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HomeMy WebLinkAboutPD Background Report (PL-USE-2026-000046 & PL-SPP-2026-000136)1 BKeaauBenioffHealthCenterSPP&Use8/12/26 COUNTY OF HAWAIʻI PLANNING DEPARTMENT BACKGROUND REPORT KEAʻAU BENIOFF HEALTH CENTER USE PERMIT APPLICATION NO. (PL-USE-2026-000046) SPECIAL PERMIT APPLICATION NO. (PL-SPP-2026-000136) HILO BENIOFF MEDICAL CENTER has submitted related Use Permit and Special Permit applications for the Keaʻau Benioff Health Center. The Use Permit would allow the construction and operation of an approximately 40,000-square-foot medical clinic and accessory uses on an approximately 20.018-acre portion of a 108.8-acre parcel of land. The Special Permit would allow the construction of a project access driveway and associated infrastructure on a 2.648 acres portion of a 1,247.941-acre parcel in the State Land Use Agricultural District. The subject properties are located on the west side of Volcano Highway (State Route 11), near its intersection with Keaʻau-Pāhoa Road (State Route 139) and the Keaʻau-Pāhoa Bypass (State Route 130), Keaʻau, Puna, Hawaiʻi, TMKs (3) 1-6-003:127 (por.) and (3) 1-6-003:007 (por.). APPLICANT’S REQUEST 1. Use Permit Request: The applicant is requesting a Use Permit to construct and operate an approximately 40,000-square-foot medical clinic and accessory uses on an approximately 20.018-acre portion of a 108.8-acre parcel situated within the State Land Use Urban District and County Agricultural-20 acre (A-20a) zoning district. 2. Special Permit Request: The applicant is requesting a Special Permit to construct and use a two-lane access driveway, including street lighting and electrical, telecommunications, and other utility infrastructure, across approximately 2.648 acres of a 1,246.941-acre parcel situated within the State Land Use Agricultural District and County A-20a zoning district. 3. Proposed Development: The applicant proposes to construct the Keaʻau Benioff Health Center, consisting of a single-story, approximately 40,000-square-foot medical center comprised of a clinical wing, a behavioral health wing, urgent care, primary and specialty care, imaging, laboratory, counseling and related outpatient services. The project plans identify 204 parking stalls, including ADA 22 accessible 2 stalls, loading areas, internal circulation, landscaping, drainage facilities, utilities, and an on-site wastewater treatment system. The facility would not operate as an emergency room or drug-rehabilitation facility. According to the applicant, ambulances would not routinely deliver patients to the facility, although patient transfers could occur when necessary. 4. Access and Utility Corridor: Permanent access would be provided by an approximately one-half mile-long, two-lane paved driveway extending mauka from Volcano Highway (State Route 11), generally opposite the existing Shipman Park driveway. The overall access corridor is approximately 3.266 acres, consisting of approximately 0.618 acre within the State Urban District on TMK (3) 1-6-003:127 and approximately 2.648 acres within the State Agricultural District on TMK (3) 1-6-003:007. The driveway is anticipated within a 60-foot-wide right-of-way with a minimum 20-foot paved width and would contain lighting and utility infrastructure. W.H. Shipman, Limited would retain ownership and maintenance responsibility for the private driveway. The driveway corridor would ultimately be subdivided from the affected parcels as a separate roadway lot/right-of-way. 5. Reasons for the Requests: According to the applicant, the proposed Keaʻau Benioff Health Center is needed to address the growing demand for healthcare services in the Puna District. According to the application, Puna is the fastest- growing region in the State, and existing healthcare facilities are insufficient to meet the increasing demand for these services. The proposed health center is intended to improve access to medical services for Puna residents, reduce the need to travel to Hilo for healthcare, alleviate overcrowding and long wait times at Hilo Benioff Medical Center, and support the healthcare objectives of the County General Plan 2045 and the Puna Community Development Plan. 6. Employment and Activity: The applicant anticipates approximately 95 employees and 25 health-care providers, for a total staffing level of approximately 120 personnel. Staff will include medical professionals, administrators, therapists, social workers, maintenance, and custodial personnel. 7. Hours of Operation: Urgent-care services are proposed from 8:00 a.m. to 8:00 p.m., seven days per week, including holidays. Other clinical and 3 administrative services are generally proposed from 8:00 a.m. to 4:00 p.m., Monday through Friday. 8. Construction Timetable and Estimated Cost: Groundbreaking is anticipated in spring 2027, with completion by the end of 2028 or early 2029. The estimated cost of the overall project is approximately $90 million. 9. Related Subdivision: Subdivision application PL-SUB-2026-000419 was filed in March 2026 to create the approximately 20.018-acre health-center site, the approximately 0.618-acre Urban District driveway parcel, and the remaining lands from TMK (3) 1-6-003:127. 10. Landowner: W.H. Shipman, Limited. 11. Supportive Information: The applicant submitted the combined Use Permit and Special Permit application packet, project plans, Final Environmental Assessment and Finding of No Significant Impact, traffic analysis, biological studies, archaeological and cultural studies, and related technical information in support of the requests. (Planning Department Exhibit 1) STATE AND COUNTY PLANS 12. State Land Use District: The approximately 20.018-acre health-center site and approximately 0.618-acre portion of the access corridor are within the State Land Use Urban District. The approximately 2.648-acre portion of the access corridor that is the subject of the Special Permit application is within the State Land Use Agricultural District. 13. County Zoning: The project site and access corridor are zoned Agricultural-20 acre (A-20a). A separate approximately 32.028-acre area in the northeastern portion of TMK (3) 1-6-003:127 was rezoned to Limited Industrial-20,000 square feet (MCX-20) by Ordinance No. 02-23; that area is not part of the proposed health- center site. 14. General Plan 2045 Land Use Map: The project area is designated Medium Density Urban by the Hawaiʻi County General Plan 2045. 15. Puna Community Development Plan: The project is within the Keaʻau Regional Town Center area identified by the Puna Community Development Plan, which calls for concentrating regional services and facilities in and around Keaʻau. 4 16. Chapter 343, HRS: Environmental review was conducted pursuant to Chapter 343, Hawaiʻi Revised Statutes. On May 1, 2026, the Hawaiʻi Health Systems Corporation, East Hawaiʻi Region, accepted the Final Environmental Assessment and issued a Finding of No Significant Impact (FEA-FONSI) which was published on May 8, 2026. 17. Special Management Area: The project area is outside the Special Management Area and is approximately four miles from the nearest coastline. DESCRIPTION OF PROPERTY AND SURROUNDING AREA 18. Subject Properties: TMK (3) 1-6-003:127 contains approximately 108.8 acres and is located mauka of Volcano Highway near its intersection with Keaʻau-Pāhoa Road and the Keaʻau-Pāhoa Bypass. The proposed health-center site occupies approximately 20.018 acres of this parcel. TMK (3) 1-6-003:007 contains approximately 1,246.941 acres of agricultural and undeveloped W.H. Shipman lands; approximately 2.648 acres would be used for the proposed access and utility corridor. The lands have a history of agricultural use and are generally undeveloped or previously disturbed within the project area. 19. Surrounding Zoning and Land Uses: The surrounding area contains agricultural, residential, commercial, industrial, recreational, religious, and public uses. Nearby features include Shipman Industrial Business Park and other W.H. Shipman lands to the north, Herbert Shipman Park and agricultural lands to the south, Volcano Highway and Keaʻau-area development to the east, and agricultural and undeveloped lands to the west. 20. U.S.D.A. Soil Type: Panaʻewa very cobbly hydrous loam on 2-to-10-percent slopes. The soil consists of basic volcanic ash over pāhoehoe lava, is moderately well drained, and is not identified as prime farmland. 21. Land Study Bureau Soil Rating: The Agricultural District access area crosses lands rated Class C (Fair) and Class D (Poor) for agricultural productivity. 22. Agricultural Lands of Importance to the State of Hawaiʻi: The access area includes lands classified as Other Important Agricultural Land and portions not classified under ALISH. 5 23. Flood Zone/FIRM: The project area is within Flood Zone X, outside the mapped 0.2-percent-annual-chance floodplain. 24. Soil Contamination: Soil screening conducted in September 2025 identified arsenic-impacted soil within portions of the project area. The Final Environmental Assessment states that a project-specific Contaminated Media Emergency/Health and Safety Management Plan will be submitted to and approved by the Department of Health, Hazard Evaluation and Emergency Response Office, before disturbance of identified soils. The plan is to address dust monitoring and suppression, worker and public protection, soil handling, and lawful disposal. 25. Flora Resources: The applicant submitted a Botanical Survey prepared by Geometrician Associates, LLC, that included field surveys of the subject property. The survey concluded that no threatened, endangered, or candidate plant species were identified within the project area, and no designated critical habitat for listed plant species is present on the property. The project site consists primarily of previously disturbed lands associated with historic sugarcane cultivation and is dominated by common non-native vegetation. The report concluded that the proposed development is not expected to result in significant impacts to botanical resources and recommended the use of native Hawaiian plant species in the project's landscape plan where practicable. 26. Fauna Resources: The applicant submitted a Vertebrate Faunal Survey prepared by Geometrician Associates, LLC. The survey documented common resident and introduced bird species utilizing the project area. Although no threatened or endangered wildlife species were observed during the surveys, several listed species, including the Hawaiian Hoary Bat (ʻŌpeʻapeʻa), Hawaiian Hawk (ʻIo), Hawaiian Goose (Nēnē), Hawaiian Petrel (ʻUaʻu), Newell's Shearwater (ʻAʻo), Hawaiian Coot (ʻAlae keʻokeʻo), Hawaiian Duck (Koloa maoli), Hawaiian Stilt (Aeʻo), and Band-rumped Storm-petrel (ʻĀkēʻakē), may occasionally fly over or utilize nearby habitats. The report concluded that the proposed development is not expected to result in significant impacts to faunal resources, provided standard mitigation measures are implemented during construction and operation, including 6 vegetation clearing restrictions, invasive species management, appropriate lighting, and the use of native landscaping. 27. Archaeological/Historical Resources: Although an archaeological survey was not conducted specifically for the proposed project, the project area and surrounding W.H. Shipman lands have been subject to several prior archaeological studies. A 2004 Archaeological Assessment included the subject project area and identified no early historic or traditional Hawaiian remains; SHPD accepted the assessment on February 16, 2005. Additional archaeological investigations of the broader Shipman property were accepted by SHPD in 2014 and 2018. These studies documented plantation-era features elsewhere on the broader property but identified no pre-Contact archaeological sites within the surveyed areas. The project area has also been substantially disturbed by former sugarcane cultivation and repeated land clearing. Based on the prior archaeological studies and history of disturbance, archaeological resources are not anticipated within the project area. A new request for SHPD review has been submitted for the proposed project. As of the date of this report, SHPD has not provided a response. 28. Cultural or Native Gathering Rights: The applicant submitted a Cultural Impact Assessment (CIA) prepared for the Keaʻau Village Master Plan area. The CIA evaluated traditional and customary Native Hawaiian practices through background research and consultation with knowledgeable community members. Based on the findings of the CIA, there is no evidence that traditional or customary Native Hawaiian gathering rights are currently exercised within the subject property, and the proposed development is not anticipated to adversely affect cultural practices or native gathering rights. 29. Public Access: The record does not identify a designated public shoreline or mountain access traversing the project area. 7 PUBLIC FACILITIES, UTILITIES AND SERVICES 30. Access: The Project Site is currently accessed from Old Volcano Road via an existing approximately 20-foot-wide paved road that passes through an underpass north of the Puna Hongwanji Temple and connects to an existing cane haul road leading directly to the site. A second existing access road, currently overgrown, is located north of Shipman Park. Both access points are gated and locked. Permanent access to the proposed Keaʻau Benioff Health Center would be provided by a new approximately one-half-mile-long, two-lane paved driveway extending west (mauka) from Volcano Highway (State Route 11), across from the intersection with Keaʻau-Pāhoa Road (State Route 139) and then turning north toward the Project Site. The approximately 3.266-acre driveway corridor would be established within a 60-foot-wide right-of-way and subdivided as a separate roadway lot. W.H. Shipman, Limited would retain ownership and maintenance responsibility for the driveway. The proposed health center would not receive patients by ambulance; however, ambulance transport from the health center to Hilo Benioff Medical Center may occur when deemed medically necessary. 31. Traffic: The applicant submitted a Traffic Impact Analysis Report (TIAR) prepared by SSFM International (January 2026) to evaluate the traffic impacts associated with the proposed Keaʻau Benioff Health Center. The TIAR analyzed existing (2025), future without project (2028), and future with project (2028) traffic conditions at four signalized intersections: (1) Route 11 and Route 130, (2) Route 11 and Route 139/Shipman Park Driveway, (3) Route 11 and Paʻahana Street/Naʻauao Road, and (4) Route 130 and Route 139. The study concluded that the proposed health center is expected to generate approximately 96 vehicle trips during the AM peak hour and 144 vehicle trips during the PM peak hour. The analysis determined that all study intersections will continue to operate at acceptable Levels of Service (LOS) under future with-project conditions, and no roadway or intersection improvements are recommended to accommodate project-generated traffic. Additionally, no modifications to the Route 11/Route 139 (Shipman Park Driveway) intersection are required. The TIAR also concluded that, even when accounting for background growth and the planned Keaʻau Mountain 8 View Public Library, the surrounding roadway network has sufficient capacity to accommodate the anticipated traffic generated by the proposed project without significant adverse impacts. 32. Water: The applicant proposes to serve the project with County water. The Department of Water Supply (DWS) indicated that water can be made available to the project from an existing 16-inch waterline along Hawaiʻi Belt Road or from an existing 16-inch waterline at the intersection of Old Volcano Road and Keaʻau- Pāhoa Road, subject to DWS water availability conditions. DWS has requested estimated maximum daily water-use calculations and based on those calculations, will determine the appropriate service lateral, meter size, and any other required water system improvements. DWS also requires fire hydrants to be spaced no more than 300 feet apart and within 150 feet of the driveway or access for each lot. 33. Wastewater: There is no County wastewater collection system available to serve the project area. According to the applicant, the proposed development will be served by an on-site wastewater treatment system designed in accordance with State Department of Health (DOH) requirements. The wastewater treatment facility will provide secondary treatment for wastewater generated by the proposed medical clinic and associated uses. The applicant states that the system will be designed, permitted, and constructed in compliance with applicable DOH regulations prior to operation of the facility. 34. Solid Waste: According to the applicant, solid waste generated by the proposed medical clinic will be collected and disposed of by a private refuse collection service. Medical waste generated by the facility will be handled and disposed of in accordance with applicable State Department of Health requirements through a licensed medical waste disposal contractor. 35. Police, Fire, and Medical Services: Essential utilities and public services are available to serve the subject property. Police and fire services are located within Keaʻau Village, while medical services are available within approximately seven miles of the property. 9 36. Electrical and Telecommunications: Electrical and telecommunications infrastructure would be extended through the access corridor to serve the health center, subject to the requirements of the applicable utility providers. AGENCIES’ AND ORGANIZATIONS’ COMMENTS 37. Police Department: (Planning Department Exhibit 2 – Memo dated July 13, 2026) 38. Department of Water Supply (Planning Department Exhibit 3 – Memo dated July 27, 2026) 39. State Department of Health (Planning Department Exhibit 4 – Memo dated July 9, 2026) 40. State Department of Transportation (Planning Department Exhibit 5 – Memo dated August 3, 2026) AGENCIES – NO COMMENT OR CONCERN 41. State Office of Planning and Sustainable Development. AGENCIES – NO RESPONSE 42. Department of Public Works – Engineering Division; Department of Public Works – Traffic Division; Department of Environmental Management; Hawaiʻi Fire Department; State Land Use Commission; State Department of Agriculture; State Department of Land and Natural Resources; State Historic Preservation Division; Hawaiian Electric; Hawaiian Telcom; and other referred agencies or organizations not listed above. APPLICANT’S RESPONSE TO AGENCY COMMENTS 43. Letter from Daryn Arai (Planning Department Exhibit 6 – Dated August 21, 2026) PUBLIC COMMENTS 44. Email from Kris Toriano (Planning Department Exhibit 7 – Email dated August 24, 2026) 45. Letter from Karin Coleman (Planning Department Exhibit 8 – Letter dated August 28, 2026) 46. Letter from Ken Allison (Planning Department Exhibit 9 – Letter dated August 28, 2026) 10 47. Email from Alexander Bazuzi (Planning Department Exhibit 10 – Email dated August 24, 2026) 48. Letter from Danette Vincent (Planning Department Exhibit 11 – Letter dated August 24, 2026) 49. Letter from Kristin Obana (Planning Department Exhibit 12 – Letter dated August 28, 2026) 50. Letter from Cheryl Jackson (Planning Department Exhibit 13 – Letter dated August 28, 2026) 51. Letter from Terri Haina (Planning Department Exhibit 14 – Letter dated August 28, 2026) 52. Letter from Kelsey Okuda (Planning Department Exhibit 15 – Letter dated August 28, 2026) 53. Email from Alice Takamine (Planning Department Exhibit 16 – Email dated August 25, 2026) 54. Letter from Sharlene Macasieb (Planning Department Exhibit 17 – Letter dated August 28, 2026) 55. Letter from County Council Vice Chair Dennis “Fresh” Onishi (Planning Department Exhibit 18 – Letter dated August 24, 2026) 56. Letter from Joseph Grennier (Planning Department Exhibit 19 – Letter dated August 25, 2026) 57. Letter from Gerald Koesters (Planning Department Exhibit 20 – Letter dated August 26, 2026) 58. Letter from Senator Dru Mamo Kanuha (Planning Department Exhibit 21 – Letter dated August 31, 3026) 59. Email from Luke Alfsen (Planning Department Exhibit 22 – Email dated August 26, 2026) Daryn Arai Land Use Planning Consultant P.O. BOX 4501, HILO HAWAII 96720 PHONE: (808) 895-3218 EMAIL: June 1, 2026 Mr. Jeffrey Darrow Planning Director 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Director Darrow: Subject: Use and Special Permit Applications for Hilo Benioff Medical Center Proposed Uses: Health Center and related support facilities TMK: 1-6- In partnership with the landowner of the above-described properties, W.H. Shipman, Limited, the Hilo Benioff Medical Center presents the accompanying Use and Special Permit applications that would, if approved, allow for Health The Use Permit application encompasses the proposed 40,000 square-foot health center and related facilities on approximately 20.018-acres of land within a larger 108.8-acre property (Parcel 127) situated within the State Land Use Urban District along with its driveway access traversing over an additional 0.618-acre of land within the same property. The Special Permit application seeks approval to allow for a proposed 60-foot wide driveway access from the Volcano Highway (State Route 11) to the project site traversing across approximately 2.648 acres of land within a larger 1,246.941-acre property (Parcel 007) that is situated within the State Land Use Agricultural District. We hope that you find this submittal in order. Should you have any questions or require additional information, please feel free to contact me. Thank you very much! Sincerely, Daryn Arai Land Use Planning Consultant Enclosures copy Mr. Dan Brinkman, East Hawaii Regional CEO, Hawaii Health Systems Corporation Ms. Peggy Farias, President, W.H. Shipman, Limited Kea au Beniof f Health Center - -- - -- - -- - - -- -- - -- - - SUPPORTING INFORMATION REGARDING SPECIAL and USE PERMIT APPLICATIONS FOR KEAʻAU BENIOFF HEALTH CENTER Affecting Tax Map Keys: (3) 1-6-003: 007 (por) and 127 (por); Keaʻau, Puna A. LOCATION OF PROJECT SITE AND LANDOWNERSHIP 1. Applicant’s Requests Hilo Benioff Medical Center (Applicant), is requesting a Use Permit to allow for the construction and establishment of the proposed Keaʻau Benioff Health Center (hereinafter referred to as “health center”) on an approximately 20.018-acre portion (Project Site) of a larger 108.8-acre parcel (Parcel 127) situated within the State Land Use Urban District. Also a part of this request is the construction of an access driveway, along with street lighting and electrical and telecommunication utilities that will support the proposed health center, within that portion of Parcel 127 also traversing the Urban District and comprising approximately 26,920 square feet (0.618 acre). In addition, the Applicant is seeking a Special Permit to allow for the construction of a two-lane access driveway to the Project Site, along with street lighting and electrical and telecommunication utilities, from the Keaʻau-Pahoa Road (State Route 11) that traverses over approximately 2.648 acres of land within the larger Parcel 007 (1,246.941 acres) that is situated within the State Land Use Agricultural District. 2. Location of Property The Project Site is situated within the village of Keaʻau within the Puna District which lies to the south of the City of Hilo and roughly 7 miles south of the Hilo International Airport. The Project Site is located along the west side of the Volcano Highway (State Route 11) near its intersections with the Keaʻau-Pāhoa Road (State Route 139) and the Keaʻau-Pāhoa Bypass (State Route 130), as shown below on Figure 1-Location Map and Figure 2-Vicinity Map below. The Project Site is located between Shipman Business Park to the north and the Herbert Shipman Park to the south. Across the Volcano Highway to the east is the village of Keaʻau that currently accommodates most of the commercial, residential and public services that supports this particular section of Puna. 3. Landownership The 20.018-acre Project Site that will support the proposed Keaʻau Benioff Health Center and the 3.226-acre access driveway are situated on lands owned by W.H. Shipman, Limited who has authorized the filing of the subject Use and Special Permit applications. It is intended that upon approval of both the Use and Special Permits, the Applicant will purchase, in fee, the 20.018-acre Project Site. W.H. Shipman, Limited will retain ownership of the proposed access driveway totaling 3.266 acres. 1 | P a g e Figure 1 - Location Map B. STATEMENT OF OBJECTIVES AND PROJECT OPERATIONAL DETAILS 1. Statement of Objectives and reasons for the requests Hilo Benioff Medical Center is tasked with serving not only the residents of Hilo but also those from surrounding areas including Puna, Volcano, and the Hāmākua Coast. Puna is the fastest growing region in the state. According to census data, it has seen a population increase from about 31,000 people in 2000 to nearly 52,000 people in 2020 and is expected to top 75,000 residents within the next 6 years. Its rapid population growth has created increased pressure on the existing healthcare services, which are currently insufficient to serve the growing population, especially with regard to urgent health care and specialty services. The entire Puna District currently contains two East Hawaiʻi Health Urgent Care clinics – the East Hawaiʻi Health Clinic in Keaʻau and the East Hawaiʻi Health Clinic in Pāhoa, along with Keaʻau Urgent Care. Urgent care services are only provided by these clinics between 7:00 a.m. and 7:00 p.m., 7:00 a.m. and 5:00 p.m., and 9:00 a.m. and 7:00 p.m. respectively. 2 | P a g e Additionally, access to specialty care, EKG and imaging services are also very limited in Puna and currently only offered at the Keaʻau East Hawaiʻi Health Clinic. Insufficient access to health services in Puna requires many Puna residents to seek care in Hilo. As a result, Hilo Medical Center has strained to accommodate the influx of patients, resulting in long wait times and overcrowding. Development of the new health center will help to fill in existing gaps in the availability of urgent care, specialty care and imaging services for Puna residents. Both the Hawaiʻi County General Plan and the Puna Community Development Plan discuss the importance of improving social and health care services including to the growing population within the Puna District. Figure 2 – Vicinity Map 3 | P a g e Figure 3 – Aerial Site Plan 2. Proposed Project and Operational Details - Refer to following Figures: • Figure 4 – Overall Site Plan • Figure 5 – Detailed Site Plan • Figure 6 – Access Driveway Plan • Figure 7 – Urgent, Primary, Specialty Care & Imaging Floor Plan (North Wing) • Figure 8 – Behavioral Health Floor Plan (South Wing) a. Development Details i. Plans include construction of a single-story health office building complex consisting of a clinical wing and a behavioral health wing, totaling approximately 40,000 square feet. ii. Approximately 204 paved parking stalls, of which 22 are accessible, will be provided on-site along with loading zones are proposed meeting zoning code requirements. iii. The total disturbance area for the project is proposed to be approximately 13 acres, along with roughly 3.266 acres for the construction of the access driveway that will also include street lighting and electrical and telecommunication utilities within this access corridor. Selected clearing and grubbing are proposed to maintain a buffer around the facility and optimize the appearance of the site. 4 | P a g e iv. On-site infrastructure is expected in the form of driveways, parking, electrical, water supply, storm water management and wastewater disposal facilities. Electricity will be available to the site via HELCO. The Department of Water Supply (DWS) has confirmed that the clinic will be connected to county water supply. Consultation with DWS indicates that adequate water is available for the proposed use and for fire suppression. Preliminary water calculations have been provided to the DWS, as further discussed in Section E(3) of this report, to determine the appropriate water supply lateral size for the proposed development. New water mains will be extended to the site. There is no County sewer line in the area. Wastewater will be handled through a wastewater treatment facility that provides secondary treatment required by the Department of Health rules. v. Access to the clinic is proposed via a new access driveway from the highway. The approximately 0.5-mile access driveway will be constructed through the adjacent Shipman property identified as TMK (3) 1-6-003: 007 and connect to the highway across from the intersection with Keaʻau-Pāhoa Road (State Route 139). The approximately 3.266-acre driveway area will be subdivided from the affected properties onto its own separate road right-of-way. vi. Construction access to the Project Site will be provided via an existing underpass from the Old Volcano Road located adjacent to the north of the Puna Hongwanji Temple. This underpass leads to an existing cane haul road that leads directly to the Project Site. Figure 4 – Overall Project Site Plan 5 | P a g e Figure 5 – Detailed Project Site Plan Figure 6 – Access Driveway Plan 6 | P a g e b. Operational Details i. The proposed facilities will provide urgent care services seven (7) days per week, including holidays, from 8:00 a.m. to 8:00 p.m. ii. Primary care services, specialty clinic services (e.g. cardiology, urology), imaging services (e.g. X-rays, CT scans, ultrasounds), laboratory services, and behavioral health and counseling services will be available Monday–Friday from 8:00 a.m. to 4:00 p.m. iii. Enhanced Urgent Care – no emergency room. iv. Behavioral Health services will provide preventive and management services for adults and children. No crisis management or substance abuse treatments will be provided at the health center. v. Staffing: 95 employees and 25 providers vi. The health center facilities will serve the general public but will be primarily focused on residents of Puna and South Hilo. It is anticipated that the facility will serve over 100 patients per day. vii. The facility will provide outpatient care only and will not be an emergency room or provide drug rehabilitation services. The clinic will not receive ambulances, although ambulance transportation of patients from the proposed health center to the Hilo Benioff Medical Center may occur when deemed necessary. Figure 7 – Urgent, Primary, Specialty Care & Imaging Floor Plan (South Wing) 7 | P a g e Figure 8 – Outpatient Behavioral Health Floor Plan (North Wing) c. Community Engagement i. The Applicant, along with W.H. Shipman, conducted a total of 3 community meetings within Keaʻau between the months of October and December 2025 that included area businesses, services and other community-based stakeholders. The Applicant also made a presentation before the Puna Community Development Plan Action Committee at its April 23, 2026 meeting. The collective comments provided during these meetings were considered and included in the Final Environmental Assessment prepared for this project as well as this report. ii. The Applicant has worked very hard with the landowner, W.H. Shipman, Limited, and the Benioff Foundation to identify the best location with Keaʻau to support this project. This effort also included many discussions with State Legislators, County Councilmembers, the Mayor and his department heads, public and private schools and first responders. 3. Project Timeframe Upon approval of both the Use and Special Permits, the Applicant will immediately apply for Plan Approval of the conceptual development plans with groundbreaking sometime during Spring 2027 with completion of the project by the end of 2028 or early 2029. The total project costs are roughly $90 million. Note that an existing subdivision application (PL-SUB-2026-000419) was submitted in March 2026 to subdivide Parcel 127 into the 20.018-acre Project Site, the 0.618-acre access driveway and remainder lot. 8 | P a g e C. LAND USE AND OTHER REGULATORY CONSIDERATIONS 1. Chapter 343, HRS: Finding of No Significant Impact By letter dated May 1, 2026, the Hawaiʻi Health Corporation, East Hawaiʻi Region accepted the Final Environmental Assessment (FEA) for the proposed Keaʻau Benioff Health Center and issued a Finding of No Significant Impact (FONSI). The FEA and FONSI determination, in its entirety, accompanies this Use and Special Permit application as Exhibit A. 2. General Plan Designation: Medium Density Urban The County of Hawaiʻi General Plan is the policy document for the long-range comprehensive development of the island of Hawaiʻi. The General Plan 2045 Land Use (GPLU) map, as shown on Figure 9 – General Plan 2045 Map, classifies the Project Site for Medium Density Urban uses that may accommodate village and neighborhood commercial, light service industrial, and single-family and multiple-family residential uses with densities up to 35 units per acre. Figure 9 – General Plan 2045 Map 3. Puna Community Development Plan Adopted in 2008, the Puna Community Development Plan (PCDP) called for bold planning initiatives to re-shape the pattern of future growth and development in a manner that is more in harmony with the natural setting and more supportive of a 9 | P a g e better, sustainable quality of life. While there are no specific land use concepts assigned to the Project Site, it is located within the boundaries of the Keaʻau Regional Town Center, as shown on Figure 10 – Keaʻau Regional Town Center map. Figure 10 – Keaʻau Regional Town Center Map Later in this report, a discussion will demonstrate that approval of the requested permits to allow the development of the proposed health clinic at this particular location will not be inconsistent with the policies and goals of the PCDP. 10 | P a g e 4. Keaʻau Village Master Plan By letter dated June 23, 2020, the County of Hawaiʻi Planning Department accepted the Final Environmental Assessment (FEA) for the Keaʻau Village Master Plan and issued a Finding of No Significant Impact (FONSI), with the conceptual land use plan shown as Figure 11. Figure 11 – Conceptual Land Use Plan 11 | P a g e The Keaʻau Village Master Plan was developed to help transform the existing Keaʻau Village area into a walkable, transit-friendly, regional town center concept. The approximately 258-acre project planning area infills lands adjacent to the existing Keaʻau Village, linking Keaʻau Elementary, Keaʻau High School and Keaʻau Middle School. The project could eventually add 940± single-family and multifamily dwelling units, village mixed use commercial and residential areas, and approximately 14.9 acres of regional commercial land. Besides the proposed residential and commercial uses, the planning area includes multi-modal greenways, parks, road improvements, a wastewater treatment plant, water facilities, and other supporting infrastructure. The Keaʻau Village Master Plan would be developed in two phases, each consisting of multiple sub-areas. The 20.018-acre Project Site for the proposed health center is situated immediately adjacent to the north of that area identified as Sub Area 1C. 5. State Land Use Designation: Urban and Agricultural The 20.018-acre Project Site, along with its adjoining access driveway consisting of 0.618 acre, are situated within a portion of Parcel 127 that maintains a State Land Use Urban District designation. The remainder of the access driveway encompassing approximately 2.648 acres of land traverses over the adjoining Parcel 003 that maintains a State Land Use Agricultural District designation. This is depicted on Figure 12 – State Land Use). Figure 12 – State Land Use 12 | P a g e By letter dated November 21, 2025 (see EXHIBIT B), the State Land Use Commission confirmed that Parcel 127, consisting of approximately 108.761 acres and which includes the 20.018-acre Project Site, is situated entirely within the State Land Use Urban District. The Agricultural District includes lands for the cultivation of crops, aquaculture, raising livestock, wind energy facility, timber cultivation, agriculture-support activities (i.e., mills, employee quarters, etc.) and land with significant potential for agriculture uses. Uses permitted in the highest productivity agricultural categories are governed by statute. Uses in the lower-productivity categories – C, D, E or U – were established by the Land Use Commission to include those uses allowed on A or B lands as well as those stated under Section 205-4.5, Hawaiʻi Revised Statutes. Note that agricultural suitability of soils within the Project Site is considered as Class E, or Very Poor. 6. County Zoning: Agricultural-20 acres minimum lot size (A-20a) The Agricultural (A) zoning district provides for agricultural and very low density agriculturally-based residential use, encompassing rural areas of good to marginal agricultural and grazing land, forest land, game habitats, and areas where urbanization is not found to be appropriate. See Figure 13 – Zoning. Figure 13 – Zoning 13 | P a g e 7. Coastal Zone Management, HRS, Chapter 205A The entire State of Hawaiʻi lies within the Coastal Zone Management area. The intent of the Coastal Zone Management Program is to guide and regulate public and private uses in the coastal zone management area with respect to recreational resources, historic resources, public access to the shoreline, scenic and open space resources, coastal ecosystems, marine resources, economic uses, coastal hazards, managing development, public participation, and beach protection. 8. Special Management Area (SMA) The Special Management Area is a part of the Coastal Zone Management Program that is regulated by the County, established to promote the State’s policy to preserve, protect, and where possible, to restore the natural resources of the coastal zone of Hawaiʻi. Therefore, special controls on development within the area along the shoreline are necessary to avoid permanent loss of valuable resources and the foreclosure of management options, and to ensure that adequate public access is provided to public- owned or used beaches, recreation areas, and natural reserves, by dedication or other means. The Project Site is not situated within the SMA and is located almost 4 miles from the nearest coastline and at least 3.4 miles from the closest SMA boundary. 9. Integrated Resources and Solid Waste Management Plan (IRSWM) - 2019 Due to the close proximity of the Hilo Transfer Station, the sort station, green waste facility and recently closed landfill, the IRSWM previously identified existing operational and abandoned quarry sites as a potential location for future expansion of the South Hilo landfill. However, the 2019 IRSWM update noted that a study of this possible expansion into nearby abandoned quarry sites was deemed unfeasible due to the proximity of the Hilo International Airport, among other considerations. Solid waste residuals that are not recycled are transported to the West Hawaii Sanitary Landfill at Puʻuanahulu in North Kona. D. DESCRIPTION OF PROPERTY AND SURROUNDING AREA 1. Project Site The 20.018-acre Project Site maintains a roughly rectangular shape along the southwestern corner of the larger 108.8-acre Parcel 127 and includes a proposed access driveway on an approximately 0.618-acre of land immediately makai (east) of the Project Site (see Figure 3-Aerial Site Plan). The proposed access driveway will be extended to the south of the Project Site through the adjoining 1,246.941-acre Parcel 007 before turning to the east (makai) to intersect with the Volcano Highway (State Route 11). A 60-foot wide right-of-way encompassing approximately 2.648 acres will be created to accommodate this access driveway. The entirety of the Project Site, which resides at an elevation between 280 feet above sea level along its makai (eastern) boundary to 350 feet along its mauka (western) boundary, were cultivated with sugarcane along with adjoining lands in the immediately 14 | P a g e surrounding area until the closure of Puna Sugar Company in 1982. The Project Site has since been utilized for the cultivation of other crops, such as papaya. Due to the extensive agricultural history, the Project Site and wider property are vegetated with nonnative plants. 2. Parcel Background Information a. July 16, 1994 – State Land Use Commission Decision and Order (see EXHIBIT C) issued to Petitioner Office of State Planning to amend 660 acres of land that includes the Project Site from the Agricultural to the Urban District as part of the Hawaii State Land Use District Boundary Review-Hawaii (OSP 1992) (“Boundary Review Report”), that recommended that the Property be reclassified from the Agricultural to Urban District. The purpose of the Five-Year Boundary Review is to conduct a comprehensive, statewide evaluation of State land use districts. Based on this evaluation, there was a recommendation to allocate sufficient land for future urban growth and also to direct urban growth to appropriate areas. The intent is to provide for lang-range planning by designating areas for future urban growth rather than reacting to landowner-initiated petitions. b. February 28, 2002 – Effective date of Ordinance No. 02 23 that rezoned 32.028 acres within the northeastern corner of 108.08-acre Parcel 2 from the Agricultural-20 acre (A-20a) zoning district into the Industrial-Commercial Mixed Use-20,000 square feet minimum lot size (MCX-20) zoning district in support of then-proposed Gateway Shopping Center and adjoining mixed use commercial/light industrial area. This zoning ordinance, and the conditions that accompany it, do not directly affect the Project Site as this project was never pursued. 3. Surrounding Zoning/Land Uses The Project Site is situated a little over 7 miles from Downtown Hilo along the western (mauka) side of the Volcano Highway (State Route 11) between Shipman Business Park (zoned MG-1a) to the north and the Herbert Shipman Park (zoned A-20a) to the south. As mentioned above, a 32.028-acre portion of Parcel 127 rezoned to the MCX-20 zoning remains fallow and undeveloped. 4. ALISH Soils within the Project Site are not classified (see Figure 14 – ALISH Map) according to the Agricultural Lands of Importance to the State of Hawaiʻi, due to its designation for Urban land uses by the State Land Use Commission. 5. Land Study Bureau's Detailed Land Classification System The soils within the Project Site are not classified for agricultural productivity due to its designation for Urban land uses by the State Land Use Commission (see Figure 15 – Land Study Bureau Map). Surrounding lands are generally designated as Class D or “Poor” for agricultural productivity. 15 | P a g e Figure 14 – ALISH Map Figure 15 – Land Study Bureau Map 16 | P a g e 6. US Soil Survey Soils within the Project Site are comprised of Panaewa very cobbly hydrous loam with 2 to 10 percent slopes (2klkz). This soil series consist of basic volcanic ash over pahoehoe lava and is moderately well drained with a high runoff class. This soil type is not considered prime farmland. 7. FIRM: Zone X The entire Project Site is designed within Zone "X" - determined to be outside the 500- year flood plain. While USGS Stream Stats indicate the presence of several unnamed drainage paths that run through the larger 108.8-acre Parcel 127, the Project Site has been situated to avoid issues with drainage or flooding. A drainage basin extends to cover a portion of the southern end of the property. The drainage basin is calculated to generate 2,720 cubic feet per second (cfs) of runoff in a 100-year storm event (USGS, 2024). Project construction is proposed to be sited within an area that will not be affected by this existing drainage basin. A proper drainage feature will be installed where the drainage basin crosses under the new access road. 8. Flora/Fauna Resources As part of the FEA, a biotic survey of the Project Site was conducted on September 30, 2025 that identified only one species of native plant (Popolo-Solanum nigru). Due to the past extensive cultivation of these lands for sugar cane and other more-recent agricultural activities, it is unlikely that any endangered plant species exist or will be adversely affected by the proposed project. The survey also determined that it is unlikely that any threatened or endangered species of animals exist within the Project Site. Common non-native birds were observed, such as common myna (Acridotheres Trista), house sparrow (Passer domesticus), house finch (Haemorhous mexicanus), yellow billed cardinal (Paroaria capitata), and spotted dove (Spilopelia chinensis). It would be possible for one (1) mammal and seven (7) federally listed bird species to fly over, roost, or utilize resources near the Project Site. While not on the federal list, it may also be possible for one (1) state listed bird to frequent the area. These include the following: Federally Listed: 1. Hawaiian Hoary Bat (ʻOpeʻapeʻa) (Lasiurus cinereus semotus) 2. Hawaiian Coot (Alae keʻokeʻo) (Fulica alai) 3. Hawaiian Duck (Koloa Maoli) (Anas wyvilliana) 4. Hawaiian Stilt (Aeʻo) (Himantopus mexicanus knudseni) 5. Band-rumped Storm-petrel (ʻAkēʻakē) (Hydrobates castro) 6. Hawaiian Goose (Nēnē) (Branta (=Nesochen) sandvicensis) 7. Hawaiian Petrel (ʻUaʻu) (Pterodroma sandwichensis) 8. Newell’s Shearwater (ʻAʻo) (Puffinus newelli) State Listed: 9. Hawaiian Hawk (ʻIo) (Buteo solitarius) 17 | P a g e As discussed in further detail within the FEA, the Applicant will adhere to all mitigating measures to protect listed mammals and birds as outlined in the section below: Impacts and Mitigating Measures 1. The Hawaiʻi Division of Forestry and Wildlife (DOFAW) recommends minimizing the movement of plant or soil material between worksites to avoid or reduce potential impacts from fungal pathogens. All equipment, materials, and personnel should be cleaned of excess soil and debris to minimize the risk of spreading invasive species. 2. Native plant species that are appropriate for the area will be used for landscaping. No detrimental invasive species will be planted on site. DOFAW recommends consulting with the Big Island Invasive Species Committee (BIISC) to help plan, design, and construct the project, learn of any high-risk invasive species in the area, and ways to mitigate their spread. The Plant Pono guide found at www.plantpono.org can also be used for guidance on the selection and evaluation of landscaping plants and to determine the potential invasiveness of plants to be used on site. 3. Cats are natural predators of native birds, including State-listed endangered waterbirds, seabirds, and forest birds. Their hunting instincts mean that even well-fed cats will actively hunt and prey on wildlife. As a result, DOFAW advises that no feeding of feral cats takes place on the property. With the mitigating measures outlined above, impacts to native flora and fauna will not change appreciably under any alternative action, except a no action alternative. 9. Archaeological Resources Rechtman Consulting, LLC conducted an Archaeological Assessment of an approximately 112 Acre portion of TMKs (3) 1-6-003:007 and (3) 1-6-146:017 in September of 2004 as was included as Appendix F within the FEA. That assessment, which included the entirety of the 20.018-acre Project Site, produced no evidence of early historic or traditional Hawaiian remains. The survey confirmed that most of the area consisted of fallow sugarcane fields. The small, seemingly uncultivated portion of the assessed area was intensively surveyed and contained no cultural remains. The assessment recommended that no further archaeological work need be conducted of the area prior to development. That report was accepted by SHPD on February 16, 2005. Additionally, Scientific Consultant Services (SCS) conducted an Archaeological Inventory Survey (AIS) of approximately 254.1 acres of the broader W.H. Shipman property in Keaʻau, which encompasses and surrounds the Project Site (Escott, G.G., 2018). “Area C” in that study includes the area of the proposed access road. Fieldwork was conducted between January and December 2016, and SCS submitted the AIS to the State Historic Preservation Division (SHPD) for review in May 2017. In a letter dated February 12, 2018, SHPD accepted the findings and recommendations of the AIS. Additionally, an earlier archaeological field investigation conducted by SCS in 18 | P a g e July 2014 covering adjacent portions of the Shipman property was accepted by SHPD in a letter dated September 4, 2014, with SHPD concurring that no historic properties would be affected within that surveyed area. Based on historical research and prior archaeological studies, the Keaʻau area was not known to be inhabited prior to its development as a sugar plantation town. Plantation-era foundations, footings, and constructed boundaries from the early to mid-1900s may remain on portions of the broader Shipman property; however, these site types are not anticipated within the subject 20.018-acre Project Site given its uninterrupted history of sugar cultivation and repeated land clearing. Aerial imagery from 1965 and present day confirms the extent of clearing and land disturbance for agricultural use. Imagery from 2019 compared to present day further confirms that significant clearing and agricultural use of the property have continued. The entirety of the Project Site has been heavily disturbed by sustained agricultural operations and it is highly unlikely that any pre-Contact or historic archaeological resources remain within the project area. 10. Cultural or Native Gathering Rights PBR HAWAII prepared a Cultural Impact Assessment (CIA) for the Keaʻau Village Master Plan, which covers the W.H. Shipman property that also encompasses the Project Site (PBR Hawaii & Associates Inc. 2017). The CIA provides detailed information on the cultural and historical context of the Keaʻau ahupuaʻa, prior archaeological work, and summaries of community consultations regarding cultural practices in the area. The findings and conclusions of the CIA are applicable to the Project Site, as it is located within the same ahupuaʻa and on the same landholding. The CIA includes information from community consultations and “talk story” interviews with individuals knowledgeable about the cultural resources and practices of the Keaʻau area. A review of these consultations did not reveal or identify historic or cultural resources or practices that may be adversely affected by development within the Project Site and immediately surrounding area. Ongoing cultural activities in the broader Puna District include those at the Makuʻu Farmers Market, the Kamehameha Schools Hawaiʻi campus, ʻAha Pūnana Leo, and Ke Kula ʻO Nāwahīokalaniʻōpuʻu, all of which are located outside the Keaʻau Village planning area away from the Project Site. The ʻōlelo noʻeau and cultural traditions of Keaʻau speak to the lush vegetation of these lands, including maile, lehua, and hala. The people of Puna were historically known as master weavers; cultural practices including lāʻau lapaʻau (Hawaiian herbal medicine) and the gathering of lauhala (pandanus leaf) for weaving were recorded and continue to be practiced in the broader Puna District. The Project Site, given its long history of commercial sugarcane cultivation and repeated clearing, does not appear to contain the native plant resources typically associated with traditional Hawaiian gathering practices. The Hawaiʻi State Supreme Court’s PASH and Ka Paʻakai O Ka ʻAina decisions require decision-makers to consider a project’s impact to native Hawaiian practices and 19 | P a g e resources. Specifically, prior to making a decision, State and County agencies must identify the cultural, historical, and natural resources and associated traditional and customary practices of the Project Site, the impacts of the proposed project to those resources and practices, and the feasible action (i.e. mitigating measures), if any, to protect such resources and practices. The FEA concludes that based on the CIA prepared by PBR HAWAII, the AIS conducted by Scientific Consultant Services, and the Archaeological Assessment conducted by Rechtman Consulting, LLC for the broader Shipman property, and consistent with the Hawaiʻi State Supreme Court’s PASH and Ka Paʻakai O Ka ʻAina decisions, no significant adverse impacts to cultural resources, traditional practices, or gathering rights are anticipated from the development of the proposed health center. Archeological studies conducted throughout the Keaʻau area since the 1990s have not found evidence of pre- Contact habitation or traditional resource use within the sugarcane cultivation areas that included the Project Site and surrounding area; rather, they have identified only sites related to plantation-era railroad, commercial sugar, and residential uses during the Historic or Modern eras. No cultural informants or community consultees identified cultural resources or practices that would be adversely impacted by the proposed development. These conclusions will not change appreciably under any alternative. As a mitigating action, the FEA notes that construction documents for the proposed health center will include a provision that should any undocumented archaeological or cultural resources — including artifacts, shells, bones, midden deposits, charcoal deposits, lava tubes, stone platforms, pavings, or rock walls — be encountered during grading or construction, all work in the immediate vicinity of the find will cease and the State Historic Preservation Division (SHPD) will be contacted to determine the significance of the find and to approve an acceptable mitigation plan as needed. If human burials are encountered, they will be treated in accordance with the specific provisions of Chapter 6E, HRS. 11. Public Access There is no record of a designated public access to the shoreline or mountain areas that traverses through the Project Site. E. PUBLIC UTILITIES AND SERVICES 1. Access Access to the Project Site will be provided by a new two-lane paved access driveway extending to the west (mauka) from the intersection of Volcano Highway (State Route 11) and the old Keaʻau-Pahoa Road (State Route 139). This access driveway will then turn to the north to extend to the Project Site. The entire access driveway will be placed within a 60-foot wide road right-of-way to be owned and maintained by the landowner, W.H. Shipman, Limited. The Applicant is anticipating that a minimum pavement width of 20 feet will be necessary to comply with Fire Department regulations while the shoulders will be either compacted gravel or grassed. 20 | P a g e 2. Traffic As part of the FEA, a Traffic Impact Analysis Report (TIAR) was completed in September 2025 by SSFM International to evaluate potential traffic impacts from the proposed health center based on Existing Conditions (2025), and Future Without Project and Future With Project Conditions in 2028. The TIAR analyzed peak period turning movements at the following four (4) intersections based on three (3) Hawaiʻi Department of Transportation 24-hour traffic count locations. Study Intersections: 1. Route 11 and Route 130 2. Route 11 and Route 139/Shipman Park Driveway 3. Route 11 and Paʻahana Street/Naʻauao Road 4. Route 130 and Route 139 HDOT 24-Hour Traffic Count Locations: 1. Route 11 between Old Volcano Road to Paʻahana Street 2. Route 130 between Keaʻau Bypass Road to Kukula Street 3. Route 139 between Keaʻau Pāhoa Road to Keaʻau Kula Road Several other intersections in the area were not analyzed by the TIAR. Analysis of the intersection of Route 11 and Kipimana Street was determined, in consultation with HDOT, to be unnecessary due to project trip expectations. As most project trips are expected to originate from or travel to the communities of Keaʻau, Pāhoa, or Mountain View, and very few trips are expected to be associated with travel to or from Hilo, this intersection is not expected to be impacted by the project. Additionally, the intersection of Old Volcano Road and Route 139 was analyzed in three previous traffic reports in the area from 2020, 2023, and 2024. The intersection operated at an acceptable level of service or better in each report and was therefore assumed not to require further analysis. SSFM International consulted with DOT regarding the choice of study intersections for the TIAR. The TIAR was submitted to HDOT in October 2025 and to date no comments have been received. In summary, the proposed health center is projected to generate up to 96 total trips during the AM peak hour and 144 total trips during the PM peak hour. All signalized intersections are projected to operate at an acceptable overall LOS under Future (2028) With Project conditions. Movements expected to operate at LOS E or worse are not considered significant. Therefore, no improvements are recommended for Future (2028) With Project conditions. In addition, no changes to the intersection configuration at Route 11 and Route 139/Shipman Park Driveway are required to accommodate the proposed health center-generated trips. 3. Water County water service is available to the Project Site, preliminarily through a new 12-inch waterline to be extended from an existing 16-inch water main along the Old Volcano Road. Preliminary water demand calculations arrived at 3,960 gallons per day (gpd) on 21 | P a g e average, equivalent to 10 units of water. Engineering Partners, Inc. developed estimated maximum daily water usage calculations and submitted to the Department of Water Supply (DWS) for review and approval. These calculations include estimated peak flow in gallons per minute and the total estimated maximum daily water usage in gallons per day, including irrigation use. Based on the water demand calculations, the DWS will determine the appropriate service lateral and meter size required to satisfy all water needs including fire suppression requirements. Differences in water main or lateral/meter size would not entail any changes in the environmental impacts of the proposed action. 4. Wastewater There is no municipal sewer system available in the immediate vicinity of the Project Site and an onsite wastewater treatment works (WWTW) will be required. The project is anticipated to generate wastewater at more than 1,000 gallons per day (gpd), mandating compliance with Department of Health (DOH) regulations for a package wastewater treatment works (WWTW) providing secondary treatment. Acceptable treatment technologies include Activated Sludge, Sequential Batch Reactor, Fixed Bed Biofilm Reactor (FBBR), Moving Bed Biofilm Reactor (MBBR), Membrane Bioreactor (MBR), or other advanced methods ensuring effluent quality aligning with DOH’s Chapter 11-62 standards. Detailed wastewater flow calculations will be prepared as part of the permit application submitted to DOH for the WWTW. No injection wells will be used. Treated wastewater effluent will be infiltrated into soils through properly sized leach fields or absorption beds. The treated effluent will be disposed of underground via an absorption bed or other types of drain field. A 100% backup of disposal system is required by DOH. Due to the potential fast percolation rate, soil replacement below the absorption bed may be required for septic effluent. However, the soil replacement requirement may be waived if it is used to receive WWTW effluent. Efforts to minimize wastewater will be reflected in the design of the project, including water efficient fixtures (e.g. low flow systems and timed shut off for appropriate devices in all bathroom and proposed kitchens) and proper landscaping best- management practices. Medical and clinical operations generate regulated medical waste, including sharps, biological materials, and pharmaceutical waste. These materials will be managed separately from the general wastewater stream in accordance with HAR Chapter 11- 104.1 (Regulated Medical Waste) and applicable DOH guidelines, and will be disposed of through licensed medical waste disposal contractors. Such waste will not enter the onsite WWTW. The WWTW will be operated and maintained by a licensed operator in accordance with DOH Chapter 11-62 requirements. An operations and maintenance (O&M) plan will be submitted to DOH as part of the permit application, detailing inspection schedules, 22 | P a g e effluent sampling and monitoring requirements, and corrective action procedures to ensure the system performs as designed and protects groundwater quality. 5. Solid Waste The County of Hawaiʻi Solid Waste Division operates the only landfill on island, the West Hawaii Sanitary Landfill at Puʻuanahulu, which is located approximately 57 miles from the Project Site. The nearest transfer station is located approximately 2 miles away in Keaʻau. Solid waste is expected to be generated by standard operational activities of the health center. All solid waste will be properly recycled and/or disposed of in accordance with County and State DOH rules. A solid waste management plan will be developed in accordance with the Department of Environmental Management guidelines prior to any project activities to determine potential impacts and appropriate mitigating measures. During health center operation, local waste management companies will be contracted to dispose of waste on site. The Applicant will also plan for recycling stations throughout the facilities. Waste disposal will adhere to Department of Health regulations as outlined in HAR §11-104.1 and §11-58.1. 6. Essential Utilities and Services Electricity, telecommunication and internet services are or will be made available to the Project Site in support of the proposed health center operations. At this preliminary juncture, electrical and telecommunication utilities will utilize the proposed access driveway corridor along with necessary street lighting fixtures. Ultimately, the utility companies will likely dictate the location of facilities necessary to support the proposed health clinic. The Applicant, along with W.H. Shipman, Limited, continues to work closely with the utility companies and will finalize system design upon approval of the requested Use and Special Permits. The Applicant is proposing to install solar photovoltaic and solar hot water systems for non-critical patient care areas. 7. Public Safety As the Project Site is located within the village of Keaʻau and less than 7 miles from the City of Hilo, police, medical and fire services are readily available. 23 | P a g e F. STATEMENT OF REASONS IN SUPPORT OF GRANTING USE PERMIT In considering a Use Permit for any proposed use, Rule 7 of the Planning Commission relating to Use Permits requires that such action conform to the following guidelines: 1. The granting of the proposed use shall be consistent with the general purpose of the zoned district, the intent and purpose of the Zoning Code and the County General Plan. The intent and purpose of the Zoning Code is to promote health, safety, morals, or the general welfare of the community through regulations and restrictions relative to the location and use of buildings, off-street parking, the percentage of lots that may be occupied, the density of population and land for trade, industry, residence, or other purposes. The proposed health center will be situated within the State Land Use Urban District and the Agricultural-20 acre (A-20a) zoning district. The existing A-20a zoning of the Project Site is a reflection of its past use for sugar cane cultivation as far back as 1900 and continuing until the early 1980s with the closure of Puna Sugar Company. The Project Site continued to be utilized for the cultivation of other crops, such as papaya. However, actions by both the State, County and community members as far back as the mid-1990s have prioritized the Project Site and its immediately surrounding area as part of the Keaʻau Regional Town Center. The Use Permit process provides an avenue to review and analyze a proposed project on a case-by-case basis relative to infrastructure and impacts on surrounding properties and existing uses as well as the goals and policies of the General Plan. The proposed Keaʻau Benioff Health Center will be developed in compliance with Zoning Code regulations related to building height, yard setbacks, off-street parking, and landscaping. Additionally, a health center is one of a limited class of uses whereby the Zoning Code allows for the granting of a Use Permit to ensure that the proposed use will neither unduly burden public agencies to provide public services nor cause substantial adverse impacts upon the surrounding community. The Applicant firmly believes, through this report and the accompanying FEA, that potential adverse impacts directly caused by the proposed health center operations will be minimal due to proper mitigating actions. The Applicant will need to secure the necessary building permit(s) for any proposed related structures. The Building Permit will allow other agencies to review for compliance with various county and state codes, including but not limited to Fire Code, Health Codes, ADA accessibility, electrical, plumbing and structure regulations. The recently adopted General Plan 2045 serves as a 25-year blueprint for the long- term growth and sustainable development of Hawaiʻi County. It envisions a future that balances growth with the preservation of the County’s unique natural and cultural resources. 24 | P a g e The General Plan 2045 Land Use (GPLU) Map identifies the subject properties and its immediately surrounding area for Medium Density Urban uses, which allows for village and neighborhood commercial, light service industrial and single-family and multiple-family residential uses. Medical clinics, as presented by the proposed Keaʻau Benioff Health Center, is a permitted use within all commercial zoning districts and would be, if approved, consistent with the Medium Density designation the encumbers the Project Site. A. Objectives and Policies The General Plan 2045 presents four (4) overarching goals, each with its Objectives, Policies, and Actions as discussed below. Standards or guidelines were also introduced for some of these goals. 1. Collaborative Biocultural Stewardship The Goal here is to assure that natural, cultural and historic assets are “sustainably managed, preserved, and restored to maintain our unique and diverse environment.” The five (5) Objectives (Objectives 1 to 5), in summary or excerpts, are 1) increase the biodiversity and resilience of native habitats; 2) apply Native Hawaiian ahupuaʻa framework to preserve and enhance health and function of watersheds to promote water recharge, improve water quality, and reduce runoff; 3) increase direct community restoration and collaborative efforts to conserve and nourish the island’s biocultural resources; 4) protect, restore and treat as unique assets the historical integrity, character, scenic assets and open spaces of our communities; and 5) protect, restore and enhance our communities’ unique character. The proposed Keaʻau Benioff Health Center will be situated on lands that have been historically cultivated for sugar cane and other crops. Biological and archaeological surveys have not identified any Native Hawaiian habitats or public trust resources within the Project Site. The location of the Project Site away from coastal waters, streams or old-growth forests helps to mitigate the effects of the proposed project upon these valued community resources. As represented within the Final Environmental Assessment prepared for the Keaʻau Benioff Health Center, the landowner is in the process of developing design guidelines for the Project. Native plant species, such as ʻohiʻa and puhala would be encouraged for landscape plantings where appropriate. Invasive species will be prohibited from active planting. These policies are 25 | P a g e intended to encourage the use of native plants, to minimize the spread of invasive species, and to reduce irrigation needs once any given property is developed and landscaped. It is intended that both recommended native plants and prohibited invasive species will be identified in CC&Rs. The Applicant will also follow recommendations to avoid adverse impacts to the endangered but widespread native birds and the Hawaiian hoary bat that may utilize the area by implementing the following mitigating actions: • To minimize impacts to the endangered Hawaiian hoary bat, trees taller than 15 feet should not be removed or trimmed during the bat birthing and pup rearing season (June 1 through September 15), to the extent practical. • To minimize impacts to Hawaiian Hawks, avoid earthmoving within 100 meters of tall trees or tree cutting during the breeding season for Hawaiian Hawks (March through the end of September). If this period cannot be avoided, arrange for a hawk nest search to be conducted by a University of Hawaiʻi at Hilo biologist or other qualified biologist. If hawk nests are present in or near the Project Site, all land clearing activity should cease until the expiration of the breeding season. • To avoid the potential downing of Hawaiian Petrels and Newell’s Shearwaters by their interaction with outdoor lighting, there should be no construction or unshielded equipment maintenance lighting after dark between the months of April and October. All permanent lighting should be shielded in strict conformance with the Hawaiʻi County Outdoor Lighting Ordinance, which requires shielding of exterior lights to lower the ambient glare caused by unshielded lighting. 2. Climate Change For Island-Wide Health The overarching Goal here is to ensure “a just transition to a climate resilient island by addressing the causes and impacts of climate change through incorporating equitable climate mitigation and adaptation priorities into policies, programs, infrastructure, and decision-making.” The three (3) Objectives (Objectives 6 to 8), in summary or excerpts, are: “a) Ensure that climate actions are equitable and uplift marginalized and disadvantaged communities; b) Reduce the County government’s carbon footprint to net zero emissions by 2045…; c) Improve the identification of climate change threats, assessments of potential consequences, and evaluation of adaptation options.” 26 | P a g e The Goal and Objectives here are more applicable to government. However, it should be noted that the Applicant will explore methods to minimize its contribution toward broader climate change factors that may be ongoing regardless of local development, through provisions such as the encouragement of multimodal means of transportation, renewable energy sources and passive energy-conserving measures such as natural ventilation, solar water heating, and photovoltaic energy. However, long-term solutions to mitigate climate change on a global scale are beyond the scope of the proposed project and may best be handled through national and global policy changes to mitigate and adapt to climate change. One thing remains clear – the proposed medical clinic will provide medical services closer to where people live, thereby reducing the effects associated with commuting to Hilo for medical services. 3. Sustainable Development and Resilient Communities The articulated Goals, in summary or excerpts, are: • to “apply progressive land use strategies incorporating indigenous and contemporary knowledge and place-based practices to direct and manage growth for the health, safety, and emergency response and preparedness services for our communities. • to have “Each community is connected by a multimodal and modernized transportation network that provides a system for safe, efficient, and comfortable movement of people and goods.’ • to have the communities “adequately served by sustainable and efficient public infrastructure, utilities, and services based on existing and future growth needs, sound design principles, and effective maintenance practices.” • to have the communities “safe and protected, and have access to integrative health, education, and social services to support a high quality of life for all residents.” • Strive to have “Residents have access to adequate and affordable housing to meet the needs of population and provide equitable opportunities for household flexibility and mobility.” The conformity of the proposed health center with long-held planning policies for this particular area is supported by the Puna Community Development Plan (PCDP) that shaped the pattern of future growth and development in a manner that is more in harmony with the natural setting and more supportive of a better, sustainable quality of life. The vision of the PCDP is to reshape the development pattern by moving away from the sprawl effects of the existing subdivisions and toward the formation of village and town centers. Over the long term, this will improve 27 | P a g e the feasibility of developing supporting infrastructure for populated areas, give residents better access to public and commercial services, stimulate local employment opportunities, and reduce dependence on the automobile for transportation. It will also help preserve natural and cultural resources by limiting the spread of the development. While there are no specific land use concepts assigned to the Project Site, it is located within the boundaries of the roughly 600-acre Keaʻau Regional Town Center, which consists of two parts. The area bounded by Highway 11 and the Highway 130 By-Pass, including the original plantation village, are for uses that are oriented primarily to residents of the Keaʻau community itself, with the exceptions being the middle and high school and the post office next to Keaʻau Shopping Center, which are region-serving facilities. Most uses of a regional orientation – e.g., Shipman Business Park, the areas already zoned for commercial and light industrial uses, and proposed new police, fire, transit, and medical facilities – are to be located north of Highway 11 to provide convenient vehicular access. The Project Site is situated within this particular region-serving section of the Keaʻau Regional Town Center, where the PCDP notes that commercial development that serves regional uses should be limited to the “regional town center” boundaries. Commercial development that serves community village or neighborhood village uses may be located adjacent to a regional town center. Approval of the Keaʻau Benioff Health Center within the Keaʻau Village Town Center will help to achieve the following goals and objectives of the PCDP: • Services and community facilities are more accessible in village/town centers that are distributed throughout the region, including the underserved subdivisions that have been experiencing higher levels of development growth. • Enhance the role of existing and new village/town centers by allowing expanded commercial uses, facilitating the development of farmers markets and community gathering places, opportunities for special needs housing, and infrastructure to support more compact development form and multi-modal travel. • Target investments in public services and infrastructure to promote the development of village/town centers and, secondarily, to serve the peripheral subdivision areas. • Puna residents have improved access to emergency and primary medical care and preventive public health programs In summary, the General Plan 2045 and the Puna Community Development Plan mutually support each other towards providing enhanced public health services within an area that will help to create a sustainable and resilient community. 28 | P a g e 4. Thriving, Diverse, and Regenerative Economy The overarching Goal here, in summary or excerpt, is to “improv(ing) and maintain(ing) the financial well-being of our residents with a focus on increasing local economic opportunities.” Relative to Economic Goal, Objectives, Policies and Actions (Section 5.2), the three (3) Objectives (43-45), in summary or excerpts, are: 1) Improve access at all levels for education and training 2) Increase the growth and health of small businesses 3) Incorporate resiliency, diversity, and innovation in County programs, plans, and research to support healthy economic development and revitalization. While this goal is likely more directed towards government initiatives, one can all agree that a healthy and thriving economy is dependent upon a healthy community. The hope is that the Keaʻau Benioff Health Center can be another core health facility that the residents of East Hawaiʻi can rely upon. As recited within the Keaʻau Village Master Plan (2020), Keaʻau is a long- established residential and commercial center that grew around the ʻŌlaʻa Sugar Company (later called Puna Sugar Company) in the late 1800’s. The town of Keaʻau became a focal point for area plantation activities and facilities—much of which was built on W.H. Shipman lands. The town included plantation housing, a plantation store, churches, a gym, a school, and a row of supervisors’ homes. Sugar production eventually ceased in 1984 when it succumbed to forces affecting the sugar industry statewide. The Keaʻau Village Master Plan was conceived by W.H. Shipman, Limited to honor and to revitalize the village’s plantation and small-town heritage by expanding on the existing village, offering more workforce and other housing, providing opportunities for small commercial enterprises to co-exist with residential uses, and acting as a transition to a surrounding band of agricultural and rural uses. The Project also provides a venue (Sub-Area 1C) outside of the existing village, and just south of the Project Site, to relieve the pressure for large-scale regional commercial interests in the existing village. The proposed Keaʻau Benioff Health Center will establish a core support facility for the entire Keaʻau Village, improving upon the health of residents from Hilo to Kaʻu and in turn, revitalizing the community of Keaʻau Village. 29 | P a g e 2. The granting of the proposed use shall not be materially detrimental to the public welfare nor cause substantial adverse impact to the community's character or to surrounding properties; The Applicant worked carefully with the landowner, community stakeholders and government representatives and agencies to assess the desirability and capability of the Project Site to support the existing and future health care needs of Keaʻau and the broader Puna community. The Project Site is situated between the Shipman Business Park to the north and the Herbert Shipman Park to the south. After careful consideration, the Project Site was selected due to its location within an area already planned for future regional urban development, its proximity to supporting infrastructure, and its accessibility to the very communities it wishes to serve. The FEA and FONSI issued by the Hawaiʻi Health Corporation, East Hawaiʻi Region, demonstrates the ability of the Project Site to host this much-needed health center with minimal application of mitigating actions to address the any potential adverse impacts that may be generated by the facility. Some of these mitigating actions include managing the hours of operation and scope of services to be offered at the health center to ensure compatibility with surrounding uses such as nearby schools, parks and residential areas. Operational hours for urgent care will be from 8:00am to 8:00pm, daily, with primary care services primarily available from Monday thru Friday, 8:00am to 4:00pm. No emergency room or drug rehabilitation services will be provided at this health center. The Project Site was historically cultivated in sugar cane and other crops for over a century and is not known to be subject to any geological hazards, as extensively discussed within the FEA. The Project Site is not within a designated flood zone nor situated within an ecologically-sensitive area. 3. The granting of the proposed use shall not unreasonably burden public agencies to provide roads and streets, sewers, water, drainage, school improvements, police and fire protection and other related infrastructure. The Project Site is or will be served by necessary utilities and services such as a new access driveway, potable water, compliant wastewater treatment facility, electrical and communications services. A TIAR was prepared which determined that all signalized intersections within the study area are projected to operate at an acceptable overall levels of service (LOS) under Future (2028) With Project conditions. Movements expected to operate at LOS E or worse are not considered significant. Therefore, no improvements are recommended for Future (2028) With Project conditions. In addition, no changes to the intersection configuration at Route 11 and Route 139/Shipman Park Driveway are required to accommodate the proposed health center-generated trips. 