 17 100% Nomura Hawaii 14 SF within 4 100% Village buildings Total 187 units *SF stands for single family homes Other Private pool, spa, 31,881 47,821 landscaping, community pool Private pool, hot 96,912 145,368 tub, landscaping 2 community 325,383 488,075 pools, sauna, private pools, landscaping None known 38,621 57,931 Community pool, 43,810 65,716 landscaping 1,169,859 1,754,789 Other facilities within Mauna Lani that use potable water include shops, restaurants, office buildings and the wastewater treatment plant. These facilities have a total average day water use of 170,284 GPD. Water use for these facilities are limited to bathrooms, sinks, irrigation for landscaping and wastewater plant operations. Table 4. Resort Accommodations Existing Water Use Property Average Day Water Use Maximum Day Water Use (GPD) (GPD) Shops at Mauna Lani 35,219 52,828 (includes restaurants) Beach Club 10,294 15,441 Mauna Lani Golf Clubhouse 1,192 1,788 (includes restaurant) Mauna Lani Spa 9,242 13,863 Former Preschool (closed) 1,951 2,926 Resort Association Office 5,323 7,985 Building Wastewater Treatment Plant 9,051 13,576 Entry/Guard Shack/Admin 3,411 5,116 Office Mauna Lani Dr. & Kaniku Dr. 60,721 Landscaping Pauoa Beach Landscaping 33,631 Hawaiian Earth Recycling 250 375 Total 170,284 255,426 Manua Lani Resort -Water Use Study Properties Not Included in Tom Nance Water Resource Engineering Memo Prospect Hill Group identified several properties that were not listed in Table 1 of the Tom Nance Water Resource Engineering Memo. These properties are fully built out and have a total average day water use of 75,984 GPD (2017). Table 5. Properties Not Included in Tom Nance Water Resource Engineering Memo Property Average Day Water Use Maximum Day Water Use (GPD) (2017) (GPD) (2017) Mauna Lani Beach House 22,173 33,260 Mauna Lani Boat House 52,461 78,692 Golf Course Maintenance 1,350 2,025 Building Total 75,984 113,976 5. HAWAII COUNTY DEPARTMENT OF WATER SUPPLY POTABLE WATER SYSTEM PLANNING STANDARDS The DWS WSS provide standards of planning for the minimum limits for water uses such as fire flow and domestic consumption. As stated in the WSS, the guidelines may be revised by the Manager based on variable factors that influence water consumption rates. Table 100- 18 Domestic Consumption Guidelines in the WSS highlights the average daily demand that provides an adequate water system for different zoning types: Residential zoning as 400 gals/unit, Commercial zoning as 3000 gals/acre and Resort zoning as 400 gals/unit. Table 100-19 Fire Flow Requirements in the WSS highlights the fire flows considered as the minimum by the Department. The maximum daily demand for Hawaii Island is 1.5 times the average daily demand, as shown in WSS Table 100-20 Demand Factors. 6. PROPOSED WATER USE ANALYSIS AND SUMMARY Based on the DWS allocation of 6.013 MGD maximum day use and existing maximum day use of 4,106,327 GPD, Mauna Lani has a remaining maximum day allocation of 1,906,673 gallons per day, or an average day allocation of 1,271,115 gallons per day, for the remaining Manua Lani Resort -Water Use Study developments within the resort. To determine whether there is enough water allocation to develop the remaining parcels, water use for the remaining planned developments was estimated based on the existing developments observed during the March 27, 2017 field survey, updated meter readings from 2022 to 2024, as well as best available information. The water use and number of built & unbuilt units in this report has been updated to reflect the construction and build-out that has occurred since the original 2017 report and tour. The DWS Water System Standards' Domestic Consumption Guidelines (Table 100-18} for Resort, Single Family, and Multi-Family Residential zoning designations use average daily demand of 400 GPD/unit. The total estimated average day water use for unbuilt lots is 577,600 GPD, which is equivalent to a maximum day use of 866,400 GPD. Multi Family Since almost all of the community areas are built out, the additional water use for the remaining units reflects the water use required for each individual unit. There are seven (7) planned single family homes in Ka Milo which may have private pool/spa facilities on the property. The total estimated average day water use for the remaining 153 multi-family units is 61,200 GPD. Manua Lani Resort -Water Use Study Table 6. Estimated Multi Family Water Use Property Number of Possible Estimated Estimated Estimated Units Amenities Average Average Day Maximum Remaining* Day Water Water Use Per Day Water Use Per Development Use (GPD) Unit (GPD) (GPD/Unit) Ke Kailani 16 duplex Landscaping 400 6,400 9,600 units Kulalani 20 MF Landscaping 400 8,000 12,000 townhouse units Ka Milo 7 SF Landscaping, 400 14,800 22,200 30 duplex private units pool/spa Nohea 80SF Landscaping, 400 32,000 48,000 Phase 2 will share community pool with Nohea Phase 1 Total 153 units 61,200 91,800 *MF stands for multi-family Single Family The total estimated average day water use for 71 single family homes is 28,400 GPD. Table 7. Estimated Single Family Water Use Property Number of Estimated Estimated Estimated Units Average Day Average Day Maximum Day Remaining* Water Use Per Water Use Per Water Use (GPD) Unit Development (GPD/Unit) (GPD) 49 Black Sand 6 SF 400 2,400 3,600 Beach Ke Kailani 31 SF 400 12,400 18,600 The Estates 0 SF 400 0 0 Champion Ridge 6 SF 400 2,400 3,600 Nohea Phase 1 23 SF 400 9,200 13,800 Cape 2 SF 400 800 1,200 Pauoa Beach 3 SF 400 1,200 1,800 Laule'a 0 SF 400 0 0 Total 71 units 28,400 42,600 *SF stands for single family Manua Lani Resort -Water Use Study Potential Developments Sites for potential development and the associated proposed units were provided by ProspectHill Group. The driving range and Site M are currently undeveloped. The driving range is a graded lot with turf. ProspectHill Group owns Site M and can control whether any development occurs there. The below list contains potential developments. Table 8. Estimated Water Use for Proposed Developments Property Proposed Estimated Estimated Maximum Day Units Average Day Average Day Water Use Water Use Per Water Use (GPD) Unit (GPD/Unit) (GPD) Driving Range 100 400 40,000 60,000 South Lawn at Hotel 30 400 12,000 18,000 Bungalows at Hotel 5 400 2,000 3,000 Site M -Residential 600 400 240,000 360,000 Site M -Resort 375 400 150,000 225,000 Total 1,110 units 444,000 666,000 Sites Sold to Others Although portions of the property have been sold to private land owners, Mauna Lani is still responsible for providing water use to those properties. The water use from these properties would come from Mauna Lani's overall water allocation. The undeveloped golf course and Fairmont Orchid Condos are currently undeveloped and do not currently have a water use. Based on DWS' water chart from 2009, Fairmount Orchid Condos has an estimated average water allocation of 44,000 GPD. The Undeveloped Golf Course parcel has no water allocation from DWS, no entitlements and is zoned A-Sa (Agricultural, with a requirement of a minimum of 5 acres per building site); further, ProspectHill Group, as owner of Mauna Lani, has no obligation to allocate water to the Undeveloped Golf Course, so it is not included in this chart as a potential user of water. Manua Lani Resort -Water Use Study Table 9. Water Allocations for Sites Sold to Others Property Proposed Units Estimated Average Day Water Use (GPD) Fairmont Orchid Condos 110 44,000 After full buildout, there will be a remaining maximum day allocation of 1,678,673 GPD, which is equivalent to an average day allocation of 1,119,115 GPD. It is important to note that per the water agreement, unused water allocations will revert back to the DWS after a period of 20 years from dedication of Wells No. 3 and 4, which occurred on May 26, 2009. Construction of the remaining developments should be completed prior to this, or ProspectHill Group should request an extension with DWS, to maximize development. Manua Lani Resort -Water Use Study 7. REFERENCES Water System Standards, Department of Water Supply, County of Hawaii dated 2002 and as amended Hawaii County Water Use and Development Plan Update, Hawaii Water Plan, dated August 2010 State of Hawaii, Department of Land & Natural Resources, Commission on Water Resource Management, Island of Hawaii Hydrologic Units, Sustainable Yield/Aquifer Code Map, dated August 2008 Manua Lani Resort -Water Use Study EXHIBITS Manua Lani Resort -Water Use Study -~•~•,,~II 0 NOTTO SCALE ' ' 6 \/ RESORT OOL J ASSOCIATION ER) ; ENTRY/GU 1 C A SHACK, 1 ' TOKYU ADMIN :::::;.r ~ " / -=- .l~§E_JC ~ . ~ INSET D MAUNA LANI WATER USE STUDY EXHIBIT VICINITY MAP 1 NOTTO SCALE MALINA LANI WATER USE STUDY LOCATION MAP I ~;IT I E] a. <C ::E > ::E C => w I-I-fl) t/J w fl) > => t/J 0:: 0:: w i w i z ~ <C ...J z <C => z <C :ii: 0 (!) w 0:: w 0! z Exhibit 4 -Mauna Lani Water Usage Akinaka Estimates -Updated July 2025 Current and Potential Future Use Noted ____ Aae3!....______ Type ______ NmnberofUnits ______ PresentlyBuiltUnits(1) _______ UnbuiltUnits _____ _ Project/Parcel Name in PSA TMK Total Roads and Net Acre/Unit of Unit at Full Build Out Presently Built To Be Built Avg GPD AVCNgC Avg GPD DWS' GPD Estimated Amenity Actual Usage GPD / Unit Eatimated (Avg* t.5x) GPD / Unit M NANCE CHART Hotel Romm MaunaLani 6-8-22,15 Hotel.Rooms 341 341 181,301 532 Fainnont 6-8-22:08 Hotel Rooms 540 540 0 306~7 567 Total 881 881 0 487,558 Multi-Family Mauna Lani Tettacc 6-8-22:06 13.3 3.7 9.7 0.12 MF 80 80 76,948 962 Mauna Lani Point 6-8-22:28 17.8 4.6 13.2 0.11 MF 116 116 93,467 806 Idand, 6-8-22:21 21.9 5.4 16.5 0.36 MF 46 46 71,291 1,550 V,lhgc, X 6-8-22,04 29.9 7.0 22.9 0.18 MF 130 130 115,585 889 KcK,;lani(MF) X 6-8-36:16 8.1 0.0 8.1 0.41 MF 20 16 20,267 5,067 6,400 9,600 400 GolfV.illas X 6-8-22:52 13.8 3.8 10.1 0.12 MF 87 87 0 74,793 860 Fairways X 6-8-22,05 20.1 5.0 IS.I 0.12 MF 126 126 111,375 884 Kubloni (Somfonl C,n) X 6-8-22:07 30.6 7.1 23.4 0.19 MF 126 106 20 45,228 427 8,000 12,000 400 Ka Milo (Brookfield) X 6-8-22:41 25.1 6.0 19.1 0.14 MF 137 100 37 174,499 1,745 14,800 22,200 400 PalmV.illas X 6-8-22:18 6.7 1.7 5.0 0.11 MF 44 44 0 35,898 816 Nohca (Phase 2 -MF) X 6-8-43,37 17.1 4.4 12,7 0.16 SF 80 80 14,514 32,000 48,000 400 Total 992 839 153 833,865 61,200 91,800 Smgle Family 49 Black Sand Beach X 6-8-33:01 to 53 60.0 17.0 43.0 0.90 SF 48 42 349,554 8,323 2,400 3,600 400 Kc K,;lani (SF) X 6-8-36:01 to 15, 17 56.9 25.7 31.1 0.80 SF 39 31 131,166 16,396 12,400 18,600 400 to41 Estates 6-8-24:01 to 19 9.0 2.8 6.2 0.33 SF 19 19 40,769 2,146 0 400 Champion Ridge 6-8-27:01 to 35 23.5 5.7 17.8 0.54 SF 33 27 111,762 4,139 2,400 3,600 400 Noh~ (Phase 1 -SF) X 6-8-43:01 1D 35 15.0 4.0 11.0 0.37 SF 30 7 23 31,881 4,554 9,200 13,800 400 Cape 6-8-24:23 1D 36 SF 14 12 96,912 8,076 800 1,200 400 P11.uo11.Bca.ch X 6-8-34:01 tn 45 SF 44 41 325,383 7,936 1,200 1,800 400 Laulc'a (Parcel P) X 6-8-22:24 5.2 2.0 3.1 0.18 SF 17 17 38,621 0 0 400 Nomura Hawaiian Village 6-8-22:25 22.6 5.5 17.1 1.22 SF 14 14 43,810 3,129 0 Total 258 187 71 1,169,859 28,400 42,600 OtJ,., Shops 11.t M2un.a Lani X 6-8-22:02 35,219 Beach Club 6-8-24,39 10,294 Golf Oubhousc 6-8-22,43 1,192 M2un.al.aaiSpa 6-8-22,19 9,242 Pte-School 6-8-01:58 1,951 Resort Association 6-8-22,29 5,323 Wastewater Treatment Plant 6-8-01,49 9,051 Entty/Guanl Sh,ck/ 6-8-01:57 3,411 TokyuAdmin Maun.a Lani Dt and Kaniku Dr 6-8-22:35 60,721 Pauoa Bea.ch u.ndsc:aping 6-8-22:09 33,631 Haw,iian Eatth Recycling 6-8-01,49 250 Total 170,284 Noted ____ Acre=--.______ Type ______ NumberofU:nita ______ ~~ _______ UnbuiltUnits _____ _ Project/Parcel Name in PSA TMK Total Roads and Net Acre/Unit of Unit at Full Build Out Presently Built To Be Built Avg GPD Average Avg GPD DWS' GPD Estimated Amenity Actual Usage GPD / Unit Estimated (Avg* t.5x) GPD / Unit OT INCLUDED IN TOM NANCE CHART Othe, ML Bea.ch House ML Boat House Golf Maintenance Building Total Sitea Buyer May Want to Devel.op Driw,g Range South Lawn at Hotel Bungalows at Hotel Site M -Residential SiteM-Hotcl Site M -Open Space Total 6-8-022:026 6-8-022:026 6-8-022:043 6-8-022:022 6-8-22,15 6-8-22,15 X 6-8-001 :054 X 6-8-001 :054 X 6-8-022:010 20.7 5.14 100.8 TBD (Por. of above) 49.1 15.56 0.16 NOT INCLUDED TOM NANO\ CHA!l't-NOT CONJ'ROLLl!D Sitea Sold to <>then Undcvclopcd Golf Course Fairmont Orchid Condos !TOTAL Water Uae SUMMARY Allocation From DWS Less: Presently Built Usage (1) Awilablc for Unbuilt Less: Unbuilt Estimated Usage Awilablc for Rcm2ining Unbuilt X 6-8-001 :022 6-8-022:063 552.8 5.6 (1) Water usage for Presently Built Units based on Nov 2023 to Nov 2024 Meter readings. Avg Day DWS Max Day Water Use Multiplier Water Use 4,008,667 2,737,551 1,271,115 577,600 693,515 1.Sx 1.Sx 1.5x 1.5x 1.5x 6,013,000 4,106,327 1,906,673 866,400 1,040,273 22,173 52,461 1,350 75,984 100 100 30 30 600 600 375 375 1,110 1,110 110 110 110 110 2,737,551 40,000 12,000 2,000 240,000 150,000 0 444,000 44,000 44,000 577,600 60,000 18,000 3,000 360,000 225,000 666,000 66,000 66,000 866,400 400 400 400 400 400 400 APPENDIX A. County of Hawaii, Department of Water Supply -Water Rates Manua Lani Resort -Water Use Study Our Mission: Providing Safe & Dependable Drinking Water ata Reasonable Cost How is your money spent? Water Quality Providing safe drinking water is the foremost goal of the Department. We intend to meet the stringent requirements of the federal Safe Drinking Water Act. This includes testing of the water on a regular basis, developing better sources, and furnishing more treatment facilities. Dependable Systems Making sure that you have water involves drilling more wells (since well water is more dependable and less susceptible to droughts than surface sources); repairing and replacing outdated systems; and installing new modem equipment to monitor our systems. You Can Contact Us at the Following Numbers: Administration/Finance/General ........ (808) 961-8050 Billing/Customer Service ..................... (808) 961-8060 Engineering .......................................... (808) 961-8070 Emergencies & Field Operations ........ (808) 961-8790 Water Quality ........................................ (808) 961-8670 Website Address ............................ www.hawaiidws.org EXPLANATION OF CHARGES: Your water bill consists of four components: 1. Standby Charge: This is a minimum monthly service charge based on meter size. 2. Consumption Charge: This is a service charge based on water use. 3. Power ,CQ§! Charge: This is a charge to offset power costs incurred by the Department. 4. Energy CIP (Capital Improvement Project) Charge: This is a charge to fund projects that improve energy efficiency. HOW TO PAY YOUR BILL: 1. Mail in your payment. 2. In person at our office at 345 Kekiianao'a St., Suite 20, in Hilo, or at our district offices in Waimea and Kona. 3. By Automatic Bill Payment from your checking account. 4. On-line at www.hawaiidws.org. Follow the "Water Bill" link. 5. Call toll free (844) 216-1994. Please allow sufficient time for your payment to reach us by the DUE DATE. We are not responsible for any payment which may be in transit on the due date. A late payment penalty of one-percent (1 %) per month will be assessed on unpaid account balances outstanding for more than 30 days. If payment is not received by the due date, a shut-off notice with a scheduled shut-off date will be mailed to the account holder. Contact us immediately if you are unable to pay amounts due by the due date. A disconnected service will not be restored until all amounts due are paid. We assess a $30 fee for all dishonored payments. All water charges will continue to be your responsibility until you notify us to close your account. ESTIMATED READINGS: We try to read your meter each billing period. However, if it is not pos- sible to do so, we will estimate your consumption based on your recent average water usage. Please help us by keeping your meter accessible and clear of cars, fences, walls, debris, foliage, and animals. The Department of Water Supply is an equal opportunity provider and employer. . ~ ~ ;! ~ CD '"~ tJ {g a Q) ~ CD ~ ~ 0 ~ ..... ~ ~ ~ Cl) -§ 'tJ ~ V'.l ;;;· ~ ~ ~ CD .Q §_ ~ .g "O 0 ~ e-::, ~-~ a 'tJ a ~ [ V'.l CD .., Q) ~ ::, Q, CD i ~ ~ a :-, ~ ~ ~ . CJ) i:: "'1j "'1j ,-... "< Water Rates Department of Water Supply County of Hawai'i 345 Kekuanao'a Street, Suite #20 Hilo, Hawai'i 96720 Effective July 1, 2025 A. MONTHLY STANDBY CHARGES* All meter connections shall be subject to a monthly standby charge as follows: Meter Size Effective Effective (inches) July 1. 2025 lulyl.2026 5/8" $ 32.82 s 35.93 1" 69.86 76.49 1-½" 129.96 142.31 2" 203.07 222.36 3" 372.02 407.36 4" 612.46 670.65 6" 1,213.55 1,328.83 8" 1,936.47 2,120.44 10,, 2,794.23 3,059.68 12" 4,873.66 5,336.66 *Standby charge is a minimum monthly charge. B. GENERAL USE RATES (per 1,000 gallons) In addition to standby, power cost, and energy CIP charges, a consumption charge will be applied to all general use cus- tomers as follows: Effective Effective July 1, 2025 July 1. 2026 1" Block $ 1.50 $ 1.64 2ndBlock 3.26 3.57 3"'Block 5.73 6.28 4"'Block 7.61 8.34 BLOCK THRESHOLDS (gallons per month) The threshold for the rate blocks vary with the size of the water meter as follows: Meter Size 1st 2nd ltd 4th (inches) Block Blad< mock Blad< 5/8" 5,000 5,001-15,000 15,001 40,000 > 40,000 1" 5,000 5,001-100,000 100,001 300,000 > 300,000 1-½" 5,000 5,001-400,000 400,001 1,000,000 > 1,000,000 2" 5,000 5,001-900,000 900,001 2,000,000 > 2,000,000 3" 5,000 5,001-2,000,000 2,000,001 -5,000,000 > 5,000,000 4" 5,000 5,001-4,700,000 4,700,001 -10,000,000 > 10,000,000 6" 5,000 5,001-10,000,000 10,000,001-25,000,000 > 25,000,000 8" 5,000 5,001-20,000,000 20,000,001-50,000,000 > so,000,000 10" 5,000 5,001-40,000,000 40,000,001-100,000,000 >100,000,000 12" 5,000 5,001-60,000,000 60,000,001-150,000,000 >150,000,000 C. AGRICULTURAL USE RATES (per 1,000 gallons) In addition to standby, power cost, and energy CIP charges, a consump- tion charge will be applied to all agricultural use customers as follows: Effective Effective Tuiy 1 2025 Tu]y l 2026 1st Block $1.50 $1.64 2nd Block 3.26 3.57 ltd Block 2.07 2.27 AGRICULTURAL BLOCK THRESHOLDS (gallons per month) 1st 2nd 3rd Meter Size Block Block Block All Sizes 5,000 5,001 -15,000 >15,000 In order to qualify for agricultural rates, applicants shall file annually with the Department, a written application and furnish upon request, satisfac- tory proof (as determined by the Department), of engagement in agricul- ture, stock raising or dairy farming on a commercial basis, and that water used in addition to the above is limited to one dwelling. The Department reserves the right to limit or restrict water flow to agricultural users in the event of water shortage or in the event water service to domestic users is disrupted or lowered because of agricultural water use. Applicants sball install backflow preventers which shall be inspected and approved by the Department before water service is granted. Agricultural rates are not applicable to canneries, mills or markets or other establishments engaged in the conversion or tteatment or packaging of agricultural products. D. FIRE PROTECTION - MONTHLY STANDBY CHARGES* For each connection of automatic fire sprinklers or other private fire protection, there shall be a standby charge per month, in addition to consumption, power cost, and energy CIP charges, based on the size of the connection as follows: Size of Service Effective Effective (inches) July 1. 2025 Julyt. 2026 2" s 29.24 $ 32.02 3" 56.86 62.26 4" 77.98 85.39 6" 193.32 211.68 8" 294.05 321.98 *Standby charge is a minimum monthly charge. E. FIRE LINE OR FIRE SERVICE METERS - MONTHLY STANDBY CHARGES* For each connection of combined fire & domestic services, there shall be a standby charge per month, in addition to consumption, power cost, and energy CIP charges, based on the larger size of the connection as follows: Size of Service Effective Effective (inches) July 1 2025 July 1 2026 3" $ 336.28 $ 368.23 4" 552.35 604.82 6" 1,096.58 1,200.75 8" 1,751.27 1,917.64 10" 2,519.69 2,759.06 *Standby charge is a minimum monthly charge. F. SERVICE LATERAL INSTALLATION CHARGES Installation charge for service lateral connection with a 5/8-inch meter: Effective July 1, 2010 Effective Same Side Cross Road January 1, 2021 Same Side Cross Road County Right-of-Way State Right-of-Way S 3,000.00 S 4,000.00 12,000.00 17,000.00 CONDITIONS: $ 3,000.00 $ 6,000.00 17,000.00 21,000.00 1) For special conditions such as concrete sidewalks, compaction tests, large cut or £11 areas where additional work is required, additional charges, as determined by the Department, shall be added to the installation charges listed above. 