Of the Certified Shoreline and Within Rubble-Masonry( CRM)

ASR_BKonaReef SMA_SSV_2021

COUNTY OF HAWAII PLANNING DEPARTMENT BACKGROUND REPORT

AOAO KONA REEF, INC. SPECIAL MANAGEMENT AREA USE PERMIT APPLICATION (SMA 20- 000076) SHORELINE SETBACK VARIANCE APPLICATION (SSV 20- 0000121

AOAO KONA REEF, INC. has submitted applications for a Special Management Area( SMA)

Use Permit and a Shoreline Setback Variance to construct a 220-foot-long Concrete- Rubble- Masonry ( CRM) wall approximately 1- foot inland (mauka) of the certified shoreline and within the shoreline setback area located seaward ( makai) of the Kona Reef Condominium Complex on an approximately 2, 500- square foot portion of a larger 3. 08- acre parcel situated in the Special Management Area. The subject parcel is located at 75- 5888 Alii Drive, Pua' a 3' a- Waiaha 2ne

North Kona District, Hawaii, TMK: (3) 7- 5- 018: 071.

APPLICANT' S REQUEST

1. Request: AOAO Kona Reef, Inc. proposes to build a continuous 220-foot-long concrete- rubble- masonry( CRM) wall within the 40- foot shoreline setback area. The structure would be located entirely above( mauka) of the Certified Shoreline approximately 12 to 18 inches wide at ground level and approximately 24 to 36 inches wide at the base, which would be anchored to the bedrock. The entire structure would have a length of approximately 220 linear feet and would roughly parallel the mauka side of the Certified Shoreline by a buffer of at least 12 inches. The structure would be embedded in the existing soil on both sides for about % of its length, and on approximately the northern 1/2 of its length the structure

would be exposed on the makai side. Drainage would be a component of the design, so that

water in the sub- grade is not retained and flow from the mauka side of the structure to the

side would be allowed. The wall depth will vary with the subsurface depth of the bedrock and will include a drainage pipe that will run the length of the structure ( mauka side) and

daylight at the wall end for drainage. The project will include the removal and excavation

of soil and rock to accommodate the finished face of the wall.

1- 2. Reasons for Request: The primary purpose of the wall is to prevent future erosion of the

lawn area, and to mitigate the effects of the rare storm or tsunami surges that could cross the shoreline. Additionally, the applicant claims pedestrian foot traffic entering and exiting the shoreline is eroding the face of the lawn and fill area.

SUPPORTIVE INFORMATION

3. Submitted Application(s): The applicant has submitted the attached in support of the

request: ( Planning Department Exhibit 1 - Shoreline Setback Variance Application

and Special Management Area Use Permit Application dated September 21, 2020).

4. Chapter 343, Hawaii Revised Statutes (HRS): The improvements are proposed within

the shoreline area and are subject to the requirements of Chapter 343, Hawaii Revised Statutes, for Environmental Impact Statements. A Finding of No Significant Impact FONSI) declaration for a Final Environmental Assessment ( FEA) was issued by the Planning Director in a letter dated February 12, 2018 to the Office of Environmental Quality Control. ( Planning Department Exhibit 2 - February 12, 2018 Letter and

attached Final Environmental Assessment)

5. Certified Shoreline: The certified shoreline survey submitted with the applications was approved by the Chairman of the Board of Land and Natural Resources on April 20, 2020.

STATE AND COUNTY PLANS

6. State Land Use District: Urban

7. General Plan Land Use Pattern Allocation Guide ( LUPAG) Map Designation: High Density Urban( hdu).

8. County Zoning: Resort-Hotel( V-.75)

9. Kona CDP: The project is within the Kona Urban Area.

10. Special Management Area( SMA): The Special Management Area is part of the Coastal

Zone Management Program and regulated by the County. The property is situated within the Special Management Area and the proposed project is within the 40-foot shoreline

setback area, therefore the applicant has submitted the Special Management Area Use

Permit and Shoreline Setback Variance applications.

2- DESCRIPTION OF SUBJECT PROPERTY AND SURROUNDING AREA 11. Description of Property: The project site is the 3. 08-acre Kona Reef Condominium Complex located makai of Ali' i Drive, adjacent to the Hawai`i County Wai`aha Beach Park at Honl' s Beach. Portions of the existing Kona Reef Condominium structures, including an irrigation system, portions of the pre- existing CRM wall, and the lawn area itself were permitted by Shoreline Setback Variance# 610 dated June 25, 1981, which also stipulated preparation of a public shoreline access plan including a pedestrian easement along the north property line, and provisions for lateral easement across the makai portion of the property boundary. The project area will cover the southern halfof the 430-foot long makai property boundary located adjacent to the Beach park. The shoreline fronting the property is rocky boulders, with some sandy pockets and a grass strip between the development and the shoreline. The property is roughly rectangular-shaped with the makai side building elevation of 11- feet above sea level. The topography of the property is relatively flat

sloping towards the shoreline. 12. Surrounding Zoning/Land Uses: The property and the surrounding areas are zoned Resort-Hotel, Single and Multiple-Family Residential and Village Commercial. To the south of the proposed project site is the County' s Wai`aha Beach Park at Honl' s Beach. To the north( along the shoreline) is a long-standing single family residential structure, as well as a concrete foundation for a condominium project originally approved under SMA 388. Lastly, to the east( mauka) of the Alii Drive is the Alii Cove residential complex. 13. U.S. D.A. Soil Type: The soil in the project area is Wai` aha extremely stony silty loam on

6- 12% slopes overlain on pahoehoe bedrock.

14. Flora/Fauna Resources: A Floral and Faunal study was completed as part of the Environmental Assessment process in April 2016 by an agent for the applicant. The study found that all of the plants within the project area are common species commonly used for landscaping. Floral species makai of the shoreline include indigenous species such as naupaka. The vegetation is typical of disturbed development sites in coastal areas, and no

threatened or endangered animal or plant species were found or would be expected within

the project area. Plants observed included naupaka, beach morning glory, and uhaloa.

3- Terrestrial faunal species included primarily introduced avian species and it was found that the project site does not contain any important resources, such as nesting or food sources. The study concludes that marine mammals or reptiles could move onto the beach from the ocean, including the Hawaiian monk seal or sea turtles. 15. Archaeological/Historic Resources: An archaeological inventory survey ( AIS) Appendix D of Application) was conducted to evaluate the potential for subsurface resources that may exist at the project site. The AIS was submitted to the State Historic Preservation Division( SHPD) for review of treatment recommendations for a site related

to prehistoric habitation ( Site 30493). The AIS recommended no further work or preservation of the site because the disturbed nature of the deposit precludes the potential

to obtain additional archeological information. According to a letter from SHPD to the

Planning Department ( Planning Department Exhibit 3 - Letter dated November 19, 2020) an " AIS was conducted on behalf of Kona Reef Condominium to comply with the previous SHPD request( to conduct the AIS). The AIS included in the EA was not submitted to the SHPD for review and acceptance with the appropriate review fee, as specified in Hawai`i Administrative Rules ( HAR Ch. 13- 284-4). At this time, SHPD

cannot provide meaningful comments for the proposed project until such time that the AIS has been reviewed and accepted and any potential mitigation measures are put in place for the proposed project. SHPD requests that the AIS be submitted for preview and acceptance. Therefore, at this time, the applicant' s HRS Chapter 6E project effect determination has

not been accepted by SHPD. 16. Flood Zone: According to the FEMA Flood Insurance Rate Map ( FIRM), the area is designated as Special Flood Hazard Zone AE, with a base flood elevation of 10- feet, as

well as areas of Zone X located on the mauka side ofthe subject parcel. The shoreline area

makai of the project site is designated as Zone V( Flood Zone areas along coasts subject to inundation by the 1% annual chance flood event with additional hazards associated with

storm- induced waves).

17. Recreational Resources: Per a settlement agreement between the County of Hawai`i and

the applicant, public access is permitted through the parcel and along the entire coastline

4- fronting the condominium complex. The public access path is at least 10- feet wide and runs along the northern Kona Reef property boundary to the shoreline and then along the coastline. The property abuts the shoreline and includes an active public shoreline access trail and shoreline grassy area used by residents. Recreational resources at the shoreline include surfing, fishing, and other water dependent shoreline activities, including access to

the beach park south of the project site.

UTILITIES AND SERVICES

18. Access: Access to the property is from Ali' i Drive onto a privately owned paved parking area and driveway. 19. Water: Water service is provided by the County ofHawaii Department ofWater Supply. 20. Wastewater: According to the applicant, wastewater disposal is through the County

municipal sewage system.

21. Utilities: Electrical and telephone service are available to the property via underground

conduits.

AGENCIES' COMMENTS

22. State Office of Planning: Planning Department Exhibit 4- November 10, 2020 Letter. 23. State of Hawaii Department of Land and Natural Resources ( DLNR) Office of Conservation and Coastal Lands ( OCCL): Planning Department Exhibit 5 -

November 9, 2020 Letter. 24. DLNR- Engineering Division: Planning Department Exhibit 6- November 4, 2020

Memo.

25. DLNR - State Historic Preservation Division ( SHPD): Planning Department

Exhibit 7- November 19, 2020 Letter.

26. County of Hawaii Dept. of Public Works ( DPW) Engineering Division: Planning Department Exhibit 8- November 10, 2020 Memo.

5- AGENCIES- NO COMMENTS

27. DLNR - DOBOR; DLNR - Land Division; Hawai` i County Police Dept.; State

Department of Transportation( DOT); Dept. of Environmental Management( DEM).

AGENCIES- NO RESPONSE

28. Hawai`i County DPW - Building; Hawaii County Fire Dept.; State Dept. of Health

DOH); State Land Use Commission( LUC); USFWS.

PUBLIC COMMENTS

29. None as of this writing.

6- R, I AOAO Kona Reef, Inc. 75- 5888 Alii Drive, Kailua- Kona, Hawaii 96740 808) 430- 8659 Fax: 333- 5714

County of Hawaii Planning Department September21, 2020 101 Pauahi Street, Suite# 3 Hilo, HI 96720

SUBJECT: Shoreline Setback Variance Si SMA Use Permit Applications APPLICANT: AOAO Kona Reef, Inc. TAX MAP KEY: ( 3) 7- 5- 018:071

Dear Director Yee, and Planners,

AOAO Kona Reef, Inc. is requesting Hawaii County' s Planning Director and Department review and support their proposed shoreline projects. We are requesting approvals for two separate but connected by proximity needs under this one filing. The first request is to obtain the authorizations needed to build an engineered Concrete Rubble Masonry( CRM) erosion abatement and safety net protective) structure within the 40-foot shoreline setback area of the Kona Reef property. It would be built above the State certified shoreline entirely on private property. The second goal is to retain, permit and cause to be recorded encroachments into this same 40- foot setback area.

The Final Environmental Assessment, ( FEA) for the proposed project under its Determination, Findings and Reasons ( pages 34, 35, & 36), affirms the environmental neutrality of the proposed project. The FEA also supports the need and importance of the shoreline CRM wall. The Hawaii County Planning Department has also accepted the FEA and given the related project a Finding Of No Significant Impact,( FONSI).

This project can be interpreted so as to encompass many different reasonings and rationales causing it to fit into multiple categories in support of its approval. The proposed project can actually be viewed and justified with just simple perception and foresight. The most important factual questions to ask are: Will it save and protect the improvements and structures it is meant to? Is it an environmentally sound endeavor? Is it the most innocuous answer available to solve a threatening persistent problem? Will it prevent a worst-case scenario that would be absolutely disastrous for all? We contend that our project is in the best interests of everyone, financially, environmentally, recreationally, aesthetically, and for personal safety.

Attached please find a list of inclusions,( page 2) for the referenced filings.

Sincere! , Rs Raymond S. Pieri 73- 4642 Uluwehi Place Planning Dept. Kailua-Kona, Hi 96740 Exhibit I pierir00l' ilhhatyaii.rr.com 808) 989- 7439

Page l of 2 I ( P 1 14 K. COK PLANNING DEPT AOAO Kona Reef, Inc. SF?) 2C 2!020 oO:0S 4 75- 5888 A1i' i Drive, Kailua-Kona, Hawaii 96740 808) 430-8659 Fax: ( 808) 333- 5714

IN REFERENCE TO: Shoreline Setback Variance& SMA Use Permit Applications SUBJECT: Letters, Narratives and Inclusions for both Applications

To Whom It May Concern:

Applications: Project Structural Detail Clarification Letter Kona Reef Shoreline Setback Variance Application SSV Application Narrative

SMA Minor Cumulative Impact Summary Letter Best Management Practices Special Management Area Use Permit Application SMA Application Narrative

Inclusions: State of Hawaii Certified Shoreline Survey Map( April20, 2020) Pictures of Certified Shoreline Survey Location Kona Reef Shoreline Exhibit Map Showing 40' Setback Line( on back of shoreline survey map) Project Area Topographical Map with Ocean High Tide Lines 28 Kona Reef Original Site Plan( 1981)( on back of topo map with tide lines) Kailua Urban Zone Map( section 25- 8- 5) Kona Reef Resort Overview Photo Kona Reef Buildings and Apartment Units Layout Map Hawai i County Shoreline Setback Variance# 610( 1981) Variance# 610 Settlement Agreement( 1985) Kona Wai Engineering, LLC CRM Wall Design Plans( for project construction) Engineering Partners, Inc. Structural Design Plans( used for FEA, not for construction) Final Environmental Assessment Book

3 h.. , .ti>>, , AOAO Kona Reef, Inc. 75-5888 Alii Drive, KaIua-Kona, Rawer i 96740 808) 430-8659 Fax:( 808) 333- 5714

County of Hawaii Planning Department September 15, 2020 101 Pauahi Street, Suite 3 Hilo, HI 96720 808) 967- 8288

SUBJECT: AOAO Kona Reef, Inc. Shoreline Setback Variance Application RE: Clarification of Discrepancies in Project Design/Details,& BMPs TAX MAP KEY: ( 3) 7- 5- 018: 071

Director Lee and Planners;

This letter is in response to paragraph 2,( copied herein) of your letter dated July 20, 2020 requesting clarifications regarding design and construction details for the proposed Kona Reefshoreline project.

A tier our review of the Final Fay h norenull As < a+Ment( PEA) and submitted documents rur the Shoreline Setback Variance. the I' Iannmg Department is unclear on the exact dimensions. location and construction methods tiff the proposed shoreline area wall. \ Ve ask that you porvidc clear plans, designs w drawings Ilial show the exact loca6un or the proposed wall- the final dmtenstau of the proposed wall, and the Best Management Practice: ( BMPs) that will be in place to minintire or eliminate impacts to ocean wafter.. From your prt puscd coastal development.

The Planning Department' s confusion was caused by my omissions. I did not inform them that there were 2 designs drawn for the proposed project. They were also not informed that the second design would be replacing the fust or original design. The 2 designs are 100% interchangeable in all aspects as this letter will explain. The original design was drawn by Engineering Partners, Inc,( EPI) of Hilo, HI. The second design was drawn by Kona Wai Engineering, LLC of Kailua-Kona, HI. The discrepancies cited in your letter were the result of the EPI wall design being used for the FEA and the Kona Wai wall design being used for the June 15, 2020 SSV submissions. For reference purposes a signed and wet-stamped set of the EPI plans is now included with the application package and all 20 SSV Application packets have had an 11" x 17" copy added to them. Please refer to both the EPI plan and the Kona Wai plan for clarifications of statements made herein.

The EPI design was used for the FEA with the full intention of it being built. New site information gained from archaeological test holes revealed the needed wall size to be much larger than the EPI plans show it to be. The plans needed major revisions before they were useable for construction purposes. Instead of going back to EPI for an overhaul of their design I hired Kona Wai Engineering to a new one. Kona Wai produced a concrete rubble masonry ( CRM) wall design which is much more accurate and is more appropriate for the project location.

When both designs were compared side by side the Kona Wai Engineering design was far superior by a wide margin in every way. Their design is the widely accepted and standard design used for walls everywhere. It is much faster and easier to build. It will produce far less waste materials. The entire project area does not need to be excavated all at once to build it. It will cause less damage to property and the environment during its construction. Its construction will inconvenience the public far less and for a shorter period of time.

Page 1 of 2 County ofHawaii Planning Department

In contrast to Kona Wai' s design, construction of the EPI design will wreak havoc in the project and entire lawn area. The entire 220- foot length of the project will have to be excavated all at once. Concrete trucks will make huge deep Ms running the MI 400-foot plus length of the lawn and most likely break some irrigation pipes too. Construction will produce a huge pile of form lumber waste that will be sent to the County landfill. It poses more safety risks to the public because it will have form braces and concrete stakes randomly sticking out everywhere. The design will take much longer to build and is much harder to build. It will inconvenience the public for a longer period of time and to a greater extent. It is the larger pollution generator and bigger threat to the environment.

The Kona Wai wall design is currently buildable just as it is drawn and the EPI design is not. The construction materials used in both designs are identical except that the EPI design is mostly concrete with a semi-imbedded rock face and the Kona Wai' s design is a mixture of concrete and rock throughout the structure. The final overall size and dimensions for both designs will be exactly the same once upsizing adjustments are made to the EPI design. The wall location will also be exactly the same for both designs.

The Kona Wai design is our preferred design and the one we propose to build. Kona Wai Engineering' s wall design and dimensions were used in the June 156 SSV filings and are again being used for the current SSV application filings.

The proposed wall, when finished, will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches, and be 12 to 18 inches wide across the top. The concrete foundation of the wall will be 12- inches inland of and run roughly parallel to the certified shoreline making the top of the wall even farther inland because the ocean face of the wall slopes inward.