30 | P a g e The Applicant will develop and apply best management practices to reduce the use of potable water, electricity and the generation of solid waste while also properly managing stormwater runoff and maintaining air quality during both construction and operational activities. G. STATEMENT OF REASONS IN SUPPORT OF GRANTING SPECIAL PERMIT In considering a Special Permit for any proposed use, Rule 6 of the Planning Commission relating to Special Permits requires that such action conform to the following guidelines: 1. Such use shall not be contrary to the objectives sought to be accomplished by the Land Use Law and Regulations The request, which is limited to the construction of a two-lane access driveway to support the establishment and operation of a proposed health center, is considered an unusual and very reasonable use of agricultural lands. The proposed access driveway will roughly occupy approximately 2.648 acres of marginal agricultural land and will not adversely affect the preservation and agricultural use of the County’s prime agricultural land and therefore, is not contrary to the objectives sought to be accomplished by the State Land Use Law and regulations. Portions of the Project Site are being farmed and the landowner, W.H. Shipman, Limited, is working closely with these tenant farmers to help them relocate while minimizing any significant disruption to their farming activities. The General Plan identifies the Project Site as an Urban Expansion Area. The State has not identified these lands as Prime or Other Important Agricultural Lands, and soils within the Project Site and the U.S. Soil Survey has determined that the soil type found within the Project Site is not considered prime farmland. Finally, the Land Study Bureau finds that the agricultural potential of these soils is Poor. Therefore, to commit the Project Site as much-needed health center is an unusual and reasonable use of marginal agricultural lands that will not compromise the island’s inventory of valuable agricultural lands. In its 1994 Decision and Order that reclassified the adjoining Project Site to the Urban District, the State Land Use Commission found that “There is a need to establish an urban core in Puna to service the growing population. Keaau is a desirable location for an urban care because it is at lower risk of lava inundation than most of Puna and is relatively central in location with respect to the widely dispersed villages of Puna. Keaau also contains an employment center with the W. H. Shipman Industrial Park and the Keaau Town Center.” 31 | P a g e 2. The desired use shall not adversely affect surrounding properties As previously discussed in Section F(2) and summarized here for relevancy to the use of less than an acre of agricultural land for a two lane access driveway, the Applicant worked carefully with the landowner, community stakeholders and government representatives and agencies to assess the desirability and capability of both the proposed access driveway and the Project Site to support the proposed health center that will serve the existing and future health care needs of Keaʻau and the broader Puna community. The Project Site is situated between the Shipman Business Park to the north and the Herbert Shipman Park to the south. After careful consideration, the proposed access driveway and the adjoining Project Site were selected due to its location within an area already planned for future regional urban development, its proximity to supporting infrastructure, and its accessibility to the very communities it wishes to serve. The acceptance of the FEA and the issuance of a FONSI demonstrate the ability of the Project Site and its access connection to the Volcano Highway to host this much-needed health center with minimal application of mitigating actions to address the any potential adverse impacts that may be generated by the facility. The access driveway and Project Site were historically cultivated in sugar cane and other crops for over a century and is not known to be subject to any geological hazards, as extensively discussed within the FEA. Both sites are not within a designated flood zone nor situated within an ecologically-sensitive area. Construction of the proposed access driveway will provide a benefit for both the clients and employees of the proposed health center as well as to the potential agricultural leasees of W.H. Shipman, Limited lands who may continue to cultivate the surrounding lands. 3. Such use shall not unreasonably burden public agencies to provide roads and streets, sewers, water, drainage, school improvements, and police and fire protection The proposed access driveway will be constructed and maintained by the landowner, W.H. Shipman, Limited. A TIAR was prepared which determined that all signalized intersections within the study area are projected to operate at an acceptable overall levels of service (LOS) under Future (2028) With Project conditions. Movements expected to operate at LOS E or worse are not considered significant. Therefore, no improvements are recommended for Future (2028) With Project conditions. In addition, no changes to the intersection configuration at Route 11 and Route 139/Shipman Park driveway are required to accommodate the proposed health center-generated trips. 32 | P a g e The Applicant understands that should they or the landowner wish to dedicate this access driveway to the County as some point in the future, the access driveway must be improved to County-dedicable standards. 4. Unusual conditions, trends, and needs have arisen since the district boundaries and regulations were established An access driveway provides vehicular access, whether for agricultural or other purposes. However, since the proposed two-lane access driveway is situated on Agricultural-designated lands and will be providing access to a proposed health center situated on adjoining Urban-designated lands, its construction and use is not permitted within the Agricultural District and requires the issuance of a Special Permit. Nevertheless, providing a means of access to the 20.018-acre Project Site will also provide easier access to the other existing landholdings of W.H. Shipman, Limited, much of which remain in agricultural uses. Improving access to the Project Site and surrounding area will always improve circumstances, whether it be for agricultural activities or future opportunities that align with broader land use policies for this particular area of Keaʻau. 5. The land upon which the proposed use is sought is unsuited for the uses permitted within the district The proposed access driveway and its immediately surrounding area have historically been utilized for the cultivation of various agricultural commodities, namely sugar cane, papaya and other truck crops. More recently, much of the Project Site has remained fallowed and is now overgrown with invasive and non- native plant species. Soils with the Project Site are classified as “D” or “Poor” for agricultural productivity. 6. The proposed use will not substantially alter or change the essential character of the land and the present use The request is limited to the proposed construction of a two-lane access driveway across Agricultural lands. Whether that access driveway serves the proposed health center or the extensive agricultural landholdings of W.H. Shipman, Limited, the essential character of this particular area of Keaʻau will not be adversely affected by the mere construction of a driveway. The General Plan, Puna CDP and Keaʻau Village Master Plan all envision the expansion of the urban core to include the affected area along the western (mauka) side of State Route 11 between Shipman Business Park to the north and the Herbert Shipman Park to the south. This request for a Special Permit to build the access driveway is almost perfunctory in nature, given the land use policy direction established for this area of Keaʻau. 33 | P a g e 7. The request will not be contrary to the General Plan and official Community Development Plan and other documents such as Design Plans This was discussed extensively in section F(1) above. In summary, approval of a Special Permit to construct a two-lane access driveway and electrical and telecommunication facilities in support of a proposed health center on an adjoining property will provide the necessary support to realize the expansion of services and facilities within the Keaʻau Regional Town Center envisioned as far back as 1994 with the reclassification of certain lands by the State Land Use Commission into the Urban District in alignment with similar policy directions expressed in both the General Plan and the Puna CDP. H. GROUNDS FOR APPROVAL OF A SPECIAL PERMIT (Planning Department Rule Section 6-7) The Planning Commission shall not approve a Special Permit unless it is found that the proposed use: 1. Is an unusual and reasonable use of land situated within the Agricultural or Rural District, whichever the case may be. In recognizing that lands within Agricultural districts might not be best suited for agricultural activities and yet classified as such, and in recognition that certain types of uses might not be strictly agricultural in nature, yet reasonable in such districts, the Legislature has provided for the Special Permit process to allow certain unusual and reasonable uses within the Agricultural district. This request is quite simple: to allow for the construction of a two-lane driveway and installation of electrical and telecommunication utilities on approximately 2.648 acres of Agricultural-designated lands in support of a much-needed health center. The Applicant believes that such a request is considered an unusual and reasonable use of land within the State Land Use Agricultural District. 2. Would promote the effectiveness and objectives of Chapter 205, Hawaii Revised Statutes, as amended. The State Land Use Law and Regulations are intended to preserve, protect and encourage the development of lands for those uses to which they are best suited in the interest of the public welfare of the people of the State of Hawaiʻi. In the case of the Agricultural District, the intent is to preserve or keep lands of high agricultural potential in agricultural use. The request is very limited in scope, a two-lane driveway and supporting electrical and telecommunication utilities upon 2.648 acres of agricultural land that is situated within an area designated for future urban development. While the affected land area was historically cultivated in sugar cane and more recently in crops like papaya, soils within the affected area is not considered prime agricultural land. 34 | P a g e Nevertheless, the proposed access driveway may also benefit potential agricultural leasees on the remaining agricultural landholdings of W.H. Shipman, Limited. Therefore, the issuance of a Special Permit to allow the construction of a two- lane driveway and public utilities in support of a proposed health clinic will not displace any existing agricultural activity or diminish the agricultural potential of the Project Site or the immediately surrounding area, especially when considering the extent of existing agricultural lands managed by W.H. Shipman, Limited. Therefore, the proposed use will not adversely affect the preservation and agricultural use of the County's prime agricultural lands, and is not contrary to the objectives sought to be accomplished by the State Land Use Law and Regulations. I. COASTAL ZONE MANAGEMENT The requested Use and Special Permits, if approved, will not be contrary to Chapter 205A, Hawaiʻi Revised Statues, relating to Coastal Zone Management. The Project Site is not situated within the Special Management Area, being located about 4 miles from the nearest shoreline and is not subject to any coastal hazard nor anticipate to have any adverse impact upon coastal resources such as coastal recreational and marine resources, coastal ecosystems or the public use and recreational use of any beach. There is no record of a designated public access that traverses the Project Site. The Project Site has been extensively altered by past sugar cane cultivation activities, and more recent truck farming operations. Given the that the Project Site is absent of any archaeological features due to its historic use for agricultural activities and that its current fallow condition has allowed for a myriad of non-native species of plants to inhabit the Project Site, it can be reasonably concluded that native Hawaiian cultural practices are not being exercised within the Project Site due to the absence of culturally- related resources. There are no caves, springs, puʻu, native forest groves or other natural features. Combined with the highly disturbed vegetation that is dominated by invasive, weedy species and secondary growth in most areas, the Project Site does not contain the quality of resources that would be important for native gathering. The FEA concludes that based on the CIA prepared by PBR HAWAII, the AIS conducted by Scientific Consultant Services, and the Archaeological Assessment conducted by Rechtman Consulting, LLC for the broader Shipman property, and consistent with the Hawaiʻi State Supreme Court’s PASH and Ka Paʻakai O Ka ʻAina decisions, no significant adverse impacts to cultural resources, traditional practices, or gathering rights are anticipated from the development of the proposed health center. Archeological studies conducted throughout the Keaʻau area since the 1990s have not found evidence of pre-Contact habitation or traditional resource use within the sugarcane cultivation areas that included the Project Site and surrounding area; rather, they have identified only sites related to plantation-era railroad, commercial sugar, and residential uses during the Historic or Modern eras. No cultural informants or community consultees identified cultural resources or practices that would be adversely 35 | P a g e impacted by the proposed development. These conclusions will not change appreciably under any alternative. As a mitigating action, the FEA notes that construction documents for the proposed health center will include a provision that should any undocumented archaeological or cultural resources — including artifacts, shells, bones, midden deposits, charcoal deposits, lava tubes, stone platforms, pavings, or rock walls — be encountered during grading or construction, all work in the immediate vicinity of the find will cease and the State Historic Preservation Division (SHPD) will be contacted to determine the significance of the find and to approve an acceptable mitigation plan as needed. If human burials are encountered, they will be treated in accordance with the specific provisions of Chapter 6E, HRS. Therefore, it is not anticipated that the requests will have any adverse impact on cultural or historical resources in the area. Therefore, this combined requests are supportive of the County’s efforts towards properly managing development. Finally, in terms of the public participation objective, this is generally a public agency function. This has been and will be achieved through community and stakeholder outreach meetings conducted by the Applicant; the early consultation and review process associated with the FEA/FONSI and the public hearing process required pursuant to the Planning Commission’s Rules regarding these applications. Notices of these applications will become available through the posting of a sign on the property, as well as sending two (2) notices to surrounding property owners, one at the time the application is filed and again, prior to the public hearing. In view of the Hawaiʻi State Supreme Court's "PASH" and "Ka Paʻakai O Ka ʻAina" decisions, the issue relative to native Hawaiian gathering and fishing rights must be addressed in terms of the cultural, historical, and natural resources and the associated traditional and customary practices of the site. As the Project Site is located about 4 miles from the shoreline and has been significantly altered by past agricultural activities, the FEA found that no valued cultural, historic, or natural resources related to traditional and customary practices were identified within the project site, and no traditional and customary native Hawaiian rights are exercised therein. Archaeological and biological surveys conducted by the Applicant and included within the FEA could not identify any such valued resources within the Project Site. For these reasons, the Applicant could find no evidence of any possible significant adverse effects or impairments that will occur to any valued resources should this Special Permit request be approved. Should the Applicant inadvertently encounter any remains of historic sites, such as rock walls, terraces, platforms, marine shell concentrations or human burials, the Applicant agrees to cease work in the immediate area and contact the Department of Land and Natural Resources-State Historic Preservation Division (DLNR- HPD), resuming activities only upon securing archaeological clearance from DLNR-HPD when it finds that sufficient mitigation measures have been taken. 36 | P a g e J. CONCLUSION Based on the discussion above, the Applicant finds that the issuance of a Use Permit to allow for the establishment of a health center on 20.018 acres of land along with an access driveway and supporting electrical and telecommunication facilities on 0.618-acre of land within the State Land Use Urban District and a Special Permit to allow for the construction and use of an access driveway in support of the health center operations on approximately 2.648 acres of land acres situated within the State Land Use Agricultural District would support the objectives sought to be accomplished by the State Land Use Law and Regulations and consistent with Coastal Management Area guidelines as listed under HRS 205A. 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 May 1, 2026 Mary Alice Evans, Director Office of Planning and Sustainable Development Environmental Review Program 235 S. Beretania Street, Suite 702 Honolulu, HI 96813 Dear Ms. Evans: Subject: Environmental Assessment (EA) Finding of No Significant Impact (FONSI) (PL-ENV- 2025-000051) Project: Hilo Benioff Medical Center Keaʻau Outpatient Center; TMK: (3) 1-6-003:127 and 1-6-003:007 (por.), Keaʻau, Puna, Hawai`i The EA (EA) assesses the potential effects of constructing and operating the proposed project. Hawai`i Health Corporation, East Hawaii Region as the proposing and approving agency, anticipates that the proposed action is not likely to have a significant effect and therefore is issuing a notice of an Finding of No Significant Impact, subject to the public review provisions of HAR Section 11-200.1-20. Please publish a notice of the EA and FONSI in the next edition of The Environmental Notice. Please contact me at (808) 932-3802 if you have any questions. We are also providing a pdf copy of the EA, the action summary, significance criteria, and other required information via the Environmental Notice online submittal platform. Please contact our project consultant, John Pipanof Pipan Consulting, at (808) 430-1441, if you have any questions concerning the submittal. Sincerely, Kris Wilson Assistant Hospital Administrator East Hawaii Region Enclosures as noted above cc: Dan Brinkman, East Hawaii Region CEO John Pipan, President Pipan Consulting LLC EXHIBIT A From: dbedt.opsd.erp@hawaii.gov To: DBEDT OPSD Environmental Review Program Subject: New online submission for The Environmental Notice Date: Friday, May 1, 2026 3:55:45 PM Action Name Hilo Benioff Medical Center Construction of Medical Offices in Kea'au (FONSI) Type of Document/Determination Final environmental assessment and finding of no significant impact (FEA-FONSI) HRS §343-5(a) Trigger(s) (1) Propose the use of state or county lands or the use of state or county funds Judicial district Puna, Hawaiʻi Tax Map Key(s) (TMK(s)) (3)1-6-003:127, (3)1-6-003-007 Action type Agency Other required permits and approvals Use Permit, Special Permit, Plan Approval, Building Permits, Grubbing & Grading, Permit to Perform Work Upon State Highways, Permit for the Occupancy and Use of State Highways, National Pollutant Discharge Elimination System (NPDES) Permit, Storm Water Pollution Prevention Plan (SWPPP), Department of Health Individual Wastewater Treatment Works (WWTW), Department of Health Construction-Environmental Hazard Management Plan (C-EHMP), Potential Noise Permit Proposing/determining agency Hawaii Health Systems Corporation (HHSC) Agency jurisdiction State of Hawaiʻi Agency contact name Kris Wilson Agency contact email (for info about the action) Email address for receiving comments john@landplanninghawaii.com Agency contact phone (808) 932-3802 Agency address Hilo, HI 96727 United States Map It Is there a consultant for this action? Yes Consultant Land Planning Hawaii Consultant contact name John Pipan Consultant contact email john@landplanninghawaii.com Consultant contact phone (808) 333-3391 Consultant address 194 Wiwoole Street Hilo, HI 96720 United States Map It Action summary HMC is proposing to construct a new medical facility in Kea‘au known as the Keaʻau Outpatient Center (KOC). The subject property is located to the west of Volcano Road, including the intersections with Kea‘au Bypass Road and Hawaiʻi Belt Road. The property is 108.8 acres and owned by W.H. Shipman Ltd. The project site is proposed to be constructed on a 20-acre portion of the parcel zoned Agricultural 20-acres (A-20a) which will be subdivided from the larger parcel. The clinic will be sited on 13-acres of this 20-acre area. The current extent of the proposed project includes the 20-acre area and the proposed access driveway. The new access driveway would be built within a new 4.4-acre roadway lot to be subdivided from parcel 007. Plans include construction of a single-story medical office building complex consisting of a clinical wing and a behavioral health wing, totaling approximately 40,000 square feet. Sufficient paved parking stalls and loading zones are proposed meeting zoning code requirements. The total disturbance area for the project is proposed to be approximately 13 acres, along with 4.4 acres for the construction of the access driveway. Selected clearing and grubbing are proposed to maintain a buffer around the facility and optimize the appearance of the site. Reasons supporting determination Please refer to Section 5.2 of the Environmental Assessment. Attached documents (signed agency letter & EA/EIS) HMC_Keaau_Medical_Clinic_FEA_ADA_CHECKSv4.pdf FONSI_Keaau-Benioff.pdf Shapefile The location map for this Final EA is the same as the location map for the associated Draft EA. Action location map HBMC_Action_Location.zip Compliance certification (HRS §368-1.5): The authorized individual listed below certifies that documents submitted are unlocked, searchable, and compliant with the Hawaii Electronic Information Technology Disability Access Standards (including, but not limited to transcripts, captions, and other descriptions accompanying audio/video files). The individual acknowledges that the submitter retains the responsibility for compliance after documents have been published and any compliance queries will be directed back to the agency and/or applicant. Authorized individual John Pipan Authorized individual email john@landplanninghawaii.com Authorized individual phone (808) 333-3391 Authorization The above named authorized individual hereby certifies that he/she has the authority to make this submission. HILO BENIOFF MEDICAL CENTER KEA‘AU OUTPATIENT CENTER BENIOFF MEDICAL CENTER DRAFT FINAL ENVIRONMENTAL ASSESSMENT ENVIRONMENTAL ASSESSMENT FOR HILO BENIOFF MEDICAL CENTER (HBMC) CONSTRUCTION OF MEDICAL OFFICES KEA‘AU, PUNA, ISLAND OF HAWAI‘I TMK (3) 1-6-003: 127 TMK (3) 1-6-003: 007 (por.) December 2025 April 2026 Prepared by Land Planning Hawai‘i LLC 194 Wiwo‘ole Street Hilo, Hawai‘i 96720 This document is prepared pursuant to: The Hawai‘i Environmental Policy Act, Chapter 343, Hawai‘i Revised Statutes (HRS), and Title 11, Chapter 200.1, Hawai‘i Department of Health Administrative Rules (HAR) Page left blank intentionally 2 TABLE OF CONTENTS ALL PAGE NUMBERS UPDATED FOR FEA SUMMARY OF PROJECT, ENVIRONMENTAL IMPACTS, AND MITIGATION MEASURES . 7 PART 1: PROJECT DESCRIPTION AND ENVIRONMENTAL ASSESSMENT PROCESS ....... 10 1.1 Purpose and Need .................................................................................................................... 10 1.2 Project Description and Location .......................................................................................... 11 1.3 Cost and Schedule.................................................................................................................... 11 1.4 Environmental Assessment Process ....................................................................................... 12 1.5 Public Involvement and Agency Coordination ..................................................................... 12 PART 2: ALTERNATIVES..................................................................................................................... 16 2.1 Alternate Location.......................................................................................................................... 16 2.2 Alternate Site Layout, Phasing, Access & Building Design ........................................................ 17 2.3 No Action ......................................................................................................................................... 17 PART 3: ENVIRONMENTAL SETTING, IMPACTS, AND MITIGATION.................................... 17 3.1 Physical Environment .................................................................................................................... 17 3.1.1 Geology, Geologic Hazards, and Soils ................................................................................... 18 3.1.2 Flood Zones.............................................................................................................................. 22 3.1.3 Climate and Climate Change ................................................................................................. 24 3.1.4 Water Quality .......................................................................................................................... 28 3.1.5 Flora and Fauna ...................................................................................................................... 30 3.1.6 Air Quality ............................................................................................................................... 36 3.1.7 Noise ......................................................................................................................................... 37 3.1.8 Scenic Resources...................................................................................................................... 38 3.1.9 Hazardous Substances, Toxic Waste, and Hazardous Conditions...................................... 38 3.1.10 Solid Waste............................................................................................................................. 42 3.2 Socioeconomic and Cultural .......................................................................................................... 44 3.2.1 Land Use .............................................................................................................................. 44 3.2.2 Socioeconomic Characteristics........................................................................................... 45 3.2.3 Parks and Recreation.......................................................................................................... 47 3.2.4 Cultural and Historic Resources ................................................................................... 48 3.3 Public Roads, Services, and Utilities ............................................................................................. 55 3.3.1 Roads and Access .................................................................................................................... 55 3.3.2 Public Utilities and Services ................................................................................................... 67 3.4 Secondary and Cumulative Impacts ............................................................................................. 71 PART 4: CONSISTENCY WITH GOVERNMENT PLANS AND POLICIES ................................. 72 4.1 Hawai‘i County General Plan........................................................................................................ 72 4.1.1 2005 Hawai‘i County General Plan ....................................................................................... 72 4.2 Puna Community Development Plan............................................................................................ 77 4.3 County Zoning and Special Management Area........................................................................... 79 4.4 Hawai‘i State Land Use Law ......................................................................................................... 80 4.5 Required Permits and Approvals.................................................................................................. 80 3 PART 5: DETERMINATION, FINDINGS, AND REASONS ............................................................. 81 5.1 Determination ................................................................................................................................. 81 5.2 Findings and Supporting Reasons................................................................................................. 81 REFERENCES.......................................................................................................................................... 85 FIGURES 1. Location Map…………………………………………………………………...…………8 2. Conceptual Site Plan..………………………………………………………………....…..9 3. 2021 USGS Model of Earthquake Probability for the Hawaiian Islands…………..……19 4. Soil Map………………………………………………………………………..……...…21 5. Flood Hazard Map………………………………………………………..……………...23 6. Hawaii State Wildfires Between 1999 and 2022……………………………….………..27 7. Employment Industries in Kea‘au-Mountain View CCD…………………………….….46 8. Employment Industries in Pāhoa-Kalapana CCD…………………………………….….46 9. Historic Aerial Imagery………………………………………………………….………52 10. 2019 Aerial Imagery……………………………………………………………………..53 11. Map of Study Intersections and 24-Hour Traffic Count Locations…………….………..57 12. Future (2028) Without Project Intersection Peak Hour Volumes……………….……….62 13. Future (2028) With Project Intersection Peak Hour Volumes...…………………………65 TABLES 1. October Stakeholder Meeting Attendance…………………………………………….…14 2. Flora Species Observed on Property ………………………………………………….…30 3. Soil Screening Survey Conceptual Site Model…………………………………………..40 4. Existing (2025) LOS .……………………………………………………………......…..59 5. Future (2028) Without Project LOS …………………………………………………….63 6. Future (2028) With Project LOS …………………………………………………..….…66 APPENDICES Appendix A: Traffic Impact Analysis Report Appendix B: Comments in Response to Early Consultation Appendix C: Soil Screen Report Appendix D: Water Demand Calculations Appendix E: Comments in Response to Publication of Draft Environmental Assessment Appendix F: Archaeological Assessment and SHPD Acceptance Letter Appendix G: Status report on compliance with the conditions of State Land Use Boundary Amendment 884 Note: Page numbers have been updated in the Table of Contents, tables and Figures Lists for the Final EA 4 ABBREVIATIONS HMC Hilo Medical Center HBMC Hilo Benioff Medical Center KOC Kea‘au Outpatient Center DWS Department of Water Supply BMPs Best Management Practices TIAR Traffic Impact Analysis Report HDOT Hawai‘i Department of Transportation SHPD State Historic Preservation Division GP Hawai‘i County General Plan PCDP Puna Community Development Plan EA Environmental Assessment DEA Draft Environmental Assessment FEA Final Environmental Assessment HEPA Hawai‘i Environmental Policy Act HRS Hawai‘i Revised Statutes HAR Hawai‘i Administrative Rules FONSI Finding of No Significant Impact EIS Environmental Impact Statement DOH Department of Health USGS United States Geological Survey USDA United States Department of Agriculture FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map SMA Special Management Area HWMO Hawai‘i Wildfire Management Organization UIC Underground Injection Control DOFAW Division of Forestry and Wildlife DLNR Department of Land and Natural Resources ROD Rapid ‘Ōhi‘a Death CAA Clean Air Act PPE Personal Protective Equipment WWTW Wastewater Treatment Works LUPAG Land Use Pattern Allocation Guide CDP Community Development Plan NPDES National Pollutant Discharge Elimination System SWPPP Storm Water Pollution Prevention Plan SWMP Solid Waste Management Plan 5 ABBREVIATIONS HMC Hilo Medical Center HBMC Hilo Benioff Medical Center KOC Kea‘au Outpatient Center DWS Department of Water Supply BMPs Best Management Practices TIAR Traffic Impact Analysis Report HDOT Hawai‘i Department of Transportation SHPD State Historic Preservation Division GP Hawai‘i County General Plan PCDP Puna Community Development Plan EA Environmental Assessment DEA Draft Environmental Assessment FEA Final Environmental Assessment HEPA Hawai‘i Environmental Policy Act HRS Hawai‘i Revised Statutes HAR Hawai‘i Administrative Rules FONSI Finding of No Significant Impact EIS Environmental Impact Statement DOH Department of Health USGS United States Geological Survey USDA United States Department of Agriculture FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map SMA Special Management Area HWMO Hawai‘i Wildfire Management Organization UIC Underground Injection Control DOFAW Division of Forestry and Wildlife DLNR Department of Land and Natural Resources ROD Rapid ‘Ōhi‘a Death CAA Clean Air Act PPE Personal Protective Equipment WWTW Wastewater Treatment Works LUPAG Land Use Pattern Allocation Guide CDP Community Development Plan NPDES National Pollutant Discharge Elimination System SWPPP Storm Water Pollution Prevention Plan SWMP Solid Waste Management Plan 5 SUMMARY OF PROJECT, ENVIRONMENTAL IMPACTS, AND MITIGATION MEASURES Hilo Medical Center (HMC), recently renamed Hilo Benioff Medical Center (HBMC) has served as the largest hospital and primary healthcare provider on the Island of Hawai‘i since 1897. They have also played a vital role in expanding healthcare access to rural areas of the island by establishing primary and specialty care clinics throughout Puna. The Puna District faces many healthcare challenges including increasing demand, overcrowding, and accessibility issues. Therefore, HMC is proposing to construct a new medical facility in Kea‘au known as the Keaʻau Outpatient Center (KOC) Kea‘au Benioff Medical Center to help address these issues. The subject property is located to the west of Volcano Road, including the intersections with Kea‘au Bypass Road and Hawaiʻi Belt Road (Figure 1). The property is 108.8 acres and owned by W.H. Shipman Ltd. The project site is proposed to be constructed on a 20-acre portion of the parcel zoned Agricultural 20-acres (A-20a) which will be subdivided from the larger parcel. The clinic will be sited on 13-acres of this 20-acre area. The current extent of the proposed project includes the 20-acre area and the proposed access driveway. The new access driveway would be built within a new 4.4-acre roadway lot to be subdivided from parcel 007. Plans include construction of a single-story medical office building complex consisting of a clinical wing and a behavioral health wing, totaling approximately 40,000 square feet. Sufficient paved parking stalls and loading zones are proposed meeting zoning code requirements. The total disturbance area for the project is proposed to be approximately 13 acres, along with 4.4 acres for the construction of the access driveway (Figure 2). Selected clearing and grubbing are proposed to maintain a buffer around the facility and optimize the appearance of the site. On-site infrastructure is expected in the form of driveways, parking, electrical, water supply, storm water management, and wastewater disposal facilities. Electricity will be available to the site via HELCO. The Department of Water Supply (DWS) has confirmed that the clinic will be connected to county water supply. Consultation with DWS indicates that adequate water is available for the proposed use and for fire suppression. Water calculations will be developed in consultation with DWS to determine appropriate water supply lateral size for the proposed development. New water mains will be extended to the site. There is no County sewer line in the area. Wastewater will be handled through a wastewater treatment facility that provides secondary treatment required by the Department of Health rules. Minor and short-term construction phase impacts to noise, air and water quality will be mitigated by Best Management Practices (BMPs) associated with Department of Health regulations, Grubbing and Grading Permits, a National Pollutant Discharge Elimination System (NPDES) permit and Storm Water Pollution Prevention Plan (SWPPP). Access to the clinic is proposed via a new access driveway from the highway. The approximately 0.5-mile access driveway will be constructed through the adjacent Shipman property identified as TMK (3) 1-6-003: 007 and connect to the highway across from the intersection with Kea‘au-Pāhoa Road. The 4.4-acre roadway area will be subdivided from the property. 7 Figure 1: Location Map ... -'Rl. ~. ~fl;/:.J !:"/~:V~J A Traffic Impact Analysis Report (TIAR) was completed in September 2025. The TIAR is summarized in Section 3.3.1 and the full report can be found in Appendix A. All traffic and access improvements will be completed in consultation with HDOT. No threatened or endangered flora or fauna species are expected to be present within the project site. Vegetation primarily consists of introduced and invasive species such as gunpowder tree (Trema orientale), albizia (Falcataria Moluccana), Honohono grass (Commelina diffusa), Guinea grass (Megathyrsus maximus), and others. The subject site has been previously cleared and used for agricultural purposes, primarily for sugarcane and papaya production. In the unlikely event that undocumented archaeological resources, including shells, bones, midden deposits, lava tubes, or similar finds, are encountered during construction, work in the immediate area of the discovery will be halted, and the State Historic Preservation Division (SHPD) will be contacted to determine the appropriate actions. The proposed action does not conflict with the Hawai‘i County General Plan (GP) or the Puna Community Development Plan (PCDP). A Use Permit will be submitted to the Hawai‘i County Planning Department in line with § 25-2-61 (9) and § 25-5-72 (d) (7) in conjunction with this EA to justify unusual and reasonable use according to State Land Use Regulations. In addition, a Special Permit will be submitted to the Hawai‘i County Planning Department to allow the construction of the access road. As the Special Permit petition area does not exceed 15 acres in land area, the authority to grant the request remains with the County Planning Commission. Establishment of the proposed use will not be contrary to the objectives sought to be accomplished by State Land Use Laws and Regulations. PART 1: PROJECT DESCRIPTION AND ENVIRONMENTAL ASSESSMENT PROCESS 1.1 Purpose and Need Hilo Benioff Medical Center is tasked with serving not only the residents of Hilo but also those from surrounding areas including Puna, Volcano, and the Hāmākua Coast. Puna is the fastest growing region in the state. According to census data, it has seen a population increase from about 31,000 people in 2000 to nearly 52,000 people in 2020 and is expected to top 75,000 residents within the next 6 years. Its rapid population growth has created increased pressure on the existing healthcare services, which are currently insufficient to serve the growing population, especially with regard to urgent health care and specialty services. The entire Puna District currently contains two East Hawaiʻi Health Urgent Care clinics – the East Hawaiʻi Health Clinic in Keaʻau and the East Hawaiʻi Health Clinic in Pāhoa, along with Keaʻau Urgent Care. Urgent care services are only provided by these clinics between 7:00 a.m. and 7:00 p.m., 7:00 a.m. and 5:00 p.m., and 9:00 a.m. and 7:00 p.m. respectively. Additionally, access to specialty care, EKG and imaging services are also very limited in Puna and currently only offered at the Keaʻau East Hawaiʻi Health Clinic. Insufficient access to health services in Puna requires many Puna residents to seek care in Hilo. As a result, Hilo Medical Center has strained to accommodate the influx of patients, resulting in long wait times and overcrowding. Development of the new Hilo Medical 10 Center facilities i n Ke aʻau wi ll help t o fill in e xisting ga ps i n a vailability of urgent care, spe cialty care and i maging se rvices for Puna residents. The Hawai‘i County Ge neral Plan discusses t he importance of so cial services i ncluding: Social services include not only programs t o prov ide assistance to special needs popul ations, but also he alth and me dical facilities to serve the entire community. “M edical facilities”, i n this instance, doe s not apply to C ounty emergency paramedical services (…). With a grow ing population, P una c learly needs more social and he alth care services within t he district. Ye t, there are two ma jor c hallenges t o mak ing t hem a ccessible to re sidents:  As a rural area w ith a ru dimentary transportation system and di spersed population, i t is difficult for re sidents i n n eed to re ach t he services; and  Puna’s hi gh pe rcentage of low-income residents t ends t o i ncrease the need for soc ial services, y et discourages private health c are providers from l ocating i n P una due to insurance issues. 1.2 Project Description and Location The subject property i s l ocated t o t he west of Highway 11, a cross fro m the intersection wi th Kea‘au-Pāhoa Road. Plans i nclude construction of a single-story medical office building c omplex c onsisting of a clinical wing a nd a behavioral health wi ng t otaling a pproximately 40,000 sq uare feet. Su fficient paved parking st alls a nd l oading z ones are proposed m eeting z oning c ode requirements. T he parking l ot will include 22 Am ericans wi th Disabilities (AD A) c ompliant perpendicular pa rking stalls a nd 182 st andard p erpendicular pa rking st alls. T he total disturbance area for t he project is proposed t o be approximately 17.4 a cres. The proposed f acilities w ill provide urgent care services se ven (7) days pe r week, i ncluding holidays, from 8:00 a .m. t o 8: 00 p.m . Pri mary c are services, spe cialty clinic services ( e.g. cardiology), i maging se rvices (e.g. X -rays, C T scans, u ltrasounds), l aboratory se rvices, and behavioral health and counseling se rvices will be available Monday – Fr iday fr om 8:00 a .m. – 4:00 p.m. T he facilities wi ll serve the general public but will be primarily fo cused on r esidents of Puna and Sout h Hi lo. It is anticipated t hat the facility wi ll serve over 100 p atients pe r day. The facility wi ll provide outpatient care only and will not be an e mergency room or pro vide drug rehabilitation se rvices. T he clinic will not receive ambulances, a lthough a mbulance transportation of patients from the facility to t he Hilo Benioff Medical Center may oc cur wh en warranted. 1.3 Cost and Sc hedule Total project costs a re roughly $90 m illion a nd c ompletion i s e stimated by the end of 2028 late 2028 or e arly 2029 . 11 1.4 Environmental Assessment Process In 1974 the Hawai‘i State Legislature enacted the Hawai‘i Environmental Policy Act (HEPA), which requires State and County agencies to conduct an environmental impact analysis prior to making decisions on actions that may impact the environment. This Environmental Assessment (EA) is being conducted in accordance with Chapter 343 of the Hawai‘i Revised Statutes (HRS), along with the implementing regulations, Title 11, Chapter 200.1, of the Hawai‘i Administrative Rules (HAR). This law is the basis for the environmental impact assessment process in the State of Hawai‘i. An EA is necessary for the proposed project since the project involves the use of State of Hawai‘i funds or land. Improvements within the State Right-Of-Way are anticipated for the proposed access to the project. Additionally, the project will utilize public funding sources for its completion. Since discretionary approval is required for the project in the form of a Use Permit and Special Permit, HRS 343-5.5 requires the EA to be completed. According to Chapter 343, an EA is prepared to determine impacts associated with a proposed action, develop mitigation measures for any discovered adverse impacts, and determine whether the impacts are significant (according to the thirteen specific criteria). If a study concludes that no significant impacts would occur from implementation of the proposed action, a Finding of No Significant Impact (FONSI) is prepared. If a study finds that significant impacts are expected to occur because of a proposed action, then an Environmental Impact Statement (EIS) is prepared to allow deeper investigation of impacts and allow more extensive public involvement. The following EA discusses alternatives to the proposed action, existing environment and impacts associated with the proposed action, the anticipated determination and the findings made by HBMC in consultation with the County of Hawai‘i Planning Department and the expert consultants who prepared supporting studies for this EA. 1.5 Public Involvement and Agency Coordination Agency coordination and public involvement are crucial components of the environmental assessment process to understand the impacts caused by the proposed action. The agencies, organizations, and individuals below have been consulted as part of the environmental assessment process and have also been provided a link with the full text of the DEA for review and comment. Copies of correspondence during the early consultation and draft review period can be found in Appendix B and Appendix E. State of Hawai‘i -Department of Land and Natural Resources, Land Division -Department of Land and Natural Resources, Division of Aquatic Resources -Department of Land and Natural Resources, Division of Forestry and Wildlife -Department of Land and Natural Resources, Office of Conservation & Coastal Lands -Department of Land and Natural Resources, Engineering -Department of Land and Natural Resources, Historic Preservation 12 -Hawai‘i Department of Transportation -Office of Hawaiian Affairs -State Department of Health -State Office of Planning and Sustainable Development -Department of Education o DOE Schools in the area: Keaʻau Elementary, Middle, and High schools County of Hawai‘i: -Planning Department -Fire Department -Police Department -Department of Environmental Management -Department of Public Works -Department of Water Supply -Civil Defense Private -Surrounding Property Owners within 300 feet of the Property outline -Stakeholder Meeting August 25th -Community Stakeholder Meetings October 9th and 15th -Community Informational Meeting Scheduled for December 16th, 2025 -W.H. Shipman Ltd. A comment letter was received from the Office of Hawaiian Affairs after their review of the Draft EA and is included in Appendix E. Per their comments, additional consult letters were mailed to the following organizations in an attempt to gain additional consult from the community and cultural practitioners: -Association of Hawaiian Civic Clubs -Cultural Resources Division of the Bernice Pauahi Bishop Museum -The Department of Hawaiian Home Lands -Hui Mālama I Nā Kupuna O Hawaiʻi Nei -Ka Haka ʻUla O Keʻelikōlani — College of Hawaiian Language, UH Hilo The above agencies were given a 30-day period to respond to the comment letters. To date, no responses have been received. Community Engagement A list of community stakeholders was compiled for the purpose of conducting meetings to garner feedback from these community stakeholders on the impact of the project on the community. These meetings were subsequently held on October 9th and 15th. A variety of stakeholders attended the meetings, including representatives from the Puna Community Development Action 13 Plan Committee (PCDAC) and the Hawaii DOE and area schools. Community Stakeholder meeting attendees are listed below: Table 1: October Stakeholder Meeting Attendance Attendee Organization/Affiliation Matthew Kanealii-Kleinfelder County Council C. Kimo Alameda, Mayor County of Hawai'i Adria Medeiros Hawai'i DOE, Mountain View Elementary School Dennis Onishi Hawai'i County Council Vice Chair 'Iwalani Harris Hawai'i DOE Ka'ū-Kea'au-Pāhoa Complex Area Elaine Higa Hawai'i DOE Ka'ū-Kea'au-Pāhoa Complex Area Kazuo Todd Hawai'i Fire Department Joy San Buenaventura Hawai'i State Senate Jim Staub HFS Federal Credit Union Shawn Slater Hawai'i DOE Ka'ū-Kea'au-Pāhoa Complex Area Brenda Dunne Hilo/ Kea'au Urgent Care Jeanne Kapela House of Representatives Darryl Oliveira HPM Building Supply Kanoe Wilson Kamehameha Schools & PCDAC Kehaulani Aipia-Peters Ke Kula O Nawahiokalaniopuu Mitchell Gacula Kea'au Filipino Food Store Dean Cevallos Hawai'i DOE, Kea'au High School Kasey Eisenhour Keonepoko Elementary School Bob Hamilton Plant it Hawai'i Greg Henkel PCDAC M. Leilani DeMello PCDAC Stephanie Bath PCDAC Richard Solie Puna Hongwanji Buddhist Temple Jennifer Kurohara Puna Hongwanji Buddhist Temple A Community Informational Meeting was held on December 16th, 2025, at Keaʻau High School to further engage with community stakeholders and the general public. Community comments and HBMC responses are summarized below: 1. Physician Staffing and Continuity of Care Community members expressed concern about the high turnover of cardiology providers and questioned how the proposed clinic would be staffed sustainably. There was a strong desire for long-term physician relationships and stability. Facility representatives acknowledged the concern and explained that physician turnover is now common nationwide, particularly in specialty care. The facility’s approach emphasizes maintaining a small number of community-anchored physicians, supported by rotating providers, with an ongoing focus on recruitment and continuity to ensure access to care. 2. Trust and Past Experience with Staffing Some attendees shared that their personal experiences have made them skeptical about promises of staffing stability, particularly in specialty services. Facility leadership acknowledged this 14 perspective and noted that success varies by specialty. Primary care was cited as an area of relative stability, while cardiology was recognized as an ongoing challenge that leadership is actively working to stabilize. 3. Community Character and Sense of Place Participants reflected on changes in Keaʻau over time and the loss of historic structures and local character. Questions about building design and infrastructure reflected a broader concern about preserving community identity while accommodating growth. Facility representatives confirmed that the project includes standard safety and building requirements while acknowledging the community’s connection to place. 4. Land Use, Environmental Review, and Cultural Sensitivity Questions were raised regarding the agricultural history of the site and whether environmental, archaeological, or cultural issues could delay the project. The facility explained that a formal Environmental Assessment (EA) is underway, including soil testing and industry-standard due diligence. Because the land has been in long-term agricultural use, the likelihood of undiscovered cultural or archaeological resources is considered low, though mitigation processes are in place should anything be identified. Community members were informed that the environmental assessment will be publicly available, with opportunities for public comment. 5. Communication and Transparency Attendees appreciated the option to receive updates and requested notification when environmental documents become available. Facility staff committed to ongoing communication and maintaining sign-in lists to support future updates and transparency. 6. Traffic and Transportation Impacts Traffic congestion in Puna was a significant concern. Community members asked whether the project could contribute to solutions, such as partnerships on road improvements. Facility representatives emphasized that the project is designed to avoid adding traffic burden, and noted that broader road planning falls under state and county jurisdiction. Leadership expressed a commitment to ensuring the project does not worsen existing traffic conditions. 15 7. Obstetrics, Birthing Care, and Maternal Health There was strong community interest in obstetrics, birthing support, and emergency services, particularly for lower Puna. While a full birthing facility was described as outside the scope of the outpatient clinic due to regulatory and resource requirements, leadership acknowledged opportunities to improve prenatal care, maternal support, and partnerships, including services aligned with more natural or home-birth preferences. Declining birth volumes were also noted as a factor in service planning. 8. Community Safety and Access to Care Participants highlighted concerns that limited access to prenatal and maternal care may lead families to pursue unsafe alternatives. There was shared recognition that local prenatal services and supportive care options could help bridge gaps and improve safety, even if full inpatient services remain centralized elsewhere. 9. Ongoing Engagement Community members asked whether additional meetings would be held beyond those already scheduled. Facility leadership stated that future meetings will be driven by interest and need, and that additional public comment opportunities will occur as part of permitting and regulatory processes. Leadership emphasized a philosophy of over-communication rather than under- communication. PART 2: ALTERNATIVES 2.1 Alternate Location During early phases of project planning HBMC evaluated alternate locations for the project in the general area. After full consideration the property was selected as it provides the best overall location for the proposed facility. The property is centrally located and of sufficient size for the full buildout. Necessary utilities and infrastructure can be made available at the project site. A fundamental purpose of the project is to provide outpatient medical services to the underserved Puna District community, which currently lacks a comparable outpatient clinic facility. The proposed Kea‘au location, at the intersection of Routes 11 and 130, is the most accessible point in Puna for residents traveling from throughout the district. There do not appear to be any significant environmental or other factors relating to the proposed use of the site. As such no alternative sites have been identified for study in the Environmental Assessment. The selected site satisfies the project’s key siting criteria: sufficient acreage for a phased multi-building medical campus, proximity to the primary regional highway corridor for patient access, availability of water and electrical utilities, and absence of significant environmental constraints. No other evaluated location in the Puna District met this combination of criteria. The site’s adjacency to Shipman Business Park and Kea‘au town center further 16 supports the integration of medical services within the existing commercial and community node at Kea‘au. 2.2 Alternate Site Layout, Phasing, Access & Building Design Aside from the proposed action, two alternative site designs were evaluated for the project. The first included constructing three (3) two-story 20,000 square foot buildings over two (2) construction phases. The second alternatve design proposed constructing two (2) single-story 20,000 square foot buildings over two (2) construction phases. These alternative designs or other similar designs would entail similar overall impacts to the proposed action. The phasing alternatives similarly, do not affect the overall impact of the project. Access Alternatives The access to the project would be from a new access driveway proposed to be constructed off Route 11 and Route 139 to connect the Medical Clinic to Shipman Park Driveway at Route 11. This driveway is intended to permit access to the site from an appropriate intersection with the highway. One alternative to the proposed access driveway would be to develop an access from the opposite side of the property extending through Shipman Business Park, extending from Kalara Street. This alternative is not ideal given that the proposed access driveway would be shorter than access through the Business Park and W.H. Shipman Ltd. has noted topographic concerns with this alternative. Further, the proposed access was planned in consultation with WHS with consideration of future plans they are developing for the northern portion of the parcel. Additionally, the intersection with Keaʻau-Pahoa Road is better able to accommodate traffic generated by the medical clinic than the highway intersection at Shipman Business Park as discussed in the TIAR. 2.3 No Action Under a No Action alternative, the medical facility would not be built, and no improvements would be made to the land. The lot would remain undeveloped. The potential for economic development and positive community impact would largely be lost. This EA considers the No Action alternative as the baseline for this project and all environmental effects will be based off this alternative. PART 3: ENVIRONMENTAL SETTING, IMPACTS, AND MITIGATION 3.1 Physical Environment The proposed medical clinic will be located to the west of Highway 11, across from the intersection with Kea‘au-Pāhoa Road. The subject property is located adjacent to the Keaʻau town center and borders open and agricultural land to the west. The entirety of the property and surrounding areas were cultivated with sugarcane until the closure of Puna Sugar Company in 17 1982. The property has since been utilized for the cultivation of other crops, such as papaya. Due to the extensive agricultural history, the project area and wider property are vegetated with non- native plants. 3.1.1 Geology, Geologic Hazards, and Soils Environmental Settings Volcanic Activity Geological hazards are frequent island wide, but particularly so in the Puna area. According to the Puna Community Development Plan, all of Puna lies within the three most hazardous geological risk zones, Lava Zone 1, 2 and 3, on a scale ranging from 9 to 1, ranking least hazardous to most. The subject property lies within Lava Zone 3, approximately 1-5 percent of which has been covered by lava flows since 1800, and 15-75 percent within the past 750 years (Thomas et al., 1992). The subject property sits close to the boundary between Mauna Loa and Kīlauea volcanoes. Nonetheless, according to most geological maps, the site falls just within the boundaries of Mauna Loa. Mauna Loa is the largest active volcano on earth, rising over 13,500 feet above sea level and extending to a depth of 16,400 feet below sea level. The sea floor is depressed another 26,250 feet due to the volcano’s enormous mass. Therefore, from the base to the summit, Mauna Loa is more than 56,000 feet high (HVO, 2022). Since 1843, Mauna Loa has erupted 33 times with an average of one eruption every five years. Exceptions to this pattern occurred during a 25-year hiatus between 1950 and 1975 and a 38-year hiatus from 1984 to 2022. On Sunday November 27, 2022, an eruption began in the summit caldera, Moku‘āweoweo. After some hours, new fissures opened along the Northeast Rift Zone. By December 2, the eruption was limited to one fissure, which advanced less than 2 miles from Saddle Road. On December 13, 2022, the eruption ceased. It's probable that the subject property hasn't experienced a lava flow for thousands of years because of its considerable distance from Mauna Loa’s most active rift zones. Furthermore, Moore and Trusdell (1991), suggest only eleven lava flows have traveled northeast from Kilauea’s East Rift Zone over the past 1,500 years. Earthquake Activity Aside from lava, the Island of Hawai‘i is also susceptible to earthquakes. The USGS recently came out with a model of earthquake probability for the Hawaiian Islands, which better estimates hazard probability compared to previous models. The ground shaking model indicates that Hawai‘i Island has a greater than 90 percent chance of experiencing an earthquake with slight (or greater) damage during the next 100 years (Figure 3). 18 The Kea‘au area is susceptible to ground shaking from earthquakes originating from both Mauna Loa and Kīlauea volcanoes. It is not uncommon to experience frequent slight tremors in Kea‘au as a result. Larger events, however, occur much less frequently and are more difficult to predict. Notable earthquakes that have impacted the area occurred in 1973, 1975, and 2018. In 1973, a magnitude-6.2 earthquake struck 29 miles beneath the town of Honomu, just north of Hilo. The depth of the earthquake is what caused such widespread and severe damage. Eleven people were reported injured in Hilo, four of which were hospitalized. An unknown number of injuries were also reported in Waimea. Approximately $5.6 million dollars of structural damage was recorded across the island (~$40 million today). In 1975, a magnitude-7.2 earthquake struck the southern flank of Kīlauea volcano near the town of Kalapana and caused significant shaking throughout the entire island. This earthquake also caused significant subsidence along southeastern shores of the island. Most recently, the 2018 Kīlauea eruption proved to be historic in many ways, including the magnitude-6.9 earthquake that rattled the entire island. This earthquake caused significant shaking throughout Puna and Hilo. There were even some reports of shaking as far as O‘ahu. Figure 3: 2021 USGS Model of Earthquake Probability for the Hawaiian Islands Topography and Soil The topography of the property slightly decreases from the western end at approximately 350 feet in elevation, to the eastern end, roughly 280 feet above sea level. According to the Land Study Bureau Productivity Rating, soils in the project area are classified as C (Fair Soils) and D 19 (Poor Soils) and the Agricultural Land of Importance to the State of Hawaiʻi (ALISH) classification identifies the project area as Other or Unclassified. The United States Department of Agriculture (USDA) Natural Resources Conservation Service Soils Survey Report classifies approximately 92 percent of the soil in this area as Panaewa very cobbly hydrous loam with 2 to 10 percent slopes (2klkz). This series is basic volcanic ash over pahoehoe lava and is moderately well drained with a high runoff class. The remaining soil is classified as Papai extremely cobbly highly decomposed plant material with 2 to 10 percent slopes (2klky). This soil type consists of organic material over ʻaʻa lava and is well drained with a low runoff class. Neither soil type is considered prime farmland. Figure 4 shows the Papai series on the northern portion of the property identified as 628 and the Panaewa series lies on the southern portion, labeled 629. The 20-acre project area is within the area with Panaewa series soil. Potential Environmental Impact from Proposed Action Potential impacts from volcanic activity and earthquakes are expected to be minimal. Potential impacts from geological hazards and soils will not change appreciably under any alternative action, except a no action alternative. In the event of an earthquake, there may be some ground shaking, particularly during a significant seismic event. However, all structures will be designed and engineered to withstand seismic activity, adhering to the standards outlined in the Hawai‘i County Code. Should a lava flow pose a threat to Kea‘au, there would likely be adequate time to evacuate to a secure location. Located just west of Highway 11, the subject property offers a strategic position for swift and efficient evacuation. However, considering the intended use of the project as a medical facility, it may be necessary to develop an emergency response plan. If required, HBMC will ensure the development and implementation of a comprehensive evacuation strategy to safeguard the safety and well-being of all occupants. Mitigating Measures Geology, Geological Hazards, and Soils Considering and implementing appropriate safety measures and protocols associated with geological hazards is essential in the development of any public facility. All buildings intended for the proposed development will be engineered and designed to endure seismic hazards, in compliance with the Hawai‘i County Code. If required, an Emergency Preparedness and Response Plan will be submitted to the Hawai‘i County Civil Defense Agency for review and approval. Best Management Practices for construction activities will be strictly followed to prevent adverse impacts to soil. Hawai‘i Administrative Rules Chapter 11-55, Appendix C, under Special Conditions for Land Disturbances, describes the following construction management techniques to protect soil: 20 Figure 4: Soil M ap ~ Soil Map-Island of Hawaii Area, Hawaii ~ ~ (TMK (3) 1-6-003 127) i:l N"' ~ ~ 19" 38' ll"N ~ 1'i ~ N ~ ~ "' 8 ~ 1'i ~ "' ~ 1'i !i! "' ~ ~ ;::: 1'i § ;::: 1'i Iii;::: 1'i 19"3735"N 19" 38' ll" N ~ "' ~ 1'i ~ N ~ 1'i § ~ N ~ 1'i § ;::: 1'i ~ ;::: 1'i ~ -;::: 1'i § ;::: 1'i ~ ;::: 1'i 19"3735"N a. Clearing and grubbing shall be held to the minimum necessary for grading and equipment operation. b. Construction shall be sequenced to minimize the exposure time of the cleared surface area. c. Construction shall be staged or phased for large projects. Areas of one phase shall be stabilized before another phase is initiated. Stabilization shall be accomplished by temporarily or permanently protecting the disturbed soil surface from rainfall impacts and runoff. d. Erosion and sediment control measures shall be in place and functional before earth moving operations begin. These measures shall be properly constructed and maintained throughout the construction period. e. All control measures shall be checked and repaired as necessary, for example, weekly in dry periods and within twenty-four hours after any rainfall of 0.5 inches or greater within a 24-hour period. During prolonged rainfall, daily checking is necessary. Record of checks and repairs must be maintained. f. Records of the duration and estimated volume of storm water discharge must be maintained. g. A specific individual shall be designated to be responsible for erosion and sediment controls on the project site. 3.1.2 Flood Zones Environmental Setting According to the Federal Emergency Management Agency (FEMA), the subject property is located within Flood Zone X, which is outside the 500-year floodplain (Figure 5). It is also located 4 miles from the coast and is not within the County Special Management Area (SMA) or the County Tsunami Evacuation Zone. The proposed project will not be impacted by any coastal hazards or affect erosion, coastal ecosystems, or marine resources. There are no naturally occurring wetlands, ponds, or lakes in the area. USGS Stream Stats indicate the presence of several unnamed drainage paths that run through the property; however, the project has been sited to avoid issues with drainage or flooding. A drainage basin extends to cover a portion of the southern end of the property. The drainage basin is calculated to generate 2,720 cubic feet per second (cfs) of runoff in a 100-year storm event (USGS, 2024). Potential Environmental Impact from Proposed Action Since the property is outside of the 500-year floodplain, overall flooding risk for the site is low. Project construction is proposed to be sited within an area that will not be affected by the existing drainage basin. A proper drainage feature will be installed where the drainage basin crosses under the new access road. 22 Figure 5: Flood Hazard Map Legend Subject Property D Flood Hazard x D Hawaii Statewide GIS Program, County of Hawaii, Esri Potential impacts from flooding will not change appreciably under any alternative action, except a no action alternative. However, a no-action alternative lacks significant justification since appropriate measures will properly mitigate risks. Impacts and Mitigating Measures Improvements to onsite drainage must adhere to the Drainage Standards of the Hawai‘i County Department of Public Works. The drainage study will undergo review and approval by DPW- Engineering before plan submission for approval. The design for storm drainage will be based on a 10-year, one-hour storm event, with all post-development increases required to be retained on-site. 3.1.3 Climate and Climate Change Environmental Settings Climate The climate in the subject area is warm and moist, with an average annual rainfall of 142 inches and a mean annual temperature of 75 degrees Fahrenheit (Giambelluca et al., 2013). Climate Change The Hawai‘i Revised Statues §226-109 and Hawai‘i Administrative Rules §11-200.1 strongly encourages a climate change perspective be incorporated into the environmental assessment process. This entails evaluating how the outcomes of the analysis may be influenced by foreseeable future conditions impacted by climate change. Given the widespread impact of climate change on U.S. communities, it is imperative to assess the vulnerability of each factor under review to present and anticipate climate change effects. Additionally, careful consideration should be given to ensuring that the project and its occupants are adequately safeguarded from the potential impacts of climate change. This proactive approach aligns with the commitment to environmental responsibility and resilience in the face of evolving climatic conditions. Human activities, particularly the emissions of greenhouse gases, have undeniably caused global warming, resulting in a 1.1°C increase in global surface temperature from 2011 to 2020 compared to 1850-1900 levels. The rise in greenhouse gas emissions stems from unsustainable practices in energy use, land use, lifestyle, and consumption patterns, contributing to an uneven global impact. This has triggered widespread and rapid change across the atmosphere, ocean, cryosphere, and biosphere, influencing various weather and climate extremes globally. These changes have led to adverse impacts on nature and people, causing significant losses and damage. Regional effects include heightened tropical cyclones, extratropical storms, increased aridity, and elevated fire weather. Continued emissions are projected to further raise global temperatures, potentially reaching 1.5°C in the near term, intensifying multiple concurrent hazards with each incremental warming (IPCC, 2023). The University of Hawai‘i’s Sea Grant College Program confirms that Hawai‘i is getting warmer. Data shows an increase in air temperature over the last 30 years of roughly 0.3°F per 24 decade. For Hawai‘i this not only means rising sea levels, but also more contrast in the wet and dry season, which may lead to more frequent and intense precipitation and flooding (Tetra Tech, 2020). In general, rainfall in Hawai‘i has been variable in the recent past with some drier years and some wetter years on average. El Niño provides periodic variation in winds and sea surface temperatures in the Pacific contributing to warming phases, while La Niña contributes to cooling phases. Increases in air temperature related to climate change will lead to more evaporation and more moisture in the air, which will contribute to variability in El Niño and La Niña events. The 2019 Intergovernmental Panel on Climate Change (IPCC) Special Report on the Ocean and Cryosphere in a Changing Climate explicitly highlights a rise in the frequency of Category 4 and 5 tropical cyclones, commonly referred to as ‘hurricanes’ in the central Pacific. The average intensity of tropical cyclones, the proportion of Category 4 and 5 tropical cyclones and the associated average precipitation rates are projected to increase for a 2oC global temperature rise above any baseline period (medium confidence). Rising mean sea levels will contribute to higher extreme sea levels associated with tropical cyclones (very high confidence). Coastal hazards will be exacerbated by an increase in the average intensity, magnitude of storm surge and precipitation rates of tropical cyclones (Collins et al., 2019). In addition, according to the AR6 Synthesis Report produced by the IPCC in 2023, “It is likely that the global proportion of major (Category 3–5) tropical cyclone occurrence has increased over the last four decades”. Historically, the Island of Hawai‘i has been viewed as largely protected from experiencing storms of this magnitude due to the presence of Mauna Loa and Mauna Kea. However, recent years have shown that storms such as Iselle (2014) and Lane (2018) can have very damaging effects to the island. On August 8, 2014, Hurricane Iselle made landfall in the Puna District of Hawai‘i County as a moderate tropical storm with sustained wind speeds of 70 miles per hour. Significant damage was felt in the southeastern portions of the Big Island, especially in the Wai‘ōpae area, which is a coastal stretch dotted with anchialine ponds and tidepools, known as Kapoho Tide Pools. Many homes were heavily damaged in this area. This was the most heavily damaged area, which is approximately 23 miles southeast of the subject site. Most of the southeastern portion of the Big Island experienced high winds, heavy rain, downed trees, and powerlines, cutting thousands of people off from electricity, water, and transportation for several days (Kimberlain et al., 2018). Hurricane Lane occurred in late August 2018 and brought significant damage to the Hawaiian Islands from flash flooding and mudslides. Over a four-day period, Hawai‘i Island received an average of 17 inches of rain. Up to 159 structures were damaged, making it the wettest tropical storm to impact the Island. Although most of the flooding impacts were concentrated to Hilo, much of the southern windward side, including southern Puna, experienced impacts (Beven, 2019). 25 Wildfires are becoming more frequent and intense due to rising temperatures, change in rainfall patterns and the growth of non-native, fire prone grasses and shrubs. According to the Pacific Fire Exchange (PFE) (2021), “Fire risk is closely tied to wet and dry cycles where grasslands and savannas grow and then dry out”. Up to 25% of land in Hawai‘i is at fire-prone risk. According to the Hawai‘i Wildfire Management Organization (HWMO), about 0.5% of Hawai‘i’s total land area burns every year. Climate change is beginning to play a very serious role in the frequency and intensity of fires seen across the state. “Human ignitions coupled with an increasing amount of non-native, fire-prone grasses and shrubs and a warming, drying climate have greatly increased the wildfire problem” (HWMO, 2018). Further, expanding non-native, fire-prone grasses are less likely to recover from wildfires. Wildfires were once limited to active volcanic eruptions and infrequent lightning strikes. The increase in wildfire prevalence poses threats to safety, agricultural production, natural and cultural resources (PFE, 2014). In early August 2021, a vegetation fire ignited near Mana Road and traveled throughout Waimea and South Kohala. Approximately 40,000 acres were burned according to estimates from fire officials. It was the largest wildfire every recorded in Hawai‘i County. Thousands of people were forced to evacuate from Waiki‘i Ranch and Pu‘u Kapu Hawaiian Homesteads, where two homes were destroyed. Governor David Ige declared a state of emergency on August 4, 2021, to protect the health, safety, and welfare of Hawai‘i (West Hawai‘i Today, 2021). Figure 6 is a map of wildfires in Hawai‘i between 1999 and 2022, including the Mana Road Fire depicted in dark red. 26 Figure 6: Hawai‘i State Fires Between 1999 and 2022 Not depicted on the above map are the devastating wildfires that occurred in August 2023. Hurricane Dora, moving south of the Island of Hawai‘i, interacted with a robust anticyclone north of the Hawaiian Islands. This interaction resulted in a sharp pressure gradient, generating powerful winds. Coupled with prevailing drought conditions, it led to wildfires on both Maui and Hawai‘i Island. Early on August 8, 2023, several brush fires fueled by strong winds ignited on Maui. A Lahaina fire flareup prompted evacuations, road closures, and shelter-in-place advisories on western Maui. However, little warning, few escape routes, and interruption to cell phone service created a perfect storm of disastrous conditions. The Lahaina wildfire has since become the largest natural disaster in Hawai‘i’s state history and one of the deadliest wildfires in recorded U.S. history. More than 100 lives were lost, and over 2,200 buildings destroyed in Lahaina alone. On the same day, wildfires ignited in the Kohala District on Hawai‘i Island, prompting evacuations for several nearby subdivisions and beach resorts. Roughly 1,000 acres of land burned with no loss of life. Communities on the leeward side of the Hawaiian Islands are generally characterized by drier 27 conditions and are therefore particularly vulnerable to wildfires. However, those on the windward side are progressively at greater risk due to the islands undergoing more frequent episodes of drought. Potential Environmental Impact on the Proposed Action While the proposed action will not exacerbate the adverse effects of climate change, it may be at risk of experiencing impacts from climate events. Coastal flooding and sea level rise do not currently pose a threat to the subject parcel due to its distance from the shoreline; however, hurricanes have the potential to extend their impact several miles inland. Potential impacts from hurricanes could include high winds, heavy rainfall, and localized flooding from mountain regions and overwhelmed drainage systems. Additionally, wildfires in the vicinity have the potential to produce poor air quality, disruptions to power, and property damage in extreme cases. Any potential impacts relating to climate change will not change appreciably under any alternative action. Impacts and Mitigating Measures for Climate and Climate Change It is imperative the development of any public facility implements appropriate safety measures and protocols in case of an adverse climate event. All buildings will be designed and engineered to withstand wind hazards according to the Hawai‘i County Building Codes. The proposed action will comply with all required codes and regulations regarding drainage and runoff mitigation. These protections will prevent any adverse impacts relating to flooding potential in a storm event. The proposed action will not contribute to adverse impacts resulting from climate change. The development will not promote any fire prone vegetation. As these protective regulations apply equally to each alternative, there are no appreciable differences in potential impacts between project alternatives. If required, an emergency response plan will be drafted for the proposed development in the case of potential adverse impacts from a storm event. 