2) Deduct $40 if no meter is required. G. FACILITIES CHARGES A facilities charge will be applicable to all new service connections based on the maximum size of the meter and type of service the service lateral can support or by the number of lots, dwelling units or equivalent units in the development, whichever cost is larger. The unit cost in determination of the facilities charges shall be $6,095.00 for each additional lot, dwelling unit, or equivalent unit. The facil- ities charge is in addition to the service lateral installation charge. The schedule of facilities charges is as follows: Meter Effective Effective Size July 1, January 1, (inches} 2010 2021 5/8" First Connection s 1,190.00 $ 1,319.00 Additional Connection 5,500.00 6,095.00 1" Each Connection 13,750.00 15,237.00 1-½" Each Connection 27,500.00 30,474.00 2" Each Connection 44,000.00 48,759.00 3" Each Connection 82,500.00 97,518.00 4" Each Connection 137,500.00 152,372.00 6" Each Connection 275,000.00 304,744.00 8" Each Connection 495,000.00 487,591.00 10" Each Connection 797,500.00 1,279,927.00 12" Each Connection 1,182,500.00 1,615,146.00 H. TEMPORARY SERVICE ON HYDRANT CHARGES Each applicant for a temporary connection of a meter to a fire hydrant shall be charged an initial payment, to be set periodically by the Department, in addition to consumption, standby, power cost, and energy CIP charges. Service shall be limited to a period not longer than 180 calendar days. The Department reserves the right to deny any application or remove any temporary connection at anytime. I. STANDPIPE CHARGES New customers obtaining water service from Department of Water Supply standpipe facilities shall be charged an initial payment and a proportional cost of the standpipe facility on a monthly basis. These charges are as follows and are in addition to consumption, standby, power cost, and energy CIP charges: Effective Effective Tulyl.2025 July 1. 2026 Initial Payment Meter Size 5/8" $ 297.29 $ 325.54 1" 599.46 656.41 1-½" 747.30 818.29 2" 895.13 980.17 Amortized Installation Cost -Monthly Motet Size 5/8" s 16.25 17.79 1" 32.49 35.58 1-½" 40.61 44.47 2" 47.11 51.59 J. POWER COST CHARGES (per 1,000 gallons) All water use shall be subject to the imposition of a Power Cost Charge in addition to consumption, standby, and energy CIP charges. The Department shall calculate the rate based on actual power costs and consumption every two months or for the period since the last revision to the power cost charge. Current and historic power cost charges are as follows: Effective Date June 1, 2025 February 1, 2025 September 1, 2024 Mayl,2024 February 1, 2024 Power Cost Charges $2.08 $2.32 $3.04 $2.77 $2.37 K. ENERGY CIP CHARGES (per 1,000 gallons) All water use shall be subject to the imposition of an Energy CIP Charge in addition to consumption, standby, and power cost charges. The rate shall be adjusted annually in order to fund projects designed to improve the Department's energy efficiency. The current energy CIP charge is as follows: Effective Date Energy CIP Charge July 1, 2016 $0.05 APPENDIX B. Water System Standards Consumption Tables Manua Lani Resort -Water Use Study DNISION 100 -PLANNING Table 100-18 -DOMESTIC CONSUMPTION GUIDELINES AVERAGE DAILY DEMAND* ZONING DESIGNATION HAWAII KAUAI MAUI OAHU RESIDENTIAL: Single Family or Duplex 400 gals/unit 500 gals/unit 600 gals/unit 500 gals/unit or 3000 gals/ acre or 2500 gals/ acre Multi-Family Low Rise 400 gals/unit 350 gals/unit 560 gals/unit 400 gals/unit or 5000 gals/ acre or 4000 gals/ acre Multi-Family High Rise 400 gals/unit 350 gals/unit 560 gals/unit 300 gals/unit COMMERCIAL: Commercial Only 3000 gals/acre 3000 gals/ acre 6000 gals/ acre 3000 gals/ acre Commercial/Industrial Mix --5000 gals/acre 140 gals/1000 sq. ft. 100 gals/1000 sq. ft. Commercial/Residential Mix --3000 gals/acre 140 gals/1000 sq. ft. 120 gals/1000 sq. ft. RESORT (To include hotel for Maui 400 gals/unit ( 1) 350 gals/unit 350 gals/unit 350 gals/unit only) or 17000 gals/acre or 4000 gals/ acre LIGHT INDUSTRY: 4000 gals/ acre 4000 gals/ acre 6000 gals/ acre 4000 gals/ acre SCHOOLS, PARKS: 4000 gals/ acre 4000 gals/ acre 1700 gals/acre 4000 gals/ acre or 60 gals/ student or 60 gals/ student or 60 gals/ student or 60 gals/ student AGRICULTURE: 2,500 gals/acre 5000 gals/ acre 4000 gals/ acre * -Where two or more figures are listed for the same zoning, the daily demand resulting in higher consumption use shall govern the design unless specified otherwise. (1) -Subject to special review and control by the Manager. 111-3 DNISION 100 -PLANNING Table 100-19 -FIRE FLOW REQUIREMENTS LAND USE FLOW (GPM)/DURATION (HRS)/FIRE HYDRANT SPACING (FT.) HAWAII KAUAI MAUI Agriculture 500/0.5/600 (1) 250/1/500 500/2/500 Rural 1000/2/500 Single Family (2) (4) 1000/2/350 Duplex 1500/1/300 (4) 1250/2/350 PUD Townhouse and Low Rise 1500/1/300 (4) (5) Apartments Schools, Neighborhood Businesses, Small 2000/2/300 2000/2/350 2000/2/250 Shopping Centers, Hotels (except Maui), and High Rise Apartments Light Industry, Downtown Business, 2,000/2/300 3000/3/350 2000/2/250 Large Shopping Center, and Hospitals Heavy Industry, Hotels 2,000/2/300 3000/3/350 2,500/2/ 250 (1) -Applies to one acre lot size or less (2) -10,000 sq. ft. or larger lot size = 500/2/600; Less than 10,000 sq. ft. lot size = 1000/1/600 (3) -Subject to special review and control by Manager (4) -R-2 = 500/1/500 R-4 = 750/2/500 R-6 = 1000/2/500 R-10 = 1250/2/350 R-20 = 1500/2/350 RR-10 = 1500/2/350 RR-20 = 2000/2/350 (5) -A-1 = 1500/2/250 A-2 = 2000/2/250 Note.:. OAHU 1000/0.5/700 1000/1/350 1000/1/350 1500/1/250 2000/2/250 4000/3/250 (3) 1. On dead end streets, the last F.H. shall be located at one half the spacing distance for F.H.s from the last house/unit (frontage property line or to the driveway/access for the property). 2. Spacing of fire hydrant shall be measured along the roadway. 111-4 DNISION 100 -PLANNING Table 100-20 -DEMAND FACTORS Maximum Island Daily Demand Peak Hour Hawaii 1.5 x Average Day 5.0 x Average Day Kauai, Maui, 1.5 x Average Day 3.0 x Average Day Oahu 111.06 PIPELINE SIZING. Pipelines shall be sized to meet the following requirements: 1. Maximum daily flow plus fire flow with a residual pressure of 20 psi at critical fire hydrant. 2. Peak hour flow with a minimum residual pressure of 40 psi. 3. In determining the carrying capacity of the mains, the "C"* values to be applied are shown in Table 100-21. Table 100-21 -11c11 • FACTORS Pipe Diameter (In.) "C" 4", 6" 100 8", 12" 110 16", 20" 120 24" and Larger 130 * Not for metallic non-cement lined pipe. 4. Maximum velocity in distribution main (without fire flow) is 6 feet per second. 5. For Maui Only: In addition, the maximum velocity in mains shall apply as follows: a. Distribution mains -JO feet per second with fire flow at max day domestic flow. b. Transmission mains without water services or fire flow -20 feet per second. c. Fire lines -13 feet per second. 111-5 APPENDIX C. Memorandum for Mauna Lani Resort's Present Water Use of the Department of Water Supply's Lalamilo System Relative to its Allocation from the System by Tom Nance Water Resource Engineering dated March 20, 2017 Manua Lani Resort -Water Use Study Re omce Engineering MEMORANDUM To: From: Tetsuaki Okada -Mauna Lani Resort (Operation), Inc. Tom Nance No. of pages: § Email: tokada@maunalani.com greg@tnwre.com todd@tnwre.com Original □ will Ii'.'.! will not be mailed to you. March 20, 2017 16-40 Subject: Mauna Lani Resort's Present Water Use of the Department of Water Supply's Lalamilo System Relative to its Allocation from the System Introduction This memo and its attachments present Mauna Lani Resort's (MLR) metered water use of the DWS' Lalamilo System for the two year period from January 2015 through January 2017. This use is then compared to MLR's allocated supply from the Lalamilo System. Mauna Lani Resort's Allocated Supply from DWS' Lalamilo System As set out on Exhibit 4 of the April 2006 Tri-Party Agreement between Mauna Lani Service, Mauna Kea Properties, and the Water Board of the County of Hawaii, MLR's share of the capacity of DWS' Lalamilo System is 6.013 million gallons per day (MGD). This amount is expressed as the "maximum day use". The agreement states specifically how the maximum day use is to be calculated from DWS' bi-monthly compilations of metered water use. As stated on page 3 of the agreement, the 12- month moving average (12-MAV) of metered use is defined as the average water use. The maximum day use is defined as 1.5 times this average water use. The peak of the calculated maximum day use defines how much of the allocated supply has been used. Mauna Lani Resort's Bi-Monthly Metered Use from January 2015 to January 2017 Figure 1 is a plot of MLR's total bi-monthly metered water use for the 2-year period from January 2015 through January 2017 and the calculated 12-month moving average of this water use (the 12-MAV) for the second of these two years. Figure 2 compares "maximum day'' of this metered use, calculated as 1.5 times the 12-MAV, to MLR's 6.013 MGD allocated supply from the Lalamilo System. Based on this 560 N. Nimitz Hwy. -Suite 213 • Honolulu, Hawaii 96817 • Phone: (808) 537-1141 • Fax: (808) 538-7757 • Email: tom@tnwre.com Page2 March 20, 2017 16-40 tabulation, 1.909 MGD of the 6.013 MGD supply allocation remains to supply projects not fully built out and/or occupied. Details of Mauna Lani Resort's Average Water Use for the January 2016 to January 2017 Period Table 1 is a listing of the development status of metered water uses within the Resort, their average water use over the January 2016 through January 2017 period, and their average use per occupied unit. There is a wide range of average use per occupied unit for both multi-family and single family projects. All of these use rates exceed DWS standards, a result which is typical for all the high end resorts in West Hawaii. Attachments ec: Greg Fukumitsu and Todd Yonamine -TNWRE, Inc. 4.0 3.5 3.0 g2.5 (!) :ii:: -Cl) ~ 2.0 Cl) C, l'!! Cl) ~ 1.5 1.0 0.5 - 0.0 1/1/15 Figure 1. Metered Potable Water Use at Mauna Lani Resort from January 2015 through January 2017 Jr / -----.; 3/18/15 6/2/15 _,(),__ ........ .......... 8/17/15 _J"\...... ::. - 11/1/15 - 1/16/16 Date _J ~ --~ ---- 4/1/16 6/16/16 8/31/16 ~Bi-Monthly Metered Use ~12-MAV of Metered Use J :'\. - 11/15/16 4.0 3.5 3.0 -'\. --- ~ 2.5 2.0 1.5 1.0 0.5 0.0 1/30/17 6.5 6.0 5.5 5.0 4.5 c4.o (!) :E ";' 3.5 Ill ::, cu 3.0 C> l'!! ,i 2.5 2.0 1.5 1.0 0.5 0.0 0 1/1/15 ,T 3/18/15 .J:r Figure 2. Interpretation of MLR's Use of its Allocated Supply Based on Metered Water Use from January 2015 through January 2017 I I MLR's 6.013 MGD Allocated Supply Defined Maximum Day of Use --------...... l".ll. --------- ~~ ~ J ._ ----""'------...... 6/2/15 8/17/15 11/1/15 1/16/16 Date 4/1/16 6/16/16 ' 1.909 MGD Unused Allocation ~ ---- . -J -~ ----" -.... I "'u L_ 12-MAV of Use 6.5 6.0 5.5 5.0 4.5 4.0 3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0 8/31/16 11/15/16 1/30/17 ~Bi-Monthly Metered Use ~12-MAV of Metered Use ~1.5 Times the 12-MAV -MLR's Allocated Supply Project / Parcel Name Hotel Rooms Mauna Lani Fairmont Multi-Family Mauna Lani Terrace Mauna Lani Point Islands Villages Ke Kailani (MF) Golf Villas Fairways Kulalani (Golf Partners) Ka Milo (Stanford Carr) Palm Villas Single Family 49 Black Sand Beach Ke Kailani (SF) Estates Champion Ridge Nohea (Phase 1) Nohea (Phase 2) Cape Pauoa Beach Laule'a (Parcel P) Nomura Hawaiian Village Other Metered Water Uses Shops at Mauna Lani Beach Club Golf Clubhouse Mauna Lani Spa Pre-School Resort Association Wastewater Treatment Plant Entry/Guard Shack Tokyu Admin o:_16-40 Table 1. Average Metered Use in 2016 in the Mauna Lani Resort TMK 6-8-22:15 6-8-22:08 6-8-22:06 6-8-22:28 6-8-22:21 6-8-22:04 6-8-22:64 6-8-22:52 6-8-22:05 6-8-22:41 6-8-22:07 6-8-22:18 6-8-33:01 to 53 6-8-36:01 to 41 6-8-24:01 to 19 6-8-27:01 to 35 6-8-43:01 to 35 6-8-43:37 6-8-24:01 to 14 6-8-34:01 to 45 6-8-22:24 6-8-22:25 6-8-22:02 6-8-24:39 6-8-22:43 6-8-22:19 6-8-01:58 6-8-22:29 6-8-01:49 6-8-01:57 6-8-01:57 Type of Units Hotel Rooms Hotel Rooms MF MF MF MF MF MF MF MF MF MF SF SF SF SF SF SF SF SF SF SF Number of Units at Full Build Out 341 540 80 116 46 130 20 87 126 126 137 44 48 39 19 33 30 53 14 44 17 14 Number of Units Presently Built 341 540 80 116 46 130 4 87 126 62 49 44 38 3 15 25 2 0 11 42 0 14 Totals Based on Jan. 2016 to Jan. 2017 Metered Use Average GPO 238,913 298,998 60,389 104,507 101,502 167,909 20,530 79,685 121,867 191,979 124,154 49,062 306,018 30,795 35,778 123,017 19,419 8,691 62,634 278,760 0 62,165 30,768 7,052 23,082 37,053 2,310 57,768 7,268 15,575 11,276 2,678,924 I Average GPO/Unit 701 554 755 901 2207 1292 5133 916 967 3096 2534 1115 6260 10265 2385 3379 9710 5694 4249 4440 APPENDIX D. Agreement-Tri Party, Parker Well Nos. 3 & 4, Water Board of the County of Hawaii, Mauna Lani Service, Inc, Mauna Kea Properties, Inc. Manua Lani Resort -Water Use Study DEPARTMENT OF WATER SUPPLY • COUNTY OF HAWAl'I 3 4 5 KEKOANAO'A STREET, SUITE 20 • HILO, HAWAl'I 96720 TELEPHONE (808) 961-8050 • FAX (808) 961-8657 Pamela J. Larson, Esq. Watanabe Ing & Komeiji LLP 999 Bishop Street, 23rd Floor Honolulu, HI 96813 AGREEMENT -TRI PARTY April 11, 2006 WATER BOARD OF THE COUNTY OF HAW AI'I, MA UNA LANI SERVICE, INC., AND MAUNA KEA PROPERTIES, INC. PARKER WELL NO. 3 AND PARKER WELL NO. 4 Enclosed is an executed copy of the above-mentioned agreement for your files. If you have any questions, please call us at 808-961-8050. pt Enc. Sincerely yours, ilton D. Pavao, P.E. Manager . .. Water bring-j prog-rMj ... The Department of Water Supply is an Equal Opportunity provider and employer. To file a complaint of discrim'1nation, write: USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington DC 20250-9410. Or call (202) 720-5964 (voice and TDD) AGREEMENT This Agreement is made this 6th day of Apri 1 , 2006 by and among the WATER BOARD OF THE COUNTY OF HAWAl'I ("Board"), MAUNA LANI SERVICE, INC., a Hawai'i corporation ("MLS"), and MAUNA KEA PROPERTIES, INC., a Hawai'i corporation ("MKP"). RECITALS: A. WHEREAS, the Department of Water Supply ("DWS") currently operates and maintains the Lalamilo Water System ("Lalamilo System") in South Kohala on the Island of Hawai'i; and B. WHEREAS, as a part of its regional water resource development program, Mauna Lani Resort, Inc., MLS' predecessor in interest, previously developed Parker Well No. 1 and Parker Well No. 2 at the 1200 foot level immediately south of the DWS Lalamilo System wells which have been connected to the Lalamilo System. The Lalamilo System now includes Parker Well No. 1, Parker Well No. 2, and Lalamilo Wells A through D (hereinafter referred to as "Lalamilo Wells"); and C. WHEREAS, MLS wishes to develop the remaining two (2) Parker Well sites known as Parker Well No. 3 and Parker Well No. 4, and connect those wells to the Lalamilo System. Exhibit 1, attached hereto, shows the location of Parker Wells Nos. 1 through 4 (hereinafter collectively called the "Parker Wells") and the Lalamilo Wells; and 1 D. WHEREAS, MLS has agreed to assign a portion of the water from Parker Well No. 3 to MKP; and E. WHEREAS, the parties wish to set forth their agreement regarding development of Parker Wells Nos. 3 and 4 and the allocation of water from those wells; and F. WHEREAS, the parties also wish to set forth their agreement regarding the standards to be used in determining the allocation and usage of water from the Lalamilo Wells and the Parker Wells. NOW THEREFORE, THE PARTIES HEREBY COVENANT AND AGREE AS FOLLOWS: 1. Design Criteria. The parties agree that the following design criteria shall be used in determining the allocation and usage of water from the Lalamilo Wells and Parker Wells for MLS, MKP and DWS: 1. 1 . Except as specified below, all design criteria shall be as stated in DWS' Water System Standards 2002 and DWS' Rules and Regulations effective October 21, 2004. 1.2. In determining the safe supply capacity from the Lalamilo Wells and Parker Wells, the standby criterion shall be a total of two wells. Specifically, standby will be defined as one of the 1000 GPM Lalamilo wells and one of the 1250 GPM Parker wells. This standby criterion shall remain the same if and when Parker Well No. 3 and Parker Well No. 4 are added to the system. 1.3. In allocating the safe supply capacity of the Lalamilo Wells 2 and Parker Wells among DWS, MKP and MLS, shares shall be based on each party's share of the total installed pumping capacity. Shares of the installed pumping capacity and allocated safe supply among the existing wells are shown on Exhibit 2, attached hereto. When Parker Well No. 3 and Parker Well No. 4 are added to the system, the same method shall be used to calculate each party's allocable supply of the system's safe capacity. 1.4. In developing Parker Well No. 3 and Parker Well No. 4, the objective is to install 1250 GPM pumps, subject to satisfactory pump test results and DWS' concurrence with the interpretation of these results. Regardless of the pump capacities ultimately installed, 10% of the capacities of Parker Well No. 3 and Parker Well No. 4 will be allocated to DWS. 1.5. In determining the use by MLS and MKP of their allocated supply from the Lalamilo Wells and Parker Wells, respective average use shall be defined in this situation as the 12-month moving average (12- MAV) of DWS' meter readings. Maximum day use shall be defined as 1.5 times this 12-MAV of metered use. MLS's and MKP's use of its allocated supply and the number of residential units it can develop with this allocated supply shall be defined as its peak maximum day use as defined herein. DWS design standards for residential use shall not apply. Figures 1 and 2, attached hereto, illustrate average use, the 12-MAV, and maximum day use in comparison to allocated supply for MLS and MKP. 3 1.6. Owing to the unique diurnal pattern of water use within Mauna Lani Resort, distribution pipelines from the 319-foot tank to and within Mauna Lani Resort shall be sized to meet both of the following criteria: (i) to maintain a residual pressure of at least 40 pounds per square inch (PSI) at peak flow rate everywhere within the system with velocities not exceeding six (6) feet per second (FPS); and (ii) To provide fire flow rates with a minimum residual pressure of 20 PSI everywhere within the system with coincident maximum day flow rate as defined in paragraph 1.5. Determination of the peak flow rate in the application of criterion (i) above shall consider both the morning and evening domestic use peaks and the nighttime irrigation use peak and shall be approved by DWS. 2. Allocation of Water from Parker Well No. 3 and Parker Well No. 4. Water from Parker Well No. 3 will be allocated as follows: ten percent (10%) to DWS; seventy percent (70%) to MLS; and twenty percent (20%) to MKP. Water from Parker Well No. 4 will be allocated as follows: ten percent (10%) to DWS; ninety percent (90%) to MLS. Exhibit 3, attached hereto, summarizes the total supply allocations to all three parties upon the completion of Parker Well No. 3. Exhibit 4, attached hereto, summarizes the total supply allocations to all three parties upon the completion of Parker Well No. 4. MLS and MKP may assign all or a portion of their water allocations described herein to a third party for use within MLS' or MKP's development areas only, or to the other party, or their or 4 the other party's successors or assigns, within the respective development areas only, and subject to the written consent of the Board. (See Exhibit 5 and Exhibit 6, attached hereto, which define the development areas of MLS and MKP, respectively). Pursuant to the requirement of the Board, the allocations to MLS and MKP shall be reserved for their use for a period of 20 years from the date Parker Well No. 3 and Parker Well No. 4 are dedicated to the Board, after which the unused allocations shall automatically revert to DWS. "Unused allocations" as used in this paragraph shall not include those situations where a development has been constructed, a service lateral is installed to the development, and there remains an available allocation to service a particular parcel within the development. 3. Development of Parker Well No. 3 and Parker Well No. 4. 