As with all construction projects that include excavation, unseen onsite conditions can require adjustments to the physical dimensions of the project. The above-stated dimensions are cited as variables because they will vary at different points along the length of the project to maintain design specifications. The structures final dimensions will depend entirely on the depth needed to achieve solid foundation anchoring. If the dimensions we are providing were proven to be inaccurate it would serve no purpose except to foolishly and needlessly cause problems or delays to our own project once construction was started.

If further explanation is needed please request it

Best Management Practices has been added to the SMA Major Application

Sincerely 0/14,44 Raymond S Pieri Project Manager 73- 4642 Uluwehi Place Kailua-Kona, HI 96740 piericOol(a.hawaii.rr.com 808) 989- 7439

Page 2 of 2 OOfi PLHNHIh'G DEPT SEP 25 2020 ni3.08

SHORELINE SETBACK VARIANCE APPLICATION

COUNTY OF HAWAII PLANNING DEPARTMENT

APPLICANT: AOAO Kona Reef, Inc.

pp /pJ APPLICANTS SIGNATURE: t_in 0-ant, DATE. 6`/ 9. Zp

ADDRESS: 75- 5888 Alii Drive, Kailua-Kona, HI 96740

CIO Hawaiians.Management Company, Ltd. Palani Court. Suite 215

74-5620 Palani Road, Kailua-Kona HI 96740

LIST APPLICANTS INTEREST IF NOT OWNER.

LIST PRINCIPAL( S) INCLUDING NAMES OF MAIN OFFICERS: William M. Armer Jr.-

President- AOAO Kona Reef, Inc. Board of Directors.

PHONE: (Bus.) ( 808) 896- 4535 ( Res.) Fax.)

LANDOWNER( S): Inc. AOAOKonaReeff, DD 11 LANDOWNER SIGNATURE(S): !/ G itle m 7", DATE: Z/ 4yZ LANDOWNER(S) ADDRESS: 75-5888 Mil Drive, Kailna-Kana,.HI 96740

C/O Hawaiiana Management Company, Ltd. Palani Court, Suite 215

74-5620 Palani Road.Kailna-Kona. HI 96740

REQUEST: The issuance of a shoreline setback variance required to make improvements

within and to retain encroachments into the 40-foot shoreline setbackareafrontinp the Knna

Reef property. The proposed project is the construction of a concrete- rubble- masonry

CBM) wall to serve as protection for privateproperty and the ocean environment

TAX MAP KEY:( 3) 7- 5- 018- 071 ZONING: Resort Hotel( V-.75)

AREA OF PROPERTY: approximately 3. 08acres

AGENT: Raymond S. Pieri

ADDRESS: 73- 4642 UluwehiPlace. Kailua- Kona, HI 96740

PHONE: ( Bus.) ( 808) 989- 7439 ( Res.) Fax.)

Please indicate to whom original correspondence and copiesshould be sent

ORIGINAL: Raymond S. Pieri ( e- mail: pier r001hawaii.rr.com)

COPIES: Raymond S. Pieri Shoreline Setback Variance Application County of Hawaii Planning Department for AOAO Kona Reef, Inc. Erosion Abatement Project 75- 5888 Alii Drive, Kailua- Kona, HI 96740 TMK: (3) 7- 5- 018: 71

149

45 AA

YAC v

Kona Reef Condominium Complex Shoreline Setback Variance Application AOAO Kona Reef, Inc. TMK: (3) 7- 5- 018: 071

Table of Contents:

A) Final Environmental Assessment Summary _ 1 B) Detailed Project Description 1

Proposed Project 1

Project Site 1

Construction Details 2

Structure Dimension Details 2

Structural Caveat 3

Project Objectives 3

Reasons for Request 4

8- 10 Criteria for Approval of a Variance 5

a)( 3) Necessary for Landscaping 5 b)( 1) Shoreline Dependent Facility 5 b)( 2) Public Interest Standard 5 3)( 3) Hardship Standard 6

C) Description of the Subject Property 7 Property Location 7 Onsite Property Structures/ Amenities 8 Property Topography 8 Existing Property Uses 8

D) State/ County Community Plans& Designation 9 E) Special Management Area Objectives& Policies 9

F) Surrounding Zoning and Land Uses 9 G) Flood Insurance Rate Map( FIRM) Designation 9 H) Archaeological Resources 9

I) Flora and Fauna Resources 9

1) Valued Cultural Resources 10

K) Public Access to the Shoreline 10

L) Description of General Property Access 10 M) Traffic Impacts 10

N) Availability of Utilities 10

Flood Hazzard Assessment Report Map 11 Jobsite Access Photos 12

Project Site Pictures 13

Project Location Photos 14 SHORELINE SETBACK VARIANCE APPLICATION COUNTY OF HAWAII For AOAO KONA REEF, INC. TMK: (3) 7- 5- 018: 071

A) Final Environmental Assessment Summary The Final Environmental Assessment ( FEA) for the proposed erosion abatement project was submitted to and accepted by the Hawai' i County Planning Department. The FEA received a Finding of No Significant Impact, ( EONS!). No sensitive cultural, biological, hydrological, archaeological, or other important resources are present on the project site. The proposed project will not negatively impact or alter the pre-existing physical characteristics, views, or ambiance of the property or the surrounding areas. The completed project will not adversely impact shoreline processes and has very little potential to cause long-term adverse impacts or to cause adverse cumulative or secondary impacts to the immediate or surrounding areas. The evidence to support this statement of non-effect can be found on pages 34, 35 & 36 of the FEA under Determination, Findings and Reasons. The FEA supports the project as the best defensive alternative available for this site.

B) Detailed Project Description Proposed Project: AOAO Kona Reef, Inc. proposes to build a continuous 220- foot-long concrete-rubble masonry CRM) wall within the 40-foot shoreline setback area of their property. The primary purposes of the wall are for erosion abatement reasons and to protect the Kona Reef property from the damages that hurricane storm waves and tsunami surges can wreak and thereby prevent the ensuing massive pollution of the ocean environment. All construction would take place entirely on Kona Reef' s private property above the State Certified Shoreline. The structure is not meant to serve as a seawall to deflect wave energy or to hold soil in place against the eroding, action of waves. The proposed project will not alter existing physical characteristics, views, or ambiance of the property or the surrounding areas. It also will not adversely impact shoreline processes and has very little potential to cause long- term adverse impacts or to cause adverse cumulative or secondary impacts to the immediate environment or surrounding areas.

Included under this application and the variance application AOAO Kona Reef, Inc. is seeking to retain, permit and cause to be recorded building and CRM wall encroachments into the same shoreline setback area. These new encroachments were revealed after a 40- foot setback line was drawn onto a current shoreline survey map. A copy of that survey map is included with this application package.

Project Site: The proposed project site is the 3. 1- acre Kona Reef Condominium Complex property. It is a 40- year-old 100% built out condominium complex. The project will be confined to the southern half of the roughly 430-foot long strip of the complex' s oceanfront lawn. The adjoining offshore area is an exposed shelf of overlapping pahoehoe flows that extend randomly into the ocean. To the north of the project area is a long- standing private residence, adjacent to the south is Hawaii County' s Wai' aha Beach Park, better known as Honl' s Beach. Improvements to this shoreline setback area which encompasses the project area are as permitted by Hawaii County Shoreline Setback Variance# 610. A supplementary recorded agreement to Variance # 610 clearly delineates the dedicated public shoreline access for this area. Copies of both are inclusions with this application.

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The red line indicates proposed project area. Wai' aha Beach Park is on the right and a private residence is on the far left toward the bottom with a vacant concrete slab at the upper left.

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LANNAAWN

Proposed project property and immediate surrounding area.

Structure Dimension Details: The project will be an engineered concrete- rubble masonry ( CRM) wall. The proposed wall, when finished, will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches, and be 12 to 18 inches wide across the top. The concrete foundation of the wall will be 12- inches inland of and run roughly parallel to the certified shoreline making the top of the wall a little farther inland because the ocean face of the wall slopes inward.

2 Structural Caveat: As with all construction projects that include excavation, unseen onsite conditions can require adjustments to the physical dimensions of the project. The above- stated dimensions are cited as variables because they will vary at different points along the length of the project to maintain design specifications. The structures final dimensions will depend entirely on the depth needed to achieve solid foundation anchoring. The following example picture taken from the Archaeological Inventory Study shows a depth range to solid anchoring from 50 to 130 centimeters or about 19- 1/ 2 to 51- 1/ 4 inches. These depths do not include any depth for the actual solid anchoring. If further explanation is needed please request it. Any adjustments to the wall' s size beyond the stated parameters will be submitted to and vetted by appropriate agencies and/ or individuals before being implemented.

1__® y

Archaeological Inventory Study test hole depth examples for demonstration of the need for using parameters when stating dimensions of the CRM structure.

Project Objectives: The objectives of this project are: To as permanently as possible stabilize, preserve, and protect this very valuable and popular one- of-a- kind public shoreline recreational asset without hindering the shoreline processes or shoreline access in any way. To stop current and prevent future pollution of the ocean and shoreline environment resulting from natural forces and human carelessness. To defend landscaping improvements, structures, and buildings from destructive ocean intrusions which are guaranteed to happen and cause huge unrecoverable shoreline and property losses. To prevent financial hardships created by the loss of or damage to property and structures. To incorporate all possible mitigation measures needed to assure an environmentally justifiable structure, be site specific, be aesthetically pleasing, and maintain all existing uses of this area. To reduce liability concerns related to potential personal injuries that may generate litigation against the property owners, the State, and the County.

The AOAO would also like to retain, permit and cause to be recorded encroachments into this same setback area that were discovered after a setback line was added to the shoreline survey.

3 Reasons for Request: The Kona Reef AOAO' s foremost fiduciary duty to its owners is to safeguard their property and financial interests. It also has a moral obligation to everyone to prevent environmental pollution and to protect the community' s property interests and finances.

Currently small quantities of topsoil and the underlying fill are being dislodged from a few small areas where the seaward face of the lawn is exposed. In these open- faced areas the wind, rain, animals, and humans loosen the material and then transport it into the ocean environment. These areas are also very vulnerable to tsunamis surges and hurricane produced waves.

Tsunami surges and hurricane waves have caused extensive damage to this shoreline area and the Kona Reef buildings in the past. Major ocean intrusions will inevitably batter this shoreline area again. Any one of which could very easily undercut inland structures and buildings at the south end of the property where the underlying fill is deepest. The proposed CRM wall is crucial for protection against these expected events that can and will eventually cause millions in damage and may even leave some buildings uninhabitable and in need of demolition. Even if all structures did remain intact, hundreds of cubic yards of fill materials would still wash into the ocean causing massive pollution of the environment and the loss of huge sections of the lawn area. Kona Reef should not have to go through another series of protracted processes to repair avoidable damages,( if indeed they would be repairable at all), that should not have been allowed to happen and that can effectively and sensibly be addressed now.

The AOAO must act to protect their property as well as that of others from major financial losses resulting from rogue natural occurrences. Any losses to Kona Reef property value will have a ripple effect on all Kona properties because comparable sales in the market area are used for appraisals of other properties. Lower property values would negatively impact Hawaii County property tax revenues. The loss of rental income from the Kona Reef property would also greatly affect State and County tax intake.

AOAO Kona Reef, Inc., Hawaii County, & the State have liability concerns because the entire oceanfront lawn and shoreline area is allowed to be accessed and used by everyone for almost any purpose. The ADAC, believes this project is a required preventive measure toward decreasing the threat of unknown liabilities stemming from accidental personal injuries that may occur.

The proposed structure is vital for the protection and preservation of this popular, well- used and legally improved shoreline lawn area fronting the complex. The project is crucial for the protection of the very vulnerable inland buildings and structures from predictable catastrophic ocean intrusions. In addition, it would prevent needless pollution from entering the ocean environment and causing death and damage to sea life. Although the lawn area that encompasses the project is Kona Reef private property, it is now and always has been maintained by the AOAO Kona Reef, Inc. as a public amenity and asset.

The request for retention and recorded documentation of shoreline setback encroachments is based on them being legally built during the complex' s original construction. Prior encroachments into this setback area are as documented and recorded as part of Hawaii County Shoreline Setback Variance# 610. The newer areas of encroachment are mainly due to the moving of the shoreline to coincide with the newest shoreline location definition and not because of any major shoreline deterioration or loss.

4 No construction equipment or wall material will be stored in the setback area overnight. Materials deliveries will be restricted to what is needed to cover each day' s needs and stockpiled in the project area in this way only. All construction materials used in this project will be for site specific usage while meeting structural and design standards. Some loose construction materials i.e. mortar sand, excavated fill and soil etc. may get blown around by strong winds. All such materials will be continuously watered down and/ or covered with tarps.

Structure: The project will be an engineered concrete-nibble masonry( CRM) structure. It will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches, and be 12 to 18 inches wide across the top. As with all construction projects that include excavation, onsite conditions can require adjustments to the physical dimensions of the project. The above- stated dimensions are therefore cited as variables because they will vary at different points along the length of the project to maintain design specifications. The structures final dimensions will depend on the depth needed to achieve solid foundation anchoring. Any adjustments beyond the stated parameters will be properly submitted to and vetted by appropriate agencies and/ or individuals before execution. A few well- used spots for traversing the shoreline may pose safety problems because of elevation changes from the lawn above to the offshore area below. The public' s safety may necessitate adding a step to the makai side, above the certified shoreline, of the CMU wall in one or two of the areas that are used the most for crossing back and forth. The need for steps will not be determined until onsite structural conditions are measured and the actual height difference has been established. Another major area of concern is on State Land makai of the certified shoreline at the south end of the property. Hurricane generated waves washed away a large section of land and produced a drop- off area that currently presents an ongoing major safety problem. This area most likely will require a safety railing be added to the top of the CRM structure for public safety and liability concerns. If either of these changes is needed to protect life and limb, they will be properly vetted and approved before implementation.

Objectives: The main objectives of this project are: To stop current and prevent future pollution of the ocean and shoreline environment resulting from natural and other forces. To protect landscape improvements, structures, and buildings from destructive ocean intrusions which are guaranteed to happen and almost certainly will cause huge unrecoverable shoreline and property losses. To prevent financial hardships created by the loss of and damage to property and structures. To reduce the potential for personal injuries that may generate litigation against property owners, the State, and the County. To cause encroachments into this shoreline setback area to be permitted and recorded.

Reasons: The Kona Reef AOAO' s foremost fiduciary duty to its owners is to safeguard their property and financial interests. It also has a moral obligation to everyone to prevent environmental pollution and to protect the community' s property interests and finances.

Currently small quantities of topsoil and the underlying fill are being dislodged from a few small areas where the seaward face of the lawn is exposed. These areas were well protected by CMU walls for 30 plus years until a tsunami surge dislodged some sections and the State DLNR ordered the rest of the protective barriers removed as a requirement for them to certify a new shoreline survey. In these open- faced areas the wind, rain, animals, and humans loosen the material and then transport it into the ocean environment. These small losses will accumulate and do more and more damage to the lawn area while producing more and more preventable ocean pollution.

3 Major ocean intrusions will inevitably batter this shoreline area again. Just one could very easily undercut inland structures and buildings at the south end of the property where the underlying fill is deepest. The proposed CRM wall is crucial for protection against these expected events that would cause millions in damage and may even leave some buildings uninhabitable and in need of demolition. Even if all structures did remain intact, hundreds of cubic yards of fill materials will still wash into the ocean causing massive pollution of the environment and the loss of this valuable and much- loved mecca of shoreline recreation. A prime example of expected damage is seen in the pictures below. Waves generated by Hurricane Barbara in July 2019 washed a large section of State land out to sea.

Damage received from Hurricane Barbara waves July 2019 The AOAO must act to protect their property as well as that of others from financial losses regardless of causation. The most likely source of major financial losses is from ocean generated damages. Any losses to Kona Reef property value will have a ripple effect on all Kona properties because comparable sales in the market area are used for appraisals of other properties. Lower property values would negatively impact Hawaii County property tax revenues. The loss of rental income from the Kona Reef property would also greatly affect State and County tax intake.

AOAO Kona Reef, Inc., Hawaii County, & the State have liability concerns because the entire oceanfront lawn and shoreline area is allowed to be accessed and used by everyone for almost any purpose. The AOAO believes this project is a required preventive measure toward decreasing the threat of unknown liabilities stemming from accidental personal injuries that may occur.

The request for retention and recorded documentation of shoreline setback encroachments is based on them being legally built during the complex' s original construction. It would cause an extreme unwarranted hardship to require the demolition of structures and 4 story buildings in order to comply fully with the 40- setback restriction. Prior encroachments into this setback area are documented and recorded as part of Hawai' i County Shoreline Setback Variance # 610. The newer areas of encroachment are mainly due to the moving of the shoreline to coincide with the newest shoreline location definition and not because of any major shoreline deterioration or loss.

4 This project may not completely resolve the at-risk shoreline situation because no one can predict the power of natural forces. It does however address them with an appropriate solution that just may temper or avoid catastrophic results. It would be inexcusable to sit back, do nothing, and wait for preventable disastrous consequences to occur. The logical, intelligent, common sense answer is to build this well vetted, environmentally neutral, modest mostly unseen structure as protection against destructive inevitabilities. No one plans to fail, but we do not want to assume the risk that comes with failing to plan and take action. Kona Reef should not have to go through another series of protracted processes to repair avoidable damages, ( if indeed they would be repairable at all), that should not have been allowed to happen and that can effectively and sensibly be addressed now.