3.1.4 Water Quality Environmental Setting According to the State Department of Health, the Underground Injection Control (UIC) line was established to protect ground water resources with drinking water potential. Areas mauka of the line are considered potential drinking water sources from the Hilo Aquifer. This is where most municipal water comes from. In contrast, areas makai of the line are considered non-potable. The subject property lies above the UIC line, therefore, a UIC permit may be required at the time of engineering site design, depending on whether deep or shallow drywells are used. 28 Potential Environmental Impact from the Proposed Action The proposed action is not expected to pose a significant adverse risk to water quality, aquatic, or marine habitats due to the establishment of mitigating measures and BMPs. Additionally, the proposed action would control stormwater runoff from the site with appropriate drywells or similar drainage features. Furthermore, current construction plans do not anticipate encountering groundwater at the site. No jurisdictional water bodies are present on site per Section 404 of the Clean Water Act, and a jurisdictional determination from the U.S. Army Corps of Engineers will not be necessary. The implementation of mitigating measures means potential impacts to water quality won’t change appreciably under any alternative action. Impacts and Mitigating Measures To safeguard near-shore waters and marine ecosystems, Best Management Practices will be implemented before and after construction to effectively contain soil and sediment and prevent potential harm. HBMC will ensure all earthwork and grading will be conducted in compliance with: (a) “Storm Drainage Standards,” County of Hawai‘i, 1970 and as revised (b) “Flood Control,” Chapter 27 of the Hawai‘i County Code (c) Standards and regulations of the Federal Emergency Agency (FEMA) (d) “Erosion and Sedimentation Control,” Chapter 10 of the Hawai‘i County Code (e) Conditions of an NPDES permit, if required, and any additional Best Management Practices required by the Department of Health Clean Water Branch Construction activities may occur in an area greater than one acre and thus may require a National Pollutant Discharge Elimination System (NPDES) permit and a Storm Water Pollution Prevention Plan (SWPPP). A list of Best Management Practices (BMPs) will be established to properly manage storm water runoff. These BMPs may include, but are not limited to: • Minimizing soil loss and erosion by revegetating and stabilizing slopes and disturbed areas of soil. • Minimizing sediment loss by placing structural controls including silt fences, gravel bags, sediment ponds, check dams, and other barriers. • Applying sediment wattles and protective covers to soil and material stockpiles. • Gravel check dams in gutters. • Constructing and using a stabilized construction vehicle entrance, with a designated vehicle wash area that discharges to a sediment pond. • Washing of all vehicles in the designated wash area before leaving the project site. • Use of drip pans beneath vehicles to trap vehicle fluid. • Performing routine inspection and maintenance of structural BMPs by trained personnel. • Properly cleaning significant leaks or spills and disposing at an approved site. 29 Impermeable surfaces can increase the volume and rate of stormwater runoff. However, per Hawai‘i County Code, Chapter 27, the volume of stormwater leaving the site will not increase. Wastewater will be managed by a wastewater treatment plant on site designed and permitted according to DOH standards. 3.1.5 Flora and Fauna Environmental Settings Flora Section 7(c) of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), requires an official species list from the United States Fish and Wildlife Service (USFWS) of identified threatened and endangered species, as well as critical habitat, that may occur within the boundary of the project area. According to the USFWS, it would be possible for the following six (6) endangered flowering plants and one (1) endangered fern to possibly exist in the area, although no critical habitat exists on or near the property: 1. Alani (Melicope zahlbruckneri) 2. Haiwale (Cyrtandra nanawaleensis) 3. Hau Kuahiwi (Hibiscadelphus giffardianus) 4. Holei (Ochrosia haleakalae) 5. Holei (Ochrosia kilaueaensis) 6. Nanu (Gardenia remyi) 7. Palapalai (Microlepia strigosa var. mauiensis) A biotic survey of the site was conducted on 9/30/25, only one species of native plant was observed on the property and it is not likely that any endangered species would be affected due to extensive past agricultural development. Plant species that were observed on the property are listed below. Table 2: Flora Species Observed on Property – Under Status: A = Alien or Non-native species, I = Indigenous species, PI = Polynesian Introduced species, E = Endemic, En = Endangered Latin Name Common Name Family Status Trema orientale Gunpowder Tree Cannabaceae A Commelina diffusa Honohono grass Commelinaceae A Momordica charantia Bitter Melon Cucurbitaceae A Macaranga mappa Bingabing Euphorbiaceae A Macaranga tanarius Parasol leaf tree Euphorbiaceae A Ricinus communis Castor Bean Euphorbiaceae A Falcataria moluccana Albizia Fabaceae A 30 Desmodium incanum Creeping Beggarweed Fabaceae A Clidemia hirta Koster's curse Melastomataceae A Tibouchina urvilleana Glory Bush Melastomataceae A Cecropia obtusifolia Trumpet tree Moraceae A Megathyrsus maximus Guinea Grass Poaceae A Paederia foetida Stinkvine Rubiaceae A Solanum nigrum Popolo Solanaceae I Nephrolepis brownii Asian sword fern Nephrolepidaceae A Spathodea campanulata African tulip tree Bignoniaceae A Cenchrus purpureus Cane Grass Poaceae A Hyptis pectinata Comb hyptis Lamiaceae A Setaria palmifolia Palm Grass Poaceae A Fauna It is not likely that any threatened or endangered species exist on the subject property. Common non-native birds were observed, such as common myna (Acridotheres Trista), house sparrow (Passer domesticus), house finch (Haemorhous mexicanus), yellow billed cardinal (Paroaria capitata), and spotted dove (Spilopelia chinensis). It would be possible for one (1) mammal and seven (7) federally listed bird species to fly over, roost, or utilize resources near the subject property. While not on the federal list, it may also be possible for one (1) state listed bird to frequent the area. These include the following: Federally Listed: 1. Hawaiian Hoary Bat (‘Ope‘ape‘a) (Lasiurus cinereus semotus) 2. Hawaiian Coot (Alae ke‘oke‘o) (Fulica alai) 3. Hawaiian Duck (Koloa Maoli) (Anas wyvilliana) 4. Hawaiian Stilt (Aeʻo) (Himantopus mexicanus knudseni) 5. Band-rumped Storm-petrel (ʻAkēʻakē) (Hydrobates castro) 6. Hawaiian Goose (Nēnē) (Branta (=Nesochen) sandvicensis) 7. Hawaiian Petrel (ʻUaʻu) (Pterodroma sandwichensis) 8. Newell’s Shearwater (ʻAʻo) (Puffinus newelli) State Listed: 9. Hawaiian Hawk (ʻIo) (Buteo solitarius) This Environmental Assessment will focus on the nine (9) State and Federally listed mammal and bird species that may fly over, roost, or otherwise utilize resources near the subject property, as they are the most likely to be potentially impacted by the proposed project. The following provides a description of each species, their range, and preferred habitat. 31 1. Hawaiian Hoary Bat (‘Ope‘ape‘a) (Lasiurus cinereus semotus) Federally Listed Endangered The Hawaiian Hoary Bat prefers roosting within the foliage of both native and non-native trees. Their foraging grounds encompass a diverse range of habitats, such as forest gaps, clearings, areas above the forest canopy, and alongside roads. Notably, on the Big Island, the Ōpe‘ape‘a engage in seasonal migration, with summers spent in the lowlands and overwintering occurring in higher altitude regions. 2. Hawaiian Coot (Alae ke‘oke‘o) (Fulica alai) Federally Listed Endangered The Hawaiian Coot typically inhabits lowland wetland environments, generally below 1,300 feet in elevation, such as the Waiaka-Loko Waka ponds located on Hawaiʻi Island. However, instances of their presence have been documented at altitudes as high as 6,600 feet on the island. These birds display a preference for wetland habitats characterized by the presence of appropriate emergent plant species amidst open water, particularly favoring freshwater wetlands and reservoirs. 3. Hawaiian Duck (Koloa Maoli) (Anas wyvilliana) Federally Listed Endangered The Hawaiian duck is found in various habitats such as low wetlands, river valleys, coastal ponds, lakes, swamps, flooded grasslands, and mountain streams, ranging from sea level to elevations of 3,300 meters. Social interactions may occur more frequently in managed wetlands for waterbirds compared to wetlands cultivated with taro, while resting was observed more often in taro cultivated wetlands. This suggests that both managed and cultivated wetlands are crucial for meeting the basic daily and seasonal needs of this species. However, the wider array of activities and foraging techniques observed in managed wetlands may indicate a greater diversity of habitats in these areas. 4. Hawaiian Stilt (Aeʻo) (Himantopus mexicanus knudseni) Federally Listed Endangered Hawaiian stilts make use of diverse aquatic environments, mostly in lower-altitude areas, yet their presence is influenced by water depth and the density of vegetation. These birds depend on early-stage marshlands with water depths below 24 centimeters (9 inches), and they frequent regions with scant, short perennial plants or open tidal flats. Hawaiian stilts seem to prefer nesting sites with minimal or no surrounding vegetation, likely to maintain visibility and better detect potential predators. 32 5. Band-rumped Storm-petrel (ʻAkēʻakē ) (Hydrobates castro) Federally Listed Endangered The Band-rumped Storm-petrel is a seabird known to nest in remote cliff locations on, in steep open to vegetated cliffs, and in little vegetated, high-elevation lava fields. These birds are regularly seen in and around coastal waters of Kaua‘i, Niihau, and Hawai‘i Island. Band-rumped storm-petrels are long-lived (15 to 20 years). When not at nesting sites, adults spend their time foraging on the open ocean for small fish, squid, and crustaceans. 6. Hawaiian Goose (Nēnē) (Branta (=Nesochen) sandvicensis) Federally Listed Threatened Historically, The Hawaiian Goose (Nēnē) (Branta sandvicensis) were found in lowland dry forests, shrublands, grasslands, and montane dry forests. Their current habitat preferences may be influenced by the release locations of captive-bred birds. Presently, they inhabit a diverse array of environments, such as coastal dune vegetation and non-native grasslands (like golf courses, pastures, and rural areas), sparsely vegetated low-and high-elevation lava flows, mid-elevation native and non-native shrublands, early successional cinderfall, cinder deserts, native alpine grasslands and shrublands, and open interfaces between native and non-native alpine shrubland-woodland communities. Nēnē nest in various habitats, including beach strands, shrublands, grasslands, lava rocks, and across different elevations. 7. Hawaiian Petrel (ʻUaʻu) (Pterodroma sandwichensis) Federally Listed Endangered The Hawaiian Petrel is found in remote and high elevation areas on the island of Hawai‘i, Maui, Moloka‘i, Lanai, and Kaua‘i. The majority of known nests on Hawaiʻi island are within Hawaiʻi Volcanoes National Park on the lower alpine and subalpine slopes of Mauna Loa. Wildlife biologists estimate only 50 to 60 breeding pairs remaining. 8. Newell’s Shearwater (ʻAʻo) (Puffinus newelli) Federally Listed Threatened The Newell’s Shearwater nest on the slopes and cliffs of Kaua‘i. Small colonies also exist on Moloka‘i, Maui, and Hawai‘i Island. On the island of Hawai‘i, they nest within forested cinder cones. Colonies are usually located in areas of open native forest dominated by ‘ōhi‘a (Metrosideros polymorpha) with a dense understory of ‘uluhe fern (Dicranopteris linearis). 33 9. Hawaiian Hawk (I‘o) (Buteo solitarius) Formerly State Listed Endangered The Hawaiian Hawk (I‘o) (Buteo solitarius) inhabits lowland non-native forests, urban locales, agricultural fields, pasturelands, and high-elevation native forests. Primarily, nesting takes place within native 'ōhi'a trees, though instances also occur in non-native tree species such as eucalyptus, ironwood, mango, coconut palm, and macadamia. During winter, sightings have been recorded in subalpine māmane-naio forests, indicating potential seasonal migrations. Their habitat can range between near sea level and 8,000 feet above sea level. Potential Environmental Impact from the Proposed Action The Hawaiian Hoary Bat roosts in both exotic and native woody vegetation across all islands and will leave young unattended in trees and shrubs when they forage. During the pupping season, clearing trees or shrubs taller than 15 feet poses a danger, as the young bats, unable to fly and still very vulnerable, may inadvertently suffer harm or death if they are unable to move away. Furthermore, these bats search for insects anywhere from as low as 3 feet to heights exceeding 500 feet above ground level, putting them at risk of becoming tangled in barbed wire typically used for fencing. Hawaiian waterbirds, such as the Hawaiian stilt, coot, and duck listed by the USFWS, inhabit fresh and brackish-water marshes as well as natural or man-made ponds. Hawaiian stilts can also be seen in areas with temporary or permanent standing water. These species face challenges from non-native predators, loss of habitat, and habitat deterioration. Additionally, Hawaiian ducks are at risk due to hybridization with introduced mallards. The creation of standing or open water may result in the attraction of Hawaiian waterbirds to a site. In particular, the Hawaiian stilt is known to nest in sub-optimal locations (e.g. ponding water), if water is present. Hawaiian waterbirds attracted to sub-optimal habitat may suffer adverse impacts, such as predation and reduced reproductive success. Hawaiian seabirds might pass through the project area during the nighttime breeding, nesting, and fledging seasons, spanning from March 1st to December 15th. The presence of outdoor lighting could lead to disorientation, fallout, and potential injury or death for these seabirds. These birds are naturally drawn to lights, and after circling them, they may become fatigued and collide with nearby structures such as wires, buildings, or other objects, or they may even land on the ground. Seabirds that have landed are at a higher risk of mortality due to collisions with vehicles, starvation, and attacks by predators such as dogs, cats, and other wildlife. Young birds, particularly fledglings, traversing the project area between September 15th and December 15th, during their first flights from mountain nests to the sea, are especially susceptible to being attracted to lights. Permanent lighting also poses a risk of seabird attraction, and as such should be minimized or eliminated to protect seabird flyways and preserve the night sky. Additionally, seabirds have been known to collide with fences, powerlines, and other structures near nesting colonies. 34 Soil and plant material may contain detrimental fungal pathogens (e.g., Rapid ‘Ōhi‘a Death), vertebrate and invertebrate pests (e.g., Little Fire Ants and Coqui Frogs), or invasive plant parts (e.g., African Tulip, Octopus Tree, Trumpet Tree, etc.) that could harm native species and ecosystems. Additionally, the invasive Coconut Rhinoceros Beetle (CRB) scientifically known as Oryctes rhinoceros, is an invasive species present on the islands of O‘ahu, Hawai‘i Island, Maui, and Kaua‘i. On July 1, 2022, the Hawai‘i Department of Agriculture implemented Plant Quarantine Interim Rule 22-1. This regulation imposes restrictions on the transportation of CRB- host material within or to and from O‘ahu, which is defined as the Quarantine Area. Items considered regulated materials (such as host plants or materials) pose a potential risk for CRB infestation. Specifically, CRB-host materials include: a. Entire dead trees; b. Mulch, compost, trimmings, fruit, and vegetative scraps; c. Decaying stumps. CRB host plants encompass live palm plants from the following genera: • Washingtonia, Livistona, and Pritchardia (all commonly known as fan palms) • Cocos (coconut palms) • Phoenix (date palms) • Roystonea (royal palms) The movement of such materials or these specified plants carries the risk of CRB spread, as they could harbor CRB at any stage of their life cycle. Mitigating measures will be implemented to avoid or minimize all potential impacts from plant material. HBMC will adhere to all mitigating measures to protect listed mammals and birds as outlined in the section below. Impacts and Mitigating Measures The Hawai‘i Division of Forestry and Wildlife (DOFAW) recommends minimizing the movement of plant or soil material between worksites to avoid or reduce potential impacts from fungal pathogens. All equipment, materials, and personnel should be cleaned of excess soil and debris to minimize the risk of spreading invasive species. Native plant species that are appropriate for the area will be used for landscaping. No detrimental invasive species will be planted on site. DOFAW recommends consulting with the Big Island Invasive Species Committee (BIISC) to help plan, design, and construct the project, learn of any high-risk invasive species in the area, and ways to mitigate their spread. The Plant Pono guide found at www.plantpono.org can also be used for guidance on the selection and evaluation of landscaping plants and to determine the potential invasiveness of plants to be used on site. Cats are natural predators of native birds, including State-listed endangered waterbirds, seabirds, and forest birds. Their hunting instincts mean that even well-fed cats will actively hunt and prey on wildlife. As a result, DOFAW advises that no feeding of feral cats takes place on the property. 35 With the mitigating measures outlined below impacts to native flora and fauna will not change appreciably under any alternative action, except a no action alternative. 3.1.6 Air Quality Environmental Setting Air quality in this area is currently very good. In the past, volcanic emissions such as sulfur dioxide from the Kīlauea volcano, have resulted in “vog,” which can impact air quality in the Puna District at times. Vog is created when sulfur dioxide reacts chemically with sunlight, oxygen, dust particles and water in the air. During eruptions, the trade winds generally keep the Kea‘au area free from severe vog, however, weak winds particularly in the winter may result in worse conditions. In the future, during episodes of volcanic eruptions, HBMC would have no worse air quality conditions than the rest of the Puna District. Vehicles are another source of minor air pollution, which is minimal on Hawai‘i Island. Vehicle emissions in the area would mainly come from Hawaiʻi Belt Road (Hwy 11), which is adjacent to the subject site and Highway 130. All Hawai‘i Island meets the standards set by the Clean Air Act (CAA) and HRS §342B. Potential Environmental Impact from the Proposed Action Air pollutants during construction will be limited and temporary. The main sources of short-term air pollutants are construction equipment exhaust and dust. During operation, the main source of air pollution will be through regular vehicle trips including the movement of employees and patients. With the outlined mitigation measures, potential impacts to air quality will not change appreciably under any alternative action. Mitigating Measures Air pollutants during construction will be limited and temporary. The main sources of short-term air pollutants are construction equipment exhaust and dust. HAR §11-60 on Fugitive Dust prohibits visible emissions of dust from construction activities. These regulations will be strictly followed to prevent dust impacts to Hawaiʻi Belt Road. In addition, reasonable measures to control airborne and visible fugitive dust from road areas are outlined by the Department of Health’s Clean Air Branch. These measures include, but are not limited to: • Planning the different phases of construction, focusing on minimizing the amount of airborne, visible fugitive dust-generating materials and activities, centralizing on-site vehicular traffic routes, and locating potential dust-generating equipment in areas of the least impact. • Providing adequate water sources at the site prior to start-up of construction activities; Landscaping and providing rapid covering of bare areas, including slopes, starting from the initial grading phase. • Minimizing airborne, visible fugitive dust from shoulders, and access roads. 36 • Providing reasonable dust control measures during weekends, after hours, and prior to daily start-up of construction activities. • Controlling airborne, visible fugitive dust from debris being hauled away from the project site. These mitigating measures will be used during all phases of construction to prevent significant impacts to the Hawaiʻi Belt Road, Highway 130, and surrounding areas. 3.1.7 Noise Environmental Setting Noise on the project site varies from low to moderate, with the main source being from vehicles on Hawaiʻi Belt Road and Highway 130. Potential Environmental Impact from Proposed Action Short-term noise impacts may occur during construction from excavation, grading, vehicle and equipment operation, and the construction of new infrastructure, which will be mitigated by BMPs. Noise levels are expected to increase moderately during operation with higher levels of traffic to and from the proposed medical center and operational noise sources for the clinic, as well as more occupants and users from the community. Traffic noise along the highway is expected to remain the primary source of noise in the area following project development. Careful siting of HVAC equipment should mitigate for any noise impacts due to the use outside of construction. However, hours of operation will be primarily Monday – Friday from 8:00 a.m. – 4:00 p.m., with urgent care services available seven (7) days per week from 8:00 a.m. to 8:00 p.m. The facility will not be an emergency room, will not receive ambulances, and will not provide drug rehabilitation services. Thus, noise impacts should be similar to those of other nearby commercial and community uses. Potential impacts relating to noise will not change appreciably under any alternative action, except a no action alternative. Mitigating Measures Rules and regulations outlined in Hawai‘i Administrative Rules Title 11, Chapter 46 “Community Noise Control,” will be followed during all construction and operation activities. If there is a potential for construction noise to exceed the State Department of Health’s maximum permissible noise levels, a noise permit will be sought. During operation, appropriate landscaping will be incorporated to screen the property and buffer noise to surrounding areas. 37 3.1.8 Scenic Resources Environmental Setting There are no scenic resources listed in the Hawai‘i County General Plan on or near the subject parcel. Potential Environmental Impact from Proposed Action No significant impacts are expected to scenic resources. The grounds and buildings will be aesthetically pleasing and screened by appropriate landscaping vegetation. While there is a risk of light pollution affecting scenic views, the night sky visibility, and potentially impacting seabirds utilizing nearby resources, these concerns will be effectively addressed through the implementation of BMPs discussed below. Views to and from the shoreline will not be impacted by the project. Potential impacts to scenic resources will not change appreciably under any alternative action. Mitigating Measures Light pollution is another important aspect of maintaining scenic resources and the visibility of the night sky. Therefore, the following guidelines to minimize light pollution will be adhered to: 1. Any outdoor lighting must conform to the standards established by the Hawai‘i County Outdoor Lighting Ordinance (Hawai‘i County Code Chapter 14, Article 9: “Outdoor Lighting”). 2. The minimum possible amount of outdoor/exterior lighting should be used and should be turned off when not needed. Motion sensor activated lighting will be used wherever feasible. 3. All exterior lighting should be fully shielded. This means that all lighting fixtures must emit zero light above the horizontal plane. 4. Conformity to the Outdoor Lighting Ordinance also requires the use of blue-deficient exterior lighting. This means that exterior LED lighting must emit less than 2% of its total energy at wavelengths less than 500 nm. The best choice for this is either filtered LED lights, or amber LED lights. 5. White light should be avoided. Any white light used should have Correlated Color Temperature of 2700 K or below. 6. Rig lights during construction must be shielded to minimize stray lighting. 3.1.9 Hazardous Substances, Toxic Waste, and Hazardous Conditions Environmental Setting The subject property has a history of being utilized for commercial agricultural purposes, including sugarcane production, dating back to at least 1900. Previous studies on former commercial agricultural lands in Hawai‘i have indicated higher concentrations of pesticides and 38 metals in the soil. Additionally, there have been findings of increased levels of arsenic in the soil within the vicinity. A Soil Screen Report was conducted on the subject Property in September 2025 by Lehua Environmental Inc (Appendix C). The objective of the Soil Screen was to identify the presence (if any) of Resource Conservation Recovery Act (RCRA) 8 metals-and organochlorine pesticide-contaminated soils within the areas of planned disturbance for the Project at the Subject Site, so that the information can be incorporated in the design of the Project. The soil survey identified twenty-four (24) decision units at the Subject Site and collected a total of thirty (30) multi-increment (MI) soil samples from the 24 decision units of the Subject Site, which included duplicate and triplicate samples per the Hawaii Department of Health (DOH) Hazard Evaluation and Emergency Response (HEER) Technical Guidance Manual (TGM) recommendations. Each MI soil sample included 50 increments collected utilizing DOH recommended hand tools and equipment. Samples were collected from surface soils (0-6” below ground surface (bgs)) and shallow subsurface soils (6”-12” bgs). Decision unit (DU) sizes ranged from 16,250 square feet to 20,000 square feet and the volumes ranged from 301 cubic yards (cy) to 370 cy. The collected soil samples were tested according to the following analysis: • MIS laboratory preparation non-volatile • RCRA 8 metals by EPA 6020B/EPA 3050B • Bioaccessible arsenic by EPA 1340 • Organochlorine pesticides by EPA 8081B/3550C Bioaccessible arsenic was detected above the Tier 1 (unrestricted land use) EAL in decision units: DU-23 and DU-24 at the Subject Site. Additionally, total arsenic was detected above the Tier 1 (unrestricted) and/or Tier 2 (commercial/industrial) EAL in decision units: DU-1, DU-2, DU-3, DU-4, DU-5, DU-6, DU-7, DU-8, DU-9, DU-10A, DU-10B, DU-10C, DU-11, DU-12, DU-13, DU-14, DU-15, DU-16, DU-17, DU-18, DU-19, DU-20A, DU-20B, DU-20C, DU-21, DU-22, DU-23, DU-24A, DU-24B and DU-24C. However, further analysis via bioaccessible arsenic did not detect concentrations of bioaccessible arsenic that exceed the Tier 1 EAL. The requirements and recommendations listed in the report will be followed. Potential Environmental Impact from Proposed Action The soil contaminants found in the soil screening survey pose potential environmental hazards should there be any direct exposure of construction workers, site personnel, and future users of the site to contaminated soil during project activities. The Conceptual Site Model (CSM) outlines the potential exposure pathways and hazards (Table 3). The CSM identifies the hazards to be limited to direct exposure to construction workers through dust or vapors during remediation. There is no identified risk to the general public. Any potential impacts from the contaminants in 39 Conceptual Site Model Primary Sources Primary Release Mechanism Secondary Sources Potential Environmental Hazards Hazard Present Under Current Site Conditions Presence of arsenic in soil Improper handling of contaminated soil during site remedial activities Soil Risk to Human Health Exposure Type Secondary Release Mechanism Exposure Route Receptors Construction Workers Offsite Residents/General Public During Remediation Post-Remediation During Remediation Post-Remediation Direct Exposure Dust/Vapors Ingestion Yes No No No Dermal Yes No No No Inhalation Yes No No No Vapor Intrusion into Buildings Vapors Inhalation No No No No Leaching During Remediation - No expected Post-Remediation – No Gross Contamination During Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Post-Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Groundwater Risk to Human Health Exposure Type Secondary Release Mechanism Exposure Route Receptors Onsite Workers Offsite Residents/General Public During Remediation Post-Remediation During Remediation Post-Remediation Direct Exposure Dust/Vapors Ingestion No No No No Dermal No No No No Inhalation No No No No Vapor Intrusion into Buildings Vapors Inhalation No No No No Leaching During Remediation -No During Remediation -No Gross Contamination During Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Post-Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Table :3 Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic the soil will be mitigated through strict adherence to the requirements and recommendations of the soil report. Medical facilities generate a variety of hazardous waste, which requires specialized handling and disposal procedures. Effective waste management practices are vital to ensure the safety of staff, patients, and the environment. Petroleum products may be used for landscaping equipment such as lawnmowers, weedwhackers, and other machinery for general maintenance. Petroleum products can be considered hazardous if not handled or stored properly. Compliance with Department of Health mitigation and remediation procedures will ensure potential impacts relating to Hazardous Materials will not change appreciably under any alternative action, except a no action alternative. Mitigating Measures Appropriate mitigating measures outlined in the soil screen report will be strictly adhered to. This will include the following: • Assume subsurface soils ≥ 12” bgs within DU-23, DU-24A, DU-24B and DU-24C boundaries are arsenic-impacted soils until further testing determines otherwise. • Contaminated soil removed from the Subject Site must be disposed of in accordance with Federal and State rules and regulations. • Dust control practices should include both wetting during soil disturbance activities and monitoring by a designated competent person, in addition to containing temporary soil stockpiles. • Use of good general hygiene practices for tenants, public, employees and workers to avoid soil exposure. • Long-term controls should be implemented on the site to minimize the potential for exposure to contaminated soil by tenants, public, employees and workers • Possible need to cover any bare soil, if subject to wind or water transport off-site. • Limit exposure to the contaminated soils to properly trained personnel. • Prepare and submit for approval to the DOH HEER office a C-EHMP which outlines the proper handling and management of soil and/or groundwater, sampling and analysis protocol for soil, the planned re-use/disposal locations for excavated soil, health and safety measures to be taken to protect workers, environment and the general public. The project specific C-EHMP must be approved by the DOH HEER office prior to the start of any construction activity that disturbs the identified contaminated soils at the Subject Site. • Have air monitoring conducted for airborne arsenic-impacted dust by qualified personnel during any contaminated soil disturbance. If at any time, any additional hazardous substances or waste are discovered on the property during construction, all work will cease, and appropriate authorities will be contacted. A remediation specialist will be contacted to supervise the appropriate disposal and management of 41 substances deemed necessary. HBMC will require all users and occupants of the proposed facilities to follow all government regulations pertaining to hazardous and toxic substances. All petroleum products, pesticides, and herbicides used for landscaping purposes will be stored properly in a secure location. Personnel who have completed the proper education and training will be the only qualified individuals to handle such products, which will only be used according to the original label on the container. Material Safety Data Sheets (MSDS) must be made readily available and visible in an appropriate area. Personal Protective Equipment (PPE) will be used at all times and checked regularly. Following the guidelines of State and County requirements, to minimize the possibility for spills and hazardous materials during construction, HBMC proposes the following: • Unused materials and excess fill (if any) will be properly disposed of at an authorized waste disposal site. • During construction, emergency spill treatment, storage, and disposal of all hazardous materials, will be explicitly required to meet all State and County requirements, and the contractor will adhere to “Good Housekeeping” for all appropriate substances, with the following instructions: o Onsite storage to minimum practical quantity of hazardous materials necessary to complete the job; o Fuel storage and use will be conducted to prevent leaks, spills or fires; o Products will be kept in their original containers unless non-resealable, and original labels and safety data will be retained o Disposal of surplus will follow manufacturer’s recommendation and all regulations; o Manufacturers’ instructions for proper use and disposal will be strictly followed; o Regular inspection by contractor to ensure proper use and disposal; o Onsite vehicles and machinery will be monitored for leaks and receive regular maintenance; o Construction materials, petroleum products, wastes, debris, and landscaping substances (herbicides, pesticides, and fertilizers) will be prevented from blowing, falling, flowing, washing or leaching into the ocean; and o All spills will be cleaned up and properly disposed of immediately after discovery. 3.1.10 Solid Waste Environmental Setting The County of Hawai‘i Solid Waste Division operates the landfill and transfer stations on island. There is only one landfill on island, the West Hawaii Sanitary Landfill, which is located approximately 57 miles from the subject site. The nearest transfer station is located approximately 2 miles away in Keaʻau. Solid waste is expected to be generated by standard 42 operational activities of the medical center. All solid waste will be properly recycled and/or disposed of in accordance with County and State DOH rules. Potential Environmental Impact from Proposed Action The quantity of waste to be produced from the medical facility is not known. However, a solid waste management plan will be developed prior to any project activities to determine potential impacts and appropriate mitigating measures. Potential impacts relating to solid waste will not change appreciably under any alternative action, except a no action alternative. Mitigating Measures During operation, local waste management companies will be contracted to dispose of waste on site. HBMC will also plan for recycling stations throughout the facilities. Waste disposal will adhere to Department of Health regulations as outlined in HAR §11-104.1 and §11-58.1. Additionally, HBMC will comply with the following regulations outlined by the Hawai‘i County Department of Environmental Management (DEM) Solid Waste Division: • Commercial operations, State and Federal agencies, religious entities and non-profit organizations may not use transfer stations for disposal. • Aggregates and any other construction/demolition waste should be responsibly reused to its fullest extent. • Ample room should be provided for rubbish and recycling. • Green waste may be transported to the green waste sites located at the West Hawai‘i Organics Facility and East Hawai‘i Organics Facility, or other suitable diversion programs. • Construction and demolition waste is prohibited at all County Transfer Stations. • All construction and demolition waste shall be transported to the West Hawai‘i Sanitary Landfill for disposal. HBMC will also submit a Solid Waste Management Plan (SWMP) completed by a licensed engineer or architect in accordance with DEM guidelines. The SWMP will be used to: 1. Promote and implement recycling and recycling programs. 2. Predict the waste generated by the proposed development and anticipate the impacts on County Solid Waste Management Facilities. 3. Predict the additional vehicular traffic being generated because of waste and recycling transfers. According to DEM guidelines, the SWMP will contain the following: 1. A description of the project and the potential waste that may be generated: e.g. analysis of anticipated waste volume and composition. This includes waste generated during the construction and operation or maintenance phases. Waste types shall include (but not be limited to): 43 a. Organics (including food waste and green wastes); b. Construction and demolition materials; c. Paper (including cardboard); d. Metal (including ferrous and non-ferrous metals); e. Plastic; f. Special (including ash, sludge, treated medical waste, bulky items, tires); g. Hazardous (including paint, vehicle fluids, oil, batteries); and h. Glass. 2. Indicate onsite source separation by waste type, e.g. source separation bins for glass, metal, plastic, cardboard, aluminum, etc. Provide ample space for rubbish and recycling. 3. Identification and location of the proposed waste reduction, waste re-use, recycling facility or disposal site and associated transportation methods for the various components of the development’s waste management system, including the number of vehicle movements and associated routes that will be used to transport the waste and recycled materials. 4. The report will include identification of any impact to County-operated waste management facilities, and the appropriate mitigation measures that will be implemented by the development to minimize these impacts. 5. Analysis will be based on the highest potential use or zoning of the development. 3.2 Socioeconomic and Cultural 3.2.1 Land Use Environmental Setting Puna is desirable for its relatively inexpensive land, which typically ranges in size from 1 to 3 acres. Residents from the U.S. mainland and other parts of the State of Hawai‘i continue to seek these affordable properties. The basis of the economy of Puna has evolved from cattle ranching and sugar to diversified agriculture and tourism stimulated by Kīlauea volcano. The Puna District is a significant socioeconomic area for Hawai‘i County. It is the leader in the agriculture industry on the Island of Hawai‘i. Some Puna subdivisions between Pāhoa and Hilo (including Hawaiian Paradise Park, Hawaiian Beaches, and Hawaiian Shores), are now primarily bedroom communities for Hilo’s workforce. Kea‘au has become a convenient central hub for services within the Puna District including grocery and retail stores, restaurants, cafes, gas stations, and healthcare facilities. The subject property and the adjacent parcels to the south, west, and northeast are zoned Agricultural – 20 acres (A-20a). To the north is the Shipman Business Park, which is zoned MG-20. To the east there are also various residential, family agricultural, and industrial zoned properties. Kea‘au Village Center is located to the southeast with mixed commercial and residential zoning. A portion of the subject property is zoned MCX-20, which was rezoned from A-20a in 2002 under Ordinance No. 02-023. The property is located within 1.5 miles of multiple schools, all located to the south. These include Kea‘au High School, Kea‘au Middle School, Kea‘au Elementary, Kea‘au Preschool, Kamehameha Schools Hawaiʻi, Christian Liberty Academy, Ke Kula ‘o Nāwahīokalani‘ōpu‘u Iki Lab Public Charter School, and Pūnana Leo o Hilo. 44 Potential Environmental Impact from Proposed Action The proposed development aligns with the existing and proposed land use patterns in the surrounding area, characterized by a mix of schools, businesses, housing, and community spaces. Potential impacts to land use will not change appreciably under any alternative. Mitigating Measures The proposed land use will require a Use Permit and Special Permit approved by the County Windward Planning Commission to ensure the proposed use is compatible and complies with all land use laws. 3.2.2 Socioeconomic Characteristics Environmental Setting According to the 2022 United State Census Bureau, the two most populated census county divisions (CCD) within the Puna District are the Keaʻau-Mountain View CCD, with a population of 41,210 and a median household income of $65,750 and the Pāhoa-Kalapana CCD, with a population of 10,494 and a median houshold income of $38,162. These average median incomes are notably lower than the State median of $83,173. Furthermore, a significant 58% of families in State House District 4, which contains the majority of the Puna District, are classified as Asset Limited, Income Constrained, Employed (ALICE), a term used to describe households in the community earning more than the Federal Poverty Level, yet falling short of covering the basic cost of living in Hawai‘i County, often despite working multiple jobs (ALICE Threshold, 2022; American Community Survey, 2022). Even though these households are employed, they grapple with meeting essential expenses such as housing, childcare, food, transportation, and healthcare. By far, the largest employment industry in both CCDs is educational services, health care and social assistance, which comprises approximately 25.9% of the Kea’au-Mountain View CCD workforce (Figure 7) and 33.1% of the Pāhoa-Kalapana CCD workforce (Figure 8). 45 Figure 7: Employment Industries in Kea‘au-Mountain View CCD Figure 8: Employment Industries in Pāhoa-Kalapana CCD 46 Potential Environmental Impact from Proposed Action The proposed project will have a positive impact on socioeconomic characteristics in the Kea‘au area and larger Puna District by stimulating economic growth through job creation and increased access to essential healthcare services. In the short term, the project is estimated to create upwards of 50 full-time & temporary jobs related to the design and build-out phase of the project. These jobs will include professional services (i.e. architectural, engineering, etc.) as well as trade workers (i.e. contractors, builders, masons, electricians, plumbers, landscapers, etc.). In the long term, the proposed medical facility is anticipated to create approximately 120 full-time positions. These positions would include medical professionals, administrators, therapists, social workers and maintenance and custodial workers. As noted above, the primary labor industry in the area is educational services, health care and social assistance. Employees are anticipated to be primarily Puna and Hilo residents making the creation of additional health care and social assistance jobs appropriate for this area. Furthermore, in addition to alleviating travel time for patients who would otherwise have to go to Hilo to receive health care services, the creation of additional health care related employment opportunities in Puna will decrease commute times for health care workers living in the Puna District. Mitigating Measures The project is expected to have a measurable positive impact on socioeconomic characteristics through the creation of over 170 short and long-term employment opportunities and increased access to healthcare services for Puna residents. Therefore, no mitigating measures are required. 3.2.3 Parks and Recreation Environmental Setting Herbert Shipman Park is located approximately 0.3 miles south of the subject parcel. Potential Environmental Impact from Proposed Action The proposed action will have negligible impact on nearby parks and recreation activities. Public access to the parks and ocean will not be impacted by the request. This will not change under any action alternative. Mitigating Measures No mitigating measures are expected to be necessary for parks and recreation. 47 3.2.4 Cultural and Historic Resources Environmental Settings Ahupua‘a Hawaiʻi is believed to be first inhabited by voyagers from the Marquesas around 1,000 A.D, however, recent studies have shown that initial Polynesian colonization of Hawaiʻi Island occurred between 1220 and 1261 A.D. Early Hawaiian settlements incorporated new strategies and structures to adapt to their new environment. Traditional Polynesian philosophies and ideals were used to form new societal standards and structures including the principle of genealogical seniority, observance of gods such as Kāne, Ku, and Lono, the kapu system of law and order, ahupuaʻa land systems, and various beliefs and values that determined day-to-day protocol and lifestyle such as mana and the ‘aumakua. It is believed that Hilo is likely one of the first settlements on Hawai‘i Island. Hilo is known to have rich marine resources accessed at Hilo Bay and additional abundant resources from the forests that descend from Mauna Loa and Mauna Kea. Ancient Hawaiians understood the critical importance of fresh water. Fresh water streams and springs were believed to be created by the gods Kāne and Kanaloa, which established a spiritual connection between people and water. In accordance with the native Hawaiians respect for water, land management units were organized around freshwater supplies in a traditional system known as the ahupua‘a resource-management system (CWRM, 2019). According to the Water Resource Protection Plan, “water was viewed as such a critical resource to the health and well-bring of the people of ancient Hawai‘i, that the concept of private ownership did not exist” (CWRM, 2019). The ahupua‘a system, divided near the end of the 16th century, or early 17th century, was designed to provide all the necessary resources to live including agricultural resources inland and ocean resources at the coast. The subject property is located within the Kea‘au Ahupua‘a. Puna District The earliest documentation of Hilo is found in ʻUmi-a-Liloa’s conquest of Hawai‘i Island in the sixteenth century, which established Hilo as a royal center for the island. In the account, ‘Umi-a-Liloa began his conquest of the Island of Hawai‘i by defeating chief Kulukulu‘ā, who lived in Waiākea, and the other chiefs of Hilo. ʻUmi-a-Liloa’s son Keawe-nui-a-ʻUmi ruled Hamākua, Hilo and Puna. After the death of Keawe-nui-a-ʻUmi, the ruling kingdom was divided into three parts and was established under warring chiefs (Kamakau, 1992). In 1738 Kamehameha I was born. Chief Kalani‘opu‘u was the high chief during Cook’s arrival in 1779. After the chief’s death in 1782, his son Kiwala‘o, and his nephew, Kamehameha I began to compete for control of the west side of Hawai‘i Island. Kamehameha won the battle of Moku‘ohai against Kiwala‘o in Kona, officially controlling the western half of the island. In 1791, Kamehameha, having gained control of Hilo, fought, and won a battle against his cousin Keoua at Kawaihae for control of the entire Island of Hawai‘i. In 1795, Kamehameha conquered 48 Maui, Moloka‘i, Lana‘i and O‘ahu. He also received Kaua‘i by cession in 1810 (Kamakau, 1992). Kamehameha’s son Liholiho was born in Hilo in November 1797. Waiākea was inherited by Lihiliho after Kamehameha’s death. The ‘ili kūpono of Pi‘opi‘o and its royal fishpond were given to his favorite wife, Ka‘ahumanu (Escott and Dols, 2020). The Puna District was originally one of six chiefdoms or moku of the island of Hawai‘i. Puna was not a district that produced any great and powerful chiefs; the area was often controlled by chiefs and rulers from the Hilo District to the north, or the Ka‘u District to the south (Cordy, 2000). Puna is historically known for its rich soils, high rainfall, and frequent volcanic activity. Many parts of the district have been covered in lava over the past 1,000 years. The coastal areas are characterized by thin soil and steep volcanic cliffs, which are met by rough and wind-blown ocean. Historic settlement patterns reflected favorable agricultural activities, which were found inland from the coast. Villages were often spread out across large areas and abundant in population (Kelly et al. 1981). The Puna District is known for its valuable products, such as hogs, gray kapa cloth (‘eleuli), tapas made of mamaki bark, fine mats made of young pandanus blossoms (‘ahuhinalo), mats made of young pandanus (Hala) leaves (‘ahuao), and feathers of the ‘o‘o and mamo birds. Puna was also famous for its abundant ulu (breadfruit) (Ellis, 1963). Neighboring villages in the ʻOlaʻa Ahupuaʻa were known for their hand made products. These two Ahupuaʻa were important sources of forest and agricultural products for the ruling elite in Hilo. In 1839, King Kamehameha III signed the Bill of Rights, which sought to ensure that the people’s land would not be taken from them. In 1840, the first Constitution of Hawai‘i was enacted. In 1845, the Land Commission was created by Kamehameha III to award land claims, although this could not be done under the current feudal system of land tenure as individuals did not hold title to the land. In 1848 The Great Māhele (Land Division) established a system of private land ownership, which divided all Hawai‘i’s land into three classifications: Crown Lands, Government Lands and Konohiki Lands. The Keauohana, Kehena Ahupua‘a was deemed Government Lands. Crown, Government and Konohiki lands remained subject to the rights of the kanaka who were in possession and cultivating the lands. As land sales between the Crown, Government and Konohiki continued, the rights of the kanaka became an issue. In 1850, the Land Commission moved to award title of land to kanaka who remained in physical possession, cultivated, or improved any portion of Konohiki Lands. These became Kuleana Lands. Very few Kuleana Land claims were made during the Māhele for Puna (McGregor, 1999). Only 19 Land Commission awards were granted in the entire Puna District. Of these, 16 awards were made in large tracts to 10 chiefs who lived outside of Puna. The ahupua‘a of Kea‘au was granted to William C. Lunalilo as part of Land Commission Award (LCA) 8559-B. In 1893, the Hawaiian Monarchy was overthrown, and Queen Liliuokalani was imprisoned. The remaining Crown Lands were confiscated by the government and made a part of the public domain (Chinen, 1961). Between 1845 and 1900 Hilo began to significantly change through the increased presence of foreign vessels, expansion and growth of tourism, the establishment of missions, private land ownership legalization, the presence of the whaling, cattle, and sugar industries, and the 49 construction of Government roads and railroad lines (Kelly et al. 1981). The changes that occurred in the Hilo district began to dictate and impact surrounding districts such as the Puna district to the south. Changes and patterns of residential locations and growth of towns and villages in the Puna district were driven by the demand for agricultural products, thus prompting settlement near land suited to commercial crops and near newly constructed roads and transportation networks. In 1882, the entire Kea‘au Ahupua‘a was purchased by William H. Shipman who operated cattle ranches across the island in places such as Kapoho, Waiakea, and Kea‘au. Portions of Kea‘au Ahupua‘a were leased to the Ola‘a Sugar Company in 1899. The expansion and operation of the Ola‘a Sugar Company led to the construction of the sugar mill in Kea‘au, numerous sugar company camps, which created and influenced modern day Kea‘au as a small residential and commercial center in the district. Ola‘a Sugar Company became the largest sugar cane operation in the district. It was eventually sold to American Factors (AMFAC) in 1969, who expanded production to include a bagasse and trash burning power plant that produced 12.5KW of power for Hawaiian Electric Light Company (HELCO). By 1982, AMFAC closed Puna Sugar Company and sold it to Fiji Sugar Corporation in 1988. Potential Environmental Impact from Proposed Action Archaeological Although an archaeological survey was not conducted on the site, it is highly unlikely any such resources exist due to the prior clearing of the property and its use for agriculture. The subject site has been cleared repeatedly and used extensively for agricultural purposes, primarily for sugarcane production. Aerial imagery from 1965 and present day shows the extent of clearing and land disturbance for agricultural use on the property in relation to the project area (Figure 9). Further, imagery from 2019 compared to present day shows that significant clearing and agricultural use of the property have occurred recently (Figure 10). The entirety of the project area has been affected, and it is highly unlikely any historic resources exist in the area. Rechtman Consulting, LLC conducted an Archaeological Assessment of an approximately 112 Acre portion of TMKs (3) 1-6-003:007 and (3) 1-6-146:017 in September of 2004 (Appendix F). That assessment, which included the entirety of the subject project area, produced no evidence of early historic or traditional Hawaiian remains. The survey confirmed that most of the area consisted of fallow sugarcane fields. The small, seemingly uncultivated portion of the assessed area was intensively surveyed and contained no cultural remains. The assessment recommended that no further archaeological work need be conducted of the area prior to development. That report was accepted by SHPD on February 16, 2005. Additionally, Scientific Consultant Services (SCS) conducted an Archaeological Inventory Survey (AIS) of approximately 254.1 acres of the broader W.H. Shipman property in Keaʻau, which encompasses and surrounds the project site (Escott, G.G., 2018). “Area C” in that study includes the area of the proposed access road. Fieldwork was conducted between January and December 2016, and SCS submitted the AIS to the State Historic Preservation Division (SHPD) for review in May 2017. The survey was conducted in accordance with Hawaiʻi Administrative Rules 13-284 and the Rules Governing Minimal Standards for Archaeological Inventory Surveys 50 and Reports contained in Hawaiʻi Administrative Rules 13-276. In a letter dated February 12, 2018, SHPD accepted the findings and recommendations of the AIS. Additionally, an earlier archaeological field investigation conducted by SCS in July 2014 covering adjacent portions of the Shipman property was accepted by SHPD in a letter dated September 4, 2014, with SHPD concurring that no historic properties would be affected within that surveyed area. The AIS identified three surface historic properties within the broader Shipman Master Plan Area: Site TS-001 (consisting of six plantation dwellings and six garden features associated with Luna Row) and Site TS-002 (a rock wall enclosing the former plantation doctor’s house lot). Both sites are associated with historic-era plantation housing constructed between the early 1900s and the 1950s. Thirteen (13) historic era sugarcane features (SIHP 50-10-44-30646), consisting of twelve (12) rock clearing mounds and a retaining wall were also documented in the AIS. No pre-Contact archaeological sites were identified within any of the surveyed portions of the Shipman property. All three sites were adequately documented and SHPD concurred that no further work was necessary. Based on historical research and prior archaeological studies, the Keaʻau area was not known to be inhabited prior to its development as a sugar plantation town. Plantation-era foundations, footings, and constructed boundaries from the early to mid-1900s may remain on portions of the broader Shipman property; however, these site types are not anticipated within the subject 20-acre project area given its uninterrupted history of sugar cultivation and repeated land clearing. Aerial imagery from 1965 and present day confirms the extent of clearing and land disturbance for agricultural use (Figure 9). Imagery from 2019 compared to present day further confirms that significant clearing and agricultural use of the property have continued (Figure 10). The entirety of the project area has been heavily disturbed by sustained agricultural operations, and it is highly unlikely that any pre-Contact or historic archaeological resources remain within the project area. Cultural PBR HAWAII prepared a Cultural Impact Assessment (CIA) for the Keaʻau Village Master Plan, which covers the W.H. Shipman property that encompasses the subject project site (PBR Hawaii & Associates Inc. 2017). The CIA provides detailed information on the cultural and historical context of the Keaʻau ahupuaʻa, prior archaeological work, and summaries of community consultations regarding cultural practices in the area. The findings and conclusions of the CIA are applicable to the subject project site, as it is located within the same ahupuaʻa and on the same landholding. Key cultural background and findings from the CIA are summarized below. 51 Aerial Images of TMK (3) 1-6-003: 127 and Project Area Figure 9 Hawaii Statewide GIS Program United States Geological Survey (USGS) County of Hawaii United States Department of Agriculture (USDA) Esri National Oceanic and Atmospheric Administration (NOAA) Aerial Images of TMK (3) 1-6-003: 127 and Project Area Figure 10 Nā ʻŌlelo Noʻeau Many ʻōlelo noʻeau (Hawaiian proverbs and poetical sayings) speak to the people and natural elements of Puna and Keaʻau, and to connections with the Hawaiian deities Kāne and Pele. Among those recorded in the CIA are: He ike hala au no Keaʻau, ʻaʻohe pōhaku ʻalā e nahā ai — “I am a small hala fruit of Keaʻau, but there is no rock hard enough to smash me” (the boast of a Puna man — I am small, perhaps, but mighty) (Pukui, 1983; No. 624); Ka makani hali ʻala o Puna — “The fragrance-bearing wind of Puna,” referring to Puna’s fame for the fragrance of maile, lehua, and hala carried to fishermen at sea (Pukui, 1983; No. 1458); and Ka ua kāhiko hala o Keaʻau — “The rain that adorns the pandanus trees of Keaʻau,” referring to the pandanus grove of Keaʻau, Puna (Pukui, 1983; No. 1560). Moʻolelo By cultural tradition, Kīlauea is home to the goddess Pele, giving the volcano and its surroundings sacred status. Ancient Hawaiians recognized Puna as Pele’s land, with human habitation subject to Pele’s will. Many legends record Pele’s interactions with Puna chiefs. The Legend of Kumukahi and The Legend of Kahawali are both set in the Puna District and speak to the sacred relationship between the Hawaiian people and the volcanic landscape (Westervelt, 1916). Community Consultations and Traditional Practices The CIA includes information from community consultations and “talk story” interviews with individuals knowledgeable about the cultural resources and practices of the Keaʻau area. A review of these consultations did not reveal or identify historic or cultural resources or practices that may be adversely affected by development within the project area. Ongoing cultural activities in the broader Puna District include those at the Makuʻu Farmers Market, the Kamehameha Schools Hawaiʻi campus, ʻAha Pūnana Leo, and Ke Kula ʻO Nāwahīokalaniʻōpuʻu, all of which are located outside the project area. The ʻōlelo noʻeau and cultural traditions of Keaʻau speak to the lush vegetation of these lands, including maile, lehua, and hala. The people of Puna were historically known as master weavers; cultural practices including lāʻau lapaʻau (Hawaiian herbal medicine) and the gathering of lauhala (pandanus leaf) for weaving were recorded and continue to be practiced in the broader Puna District. The subject project site, given its long history of commercial sugarcane cultivation and repeated clearing, does not appear to contain the native plant resources typically associated with traditional Hawaiian gathering practices. The Hawai‘i State Supreme Court’s PASH and Ka Pa‘akai O Ka ‘Aina decisions require decision-makers to consider a project’s impact to native Hawaiian practices and resources. Specifically, prior to making a decision, State and County agencies must identify the cultural, historical, and natural resources and associated traditional and customary practices of the subject site, the impacts of the proposed project to those resources and practices, and the feasible action (i.e. mitigating measures), if any, to protect such resources and practices. It is not known whether the subject property or immediate surrounding area have ever been used for the gathering of plants by native Hawaiians in the past. However, it would appear very unlikely that the site would serve such a purpose today and/or in the recent past due to past 54 commercial agricultural use. Therefore, it does not appear that the project would have any potential adverse impact relating to cultural practices in the area. These potential impacts will not change appreciably under any alternative. Based on the CIA prepared by PBR HAWAII, the AIS conducted by Scientific Consultant Services, and the Archaeological Assessment conducted by Rechtman Consulting, LLC for the broader Shipman property, and consistent with the Hawaiʻi State Supreme Court’s PASH and Ka Paʻakai O Ka ʻAina decisions, no significant adverse impacts to cultural resources, traditional practices, or gathering rights are anticipated from the proposed project. Archeological studies conducted throughout the Keaʻau area since the 1990s have not found evidence of pre-Contact habitation or traditional resource use within the sugarcane cultivation areas of the property; rather, they have identified only sites related to plantation-era railroad, commercial sugar, and residential uses during the Historic or Modern eras. No cultural informants or community consultees identified cultural resources or practices that would be adversely impacted by the proposed development. These conclusions will not change appreciably under any alternative. Mitigating Measures In the event any undocumented archaeological or cultural resources are found on site, all work will cease in the immediate area of the find, and the State Historic Preservation Division will be contacted for appropriate action. Construction documents for the proposed project will include a provision that should any undocumented archaeological or cultural resources — including artifacts, shells, bones, midden deposits, charcoal deposits, lava tubes, stone platforms, pavings, or rock walls — be encountered during grading or construction, all work in the immediate vicinity of the find will cease and the State Historic Preservation Division (SHPD) will be contacted to determine the significance of the find and to approve an acceptable mitigation plan as needed. If human burials are encountered, they will be treated in accordance with the specific provisions of Chapter 6E, HRS. 3.3 Public Roads, Services, and Utilities 3.3.1 Roads and Access Environmental Setting The property is currently accessed via a partially paved driveway off Hawaiʻi Belt Road approximately 640 feet north of the intersection with Keaʻau Bypass Road and an unpaved road through the adjacent Shipman property to the south. The proposed access to the medical clinic would be from a new proposed access driveway. The driveway is proposed to be constructed off Route 11 and Route 139 to connect the Medical Clinic to Shipman Park Driveway at Route 11. It is proposed to run east-west from Shipman Park Driveway before turning north-south, connecting to the proposed Medical Clinic. WHSL plans to subdivide a separate roadway lot that will be used to access future developments as well 55 as the medical clinic. The road will eventually be constructed to county dedicable standards, however, will be initially constructed as a driveway for the clinic. Proper standards for road development will be determined by conditions of the Use Permit and Special Permit. Potential Environmental Impact from the Proposed Action A letter requesting comments was sent to the Hawaii Department of Transportation (HDOT) on July 24, 2025. In a letter dated August 27, 2025, the HDOT indicated that a Traffic Impact Analysis Report (TIAR) should be prepared. This correspondence can be found in Appendix B. SSFM International was contracted to perform the TIAR. Their office corresponded directly with the HDOT to ensure a thorough evaluation of traffic impacts in accordance with the requirements of the HDOT. SSFM received concurrence via email from HDOT that the intersections that were included in the study were adequate. The Traffic Impact Analysis Report (TIAR) was completed in September 2025, by SSFM International to evaluate potential traffic impacts from the proposed project based on Existing Conditions (2025), and Future Without Project and Future With Project Conditions in 2028. The TIAR analyzed peak period turning movements at the following four (4) intersections based on three (3) Hawai‘i Department of Transportation 24-hour traffic count locations (Figure 11). Study Intersections: 1. Route 11 and Route 130 2. Route 11 and Route 139/Shipman Park Driveway 3. Route 11 and Paʻahana Street/Naʻauao Road 4. Route 130 and Route 139 HDOT 24-Hour Traffic Count Locations A. Route 11 between Old Volcano Road to Paʻahana Street B. Route 130 between Kea‘au Bypass Road to Kukula Street C. Route 139 between Kea‘au Pāhoa Road to Kea‘au Kula Road 56 Figure 11: Map of Study Intersections and 24-Hour Traffic Count Locations 57 Several other intersections in the area were not analyzed by the TIAR. Analysis of the intersection of Route 11 and Kipimana Street was determined, in consultation with HDOT, to be unnecessary due to project trip expectations. As most project trips are expected to originate from or travel to the communities of Kea‘au, Pāhoa, or Mountain View, and very few trips are expected to be associated with travel to or from Hilo, this intersection is not expected to be impacted by the project. Additionally, the intersection of Old Volcano Road and Route 139 was analyzed in three previous traffic reports in the area from 2020, 2023, and 2024. The intersection operated at an acceptable level of service or better in each report and was therefore assumed not to require further analysis. SSFM International consulted with DOT regarding the choice of study intersections for the TIAR. The TIAR was submitted to HDOT in October 2025 and to date no comments have been received. Turning movement counts were taken on Wednesday, May 7, 2025, at the designated study intersections. Counts were observed from 6:30-8:30 AM and 3:00-5:00 PM and peak hours were found to vary between the study intersections. The AM and PM peak hour at the Route 11 and Route 130 intersection was selected to be used for the study given the project location off Route 11. The resulting peak hours were determined to be 6:45-7:45 AM and 3:00-4:00 PM. Existing (2025) intersection Levels of Service for AM and PM peak hours were determined using Synchro 11 traffic analysis software. Level of Service is a quantitative measure used to describe the conditions of traffic flow at intersections, with values ranging from free-flow conditions at LOS A, with little to no delays, to congested conditions at LOS F, where extreme delays exist. Guidelines state that LOS D or better is appropriate for the study intersection and movements. Existing (2025) Intersection LOS Analysis The following are the existing (2025) LOS at each study intersection. All study intersections operated at an overall acceptable LOS; however, several left-turn movements were found to operate at LOS E during AM or PM peak hours. The remaining study intersections had all movements operate at LOS C or better (Table 4). 1. Route 11 and Route 130 a. All movements occurred at LOS C or better. 2. Route 11 and Route 139/Shipman Park Driveway a. The Route 11 southbound left turn operates at LOS E (v/c of 0.89 and v/c of 0.92) during the AM and PM peak hours, respectively. 3. Route 11 and Paʻahana Street/Naʻauao Road a. The Route 11 northbound and southbound left turns operate at LOS E (v/c of 0.31 and v/c of 0.61) during the PM peak hour. 4. Route 130 and Route 139 a. The Route 130 northbound left turn operates at LOS E (v/c of 0.87) during the PM peak hour. 58 Table 4: Existing (2025) LOS Future Without Project Conditions A. Background Growth Rate The historical average annual daily traffic (AADT) data for Route 11, 130, and 139 within the study area between 2016 and 2022 demonstrated annual growth rates ranging from 0.46% to 3.86%. According to the Federal-Aid Highways 2035 Transportation Plan for the District of Hawai‘i, the forecast anticipates a compounded annual increase of 2.12% in traffic within the planning district of Puna from 2020 to 2035. A 2.12% compounded annual growth rate was therefore applied to through volumes on Route 11, 130, and 139, as well as to the southbound left-turn movement from Route 11 to Route 130 and the westbound right-turn movement from Route 130 to Route 11, given their regional significance between Hilo and Pāhoa. This forecasted growth rate reflects the anticipated 59 future growth within the area and accounts for developments that may be completed but not individually included in the 2028 background growth projection. B.Surrounding Projects 1.HS17 Kea‘au -Pāhoa Route (Route 130) Improvements, Kea‘au Bypass to Pāhoa- Kapoho Road Research was completed in July 2025 for the Statewide Transportation Improvements Program (STIP) four year forecast outlining state and county transportation projects. One project, HS17 Kea‘au -Pāhoa Route Improvements, is in the vicinity of the proposed medical clinic and may impact traffic operations in the area. This project proposes improvements to improve traffic circulation and safety along Route 130. However, no estimated construction timeline is available at this time. 2.Kea‘au Village Master Plan The Kea‘au Village Master Plan was proposed to construct 590 single-family homes, 350 multi-family homes, 220,408 square feet of commercial space, 43,600 square feet of office space, and 100 hotel rooms. The project was expected to be completed over 2023, 2028, and 2038. However, construction has not yet started, the project is delayed, and there is no current updated estimation on the completion of the Kea‘au Village Master Plan. Given this, it is assumed that no construction will begin within the three-year timeframe between the Existing conditions and the Kea‘au Villages Master Plan Future occupation year. Therefore, it is expected that the development of the Kea‘au Village would not impact the traffic operations of the proposed Medical Clinic. Traffic data for the Master Plan’s TIAR was collected in 2015 and 2016 and as such is not an ideal reference for additional traffic information to supplement the medical clinic TIAR. In addition, the development of the proposed medical clinic will not interfere with the future implementation of the Kea‘au Village Master plan but would instead compliment the vision of the plan by adding essential and beneficial services to the Keaʻau town center. 3.Kea‘au Mountain View Public Library A 12,000 square foot public library is proposed northeast of the intersection of Route 139 and Old Volcano Road to replace the existing library at the Kea‘au Middle School and Mountain View Elementary School. The project is expected to be complete by 2027 and therefore was included in the subject project’s traffic analysis. The library is projected to generate 42(43) AM(PM) peak hour trips and these trips were included in the Future Without Project and Future With Project conditions. C.Future (2028) Without Project Traffic Volumes 60 Projected traffic volumes for Future (2028) Without Project were determined by combining Future (2028) background growth volume with projected trips generated from the Kea‘au Mountain View Public Library (Figure 12). The following are the Future (2028) Without Project LOS at each study intersection (Table 5). 1. Route 11 and Route 130 a. All movements occurred at LOS D or better. 2. Route 11 and Route 139/Shipman Park Driveway a. The Route 11 southbound left turn operates at LOS E (v/c of 0.94) during the PM peak hour. 3. Route 11 and Paʻahana Street/Naʻauao Road a. The Route 11 northbound left turn operates at LOS F (v/c of 0.36) during the PM peak hour. b. Four movements operate at LOS E during the PM peak hour: Route 11 southbound left turn (v/c of 0.63), Paʻahana eastbound left turn (v/c of 0.57), Paʻahana eastbound left-through-right (v/c of 0.48), and Naʻauao westbound left- through-right (v/c of 0.08). 4. Route 130 and Route 139 a. The Route 130 northbound left turn operates at LOS E (v/c of 0.88) during the PM peak hour. 61 Figure 12: Future (2028) Without Project Intersection Peak Hour Volumes 62 Table 5: Future (2028) Without Project LOS Future With Project Traffic Volumes Future traffic volumes with the proposed project were analyzed using rates developed by the Institute of Transportation Engineers (ITE) and published in the Trip Generation Manual, 11th Edition. A. Future (2028) With Project Traffic Volumes Anticipated trip distribution was determined by analyzing historic HDOT traffic volumes and the population of the surrounding area. These numbers are the sum of Future (2028) without volumes and the project generated (Figure 13). The following are the Future (2028) With Project LOS at each study intersection (Table 6). 63 1. Route 11 and Route 130 a. All movements occurred at LOS D or better. 2. Route 11 and Route 139/Shipman Park Driveway a. The Route 11 southbound left turn operates at LOS E (v/c of 0.94) during the PM peak hour. 3. Route 11 and Paʻahana Street/Naʻauao Road a. The Route 11 northbound left turn operates at LOS F (v/c of 0.36) during the PM peak hour. b. Four movements operate at LOS E during the PM peak hour: Route 11 southbound left turn (v/c of 0.63), Paʻahana eastbound left turn (v/c of 0.57), Paʻahana eastbound left-through-right (v/c of 0.48), and Naʻauao westbound left- through-right (v/c of 0.08). 4. Route 130 and Route 139 a. The Route 130 northbound left turn operates at LOS E (v/c of 0.91) during the PM peak hour. 64 Figure 13: Future (2028) With Project Intersection Peak Hour Volumes 65 Table 6: Future (2028) With Project LOS Summary and Recommended Mitigating Measures Future (2028) Without Project analysis added 2.12% annual background growth for major movements, along with the project trips associated with the Keaʻau Mountain View Public Library relocation. All signalized intersections are projected to operate at an acceptable overall LOS. Movements that are projected to operate at LOS E or worse are not significant and the TIAR did not recommend improvements for Future (2028) Without Project conditions. Based on the Trip Generation Manual 11th Edition, the project is projected to generate up to 96 total trips during the AM peak hour and 144 total trips during the PM peak hour. All signalized intersections are projected to operate at an acceptable overall LOS under Future (2028) With Project conditions. Movements expected to operate at LOS E or worse are not considered significant. Therefore, no improvements are recommended for Future (2028) With Project conditions. In addition, no changes to the intersection configuration at Route 11 and Route 66 139/Shipman Park Driveway are required to accommodate the proposed Medical Clinic generated trips. 3.3.2 Public Utilities and Services 3.3.2.1 Water Supply Environmental Setting Consultation with DWS indicates that adequate water is available for the proposed use and for fire suppression. HBMC has engaged Engineering Partners, Inc. to estimate water demand for the proposed project. Daily water demand was calculated to be 3,960 gpd on average, or 10 water units (Appendix D). The proposed clinic has a water fixture unit count of 286.5, or 109 gpm of peak hour flow. A meeting to discuss water access was held on August 18, 2025, and attended by representatives from WHS, East Hawaii Region (HER), Hawaii County, and DWS. Due to the availability of water service and the area and the community benefit provided by the proposed project, DWS has confirmed that HBMC will have access to the needed water units. Water can come from the highway and connect back to the main at Kea`au Pahoa highway. With this loop option, the project will be able to utilize an 8-inch water main instead of a 12-inch main as required for a direct connection. Potential Environmental Impact from the Proposed Action Estimated maximum daily water usage calculations, prepared by a professional engineer, licensed in the State of Hawai‘i, were submitted to DWS for review and approval. These calculations include estimated peak flow in gallons per minute and the total estimated maximum daily water usage in gallons per day, including irrigation use. Based on the water demand calculations, the Department will determine the appropriate service lateral and meter size required to satisfy all water needs including fire suppression requirements. Differences in water main or lateral/meter size would not entail any changes in the environmental impacts of the proposed action. Mitigating Measures Water conservation measures will be implemented into the project design to minimize water use. Water efficient fixtures such as low flow systems and timed shut off in appropriate areas. The Commission on Water Resource Management also recommends implementing appropriate landscaping irrigation conservation Best Management Practices endorsed by the Landscape Industry Council of Hawai‘i. These include the following installation and maintenance BMPs: Installation Best Management Practices: 67 1. Irrigation system plans and specifications should include post-construction documentation, including drawing of record (as-built drawings), maintenance recommendations, design precipitation rates and manufacturer’s operational guide. 2. Design irrigation system with sprinklers spaced with head-to-head coverage or better. 3. Irrigate with a precipitation rate not exceeding soil infiltration rate. 4. Design systems to irrigate similar hydrozones such as slope, sun exposure, soil conditions, and plant materials with similar water use. 5. Use smart controllers. 6. Encourage the use of drip irrigation for individual specimen plants, shrubs, and trees during establishment period. 7. Use flow sensors with smart controllers to detect leaks or drastic changes in water use. 8. Use an irrigation submeter that measures water use on large sites. 9. Use water conservation irrigation components, such as rotary nozzles, pressure regulated spray heads and valves, rain switches, and high efficiency nozzles. 10. Sprinklers in low-lying areas and slopes should be equipped with check valves. 11. Incorporate Low Impact Development (LID) storm water design methods, including rain gardens, infiltration beds, rain barrels, swales, and basins, that allow water to collect and soak into the ground on site. 12. Preserve existing native trees and non-invasive vegetation where feasible during development and do not install irrigation in these areas. 13. Incorporate compost into soils at planting. 14. Encourage xeriscaping practices to include native and non-invasive ornamental plants. 15. Encourage the use of non-potable water for irrigation. 16. Use a qualified irrigation designer, irrigation supplier, landscape architect and installation contractor. Maintenance Best Management Practices: 1. If not using a climate-based controller, manually manage controller run times and days to water according to soil conditions and seasonal weather conditions. 