HomeMy WebLinkAbout2025-09-11 Proof of Service to the Director DeVera, Ashley
From: Arushini Sinnaduray <arushini@hawaiilawyer.com>
Sent: Thursday, September 11, 2025 3:17 PM
To: Planning Internet Mail
Cc: Toren K. Yamamoto
Subject: Kona Plantation LLC; Notice of Appeal; Holualoa 3rd, Kaumalumalu, HI 96740
Attachments: Notice of Appeal to Planning Department.pdf
Good Afternoon,
Please find attached a letter to you of today's date regarding Kona Plantation LLC, Notice of Appeal.
Should you have any questions or concerns, please contact our office.
A hard copy of the letter has been sent to you via first class mail.
Thank you,
Arushini Sinnaduray
Assistant to Gregory Kugle
Arushini Sinnaduray I Legal Assistant/Paralegal
Office: (808)531-8031
Fax: (808)533-2242
Mail: arushini@hawaiilawyer.com
Web: www.hawaiilawyer.com
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DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Gregory W. Kugle
Toren K.Yamamoto
September 11, 2025 1003 Bishop Street,Suite 1600
Honolulu, Hawaii 96813-6452
Telephone (808) 531-8031
Facsimile (808) 533-2242
E-Mail:gwk@hawaiilawyer.com
tky@hawaiilawyer.com
www.hawaiilawyer.com
VIA CERTIFIED MAIL
RETURN RECEIPT REQUESTED and EMAIL
Kathy Lewis, Chairperson
Board of Appeals
25 Pauahi Street
Hilo, Hawaii 96720
boardofappeals@hawaiicounty.gov
Re: Notice of Appeal to Planning Department
Notice of Violation and Order
Holualoa 3"d,Kaumalumalu (Beach Section),Hawaii 96740
TMKs (3) 7-7-04:073
Dear Chairperson Lewis,
This firm represents Bruce Bergey ("Bruce" or "Owner"), Member of Kona Plantation,
LLC, an Oregon limited liability company ("Company"). On August 12, 2025, our client received
a Notice of Violation and Order, dated July 31, 2025, ("NOVO"), from the County of Hawaii
Planning Department ("Planning Department") alleging that the Owner was using its property,
located at 77-360 Hoomaluhia Dr., Kailua Kona, in violation of County ordinances and certain
settlement obligations between the County and the Owners. The allegations made within the
NOVO are patently untrue and erroneous. Therefore, please treat this letter as a notice of appeal
of the NOVO and the cited to violations within.
L DESCRIPTION OF THE PROPERTY
The Company owns that certain property located at 77-360 Hoomaluhia Dr., Kailua-Kona,
Hawaii 96740, more particularly described as TMK (3) 7-7-004-073:0001 ("Unit A") & 0002
("Unit B", and collectively with Unit A,the"Property"). Owner is a member and majority interest
holder of the Company. For over 25 years Owner has legally operated the Property for agricultural
purposes.
lil MERITAS"
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hawai i lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 2
II. BACKGROUND
In around April of 2000, Owner, with the help of his son Matthew A. Bergey ("Matthew",
collectively with Owner, the "Owners")), began the process of attaining various building permits
related to the creation of two separate 8-bedroom/4-bathroom dwellings on the Property. The
Planning Department, for its part, approved the creation of both dwellings, authorizing the total of
16-bedrooms on the Property via the issuance of Building Permit numbers 005433 and 005931.
In 2002, Owners moved to separate Unit A and Unit B into two distinct condominium
properties. In order to achieve that end a Declaration of Condominium Property Regime of
Plantation Estates, dated November 13, 2002, was recorded in the Bureau of Conveyances of the
State of Hawaii ("Bureau") as Document No. 2002-205148.
On January 30, 2004, Owners were issued a Notice of Violation and Order, alleging that
the Property maintained an "unpermitted additional farm dwelling" and was being used for the
"operation of vacation rentals/retreats without an SMA permit." Owners, in turn, filed an appeal
(BOA 04-004)which culminated in a settlement between the County and Owners dated September
8, 2004 ("2004 Settlement").
The 2004 Settlement required that Owners delete a website(www.konaplantation.com), as
well as a prohibition from using Unit B as a "vacation rental." Sometime in or around January
2008, the County once again levied a Notice of Violation and Order against the Property and the
Owners. On January 28, 2008, Owners once again appealed said Notice to the County of Hawaii
Board of Appeals ("2008 Appeal"). Upon information and belief, as a result of the 2008 Appeal,
the parties entered into a second settlement agreement("2008 Settlement"),which superseded the
2004 Settlement.
The 2008 Settlement echoed the 2004 Settlement and provided that Unit A "shall not be
occupied at any given time by more than five unrelated persons," and that Unit B was to be
"occupied only by individuals involved in the agricultural or farm related activity on the Property."