8- 10 Criteria for Approval of a Variance In referencing The Hawaii County Planning Commission' s Rules of Practice and Procedure Rule 8- 10 the proposed CRM structure can fall under multiple categories of justifications necessary for its approval. The obvious and overwhelming reasons for approval are, 1. This project is vital for the protection of structures, buildings, landscaping improvements, and the environment. 2. Completion of this project will benefit and is in the best interest of the entire community because this area is a well-used and enjoyed public recreational and shoreline access area. 3. Without this preventative action Kona Reef property owners will without doubt suffer the hardships of unrecoverable property damage and financial losses. The project is not contrary to the purpose, reason, or the intent of the rules and regulations governing projects in the SMA and shoreline setback area. Rule 8- 10 is met in spirit and compliance by every aspect of this project. a)-( 3) Necessary for Landscaping: A Settlement Agreement recorded on 1/ 04/ 1985 by and between AOAO Kona Reef, Inc. and Hawaii County regarding the status of and responsibility for the maintenance of the shoreline area fronting the Kona Reef contains the following statement: " The Association covenants and agrees to assume exclusive responsibility for the maintenance of said public access areas as part of the common elements of the Kona Reef Condominium project for as long as the Association shall remain in existence." Completion of the proposed project is mandatory for the AOAO to continue to conscientiously meet the requirements of the stewardship given to them by this agreement. b)-( 1) Shoreline Dependent Facility: The AOAO Kona Reef, Inc. considers their property to be a shoreline dependent facility because it is dependent on its location for its financial well-being, property values, recreational opportunities, and its all-around popularity with resident and tourist alike. The Reef complex was built because it is location dependent. The proposed project is critical for the future preservation of the Kona Reef Complex' s financial security. lb)-(2) Public Interest Standard: The preservation of this valuable and popular public amenity adjacent to the ocean is a significant justification for the approval of this project. This project is being undertaken for the benefit of and in the best interest of the public as well as the Kona Reef owners. The entire shoreline area fronting the Kona Reef is always open to the public for their unimpeded use. It provides ease of access to the shoreline, the ocean, and the large explorable offshore pahoehoe shelf for everyone including the disabled. It is within close walking distance to town for tourists and many residents. The area is a valuable community asset and amenity because of what it is, where it is, and the recreational opportunities it provides for everyone. The preservation of this area and the protection of the environment is important to everyone. The project will secure and enhance access to the ocean and shoreline area now and long into the future.

5 b)-( 3) Hardship Standard: The improved shoreline area of the Kona Reef property is slowly being lost to preventable wear and tear. The likelihood of a large section of this area being lost all at once due to an ocean intrusion is a given without some form of defensive measure. The needless loss of this community asset would be inexcusable and an extreme unnecessary hardship for both the public and the Kona Reef property owners. The threats to property and financial security cited in the 1981 shoreline setback variance approval are the same threats present today that we are proposing to address with this project. The following was the position of the Hawaii County Planning Department in 1981when approving Shoreline Setback Variance# 610, ( attached to this application); That the retention of portions of the existing concrete-masonry wall along the shoreline will provide additional protection to the existing residential units and along the Kona Coast. It is therefore determined that the denial of these improvements may increase the potential of storm wave damage to the subject area and therefore will constitute an undue hardship to the petitioner."

b)-( 3)-( A) structure or activity may be granted a variance upon grounds of hardship only if: 0) The loss of the landscaping improvements in this area would assure the loss of most of the usefulness of the area for the owners and the public. No protective structure means eventually no fill or soil which means no green recreational playground for anybody. ii) The circumstances are: What do you do if you have something of great recreational and economic value that is beneficial and enjoyable for everyone but can be lost forever by inaction? Do you act to save and protect it because it is the best thing to do for the community and environment? Or do you pass on the proposed harmless solution to prevent its loss when it is known that the worst- case scenario is unquestionably disastrous for all? iii) AOAO Kona Reef, Inc. is proposing this project in the best interests of everyone financially, environmentally, recreationally, historically, aesthetically, and with the safety of the public in mind. O This desired CRM wall project is the only vetted solution that addresses the ever- present probability of extensive damage to the environment and/ or the destruction of property from invasive ocean events and human- generated deterioration.

b)-( 3)-( B) The current use of the land containing the project site is not going to be altered or changed in any way. The PEA addressed all shoreline and project area environments, including flora& fauna, archeological & cultural significance, public & private use of the land, erosion, surf & flood conditions, and the geography of the lot as it relates to the health and safety of the public and the environment in the projects immediate& surrounding area. The proposed project is the best possible and only viable solution that will help to protect from hardships created by ocean anomalies.

b)-(3)-( C) The intended purpose of the CMU structure is not to artificially fix the shoreline. It is meant as defense against the threat of damaging ocean intrusions. That being said, it would be irrational and naïve to think that at some point in the future some areas, if not all, of the CRM wall will not serve in this capacity. The project' s shoreline location is highly vulnerable to damages by tsunamis surges and/ or hurricane storm waves which may cause the loss of materials on the ocean side of the structure. Not building the project would be assuring valuable shoreline loss, extreme ocean pollution, the death of some ocean life, and possible financial ruin for some property owners It is evident that without the desired project extreme hardship and environmental disaster is very real and can happen in an instant at any time.

6 b)-( 3)-( D) Hardship not determined by Zoning amendments, PUD' s, and CDP' s etc.: This is non-relevant or applicable to this project or its approval in any way. c) No variance shall be granted unless appropriate conditions are imposed as applicable: 1) The proposed structure will comply fully with Chapters 10 and 27 of the Hawaii County Code pertaining to Erosion and Sedimentation Control and Flood Control. The design and the finish height of the project preclude it from adversely impacting, altering, or affecting the existing flood plain or sedimentation control areas. It will be built entirely above the certified shoreline on private property and not encroach on the shoreline or offshore areas.

2) This project will preserve and protect shoreline and ocean access for everyone. It will make it easier and safer to negotiate the area laterally by improving places where instability currently exists.

3) " Appendix E" of the FEA is " Geological and Marine Factors That Affect Shoreline Erosion" by Geohazards Consultants International, INC. The study states under its Conclusions": No significant erosion of the shoreline fronting the Kona Reef Condominiums has taken place in historical time, although global sea-level rise and continuing subsidence of Hawaii Island could result in inland migration of the shoreline over the next century. That erosion can be mitigated by the construction of a low stone wall (Erosion Abatement Structure) immediately mauka of the shoreline. Such a structure would have no negative environmental impacts or effects on adjoining coastal areas."

4) The inevitability of major shoreline loss and likely damage to structures which will create financial chaos along the shoreline is a principal reason for requesting this project. Eventually, tsunami or hurricane storm waves will again batter the shoreline with unknown results. Structures and buildings could easily be undercut and become useless. This project is the only vetted and logical solution that addresses the ever- present threat of extensive damage to or destruction of property from ocean intrusions. The project is in no way a guarantee that it will completely protect against the inevitable, but it does fall within the guidelines of permitted solutions that can be built.

5) The project will not adversely impact public views too, from, or along the shoreline because it will be no higher than the height of the existing lawn at any point and be completely covered for most of its length. Any areas of the wall that may be seen from anywhere along the shoreline or from offshore will blend with the colors and textures of the offshore pahoehoe shelf. The wall' s primary material will also aid in camouflaging it and is the material most used for the same purpose along the Kona Coast and everywhere in the state. Lastly, just trying to be practical, with such a great view of Kailua Bay, boats, the coastline, the ocean, the mountains, whales, dolphins, yellow tang and turtles riding in the face of the surf, etc. why would you dwell on a CRM wall that is flush with the ground?

C) Description of the Subject Property Property Location: The Kona Reef Condominium Complex' s street address is 75- 5888 Ali' i Drive, Kailua- Kona, HI with the TMK:( 3) 7- 5- 018: 071. It is about 1 mile south of the Kailua Pier on the ocean side of Alii Drive. Its multi- storied masonry buildings are a light creamy tan color with blue barrel tile roofing and blue wood trims. Kahakai Road which intersects with Ali' i Drive and runs west toward the ocean is the border for most of the property' s northern face. A long-standing single- family home along the shoreline completes the north facing property line. War aha, aka Honl' s, Beach Park is the adjacent property on the south. The property boundary on the east is Ali' i Drive and on the west, it is the Pacific Ocean.

7 Onsite Property Structures/ Amenities: There are 6 interconnected multi- storied masonry buildings, ( labeled A thru F in the photo below) on the property that contain a total of 130 residential units. One building, ( F) is 5 stories high with 3 upper floors of residential units and 2 lower floors of enclosed parking. The remaining 5 buildings are 4 stories high and contain only residential units. Other onsite structures include a small wood frame-gazebo, a small office building, and a multi- purpose central courtyard building which contains a restroom, pool equipment room, and a covered grilling area. Other amenities are, a freshwater swimming pool with a corresponding spa, a large oceanfront lawn with 2 small side yards, 2 uncovered asphalt paved parking lots, and 2 large open- air decks, and some wood privacy fencing along Ali'i Drive. Numerous CRM walls of different sizes and heights are dispersed throughout the complex. The property is landscaped throughout with introduced tropical shrubs, plants, trees, and grasses designed to create a tropical atmosphere.

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Condo ? Y tirA` Gr ch. <, Kona Reef buildings and amenities layout. Ali' i Drive is at the top of the photo and Kahakai Road is on the left side between the complex and the vacant concrete slab. Waiaha, ( Honl' s) Beach Park is on the right. The dedicated shoreline access is from the left side of building" D" where the gray sidewalk near the palm trees can be seen. Property Topography: The Kona Reef Condominium Complex is a roughly 3. 1- acre shoreline parcel. The property' s 6 main buildings have a ground floor elevation of approximately 9'- 6" above sea level. The general topography of the site is that of the typical Ali' i Drive resort complex with the buildings forming a" U" around a central courtyard area,( see above photo). The swimming pool, spa, and barbeque area are the centerpieces of the courtyard area. There are multiple CRM walls dispersed throughout the property that serve structural, privacy, safety, landscaping, and elevation change purposes. These walls enable the complex' s multiple levels to blend with the slope of the land to create an accessible and aesthetically pleasing design. The landscaping is introduced tropical shrubs, plants, trees, and grasses. The current topography and property layout/design will not be altered or affected in any way by the proposed project.

Existing Property Uses: The property usage is a mixture of owner-occupied residences, long term lease tenants, and resort vacation rentals. All structures and uses conform to all applicable state and county regulations. Completion of the project will not alter or change the current usage in any way.

8 jD) State/ County Plans, GPD, CDP The Kona Reef property is located in the Special Management Area (SMA) along the shoreline. It is designated Urban by the State Land Use Commission. Hawai' i County zoning is Resort Hotel V-. 75). The County of Hawai' i LUPAG, ( Land Use Allocation Guide) Map dated October 2015 designates this parcel as Resort Node and Open along the shoreline. There are no conflicts with the objectives & standards of any County of Hawaii or Kona Community Development Plans.

E) Special Management Area Obiectives & Policies The project will be compliant with Hawaii Revised Statutes, HRS Chapter 205A SMA ( Special Management Area) objectives & policies. It would not adversely affect historic, scenic, open space resources, economic uses, public access to recreation areas or create any coastal hazards.

F) Surrounding Zoning and Land Uses The property and the surrounding area are designated as high- density urban. The proposed project will not alter or change this in any way. Next door to the south is Hawaii County' s Waiaha aka Honl' s Beach Park. To the north along the shoreline is long- standing single-family residence. A large abandoned concrete slab for another development that is in limbo is also next door to the north across Kahakai Road from the complex' s main buildings. The Ali' i Cove residential complex is on the mauka side of Ali' i Drive across from the Kona Reef.

G) Flood Insurance Rate Map( FIRM) Designation The FEMA FIRM ( Flood Insurance Rate Map) Panel: # 1551660738F designates the area of the project site as Special Flood Hazard Area Zone AE, with a base flood elevation of 10- feet, and Zone X for surrounding areas mauka of the site. The shoreline area seaward of the project is designated as Zone V.

H) Archaeological Resources Haun & Associates Archaeological, Cultural, and Historic Resource Management Services were retained to perform an Archaeological Inventory Study( AIS) to evaluate the potential for subsurface resources that may exist in the immediate project site area. That AIS is" Appendix D" in the FEA. The site is assessed as significant for its information content. It has yielded information important for understanding prehistoric habitation in the area. The documentation of the Site 30493 cultural deposit adequately records it and no further work or preservation is recommended because the disturbed nature of the deposit precludes the potential to obtain additional archaeological information."

I) Flora and Fauna Resources Appendix F" of the FEA is the flora& fauna study for the project site. The project completion will cause minimal, if any, consequences or changes to the existing environment. 4. 11 Discussion of Plant Resources All of the plants within the project site are very common species that have no importance for the conservation of Hawaiian biodiversity. These plants are valuable for the stabilization of the soil and for the aesthetic values provided to the people who use the area. 4. 12 Recommendations for Plant Resources The plant life on the project site should be maintained or replaced after construction to minimize soil erosion and to preserve the recreational and esthetic values of the area. 4.22 Recommendations for Terrestrial Animal Resources No discernible adverse impact on terrestrial animals is anticipated. No recommendations are made.

9 4.32 Recommendations for Marine Resources Best Management Practices and all other necessary actions should be taken to ensure that no soil, fill or any other material from the proposed action enters the waters of the Pacific Ocean. Marine mammals and turtles should not be disturbed or harassed in any way. It is recommended that the US Fish and Wildlife Service be notified if any such animals are seen near the project site.

J) Valued Cultural Resources The proposed project will not affect or infringe on any native Hawaiian rights. As part of the FEA investigative process, Hawaiian cultural organizations including the Kona Hawaiian Civic Club and the Office of Hawaiian Affairs were contacted to request information concerning cultural uses of a more expansive area surrounding the Kona Reef property. No responses were received. The area does not contain evidence or support for any traditional gathering uses and is not vital for access to traditional cultural sites. The gathering of ocean resources,( fishing, etc.) and numerous ocean and other sports activities occur regularly in the project vicinity. The proposed project will not affect or infringe on these or any native Hawaiian rights.

K) Public Access to the Shoreline Public shoreline access is maintained as per a" Settlement Agreement" between Hawaii County and AOAO Kona Reef, Inc. Access is through the north- facing side yard off Kahakai Road. A gravel walkway passes through an opening in a rock which leads to lateral access for the entire length of the shoreline area fronting the property. Access is always open, easily accessible, diligently maintained, and extensively used. Hawaii County' s War aha Beach Park is the open-access point from the south. No access is available to the public which would include traversing the interior confines of the Kona Reef Condominium Complex itself. The CRM wall will help to preserve and protect the existing dedicated shoreline access area.

L) Description of General Property Access The only vehicle access points onto the property are off Alii Drive and Kahakai Road. Alii Drive and Kahakai Road are both paved county- maintained roads. From Ali' i Drive there is access into a semi-enclosed parking garage at about the mid-point of the property. Kahakai Road has access to upper and lower parking lots that are adjacent to the buildings with the lower parking lot being the access for a first- floor parking garage. Foot traffic access is through any of the parking areas. Shoreline access is from War aha Beach Park on the south or Kahakai Road on the north.

M) Traffic Impacts The project has no potential whatsoever to impact traffic flow, density, or patterns in any way.

N) Availability of Utilities The property is serviced by underground connections to all publicly available utilities. There are and will be no public utilities installed along the shoreline or in the vicinity of the project area.

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Photo is taken from near the northern end of the proposed erosion wall looking south. It will Start near where the south end of the sun bather on the right.

Project will be built on the mauka side of coconut palms and be buried completely allowing the lawn to grow over it and completely hide it from site except in a very small area at the far end in this picture.

13 These pictures were taken from the State Certified Shoreline Survey submission to the State DLNR. The red line is the shoreline/ survey line. The seaward face of the proposed CRM wall will be approximately 12" inland from this line.

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111 n+wkyyty l ' f AOAO Kona Reef. Inc. 75- 5888 Alii Drive, Kailna-Kona, Hawaii 96740 4808) 430-8659 Fart( 808) 333-5714

County of Hawaii Planning Department September 15, 2020 101 Pauahi Street, Suite 3 Hilo, HI 96720 808) 961- 8288

RE: Summary of Special Management Area Use Permit Application Filings& Permits AOAO Kona Reef, Inc. TREK:( 3) 7- 5- 018: 71

To Whom It May Concern;

On Iune 15, 2020 a Sprrial Management Area Use Permit Assessment Appjjyation in conjunction with a Shoreline Setback Variance Application was submitted to the Hawaii County Planning Department. The SMA Assessment Application was rejected by Planners and returned with instructions that a Special Management Area Use PermitApp iratinn was requireth

As part of the SMA Use Permit Application filing it was stated to me that I was to write a letter explaining and justifying the County Planning Department' s decision to require a Major SMA. The letter is to contain information concerning past and future Planning Department SMA filings and permits I do not clearly understand what is being demanded ofme. This information is already included in the FEA for the proposed project in an easy to read list on pages 20 and 21. Ergo this letter is a summary of information relating to SMA flings rotative to my minimal understanding of the demand.