2. Program irrigation controller to encourage deep watering by using longer, less frequent watering times to improve deep rooting and increase drought resistance. 3. To reduce the amount of water evaporating from the soil surface, schedule night or early morning (5 p.m. to 9 a.m.) start times for established plantings. In areas where ponding, compaction, or runoff occurs, set 2-3 short run time cycles. 4. Mulch with wood chips around base of trees and shrub beds and refresh as necessary to maintain a minimum of two inches. 5. Allow grass to grow taller in summer months to conserve water and encourage deep rooting. 6. Aerate lawns when compaction occurs. 7. At a minimum, conduct a monthly inspection to verify system operation and correct deficiencies. 8. Conduct a practical water audit once every 2 to 5 years by a qualified irrigation professional. 68 9. Attend water conservation seminars and webinars including Board of Water Supply, Landscape Architects, University of Hawai‘i, EPA Water Sense, and the Irrigation Association. 10. Use a licensed maintenance contractor with water conservation expertise. 3.3.3.2 Wastewater Environmental Setting There is no municipal sewer system available in the vicinity of the project and onsite wastewater treatment works (WWTW) will be required. Records from the Department of Health (DOH) indicate no existing Cesspool or Individual Wastewater System on the site. Potential Environmental Impact from Proposed Action Improper management of wastewater has the potential to contaminate ground and surface waters and could pose a hazard to human health. With a properly designed and maintained WWTW the potential for environmental impacts from wastewater are minimized. Mitigating Measures The project is anticipated to generate wastewater at more than 1,000 gallons per day (gpd), mandating compliance with DOH regulations for a package Wastewater Treatment Works (WWTW) providing secondary treatment. Acceptable treatment technologies include Activated Sludge, Sequential Batch Reactor, Fixed Bed Biofilm Reactor (FBBR), Moving Bed Biofilm Reactor (MBBR), Membrane Bioreactor (MBR), or other advanced methods ensuring effluent quality aligning with DOH’s Chapter 11-62 standards. Detailed wastewater flow calculations will be prepared as part of the permit application submitted to DOH for the WWTW. No injection wells will be used; treated wastewater effluent will be infiltrated into soils through properly sized leach fields or absorption beds. The treated effluent will be disposed of underground via an absorption bed or other types of drain field. A 100% backup of disposal system is required by DOH. Due to the potential fast percolation rate, soil replacement below the absorption bed may be required for septic effluent. However, the soil replacement requirement may be waived if it is used to receive WWTW effluent. Efforts to minimize wastewater are reflected in the design of the project, including water efficient fixtures (e.g. low flow systems and timed shut off for appropriate devices in all bathroom and proposed kitchens) and landscaping practices as outlined above. Medical and clinical operations generate regulated medical waste, including sharps, biological materials, and pharmaceutical waste. These materials will be managed separately from the general wastewater stream in accordance with HAR Chapter 11-104.1 (Regulated Medical Waste) and applicable DOH guidelines, and will be disposed of through licensed medical waste disposal contractors. Such waste will not enter the onsite WWTW. 69 The WWTW will be operated and maintained by a licensed operator in accordance with DOH Chapter 11-62 requirements. An operations and maintenance (O&M) plan will be submitted to DOH as part of the permit application, detailing inspection schedules, effluent sampling and monitoring requirements, and corrective action procedures to ensure the system performs as designed and protects groundwater quality. 3.3.2.3 Electricity Environmental Setting Electricity is available to the site via Hawai‘i Electric Light Company (HELCO). Potential Environmental Impact from the Proposed Action The project would impose only modest demands on utility services and would not require any mitigation or special planning. Mitigating Measures HBMC is proposing to install solar photovoltaic and solar hot water systems for non-critical patient care areas. 3.3.2.4 Schools Environmental Setting Several schools are within the vicinity of the subject property. Kea‘au High School, Kea‘au Middle School, and Kea‘au Elementary School are all within 1.5 miles of the project site. Other schools in the general surrounding area include: Mountain View Elementary School, Christian Liberty Academy, Pūnana Leo o Hilo, Nāwahīokalani‘opu‘u, and Kamehameha Schools. Potential Environmental Impact from the Proposed Action The proposed project is not expected to impact schools. No traffic impacts are expected both during and post construction. All construction on the proposed access road will not affect intersection or school operations. During initial consultation with the DOE, consultation with school administrators in the Keaʻau area to discuss any potential vehicular or traffic impacts posed by construction to school operations was recommended. School administrators were contacted by email and provided with information regarding potential traffic impacts along with site plans for the proposed clinic and access road. Several DOE representatives were in attendance of the October Stakeholder meetings. No further comments from administrators or HIDOE were received. 70 Mitigating Measures The project would not significantly impact schools and would not require any mitigation. 3.4 Secondary and Cumulative Impacts The proposed project will not generate any long-term secondary impacts, such as population changes or effects on public facilities. Any effects on public facilities are expected to be minimal given the adherence to proposed mitigation measures. Cumulative impacts occur when the implementation of multiple separate projects with limited individual impacts combine to produce more severe impacts or conflicts. Impacts should be considered with respect to past and current impacts on area resources. Planned projects in the area that reasonably could affect area resources include: Kea‘au Village Master Plan Phase 1 and Phase 2 The proposed Master plan was projected to be completed in three construction phases over years 2023, 2028, and 2038 and would include: • 590 single-family homes, • 350 multi-family homes, • 220,408 SF of commercial space, • 43,600 SF of office space, and • 100 hotel rooms Construction for the project is currently on pause due to infrastructure costs and it is not known when it will proceed at this time. With this ambiguity it is difficult to predict when possible impacts from this development may occur. Therefore, it is assumed that should any portion of this development be completed in the next 13-16 years, it will be accounted for in the 2.12% annual background growth rate included in the TIAR calculations. Kea‘au Mountain View Public Library The Kea‘au Mountain View Public Library is proposed to be developed northeast of the intersection of Route 139 and Old Volcano Road. The proposed library will be 12,000 SF and will replace the existing library at the Kea‘au Middle School and Mountain View Elementary School. The project is anticipated to be completed in 2027 and anticipated traffic from the library has been incorporated into the TIAR calculations Although there is the potential to increase traffic above future estimated levels without the project, the total traffic is expected to be within the capacity of the system to accommodate it without significant effects. Nearly all long-term impacts from the proposed project are negligible, with no meaningful effects on ecosystems or protected species, water quality, erosion and sedimentation, historic properties, noise and air quality and other measures. The proposed project’s utility infrastructure is largely self-contained: wastewater will be treated and disposed of entirely on site through the package WWTW and leach field system, and stormwater will be managed on site in compliance with Hawai‘i County Code Chapter 27. This 71 self-contained approach avoids placing additional demand on off-site utility systems and provides a net beneficial cumulative contribution to the area by supplying needed medical services without burdening regional infrastructure. However, water and electrical supply lines will be extended to the site. Any future expansion of the medical campus beyond the scope described in this EA will require a separate environmental review under HRS Chapter 343 prior to approval. Such a review would evaluate cumulative impacts in light of conditions at the time of the proposed expansion, including the status of the Kea‘au Village Master Plan and other planned projects in the area. PART 4: CONSISTENCY WITH GOVERNMENT PLANS AND POLICIES 4.1 Hawai‘i County General Plan 4.1.1 2005 Hawai‘i County General Plan The Hawai‘i County General Plan serves as a guiding document for decision-making and the implementation of goals for Hawai‘i Island. The plan was adopted in 1989 by ordinance and most recently revised in 2005. The General Plan uses the Land Use Pattern Allocation Guide (LUPAG) Map to designate land on Hawai‘i Island for future developments. The LUPAG is a broad, flexible design tool to guide the direction and quality of future developments in a coordinated manner. It indicates the general location of various land uses in relation to each other. The LUPAG map designates the project area as Urban Expansion, which allows for a mix of high density, medium density, low density, industrial, industrial-commercial and/or open designations in areas where new settlements may be desirable, but where the specific settlement pattern and mix of uses have not yet been determined. Additionally, the draft version of the 2045 General Plan designates the subject property as Medium Density Urban, which is intended for village and neighborhood commercial and single family and multiple family residential and related functions. Additionally, a small portion of parcel 007, which is outside of the project area is designated as Important Agricultural Land (IAL). Due to the importance of the LUPAG designations in determining the suitability of land-use projects and developments, the following goals, policies, and standards that align with the proposed action are discussed below: 2.2 ECONOMIC GOALS a. Provide residents with opportunities to improve their quality of life through economic development that enhances the County’s natural and social environments. b. Economic development and improvement shall be in balance with the physical, social, and cultural environments of the island of Hawai‘i. c. Strive for diversity and stability in the economic system. 72 d. Provide an economic environment that allows new, expanded, or improved economic opportunities that are compatible with the County’s cultural, natural, and social environment. e. Strive for an economic climate that provides its residents an opportunity for choice of occupation. f. Strive for diversification of the economy by strengthening existing industries and attracting new endeavors. g. Strive for full employment. h. Promote and develop the island of Hawai‘i into a unique scientific and cultural model, where economic gains are in balance with social and physical amenities. Development should be reviewed on the basis of total impact on the residents of the County, not only in terms of immediate short run economic benefits. 2.3 ECONOMIC POLICIES x. Encourage the health/wellness industry. Discussion: The proposed project is set to advance economic development in the area by creating stable long-term employment opportunities, including roles such as doctors, nurses, medical technicians, office administrators, and grounds and maintenance workers. 4.2 ENVIRONMENTAL QUALITY GOALS a. Define the most desirable use of land within the County that achieves an ecological balance providing residents and visitors the quality of life and an environment in which the natural resources of the island are viable and sustainable. b. Maintain and, if feasible improve the existing environmental quality of the island. c. Control pollution. 4.3 ENVIRONMENTAL QUALITY POLICIES a. Take positive action to further maintain the quality of the environment. 4.4 ENVIRONMENTAL QUALITY STANDARDS a. Pollution shall be prevented, abated, and controlled at levels that will protect and preserve the public health and well-being, through the enforcement of appropriate Federal, State and County standards. b. Incorporate environmental quality controls either as standards in appropriate ordinances or as conditions of approval. c. Federal and State environmental regulations shall be adhered to. Discussion: HBMC will adhere to all environmental quality goals, policies, and standards. The subject site will be serviced by a Wastewater Treatment Works and control potential stormwater runoff. 73 5.2 FLOODING AND OTHER NATURAL HAZARDS GOALS a. Protect human life. b. Prevent damage to man-made improvements. c. Control pollution. d. Prevent damage from inundation. e. Reduce surface water and sediment runoff. f. Maximize soil and water conservation. 5.3 FLOODING AND OTHER NATURAL HAZARDS POLICIES d. Any development within the Federal Emergency Management Agency designated floodplain must be in compliance with Chapter 27. g. Development-generated runoff shall be disposed of in a manner acceptable to the Department of Public Works and in compliance with all State and Federal laws. q. Consider natural hazards in all land use planning and permitting. r. Discourage intensive development in areas of high volcanic hazard. 5.4 FLOODING AND OTHER NATURAL HAZARDS STANDARDS a. “Storm Drainage Standards,” County of Hawai‘i, October 1970, and as revised. b. Applicable standards and regulations of Chapter 27, “Flood Control,” of the Hawai‘i County Code. c. Applicable standards and regulations of the Federal Emergency Management Agency (FEMA). d. Applicable standards and regulations of Chapter 10, “Erosion and Sedimentation Control,” of the Hawai‘i County Code. e. Applicable standards and regulations of the Natural Resources Conservation Service and the Soil and Water Conservation Districts. Discussion: The Flood Insurance Rate Map (FIRM) designates the subject site to be in Flood Zone X (areas outside of the 500-year floodplain). There are no naturally occurring wetlands, ponds, lakes, or rivers on the parcel, however there is a small unnamed drainageway that crosses a portion of the site. The site has been previously cleared and has been in agricultural use for decades. Accordingly, the site has not been and should not be subject to flooding, coastal hazards, or erosion. The property is outside the Tsunami Evacuation Zone and Special Management Area. 6.2 HISTORIC SITES GOALS a. Protect, restore, and enhance the sites, buildings, and objects of significant historical and cultural importance to Hawai‘i. b. Appropriate access to significant historic sites, buildings, and objects of public interest should be made available. 74 6.3 HISTORIC SITES POLICIES a. Agencies and organizations, either public or private, pursuing knowledge about historic sites should keep the public apprised of projects. b. Amend appropriate ordinances to incorporate the stewardship and protection of historic sites, buildings, and objects. c. Require both public and private developers of land to provide historical and archaeological surveys and cultural assessments, where appropriate, prior to the clearing or development of land when there are indications that the land under consideration has historical significance. d. Public access to significant historic sites and objects shall be acquired, where appropriate. Discussion: There are no known archaeological or cultural resources on the property as it has been cleared and used for agricultural purposes and sugarcane production since at least the 1950s. In the event any inadvertent historic, archaeological, or cultural discoveries are made, all work will cease, and HBMC will immediately notify the Hawai‘i County Planning Department and the DLNR SHPD and secure their clearances before proceeding further. 7.2 NATURAL BEAUTY GOALS a. Protect, preserve, and enhance the quality of areas endowed with natural beauty, including the quality of coastal scenic resources. b. Protect scenic vistas and view planes from becoming obstructed. c. Maximize opportunities for present and future generations to appreciate and enjoy natural and scenic beauty. 7.3 NATURAL BEAUTY POLICIES h. Protect the views of areas endowed with natural beauty by carefully considering the effects of proposed construction during all land use reviews. Discussion: There are no notable areas of natural beauty that would be impacted by the proposed action. The proposed improvements will be aesthetically pleasing and may improve the overall visual appeal and functionality of the site of the site. Appropriate landscaping will be incorporated to beautify the property and mitigate any possible negative visual impacts from the road. 8.2 NATURAL RESOURCES AND SHORELINES GOALS a. Protect and conserve the natural resources from undue exploitation, encroachment, and damage. b. Provide opportunities for recreation, economic, and educational needs without despoiling or endangering natural resources. 75 c. Protect and promote the prudent use of Hawai‘i’s unique, fragile, and significant environmental and natural resources. d. Protect rare or endangered species and habitats native to Hawai‘i. e. Protect and effectively manage Hawai‘i’s open space, watersheds, shoreline, and natural areas. f. Ensure that alterations to existing landforms, vegetation, and construction of structures cause minimum adverse effect to water resources, and scenic and recreational amenities and minimum danger of floods, landslides, erosion, siltation, or failure in the event of an earthquake. 8.3 NATURAL RESOURCES AND SHORELINES POLICIES a. Require users of natural resources to conduct their activities in a manner that avoids or minimizes adverse effects on the environment. p. Encourage the use of native plants for screening and landscaping. r. Ensure public access is provided to the shoreline, public trails and hunting areas, including free public parking where appropriate. u. Ensure that activities authorized or funded by the County do not damage important natural resources. Discussion: The proposed project will adhere to strict environmental standards and will not encroach on any open spaces or areas of natural beauty. Wastewater will be handled by an on site WWTW. Contractors will follow all County and State laws to manage stormwater runoff during construction. Plantings will screen the property. The site is not adjacent to the ocean and does not have any access to shoreline areas, public trails, or hunting areas. It is roughly 4 miles inland at an elevation of approximately 300 feet above sea level. It is also outside the County Tsunami Evacuation Zone. As such, the proposed project should not have any adverse impacts on the area’s coastal zone or shoreline resources. 10.1.2 PUBLIC FACILITIES GOALS a. Encourage the provision of public facilities that effectively service community and visitor needs and seek ways of improving public service through better and more functional facilities in keeping with the environmental and aesthetic concerns of the community. 10.5.2 PUBLIC FACILITIES: HEALTH AND SANITATION POLICIES e. Encourage the establishment or expansion of community health centers and rural health clinics. 10.5.3 PUBLIC FACILITIES: HEALTH AND SANITATION STANDARDS 76 b. Hospitals should be on sites capable of handling moderate expansion of facilities. Quiet surroundings, convenient and adequate access, and compatibility with adjoining uses shall be required. c. Hospitals shall be served by a public sewage system or have self-contained sewage systems. d. Hospital solid waste shall be disposed of in accordance with all Federal, State, and County laws and regulations. 10.5.4.2 PUBLIC FACILITIES: HEALTH AND SANITATION COURSES OF ACTION a. Improvement and expansion of hospital facilities shall be undertaken as the need arises Discussion: The proposed project would significantly increase access to health care services in a traditionally underserved and quickly growing area. The development of the new medical center will help to strengthen access to healthcare for rural communities. Should the project not proceed the improvements to health care would not be realized. 14.1.2 LAND USE GOALS a. Designate and allocate land uses in appropriate proportions and mix and in keeping with the social, cultural, and physical environments of the County. b. Protect and preserve forest, water, and natural and scientific reserves and open areas. 14.1.3 LAND USE POLICIES f. Encourage the development and maintenance of communities meeting the needs of its residents in balance with the physical and social environment. Discussion: There are no significant adverse land use concerns since the proposed action will be limited in extent and will fulfill a community need. 4.2 Puna Community Development Plan The Puna Community Development Plan (PCDP) was developed through the implementation of the 2005 County of Hawai‘i General Plan. CDP’s are designed to translate and implement the goals, policies, and standards of the General Plan as they apply to specific communities and districts. Additionally, they serve as important framework for a community’s intended outcome and vision and are often used as forum for community input in terms of land-use, availability of public resources, and overall development. The vision of the Puna CDP is for “residents of Puna live in harmony with the land, while promoting a sustainable vibrant local economy, healthy community, and a viable transportation system that is accessible, friendly and safe for now and future generations.” The subject site is within the area identified as the Keaʻau Regional Town Center by the PCDP, which designates areas suitable for commercial development. The 77 following goals and objectives outlined in the PCDP apply to the project area and proposed development: 2.1.1 Goals a. Structures and cultural sites that are significant to Puna’s history and cultural traditions are preserved. b. The design character and natural setting of older communities that are representative of Puna’s historic development are perpetuated. c. Areas of scenic and cultural interest are accessible to the public in a manner that does not detract from their aesthetic, natural and cultural value. d. Awareness and appreciation of the host culture is expanded. 3.1.1 Goals a. Puna retains a rural character while it protects its native natural and cultural resources. b. The quality of life improves, and economic opportunity expands for Puna’s residents. c. Services and community facilities are more accessible in village/town centers that are distributed throughout the region, including the underserved subdivisions that have been experiencing higher levels of development growth. d. Exposure to high risk from natural hazards situations is reduced. 3.3.1 Goals a. Puna residents have improved access to emergency and primary medical care and preventative public health programs. 3.3.3 Actions a. Develop a centrally-located, 24-hour, full-service medical facility, with trauma care, in Puna. 3.4.1 Goals a. All residents have an equitable level of service access to police, fire, and paramedical services. 3.4.2 Objectives a. Provide additional locations for emergency services to reduce the response time to a larger percentage of residents. 4.1.1 Goals b. The percentage of residents who commute to employment or travel for services outside of Puna is reduced. 78 4.1.2 Objectives b. Provide more services and employment within Puna’s village and town centers. c. Create new employment opportunities in Puna to reduce long commuting. Discussion: The proposed project would significantly increase access to health care services in a traditionally underserved and quickly growing area. There is a lack of adequate healthcare facilities within Puna and many residents have to drive significant distances to receive medical care. The establishment of a new medical center would make medical services much more accessible in the area. Should the project not proceed the improvements to health care would not be realized. 4.3 County Zoning and Special Management Area The County Zoning of the property is currently A-20a. Although the property is designated for agricultural uses by County land use laws, the non-agricultural uses may be allowed through the issuance of a Use Permit and Special Permit. HBMC will prepare and submit a Use Permit and Special Permit application for review and approval by the County Windward Planning Commission. The subject property has been subject to prior County zoning actions that are relevant to the present application. County Change of Zone Ordinance No. 02-23, approved on February 28, 2002, reclassified portions of the subject property from the Agricultural District (A-20a) to Industrial-Commercial Mixed Use (MCX-20). The MCX-20 zoning designation permits a range of commercial and light industrial uses subject to applicable development standards under Chapter 25 of the Hawaiʻi County Code. Any conditions of approval associated with Ordinance No. 02-23 remain binding on those portions of the property and must be reviewed prior to development of those areas. The proposed medical clinic use would occur on portions of the subject properties with A-20a zoning. Approvals will be addressed through the Use Permit and Special Permit process described above. The proposed development is designed to comply with all applicable County zoning standards, and the Use Permit and Special Permit proceedings will provide the appropriate forum for a full consistency determination. The property does not lie within the Special Management Area. The subject property is located approximately 4 miles from the nearest shoreline and will not be impacted by coastal hazards or beach erosion. There is no designated public access to the mountain or shoreline areas over the property. As such, the proposed project will not adversely affect any recreational resources, including access to and along the shoreline, scenic and open space or visual resources, coastal ecosystems, and marine and coastal resources Therefore, the proposed use is not contrary to the objectives of Chapter 205 A, HRS relating to coastal zone management. 79 4.4 Hawai‘i State Land Use Law All land in the State of Hawai‘i is classified into one of four categories for land use – Agricultural, Conservation, Rural, or Urban. These districts have been established by the State Land Use Commission pursuant to Chapter 205 HRS. In 1993, the State Land Use Commission amended several land use boundaries and designated several areas as Urban in Keaʻau under Docket BR93-699, including a 109.000 area referred to as “Area D” in the vicinity of the Property and project area. W.H. Shipman Ltd. has requested a boundary interpretation for confirmation, but it is expected that the Urban area will follow the parcel boundary, and the project area will be entirely within the SLU Urban district. Per the Hawaiʻi County Planning Department, Parcel 127 is primarily designated Urban, with a small portion designated Agricultural and Parcel 007 is designated Agricultural and Urban by the State Land Use Commission. State Land Use Boundary Amendment No. 884 (LUC Docket No. BR96-699) was approved on July 18, 1994, amending approximately 660 acres in Keaʻau, Puna, Hawaiʻi Island from the Agricultural District to the Urban District. This boundary amendment, in conjunction with the prior 1993 action under Docket BR93-699, established the Urban District classification for lands in the Keaʻau area, including portions of and in the vicinity of the subject property. Any conditions of approval imposed by the Land Use Commission in connection with Boundary Amendment No. 884 or LUC Docket BR93-699 remain applicable to the subject property. A recent status report on compliance with the conditions of the Decision and Order is included as Appendix G. The proposed project is located within the State Land Use Urban District as established by these prior boundary amendments. Development of a medical clinic and associated access improvements within the Urban District is consistent with the purposes and intent of the Urban District classification under Chapter 205, HRS, which is designed to accommodate areas where urbanization is appropriate and planned. The proposed medical clinic is an appropriate Urban District use and does not require a new boundary amendment or petition to the Land Use Commission. 4.5 Required Permits and Approvals The following permits and approvals are required for the proposed construction of a medical clinic: County of Hawai‘i Use Permit Special Permit Building Permits Grubbing/Grading Permits Electrical Review Mechanical/Plumbing Review Fire Review 80 Engineering Review Sanitation Review Solid Waste Management Plan State of Hawai‘i Permit to Perform Work Upon State Highways Permit for the Occupancy and Use of State Highways National Pollutant Discharge Elimination System (NPDES) Permit Storm Water Pollution Prevention Plan (SWPPP) Department of Health Individual Wastewater Treatment Works (WWTW) Department of Health Construction-Environmental Hazard Management Plan (C-EHMP) & if necessary, a Removal Action Work Plan (RAWP) and Removal Action Report (RAR) Potential Noise Permit PART 5: DETERMINATION, FINDINGS, AND REASONS 5.1 Determination HBMC expects that the County of Hawai‘i Planning Department Hawaii Health System Corporation will determine that the proposed action will not significantly alter the environment and will accordingly issue a Finding of No Significant Impact (FONSI). This determination will be based on comments to the Draft Environmental Assessment (DEA). The Final Environmental Assessment (FEA) will outline the final determination. 5.2 Findings and Supporting Reasons Agencies must consider several factors to determine whether an Action has significant effects, as outlined in HAR Chapter 11-200.1. The following factors evaluate the sum of effects of the proposed action on the quality of the environment by considering every phase of a proposed action, the expected impacts, and the proposed mitigation measures: 1. The proposed project will not involve an irrevocable commitment or loss or destruction of any natural, cultural, or historic resource. No valuable natural or cultural resources would be affected or lost due to construction of the proposed project. The property has been previously cleared and used agriculturally for many years; thus it is unlikely that the project would involve an irrevocable commitment or loss or destruction of any natural, cultural or historic resource. 2. The proposed project will not curtail the range of beneficial uses of the environment. 81 No restriction of beneficial uses would occur under the proposed action. It is not known whether the Properties have been used for cultural practices in the past, however, it is very unlikely it is used in such a capacity today due to current and historic land use. 3. The proposed project will not conflict with the State’s environmental policies or long- term environmental goals established by law. The State’s long-term environmental policies are set forth in HRS Chapter 344. The broad goals of this policy are to conserve natural resources and enhance quality of life. The requested action will have no significant impact to environmental processes, nor will it negatively impact quality of life. The proposed project would improve the quality of life for the community by providing access to required health care services. No significant impacts to natural resources will occur. It is therefore consistent with all elements of the State’s long-term environmental policies. 4. The proposed project will not have a substantial adverse effect on the economic welfare, social welfare, or cultural practices of the community and State. The proposed action will create positive impacts on the economic and social welfare of the region by providing employment opportunities and vital health care options. 5. The proposed project will not have a substantial adverse effect on public health. The proposed action would have a positive effect on public health by providing expanded, improved and more convenient health care services for the community. Minor and short- term impacts to air quality and noise levels may occur during construction but will be mitigated by using Best Management Practices and appropriate permitting such as noise permits. Public health is anticipated to improve with the proposed action by providing essential healthcare and emergency services to an underserved area. 6. The proposed project will not involve adverse secondary impacts, such as population changes or effects on public facilities. The proposed action does not include new residential units and thus will not involve adverse impacts to population changes. The project aims to help manage the current upward trend in population growth by meeting the rising demand for healthcare services, enhancing accessibility, alleviating overcrowding, customizing healthcare services to fit community requirements, and strengthening emergency readiness in the area. The project will aid in retaining residents by providing accessible healthcare services and reducing the need for travel. 7. The proposed project will not involve a substantial degradation of environmental quality. 82 The proposed action is relatively minor and environmentally benign and thus would not contribute to environmental degradation. The property has been previously cleared and used extensively for agricultural purposes. 8. The proposed project is not one which is individually limited and will not have substantial adverse effect upon the environment or involve a commitment for larger actions. The proposed action will not have substantial adverse effect upon the environment or involve a commitment for larger actions. Nearly all long-term impacts from the proposed project are negligible, with no measurable effects on sensitive ecosystems or rare species, water quality, erosion and sedimentation, historic properties, noise and air quality, and other measures. Potential cumulative impacts on area traffic conditions has been detailed in the included traffic study which found that the total anticipated traffic is expected to be within the capacity of the system to absorb it and only modest mitigations are expected for traffic. 9. The proposed project will not have a substantial adverse effect on a rare, threatened, or endangered species, or its habitat. Although there was no formal biotic survey of the Property, there are likely no naturally occurring rare, threatened, or endangered species present due to past agricultural development. Additionally, the majority of species observed on the property are introduced. With the proposed mitigation measures, impacts to rare, threatened or endangered species will not occur. 10. The proposed project will not have a substantial adverse effect on air or water quality or ambient noise levels. The proposed action would have minimal and short-term effects on air quality and ambient noise levels during construction. Mitigating measures will be strictly followed to reduce impacts to both air quality and noise during construction. If maximum permissible levels are exceeded during any stage, the contractor will consult with the Department of Health and determine whether permits are necessary. The facility will provide outpatient care only and will not be an emergency room and will not receive ambulances. Thus, the long-term noise impacts of the proposed project will be on par with other commercial-type uses in the area. 11. The proposed project will not have a substantial adverse effect on or be likely to suffer damage by being located in an environmentally sensitive area such as a flood plain, tsunami zone, sea level rise exposure area, beach, erosion-prone area, geologically hazardous land, estuary, fresh water, or coastal waters. 83 The subject property is located 4 miles inland from the shoreline and will not be impacted by any coastal hazards such as tsunamis, sea level rise, or erosion. The property is also in an area of minimal flood hazard. The property is located in an area subject to volcanic and seismic hazards, however much of the island shares these hazards. All buildings would be designed according to County building codes to withstand an acceptable level of seismic activity and wind resistance. 12. The proposed project will not have a substantial adverse effect on scenic vistas and viewplanes, during day or night, identified in county or state plans or studies. The proposed construction will not impose on views to or from any listed resource in the General Plan. After construction, landscaping will be incorporated to beautify the site. 13. The proposed project will not require substantial energy consumption or emit substantial greenhouse gases. The proposed action will not emit substantial greenhouse gases. The main source of greenhouse gas emissions will be from vehicles. Energy consumption will be mitigated through energy and water conserving practices. Such methods include energy efficient appliances and lights, low flow systems in bathrooms for toilets and sinks with timed shut off for appropriate devices and landscaping vegetation that requires minimal watering. 84 REFERENCES Beven, J. and Wroe, D. 2019. Hurricane Lane (EP142018). National Hurricane Center, Central Pacific Hurricane Center, Tropical Cyclone Report. Collins M. et al., 2019: Extremes, Abrupt Changes and Managing Risk. In: IPCC Special Report on the Ocean and Cryosphere in a Changing Climate [H.-O. Partner, D.C. Roberts, V. Masson-Delmotte, P. Zhai, M. Tignor, E. Poloczanska, K. Mintenbeck, A. Alegr􏱇a, M. Nicolai, A. Okem, J. Petzold, B. Rama, N.M. Weyer (eds.)]. In press. Commission on Water Resource Management (CWRM). 2019a. Water Resource Protection Plan Update (WRPP) Appendix F. Hawai‘i Water Plan, State of Hawai‘i. Department of Land and Natural Resources. 2024. Division of Forestry and Wildlife: Wildlife Program. Native Birds of Hawai‘i. Hawaii.gov. Escott, G. G, 2018. An Archaeological Inventory Survey Report For W.H. Shipman Kea‘au Town Property in Kea‘au Ahupua‘a, Puna District, Hawai‘i Island, Hawai‘i Giambelluca, T.W., Q. Chen, A.G. Frazier, J.P. Price, Y.-L. Chen, P.-S. Chu, J.K. Eischeid, and D.M. Delparte, 2013: Online Rainfall Atlas of Hawai‘i. Bull. Amer. Meteor. Soc. 94, 313-316, doi: 10.1175/BAMS-D-11-00228.1. Hawai‘i County Civil Defense Agency. 2023. Hawai‘i County Volcano Hazards: know your indundation zone. Retrieved from: https://hawaiicountygis.maps.arcgis.com/apps/instant /lookup/index.html?appid=1ddc852f98854f3685ddacf62d5b2b10 Hawai‘i County Planning Department. 2008. Puna Community Development Plan. Hilo. Hawai‘i County Planning Department. 2005. General Plan, County of Hawai‘i. Hilo. Hawai‘i State Department of Land and Natural Resources (DLNR). 2017. Rapid ‘Ōhi‘a Death: Part I: Strategic Response Plan for Hawai‘i, 2017-2019. Prep. by Division of Forestry & Wildlife. Honolulu. Hawaiian Volcano Observatory (HVO). 2022. Frequently Asked Questions about Mauna Loa Volcano. United States Geological Survey (USGS). Retrieved from: https://www.usgs.gov /observatories/hawaiian-volcano-observatory/frequently-asked-questions-about-mauna-loa-volcano. Hoopes, Stephanie, Ph.D. 2024. ALICE in the Crosscurrents: An Update on Financial Hardship in the United States. United For ALICE. Hoover, J. 2023. 2022 Hawai‘i County Comprehensive Economic Development Strategy. Hawai‘i Island Economic Development Board. 85 IPCC, 2023: Summary for Policymakers. In: Climate Change 2023: Synthesis Report. Contribution of Working Groups I, II and III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, H. Lee and J. Romero (eds.)]. IPCC, Geneva, Switzerland, pp. 1-34, doi: 10.59327/IPCC/AR6-9789291691647.001 Kamakau, S.M. 1992. Ruling Chiefs of Hawaii. Kamehameha Schools Press, Honolulu. Kelly, M., B. Nakamura, and D. Barrere. 1981 Hilo Bay: A Chronological History, Land and Water Use in the Hilo Bay Area, Island of Hawaiʻi. Department of Anthropology, Bernice P. Bishop Museum. Kimberlain, T., Brennan, M., and Wroe, D. 2018. Hurricane Iselle (EP092014). National Hurricane Center, Central Pacific Hurricane Center, Tropical Cyclone Report. PBR Hawaii & Associates Inc. 2017. Cultural Impact Assessment Kea‘au Village Master Plan, Phases 1 & 2 Rechtman Consulting, LLC, 2004. Archaeological Assessment of a 112 Acre Property Tetra Tech. 2020. County of Hawai‘i Multi-Hazard Mitigation Plan. Prepared for County of Hawai‘i Civil Defense Agency. Thomas, W. et al., 1992. Map Showing Lava-Flow Hazard Zones, Island of Hawai‘i. Trusdell, F.A., and Lockwood, J.P., 2017, Geologic map of the northeast flank of Mauna Loa volcano, Island of Hawai‘i, Hawaii: U.S. Geological Survey Scientific Investigations Map 2932- A, pamphlet 25 p., 2 sheets, scale 1:50,000, https//doi.org/10.3133/sim2932A. United States Geological Survey (USGS). 2024. Stream Stats. Web Application Retrieved from: https://streamstats.usgs.gov/ss/ U.S. Census Bureau. (n.d.) Industry for Civilian Employed Population 16 Years and Over in Pāhoa-Kalapana CCD, Hawaii County, Hawaii. U.S. Department of Commerce. Retrieved September 18, 2024, from https://data.census.gov/ U.S. Census Bureau. (n.d.) Industry for Civilian Employed Population 16 Years and Over in Kea‘au -Mountain View CCD, Hawaii County, Hawaii. U.S. Department of Commerce. Retrieved September 18, 2024, from https://data.census.gov/ West Hawai‘i Today. 2021. Brush fire burns 40,000 acres on Hawai‘i’s Big Island. Retrieved from: https://wildfiretoday.com/2021/08/03/brush-fire-burns-40000-acres-on-hawaiis-big-island/ 86 Kea‘au Medical Clinic Traffic Impact Analysis Report Kea‘au, Hawai‘i January 2026 Prepared for: Hawai‘i Health Systems Corporation Prepared by: HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Table of Contents I. PROJECT DESCRIPTION ........................................................................................................ -1 - II. EXISTING CONDITIONS ........................................................................................................ -4 - A. Geometric Configuration ................................................................................................. -4 - B. Study Intersections .......................................................................................................... -5 - C. Nearby Attractions and Destinations............................................................................... -8 - D. Vehicle Volumes............................................................................................................. -12 - E. Highway Capacity Manual.............................................................................................. -15 - F. Existing (2025) Intersection LOS Results........................................................................ -16 - III. Future (2028) Without Project Conditions........................................................................ -19 - A. Background Growth Rate............................................................................................... -19 - B. Upcoming Planned Projects........................................................................................... -19 - C. Future (2028) Without Project Traffic Volumes ............................................................ -20 - D. Future (2028) Without Project LOS ............................................................................... -20 - IV. Future (2028) With Project Conditions ............................................................................. -24 - A. Future (2028) With Project Generated Volumes........................................................... -24 - B. Future (2028) With Project LOS ..................................................................................... -29 - V. Summary and Recommendations ..................................................................................... -31 - VI. References ......................................................................................................................... -32 - List of Figures Figure 1: Proposed Medical Clinic Location Map ....................................................................... -2 - Figure 2: Conceptual Site Plan .................................................................................................... -3 - Figure 3: Existing (2025) Lane Configuration ..............................................................................-7 - Figure 4: Existing (2025) Nearby Attractions, Destinations, and Multimodal Facilities ........... -11 - Figure 5: Existing (2025) Intersection Peak Hour Volumes ...................................................... -14 - Figure 6: Future (2028) Without Project Intersection Peak Hour Volumes ............................. -21 - Figure 7: East Hawaii Census Designated Place Groupings ...................................................... -25 - Figure 8: Proposed Medical Clinic Generated Trips.................................................................. -27 - Figure 9: Future (2028) With Project Volumes ......................................................................... -28 - i HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 List of Tables Table 1: Historic HDOT 2016-2022 AADT.................................................................................. -12 - Table 2: Peak Hour Pedestrian and Bicycle Volumes ............................................................... -13 - Table 3: HCM6 LOS Criteria for Signalized Intersections .......................................................... -15 - Table 4: HCM2000 LOS Criteria for Signalized Intersections .................................................... -16 - Table 5: Existing (2025) LOS...................................................................................................... -17 - Table 6: Future (2028) Without Project LOS............................................................................. -22 - Table 7: ITE Trip Generation – Equation and Rates for Medical Clinics ................................... -24 - Table 8: ITE Trip Generation – Medical Clinic Related Trips..................................................... -24 - Table 9: Census Designated Places Population ........................................................................ -26 - Table 10: Census and Traffic Volume Comparison with Resulting Trip Distribution Percent .. -26 - Table 11: Future (2028) With Project LOS ................................................................................ -29 - List of Appendices Appendix A – Traffic Count Data Appendix B – Analysis Report Existing Conditions Appendix C – Analysis Report Future Without Project Conditions Appendix D – Analysis Report Future With Project Conditions ii HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 I. PROJECT DESCRIPTION The Hawai‘i Health Systems Corporation (HHSC) is proposing to develop a new medical clinic (Medical Clinic) in Kea‘au, on the Island of Hawai‘i on an A-20a zoned parcel (Tax Max Key (TMK) (3) 1-6-003:127). The proposed Medical Clinic location map is shown in Figure 1. To support this effort, a Use Permit will be pursued. Should the Use Permit be approved, HHSC is proposing to construct a medical clinic with approximately 40,000 square feet (sf) of building space. The parking lot will include 22 Americans with Disabilities (ADA) compliant perpendicular parking stalls and 182 standard perpendicular parking stalls. The conceptual site plan is shown in Figure 2. Construction is estimated to be completed by 2028. This Traffic Impact Analysis Report (TIAR) is being prepared in support of a Use Permit application to analyze the potential traffic impacts of the proposed Medical Clinic and recommended mitigations. The Hawai‘i County Code Chapter 25, Section 25-2-60 “Use Permits” permits medical clinics in districts zoned as RS, RD, RM, RA, FA, and A. There are no standards and regulations regarding traffic impacts resulting from the development of a medical clinic. Therefore, Existing (2025) and Future (2028) Without and With Project traffic impact were analyzed as part of this TIAR. -1 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 1: Proposed Medical Clinic Location Map -2 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 2: Conceptual Site Plan -3 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 II. EXISTING CONDITIONS A. Geometric Configuration 1. State Route 11 Within the vicinity of the Medical Clinic, Route 11 is a State-owned small urban principal arterial north of Route 139 and a rural minor arterial to the south. It is a two-way divided arterial generally oriented north–south, with two travel lanes in each direction. Route 11 narrows to one lane in each direction south of Pa‘ahana Street/Na‘auao Road and north of Kipimana Street. No sidewalks, curbs, gutters, on-street parking or designated bike facilities exist along the corridor. Marked shoulders of variable width—ranging from 8 to 24 feet—exist on both sides. The posted speed limit is 45 miles per hour (MPH), decreasing to 35 MPH near Route 139 before returning to 45 MPH beyond the commercial area of Kea‘au. Route 11 is known by various names, including Kanoelehua Avenue, Māmalahoa Highway, Hawai‘i Belt Road, Volcano Road, Kuakini Highway, and Queen Ka‘ahumanu Highway Extension. To avoid confusion, the name “Route 11” will be used throughout this report. 2. State Route 130 Route 130 is a State-owned small urban minor arterial, generally oriented north–south, with two travel lanes in each direction. Approximately 2,200 feet north of its intersection with Route 139, it becomes divided by a concrete and grass median. No sidewalks, curbs, gutters, on-street parking or dedicated bike facilities exist in the Medical Clinic area. Marked shoulders ranging from 4 to 24 feet are present on both sides. The posted speed limit in the area is 45 MPH. Route 130 is also known by several names, including Kea‘au–Pāhoa Bypass Road, Kea‘au–Pāhoa Road, Pāhoa–Kalapana Road, and Kaimu–Chain of Craters Road. To avoid confusion, the name “Route 130” will be used throughout this report. 3. State Route 139 Route 139 is a State-owned two-way roadway, generally oriented east–west, with one travel lane in each direction. Within the commercial area of Kea‘au, it is divided by a concrete and grass median, transitioning to an undivided roadway south of its intersection with Old Volcano Road. Dedicated turn lanes are provided at major intersections. Paved sidewalks exist on both sides fronting the commercial area and Kea‘au Elementary School, extending approximately 300 feet from Old Volcano Road and continuing along the westbound (WB) direction. Bike lanes are located on the WB side between the Kea‘au High School northern driveway and southern exit driveway. Marked shoulders ranging from 4 to 10 feet are present along the entire WB side, while the eastbound (EB) side has intermittent shoulders ranging from 2 to 10 feet in width. The posted speed limit is 25 MPH. Route 139 is also known as Old Kea‘au-Pāhoa Road but to confusion, the name “Route 139” will be used throughout this report. -4 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 4. Na‘auao Road Na‘auao Road is a privately-owned roadway extending approximately 630 feet west from its intersection with Route 11 to a guard shack owned and operated by the Kamehameha Schools Bishop Estate (Bishop Estate) trust. Na‘auao Road is classified as a local collector, generally oriented east–west. No sidewalks, curbs, gutters, on-street parking or designated bike facilities exist. The posted speed limit is 25 MPH. 5. Pa‘ahana Street Pa‘ahana Street is a two-way, County of Hawai‘i (COH)-owned, undivided local collector generally oriented east–west. East of Palula Place, it narrows to a one-lane roadway with two-way operations. A 20-foot centerline is marked in both directions at each intersection. No sidewalks, curbs, gutters, on-street parking or designated bike facilities exist along the corridor. Speed humps are located between Palula Place and Meaulu Street, and between Pala‘ai Street and Ipuaiwaha Street. The posted speed limit is 25 MPH. 6. Shipman Park Driveway Shipman Park Driveway extends internally within the park’s off-street parking lot to Route 11 across of Route 139. No sidewalks, curbs, gutters, on-street parking or designated bike facilities exist along the roadway. There is no posted speed limit. 7. Proposed Medical Clinic Roadway As part of this project, a new roadway is proposed to be constructed off Route 11 and Route 139 to connect the Medical Clinic to Shipman Park Driveway at Route 11. The proposed Medical Clinic roadway will pass through privately owned land. The proposed Medical Clinic roadway is proposed to run east-west from Shipman Park Driveway before turning north-south, connecting to the proposed Medical Clinic. B. Study Intersections The trip distribution section of this TIAR will detail how most project trips are expected to originate from or travel to the communities of Kea‘au, Pāhoa, or Mountain View, with a limited number associated with Hilo due to the travel distance and proximity to existing alternative facilities. Given these travel patterns, the Medical Clinic project trips are not anticipated to create any significant impacts at the intersection of Route 11 and Kipimana Street and therefore analysis of this intersection was determined to be unnecessary. Separately, the intersection of Old Volcano Road and Route 139 was analyzed in three previous traffic reports in the area from 2020, 2023, and 2024. The intersection operated at an acceptable level of service (LOS) C or better in each report and was therefore assumed not to require further analysis. -5 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Four study intersections were analyzed as a part of the proposed Medical Clinic. The existing lane configurations are shown in Figure 3. 1. Route 11 and Route 130 The intersection of Route 11 and Route 130 is a three-leg signalized intersection operating under actuated traffic signal control. The northbound (NB) approach on Route 11 consists of two through lanes and a channelized, yield-controlled right-turn lane. The southbound (SB) approach has two through lanes and two dedicated left-turn lanes operating under protected traffic signal phasing. The WB approach on Route 130 includes one dedicated left-turn lane with protected traffic signal phasing and two channelized, free-flowing right-turn lanes. Signal cycle lengths varied between the AM and PM peak periods, with the WB phase skipped when no vehicles were present. U-turns are prohibited at all left-turn locations. Marked crosswalks are present on the south leg of Route 11 and the east leg of Route 130. Approximately 750 feet north of the intersection, Route 11 drops from four lanes to three lanes, Route 11 drops another lane, from three lanes to two lanes, about 0.70 miles north of Route 11 and Route 130. The combination of these lane drops with the significant NB volumes requires merging that result in long queues for the NB approach at times. During these times, vehicle queues reach Route 130, resulting in NB through vehicles not being able to enter the intersection. Therefore, traffic volumes counted during the AM peak hour is less than the traffic demand. 2. Route 11 and Route 139/Shipman Park Driveway The intersection of Route 11 and Route 139 is a four-way signalized intersection operating under actuated traffic signal control. The NB and SB approaches of Route 11 each have a dedicated left- turn lane with protected traffic signal phasing, a through lane, and a shared through–right lane. Channelized, yield-controlled right turns are provided on the NB and WB approaches. The Route 139 approach consists of a shared left–through lane and a separate right-turn lane, while the Shipman Park Driveway approach has a shared left-through-right lane. Traffic signal cycle lengths varied between the AM and PM peak periods, with the NB and SB phases being skipped when no vehicles were present. Marked crosswalks exist on all legs of the intersection. As part of the proposed Medical Clinic, a new roadway will extend from Route 11 and Route 139 to connect the Medical Clinic with Route 11 at the Shipman Park Driveway. -6 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 3: Existing (2025) Lane Configuration -7 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 3. Route 11 and Pa‘ahana Street/Na‘auao Road The intersection of Route 11 and Pa‘ahana Street/Na‘auao Road is a four-leg, signalized intersection. The NB approach consists of one through lane, a dedicated left-turn lane, and a dedicated right-turn lane, with approximately 325 feet of storage. The SB approach includes one through lane, a dedicated left-turn lane, and a shared through–right lane, with approximately 450 feet of storage. The Na‘auao Road EB approach has a dedicated left turn lane and a shared left-through-right turn lane. The Pa‘ahana Street WB approach has a shared left-through-right turn lane. All left-turn movements operate with protected traffic signal phasing, and the EB and WB approaches operate with split phasing. Signal cycle lengths varied between the AM and PM peak periods, with the WB phase, NB left phase, and SB left phase being skipped when no vehicles were present, suggesting the intersection has actuated timing. Marked crosswalks exist on the western, southern, and eastern legs of the intersection. 4. Route 130 and Route 139 The intersection of Route 130 and Route 139 is a signalized T-intersection. The NB approach consists of two through lanes and a dedicated left-turn lane with approximately 1,350 feet of storage. The SB approach has two through lanes and a dedicated, channelized, yield-controlled right-turn lane with approximately 400 feet of storage. The EB approach includes a dedicated left-turn lane and a right-turn lane with permitted-overlap traffic signal phasing; both turn lanes are approximately 450 feet long. Traffic signal cycle lengths varied between the AM and PM peak periods. The signage prohibiting the EB right turn on red arrow is no longer present. Therefore, in accordance with the 2024 Hawai‘i Revised Statutes §291C-32, a right turn on red is permitted after a complete stop and yielding to oncoming traffic and pedestrians, unless prohibited by signage. U-turn movements are prohibited for all left turns at this location. C. Nearby Attractions and Destinations 1. HDOE Schools There are three State of Hawai‘i Department of Education (HDOE) public schools in the area: Kea‘au Elementary School, Kea‘au Middle School, and Kea‘au High School. Kea‘au Elementary School is located just east of the proposed Medical Clinic along Route 139 near the intersection of Kukula Street. Kea‘au Middle School is located near the Old Volcano Road and Route 139 intersection. Kea‘au High School is located along Route 139 near the intersection of Old Kea‘au- Pāhoa Road. Each school has a slightly different bell schedule. The AM traffic counts captures the school morning peak hours. The PM traffic count occurs later in the day and does not capture the after school peak hour but may have captured some of the parents who may still be in the process of picking up their students from school. -8 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 2. Kamehameha Schools The Kamehameha Schools Hawai‘i Island campus, located off Na‘auao Road, provides education to students from kindergarten through 12th grade. School starts at 7:45 AM and ends at 2:30 PM and 2:45 PM for even days and odd days, respectively. The AM traffic counts captures the school morning peak hours. The PM traffic count occurs later in the day and does not capture the after school peak hour but may have captured some of the parents who may still be in the process of picking up their students from school. 3. Kea‘au Public Library Kea‘au Public Library is currently located on the Kea‘au Middle School campus at the southeast corner of the intersection of Old Volcano Road and Route 139. The library has varying operating hours, opening at 9:00 AM or 12:00 PM and closing at 4:00 PM or 7:00 PM. The library is proposed to be replaced by a 12,000 sf public library and 42-stall parking lot located in the currently empty grassy field closer to Route 139. The new library is scheduled to be completed by 2027. 4. Kea‘au Shopping Center Kea‘au Shopping Center is bound by Route 11, Route 139, and Old Volcano Road. This shopping center has a variety of tenants including retail, fast-casual restaurants, and service providers. Major anchor stores include Foodland and Ace Hardware. The shopping center operating hours are from 6:00 AM to 9:00 PM, seven days a week. 5. Herbert Shipman Park Herbert Shipman Park is located west of the intersection of Route 11 and Route 139. The park includes two tennis courts, a baseball field, a basketball court, a playground, a public restroom, and approximately 50 parking stalls. According to the COH Department of Parks & Recreation, the park also includes the Kea‘au Armory and the Buddy Perry Soccer Field. The parking lot to Shipman Park is open between 7:00 AM and 7:00 PM. The gated driveway to the Kea‘au Armory is open between 7:00 AM and 8:00 PM. 6. Transit Facilities The COH operates the Hele-On Bus (COH Bus) throughout the island, of which five routes operate within the vicinity of the proposed Medical Clinic: • Route 10 (Hilo to Ocean View) o Bus Route 10 operates a one-way round trip that begins in Hilo and ends in Kailua- Kona before returning to Hilo. Only one round trip is provided each day. The eastbound trip leaves Ocean View in Kona at 6:40 AM and arrives in Hilo at 9:08 AM. The returning westbound trips leaves Hilo at 3:30 PM and arrives in Ocean View at 6:04 PM. Within the vicinity of the proposed Medical Clinic, Route 10 stops at the intersection of Route 139 and Old Volcano Road. -9 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 • Route 11 (Red Line – Hilo to Volcanos National Park) o Bus Route 11 provides five round trips daily from Hilo to Hawai‘i’s Volcanoes National Park and back to Hilo. A total of two AM, one midday, and two PM round trips are provided. The first trip from Hilo to the Volcanoes National Park leaves Hilo at 5:00 AM. The last scheduled departure from Hawai‘i’s Volcanoes National Park leaves at 6:15 PM and arrives in Hilo at 7:22 PM. Within the vicinity of the proposed Medical Clinic, Route 10 stops at the intersection of Route 139 and Old Volcano Road. • Route 40 (Hilo to Pāhoa) o Bus Route 40 provides 17 round trips from Hilo to Pāhoa. The first scheduled departure from Pāhoa leaves at 5:30 AM with busses running every hour. The last scheduled departure from Pāhoa leaves at 9:30 AM and returns to Hilo at 10:27 PM. Within the vicinity the proposed Medical Clinic, Bus Route 40 has six stops. • Route 402 (Hawaiian Paradise Park/Hawaiian Acres/Ainaloa) o Bus Route 402 provides eight round trips from Pāhoa to Kea‘au. The first scheduled departure leaves from Hawaiian Acres at 5:00 AM and arrives in Pāhoa at 5:30 AM. The remaining departures from Pāhoa will make the full round trip from Pāhoa to Kea‘au with busses running every two hours. The last scheduled departure from Pāhoa leaves at 7:30 PM and arrives in Kea‘au at 8:25 PM. Within the vicinity of the proposed Medical Clinic, Route 10 stops at the intersection of Route 139 and Old Volcano Road. • Route 403 (Fern Acres) o Bus Route 403 provides five round trips from Kea‘au to Forest Fern. The first scheduled departure form Kea‘au levaes at 9:00 AM with busses running every two hours. The last scheduled departure from Kea‘au leaves at 5:10 PM and arrives in Forest Fern at 5:45 PM. Within the vicinity of the proposed Medical Clinic, Route 10 stops at the intersection of Route 139 and Old Volcano Road. COH bus routes and stops within the vicinity of the proposed Medical Clinic are shown in Figure 4. Most routes travel along Route 11, turn onto Old Volcano Road, and stop at the Route 139/Old Volcano Road bus stop before returning to Route 11. The exception is Route 40, which serves Route 139 and Kea‘au High School. Bus drivers will also stop for riders who flag them down, provided there is a safe location to pull over. The COH bus system offers connections to numerous other routes serving the entire island. COH bus fares are free through December 31, 2025. -10 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 4: Existing (2025) Nearby Attractions, Destinations, and Multimodal Facilities -11 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 D. Vehicle Volumes 1. 24-Hour Volume Historic Hawai‘i Department of Transportation (HDOT) Annual Average Daily Traffic (AADT) counts were available between the years 2016 and 2022. Three HDOT stations were identified within the vicinity of the proposed Medical Clinic based on their proximity to regional travel routes: • Route 11 between Old Volcano Road to Pa‘ahana Street, • Route 130 between Keaau Bypass Road to Kukula Street, • Route 139 between Keaau Pahoa Road to Kea‘au Kula Road. Table 1 summarizes the AADT along all three HDOT stations identified along with its respective calculated growth rate from 2016-2022. The historic HDOT data can be found in Appendix A. Table 1: Historic HDOT 2016-2022 AADT Station Location Year AADT Growth Rate 2016-2022 B71001100777 Route 11 between Old Volcano Road and Pa‘ahana Street 2016 19,400 3.86% 2017 22,000 2018 22,000 2019 19,800 2020 17,400 2021 24,400 2022 24,351 B71013900070 Route 139 Between Kea‘au Pahoa Road to Kea‘au Kula Road 2016 7,600 1.03% 2017 7,100 2018 8,600 2019 8,600 2020 7,000 2021 8,100 2022 8,084 B71013000138 Route 130 Between Kukula Street to Kea‘au Bypass Road 2016 23,400 0.46% 2017 23,634 2018 23,900 2019 24,330 2020 21,600 2021 24,100 2022 24,052 -12 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 2. Intersection Peak Turning Movement Counts Turning movement counts were taken at the four study intersections on Wednesday, May 7, 2025, from 6:30–8:30 AM and 3:00–5:00 PM. AM and PM peak hours varied between the study intersections. Given that the Medical Clinic Roadway is proposed off Route 11 and Route 130, the Route 11 and Route 130 AM and PM peak hour was used for the remaining study intersections. The resulting peak hours were identified to be 6:45-7:45 AM and 3:00-4:00 PM, respectively. The AM and PM peak hour volumes at the study intersections are shown in Figure 5. Traffic count data at the study intersections are included in Appendix A. 3. Pedestrian and Bicycle Volumes Peak hour intersection pedestrian and bicycle volumes were taken at the four study intersections on Wednesday, May 7, 2025, from 6:30–8:30 AM and 3:00–5:00 PM. Table 2 summarizes the total pedestrian and bicycle volume counted during the AM and PM peak hours. Generally, pedestrian and bicycle volumes remained low to none during both the AM and PM peak. However, pedestrian and bicycle volumes peaked during the PM hour at the intersection of Route 11 and Route 139. Pedestrian and bike at the study intersections are included in Appendix A. Table 2: Peak Hour Pedestrian and Bicycle Volumes Intersection Pedestrian Volume Bicycle Volume AM Peak PM Peak AM Peak PM Peak Route 11 at Route 130 0 0 0 1 Route 11 at Route 139 0 12 0 3 Route 11 at Pa‘ahana Street/Na‘auao Road 1 0 0 0 Route 130 at Route 139 0 0 1 1 -13 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 5: Existing (2025) Intersection Peak Hour Volumes -14 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 E. Highway Capacity Manual LOS is a rating system used in traffic engineering to measure the effectiveness of roadway operating conditions. There are six LOS ranging from A to F. LOS A is defined as being the least interrupted flow conditions with little or no delays, whereas LOS F is defined as conditions where extreme delays exist. Intersection LOS and delay was determined for the AM and PM peak hours using Synchro Version 11.0 traffic analysis software which is based on the methodologies from the Highway Capacity Manual 6th Edition (HCM6) (TRB, 2016). The HCM6 was not able to be used to analyze Route 11 at Route 130, Route 139/Shipman Park Driveway and the Route 130 at Route 139 intersection as it does not analyze approaches that have both dedicated and shared turn lanes serving the same movement. The intersection of Route 11 at Pa‘ahana Street/Na‘auao Road has a dedicated left turn lane and a shared left- through-right turn lane and cannot be analyzed using HCM6. Therefore, the Highway Capacity Manual 2000 (HCM2000) (TRB, 2000) was used to analyze the Route 11 at Pa‘ahana Street/Na‘auao Road intersection. 1. HCM6 The LOS analysis for signalized intersections is determined by average total vehicle delay based on the methodologies of the HCM6 shown in Table 3. High numbers of vehicles passing through the intersection, long cycle lengths, inappropriate signal phasing, or poor signal progression can result in long delays, and consequently poor LOS. Table 3: HCM6 LOS Criteria for Signalized Intersections Average Control Delay LOS by v/c Ratio (s/veh) <=1.0 >1.0 ≤10.0 A F >10 and ≤20 B F >35 and ≤55 C F >35 and ≤55 D F >55 and ≤80 E F >80 F F Another measure of intersection operation is the volume to capacity (v/c) ratio. This is the ratio of the volume of traffic utilizing the intersection compared to the maximum volume of vehicles that can be accommodated by the intersection during a specific period of time. A v/c ratio under 0.85 means the intersection is operating under capacity and excessive delays are not experienced. An intersection is operating near its capacity when v/c ratios range from 0.85 to 0.95. Unstable flows are expected when the v/c ratio is between 0.95 and 1.0. Any v/c ratio greater than or equal to 1.0 indicates that the intersection is operating at or above capacity which -15 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 results in a LOS F per the HCM6 (TRB, 2016). A traffic movement can have a poor LOS but low v/c which suggests that the traffic volumes along that movement are low but may have to wait a longer time to make the movement which may be due to longer cycle lengths or vehicles waiting for a sufficient gap before making left-turns. 2. HCM2000 The LOS analysis for signalized intersections were determined by control delay based on the methodologies of the HCM2000 (TRB, 2000). The average control delay per vehicle for each lane group is aggregated to obtain the total control delay for each approach and for the intersection. Table 4 outlines the different LOS delay thresholds for signalized intersections according to the HCM2000. Unlike the HCM6, HCM2000 does not utilize v/c ratios as part of the LOS threshold. However, v/c ratios were still calculated. Table 4: HCM2000 LOS Criteria for Signalized Intersections Average Control Delay (s/veh) LOS ≤10.0 A >10 and ≤20 B >35 and ≤55 C >35 and ≤55 D >55 and ≤80 E >80 F F. Existing (2025) Intersection LOS Results Existing (2025) intersection and movement LOS and delay (in seconds per vehicle) were determined for the AM and PM peak hours using Synchro 11 traffic analysis software. Field observations confirmed that all signalized intersections operate with actuated control, and therefore, signal timings were optimized for all intersections prior to analysis. Existing (2025) traffic operations are shown in Table 5, with movements operating at LOS E or worse highlighted in yellow. The overall intersections operate at an acceptable LOS however, several left-turn movements operate at LOS E or worse. These delays result from the traffic signal prioritizing major movements. Green times for all left turn phases appeared to be adjusted to allow the queues clear the intersection each cycle. Existing (2025) Synchro worksheets can be found in Appendix B. -16 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Table 5: Existing (2025) LOS Intersection Movement AM Peak PM Peak LOS Delay (s/veh) v/c LOS Delay (s/veh) v/c Route 11 and Route 130 B 13.0 -B 18.3 - Route 11 NB Through B 13.3 0.66 C 26.1 0.73 Route 11 SB Left C 25.2 0.82 C 3.0 0.88 Route 11 SB Through A 1.9 0.28 A 34.7 0.41 Route 130 WB Left C 32.5 0.49 C 26.5 0.62 Route 11 and Route 139/Shipman Park Driveway C 23.0 -C 22.5 - Route 11 NB Left D 35.8 0.48 C 32.9 0.48 Route 11 NB Through-Right C 22.1 0.79 B 19.9 0.68 Route 11 SB Left E 63.4 0.89 E 60.9 0.92 Route 11 SB Through-Right B 13.7 0.37 B 16.3 0.63 Shipman Park EB Left-Through-Right B 12.5 0.07 B 11.2 0.08 Route 139 WB Left-Through B 19.3 0.56 B 14.5 0.39 Route 11 and Pa‘ahana Street/Na‘auao Road C 24.3 -C 20.8 - Route 11 NB Left D 41.6 0.71 E 69.1 0.31 Route 11 NB Through-Right B 19.6 0.68 A 9.8 0.29 Route 11 SB Left D 46.0 0.52 E 61.2 0.61 Route 11 SB Through C 26.4 0.65 B 19.0 0.82 Route 11 SB Right B 19.6 0.29 A 5.7 0.02 Pa‘ahana EB Left C 31.3 0.60 D 50.6 0.43 Pa‘ahana EB Left-Through-Right C 29.1 0.52 D 52.3 0.53 Na‘auao WB Left-Through-Right C 30.5 0.28 D 53.8 0.09 Route 130 and Route 139 B 17.2 -C 25.9 - Route 130 NB Left D 40.4 0.91 E 59.4 0.87 Route 130 NB Through B 11.5 0.84 A 7.9 0.39 Route 11 SB Through B 19.6 0.43 C 32.1 0.92 Route 139 EB Left C 24.9 0.28 C 21.6 0.10 Route 139 EB Right B 12.3 0.41 C 25.7 0.76 1.Route 11 and Route 130 Route 11 and Route 130 operates at LOS B and LOS C during the AM and PM peak hour, respectively. All movements operate at LOS C or better. No mitigation is recommended for this intersection. It should be noted that field observations showed queues along the NB through and WB right during the AM peak hour. This is likely due to the two lane drops located approximately 750 feet and 3,700 feet (0.70 miles) north of the intersection that result in four lanes of traffic merging into two lanes. The queues were observed to not last long, but it is noticeable as vehicles in the NB through and WB right lanes are sometimes delayed from moving through the intersection. -17 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 2. Route 11 and Route 139/Shipman Park Driveway The intersection of Route 11 and Route 139 operate at LOS C for both the AM and PM peak hour. The SB left turn operates at LOS E during both peak hours, with a v/c of 0.89 and 0.92 during the AM and PM peak hour, respectively. The SB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. All other movements operate at LOS D or better. No mitigation is recommended for this intersection. 3. Route 11 and Pa‘ahana Street/Na‘auao Road The intersection of Route 11 and Pa‘ahana Street/Na‘auao Road operates at LOS C during both the AM and PM peak hour. The NB and SB left turns operate at LOS E (v/c of 0.31 and 0.61, respectively). The higher v/c ratio may be due to the limited green time allocated to this movement. The NB and SB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. All other movements operate at LOS D or better during both peaks. No mitigation is recommended for this intersection. 4. Route 130 and Route 139 The intersection of Route 130 and Route 139 operates at LOS B and LOS C during the AM and PM peak hour, respectively. The Route 130 northbound left turn movement operates at LOS E (v/c of 0.87) during the PM peak hour. The NB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. All other movements operate at LOS D or better during both peaks. No mitigation is recommended for this movement. -18 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 III. Future (2028) Without Project Conditions Regional traffic growth and future surrounding area development traffic were added to the roadway network and analyzed for the 2028 Opening Year. A. Background Growth Rate Historical HDOT counts between the years 2016-2022 were identified in the vicinity of the proposed Medical Clinic on Route 11, Route 130, and Route 139 along with its respective calculated growth rate (see Table 1). Separately, the Federal-Aid Highways 2035 Transportation Plan for the District of Hawai‘i (CH2M Hill, 2014) forecasts a compounded annual increase of 2.12% in the planning district of Puna between 2020 to 2035. In the surrounding area, both the Kea‘au Villages Master Plan TIAR and the Kea‘au Mountain View Public Library TIAR applied a de facto growth rate of 0.50%, derived from the 2035 Travel Demand Forecasting Model. For the proposed Medical Clinic, a higher forecasted growth rate of 2.12% was used to better reflect anticipated future growth and account for developments that may be completed but not individually included in the 2028 background growth. Therefore, a 2.12% compounded annual growth rate was applied to through volumes along Route 11, Route 130, and Route 139, as well as to the southbound left-turn movement from Route 11 to Route 130 and the westbound right-turn movement from Route 130 to Route 11, given their regional significance between Hilo and Pahoa. B. Upcoming Planned Projects 1. STIP Research was completed on July 31, 2025 at the Statewide Transportation Improvements Program (STIP) FY 2025-2028 website. The STIP is a four-year forecast that identifies state and county transportation projects to be funded with Federal Highway and Federal Transit funds. The latest STIP was revised and processed on June 16, 2025. One project was identified within the vicinity of the proposed Medical Clinic which may impact traffic operations. a) HS17 Keaau-Pahoa Route (RTE 130) Improvements, Keaau Bypass to Pahoa-Kapoho Road The HS17 Keaau-Pahoa Route (RTE 130) Improvements, Keaau Bypass to Pahoa-Kapoho Road proposes to improve traffic circulation and safety along Route 130. The estimated project cost is $19,000,000. There is no estimated construction timeline available. 