Of note, the 2008 Settlement did not include a prohibition of website advertisements nor did it
prohibit "vacation rentals." The 2008 Settlement did, however, expressly "supersede[] and
replace[] the [2004 Settlement]."
On August 12, 2008, Unit A and Unit B were both transferred to Kona Plantation, LLC,
an Oregon limited liability company, via Apaitinent Deeds recorded in the Bureau as Doc No(s)
hawai i lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 3
2008-128262 and 2008-128263 respectively. After which Company was the fee simple owner of
the Property. Bruce Bergey is the majority interest holder and member of the Company. Bruce's
son Matthew, and Bruce's grandson Andrew Bergey ("Andrew") are also members of the
Company.
For twenty-six years, Owner managed and operated the Property without interruption under
the dictate of the 2008 Settlement. It was only in 2024 that issues once again started to arise.
Specifically on October 14,2024,the Planning Department sent out a"Courtesy Letter"indicating
that a complaint had been received about the Property's operations and that a Planning Inspector
would be conducting a site inspection. On June 17, 2025, such site inspection was conducted by
Planning Inspector Tiffany Clark("Inspector").
During the site inspection Owner, when discussing website listings for the Property,
mentioned to the Inspector that a platform had previously reached out to list the Property, but the
Owner had since decided to remove such listing. Owner was not referring to the "Ohana Retreat"
website as alleged in the NOVO.
The Inspector also erroneously concluded that all sixteen bedrooms on the Property
constituted as"dwelling units"upon the Property, despite the fact that key elements of establishing
a "dwelling unit" under the Hawaii County Code were absent from said bedrooms. Specifically,
heating elements are not and should not be present in any of the sixteen bedrooms.
Finally, the inspector alleged that the "host currently resides in the additional farm
dwelling" but does not "actively engage[] in agricultural operations on the property." This is
simply false. The Property is used and operated for farm activities. Specifically, 200 trees are
maintained on the Property including both cacao and coffee trees. Both the cacao and coffee that
are grown on the Property are processed into consumables (chocolate and Kona coffee) on the
Property grounds. Bruce actively farms the Property to this day despite some health complications,
and continues to plant, water, and prune the farm's trees. Andrew assists his grandfather in the
year-round management and operation of the farm. Thus,Bruce and Andrew both qualify to reside
in Unit B of the Property.
It is unclear why the County has changed its position after almost seventeen years of
uninterrupted operations on the Property, but it is clear that the Planning Department's NOVO is
completely contrary to the Parties 2008 Settlement and is based on erroneous findings of fact and
conclusions of law.
hawai i lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 4
III. ANALYSIS
1. Owner has not Violated the 2008 Settlement.
Pursuant to Section 1(g) of the 2008 Settlement, said document "supersede[d] and
replace[d]"the 2004 Settlement. That being said, the 2008 Settlement does not prohibit the use of
the Property as a "vacation rental" nor does it prohibit the Owner from establishing a website to
advertise the Property. The 2008 Settlement simply requires that Unit A "shall not be occupied at
any given time by more than five unrelated persons" and that Unit B "shall be occupied only by
those individuals involved in the agricultural or farm related activity on the Property." Owner has
adhered to both of these requirements.
First, County unlawfully and erroneously levies allegations against Owner that they have
violated a settlement obligation to only rent Unit A to no more than five unrelated persons,
however, they provide no evidence to corroborate this assertion. This is likely due to the simple
fact that no such evidence exists, after all, the "Ohana Retreat" is aptly named and Unit A is and
has only ever been advertised for"large famil[ies]". In order to comport with the 2008 Settlement,
Owners have always maintained that the while 8-bedrooms are available for rent in Unit A, said
premises capacity could only be reached so long as no more than five unrelated persons were
renting it. This has been Owner's requirements since the 2008 Settlement took effect and County
has no evidence to show that Owner has breached that responsibility.
Second, County unlawfully and erroneously alleges that the Owner has breached its
responsibility to engage in farm activity while living in Unit B. Unit B is and has only ever been
lived in by "individuals involved in the agricultural or farm related activity." Owner (Bruce
Bergey), who lives in Unit B, has extensively engaged in farm activity on the Property for over
25-years. Owner has hand planted over 1,000 trees on the Property and to this day waters,prunes,
harvests, and plants crops throughout the year.