Researchinto county files found approximately 18 consequential Planning Department filings have been made for the Kona Reefproperty since its construction in 1981. From 1981 until 2011 there was no evidence of any filings except for mm's that wererelated to the development's original construction- Since 2011 there have been about 7 Minor SMA Permits issued. Most of the 7 permits that were issued were for repairs, replacements and general maintenance projects. This makes perfect sense since most larger repairs and maintenance projects don'tnormallyneed to be done tonew buildings andstructures, but for 230 to 40- year- old development this would be standard. One of the permits issued was for a roof top solar electric panel installation and its peripherals and one other was for the installation of 1OAC units. Quite a few of the Planning Department filings are just simply overlapping submicsions pertaining to the same project or request. Numerous filings, which account for a few of the overlapping submissions were for State mandated actions along theshorelinerelating to chnreline survey certification&

In reference to all future filings with the Planning Department, including SMA filings, it can only be said with perfect candor," There will be future filings for upgrades, repairs, replacements and maintenance to this 40-year-old condominium property, its structures and other amenities_"

Se Raymond S Pieri Project Manager 73- 4642 Uluwehi Place Kailua-Kona, HI 96740 pierir001 @hawaiirr.com 808) 989- 7439 CU PLANNING DEPT SEP 25 2020 pw3: 0B SPECIAL MANAGEMENT AREA USE PERMIT APPLICATION

COUNTY OF HAWAII PLANNING DEPARTMENT Type or legibly printthe requested information}

APPLICANT: AOAO Kona.Reef, Inc.

y7 / APPLICANT S SIGNATURE: x EJ la}/'DATE: Sri, / 7 r 2i2 layU ADDRESS: 75- 5888 AlfAi Drive, Kailua- Kona, HI 96740

C/O: Hawaiians Management Company, Ltd.

Palani Court Suite 215, 74- 5620 Palani Road, Kailua-Kona HI 96740

LIST APPLICANT S INTEREST IF NOT OWNER:

LIST PRINCIPAL(S) INCLUDING NAMES OF MAIN OFFICERS: William M. Armer Jr. President, AOAO Kona Reef, Inc. Board. of Directors.

PHONE:( Bus.) ( 808) 896- 4535 Res.) Fax)

LANDOWNER(S): AOAO Kona Reef, Inc

6t4Ac J LANDOWNER SIGNATURE( S): x J r.'!(bi/4/9 4 ./fie DATE: St 19, 7.0( May be by letter) l/ LANDOWNER( S) ADDRESS: 75- 5888 Alii Drive, Kailua-Kona, HI 96740

C/ O: Hawaiian Management Company. Ltd.

Palani Court Suite 215, 74- 5620 Palani Road, Kailua-Kona, HI 96740

REQUEST:.Permission to construct anerosion abatement/protective CRM( concrete rock masonry) wall approximately 1- foot inland of the State Certified Shoreline within the 40-foot shoreline setback area of the existing oceanfront lawn.

TAX MAP KEY: ( 3) 7- 5- 018- 071 ZONING: Resort Hotel V-.75

SJZF OF PROPERTY OR AFFECTED AREA( S): Project area is less than 1, 000 sq. ft- Property is approximately 3.08 acres

AGENT: Raymond S. Pieri.

ADDRESS: 73- 4646 Uluwehi Place, Kailua-Kona HI 96740

Finaa• pierir00I4ihawaiLrr.com

TELEPHONE:(Bus.)( 808) 989- 7439 Res.) N/A Fax) NONE

Pince indicate to whom original correspondence and copies should be mnt).

ORIGINAL:.Raymond S. Pieri COPIES_Raymond.S. Pieri Special Management Area Use Permit Application AOAO Kona Reef, Inc. TMK: (3) 7- 5- 018: 71

SUBJECT: Best Management Practices September 15, 2020 Kona Reef Shoreline Project

Best Management Practices ( BMPs) are of significant concern and have been incorporated as a key part of the construction plans for the AOAO Kona Reef, Inc' s shoreline project. Close monitoring of all activities during all phases of the project' s construction will ensure strict adherence to BMPs, and all federal, state, and county procedures, rules, laws, or restrictions applicable to construction in this sensitive shoreline and ocean environment. If any adverse or harmful situations do arise, they would be very localized and immediately remedied. Work days and hours will depend on up-to-the minute environmental conditions. Excessive winds, heavy rains and possible problematic ocean conditions will all be factors in determining construction activities When any situation arises that may cause pollution of the ocean or the greater environment all work will come to a full halt until the situation ceases or has been corrected. All construction and supporting activities will be performed entirely above the shoreline except for the placement of silt screens and or sand bags as needed for ocean and environmental protection. No construction equipment, excavated material or wall material will be stored in the shoreline setback area overnight. The amount of materials in the project area at one time will be restricted to what is needed to cover one day' s needs. No stockpiling will occur. Only the trench area needed for a few day' s work will be excavated at a time and not the entire project area all at once. Excavated areas where the wall has been finished and inspected will be backfilled immediately. All construction materials used in this project will be eco-friendly and site sensitive while still meeting Cstructural and design standards. All trash, waste and other debris will be transported from the site daily and disposed of through proper channels. Some loose construction materials i. e. mortar sand, excavated fill etc. can get blown around and into the ocean by strong winds or washed into it with a heavy rain. All such loose materials will be continuously monitored and watered down when needed to prevent windbome particles or covered with tarps in rainy situations to prevent ocean polluting run off. Some construction equipment will contain small quantities of fuels, motor oils, and hydraulic fluids. Close monitoring of all equipment for leaks or spills will be a priority. Absorption materials will be kept onsite at all times. At no time will any faulty, leaky, or unmaintained equipment be allowed to operate or park on the subject property. No fuels, motor oils, hydraulic fluid, solvents, or other hazardous materials will be stored anywhere in the shoreline setback area or project vicinity. No refueling or maintenance on equipment of any kind will be performed in the project setback area. Construction activities are not likely to encounter any on site hazardous substances or toxic waste. Site conditions will be continuously monitored enabling immediate identification of any suspect or suspicious substances or conditions. If anything is found it will be reported to appropriate agencies and/ or dealt with immediately upon its discovery. The project will entail excavation in an area of possible valuable or important buried content. The Archaeological Inventory Survey' s information and its conclusions for the area indicate only a remote possibility exists for the finding of items of historic or cultural interest. But diligence is still required and the discovery of any unidentified sites or remains, such as artifacts, shell, bone or charcoal deposits, human burials, rock or coral alignments, etc. will require that all work stop immediately. The Planning Director or his office will be promptly notified. An archaeological clearance may be required which will ensure that necessary mitigative and correct procedural measures are taken to protect the discovery. Written guidance from the State Historic Preservation Division of the Department of Land and Natural Resources as to procedures for continued activity in the area will be solicited and conscientiously adhered to. SMA Use Permit Application AOAO Kona Reef, Inc, TMK: (3) 7- 5- 018: 071

Table of Contents: Project Summary 1

3. B. Detailed Description of Proposed Project 2

Description of Project Site 2

Construction Details 2

Structure Dimensions Details 2 Structural Caveat 2 Project Objectives 3

Reasons for Proposed Project 3 3. C. Description of Subject Property 4 Property Location 4 Existing Property Uses 4 Existing Structures & Amenities 4 Property Topography 5

3. D. Statement of Proposed Project Valuation 5

3. E. Relationship to Land Use Plans, Policies and Control 5 3. F. Objectives and Policies per Chapter 205A, HRS,& SMA Guidelines 5

Recreational Resources 5

Historic Resources 5

Scenic and Open Space Resources 6

Coastal Ecosystems 6

Economic Resources 6

Coastal Hazards 6

Public Participation & Input 6

3. G. Surrounding Area Zoning and Land Uses 7 3. H. Flood Insurance Rate Map Designation 7 3. 1. Historical/Archaeological Resources 7

3. J. Natural, Flora and Fauna Resources 7

Discussion of Plant Resources 7

Recommendations for Plant Resources 7

Recommendations for Terrestrial Animal Resources 7

Recommendations for Marine Resources 7

3. K Valued cultural resources 7

Native Hawaiian Rights and Actions to Protect All Relative Interests 8

3. L Public access to the Shoreline 8 3. M Description of General Property Access 8 3. N Traffic Impacts 9

3. O Availability of Utilities 9 4. A. Description of Environmental Setting 9 4. B. Relationship to Land Use Plans, Policies and Control 9

4. C. Probable Impact of Project on the Environment 9

4.0 Determination, Findings and Reasons ( FEA pages 34, 35, & 36 verbatim) 9 4.D. Impacts Which Cannot Be Avoided and Mitigating Measures 11 4.E. Alternatives to the Proposed Project 11

4. F. Mitigating Measures to Minimize Impacts 11 4. G. Any Irreversible and Irretrievable Commitment of Resources 11 Special Management Area Use Permit Application AOAO Kona Reef, Inc. TMK: (3) 7- 5-018: 71

Project Summary AOAO Kona Reef, Inc. proposes to build a continuous 220-foot-long concrete-rubble masonry CRM) wall within the 40-foot shoreline setback area of their property. The primary purposes of the wall are to stop the current small amounts of daily ocean pollution and shoreline loses, to protect the Kona Reef property from the damages that hurricane storm waves and tsunami surges can wreak, and to prevent a massive pollutive event of the ocean environment. This project may not completely resolve the at- risk shoreline situation because no one can predict the power natural forces can generate. It does however address them with an appropriate solution that just may temper or avoid catastrophic results. It would be inexcusable to sit back, do nothing, and wait for preventable disastrous consequences to occur. The logical, intelligent, common sense answer is to build this well vetted, environmentally neutral, modest structure as protection against destructive inevitabilities. No one plans to fail, but we do not want to assume the risk that comes with failing to plan and take

action.

All construction would take place entirely on Kona Reef' s private property above the State Certified Shoreline. The structure is not meant to serve as a seawall to deflect wave energy or to hold soil in place against the eroding action of waves. The proposed project will not alter existing physical characteristics, views, or ambiance of the property or the surrounding areas. It also will not adversely impact shoreline processes and has very little potential to cause long-term adverse impacts or to cause adverse cumulative or secondary impacts to the immediate environment or surrounding areas.

The project area is part of a rare recreational amenity and community asset that provides excellent shoreline and offshore access to everyone including persons with physical disabilities. Members of the public, Kona Reef owners and its residents, all use the improved lawn area which encompasses the project' s site for every recreational activity imaginable. The Ironman Triathlon, canoe races, surf meets, fireworks over Kailua Bay, etc... all draw large crowds to the area. Its well-maintained grassy lawn is a perfect location for them to relax and enjoy these events. It is also a popular place to enjoy the unobstructed Kona Coastline views north and south, watch sunsets, sun- bathe, see whales swimming and breaching, dolphins playing, catch a glimpse or sea turtles, and a large variety of sea life in its natural setting. Another very popular activity for just about everyone is exploring the offshore pahoehoe shelf. Wai' aha Beach Park, aka as Honl' s is next door and is accessed through this area for direct ocean access for swimming snorkeling etc.

AOAO Kona Reef, Inc. is applying for a new Shoreline Setback Variance( SSV) in conjunction with this SMA Use Permit Application filing. Some of the information included in this SMA Application is copied from the SSV Application and some from the Final Environment Assessment ( FEA) for this project. This complete application, the complete SSV Application, and the project' s FEA are on the CD-ROM disc that is included with this filing.

application package.

1- 3. B.) Detailed Description of the Proposed Project Description of Project Site: The project site property is the 3. 1- acre Kona Reef Condominium Complex property. The project will be confined to the southern half of the roughly 430-foot long strip of the complex' s oceanfront lawn. The adjoining offshore area is an exposed shelf of overlapping pahoehoe flows that extend randomly into the ocean. To the north of the project area along the shoreline is a long- standing private residence, adjacent to the south is Hawaii County' s Wal aha Beach Park, better known as Honl' s Beach. Improvements to this shoreline setback area which encompasses the project area are as permitted by Hawai' i County Shoreline Setback Variance 610. A supplementary recorded agreement to Variance# 610 clearly delineates the dedicated public shoreline access for this area. Copies of both are inclusions with this application.

Red line indicates the proposed project area. Wai aha Beach Park is on the right and a private residence is on the far left toward the bottom with a vacant concrete slab at the upper left.

Construction Details: The time needed to build the proposed project will be between 1 and 2 months. The duration of the project, the work hours and work days will depend entirely on up- to- the minute ocean and other environmental conditions. All construction and supporting activities will be performed entirely above the shoreline. The proposed CRM wall would be built on Kona Reef s private property approximately 1- foot inland of the Hawaii State Certified Shoreline. It would start near the southwest corner of the property and continue in a northwesterly direction along a path roughly parallel to the certified shoreline for approximately 220- feet. A large part of the wall will top out at a few inches lower than the lawn height and be backfilled from both sides over the top allowing grass to cover it completely. In the remaining areas it will be built to site dictated conditions and backfilled accordingly. At no point will the structure exceed the height of the existing lawn. Structure Dimension Details: The project will be an engineered concrete-rubble masonry ( CRM) wall. The proposed wall, when finished, will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches, and be 12 to 18 inches wide across the top. The concrete foundation of the wall will be I2-inches inland of and run roughly parallel to the certified shoreline making the top of the wall a little farther inland because the ocean face of the wall slopes inward.

Structural Caveat: As with all construction projects that include excavation, unseen onsite conditions can require adjustments to the physical dimensions of the project. The above- stated dimensions are cited as variables because they will vary at different points along the length of the project to maintain design specifications. The structures final dimensions will depend entirely on the depth needed to achieve solid foundation anchoring. If further explanation is needed please request it. Any adjustments to the wall' s size beyond the stated parameters will be submitted to and vetted by appropriate agencies and/ or individuals before being implemented. Project Objectives: The main objectives of this project are: To preserve and protect this very valuable and popular one-of-a- kind public shoreline recreational asset. To stop current and prevent future pollution of the ocean and shoreline environment resulting from natural forces and human carelessness. To defend landscaping improvements, structures, and buildings from destructive ocean intrusions which are guaranteed to happen and cause huge unrecoverable shoreline and property losses. To prevent financial hardships created by the loss of or damage to property and structures. To reduce the potential for personal injuries that may generate litigation against the property owners, the State, and the County. To cause encroachments into this shoreline setback area to be permitted and recorded.

Reasons for Proposed Project: The Kona Reef AOAO' s foremost fiduciary duty to its owners is to safeguard their property and financial interests. It also has a moral obligation to everyone to prevent environmental pollution and to protect the community' s property interests and finances. Currently small quantities of topsoil and the underlying fill are being dislodged from a few small areas where the seaward face of the lawn is exposed. In these open- faced areas the wind, rain, animals, and humans loosen the material and then transport it into the ocean environment. These areas are also very vulnerable to tsunamis surges and hurricane produced waves.

Tsunami surges and hurricane waves have caused extensive damage to this shoreline area and the Kona Reef buildings in the past. Major ocean intrusions will inevitably batter this shoreline area again. Any one of which could very easily undercut inland structures and buildings at the south end of the property where the underlying fill is deepest. The proposed CRM wall is crucial for protection against these expected events that can and eventually will cause millions in damage and may even leave some buildings uninhabitable and in need of demolition. Even if all structures did remain intact, hundreds of cubic yards of fill materials would still wash into the ocean causing massive pollution of the environment and the loss of huge sections of the lawn area. Kona Reef should not have to go through another series of protracted processes to repair avoidable damages,( if indeed they would be repairable at all), that should not have been allowed to happen and that can effectively and sensibly be addressed now.

AOAO Kona Reef, Inc., Hawaii County, & the State have liability concerns because the entire oceanfront lawn and shoreline area can be accessed and used by everyone for almost any purpose. The AOAO believes this project is a required preventive measure toward decreasing the threat of unknown liabilities stemming from accidental personal injuries that may occur. The proposed structure is vital for the protection and preservation of this popular, well- used and legally improved shoreline lawn area fronting the complex. The project is crucial for the protection of the very vulnerable inland buildings and structures from predictable catastrophic ocean intrusions. In addition, it would prevent needless pollution from entering the ocean environment and causing death and damage to sea life. Although the lawn area that encompasses the project is Kona Reef private property, it is now and always has been maintained by the AOAO Kona Reef, Inc. as a public amenity and asset.

3- The request for retention and recorded documentation of shoreline setback encroachments is based on them being legally built during the complex' s original construction. Prior encroachments into this setback area are as documented and recorded as part of Hawai' i County Shoreline Setback Variance# 610. The newer areas of encroachment are mainly due to the moving of the shoreline to coincide with the newest shoreline location definition and not because of any major shoreline deterioration or loss.

13. C.) Description of Subject Property Project Location: The Kona Reef Condominium Complex' s street address is 75- 5888 Ali' i Drive, Kailua-Kona, HI. It is about 1 mile south of the Kailua Pier on the ocean side of Ali'i Drive. Its multi-storied masonry buildings are a light creamy tan color with blue barrel tile roofing and blue wood trims. Kahakai Road which intersects with Ali' i Drive and runs west toward the ocean is the border for most of the property' s northern face. A long- standing single-family home along the shoreline completes the north facing property line. Wai aha, aka Honl' s, Beach Park is the adjacent property on the south. The property boundary on the east is Ali' i Drive and on the west, it is the Pacific Ocean.

Existing Property Uses: The Kona Reef Condominium Complex is a 40-year-old 100% built out residential complex. The property' s occupancy( usage) is a mixture of owner-occupied residences, long term lease tenants, and resort vacation rentals. All structures and uses conform to all applicable state and county regulations.