2. OEQC Research was completed on July 31, 2025 at the State of Hawai‘i Office of Environmental Quality Control (OEQC) website. The OEQC website provides Environmental Impact Statement (EIS) and Environmental Assessments (EA) available to the public. As of July 2021, the OEQC was renamed the Environmental Review Program (ERP), but the URL led to the old OEQC website. Projects from -19 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 the OEQC website in the surrounding area from (2020-2025) were reviewed. Two projects were identified to impact the proposed Medical Clinic. a) Kea‘au Villages Master Plan W.H. Shipman Limited is proposing to develop the Kea‘au Villages Master Plan (Wilson Okomoto, 2020) which will include residential, office, hotel, commercial and retail uses. This masterplan is an update to the previous 2016 Traffic Impact Report for the Kea‘au Villages Master Plan Phase 1 & 2 to incorporate changes to the project development plan. The Kea‘au Villages is proposed to be constructed in three major phases. The completion years for Phase 1, Phase 2, and Phase 3 was estimated to be 2023, 2028, and 2038, respectively. However, the Kea‘au Villages Master Plan appears to be significantly delayed, and existing conditions show that construction has not yet started. Given this, it is assumed that no construction will begin within the three-year timeframe between the Existing conditions and the Kea‘au Villages Master Plan Future occupation year. Therefore, it is expected that the development of the Kea‘au Villages would not impact the traffic operations of the proposed Medical Clinic. b) Kea‘au Mountain View Public Library (ATA, 2023) The Kea‘au Mountain View Public Library TIAR analyzed a proposed 12,000 sf public library with 42 parking stalls located northeast of the intersection of Route 139 and Old Volcano Road. The proposed library will replace the existing library located on Kea‘au Middle School and Mountain View Elementary School campus. The library is anticipated to be completed in 2027 and therefore will be included in this proposed Medical Clinic’s future analysis. The library is proposed to generate 42 and 43 AM and PM peak hour trips, respectively. Applicable library generated trips were included in the Future Without Project and Future With Project conditions. Library generated trips were distributed using Existing (2025) traffic patterns. C. Future (2028) Without Project Traffic Volumes The Future (2028) Without Project traffic volumes were calculated by adding the trips generated from the Kea‘au Public Library with the 2028 background growth volume (see Figure 6). D. Future (2028) Without Project LOS Future (2028) Without Project intersection and movement LOS and delay (in seconds per vehicle) were determined for the AM and PM peak hours using Synchro 11 traffic analysis software. Results are shown in Table 6. Signal timings were optimized for analysis. Movements that operate at LOS E or worse are highlighted in yellow and discussed below. Future (2028) Without Project Synchro worksheets can be found in Appendix C. -20 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 6: Future (2028) Without Project Intersection Peak Hour Volumes -21 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Table 6: Future (2028) Without Project LOS Intersection Movement AM Peak PM Peak LOS Delay (s/veh) v/c LOS Delay (s/veh) v/c Route 11 and Route 130 B 13.9 -C 20.2 - Route 11 NB Through B 14.2 0.69 C 29.3 0.79 Route 11 SB Left C 27.5 0.84 C 29.3 0.92 Route 11 SB Through A 1.8 0.30 A 3.1 0.44 Route 130 WB Left D 35.3 0.50 D 35.4 0.62 Route 11 and Route 139/Shipman Park Driveway C 23.2 -C 23.3 - Route 11 NB Left D 38.5 0.49 C 33.3 0.48 Route 11 NB Through-Right C 24.2 0.81 B 19.9 0.69 Route 11 SB Left D 52.5 0.83 E 66.3 0.94 Route 11 SB Through-Right B 14.2 0.37 B 16.9 0.66 Shipman Park EB Left-Through-Right B 13.5 0.07 B 11.5 0.08 Route 139 WB Left-Through C 20.6 0.56 B 14.9 0.39 Route 11 and Pa‘ahana Street/Na‘auao Road C 25.0 -C 22.4 - Route 11 NB Left D 49.3 0.78 F 86.1 0.36 Route 11 NB Through-Right C 20.6 0.73 A 9.8 0.29 Route 11 SB Left D 46.1 0.52 E 72.5 0.63 Route 11 SB Through C 26.4 0.67 B 19.9 0.84 Route 11 SB Right B 19.1 0.29 A 5.4 0.02 Pa‘ahana EB Left C 31.4 0.60 E 64.4 0.57 Pa‘ahana EB Left-Through-Right C 29.2 0.52 E 61.4 0.48 Na‘auao WB Left-Through-Right C 30.6 0.28 E 63.2 0.08 Route 130 and Route 139 B 18.1 -C 26.8 - Route 130 NB Left D 39.8 0.91 E 61.9 0.88 Route 130 NB Through B 13.1 0.87 A 7.6 0.40 Route 11 SB Through C 20.2 0.43 C 32.6 0.93 Route 139 EB Left C 27.3 0.29 C 24.0 0.11 Route 139 EB Right B 13.4 0.41 C 30.0 0.80 1. Route 11 and Route 130 Route 11 and Route 130 is projected to operate at LOS B and LOS C during the AM and PM peak hour, respectively. All movements are projected to operate at LOS D or better. 2. Route 11 and Route 139/Shipman Park Driveway The intersection of Route 11 and Route 139 is projected to operate at LOS C for both the AM and PM peak hour. The SB left turn is projected to operate at LOS E (v/c of 0.94) during the PM peak hour. The existing SB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. The future SB left turn queue is expected to also clear every cycle. All other movements are projected to operate at LOS D or better. No mitigation is recommended for this intersection. -22 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 3. Route 11 and Pa‘ahana Street/Na‘auao Road The intersection of Route 11 and Pa‘ahana Street/Na‘auao Road is projected to operate at LOS C during both the AM and PM peak hour. Several movements operate at LOS E or worse during the PM peak hour. The delays are caused by a combination of the cycle length, the signal prioritizing the major NB and SB through movements, and the split phasing for the EB and WB approaches. The NB left turn is projected to operate at LOS F (v/c of 0.36) but with a volume of only 4 vph. The NB left turn will not have any issues clearing the intersection. The SB left turn is projected to operate at LOS E (v/c of 0.63) with a volume of 64 vph, or about one vehicle per minute. The SB left turn will not have any issues clearing the intersection. The EB left and shared left-through- right lanes are projected to operate at LOS E, with a v/c of 0.57 and 0.48 respectively. The WB approach is projected to operate at LOS E with a v/c of 0.08. The minor street volumes are not significant, and the delays are caused by the cycle length and split phasing. The EB and WB approaches are not expected to have any issues clearing the intersection. 4. Route 130 and Route 139 The intersection of Route 130 and Route 139 operates at LOS B and LOS C during the AM and PM peak hour, respectively. The Route 130 northbound left turn movement operates at LOS E (v/c of 0.88) during the PM peak hour. The NB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. All other movements operate at LOS D or better during both peaks. No mitigation is recommended for this movement. -23 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 IV. Future (2028) With Project Conditions Current plans are for the development of a medical office building with approximately 40,000 sf of building space with an associated 204-stall off-street parking lot. As part of the proposed Medical Clinic, a new roadway is proposed to be built off the intersection of Route 11 and Route 139 extending from the Shipman Park Driveway to provide access into the new medical office. Clinic hours have not been determined at this time. Most of the clinics in the surrounding region, including Hilo, are in operation during the both the AM and PM peak hours and so for the purposes of this study, it was assumed the proposed Medical Clinic will be open during those time as well. A. Future (2028) With Project Generated Volumes The expected traffic from the proposed Medical Clinic was determined using the following four- step methodology: trip generation, trip distribution, modal choice, and route assignment. 1. Trip Generation The trip generation methodology is typically based upon rates developed by the ITE and published in the Trip Generation Manual, 11th Edition (ITE, 2021). The ITE trip rates are developed by correlating the total vehicle trip generation data with various activity/land use characteristics. Clinic (ITE Code 630) was used to generate trips for the planned development. Trip generation rates are shown in Table 7. Table 7: ITE Trip Generation – Equation and Rates for Medical Clinics Land Use ITE Code Independent Variable AM Peak Hour of Adjacent Street (7 to 9 AM) PM Peak Hour of Adjacent Street (4 to 6 PM) Equation In % Out % Equation In % Out % Clinic 630 1,000 SF GLA T = 2.19(X) + 8.68 81 19 T = 3.53(X) + 2.98 30 70 The resulting Medical Clinic generated volumes are shown in Table 8. Table 8: ITE Trip Generation – Medical Clinic Related Trips Land Use ITE Code Independent Variable AM Peak Hour of Adjacent Street (7 to 9 AM) PM Peak Hour of Adjacent Street (4 to 6PM) In Trips Out Trips Total In Trips Out Trips Total Clinic 630 1,000 SF GLA 78 18 96 43 101 144 2. Trip Distribution/Assignment The surrounding area population and historic HDOT traffic volumes were used to determine the anticipated trip distribution of the proposed Medical Clinic. Population size was obtained from the 2020 U.S Census Bureau Census Designated Places (CDP) (see Figure 7). The CDPs within the east Hawai‘i region were geologically divided into three sections based on their proximities to -24 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Route 11, Route 130, and Route 139. The population for each CDP was aggregated to determine the percentage of residents within each grouping as shown in Table 9. Figure 7: East Hawaii Census Designated Place Groupings It was found that the 2020 Census volumes were comparable to the HDOT volume distribution along Routes 11, 130, and 139. It was assumed that the proposed Medical Clinic would serve residents of East Hawai‘i proportional to their population with the exception of Hilo given that the majority of residents have closer facilities. Using the percentages shown in Table 10, it was assumed that 60%, 30%, and 5% would travel along Route 130, Route 11, and Route 139, respectively to get to and from the Medical Clinic. The remaining 5% was conservatively assumed to come from Hilo to capture any potential trips that may originate in that area. The proposed Medical Clinic generated trips are shown in Figure 8. -25 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Table 9: Census Designated Places Population To/From CDP 2020 Population Percentage Pāhoa Hawaiian Paradise Park 14,957 62% Hawaiian Beaches 3,976 Pāhoa 924 Nanawale Estates 1,652 Leilani Estates 1,139 Kamaili 157 Orchidlands Estates 3,165 Tiki Gardens 555 Ainaloa 3,609 Black Sands 416 Kalapana 167 Mountain View Kurtistown 2,151 35% Hawaiian Acres 3,426 Mountain View 4,215 Fern Acres 1,965 Eden Roc 1,386 Fern Forest 1,150 Royal Hawaiian Estates 790 Mauna Loa Estates 1,057 Volcano 736 Volcano Golf Course 363 Kea‘au Kea‘au 1,195 2% Total 49,151 100% Table 10: Census and Traffic Volume Comparison with Resulting Trip Distribution Percent To/From 2020 CDP Population 24 Hour Bi-Directional AADT Recommended Rounded Trip Distribution (%) Route 130 From Pāhoa/HPP 62% 65% 60 Route 11 From Kurtistown/Mountain View 35% 35% 30 Route 139 From Downtown Kea‘au 2% -5 Percentage from Hilo --5 3. Modal Choice All Medical Clinic-related external trips were assumed to be by private vehicle. This reflects the worst-case traffic condition with all trips occurring by private vehicle. Resulting Future (2028) With Project volumes are shown in Figure 9. -26 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 8: Proposed Medical Clinic Generated Trips -27 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 Figure 9: Future (2028) With Project Volumes -28 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 B. Future (2028) With Project LOS Future (2028) with Project intersection and movement LOS and delay (in seconds per vehicle) was determined for the AM and PM peak hours using Synchro 11 traffic analysis software. The Future (2028) with Project traffic operations is shown in Table 11. The signal timing was kept the same as in the Existing (2025) analysis to allow for a clearer comparison of operational impacts from increased traffic volumes using an identical cycle length. Movements that operate at LOS E or worse are highlighted in yellow and discussed below. Future (2028) With Project Synchro worksheets can be found in Appendix D. Table 11: Future (2028) With Project LOS Intersection Movement AM Peak PM Peak LOS Delay (s/veh) v/c LOS Delay (s/veh) v/c Route 11 and Route 130 B 13.9 -C 20.2 - Route 11 NB Through B 14.2 0.69 C 29.5 0.80 Route 11 SB Left C 27.5 0.84 C 29.3 0.92 Route 11 SB Through A 1.8 0.30 A 3.4 0.44 Route 130 WB Left D 35.3 0.50 D 35.4 0.62 Route 11 and Route 139/Shipman Park Driveway C 26.9 -C 23.1 - Route 11 NB Left D 44.6 0.63 C 31.5 0.53 Route 11 NB Through-Right C 28.8 0.82 B 19.9 0.69 Route 11 SB Left D 54.5 0.82 E 66.3 0.94 Route 11 SB Through-Right B 18.2 0.39 B 17.7 0.68 Shipman Park EB Left-Through-Right B 14.4 0.09 B 12.8 0.23 Route 139 WB Left-Through C 22.6 0.60 B 15.4 0.45 Route 11 and Pa‘ahana Street/Na‘auao Road C 25.2 -C 23.2 - Route 11 NB Left D 49.3 0.78 F 86.1 0.36 Route 11 NB Through-Right C 21.0 0.74 A 9.8 0.29 Route 11 SB Left D 46.1 0.52 E 72.5 0.63 Route 11 SB Through C 26.7 0.68 C 21.7 0.86 Route 11 SB Right B 19.1 0.29 A 5.4 0.02 Pa‘ahana EB Left C 31.4 0.60 E 64.4 0.57 Pa‘ahana EB Left-Through-Right C 29.2 0.52 E 61.4 0.48 Na‘auao WB Left-Through-Right C 30.6 0.28 E 63.2 0.08 Route 130 and Route 139 B 18.6 -C 30.6 - Route 130 NB Left D 40.5 0.92 E 65.3 0.91 Route 130 NB Through B 13.1 0.87 A 7.6 0.40 Route 11 SB Through C 22.0 0.47 D 37.1 0.96 Route 139 EB Left C 27.3 0.29 C 24.0 0.11 Route 139 EB Right B 12.3 0.40 D 36.5 0.88 1. Route 11 and Route 130 Route 11 and Route 130 is projected to operate at LOS B and LOS C during the AM and PM peak hour, respectively. All movements are projected to operate at LOS D or better. No mitigation is recommended for this intersection. -29 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 2. Route 11 and Route 139/Shipman Park Driveway The intersection of Route 11 and Route 139 is projected to operate at LOS C for both the AM and PM peak hour. The SB left turn is projected to operate at LOS E (v/c of 0.94) during the PM peak hour. The existing SB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. The future SB left turn queue is expected to also clear every cycle. All other movements are projected to operate at LOS D or better. No mitigation is recommended for this intersection. 3. Route 11 and Pa‘ahana Street/Na‘auao Road The intersection of Route 11 and Pa‘ahana Street/Na‘auao Road is projected to operate at LOS C during both the AM and PM peak hour. Several movements operate at LOS E or worse during the PM peak hour. The delays are caused by a combination of the cycle length, the signal prioritizing the major NB and SB through movements, and the split phasing for the EB and WB approaches. The NB left turn is projected to operate at LOS F (v/c of 0.36) but with a volume of only 4 vph. The NB left turn will not have any issues clearing the intersection. The SB left turn is projected to operate at LOS E (v/c of 0.63) with a volume of 64 vph, or about one vehicle per minute. The SB left turn will not have any issues clearing the intersection. The EB left and shared left-through- right lanes are projected to operate at LOS E, with a v/c of 0.57 and 0.48 respectively. The WB approach is projected to operate at LOS E with a v/c of 0.08. The minor street volumes are not significant and the delays are caused by the cycle length and split phasing. The EB and WB approaches are not expected to have any issues clearing the intersection. No mitigation is recommended for this intersection. 4. Route 130 and Route 139 The intersection of Route 130 and Route 139 operates at LOS B and LOS C during the AM and PM peak hour, respectively. The Route 130 northbound left turn movement operates at LOS E (v/c of 0.91) during the PM peak hour. The NB left turn green time varied, with observations indicating that the signal adjusted to allow the queue to clear each cycle. All other movements operate at LOS D or better during both peaks. No mitigation is recommended for this movement. -30 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 V. Summary and Recommendations HHSC is proposing to develop a new medical clinic in Kea‘au, on the Island of Hawai‘i, with approximately 40,000 square feet (sf) of building space. The parking lot will comprise of 22 ADA compliant perpendicular parking stalls and 182 standard perpendicular parking stalls. Construction is estimated to be completed by 2028. Site access is proposed off a new roadway proposed to run east-west from Shipman Park Driveway before turning north-south, connecting to the proposed Medical Clinic. Future (2028) Without Project analysis added a 2.12% annual background growth for major movements, along with projected trips associated with the Kea‘au Mountain View Public Library relocation. All signalized intersections are projected to operate at an acceptable LOS. Movements that are projected to operate at LOS E or worse are not significant. There are no recommended improvements for Future (2028) Without Project conditions. All signalized intersections are projected to operate at an acceptable LOS under Future (2028) With Project conditions. Movements expected to operate at LOS E or worse are not considered significant. Therefore, no improvements are recommended for Future (2028) With Project conditions. In addition, no changes to the intersection configuration at Route 11 and Route 139/Shipman Park Driveway are required to accommodate the proposed Medical Clinic generated trips. -31 - HHSC Kea‘au Medical Office SSFM International Traffic Impact Analysis Report January 2026 VI. References ATA, Inc. Kea‘au-Mountain View Public Library TIAR, July 2023. County of Hawai‘i. Hawaii Island Hele-On Bus, <http://heleonbus.org>. a FHWA. Manual on Uniform Traffic Control Devices, 2023 Edition. Office of Environmental Review Program (ERP). EA and EIS Online Library, Accessed 2023, <https://planning.hawaii.gov/erp/>. State of Hawai‘i, Department of Transportation. Bike Plan Hawaii, September 2003. State of Hawai‘i, Department of Transportation. Federal-Aid Highways 2035 Transportation Plan for the District of Hawaii, July 2014. State of Hawai‘i, Department of Transportation. FY 2025-2028 Statewide Transportation Improvements Program (STIP), <http://hawaii.gov/dot/highways/STIP> State of Hawai‘i, Department of Transportation. Historical Traffic Station Maps 2013-2022. Transportation Research Board, National Research Council. Highway Capacity Manual, Washington, D.C., 2016 Edition. Wilson Okamoto Corporation. Kea‘au Villages Master Plan Phase 1 & 2 TIR, July 2017. -32 - APPENDIX B Early Consultation Comments C. Kimo Alam1.-da, PhD Mayor Talmadge J. Magno Ciril Di'frnse AcfministratorWilliam V. Brilhante Jr. Managing Director ©:ounfJ! of ~afuaii Merrick Nishimoto CIVIL DEFENSE AGENCYDeputy Managing Diri'ctor 920 Ulul:mi Stn.'Ct • Hilo, Hawai'i 96710-3958 (808) 935-0031 August 6, 2025 Land Planning Hawai 'i LLC 194 Wiwo'ole Street Hilo, HI 96720 info(p,landplanninghawaii.com Subject: Early Request for Comment -Kea'au Outpatient Center EA Aloha, Thank you for the opportunity to provide early comments on the proposed Environmental Assessment (EA) for the Kea'au Outpatient Center. After review, the Hawai'i County Civil Defense Agency offers the following initial concerns and recommendations: I. Traffic Concerns The proposed location at the intersection of Kea'au-Pahoa Road and Volcano Road is already prone to significant congestion. The additional traffic generated by staff, patients, and service vehicles will likely worsen this issue. A comprehensive Traffic Impact Analysis Report (TIAR) will be essential to assess whether the existing infrastructure can support the increased load, and if not, what mitigation measures will be implemented. 2. Alternate Site Consideration It was our understanding that earlier plans had considered a location near Kea'au High School, which appeared to be a more favorable site in terms ofaccess and potential impacts. We would appreciate clarification on why that location is no longer being pursued and how this current site was selected. 3. Roadway Connectivity There was also previous discussion regarding improved roadway connectivity in this area, including the possibility ofa major roadway connecting from Puna through Waiakea Uka to the Daniel K. Inouye Highway (Saddle Road/Steinbeck Highway). This type ofconnection would significantly improve emergency access and reduce regional traffic pressure. We would like to know whether this connection is still being considered and how the current project may impact or limit future roadway planning. We look forward to reviewing the completed EA and continuing coordination to ensure that public safety and emergency access considerations are incorporated into this project. Mahalo,Ji:;;; Tal~e-M~ Administrator, Hawai 'i Cou ty Civil Defense Agency Hawai'i County is an equal opportunity provider and 1.'111ploycr C. Kimo Alameda, Ph.D. Benjamin T. Moszkowicz Mayor Police Chief William V. Brilhante, Jr. Reed K. Mahuna Managing Director Deputy Police Chief County of Hawai'i POLICE DEPARTMENT 349 Kapi'olani Street • Hilo, Hawai'i 96720-3998 (808) 935-3311 • Fax (808) 961-2389 August 11, 2025 John Pipan Planning Administrator Land Planning Hawaii, LLC 194 Wiwo'ole Street Hilo, Hawaii 96720 Email: info@landplanninghawaii.com Dear Mr. Pipan, SUBJECT: EARLY REQUEST FOR COMMENT FOR A HAWAI'I ENVIORNMENTAL POLICY ACT (HEPA) ENVIRONMENTAL ASSESSMENT (EA) RE: KEA'AU OUTPATIENT CENTER-HILO BENIOFF MEDICAL CENTER (HBMC) NEW LOCATION APPLICANT: HILO BENIOFF MEDICAL CENTER (HBMC) LOCATION: KEA'AU, PUNA HAWAI'I TMK (3) 1-6-003: 127 (POR.), TMK (3) 1-6-003: 007 (POR.) This is in response to your letter dated July 24, 2025, in which you requested input for an Environmental Assessment (EA) in accordance with the Hawaii Environmental Policy Act (HEPA) on behalf of HBMC in order to determine possible impacts associated with the proposed development, in accordance with Chapter 343 of the Hawai'i Revised Statutes and Title 11, Chapter 200.1 of the Hawai'i Administrative Rules (HAR). Staff, upon reviewing the provided documents, does not anticipate any significant impact on traffic and/or public safety concerns. Thank you for allowing us the opportunity to comment. If you have any questions, please contact our Puna District Commander, Captain Todd Pataray at (808) 965-2716 or email Todd.Pataray@hawaiicounty.gov. Sincerely, NNETH A.K. 0 ASSISTANT POLICE CHIEF AREA I OPERATIONS "Hawai'i County is an Equal Opportunity Provider and Employer" KEITH T. HAYASHIJOSH GREEN, M.D. SUPERINTENDENT GOVERNOR C. Kimo Alameda, Ph.D. John Pipan Land Planning Hawai'i LLC Page 2 September 24, 2025 Based on our review of the available project information, we offer the following early consultation comments for consideration in the preparation of the Draft Environmental Assessment, pursuant to HRS Chapter 343. 1. The subject parcel, identified as TMK (3) 1-6-003:127, is approximately 108.761 acres in size. It is primarily designated Urban, with a small portion designated Agricultural by the State Land Use Commission. The Hawai'i County General Plan Land Use Pattern Allocation Guide (LUPAG) Map designates the parcel as Urban Expansion (ue). It is zoned Agricultural 20-acres (A-20a) and Industrial-Commercial Mixed Use (MCX-20) by the County ofHawai'i. It is not situated within the Special Management Area (SMA). Parcel identified as TMK (3) 1-6-003:007 is approximately 1,235.835 acres in size. It is designated Agriculture and Urban by the State Land Use Commission, and the Hawai'i County General Plan Land Use Pattern Allocation Guide (LUPAG) Map designates the parcel as Urban Expansion (ue) and Important Agricultural Lands (ial). It is zoned Agricultural 20-acres (A-20a) by the County of Hawai'i. This parcel is not situated within the Special Management Area (SMA). 2. According to the County of Hawai'i Real Property Tax records, these parcels are privately owned by W. H. Shipman, LTD. The proposed use of State or County funds triggers the Hawai'i Revised Statutes Chapter 343 environmental review process (HAR §11-200.1-13). 3. In Agricultural zoned areas, a Special Permit and a Use Permit are required for medical clinics in accordance with the Hawai' i County Zoning Code Section 25-5-72( d)(7) and 25-2-61(a)(9). In areas zoned MCX, the Hawai'i County Zoning Code Section 25-5­ 132(a)(31) identifies medical clinics as a permitted use. A medical clinic is defined as an office building or group of offices for persons engaged in the practice of a medical or dental profession or occupation. 4. Ordinance 2002-023, effective on February 28, 2002, allowed for rezoning a portion of parcel identified as TMK (3) 1-6-003:127 from A-20a to MCX-20, with conditions. Please adhere to the conditions set forth in the ordinance. 5. Include an analysis in the Draft Environmental Assessment addressing protective design measures in wastewater management; stormwater management; drainage, erosion, and sediment control; and spill prevention and response protocols. Please consult with the County of Hawai'i Department of Environmental Management and the DLNR Hawai'i Association of Conservation Districts and Soil & Water Conservation Districts. 6. Please consult with the County of Hawai'i's Department of Water Supply to discuss water availability and potential impacts to potable water resources, and the project's anticipated water demand. The Draft Environmental Assessment should summarize these consultations, including items discussed, recommendations provided, and commitments or design modifications resulting from these discussions. John Pipan Land Planning Hawai'i LLC Page 3 September 24, 2025 7. Please provide an explanation about the considerations taken for alternative access to the development. Specifically, proposing to create a 0.5-mile-long access road to the Kea'au­ Pahoa Road instead of, or in addition to, connecting to the adjacent Shipman Industrial Area. Please provide an evaluation of reasonable access alternatives, and discuss the comparative environmental, cultural, and infrastrncture impacts of each alternative. 8. Please consult with the Department of Land and Natural Resources Hawai'i Invasive Species Council and the USDA Forest Service for regulations and best practices to prevent and control the spread and/or introduction of invasive pest species during the constrnction of the project. Additional consultation may include the Big Island Invasive Species Committee. Summarize the discussions and recommendations provided and commitments resulting from these discussions. 9. Conduct an analysis of potential critical or native habitat areas or species and provide mitigating measures as necessary. Consider incorporating the use of native plants into the landscaping plan. Utilizing native plant species can help to reduce maintenance costs and support the preservation of Hawai'i's unique natural environment. We encourage consultations with experts such as the University of Hawai'i's College of Tropical Agriculture and Human Resources. 10. In addition to agency consultations, please engage in early and meaningful consultation with the Kea'au community, consistent with HAR 11-200.1. As part of this process, the Puna Community Development Action Committee may serve as a valuable resource for community engagement, helping to identify stakeholders and gathering input on cultural, environmental, or other concerns related to the project. If you have any questions about this correspondence, please contact Kim Tanaka at (808) 961­ 8833 or via email at kim.tanaka@hawaiicounty.gov. Sincerely, 'Dethart Morr/sort Bethany Morrison Sep 24, 2025 10:50:42 HST) ft7V" JEFFREY W. DARROW Planning Director KLT:ad \lhawaiicounty.gov\Depts\PLIPL\planninglpubliclwpwin60\CH343\2025\PL-ENV-2025-000046 Keaau Outpatient Center\2023-09-24 PL-INT­ 2025-000046 Keaau Outpatient Center.doc JOSH GREEN, M.D. GOVERNOR KE KIAʻĀINA STATE OF HAWAIʻI | KA MOKUʻĀINA ʻO HAWAIʻI DEPARTMENT OF TRANSPORTATION | KA ʻOIHANA ALAKAU 869 PUNCHBOWL STREET HONOLULU, HAWAII 96813-5097 EDWIN H. SNIFFEN DIRECTOR KA LUNA HOʻOKELE Deputy Directors Nā Hope Luna Hoʻokele DREANALEE K. KALILI TAMMY L. LEE CURT T. OTAGURO ROBIN K. SHISHIDO IN REPLY REFER TO: DIR0002308 HWY-PL 25-2.35109 August 27, 2025 Mr. John Pipan Planning Administrator Land Planning Hawaii, LLC 194 Wiwoole Street Hilo, Hawaii  96720 Dear Mr. Pipan: Subject: Request for Early Consultation Comments Draft Environmental Assessment (DEA) Keaau Outpatient Center – Hilo Benioff Medical Center Keaau, Puna, Hawaii Tax Map Key No. (3) 1-6-003: 007 and 127 (por.) Thank you for your letter requesting our comments for an upcoming DEA under the requirements of Hawaii Revised Statutes Chapter 343 involving the use of county or state funds. We apologize for the delay in response. The applicant is proposing to develop a new medical facility within a 20-acre portion of agricultural land to meet the growing demands in the Puna area. The proposed project includes new construction of a medical building and a parking lot to serve primary care, specialty clinics and lab services seven days per week. We have reviewed the submitted application 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 2025-039. Sincerely, EDWIN H. SNIFFEN Director of Transportation Attachment ATTACHMENT The Hawaii Department of Transportation Comments DIR0002308 No. Comment 1. The project site is adjacent to Volcano Road (State Route 11), with the proposed access roadway located off Old Keaau Pahoa Road. 2. A Traffic hnpact Analysis Repo1i should be prepared by a licensed professional engmeer. 1. Our Hawaii District Engineer recommends that specific intersections and traffic signal locations be included in the study as follows: a. Kamehameha Schools Hawaii Keaau Campus Paahana Street (State Route 11) at traffic signal b. Herbe1i Shipman Park-Old Keaau Pahoa Road (State Route 139) at traffic signal c. Keaau Bypass - Keaau Pahoa Road (State Route 130) at traffic signal d. Shipman Industrial Park -Kipimana Street at tempora1y traffic signal e. Old Volcano Road and Old Keaau Pahoa Road (State Route 139) at traffic signal 2. A discussion ofmultimodal conditions to include a description ofthe infrastrncture for pedestrians, bicyclists, and transit riders at the site or the nearby intersection. Include qualitative assessment for the potential adverse impacts on safety for all users. Describe strategies to reduce carbon emissions from the project, if any. Suggestions include: 1. Incmporate elements that encourage and enhance the use of multiple types of transpo1iation to reduce carbon emissions. 2. hnplement energy-efficient technologies and practices, such as light-emitting diode lighting. 3. Use sustainable, recycled, or low-emission materials in constrnction and manufacturing. JOSH GREEN, M.D. GOVERNOR | KE KIAʻĀINA SYLVIA LUKE LIEUTENANT GOVERNOR | KA HOPE KIAʻĀINA DAWN N. S. CHANG CHAIRPERSON BOARD OF LAND AND NATURAL RESOURCES COMMISSION ON WATER RESOURCE MANAGEMENT STATE OF HAWAIʻI | KA MOKUʻĀINA ʻO HAWAIʻI DEPARTMENT OF LAND AND NATURAL RESOURCES KA ‘OIHANA KUMUWAIWAI ʻĀINA LAND DIVISION P.O. BOX 621 HONOLULU, HAWAII 96809 September 2, 2025 John Pipan, Planning Administrator Land Planning Hawaii LLC via email: info@landplanninghawaii.com 194 Wiwo’ole St. Hilo, Hawai’i 96720 SUBJECT: Early Request for Comment for a Hawai’i Environmental Policy Act (HEPA) Environmental Assessment (EA) for the Kea’au Outpatient Center - Hilo Benioff Medical Center located in Kea’au, Puna, Hawai’i TMK (3) 1-6-003:127 (por.), TMK (3) 1-6-003:007 (por.) Dear Mr. Pipan: Thank you for the opportunity to review and comment on the subject matter. The Land Division of the Department of Land and Natural Resources (DLNR) distributed or made available a copy of your request to the DLNR Divisions for their review and comments. Currently, we have received two responses: 1) from the Hawai’i District Land Division office dated August 18, 2025 and 2) from the Engineering Division dated August 27, 2025. If you have any questions, please contact Raymond Severn at (808) 587-0554 or email raymond.severn@hawaii.gov. Sincerely, Ian C. Hirokawa Acting Land Administrator Enclosures cc: Central Files ------------------------------------- JOSH GREEN, M.D. GOVERNORIKE KIA'AINA SYLVIA LUKE LIEVTENANT GOV1:RNOR IKA HOPE KIA'AINA DEPARTMENT OF LAND AND NATURAL RESOURCES ENGINEERING DIVISION LD/Ian C. Hirokawa Ref: Early Request for Comment for a HEP A Environmental Assessment (EA) for the Kea'au Outpatient Center - Hilo Benioff Medical Center in Kea'au, Puna, Hawai'i Location: Kea'au, Puna, Hawai'i TMK(s): (3) 1-6-003:127 (por.) and (3) 1-6-003:007 (por.) Applicant: John Pipan, Land Planning Consultants for Hilo Benioff Medical Center, Applicants COMMENTS The rules and regulations of the National Flood Insurance Program (NFIP), Title 44 of the Code of Federal Regulations (44CFR), are in effect when development falls within a Special Flood Hazard Area (high-risk areas). Be advised that 44CFR, Chapter 1, Subchapter B, Part 60 reflects the minimum standards as set forth by the NFIP. Local community flood ordinances may stipulate higher standards that can be more restrictive and would take precedence over the minimum NFIP standards. The owner of the project property and/or their representative is responsible for researching the Flood Hazard Zone designation for the project. Flood zones subject to NFIP requirements are identified on FEMA's Flood Insurance Rate Maps (FIRM). The official FIRMs can be accessed through FEMA's Map Service Center (msc.fema.gov). Our Flood Hazard Assessment Tool (FHAT) (fhat.hawaii.gov) could also be used to research flood hazard information. If there are questions regarding the local flood ordinances, please contact the applicable County NFIP coordinating agency below: o Oahu: City and County of Honolulu, Department of Planning and Permitting (808)768-8098. o Hawaii Island: County of Hawaii, Department of Public Works (808) 961-8327. o Maui/Molokai/Lanai County of Maui, Department of Planning (808) 270-7139. o Kauai: County of Kauai, Department of Public Works (808) 241-4849. Signed: DINA U. LAU, ACTING CHIEF ENGINEER Date: --------------Aug 27, 2025 JOSH GREEN, M D. GOVERNOR | KE KIAʻĀINA DAWN N.S. CHANG CHAIRPERSON KENNETH S. FINK, M.D., MGA, MPH AURORA KAGAWA-VIVIANI, PH D. WAYNE K. KATAYAMA LAWRENCE H. MI KE, M D., J D. HANNAH K HALANI SPRINGER CIARA W.K. KAHAHANE DEPUTY DIRECTOR STATE OF HAWAI‘I | KA MOKU‘ĀINA ‘O HAWAI‘I DEPARTMENT OF LAND AND NATURAL RESOURCES | KA ‘OIHANA KUMUWAIWAI ʻĀINA COMMISSION ON WATER RESOURCE MANAGEMENT | KE KAHUWAI PONO P.O. BOX 621 HONOLULU, HAWAII 96809 Sept 2, 2025 REF: RFD.6495.8 TO: Mr. Ian Hirokawa, Acting Administrator Land Division FROM: Ciara W.K. Kahahane, Deputy Director Commission on Water Resource Management SUBJECT: Kea’au Outpatient Center - Hilo Benioff Medical Center FILE NO.: RFD.6495.8 TMK NO.: (3) 1-6-003:007, (3) 1-6-003:127 Thank you for the opportunity to review the subject document. The Commission on Water Resource Management (CWRM) is the agency responsible for administering the State Water Code (Code). Under the Code, all waters of the State are held in trust for the benefit of the citizens of the State, therefore all water use is subject to legally protected water rights. CWRM strongly promotes the efficient use of Hawaii's water resources through conservation measures and appropriate resource management. For more information, please refer to the State Water Code, Chapter 174C, Hawaii Revised Statutes, and Hawaii Administrative Rules, Chapters 13-167 to 13-171. These documents are available via the Internet at http://dlnr.hawaii.gov/cwrm. Our comments related to water resources are checked off below. 1. We recommend coordination with the county to incorporate this project into the county's Water Use and Development Plan. Please contact the respective Planning Department and/or Department of Water Supply for further information. 2. We recommend coordination with the Engineering Division of the State Department of Land and Natural Resources to incorporate this project into the State Water Projects Plan. 3. We recommend coordination with the Hawaii Department of Agriculture (HDOA) to incorporate the reclassification of agricultural zoned land and the redistribution of agricultural resources into the State's Agricultural Water Use and Development Plan (AWUDP). Please contact the HDOA for more information. X 4. We recommend that water efficient fixtures be installed and water efficient practices implemented throughout the development to reduce the increased demand on the area's freshwater resources. Reducing the water usage of a home or building may earn credit towards Leadership in Energy and Environmental Design (LEED) certification. More information on LEED certification is available at http://www.usgbc.org/leed. A listing of fixtures certified by the EAP as having high water efficiency can be found at http://www.epa.gov/watersense. X 5. We recommend the use of best management practices (BMP) for stormwater management to minimize the impact of the project to the existing area's hydrology while maintaining on-site infiltration and preventing polluted runoff from storm events. Stormwater management BMPs may earn credit toward LEED certification. More information on stormwater BMPs can be found at http://planning.hawaii.gov/czm/initiatives/low-impact-development/ 6. We recommend the use of alternative water sources, wherever practicable. X 7. We recommend participating in the Hawaii Green Business Program, that assists and recognizes businesses that strive to operate in an environmentally and socially responsible manner. The program description can be found online at http://energy.hawaii.gov/green-business-program. X 8. We recommend adopting landscape irrigation conservation best management practices endorsed by the Landscape Industry Council of Hawaii. These practices can be found online at http://www.hawaiiscape.com/wp-content/uploads/2013/04/LICH_Irrigation_Conservation_BMPs.pdf. Mr. Ian Hirokawa Page 2 September 2, 2025 9. There may be the potential for ground or surface water degradation/contamination and recommend that approvals for this project be conditioned upon a review by the State Department of Health and the developer's acceptance of any resulting requirements related to water quality. 10. The proposed water supply source for the project is located in a designated water management area, and a Water Use Permit is required prior to use of water. The Water Use Permit may be conditioned on the requirement to use dual line water supply systems for new industrial and commercial developments. 11. The Hawaii Water Plan is directed toward the achievement of the utilization of reclaimed water for uses other than drinking and for potable water needs in one hundred per cent of State and County facilities by December 31, 2045 (§174C-31(g)(6), Hawaii Revised Statutes). We strongly recommend that this project consider using reclaimed water for its non-potable water needs, such as irrigation. Reclaimed water may include, but is not limited to, recycled wastewater, gray water, and captured rainwater/stormwater. Please contact the Hawai‘i Department of Health, Wastewater Branch, for more information on their reuse guidelines and the availability of reclaimed water in the project area. 12. A Well Construction Permit(s) is (are) are required before the commencement of any well construction work. 13. A Pump Installation Permit(s) is (are) required before ground water is developed as a source of supply for the project. 14. There is (are) well(s) located on or adjacent to this project. If wells are not planned to be used and will be affected by any new construction, they must be properly abandoned and sealed. A permit for well abandonment must be obtained. 15. Ground-water withdrawals from this project may affect streamflows, which may require an instream flow standard amendment. 16. A Stream Channel Alteration Permit(s) is (are) required before any alteration can be made to the bed and/or banks of a steam channel. 17. A Stream Diversion Works Permit(s) is (are) required before any stream diversion works is constructed or altered. 18. A Petition to Amend the Interim Instream Flow Standard is required for any new or expanded diversion(s) of surface water. 19. The planned source of water for this project has not been identified in this report. Therefore, we cannot determine what permits or petitions are required from our office, or whether there are potential impacts to water resources. X OTHER: Planning - The proposed water source(s) and projected water demands for the project, both potable and non-potable, should be identified and the calculations used to estimate demands should be provided. A discussion of the potential impacts on water resources and other public trust uses of water should be included, and any proposed mitigation measures described. Water conservation and efficiency measures to be implemented should also be discussed. If you have any questions, please contact Ryan Imata of the Groundwater Regulation Branch at (808) 587-0225 or Katie Roth of the Planning Branch (808) 587-0216. TABLE OF CONTENTS 1.0 CERTIFICATIONS AND LIMITATIONS ............................................................................ 1 2.0 INTRODUCTION/SCOPE OF WORK .................................................................................. 2 3.0 BACKGROUND..................................................................................................................... 3 4.0 METHODOLOGY/PURPOSE ............................................................................................... 6 5.0 RESULTS.............................................................................................................................. 12 6.0 RECOMMENDATIONS ...................................................................................................... 19 7.0 REFERENCES ..................................................................................................................... 22 TABLES Table A. Conceptual Site Model..................................................................................................... 5 Table B. Summary of Decision Units and Analysis ....................................................................6-7 Table C. Summary of Samples with COPC that Exceed the Laboratory Detection Limit ............................................................................ Appendix I Table 1. Soil Screen Summary........................................................................................ Appendix I APPENDICES Appendix I: Table 1. Soil Screen Summary Table C. Summary of Samples with COPC that Exceeded the Laboratory Detection Limit Appendix II: Figure 1: General Site Location Figure 2: Project Location Impacted Soils Figure 3: Decision Unit (DU) Boundaries Figure 4: Locations of Identified Arsenic- Appendix III: Soil Laboratory Analytical Results and Chain-Of-Custody Forms Level 2 Laboratory Report including Blank, MS/MSD and LCS/LCSD Information Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Table of Contents C/I LIST OF ACRONYMS < less than % percent %R percent recovery bgs below ground surface commercial/industrial C-EHMP Construction-Environmental Hazard Management Plan COPC chemicals of potential concern cy cubic yards DOH State of Hawaii Department of Health DU decision unit DQO data quality objective EAL Environmental Action Level EPA Environmental Protection Agency ft feet g gram HEER Hazard Evaluation and Emergency Response in inch LEI Lehua Environmental Inc. mg/kg milligrams per kilogram MI multi-increment NA not applicable ND not detected QA/QC quality assurance/quality control RCRA Resource Conservation Recovery Act SBRC Solubility/Bioavailability Research Consortium TGM Technical Guidance Manual Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic List of Acronyms 1.0 CERTIFICATIONS AND LIMITATIONS Lehua Environmental Inc. (LEI) has completed this Soil Screen for the Keaau Benioff Health Center Wellness and Behavioral Health Clinic (Project), located within a 10-acre portion of TMK: (3) 1-6-003-127 (Figure 2), in Keaau, Hawaii (Subject Site). LEI’s findings and recommendations contained herein are based on research, site observations, government regulations and laboratory data, which were gathered at the time and location of the study. Opinions stated in this report do not apply to changes that may have occurred after the services were performed. LEI has performed specified services for this project with the degree of care, skill and diligence ordinarily exercised by professional consultants performing the same or similar services. No other warranty, guarantee, or representation, expressed or implied, is included or intended; unless otherwise specifically agreed to in writing by both LEI and LEI’s Client. This report is intended for the sole use of LEI’s client exclusively for the Subject Site. LEI’s client may use and release this report, including making and retaining copies, provided such use is limited to the particular site and project for which this report is provided. However, the services performed may not be appropriate for satisfying the needs of other users. Release of this report to third-parties will be at the sole risk of LEI’s Client and/or said user, and LEI shall not be liable for any claims or damages resulting from or connected with such release or any third party's use or reuse of this report. Prepared By: Kamalana Kobayashi Senior Environmental Scientist/President Date: September 29, 2025 Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 1 2.0 INTRODUCTION/SCOPE OF WORK The objective of the Soil Screen was to identify the presence (if any) of Resource Conservation Recovery Act (RCRA) 8 metals-and organochlorine pesticide-contaminated soils within the areas of planned disturbance for the Project at the Subject Site, so that the information can be incorporated in the design of the Project. Specifically, LEI completed the following tasks: • Identified a total of twenty-four (24) decision units at the Subject Site; • Collected a total of thirty (30) multi-increment (MI) soil samples from the 24 decision units of the Subject Site, which included duplicate and triplicate samples per the Hawaii Department of Health (DOH) Hazard Evaluation and Emergency Response (HEER) Technical Guidance Manual (TGM) recommendations. Each MI soil sample included 50 increments collected utilizing DOH recommended hand tools and equipment. Samples were collected from surface soils (0-6” below ground surface (bgs)) and shallow subsurface soils (6”-12” bgs). Decision unit (DU) sizes ranged from 16,250 square feet to 20,000 square feet and the volumes ranged from 301 cubic yards (cy) to 370 cy. • Submitted the thirty (30) MI soil samples to Advanced Analytical Laboratories in Honolulu, Hawaii for the following analysis: o MIS laboratory preparation non-volatile o RCRA 8 metals by EPA 6020B/EPA 3050B o Bioaccessible arsenic by EPA 1340 o Organochlorine pesticides by EPA 8081B/3550C • Prepared this report documenting the field activities and the results of the investigation including analytical results, photographs and recommendations. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 2 3.0 BACKGROUND Site Description The project site is located on the eastern portion of the Island of Hawaii in the Puna district. Keaau lies at modest elevation of a few hundred feet above sea level. The project site includes an approximate 10-acre portion of the parcel identified by TMK: (3) 1-6-003-127. The project site is heavily vegetated with portions of the parcel used for agriculture. The parcel is zoned for agriculture use and the surrounding properties include commercial properties to the north, highway 11 to the east and vacant land to the west and south. Climate The climate in the Puna district (which includes Kea´au) has a mild tropical climate with abundant rainfall overall. The annual rainfall in Kea´au is approximately 30 inches with the wettest months being December through February. Kea´au experiences small seasonal variances in temperature, with an average mean temperature of 75 degrees Fahrenheit. Soils/Geology The Island of Hawaii is the youngest and most southeasterly of the emerged volcanic edifices of the Hawaiian chain. The island has an area of 4,038 square miles and consists of five large volcanoes including Mauna Kea, Kohala, Hualalai, Mauna Loa and Kilauea, to form the island. The island consists entirely of the slopes of these mountains and of the broad saddles between them. Soil within the project area includes Keaukaha soil series. These are very shallow, well drained soils formed in organic material overlying pahoehoe lava with a depth to rock typically from 6 inches to 20 inches. The moisture regime is often perudic being moist the majority of the year with poor drainage (USDA, 2025). Surface Water Due to the poor drainage characteristics of the Keaukaha soil series, surface water (runoff, ponding) is more likely in areas with this soil type. This suggests retention of water near the surface, slower drainage, possibly surface saturation during/after rain events. There are no other significant water features within close proximity to the project site. Groundwater The aquifer that underlies the Subject Site is the Mauna Loa Aquifer System. The aquifer’s main source is classified as basal (fresh water in contact with seawater). Although, other types of groundwater systems exist in the area due to complex volcanic geology (Mink and Lau, 1990). Historical, Current and Planned Future Land Use Public land records indicate the Subject Site was historically been used for agriculture. The site is owned by the W.H. Shipman Ltd. The future planned use of the Subject Site is a healthcare and medical facility with a parking lot. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 3 Conceptual Site Model The Conceptual Site Model (CSM) is provided in Table A below. The CSM outlines a general framework for evaluating exposure pathways, identified potential pathways for the transport of COPCs confirmed on-site; and assesses the likelihood of these pathways reaching human and ecological receptors. Potential environmental hazards considered in the CSM include direct exposure to construction workers, leaching to groundwater resources and gross contamination. Identified potential receptors for current and planned soil excavation work at the Subject Site include the construction workers for the project. The elements of the exposure pathways include the source and release of contaminants, transport of contaminants, exposure points of contact and the route of exposure (inhalation, ingestion, dermal contact, injection). Potential exposure pathways at the Subject Site largely depend on the disturbance of soil containing COPCs. Construction workers may be exposed to contaminants in the soil during earthwork activities, either through direct contact with the soil or by the generation of fugitive dust, which could lead to dermal absorption, oral ingestion, or inhalation of COPCs. Sediment from runoff may discharge into neighboring parcels due to runoff channels, or through leaching into groundwater. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 4 Table A. Conceptual Site Model Primary Sources Primary Release Mechanism Secondary Sources Potential Environmental Hazards Hazard Present Under Current Site Conditions Presence of arsenic in soil Improper handling of contaminated soil during site remedial activities Soil Risk to Human Health Exposure Type Secondary Release Mechanism Exposure Route Receptors Construction Workers Offsite Residents/General Public During Remediation Post-Remediation During Remediation Post-Remediation Direct Exposure Dust/Vapors Ingestion Yes No No No Dermal Yes No No No Inhalation Yes No No No Vapor Intrusion into Buildings Vapors Inhalation No No No No Leaching During Remediation - No expected Post-Remediation – No Gross Contamination During Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Post-Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Groundwater Risk to Human Health Exposure Type Secondary Release Mechanism Exposure Route Receptors Onsite Workers Offsite Residents/General Public During Remediation Post-Remediation During Remediation Post-Remediation Direct Exposure Dust/Vapors Ingestion No No No No Dermal No No No No Inhalation No No No No Vapor Intrusion into Buildings Vapors Inhalation No No No No Leaching During Remediation -No During Remediation -No Gross Contamination During Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Post-Remediation -No Tier 1 EAL for gross contamination of 1,000 mg/kg not exceeded Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 5 4.0 METHODOLOGY/PURPOSE This Soil Screen is limited to the Project boundaries and included a surface (0"-6" bgs) and shallow subsurface (6”-12” bgs) Soil Screen for contaminants of potential concern (COPC) with established Department of Health (DOH) Environmental Action Levels (EALs). The purpose of this Soil Screen is to provide a screen of COPCs in surface and shallow subsurface soils with planned disturbance during this project. This Soil Screen is not intended to characterize the horizontal and vertical extents of the COPC within the entire Subject Site. A Sampling and Analysis Plan (SAP) was not completed for this Soil Screen, however a SAP may be completed for the entire property and/or the soils with planned disturbance within the project boundaries, prior to further site characterization. The laboratory analytical results of this Soil Screen were used to determine if the surface and shallow subsurface soils with planned disturbance contain COPC that exceed applicable DOH commercial/industrial EALs at the Subject Site. Selection of Decision Units Twenty-four (24) decision units were designated for this project at the Subject Site. The areas included in the DUs ranged from 16,250 square feet to 20,000 square feet and the volumes ranged from 301 cubic yards (cy) to 370 cy. Based on the planned future use of the Subject Site as a commercial facility, the Tier 2 (commercial/industrial) land use maximum volume of 400 cy per DU was utilized. Soil re-use at the Subject Site is limited to commercial/industrial land use. For unrestricted land use and soil re-use, further evaluation of the soils is required to assess whether the soils are sufficient for unrestricted use. A description of each DU and sampling locations are presented in the table below: Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 6 historically used in paints. Over time, lead-based paint can flake off building surfaces, accumulating in nearby soil. Arsenic and lead are likely to remain in the upper layers of soil, as they typically do not leach downward due to their strong tendency to attach to soil particles and sediments. Soil Screen Sampling Activities LEI personnel collected fifty increments for the surface MI soil samples utilizing a 33-inch-long hand-held core sampler with a 7/8-inch diameter core. Shallow subsurface MI soil samples were collected by first utilizing a stainless-steel hand shovel to remove the top layer of soil. Once the desired depth of the sample was achieved, the 33-inch-long hand-held core sampler with a 7/8-inch diameter core was utilized to collect the MI soil sample. If rock or other underground anomalies which restricted access to deeper soil depths were encountered, a replacement MI soil sample was collected directly adjacent to the original MI soil sample location. This process was repeated until 50 increments were collected for each surface and shallow subsurface decision unit. For all non-volatile soil samples collected, each increment was taken and then placed into a double-bagged Ziploc® bag. Soil samples were placed in a field cooler with ice packs and sent to the Advanced Analytical Laboratory in Honolulu, Hawaii. MI soil sampling was chosen for the Subject Site so that reproducible data, representative of average background concentrations, can be obtained for use as reference control data. A total of twenty-four (24) DUs were identified at the Subject Site. DU boundaries were based on the location of the proposed site work and site characteristics (Figure 3, Appendix II). Each MI soil sample consisted of 50 increments. Based on sampling theory (Pitard, 1993), a minimum of 30 increments per sample is generally recommended in order to obtain a reliable estimate of the mean concentration. The DOH typically specifies the use of 30 to 100 increments per sample in their Technical Guidance Manual (DOH, 2009b). Each increment was taken from 0-6 inches below ground surface [bgs] for surface soils and from 6-12 inches bgs for subsurface soils. The location of each increment was based on a systematic random grid that was developed during the site visit. The grid was drawn with a random starting point for even distribution across the sampling area. The systematic random sampling design provided coverage of the DUs along a horizontal plane, without the gaps associated with purely random designs. Triplicate Sample Collection A duplicate sample and triplicate sample were collected from decision units: DU-10, DU-20 and DU24 at predetermined independent locations. The distance between the primary, duplicate and triplicate samples were considered adequate to evaluate variability. The DOH HEER technical guidance manual following sampling protocol was used to collect the primary, duplicate and triplicate samples: Per the recommendation provided in Section 4, Appendix L.1 of the DOH HEER technical guidance manual (DOH 2023), three separate increments were collected from each grid cell, one for each replicate sample. Samples were labeled “A”, “B” and “C” as part of the DU Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 9 identification (i.e. DU-10A, DU-10B and DU-10C). The primary, duplicate, and triplicate samples were collected from a spacing of roughly one-third the distance of the DU increment spacing, forming an equilateral triangle pattern. The triangle’s corners were labeled “A”, “B” and “C” and each point of the triangle represents the collection location for each of the replicate increments. Each increment was placed in a separate, properly labeled sampling container. Equipment Decontamination and Investigation-Derived Waste All sampling equipment used to collect MI soil samples were decontaminated prior to use between DUs. The decontamination procedure for sampling equipment is as follows: 1. Clean with distilled water and brush, if necessary, to remove particulate matter and surface films. 2. Rinse thoroughly with distilled water. 3. Rinse thoroughly with Liquinox™. 4. Rinse with distilled water. Investigation-derived waste (IDW) consisted of items such as disposable personal protective equipment (PPE), decontamination water, and rags. Each sampling event produced approximately one-quarter of a 15-gallon trash bag filled with PPE, disposable wipes, rags and paper towels, which were discarded in a municipal waste dumpster. The decontamination water was poured on site to infiltrate into the ground after field sampling was completed. Data Quality Control and Review In accordance with DOH policy, LEI implemented a 10% QC program, meaning that a duplicate and triplicate sample were taken for a minimum of 10% of primary samples, and submitted for chemical analysis. The duplicate and triplicate samples were taken from locations directly adjacent to and at approximately the same depth of the primary sample. The duplicate and triplicate samples were collected, handled, and analyzed using the same methods as the primary samples. QA of samples collected in the field was ensured through the use of trained sampling personnel, documented and standardized procedures, and collection of field QC samples. Field QC samples were analyzed for the same parameters as the primary samples. Laboratory QC samples and surrogates were analyzed according to the laboratory’s SOPs. Precision is defined as the agreement between a set of replicate measurements without assumption and knowledge of the true value. Precision was evaluated using a sample group consisting of primary, duplicate, and triplicate samples for ISM soil samples. QC samples were collected at a rate of 10% of project samples. For the ISM samples collected, the field QC sample groups consisted of a primary sample, duplicate sample, and a triplicate sample. The mean and relative standard deviations were used to evaluate the precision of the QC sample groups. If the relative standard deviation of the sample group is less than 35%, then the reported concentrations are considered precise. For the field QC samples collected from the ISM sampling all analytes had a standard deviation less than 35% for every analyte. Additionally, Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 10 laboratory QC tests were all within their acceptable ranges which points to the accuracy of the reported concentrations. Therefore, the results of all analytes are considered precise. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 11 5.0 RESULTS Arsenic Bioaccessible arsenic was detected above the Tier 1 (unrestricted land use) EAL in decision units: DU-23 and DU-24 at the Subject Site. Subsurface soils ≥12” below ground surface within decision units: DU-23, DU-24A, DU-24B and DU-24C boundaries are assumed to be arsenic-impacted soils until further testing determines otherwise. Additionally, total arsenic was detected above the Tier 1 (unrestricted) and/or Tier 2 (commercial/industrial) EAL in decision units: DU-1, DU-2, DU-3, DU-4, DU-5, DU-6, DU-7, DU-8, DU-9, DU-10A, DU-10B, DU-10C, DU-11, DU-12, DU-13, DU-14, DU-15, DU-16, DU- 17, DU-18, DU-19, DU-20A, DU-20B, DU-20C, DU-21, DU-22, DU-23, DU-24A, DU-24B and DU-24C. However, further analysis via bioaccessible arsenic did not detect concentrations of bioaccessible arsenic that exceed the Tier 1 EAL. Table 1 located in Appendix I summarizes the soil screen results for the Subject Site. Figure 4 in Appendix II identifies the locations of the identified arsenic-impacted soils at the Subject Site. Laboratory results are included in Appendix III. Remaining RCRA 8 Metals (Barium, Cadmium, Chromium, Lead, Selenium, silver and mercury) The remaining RCRA 8 metals were not detected above the applicable HDOH Tier 1 EALs. Organochlorine Pesticides Organochlorine pesticides were not detected above the applicable HDOH Tier 1 EALs. 5.1 DU-1 Surface (0”-6” bgs) Total arsenic was measured at 170 mg/kg, exceeding the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 13 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.2 DU-2 Subsurface (6”-12” bgs) Total arsenic was measured at 180 mg/kg, exceeding the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 13 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 12 5.3 DU-3 Surface (0”-6” bgs) Total arsenic was measured at 95 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 10 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.4 DU-4 Subsurface (6”-12” bgs) Total arsenic was measured at 92 mg/kg, exceeding the HDOH EAL of 24 mg/kg for unrestricted land use. However, further analysis of bioaccessible arsenic was measured at 8.7 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.5 DU-5 Surface (0”-6” bgs) Total arsenic was measured at 150 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 14 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.6 DU-6 Subsurface (6”-12” bgs) Total arsenic was measured at 150 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 13 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.7 DU-7 Surface (0”-6” bgs) Total arsenic was measured at 120 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 10 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 13 5.8 DU-8 Subsurface (6”-12” bgs) Total arsenic was measured at 120 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 9.2 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.9 DU-9 Surface (0”-6” bgs) Total arsenic was measured at 190 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 12 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.10 DU-10A Subsurface (6”-12” bgs) Total arsenic was measured at 170 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 11 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.11 DU-10B Subsurface (6”-12” bgs) Total arsenic was measured at 170 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 12 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.12 DU-10C Subsurface (6”-12” bgs) Total arsenic was measured at 170 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 11 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 14 5.13 DU-11 Surface (0”-6” bgs) Total arsenic was measured at 190 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 15 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.14 DU-12 Subsurface (6”-12” bgs) Total arsenic was measured at 180 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 15 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.15 DU-13 Surface (0”-6” bgs) Total arsenic was measured at 140 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 10 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.16 DU-14 Subsurface (6”-12” bgs) Total arsenic was measured at 140 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 11 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.17 DU-15 Surface (0”-6” bgs) Total arsenic was measured at 200 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 20 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 15 5.18 DU-16 Subsurface (6”-12” bgs) Total arsenic was measured at 190 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 17 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.19 DU-17 Surface (0”-6” bgs) Total arsenic was measured at 220 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 18 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.20 DU-18 Subsurface (6”-12” bgs) Total arsenic was measured at 240 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 16 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.21 DU-19 Surface (0”-6” bgs) Total arsenic was measured at 160 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 14 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.22 DU-20A Subsurface (6”-12” bgs) Total arsenic was measured at 180 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 13 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 16 5.23 DU-20B Subsurface (6”-12” bgs) Total arsenic was measured at 170 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 13 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.24 DU-20C Subsurface (6”-12” bgs) Total arsenic was measured at 170 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 12 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.25 DU-21 Surface (0”-6” bgs) Total arsenic was measured at 160 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 9.8 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.26 DU-22 Subsurface (6”-12” bgs) Total arsenic was measured at 200 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 14 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.27 DU-23 Surface (0”-6” bgs) Total arsenic was measured at 190 mg/kg, exceeding the HDOH EAL of 95 mg/kg for commercial/ industrial land use. Bioaccessible arsenic was measured at 26 mg/kg, exceeding the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 17 5.28 DU-24A Subsurface (6”-12” bgs) arsenic was measured at 200 mg/kg, exceeding the HDOH EAL of 95 mg/kg for commercial/ industrial land use. Bioaccessible arsenic was measured at 25 mg/kg, exceeding the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, lead, and dieldrin were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and other organochlorine pesticides were not identified above laboratory reporting limits. 5.29 DU-24B Subsurface (6”-12” bgs) Total arsenic was measured at 210 mg/kg, equal to the HDOH EAL of 95 mg/kg for commercial/ industrial land use. However, further analysis of bioaccessible arsenic was measured at 23 mg/kg, which is below the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, and lead were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and organochlorine pesticides were not identified above laboratory reporting limits. 5.30 DU-24C Subsurface (6”-12” bgs) arsenic was measured at 200 mg/kg, exceeding the HDOH EAL of 95 mg/kg for commercial/ industrial land use. Bioaccessible arsenic was measured at 24 mg/kg, equal to the HDOH EAL of 24 mg/kg for unrestricted land use. Measurable concentrations of barium, chromium, lead, and dieldrin were reported in the soil samples below the HDOH EALs. Cadmium, selenium, silver, mercury, and other organochlorine pesticides were not identified above laboratory reporting limits. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 18 6.0 RECOMMENDATIONS LEI recommends the following for the identified arsenic-impacted soils at the Subject Site: • The discovery of soil contamination at concentrations that exceeds the arsenic Tier 1 EALs indicates a release, or potential threat of a release, that may pose a risk to human health or the environment and must be addressed in accordance with the Hawaii Environmental Response Law, Hawaii Revised Statute (HRS) 128D and the State Contingency Plan, Hawaii Administrative Rule (HAR) 11-451. To ensure an adequate response and to comply with reporting requirements all new releases must be reported to HEER Office Emergency Planning and Response (EP&R) personnel following the release reporting guidance at https://health.hawaii.gov/heer/reporting/how-to-report-a- release-spill/. Newly discovered contamination from historic releases or applications that exceeds the Tier 1 and/or Tier 2 EALs and therefore poses a potential risk to human health and the environment must also be reported to EP&R personnel following the above guidance. Therefore, detection of arsenic at concentrations that exceed the Tier 1 EAL at the Subject Site must be reported with an initial verbal notification and a follow- up written notification to the HEER Office emergency responders. • Following discovery of contamination that may pose a threat to human health and/or the environment at the site, the process described in the State Contingency Plan (HAR 11- 451) and in the HEER Office technical Guidance Manual (TGM) must be followed: a. First, a site characterization must be completed to delineate the nature and extent of the contamination at the site. b. Once the site is adequately characterized, an updated Conceptual Site Model (CSM) must be prepared, and an Environmental Hazard Evaluation (EHE) must be developed. The CSM and EHE may be incorporated into the soils report or may be a stand-alone document. c. Once the environmental hazards have been identified in an EHE, remedial alternative must be considered, and a determination must be made whether a Remedial Action or a Removal Action is appropriate for the site. Guidance for selecting the appropriate Response Action is in the State Contingency Plan and in the TGM. If a Remedial Action is selected, then a Remedial Alternatives Analysis, a Draft Remedial Action Memorandum (RAM), and a Final RAM must be prepared, followed by a Response Action Work Plan (RAWP). Following the completion of a Remedial Action Work Plan (WP) and the completion of the Remedial Action, A Remedial Action Completion Report (RACR) must be prepared describing the activities conducted during the Remedial Action. d. If a Removal Action is selected, then the EHE and the assessment of Removal Action alternatives may be combined together into a Removal Action Work Plan. Following the approval of the Removal Action Work Plan and the completion of the Removal Action, a Removal Action Report (RAR) must be prepared and describe the activities conducted during the Removal Action. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 19 e. If contamination will remain on site and be managed in place as part of the Response Action, then a Long-term/Site-Specific Environmental Hazard Management Plan (EHMP) must be prepared. f. If you are not prepared to complete the required site characterization and Response Action at this time, then it may be acceptable to implement temporary institutional controls (ICs) under an Interim EHMP, with approval from the HEER Office. If additional site investigations to delineate the nature and extent of contamination at the Subject Site and evaluate the environmental hazards in accordance with State regulations and guidance will not be conducted in the near future, then a Removal Action or Interim Remedial Action to implement interim engineering and/or ICs must be conducted to mitigate and manage known and suspected environmental hazards at the Subject Site until a final response action can be selected and implemented. This requires developing an Environmental Hazard Evaluation (EHE) which can be integrated into the Interim Remedial Action Work Plan (for Interim Remedial Action) or Removal Action Work Plan (for Removal Action). Once interim controls are documented in place an Interim RACR (for Remedial Action) or RAR (for Removal Action), and all known and potential environmental hazards are satisfactorily mitigated, an Interim Environmental Hazard Management Plan (EHMP) will be required to continue to manage and maintain the interim controls until a future final remedy is implemented. • Assume subsurface soils ≥ 12” bgs within DU-23, DU-24A, DU-24B and DU-24C boundaries are arsenic-impacted soils until further testing determines otherwise. • The following recommendations should be followed in areas with soils identified to exceed the Tier 1 EAL for arsenic in soils at the Subject Site. Important Note: A Response Action in accordance with the State Contingency Plan (HAR 11-451) and the HEER Office Technical Guidance Manual (TGM) should be completed prior to preparing a C-EHMP (or C-EHMP Addendum) for redevelopment. Following the completed Response Action and prior to the start of any construction activity that disturbs soils with arsenic concentrations above DOH EAL, a project specific C-EHMP must be approved by the DOH HEER office. 1) contaminated soil removed from the Subject Site must be disposed of in accordance with Federal and State rules and regulations, 2) dust control practices should include both wetting during soil disturbance activities and monitoring by a designated competent person, in addition to containing temporary soil stockpiles, 3) use of good general hygiene practices for tenants, public, employees and workers to avoid soil exposure, 4) long-term controls should be implemented on the site to minimize the potential for exposure to contaminated soil by tenants, public, employees and workers, 5) possible need to cover any bare soil, if subject to wind or water transport off-site, 6) limit exposure to the contaminated soils to properly trained personnel. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 20 • Prepare and submit for approval to the DOH HEER office a C-EHMP which outlines the proper handling and management of soil and/or groundwater, sampling and analysis protocol for soil, the planned re-use/disposal locations for excavated soil, health and safety measures to be taken to protect workers, environment and the general public. The project specific C-EHMP must be approved by the DOH HEER office prior to the start of any construction activity that disturbs the identified contaminated soils at the Subject Site. • Have air monitoring conducted for airborne arsenic-impacted dust by qualified personnel during any contaminated soil disturbance. Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 21 REFERENCES • County of Hawaii. (2018, January 26). Hawaii County Real Property Tax Office Property Search. Retrieved September 7, 2025, from Hawaii County Real Property Tax Office: http://www.hawaiipropertytax.com • Pitard, Francis F. (1993). Pierre Gy’s Sampling Theory and Sampling Practice: Heterogeneity, Sampling Correctness, and Statistical Process Control. 2nd Ed. Boca Raton, FL: CRC Press. • Department of Health (DOH). Hazard Evaluation and Emergency Response (HEER) website, http://www.hawaiidoh.org/tgm.aspx. • DOH. (2018, May). Arsenic in Hawaiian Soils: Questions and Answers on Health Concerns. Hawaii Department of Health Hazard Evaluation and Emergency Response Office. Retrieved September 9, 2025, from http://eha-web.doh.hawaii.gov/eha- cma/Leaders/HEER/soi-arsenic-guidance-and-information • DOH. (2011, September). Termiticides Fact Sheet. • DOH. (Spring 2024). Environmental Action Levels Surfer. Retrieved from Environmental Hazard Evaluation and Environmental Action Levels: http://eha- web.doh.hawaii.gov/eha-cma/leaders/HEER/environmental-hazard-evaluation-and-environmental-action-levels • DOH. (2009a). Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater. Office of Hazard Evaluation and Emergency Response. March. • DOH. (2009b). Technical Guidance Manual for the Implementation of the Hawaii State Contingency Plan. • DOH. (Fall 2017). Environmental Action Levels Surfer. Retrieved from Environmental Hazard Evaluation and Environmental Action Levels: http://eha-web.doh.hawaii.gov/eha- cma/Leaders/HEER/environmental-hazard-evaluation-and-environmental-action-levels • DOH. (Fall 2017). Evaluation of Environmental Hazards at Sites with Contaminated Soil and Groundwater. Retrieved from http://hawaii.gov/health/environmental/hazard/index.html Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Page 22 Appendix I TABLE 1. SOIL SCREEN SUMMARY TABLE C. SUMMARY OF SAMPLES WITH COPC THAT EXCEEDED THE LABORATORY DETECTION LIMIT Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Appendix Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-1 DU-2 DU-3 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 170 2 180 2 95 2 Bioassessible Arsenic EPA 1340 24 95 13 0.1 13 0.1 10 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 6.9 5 6.4 5 5.9 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 130 2 120 2 67 2 Lead (Pb) EPA 3051m/7000Bm 200 800 4.7 1 5.2 1 2.4 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 0.002 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 1 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-4 DU-5 DU-6 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 92 2 150 2 150 2 Bioassessible Arsenic EPA 1340 24 95 8.7 0.1 14 0.1 13 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 6 5 6.3 5 4.5 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 68 2 79 2 91 2 Lead (Pb) EPA 3051m/7000Bm 200 800 2.4 1 4.1 1 3.2 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 2 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-7 DU-8 DU-9 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 120 2 120 2 190 2 Bioassessible Arsenic EPA 1340 24 95 10 0.1 9.2 0.1 12 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 7.3 5 7.7 5 7.8 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 60 2 71 2 91 2 Lead (Pb) EPA 3051m/7000Bm 200 800 2.3 1 2.3 1 4.6 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 3 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-10A DU-10B DU-10C Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 170 2 170 2 170 2 Bioassessible Arsenic EPA 1340 24 95 11 0.1 12 0.1 11 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 7.1 5 8 5 7.1 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 110 2 96 2 87 2 Lead (Pb) EPA 3051m/7000Bm 200 800 4.2 1 4.7 1 4.4 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 4 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-11 DU-12 DU-13 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 190 2 180 2 140 2 Bioassessible Arsenic EPA 1340 24 95 15 0.1 15 0.1 10 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 9.4 5 9.8 5 8.6 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 90 2 89 2 82 2 Lead (Pb) EPA 3051m/7000Bm 200 800 4.9 1 4.9 1 3.8 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 5 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-14 DU-15 DU-16 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 140 2 200 2 190 2 Bioassessible Arsenic EPA 1340 24 95 11 0.1 20 0.1 17 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 9.7 5 11 5 9.7 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 85 2 97 2 84 2 Lead (Pb) EPA 3051m/7000Bm 200 800 4 1 6.1 1 5 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 6 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-17 DU-18 DU-19 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 220 2 240 2 160 2 Bioassessible Arsenic EPA 1340 24 95 18 0.1 16 0.1 14 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 9.5 5 8.1 5 6.2 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 99 2 86 2 99 2 Lead (Pb) EPA 3051m/7000Bm 200 800 6.1 1 5.3 1 4.7 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 7 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-20A DU-20B DU-20C Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 180 2 170 2 170 2 Bioassessible Arsenic EPA 1340 24 95 13 0.1 13 0.1 12 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 6.2 5 5.6 5 5.3 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 100 2 100 2 100 2 Lead (Pb) EPA 3051m/7000Bm 200 800 5.2 1 5 1 6.3 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 0.0014 0.01 0.0027 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 8 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-21 DU-22 DU-23 Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 160 2 200 2 190 2 Bioassessible Arsenic EPA 1340 24 95 9.8 0.1 14 0.1 26 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 6.2 5 6 5 12 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 96 2 100 2 89 2 Lead (Pb) EPA 3051m/7000Bm 200 800 3.8 1 4.2 1 5.2 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 ND 0.01 ND 0.01 ND 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 9 of 10 Table 1. Soil Screen Summary Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Descriptive Sample ID DU-24A DU-24B DU-24C Analyte Laboratory Analytical Method DOH EAL Unrestricted Land Use (mg/kg) DOH EAL Commercial/ Industrial Land Use (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) Result (mg/kg) Laboratory Reporting Limit (mg/kg) RCRA 8 Metals Arsenic (Total) EPA 3051m/7061Am 24 95 200 2 210 2 200 2 Bioassessible Arsenic EPA 1340 24 95 25 0.1 23 0.1 24 0.1 Barium (Ba) EPA 3051m/7000Bm 1000 2500 10 5 11 5 10 5 Cadmium (Cd) EPA 3051m/7000Bm 14 72 ND 1 ND 1 ND 1 Chromium (Cr) EPA 3051m/7000Bm 1100 1100 88 2 92 2 86 2 Lead (Pb) EPA 3051m/7000Bm 200 800 5.4 1 5.5 1 5.3 1 Selenium (Se) EPA 6020B/3050B 78 1000 ND 2 ND 2 ND 2 Silver (Ag) EPA 3051m/7000Bm 78 1000 ND 1 ND 1 ND 1 Mercury (Hg) EPA 3051m/7471Bm 4.7 61 ND 0.5 ND 0.5 ND 0.5 Organochlorine Pesticides 4,4'-DDD EPA 8081B/3550C 2.2 8.4 ND 0.05 ND 0.05 ND 0.05 4,4'-DDE EPA 8081B/3550C 1.9 8.2 ND 0.05 ND 0.05 ND 0.05 4,4'-DDT EPA 8081B/3550C 1.8 5.6 ND 0.05 ND 0.05 ND 0.05 Aldrin EPA 8081B/3550C 3.9 8.4 ND 0.01 ND 0.01 ND 0.01 alpha-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 beta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Chlordane (Technical) EPA 8081B/3550C 17 23 ND 0.1 ND 0.1 ND 0.1 delta-BHC EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Dieldrin EPA 8081B/3550C 2.5 24 0.0055 0.01 0.0012 0.01 0.0018 0.01 Endosulfan I EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan II EPA 8081B/3550C 13 13 ND 0.05 ND 0.05 ND 0.05 Endosulfan sulfate EPA 8081B/3550C 13 13 ND 0.1 ND 0.1 ND 0.1 Endrin EPA 8081B/3550C 3.8 30 ND 0.01 ND 0.01 ND 0.01 Endrin Aldehyde EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 Endrin ketone EPA 8081B/3550C NA NA ND 0.05 ND 0.05 ND 0.05 gamma-BHC (Lindane) EPA 8081B/3550C NA NA ND 0.01 ND 0.01 ND 0.01 Heptachlor EPA 8081B/3550C 1.3 5.6 ND 0.01 ND 0.01 ND 0.01 Heptachlor epoxide EPA 8081B/3550C 0.2 2.7 ND 0.01 ND 0.01 ND 0.01 Methoxychlor EPA 8081B/3550C 16 16 ND 0.05 ND 0.05 ND 0.05 Notes: ND = Not detected above the laboratory detection limit EAL = Environmental Action Level DOH = State of Hawai'i Department of Health mg/kg = Milligrams per kilogram EPA = Environmental Protection Agency NA = Not available Page 10 of 10 Table C. Summary of Samples with COPC that Exceeded the Laboratory Detection Limit Keaau Benioff Health Center - Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3) 1-6-003-127 Stockpile Sample ID Sample Date Stock Pile Volume (cubic yards) As (mg/kg) Bioassessible As (mg/kg Ba (mg/kg) Cr (mg/kg) Pb (mg/kg) Dieldrin (mg/kg) DU-1 9/9/2025 370 170 13 6.9 130 4.7 ND DU-2 9/9/2025 370 180 13 6.4 120 5.2 ND DU-3 9/9/2025 370 95 10 5.9 67 2.4 0.002 DU-4 9/9/2025 370 92 8.7 6 68 2.4 ND DU-5 9/9/2025 370 150 14 6.3 79 4.1 ND DU-6 9/9/2025 370 160 13 4.5 91 3.2 ND DU-7 9/9/2025 370 120 10 7.3 60 2.3 ND DU-8 9/9/2025 370 120 9.2 7.7 71 2.3 ND DU-9 9/9/2025 370 190 12 7.8 91 4.6 ND DU-10A 9/9/2025 370 170 11 7.1 110 4.2 ND DU-10B 9/9/2025 370 170 12 8 96 4.7 ND DU-10C 9/9/2025 370 170 11 7.7 87 4.4 ND DU-11 9/9/2025 370 190 15 9.4 90 4.9 ND DU-12 9/9/2025 370 180 15 9.8 89 4.9 ND DU-13 9/9/2025 370 140 10 8.6 82 3.8 ND DU-14 9/9/2025 370 140 11 9.7 85 4 ND DU-15 9/9/2025 370 200 20 11 97 6.1 ND DU-16 9/9/2025 370 190 17 9.7 84 5 ND DU-17 9/9/2025 370 220 18 9.5 99 6.1 ND DU-18 9/9/2025 370 240 16 8.1 86 5.3 ND DU-19 9/9/2025 301 160 14 6.2 99 4.7 ND DU-20A 9/9/2025 301 180 13 6.2 100 5.2 ND DU-20B 9/9/2025 301 170 13 5.6 100 5 0.0014 DU-20C 9/9/2025 301 170 13 5.3 100 6.3 0.0027 DU-21 9/9/2025 370 160 9.8 6.2 96 3.8 ND DU-22 9/9/2025 370 200 14 6 100 4.2 ND DU-23 9/9/2025 364 190 26 12 89 5.2 ND DU-24A 9/9/2025 364 200 25 10 88 5.4 0.0055 DU-24B 9/9/2025 364 210 23 11 92 5.5 0.0012 DU-24C 9/9/2025 364 200 24 10 86 5.3 0.0018 Tier 1 EAL (mg/kg): 24 24 1000 1100 200 3.6 C/I EAL (mg/kg): 95 95 2500 1100 800 1.5 Appendix II FIGURE 1: GENERAL SITE LOCATION FIGURE 2: PROJECT LOCATION FIGURE 3: DECISION UNIT (DU) BOUNDARY MAP FIGURE 4: LOCATIONS OF IDENTIFIED ARSENIC-IMPACTED SOILS Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Appendix Figure 2. Project Area Soil Screen Kea´au Benioff Health Center – Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3)1-6-003-127 Figure 3. Decision Unit (DU) Boundaries Soil Screen Kea´au Benioff Health Center – Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3)1-6-003-127 Figure 4. Locations of Arsenic-Impacted Soils Soil Screen Kea´au Benioff Health Center – Wellness and Behavioral Health Clinic 10-Acre Portion of TMK: (3)1-6-003-127 Appendix III SOIL LABORATORY ANALYTICAL RESULTS AND CHAIN-OF-CUSTODY FORMS LEVEL 2 LABORATORY REPORT INCLUDING BLANK, MS/MSD AND LCS/LCSD INFORMATION Soil Screen Report September 29, 2025 Kea´au Benioff Health Center – Wellness and Behavior Health Clinic Appendix September 18, 2025 Lehua Environmental Inc PO BOX 1018 Kamuela, HI 96743 Dear Kama Kobayashi: Please find enclosed the analytical report for: Project Name: HBMC Soil AAL Project #: AA599 final report Date Received: 09/10/2025 MIS Prep: Yes The results, applicable reporting limits, QA/QC data, invoice, and copy of COC are included. Advanced Analytical Laboratory appreciates the opportunity to provide analytical services for this project. If you have any questions regarding this project, please don’t hesitate to contact AAL. Thank you for your business and continuing support. Sincerely, Uwe Baumgartner, Ph.D Elisa M. Young Owner Owner ▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬▬ 544 Ohohia Street #10 HONOLULU HAWAII 96819 tel (808) 836-2252 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-3 DU 1 DU 2 DU 3 DU 4 Client sample ID Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-1 25-AL0915-1-2 25-AL0915-1-3 25-AL0915-1-4 Matrix Solid Solid Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 α-BHC 1.0 ug/kg nd nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd 123% nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd nd Heptachlor 1.0 ug/kg nd 101% nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd nd Aldrin 1.0 ug/kg nd 131% nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd nd Dieldrin 1.0 ug/kg nd 123% nd nd 2.0 nd Endrin 1.0 ug/kg nd 118% nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd nd 4,4'-DDT 5.0 ug/kg nd 115% nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 100% 116% 94% 112% 105% 118% 100% 119% 103% 118% 94% 109% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 1 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-3 DU 5 DU 6 DU 7 DU 8 DU 9 DU 10A Client sample ID Lab ID MRL Unit 25-AL0915-1-5 25-AL0915-1-6 25-AL0915-1-7 25-AL0915-1-8 25-AL0915-1-9 25-AL0915-1-10 Matrix Soil Soil Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 α-BHC 1.0 ug/kg nd nd nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd nd nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd nd nd Heptachlor 1.0 ug/kg nd nd nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd nd nd Aldrin 1.0 ug/kg nd nd nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd nd nd Dieldrin 1.0 ug/kg nd nd nd nd nd nd Endrin 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd nd nd 4,4'-DDT 5.0 ug/kg nd nd nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 99% 117% 105% 125% 105% 123% 99% 121% 104% 120% 103% 121% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 2 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-3 DU 10B DU 10C DU 11 DU 12 DU 13 DU 14 Client sample ID Lab ID MRL Unit 25-AL0915-1-11 25-AL0915-1-12 25-AL0915-1-13 25-AL0915-1-14 25-AL0915-1-15 25-AL0915-1-16 Matrix Soil Soil Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 α-BHC 1.0 ug/kg nd nd nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd nd nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd nd nd Heptachlor 1.0 ug/kg nd nd nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd nd nd Aldrin 1.0 ug/kg nd nd nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd nd nd Dieldrin 1.0 ug/kg nd nd nd nd nd nd Endrin 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd nd nd 4,4'-DDT 5.0 ug/kg nd nd nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 106% 124% 107% 125% 100% 117% 99% 118% 103% 122% 96% 110% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 3 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-3 DU 15 DU 16 DU 17 DU 18 Client sample ID Lab ID MRL Unit 25-AL0915-1-17 25-AL0915-1-18 25-AL0915-1-19 25-AL0915-1-20 Matrix Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/15/2025 9/15/2025 9/16/2025 9/16/2025 α-BHC 1.0 ug/kg nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd Heptachlor 1.0 ug/kg nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd Aldrin 1.0 ug/kg nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd Dieldrin 1.0 ug/kg nd nd nd nd Endrin 1.0 ug/kg nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd 4,4'-DDT 5.0 ug/kg nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 98% 113% 105% 121% 103% 118% 105% 127% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 4 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-3 MS MSD RPD Client sample ID Lab ID MRL Unit 25-AL0915-1-10 25-AL0915-1-10 25-AL0915-1-10 Matrix Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/15/2025 9/15/2025 9/15/2025 α-BHC 1.0 ug/kg Ȗ-BHC (Lindane) 1.0 ug/kg 115% 116% 1% ȕ-BHC 1.0 ug/kg Heptachlor 1.0 ug/kg 107% 112% 5% β-BHC 1.0 ug/kg Aldrin 1.0 ug/kg 125% 130% 4% Heptachlor Epoxide 1.0 ug/kg Ȗ-Chlordane 5.0 ug/kg α-Chlordane 5.0 ug/kg Endosulfan I 1.0 ug/kg 4,4'-DDE 5.0 ug/kg Dieldrin 1.0 ug/kg 94% 114% 19% Endrin 1.0 ug/kg 114% 116% 2% 4,4'-DDD 5.0 ug/kg Endosulfan II 5.0 ug/kg 4,4'-DDT 5.0 ug/kg 58% 62% 7% Endrin Aldehyde 5.0 ug/kg Methoxychlor 5.0 ug/kg Endrin Ketone 5.0 ug/kg Endosulfan Sulfate 10 ug/kg Technical Chlordane 0.10 mg/kg Toxaphene 0.20 mg/kg Surrogate Recoveries Tetrachloro-m-xylene 109% 109% Decachlorobiphenyl 121% 128% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 5 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-5 DU 19 DU 20A DU 20B DU 20C Client sample ID Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-21 25-AL0915-1-22 25-AL0915-1-23 25-AL0915-1-24 Matrix Solid Solid Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/15/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 α-BHC 1.0 ug/kg nd nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd 109% nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd nd Heptachlor 1.0 ug/kg nd 91% nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd nd Aldrin 1.0 ug/kg nd 115% nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd nd Dieldrin 1.0 ug/kg nd 109% nd nd 1.4 2.7 Endrin 1.0 ug/kg nd 121% nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd nd 4,4'-DDT 5.0 ug/kg nd 110% nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 95% 133% 105% 121% 95% 114% 98% 115% 98% 117% 100% 119% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 6 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-5 DU 21 DU 22 DU 23 DU 24A DU 24B DU 24C Client sample ID Lab ID MRL Unit 25-AL0915-1-25 25-AL0915-1-26 25-AL0915-1-27 25-AL0915-1-28 25-AL0915-1-29 25-AL0915-1-30 Matrix Soil Soil Soil Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 α-BHC 1.0 ug/kg nd nd nd nd nd nd Ȗ-BHC (Lindane) 1.0 ug/kg nd nd nd nd nd nd ȕ-BHC 1.0 ug/kg nd nd nd nd nd nd Heptachlor 1.0 ug/kg nd nd nd nd nd nd β-BHC 1.0 ug/kg nd nd nd nd nd nd Aldrin 1.0 ug/kg nd nd nd nd nd nd Heptachlor Epoxide 1.0 ug/kg nd nd nd nd nd nd Ȗ-Chlordane 5.0 ug/kg nd nd nd nd nd nd α-Chlordane 5.0 ug/kg nd nd nd nd nd nd Endosulfan I 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDE 5.0 ug/kg nd nd nd nd nd nd Dieldrin 1.0 ug/kg nd nd nd 5.5 1.2 1.8 Endrin 1.0 ug/kg nd nd nd nd nd nd 4,4'-DDD 5.0 ug/kg nd nd nd nd nd nd Endosulfan II 5.0 ug/kg nd nd nd nd nd nd 4,4'-DDT 5.0 ug/kg nd nd nd nd nd nd Endrin Aldehyde 5.0 ug/kg nd nd nd nd nd nd Methoxychlor 5.0 ug/kg nd nd nd nd nd nd Endrin Ketone 5.0 ug/kg nd nd nd nd nd nd Endosulfan Sulfate 10 ug/kg nd nd nd nd nd nd Technical Chlordane 0.10 mg/kg nd nd nd nd nd nd Toxaphene 0.20 mg/kg nd nd nd nd nd nd Surrogate Recoveries Tetrachloro-m-xylene Decachlorobiphenyl 105% 123% 105% 119% 103% 117% 102% 115% 103% 117% 103% 119% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 7 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Project Manager Project Name Client Project# Project# Advanced Analytical Laboratory 544 Ohohia Street #10 Honolulu, HI, 96819 Uwe Baumgartner/ Elisa Young HBMC Soil AA599 Acculab WO# Date Sampled Date Received Date Reported 25-AL0915-1 9/9/2025 9/15/2025 9/18/2025 Organochlorine Pesticides in Soil by EPA 8081B/3550C Accu Lab Batch# AL091525-5 MS MSD RPD Client sample ID Lab ID MRL Unit 25-AL0915-3-1 25-AL0915-3-1 25-AL0915-3-1 Matrix Soil Soil Soil Date Extracted 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 α-BHC 1.0 ug/kg Ȗ-BHC (Lindane) 1.0 ug/kg 113% 116% 2% ȕ-BHC 1.0 ug/kg Heptachlor 1.0 ug/kg 108% 114% 5% β-BHC 1.0 ug/kg Aldrin 1.0 ug/kg 127% 130% 2% Heptachlor Epoxide 1.0 ug/kg Ȗ-Chlordane 5.0 ug/kg α-Chlordane 5.0 ug/kg Endosulfan I 1.0 ug/kg 4,4'-DDE 5.0 ug/kg Dieldrin 1.0 ug/kg 110% 123% 11% Endrin 1.0 ug/kg 107% 110% 3% 4,4'-DDD 5.0 ug/kg Endosulfan II 5.0 ug/kg 4,4'-DDT 5.0 ug/kg 66% 50% 27% Endrin Aldehyde 5.0 ug/kg Methoxychlor 5.0 ug/kg Endrin Ketone 5.0 ug/kg Endosulfan Sulfate 10 ug/kg Technical Chlordane 0.10 mg/kg Toxaphene 0.20 mg/kg Surrogate Recoveries Tetrachloro-m-xylene 108% 101% Decachlorobiphenyl 127% 130% Acceptable Recovery Limits: Surrogates 50-150% LCS/MS/MSD 50-150% Acceptable RPD limit: 30% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 8 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091525-13 Client sample ID DU 1 DU 2 DU 3 DU 4 Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-1 25-AL0915-1-2 25-AL0915-1-3 25-AL0915-1-4 Matrix Solid Solid Soil Soil Soil Soil Date Digested 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg nd 114% 310 330 170 190 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 9 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091525-13 Client sample ID DU 5 DU 6 DU 7 DU 8 DU 9 DU 10A Lab ID MRL Unit 25-AL0915-1-5 25-AL0915-1-6 25-AL0915-1-7 25-AL0915-1-8 25-AL0915-1-9 25-AL0915-1-10 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg 200 130 160 220 280 230 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 10 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091525-13 Client sample ID DU 10B DU 10C DU 11 DU 12 DU 13 DU 14 Lab ID MRL Unit 25-AL0915-1-11 25-AL0915-1-12 25-AL0915-1-13 25-AL0915-1-14 25-AL0915-1-15 25-AL0915-1-16 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg 270 280 300 290 220 240 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 11 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091525-13 Client sample ID DU 15 DU 16 DU 17 DU 18 Lab ID MRL Unit 25-AL0915-1-17 25-AL0915-1-18 25-AL0915-1-19 25-AL0915-1-20 Matrix Soil Soil Soil Soil Date Digested 9/15/2025 9/15/2025 9/15/2025 9/15/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg 310 300 380 350 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 12 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091525-13 Client sample ID MS MSD RPD Lab ID Matrix Date Digested Date Analyzed MRL Unit 25-AL0915-1-1 Soil 9/15/2025 9/16/2025 25-AL0915-1-1 Soil 9/15/2025 9/16/2025 25-AL0915-1-1 Soil 9/15/2025 9/16/2025 Arsenic (As) Acceptable Recovery Limits: LCS MS/MSD Acceptable RPD limit: 2.0 mg/kg 75-125% 20% 80-120% 81% 80% 1% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 13 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091625-11 Client sample ID DU 19 DU 20A DU 20B DU 20C Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-21 25-AL0915-1-22 25-AL0915-1-23 25-AL0915-1-24 Matrix Solid Solid Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg nd 115% 350 290 280 220 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 14 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091625-11 Client sample ID DU 21 DU 22 DU 23 DU 24A DU 24B DU 24C Lab ID MRL Unit 25-AL0915-1-25 25-AL0915-1-26 25-AL0915-1-27 25-AL0915-1-28 25-AL0915-1-29 25-AL0915-1-30 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Arsenic (As) 2.0 mg/kg 260 330 300 320 350 270 Acceptable Recovery Limits: LCS 80-120% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 15 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Metals in Soil by EPA 6020B/EPA3050B (<0.25mm Fraction) Accu Lab Batch# AL091625-11 Client sample ID MS MSD RPD Lab ID Matrix Date Digested Date Analyzed MRL Unit 25-AL0729-1-21 Soil 9/16/2025 9/16/2025 25-AL0729-1-21 Soil 9/16/2025 9/16/2025 25-AL0729-1-21 Soil 9/16/2025 9/16/2025 Arsenic (As) Acceptable Recovery Limits: LCS MS/MSD Acceptable RPD limit: 2.0 mg/kg 80-120% 75-125% 20% M M This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 16 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 1 DU 2 DU 3 DU 4 DU 5 Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-1 Soil 9/16/2025 9/16/2025 25-AL0915-1-2 Soil 9/16/2025 9/16/2025 25-AL0915-1-3 Soil 9/16/2025 9/16/2025 25-AL0915-1-4 Soil 9/16/2025 9/16/2025 25-AL0915-1-5 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 13 13 10 8.7 14 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 17 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 6 DU 7 DU 8 DU 9 DU 10A Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-6 Soil 9/16/2025 9/16/2025 25-AL0915-1-7 Soil 9/16/2025 9/16/2025 25-AL0915-1-8 Soil 9/16/2025 9/16/2025 25-AL0915-1-9 Soil 9/16/2025 9/16/2025 25-AL0915-1-10 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 13 10 9.2 12 11 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 18 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 10B DU 10C DU 11 DU 12 DU 13 Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-11 Soil 9/16/2025 9/16/2025 25-AL0915-1-12 Soil 9/16/2025 9/16/2025 25-AL0915-1-13 Soil 9/16/2025 9/16/2025 25-AL0915-1-14 Soil 9/16/2025 9/16/2025 25-AL0915-1-15 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 12 11 15 15 10 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 19 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 14 DU 15 DU 16 DU 17 DU 18 Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-16 Soil 9/16/2025 9/16/2025 25-AL0915-1-17 Soil 9/16/2025 9/16/2025 25-AL0915-1-18 Soil 9/16/2025 9/16/2025 25-AL0915-1-19 Soil 9/16/2025 9/16/2025 25-AL0915-1-20 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 11 20 17 18 16 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 20 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 19 DU 20A DU 20B DU 20C DU 21 Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-21 Soil 9/16/2025 9/16/2025 25-AL0915-1-22 Soil 9/16/2025 9/16/2025 25-AL0915-1-23 Soil 9/16/2025 9/16/2025 25-AL0915-1-24 Soil 9/16/2025 9/16/2025 25-AL0915-1-25 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 14 13 13 12 9.8 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 21 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 22 DU 23 DU 24A DU 24B DU 24C Lab ID Matrix Date Extracted Date Analyzed MRL Unit 25-AL0915-1-26 Soil 9/16/2025 9/16/2025 25-AL0915-1-27 Soil 9/16/2025 9/16/2025 25-AL0915-1-28 Soil 9/16/2025 9/16/2025 25-AL0915-1-29 Soil 9/16/2025 9/16/2025 25-AL0915-1-30 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.10 mg/kg 14 26 25 23 24 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 22 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 1 DU 2 DU 3 DU 4 DU 5 Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-1 Soil 9/16/2025 9/16/2025 25-AL0915-1-2 Soil 9/16/2025 9/16/2025 25-AL0915-1-3 Soil 9/16/2025 9/16/2025 25-AL0915-1-4 Soil 9/16/2025 9/16/2025 25-AL0915-1-5 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 4.1% 4.1% 5.9% 4.6% 7.2% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 23 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 6 DU 7 DU 8 DU 9 DU 10A Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-6 Soil 9/16/2025 9/16/2025 25-AL0915-1-7 Soil 9/16/2025 9/16/2025 25-AL0915-1-8 Soil 9/16/2025 9/16/2025 25-AL0915-1-9 Soil 9/16/2025 9/16/2025 25-AL0915-1-10 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 9.7% 6.3% 4.2% 4.4% 4.8% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 24 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 10B DU 10C DU 11 DU 12 DU 13 Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-11 Soil 9/16/2025 9/16/2025 25-AL0915-1-12 Soil 9/16/2025 9/16/2025 25-AL0915-1-13 Soil 9/16/2025 9/16/2025 25-AL0915-1-14 Soil 9/16/2025 9/16/2025 25-AL0915-1-15 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 4.3% 4.0% 5.0% 5.2% 4.5% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 25 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 14 DU 15 DU 16 DU 17 DU 18 Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-16 Soil 9/16/2025 9/16/2025 25-AL0915-1-17 Soil 9/16/2025 9/16/2025 25-AL0915-1-18 Soil 9/16/2025 9/16/2025 25-AL0915-1-19 Soil 9/16/2025 9/16/2025 25-AL0915-1-20 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 4.4% 6.5% 5.6% 4.8% 4.7% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 26 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 19 DU 20A DU 20B DU 20C DU 21 Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-21 Soil 9/16/2025 9/16/2025 25-AL0915-1-22 Soil 9/16/2025 9/16/2025 25-AL0915-1-23 Soil 9/16/2025 9/16/2025 25-AL0915-1-24 Soil 9/16/2025 9/16/2025 25-AL0915-1-25 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 4.1% 4.5% 4.5% 5.5% 3.8% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 27 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 22 DU 23 DU 24A DU 24B DU 24C Lab ID Matrix Date Extracted Date Analyzed Unit 25-AL0915-1-26 Soil 9/16/2025 9/16/2025 25-AL0915-1-27 Soil 9/16/2025 9/16/2025 25-AL0915-1-28 Soil 9/16/2025 9/16/2025 25-AL0915-1-29 Soil 9/16/2025 9/16/2025 25-AL0915-1-30 Soil 9/16/2025 9/16/2025 Arsenic (As) Bioaccessibility % 4.2% 8.8% 7.7% 6.7% 8.9% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 28 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 1 DU 2 DU 3 DU 4 Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-1 25-AL0915-1-2 25-AL0915-1-3 25-AL0915-1-4 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l nd 108% 0.13 0.13 0.10 0.087 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 29 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 5 DU 6 DU 7 DU 8 DU 9 DU 10A Lab ID MRL Unit 25-AL0915-1-5 25-AL0915-1-6 25-AL0915-1-7 25-AL0915-1-8 25-AL0915-1-9 25-AL0915-1-10 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l 0.14 0.13 0.10 0.092 0.12 0.11 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 30 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 10B DU 10C DU 11 DU 12 DU 13 DU 14 Lab ID MRL Unit 25-AL0915-1-11 25-AL0915-1-12 25-AL0915-1-13 25-AL0915-1-14 25-AL0915-1-15 25-AL0915-1-16 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l 0.12 0.11 0.15 0.15 0.10 0.11 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 31 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID DU 15 DU 16 DU 17 DU 18 Lab ID MRL Unit 25-AL0915-1-17 25-AL0915-1-18 25-AL0915-1-19 25-AL0915-1-20 Matrix Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l 0.20 0.17 0.18 0.16 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 32 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-10 Client sample ID MS MSD RPD Lab ID Matrix Date Digested MRL Unit 25-AL0729-1-1 Soil 9/16/2025 25-AL0729-1-1 Soil 9/16/2025 25-AL0729-1-1 Soil 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l 115% 117% 2% Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 33 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 19 DU 20A DU 20B DU 20C Lab ID MRL Unit MTH BLK LCS 25-AL0915-1-21 25-AL0915-1-22 25-AL0915-1-23 25-AL0915-1-24 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l nd 105% 0.14 0.13 0.13 0.12 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 34 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID DU 21 DU 22 DU 23 DU 24A DU 24B DU 24C Lab ID MRL Unit 25-AL0915-1-25 25-AL0915-1-26 25-AL0915-1-27 25-AL0915-1-28 25-AL0915-1-29 25-AL0915-1-30 Matrix Soil Soil Soil Soil Soil Soil Date Digested 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Date Analyzed 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l 0.098 0.14 0.26 0.25 0.23 0.24 Acceptable Recovery Limits: LCS 85-115% MS/MSD 75-125% Acceptable RPD limit: 20% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 35 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Project# AA599 Bioaccessible Arsenic in Soil (<0.25mm Fraction) by EPA1340 Accu Lab Batch# AL091625-12 Client sample ID MS MSD RPD Lab ID MRL Unit 25-AL0915-1-21 25-AL0915-1-21 25-AL0915-1-21 Matrix Date Digested Date Analyzed Soil 9/16/2025 9/16/2025 Soil 9/16/2025 9/16/2025 Soil 9/16/2025 9/16/2025 Bioaccessible Arsenic (As) 0.0020 mg/l Acceptable Recovery Limits: LCS MS/MSD Acceptable RPD limit: 20% 85-115% 75-125% 117% 120% 3% This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 36 of 37 12524 130th Lane NE Kirkland WA 98034 Tel: (425) 214-5858 (425) 214-5868 Email: lisa@accu-lab.com website: www.accu-lab.com Analytical Report Client Advanced Analytical Laboratory Acculab WO# 25-AL0915-1 544 Ohohia Street #10 Honolulu, HI, 96819 Date Sampled 9/9/2025 Project Manager Uwe Baumgartner/ Elisa Young Date Received 9/15/2025 Project Name HBMC Soil Date Reported 9/18/2025 Client Project# Project# AA599 Data Qualifiers and Comments: Results reported on dry-weight basis for soil samples. MRL-Method Reporting Limit nd-Indicates the analyte is not detected at the listing reporting limit. C-Coelution with other compounds. M-% Recovery of surrogate, MS/MSD is out of the acceptable limit due to matrix effect. B-Indicates the analyte is detected in the method blank associated with the sample. J-The analyte is detected at below the reporting limit. E-The result reported exceeds the calibration range, and is an estimate. D-Sample required dilution due to matrix. Method Reporting Limits were elevated due to dilutions. H-Sample was received or analyzed past holding time Q-Sample was received with head space, improper preserved or above recommended temperature. I-Due to insufficient sample, LCS/LCS DUP were analyzed in place of MS/MSD. R-The recovery of this analyte in QC sample failed high, but the analyte was not detected in all related samples. No action was taken. R-1-The RPD value for the MS/MSD was outside of QC acceptance limits however both recoveries were acceptable. All related samples were "nd". No action was taken. R-2-The recovery of the surrogate in sample failed high, but all related analytes were not detected in the sample. No action was taken. This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. Page 37 of 37 APPENDIX E COMMENTS IN RESPONSE TO PUBLICATION OF DRAFT ENVIRONMENTAL ASSESSMENT C. Kimo Alameda, Ph.D. Jeffrey W. Darrow Mayor Director William V. Brilhante, Jr. Michelle S. Ahn Managing Director Deputy Director i Office 74- West Hawai i Office 101 Pauahi Street, Suite 3 Kailua-Kona, lole Hwy i 96740 Phone (808) 323-4770 Phone (808) 961-8288 Fax (808) 327-3563 PLANNING DEPARTMENT Fax (808) 961-8742 John Pipan Pipan Consulting LLC P. O. Box 421 Honokaa, 96727 VIA EMAIL Dear John Pipan: SUBJECT: Environmental Assessment (PL-ENV-2026-000060) Project: Hilo Benioff Medical Center (HBMC), New Location Tax Map Key: (3) 1-6-003:127 (por.) and 1-6-003:007 (por.), This letter is in response to your February 20, 2026 transmittal of the Draft Environmental Assessment (DEA) and Anticipated Finding of No Significant Impact February 23, 2026 Environmental Review Bulletin (ERB). The following comments are Hilo Benioff Medical Center (HBMC) proposes to construct a new medical facility in i Belt Road. The parent parcel, identified as TMK (3) 1-6-003:127, is approximately 108.8 acres and is owned by W.H. Shipman Ltd. The proposed project site consists of a 20-acre portion of the parent parcel currently zoned Agricultural 20- acres (A-20a), which would be subdivided from the larger parcel. The clinic is proposed to occupy approximately 13 acres within the 20-acre project area. A new access driveway would be constructed within a 4.4-acre roadway lot to be subdivided from TMK (3) 1-6-003:007. Plans include the construction of a single-story medical office building www.planning.hawaiicounty.gov Hawai i County is an Equal Opportunity Provider and Employer planning@hawaiicounty.gov John Pipan Pipan Consulting LLC Page 2 complex consisting of a clinical wing and a behavioral health wing totaling approximately 40,000 square feet, along with associated parking and loading areas. B provided: 1. TMK (3) 1-6-003:127 is approximately 108.761 acres in size. The property is zoned Agricultural 20-acres (A-20a) and Industrial-Commercial Mixed Use (MCX- 20). The parcel is primarily designated Urban, with a small portion designated Land Use Pattern Allocation Guide (LUPAG) Map designates the parcel as Urban Expansion (UE). The parcel is not located within the Special Management Area (SMA). 2. TMK (3) 1-6-003:007 is approximately 1,235.835 acres in size. The parcel is designated Agricultural and Urban by the State Land Use Commission. The General Plan LUPAG Map designates the parcel as Urban Expansion (UE) and Important Agricultural Lands (IAL). The property is zoned Agricultural 20-acres (A- 20a) and is not located within the Special Management Area (SMA). 3. According to County Real Property Tax Records, the subject parcels are privately owned by W.H. Shipman Ltd. 4. The Zoning Code. Based on the information provided in the DEA, a Use Permit is required for development within the portion of the property located in the State Land Use Urban District, and a Special Permit is required for development within the portion of the property located in the State Land Use Agricultural District. The DEA should clearly identify all required discretionary permits and approvals and confirm consistency with applicable zoning and State Land Use regulations. 5. State Land Use Boundary Amendment No. 884 (LUC Docket No. BR96-699) was of Zone Ordinance No. 02-23, approved on February 28, 2002, reclassified portions of the property to Industrial-Commercial Mixed Use (MCX-20). The DEA does not clearly provide comprehensive permitting and zoning history for the subject property. The DEA should be revised to include a complete summary of prior approvals, including State Land Use actions, County zoning ordinances, and any associated conditions of approval, and should clarify whether the proposed project and access improvements are consistent with those approvals. Page 3 John Pipan Pipan Consulting LLC 6. According to the Land Study Bureau Productivity Rating, soils in the project area are classified as C (Fair Soils) and D (Poor Soils) and the Agricultural Lands of as Other or Unclassified. 7. The DEA includes a general discussion of wastewater disposal, stormwater management, drainage, and erosion and sediment control; however, it does not clearly identify or depict these infrastructure components on the conceptual site plan. The DEA should be revised to include a complete list of required permits and approvals, and document any resulting requirements or mitigation measures. The document should also address spill prevention measures associated with both construction and operation of the project. 8. Transportation (HDOT) regarding traffic and access impacts; however, it does not provide sufficient detail regarding the substance and outcomes of that coordination. The DEA should be revised to include a clearer summary of consultation with HDOT, identify any required roadway or intersection improvements, and describe any traffic-related mitigation measures. 9. The DEA should include a summary of any concerns raised by surrounding community members and stakeholders and describe how those concerns have been addressed. 10. The DEA indicates that no Archaeological Inventory Survey (AIS) has been conducted. Given that the project involves ground-disturbing activities, the DEA does not adequately document consultation with the State Historic Preservation Division (SHPD) pursuant to HRS Chapter 6E. The DEA should be revised to include documentation of consultation with SHPD and clarify whether an AIS or other cultural resource study is required, along with any resulting recommendations or conditions. The DEA should also clearly identify all agencies consulted during its preparation and confirm that the Department of Transportation (HDOT), County Department of Water Supply (DWS), State Historic Preservation Division (SHPD), and Department of Health (DOH) Wastewater Branch were provided a draft of the DEA for review, and summarize the outcomes of those consultations. John Pipan Pipan Consulting LLC Page 4 If you should have further questions, please contact Tracie Camero of this office at (808) 961-8166 or via email at Tracie-Lee.Camero@hawaiicounty.gov. Sincerely, JEFFREY W DARROW Planning Director TLC:sm \\hawaiicounty.gov\depts\PL\PL\planning\public\wpwin60\PC\letters\2026\PL-ENV-2026-000060 - Benioff Center Comments.doc 194 Wiwoole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com April 29, 2026 Mr. Jeffrey Darrow, Director Planning Department COUNTY OF HAWAII 101 Pauahi Street Hilo, HI 96720 Dear Mr. Darrow: Subject: Response to Comments for Hilo Benioff Medical Center Kea’au Outpatient Center Draft Environmental Assessment (EA) RE: Construction of a New Medical Clinic Facility Applicant: Hilo Benioff Medical Center (HBMC) Location: Kea‘au, Puna, Hawai‘i TMK (3) 1-6-003: 127, TMK (3) 1-6-003: 007 (por.) Thank you for your comments dated March 19, 2026 regarding the subject Draft Environmental Assessment (DEA) for the Hilo Benioff Medical Center (HBMC) Kea’au Outpatient Center, located to the west of Highway 11, across from the intersection with Kea‘au-Pāhoa Road. HBMC is proposing to construct a new medical facility in Kea‘au known as the Keaʻau Outpatient Center (KOC). Plans include construction of a single-story medical office building complex consisting of a clinical wing and a behavioral health wing totaling approximately 40,000 square feet. The proposed facilities will provide urgent care services, primary care services, specialty clinic services, imaging services, laboratory services, and behavioral health and counseling services. The facilities will serve the general public but will be primarily focused on residents of Puna and South Hilo. The Final Environmental Assessment has been revised to address the following comments received from the Planning Department: 1.TMK (3) 1-6-003:127 is approximately 108.761 acres in size. The property is zoned Agricultural 20-acres (A-20a) and Industrial-Commercial Mixed Use (MCX-20). The parcel is primarily designated Urban, with a small portion designated Agricultural by the State Land Use Commission. The Hawaiʻi County General Plan Land Use Pattern Allocation Guide (LUPAG) Map designates the parcel as Urban Expansion (UE). The parcel is not located within the Special Management Area (SMA). The Final EA has been revised where necessary to reflect the preceding information. 2.TMK (3) 1-6-003:007 is approximately 1,235.835 acres in size. The parcel is designated Agricultural and Urban by the State Land Use Commission. The General Plan LUPAG Map designates the parcel as Urban Expansion (UE) and Important Agricultural Lands (IAL). The property is zoned Agricultural 20-acres (A-20a) and is not located within the Special Management Area (SMA). The Final Environmental Assessment has been revised to provide additional information regarding the LUPAG designation of the parcels in Section 4.1.1 2005, Hawaiʻi County General Plan, additional information on the zoning of the parcels in Section 4.3, County Zoning and Special Management Area and additional information on the State Land Use designation of the parcels in Section 4.4, Hawaiʻi State Land Use Law. 3.According to County Real Property Tax Records, the subject parcels are privately owned by W.H. Shipman Ltd. Page 6 of the Draft and Final Environmental Assessment concur with this comment. 4.The proposed development is subject to the requirements of the Hawaii County Zoning Code. Based on the information provided in the DEA, a Use Permit is required for development within the portion of the property located in the State Land Use Urban District, and a Special Permit is required for development within the portion of the property located in the State Land Use Agricultural District. The DEA should clearly identify all required discretionary permits and approvals and confirm consistency with applicable zoning and State Land Use regulations. This is correct and further elaborated on in the Summary of Project, Environmental Impacts, and Mitigation, Measures section of the report. The Final Environmental Assessment has been revised throughout to consistently identify the need for both a Use Permit and a Special Permit. 5.State Land Use Boundary Amendment No. 884 (LUC Docket No. BR96-699) was approved on July 18, 1994, amending approximately 660 acres in Keaʻau, Puna, Hawaiʻi Island from the Agricultural District to the Urban District. County Change of Zone Ordinance No. 02-23, approved on February 28, 2002, reclassified portions of the property to Industrial-Commercial Mixed Use (MCX-20). The DEA does not clearly provide comprehensive permitting and zoning history for the subject property. The DEA should be revised to include a complete summary of prior approvals, including State Land Use actions, County zoning ordinances, and any associated conditions of approval, and should clarify whether the proposed project and access improvements are consistent with those approvals. Section 4.4, Hawaiʻi State Land Use Law, of the final Environmental Assessment has been revised to provide this additional information. 6.According to the Land Study Bureau Productivity Rating, soils in the project area are classified as C (Fair Soils) and D (Poor Soils) and the Agricultural Lands of Importance to the state of Hawai’i (ALISH) classification identiefies the project area as Other or Unclassified. Section 3.1: Environmental Setting, Impacts, and Mitigation, Topography and Soil, of the Final Environmental Assessment has been revised to include this information. 7.The DEA includes a general discussion of wastewater disposal, stormwater management, drainage, and erosion and sediment control; however, it does not clearly identify or depict these infrastructure components on the conceptual site plan. The DEA Should be revised to include a complete list of required permits and approvals, and document any resulting requirements or mitigation measures. The document should also address spill prevention measures associated with both construction and operation of the project. The site plan is conceptual at this point and cannot be finalized until potential conditions of the Use Permit and Special Permit are accounted for. The location of specific components or design of mitigation measures will come at later permitting phases. A complete list of required permits and approvals is provided in the Draft and Final EA in Section 4.5. Spill prevention measures are detailed in Section 3.1.9 of the Draft and Final EA. 8.The DEA references consultation with the Hawai’i State Department of Transportation (HDOT) regarding traffic and access impacts; however, it does not provide sufficient detail regarding the substance and outcomes of that coordination. The DEA should be revised to include a clearer summary of consultation with HDOT, identify any required roadway or intersection improvements, and describe any traffic-related mitigation measures. Section 3.3 Public Roads, Services, and Utilities of the Final Environmental Assessment has been revised to include additional information on the consultation with HDOT. Consultation with the HDOT was primarily conducted through SSFM International, the engineering firm that conducted the Traffic Impact Analysis Report (TIAR) for the project. The TIAR did not recommend any intersection improvements or traffic-related mitigation measures. A copy of the TIAR and the Draft Environmental Assessment has been provided to the HDOT and no comment has been received as of the date of the letter. 9.The DEA should include a summary of any concerns raised by surrounding community members and stakeholders and describe how those concerns have been addressed. Section 1.5 has been edited to include more information about the stakeholder and community consultation process, including topics raised as community member concerns and how HBMC has addressed the concerns. 10. The DEA indicates that no Archaeological Inventory Survey (AIS) has been conducted. Given that the project involves ground-disturbing activities, the DEA does not adequately document consultation with the State Historic Preservation Division (SHPD) pursuant to HRS Chapter 6E. The DEA Should be revised to include documentation of consultation with SHPD and clarify whether an AIS or other cultural resource study is required, along with any resulting recommendations’ or conditions. y, Section 3.2.4 Cultural and Historic Resources, Potential Environmental Impact from Proposed Action, of the Final Environmental Assessment has been revised to include information that was recently compiled relating to prior archaeological studies which were conducted on the subject properties and the larger area. This additional information includes an additional appendix containing a prior Archaeological Assessment of the area and a letter from SHPD concurring with the findings of that Assessment that no further archaeological work is necessary. We trust that everything is in order for your acceptance of this Final Environmental Assessment. If not, or if there are questions relating to this matter, please feel free to direct them to me. Thank you very much. Sincerel JOHN PIPAN Planning Administrator Standard Comments for Land Use Reviews Clean Air Branch Hawaii State Department of Health July 3, 2024 All project activities shall comply with Hawaii Administrative Rules (HAR), Chapter 11-59 and 11-60.1. If your proposed project: Requires an Air Pollution Control Permit • You must obtain an air pollution control permit from the Clean Air Branch and comply with all applicable conditions and requirements. If you do not know if you need an air pollution control permit, please contact the Permitting Section of the Clean Air Branch. • Permit application forms can be found here: https://health.hawaii.gov/cab/permit- application-forms/ Has the potential to generate fugitive dust • You must reasonably control the generation of all airborne, visible fugitive dust. Note that construction 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, visible fugitive dust. The plan, which does not require Department of Health approval, should help you recognize and minimize potential airborne, visible fugitive dust problems. • Construction activities must comply with the provisions of Hawaii Administrative Rules, §11- 60.1-33 on Fugitive Dust. In addition, for cases involving mixed land use, it is strongly recommended that buffer zones be established, wherever possible, in order to alleviate potential dust concerns. • You must provide reasonable measures to control airborne, visible fugitive dust from the road areas and during the various phases of construction. These measures include, but are not limited to, the following: o Planning the different phases of construction, focusing on minimizing the amount of airborne, visible fugitive dust-generating materials and activities, centralizing on-site vehicular traffic routes, and locating potential dust-generating equipment in areas of the least impact; o Providing an adequate water source at the site prior to start-up of construction activities; o Landscaping and providing rapid covering of bare areas, including slopes, starting from the initial grading phase; o Minimizing airborne, visible fugitive dust from shoulders and access roads; o Providing reasonable dust control measures during weekends, after hours, and prior to daily start-up of construction activities; and o Controlling airborne, visible fugitive dust from debris being hauled away from the project site. • If you have questions about fugitive dust, please contact the Enforcement Section of the Clean Air Branch. Please also see fugitive dust fact sheet at: https://health.hawaii.gov/ cab/files/2024/02/Hawaii-Fugitive-Dust-Fact-Sheet-February-2024.pdf. Includes construction, demolition, or renovation activities that involve potential asbestos and lead containing materials • Please contact the Indoor and Radiological Health Branch at (808) 586-4700 or visit: https://health.hawaii.gov/irhb/ Increases the population and potential number of vehicles in an area • The creation of apartment buildings, complexes, and residential communities may increase the overall population in an area. Increasing the population in an area may inadvertently lead to more air pollution via vehicle exhaust. Vehicle exhaust releases pollutants in the air that can negatively impact human health and air quality, including lung irritants, carcinogens, and greenhouse gases. • Ensure that drivers keep vehicle idling times to three (3) minutes or less. • Consider and incorporate support for alternative transportation options such as bike racks and/or electric vehicle charging stations where possible. If you have any questions, please contact the Clean Air Branch at (808) 586-4200 or at cab@doh.hawaii.gov. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com April 29, 2026 Clean Air Branch Hawaii State Department of Health 919 Ala Moana Blvd, Room 203 Honolulu, HI 96814 Subject: Response to Clean Air Branch Standard Comments on the Draft Environmental Assessment — Hilo Benioff Medical Center Keaʻau Outpatient Center RE: Keaʻau Benioff Medical Center — Hilo Benioff Medical Center (HBMC) New Location Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Clean Air Branch, Mahalo for your review of the Draft Environmental Assessment (DEA) for the proposed Hilo Benioff Medical Center (HBMC) Keaʿau Outpatient Center. Land Planning Hawaiʻi LLC, on behalf of HBMC, has carefully reviewed the Clean Air Branch (CAB) standard comments for land use reviews and welcomes the opportunity to respond. The CAB comments address four topics: (1) air pollution control permits, (2) fugitive dust during construction, (3) asbestos and lead-containing materials, and (4) increased vehicle traffic. Each topic is addressed below and in the Final Environmental Assessment (FEA) at Section 3.1.6 (Air Quality). 1. Air Pollution Control Permit The CAB advises that an air pollution control permit must be obtained if required for the proposed project and that applicable conditions and requirements must be met. The FEA acknowledges at Section 3.1.6 that all Hawaiʻi Island meets the standards set by the Clean Air Act (CAA) and HRS §342B, and that air quality in the Keaʿau area is currently very good. The proposed project is the construction of a single-story outpatient medical office building totaling 40,000 square feet. The project does not involve combustion sources, industrial processes, or operations that are anticipated to require an air pollution control permit under HAR Chapter 11-60.1. During the engineering and permitting phase, the applicant will evaluate all applicable permit requirements and will obtain any required air pollution control permit from the CAB Permitting Section prior to construction or operation of any equipment subject to such requirements. The applicant acknowledges the CABʿs Permitting Section as the appropriate point of contact for permit applicability determinations. 2. Fugitive Dust During Construction The CAB advises that construction activities must comply with HAR §11-60.1-33 on Fugitive Dust and that a dust control management plan is recommended. The FEA addresses this 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com comment at Section 3.1.6 and incorporates the CABʿs recommended fugitive dust mitigation measures in full. Air pollutants during construction will be limited and temporary. The main sources of short-term air pollutants are construction equipment exhaust and dust. HAR §11-60 on Fugitive Dust, which prohibits visible emissions of dust from construction activities, will be strictly followed to prevent dust impacts to Hawaiʻi Belt Road and surrounding areas. The FEA (Section 3.1.6) commits the project to the following measures to control airborne, visible fugitive dust, consistent with the CABʿs standard requirements: • Planning the different phases of construction, focusing on minimizing the amount of airborne, visible fugitive dust-generating materials and activities, centralizing on-site vehicular traffic routes, and locating potential dust-generating equipment in areas of the least impact; • Providing an adequate water source at the site prior to start-up of construction activities; • Landscaping and providing rapid covering of bare areas, including slopes, starting from the initial grading phase; • Minimizing airborne, visible fugitive dust from shoulders and access roads; • Providing reasonable dust control measures during weekends, after hours, and prior to daily start-up of construction activities; and • Controlling airborne, visible fugitive dust from debris being hauled away from the project site. These measures will be implemented during all phases of construction to prevent significant impacts to Hawaiʻi Belt Road, Highway 130, and surrounding areas. The project site is located within an agricultural area, and nearby residents and businesses will benefit from these proactive dust management measures. A site-specific dust control management plan will be developed as part of the contractorʿs Best Management Practices (BMPs) prior to the start of construction, consistent with the CABʿs recommendation. 3. Asbestos and Lead-Containing Materials The CAB advises that construction, demolition, or renovation activities involving potential asbestos or lead-containing materials require contact with the Indoor and Radiological Health Branch (IRHB). The proposed project is a new construction on a previously agricultural (fallow sugarcane field) site. There are no existing structures on the 20-acre project footprint that would require demolition or renovation. Accordingly, the project does not anticipate construction or demolition activities involving asbestos or lead-containing building materials. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com The FEA at Section 3.1.9 (Hazardous Substances, Toxic Waste, and Hazardous Conditions) addresses site history and potential contamination concerns. The subject site has been used for agricultural purposes, primarily sugarcane production, for over a century. A Soil Screening Survey (Appendix C of the FEA) was conducted for the project area to assess the potential for residual agricultural chemicals in the soil. The projectʿs Soil Management Plan, which is incorporated as a mitigating measure in the FEA, addresses management of any impacted soils encountered during grading and construction. Again, as a new construction project on a previously cleared agricultural site, asbestos and lead concerns associated with building demolition are not applicable. Should any previously unidentified structures or materials be encountered during site preparation, the applicant will contact the IRHB as directed. 4. Increased Vehicle Traffic and Emissions The CAB advises that increased population and vehicle numbers can lead to greater air pollution via vehicle exhaust, and recommends that vehicle idling times be kept to three (3) minutes or less and that support for alternative transportation options — such as bike racks and/or electric vehicle charging stations — be considered. The FEA acknowledges at Section 3.1.6 that vehicle emissions from the proposed facility will represent the primary source of operational air quality impacts, which are anticipated to be minor given the context of Hawaiʻi Island. Vehicle Idling The proposed Keaʿau Outpatient Center will implement a policy requiring that drivers keep vehicle idling times to three (3) minutes or less in surface parking areas, consistent with the CABʿs recommendation. This measure will be incorporated into the facilityʿs operational management plan and posted signage will be provided in parking areas to inform patients, visitors, and employees. Alternative Transportation Support The project will incorporate support for alternative transportation options consistent with its role as a community healthcare facility serving the Puna District. Bicycle parking will be provided at the facility. The project site is located along Hawaiʻi Belt Road (Route 11), which is served by the Hele-On Bus public transit system, providing an existing transit option for patients and employees who choose not to drive. The feasibility of electric vehicle (EV) charging stations will be evaluated during the design phase; given the rapidly growing adoption of EVs on Hawaiʻi Island, the applicant anticipates providing EV charging infrastructure as part of the facilityʿs parking facilities. Overall Air Quality Impact The Traffic Impact Analysis Report (TIAR) prepared by SSFM International and incorporated into the FEA as Appendix A evaluated traffic conditions at four study intersections in the Keaʿau area under existing (2025) and future (2028) with-project conditions. The TIAR concludes that the roadway network in the Keaʿau area can accommodate anticipated traffic volumes without significant adverse effects, even accounting for background area growth. With the outlined 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com mitigation measures, potential impacts to air quality from vehicle emissions will not change appreciably under any alternative and will remain within standards set by the Clean Air Act and HRS §342B. Air quality in the Keaʿau area is currently very good and the proposed project is not expected to result in any meaningful degradation of regional air quality. We trust that the above responses address the comments made by the Clean Air Branch and that the Final Environmental Assessment adequately evaluates and mitigates potential air quality impacts associated with the proposed Keaʿau Outpatient Center. The applicant is committed to complying with all applicable requirements under HAR Chapters 11-59 and 11-60.1, and to implementing the fugitive dust, idling, and transportation measures described above. Please do not hesitate to contact us directly with any additional questions. Sincerely, John Pipan Planning Administrator Land Planning Hawaiʻi LLC PRP Comments on Draft Environmental Assessment: Hilo Benioff Medical Center Kea'au Outpatient Center Pacific Resource Partnership (PRP) appreciates the opportunity to review and comment on the Draft Environmental Assessment (DEA) for the proposed Hilo Benioff Medical Center Kea 'au Outpatient Center project. PRP represents construction industry stakeholders who regularly work on large public infrastructure and vertical construction projects throughout Hawai'i, including projects involving healthcare facilities and water infrastructure. Our contractors and affiliated trades are frequently responsible for implementing environmental mitigation measures associated with projects of this scale. PRP supports the expansion of healthcare services in the Puna District and recognizes the need for additional medical facilities to serve the growing population. At the same time, PRP believes it is important that the environmental review process fully analyze potential impacts associated with the proposed development to ensure that all environmental issues are adequately addressed. After reviewing the Draft EA, PRP respectfully submits the following comments. 1. Wastewater Treatment and Groundwater Protection The Draft EA states that the project will utilize an on-site wastewater treatment syste m because no county sewer connection currently exists in the area . The document also indicates that the property lies above the Underground Injection Control (UIC) line used by the State Department of Health to protect groundwater resources that may serve as drinking water supplies. However, the Draft EA provides limited information regarding the design and operation of the proposed wastewater treatment system. Given that the proposed facility will provide clinical services and is expected to serve more than 100 patients per day, PRP requests that the Final EA provide additional information regarding: • anticipated wastewater generation volumes • the type of wastewater treatment technology proposed • whether deep or sha llow injection wells will be used • potential impacts to groundwater resources • long-term system maintenance and monitoring requirements "' r ' WWW. PR P • H AWA 11 . COM PHONE ) 808.5/8.5557 llOOALAKEASTREET/4THFLOOR {5) TWITTER 0 WVNlrACfllOOK COM/ HONOLULU / H: 9681c dPRPHAWAll PACIFICRESOURCEPARTNERSHIP The Draft EA should also clarify whether medical wastewater or substances associated with clinical services could enter the wastewater treatment system and whether additional review by th e Department of Health will be req uired. Because the site lies above groundwater resources with potential drinking water value, additional analysis of groundwater protection measures would help ensure that environmental impacts are fully considered. 2. Alternatives Analysis The Draft EA indicates that alternate locations were evaluated during early project planning but ultimately concludes that no alternative sites warrant further study. However, the discussion of altern ative locations in the Draft EA is limited. Given the scale of the proposed development and the use of public funding sources, PRP requests that the Final EA provide additional explanation re garding the altern atives consid ered during project planning. Additional discussion could include: • whether alternative locations within alrea dy developed areas were eva luated • whether expansion of existing medical facilities was considered • the criteria used to se lect the proposed site over other potential locations A more detailed explanation of the alternatives considered would help clarify the basis for the se lected site and ensure that the environmental revi ew process adeq uately evaluates reaso nable alternatives. 3. Cumulative and Secondary Impacts Th e Draft EA acknowledges that the Puna Di strict has experienced rapid populat ion growth and is expected to continue growing signifi cantly in the coming years. The project site is also part of a large r property owned by W.H . Shipman Ltd ., with the proposed development occupying a portion of a large r parcel. Given these circumstances, PRP req uests that the Final EA provide additional discussion regarding cu mulative and secondary impacts associated with the proposed project. This could include consideration of: • foreseeable development on adjacent portions of the property • cumulative traffic impacts in the Kea'au area • long-term infrastructure demands related to population growth • potential expa nsion of medical facilities in the future "' i' I : [ WWW, P RP · HAWAII . C 0 M T '. • I ' PHONE ) BOB.528.5557 llOOALAKEASTREEI fl,THFLOOH ~ TWITTER 0 WWWfACEllOOKCOM/ HONOLULU I HI 96813 f.JPRPllAWAI PACIFtCRE50URCEPARTNERSl!IP Additional discussion of cumulative impacts would help provide a clearer understanding of how th e proposed project may interact with future development and infrastructure needs in the area. In addition to the comments above, PRP respectfully requests that the proposing agency fully address the issues raised in these co mments in the Final Environmental Assessment. PRP reserves the right to raise additional issues related to the environmental review of this project should add itional information become avai lable or should the Final Environmental Assessment fail to adequately address the concerns identified during the public review process. PRP further re se rves all ri ghts ava ilable under Ha wa i'i Revised Statutes Chapter 343 and related laws and regulations. Based on the issues identified above, PRP respectfully requests that the agency carefully consider whether additional environmental analysis may be warranted to fully evaluate potential impacts associated with the proposed project prior to issuing a Finding of No Significant Impact. ' .. WWW.PR P -H AWAI I. COM '' I PHONE 'l 808.528.5557 "00/1LAKEASTREU -TH fLOOP © )'.". TER 0 \WNllACEOOC~C0\1 H0'~0LuLU H, 9~81J dPRPHA\'.'AI PAC FICRESOURCEPARl'JERSH P 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com April 29, 2026 Pacific Resource Partnership (PRP) 1100 Alakea Street, 4th Floor Honolulu, HI 96813 Subject: Response to Public Comments on the Draft Environmental Assessment — Hilo Benioff Medical Center Keaʻau Outpatient Center RE: Keaʻau Outpatient Center — Hilo Benioff Medical Center (HBMC) New Location Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Pacific Resource Partnership, Mahalo for your review of the Draft Environmental Assessment (DEA) for the proposed Hilo Benioff Medical Center (HBMC) Keaʻau Benioff Medical Center and for your comments submitted during the public comment period. Land Planning Hawaiʻi LLC, on behalf of HBMC, has carefully reviewed Pacific Resource Partnership’s (PRP) comments and welcomes the opportunity to respond. PRP’s three comment topics — wastewater treatment and groundwater protection, alternatives analysis, and cumulative and secondary impacts — have each been addressed in the Final Environmental Assessment (FEA), as summarized below. 1. Wastewater Treatment and Groundwater Protection PRP requested additional information regarding anticipated wastewater generation volumes, the type of wastewater treatment technology proposed, whether injection wells will be used, potential impacts to groundwater resources, and long-term system maintenance and monitoring requirements. These are addressed in turn below and in the FEA at Section 3.3.3.2 (Wastewater). Wastewater Generation Detailed wastewater generation calculations will be developed at the time of engineering design and prepared as part of the permitting package submitted to the State Department of Health (DOH). Wastewater flow calculations will be based on DOH guidance for the type of use, number of employees, and anticipated patient volumes. Similar to the approach used for water calculations — which will be developed in consultation with the Department of Water Supply as noted in the FEA — wastewater calculations are a permitting-stage deliverable developed in coordination with the regulatory agency once detailed building programs and fixture counts are established. The facility is anticipated to serve more than 100 patients per day across its clinical and behavioral health wings. Based on DOH guidance for outpatient medical facilities of this scale, the project is anticipated to generate wastewater at more than 1,000 gallons per day (gpd), mandating compliance with DOH regulations for a Wastewater Treatment Works (WWTW) providing secondary treatment under Hawaiʻi Administrative Rules (HAR) Chapter 11-62. Precise flow calculations will be developed and submitted to DOH as part of the WWTW permit application during the engineering and permitting phase, prior to construction. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com Proposed Package Wastewater Treatment Works The project will utilize a package Wastewater Treatment Works (WWTW) providing secondary treatment of all wastewater generated on-site. A package WWTW is a self-contained, factory-built treatment unit that integrates all biological treatment processes in a compact system, making it well-suited for commercial and institutional facilities that exceed the capacity of conventional septic systems but are not connected to a municipal sewer. Acceptable secondary treatment technologies include Activated Sludge, Sequential Batch Reactor (SBR), Fixed Bed Biofilm Reactor (FBBR), Moving Bed Biofilm Reactor (MBBR), Membrane Bioreactor (MBR), or other advanced methods ensuring effluent quality meeting DOH’s Chapter 11-62 standards. The specific package unit will be selected during the engineering design phase in coordination with DOH to ensure compliance with all applicable standards for a facility of this type and size. No Injection Wells — Treated Effluent Infiltrated via Leach Fields No deep or shallow injection wells will be used for wastewater disposal. Treated secondary effluent from the package WWTW will be disposed of underground via a properly sized absorption bed (leach field) or other type of drain field, designed and permitted in accordance with DOH Chapter 11-62 requirements. DOH requires a 100% backup absorption system to ensure redundancy. Because the soils in the Puna District can exhibit fast percolation rates, soil replacement below the absorption beds may be evaluated during engineering design; however, the soil replacement requirement may be waived by DOH when the disposal system receives WWTW secondary effluent rather than raw septic effluent. The FEA notes (Section 3.1.4) that the subject property lies above the Underground Injection Control (UIC) line established by DOH to protect groundwater resources with drinking water potential — the zone where the Hilo Aquifer, which supplies most municipal water on the Island, is recharged. The UIC permit requirement referenced in the FEA applies to any stormwater drywells that may be used for drainage management. Because no injection wells are proposed for wastewater disposal, the wastewater system is not subject to UIC permitting requirements. The leach field system will be engineered and permitted by DOH to ensure that secondary-treated effluent meets all applicable standards before infiltrating the soil, providing a protective barrier for underlying groundwater resources. Medical and Clinical Wastewater Clinical operations at the Keaʻau Benioff Medical Center will generate wastewater typical of an outpatient medical facility, including sanitary waste, hand-washing drainage, imaging-related drainage, and laboratory sinks. The facility is an outpatient clinic — not a hospital or inpatient facility — and is not anticipated to generate high-strength or hazardous medical wastewater beyond what is typical of an outpatient setting. The proposed package WWTW is designed to handle the full wastewater stream from the facility. Hazardous waste and regulated medical waste generated by clinical operations (sharps, biohazardous materials) are managed through separate solid waste and hazardous materials handling protocols consistent with DOH and EPA regulations, and do not enter the wastewater treatment system. No additional DOH review beyond the standard WWTW permit process is anticipated for the wastewater stream from this outpatient facility. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com Maintenance and Monitoring Package WWTW systems of the type proposed are subject to ongoing operation, maintenance, and monitoring requirements under DOH Chapter 11-62. These requirements include: regular inspection and servicing of all mechanical components (pumps, blowers, treatment media, instrumentation) by a licensed O&M contractor; periodic sampling and laboratory analysis of treated effluent to confirm compliance with secondary treatment standards for BOD, TSS, and other parameters specified in the DOH permit; recordkeeping and periodic reporting to DOH; and immediate notification to DOH in the event of system malfunction, effluent permit exceedance, or other abnormal conditions. A licensed individual wastewater system operator will be retained for the operational life of the facility, consistent with DOH licensing requirements. The leach field system will also be periodically inspected to ensure proper function and drainage. These maintenance and monitoring commitments are reflected in the FEA as mitigating measures for Section 3.3.3.2 (Wastewater) and will be incorporated as conditions of the DOH WWTW permit. 2. Alternatives Analysis PRP requested that the FEA provide additional explanation regarding alternatives considered during project planning, including whether alternative locations within already-developed areas were evaluated, whether expansion of existing medical facilities was considered, and the criteria used to select the proposed site over other potential locations. The FEA addresses alternatives at Part 2 (Alternatives), and this response supplements that discussion. The fundamental purpose of the Keaʻau Outpatient Center is to bring primary care, specialty care, urgent care, imaging, laboratory, and behavioral health services directly to the Puna District, substantially reducing the burden on HBMC in Hilo and the long travel distances currently faced by Puna’s approximately 50,000 residents. Expansion of existing HBMC facilities at the Hilo campus was evaluated and determined not to address this objective, as doing so would not meaningfully improve healthcare access for Puna residents. A new facility located in Keaʻau — near the geographic center of the Puna District’s population — is the appropriate means to achieve the project’s community healthcare goals. During early planning phases, HBMC evaluated alternative locations for the facility in the Keaʻau area, including commercially and agriculturally zoned parcels. The W.H. Shipman property was selected as the preferred site based on the following criteria: (1) central location within the Keaʻau commercial node, at the intersection of Route 11 (Hawaiʻi Belt Road) and the Keaʻau-Pāhoa Road corridor, providing convenient access from throughout Puna; (2) sufficient parcel size — 108.8 acres total, with the 20-acre project footprint accommodating the full facility buildout, required parking, the on-site WWTW, and associated infrastructure without requiring land assemblage or consolidation of multiple smaller parcels; (3) confirmed availability of county water supply (per Department of Water Supply consultation) and electrical service (HELCO), and the feasibility of an on-site WWTW given site size and soil conditions; and (4) the absence of significant environmental or other factors at the site that would render the proposed use unsuitable, as confirmed by the biotic survey, archaeological studies, and other technical analyses prepared for the FEA. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com Alternative sites examined during planning were constrained by smaller parcel sizes, more complex access configurations, proximity to existing residences, limited utility availability, or development costs and zoning conditions that would compromise the project’s feasibility or introduce greater environmental impacts. The selected site is already in active agricultural use and previously cleared, contains no significant sensitive ecological resources, and does not pose the development challenges presented by other candidate locations. No alternative sites were identified that offered superior environmental outcomes while meeting the project’s program requirements for size, access, utilities, and proximity to Puna residents. The FEA’s Section 2.1 (Alternate Location) reflects this evaluation and the determination that no alternative sites warrant further comparative study within the EA process. 3. Cumulative and Secondary Impacts PRP requested additional discussion regarding cumulative and secondary impacts, including foreseeable development on adjacent portions of the Shipman property, cumulative traffic impacts in the Keaʻau area, long-term infrastructure demands related to population growth, and potential future expansion of medical facilities. The FEA addresses secondary and cumulative impacts at Section 3.4 (Secondary and Cumulative Impacts), and this response provides additional context. The Keaʻau Village Master Plan, which covers additional portions of the W.H. Shipman property adjacent to the project site, was projected to develop in three phases over approximately 2023– 2038 and would ultimately include 590 single-family homes, 350 multi-family homes, 220,408 square feet of commercial space, 43,600 square feet of office space, and 100 hotel rooms. However, as noted in the FEA, construction of the master plan is currently on pause due to infrastructure costs, and the timing of any future phases remains uncertain. Because the master plan’s phasing is speculative, the Traffic Impact Analysis Report (TIAR) prepared for this project incorporated a 2.12% annual background traffic growth rate that conservatively accounts for area-wide growth, including any foreseeable development on surrounding Shipman parcels. The TIAR concludes that even with projected background growth, the roadway network in the Keaʻau area can accommodate anticipated traffic volumes without significant adverse effects. The Keaʻau Mountain View Public Library, proposed northeast of the Route 11/139 intersection, is anticipated to be completed by 2027 and was specifically incorporated into the TIAR traffic projections. The TIAR’s analysis confirms that even accounting for the library and background growth, total traffic remains within the capacity of the roadway network without significant effects. With respect to long-term infrastructure demands, the proposed Keaʻau Outpatient Center is itself a direct response to population growth — it is being developed specifically to address an existing and growing deficit in healthcare access for Puna’s rapidly growing community. The facility’s infrastructure, including the on-site package WWTW, water service lateral, parking, and access driveway, are sized for the proposed 20-acre medical facility. Infrastructure for the project is self-contained and does not rely on public wastewater or sewer systems. In this respect, the project’s cumulative effect on public infrastructure is limited and largely beneficial: it absorbs healthcare demand that would otherwise be borne by HBMC in Hilo and reduces the cumulative impact of population growth on the existing Hilo medical campus. 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com Regarding future expansion of the medical facility, no expansion beyond the current 20-acre project footprint is proposed or evaluated in the FEA. Any future expansion of the facility would be a separate action subject to its own environmental review and permitting under HEPA and applicable county and state regulations. As the FEA concludes, nearly all long-term impacts from the proposed project are negligible, with no meaningful effects on ecosystems or protected species, water quality, historic properties, noise, air quality, or other environmental measures. We trust that the above responses address the concerns raised by PRP and that the Final Environmental Assessment adequately evaluates the potential environmental impacts associated with the proposed Keaʻau Outpatient Center. We remain committed to a thorough and transparent environmental review process and welcome further engagement. Please do not hesitate to contact us directly with any additional questions or to arrange a meeting at your convenience. Sincerely, John Pipan Planning Administrator Land Planning Hawaiʻi LLC OHA Comment Re: DEA for Hilo Benioff Medical Center Kamakana Ferreira < kamakanaf@oha.org > Wed, 11 Mar 2026 10:27:17 AM -1000 To "john@landplanninghawaii.com" <john@landplanninghawaii.com>,"info@landplanninghawaii.com" <info@landplanninghawaii.com> Cc ""<> Aloha, The Office of Hawaiian Affairs (OHA) is in receipt of your letter dated February 20, 2026, inviting comment on the draft environmental assessment (DEA) for the Hilo Benioff Medical Center project in Kea’au. Land Planning Hawaii LLC has prepared this DEA on behalf of Hilo Benioff Medical Center per Hawaii Revised Statutes (HRS) 343. The proposed property is 108.8 acres and the site will take up a 20-acre portion of the parcel zoned for ag (A-20a). The clinic (a single story medical office building with a clinical wing and behavioral health wing, totaling 40,000 sq ft) will be 13 acres of the 20 acre parcel. A new driveway will be built. DEA claims that while an archaeological inventory survey (AIS) wasn’t done, they believe its highly unlikely any resources exist as the site has already been cleared and previously used for sugarcane production. Minimally, we recommend completion of an archaeological literature review and field inspection (ALRFI) and consultation with the State Historic Preservation Division (SHPD) to see if there are any historic or archaeological resources around the project area. For cultural resources, the DEA says that its unknown if the subject property or surrounding area was used for gathering practices. As such, the DEA concludes its unlikely that such practices would exist today. Currently, its unclear if any type of community outreach specific to cultural resources occurred. Guidelines for assessing cultural impacts are provided by the Office of Environmental Quality Control (OEQC) in the Guide to Implementation and Practice of the Hawaii Environmental Policy Act, Exhibit 1-1, 2012 Edition. The process should involve an attempt to consult with community and cultural practitioners to ascertain ethnographic information on cultural resources and practices that occur on the site or in the broader area. As the DEA fails to mention any type of outreach specific to cultural related consultation, it is unclear if the project will effect cultural practices occurring nearby. We thus encourage the applicant to complete some level of cultural outreach for this particular project and to document their findings on possible impacts to cultural resources or practices. Mahalo for the opportunity to comment. We look forward to seeing our comments taken into consideration. Please let me know if you have any questions. Mahalo, Kamakana C. Ferreira Compliance Archaeologist Office of Hawaiian Affairs 560 N. Nimitz Hwy Honolulu, Hi. 96817 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com April 29, 2026 Kamakana C. Ferreira Compliance Archaeologist Office of Hawaiian Affairs 560 N. Nimitz Hwy Honolulu, HI 96817 Subject: Response to OHA Comments on the Draft Environmental Assessment — Hilo Benioff Medical Center Keaʻau Outpatient Center RE: Keaʻau Benioff Medical Center — Hilo Benioff Medical Center (HBMC) New Location Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Mr. Ferreira, Mahalo for your review of the Draft Environmental Assessment (DEA) for the proposed Hilo Benioff Medical Center (HBMC) Keaʿau Outpatient Center and for the comments submitted by the Office of Hawaiian Affairs (OHA) on March 11, 2026. Land Planning Hawaiʻi LLC, on behalf of HBMC, has carefully reviewed OHAʿs comments and welcomes the opportunity to respond. OHAʿs two comment topics — archaeological resources and cultural resources/community outreach — have each been addressed in the Final Environmental Assessment (FEA), as summarized below. 