An additional room in Unit B is also inhabited by Andrew Bergey, the onsite manager of
the Property. Andrew assists Owner with the Property's agricultural activity and is charged with
maintaining the agricultural operations on the Property when Owner is on and off the island. Thus,
while the Owner does spend some time off island, that does not bar him from inhabiting Unit B
when he is in the State. As long as an occupant involves him or herself in the agricultural process
while on the Property, they are not restricted from living in Unit B.
hawaii lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 5
Finally, the 2008 Settlement, unlike the 2004 Settlement, does not restrict the Owner from
maintaining a website for the Property, nor does it prohibit the use of the Property for short-term
accommodations. Because the 2008 Settlement superseded and replaced the 2004 Settlement, it is
unlawful to now hold Owners responsible for adhering to terms within the 2004 Settlement.
Thus, because the 2008 Settlement is the controlling agreement between the Owner and
the County, and because the Owner has strictly adhered to the terms within the 2008 Settlement,
the NOVO's allegation that the Owner has breached its settlement obligations is clearly erroneous
and unlawful.
2. Owner has not Violated the Additional Farm Dwelling Agreement.
Likewise, the Additional Farm Dwelling Agreement (recorded January 19, 2000) governing
Unit B has also not been violated. As stated above, Owner and Adrew Bergey (the individuals who
reside in Unit B)"actively engage[] in agricultural or farm-related activit[ies]"while staying at the
Property, and are therefore lawfully permitted to reside in Unit B.
3. Owner has not Violated County Code.
The NOVO erroneously alleges that (1) Owner "established 16 additional dwelling units
without executing the required farm dwelling agreement or providing the necessary supporting
documentation for agricultural activity",(2)that"alterations to create 16 dwelling units were made
without the required Special Management Area permit,"and(3)the Property was being advertised
for event use.
a. 16 Dwelling Units do not Exist on the Property, and all Bedrooms were Lawfully
Established.
The NOVO erroneously claims that the Owner established "multiple dwelling units" on the
Property by equipping the bedrooms with "independent heating elements." This allegation is
completely erroneous.
HCC Section 25-1-5 defines a "dwelling unit" as "one or more rooms designed for or
containing or used as the complete facilities for the cooking, sleeping and living area of a single-
family only and occupied by no more than one family and containing a single kitchen." The HCC
hawai i lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 6
further defines a"kitchen"as"a room or a portion of a room designed to be used for the preparation
of food and containing at least one item from both of the following categories: (A) Fixtures,
appliances or devices for heating or cooking food; and (B) Fixtures, appliances or devices for
washing utensils used for dining and food preparation and/or for washing and preparing food."
The individual Bedrooms do not have individual "kitchens" raising them to "dwelling units"
as prescribed under the HCC. Further, all necessary building permits to create the sixteen
bedrooms on the Property were lawfully provided by the Planning Department in 2002. Even if
such permits were erroneous, the Owner (and predecessor in interest) has reasonably relied on
such permits for over twenty-five years. See Waianae Model Neighborhood Area Ass'n v. City and
Cty. of Honolulu, 55 Haw. 40, 44, 514 P.2d 861, 864 (1973) (when a government official acting
within the ambit of his authority makes official assurances, the recipient is entitled to rely).
To the extent that unpermitted heating elements are available in the bedrooms, Owner will
remove such appliances. But at this time we are unaware of any such heating elements being
present within the bedrooms.
a. The Property is not Advertised for Event Use.
The NOVO erroneously claims that the Owner is "advertising that the [P]roperty can be used
for events."
Owner does not allow events on the Property and never has. The notes from the site inspection
(listed in the NOVO) makes no mention of any such events occurring on the Property, nor does
the NOVO include evidence of such advertising. The Property is and has only ever been advertised
as a rental, not as an event space. Thus, it is entirely unclear why the County raises this
unsubstantiated assertion.
For the foregoing reasons, and such others that may be shown at the hearing — Owner
reserves the right to amend, supplement and assert further objections—Owner respectfully appeals
to the Board of Appeals from the Planning Department's decision.
hawai i lawyer.com®
DAMON KEY LEONG KUPCHAK HASTERT
A LAW CORPORATION
Kona Plantation, LLC
September 11, 2025
Page 7
We appreciate your attention to this matter. Please do not hesitate to contact the
undersigned at(808) 531-8031.
Very truly yours,
DAMON KEY LEONG KUPCHAK HASTERT
Gregory W. Kugle
Toren K. Yamamoto
CC: VIA U.S. MAIL and EMAIL
Jeffrey W. Darrow
Planning Department Director
planning@hawaiicounty.gov
Aupuni Center
101 Pauahi Street, Suite 3
Hilo, Hawaii 96720
GWK/TKY:das
930250