Existing Structures & Amenities: There are 6 interconnected multi-storied masonry buildings, labeled A thru F in photo), on the property that contain a total of 130 residential units. One building, F) is 5 stories high with 3 upper floors of residential units and 2 lower floors of semi- enclosed parking. The remaining 5 buildings are 4 stories high and contain only residential units. Other onsite structures include a small wood frame- gazebo, a small office building, and a multi- purpose central courtyard building which contains a restroom, pool equipment room, and a covered grilling area. Numerous rock walls are dispersed throughout the interior of the property and around its boundaries with some wood privacy fencing topping walls along Ali' i Drive. Other amenities are, a freshwater swimming pool with a corresponding spa, a large oceanfront lawn, 2 small side yards, 2 uncovered asphalt paved parking lots and 2 large open- air decks.

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Kona Reef buildings and amenities layout. Ali' i Drive is at the top of the photo and Kahakai Road is on the left side between the complex and the vacant concrete slab. Waiaha, ( Honl' s) Beach Park is on the right. The dedicated shoreline access is from the left side of building" D".

4. Property Topography: The Kona Reef Condominium Complex is a roughly 3. 1- acre shoreline parcel. The property' s 6 main buildings have a ground floor elevation of approximately 9'- 6" above sea level. The general topography of the site is that of the typical oceanside Ali' i Drive condominium complex with the buildings forming a" U" around a central courtyard area. The swimming pool, spa, and barbeque area are the centerpieces of the courtyard area. There are multiple CRM walls dispersed throughout the property that serve structural, privacy, safety, landscaping, and elevation change purposes. These walls enable the complex' s multiple levels to blend with the slope of the land to create an accessible and aesthetically pleasing tropical feeling design. The landscaping is introduced tropical shrubs, plants, trees, and grasses. The current topography and property layout/design will not be altered or affected in any way by the proposed project. 3. D.) Statement of Proposed Project Valuation: The dollar value of the proposed project is very easily estimated. The preservation of this popular recreational shoreline lawn area and the Kona Reef buildings and structures is immeasurable to the Kona Reef property owners and the community. The total cost of the proposed project will be between $ 225, 000.00 and $ 250,000.00 depending on currently unknown site conditions that cannot be assessed until actual construction has been started.

3. E.) Relationship to Land Use Plans, Policies and Control: The Kona Reef property is located in the Special Management Area ( SMA) along the shoreline. It is designated Urban by the State Land Use Commission. Hawaii County zoning is Resort Hotel ( V-.75). The County of Hawaii LUPAG, ( Land Use Allocation Guide) Map dated October 2015 designates this parcel as Resort Node and Open along the shoreline. Improving the project' s area to better safeguard and serve the publics interest' s is encouraged and does not conflict with the objectives& standards of any County of Hawaii or Kona Community Development Plans. The FEA has explained in detail the full compliance of the project to all State & County Plans. The County of Hawaii General Plan goals and policies applicable to the project are listed and discussed in depth starting on page 26 of the FEA.

J3. F.) Objectives & Policies per Chapter 205A, HAS, & SMA Guidelines: The project will be fully compliant with Chapter 205A, HRS, objectives and policies and Special Management Area guidelines. An in-depth account of these advices can be found in the FEA. The proposed wall would not adversely affect historic, scenic, open space resources, economic uses, public access to recreation areas or create any coastal hazards or public access to recreation areas.

Recreational Resources: The project site is a well maintained, large, flat, landscaped, shoreline lawn area used daily by the public, Kona Reef residents and visitors alike for every recreational activity imaginable. The proposed project is intended to protect and preserve this valuable public area from damage and/ or almost complete loss from disastrous ocean intrusions. It is in everyone' s interest to protect both the recreational use of the project site itself, and access to other recreational resources, including the adjacent shoreline, Honl' s Beach Park next door, and offshore areas used for surfing and water sports.

Historic Resources: An archaeological inventory survey of the project site has been completed and no sites appear to be present on the surface. The archaeological inventory survey identified a subsurface cultural deposit, and the site consisting of this deposit was assessed as significant for its information content only, and no further work or preservation is recommended. Scenic and Open Space Resources: The top of proposed structure would be no higher than the existing landscaped lawn surface. It would not obstruct views of the ocean or any other scenic areas. 1 Coastal Ecosystems: Any impacts to the coastal ecosystem would only be beneficial for the environment. The completion of the project would protect the ocean and near shore areas from needless small amounts of daily pollution and a foreseeable massive harmful pollution event. See Appendix " E" of the FEA compiled by John P. Lockwood from Geohazards Consultants International, INC. for verification of the above stated assertions and conclusions.

Economic Resources: There will be no adverse economic effects from the completion of this project. There are however economic considerations which pertain to loss of property, property value, and income. The project site is private property and is maintained by the AOAO Kona Reef as a public/ private shoreline recreational and access area. No action would allow this resource to be degraded over the long term and most likely be heavily damaged and / or a large section of it lost completely at some point. This project is vital for the economic security and protection of the community because any losses generated here will reverberate throughout the Real Estate market.

Coastal Hazards: The intended purpose of the CMU structure is not to artificially fix the shoreline. It is meant to stem human and elemental caused erosion and as a defensive measure against the threats of coastal ocean anomalies. The project' s shoreline location is highly vulnerable to damages and loss from tsunamis surges and/ or hurricane storm waves. Not building the project would be assuring valuable shoreline loss, extreme ocean pollution, the death of some ocean life, and possible financial ruin for property owners It is evident that without the construction of the project extreme hardship and environmental disaster is inevitable and can happen instantly at any time.

Public Participation & Proposed Project Input( copied herein from FEA): l ) 1. 4 Public Involvement and Agency Coordination The following agencies, organizations, and individuals have been consulted during the Environmental Assessment Process: County: Department of Public Works Planning Department County Council Mayor' s Office

Department of Parks and Recreation Fire Department Police Department Leeward Planning Commission State:

Office of Environmental Quality Control Office of Conservation and Coastal Lands Department of Land and Natural Resources( DLNR) State Historic Preservation Division Department of Health, Environmental Planning Office Office of Hawaiian Affairs—West Hawaii Division of Boating and Ocean Recreation Federal: United States Army Corps of Engineers Private:

Kona Hawaiian Civic Club Kona Outdoor Circle Adjacent Property Owners Surfrider Foundation Copies of the communications received during early consultation are contained in Appendix Al of the FEA. Comments to the Draft EA and responses to these comments are contained in Appendix lb. Specific portions of the Final EA have been modified to reflect comments received; amended or modified text is denoted by double underlines, as in these sentences.

6• 3. G.) Surrounding Area Zoning and Land Uses: The property and the surrounding area are designated as high- density urban. Next door to the south is Hawaii County' s Wai' aha aka Honl' s Beach Park. Adjacent to the north along the shoreline is long-standing single-family residence. Another development that is in limbo sits across Kahakai Road on the north also. The Ali' i Cove residential complex is on the mauka side of Ali' i Drive across from the Kona Reef.

3. H.) Flood Insurance Rate Map( FIRM) Designation: The FEMA FIRM( Flood Insurance Rate Map) Panel: # 1551660738F, included with this application package, designates the area of the project site as Special Flood Hazard Area Zone AE, with a base flood elevation of 10- feet, and Zone X for surrounding areas mauka of the site. The shoreline area seaward of the project is designated as Zone V ( Coastal High Hazard Area).

3. I.) Historica1IArchaeoloeical Resources: Haun & Associates Archaeological, Cultural, and Historic Resource Management Services were retained to perform an Archaeological Inventory Study( AIS) to evaluate the potential for subsurface resources that may exist in the immediate project site area. That AIS is " Appendix D" in the FEA. The site is assessed as significant for its information content. It has yielded information important for understanding prehistoric habitation in the area. The documentation of the Site 30493 cultural deposit adequately records it and no further work or preservation is recommended because the disturbed nature of the deposit precludes the potential to obtain additional archaeological information."

0.J.) 4-a. Natural/Flora& Fauna Resources: " Appendix F' of the FEA is the flora& fauna study for the project site. The project completion will cause minimal, if any, consequences or changes to the existing environment. 4.11 Discussion of Plant Resources: All of the plants within the project site are very common species that have no importance for the conservation of Hawaiian biodiversity. These plants are valuable for the stabilization of the soil and for the esthetic values provided to the people who use the area. 4.12 Recommendations for Plant Resources: The plant life on the project site should be maintained or replaced after construction to minimize soil erosion and to preserve the recreational and esthetic values of the area. 4. 22 Recommendations for Terrestrial Animal Resources: No discernible adverse impact on terrestrial animals is anticipated. No recommendations are made. 4.32 Recommendations for Marine Resources: Best Management Practices and all other necessary actions should be taken to ensure that no soil, fill or any other material from the proposed action enters the waters of the Pacific Ocean. Marine mammals and turtles should not be disturbed or harassed in any way. It is recommended that the US Fish and Wildlife Service be notified if any such animals are seen near the project site.

3. K.) Valued cultural resources: The proposed project will not affect or infringe on any native Hawaiian rights. As part of the FEA investigative process, Hawaiian cultural organizations including the Kona Hawaiian Civic Club and the Office of Hawaiian Affairs were contacted to request information concerning cultural uses of a more expansive area surrounding the Kona Reef property. No responses were received. The area does not now contain evidence or support for any traditional gathering uses and is not vital for access to traditional cultural sites. The gathering of ocean resources,( fishing, etc.) and numerous ocean and other sports activities occur regularly in the project vicinity. The project will not affect or infringe on these or any native Hawaiian rights.

7- Native Hawaiian Rights and Actions to Protect All Relative Interests: The absence of the presence of traditional and customary native Hawaiian rights in the project vicinity removes them from the requirement to address the possible negative consequences that may threaten them. Likewise, cultural, historical, and natural resources will not incur any negative consequences from the construction of the proposed project. With no foreseen consequences, it is not plausible that feasible or any other actions will be necessary.

3. L.) Public Access to the Shoreline: Public shoreline access is maintained as per a' Settlement Agreement" between Hawaii County and AOAO Kona Reef, Inc. Access is through the north- facing side yard off Kahakai Road. A gravel walkway passes through an opening in a rock wall and connects to a concrete sidewalk. The sidewalk leads to lateral access for the entire length of the shoreline area fronting the property. Access is always open, easily accessible, diligently maintained, and extensively used. Hawaii County' s Wai' aha aka Honl' s Beach Park serves as the open- access point from the south. There is no access available to the public which would include traversing the interior confines of the Kona Reef Condominium Complex itself.

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Always open public shoreline access and project site access is through the same area

Aerial view of project site access. 3. M.) Description of General Property Access: The only vehicle access points onto the property are off AlFi Drive and Kahakai Road. Alii Drive and Kahakai Road are both paved county- maintained roads. From Alii Drive there is access into a semi-enclosed parking garage at about the mid-point of the property. Kahakai Road has access to upper and lower parking lots that are adjacent to the buildings with the lower parking lot being the access for a first-floor parking garage. Foot traffic access is through any of the parking areas. Shoreline access is from Wal aha Beach Park on the south or Kahakai Road on the north.

S- 3. N.) Traffic Impacts: There is no potential to impact traffic flow, density or patterns in any way. 13. 0.)Availability of Utilities: The property is serviced by underground connections to all publicly available utilities. There are no public utilities involved with this project in any way.

14. A.)" Description of Environmental Setting": Environmental Setting means `the descriptive information that portrays or captures various aspects of the existing environmental condition within an area including existing burdens relating to the environment and public health." The FEA and this application submittal contain the complete description of the environmental setting. They cover the Natural, Social and Industrial Environments.

4. B.) Relationships to Land Use Plans, Policies, & Controls: The property has a zoning designation of V- 0.75 ( Resort-Hotel) by the County of Hawaii and is located within the State Land Use Urban District. The County of Hawaii General Plan Land Use Pattern Allocation Guide LUPAG) maps show the project site and vicinity designated as high density urban. The project site is located within the shoreline setback area, which is defined by Hawai' i Revised Statutes Section 205A- 43( a) and Planning Department Rule 11- 5, as extending inland from the shoreline a minimum distance of 40 feet. The proposed project would be located within the shoreline setback and would therefore require a shoreline setback variance. As a result, the proposed project triggers the environmental review requirements under Chapter 343, Hawaii Revised Statutes, known as the Hawai' i Environmental Policy Act" The authority to determine whether an Environmental Impact Statement is required is the accepting authority, the County of Hawaii Planning Department 4. C.) Probable Impact of the Project on the Environment: Probable environmental impacts are covered on pages 34, 35 & 36 of the FEA. Those pages are copied herein below. The FEA has received a Finding of No Significant Impact, ( FONSI) from the Hawaii County Planning Department.

4.0 Determination, Findings and Reasons( FEA pages 34, 35, & 36 copied verbatim) 4.1 Determination Based on the findings below, and upon consideration of comments to the Draft EA, the County of Hawai' i Planning Department has determined that the proposed action will not have any significant effect in the context of Chapter 43, Hawaii Revised Statutes and section 11- 200- 12 of the State of Hawaii Administrative Rules, and has issued a Finding of No Significant Impact ( FONSI). The findings below present the reasons the proposed project is not expected to have any significant effect in the context of Chapter 343, Hawaii Revised Statues and Section 11- 200- 12 of the State Administrative Rule.

4.2 Findings and Supporting Reasons 1. The proposed project will not involve an irrevocable commitment or loss or destruction ofany natural or cultural resources. No valuable natural or cultural resource would be involved, committed or lost. No native ecosystems or historic sites are present. No valuable cultural resources or practices such as coastal access, fishing, gathering, hunting, or access to ceremonial activities would be affected in any way. 2. The proposed project will not curtail the range of beneficial uses of the environment. No restriction of beneficial uses would occur.

9- 3. The proposed project will not conflict with the State's long-term environmental policies. The State' s long-term environmental policies are set forth in Chapter 344, HRS. The broad goals of this policy are to conserve natural resources and enhance the quality of life. The project is minor and its impacts are negligible, and it is thus consistent with all elements of the State' s long-term environmental policies. 4. The proposed project will not substantially affect the economic or social welfare ofthe community or State. The project would not have any substantial effect on the economic or social welfare of the Kona community or State. 5. The proposed project does not substantially affect public health in any detrimental way. The project would not affect public health and safety in any way. 6. The proposed project will not involve substantial secondary impacts, such as population changes or effects on public facilities. As the project is minor, it would not involve any substantial secondary impacts, including population changes or effects on public facilities. 7. The proposed project will not involve a.substantial degradation ofenvironmental quality. The project is minor, environmentally benign, and it would thus not contribute to environmental degradation. S. The proposed project will not substantially affect any rare, threatened or endangered species offlora orfauna or habitat. The project site has been previously modified, is landscaped, and supports almost entirely non- native plant species, with the exception of several coconut palms. No rare, threatened or endangered species of flora or fauna are known to exist on the project site, and none would be affected by any project activities. 9. The proposed project is not one which is individually limited but cumulatively may have considerable effect upon the environment or involves a commitmentfor larger actions. The adverse effects of constructing the erosion abatement structure are very minor and involve temporary disturbance to scenery and noise during construction, primarily affecting residents of the Kona Reef Condominiums. The project is not related to other activities in the region in such a way as to produce adverse cumulative effects or involve a commitment for larger actions. Other than the precautions for preventing any effects to water quality during construction listed above, no special mitigation measures would be required. 10. The proposed project will not detrimentally affect air or water quality or ambient noise levels. No substantial effects to air, water, or ambient noise would occur. Brief, temporary effects could occur during construction and will be mitigated. 11. The project does not affect nor would it likely to be damaged as a result of being located in environmentally sensitive area such as a flood plain, tsunami zone, erosion prone area, geologically hazardous land, estuary, fresh water, or coastal area. The project is inside the flood zone, according to FIRM maps, but all improvements will conform to appropriate regulations concerning development within such zones. Although the proposed project would be located in a zone exposed to earthquake and volcanic hazards, there are no reasonable alternatives that would avoid such exposure. The proposed erosion abatement structure is unlikely to be damaged in the event of a tsunami.

10- 12. The project will not substantially affect scenic vistas and view planes identified in county or State plans or studies. The project is low-profile, would be build flush to the existing ground surface and would not impact views to, from or along the shoreline, nor any views listed in the Hawaii County General Plan or other plans. 13. The project will not require substantial energy consumption. Small amounts of energy input would be required for construction and operation. 4. D.) Impacts Which Cannot Be Avoided and Mitigating Measures: The adverse effects of construction of the proposed CRM wall on the subject property are very minor and include temporary disturbances to air quality, noise, access to active construction areas of the lawn, and visual quality during construction. No special mitigation measures should be required to counteract any small, adverse cumulative effect of nearby construction. It is particularly important to note that the project is expected to generate negligible scenic impact, no long-term adverse impact to public use and enjoyment of adjacent shoreline areas, and no effect to historic or cultural properties. There would thus be no risk of cumulative impact to these resources. Some loose construction materials i.e. mortar sand, excavated fill and soil etc. may get blown around by strong winds. All such materials will be continuously watered down and/ or covered with tarps. 4. E.) Alternatives to the Proposed Project: A properly anchored solid CRM structure is the only viable and practical solution to fulfill all project objectives. Under the No Action Alternative, the CRM wall would not be built. The obvious costs of the No Action Alternative would be guaranteed adverse impacts to water quality, shoreline/coastal habitats and property damage or destruction. The placement of rip-rap, or other coarse material would not achieve any of the project' s goals. It would render the near offshore area almost unusable and upend the current the environment. A bulkhead design would be not site appropriate. It would be overkill because of size and design. Designs that would be wholly or partially outside of the Kona Reef property aren' t feasible. 4. F.) Mitigating Measures to Minimize Impacts of the Project: The finished project will not create impacts that require minimalization. It will be a mostly hidden structure that will most likely be completely unnoticed. Any impacts that it may create will happen during the construction phase and they will be addressed by adhering to the Best Management Practices as they are written and prescribed. 4. G.) Any Irreversible and Irretrievable Commitment of Resources: There will not be any commitment of any resources that will be irreversible or irretrievable.