3.1. Construction. MLS will construct the following source, storage, and transmission capacity (collectively the "Parker 3 and 4 Improvements"), in order to supply the anticipated future build-out of the presently zoned land in MLS' development area (Note: All tank elevations refer to overflow elevations): (a) Parker Well No. 3 and Parker Well No. 4, each with a 1250 GPM pump, subject to and adjusted for actual pump test results with DWS' concurrence. (b) A 2. 0 MG tank at 1103 foot elevation, with site to be acquired by MLS in fee simple or as a perpetual exclusive easement and dedicated, free and clear of all liens and encumbrances, except for easements acceptable to DWS in its sole discretion, to the Board, tentatively sited on Waikoloa Village Association property. (c) A parallel pipeline between the tanks at 1103 5 foot and 610-foot elevations, sized to meet the maximum use of Lalamilo Wells and Parker Wells in accordance with DWS standards. (d) A 2.0 MG tank at 610-foot elevation, with site to be acquired by MLS in fee simple or as a perpetual exclusive easement and dedicated, free and clear of all liens and encumbrances, except for easements acceptable to DWS in its sole discretion, to the Board, tentatively sited on Waikoloa Village Association property. (e) A parallel pipeline between the 610-foot and 319-foot tanks, sized to meet the maximum use of Lalamilo Wells and Parker Wells in accordance with DWS standards. A parallel pipeline from the 319-foot tank to the makai side of Queen Kaahumanu Highway, sized to meet the maximum use of Lalamilo Wells and Parker Wells in accordance with DWS standards. 3.2. Connection and Dedication. MLS agrees to provide the connection of Parker Well No. 3 and Parker Well No. 4 to the Lalamilo System and agrees to dedicate the Parker 3 and 4 Improvements, the land for the well sites, and easements for all tank sites and pipelines to the Board. The Board agrees to allow connection of Parker Well No. 3 and Parker Well No. 4 to the Lalamilo System and to accept the dedication of the Parker 3 and 4 Improvements, the land for the well sites, and easements for all tank sites and pipelines upon completion, provided all improvements pass final inspection by DWS to assure conformance to DWS' standards of construction, and provided that fee simple title or perpetual exclusive easements, free and clear of all liens and encumbrances, except for easements acceptable to DWS in its 6 sole discretion, can be given to the Board. Pursuant to Rule 4-11 of the DWS Rules and Regulations effective October 21, 2004, the Water Board specifically finds that modification of Rule 4-10, which rule requires fee simple conveyance to the Water Board of any tanks or reservoirs, is reasonably necessary and expedient as the property in the Waikoloa Village on which the tanks may be located at a suitable elevation is owned by the Waikoloa Village Association, and acquiring title in fee simple would be difficult, time consuming and may necessitate the Water Board becoming members of the Waikoloa Village Association. 3.3 Reduction of Allocation. The allocable supply from Parker Well No. 3 and Parker Well No. 4 as described in Sections 1.4, 1.5, and 2 above is contingent on the wells being able to produce the necessary quantities of water at salinity levels at or below 160 mg/L as chlorides. If, at any time before pumping Parker Well No. 3 and Parker Well No. 4 for 10,000 hours each, either Parker Well No. 3's or Parker Well No. 4's chloride levels rise above 160 mg/L, use of both or either wells shall be curtailed and/or adjusted as determined by DWS to maintain chlorides below 160 mg/L. If curtailing or adjusting the pumping rate causes the wire-to-water efficiency to drop three (3) or more percentage points, MLS shall be required to provide and install (a) replacement pump(s) designed at peak efficiency at the curtailed rate within nine 7 (9) months from written notice from DWS. The readjusted allocable -supply to all parties (MLS, MKP, and DWS) based o~ this reduction shall be in the proportions specified in Section 2 above. 3.4 Development Schedule. A tentative schedule for implementation of the Parker 3 and 4 Improvements is attached hereto as Exhibit 7. MLS shall implement all of the required improvements in their entirety in a single phase of construction. 4. Time. Time is of the essence for this Agreement. Performance of this Agreement shall commence within sixty (60) days of the execution of this Agreement and shall be completed on or before two (2) years from the date of the execution of this Agreement unless otherwise modified upon the approval of the Board, and except to the extent that such performance is delayed by force majeure events. "Force majeure events" shall mean any act of God, war, strikes, and work stoppages, or other similar matters beyond the control of MLS. 5. Rates and Charges. MLS and MKP shall pay for the use of water service from Parker Well No. 3 and Parker Well No. 4 distributed through the Lalamilo System in accordance with DWS' prevailing rate schedule at the time when the water is used. With respect to any new potable water meter installed on any undeveloped property within MLS' or MKP's development areas that are owned by MLS, MKP or their affiliates as of the date of this Agreement, with the exception of those parcels or lots that are or will be serviced by a separate non- potable water irrigation system, MLS or MKP, or the future owner or developer of such property, shall install separate meters for all irrigation use at their expense 8 and shall execute (an) Irrigation Agreement(s) with DWS for each irrigation meter substantially in the form attached hereto as Exhibit 8. Facilities charges credit, in accordance with Section 4-6 of DWS' Rules and Regulations, shall be granted for the drilling and outfitting of the wells, storage tanks, and transmission pipelines constructed under this agreement. To receive a credit for the drilling and outfitting of the wells, and construction of the storage tanks and transmission pipelines, MLS's and MKP's construction costs must be more than the facilities charges. 6. MLS's Credit for Installed Storage Capacity. Upon completion of the two proposed storage tanks, MLS's credit for installed storage capacity shall be 6.05 MG as follows: Existing Tanks MG of Storage 50% of the 0.10 MG, 1103-Ft. Tank.... 0.05 100% of the 0.50 MG, 1103-Ft. Tank.. 0.50 50% of the 1.0 MG, 610-Ft. Tank........ 0.50 100% of the 1.0 MG, 319-FtTank....... 1.00 Total for Existing Tanks .... 2.05 Proposed Tanks 100% of 2.0 MG Tank, 1103-Ft. tank 2.00 100% of the 2.0 MG, 610-Ft Tank. 2.00 Total for Proposed Tanks... 4.00 Total Storage Volume... 6.05 If MLS completes the two new storage tanks as set forth in Section 3.1 and its maximum day use as defined herein exceeds 6.05 MGD, payment of the applicable portion of the prevailing facilities charges shall be made for the maximum day use in excess of 6.05 MGD. 9 7. Interim Water Service. Upon execution of this Agreement and with the prior approval of DWS, MLS shall order and purchase the pump, motor, controls, power cable, and column components for the Parker Well No. 3 based on a 1250 GPM pumping capacity (hereinafter referred to collectively as the "Stand-by Equipment"). This Stand-by Equipment shall be stored by MLS and shall be made available for installation in either the Parker Well No. 1 or Parker Well No. 2, if necessary and requested by DWS, at any time prior to its installation in the Parker Well No. 3. Also, when and if necessary during the period from the execution of this Agreement until the dedication of Parker Well No. 3 to the Board (the "Interim Period") and at DWS' request, MLS and MKP shall reduce the irrigation use at facilities within the Resort that they control and make continued reasonable efforts to reduce the irrigation use by others in their respective resorts. The standard 12-month warranty period for the Parker Well No. 3 pump, motor, and related components shall not begin until this equipment is installed, accepted by DWS, and made operational in one of the Parker Wells. If it becomes necessary to install any of the Stand-by Equipment in either the Parker Well No. 1 or Parker Well No. 2 prior to the completion of the Parker Well No. 3, all costs to complete this installation are to be borne by DWS. These costs shall include: pulling the pump equipment from either the Parker Well No. 1 or Parker Well No. 2 and installing and making fully operational the replacement pump equipment used for that well. Should the pre-purchased stand-by pump equipment be used to replace the pump equipment in either Parker Well No. 1 or Parker Well No. 2, MLS shall at its sole expense purchase 10 all of the pump equipment to be used for both Parker Well Nos. 3 and 4. MLS may also repair the removed pump equipment, subject to the approval of DWS, for use in either Parker Well No. 3 or 4. Subject to the Stand-by Equipment being stored and available on island, stand-by during the Interim Period shall be defined as one of the 1000 GPM Lalamilo wells. The availability of the pre-purchased Stand-by Equipment , together with MLS' and MKP's reduction of irrigation use, including possible termination of irrigation use when requested by DWS in accordance with any Irrigation Agreement(s) (in the form attached hereto as Exhibit 8), and MLS' and MKP's continued reasonable efforts to reduce the irrigation use by others in their respective development areas, shall provide standby for either the Parker Well No. 1 or Parker Well No. 2 during the Interim Period. Exhibit 9, attached hereto, lists the total supply allocations to MLS, MKP, and DWS during the Interim Period. Neither DWS nor the Water Board nor its employees, members or agents shall be responsible for any damage to landscape based on the reduction or termination of irrigation, and MLS and MKP agree to defend and indemnify the DWS, Water Board and its employees, members and agents should any claim, demand or lawsuit be made. 8. Satisfaction of Requirements. DWS acknowledges that construction of the pipeline and other facilities described in Section 3.1 above satisfies any remaining construction obligations of MKP and MLS under that certain Agreement dated July 11, 1996 relating to Parker Well No. 2 (the "Parker 2 Well Agreement"). 11 9. Sharing of Costs. The costs of improvements required to be made by MLS pursuant to this Agreement shall be shared by MLS and MKP pursuant to a separate agreement between MLS and MKP, a copy of which shall be provided to DWS. 10. Project Completion Guarantee. Within sixty (60) days after the date of this Agreement, MLS shall provide to the DWS an estimate of the total costs of the Parker 3 and 4 Improvements prepared by Tom Nance Engineering or other licensed civil engineer as determined by MLS and MKP (the "Cost Estimate") and an allocation of those costs between MLS and MKP. The Cost Estimate shall be subject to the approval of DWS. Also within sixty (60) days after the date of this Agreement, MLS, MKP and the Board shall execute and deliver an Escrow Agreement with Title Guaranty Escrow Services, Inc. or other escrow agency as determined by MLS and MKP("TG"), which shall contain the terms set forth below, as well as such other terms and conditions as may be agreed upon by the parties thereto: a. TG shall establish two separate escrow accounts: (i) the "MLS Escrow", and (ii) the "MKP Escrow". Upon execution of the Escrow Agreement, MLS shall deposit its allocated share of the approved Cost Estimate into the MLS Escrow and MKP shall deposit its allocated share of the approved Cost Estimate into the MKP Escrow. b. On or before the 15th day of every July and January after the date of this Agreement, MLS shall provide to DWS an updated estimate of the remaining cost of completion of the Parker 3 and 4 Improvements prepared by 12 Tom Nance Engineering or other licensed civil engineer as determined by MLS and MKP, and a statement from TG showing the total amounts remaining in the MLS Escrow and the MKP Escrow. If total amounts remaining in the MLS Escrow and the MKP Escrow are not sufficient to pay the updated estimated remaining cost of completion, MLS shall deposit and/or cause MKP to deposit the amount of any such deficiency into the MLS Escrow and/or MKP Escrows. c. The funds deposited into the MLS Escrow and the MKP Escrow shall be used solely for the construction of the Parker 3 and 4 Improvements, as required under this Agreement. d. Until such time as the DWS notifies TG in writing of a default by MLS under this Agreement in accordance with subsection (h) below, TG shall be authorized to disburse funds from the MLS Escrow and/or MKP Escrow upon written instruction signed by MLS, together with an invoice for the total amount of the disbursement(s) approved in writing by the construction manager for MLS and MKP, and the DWS. e. At the same time as MLS instructs TG to make any disbursement from the MLS Escrow and/or the MKP Escrow, MLS shall provide to MKP and DWS a copy of the disbursement request (including all attachments), together with a statement of the allocation of the constructions costs to be disbursed between MLS and MKP. f. All interest accrued on the MLS Escrow shall belong to MLS and all interest accrued on the MKP Escrow shall belong to MKP. 13 g. Upon delivery to TG of certification by DWS that the Parker 3 and 4 Improvements have been completed, accepted, and dedicated to the Board, any funds remaining in the MLS Escrow shall be returned to MLS and any funds remaining in the MKP Escrow shall be returned to MKP. h. In the event that MLS and/or MKP fail to timely perform any of its obligations under Sections 3 or 4 of this Agreement, the DWS shall give MLS and MKP written notice of such failure. If MLS and/or MKP does not cure the failure within sixty (60) days after receipt of such written notice, MLS and/or MKP shall be in default under this Agreement, and the DWS shall have the right to give notice of such default to TG. After the DWS has given such notice to TG, TG shall be authorized to disburse any and all remaining funds from the MLS Escrow and/or the MKP Escrow to the Board upon written instruction by the DWS. All such funds shall be used by the Board solely for the completion of the Parker 3 and 4 Improvements. Upon any such disbursement of funds to the Board, MLS and MKP shall be deemed to have satisfied all of their obligations to the Board under this Agreement if the amounts remaining in the MLS Escrow and MKP Escrow are sufficient to cover the remaining costs of completing the Parker 3 and 4 improvements plus thirty percent (30%). To determine whether MLS's and MKP's Escrow accounts are adequately funded to complete the Parker 3 and 4 Improvements, a cost estimate shall be completed by DWS for the remaining work to complete the Parker 3 and Parker 4 Improvements. MLS and MKP shall have thirty (30) days from the completion of the DWS' cost estimate to increase the funds in their escrow accounts to meet the cost estimate, plus thirty percent 14 (30%). If within thirty (30) days the full amount is not deposited in MLS's and MKP's escrow accounts to complete the Parker 3 and Parker 4 Improvements, neither MLS nor MKP nor their successors or assigns shall be entitled to any of the water allocation set forth in this agreement, and neither DWS nor the Board shall be obligated to complete the Parker 3 and Parker 4 Improvements, 11. Miscellaneous. 11.1. This Agreement shall be governed by and interpreted in accordance with the laws of the State of Hawai'i. 11.2. This Agreement shall be binding on the successors and assigns of each party. Without limiting the foregoing, until such time as no construction obligations remain under this Agreement, if MLS and/or MKP cease(s) to exist or no longer own(s) any interest in its respective development area, MLS and/or MKP, as applicable, shall assign, with the written consent of the Board, all of its rights and obligations under this Agreement to another entity which has sufficient assets to satisfy the remaining construction obligations hereunder, including those obligations under paragraph 8. 11.3. This Agreement may be modified only by written agreement signed by all parties. 11.4. Each party will execute, acknowledge and deliver or cause to be executed, acknowledged and delivered, such further instruments and documents and to do any and all other acts as may be reasonably necessary to carry out the intent and purpose of this Agreement. 15 IN WITNESS WHEREOF, the parties have executed this Agreement as of the date written above. MAUNA LANI SERVICE, INC. MAUNA KEA PROPERTIES, INC. Name: i By --\,L,L-./l-'-"'-;./;.--4,,·4--/y___:,_________::7 __ _ Name: Yoichi Asari Title: President Title: President 16 WATER BOARD OF THE COUNTY OF :AW~n!Ph~ Name: THOMAS S. GOYA Title: Vice-Chairman APPROVED AS TO FORM: Deputy Corporation Counsel County of Ha~'i / /; Dated: ;)£'! 0 l 1 _Manager, I 17 STATE OFHAWAI'I ) ) ss. COUNTY OF HAW AI'I) On this 6th day of April 2006, before me appeared THOMAS S. GOY A, to me personally known, who, being by me duly sworn, did say that he is the Vice-Chairman of the Water Board of the County ofHawai'i and that the seal affixed to the foregoing instrument is the seal of the Department of Water Supply of the County ofHawai'i, and that the instrument was signed and sealed in behalf of the Water Board by authority of the Water Board and said THOMAS S. GOYA, acknowledged the instrument to be the free act and deed of the Water Board. Agreement -Tri Party Parker Well Nos. 3 and 4 Water Board of the County ofHawai'i Mauna Lani Service, Inc. Mauna Kea Properties, Inc. ~4Z,_~r;~#~~--~--~~---ff, ~ryPublic Pats~chi State ofHawai'i My commission expires: July 3, 2007 Ex. 1.0 MG Tank -1-1--1----~ 319-Ft. .)... p,,. I I \-\,..~, 2) of , .. \.o 6 - 0 6 - Future Tank (2.0 MG) Walkoloa Village Association (TMK:6-8-02:Lot 19) Lalamilo Well D ex.16" ex.16" Lalomilo Well C Lalamilo Well A Ex. 0.10 & 0.50 MG 1103-Ft. Tanks &: Lalamno Well B .....-------Exist. F'arker Well No. 2 PARKER RANCH (TMK: 6-8-01 :LOT 1) ---Exist. Parker Well No. New 12" L=1810' ----Porker Well No. 4 Exhibit 1 of the Lalamilo and Parker Weis 2000' 1000' 0 A A 2000' 4000' Exhibit 2. Summary of Well Pumping Capacities and Allocated Supply of the Existing Lalamllo and Parker Wells System Present Installed Well Pumping Capacities We I I GPM MGD Lalamllo Wells A 700 1.008 B 1000 1.440 C 1000 1.440 D 1000 1.440 Parker Wells 1 1250 1.800 2 1250 1.800 Total Installed Pumping Capacity 6200 8.928 Pro-Rata Shares of Individual Existing Well Capacities MLR MKP DWS Well % Share Equiv.MGD %Share Equiv. MGD % Share Equiv. MGD Lalamilo A 50.00 0.504 50.00 0.504 0.00 0.000 B 34.72 0.500 34.72 0.500 30.56 0.440 C 34.72 0.500 34.72 0.500 30.56 0.440 D 90.00 1.296 0.00 0.000 10.00 0.144 Parker 1 " 90,00 1 .620 0.00 0.000 10.00 0.180 2 45.00 0.810 45.00 0.810 10.00 0.180 Pro-Rata Share of the Present Installed Capacity :MGD 5.230 2.314 1.384 : % of Total 58.580 25.918 15.502 Allocable Supply From the System's Safe Capacity With Two Standby Wells Total Safe Shares of the Safe Capacity Status of the System Capacity MLR MKP uw::, (MGD) % MGD % MGD % MGD Present Six Wells 5.688 58,580 3.332 25.918 1.474 15.502 0,882 II 18_repts_04-24+05-22_mauna. lanl_7-15-05 C (!) :it w (!) <C 0:: w > <C 5.0 4.5 4.0 3.5 3.0 2.5 2.0 1.5 1.0 0.5 --- i - FIGURE 1. MAUNA LANI RESORT'S WATER USE, 12-MAV OF USE, MAXIMUM DAY USE, AND ALLOCATED SUPPLY -- 5.0 ! ,-4.5 --........ •-·-·-·····--·-··'t .. 4.0 ----,---~ ~ 3.5 3.0 ·······--------------· 2.0 -... -·-· -. -·------~----.. -.... -, ... _ ................. _ ...... _,_,., ..... _ .... _ ............................................... _._ ...... , __ ........... --...... -............ -............... _ .. . . I . 0.5 0.0 ......._.._,__._,__~~....._.~ ......... ~.._._.-......-..... .................. -....._. __ ._,_.._._.._._.-.....--.... .............................. ....._. .................... ._,_..._._.......,_..__.___.__._ .................................... ._._.__,__,_,_, 0.0 2000 2000.5 2001 2001.5 2002 2002.5 2003 2003.5 2004 2004.5 2005 2005.5 2006 2006.5 YEAR -fffil--BI-MONTHL Y METERED USE --<r-12-MONTH MOV. AVG. --<>--MAX. DAY OF 12-MAV ,_ • ALLOCATED SUPPLY i w FIGURE 2. MAUNA KEA RESORT'S WATER USE, 12-MAV OF USE, MAXIMUM DAY USE, AND ALLOCATED SUPPLY 2.00 .-----,---~--------------------,---------------,-----, 2.00 - 1.75 --·············-············ .......................................... ·································-······-·····-····· ·····-····--·· ···-····-··-··-······-······----l·I···· .... 1. 