1. Archaeological Resources OHA recommends completion of an Archaeological Literature Review and Field Inspection (ALRFI) and consultation with the State Historic Preservation Division (SHPD) to identify any historic or archaeological resources in and around the project area. The FEA addresses archaeological resources at Section 3.2.4 (Cultural and Historic Resources) and documents a substantial body of prior archaeological work completed for the subject property and the broader W.H. Shipman landholding, all accepted by SHPD. Prior Archaeological Studies Multiple archaeological studies have been completed for the subject property and surrounding lands. These studies collectively satisfy the concerns raised by OHA regarding the absence of an AIS in the DEA. Rechtman Consulting, LLC conducted an Archaeological Assessment of an approximately 112- acre portion of TMKs (3) 1-6-003:007 and (3) 1-6-146:017 in September 2004 (FEA Appendix F). That assessment encompassed the entirety of the subject 20-acre project area and produced no evidence of early historic or traditional Hawaiian remains. The assessed area was confirmed to consist primarily of fallow sugarcane fields, and the small, seemingly uncultivated portion of 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com the assessed area was intensively surveyed and contained no cultural remains. The assessment recommended that no further archaeological work need be conducted prior to development. SHPD accepted the findings of this report on February 16, 2005. Scientific Consultant Services (SCS) subsequently conducted an Archaeological Inventory Survey (AIS) of approximately 254.1 acres of the broader W.H. Shipman property in Keaʿau, which encompasses and surrounds the project site. Fieldwork was conducted between January and December 2016, and the AIS was submitted to SHPD in May 2017. The survey was conducted in accordance with Hawaiʻi Administrative Rules 13-284 and the Rules Governing Minimal Standards for Archaeological Inventory Surveys and Reports (HAR 13-276). SHPD accepted the findings and recommendations of the AIS in a letter dated February 12, 2018. An earlier SCS field investigation in July 2014 covering adjacent Shipman property was also accepted by SHPD on September 4, 2014, with SHPD concurring that no historic properties would be affected within that surveyed area. Collectively, the AIS identified three surface historic properties within the broader Shipman Master Plan Area, all associated with historic-era plantation activities from the early 1900s to 1950s: Site TS-001 (plantation dwellings and garden features of Luna Row) and Site TS-002 (a rock wall enclosing the former plantation doctorʿs house lot). Thirteen historic-era sugarcane features were also documented. No pre-Contact archaeological sites were identified within any portion of the surveyed Shipman property, and SHPD concurred that no further work was necessary for the areas encompassing the subject project site. These sites are not within or adjacent to the project area. The subject project areaʿs uninterrupted history of commercial sugarcane cultivation and repeated clearing renders it highly unlikely that pre-Contact or historic archaeological resources remain within the 20-acre project footprint. Aerial imagery from 1965 through the present, presented in Figures 9 and 10 of the FEA, confirms the extent and continuity of this agricultural disturbance. Based on the foregoing, and consistent with SHPDʿs prior concurrences, no additional ALRFI or AIS is required for the subject project area prior to development. Inadvertent Discovery Provision Notwithstanding the thorough prior archaeological coverage, the FEA includes a standard inadvertent discovery provision as a mitigating measure: should any undocumented archaeological or cultural resources — including artifacts, shells, bones, midden deposits, charcoal deposits, lava tubes, stone platforms, pavings, or rock walls — be encountered during grading or construction, all work in the immediate vicinity of the find will cease and SHPD will be contacted to determine the significance of the find and to approve an acceptable mitigation plan as needed. If human burials are encountered, they will be treated in accordance with the specific provisions of Chapter 6E, HRS. 2. Cultural Resources and Community Outreach OHA notes that the DEA does not describe community outreach specific to cultural resources and encourages the applicant to conduct cultural outreach and document findings regarding 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com possible impacts to cultural resources or practices, consistent with the OEQCʿs guidance in the Guide to Implementation and Practice of the Hawaii Environmental Policy Act and the Hawaiʻi Supreme Courtʿs PASH and Ka Paʿakai O Ka ʻAina decisions. The FEA addresses these concerns at Section 3.2.4 and documents both a Cultural Impact Assessment and additional outreach efforts undertaken in direct response to OHAʿs DEA comments. Cultural Impact Assessment PBR HAWAII prepared a Cultural Impact Assessment (CIA) for the Keaʿau Village Master Plan, which covers the W.H. Shipman property that encompasses the subject project site. As the project site is located within the same Keaʿau Ahupuaʿa and on the same landholding studied in the CIA, the findings and conclusions of the CIA are directly applicable. The CIA provides detailed information on the cultural and historical context of the Keaʿau Ahupuaʿa, prior archaeological work, and summaries of community consultations and ʼtalk storyʽ interviews with individuals knowledgeable about cultural resources and practices in the area. A review of these consultations did not reveal or identify cultural resources or practices that may be adversely affected by development within the project area. The subject project site, given its long history of commercial sugarcane cultivation and repeated clearing, does not appear to contain the native plant resources typically associated with traditional Hawaiian gathering practices. Additional Cultural Outreach for the FEA In direct response to OHAʿs DEA comments, Land Planning Hawaiʻi LLC mailed additional consultation letters to the following organizations, each provided a 30-day period to respond: • Association of Hawaiian Civic Clubs • Cultural Resources Division of the Bernice Pauahi Bishop Museum • The Department of Hawaiian Home Lands • Hui Mālama I Nā Kupuna O Hawaiʻi Nei • Ka Haka ʿUla O Keʿelikōlani — College of Hawaiian Language, UH Hilo To date, no responses have been received from any of the above organizations. This outreach is documented in Section 1.5 (Public Involvement and Agency Coordination) and Appendix E of the FEA. Consistency with PASH and Ka Paʿakai O Ka ʻAina The FEA addresses the Hawaiʻi Supreme Courtʿs requirements under PASH and Ka Paʿakai O Ka ʻAina, which require decision-makers to: (1) identify cultural, historical, and natural resources and associated traditional and customary practices of the subject site; (2) assess the impacts of the proposed project on those resources and practices; and (3) identify feasible mitigating measures to protect such resources and practices. Based on the CIA, the AIS, and the Archaeological Assessment collectively, no significant adverse impacts to cultural resources, 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com traditional practices, or gathering rights are anticipated from the proposed project. Archaeological studies conducted throughout the Keaʿau area since the 1990s have not found evidence of pre-Contact habitation or traditional resource use within the sugarcane cultivation areas of the Shipman property, and no cultural informants or community consultees identified practices that would be adversely impacted by the proposed development. These conclusions are documented in FEA Section 3.2.4. We trust that the above responses address the concerns raised by OHA and that the Final Environmental Assessment adequately evaluates potential impacts to archaeological and cultural resources associated with the proposed Keaʿau Outpatient Center. We remain committed to a thorough and transparent environmental review process and welcome further engagement. Mahalo for the opportunity to respond, and please do not hesitate to contact us directly with any additional questions. Sincerely, John Pipan Planning Administrator Land Planning Hawaiʻi LLC 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com March 24, 2026 President Association of Hawaiian Civic Clubs Hawaiian Civic Club of Puna P.O. Box 1135 Honolulu, Hawaiʻi 96808 Subject: Cultural Resource Consultation – HEPA Environmental Assessment RE: Keaʻau Benioff Health Center Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear President, Hilo Benioff Medical Center (HBMC) is writing to invite your organization's participation in the cultural resource consultation process for the proposed HBMC Keaʻau Benioff Health Center. HBMC proposes to develop an outpatient medical facility on a 20-acre portion of a 108.8-acre parcel located in the Keaʻau Ahupuaʻa, Puna District, Island of Hawaiʻi. The project area consists largely of former Olāʻa / Puna Sugar Company sugarcane lands that have been in agricultural use for several decades. A Draft Environmental Assessment (DEA) has been prepared pursuant to the Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343. HBMC is writing to the Puna Hawaiian Civic Club as a community organization representing Hawaiian interests across the Puna District — the moku within which the Keaʻau Ahupuaʻa is located. The Club's members include kūpuna and community leaders with generational ties to the Keaʻau area and knowledge of its traditional resources, cultural history, and contemporary Hawaiian community values. We respectfully invite your organization's participation in the cultural resources consultation process as part of the Environmental Assessment review under HEPA, HRS Chapter 343. This process is also intended to satisfy the requirements of HRS Chapter 6E (State Historic Preservation Law), the Environmental Council's Guidelines for Assessing Cultural Impacts (1997), and the standards established by the Hawaiʻi Supreme Court in PASH and Ka Paʻakai O Ka ʻĀina. Request for Information We respectfully request any information your organization can share regarding the following: • Traditional and customary Native Hawaiian cultural practices, land use patterns, and gathering rights associated with the Keaʻau Ahupuaʻa and the surrounding Puna District; • Oral traditions, moʻolelo, place names, or traditional ecological knowledge pertaining to the project area or its vicinity; • Known or suspected archaeological sites, heiau, burial sites, traditional cultural properties (TCPs), or other cultural resources in or near the project area; • Any concerns regarding ground-disturbing construction activities within the Keaʻau Ahupuaʻa; 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com We invite the Club's members and officers to share any knowledge of traditional cultural resources, practices, oral histories, or cultural associations with the Keaʻau Ahupuaʻa and the former Olāʻa Sugar lands. We also welcome the Club's perspective on how HBMC can most respectfully and meaningfully engage the Puna Hawaiian community throughout the project planning and Environmental Assessment process. Response Requested We respectfully request a written response within thirty (30) calendar days from the date of this letter. If your organization would prefer to meet in person or by telephone, we welcome that opportunity. HBMC will ensure that information gathered through this consultation is respectfully documented and incorporated into the final Environmental Assessment. HBMC is committed to being a respectful and responsible member of the Keaʻau community and looks forward to the Puna Hawaiian Civic Club's input. Sincerely, John Pipan Planning Administrator 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com March 24, 2026 Cultural Resources Division Bernice Pauahi Bishop Museum 1525 Bernice Street Honolulu, Hawaiʻi 96817 Subject: Cultural Resource Consultation – HEPA Environmental Assessment RE: Keaʻau Benioff Health Center Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Cultural Resources Division, Hilo Benioff Medical Center (HBMC) is writing to invite your organization's participation in the cultural resource consultation process for the proposed HBMC Keaʻau Benioff Health Center. HBMC proposes to develop an outpatient medical facility on a 20-acre portion of a 108.8-acre parcel located in the Keaʻau Ahupuaʻa, Puna District, Island of Hawaiʻi. The project area consists largely of former Olāʻa / Puna Sugar Company sugarcane lands that have been in agricultural use for several decades. A Draft Environmental Assessment (DEA) has been prepared pursuant to the Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343. HBMC is writing to the Bernice Pauahi Bishop Museum in recognition of the Museum's unparalleled collections of archaeological, historical, and cultural materials relating to the Puna District and the Island of Hawaiʻi. The Museum's libraries, archives, and cultural collections — including records of the Olāʻa / Puna Sugar Company era and pre-contact land use in the Keaʻau Ahupuaʻa — represent a critical resource for the review of potential cultural impacts of the proposed project. We respectfully invite your organization's participation in the cultural resources consultation process as part of the Environmental Assessment review under HEPA, HRS Chapter 343. This process is also intended to satisfy the requirements of HRS Chapter 6E (State Historic Preservation Law), the Environmental Council's Guidelines for Assessing Cultural Impacts (1997), and the standards established by the Hawaiʻi Supreme Court in PASH and Ka Paʻakai O Ka ʻĀina. Request for Information We respectfully request any information your organization can share regarding the following: • Traditional and customary Native Hawaiian cultural practices, land use patterns, and gathering rights associated with the Keaʻau Ahupuaʻa and the surrounding Puna District; • Oral traditions, moʻolelo, place names, or traditional ecological knowledge pertaining to the project area or its vicinity; • Known or suspected archaeological sites, heiau, burial sites, traditional cultural properties (TCPs), or other cultural resources in or near the project area; • Any concerns regarding ground-disturbing construction activities within the Keaʻau Ahupuaʻa; 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com We respectfully request the Museum's assistance in identifying any archival materials, archaeological site records, historic maps, oral history collections, or published reports relating to the Keaʻau Ahupuaʻa and the former Olāʻa Sugar lands. We also welcome the Museum's comment on any aspects of the project's potential effects on cultural resources in the Puna District. Copies of relevant materials, to the extent they can be shared, would be greatly appreciated. Response Requested We respectfully request a written response within thirty (30) calendar days from the date of this letter. If your organization would prefer to meet in person or by telephone, we welcome that opportunity. HBMC will ensure that information gathered through this consultation is respectfully documented and incorporated into the final Environmental Assessment. HBMC values the Bishop Museum's scholarly resources and looks forward to benefiting from the Museum's expertise in this consultation. Sincerely, John Pipan Planning Administrator 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com March 24, 2026 Mr. Kali Watson Chairman Department of Hawaiian Home Lands 91-5420 Kapolei Parkway Kapolei, Hawaiʻi 96707 Subject: Cultural Resource Consultation – HEPA Environmental Assessment RE: Keaʻau Benioff Health Center Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Mr. Watson, Hilo Benioff Medical Center (HBMC) is writing to invite your organization's participation in the cultural resource consultation process for the proposed HBMC Keaʻau Benioff Health Center. HBMC proposes to develop an outpatient medical facility on a 20-acre portion of a 108.8-acre parcel located in the Keaʻau Ahupuaʻa, Puna District, Island of Hawaiʻi. The project area consists largely of former Olāʻa / Puna Sugar Company sugarcane lands that have been in agricultural use for several decades. A Draft Environmental Assessment (DEA) has been prepared pursuant to the Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343. HBMC is writing to the Department of Hawaiian Home Lands (DHHL) in recognition of the Department's significant landholdings in the Puna District and its mandate to benefit Native Hawaiian beneficiaries. DHHL's presence in the Keaʻau area and its knowledge of Native Hawaiian land tenure, community needs, and cultural resources in the Puna District make the Department an important consulting party for this project. HBMC is respectful of DHHL's kuleana and seeks to ensure that the proposed facility does not adversely affect DHHL beneficiaries or their cultural resources. We respectfully invite your organization's participation in the cultural resources consultation process as part of the Environmental Assessment review under HEPA, HRS Chapter 343. This process is also intended to satisfy the requirements of HRS Chapter 6E (State Historic Preservation Law), the Environmental Council's Guidelines for Assessing Cultural Impacts (1997), and the standards established by the Hawaiʻi Supreme Court in PASH and Ka Paʻakai O Ka ʻĀina. Request for Information We respectfully request any information your organization can share regarding the following: • Traditional and customary Native Hawaiian cultural practices, land use patterns, and gathering rights associated with the Keaʻau Ahupuaʻa and the surrounding Puna District; • Oral traditions, moʻolelo, place names, or traditional ecological knowledge pertaining to the project area or its vicinity; • Known or suspected archaeological sites, heiau, burial sites, traditional cultural properties (TCPs), or other cultural resources in or near the project area; 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com • Any concerns regarding ground-disturbing construction activities within the Keaʻau Ahupuaʻa; We respectfully request DHHL's review of the project description and site location and any information the Department can provide regarding: (a) cultural or archaeological resources on or adjacent to the project site within DHHL's planning records; (b) any DHHL beneficiary families or homestead communities in the Keaʻau area that should be directly consulted; and (c) DHHL's assessment of whether the proposed project may affect access to or the exercise of customary or traditional practices by DHHL beneficiaries. Response Requested We respectfully request a written response within thirty (30) calendar days from the date of this letter. If your organization would prefer to meet in person or by telephone, we welcome that opportunity. HBMC will ensure that information gathered through this consultation is respectfully documented and incorporated into the final Environmental Assessment. HBMC values DHHL's role as a trustee for Native Hawaiian land and looks forward to a collaborative consultation. Sincerely, John Pipan Planning Administrator 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com March 24, 2026 Executive Director Hui Mālama I Nā Kupuna O Hawaiʻi Nei P.O. Box 896 Honolulu, Hawaiʻi 96808 Subject: Cultural Resource Consultation – HEPA Environmental Assessment RE: Keaʻau Benioff Health Center Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Executive Director, Hilo Benioff Medical Center (HBMC) is writing to invite your organization's participation in the cultural resource consultation process for the proposed HBMC Keaʻau Benioff Health Center. HBMC proposes to develop an outpatient medical facility on a 20-acre portion of a 108.8-acre parcel located in the Keaʻau Ahupuaʻa, Puna District, Island of Hawaiʻi. The project area consists largely of former Olāʻa / Puna Sugar Company sugarcane lands that have been in agricultural use for several decades. A Draft Environmental Assessment (DEA) has been prepared pursuant to the Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343. HBMC is writing to Hui Mālama I Nā Kupuna O Hawaiʻi Nei in recognition of the organization's kuleana for the care and protection of iwi kūpuna and burial sites throughout the Hawaiian Islands. The Keaʻau Ahupuaʻa, as a historically inhabited area with documented land tenure records dating to the Māhele of 1848, may contain burial sites or ancestral remains associated with the generations of Native Hawaiians who lived and worked the land in this ahupuaʻa. The Archaeological Literature Review and Field Inspection to be conducted for this project will address burial-related concerns, but HBMC wishes to ensure that Hui Mālama's guidance informs the scope of that work. We respectfully invite your organization's participation in the cultural resources consultation process as part of the Environmental Assessment review under HEPA, HRS Chapter 343. This process is also intended to satisfy the requirements of HRS Chapter 6E (State Historic Preservation Law), the Environmental Council's Guidelines for Assessing Cultural Impacts (1997), and the standards established by the Hawaiʻi Supreme Court in PASH and Ka Paʻakai O Ka ʻĀina. Request for Information We respectfully request any information your organization can share regarding the following: • Traditional and customary Native Hawaiian cultural practices, land use patterns, and gathering rights associated with the Keaʻau Ahupuaʻa and the surrounding Puna District; • Oral traditions, moʻolelo, place names, or traditional ecological knowledge pertaining to the project area or its vicinity; • Known or suspected archaeological sites, heiau, burial sites, traditional cultural properties (TCPs), or other cultural resources in or near the project area; 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com • Any concerns regarding ground-disturbing construction activities within the Keaʻau Ahupuaʻa; We request Hui Mālama's guidance regarding appropriate protocols for unanticipated burial discoveries during construction in the Keaʻau area, consistent with HRS §6E-43.5. We also welcome any information the organization may have regarding known burial locations or traditional burial practices within the Keaʻau Ahupuaʻa. Response Requested We respectfully request a written response within thirty (30) calendar days from the date of this letter. If your organization would prefer to meet in person or by telephone, we welcome that opportunity. HBMC will ensure that information gathered through this consultation is respectfully documented and incorporated into the final Environmental Assessment. HBMC is committed to the respectful treatment of any burial sites that may be encountered and to full compliance with HRS §6E-43.5 and Hui Mālama's guidance. Sincerely, John Pipan Planning Administrator 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com March 24, 2026 Dean / Director Ka Haka ʻUla O Keʻelikōlani — College of Hawaiian Language, UH Hilo University of Hawaiʻi at Hilo 200 W. Kāwili Street, Hilo, Hawaiʻi 96720 Subject: Cultural Resource Consultation – HEPA Environmental Assessment RE: Keaʻau Benioff Health Center Applicant: Hilo Benioff Medical Center (HBMC) Location: Keaʻau, Puna, Hawai‘i TMK (3) 1-6-003: 127 (por.), TMK (3) 1-6-003: 007 (por.) Dear Dean / Director, Hilo Benioff Medical Center (HBMC) is writing to invite your organization's participation in the cultural resource consultation process for the proposed HBMC Keaʻau Benioff Health Center. HBMC proposes to develop an outpatient medical facility on a 20-acre portion of a 108.8-acre parcel located in the Keaʻau Ahupuaʻa, Puna District, Island of Hawaiʻi. The project area consists largely of former Olāʻa / Puna Sugar Company sugarcane lands that have been in agricultural use for several decades. A Draft Environmental Assessment (DEA) has been prepared pursuant to the Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343. HBMC is writing to Ka Haka ʻUla O Keʻelikōlani, the College of Hawaiian Language at UH Hilo, in recognition of the College's expertise in documenting and preserving oral traditions, place names, and traditional ecological and cultural knowledge for East Hawaiʻi. The College's faculty and students work with Hawaiian-language sources that may contain information about the Keaʻau Ahupuaʻa and its traditional cultural resources that is not available in English-language archives. We respectfully invite your organization's participation in the cultural resources consultation process as part of the Environmental Assessment review under HEPA, HRS Chapter 343. This process is also intended to satisfy the requirements of HRS Chapter 6E (State Historic Preservation Law), the Environmental Council's Guidelines for Assessing Cultural Impacts (1997), and the standards established by the Hawaiʻi Supreme Court in PASH and Ka Paʻakai O Ka ʻĀina. Request for Information We respectfully request any information your organization can share regarding the following: • Traditional and customary Native Hawaiian cultural practices, land use patterns, and gathering rights associated with the Keaʻau Ahupuaʻa and the surrounding Puna District; • Oral traditions, moʻolelo, place names, or traditional ecological knowledge pertaining to the project area or its vicinity; • Known or suspected archaeological sites, heiau, burial sites, traditional cultural properties (TCPs), or other cultural resources in or near the project area; • Any concerns regarding ground-disturbing construction activities within the Keaʻau Ahupuaʻa; 194 Wiwo‘ole St. Hilo, HI 96720 (808) 333-3393 info@landplanninghawaii.com We respectfully request the College's assistance in identifying any Hawaiian-language documents, oral tradition collections, place name studies, or traditional ecological knowledge records pertaining to the Keaʻau Ahupuaʻa and the former Olāʻa Sugar lands. We also welcome recommendations for Hawaiian cultural practitioners or kūpuna in the Puna area who should be directly consulted. Response Requested We respectfully request a written response within thirty (30) calendar days from the date of this letter. If your organization would prefer to meet in person or by telephone, we welcome that opportunity. HBMC will ensure that information gathered through this consultation is respectfully documented and incorporated into the final Environmental Assessment. HBMC values the unique expertise and resources of Ka Haka ʻUla O Keʻelikōlani and looks forward to learning from your institution's knowledge. Sincerely, John Pipan Planning Administrator APPENDIX F ARCHAEOLOGICAL ASSESSMENT AND SHPD ACCEPTANCE LETTER RC-0260 Archaeological Assessment of a 112 Acre Property (TMK: 3-1-6-03:por. 07 and 3-1-6-146:17) Kea‘au Ahupua‘a Puna District Island of Hawai‘i PREPARED BY: Michael Desilets, M.A. and Robert B. Rechtman, Ph.D PREPARED FOR: Dean Hirabayashi A & B Properties, Inc. 822 Bishop Street Honolulu, Hawai‘i 96813 September 2004 RCR C , LLCECHTMAN ONSULTING A , C , H SRCHAEOLOGICAL ULTURAL AND ISTORICAL TUDIES HC 1 Box 4149 Kea‘au, Hawai‘i 96749 phone: (808) 966-7636 toll-free fax: (800)406-2665e-mail: bob#rechtmanconsulting.com Archaeological Assessment of a 112 Acre Property (TMK: 3-1-6-03:por. 07 and 3-1-6-146:17) Kea‘au Ahupua‘a Puna District Island of Hawai‘i RC-0260 EXECUTIVE SUMMARY At the request of Dean Hirabayashi of A & B Properties, Inc., Rechtman Consulting, LLC performed an archaeological assessment survey of two parcels (TMK:3-1-6-003:por. 07 and 3-1-6-146:17) in Kea‘au Ahupua‘a, Puna District, Island of Hawai‘i. The purpose of this study was to document the presence of any historic properties that might exist within the 112-acre project area, assess the significance of any such resources, and provide a statement of impact to any such resources resulting from future development. Fieldwork for the project area was conducted between July 14–16, 2004 under the supervision of Robert B. Rechtman, Ph.D. The property was surveyed using pedestrian transects with 15 meter spacing. Parallel transects were walked on a north/south bearing across the length of the project area. Vegetation was very dense and ground visibility was poor. Evidence of modern cultivation was observed during the survey and consisted of ‘dozer-push’ piles and abandoned field roads. These were interpreted as remnants of late twentieth century sugarcane cultivation. Archaeological survey of the project area produced no evidence of early historic or traditional Hawaiian remains. The survey confirmed that most of the area consisted of fallow sugarcane and papaya fields. A small seemingly uncultivated portion of the project area was intensively surveyed and contained no cultural remains. As there were no significant cultural sites or deposits encountered within the study parcels, it is recommended that no further archaeological work need be conducted prior to development. However, in the unlikely event that historic properties are inadvertently discovered during construction activities, such activities should be immediately suspended in the vicinity of the discovery, and DLNR-SHPD notified as outlined in the Hawai‘i Administrative Rules 13§13-284. ii RC-0260 Contents INTRODUCTION .........................................................................................................1 PROJECT AREA DESCRIPTION................................................................................1 BACKGROUND STUDIES ..........................................................................................6 Puna District and Kea‘au Ahupua‘a ..............................................................................6 Previous Archaeology....................................................................................................7 CURRENT PROJECT EXPECTATIONS ..................................................................11 FIELDWORK METHODS AND RESULTS..............................................................12 CONCLUSIONS AND RECOMMENDATIONS ......................................................12 REFERENCES CITED................................................................................................12 Figures 1. Project area location...................................................................................................2 2. Portion of TMK:3-1-6-03 showing project area within Parcel 7 and location of previous archaeological survey......................................................................................3 3. Large palms in base of drainage in the northern part of the project area...................4 4. Far northern portion of project area showing broken pāhoehoe and surrounding vegetation.......................................................................................................................4 5. One of several large grassy expanses within the project area....................................5 6. TMK:3-1-6-146 showing Parcel 17. ..........................................................................5 7. Aerial photograph taken in 1975 showing project area outlined in white with undeveloped area (dashed line)......................................................................................8 8. Aerial photograph taken in 1994 showing project area outlined in black. ................9 9. Aerial photograph taken in 1999 showing project area outlined in white. ..............10 10. Map depicting locations of ash deposits corresponding to the Upland Agricultural Zone (adapted from McEldowney 1979:63). ..........................................11 Tables 1. Prior relevant archaeological and historical studies...................................................7 iii RC-0260 INTRODUCTION At the request of Dean Hirabayashi of A & B Properties, Inc., Rechtman Consulting, LLC performed an archaeological assessment of two parcels (TMK:3-1-6-003:por. 07 and 3-1-6-146:17) in Kea‘au Ahupua‘a, Puna District, Island of Hawai‘i (Figure 1). The purpose of this study was to document the presence of any historic properties that might exist within the 112-acre project area, assess the significance of any such resources, and provide a statement of impact to any such resources resulting from future development. This report is intended to fulfill the requirements of the County of Hawai‘i Planning Department and the Department of Land and Natural Resources-State Historic Preservation Division (DLNR-SHPD) with respect to permit approvals for land-altering and development activities. The current project was undertaken in compliance with the historic preservation review process requirements of the Department of Land and Natural Resources-State Historic Preservation Division (DLNR-SHPD) as specified in Hawai‘i Administrative Rules.13§13–284. This report details the current project objectives and scope of work, field methods and procedures, and survey findings. A brief archaeological and historical background is provided, which forms the basis for a set of project expectations. Recommendations addressing future historic preservation concerns are offered. PROJECT AREA DESCRIPTION The current project area consists of two parcels covering a combined area of 112 acres immediately mauka of Highway 11 (Figure 2). The area is generally level with a slight slope to the northeast. Elevation ranges from 280 to 320 feet above mean sea level. The larger parcel, TMK:3-1-6-003:por. 07, covers 109 acres and borders Highway 11 for approximately 870 meters. The parcel begins at W.H. Shipman Business Park and extends to the south. Vegetation in this area is very dense with tall grass dominating large expanses (Figure 3). Much of the area is also semi-wooded with moderate to dense understory. Mature stands of Moluccan albizia (Falcataria moluccana) are present. Most of the vegetation consists of fast growing, invasive species. This suggests that the area is in the early stages of forest development and has likely undergone large-scale disturbance in the recent past. Also included in the larger parcel is a narrow east/west trending drainage containing a variety of palms, ferns, and large banyon trees (Figure 4). Sediment in the base of the drainage is a rich, moist, silt loam. On the drainage slopes, however, broken pāhoehoe constitutes the dominant surface material (Figure 5). This small drainage appears unmodified by historic era processes. The smaller parcel, 3-1-6-146:17, covers 2.8 acres within W. H. Shipman Business Park (Figure 6). This lot has been entirely landscaped, filled, and leveled to facilitate use as an industrial staging area. Vegetation consists of only a few intrusive weeds and grasses. The ground surface consists of gravel and crushed cobbles with minimal interstitial silt loam. 1 RC-0260 Figure 1. Project area location. 2 RC-0260 Figure 2. Portion of TMK: 3-1-6-03 showing project area within Parcel 7 and location of previous archaeological survey. 3 RC-0260 Figure 3. Large palms in base of drainage in the northern part of the project area. Figure 4. Far northern portion of project area showing broken pāhoehoe and surrounding vegetation. 4 RC-0260 Figure 5. One of several large grassy expanses within the project area. 5 RC-0260 BACKGROUND STUDIES This section of the report describes and synthesizes prior archaeological, cultural, and historical studies that are relevant to the current project area; and provides a brief culture-historical background of Puna District and Kea‘au Ahupua‘a specifically. Puna District and Kea‘au Ahupua‘a Kea‘au Ahupua‘a is a portion of the larger Puna District, one of six major districts on the island that remain intact today. This division of districts (and likely all of the smaller land divisions) extends back in time to at least A.D. 1475, in the time of the Chief Līloa; and were brought together under a single ruler when ‘Umi a Līloa (son of Līloa) came to power in about A.D. 1525 (Maly 1999). Barrère (1959) summarizes the Precontact geopolitics of the Puna District as follows: Puna, as a political unit, played an insignificant part in shaping the course of history of Hawaii Island. Unlike the other districts of Hawaii, no great family arose upon whose support one or another of the chiefs seeking power had to depend for his success. Puna lands were desirable, and were eagerly sought, but their control did not rest upon conquering Puna itself, but rather upon control of the adjacent districts, Kau and Hilo. (Barrère 1959:15) The Puna District generally remained under the control of outside chiefs until the time of Kalani‘ōpu‘u’s reign. Shortly before his death in A.D. 1782, Kalani‘ōpu‘u’s dominion over Puna and portion of Ka‘ū was challenged by the Puna chief ‘Īmakakōloa. Kalani‘ōpu‘u resolved the unrest, but following his death the disposition of Puna once again became an issue until Kamehameha I successfully brought the entire island under his control in A.D 1793. As a result of the Māhele of A.D 1848, most of Puna was retained as crown land. Research conducted by Kepā Maly shows that although Kea‘au ahupua‘a was well populated at the time, only two claims were awarded for these lands. Practically the entire ahupua‘a was awarded to prince William Lunalilo (Land Claim Award 8559-B, Parcel 16). A detailed description of subsequent land conveyances for Kea‘au can be found in Hurst’s background for the Kea‘au Bypass corridor (Hurst 1994). Essentially, most of the land were leased out for use as ranch land. By 1884 ownership had passed to William H. Shipman and ranching continued as the primary land use until at least 1895. By the 1890s the government was investigating ways to improve access and resources in Puna. In A.D 1892 Loebenstein was directed to survey a new inland road (roughly in the location of the current Highway 130) through the district. In a newspaper interview, he describes the area as follows: The arable belt of Puna is from three to six miles from the sea coast, and is consequently unexplored. It is a wonderful country and I could talk of it by the hour. It only lies in the hands of the Government to develop it. Everything depends on an appropriation being made for the road, of which the preliminary survey has been made. . . . The road begins at the edge of the Ramie camp, one mile from the edge of the woods–nine miles from Hilo. It follows the old road for a mile and a half more, and is to extend to Kaimu on a new survey . . . I met with ancient trails showing traces of a dense population and cultivation in early times. The road, if opened, will afford beautiful scenery to tourists, as there are natural wonders all along, lava trees, pit craters and lava tunnels extending for miles which formed ancient burial places. There are natural benches formed by the lava, where the dead were placed, and on these are the bones, skulls and sometime complete skeletons. These tunnels are from 25 to 30 feet wide and about the same in height, and of course pitch dark . . . From the ninth to the nineteenth mile [the current study area is at about the ninth mile] the road is over pahoehoe, the arable land lying about a mile and a half above . . . There is considerable sandal wood growing on the pahoehoe, but the ranchers are too indolent to drive cattle, so they make fires and burn off the brush, which kills the sandal wood. It is a shame. There are no wild cattle in Puna . . . (Hawaiian Gazette, March 22, 1892) In 1899 large tracts of land in Kea‘au were turned to new uses. Most of the richest land was leased by the Ola‘a Sugar Company. This land, including most of the current project area, remained in sugar cultivation until September of 1984. 6 RC-0260 Previous Archaeology A number of archaeological studies have been performed in Kea‘au, five of which were conducted in inland areas comparable to the current study area (Table 1). The earliest of these (Rosendahl 1982) was for the 490 acre Shipman Industrial Park located immediately adjacent to the current study area. As a result of that study, Rosendahl reported that, “No archaeological sites or features of any kind were found wither within or immediately adjacent to the limits of the proposed industrial park.” (1982:3). In 1993, Hunt (1993) conducted a 600 acre survey of lands west of Kea‘au Town, which included a portion of the present project area (Figure 2). Hunt recorded a variety of features associated with sugarcane cultivation on property outside of the current study area. These included mounds, enclosures, alignments, walls, facings, and a terrace mound. No traditional Hawaiian sites were identified. Hurst performed subsequent archaeological survey for the Kea‘au Bypass corridor (Hurst 1993). This survey produced only historic remains associated with former 81/2 Mile Camp. The corridor had apparently been heavily impacted by agricultural uses such as sugarcane, macadamia orchards, as well as recent residential development. More recently, Walker et al. conducted archaeological and historical research at the 75-acre Kea‘au High School Site. About 50% of this area was surveyed. Survey was primarily conducted via automobile; however, an old railroad right of way was surveyed on foot. This right of way was identified as part of the former Hilo Railroad Company. Other than this historic find, no archaeological sites were recorded in the project area. In 1999, a 30-acre parcel adjacent to the current project area was investigated (Rechtman 1999). This area was largely disturbed by sugarcane cultivation. A small, undisturbed area was intensively surveyed but also produced no cultural remains. Recent archaeological investigation in and around the current project area demonstrates the highly impacted nature of the land surrounding Kea‘au Town. It appears that almost every available acre was under direct cultivation or was utilized for supporting infrastructure (worker’s housing, mills, etc.). Table 1. Prior relevant archaeological and historical studies. Author/Date Type of Study Ahupua‘a Hunt/1993 Archaeological Survey Kea‘au Hurst/1994 Archaeological Survey Kea‘au Walker et al./1997 Archaeological Survey and Historical Research Kea‘au Rechtman/1999 Reconnaissance Survey Kea‘au Rosendahl/1992 Reconnaissance Survey Kea‘au Aerial Photographs As part of the background research for this project, a series of aerial photographs of the project area were obtained (Figures 7, 8, and 9). The photos show the transition of the project area from fully cultivated land, to fallow land, to resumed limited cultivation as late as 1999. Figure 7 shows an outline of the project area superimposed on an aerial photograph taken in December 1975. The figure clearly shows the system of cane fields in operation at the time including the east-west trending field roads. The northern portion of the project area was still forested at the time and does not appear to have been impacted. By May of 1994 (Figure 8), the photo indicates: that the area was no longer under cultivation, that the W. H. Shipman Business Park was under construction, and that parcel TMK:3-1-6-146:17 was cleared. The area of darker vegetation at the northern end of parcel TMK:3-1-6-003:07 remained undeveloped between the old cane fields and the new industrial park. Four years later (Figure 9), large portions of the project area are again under cultivation, this time papaya was the chosen crop. In 2004, at the time of the current survey, the land was again fallow. This series of photographs is very informational. Clearly a vast majority of the project area has been subject to repeated severe impact in the recent past through sugarcane and papaya cultivation and industrial development. The exception to this is a single narrow strip of land on the northern edge of the fields, bordering the W. H. Shipman Business Park (see Figure 7). This area does not appear to have sustained recent disturbance and likely has a higher chance of containing early historic or traditional Hawaiian cultural material. 7 RC-0260 Figure 7. Aerial photograph taken in 1975 showing project area outlined in white with undeveloped area (dashed line). 8 RC-0260 Figure 8. Aerial photograph taken in 1994 showing project area outlined in black. 9 RC-0260 Figure 9. Aerial photograph taken in 1999 showing project area outlined in white. 10 RC-0260 CURRENT PROJECT EXPECTATIONS Based solely on elevation, the current project area falls within the Upland Agricultural Zone (Zone II) as defined by McEldowney (1979:49). This zone corresponds with the distribution of ash soils (Figure 10), which, although having an elevated theoretical probability of sites, were also commonly planted in sugarcane historically. The aerial photographs presented in the previous section clearly indicate that this was the case in the current project area. It is therefore expected that the majority of the project area will contain only features associated with late historic sugarcane cultivation. These features may include field roads, irrigation ditches, and stone piles. Given that the area was under almost complete cultivation as late as 1975 and under partial cultivation by 1994, most of the extant features are expected to be modern. One small portion of the project area may not have been impacted by recent agricultural and industrial activities. This is the small strip of land between W. H. Shipman Business Park and the former cane fields shown in the aerial photographs (see Figure 7). This piece of land may possess qualities making it unsuitable for large-scale agricultural development. It is therefore expected that remnant historic or traditional Hawaiian cultural remains are most likely to be found in this region of the project area. According to the model developed by McEldowney, within this Upland Agricultural Zone, the possibilities of remnant agricultural complexes could be high on both ash and older aa or pahoehoe substrates that have not been disrupted by historic agricultural practices. (McEldowney 1979:19) If present, remains may include agricultural features such as mounds, terracing, or walls as well as utilized lava tubes, trails, and trail markers. The 2.8 acre parcel in W. H. Shipman Business Park (TMK:3-1-6-146:17) was developed for industrial use by 1994 and was likely bulldozed, filled, and graded. No historic or traditional Hawaiian remains are expected on this parcel. Figure 10. Map depicting locations of ash deposits corresponding to the Upland Agricultural Zone (adapted from McEldowney 1979:63). 11 RC-0260 FIELDWORK METHODS AND RESULTS Archaeological survey of the project area was conducted on July 14, 15, and 16, 2004 by Christopher Hand, B.A., Thomas B. Jones, B.A., Michael Vitousek, and Michael Desilets, M.A., under the supervision of Robert B. Rechtman, Ph.D. The property was surveyed using pedestrian transects with 15 meter spacing. Parallel transects were walked on a north/south bearing across the length of the project area (TMK:3-1-6-003:por. 07). Vegetation in this area was very dense and ground visibility was poor. Evidence of cultivation was observed during much of the survey and consisted of ‘dozer-push’ piles and abandoned field roads. These were interpreted as remnants of late twentieth century sugarcane cultivation. No other cultural remains were observed. Following completion of the north/south transects, an additional series of east/west (mauka/makai) transects were walked within the narrow drainage between W. H. Shipman Business Park and the former sugarcane fields (Figure 7). Based on the background information presented above, as well as field observation during initial transecting, this area was considered to have a relatively high probability for containing cultural remains. Intensive survey within this area confirmed that it had not been impacted by industrial and agricultural activities to the north and south. The additional survey effort, however, did not result in the identification of any early historic or traditional Hawaiian remains. On the small parcel within Shipman Industrial Park (TMK:3-1-6-146:17), a systematic investigation was also conducted consisting of pedestrian transects with 15 meter spacing. There was almost no vegetation in this area and ground visibility was excellent. The parcel is currently used as a staging area for drilling equipment, and had been filled, leveled, and graded. No early historic or traditional Hawaiian remains were observed on this parcel. CONCLUSIONS AND RECOMMENDATIONS Archaeological survey of the 112 acre project area produced no evidence of early historic or traditional Hawaiian remains. The survey confirmed that most of the area consisted of fallow sugarcane fields. The small seemingly uncultivated portion of the project area was intensively surveyed and contained no cultural remains. As there were no significant cultural sites or deposits encountered within the study parcels, it is recommended that no further archaeological work need be conducted prior to development. However, in the unlikely event that historic properties are inadvertently discovered during construction activities, such activities should be immediately suspended in the vicinity of the discovery, and DLNR-SHPD notified as outlined in the Hawai‘i Administrative Rules 13§13-284. REFERENCES CITED Barrère, D. 1959 Political History of Puna. IN: Natural and Cultural History Report on the Kalapana Extension of the Hawai‘i Volcanoes National Park: Vol. I, pp. 15-65. Compiled by Emory, K.P., W.J. Bonk, Y.H. Sinoto, D.B. Barrere, Department of Anthropology, B.P. Bishop Museum, Honolulu. Hunt, T.L. 1993 Archaeological Assessment of Shipman Lands in Kea‘au, Puna, Island of Hawai‘i. Prepared for W.H. Shipman Corporation. Hurst, G., and A. Schilz 1994 Archaeological Survey of the Kea‘au-Pahoa Road, Keaau Town Section, Project No. 130B-01-92, Puna Hawai‘i (TMK:1-6-03). Ogden Environmental and Energy Services Co., Inc. Prepared for GK & Associates. Maly, K. 1999 The Historic Puna Trail-old Government Road (Kea‘au Section): Archaival-Historical Documentary Research, Oral History and Consultation Study, and Limited Site Preservation Plan. Kumu Pono Associates report, prepared for Na Ala Hele Program, DOFAW, Hilo. 12 RC-0260 McEldowney, H. 1979 Archaeological and Historical Literature Search and Research Design: Lava Flow Control Study, Hilo, Hawaii. Department of Anthropology, B.P. Bishop Museum, Honolulu. Prepared for U.S. Army Engineer Division, Pacific Ocean. Rechtman, R 1999 Archaeological Field Inspection, 30 Acre Development Parcel (TMK: 3-1-6-03:por. 12). PHRI Letter Report 1942-032499. Prepared for W. H. Shipman, Ltd. Rosendahl, M. 1982 Archaeological Reconnaissance Survey Proposed W. H. Shipman Industrial Park TMK: 3-1-6-03: por. 12. PHRI Report Ms. 75-112282. Prepared for Okahara, Shigeoka & Associates. Spencer, C., N. Ishihara, and H. Hammatt 2017 [Draft] Cultural Impact Assessment for the Kea‘au Zero Waste Facility, Kea‘au Ahupua‘a, Puna District, Hawai‘i Island, TMKs: [3] 1-6-151:002 and portions of 003, 006, and 999. Cultural Surveys Hawai‘i, Inc. Job Code KEAAU 12. Prepared for The Limtiaco Consulting Group. Walker, A.T., K. Maly, and P.H. Rosendahl 1997 Historical and Archaeological Research Proposed Kea‘au High School Site, Puna District, Island of Hawai‘i (TMK:1-6-03:Por.3,15,84). PHRI Report 1694-071697. Prepared for Group 70 International, Inc. 13 LINDA LINGLE GOVERNOR OF HAWAII PETER T. YOUNG CHAIRPERSONBOARD OF LAND AND NATIJRAL RESOURCES COMMISSION ON WATER RESOURCE MANAGEMENT DAN DAVIDSON DEPUTY DIRECTOR ·LAND YVONNE Y. IZU DEPUTY DIRECTOR ·WATER AQUATIC RESOURCES BOATING AND OCEAN RECREATION BUREAU OF CONVEYANCES COMMISSION ON WATER RESOURCE MANAGEMENT CONSERVATION AND COASTAL LANDS DEPARTMENT OF LAND AND NATURAL RESOURCES CONSERVATION AND RESOURCES ENFORCEMENT STATE OF HAWAII ENGINEERING FORESTRY AND WILDLIFEHISTORIC PRESERVATION DIVISION HISTORIC PRESERVATION KAKUHIHEWA BUILDING, ROOM 555 KAHOOLAWE ISLAND RESERVE COMMISSION LAND 601 KAMOKILA BOULEVARD STATE PARKS February 16, 2005 KAPOLEI, HAWAII 96707 Robert Rechtman, Ph.D. Rechtman Consulting Inc. LOG NO: 2005.0061 HC 1 Box 4149 DOC NO: 0501MM19 Kea'au, Hawaii 96749 Dear Dr. Rechtman: SUBJECT: Chapter 6E-42 Historic Preservation Review, "Archaeological Assessment Of a 112-Acre Property" (Desilits and Rechtman, September 2004) Ahupua'a of Kea'au, Puna District, Hawaii Island TMK: (3) 1-6-003: 007 (por) and 1-6-146:017 Thank you for your cover letter dated September 16, 2004 and a copy of the subject Archaeological Assessment Report for our review comments. The report, which was prepared for Dean Hirabayashi of A&B Properties, Inc., was received by our division on September 20, 2004. The historical background information for the Puna district and Keaau ahupua 'a, in which the 112-acre project area is located, is adequate to predict the types of historic properties that might be present and to evaluate their significance. Most of the project area is described as having been leased by the Ola' a Sugar Company after 1899, after a period in which cattle ranching dominated. Sugarcane cultivation continued until the end of the twentieth century. ·Your review of five previous archaeological studies in the area indicates that only the remains of sugarcane cultivation activities and a railroad bed have been documented. Aerial photography in 1975, 1994, and 1999 further documents extensive disturbance due to intensive agriculture and industrial development. Although pre-Contact agricultural complexes are possible on undisturbed surfaces at this elevation in ash soils, no historic or traditional Hawaiian remains were expected. We believe with the survey methodology described, the field survey was more than adequate to locate any surviving surface features. No historic properties were identified in the survey. We agree with your recommendation that no further archaeological work is necessary and consider the report adequate to fulfill the requirements of HAR 13 §13-276. If you have any questions about this review, please contact MaryAnne Maigret in our Hawaii Island office at (808) 327-3690. --~iPlanie A. Chinen, Administrator State Historic Preservation Division MM:jen c: Dean Hirabayashi, A&B Properties, Inc., 822 Bishop Street, Honolulu Hawaii, 96813 Christopher Yuen, Hawaii County Planning Department FEB 2 3 ' APPENDIX G STATUS REPORT ON COMPLIANCE WITH THE CONDITIONS OF STATE LAND USE BOUNDARY AMENDMENT 884 2025 STATUS OF THE PROJECT PROGRESS IN COMPLYING WITH LUC CONDITIONS OF THE DECISION AND ORDER 1. "The developer and/or landowner of the Property shall fund and construct adequate civil defense measures as determined by the County and State Civil Defense agencies." W.H. Shipman, Limited (WHS) Response: In a letter dated September 24, 2004, the County Civil Defense Agency confirmed to WHS that approved shelter facilities have been established at Kea`au Elementary School and Kea`au High School. To the extent that additional civil defense measures may be required in the future, WHS will continue to work with Civil Defense agencies. 2. "The developer and/or landowner of the Property shall contribute to the development, funding and/or construction of school facilities, on a pro-rata basis, as determined by and to the satisfaction of the Department of Education (DOE). Agreement by DOE on the level of funding and participation shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezoning is not required." WHS Response: This condition has been satisfied. On September 27, 2004, the Department of Education confirmed to the LUC that this condition had been satisfied by the donation of 15.399 acres for the construction of the Kea`au Elementary School, which has been completed. 3. "The developer and/or landowner of the Property shall participate in the funding and construction of adequate wastewater transmission and disposal facilities, on a pro-rata basis, as determined by the State Department of Health and the County Department of Public Works." WHS Response: The developer and/or landowner of the Property will abide by this condition. 4. "The developer and/or landowner of the Property shall provide affordable housing opportunities for low, low-moderate, and gap group income residents of the State of Hawaii to the satisfaction of the State Housing and Finance Development Corporation (HFDC) in accordance with the Affordable Housing Guidelines, adopted by the Housing and Finance Development Corporation, effective July 1, 1992, as periodically amended. The location and distribution of the affordable housing or other provisions for affordable housing shall be under such terms as may be mutually agreeable between the developer and/or landowner of the subject Property and the State Housing and Finance Development Corporation and the County of Hawaii. Agreement by the HFDC on the provision of affordable housing shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezoning is not required." STATE OF HAWAII LAND USE COMMISSION 07/01/2025 2:35 pm WHS Response: The developer and/or landowner of the Property will abide by this condition. 5. "The developer and/or landowner of the Property shall have an archaeological inventory survey conducted by a professional archaeologist prior to submitting an application to the County of Hawaii for rezoning or prior to applying for a building permit if county rezoning is not required. The findings shall be submitted to the State Historic Preservation Division, Department of Land and Natural Resources ("HPD-DLNR") in report format for adequacy review. The HPD-DLNR must verify that the survey report is acceptable, must approve significance evaluations, and must approve mitigation commitments for significant historic sites prior to the landowner and/or developer submitting an application to the county for rezoning or prior to applying for a building permit if county rezoning is not required." WHS Response: Paul H. Rosendahl, Inc. prepared an historical and archeological report for the 32 acres in Parcel D. No significant findings were discovered as the land had been in sugar cane for decades and is currently in papaya on an interim basis. The State Department of Land and Natural Resources- Historic Preservation District concurred with the report’s finding in a letter dated June 16, 1999. Paul H. Rosendahl, Inc., conducted historical and archaeological research and a field inspection for the Keaau High School site, with a report submitted to the Historic Preservation Division, DLNR. Copies of DLNR’s approval letter, dated August 12, 1997, were sent to DAGS and the Planning Department, County of Hawaii. Most recently, in April 2017, Scientific Consultant Services, Inc. prepared and submitted for State Historic Preservation Review a draft archaeological inventory survey (2017 AIS) for much of the petition areas east of the Belt Highway and which similarly concluded that no sites of significance requiring preservation remain due to the history of extensive sugar cane farming. Older structures in the vicinity have been documented for their past historic architectural styles. On February 12, 2018, SHPD approved the AIS and asked to be consulted prior to the issuance of permit applications for projects which may impact the historic integrity of architectural properties within the project area. WHS will comply with this request as project development occurs. 6. "If significant historic sites are present, then the developer and/or landowner of the Property shall agree to develop and execute a detailed historic preservation mitigation plan prior to any ground altering construction in the area. The HPD-DLNR must approve this plan, and must verify in writing to the Land Use Commission that the plan has been successfully executed." WHS Response: The developer and/or landowner of the Property will abide by this condition. To date, no significant historic sites have been determined to exist which have required preservation plans or mitigation plans. As to structures which may have historic architectural styles, WHS will consult with SHPD on whether or not mitigation as to the historic integrity of those styles will be required. -2- 7. "Should any human burials or any historic sites such as artifacts, charcoal deposits, or stone platforms, pavings or walls be found, the developer and/or landowner of the Property shall stop work in the immediate vicinity and contact the HPD-DLNR. The significance of these finds shall then be determined and approved by the HPD- DLNR, and an acceptable mitigation plan shall be approved by the HPD-DLNR (if needed). The HPD-DLNR must verify that the fieldwork portion of the mitigation plans has been successfully executed prior to work proceeding in the immediate vicinity of the find. Burials must be treated under the specific provisions of Chapter 6E, HRS." WHS Response: The developer and/or landowner of the Property will abide by this condition. 8. "The developer and/or landowner of the Property shall conduct a flora and fauna survey and prepare and agree to execute a mitigation plan which meets the requirements of the Department of Land and Natural Resources. The Department of Land and Natural Resources must approve the plan and a copy of the approved plan must be submitted to the Land Use Commission prior to the developer and/or landowner applying for county zoning or prior to the developer and/or landowner applying for county building permits if county rezoning is not required." WHS Response: DLNR Division of Forestry (DOFAW) has previously commented that the entire 660 acres comprising the subject LUC reclassification thereby including the zoning application land concludes that “…vegetation at the project site (660 acres including the Gateway project area) does not require protection other than standard procedures consistent with good soil and water conservation practices. Accordingly, no mitigation measures are needed for these resources.” With regard to fauna, DOFAW stated that “…the Hawaiian hawk is the only endangered species likely to be encountered at the project site (660 acres). In the event nesting hawks are encountered during clearing or construction phases of the project DOFAW proposes standard mitigation procedures are.” In a more recent draft flora and fauna survey conducted for much of the petition areas south of the Belt Highway conducted in 2106, Ron Terry of Geometrician Associates, LLC reported that no threatened or endangered plant species as listed by the U. S. Fish and Wildlife Service (USFWS) appear to be present on the Project Area, nor are there uniquely valuable habitats. No existing or proposed federally designated critical habitat is present on or near the Project Area. As to fauna, only common non-native species of birds were observed during the site survey. However, it was noted that the migratory resident Golden Plover (Pluvialis fulva) may be expected to be at least occasionally present, as it frequently rests and forages on pastures and open fields throughout the State of Hawai‘i during its migratory residence from August to April. Geometrician Associates, LLC, also reported that the area is can be expected to be utilized by the endemic Hawaiian -3- Hawk (Buteo solitarius). The endangered Hawaiian Hawk is widespread, hunting throughout forested, agricultural and even residential areas of the island of Hawai‘i. It nests in large trees and can be vulnerable during the summer nesting season. Aside from the hawk, it is considered unlikely that native forest birds would make much use of the Project Area because of its relatively low elevation and lack of native plants. It is possible that small numbers of the endangered endemic Hawaiian Petrel (Pterodroma sandwichensis) and the threatened Newell’s Shearwater (Puffinus auricularis newelli) over-fly the Project Area between the months of May and November. The Hawaiian Petrel was formerly common on the Island of Hawai‘i. This pelagic seabird reportedly nested in large numbers on the slopes of Mauna Loa and in the saddle area between Mauna Loa and Mauna Kea, as well as at the mid-to-high elevations of Hualālai. Hawaiian Petrels were first listed as an endangered species by the USFWS in 1967 and by the State of Hawai‘i in 1973. Newell’s Shearwaters were also once common on the Island of Hawai‘i. Geometrician Associates also considered it likely that Hawaiian Hoary Bats (Lasiurus cinereus semotus), the only native Hawaiian land mammals, are sometimes present on the Project Area. They have been found throughout Puna and in most areas on the island of Hawai‘i. Bats may forage for flying insects on the Project Area on a seasonal basis and may also roost in trees and large shrubs. Geometrician Associates, LLC offered the following recommendations in order to avoid impacts to endangered but widespread native birds and the Hawaiian hoary bat that maybe found on site: • To minimize impacts to the endangered Hawaiian hoary bat, trees taller than 15 feet should not be removed or trimmed during the bat birthing and pup rearing season (June 1 through September 15), to the extent practical. • To minimize impacts to Hawaiian Hawks, avoid earthmoving within 100 meters of tall trees or tree cutting during the breeding season for Hawaiian Hawks (March through the end of September). If this time period cannot be avoided, arrange for a hawk nest search to be conducted by a University of Hawai‘i at Hilo biologist or other qualified biologist. If hawk nests are present in or near the Project Area, all land clearing activity should cease until the expiration of the breeding season. • If development activities incorporate outdoor lighting, they may attract endangered Hawaiian Petrels and Newell’s Shearwaters, which may become disoriented by the lighting. To avoid the potential downing of Hawaiian Petrels and Newell’s Shearwaters by their interaction with outdoor lighting, there should be no construction or unshielded equipment maintenance lighting after dark between the months of April and October. All permanent lighting should be shielded in strict conformance with the Hawai‘i County Outdoor Lighting Ordinance (Hawai‘i County Code Chapter 9, Article 14), which requires shielding of exterior lights so as to lower the ambient glare caused by unshielded lighting. -4- The landowner or developer will submit the recommended mitigation measures to the Department of Land and Natural Resources (DLNR) for review of recommended mitigation measures and submit the approved plan to the LUC prior to applying for County zoning amendments or building permits, if such zoning is not required. 9. "The developer and/or landowner of the Property shall prepare a Traffic Impact Analysis Report prior to applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezoning is not required. The landowner and/or developer shall also participate in the funding and construction of local and regional transportation improvements and programs including dedication of rights-of-way as determined by the State Department of Transportation and the County Department of Public Works. Agreement by the State Department of Transportation on the level of funding and participation shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezoning is not required." WHS Response: This condition has been partially satisfied. By letter dated November 26, 1997, the State Department of Transportation considered the donation by WHS property needed for the Kea`au Bypass Road as fulfilling the requirement for participation on regional transportation improvements. The now completed Bypass Road has substantially improved regional traffic conditions. The developer and/or landowner of future rezoning of the Property will abide by this condition. The Traffic Impact Analysis Report was updated on June 15, 2022 for Area “A” and “B”. 10. "The developer and/or landowner of the Property shall monitor the traffic attributable to the proposed project at on-site and off-site locations and shall undertake subsequent mitigative measures that may be reasonably required. These activities shall be coordinated with and approved by the State Department of Transportation." WHS Response: The developer and/or landowner of the Property will abide by this condition. 11. "The developer and/or landowner of the Property shall fund the design and construction of drainage improvements required as a result of the development of the property to the satisfaction of the appropriate State and County agencies." WHS Response: The developer and/or landowner of the Property will abide by this condition. 12. "The developer and/or landowner shall coordinate with the County of Hawaii and the State Department of Health regarding the establishment of appropriate systems to contain spills and prevent materials associated with industrial and commercial uses such as -5- petroleum products, chemical or other pollutants, from adversely affecting the groundwater resources of the area." WHS Response: The developer and/or landowner of the Property will abide by this condition. 13. "The developer and/or landowner of the Property shall participate in an air quality monitoring program as specified by the State Department of Health." WHS Response: The developer and/or landowner of the Property will abide by this condition. 14. "The developer and/or landowner of the Property shall cooperate with the State Department of Health and the County of Hawaii Department of Public Works to conform to the program goals and objectives of the Integrated Solid Waste Management Act, Chapter 342G, Hawaii Revised Statutes, and the County's approved integrated solid waste management plans in accordance with a schedule and time frame satisfactory to the State Department of Health." WHS Response: The developer and/or landowner of the Property will abide by this condition. 15. "The developer and/or landowner of the Property shall be responsible for implementing sound attenuation measures to bring noise levels from vehicular traffic in the Property down to levels acceptable to the State Department of Health and the State Department of Transportation." WHS Response: The developer and/or landowner of the Property will abide by this condition. 16. "The developer and/or landowner of the Property shall notify all prospective buyers of Property of the potential odor, noise, and dust pollution resulting from surrounding Agricultural District land." WHS Response: The developer and/or landowner of the Property will abide by this condition. 17. "The developer and/or landowner of the Property shall notify all prospective buyers of property that the Hawaii Right-to-Farm Act, Chapter 165, Hawaii Revised Statues, limits the circumstances under which preexisting farming activities may be deemed a nuisance." WHS Response: The developer and/or landowner of the Property will abide by this condition. 18. "The Petitioner has represented that no golf courses will be developed within the Property by the developer and/or landowner. Any plans by the developer and/or landowner to include a golf course within the Property shall be subject to review and approval by the -6- Land Use Commission. The developer and/or landowner shall: (a) file an appropriate motion or petition, whichever is appropriate; (b) provide the necessary evidence to justify its proposed use; and (c) seek prior approval from the Commission for golf course use on the Property." WHS Response: The developer and/or landowner of the Property will abide by this condition. 19. "The developer and/or landowner of the Property shall develop the Property in substantial compliance with the representations made to the Land Use Commission. Failure to so develop the Property may result in reclassification of the Property to its former land use classification, or change to a more appropriate classification." WHS Response: The developer and/or landowner of the Property will abide by this condition. The landowner and/or the developer of the Property will include plans which are in compliance with the representations made to the Land Use Commission. 20. "The developer and/or landowner of the Property shall promptly provide without any prior notice, annual reports to the Land Use Commission, the Office of State Planning, and the County of Hawaii Planning Department in connection with the status of the subject project and the developer's and/or landowner's progress in complying with the conditions imposed." WHS Response: The developer and/or landowner of the Property will abide by this condition. 21. "The developer and/or landowner of the Property shall give notice to the Commission of any intent to sell, lease, assign, place in trust, or otherwise voluntarily alter the ownership interests in the Property, prior to the completion of the development of the Property." WHS Response: The developer and/or landowner of the Property will continue to abide by this condition. 22. "The Land Use Commission may fully or partially release these conditions as to all or any portion of the Property upon timely motion and upon the provision of adequate assurance of satisfaction of these conditions by the developer and/or landowner of the Property." 23. "Within 7 days of the issuance of the Land Use Commission's Decision and Order for the subject reclassification, the Petitioner shall: (a) record with the Bureau of Conveyances a Statement to the effect that the Property is subject to conditions imposed by the Land Use Commission in the reclassification of the Property, and -7- (b) file a copy of such recorded statement with the Commission." WHS Response: The statement of Imposition of Conditions imposed by the Land Use Commission for the real property at Keaau, Hawaii, was filed with the Bureau of Conveyances Land Court System on July 22, 1994. 24. "The Petitioner shall record the conditions imposed by the Land Use Commission with the Bureau of Conveyances pursuant to section 15-15-92, HAR." WHS Response: The Declaration of Conditions imposed by the Land Use Commission for the real property at Keaau, Hawaii, was recorded with the Bureau of Conveyances on August 11, 1994 as Document No. 94-133996, and filed on the same date with the Land Court as Document no. 2171696. -8- JOSH GREEN, M.D. GOVERNOR SYLVIA LUKE LT. GOVERNOR DANIEL ORODENKER LUC EXECUTIVE OFFICER LAND USE COMMISSION Komikina Hoʻohana ʻĀina DEPARTMENT OF BUSINESS, ECONOMIC DEVELOPMENT & TOURISM Ka ʻOihana Hoʻomōhala Pāʻoihana, ʻImi Wai wai a Hoʻomākaʻikaʻi 235 S. Beretania Street, RM 406, Honolulu, Hawaiʻi 96813 Telephone: (808) 587-3822 Mailing Address: P.O. Box 2359, Honolulu, Hawaiʻi 96804 Fax: (808) 587-3827 Email Address: dbedt.luc.web@hawaii.gov Website: luc.hawaii.gov November 21, 2025 Peggy Farias, President W.H. Shipman, Limited 16-127 Lapaʻau Road Keaʻau, Hawaiʻi 96749 Kimo Lee W.H. Shipman, Limited 16-127 Lapaʻau Road Keaʻau, Hawaiʻi 96749 SUBJECT: Boundary Interpretation No. 25-03 Tax Map Key: (3) 1-6-003:127, Keaʻau, Hawaiʻi Dear Ms. Farias and Mr. Lee: In response to your boundary determination request dated June 4, 2025, we confirm that the proposed Keaʻau Benihoff Health Center site is located within the State land Use Urban District. Based on the materials you provided, including Land Court Application 1053, Map 81, the restriction of vehicle access rights has been subdivided and dedicated to the Volcano Roadway easement, additionally, Land Court Application Map 588, identifies the adjusted Petition Area as Lot 9168-A-2, encompassing approximately 108.761 acres. The access rights portions are as follows: - Lot 9168-B (Map 581): ~6,661 sq. ft. (0.153 acre) - Lot 9168-C (Map 581): ~2,827 sq. ft. (0.065 acre) - Lot 9168-D (Map 581): ~896 sq. ft. (0.021 acre) Combined with Lot 9168-A-2, the total area is approximately 109.00 acres, as approved in SLU Docket No. BR93-699, Petitioners Exhibit No. 4A-4. As the proposed project is within the Petition Area of Docket No. BR93-699, the developer and/or landowner of the property must comply with the Conditions set forth by the Land Use Commission in the 1994, 2000, and 2005 Decision and Orders. Please EXHIBIT B Boundary Interpretation No. 25-03 November 21, 2025 Page 2 provide an updated Annual Report with discussion of the how the proposed Keaʻau Benihoff Health Center is in compliance with the Conditions. Should you have any questions, please contact our office, at (808) 587-3822 or via email at dbedt.luc.web@hawaii.gov. Sincerely, Daniel Orodenker Executive Officer Land Use Commission State of Hawaiʻi BEFORE THE LAND USE COMMISSION OF THE STATE OF HAWAII In the Matter of the Petition of OFFICE OF STATE PLANNING, STATE OF HAWAII To Amend the Agricultural Land Use District Boundary into the Urban Land Use District for Approximately 660 Acres at Keaau,Puna,Island of Hawaii,State of Hawaii,identified by Tax Map Key Numbers 1-6-03: por.3,par.7,par.8,par.11, par.12,par.13,par.14,par.15, par.68,76 and 84 DOCKET NO.BR93-699 FINDINGS OF FACT, CONCLUSIONS OF LAW, AND DECISION AND ORDER ) ) ) ) ) ) ) ~py Gf the Dectelee tmd Order en tie ki the o1~.: $~L~d~rPrn~ct~t4OB~JhJH~W~: JUL 1 8 1994 ____ ___ c FINDINGS OF FACT, CONCLUSIONS OF LAW AND DECISION AND ORDER EXHIBIT C In the Matter of the Petition of OFFICE OF STATE PLANNING, STATE OF HAWAII Ta Amend the Agricultural Land Use District Boundary into the Urban Land Use District for Approximately 660 Acres at Keaau,Puna,Island of Hawaii,State of Hawaii,identified by Tax Map Key Numbers 1-6-03: par.3,par.7,par.8,por.11, par.12,par.13,par.14,par.15, par.68,76 and 84 DOCKET NO.BR93-699 FINDINGS OF FACT, CONCLUSIONS OF LAW, AND DECISION AND ORDER FINDINGS OF FACT, CONCLUSIONS OF LAW AND DECISION AND ORDER The Office of State Planning,State of Hawaii (“Petitioner”),filed a Petition for Land Use District Boundary Amendment on November 18,1993,and First Amended Petition far Land Use District Boundary Amendment on February 24,1994, pursuant to chapter 205,Hawaii Revised Statutes,(“HRS”)and chapter 15-15,Hawaii Administrative Rules (“HAR”)to amend the State land use district boundary for approximately 660 acres of land,identified as Tax Map Key Nos.:l-6—03:por.3,par.7, par.8,por.11,par.12,par.13,par.14,por.15,par.68, 76 and 84,situated at Keaau,District of Puna,Island of Hawaii,State of Hawaii (“Property”),from the State Land Use Agricultural District to the State Land Use Urban District. The Land Use Commission (“Cammission”),having heard and examined the testimony,evidence and argument of counsel BEFORE THE LAND USE OF THE STATE OF COMMISSION HAWAII ) ) ) ) ) )) presented during the hearings,and Petitioner’s Proposed Findings of Fact,Conclusions of Law and Decision and Order, hereby makes the following findings of fact,conclusions of law and decision and order: FINDINGS OF FACT PROCEDURAL MATTERS 1.On November 18,1993,Petitioner filed a Petition for Land Use District Boundary Amendment and on February 24, 1994,Petitioner filed a First Amended Petition for Land Use District Boundary Amendment (Collectively “Petition”). 2.On March 18,1994,a prehearing conference an the Petition was held at Honolulu,Oahu,with representatives of the Petitioner and landowner,W.H.Shipman,Limited,present. At the prehearing conference,available exhibits,exhibit lists,and witness lists were submitted. 3.On April 21,1994,the Commission held a hearing on the Petition in Hilo,Hawaii pursuant to a notice published in the Hawaii Tribune-Herald,and the Honolulu Advertiser,on February 22,1994. 4.The Commission did not receive any petition for intervention into this proceeding. 5.On April 21,1994,at the meeting held by the Commission in Hilo,Hawaii,the County of Hawaii (“County”) Planning Department represented that it will not participate in the hearing proceedings for the Petition.The County also represented that it has filed stipulations with the Petitioner —2 — with respect to Petitioner’s Findings of Fact,Conclusions of Law,and Decision and Order with the exception that it did not place any conditions on the boundary amendment. 6.On April 21,1994,the Commission allowed letters from Yoshihiko Nakahara,Robert Bethea,Keith Ahue,Lunakanawai Hauania,Lt.Cal.Jerry Matsuda,P.E.,Carl Okuyama,Milton Pavao,and Richard Ha,Jr.to be admitted into evidence.The Commission also allowed Jim Albertini,Sandy Bank,Milton Pavao,Yoshi Nakahara,Paula Helfrich,Carl Okuyama,Richard Ha,and Howard Wright to testify as public witnesses. 7.The Commission received additional letters from the following individuals:Keith Ahue,Bonnie Goodell,Adrian Barber,Ole Fulks,Barbara Bell,Sandy Bonk,Patricia and Francis Jaworski,and James Albertini.Said letters were admitted into evidence on July 14,1994. DESCRIPTION OF THE PROPERTY 8.The Property consists of approximately 660 acres of land located in the District of Puna,in the Ahupua’a of Keaau,approximately four miles south of the City of Hila.The Property is comprised of four Sub—areas surrounding the existing town of Keaau at the intersection of State Highway 11 (Volcano Highway)and State Highway 130 (Keaau-Pahoa Road). 9.Sub-areas A and B are bounded by the existing Urban area of Keaau Village to the north and the Keaau Agricultural Lots to the south.Sub—areas A and B are separated by Keaau-Pahaa Road (State Highway 130).The —3 — proposed Keaau ByPass Highway is anticipated to extend along the eastern or makai edge of sub-area B.These sub—areas consist of approximately 138 and 118 acres,respectively. Sub—area c is west,or mauka,of Volcano Highway (State Highway 11)and surrounds the 9 1/2 Mile Camp and is bounded by the County’s Herbert Shipman Park to the north.This sub-area C includes approximately 295 acres.Sub—area D is also west,or mauka,of the Volcano Highway and is adjacent to the W.H.Shipman Industrial Park,which was the subject of an incremental districting approval from the State Land Use Agricultural District to the State Land Use Urban District in 1988.The second increment was reclassified in 1993 under LUC Docket No.A84-570/W.H.Shipman,Limited.Sub-area D encompasses approximately 109 acres. 