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APV-I ATION FOR VARIANCE by CENT Y HURLS, LTD. f VARlfuCE far NC 310 SNCRELINE RETRACT VABIANC3 in WMAUA. NORTH KONA, HAWAII

VARSAkCE PERMIT

The County Planting comTissian at a duly hely public ...earthy ou 3uie 25, 1431, considered the application at GENTRY 110l11.2. t•TO. for variance frob Chapter 2U5, Hawaii Revised Statutes, as amended, and Rule No. 8 of Cne Planning Cpso; alasitln Gelating to Shoreline Se*' cac5, mare specifically; to allow certain improvements wattle toe st: rel;. ne sethanx area of the hone Reek Canacminium project, 1. y-waling the retention of portions of the existing CS{ wail. ascaliation of a swank/ et system andtitling ut the area with topp_ Oil for landscaping at Raiibs, Naiena. North sena, Hawaii, Tax rrnp Rey 7 5- 1$: 73 and 12.

Tr.e Commission has round:

That the retention of portion of the existing 3-foot high concrete rock masonry ICES; sea wail and related landscaping improvements within the shoreline setback aures is not expected to have any adverse impacts on the environment, No endangered plant or animal species will on affected by the project as none are anon, to exist on tne subject parcel or in the surrounding area. No impacts are likewise anticipated by the proposed project on archaeological/ Cultural resources 1nthe area, In addition, the area was extensively altered during the COnStrUCCion of the condofliinitlnt.

That there may ; aa some advecSe l p&•CtS to the coastal waters resulting tram the piecing of top o11 for landscaping, however, the potential erosion should ne of a short duration and shoulo de mitigated with tate establishment of the landscaping, In additSOh, the proposes landscaping shemid more than orfsat the temporary adverse effect through tne creation of a greenbelt along

the shoreline.

Furthermore. existing laws ane regulations controlling grading activities snouid effectively mitigate any other potential adverse impact.

2. That the retention of portions of the existing concrete- masonry wall along tne shoreline will provide residential units and additional protection to the existing a. 00g the Kana Coa$ c. It IS therefore Cetetmined that the denial of these improvements may increase the potentialnE store wave damage to the subject area and therefore will constitute an undue wardship to the petitioner.

3. That as part of the subject improvements, the petitioner i5 proposing to provide a 10- foot wide Noire easementto the snuceline along the north property line, This easement will ensure tnatthe sorekine portion of the suhje:^.t and surrounding areas are accessible to the general public. Therefore, the proposed activities are determined to be in the public interest,

Tnererore, the Commission hereby grants to the petitioner a varim ce to allow certain improvements within the shoreline setback arae of the Kona Reef Condominium protect, including the retention of partiana of the existing CAM wail, installation of a serinklet aystco ani filling of the area with topsoil for landscaping at Ka1JQ , Weiaha, form Kona, Hawaii, tax Map Key 7. 5- 13: 71 and 72, subject to the following condition

I. That the applicant, Gentry comet, Ltd snail be responsible £ r complying with all of toe stared conditions of approval.

2 That constriction shall commshce within one ( 1) year dean the effective date of the Permit and snail he completed within one ( 1) year thereafter.

That no storage of equipment or material be permitted within the shoreline Setback area.

i. That a public s oreline across plan meeting with the approval of the Planning Director be suomitted prior to the commencement of construction of the improvement. Sarni access plan shall inckude the roli.nvirp which chaLl at in Place at the time of. completion of ail of the reqoeaceU itaproveventS:

a. A delineated pedestrian easement prong toe norrn property rine at least 10 feet rice.

b. Preeieibee for lateral easement across the seaward portions of the subject area.

c, Construction details including aignave, material usec, and final grade.

5. :' hat all other applioable rules, regulations and requirements incluainq those of the pepartue t of Public Works shall be complied wino.

It should be noted that approval of the shoreline setback varinre does not relieve the applicant tram any penalties or fines which may be imposed in accordance with applicable regulations, Ekould any of the foregoing conditions nut be met, the variance P= nr.it may be deemed null and void. The effective date of this permit shall ae from acne 25, LS81_

1_ 3EH13 H. NAKANO Chatraan. Pianninn Casmizaion

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RJI and i I WY ANTfOR4 M64, TAUNttt%IOPGa NAT COMP! TRUST 1 7 370 lea SEmEMOIT AGREEMENT

Thy Apeman rah dr 17th,, h of ray Hu, by, bo n std amaW the COUNTY OF MAWAD Dae; attr Ise • Canty% GENTRY- HONES, LTD., d Huta crpmdm alth Rd Ptd tIpd Place at ban . m IAYmhdt, Hep Oa. Latlr the ' GntTV•IMafl, The ASSOCIATION OP

OWNERS Or THE BONA REEL CONDONMNN PROJECT ( hereafter to

AmdaRe') ad GUY ANTHONY PAUt, TRUSTEE UNDER THAT CERTAIN

TRUST DATED SEPTEMBER If, H7f 0eehrfter thea Oral.

WITNESSETH

That WHEREAT, h hrlmoaal property regime amen n The pros

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In the Canty of Hank o btd Hard by tlr FOR Oars, aM

HEREAS, certain doledam ate alleged rd are pending agelnn

daeUre wad area Garay- testas II+UMN{ mnaattn activity etdda the at h Fort du daag cnrn oEwaERel,red 1 WnfltEh3, a mare a aid aWad * anions, Gentry-

Hams applied for red received a Variance Permit ( Veba Permit No. 4101erArrHansto acmmpUfh certain sada within the shoreline* stab res, which Variance Permit

specifies, inter din, eat Geary- Ismn Is to provides

I. A Wanted Pnmian asemmn slag dr lath property

bre a lean 10 feet Oda ad b. Provision fr blend venin sacs the nes+ W patient

of the caper was and

WHEREAS, GnNrlbmn ha proceeded In - filth to amply

ad the efom iati. d rMdrnnaa ed hes aerrected all of the resulted

Mprnnnts in compfrde add eh Yalta Permits red WHEREAS, ea te goad tan din by dl Pirtle Mate, II Awn Oat fr ream brad h corm t snit d h arta, .1 b Saproacal a Ile arbk s cave the dsdimin of OWk aces nnmenb to He Canty'

WHEREAS, In Bpm d h hrMpty le crate pnaaC area emenroe Pend , 1

370 4 ted Ma , w elrol none of IS flak Saran, Ma vyards,s, li o Mata I.smt M dtNq eels Ors rd impotablatles MO respect to to pubdc sae rte Met kw Mel anted awl are ad weds nmohnw lean barmen rails maw Ow.

MOR, THEREFOR!, M rauldenrkn of IS omen atom mad and of Ma mdal monads . d . pennate hydraIw . n fen, the p•nle arts moment cal awn as Warm

I, It. mos* are M lddble' A'and emailed Into and M Morro mads ape Peret ord . R b. pewrnms cm. teted Maroon and treats by Cowry-Howes flit be add as WS, * dor at d retatduan

Pik sae wad M witamm,. nn. lepryepe tw. rd ab. of the tern Meta Permit It, add Sad by IS Cagy to Oenr7• Ibne doted Rely h, 1111, as twrdrd,

2. R e Ow ehtml rd papas of de par* harm Mat such

kdpetlm of pi& tats oro be M tees*!! with Ila pendo. of Cape NO of Miran Wheel! awn army eoorar... tae, 1. Tr* Asocledon rd Os Fa Over awn it said public rases wet raid reran publk sad was kru long as IS Rao RM Cmdmien polwt da maks M de prey uw at a horleiW warty agwa S. Tae Assaate amens rel Jaren m mom ndodge mgeetWtp for sa m. bMwna of s!d pJf[ were res Si penal Ma amort aneta of IS Raw RM CaWnI*, n popct fa as law u h Asoalike

thin Int M. lath.

1, Mrs OwCasMrmrrMheOonrISMuw. rtmpadb0lt, a IhbU t7 for tie repair, nalnrwe. s w flap M mid milk saw no. a, 7h Asscia. iw m9 awn] and Nadir. Ow , w of old

pink. cost arae rel may erect twomprlato paschal manwme domrc. Mq Ma woes areas e + le rmdnw to de use of ad row,. Lisa to IS pia

mita am WOW of air Canty. 7. Re Casty Mnb. eaa. IMusrd apees rat to dedpnlm of IS perk . t» A ad We protium fa entreei ad dowel of

one= Idly Ma undid= of Wane Arndt M, alp, at amed. d,• peUNaMy

s tylr•0• pe. A. OS U.Minot

I+ A. 18370 ! 8S L The Canty bray mien and tams C ntry-Meme, from fry end ell liability for any aM el) penalties whkh might be hemmed b a remit M the plw load Mdtutm within the dear. etbrk wee of the Kum Reef CoodmMhrn relict she, It bebg ewesly acknowledged and agreed by the Comity Oat the ecteitla epcged to have been Statist were temperer ad Moe [ seed, that the effete of said alleged ' Ratko hove been need with no bene Wpm on the pit&eStalk and chit Menthe! cements end yermenn

et forth M the SettlememntmemA! represent adepYY txrolderela to the

Canny for thk release and more.

N WITNESS WHEREOF, Aro tartlet hereto hate executed them

pease the 17th. day of Hey 1911e.

COUNTY OP NAW AR

ET ( • et! Lanni • Director

CFNTRY. HOMES ETDD.,,,-

t li ASSOC] OP OWNERS OF THE KONA REEF CONDOMINIUM PROJECT

ht s RYR I APPROVED s s

FORM and IEOALITY y f nous C R TER Tr .`. Under 7Mt entire Dun Cf#4' arin. , Med September 19, 1977 C.iw'.a Cf •/ NH1 SEP 17

a e

3. 111370m STIPA CI all i ado COIMY a mt10.71

on this 3Oth day of Oweaer , 1981, before ns personally appeared flan NRC, to se personalty mom, + die, being by se duly worn, did say that ha is the Director of tin planning Department of the Cobnty of swift that the Planting Deperiwat of the Comity of Sewall hal no corporate anal; and that the itatruaeat was signed on MMl! Of CM Punning Department Ot the County of Sawati, a governmental meaty! and said Mete YOU acknowledged the liniment to be the fret act and dad of said planning

Departwnt, County of Swati,

I 1N¢ tary P t1 e S F o, naw ib' coYisatM expires. 9/ 22) 85

i 18170 1e7 i fllAyl a Waif 1 Wt CRI MIS O9on or MOO= 1

this txn. On 1 day . of in iliiJ JOSEPWJ. RAaIA before M appeared to it personally team, no, being by it duly acorn, did say that be Is

the President of COM llat5, LTD,

a Mall eorpocsaloa, and that the sell Mind to the foregoing lnstrwnt is the corporate seal of said corporation, and that said

Instrument ns signed and smiled In Well at said corporation by it authority of it. board of Directors, end the said

JOSEPq J. aet1A ectnaelsdged maid instrument to be

the foe sot and dud of old corporation,

l yjry1// ynl NOtinf IdD tl'e; 5[ at,. b'f Nar1S(

my coanleatem ! Wray 12- 2546

STATE OF SAYAII SS: CETT MID COUNT! OF BOfOLUIO )

On chi. __ day of ear HSA, before el appeared PEEVES L. saw end Nta 5c0. M1 to lie eraonally know, % o, helms by m duly avori, did say that they arm the Pusldenl and Setmitary respectively, of the ASSOCIATION IT WENS 0f IM PROJCCT; that the Aesociatian his no meal; and On the foregoing ! nutriment was signed in behalf of said Association by authority of its board of Directors, and the sand PEEVES L. Pm and CRAY S. n, AN. acknowledged old instr,Rent to be the tree act and deed of geld Auioeiition.

f/y/ pOtt! y tete o. S . 121- 1541 By Cotnlseian expires, Swell

18370 480 DESCRIPTION

Lateral Access Area

Icing a 10- foot wide pedestrian a access area, over and across Lot 1 of Land Court Application 1854 and over and across Lot 8, being y; a portion of R. P. 1930: 3, L. C. Aw. 387- 4: 2 to A. B, C. F. M. and a portion of Grant 13083 to Manuel Gomes, at Sataha 1, North Rona, Hawaii iifl il Court concrete at the end of course 8 of land SA Beginning at a pipe in 1i Application 1854, the coordinates of which referred to Government kis feet North and i3 Triangulation Station " XAHELO" being 3437. 79 Survey

measured clockwise from feet West and running by azimuths e: 1364. 49 1 '

i true South: t1 side or Ymhetai 2550 10. 34 feet the southerly i 1. 00' along Road;

remainder of Lot 1 of land r ' 3300 22' 7. 40 feet along 2. Court Application 1854; Thence alert same on a curve to the right with a radius of 10. 00 feet, I. ' distance of the chord the azimuth and being. t, i. 92 feet; A. 23° 08' 15.

remainder of tot 1 of land i 4. 750 54' 42. 09 feet along Court Application 1834; is I thence along same on a curve to the left with a radius of 30. 00 teat. distance of the chord beings the azimuth and 1: ; 17. 72 feet;

I , ' Thence along same for the following five (5) new-seat

I b. 3110 09' 30" 83. 00 feet; 62. 3E feet; I ; 7. 322. 27. 30" i . 8. 321' 07' 20" 33. 70 feet; 10" 30. 23 feet; I • 9. 311' 23' 38 feet, thence: 10. 326. 50' 26.

remainder 50.. 48. 74 feet it 33. 10' n Court maieat$ onf3F54 ane remainder of hot 8. oo' tion_of P. Y.

I EXHIBIT " A" tjod T-- 18370 490 1930, 3. 1.. C. Aw. 387- 4, 2 to :-. E. C. i. X. and a portion of Grant 13083 to Manuel Comes;

3256 12. 50. 20" 65. 50 feet along remainder of Lat F. portion of R. P. 1930: 3. L. C. :. v:. N` i7- 4: 2 to A. E. C. 1. A. and a portion of Grant A 13083 to ranuel Cones; ij

feet 13. 303° 56' 50" 31. 39 along same; f ' feet same, thence; t 14. 281° 34' 10" 27. 89 along

20 feet 15, 46° 33' 12. along remainder or R. P. 1930, 3. L. C. Aw. 387- 4. 2 to A. E. C. F. k.. ; q` 10) seashore for the following ten ( fi iThence along highwater mark. at

courses, rj

16. 101° 34. 10" 22. 88 feet;

17. 123° 56. 50" 35. 30 feet;

18. 145° 50' 20" 67. 99 feet;

50" 48. feet; 19. 152° 10' 83 j

20. 146° 50' 24. 55 feet; f 21. 131° 23' 10" 29. 72 feet;

34. feet; 22. 141° 07' 20" 68 g

61. 51 feet; 23. 142° 27' 30" i feet; 1 24. 131° 09" 30" 85. 19

30" 67 feet to a spike in concrete, thence; 25. 134° 35' 33. 84 feet 26. 255° 54' - 77. along Lot 2 of land Court &pplicatior { 1854. to a pipe in concrete;

150° 22' 10. 01 feet along same to the point of beginning i 27. and contgining an area of 5302 square feet. J03IIi D. WEEKS Registered sarveyor- En€ ineer 502ES

1982 DATED: January 18. o. ; f•- I

cam1. 14:411. li I+

1001111Tk ° Aw Page 2 of 2 pages

M: td .. a- 0 SOP ae f..•.wants.. rf. JOHN D. * MSS. , Ne. I DESCRIPTION 18370 491 Easement " 1" Being a 10- foot wide Pedestrian Easement, over and across Lot 1. t of Land Court Application 1854. to provide the general public with access to the seashore Beginning at a pipe in concrete at the end of course 8 of land Court Application 1854, the coordinates of which referred to Government Survey Triangulation Station " KARMA" being 3437. 79 feet North and 1364. 49 feet Nest, and running by azimuths measured clockwise from

true South,

1. 255° 00' 10. 34 feet along Xahakai Roads t { 2. 3306 22' 7. 40 feet along remainder of Lot 1 of Land i Court Application 1854; Thence along remainder of Lot 1 of Land Court Application 1854 on a curve to the right with a radius of 10. 00 feet, the azimuth and distance of the chord beings

s 3, 23° 08' 15. 92 feetslt

4. 75° 54• 71. 76 feet along same;

5. 134° 35' 30" 11. 70 feet along c. r. m. seawall. along I highwater mark, along remainder of Lot 1 of Land Court Application 1854, to a spike in concrete; I 6. 2550 54' 77. 84 feet along Lot 2 of land Court Applica- tion 1854 to a pipe in concrete;

containine to beginn- 7. 150° 22'' 10. 01 feet ing analond theg ofarea of 427 square feet. r JOHN D. VEERS Registered Surveyor- Engineer # 502 "

DATED, March 13, 1981 44 t_-el 5 s• REGISTERED ` P PROFESSIONAL', • ENGINEER j , No. 30715 / I

s+ i I

a writs N. solace JNN a.".. aR BONN b. NUM INC. Normae.. a annt Ye; FILE COPY Ilam Kim 2 Michael Yee Mayor D,recror C; y ' Daryn Arai Deputy Director a tots Wes Office East H 0nice 74- 5044 Ane Keohokalole 101 Pauah Street Suite 3 Edina- Kona, 96740 County of HaW81 1 Rile. Rowan 9enc Phone( 80S) 3235677023477 I' hene( 8081961- 8288 Fan 16a3) 32/- 3563 PLANNING DEPARTMENT Pat( 808) 961- 8742

February 12, 2018

1 _ cam, w U v,„ Scott Glenn, Director T 111 Office of Environmental Quality Control i m 235 South Beretania Street, Suite 702 tei Honolulu, HI 96813 xc C

Dear Mr. Glenn: G

Final Environmental Assessment( FEA) Applicant: Association of Apartment Owners of Kona Reef, Inc. Request: Kona Reef Condominiums Erosion Abatement Structure in the Shoreline Setback TMK: ( 3) 7- 5- 018: 071 North Kona, Hawaii

The County of Hawai` i Planning Department has reviewed the comments received during the 30- day comment period on the draft environmental assessment that ended 30 days after November 23. 2017 date the project was posted in the OEQC Environmental Notice). We have determined that the project will not have significant environmental effects and have issued a Finding of No Significant Impact ( FONSI). Please publish notice of availability for this project in the next available OEQC Environmental Notice.