75 1.50 .. ·····•····•····•··· ···············--•·. ·--····--··•·-·······················---····-··-·······--··-·····-············'---------------t'------1 ~ ~ ---~ --:---.::ia ~ ---lilM-,i --~ ----- f50 1.25 ·································•--l------4---------+-------+·-·---------+----·---!-·-·-·-··· 1.25 I I ~ 1.00 l-------;-~-41~~~~ . ....,.....,- a::: -.,&--@--"<§ w > <( 0.50 0.50 0.25 0. 00 .......... ..._... ................................. '-'-............................................................................................................................................................................................................... _._........_......._......_ ........................................................................... ......... 0.00 2000 2000.5 2001 2001 .5 2002 2002.5 2003 2003.5 2004 2004.5 2005 2005.5 2006 2006.5 YEAR ~Bl-MONTHLY METERED.USE-~12~M0NTHMOV. AVG. ~MAX.~DAY OF 12-MAV-••• •ALLOCATED SUPPLY., Exhibit 3. Summar-y of Well Pumping Capacities and Allocated Supply of the Existing Lalamilo and Parker Wells System After Completion of the Parker 3 Well Present Installed Well Pumping Capacities w el I GPM MGD Lalamilo Wells A 700 1.008 8 1000 1.440 C 1000 1.440 D 1000 1.440 Parker Wells 1 1250 1.800 2 1250 1.800 3 1250 1.800 Total Installed Pumping Capacity 7450 10.728 Pro-Rata Shares of Individual Existing Well Capacities MLR MKP DWS Well % Share Equiv. MGD % Share Equiv. MGD % Shara Equiv.MGD Lalamilo A 50.00 0.504 50.00 0.504 0.00 0.000 B 34.72 0.500 34.72 0.500 30.56 0.440 C 34.72 0.500 34.72 0.500 30.56 0.440 D 90.00 1.296 0.00 0.000 10.00 0.144 Parker 1 90.00 1.620 0.00 0.000 10.00 0.180 2 45.00 0.810 45.00 0.810 10.00 0.180 3 70.00 1.260 20.00 0.360 10.00 0.180 Pro-Rata Share of the Present Installed Capacity ; MGD 6.490 2.674 1.564 : % of Total 60.496 24.925 14.579 Allocable Supply From the System"s Safe Capacity With Two Standby Wells Total Safe Shares of the Safe Capacity Status of the System Capacity MLR MKP DWS (MGD) % MGD % MGD % l'v'GD Four Lalamilo and Three Parker Wells 7.488 60.496 4.530 24.925 1.866 14.579 1.092 #18_repts_04-24+05-22_mauna.lanl_7-15-05 Exhibit 4. Summary of Well Pumping Capacities and Allocated Supply of the Existing Lalamilo and Parker Wells System After Completion of the Parker 4 Well Present Installed Well Pumping Capacities We I I GPM MGD Lalamllo Wells A 700 1.008 B 1000 1.440 C 1000 1.440 D 1000 1.440 Parker Wells 1 1250 1.800 2 1250 1 .800 3 1250 1.800 4 1250 1.800 Total Installed Pumping Capacity 8700 12.528 Pro-Rata Shares of Individual Existing Well Capacities MLR MKP DWS We II % Share Equiv. MGD % Share Equiv. MGD % Share Equiv. MGD Lalamilo A 50.00 0.504 50.00 0.504 0.00 0.000 B 34.72 0.500 34.72 0.500 30.56 0.440 C 34.72 0.500 34.72 0.500 30.56 0.440 D 90.00 1.296 0.00 0.000 10.00 0.144 Parker 1 90.00 1.620 0.00 0.000 10.00 0.180 2 45.00 0.810 45.00 0.810 10.00 0.180 3 70.00 1.260 20.00 0.360 10.00 0.180 4 90.00 1.620 0.00 0.000 10.00 0.180 Pro-Rata Share of the Present Installed Capacity : MGD 8.110 2.674 1.744 : % of Total 64.735 21.344 13.921 Allocable Supply From the System's Safe Capacity With Two Standby Wells Total Safe Shares of the Safe Capacity Status of the System Capacity MLR MKP DNS (MGD) % MGD % MGD % MGD Four Lalamilo and Four Parker Wells 9.288 64.735 6.013 21.344 1.982 13.921 1.293 # 18_repts_04·24+05-22-mauna.l anl_7 -15-05 Pomkufu:; LaaoHiaka ·S .. / 1-- Waiu.l<umalae Pcint '·, ... ~---··,+----,:'---;:::;~::-· •• .. .. §: "'· -... •• --··-- ;elf. . ,.,-,....:::__~--·· ·:·--·--r-·~ ··-:.-:··-· ·-....-:---- C . ...J Exhibit 5 ,·· Development Area of Mauna Lani Service in South Kohala, Hawaii ' Inc. •• -:-::·-_:~ ,: . '-:, . ...-.. • .• ____ . ..-· .'; / ./-i /': .,,(}_,, I ···-,• .. ·i· 0 ;·,-,' ;,.91/j •• ~ ·'f.J, __ _j_ -...:..--- ill -~ 15 .c X w 0 C (/) (I) t (I) Q. e 0... (t1 (!) ~ ro C :::J (t1 2 4-0 ro (I) .... <:( c (!) E Q. 0 © > Cl 0 "iu 3 (t1 I cu ro .c 0 ~ .c -:::J 0 if) .S: r i ' _) \ \. \ \ J '': EXHIBIT 7. TENTATIVE DESIGN & CONSTRUCTION SCHEDULE FOR THE PARKER 3 AND 4 WELLS AND RELATED IMPR0 ACTIVITY PRELIMINARY DESIGN Preliminary Concept Design Coordination with DOW Topographic Survey for Well No. 3 Site Topographic Survey for Connecting Pipeline Topographic Survey for Well No. 4 Site and Connecting Road PRE-PURCHASE OF PARKER 3 WELL PUMP AND MOTOR Design and Order DWS Review and Approval Well Drilling, Casing, & Testing DRILL PARKER 3 AND 4 WELLS CWRM Well Construction Permit Prepare Well Construction Documents Bid & Award Well Drilling, Casing, & Testing PUMP FOR PARKER 3, 2.0 MG TANK & PARALLEL PIPELINE Civil Design for Parallel Pipeline (1100' to 61 0') Civil Design for Tank and Access Road Civil Design for Well Pump Soils Investigation for Tank Structural Design RC Tank Structural Design Control Building Electrical Design Review & Approval by Hawaii DWS, DPW, Planning and State ADA DOH Well Source Certification for Potable Use Prepare Bid Documents Bid & Award Project Construction of Well Pump, 2.0 MG Tank & Connecting Pipeline 2.0 MG TANK AT 610-FT ELEVATION Civil Site Design for Tank Soils Investigation for Tank Structural Design RC Tank Structural Design Chlorination Building Electrical Design Review & Approval by Hawaii DWS, DPW, Planning and State ADA Prepare Bid Documents Bid Project Construction of Tank & Connecting Pipelines PUMP FOR PARKER 4 & CONNECTING PIPELINE Civil Design for Access Road & Pipeline Civil Design for Well Pump Structural Design Control Building Electrical Design Review & Approval by Hawaii DWS, DPW, Planning and State ADA DOH Well Source Certification for Potable Use Prepare Bid Documents Bid Project Construction Well No. 4 Outfitting, Tank & Connecting Pipeline File: 04-24/SCH_FT3 Date Last Rev: Dec 3, 2004 Date Ptrd: 2/17/06 2004 2005 Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct N01 1lmmmmmim [[[[[([[([[[[[[[[[[[([[[[ [[[[([[([[[[[[([[[[[[[[[([[[[[[[[[[ [ [[[[ [[ [[ [ [[[ [[[ [[[[ [ [ [ [[ [[[ [[[[([[[I [[[[[[[[[ [[[[[[[[[[[[[[[[[[[ [[[[[[[[[[[[([[[[[[[[[[[[[([[[[[[[[[[[[[ [[[[([[[ [([ [ [[[[[[[ [[[[[([II [[[[[[[[[ I I I I I I [[[[[[[[[[[[[[[[[[[[[[[[[[[[[([[[[[[[[[[[[[[[[[[[[[[[[[[[[[[ [[[[[[[[[[[[[[[[[[[[[[[[[([[[[[[[[[[[[[[[[[([[[[[([[[[[[[([J I I I 1111mm1111mn [[[[[[[[[[[[[[[[[[[[[[[[[[([[[[[[[[[[[[ I [([[[[ [[[([[([ [ [[[[[[([[[[ [[[[([ [[([ [[[ [[[[[[[[[[[[[[[[[[[[[[[[([[[[([[[[[[[[[ [[[[[[[[[[([[[[[[[[ [[[[[[[[[ [ [[[[[[ [[[ I [[[ [ [[[[[[[[[[ [ [[[[ [ [[[ [[[[[ [ [[([ [[[ [([[([[ [[[ [[[ [[([[[[ [ [[ [[[([[[[[[[([([[[[[[[[[[[[[[[ [[([([[[[[([[[[[[([[[[([[[[[[[[[[[[[[[[ [[[[ [[[ [[[ [ [ [[ [[[ [ 11 [[[([[[[[ [([[[[[[[ [[[[[[[[[ [[[[([[[[ [[[[[[[[[ [([[[[[([[[[[[[[[[([[[[[[[[[[[ I 111m1mm1m11 [ [([[[[ [[[[[[[ [[[[[[[[[ [ [[[[[ [[[[[[[[[[[[[[[[[[[ [[[[[[[[[ [[[[[[[[[[[[[[[[[I I [[ [[[[[ [[[[[[[ [[[I [[[ [[[[[ [[([[([[[I I [[([[[[[[ [[[[[[[I [[[[[[[[[[([[[[[([ I 11111111 rlllITI :MENTS 2006 2007 )ec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul AuQ Sep Oct Nov Dec :cm [[[[[[[[[[[[[[[[[[[[[[[[[([([[[[[[[[[[[[[[[[([[[[[[[[[[[([[[[[[[[[[[([([[[([[[[[[[[[[([[[( Im I I I I I I I [[[[[[[[[[([([[[[[[ [[[[[[[[[[[[[[([[[[([[[[[[[[[([[[[[[[[[[[[[[[[[([[[[[[[[[[[([[[[[[[[[([[[[[[[[[[[[[[[[([[[[[[[[[[[[[[([[[[[[[[[[[[[[([[[[ [[[[ :m [[[[([[[[ [([[[[[[[ [[[[[[[[([[[[[[[[[[([[[[[([[[[[[([[[[[[[[[[[[[[[[[ [([[[[[[([[[([[[[[([[[([[[[[[[[[[[[[([[[[[[[([[[[[[[[([[[[[[[[[[[([[([ [[[ ([[[[[[[[([[[[[[[[[ [[([[[[[[[[([[[([[[[[[[[[[([[[([[[[[[([[[[[[([[[[[ [[[([[[[[[[[[[[([[[ [[[ I I I I I I [[[([[[([![[[[[[[[( mmmrrrmrm1mmm1[m[mr[i1[rrmmf r[mrmrmmm1mrmrr1nmrmr1mmm11mmm1mrrrm APPENDIX E. Amendment of Agreement Regarding Parker Wells Nos. 3 & 4 dated April 7, 2008 Manua Lani Resort -Water Use Study DEPARTMENT O F W AT ER SUPP LY • C O UNTY OF HAWA l'I Mauna Lani Service. [nc. 3.t5 KEKUANAO'A STREET. SUITE 20 • H LO, HAWAl 'I 96720 TELEPHONE !808) 961-8050 • F-'\X (808) 961-8657 April 7, 2008 AT fENTION: MR. KENJIRO KARAHASHI 68-l310 Mauna Lani Drive. Suite 101 Kohala Coast, HT 96743-9704 AMENDMENT OF AGREEMENT REGARDING PARKER WELLS NOS. 3 At'\/D ➔ Enclosed are two fully-executed originals of the subject Am endment of Agreement for your use. If you have any questions, please contact Mr. Kurt [naba at 961-8070, extension 238. Sincerelfyc}urs. /' L Manager vao. P.E. dms Enc. copy -(w/enc.) Mauna Kea Prope1iics. ATTENTION: MR. YOJCHI L\SARl (w/enc.) Ms. Katherine Garson. Deputy Corporation Counsel The Oepart1nent of Water Supply is an Equal Opponunity provider and employer. To file a complaint of discrimination, wnte· USDA, D1reclor, Office of Civil Rights. Room 326-W, Whitten Building, 14th and Independence Avenue. SW, Washington DC 20250-9410 Or call (202) 720-5964 (voice and TDD) FIRST AMENDMENT OF AGREEMENT (PARKER 'WELLS 3 AND -') This First Amendment of Agreement (the ''Amendment") is made this 4th day --of April . 2008 by and among the WATER BOARD OF THE COUNTY Of F-IA WAI'I (--Board''), MAUNA LANI SERVICE, INC., a Hawaii corporation ('~Ls··) and MAUNA KEA PROPERTIES. INC .. a Hawaii corporation ("MKP"). RECITALS: A. The Board, MLS anJ MKP entered into ai1 Agreement dated A pril 6, 2006 (the ·'Agreement"') which sets forth their agreements regarding the development of Parker Wells Nos. 3 and 4 and the allocation of water from those wells. B. Section 4 or the Agreement requires that perfo1111ance of the Agreement be completed within two (2) years from the date of execution of the Agreement unless otherwise modified upon approval oflhe Board. and except Lo tbe extem that performance is delayed by force majeLtre events. C. Development of Parker Wells Nos. J and 4 has been delayed due to the October 2006 eartJ1quake and subsequent delays in obtaining governmental permits and approvals. D. The Pai1:ies wish to amend the Agreement to extend the time for perfommnce tbere1mder. AGREEMENT: l. Extension of Time for Performance. The time for completion of MLS' obligations under the Agreement is hereby extended as fol lows: a. MLS shall complete construction of Parker Wells Nos. 3 and 4 on or before August J 1. 2008. b. Jv[LS sball provide connection of Pa.rker Well Nos. 3 and 4 to the Lalarnilo System and shall dedicate the improvements. land and easemenrs described in Section 3.2 of the Agreement to the Board as soon as reasonably practicable following completion of construction. 2. Except as expressly amended herein, the Agreement sha1J remain in full force and effect in accordance with its terms. JN WfTNE SS WHEREOF, the parties have execured Lb.is Amendment as of the date ,vritten nbove. MAUNA LANJ SERVICE. rNC. By~oQ~t--- Title: President WATER BOARD OF THE COUNTY OF HAWJ\TI By~'-Name:ThonrnsCGoy a -- Title: Chai rperson APPROVED AS TO FORM: Deputy Corporation Counsel Counry of Ha'?~ Dated: o/ /or , MAUNA KEA PROPERTTES. INC. By lxf,C-.~ Nam~ nicbi Asari Title: President Manager, ( APPENDIX F. Assignment of Water Allocation dated June 2009 Manua Lani Resort -Water Use Study ASSIGNMENT OF WATER ALLOCATION THIS ASSIGNMENT (the "Assignment") is made and executed this.:t>""'aay of ✓Me < ,_2009 by and between MAUNA LANI SERVICE, INC. a Hawaii corporation, whose address is 68-1310 Mauna Lani Drive #101, Kohala Coast, Hawaii 96734-9704, hereinafter called the "Assignor", and TOKYU CORPORATION, a Japan corporation, mailing address is 68- 1310 Mauna Lani Drive #101, Kohala Coast, Hawaii 96734-9704, hereinafter called the "Assignee"; RECITALS A. Assignor, the Water Board of the County of Hawai' i (the "Board") and Mauna Kea Properties, Inc. ("MKP) entered into that certain Agreement dated April 6, 2006, as amended (the "Agreement"), relating to the development of the Parker 3 and 4 Improvements (as defined in the Agreement) and the allocation of water from Parker Well No. 3 and Parker Well No. 4. B. Pursuant to Section 2 of the Agreement, Assignor and MKP may assign all or a portion of their water allocations under the Agreement to a third party for use within Assignor's or MKP's development areas only, or to the other party, or to the other party's successors or assigns, within the respective development areas only, and subject to the written consent of the Board. Assignor's development area is hereinafter referred to as the "MLS Development Area". C. Exhibit 4 of the Agreement sets forth the total allocations from the ex1stmg Lalamilo Wells and the Parker Well System following completion of Parker Well No. 3 and Parker Well No. 4. D. Assignor has completed development of the Parker 3 and 4 Improvements and has dedicated the Parker 3 and 4 Improvements to the Board. E. Assignee is the owner of certain real property within the MLS Development Area, including Lot C, as shown on File Plan No. 2447, which lot is designated as TMK (3) 6-8-1-52 ("Assignee's Lot"). F. Assignor is in the process of dissolving, and, as a part of such dissolution and winding up, wishes to assign its remaining allocation of water under the Agreement to Assignee, on the terms and conditions set forth in this Assignment. AGREEMENT NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Assignor and Assignee hereby agree as follows: 1 1. Assignment of Allocation. Assignor hereby grants, assigns, transfers and conveys to Assignee, and Assignee hereby accepts from Assignor such grant, assignment, transfer and conveyance of all of Assignee's allocation of and rights to water from Lalamilo Wells A, B, C and D and Parker Wells 1, 2, 3 and 4, as described in Exhibit 4 to the Agreement, excluding the portions of such allocation that have been assigned to other owners of property within MLS' Development Area prior to the date of this Assignment (the "Allocation"). Such prior assignments are listed on Exhibit A attached hereto. The foregoing assignment is not intended to adversely affect the rights of any person listed on Exhibit A or the rights of any person to whom Assignor has agreed to provide an allocation of water in the future. The Allocation is assigned to Assignee's Lot, but may be further assigned for use within MLS' Development Area, subject to the written consent of the Board. 2. Covenants of Assignee. Assignee agrees that the Allocation shall be subject to all of the terms and conditions in the Agreement relating to the Allocation. Without limiting the foregoing, Assignee covenants and agrees that: (a) the Allocation shall be used only in the MLS Development Area; and (b) any further assignment of all or a portion of the Allocation shall be for use within the MLS Development Area only and shall be subject to the written consent of the Board. 3. Consent of Board. This Assignment is subject to the approval of the Board. By consenting to this Assignment, the Board acknowledges and agrees that, notwithstanding the assignment of the Allocation to Assignee's Lot, Assignee may make further assignments of all or a portion of the Allocation for use on other property within the MLS Development Area, subject to the written consent of the Board. 4. Capitalized Terms. Initially capitalized terms used and not otherwise defined herein have the meanings given such terms in the Agreement. S. Further Assurances. Each party agrees to execute such other and further instructions as may be necessary or proper in order to consummate the transaction contemplated by this Assignment. 6. Successors and Assigns. This Assignment shall be binding upon and inure to the benefit of the respective successors and assigns of Assignor and Assignee. The terms "Assignor," "Assignee," as and when used hereinabove or hereinbelow shall mean and include the masculine or feminine, the singular or plural number, individuals, associations, trustees, corporations or partnerships, limited liability companies or limited liability partnerships, and their and each of their respective successors in interest, heirs, personal representatives, executors, administrators, and assigns, according to the context thereof. 7. Governing Law. This Assignment shall be governed by and construed 111 accordance with the laws of the State of Hawaii. 2 8. Counterparts. This Assignment may be executed in several counterparts and all such executed counterparts shall constitute one Assignment, binding on all of the parties hereto, notwithstanding that all of the parties hereto are not signatories to the original or to the same counterpart. IN WITNESS WHEREOF, Assignor and Assignee have executed and delivered this Assignment as of the day and year first above written. 3 MAUNA LAN1 SERVICE, 1NC. By_/fj_, _,_,~,,_4h~''---r-U ~,$-~--l4_4',tr------___.· ---- Name: Koji Nakamura Title: Vice President Assignor TOKYU COPRORAITON By___.:1....;;;;;::z:::;;;:::;..=t-~_,c....;:___..::....=:..~.!:::..--{__....._ Name: Ken· iro Title: Senior Manager Assignee CONSENT The WATER BOARD OF THE COUNTY OF HAWAl'I (the "Board") hereby consents to the foregoing Assignment by Mauna Lani Service, Inc. ("Assignor") to Tokyu Corporation ("Assignee") of all of Assignor's allocation of water from Parker Well No. 3 and Parker Well No. 4 under that certain Agreement dated April 6, 2006 (the "Agreement"). The consent granted hereby shall not be deemed to: (i) modify, waive, impair or affect any of the covenants, agreements, terms, provisions or conditions contained in the Agreement, or (ii) be a consent to any further or subsequent assignment of MLS's allocation of water under the Agreement. REC7/iP~ Mil tfun.Pavao,Ma1rnger APPROVED AS TO FORM AND LEGALITY ~~ Deputy Cy poration Counsel County 6f Hawai' i 4 Mauna Lani Water Allocations and Actual Usage --Total Allocation Allocated Usage Development/Project Name Tax Map Key (units) (@ 400 gpd/unit) Mauna Lani Resort (General) Security Office 6-8-022:022 5 2 000 V1s1tor Arrival 6-8-022:022 17 6 800 Sea Gull School 6-8-001 :052 6 2 400 Administration Buildino 6-8-001 :022 5 2,000 Mauna Lani Resort Warehouse 6-8-001 :022 5 2000 Re"""lino Center 6-8-001 :022 5 2 000 Sewer Treatment Plant 6-8-001 :022 16 6400 Holoholo Kai Beach Park 6-9-001 :015 3 1 200 The Orchid @ Mauna Lani 6-8-002:008 542 216 800 Traffic Circle lrrioation 6-8-00 I :022 5 2 000 Sales Office/Miller Museum 6-8-001 :022 1 400 Mauna Lani Bav Hotel 6-8-001 :022 84 33 600 Mauna Lani T er1ace* 6-8-022:006 & 009 81 32 400 The Point Estates• 6-8-024:001 • 022 51 20400 Mauna Lani Point• 6-8-022:028 79 31,600 6-8-022:026 & 6-8- The Caoe @ Mauna Lani* 024:023 • 037 44 17,600 Chamoion Ridqe• 6-8-027:001 • 037 85 34000 The Islands@ Mauna Lani 6-8-022:021 90 36,000 Racauet Club 6-8-022:019 25 10,000 Golf Clubhouse 6-8-022:043 5 2,000 Golf Mainlenance Buildino 6-8-022 :043 5 2000 Mauna Lani Beach House 6-8-022:026 6 2 400 Mauna Lani Boat House 6-8-022:026 8 3 200 Mauna Lani House (Nomura Villaqe) 6-8-022:025 15 6,000 LALAMILO WELLS TOTAL: 1,188 475,200 Total Allocation Allocated Usage Develooment/Proiect Name Tax Map Kev (units) (@ 400 ood/unit) 49 Black Sand Beach* 6-8-033:001 • 053 110 44,000 Pauoa Beach• 6-8-034:001 • 041 93 37 200 The Shons @ Mauna Lani 6-8-022:002 30 12000 The Villaaes (a) Mauna Lani 6-8-022:004 190 76000 Ke Kailani• 6-8-036:001 • 041 160 64,000 The Fairwavs at Mauna Lani 6-8-022:005 04 7 051 167 66,800 Golf Villas @ Mauna Lani 6-8-022:052 130 52 000 Palm Villas @ Mauna Lani 6-8-022:018 66 26,400 PARKER #1 & 2 TOTAL: 946 378,400 Total AllocaliOll Allocated Usage Develooment/Proiect Name Tax Map Kev (units) (@ 400 gpd/unit) Kulalani 6-8-022:007 258 103,200 Ka Milo 6-8-022:041 296 118,400 Laule'a 6-8-022:024 35 14,000 Fairmont Orchid Condos 6-8-022:008 165 66,000 ML Golf Vistas One 6-8-022:014 128 51 200 ML Golf Vistas Two 6-8-022:003 96 38,400 PARKER #3 & 4 TOTAL 978 391,200 Actual Usage • No. of Unused (qpd, avg. day) Accounts 176 41 ,868 7,121 7,066 979 374 6937 639 338,291 38864 - 0 178,457 65,831 1 36097 6 107 584 0 144 816 4 123 570 0 86,611 33,058 22,097 1,350 22,173 52461 76,413 1,392,833 Actual Usage • No. of Unused (Qod, avg. day] Accounts 285 464 18 284,714 7 38 516 155 644 39602 50 116,945 91,435 46,350 1,058,670 Actual Usage • No. of Unused (gpd, avg. day) Accounts 1,848 125316 0 N/A NIA N/A NIA N/A NIA N/A NIA Total No. of Accounts 1 1 1 1 1 1 1 1 1 1 1 1 14 18 12 17 10 1 1 1 1 1 1 1 Total No. of Accounts 60 53 1 1 61 1 1 1 Total No. of Accounts 1 2 N/A N/A N/A N/A 3/12/2009 Aqreement Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells lalamilo Wells lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Lalamilo Wells Aareemenr Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Parker #1 & 2 Aoreement Parker#3 & 4 Parker #3 & 4 Parker #3 & 4 Parker #3 & 4 Parker #3 & 4 Parker #3 & 4 ~1 1--m -::c >< w APPENDIX G. Mauna Lani Property Photos Manua Lani Resort -Water Use Study Champion Ridge Entry Sign Entry Gate Ka Milo Roundabout Single-Family Dwelling Ka Milo Community Landscaping Artificial Putting Green Ka Milo Backyard Landscaping Front Yard Landscaping Ka Milo Backyard Pool Front Landscaping Kulalani Parking & Common Area Landscaping Entry Road Kulalani Driveway & Landscaping Front Landscaping Kulalani Patio Backyard Kulalani & Ka Milo Shared Amenity Pool Pool Kulalani & Ka Milo Shared Amenity ... " Recreation Area Recreation Area Ke Kailani Entry Road Walkway Ke Kailani Sales Entry Vacant Lot Ke Kailani Multi Family Driveway MF Ke Kailani Amenity Grotto Grotto Nohea Landscaped Driveway Pool Area Nohea Roadway Open Graded Area Mauna Lani Resort Association Office Sign Entry and Parking Former Preschool Empty Brackish Reservoir Misc Pian n i ng Sign age Request: Special Management Area Use Appli (SMA 16-000066): Modify and Incorporate an Building and Parking Lot and Add lwo Additional Buildings and Additional Parking to Support a 20-Unlt Commercial and Ught Industrial Lease Space for Businesses, Offices, Self-Storage, and a Restaurant. Change of Zone Application (REZ 16-000215): A-5a to MC~20. Size of Property: 1. 