10.The entire Property is owned by W.H.Shipman, Limited (“Shipman”),of Keaau,Hawaii. 11.Shipman has authorized Petitioner to file the Petition. 12.The Property slopes gently upward towards the summit of Mauna Loa with elevations ranging from approximately 275 to 650 feet above sea level.The site’s topography is characterized as being moderately sloping with slopes over the entire Property averaging approximately 3.5 percent,with ranges from less than 1.7 to 13.0 percent.The highest slopes occur in the southern portion,where slopes average 5 percent. —4 — 13.The average annual rainfall in the Keaau area is between 9 and 17 inches per month,or 150 to 200 inches per year.Normally,more rain falls in the area between the months of November through April. 14.The Keaau area experiences primarily on-shore trade winds during the day from the northeast with primary low velocity night time gravity winds in the off-shore direction. Typical wind velocities range up to 12 knots,with gentler drainage winds at night.Relative humidity is also generally stable year round,with the daily average ranging from 65 to 85 percent. 15.The United States Department of Sail Conservation Service Soil Survey Report for the Island of Hawaii classifies the soil within the Property as follows: a.Olaa (0-20%)Series (OlD and OaC).The Olaa soils are well-drained silty clay loams typically nine inches thick.OlD soil is extremely stony and is classified by the United States Soil Conservation Service in capability subclass VII (severe limitations,considered unsuitable for cultivation).OaC sail has a nan—stony surface layer and falls in capability subclass III (requires special conservation practices). b.Panaewa (0-10%)Series (PeC).The Panaewa soil is similar in properties but is dotted with rock outcrops.Its capability subclass is VI.When enriched with —5 — high fertilizer inputs and treated with special conservation practices,both groups of soil may produce fair sugarcane yields. c.Keaukaha (6-20%slopes)and Papai (3-25% slopes)Series (rKFD and rPAE).These are young soils developed on lava alone (pahoehoe and a’a respectively).These soils are difficult to cultivate and bear a capability subclass VII rating.Soil permeability is rapid,runoff is medium and erosion hazard slight for both soils.Despite a measure of diversity among these soils,all share certain properties. They are generally mucky,moderately to highly stony,somewhat acidic,highly permeable,moderately corrosive,and highly subject to shrink—swell problems. 16.The University of Hawaii Land Study Bureau’s Detailed Land Classification—Island of Hawaii classifies the Property with productivity ratings between “C”and “E”,or average/fair to very poorly suited for agricultural productivity. 17.The Property contains lands which are identified as Prime or Other Important Agricultural Land under the State Agricultural Lands of Importance to the State of Hawaii (ALISH) system.Although some valuable agricultural land will be converted to urban uses under the proposed use,most of the Prime agricultural land in the Keaau area is outside of the Property. —6 — 18.The Property consists mostly of land formerly cultivated in sugarcane and is presently vacant of any uses except for 7.3 acres planted in papaya,approximately 2 acres of macadamia nuts and several residences.There are nine dwellings situated within the Property,one of which is owned by Shipman.The remaining eight dwellings are situated an lands leased from Shipman.Five of the dwellings are located on the mauka side of the Volcano Highway near the Herbert Shipman Park.These dwellings are over 50 years old and are in dilapidated condition.The existing owners of the units will be required either to relocate or to demolish these dwellings. The four dwellings on the makai side of the Volcano Highway are on relatively short leases ranging between three and ten years.There are no plans to terminate or relocate these uses at the present time. 19.The Property,as is all of the Hilo to Puna region,is susceptible to potential lava inundation from Mauna Loa,one of the five volcanoes comprising the island of Hawaii and one of the three volcanoes which have been active in historic times. 20.The Property is within lava flow hazard zone 3,a zone considered “less hazardous than zone 2”and of “medium” threat risk (the United States Geological Survey (“USGS”)has identified 9 volcanic flow hazard zones on the island of Hawaii,with “1”being the highest hazard and “9”being the lowest).Zone 3 includes most of the Hila to Pahoa area. —7 — 21.The entire island of Hawaii is susceptible to earthquakes originating in fault zones under and adjacent to it.The Big Island is classified as a Zone 3 Seismic Probability Rating f or the purposes of structural design.The classification system is based on a scale of zones with increasing risk from 0 to 4,due to seismic occurrence and danger. 22.The Federal Emergency Management Agency (“FEMA”) classifies the region in which the Property is located as flood hazard zone “X”,an area of moderate to minimal flood hazard that is outside the 100-year to 500-year flood plain. PROPOSAL FOR DEVELOPMENT 23.The Petition is based on a recommendation made by the Petitioner as part of the Hawaii State Land Use District Boundary Review-Hawaii (OSP 1992)(“Boundary Review Report”), which recommends that the Property be reclassified from the Agricultural to Urban District. 24.The purpose of the Five-Year Boundary Review is to conduct a comprehensive,statewide evaluation of State land use districts.Based on this evaluation,there was a recommendation to allocate sufficient land for future urban growth and also to direct urban growth to appropriate areas. The intent is to provide for lang-range planning by designating areas for future urban growth rather than reacting to landowner-initiated petitions. —8 — 25.To provide a basis for determining the possible land uses,land allocations,and impacts of urbanization of the Property,Shipman consultants prepared the Conceptual Keaau Development Plan f or approximately 2,000 acres in and around the Keaau Village area,which included the Property.While broad land use concepts were identified,no specific uses or densities for particular areas within the Property have been determined.The conceptual plan will be further refined during the development and consultation process with governmental agencies and the public.Uses identified as potential uses within the Property include residential,parks and open space, industrial,commercial,schools and other government facilities. 26.Shipman has represented that site constraints such as archaeological remains,transmission line easements, circulation requirements,topographic relief,and other site factors will be taken into account to determine actual land use allocations and achievable densities.Additionally,external constraints such as adequacy of public facilities and services, market support and financial feasibility factors will all heavily influence the actual land plan. 27.Shipman has represented that it intends to implement the overall Conceptual Keaau Development Plan over a period of 20 years or more,with implementation of the initial phase,which covers the Property,within five years from the receipt of zoning from the County for the various areas.More —9 — detailed planning and design will be required to establish the timing of major project phases which in turn will be coordinated with major stages of off-site infrastructure development and market support. PETITIONER’S FINANCIAL CAPABILITY TO UNDERTAKE THE PROPOSED DEVELOPMENT 28.Petitioner is a State agency and is not required to submit a statement of current financial condition pursuant to section 15-15—50(c)(8),HAR. STATE AND COUNTY PLANS AND PROGRAMS 29.The approximately 660 acres which comprise the Property lies within the State Land Use Agricultural District as shown on the Land Use Commission Boundary Maps H-66 (Hilo) and H-67 (Mountain View). 30.Petitioner published the Boundary Review Report in May,1992.The urbanization of the Keaau area is consistent with,and is supported by the Boundary Review Report.The Boundary Review Report recommends that the Property be reclassified from the State Land Use Agricultural to State Land Use Urban District. 31.The Hawaii County General Plan (Ordinance No. 89-142,as amended)(“General Plan”)designates the Property for “Low Density”,“Medium Density”,and “Urban Expansion” uses.Urbanization of the Property as proposed in the Conceptual Keaau Development Plan is consistent with the applicable designations of the General Plan. —10— 32.The Property is zoned “Agriculture”,with a minimum lot size of 20 acres (A-2Oa)under existing County zoning.Petitioner will seek appropriate zoning changes from the County. 33.Although the Property is within the Coastal Zone Management Area,it does not lie within the Special Management Area,as defined by the County. NEED FOR THE DEVELOPMENT 34.The petition is based on a recommendation made by Petitioner as part of the Boundary Review Report,which recommends reclassification of the area from the Agricultural District to the Urban District.The basis for the reclassification is stated directly in the report as follows: With an 83 percent increase in population from 1980 to 1990,the Puna district is the second fastest growing region an the island of Hawaii. This rapid growth is expected to continue and even to accelerate.Due to the youthfulness of the population,the fertility rate is the highest in the State,averaging four children per family.Responding to the needs of this rapidly growing population is all the more difficult with the population so widely dispersed throughout the district and in areas where most of the lots are zoned for agriculture and serviced by inadequate infrastructure.The town of Keaau is located —11— along a major highway with adequate infrastructure,close to Hilo,and relatively central in its location to other widely dispersed villages.Reclassification of agricultural lands adjacent to the town of Keaau would make it easier f or State and County to meet the social and physical infrastructure needs of a rapidly growing population. The specific land uses,acreages and their locations within the Property have yet to be determined. In addition: a.The proposed reclassification area is adjacent to existing Urban District Lands at Keaau Town and the W.H.Shipman Industrial Park. b.It is served by existing infrastructure including two major highways,water lines and utilities, although infrastructure improvements will be needed to accommodate the proposed urbanization.It is in proximity to existing services including an elementary and intermediate school,fire station,and police substation. c.Reclassification is in conformance with the County of Hawaii General Plan,which designates the area for low and medium density and urban expansion uses. d.Puna is second only to West Hawaii in population growth,with 128 percent growth from 1970—1980,and 76 percent growth from 1980—1990. —12— e.There is a need to establish an urban core in Puna to service the growing population.Keaau is a desirable location for an urban care because it is at lower risk of lava inundation than mast of Puna and is relatively central in location with respect to the widely dispersed villages of Puna.Keaau also contains an employment center with the W.H. Shipman Industrial Park and the Keaau Town Center. IMPACT UPON RESOURCES OF THE AREA Agricultural Resources 35.The sails of the Property are derived from geologically recent pahoehoe and a’a lava flows,covered in places with layers of Pahala Ash.The United States Soil Conservation Service classifies the soils within the Property in the Olaa,Panaewa,Keaukaha and Papai Series groupings.The University of Hawaii Land Study Bureau classifies the Property with productivity ratings between “C”and “E.”In addition, portions of the Property are identified as “Prime”or “Other Important Agricultural Land”under the State ALISH system. 36.A small portion of the Property is currently leased for farming papaya (7.3 acres)on a crop—by—crop basis and macadamia nuts (approximately 2 acres).Over the remainder of the Property,there are no agricultural activities being conducted.As such,the urbanization of the Property will have no significant negative impact on the overall agricultural productivity of the Island of Hawaii and the State of Hawaii. —13— Drainage and Flooding 37.The existing drainage area affecting the Property extends to the east and west of the Property,and there are no indications of potential flooding within the Property. Existing developed areas in the vicinity have no continuous underground drainage system. 38.Additional runoff as a result of development of the Property can be minimized by installing a system of swales and underground drainage structures which would channel the runoff into a system of dry wells. Flora 39.A botanical survey of the Property was conducted in July 1992 by Grant Gerrish,Ph.D. 40.The native vegetation on the Property site has been removed by many years of sugarcane cultivation.No rare or endangered native plant species were found on the Property. The botanical survey recorded 8 endemic and 6 indigenous native plant species,mostly located in small,remnant waste areas not previously cultivated.The abandoned cane field areas are producing a secondary growth of primarily alien species. Fauna 41.An avifauna and feral mammal survey of the Property was also conducted in July of 1992 by Grant Gerrish, Ph.D. 42.The study found no special or unique mammals or birds,including threatened or endangered species,on the —14— Property during the survey.Although the i’o or Hawaiian hawk and the hoary bat,both of which are endangered species,were not seen during the survey,they have been widely distributed on the island.Consequently,it is anticipated that the urbanization of the Property will not have any adverse impacts to avifauna or feral mammals. Historic and Archaeological Resources 43.An archaeological assessment reconnaissance study and a literature search were conducted f or the entire Property and surrounding Shipman lands in July and November 1992 by Terry L.Hunt,Ph.D. 44.The basic purpose of the assessment study was to generally survey the Property and enable predictions to be made concerning the probable nature and distribution of archaeological resources within the Property.The study was completed as a synthesis of literature review,aerial reconnaissance and a partial intensive ground surface survey of portions of the Property. 45.Five areas or “islands”of vegetation were identified by the survey,only one of which (Area 2)is located within the Property.Areas 1,2,and 3 were subjected to a complete ground surface survey,while the heavily vegetated Areas 4 and 5 were studied through the use of 100 meter transects.Within Area 2 in the Property’s Sub—area C,nine sites were mapped,measured and described.These nine sites are considered significant for their informational content and —15— may be associated with historic plantation activities.Further research is needed to definitely determine treatment of these sites within the Property.As development plans are finalized in areas where archaeological resources are identified, inventory level surveys must be conducted to provide further documentation.Due to the past sugarcane cultivation over most of the Property,large portions are free of archaeological resources. Visual and Scenic Resources 46.The existing terrain of the Property provides gently sloping views to and from the Property to many acres of Mauna Loa,Mauna Kea and the sea. 47.Future urbanization of the Property will not alter the scenic views from the Property,although development of the Property from its predominantly natural state to one of urban uses will irretrievably alter the natural open space in the region.Existing public views of the Property are infrequent and transitory,and those views will also be altered by development of the Property. Air Quality 48.Within the region of the Property,existing air quality is good.Present air quality in the Property is mostly affected by natural particulate sources such as ocean spray, pollen—producing plants and dust from natural,industrial, agricultural and/or vehicular sources.Of these natural sources of pollution,the emissions from Kilauea Volcano are —16— the mast significant when those emissions are blown northwest due to the occasional southerly winds.Emission from this eruption can be seen in the form of volcanic haze (vog)which impacts the area on occasion. 49.Short-term direct and indirect impacts on air quality could potentially occur due to construction in two ways:(1)fugitive dust from vehicle movement and site excavation;and (2)exhaust emissions from an—site construction equipment.Indirectly,there could also be short-term impacts from slow—moving construction equipment traveling to and from the project site and from a temporary increase in local traffic caused by commuting construction workers. 50.After construction is completed,use of the Property will result in increased motor vehicle traffic on nearby roadways,potentially causing long—term impacts on ambient air quality in the project vicinity.Motor vehicles with gasoline—powered engines are significant sources of carbon monoxide. Noise 51.The Property is currently exposed to relatively low ambient noise levels,primarily at narrow corridors adjacent to the highways,the power plant,and neighboring farms.Short term noise impacts will be generated by construction activities during development of the Property. 52.It is probable that noise generated by vehicular traffic along State Highway 11 (Volcano Highway)and State —17— Highway 130 (Keaau-Pahoa Road)will increase,both from construction vehicles and subsequently from vehicle trips by residents,employees and visitors to the urbanized Property. The degree to which traffic noise increases as a result of the vehicular trips associated with the urbanization of the Property cannot be projected at this time because specific uses for the Property have not yet been determined. Socioeconomic Factors 53.Although specific land uses for the Property have not been determined,it is probable that single-family residential,multi-family residential,commercial/industrial, parks/open space and public facility uses will comprise a significant percentage of its acreage.The percentage of grass land set aside for residential uses includes approximately 451 acres,which would support approximately 1,500 residential units.In this respect,the proposed reclassification could positively affect the provision of needed housing for residents of Keaau and East Hawaii. 54.Based on the above number of dwelling units,it is anticipated that the Property could add to the existing resident population approximately 4,365 new residents,assuming a population-to-household ratio of 2.91 (the current figure for occupied houses in Puna,according to calculations based on 1990 Census Data by Community Management Associates)at full buildout. —18— 55.In addition to the proposed reclassification of the Property,the Puna District has shown a phenomenal rate of increase in population of over 128 percent between 1970 and 1980.The increase,has to a large degree,been in subdivisions created without typical urban standard water, electric and roadway systems. 56.The urbanization of the Property will provide jobs and housing for the residents of Puna and East Hawaii and for others who desire to migrate to the island or region. Within the context of population projections contained in the County of Hawaii General Plan,the provision of housing and jobs will serve to support projected population increases, including in-migration. 57.The urbanization and development of the Property will generate short—term employment during the construction period.In addition,long-term employment opportunities will be created by industrial and commercial development.Not only will such action improve the economic diversification of the Puna and East Hawaii economy,it will also generate increased property,sales and income taxes. 58.The supply of residential lots with infrastructure amenities in the Puna area has failed to keep up with demand,thus resulting in an increase in lot prices.The development of residential units within the Property will be of direct benefit to the inventory of available units in this —19— category because of the proximity to the urban level of services and facilities. Traffic 59.A preliminary traffic assessment for the Property was prepared by Randall S.Okaneku,P.E.to identify issues and opportunities relative to the probable traffic impacts the reclassification of the Property will have on the region’s traffic. 60.In recognition of the existing traffic impacts within the region,the State Department of Transportation (“DOT”)is currently in the process of planning the Keaau Bypass Road to divert traffic between Pahoa and Hilo from passing through Keaau Town.The DOT presently projects completion of this bypass road in early 1997. 61.The roadway plan proposed as part of the Conceptual Keaau Development Plan envisions a Shipman Loop Road which would pass through the Property and connect to Volcano Highway/State Highway 11.This Shipman Loop Road would begin between the Pahoa Road/Keaau Bypass Road junction and Keaau Town,continue in the westward direction,and connect to Volcano Highway south/mauka of Keaau Town. 62.The development of the Property will impact an the roadways of the region.The Keaau Bypass Road and the proposed Shipman Loop Road are expected to relieve some of the existing traffic problems at Keaau Town by diverting a portion of the existing through traffic away from the center of the —20— town.Once the final alignment of the Keaau Bypass Road is chosen and the specific uses of the Property are determined, the actual traffic impacts can be determined through a traffic impact analysis. Water Supply 63.A preliminary overview of the water resources in the Puna region determined that there is an abundant source of potable groundwater available to serve the Property.The County of Hawaii Department of Water Supply maintains two water systems in the vicinity of the Property:the Hilo City water system and the Olaa water system.The Property rests atop a significant groundwater source designated the Keaau Aquifer System (Code 80402). 64.Potable water in the Keaau area of Puna is provided by the County of Hawaii Department of Water Supply from its Ola’a Water System. 65.The Property is located within the Keaau Aquifer System identified by the Water Resources Research Center of the University of Hawaii.This aquifer is thought to be capable of producing approximately 393 million gallons per day (“mgd”)of sustainable yield.The Keaau Aquifer is currently being tapped for approximately 2.34 mgd to 2.50 mgd. Wastewater Disposal 66.There is presently no municipal wastewater treatment plant in the Keaau area that can accommodate —21— wastewater that will be generated by the development of the Property. 67.The recently constructed municipal wastewater treatment plant in Hilo at Keaukaha near the airport has the capacity to handle wastewater from the development of the Property.The other option is for the developer/landowner to construct wastewater facilities in Keaau to service the development of the Property. 68.The amount of wastewater generation from the Property would roughly range from 1.5 to 1.6 mgd,including the existing Keaau Village connections. 69.Assuming that adequate wastewater treatment facilities can be constructed to service the Property,the disposal of the treated effluent may be used for landscape irrigation and agricultural uses located to the northeast/makai of the Property.Other disposal methods,such as underground injection,may be needed for the balance of the wastewater not used for irrigation. Water Quality 70.Although groundwater is probably available within the Property,the potable water well(s)developed to service uses within the Property will be located at higher elevations outside and south/mauka of the Property.The Keaau Aquifer System has more than adequate sources of potable water to service development of the Property. —22— 71.Although the urbanization of the Property may increase the opportunity far pollutants to enter groundwater via storm runoff or as leachate from materials applied to landscaped areas (fertilizers,pesticides,etc.),this would probably be much less than during the past sugarcane operations.According to Petitioner’s Environmental Report, groundwater contamination from surface activities is expected to be negligible in relation to the volume and flow rate of the aquifer.Groundwater resources are expected to remain of high quality and within permissible levels for all contaminants of concern. Electrical Power and Communication 72.Electrical service to the Property,as well as the entire island,is currently provided by Hawaii Electric Light Company (HELCO).HELCO’s Kanoelehua and Puna generating stations are located within service range of the Property.It is expected that a new electrical substation will be required to extend electrical service throughout the Property.Given these improvements,urbanization of the Property is not expected to significantly impact on the provision of electrical service by HELCO. 73.GTE Hawaiian Tel serves the Property from its Keaau station. 74.Based on general assumptions made about the acreage and potential uses involved in the proposed boundary —23— amendment,GTE Hawaiian Tel may need to expand the Keaau station to accommodate development of the Property. 75.Jones Spacelink of Hawaii,Ltd.is licensed to provide cable television service in the Keaau region.There are presently no cable lines servicing the Property. Therefore,it will be necessary to extend cable television service to the Property upon development. Police,Fire and Emergency Services 76.Police,fire and emergency medical services are available at Keaau on a limited basis.The increase in population attributable to the development of the Property will increase the demand on existing police,fire and emergency facilities within the region. Schools and Libraries 77.Current facilities planning projections for the Department of Education (DOE)include projected population increases within the Property.Although the DOE is currently reviewing site selection for an elementary school and conducting preliminary planning for a high school in Keaau, there is a projected additional enrollment associated with the urbanization of the Property that may require new and/or expanded facilities.Land areas for civic and public facility uses such as schools and libraries were allocated within the Property in the Conceptual Keaau Master Plan.Shipman has represented that it will reserve a minimum of 12 acres to accommodate an elementary school and up to 50 acres for a high —24— school in the event the DOE determines that Keaau is an appropriate location for these facilities. Recreation Facilities 78.The County of Hawaii Department of Parks and Recreation has determined that urbanization of the Property must be accompanied by additional park facilities,which would be implemented by either the development of separate park sites,or expansion of the existing Herbert Shipman Park in Keaau to a regional park. 79.The urbanization of the Property will increase the resident population and its recreational needs,which can be met by providing a pro rata share of parks and other recreational facilities within the development of the Property. Solid Waste Disposal 80.The County of Hawaii presently maintains a solid waste transfer station 1.75 miles southeast of the Property off State Highway 130.The Hilo Landfill,which presently serves the East Hawaii District,is reaching its maximum capacity and is expected to close by 1998.The Hilo Landfill will be replaced by the newly opened landfill at Puu Anahulu,south of Waikoloa.Refuse from the Property would be accepted by the municipal landfill at Puu Anahulu. Civil Defense Services 81.The property is not affected by flood hazard and is within USGS Lava Flaw Hazard Zone 3,a zone of medium threat.Should a natural disaster affect the Property after it —25— has been urbanized,the added population and urban improvements would add to the responsibilities of the various civil defense agencies. Health Care Facilities 82.The increase in resident population that is probable as a result of the urbanization of the Property will place additional demands on health care services in the region. COMPLIANCE WITH STANDARDS FOR DETERMINING DISTRICT BOUNDARIES 83.The Petitioner has conducted a “Five Year Boundary Review”pursuant to section 205-18,HRS,to comprehensively examine the State Land Use District classifications for all lands in the State. 84.Petitioner has recommended as part of its Five-Year Boundary Review Report that the Property be reclassified from the State Land Use Agricultural to the State Land Use Urban District.This recommendation is made within the context of existing State and County land use policies for the Property and the region as a whole.The Hawaii County General Plan specifically designates the Keaau area for Urban Expansion,for residential,commercial,industrial and other uses.This area has been identified for the urban growth necessary to accommodate the future population of Puna and East Hawaii. 85.The proposed reclassification of the Property meets the standards for the Urban District.The Property is adjacent to existing Urban District lands which include —26— employment generators in the W.H.Shipman Industrial Park and the Keaau Town Center.Furthermore,development in the Property will generate a new center of trading and employment, providing opportunities for residents throughout the Puna district. 86.All lands in the Property are reasonably free from environmental hazards and adverse topographic constraints such as flooding ,tsunami,unstable soil,and other adverse environmental effects.Although some risk of lava inundation is present,this situation is shared with nearly all existing urban land on the island. 87.Although the Property does not presently include land characterized by “city—like”concentration of people, structures,streets,urban level of services and other uses, the lands are adjacent to State Land Use Urban District lands having these “city—like”characteristics.Keaau is located at the junction of the two major highways in Puna,and is thus centrally located.The proposed reclassification will favorably impact the provision for employment opportunities, economic development and housing opportunities for all income groups.The Property also has existing infrastructure or the ability to easily extend and develop infrastructure required for quality growth,unlike any other region in Puna.Partly in recognition of the ideal situation of the Property amid the fast-growing district,the General Plan of the County of Hawaii has identified the area around Keaau as “Urban Expansion.” —27— 88.Urbanization of the Property does not contribute to scattered spot urban development,as it is adjacent to an existing urban area,proximal to existing urban facilities and is identified for urban uses by adopted State and County land use plans. CONFORMANCE WITH THE HAWAII STATE PLAN 89.The proposed reclassification of the Property is consistent with the following objectives and policies of the Hawaii State Plan: Section 226-5,HRS:Objectives and policies for population. Section 226-5(b)(l):Manage population growth statewide in a manner that provides increased opportunities for Hawaii’s people to pursue their physical,social,and economic aspirations while recognizing the unique needs of each county. Section 226-5(b)(2):Encourage an increase in economic activities and employment opportunities on the neighbor islands consistent with community needs and desires. Section 226-5(b)(3):Promote increased opportunities for Hawaii’s people to pursue their socio—economic aspirations throughout the islands. Section 226-5(b)(7):Plan the development and availability of land and water resources in a coordinated manner so as to provide for the desired levels of growth in each geographic area. Section 226-6,HRS:Objectives and policies for the economy —in general. Section 226-6(a)(1):Increased and diversified employment opportunities to achieve full employment, increased income and job choice,and improved living standards. —28— Section 226-6(a)(2):A steadily growing and diversified economic base that is not overly dependent on a few industries. Section 226-7,HRS:Objectives and policies for the economy -agriculture. Section 226-7(b)(lO):Assure the availability of agriculturally suitable lands with adequate water to accommodate present and future needs. Section 226-10,HRS:Objectives and policies for the economy -potential growth activities. Section 226-lO(b)(6):Provide public incentives and encourage private initiative to attract new industries that best support Hawaii’s social,economic,physical, and environmental objectives. Section 226-11,HRS:Objectives and policies for the physical environment -land—based,shoreline,and marine resources. Section 226-ll(a)(2):Effective protection of Hawaii’s unique and fragile environmental resources. Section 226-ll(b)(3):Take into account the physical attributes of areas when planning and designing activities and facilities. Section 226-12,HRS:Objectives and policies for the physical environment —scenic,natural beauty,and historic resources. Section 226—l2(b)(l):Promote the preservation and restoration of significant natural and historic resources. Section 226-13,HRS:Objectives and policies for the physical environment -land,air,and water quality. Section 226-l3(b)(2):Promote the proper management of Hawaii’s land and water resources. Section 226-l3(b)(3):Promote effective measures to achieve desired quality in Hawaii’s surface,ground, and coastal waters. Section 226-15,HRS:Objectives and policies for facility systems —solid and liquid wastes. —29— Section 226-15(b)(1):Encourage the adequate development sewerage facilities that complement planned growth. Section 226-16,HRS:Objectives and policies for facility systems -water. Section 226-l6(b)(l):Coordinate development of land use activities with existing and potential water supply. Section 226-17,HRS:Objectives and policies for facility systems -transportation. Section 226-17(b)(6):Encourage transportation systems that serve to accommodate present and future development needs of communities. Section 226-19,HRS:Objectives and policies for socio—cultural advancement —housing. Section 226—l9(b)(l):Effectively accommodate the housing needs of Hawaii’s people. Section 226-19(b)(3):Increase homeownership and rental opportunities and choices in terms of quality, location,cost,densities,styles,and size of housing. Section 226-21,HRS:Objectives and policies for socio—cultural advancement —education. Section 226—21(b)(2):Ensure the provision of adequate and accessible educational services and facilities that are designed to meet individual and community needs. Section 226-23,HRS:Objectives and policies for socio-cultural advancement -leisure. Section 226-23(b)(6):Assure the availability of sufficient resources to provide for future cultural, artistic,and recreational needs. 90.The proposed reclassification of the Property is generally consistent with objectives and policies of the following State Functional Plans:Housing,Education, Agriculture,Recreation,and Transportation. —30— CONFORMANCE WITH COASTAL ZONE MANAGEMENT OBJECTIVES AND POLICIES 91.Although the Property is within the Coastal Zone Management area,it is not located within the Special Management Area;therefore,no Special Management Area permit is required.The Petition is in general compliance with chapter 205A,HRS. RULING ON PROPOSED FINDINGS OF FACT Any of the proposed findings of fact submitted by the Petitioner or the other parties not already ruled upon by the Commission by adoption herein,or rejected by clearly contrary findings of fact herein,are hereby denied and rejected. Any conclusion of law herein improperly designated as a finding of fact shall be deemed or construed as a conclusion of law;and finding of fact herein improperly designated as a conclusion of law shall be deemed or construed as a finding of fact. CONCLUSIONS OF LAW Pursuant to chapter 205,HRS,and the Hawaii Land Use Commission Rules under chapter 15—15,HAR,and upon consideration of the Land Use Commission decision-making criteria under section 205-17,HRS,this Commission finds upon a clear preponderance of the evidence that the reclassification of the Property,identified as Hawaii Tax Map Key Nos.:1-6-03: par.3,par.7,por.8,par.11,par.12,par.13,par.14, por.15,par.68,76 and 84,consisting of approximately 660 —31— acres of land situated at Keaau,District of Puna,Island of Hawaii,State of Hawaii,from the State Land Use Agricultural District to the State Land Use Urban District,subject to the conditions provided in this Order,is reasonable,nonviolative of section 205-2,HRS,and is consistent with the Hawaii State Plan as set forth in chapter 226,HRS,and chapter 205-A,HRS. ORDER IT IS HEREBY ORDERED that the Property,being the subject of this Docket No.BR93-699 consisting of approximately 660 acres of land situated at Keaau,District of Puna,Island and County of Hawaii,State of Hawaii,and identified as Tax Map Key Nos:1-6-03:par.3,par.7,par.8,par.11,par.12, par.13,par.14,par.15,par.68,76 and 84,and approximately shown on Exhibit “A”attached hereto and incorporated by reference herein,shall be and is hereby reclassified from the State Land Use Agricultural District to the State Land Use Urban District and the State Land Use District Boundaries are amended accordingly,subject to the following conditions: 1.The developer and/or landowner of the Property shall fund and construct adequate civil defense measures as determined by the County and State Civil Defense agencies. 2.The developer and/or landowner of the Property shall contribute to the development,funding and/or construction of school facilities,on a pro rata basis,as determined by and to the satisfaction of the Department of —32— Education (DOE).Agreement by DOE on the level of funding and participation shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the developer and/or landowner applying far County building permits if County rezoning is not required. 3.The developer and/or landowner of the Property shall participate in the funding and construction of adequate wastewater transmission and disposal facilities,on a pro rata basis,as determined by the State Department of Health and the County Department of Public Works. 4.The developer and/or landowner of the Property shall provide affordable housing opportunities for low, low—moderate,and gap group income residents of the State of Hawaii to the satisfaction of the State Housing and Finance Development Corporation (HFDC)in accordance with the Affordable Housing Guidelines,adapted by the Housing Finance and Development Corporation,effective July 1,1992,as periodically amended.The location and distribution of the affordable housing or other provisions far affordable housing shall be under such terms as may be mutually agreeable between the developer and/or landowner of the subject Property and the State Housing Finance and Development Corporation and the County of Hawaii.Agreement by the HFDC an the provision of affordable housing shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the —33— developer and/or landowner applying for County building permits if County rezaning is not required. 5.The developer and/ar landowner of the Property shall have an archaeological inventory survey conducted by a professional archaeologist prior to submitting an application to the County of Hawaii for rezoning or prior to applying for a building permit if county rezoning is not required.The findings of this survey shall be submitted to the State Historic Preservation Division,Department of Land and Natural Resources (“HPD-DLNR”)in report format for adequacy review. The HPD-DLNR must verify that the survey report is acceptable, must approve significance evaluations,and must approve mitigation commitments for significant historic sites prior to the landowner and/or developer submitting an application to the county for rezoning or prior to applying for a building permit if county rezoning is not required. 6.If significant historic sites are present,then the developer and/or landowner of the Property shall agree to develop and execute a detailed historic preservation mitigation plan prior to any ground altering construction in the area. The HPD-DLNR must approve this plan,and must verify in writing to the Land Use Commission that the plan has been successfully executed. 7.Should any human burials or any historic sites such as artifacts,charcoal deposits,or stone platforms, pavings or walls be found,the developer and/or landowner of —34— the Property shall stop work in the immediate vicinity and contact the HPD-DLNR.The significance of these finds shall then be determined and approved by the HPD-DLNR,and an acceptable mitigation plan shall be approved by the HPD-DLNR (if needed).The HPD-DLNR must verify that the fieldwork portion of the mitigation plans has been successfully executed prior to work proceeding in the immediate vicinity of the find.Burials must be treated under the specific provisions of Chapter 6E,HRS. 8.The developer and/or landowner of the Property shall conduct a flora and fauna survey and prepare and agree to execute a mitigation plan which meets the requirements of the Department of Land and Natural Resources.The Department of Land and Natural Resources must approve the plan and a copy of the approved plan must be submitted to the Land Use Commission prior to the developer and/or landowner applying for county zoning or prior to the developer and/or landowner applying for county building permits if county rezaning is not required. 9.The developer and/ar landowner of the Property shall prepare a Traffic Impact Analysis Report prior to applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezoning is not required.The landowner and/ar developer shall also participate in the funding and construction of local and regional transportation improvements and programs including —35— dedication of rights-of-way as determined by the State Department of Transportation and the County Department of Public Works.Agreement by the State Department of Transportation an the level of funding and participation shall be obtained prior to the developer and/or landowner applying for County zoning or prior to the developer and/or landowner applying for County building permits if County rezaning is not required. 10.The developer and/or landowner of the Property shall monitor the traffic attributable to the proposed project at on—site and off—site locations and shall undertake subsequent mitigative measures that may be reasonably required.These activities shall be coordinated with and approved by the State Department of Transportation. 11.The developer and/ar landowner of the Property shall fund the design and construction of drainage improvements required as a result of the development of the property to the satisfaction of the appropriate State and County agencies. 12.The developer and/ar landowner shall coordinate with the County of Hawaii and the State Department of Health regarding the establishment of appropriate systems to contain spills and prevent materials associated with industrial and commercial uses such as petroleum products,chemical or other pollutants,from adversely affecting the groundwater resources of the area. —36— 13.The developer and/or landowner of the Property shall participate in an air quality monitoring program as specified by the State Department of Health. 14.The developer and/or landowner of the Property shall cooperate with the State Department of Health and the County of Hawaii Department of Public Works to conform to the program goals and objectives of the Integrated Solid Waste Management Act,Chapter 342G,Hawaii Revised Statutes,and the County’s approved integrated solid waste management plans in accordance with a schedule and timeframe satisfactory to the Department of Health. 15.The developer and/ar landowner of the Property shall be responsible for implementing sound attenuation measures to bring noise levels from vehicular traffic in the Property dawn to levels acceptable to the State Department of Health and the State Department of Transportation. 16.The developer and/or landowner of the Property shall notify all prospective buyers of property of the potential odor,noise,and dust pollution resulting from surrounding Agricultural District land. 17.The developer and/or landowner of the Property shall notify all prospective buyers of property that the Hawaii Right-to-Farm Act,Chapter 165,Hawaii Revised Statutes,limits the circumstances under which preexisting farming activities may be deemed a nuisance. —37— 18.The Petitioner has represented that no golf courses will be developed within the Property by the developer and/or landowner.Any plans by the developer and/or landowner to include a golf course within the Property shall be subject to review and approval by the Land Use Commission.The developer and/ar landowner shall:(a)file an appropriate motion or petition,whichever is appropriate;(b)provide the necessary evidence to justify its proposed use;and (c)seek prior approval from the Commission for golf course use on the Property. 19.The developer and/ar landowner of the Property shall develop the Property in substantial compliance with the representations made to the Land Use Commission.Failure to so develop the Property may result in reclassification of the Property to its former land use classification,or change to a more appropriate classification. 20.The developer and/or landowner shall promptly provide without any prior notice,annual reports to the Land Use Commission,the Office of State Planning,and the County of Hawaii Planning Department in connection with the status of the subject project and the developer’s and or landowner’s progress in complying with the conditions imposed. 21.The developer and/ar landowner of the Property shall give notice to the Commission of any intent to sell, lease,assign,place in trust,or otherwise voluntarily alter —38— the ownership interests in the Property,prior to the completion of the development of the Property. 22.The Land Use Commission may fully or partially release these conditions as to all or any portion of the Property upon timely motion and upon the provision of adequate assurance of satisfaction of these conditions by the developer and/or landowner of the Property. 23.Within 7 days of the issuance of the Land Use Commission’s Decision and Order for the subject reclassification,the Petitioner shall (a)record with the Bureau of Conveyances a Statement to the effect that the Property is subject to conditions imposed by the Land Use Commission in the reclassification of the Property,and (b)shall file a copy of such recorded statement with the Commission. 24.The Petitioner shall record the conditions imposed by the Land Use Commission with the Bureau of Conveyances pursuant to section 15—15—92,HAR. —39— DOCKET NO.BR93-699 -OFFICE OF STATE PLANNING LAND USE COMMISSION STATE OF HAWAII By (~oQ r-~--~ JO N.MATTSON Chairperson and Commissioner By TRUDY .SENDA Vice Chairperson and Commissioner By ALI~N K.HOE Coéun is s loner By Comm sian r By o4~~: Commission Filed and effective on July 18 ,1994 By (absent) RENTON L.K.NIP Commissioner Certified by: By (absent) ELTON WADA Commissioner Done at Honolulu,Hawaii,this 18th day of July 1994, per motion on July 14,1994. By By (absent) M.CASEY JARMAN Commissioner Commissioner —~J~ LLOYD F ~KAWAKAMI Executive Officer —40— ~,‘>, .•;~.., ~i.•* ~~:~-~ ~44 ~ :~— -~~;•.~ -: LOCATION MAP BR93-699 IOFFICE OF STATE PLANNING, STATE OF HAWAII TAX MAP KEY:1 —6 —03:por.3.por.7,por.8.por.11.por.12, por.13.por.14,por.15,por.68.76,&84 KEAAU,PUNA,HAWAII SCALE.~V =2,000 ft.j •:~:IPETITION AREAI.‘• EXHIBIT .A~ BEFORE THE LAND USE COMMISSION OF THE STATE OF HAWAII In the Matter of the Petition of )DOCKET NO.BR93-699 OFFICE OF STATE PLANNING,)CERTIFICATE OF SERVICE STATE OF HAWAII ) To Amend the Agricultural Land Use District Boundary into the Urban ) Land Use District for Approximately ) 660 Acres at Keaau,Puna,Island of ) Hawaii,State of Hawaii,identified by Tax Map Key Numbers 1-6-03:) par.3,par.7,par.8,par.11,) par.12,par.13,par.14,par.15, par.68,76 and 84 CERTIFICATE OF SERVICE I hereby certify that a copy of the Findings of Fact, Conclusions of Law and Decision and Order was served upon the following by either hand delivery or depositing the same in the U.S.Postal Service by certified mail: HAROLD S.MASUNOTO,Director Office of State Planning P.0.Box 3540 Honolulu,Hawaii 96811—3540 Attention:Mary Lou Kobayashi RICK J.EICHOR,ESQ. JAMES F.NAGLE,ESQ.,Attorneys for Petitioner CERT.Department of the Attorney General 425 Queen Street Honolulu,Hawaii 96813 VIRGINIA GOLDSTEIN,Planning Director CERT.Planning Department,County of Hawaii 25 Aupuni Street Hilo,Hawaii 96720 DATED:Honolulu,Hawaii,this 18th day of July 1994. ESTHER UEDA Executive Officer C.Kimo Alameda, Ph.D.Reed K. Mahuna Police Chief Mayor William V. Brilhante Jr. Sherry D. Bird Deputy Police Chief Managing Director July 13, 2026 County of Hawai' i POLICE DEPARTMENT 349 Kapi'olani Street • Hilo, Hawai'i 96720-3998 (808)935-331 I • Fax (808) 961-2389 COH PLANNING DEPT JUL 14 2026 PM12:0l REC'D HAND DELIVERED TO : JEFFREY W. �/7 1..,,.,�-DIRECTOR FROM : ANT POLICE CHIEF . REA I OPERATIONS BUREAU SUBJECT: SPECIAL PERMIT APPLICATION (PL-SPP-2026-000136) APPLICANT: HILO BENIOFF MEDICAL CENTER REQUEST: TO CONSTRUCT AND USE AN ACCESS DRIVEWAY ON APPROXIMATELY 2.648-ACRE PORTION OF A 1,247-ACRE PARCEL FOR USE BY THE HILO BENIOFF MEDICAL CENTER ON ADJACENT PARCEL 127 TAX MAP KEY: (3) 1-6-003:007 (POR.), KEA'AU, PUNA, HAWAI'I Staff, upon reviewing the provided documents, does not anticipate any significant impact to traffic and/or public safety concerns. Thank you for allowing us the opportunity to comment. If you have any questions, please contact Captain Todd Pataray, Puna Patrol, at 965-2716 or via email at Todd.Pataray@hawaiipolice.gov. "Hawai'i County is an Equal Opportunity Provider and Employer" TO: DEPARTMENT OF WATER SUPPLY • COUNTY OF HAWAl'I 345 KEKUANAO'ASTREET, SUITE 20 • HILO, HAWAl'l 96720 TELEPHONE (808) 961-8050 • FAX (808) 961-8657 Mr. Jeffrey Darrow, Director Planning Department July 27, 2026 COH PLANNING DEPTJUL 28 2026 PM3:2 l REC'D HAND DELIVERED FROM: Keith K. Okamoto, Manager-Chief Engineer SUBJECT: Special Permit Application (PL-SPP-2026-000136) Applicant: Hilo Benioff Medical Center Request: To Construct and Use an Access Driveway on Approximately 2.648-Acre Portion of a 1,247-Acre Parcel for Use by the Hilo Benioff Medical Center on Adjacent Parcel 127 Tax Map Key 1-6-003:007 (Portion) Use Permit Application (PL-USE-2026-000046) Applicant: Hilo Benioff Medical Center Request: To Construct and Operate an Approximately 40,000-Square-Foot Medical Clinic and Accessory Uses on an Approximately 20.018-Acre Portion of a 108.8-Acre Parcel Tax Map Key 1-6-003:127 (Portion) We have reviewed the subject applications for the proposed development and have the following comments: Water can be made available for proposed Lot 9168-A-2-B (TMK 1-6-003:127, Portion) from an existing 16-inch waterline along Hawai 'i Belt Road fronting the subject parcel or from an existing 16-inch waterline at the intersection of Old Volcano Road and Kea'au-Pahoa Road in accordance withthe Department's existing water availability conditions, which are subject to change without notice. The Department has no objection to the proposed application subject to the applicant understanding and accepting the following conditions: 1.The Department requests that the applicant submit estimated maximum daily water usage calculations for the proposed Lot 9168-A-2-B, for review and approval. The water usage calculations shall be prepared by a professional engineer licensed in the State of Hawai'i, andshould include the estimated peak-flow in gallons per minute (GPM), and the total estimatedmaximum daily water usage in gallons per day, including all irrigation/landscaping use . . . . Water, Our :Most <Precious 1?.gsource ... 1(a Wai)l 1(ane ... The Department of Water Supply is an Equal Opportunity provider and employer. Mr. Jeffrey Darrow, Director Page 2 July 27, 2026 2. Upon receipt of the water usage calculations above,the Department will make a determination as to the water commitment deposit amount and prevailing facilities charge (subject to change) to be paid, if necessary. Based on the water demand calculations,the Department will determine the appropriate service lateral, meter size, and any other water system improvements required for the proposed development. 3. The proposed use will require the installation of a reduced pressure-type backflow prevention assembly, within five (5) feet of the meter on private property. If a larger or additional meter is required, a backflow prevention assembly will also be required for that meter. The installation of the backflow prevention assembly must be inspected and approved by the Department before the commencement/continuation of water service. 4. Fire hydrants spaced no more than 300 feet apart and within 150 feet of the driveway or access for each lot. On dead-end streets, the last fire hydrant shall be located at one half the distance from the last house, or unit, fronting the property line, or to the driveway or access for the property. 5. Subject to other agencies' requirements to construct improvements within the road right-of-way fronting the property affected by the proposed development, the applicant shall be responsible for the relocation and adjustment of the Department's affected water system facilities, should they be necessary. 6. Submit the appropriate documents, properly prepared and executed, to convey the water system improvements and necessary easements to the Water Board of the County of Hawai`i prior to final subdivision approval being granted. A registered land surveyor shall stamp and certify the metes and bounds description within the conveyance documents. However, prior to water meter services being granted to the development, or any lots within, the conveyance documents shall be accepted by the Water Board. Should there be any questions, please contact Ms. Robyn Matsumoto of our Water Resources and Planning Branch at(808) 961-8070, extension 255. Sincerely yours, al( Keith K. Okamoto, P.E. Manager-Chief Engineer RM:dfg copy— Hilo Benioff Medical Center W. H. Shipman Ltd. Daryn Arai JOSH GREEN, M.D. KENNETH S. FINK, M.D, MGA, MPH GOVERNOR OF HAWAII DIRECTOR OF HEALTH KE KIA’AINA O KA MOKU’AINA O HAWAI’I KA LUNA HO’OKELE STATE OF HAWAII DEPARTMENT OF HEALTH P.O. BOX 916 HILO, HAWAII 96721-0916 MEMORANDUM DATE: July 9, 2026 TO: Mr. Jeffrey W. Darrow Planning Director, County of Hawaii FROM: Eric Honda District Environmental Health Program Chief SUBJECT: Special Permit Application (PL-SPP-2026-000136) Applicant: Hilo Benioff Medical Center Request: To Construct and Use an Access Driveway on Approximately 2.648-Acre Portion of a 1,247-Acre Parcel for Use by the Hilo Benioff Medical Center on Adjacent Parcel 127 TMK: 1-6-003:007 (por.), Keaʻau, Puna, Hawaiʻi 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. 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), Jeffrey W. Darrow July 9, 2026 Page 2 of 4 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. 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 Jeffrey W. Darrow July 9, 2026 Page 3 of 4 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.gov/epo/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 342I, 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/epo/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 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. Jeffrey W. Darrow July 9, 2026 Page 4 of 4 Other 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. JOSH GREEN, M.D. GOVERNOR KE KIA'AINA STATE OF HAWAl'I I KA MOK U'AINA 'O HAWAl'I DEPARTMEN T OF TRANSP ORTAT ION I KA 'OIHANAALAKAU 869 PUNCHBOWL STREET Mr. Jeffrey Darrow, Director County of Hawaii Planning Department 101 Pauahi Street, Suite 3 Hilo, Hawaii 96720 Dear Mr. Darrow: Subject: Request for Comments HONOLULU, HAWAII 96813-5097 August 3, 2026 Special Permit Application (PL-SPP-2026-000136) Use Pennit Application (PL-USE-2026-000046) Hilo Benioff Medical Center Keaau, Puna, Hawaii Tax Map Key No. (3) 1-6-003: 127 (por.) 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 01167.26 STP 01168.26 HWY-PL 26-2.35118 Thank you for your letter requesting our comments for the above-referenced Applications. We apologize for the delay in response. If approved, the Applications will allow the site to develop a 40,000 square-foot medical building and parking lot within a 13-acre portion of a larger lot in the Agricultural Zone. We responded to an earlier Draft Environmental Assessment review request, which included a January 2026 Traffic Analysis Study (HWY-PL 26-2.35054). We 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 2026-060. Sincerely, EDWIN H. SNIFFEN Director of Transportation Attachments ATTACHMENT The Hawaii Department of Transportation (HDOT) Comments STP 01167.26 and STP 01168.26 No. Comments 1. The project site is west ofthe Hawaii Belt Road/Volcano Road(State Route 11) and between the two intersections with State Route 130 and State Route 139. Primary access will be from the proposed roadway to be connected to State Route 11,via an existing driveway(located at Shipman Park; private land). 2. The HDOT does not have any objections to the Special Permit and Use Permit Applications. The proposed use does not appear to pose any significant impacts to the state highway facility. 3. Should the Special Permit and Use Permit Applications be conditionally approved,we recommend the following condition be included in the approval prior to obtaining any construction permits by the petitioner. 1. The applicant shall coordinate with the Hawaii District office relating to access connection and compliance,including obtaining the following permits: a. State highway right-of-way (ROW)to allow access onto State Route 11, modification requirements to Shipman Park driveway, and utility easements. b. Permit to Perform Work Upon State Highways is required for any work within the state highway ROW. The Applications may include a Traffic Management Plan. 2. We note that ifthere are unexpected traffic issues attributed to this project,the applicant shall mitigate them to the satisfaction of the Hawaii District Engineer at no cost to the state. 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. STP 01167.26 MTY OF•N{C. Kimo Alameda, Ph.D. moo'Jeffrey W. Darrow Mayor Director William V. Brilhante, Jr. Michelle S. Ahn Managing Director mow.' Deputy Director ryt os K`M West Hawai'i Office East Hawai'i Office 74-5044 Ane Keohokalole Hwy 101 Pauahi Street,Suite 3 Kailua-Kona, Hawai'i 96740 County of Hawaii Hilo, Hawai'i 96720 Phone(808)323-4770 Phone(808)961-8288 Fax(808)327-3563 PLANNING DEPARTMENT Fax(808)961-8742 July 07, 2026 MEMORANDUM TO: DPW-ENG — HILO HEALTH DPW-TRAFFIC DOT-PLANNING HONOLULU DWS LUC DEM OP POLICE DOA FIRE DLNR — LAND DIV. RPT DLNR — ENGINEERING ADMINISTRATIVE PERMITS LR — PUNA CDP Maia,7ackjm DY MaijaAck.iJl fc:J147-2..2c _'Hi i1FT'. FROM: JEFFREY W. DARROW Planning Director SUBJECT: Use Permit Application (PL-USE-2026-000046) Applicant: Hilo Benioff Medical Center Request: To Construct and Operate an Approximately 40,000-Square-Foot Medical Clinic and Accessory Uses on an Approximately 20.018-Acre Portion of a 108.8-Acre Parcel Tax Map Key: (3) 1-6-003:127 (por.); Kea`au, Puna, Hawaii The Use Permit Application is linked to this memo for your review and comments. We kindly ask that you submit your comments to planning(5)_hawaiicounty.gov no later than July 29, 2026. Otherwise, we will assume that you have no comments or objections on the request. Should you have any questions, please feel free to contact Tracie-Lee Camero of this department at (808) 961-8166. Thank you very much. MH iloBenioffMedicalCenterPL-USE-2026-046rms www.planning.hawaiicounty.gov Hawaii County is an Equal Opportunity Provider and Employer Planning cDhawaiicounty.Qov Daryn Arai Land Use Planning Consultant P.O. BOX 4501, HILO HAWAII 96720 PHONE: (808) 895-3218 EMAIL: August 21, 2026 Mr. Jeffrey Darrow, Planning Director County of Hawaiʻi Planning Department 101 Pauahi Street, Suite 3 Hilo, HI 96720 Applicant’s Response to Agencies’ Comments regarding Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 Request: To allow for the development of the proposed Keaʻau Benioff Health Center and related access and utility improvements Applicant: Hilo Benioff Medical Center TMKs -1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi This letter will respond to comments received from consulting agencies that have reviewed the above-described applications related to the development of the proposed Keaʻau Benioff Health Center. We appreciate these agencies’ comments being provided to the Applicant. State Office of Planning and Sustainable Development (email dated July 22, 2026) The Applicant notes that the State Office of Planning and Sustainable Development (OPSD) had no comments or objection to the subject applications and requests. Department of Health (memo dated July 9, 2026) The Applicant acknowledges that the District Health Office no longer provides individual comments to agencies or project owners to expedite the land use review and process. Nevertheless, the deploy best management practices during construction and similarly during health center operations to ensure that the proposed facility will comply with applicable clean air, clean water and safe drinking water standards, hazard evaluation and the proper disposal of solid and hazardous waste and wastewater. Some specific best-management and mitigating actions will include: Construction •Prepare and submit for approval to the DOH HEER office a C-EHMP which outlines the proper handling and management of soil and/or groundwater, sampling and analysis protocol for soil, the planned re-use/disposal locations for excavated soil, health and safety measures to be taken to protect workers, environment and the general public. The project specific C-EHMP must be approved by the DOH HEER office prior to the start of any construction activity that disturbs the identified contaminated soils at the project site. Mr. Jeffrey Darrow, Planning Director County of Hawaiʻi Planning Department August 21, 2026 Page 2 of 4 • The Applicant will coordinate with the Departments of Health and Public Works to ensure compliance with NPDES requirements during the design and construction of storm water systems within the proposed project site. • Conduct air monitoring for airborne arsenic-impacted dust by qualified personnel during any contaminated soil disturbance. • Aggregates and any other construction/demolition waste will be responsibly reused to its fullest extent. • Ample room will be provided for rubbish and recycling. • Green waste may be transported to the green waste sites located at the West Hawai‘i Organics Facility and East Hawai‘i Organics Facility, or other suitable diversion programs. • All construction and demolition waste will be transported to the West Hawai‘i Sanitary Landfill for disposal. • Unused materials and excess fill (if any) will be properly disposed of at an authorized waste disposal site. • During construction, emergency spill treatment, storage, and disposal of all hazardous materials, will be explicitly required to meet all State and County requirements, and the contractor will adhere to “Good Housekeeping” for all appropriate substances, with the following instructions: Operations • Develop a Solid Waste Management Plan (SWMP) completed by a licensed engineer or architect in accordance with DEM guidelines. The SWMP will be used to: 1. Promote and implement recycling and recycling programs. 2. Predict the waste generated by the proposed development and anticipate the impacts on County Solid Waste Management Facilities. 3. Predict the additional vehicular traffic being generated because of waste and recycling transfers. • Potable water will be provided by the County Department of Water Supply. • A package Wastewater Treatment Works (WWTW), to be reviewed and approved by the State Department of Health and providing secondary treatment, will be installed to manage wastewater generated by the proposed facility. • The WWTW will be operated and maintained by a licensed operator in accordance with DOH Chapter 11-62 requirements. An operations and maintenance (O&M) plan will be submitted to DOH as part of the permit application, detailing inspection schedules, effluent sampling and monitoring requirements, and corrective action procedures to ensure the system performs as designed and protects groundwater quality. Mr. Jeffrey Darrow, Planning Director County of Hawaiʻi Planning Department August 21, 2026 Page 3 of 4 • Medical waste from clinical operations will be managed separately from the general wastewater stream in accordance with HAR Chapter 11-104.1 (Regulated Medical Waste) and applicable DOH guidelines, and will be disposed of through licensed medical waste disposal contractors. Such waste will not enter the onsite WWTW. State Department of Transportation (memo dated August 3, 2026) The Applicant acknowledges that the State Department of Transportation (SDOT) has no objections to the proposed health clinic and its operations as it does not appear to have any significant impacts to the nearby state highway facilities. The Applicant has no objections to complying with the proposed conditions as recommended by SDOT and recited below, prior to obtaining any construction-related permits: 1. The applicant shall coordinate with the Hawaii District office relating to access connection and compliance, including obtaining the following permits: a. State highway right-of-way (ROW) to allow access onto State Route 11, modification requirements to Shipman Park driveway, and utility easements. b. Permit to Perform Work Upon State Highways is required for any work within the state highway ROW. The Applications may include a Traffic Management Plan. 2. We note that if there are unexpected traffic issues attributed to this project, the applicant shall mitigate them to the satisfaction of the Hawaii District Engineer at no cost to the state. The Applicant is willing to consider strategies to reduce carbon emissions from operations related to the proposed project, such as: • incorporating elements that encourage and enhance the use of multiple types of transportation to reduce carbon emissions; • implement energy-efficient technologies and practices, such as light-emitting diode lighting; and • Use sustainable, recycled, or low-emission materials in construction and manufacturing. Department of Water Supply (letter dated July 27, 2026) The Department of Water Supply (DWS) has confirmed water availability to support the proposed health center via a 16-inch waterline at the intersection of Old Volcano Road and the Keaʻau-Pahoa Road. In early August 2026, the Applicant prepared and submitted estimated maximum daily water usage calculations for the proposed project for the review and approval by DWS that will ultimately determine the type of water system Mr. Jeffrey Darrow, Planning Director County of Hawaiʻi Planning Department August 21, 2026 Page 4 of 4 facility improvements needed to support the proposed project along with determining the necessary water connection fees and charges that will be borne by the Applicant. Similarly, the Applicant has prepared civil construction plans that includes the location of required backflow prevention assemblies as well as fire protection water meters. These civil construction plans were also submitted to the Department of Water Supply for review and approval in early August 2026. Once all water system improvements have been completed, inspected and approved by DWS, the Applicant intends to convey the water system to the County of Hawaiʻi. Police Department (memo dated July 13, 2026) The Police Department does not anticipate any impact to traffic and/or public safety concerns as a result of construction or operation of the proposed health center. Should you have any questions or require additional information or clarification related to our responses, please do not hesitate to contact me by phone at (808) 895-3218 or by email at . Sincerely, Daryn Arai Land Use Planning Consultant cc w/encls – Dan Brinkman, East Hawaii Regional CEO, Hawaii Health Systems Corporation Margaret “Peggy” Farias, President, W.H. Shipman, Limited From:Kris Toriano To:Planning WPC Testimony Subject:LETTER OF SUPPORT: Permit for Keaau Benioff Health Center Date:Monday, August 24, 2026 2:35:55 PM Attachments:image001.png Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. As the former Nurse Manager for the clinics in Keaau, Kau, Pahoa, and Puna Kai, I can attest to the need for care in this community and that the public is asking for more services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Kris Toriano, RN BSNNurse Manager of Employee HealthEast Hawaii Region, Hawaii Health Systems CorporationMailing: 1190 Waianuenue Avenue, Hilo, HI 96720 | HR Office: 140 Rainbow Drive, Hilo, HI 96720Direct: 808-932-3596 | Main: 808-932-3147 | Fax: 808-974-6833ktoriano@hhsc.org | www.hbmc.org Join our Team! | Need Help? Submit a Ticket! Out of office: August 21st HolidayConfidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and maycontain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you arenot the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Karin Coleman Helpdesk Supervisor Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! The extended drive time from my home to the HBMC hospital/clinics is at least 45 minutes. Having a location nearer to my home will be a big change. It’s especially needed because my spouse and I are reaching retirement age and will greatly appreciate not having to drive as far. It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Ken Allison (Upper Puna Resident) IT Specialist III HBMC From: Alexander Bazuzi To: Planning WPC Testimony Subject: Special Use Permit for Keaau Benioff Health Center Date: Monday, August 24, 2026 2:56:41 PM Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Kea’au, Puna, Hawai’i As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawai’i is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Kea’au Benioff Health Center. Sincerely, Alexander Bazuzi Information Systems Specialist VI Hilo Benioff Medical Center Office 808.932.3015 EHI Help Desk 808.932.3890 Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. August 24, 2026 Mr. Louis Daniele Ill, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (par); Keaau, Puna, Hawaii As an employee of our healthcare system that includes Hilo Benioff Medical Center, I humbly ask your approval for the Use and Special Permits for the proposed Keaau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents, like myself, of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall. It is time that we the people of Puna and lower East Hawaii is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaau Benioff Health Center. Sincerely, Danette Vincent Clinic Receptionist Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Kristin Obana Business Intelligence Director Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. It will also provide additional jobs to the area and potentially decrease traffic for those employed by and/or attending the clinic. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Cheryl L. Jackson, LCSW Social Worker / Patient Services Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Terri Haina Patient Advocate Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 28, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Kelsey Okuda Administrative Services Officer Hilo Benioff Medical Center From: Alice Takamine To: Planning WPC Testimony Subject: Letter of Testimony in Support of Keaʻau Benioff Health Center Special Use Permit Date: Tuesday, August 25, 2026 9:54:00 AM Attachments:SHLPHPR0326082509500.pdf Dear Windward Planning Commission, Please find attached my letter of testimony in support of the Special Use Permit for the proposed Keaʻau Benioff Health Center. I respectfully ask the Commission to consider the importance of this project in improving access to healthcare services for the Keaʻau community and surrounding areas of East Hawaiʻi, including Puna and Ka’u. Thank you for the opportunity to provide testimony and for your consideration. Mahalo, Alice Takamine, PharmD Pharmacy Operations Manager Hilo Benioff Medical Center 1190 Waianuenue Avenue Hilo, HI 96720 Phone: (808) 932-3928 Email: atakamine@hhsc.org Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. r� HILO BENIOFF MEDICAL CENTER,' HONOKA'A HOSPITAL KA'U HOSPITAL Y. OKUTSU STATE VETERANS HOME August 28, 2026 Mr. Louis Daniele Ill, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Kea'au Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por}: Kea'au1 Puna. Hawai'i As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Kea'au Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawai'i is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Kea'au Benioff Health Center. Sincerely, Sharlene Macasieb Clinic Manager Hilo Benioff Medical Center Dennis "Fresh" Onishi Council Member District 3 August 24, 2026 HA WAI'I COUNTY COUNCIL Hawai'i County Building 25 Aupuni Street Hilo, Hawai 'i 96720 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Phone No.: (808) 961-8396 dennis.onishi@hawaiicounty.gov Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Kea'au BenioffHealth Center Applicant: Hilo Benioff Medical Center TMKs 1-6-0003:007 (por) and 127 (por); Kea'au, Puna, Hawai'i Through this letter, I am requesting that the Windward Planning Commission approve the requested Use and Special Permits that would bring the proposed Kea'au Benioff Health Center to Kea'au Village. The proposed health center is a much-needed facility that will expand access to local healthcare not only for the residents of Kea'au, but also for surrounding communities that could extend as far south as Ka 'u. The Kea' au Benioff Health Center will bring enhanced urgent care, primary and specialty care, imaging and behavioral health services to the center of a region that is continuing to grow. These services will also provide greater opportunities for early prevention in the hopes of reducing chronic health issues. For these reasons, I humbly ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Kea' au Benioff Health Center. Dennis "Fresh" Onishi, Council Vice Chair Hawai'i County Is An Equal Opportunity Provider And Employer 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 25, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Joseph Grennier IT Specialist III Hilo Benioff Medical Center 1190 WAIANUENUE AVENUE HILO, HAWAII 96720 PHONE (808) 932-3000 FAX (808) 974-4746 August 26, 2026 Mr. Louis Daniele III, Chair and Members of the Windward Planning Commission 101 Pauahi Street, Suite 3 Hilo, HI 96720 Dear Chair Daniele and Members of the Windward Planning Commission: Testimony in Support of Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136 relating to the development of the the proposed Keaʻau Benioff Health Center Applicant: Hilo Benioff MEDICAL Center TMKs 1-6-0003:007 (por) and 127 (por); Keaʻau, Puna, Hawaiʻi As an employee of our healthcare system that includes Hilo Benioff Medical Center, Kau Hospital, Honokaa Hospital, and the East Hawaii Clinics in Hilo, Keaau, Pahoa and Kau, I humbly request your approval the Use and Special Permits for the proposed Keaʻau Benioff Health Center. I am excited about the opportunities that this new health center will bring to the residents of Puna. I can foresee the time when my family, friends and neighbors will no longer have to make the long drive into Hilo for urgent, primary, and specialty care, along with imaging and other basic medical services. To have Keaau Benioff Health Center systemically integrated with Hilo Benioff Medical Center will improve health services and coordination overall! It is time that Puna and lower East Hawaiʻi is served by a comprehensive health facility that is reflective of the growth of our community and the increase in such basic health services. For these reasons, I ask the Windward Planning Commission to approve the Use and Special Permit applications for the proposed Keaʻau Benioff Health Center. Sincerely, Gerald C Koesters Facilities Maintenance HBMC m:te �enate ©ff ice of tbe ;ffmajoritp JLeaber STATE CAPITOL H ON O LU LU, HAW A l'I 9 6 8 1 3 August 31, 2026 Mr. Louis Daniele III, Chair and Members of the Winward Planning Commission 10 I Pauahi Street, Suite 3 Hilo, HI 96720 RE: Support for Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136-Proposed Kea'au BenioffHealth Center Thank you for the opportunity to express my strong support of the requested Use and Special Permits for the development of the proposed Kea'au BenioffHealth Center in Kea'au Village, Hawai'i Island. While the proposed health center is not physically located within my Senate District, I believe this project represents an important investment in healthcare access for communities across Hawai'i Island. The reality is that many of the communities I represent have limited access to basic healthcare services, and residents frequently travel significant distances to receive the care they need. The Kea'au Benioff Health Center has the potential to help address this challenge and provide meaningful benefits to residents well beyond the immediate Kea'au community. The proposed health center will provide enhanced access to urgent care, primary and specialty care, imaging, and behavioral health services in a central and growing area ofEast Hawai'i. These services will be particularly valuable for residents of rural and underserved communities, including those in Ka'u, Volcano, and other communities that may have limited healthcare options close to home. The Kea'au BenioffHealth Center would serve a region that continues to experience significant population growth, making additional healthcare capacity increasingly important. As such, I firmly believe this project will strengthen the broader healthcare network on Hawai'i Island and provide an important resource for families throughout the surrounding communities. For these reasons, I respectfully urge the Windward Planning Commission to approve Use Permit Application No. PL-USE-2026-000046 and Special Permit Application No. PL-SPP-2026-000136. I am confident that the expanded healthcare services it will provide will benefit many of the residents I have the privilege of representing, as well as communities throughout Hawai'i Island. Mahalo for your time and consideration. Please do not hesitate to contact me should you require any further information or assistance. Me ka ha'aha'a, Senator Dru Mamo Kanuha yct Senatorial District (Kona, Ka'u, Volcano) 415 S. Beretania Street, Room 206 I Honolulu, HI 96813 I PH: (808) 586-9385 I EM: senkanuha@capitol.hawaii.gov From: Luke Alfsen To: Planning WPC Testimony Subject: Medical Care for Puna Date: Wednesday, August 26, 2026 2:16:57 PM To whom it may concern, My name is Luke and I work at HBMC in Hilo. I am writing today to show my support for a facility to be built in the near future in Keaau. This facility is greatly needed to help serve the Puna and Kau districts. I cannot express how much this could help the health care needs of the members of those communities , as well as providing much needed relief to the hospital in Hilo that gets overwhelmed at times. As you review the plans for the building site please remember what a positive impact this will have on our Ohanas , especially our Kapuna. Sincerely, Luke Alfsen ( Plant Renovations) Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.