We have enclosed a completed OEQC Publication Form, one copy of the final EA, and a copy of the final EA and the project summary hardcopy on disk. If you have any questions, please feel free to contact Jeff Darrow at 961- 8158.

If you have any questions regarding the above, please contact Jeff Darrow of this department at 808) 961- 8158.

Sincerely,

Planning Dept. nit-t MICHAEL YEE Exhibit 9- Planning Director

JWD: mad P. wpwin60 CH343 2017 LKonaRee[ ErosionAbatemencStrucmre- FonsiDEA doc 354

cum Hawaii is Equal Provider Employer Yw. hiplanninedeot Canny an Opponumy, and pIannipgdhaw_ iG4unty eor Anel Scott Glenn, Director Office of Environmental Quality Control Page 2 February 12, 2018

Enclosures: Final EA ( 1 copy) Completed OEQC Publication Form and Project Summary Final EA and Project Summary( on disk) cc Itr only: Mr. Graham Paul Knopp, N.D. Office of Environmental Quality Control February 2016 Revision

APPLICANT PUBLICATION FORM

Project Name: Final Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback, Kona Reef Condominiums, 75- 5888 Alii Drive, Kailua-Kona, Hawaii

Project Short Name: Kona Reef Condominiums Erosion Abatement Structure

HR5§ 343- 5 Trigger( s): Action in the Shoreline Setback

Island( s): Hawaii Judicial District(s): North Kona

TMK( s)' 3). 7- 5- 018: 071

Permit( s)/ Approval( s): Shoreline Setback Variance, Special Management Area Approving Agency: County of Hawaii Planning Department Contact Nome, Email, Michael Yee, planninghawaiicountv.gov, ( 808) 323- 4770, 101 Pauahi Street, Suite Telephone, Address 3, Hilo, HI 96720 Applicant. Association of Apartment Owners of Kona Reef, Inc. Contact Name, Email, c/ o Ray Pieri, pierir0016thawaii.rr.com, ( 808) 989- 7439, 75- 1029 Henry Street,# 202, Telephone, Address Kailua-Kona, Hawaii 96740 Consultant: Graham Paul Knopp, Ph.D. Contact Name, Email, GK Environmental LLC, gpknoppaakenvllc. com, ( 808) 938- 8583, PO Box 1310, Telephone, Address Honokaa, HI 96727

Status( select one) Submittal Requirements DEA- AFNSI Submit I) the approving agency notice of determination/ transmittal letter on agency letterhead, 2) this completed OEQC publication form as a Word file, 3) a hard copy of the DEA, and 4) a searchable PDF of the DEA; a 30- day comment period follows from the date of publication in the Notice.

X FEA- FONSI Submit 1) the approving agency notice of determination/ transmittal letter on agency letterhead, 2) this completed OEQC publication form as a Word file, 3) a hard copy of the FEA, and 4) a searchable PDF of the FEA; no comment period follows from publication in the Notice.

FEA- EISPN Submit 1) the approving agency notice of determination/ transmittal letter on agency letterhead, 2) this completed OEQC publication form as a Word file, 3) a hard copy of the FEA, and 4) a searchable PDF of the FEA; a 30- day comment period follows from the date of publication in the Notice.

Act 172- 12 EISPN Submit 19 the approving agency notice of determination letter on agency letterhead and 2) this Direct to EIS") completed OEQC publication form as a Word file; no EA is required and a 30- day comment period follows from the date of publication in the Notice.

DEIS Submit 1) a transmittal letter to the OEQC and to the approving agency, 2) this completed OEQC publication form as a Word the, 3) a hard copy of the DEIS, 4) a searchable PDF of the DEIS, and 5) a searchable PDF of the distribution list; a 45- day comment period follows from the date of publication in the Notice.

FEIS Submit 1) a transmittal letter to the OEQC and to the approving agency, 2) this completed OEQC publication form as a Word file, 3) a hard copy of the FEIS, 4) a searchable PDF of the FEIS, and 5) a searchable PDF of the distribution list; no comment period follows from publication in the Notice.

FEIS Acceptance The approving agency simultaneously transmits to both the OEQC and the applicant a letter of its Determination determination of acceptance or nanacceptance( pursuant to Section 11- 200- 23, HAR) of the FEIS; no comment period ensues upon publication in the Notice.

FEIS Statutory The approving agency simultaneously transmits to both the OEQC and the applicant a notice that it Acceptance did not make a timely determination on the acceptance or nonacceptance of the applicant' s FEIS under Section 343- 5( c), HRS, and therefore the applicant' s FEIS is deemed accepted as a matter of law.

Page 1 of 2 Applicant Publication Form Office of Environmental Quality Control February 2016 Revision Supplemental EIS The approving agency simultaneously transmits its notice to both the applicant and the OEQC that it Determination has reviewed( pursuant to Section 11- 200- 27, HAR) the previously accepted FEES and determines that a supplemental EIS is or is not required; no EA is required and no comment period ensues upon publication in the Notice.

Withdrawal Identify the specific document( s) to withdraw and explain in the project summary section.

Other Contact the OEQC if your action is not one of the above items.

Project Summary Association of Apartment Owners of Kona Reef, Inc. (Kona Reef AOAO) proposes to build an erosion abatement structure within the lawn area fronting the Kona Reef Condominiums, located mauka( i. e. uphill or inland) of the certified shoreline and within the shoreline setback. The purpose of the structure would be to prevent erosion of soil underlying the lawn area, and consequent loss of the use of the lawn area. The project would maintain the lawn area and protect it for users, who include both members of the public and Kona Reefcondominium residents. The structure would parallel the certified shoreline for approximately 220 linear feet, would be anchored in bedrock, and would be built flush to grade ( at the same height as the surrounding lawn area). Na adverse SSnpacts from cerostritctiext of the stnicttlte to shogOjng processes are anticipated. No sensitive biological, hydrological, archaeological, cultural, or other important resources are present on the project site. Construction activities would produce short-term impacts to noise, air quality, access, and scenery, which would be mitigated by implementation of standard construction Best Management Practices, as well as restrictions on construction hours, would ensure that construction- related impacts, including potential impacts to water quality,

are avoided or minimized.

Page 2 of 2 FINAL ENVIRONMENTAL ASSESSMENT FOR EROSION ABATEMENT STRUCTURE IN THE SHORELINE SETBACK

KONA REEF CONDOMINIUMS 75- 5888 ALI`I DRIVE KAILUA-KONA, HAWAII TMK (3) 7- 5- 018: 071 ( por.)

February 2018

Prepared for: Association of Apartment Owners of Kona Reef, Inc. 75- 1029 Henry Street# 202 Kailua-Kona, Hawaii 96740 FINAL ENVIRONMENTAL ASSESSMENT FOR EROSION ABATEMENT STRUCTURE IN THE

SHORELINE SETBACK

KONA REEF CONDOMINIUMS 75- 5888 ALI`I DRIVE KAILUA-KONA, HAWAII TMK (3) 7- 5- 018: 071 (por).

February 2017

Applicant: Association of Apartment Owners of Kona Reef; Inc. 75- 1029 Henry Street# 202 Kailua- Kona, Hawaii 96740

Accepting Agency: Hawaii County Planning Department 101 Pauahi Street, Suite 3 Hilo, Hawaii 96720

Consultant: Graham Paul Knopp, Ph.D. P. O. Box 1310 Honokaa, Hawaii 96727 808) 938- 8583

Class of Action: Action in Shoreline Setback Area

iii TABLE OF CONTENTS

Toc4820894781. 0 PROJECT DESCRIPTION, PURPOSE AND NEED, AND IMPACT ASSESSMENT PROCESS 1

1. 1 PROJECT DESCRIPTION AND LOCATION 1. 2 PURPOSE AND NEED 2 1. 3 ENVIRONMENTAL ASSESSMENT PROCESS 6

1. 4 PUBLIC INVOLVEMENT AND AGENCY COORDINATION 6

2. 0 ALTERNATIVES 8

2. 1 ALTERNATIVE LOCATIONS 8 2. 2 ALTERNATIVE DESIGNS 8 2. 3 PROPOSED PROJECT 9 2. 4 NO ACTION ALTERNATIVE AND ALTERNATIVE SITES 9

3. 0 ENVIRONMENTAL SETTING, IMPACTS AND MITIGATION 11

3. 1 PHYSICAL ENVIRONMENT 11 3. 1. 1 Geology, Soils, and Geologic Hazards 11 Environmental Setting 11 3. L2 Coastal Setting, Coastal Erosion and Flood Zone 12 11. 3 Water Quality 15 3. 1. 4 Flora and Fauna 16 11. 5 Air Quality and Noise 18

3. 1. 6 Hazardous Substances, Toxic Waste and Hazardous Conditions 18 3. 2 SOCIAL AND CULTURAL ENVIRONMENT 19

3. 2. 1 Land Use, Designations, and Controls 19

3. 2. 2 Socioeconomic Characteristics and Recreation 21

3. 2. 3 Cultural and Historic Resources 22 3. 2. 4 Archaeology and Historic Sites 24 3. 3 PUBLIC FACILITIES, PUBLIC ACCESS AND UTILITIES 25 3. 4 SECONDARY AND CUMULATIVE IMPACTS 25 3. 5 REQUIRED PERMITS AND APPROVALS 26

3. 6 CONSISTENCY WITH GOVERNMENT PLANS AND POLICIES 26 3. 61 County ofHawai 9 General Plan 26 3. 6.2 Special Management Area 31 3. 6.3 Shoreline Setback Rules 32 3. 6.4 Kona Community Development Plan 33

4. 0 DETERMINATION, FINDINGS AND REASONS 34

4. 1 DETERMINATION 34 4. 2 FINDINGS AND SUPPORTING REASONS 34

iv LIST OF FIGURES Figure 1. Project Location Map 3 Figure 2. TMK Map 3 Figure 3. Aerial Photograph 4 Figure 4. Site Photographs. 5 Figure 5. Proposed Project Site Map 10 Figure 6. Preliminary DFIRM Map for Proposed Project Area 13

LIST OF TABLES Table 1. Project Vicinity General Coastal Hazards Summary 15 Table 2. Plant Species Identified on the Project Site 17

APPENDICES Appendix IA Comment Letters in Response to Early Consultation Appendix 1B Comment to Draft EA and Responses Appendix B Engineering Drawings Appendix C State Certified Shoreline Survey and Photographs Appendix I) Archaeological Inventory Survey, Haun & Associates Appendix E Coastal Resource and Erosion Assessment, GCI, Int. Appendix F Flora and Fauna Study, Grant Gerrish, Ph.D.

v SUMMARY OF PROJECT, ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

Association of Apartment Owners of Kona Reef, Inc. ( Kona Reef AOAO) proposes to build an erosion abatement structure within the lawn area fronting the Kona Reef Condominiums, located mauka ( i. e. uphill or inland) of the certified shoreline and within the shoreline setback. The purpose of the structure would be to prevent erosion of soil underlying the lawn area, and consequent loss of the use of the lawn area. The structure would parallel the certified shoreline for approximately 220 linear feet, would be anchored in bedrock, and would be built flush to grade ( at the same height as the surrounding lawn area).

The project would maintain the lawn area and protect it for users, who include both members of the public and Kona Reef condominium residents. Both types of users often use the lawn area for recreational activities including sunbathing, whale watching, and to access both the shoreline makai( i. e., downhill or towards the ocean) of the lawn area and the adjacent beach and surfing area commonly referred to as Honl' s located offshore Waiaha County Beach Park.

The project would be built above the shoreline on private lands, and no adverse impacts from construction of the structure to shoreline processes are anticipated. No sensitive biological, hydrological, archaeological, cultural, or other important resources are present on the project site.

Construction activities would produce short- term impacts to noise, air quality, access, and scenery. Implementation of standard construction Best Management Practices, as well as restrictions on construction hours, would ensure that construction-related impacts, including potential impacts to water quality, are avoided or minimized. The proposed project has negligible potential to cause long-term adverse impacts, or to cause adverse cumulative or secondary impacts. The proposed project would be built flush to surrounding grade, and would thus have no visual impact. Other long-term impacts would be negligible or positive, as the proposed project would reduce the potential for loss of soil and related discharge of polluted stormwater runoff to the shoreline, reef, and ocean habitats.

vi 1. 0 PROJECT DESCRIPTION, PURPOSE AND NEED, AND C IMPACT ASSESSMENT PROCESS

1. 1 Project Description and Location

Kona Reef Condominiums Association of Apartment Owners ( Kona Reef AOAO) proposes to build an erosion abatement structure within the ocean front lawn area of the Kona Reef Condominium property( Figures 1 — 4). The proposed project would maintain the integrity of the lawn area fronting the condominium structure by construction of a concrete- rubble masonry ( CRM) structure that would be flush to ground surface. The structure would be parallel to and located entirely mauka ( i. e., inland or uphill), of the State Certified Shoreline Survey of March 1, 2017, and separated from it by a buffer of at least 12 inches. Figure 5 presents the proposed alignment overlain on an aerial photograph. The structure would extend for approximately 220 linear feet and would be built entirely on the Kona Reef Condominium' s private property. The top of the structure would be flush to grade ( at the same elevation of the surrounding lawn area). The southern half, or approximately 100 feet, of the structure would be embedded in the existing soil on both faces ( i.e., both mauka and makai). The structure would vary from approximately 12 to 52 inches in height, depending on the depth to bedrock, with the top surface varying from approximately 12 to 15 inches in width. These dimensions are flexible to allow for adjustments to the finish height and width needed at various points along the structure, and to allow the structure to be flush with the existing lawn elevation. The proposed project would be completed within about three to four months of receipt of required permits.

The Kona Reef Condominium, located at 75- 5888 Ali`i Drive, Kailua-Kona, County of Hawaii, Tax Map Key ( TMK) ( 3) 7- 5- 018: 071, is an approximately 3. 1- acre shoreline property. The Kona Reef Condominium consists of five ( 5)- four story residential buildings, and a one- five- story residential building with two lower floors composed of a parking lot. The Kona Reef Condominium also includes a swimming pool, jacuzzi, courtyard gazebo and a poolside cabana, as well as an office structure.

The proposed structure is not a seawall as it would not receive wave energy during normal circumstances, as it is located above the shoreline as defined by Hawaii Administrative Rule 205A that defines the shoreline as, " the upper reaches of the wash of the waves, other than storm and seismic waves, at high tide during the season of the year in which the highest wash of the waves occurs, usually evidenced by the edge of vegetation growth, or the upper limit of debris left by the wash of the waves." The shoreline was recently established by a Certified Shoreline Survey dated March, 2017 File No. HA-538). The proposed project would be located within the shoreline setback and would therefore require a shoreline setback variance. As a result, the proposed project triggers the environmental review requirements under Chapter 343, Hawaii Revised Statutes, known as the " Hawai` i Environmental Policy Act." The authority to determine whether an Environmental Impact Statement is required is the accepting authority, the County of Hawaii Planning Department.

In this document the Kona Reef Condominium complex is also referred to also as Kona Reef, and the general area of the project site, including all of the Kona Reef Condominium property and adjacent properties, as the project vicinity. The terms abatement structure or structure, and erosion abatement structure refer to the proposed engineered concrete rubble masonry ( CRM) wall structure. Also, the Association of Apartment Owners of Kona Reef, Inc. is referred to generally as the Kona Reef AOAO. Portions of the existing Kona Reef Condominium structures, including an irrigation system, portions of the pre-existing CRM wall, and the lawn area itself were permitted by Shoreline Setback Variance # 610 dated June 25, 1981, which also stipulated preparation of a public shoreline access plan including a pedestrian easement along the north property line, and provisions for lateral easement across the makai portion of the property boundary.

1. 2 Purpose and Need

Kona Reef Condominiums desires to preserve the lawn area located between the condominiums and the certified shoreline by preventing loss of the soil underlying the lawn area. The soil and fill underlying the lawn area currently enters the ocean in small amounts when foot traffic, to and from the Kona Reef property and the shoreline area, causes erosion on the seaward exposed face of the lawn. Additionally, wind and storm water runoff pick up and carry the loosened soil into the ocean. Therefore, without action this recreational resource and shoreline access resource utilized by both the public and Kona Reef Condominium residents will slowly, but inevitably, be lost. Need for the project also relates to the potential effects of a major coastal flooding event. In the event of a major storm surge or tsunami, it is possible that much of the volume of the soil underlying the lawn area may be eroded and transported to the shoreline area and ocean. The proposed structure would reduce the erosion of soil from the lawn area fronting the Kona Reef Condominiums and prevent soil from entering the ocean, which occurs primarily due to pedestrian traffic. This conscientious proposed action is protective of the environment and a resource utilized by the public, and therefore urgent and timely action is warranted. Without the erosion abatement structure, soil will enter the ocean, and both members of the public and Kona Reef residents would lose use of some, or all, of the lawn area.