7 acres TMK: 6-8-001:058 For more Information contact Hawaii County PlaMlng Depl 101 Pauah1 Street, SUlte 3, HHo, HI 96720-4224 Phone 981-8288 Sign @ Location Request: Subdivision and Consolidation Application (Consolidation of lots 4 and 29 and Resubdivision into lots A, 8, and C) Proposed number of lots: Three (3) Property Size: 825.420 Acres Applicant: Mauna Lani Service, Inc. Tax Map Key: (3) 6-8-01: 52 and 6-8-22: 29 For Additional information Contact: County of Hawaii Planning Department 101 Pauahi Street, Suite 3 HIio, HI 96720 Phone: 961 -8288 or: Hanama Place 75-5706 Kuakini Hwy., Suite 109 Kailua-Kona, HI 96740 808/327-3510 . Sign @ Location rq WILSON OKAMOTO 1111 C O R P O R A T I O N _ ..... ti@·MM¥WMhiiM◄UMifi41 August 12, 2025 County of Hawaii Department of Water Supply Customer Care Operating Unit 345 Kekuanao'a St Hilo, HI, 96720 Attention: Subject: Ms. Robyn Matsumoto-Water Resources and Planning Branch Mauna Lani Site "M" -DWS Water System Adequacy TMKs: 6-8-022:010 and 6-8-001:054 Dear Ms. Matsumoto: Wilson Okamoto Corporation is requesting Department of Water Supply ("DWS") assistance to determine adequacy of the existing source, storage, and water distribution systems serving the Mauna Lani Resort ("MLR") properties, for the development of new residential and hotel units on parcels located by TMKs 6-8-022:010 and 6-8-001:054. See Figures 1-1, 1-2A, and 1-2B enclosed. The development will include the following programming: • Residential Units: 453 units o Parcel I (Stacked Flats & Townhomes)-56 units o Parcel 2 (Stacked Flats & Townhomes)-102 units o Parcel 4 (Townhomes)-133 units o Parcel 5 (Stacked Flats & Townhomes)-104 units o Parcel 6 (1-Story Villas)-58 units • Hotel Units: 374 units o Parcel 3A (Hotel Building) -270 units o Parcel 3B (Hotel Bungalows -104 units An analysis ofMLR's existing water use and calculations for the proposed additional water use was completed by Akinaka & Associates, Ltd. Per the report, the existing average daily water usage by MLR is 2.738 MGD, and the proposed development is anticipated to add 0.578 MGD of average daily water usage. A copy of the report is enclosed for DWS' review and reference. In addition to your review of the existing water system and proposed programming, we are requesting DWS flow information, pressure information, standardized potable water planning information, record drawings or as-builts, and facility maps related to the resort property. Any 1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277 Letter to Ms. Robyn Matsumoto August 12, 2025 Page2 available information that can be provided will be used in the project planning and design process to minimize potential conflicts during construction. Feel free to call or email me at require additional information. 8&fllL Brett Kuamoo, P.E. Senior Project Manager Enclosures: Figure 1-1 Project Vicinity and Location Map Figure 1-2A Tax Map Key Figure 1-2B Tax Map Key should you have any questions or Draft Water Use Study by Akinaka & Associates, Ltd. Dated July 2025 1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii• 96826 • (808) 946-2277 Mauna Lani Site "M" Preliminary Engineering Report APPENDIXC Preliminary Drainage Study Preliminary Engineering Report C-1 PRELIMINARY DRAINAGE STUDY MAUNA LANI SITE "M" WAIMEA, HAWAII TAX MAP KEY: 6-8-022:010 and 6-8-001 :054 Prepared for: DHL Mahi OpCo, LLC 235 Montogomery Street, Suite 1130 San Francisco, CA 94104 Prepared by: Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400 Honolulu, Hawaii 96826 woe Job No. 10704-01 January 2007 (Revised August 2025) Mauna Lani Site ''M" Preliminary Drainage Study TABLE OF CONTENTS Page I. INTRODUCTION ............................................................................................................. 1 A. Purpose ........................................................................................................................... 1 B. Proposed Project Location ............................................................................................. 1 C. Existing Topography ...................................................................................................... 1 D. Soils ................................................................................................................................ 1 E. Vegetation ....................................................................................................................... 1 II. EXISTING DRAINAGE CONDITIONS ....................................................................... 4 A. Drainage ......................................................................................................................... 4 B. Flood Control ................................................................................................................. 4 III. PROPOSED DRAINAGE IMPROVEMENTS ............................................................. 6 IV. HYDROLOGIC CRITERIA ........................................................................................... 6 V. HYDROLOGY ANALYSIS ............................................................................................. 6 A. Rational Method ............................................................................................................. 6 VI. RESULTS .......................................................................................................................... 7 VII. CONCLUSION ................................................................................................................. 7 VIII. REFERENCES .................................................................................................................. 8 APPENDIX A Preliminary Drainage Study i Mauna Lani Site ''M" Preliminary Drainage Study I. INTRODUCTION A. Purpose This hydrology study was conducted to: 1. Calculate storm runoff quantities occurring on-site for the areas proposed for the new development. 2. Determine any drainage improvements such as drywells, as required. B. Proposed Project Location The project site is a 149.9-acre property, located by TMKs 6-8-022:010 and 6-8- 001 :054, within the northeast boundary of the Mauna Lani Resort area ("MLR"). The project site is bounded by the Mauna Lani North Golf Course and undeveloped land to the west, an existing MLR service road to the east, North Kaniku Street to the south, and undeveloped land to the north. See Exhibit A. C. Existing Topography Mild slopes characterize the existing topography within the project. Site elevations range from 80 feet above Mean Sea Level on the southwest comer near North Kaniku Street, to 40 feet above Mean Sea Level on the northern end of the project site. D. Soils Soil series and mapping units for the island of Hawaii are found in maps in the U.S. Department of Agricultural, Soil Conservation Services. Most of the soil within the project limits consists of rock land (rRO), however, smaller areas of Kamakoa very sandy loam (KGC) and lava flows, Aa (rL V) can also be found. See Exhibit B. E. Vegetation There is sparse vegetation throughout the project site in the form of dry grass. Preliminary Drainage Study 1 PROJECT VICINITY ISLAND OF HAWAII • o Pahi H, KfJel ,e Papakona oot L~ndin N~13/1k11 ( , .. t::i MAUNA LANI SITE M fl_ / ,,-~□□-!!!!~15 ~~i!)!!!!!!!!!!!!!!!!~~$.~iiiiiiiicii, ~t , VICINITY AND LOCATION MAP EXHIBIT A 1500' 1'!11 MAUNA LANI SITE M SOILS CLASSIFICATION MAP GRAPHIC'-SµL.E 0 1:;oo 1" a: 1500' EXHIBIT B Mauna Lani Site ''M" Preliminary Drainage Study II. EXISTING DRAINAGE CONDITIONS A. Drainage Seven drainage basins were delineated based on the locations of the proposed areas of development and the existing topography. Based on the topographic survey for the project site, it does not appear that there are any defined drainage channels within the project site. See Exhibit A-1 in Appendix A. Storm water runoff generated by the project site appears to flow to low spots where the storm runoff percolates into the ground. There are no signs of concentrated storm runoff flows exiting the project site. See Exhibit A-2 in Appendix A. B. Flood Control Based on the Flood Insurance Rate Map for Hawaii County, panel number 155166 0303 F revised September 29, 2017, the project site is determined to be within Zone X, which consists of areas determined to be outside the 500-year flood plain. See Exhibit C. Preliminary Drainage Study 4 FIRM FLOOD INSURANCE RATE MAP HAWAII cou.,rv, HAWAII PANEL 303 OF 1975 iSEE f/Af' INDEX FD~ FIRl.4 rA~EL LAYOUT'. ,:,;,;JNl1,11>1::,; MAP NUMB 155166030 PTEMBER 29, 20 .!.illt::!Q_ m PROJECT LOCATION ZONE VE ZONE AE N ZONE X ~ Not to Scale FIGURE C FLOOD INSURANCE RATE MAP MAUNA LANI SITE M WAIMEA, HAWAII Mauna Lani Site ''M" Preliminary Drainage Study III. PROPOSED DRAINAGE IMPROVEMENTS Proposed improvements include residential buildings, gardens/lawns, roadways, concrete walkways, water features, pools, and various landscaping throughout the project site. The proposed areas of development can be divided into seven sub-areas with most of the storm water generated by the anticipated improvements collected and discharged into proposed drywells strategically placed throughout the project site. Storm water produced near the perimeter of the project site will sheet flow towards the surrounding areas, flow into low spots, and percolate into the ground. See Exhibit A-3 in Appendix A. IV. HYDROLOGIC CRITERIA A hydrologic analysis of the site was based on a 10-year storm runoff with an 1-hour rainfall intensity. The Rational Method was used to determine peak discharge for the existing and proposed conditions. V. HYDROLOGY ANALYSIS A. Rational Method Design runoff flows were determined by the Rational Method expressed as: Q=C*I*A where: Q = Flowrate in cubic feet per second ( cfs) C = Runoff coefficient I = Rainfall intensity in inches per hour for a duration equal to the time of concentration. A = Drainage area, in acres See Appendix A for hydrologic calculations. Drainage Area Limits of the drainage basins were delineated based on topographic features and inlet locations. The total area was determined to be 149.9 acres. Preliminary Drainage Study 6 Mauna Lani Site ''M" Preliminary Drainage Study Rainfall Intensity The runoff time of concentration and correction factor was determined in accordance with plates 3 and 4 of the Department of Public Works, County of Hawaii Storm Drain Standards, respectively. A rainfall intensity of 1.5 inches/hour was used based on a 10-year, 1-hour rainfall. Runoff Coefficient The runoff coefficients for the given areas are as referenced from the Department of Public Works, County of Hawaii Storm Drainage Standards, Table 1: Guide for the Determination of Runoff Coefficients for Built-Up Areas. Runoff coefficients for each drainage basin are shown in Table IA and 1B in Appendix A. VI. RESULTS Peak discharge as calculated by the Rational Method, for each drainage basin, is shown in Table 1B and 2B in Appendix A. The total runoff generated on-site under the existing drainage conditions is 114.32 cfs. A total discharge of 172.06 cfs was determined for the proposed condition's on-site runoff. VII. CONCLUSION In comparing the runoff quantities of the existing and proposed conditions for the future areas of development, there is an increase of approximately 57.74 cfs. Virtually all future runoff will be collected by proposed drywells at various locations throughout the residential portions of the site. Any excess flow generated at the perimeter of the north and west sides of the project will sheet flow off-site towards the surrounding bare areas and thus percolate into the ground. No drainage structures are required for the proposed golf course as it reduced the amount of discharge within its basin. A total of 122 drywells will be strategically placed throughout the project site to accommodate the proposed drainage condition. The proposed drainage system and drywells will be designed to accommodate the increase in runoff from the proposed site. Therefore, the proposed project will not adversely impact the existing runoff conditions and the adjacent and downstream properties. Preliminary Drainage Study 7 Mauna Lani Site ''M" Preliminary Drainage Study VIII. REFERENCES 1. "Storm Drainage Standards," Department of Public Works, County of Hawaii, October 1970. 2. "Soil Survey of the Island of Hawaii, State of Hawaii", United States Department of Agriculture, Soil Conservation Service, December 1973. 3. "Flood Insurance Rate Map, Hawaii County, Hawaii" Federal Emergency Management Agency, Map Revised September 29, 2017. 4. "Storm Drainage Standards," City & County of Honolulu. Department of Planning and Permitting, August 2017 Preliminary Drainage Study 8 Mauna Lani Site ''M" Preliminary Drainage Study APPENDIX A TABLE 1 -HYDROLOGIC CALCULATIONS -EXISTING CONDITIONS 1 a -Runoff Coefficient 1 b -Hydro logic Calculations TABLE 2 -HYDROLOGIC CALCULATIONS -PROPOSED CONDITIONS 2a -Runoff Coefficient 2b -Hydrologic Calculations TABLE 3 -HYDROLOGIC CALCULATIONS -SIZING OF DRYWELLS EXHIBIT A-1 -TOPOGRAPHIC MAP EXHIBIT A-2 -EXISTING CONDITION DRAINAGE PLAN EXHIBIT A-3 -PROPOSED CONDITION DRAINAGE PLAN EXHIBIT A-4 -PRECAST DRYWELL DETAIL Preliminary Drainage Study A-1 Mauna Lani Site M Runoff Coefficient -Existing Condition* -Table 1A Drainage Infiltration Relief Vegetal Dev. Design Basin Cover Ty~e Coeff. 1 0.07 0.06 0.05 0.15 0.33 2 0.07 0.06 0.05 0.15 0.33 3 0.07 0.06 0.05 0.15 0.33 4 0.07 0.06 0.05 0.15 0.33 5 0.07 0.06 0.05 0.15 0.33 6 0.07 0.06 0.05 0.15 0.33 OS 0.07 0.06 0.05 0.15 0.33 *Based on Table 1: Guide for the Determination of Runoff Coefficients for Built-Up Areas Mauna Lani Site M Hydrologic Calculations for Existing Condition -Table 1 B Draina e Draina e Draina e SLOPE Tc C Q Basin Area sf Area ac % min cfs 1 454265 10.43 470 17.0 8.95 2 499746 11.47 490 20.0 9.46 3 1416335 32.51 1157 30.0 22.53 4 720913 16.55 658 21.6 13.11 5 508733 11.68 586 23.0 9.25 6 927945 21.30 1027 26.0 16.17 OS 1999934 45.91 1054 26.0 34.85 TOTAL 149.9 114.32 Mauna Lani Site M Runoff Coefficient -Proposed Condition* -Table 2A Drainage Infiltration Relief Vegetal Dev. Design Basin Cover Ty~e Coeff. 1 0.07 0 0.03 0.4 0.50 2 0.07 0 0.03 0.4 0.50 3 0.07 0 0.03 0.4 0.50 4 0.07 0 0.03 0.4 0.50 5 0.07 0 0.03 0.4 0.50 6 0.07 0 0.03 0.4 0.50 OS 0.07 0 0 0.15 0.22 *Based on Table 1: Guide for the Determination of Runoff Coefficients for Built-Up Areas Mauna Lani Site M Hydrologic Calculations for Proposed Condition -Table 2B Draina e Draina e Draina e SLOPE Tc C Q Basin Area sf Area ac % min cfs 1 454265 10.43 470 1.0% 11.1 14.86 2 499746 11.47 490 1.0% 11.2 16.64 3 1416335 32.51 1157 1.0% 16.8 43.89 4 720913 16.55 658 1.0% 12.8 24.00 5 508733 11.68 586 12.1 16.64 6 927945 21.30 1027 15.1 28.76 OS 1999934 45.91 1054 15.1 27.27 TOTAL 149.9 172.06 Mauna Lani Site M Hydrologic Calculations -Proposed Condition Sizing of Drywells -Table 3 (10-year storm) Infiltration rate 0.20 cfs/ft 8' diameter Draina e Len th SLOPE Tc I' C Q D Basin Area (ac) (ft) (%) (min) (cfs) Required (cfs) 1 10.43 470.00 0.01 11.10 1.50 2.85 0.50 14.86 13 15.6 2 11.47 490.00 0.01 11.20 1.50 2.90 0.50 16.64 14 16.8 3 32.51 1157.00 0.01 16.80 1.50 2.70 0.50 43.89 37 44.4 4 16.55 658.00 0.01 12.80 1.50 2.90 0.50 24.00 20 24 5 11.68 586.00 0.01 12.10 1.50 2.85 0.50 16.64 14 16.8 6 21.30 1027.00 0.01 15.10 1.50 2.70 0.50 28.76 24 28.8 TOTAL 103.95 122 146.40 Diameter = 8' Infiltration Rate = 0.20 cfs/ft. depth Depth Capacity Surf. area Inf. Rate (ft) (cfs) (sf) (fps) 1 0.2 75.36 0.0027 2 0.4 100.48 0.0040 3 0.6 125.6 0.0048 4 0.8 150.72 0.0053 5 1.0 175.84 0.0057 6 1.2 200.96 0.0060 8' deep max / 't ,I; (I Fairwa~ at Mauna Lani Villages at Mauna "~. " fo,,....., ~ ~66n ~n'lan QKa~i~aY H19 11 ------ ----- ----- I --r [PROPERTY '<- LINE, TYP t -0 -----\ ------ \ \ KA MJLO Co( J 1 -------~-- ----------------_ _____I \ KULALANI ato~UNA LANI " ~ " \ Mouna Resorts (Fne Pl~ Phos~s 1B21) {Of J-6 MALINA LANI SITE M TOPOGRAPHIC MAP io1 0 EXHIBIT GRAPHIC SCALE: 200' 100' 0 200' ""' A-1 SCALE: 1"■400' KA MILO Fairways at Mauna Lani KULALANI at MALINA LANI Villages at Mauna MALINA LANI SITE M EXISTING CONDITION DRAINAGE PLAN GRAPHIC SCALE: 200' 100 0 200' SCALE: OS A -45.91 oc Q -34.85 els EXHIBIT 400 A-2 1",. 400' Fairways at Mauna Lani Villages at Mauna Lani ---- r------------\ I \ ' '--I ---..__ __ ' '\ / \ / KA MILO \ : \ I , : \ / ' \ \ • --------------------------------------------------\ \ KULALANI at MALINA LANI \ --------~ __ _,,,/_________________ _ _________ __, / '-~~~~~' 0 <·. D C\. c!) <> MALINA LANI SITE M PROPOSED CONDITION DRAINAGE _§_ A • 21,JO ac Q = 28.76 cfa 2 A =""TH7 ac Q • 16.64 cfa PLAN GRAPHIC SCALE: 200' 100' 0 200' SCALE: <OD' 1"•400' ..Qi A = 45.91 ac Q • 61.98 cfa EXHIBIT A-3 5'1111. MDUT l----+ ~o.c. ~~------llo--+W ALIER FAIRC-----1~ g.MN.FIJ.111C1C:--,j=!!~li..;~="""'"'lm~-.,,..,"'S7l'~IC,f;!j__L__l_ ClllACIEll 10 ll!ill DENSIIY(SEEIIIIE2) • !IIIEll 1. 10P SLIII OOIIPRESSIYE CONCREIE SIRENGIH • JODO PSI N 211 lllllS. 2. Pmllll 3/4" 11111" RErMIED ON 1/%" SIM. ~LANSITEM PRECAST DRYWELL DETAIL 1\i" CUI. 2· aJI. DIWNIGE OPENNGS Pm:IING-• 4S" MGl£, l'IP. EXHIBIT A-4 JOSH GREEN, M.D. GOVERNOR OF HAWAII KENNETH S. FINK, M.D, MGA, MPH DIRECTOR OF HEAL TH KE KIA'AINA O KA MOKU'AINA O HAWAl'I KA LUNA HO'OKELE STATE OF HAWAII DEPARTMENT OF HEAL TH P.O. BOX 916 HILO, HAWAII 96721-0916 MEMORANDUM DATE: February 6, 2026 TO: Mr. Jeffrey W. Darrow Planning Director, County of Hawaii FROM: Eric Honda District Environmental Health Program Chief SUBJECT: Special Management Area Use Permit Application (PL-SMA-2026-000087) Special Management Area Use Permit No. 07-000019 (SMA 07-19) Applicant: DHL Mahi Site M LLC & DHL Mahi Propco LLC Request: Amend SMA Use Permit 07-000019 for a 10-Year Time Extension to Condition No. 2 (Complete Construction); Reduce the Master Plan Development From 1,207 Units ( 691 Residential & 516 TMK: Hotel) to 925 Units (551 Residential & 374 Hotel); Remove Golf Course and Conference Center; Increase Preserved Open Space; and Construct Emergency Evacuation Road 6-8-001:050; 052-055, (3) 6-8-022:010, South Kohala, Hawai'i In most cases, the District Health Office will no longer provide individual comments to agencies or project owners to expedite the land use review and process. Agencies, project owners, and their agents should apply Department of Health "Standard Comments" regarding land use to their standard project comments in their submittal. Standard comments can be found on the Land Use Planning Review section of the Department of Health website: https://health.hawaii.gov/epo/landuse/. Contact information for each Branch/Office is available on that website. Note: Agencies and project owners are responsible for adhering to all applicable standard comments and obtaining proper and necessary permits before the commencement of any work. Planning Dept. 1Exhi'bit 2 Jeffrey W. Darrow February 6, 2026 Page 2 of 4 General summary comments have been included for your convenience. However, these comments are not all-inclusive and do not substitute for review of and compliance with all applicable standard comments for the various DOH individual programs. Clean Air Branch 1. All project activities shall comply with the Hawaii Administrative Rules (HAR), Chapters 11-59 and 11-60.1. 2. Control of Fugitive Dust: You must reasonably control the generation of all airborne, visible fugitive dust and comply with the fugitive dust provisions of HAR§ 11-60.1-33. Note that activities that occur near existing residences, businesses, public areas, and major thoroughfares exacerbate potential dust concerns. It is recommended that a dust control management plan be developed which identifies and mitigates all activities that may generate airborne and visible fugitive dust and that buffer zones be established wherever possible. 3. Standard comments for the Clean Air Branch are at: https://health.hawaii.gov/epo/landuse/ Clean Water Branch 1. All project activities shall comply with the HAR, Chapters 11-53, 11-54, and 11-55. 1. The following Clean Water Branch website contains information for agencies and/or project owners who are seeking comments regarding environmental compliance for their projects with HAR, Chapters 11-53, 11-54, and 11-55: https://health.hawaii.gov/ cwb/clean-water-branch-home- page/cwb-standard-comments/. Hazard Evaluation & Emergency Response Office 1. A Phase I Environmental Site Assessment (ESA) and Phase II Site Investigation should be conducted for projects wherever current or former activities on site may have resulted in releases of hazardous substances, including oil or chemicals. Areas of concern include current and former industrial areas, harbors, airports, and formerly and currently zoned agricultural lands used for growing sugar, pineapple or other agricultural products. 2. Standard comments for the Hazard Evaluation & Emergency Response Office are at: https://health.hawaii.gov/epo/landuse/. Indoor and Radiological Health Branch 1. Project activities shall comply with HAR Chapters 11-39, 11-45, 11-46, 11-501, 11- 502, 11-503, and 11-504. 2. Noise may be generated during demolition and/or construction. The applicable maximum permissible sound levels, as stated in Title 11, HAR, Chapter 11-46, "Community Noise Control," shall not be exceeded unless a noise permit is obtained from the Department of Health. Jeffrey W. Darrow February 6, 2026 Page 3 of 4 3. Construction/Demolition Involving Asbestos: If the proposed project includes renovation/demolition activities that may involve asbestos, the applicant should contact the Asbestos and Lead Section of the Branch at https:/ /health.hawaii.gov/irhb/asbestos/. Safe Drinking Water Branch 1. Agencies and/or project owners are responsible for ensuring environmental compliance for their projects in the areas of 1) Public Water Systems; 2) Underground Injection Control; and 3) Groundwater and Source Water Protection in accordance with HAR Chapters 11-19, 11-20, 11-21, 11-23, 11-23A, and 11- 25. They may be responsible for fulfilling additional requirements related to the Safe Drinking Water program: https://health.hawaii.gov/sdwb/. 2. Standard comments for the Safe Drinking Water Branch can be found at: https://health.hawaii.govhmo/landuse/. Solid & Hazardous Waste Branch 1. Hazardous Waste Program -The state regulations for hazardous waste and used oil are in HAR Chapters 11-260.1 to 11-279.1. These rules apply to the identification, handling, transportation, storage, and disposal of regulated hazardous waste and used oil. 2. Solid Waste Programs -The laws and regulations are contained in HRS Chapters 339D, 342G, 342H, and 3421, and HAR Chapters 11-58.1 and 11-282. Generators and handlers of solid waste shall ensure proper recycling or disposal at DOH-permitted solid waste management facilities. If possible, waste prevention, reuse, and recycling are preferred options over disposal. The Office of Solid Waste Management also oversees the electronic device recycling and recovery law, the glass advanced disposal fee program, and the deposit beverage container program. 3. Underground Storage Tank Program-The state regulations for underground storage tanks are in HAR Chapter 11-280.1. These rules apply to the design, operation, closure, and release response requirements for underground storage tank systems, including unknown underground tanks identified during construction. 4. Standard comments for the Solid & Hazardous Waste Branch can be found at: https:/ /health.hawaii.gov/mo/landuse/. Wastewater Branch For comments, please email the Wastewater Branch at doh.wwb@doh.hawaii.gov. Sanitation / Local DOH Comments: 1. According to HAR § 11-26-35, No person, firm, or corporation shall demolish or Jeffrey W. Darrow February 6, 2026 Page 4 of 4 Other clear any structure without first ascertaining the presence or absence of rodents that may endanger public health by dispersal from such premises. Should any such inspection reveal the presence of rodents, the rodents shall be eradicated before demolishing or clearing the structure. A demolition permit is required prior to demolition. 1. CDC -Healthy Places -Healthy Community Design Checklist Toolkit recommends that state and county planning departments, developers, planners, engineers, and other interested parties apply these principles when planning or reviewing new developments or redevelopment projects. 2. If new information is found or changes are made to your submittal, DOH reserves the right to implement appropriate environmental health restrictions as required. Should there be any questions on this matter, please contact the Department of Health, Hawaii District Health Office, at (808) 933-0917. From: To: Subject: Date: Martin. candace M Planning Internet Mail SMA Permit App (PL-SMA-2026-000087) Monday, February 23, 2026 9:59:47 AM Regarding the above SMA permit application and amendment to SMA 07-19 (applicant OHL Mahi Opco LLC), the Department of Land & Natural Resources, Land Division, Hawaii District Land Office has not comments or objections. Thanks for your request for comments. Candace Martin Acting District Land Agent Hawaii District Land Office DLNR-Land Diuision 180 Kalanikoa Street Hilo,Hl96720 (808) 961-9590 Planning Dept. Exhibit 3 Coastal Zone Management Program Environmental Review Program Land Use Commission Land Use Division Special Plans Branch State Transit-Oriented Development Statewide Geographic Information System Statewide Sustainability Branch STATE OF HAWAl'I OFFICE OF PLANNING JOSH GREEN, M.D. GOVERNOR SYLVIA LUKE LT. GOVERNOR & SUSTAINABLE DEVELOPMENT 235 South Beretania Street, 6th Floor, Honolulu, Hawai'i 96813 Mailing Address: P.O. Box 2359, Honolulu, Hawai'i 96804 Mr. Jeffrey W. Darrow, Director Department of Planning County of Hawai' i East Hawaii Office 101 Pauahi Street, Suite 3 Hilo, Hawai'i 96720 Attn: Alex Roy Dear Mr. Darrow: March 4, 2026 MARY ALICE EVANS DIRECTOR Telephone: (808) 587-2846 Fax: (808) 587-2824 Web: https://planning.hawaii.gov/ DTS202602061242MO Subject: Special Management Area Use Permit Application (PL-SMA-2026- 000087) to Amend SMA Use Permit 07-000019 for a 10-Year Time Extension to Condition No.2 for Completion of Construction, Reduce the Master Plan Development, Remove Golf Course and Conference Center, Increase Preserved Open Space, and Construct Emergency Evacuation Road; South Kohala, Hawai 'i; Tax Map Key: (3) 6-8-001: 050; 052-055; (3) 6-8-022: 010 Thank you for the opportunity to provide comments on the Special Management Area (SMA) Use Permit Application PL-SMA-2026-000087, transmitted via memorandum dated February 5, 2026, to request amendments to SMA Use Permit 07-000019 approved on September 4, 2008 for an additional 10- year time extension for completion of construction, reduction in the Master Plan Development, removal of golf course and conference center, increase in preserved open space, and construction of emergency evacuation road, Waikoloa, North Hilo, Hawai'i. According to the SMA Use Permit Application PL-SMA-2026-000087 from DHL Mahi Site M, LLC & DHL Mahi Propco, LLC, SMA Use Permit 07- 000019, which authorized the development of "Mauna Lani Site M" on an approximately 150-acre area within the Mauna Lani Resort, was approved subject to 24 conditions, including an 10-year period of phased development, with infrastructure to be constructed in conjunction with project scaling or building occupancy. On April 14, 2015, the County Planning Department's Director granted an initial 5-year administrative time extension until September 4, 2023, and on March 16, 2023, the second administrative extension to September 4, 2028, respectively. Planning Dept. Exhibit 4 Mr. Jeffrey W. Darrow March 4, 2026 Page 2 Under SMA Use Permit Application PL-SMA-2026-000087, the applicant proposes to amend SMA 07-000019 by reducing the size from 1,207 units to 925 units, representing a 23.4 % reduction in overall density, including a decrease in hotel rooms from 516 rooms to 3 7 4 rooms, and a decrease in residential units from 691 residential units to 551 residential units. As a result, the average density would drop from 8.9 dwelling units per acre to 6.2 dwelling units per acre. In addition, the proposed amendment will eliminate certain recreational and conference facilities and consolidate building footprints to increase landscaped open space. The reduced scale of the proposed project is anticipated to have a less impact on the special management area. The proposed project site, approximately one mile inland from the nearest shoreline, is designated as Flood Zone X, an area of minimal flood hazard. The proposed project is not expected to be directly impacted by coastal inundation or chronic flooding associated with 3.2-foot sea level rise exposure area scenarios. One page 37, "the Applicant acknowledges that it will comply with all conditions of approval and only requests modification to Condition 2 to allow an extension of time for IO years to commence (emphasis added) construction, and deletion of Condition 20 as the golf course is being eliminated, in addition to further modifications to Conditions 8 and 14 to remove referenced of the former golf course element." The State ofHawai'i Office of Planning and Sustainable Development recommends that the applicant clarify whether the additional IO-year extension from September 4, 2028 to September 4, 2038 is for completion, or commencement, of the construction in accordance with Condition 2. If you respond to this comment letter, please include DTS202602061242MO in the subject line. For any questions regarding this letter, please contact Shichao Li of our office at (808) 587- 2841 or by email at shichao.li@hawaii.gov. Sincerely, M~~av~:-'-GJG/\S Director TO: FROM: SUBJECT: DEPARTMENT OF WATER SUPPLY • COUNTY OF HAWAl'I 345 KEKUANAO'A STREET, SUITE 20 • HILO, HAWAl'l 96720 TELEPHONE (808) 961-8050 • FAX (808) 961-8657 Mr. Jeffrey Darrow, Director Planning Department March 6, 2026 Keith K. Okamoto, Manager-Chief Engineer COH PLANNING DEPT MAR 9 2026 PM4: 18 REC'D HANO DELIVERED Special Management Area Use Permit Application (PL-SMA-2026-000087) & Special Management Area Use Permit (SMA 07-19) Time Extension Applicant: DHL Mahi Site M LLC & DHL Mahi Propco LLC Tax Map Key 6-8-001:050; 052-055, 6-8-022:010 We have reviewed the subject application and have the following comments. Water must be allocated from the tri-party agreement between Mauna Lani Service, Inc., Mauna Kea Properties, Inc., and the Water Board of the County of Hawai'i. Pursuant to the agreement dated April 6, 2009, all unused allocations of water units will revert to the ownership of DWS following a 20 year period from dedication of Parker Well No. 3 and Parker Well No. 4 to the Water Board. Parker Well No. 3 and Parker Well No. 4 were dedicated to the Water Board on May 26, 2009. Therefore, on May 26, 2029, all unused water unit allocations wi 11 be returned to the ownership of the Department of Water Supply. Should there be any questions, please contact Mr. Michael Mori of our Water Resources and Planning Branch at (808) 961-8070, extension 257. MM:dfg copy -Wilson Okamoto Corporation DHL Mahi Site M LLC DHL Mahi Propco LLC Sincerely yours, ~'-J Z_ .P.. Keith K. Okamoto, P.E. Manager-Chief Engineer ... Water, Our ~ost Precious <Rgsource ... 'l(a Wai.Jl 'l(ane ... The Department of Water Supply is an Equal Opportunity provider and employer. Planning De pt. 'Exhibit 5 JOSH GREEN, M.D. GOVERNOR KE KIA'AINA STATE OF HAWAl 'I I KA MOKU'AINA 'O HAWAl'I DEPARTMENT OF TRANSPORTATION I KA 'OIHANA ALAKAU 869 PUNCHBOWL STREET Mr. Jeffrey Darrow, Director County of Hawaii Planning Department 101 Pauahi Street, Suite 3 Hilo, Hawaii 96720 Dear Mr. Darrow: HONOLULU, HAWAII 96813-5097 March 20, 2026 Subject: Request for Comments for Special Management Use (SMA) Permit Amendment SMA 07-019 and PL-SMA-2026-000087 Mauna Lani Resort -DHL Mahi Site M LLC and DHL Mahi Propco LLC EDWIN H. SNIFFEN DIRECTOR KA LUNA HO'OKELE Deputy Directors Na Hope Luna Ho'okele DREANALEE K. KALILI TAMMY L. LEE CURT T. OTAGURO ROBIN K. SHISHIDO IN REPLY REFER TO: STP 01010.26 HWY-PL 26-2.35045 Tax Map Key No. (3) 6-8-001 : 050 (por.) and 054; (3) 6-8-022: 010; (3) 6-8-052: (State Highway) Thank you for your letter requesting our comments for the above-referenced application. We apologize for the delay in response. A SMA was approved in 2007 to allow the development of a portion of the Mauna Lani Resort area with 691 residential units, 516 hotel units and 3 golf holes totaling 150 acres. The applicant's request is to amend Condition 2 to allow a 10-year time extension, reduce both residential and hotel units, increase open space, and the removal of golf course and conference center. The amendment also includes Condition 6, which requires the applicant to construct an Emergency Evacuation Corridor. We acknowledge that the application stated that the amendment request does not include Condition 10, which is related to traffic improvement requirements imposed by the Hawaii Department of Transportation (HDOT). We have reviewed the submitted applications and provided our comments in the attachment. If you have any questions, please contact Jeyan Thirugnanam, Land Use Planning Engineer, Planning Branch at (808) 587-6336 or by email at jeyan.thirugnanam@hawaii.gov. Please reference file review number PL 2026-012. Sincerely, EDWIN H. SNIFFEN Director of Transportation Attachment Planning Dept. 'Exhibit 6 No. 1. 2. 3. ATTACHMENT The HDOT Comments STP 01010.26 Comments The project development is approximately one mile west of the state-owned Queen Kaahumanu Highway and a half a mile north of Maun a Lani Drive. Primary access points are North Kaniku Drive and Hoohana Street. The HDOT does not have any objections to the amendment requests to allow a 10-year extension, unit counts reduction, or the removal of the proposed golf course and convention center. It is our understanding that the applicant's fulfillment to Condition 10 related to traffic improvements shall be complied pursuant to SMA Permit SMA 07-019 and the related Land Use Commission Docket No. A84-583 and as follows: "10. The applicant shall provide, at a minimum, the following improvements, meeting with the approval of the Department of Transportation and/or the Department of Public Works, whichever agency is applicable: 1. An exclusive left-tum lane on the eastbound approach of Mauna Lani Drive at the intersection with Queen Kaahumanu Highway. 2. An exclusive left-tum and right-tum lanes on the westbound approach of Hoohana Street at the intersection with North Kaniku Drive. 3. An exclusive right-tum lane on the northbound approach of North Kaniku Drive at the intersection with Hoohana Street. 4. Install a traffic signal system at the intersection of North Kaniku Drive with Hoohana Street." We note that the comments and conditions listed in the attached HDOT letter dated July 16, 2007 (STP 8.2542) are still valid and applicable. The applicant wishes to include in the amendment request to propose an emergency access corridor to address Condition 6 of the SMA 07-019, which states: "6. To the extent allowed by the applicable government agencies and Mauna Lani Service, Inc., applicant shall take commercially reasonable steps to enable its construction access road to also serve as an alternative emergency evacuation route for the Mauna Lani Resort and the Puako community; provided, however, that the applicant shall not be responsible for maintenance and/or control of the alternate emergency evacuation route." We recommend that the applicant coordinate a meeting with the Highways, Hawaii District Office to discuss the feasibility on the proposed emergency access road onto the state-owned Queen Kaahumanu Highway if they have not already done so. In general, state highways are typically a controlled access facility as defined by the Hawaii Revised Statutes Section 264-61, where owners or occupants of abutting land or other persons have no right or easement or have only a controlled right of easement of access, light, air, or view. 4. We recommend the following strategies to reduce carbon emissions from the project. Suggestions include: a. Incorporate elements that encourage and enhance the use of multiple types of transportation to reduce carbon emissions. b. Implement energy-efficient technologies and practices, such as light-emitting diode lighting. c. Use sustainable, recycled, or low-emission materials in construction and manufacturing. LINDA LINGLE GOVERNOR Mr. Christopher J. Yuen Director Planning Department County of Hawaii 101 Pauahi Street, Suite 3 Hilo, Hawaii 96720-3043 Dear Mr. Yuen: STATE OF HAWAII DEPARTMENT OF TRANSPORTATION 869 PUNCHBOWL STREET HONOLULU, HAWAII 96813-5097 July 16, 2007 Subject:. Stanford Carr Development, LLC Special Management Area Use Permit Application (SMA 07-000019) Mauna Lani Resort, Site M TMK: 6-8-1: 54 and 6-8-22: 10 BARRY FUKUNAGA DIRECTOR Ocpoly Ol!ectors FRANCIS PAUL KEENO BRENNON T. MORIOKA BRIAN H. SEKIGUCHI IN REPL V REFER To: STP 8.2542 We have the following comments on the subject application and the proposed development project: I. The project represents another incremental build-out o_fthe Mauna Lani Resort. 2. It is our understanding that the subject project is not the last increment to be built in the Resort's master plan, nor does the project use the last ~reage of Urban Land Use District designated land in the Resort. Mauna Lani Resort can still grow or expand. 3. Traffic mitigation measures and highway intersection improvements, including signalization, for the project and to address the cumulative impact from the existing and on .. going resort construction projects, with the addition of the new subject project, should . be provided by the landowner/master developer and/or each respective sup-developer, such as the subject applicant. The landowner/master developer and/or each sub- developer, such as the subject applicant, should also be required to participate in and contribute to regional transportation improvements. Project, cumulative resort and regional improvements should be reviewed and approved by the County and/or our Department. 4. The TIAR for the subject project and the earlier Final EIS for Mauna Lani Resort did recognize that there is a need to improve the Resort's main connection (Mauna Lani Drive) to Queen Kaahumanu Highway. Both reports also mentioned that highway widening is planned, however widening of Queen Kaahumanu Highway in the subject Mr. Christopher J. Yuen Page2 July 16, 2007 STP 8.2542 area is a long-range plan and no~ anticipated to occur in the upcoming years. The need to improve the intersection would especially be the case with any sooner implementation of the neighboring Bridge Aina Le'a project (formerly Signal Puako/Puako Hawaii/Nansay). The potential for a connection of a Kawaihae-Waimea By-Pass road at Queen K.aahumanu Highway near Puako is another factor to consider. With the possible future changes to occur and the need to improve access to Queen Kaahumanu Highway, a grade-separated intersection/interchange and lateral or :frontal roadways, similar to those presented in our conceptual master plan for Queen Kaahumanu ~ghway, should be considered along with accommodations to be provided by the landowner/master developer (e.g. reservation of land, space for road right-of-way, or other maintaining of available open land) for such facilities. 5. The phasing of improvements to the existing Mauna Lani Drive intersection with Queen Kaahumanu Highway up to and through the Bridge Aina Le'a project, the highway widening and any new intersection/interchange should be coordinated by the subject applicant for the applicant's project, and by the landowner/master developer for each subsequent increment, with our Highways Division. 6. Mauna Lani's Hoohana Road does extend northward as a service connection to Queen Kaahumanu Highway. The landowner/master developer needs to further explain and describe the current use and future use of this road. 7. The landowner/master developer ofMauna Lani Resort and the suoject applicant should consult with our Highways Division through both the Highways Hawaii District Office and Highways Planning Branch on the details for the planning and timing of implementing the mitigation measures and highway improvements deemed acceptable and/or necessary by the Highways Division. We appreciate the opportunity to provide our comments. ortation From: To: Cc: Subject: Date: Attachments: Aloha, Jay Uyeda Planning LPC Testimony Jay Uyeda DHL-Site M Support Letter Monday, March 30, 2026 10:47:28 AM DHL-Site M Letter of Support pdf Please see attached my support letter for DHL-Site M. Jay Planning Dept. Ex'hibit 7 March 30, 2026 Testimony in SUPPORT of SMA Permit Application {PL-SMA-2026-000087) Tax Map Key: (3) 6-8-001:050; 052~055, and (3) 6-8-022:010, South Kohala, Hawai'i Aloha Chair Au, Vice-Chair Noborikawa, and members of the Leeward Planning Commission, Thank you for the opportunity to express our strong support for the requested I 0-year time extension to commence construction on the Site M project within Mauna Lani. Si nee DHL purchased the Mauna Lani Bay Hotel, golf courses and undeveloped land in 20 l 7, their partnership has made a significant investment in the Mauna Lani community by renovating and revitalizing the Mauna Lani Hotel and golf course facilities. In addition, DHL has shown substantial suppmi for the local community, including important projects such as financial support of a LifcFlitc helicopter to transport residents and guests from Hawaii Island to Honolulu, the Mala'ai garden (a local community garden at Waimea Middle School), and many charitable events held at the Mauna Lani golf courses. I understand that the proposed SMA amendment significantly reduces the size of the hotel and the scale of the residential development at Site M. It also eliminates a conference center and additional golf holes, all of which were previously allowed under the originally granted SMA permit I strongly support DHL's efforts to reduce density within Site M, while maintaining more lands in open space. Finally. the construction of a reliable emergency access road-which provides an importanl secondary egress for i\fauna Lani residents in case of fire or olhcr natural disastcr--is critical to protecting the residents, guests and visitors to Mauna Lani. This secondary access would also create an important alternate route for emergency vehicJes from the Hawaii fire Department. in the event there is some obstruction at the Mauna Lani entrance. DHL's commitment to fonding and constructing this emergency access road demonstrates proactive planning and a commitment to safeguarding our Mauna Lani community. Approving the requested SMA amendment will ensure that Mauna Lani receives this necessary public safety improvement in a timely fashion. For these reasons, I respeclfully urge you to approve DHL's requested amcndmcnls to SMA Permit Application (PL-SMA-2026-000087). Mahalo, Jay M. Uyeda 73-4372 Hiolani PL Kailua-Kona, HI 96740 From: To: Subject: Date: Attachments: Aloha, Rob Kildow Plaooiog LPC Testimony Testimony Site M Mauna Lani Thursday, April 2, 2026 11:08:58 AM DOC040226(1).pdf Kindly see my attached support for DH L's 10 year extension of their SMSA permit. The reduction in density, and therefor traffic, and the construction of the much needed emergency road make if a win for all. Thank you for your consideration. I [g I Robert S. Kildow, R(B) Director of Residential Sales Principal Broker www.hualalairealty.com ~~ Cell: 808-896-8800 Local: 808-325-8500 Toll-Free: 800-983-3880 Fax: 808-325-8501 Hualalai Realty [g P.O. Box 819, Kailua-Kona, HI 96745 This e-mail and any files transmitted with it are confidential and intended only for the individual or entity it addresses. If you are not the intended recipient, you are notified that disclosing, distributing, or copying this communication and any attachments is strictly prohibited. Please notify the sender immediately by e-mail or telephone, and delete this e-mail from your system if you have received this communication in error. Pfenning Dept. Exhibit 8 JfualalaiY<eafly Testimony in SUPPORT of SMA Permit Application (PL-SMA-2026-000087) Tax Map Key: (3) 6-8-001:050; 052-055, and (3) 6-8-022:010, South Kohala, Hawai'i Aloha Chair Au, Vice-Chair Noborikawa, and members of the Leeward Planning Commission, Thank you for the opportunity to express our strong support for the requested 10-year time extension to commence construction on the Site M project within Mauna Lani. Since DHL purchased the Mauna Lani Bay Hotel, golf courses and undeveloped land in 2017, their partnership has made a significant investment in the Mauna Lani community by renovating and revitalizing the Mauna Lani Hotel and golf course facilities. In addition, DHL has shown substantial support for the local community, including important projects such as financial support of a LifeFlite helicopter to transport residents and guests from Hawaii Island to Honolulu, the Mala'ai garden (a local community garden at Waimea Middle School), and many charitable events held at the Mauna Lani golf courses. I understand that the proposed SMA amendment significantly reduces the size of the hotel and the scale of the residential development at Site M. It also eliminates a conference center and additional golf holes, all of which were previously allowed under the originally granted SMA permit. I strongly support DH L's efforts to reduce density within Site M, while maintaining more lands in open space. Finally, the construction of a reliable emergency access road-which provides an important secondary egress for Mauna Lani residents in case of fire or other natural disaster-is critical to protecting the residents, guests and visitors to Mauna Lani. This secondary access would also create an important alternate route for emergency vehicles from the Hawaii Fire Department, in the event there is some obstruction at the Mauna Lani entrance. DH L's commitment to funding and constructing this emergency access road demonstrates proactive planning and a commitment to safeguarding our Mauna Lani community. Approving the requested SMA amendment will ensure that Mauna Lani receives this necessary public safety improvement in a timely fashion. For these reasons, I respectfully urge you to approve DH L's requested amendments to SMA Permit Application (PL-SMA-2026-000087). Rob Kildow Director of Residential Sales Hualalai Resort. PO :71ax S/9, :JCcufua-:JCona, Jlawai'i96745 • (sos) 32.5-J.500 (soo) 9SJ-:JJso :J~ (sos) J2.5-S50J Courier: /OOXa'u_pufdu 7>riue Xa1fua-Xona, Jfawai'i96740 From: To: Cc: Subject: Date: Attachments: Elliot Mills Planning LPC Testimony Elliot Mills Testimony in SUPPORT of SMA Permit Application (PL-SMA-2026-000087) Monday, April 6, 2026 9:51:21 PM Letter of Support.docx Aloha Chair Au, Vice-Chair Noborikawa, and members of the Leeward Planning Commission, Please see the attached letter of support. Mahala nui, Elliot K. Mills Pl1anning Dept. Exhibit 9 HAWAII HOSPITALITY GROUP Testimony in SUPPORT of SMA Permit Application (PL-SMA-2026-000087) Tax Map Key: (3) 6-8-001:050; 052-055, and (3) 6-8-022:010, South Kohala, Hawai'i Aloha Chair Au, Vice-Chair Noborikawa, and members of the Leeward Planning Commission, Thank you for the opportunity to express our staunch support for the requested 10-year time extension to commence construction on the Site M project within Mauna Lani. Since DHL purchased the Mauna Lani Bay Hotel, golf courses and undeveloped land in 2017, their partnership has made a significant investment in the Mauna Lani community by renovating and revitalizing the Mauna Lani Hotel and golf course facilities. In addition, DHL has shown substantial support for the local community, including important projects such as financial support of a LifeFlite helicopter to transport residents and guests from Hawaii Island to Honolulu, the Mala'ai garden (a local community garden at Waimea Middle School), and many charitable events held at the Mauna Lani golf courses. I understand that the proposed SMA amendment significantly reduces the size of the hotel and the scale of the residential development at Site M. It also eliminates a conference center and additional golf holes, all of which were previously allowed under the originally granted SMA permit. I strongly support DHL's efforts to reduce density within Site M, while maintaining more lands in open space. Finally, the construction of a reliable emergency access road-which provides an important secondary egress for Mauna Lani residents in case of fire or other natural disaster-is critical to protecting the residents, guests and visitors to Mauna Lani. This secondary access would also create an important alternate route for emergency vehicles from the Hawaii Fire Department, in the event there is some obstruction at the Mauna Lani entrance. DHL's commitment to funding and constructing this emergency access road demonstrates proactive planning and a commitment to safeguarding our Mauna Lani community. Approving the requested SMA amendment will ensure that Mauna Lani receives this necessary public safety improvement in a timely fashion. For these reasons, I respectfully urge you to approve DHL's requested amendments to SMA Permit Application (PL-SMA-2026-000087). ~- Chief Executive Officer B elliot.mills@hawaiihg.com bJ 808.282.2224 ® 4634 Kilauea Ave, Suite #303 Honolulu, HI 96816 4634 Kilauea Avenue, Suite #303. Honolulu, HI 96816 From: To: Subject: Date: Cad Carlson e1aooioq LPC Jestjmoox Mauna Lani SMA Amendment Thursday, April 9, 2026 5:47:15 PM Please find the attached support testimony: Planning Dept. Exhibit 10 Car1l A. Carl.son, Jr 7.2.•4-857 H101omailie Place Kijiltua-lK0111a IHaw,aii 96740 To: C air Au, Vlc-e-Chalr ol:lOrJ awe,: emb or t e Leeward Pla nl 8 Co mlss1on fr!!lm: Carl A, Cart:so , Jr, R11; S1.1p;port orSMA P:l!!llTilt A,ppllc;ation {PL,,,SMA·:2026-00DOB?) ha you fo the oppo unlty o s b T ters ·mony fn s po ,of h ,applic n 's rn'luest for a ame nd entto SHA Use e,m1, 07-00 0019 -r c,ofls.tn.1r. o alSlt M • the Mau a la ea~ · 1~am, DHl an ct ' ,pport is b as!l d. . • pp Uc a· t's s:t,ewa rds h I !'l o, the • • ves ts In t e ejuve f elr n erous ac o s I uppo or the greate eo munlty nd our •ls lend In 11 • al. I ~ my i.in'rlerstandlng e new aste Plan and pro]Erct 0ts · e inc.l de.:s a s19'lifica ta d Vlrelc ome reduction In dens Ii_,, ot tioth new hotel a Cl r-e· aentlal u I s. !,e a .elf I at.ss the golf cou e e,xpanslon as weu as he Contere ea Ce er, T e Ma-st r Pl.an I eludes he con s1ru o on of a lo -e p roµo.sec:I and nee de o i,u bl c a e E er-gen oy Eva cue. ion •Roa,a w the: Q Ufl&r, a'ahumirnu ieh-..1.'i!l}'- A s ate d abo e, t :S le • e Is wrl en Ins po . o 'the appltc.a ·t•.s. eque!'lt and I would respect1ul1y you to ·appmve; tha regues ed amendrne s. S Mee ely yours. ~a~ Can . Carlson, J•r. From: To: Subject: Date: Doug Clark Planning LPC Testimony SMA Permit application (PL-SMA-2026-000087) to Amend SMA Use Permit No. SMA 07-019 Wednesday, April 8, 2026 5:30:26 PM Dear Planning Commission, We are opposed to the development of this location in Mauna Lani. Adding increased infrastructure to the community will increase the traffic entering and exiting Mauna Lani. This intersection is already in need of a traffic light and adding a hotel or new development without a traffic light will create a major safety concern. Please take time to view the current traffic situation at this intersection to understand the safety concern currently and major concern after adding a hotel or development. Secondly, the Mauna Lani Beach club cannot with stand an increase in access. During peak time the beach club is fully populated which also creates a safety concern. Adding a hotel or new development will put increased pressure on the Mauna Lani community and the planning commission will need to address the safety concerns of the community. By way of this e-mail the Planning Commission has been made aware of the safety concerns in approving a hotel or development without planning for the increase in traffic. Doug Clark Kulalani 2105 Doug Clark dclarkonlake@msn.com Mobile -503-537-8708 Planning Dept. Exhibit 11 From: To: Subject: Date: Brunt. Elizabeth Planning LPC Testimony Site M Mauna Lani Monday, April 13, 2026 3:32:47 AM Dear members of the Board Respectfully as a homeowner in the Villages of Mauna Lani, I am writing to express a deep concern with the proposed Site M development project. I do totally understand the draw to the Kohala Coast, and to the Mauna Lani portion of it in particular. Among the numerous attractions are the lack of overcrowding as found in numerous places on Oahu or Maui. Those of us who get to enjoy our very special lives there either in one of the developments or one of the two gorgeous hotels find the lack of overcrowded roads and beaches part of the bonus of being there. If the density of traffic alone on North Kaniku Drive were to occur, walking and biking would be adversely impacted. Additionally, during holidays, the Foodland grocery store is already burdened, along with parking in the lot of the Shops. Reservations for meals at Tommy Bahamas and the hotels restaurants are already challenging during seasons when most people come to Hawaii. And our beach club really cannot handle more than already is there. In fact, many times, folks go there on the early mornings just to put towels on a cabana to "hold" it for the upcoming day. There truly isn't room for more. And it's doubtful Napua could handle more. This development, if it were to occur, would not have a positive impact in our area. We already have two new sites being developed within Mauna Lani; we had to deal with years of lava grinding for them. I cannot imagine going through that again. Finally, has there been updated and adequate assessment of water and sewer needs/access for Site M? Will Site M be independent for those or will our water and sewer needs and costs be impacted? I am not an engineer, clearly. But my concerns are deep. I trust your committee will take them seriously and give respect them. Thank you Elizabeth Brunt, MD VML, #603 Get Outlook for iOS The materials in this message are private and may contain Protected Healthcare Information or other information of a sensitive nature. If you are not the intended recipient, be advised that any unauthorized use, disclosure, copying or the taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this email in error, please immediately notify the sender via telephone or return mail. Planning Dept. Exhib·t 12 From: To: Cc: Subject: Date: Attachments: Aloha, Sarah Blane Planning LPC Testimony Mjcah Kane: Mel Sanchez Ltr of Support_SMA 07-000018 from Micah Kane Tuesday, April 14, 2026 8:21:29 AM 04 14 26 Mjcah Kane Ltr of Support for SMA 2026-oooosz pdf Please see attached letter of support on behalf of Micah Kane, in his personal capacity, for DH L's proposed amendment to SMA Use Permit 07-000019 (original SMA 2026- 000087). This matter is scheduled to be heard at the Leeward Planning Commission meeting on Thursday, April 23, 2026. I am happy to assist with any questions or concerns and can be reached at this email or on cell at (808) 291-9335. Mahalo, Sarah K. Blane Manager, Public Relations & Government Affairs Parker Ranch (808) 291-9335 Planning Dept. Exhibit 13 From the Desk of Micah l{ane (808) 436-5200 PO Box 1977 Kamuela, HI 96743 Aloha Chair Au, Vice-Chair Noborikawa, and members of the Leeward Planning Commission, Ma halo for the opportunity to share my support for the requested 10-year time extension to begin construction on the Site M project within Mauna Lani. Since DH L's purchase of the Mauna Lani Bay Hotel, golf courses, and surrounding undeveloped lands in 2017, they have made meaningful investments in the community, including renovations to the hotel and golf course facilities. They have also supported the broader community through initiatives such as funding a LifeFlite helicopter seNice, contributing to the Mala'ai garden at Waimea Middle School, and hosting charitable events at the Mauna Lani golf courses. I understand that the proposed SMA amendment reduces the size of the hotel and residential development at Site M, while eliminating previously approved elements lil<e a conference center and additional golf holes. I support these changes, as they reduce density and preseNe more open space. The inclusion of a reliable emergency access road is also critical. This secondary egress will improve safety for residents, guests, and visitors, and provide an alternate route for emergency responders if the main entrance is blocl<ed. DH L's commitment to fund and build this road reflects strong planning and community care. Approval of the SMA amendment will help ensure this important safety improvement moves forward in a timely manner. For these reasons, I respectfully support approval of DH L's requested amendments to SMA Permit Application (PL-SMA-2026-000087). Micah A. Kane From: To: Cc: Subject: Date: Dayjd Colker Planning LPC Testimony David Colker Propsed Amendments to Use Permit No. 07-019. Tuesday, April 14, 2026 11:34:53 AM TO: Leeward Planning Commission RE: Written Testimony regarding SMA Permit Application (PL-SMA-2026-000087) SUBJECT: Amendment to SMA Use Permit No. 07-019 Dear Chair and Commissioners, Pursuant to the Notice of Hearing dated April 1, 2026, David and Alexis Colker submit this testimony regarding the requested amendments to Use Permit No. 07-019. We are residents of The Villages at Mauna Lani (Unit 609), located directly across the street from the subject development site. We formally oppose the requested 10-year extension of the construction completion deadline and any development that would occur duing that extended period. A decade-long extension is a material modification of the original 2008 permit. Moreover, it is likely that few, if any, of the proposed development components of this project could be lawfully constructed without this 10 year extension. Because the surrounding environment and infrastructure have changed drastically over the last 18 years, at a minimum the Commission should exercise its inherent authority and not grant this extension without requiring updated environmental impact studies. Our opposition is based on the following significant concerns: 1. Material Change in Baseline Conditions When Use Permit No. 07-019 was approved in 2008, the Mauna Lani Resort was far less developed. Today, there are 17 completed residential developments and others, like Nohea, currently under construction. The cumulative "environmental footprint" of the resort has changed significantly since 2008 and has reached a tipping point. The impacts anticipated in 2008 are no longer an accurate reflection of the reality in 2026. 2. Specific Adverse Impacts Requiring Updated Study We request that the Commission mandate independent studies to evaluate the following: • Traffic & Safety: Existing traffic congestion (i) at the sole Highway entrance and exit of the Mauna Lani resort, (ii) at the entrances and exits of the Food land shopping center, (iii) on roads immediately leading to the proposed development site and (iv) at the Beach Club (among other places) will be worsened by any further development arising during the 10 year extension of the construction complete deadline. An updated Traffic Impact Report is essential to evaluate pedestrian, bicycle, and vehicular safety throughout the resort. • Parking Crisis: The Beach Club and nearby public lot are currently operating beyond capacity many times throughout the year, leading to illegal parking that damages the landscape and creates safety hazards. The Commission must evaluate how additional density will exacerbate this shortage. • Infrastructure Strain: The demand for water and sewer services has increased since 2008. The project's impact on current utility capacities must be evaluated. • Ecological Degradation: Since 2008, increased resort density has placed stress on the fragile shoreline ecosystem and the coral reefs at the Beach Club and adjacent areas. Moreover, at many times during the year the physical beach club area is already at full ..--"---------, Planning Dept. Exhibit_1 ...... 4.;.__ capacity. Any development arising during the 10-year extension of the construction completion deadline allows for increased human activity that further threatens these resources. • Cultural & Archaeological Resources: Given the density of historical and culturally significant sites in the immediate area, a modern archaeological survey is necessary to ensure that no undiscovered sites within the project boundaries are disturbed by the construction of the project. • Construction Nuisance: A new 10-year window for noise, dust, and vibration is a substantial burden on the nearby residential communities. Any mitigation plans from 2008 are likely insufficient for the current density of the neighborhood. Conclusion A 10-year extension is not a mere "administrative update"-it is a major reprieve that bypasses modern environmental scrutiny. We respectfully request that the Commission defer a decision on this proposed 10 year extension of the construction period until independent, updated studies are conducted and presented in a subsequent public hearing. Thank you for the opportunity to express our views. We appreciate your consideration of these issues. Sincerely, David and Alexis Colker The Villages at Mauna Lani, Unit 609 From: To: Cc: Subject: Date: Planning LPC Testimony Sara Soltan; Allen Salta□ Site M -Mauna Lani Wednesday, April 15, 2026 6:07:52 PM April 15, 2025 Dear Sirs/Mesdames, We have been homeowners at the Villages at Mauna Lani since 2013. We consider Mauna Lani to be a very special place, steeped in Hawaiian history. We are gravely concerned regarding the size of the development being proposed by the owner of Site M in Mauna Lani. We understand that it includes 925 units from the proposed amendment, 374 of which are hotel rooms and 551 of which are condominiums. While we recognize that the owner has the right to develop their property under the existing permit, which was issued in 2009, the current conditions in Mauna Lani -and indeed Hawaii county -have substantially changed since that time. Some of these substantial changes include: over-tourism, development of other parcels of land in Mauna Lani, increased frequency of wildfires, increased water usage relating to short term vacation rentals, climate change, and perhaps most importantly the overall scarcity of water. Increasing temperatures and significantly reduced rain flow since the permit was issued has resulted in a seriously less rainfall in underground aquafers. Further, increasing sea levels risk saltwater contamination of freshwater underground supplies. We are seriously concerned that the size of the Site M development -even in its amended form -is going to cause a number of adverse environmental ,---------, Pf ann i ng De pt. 1Exhibit ____ 1 .... 5_ effects, include sewage, lack of water, and resulting fire risk. Indeed, three water restriction periods have been in effect in that last 12 months -this effects all homeowners, businesses and the public at large. For the foregoing reasons, what the developer of Site M is proposing in its amended form is wholly inappropriate and should not be allowed at all, or alternatively it should be significantly scaled back. In short, we are vigorously opposed to the developer's amendment. At the very least, we request that the County not approve the 10-year extension of the building permit without a full, independent review of a current and forecasted water availability and usage study, paid for by the developer. In this day and age of demonstrated climate change, water has become our most precious resource, and it needs to be carefully managed, as it impacts the ecology of this precious place that we are proud to call home. Of note, the Department of Water has recommended that the allotment of water for Site M be returned to the Department of Water if it is unused by May 26, 2029. Thank you for your consideration. Respectfully submitted, Sara and Allen Soltan April 10, 2026 Mr. Jeffrey Da1Tow Planning Director County of Hawai 'i Planning Department East Hawai'i Office 101 Pauahi Street Hilo, Hawai'i, 96720 DHL Mahi Propco LLC 235 Montgomery Street Suite 1130 San Francisco, CA 94104 Subject: Response to March 6, 2026 Department of Water Supply (DWS) Comments SMA Use Pennit Application (PL-SMA-2026-000087) SMA Use Permit No. 07-019 (Docket No. SMA-07-00019) Applicant: DHL Mahi Site M LL & DHL Mahi Propco LLC Tax Map Key Nos.: (3) 6-8-001 :050; 052-055, and (3) 6-8-022:010, South Kohala, Hawai'i Dear Mr. Darrow: The Applicant, DHL Mahi Site M LLC & DI-IL Mahi Propco LLC acknowledge receipt of the Department of Water Supply (DWS) comments on PL-SMA-2026-000087 dated March 6, 2026. We have listed the DWS comments below and we offer the following response: "We have reviewed the subject application and have the following comments. Water must be allocated from the tri-party agreement between Mauna Lani Service, Inc., Mauna Kea Properties, Inc., and the Water Board of the County of Hawai 'i. Pursuant to the agreement dated April 6, 2009, all unused allocations of water units will revert to the ownership of D WS following a 20 year period fi·om dedication of Parker Well No. 3 and Parker Well No. 4 to the Water Board. Parker Well No. 3 and Parker Well No. 4 were dedicated to the Water Board on May 26, 2009. Therefore, on May 26, 2029, all unused water unit allocations will be returned to the ownership of the Department of Water Supply." Applicant's Response: DHL Mahi Propco, LLC is the current successor-in-interest to Mauna Lani Service, Inc. (MLS) under the April 6, 2009 Tri-Party Agreement, based on an executed Assignment of Water Allocation dated August 1, 2017. The Tri-Paiiy Agreement formally allocated 6.013 million gallons per day (MGD) of maximum daily water nse to the MLS (now DHL Mahi Propco. LLL), which could then be assigned to development areas within the overall Mauna Lani project area (including Site M), subject to County Water Board approval. This will confirm that we are presently working with the DWS on effectuating a formal allocation of the water that DHL Mahi Propco, LLC is entitled to under the Tri-Party Agreement to the Site M property. As indicated by the DWS, any unused water unit allocations under the Tri-Party Agreement are subject to reversion to the DWS on May 26, 2029. This will further serve to confirm that we are also actively working with the parties to the Tri-Party Agreement on an extension to the May 26, 2029 reversion deadline. This extension will also require Water Board approval. Planning Dept. Exhibit 16 Page2 April 10, 2026 Thank you for the opportunity to provide our responses to the March 6, 2026 DWS comment letter. Should you require any additional information or further clarification of our position on the DWS comments, please do not hesitate to contact me at any time. Thank you for your consideration. s~ Pat Fitzgerald cc: Wilson Okamoto Corporation Carlsmith Ball LLP Mr. Michael Mori, Engineer -DWS Water Resources and Planning Branch DHL Mahi Propco LLC 235 Montgomery Street Suite 1130 San Francisco, CA 94104 April 13, 2026 Mr. Jeffrey Darrow Planning Director County of Hawai'i Planning Department East Hawai'i Office 101 Pauahi Street Hilo, Hawai'i, 96720 Subject: Response to March 20, 2026 State Department of Transportation (HDOT) Comments SMA Use Permit Application (PL-SMA-2026-000087) SMA Use Permit No. 07-019 (Docket No. SMA-07-00019) Applicant: DHL Mahi Site M LL & DHL Mahi Propco LLC Tax Map Key Nos.: (3) 6-8-001 :050; 052-055, an• (3) 6-8-022:010, South Kohala, Hawai'i Dear Mr. Darrow: The Applicant, DHL Mahi Site M LLC & DHL Mahi Propco LLC acknowledges receipt of the State Department of Transportation (HDOT) comments on PL-SMA-2026-000087 dated March 20, 2026. We have listed the HDOT comments below and we offer the following responses: "No. 1: The project development is approximately one mile west of the state-owned Queen Kaahumanu Highway and a half a mile north of Mauna Lam Drive. Primary access points are North Kaniku Drive and Hoohana Street." _AppJicant's Response: Acknowledged. "No. 2: The HDOT does not have any objections to the amendment requests to allow a JO-year extension, unit counts reduction, or the removal of the proposed golf course and convention cente,~ It is our understanding that the applicant' s fulfillment to Condition 10 related to traJfic improvements shall be complied pursuant to SMA Pennit SMA 07-019 and the related Land Use Commission Docket No. A84-583 and as follows: "10. The applicant shall provide, at a minimum, the following improvements, meeting with the approval of the Department of Transportation and/ or the Department of Public Works, whichever agency is applicable: 1. An exclusive left-turn lane on the eastbound approach of Mauna Lam Drive at the intersection with Queen Kaahumanu Highway. 2. An exclusive left-turn and right-turn lanes on the westbound approach of Hoohana Street at the intersection with North Kaniku Drive. 3. An exclusive right-tum lane on the northbound approach o_f North Kaniku Drive at the intersection with Hoohana Street. 4. Install a traffic signal system at the intersection ofNorth Kaniku D1ive with Hoohana Street." We note that the comments and conditions listed in the attached HDOT letter dated July J 1, 2007 (STP 8. 2542) are still valid and applicable. 11 Planning Dept. Exh.b,it 1 7 April 13, 2026 Annlicant's Resnonse: We acknowledge the requirements outlined under Condition No. 10 of the original • SMA approval. As noted, the proposed amendment does not modify Condition No. 10, and we remain committed to complying with applicable permit conditions. However, we should point out that the cmTent SMA amendment proposes a reduction in overall project density by decreasing total units from 1,207 units to 925 units, which represents a 23 .4% reduction in development. This reduction is anticipated to con·espond with a decrease in projected traffic generation compared to the originally approved project. In addition, ce1tain off-site improvements identified under the original SMA approval have already been completed, including the exclusive left-tum lane at Queen Ka'ahumanu Highway and Mauna Lani Drive. Fu1ihennore, the regional traffic assumptions and cumulative conditions considered in the original 2007 planning documents, specifically the Traffic Impact Analysis Report (TIAR), have evolved over time, including the status and timing of other planned developments. Based on these factors, we believe that any additional off-site traffic improvements beyond those presently imposed by the current SMA pennit are not warranted at this time. We will continue to coordinate with HDDT and the County as the project progresses to ensure that any required improvements are appropriately addressed. "No. 3: The applicant wishes to include in the amendment request to propose an emergency access corridor to address Condition 6 of the SMA 07-019, which states: 6. To the extent allowed by the applicable government agencies and Mauna Lam Service, Inc., applicant shall take commercially reasonable steps to enable its construction access road to also serve as an alternative emergency evacuation route for the Mauna Lam Resort and the Puako community; provided, howeve,; that the applicant shall not be responsible for maintenance and/ or control of the alternate emergency evacuation route." We recommend that the applicant coordinate a meeting with the Highways, Hawaii District Office to discuss the feasibility on the proposed emergency access road onto the state-owned Queen Kaahumanu Highway if they have not already done so. In general, state highways are typically a controlled access facility as defined by the Hawaii Revised Statutes Section 264-61, where owners or occupants of abutting land or other persons have no right or easement or have only a controlled right of easement of access, light, ai,; or view. 11 Applicant's Response: We acknowledge this comment and our project team is actively working to schedule a meeting to discuss the proposed Emergency Evacuation Road and its potential connection to Queen Ka'ahumanu Highway. (See "Exhibit A"). We will continue to coordinate diligently with HOOT to ensure that the planning and design of the Emergency Evacuation Road are consistent with State requirements and expectations. "No. 4: We recommend the following strategies to reduce carbon emissions from the project. Suggestions include: a. Incorporate elements that encourage and enhance the use of multiple types of transportation to reduce carbon emissions. b. Implement energy-eflkient technologies and practices, such as light-emitting diode lighting. c. Use sustainable, recycled, or low-emission materials in construction and manufacturing." April 13, 2026 Applicant's Response: We acknowledge HDOT's recommendations regarding strategies to reduce carbon emissions, including promoting multimodal transportation, incorporating energy-efficient technologies, and utilizing sustainable construction materials. These considerations are recognized and will be taken into account, as appropriate, during the ongoing design and development of the project. Thank you for the opportunity to provide our responses to the March 20, 2026 HOOT comment letter. Should you require any additional information or forther clarification of our position on these HDOT comments, please do not hesitate to contact me at any time. Thank you for your consideration. cc: Ms. Annette Matsuda, Hawaii District Engineer-HOOT Hawaii District Office Mr. Jeyan Thirugnanam, Land Use Planning Engineer -HDOT Planning Branch Ms. Jenny S. Lee, Planner, HOOT Highways Division Wilson Okamoto Corporation Carlsmith Ball LLP From: To: Cc: Subject: Date: Attachments: Hi Annette: "EXHIBIT A" Jason K, Knable "Matsuda Annette PH" Corpuz, Clifford A; "kentzje.k.mosley@hawajj.gov"; Katherjne A. Garson; Steven s.c. um; Alyssa L Sugiyama DHL -Site M -HDOT Request for Meeting Thursday, April 9, 2026 8:50:52 AM 2026-03-23 PL-SMA-2026-000087 HDOT Comments vl.pdf 2026-03-27 Ltr to Hugh Brady CPL-SMA-2026-000087) Lpc notjfjcatjon,pdf DHL -Site M -PL-SMA-2026-000087 -Figure 1 Site Plan.pdf DHL -Site M -PL-SMA-2026-000087 -ASM Emergency Access Road fl -Road AHgnment Fjgures,pdf I hope that everything is going great with you. Our firm represents DHL Mahi Site M LLC and DHL Mahi Propco LLC, the applicant under Special Management Use Permit Application (PL-SMA-2026- 000087), which seeks to amend SMA 07-00019 to provide a 10-year extension to commence construction of the "Site M" project at Mauna Lani. As I explained to Clifford recently, the amendment request is also intended to provide additional SMA coverage to construct a temporary construction access road connecting to the State highway at an existing South Kohala Fire Station intersection, which would also be utilized as an emergency access road in perpetuity, as originally conditioned under SMA 07-00019, Condition 6. HDOT submitted the enclosed March 20, 2026 comment letter on DH L's amendment request, making a recommendation that DHL "coordinate a meeting with Highways, Hawaii District Office to discuss the feasibility on the proposed emergency access road on to the state-owned Queen Ka'ahumanu Highway ... ". We apologize for the late notice, but we would like to set up a meeting with you and your team to discuss the DH L's temporary construction access road/emergency access road. In anticipation of meeting on DHL's construction access road/emergency access road soon, we have enclosed a Site Plan that shows the general location of the proposed road (but in a broad corridor) connecting Ho'ohana Street in Mauna Lani to the South Kohala Fire Station intersection with the State highway (See attached Figure 1 -Site Plan). DHL only proposed this broad corridor to provide overall SMA coverage for multiple potential alignments through the land separating these 2 roadways (See attached Road Alignment Figures). However, as you will see from the enclosed Road Alignment Figures, the proposed road is intended to utilize the existing right-in, right-out decel/accel channelized intersection at South Kohala Fire Station intersection. Our apologies for not reaching out sooner, but because of the temporary use of the construction access road, and use during emergency evacuations only from an existing access point to the State highway, we did not think HDOT would have concerns. Would you please let us know ifHDOT is available to meet on this issue with DHL's project team? If so, we would appreciate a few dates and times that would work and we will get this meeting set up immediately. I also realize that this is very short notice, but if possible, would you be able to accommodate a meeting before our scheduled 4/23/26 public hearing before the Leeward Planning Commission? Thanks for your help as always! We are looking forward to hearing from you. Aloha. 1 Harbaugh, Derek From:Matsuda, Annette DH <annette.dh.matsuda@hawaii.gov> Sent:Wednesday, April 15, 2026 3:37 PM To:Jason K. Knable; Corpuz, Clifford A; Mosley, Kentzie K Cc:pfitzgerald; Keola Cheng; Hugh Brady; Katherine A. Garson; Steven S.C. Lim; Alyssa L. Sugiyama Subject:RE: DHL - Site M - PL-SMA-2026-000087 / SMA-07-00019 - Summary of 4/15/26 HDOT meeting re: temporary construction access / emergency access road Jason, The meeting summary below is accurate. We concur with the proposed mitigation measures for the subject road and the intersection at Queen Kaahumanu Highway, Route 19. Thank you, Annette From: Jason K. Knable <> Sent: Wednesday, April 15, 2026 2:10 PM To: Matsuda, Annette DH <annette.dh.matsuda@hawaii.gov>; Corpuz, Clifford A <clifford.a.corpuz@hawaii.gov>; Mosley, Kentzie K <kentzie.k.mosley@hawaii.gov> Cc: Pat Fitzgerald <>; Keola Cheng <>; Hugh Brady <>; Katherine A. Garson <>; Steven S.C. Lim <>; Alyssa L. Sugiyama <> Subject: [EXTERNAL] DHL - Site M - PL-SMA-2026-000087 / SMA-07-00019 - Summary of 4/15/26 HDOT meeting re: temporary construction access / emergency access road Hi Annette, Clifford, and Kentzie: We appreciate you taking the time on such short notice to meet with our Site M project team today to discuss the proposed Site M temporary construction access road / emergency access road. As we discussed, this temporary construction access road / emergency access road is proposed for connection to the State highway, through the existing South Kohala Fire Station intersection, and its one of the subjects that we will cover when discussing pending SMA 07- 00019 amendment being heard by the Leeward Planning Commission (LPC) on April 23, 2026. Just to quickly summarize our meeting, we understand that HDOT – Hawaii District office: (1) generally supports the construction of emergency access roads; (2) agrees that use of a temporary construction access for Site M and a permanent emergency access road for the Mauna Lani project, connecting through the existing South Kohala Fire Station to the State highway, is acceptable; (3) suggested the applicant implement appropriate traffic control measures when large construction vehicles enter/exit the State highway from the proposed roadway, if necessary; and ~ OF TR~+,. t~ % l ~ w 0 D :a, . . d'~,..eoF~~~~ Annette Matsuda, P.E. Acting Hawaii District Engineer Hawaii Department of Transportation, Highways Division 50 Maka'ala Street, Hilo, Hawaii 96720 {808) 933-8866 Planning Dept. 'Exhibit_1 ...... a ___ • _ 2 (4) requires the applicant to develop appropriate Best Management Practices (BMPs) to avoid tracking debris onto the State highway, or creating similar safety hazards impacting the State highway users. To address HDOTs concerns, the applicant (DHL Mahi Site M LLC & DHL Mahi Propco LLC) confirmed that it would develop appropriate BMPs for HDOT consideration prior to commencement of construction of the proposed roadway, in addition to implementation of a traffic control measures, as necessary, to minimize temporary traffic disruptions and to address safety concerns when accessing the State highway. The applicant would also commit to the installation of a gate within the applicant’s property, near its point of connection with the County’s South Kohala Fire Station property, in order to stop all construction traffic, so as to avoid interfering with any County Fire Department emergency response. This will also confirm that the applicant will lock this access gate when the subject roadway is not in use for development activities or an emergency evacuation event, as the applicant will prohibit general daily use of this roadway by the public. Please feel free to correct us on any point, if anything in the above summary was misconstrued. If not, we would appreciate a simple confirming response, so we can include this discussion in the public record when we appear before the LPC on the Site M SMA amendment request next week. Again, on behalf of the Site M project team, we thank you for your time, and we appreciate your support of this important component to the Site M project. Aloha. JASON K. 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