The purpose of the project is not to deflect wave energy, or to hold soil in place against the eroding action of waves, as the structure would be located above the shoreline. Retention of all of the soil underlying the lawn area would require construction within the State- owned coastal lands, which is beyond the scope of this private action.

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Photograph is taken from the lawn area near the northern terminus of the proposed erosion abatement structure, looking to the south. The lawn area is used by both Kona Reef residents and the public.

5 1. 3 Environmental Assessment Process

The Hawaii Environmental Policy Act was enacted by the Hawaii State Legislature to require State and County agencies to consider the environmental impacts of various actions as part of the decision-making process. Agencies are required to conduct an investigation and evaluation of alternatives as part of the environmental impact analysis process, prior to making decisions that may impact the environment. The implementing regulations are contained in Title 11, Chapter 200, Hawaii Administrative Rules.

This Environmental Assessment ( EA) process was conducted in accordance with Chapter 343 of the Hawai`i Revised Statutes ( HRS). This law, along with its implementing regulations, Title 11, Chapter 200, of the Hawaii Administrative Rules HAR), is the basis for the environmental impact process in the State of Hawai` i. An EA is necessary because the site is within the shoreline setback and the County of Hawai` i does not consider the project an exempt activity. According to Chapter 343, an EA is prepared to determine impacts associated with an action, to develop mitigation measures for adverse impacts, and to determine whether any of the impacts are significant according to 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 and an action will be permitted to occur. If a study finds that significant impacts are expected to occur because of a proposed action, then an Environmental Impact Statement ( EIS) is prepared in order to allow deeper investigation of impacts and allow more extensive public involvement.

Section 2 considers alternatives to the proposed project, and Section 3 discusses the existing environment and impacts associated with this project. Section 4 discusses the determination ( anticipated determination in the Draft EA), and Section 5 lists the criteria and the findings made by the applicant in consultation with the County of Hawaii Planning Department for this project.

1. 4 Public Involvement and Agency Coordination The following agencies, organizations, and individuals have been consulted during the Environmental Assessment Process:

County: Department of Public Works Planning Department County Council Mayor' s Office Department of Parks and Recreation

Fire Department Police Department Leeward Planning Commission

6 State: Office of Environmental Quality Control Department of Health, Environmental Planning Office Department of Land and Natural Resources ( DLNR): Office of Conservation and Coastal Lands State Historic Preservation Division Division of Boating and Ocean Recreation Office of Hawaiian Affairs— West Hawaii

Federal: United States Army Corps of Engineers

Private: Kona Hawaiian Civic Club Kona Outdoor Circle Adjacent Property Owners Surfrider Foundation

Copies of the communications received during early consultation are contained in Appendix Al, Comments to the Draft EA and resoonses to these comments are contained inAonendix lb. Ssecific wrtions of the Final EA have been modified to reflect comments received' amended or modified text is denoted b double underlinesas in these sentences.

7 2. 0 Alternatives

2. 1 Alternative Locations

Alternative locations are limited to the Kona Reef Condominium property, as use of other properties were not considered feasible for the proposed project. The proposed project would prove most effective on the makai portion of the lawn area, as this location would maximize the erosion abatement effectiveness of the structure, and there are no difficulties apparent with this site, as the proposed action places the erosion abatement structure near the makai boundary of the property. The applicant was not interested in designs that would be located, partly or all, outside of their property primarily as this would not be necessary to achieve project objectives and would introduce unnecessary expense and difficulties. Further, the proposed project site was also selected as the northern portion of the lawn area is not impacted by erosion.

2.2 Alternative Designs

Alternative designs evaluated and weighed for consideration had to satisfy the following project objectives and criteria: ( I) the proposed project must stabilize the lawn area and prevent further erosion; ( 2) the proposed project must not affect the ability of users to enjoy the lawn area and use it for lateral access; ( 3) the project must not affect shoreline processes or adversely affect shoreline access; and ( 4) the project must not detract from the visual character of the area.

The project team evaluated several design options. Placement of rip-rap, or other coarse material, would not have readily achieved the project objectives of stabilizing the fill material that underlies the turf area. Placement of rip- rap or other coarse material could stabilize and hold in place finer material ( i.e., the existing soil) with placement of a geotextile membrane. This solution was evaluated and rejected as it would have required removal of a portion of the lawn area for placement of the rip-rap. Furthermore, rip-rap is used to stabilize shoreline areas that receive wave energy, and is therefore not an appropriate material to achieve project objectives. Such a design would also have either required removal of part of the lawn area, or would have encroached upon the makai State lands ( i. e., the shoreline area). Given the two requirements that the project would be restricted to the Applicant' s property and would retain soil, a solid structure extending down to bedrock is the only practical solution to fulfill project objectives. Another constraint was that of Hawaii County Code ( HCC) Chapter 27 Floodplain Management, which requires that structures within a flood zone cannot increase the volume of runoff to adjacent properties. Furthermore, as discussed in Section 3. 1. 2, HCC Chapter 27 also prohibits increasing the water surface elevation of the base flood at any point. Therefore, the proposed structure cannot be above grade, as this would increase the water surface elevation of the base flood. The proposed project' s design is compliant with these requirements.

8 Use of a geotextile membrane was also considered to stabilize the lawn area. This would require support by placement of cobbles or boulders, but this was rejected as un- aesthetic, and because it would be subject to weathering.

2.3 Proposed Project

The proposed project is described in Section 1. 1 above with engineering drawings shown in Appendix B and annotated photographs showing the current Certified Shoreline Survey in Appendix C.

The structure would be located entirely above the Certified Shoreline and would not be a seawall. Approximately 12 to 18 inches wide on the top- surface and approximately 24 to 36 inches wide at the base, the structure would be anchored in bedrock and would have a length of approximately 220 linear feet. The structure would roughly parallel the Certified Shoreline and would be located mauka of it by a buffer of at least 12 inches. The structure would be embedded in the existing soil on both sides for about '/ n of its length, and on approximately the northern V2 of its length the structure would be exposed on the makai side. Drainage would be a component of the design, so that water in the sub- grade is not retained and flow from the mauka side of the structure to the side would be allowed.

2. 4 No Action Alternative and Alternative Sites

Under the No Action Alternative, the erosion abatement structure would not be built. This EA considers the No Action Alternative as the baseline by which to compare environmental effects from the project.

The obvious costs of the No Action Alternative would be foreseeably adverse impacts to water quality and shoreline/ coastal habitats. Without stabilization, the soil underlying the lawn area will enter the ocean and result in polluted storm water runoff Furthermore, both the residents of the Kona Reef Condominiums and members of the public would lose use of some or all of the lawn area. As the project site is free to be used by members of the public for shoreline access, this resource would be degraded and possibly lost. Within Section 3 the No Action Alternative impacts are discussed only when they are notable, as demonstrating an anticipated significant difference between proposed project impacts.

9 Fi• ure 5. Pro. osed Pro ect She Ma.

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CERTIRE,D SHORELINE SURVEY

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Note: Map produced from overlay of engineering drawings ( Appendix B) and GoogleEarth image, and shows the approximate alignment of the erosion abatement structure and the Certified Shoreline Survey. Erosion abatement structure will be offset from March I, 2017 Certified Shoreline Survey by a minimum of 12 inches.

10 3. 0 ENVIRONMENTAL SETTING, IMPACTS AND MITIGATION The project site is a portion of the Kona Reef Condominium property set between the ocean and the condominiums, and above the shoreline as established by the March 1, 2017 Certified Shoreline Survey ( File No. HA-538). This area is a gradually sloping lawn area used by both the public and Kona Reef residents for sunbathing, shoreline access, lateral access, and other recreational activities. The lawn area is landscaped and irrigated. The Kona Reef Condominium property is bounded on the south by the Waiaha Beach Park ( also known as Honl' s Beach Park) and on the north by private residences and an abandoned resort structure. The shoreline to the west ( i.e. makai side) is a rough and irregular pahoehoe shelf that extends into the ocean by a distance varying from approximately 50— 150 feet in width, with the submerged portion varying with the tides. The climate in this part of Kona is hot and dry, averaging between 20 and 30 inches of rain annually, with a mean annual temperature of approximately 76 degrees Fahrenheit Giambelluca 2016).

3. 1 Physical Environment

3. 1. 1 Geology, Soils, and Geologic Hazards

Environmental Setting

The surface geology consists of lava flows from Hualalai volcano older than 10, 000 years l of age ( Wolfe and Morris 1996). According to the United States Department of Agriculture Soil Conservation Service' s " Web Soil Survey" website, soils in the area are minimal and classified as Waiaha-Punaluu- Lava complex with 2 to 10 percent slopes, formed of ash fields on top of lava, with depth to bedrock of 15 to 25 inches. Above bedrock is a medial silt loam from 0 to 8 inches and extremely cobbly medial fine sandy loam from 8 to 15 inches of depth. This is a well-drained soil with a low to moderately low capacity to transmit water. The land capability classification is 7s, meaning that this soil has severe limitations that make it unsuited to cultivation and that restrict its use largely to grazing, woodland, or wildlife, and is excessively stony( USDA 2017). Haun & Associates ( Appendix D) described the soils as consisting of the following three horizons: ( 1) surficial fill deposits of silt with roots, and varying quantities of sand and clay of approximate depth of 0. 00 to 0. 13 meters, ( 2) fill deposits of silt and silty sand from approximately 0. 13 to 0. 33 meters, and ( 3) beach sand deposits from approximately 0. 33 to 1. 07 meters.

The entire Big Island is subject to geologic hazards, especially lava flows and earthquakes. The U.S. Geological Survey classifies all of Kailua-Kona, which is on the slopes of the dormant volcano Hualalai, as within Lava Flow Hazard Zone 4, on a scale of ascending risk 9 to I ( Wright et al. 1990). This hazard risk is based on the fact that Hualalai has steep slopes and is historically the third most active volcano on the island.

li Lava Flow Hazard Zone 4 areas have had about 5 percent of the area covered with lava since 1800 and less than 15 percent of the area covered in the past 750 years.

Major earthquakes in Hawaii are not rare, and in terms of seismic risk the entire Island of Hawaii is rated Zone 4 Seismic Hazard ( Uniform Building Code, Appendix Chapter 25, Section 2518). Zone 4 areas are at risk from earthquake damage, especially to structures that are poorly designed or poorly constructed. The October 15, 2006 magnitude 6. 7 earthquake' s epicenter was located approximately 13 miles north- northwest of the project site. Other major earthquakes on Hawaii Island include the magnitude 7. 9 1868 earthquake and a magnitude 6. 9 tremor on August 21, 1951 that, " damaged scores of homes on the Kona coast and triggered numerous damaging landslides ( USGS 2016)."

Impacts and Mitigation Measures

Geologic conditions impose no substantial constraints on the project. The abatement structure would displace artificial fill, would be anchored to bedrock, and would not present a hazard in the event of a major earthquake. Although the general area is exposed to a certain degree of hazards from lava flows and earthquakes, the proposed project would present no additional geologic hazard to the public. Landowners and residents of high- hazard lava inundation areas of the island have been made aware of the potential and accept the risks and geologic hazards when they purchase and/ or inhabit such areas. In the event of a major earthquake the erosion abatement structure would serve to prevent soil from entering shoreline areas and consequent sedimentation and adverse water quality impacts.

3. 1. 2 Coastal Setting, Coastal Erosion and Flood Zone

Existing Environment, Impacts and Mitigation Measures The project site is a narrow corridor located mauka of the shoreline as defined by a certified shoreline survey published on March 1, 2017. The elevation of the project site is approximately 4- 8 feet above mean sea level. The certified shoreline roughly follows a topographic change in slope created by the edge of the soil of the Kona Reef Condominiums lawn area and a change of elevation of several feet to the lava shelf of the shoreline area.

Floodplain status for many areas of the Island of Hawaii has been determined by the Federal Emergency Management Agency ( FEMA), which produces the National Flood Insurance Program' s Flood Insurance Rate Maps ( FMEA 2017). The map for the project site is 1551660713D, which designates the area of the subject property where the proposed erosion abatement structure is to be located as Zone AE on the Preliminary DFIRM maps, with a base flood elevation of 10 feet( Figure 6). The shoreline area makai of the project site is designated as Zone VE( Coastal High Hazard Area).

Construction in flood zone AE, as per the Hawaii County Code Chapter 27, cannot increase the water surface elevation of the base flood at any point. As such, the proposed

12 structure cannot be above grade, as this would increase the water surface elevation of the base flood. Therefore, the design is consistent with the flood restrictions of the Hawaii County Code.

Figure 6. Preliminar DFIRM Ma for Pro r used Pro` ect Area

IVA ONE AE•

ONE AE

Note: FEMA flood map with preliminary flood zones shows project site within flood zone AE with a base flood elevation of 10 feet above mean sea level. Flood zones designated AE are special flood hazard areas that correspond to the one hundred- year floodplains.

Dr. John " Jack" Lockwood and Dr. Timothy Scheffler of Geohazards Consultants International, Inc. ( GCI 2016) prepared an assessment of geologic and marine factors that affect shoreline erosion ( Appendix E). This report documents the nature of erosion and shoreline migration at the Kona Reef property, basing this assessment on quantitative measurements and observations obtained through field inspection, aerial photography, satellite imagery and a review of the geologic literature. Additionally, this report assessed potential environmental impacts of the proposed project. GCI described the shoreline area makai of the project site as being underlain by an irregular shelf of dense, nearly flat pahoehoe lavas that also underlie the Kona Reef Condominiums. The age of this flow is estimated to be 10, 000 to 25, 000 years old Wolfe and Morris, 1996). GCI notes that the shoreline in front of the project site contains irregular pockets of unconsolidated sand and boulders. The sand deposits, which can be moved about by surging waves, are derived from the mechanical and biological erosion of offshore coral. GCI notes that a review of aerial photographs shows that there is significant variation in the quantity of sand in these deposits, and this variation is at least partly seasonal. GCI notes no evidence of lateral transport of sand

13 across the pahoehoe platform fronting the project site. Therefore, there is not a physical connection between the variable sand deposits on the pahoehoe shelf fronting the project site and other lateral areas beyond the project site, including Honl' s Beach( Waiaha Bay). GCI also evaluated the wave environment along the Kona Coast. Waves along the Kona Coast have three sources, south swells, Kona storms and northwesterly storms, in addition to tsunami and hurricane swells. Of these wave sources, south swells are the most common, but are also the weakest, with northwest ( i. e., winter) swells being the largest. Hurricanes can produce much larger waves, although the average return period for them is about 40 years. GO notes that of the major storms that have impacted West Hawaii over the past 60 years, four have occurred since the Kona Reef Condominiums were constructed in 1980, but none have caused serious damage. GCI observed that the rock fragments broken off of the pahoehoe shelf and transported to the shoreline are well- rounded, indicating that transport of these rocks outside of the weathering region is infrequent.

Of increasing importance with respect to land use in coastal regions throughout the world is the issue of sea level rise, which exacerbates the effects of wave erosion on the shoreline. The Earth is warming because of increases in human- produced " greenhouse" gases such as carbon dioxide and methane, which in turn has led to a rise in global sea level ( Intergovernmental Panel on Climate Change 2017). The primary mode of warming of these " greenhouse" gases is due to their absorption of thermal infrared radiation from the warm Earth' s surface, preventing escape of this heat energy to space and consequent cooling effects. According to the National Climate Data Center of the National Oceanic and Atmospheric Administration ( NOAA), global mean sea level has been rising at an average rate of 1. 7 mm/ year ( plus or minus 0. 5 mm) over the past century, a rate which has increased over the last 10 years to 3. 1 mm/ year ( Bindoff et al., 2007). NOAA forecasts an expected range of sea level rise over the next century of between 0. 18 and 0. 59 in, due mainly to thermal expansion and contributions from melting alpine glaciers. However, potential contributions from melting ice sheets in Greenland or Antarctica may yield much larger increases. On Hawaii Island, global sea level rise is coupled with local effects of subsidence, so changes in sea level are a combination of the effects of global sea level rise and subsidence of the Island. Long- term ( i. e., on a geologic timescale) subsidence of Hawaii Island, evidenced by a drowned reef terrace west of Kealakekua Bay 10 miles south of the project site formed about 13, 000 years ago, which is now at ISO m of water depth, yields an absolute rate of subsidence of 1. 8 - 3. 0 mm/ year ( Moore 1984). However, given global warming produced sea level rise a somewhat higher annual rate is reasonable. ( Huang 2005) use a figure of 4. 0 ram/ year for global sea level rise, but this does not consider subsidence of the Big Island. Therefore, GCI considers that a larger value of 6. 0 — 7. 0 mm/ year is reasonable for Hawaii Island, resulting in an estimation of about 0. 3 m, or about one foot, in 50 years as a rough estimate.

14 GCI observed unusually high storm wave surges reaching the margin of the lawn fronting the Kona reef property ( Appendix D, GCI Figure 10) and noted that the surges do not move the boulders located within the shoreline area, and may transport already loosened sediments from the margin of the lawn area. In places, OCT estimate, this erosion has caused the lawn to retreat as much as six inches since construction. Overall, however, historic retreat of the shoreline is very minor, evidenced by the presence of the coconut palms planted in the 1980s. GCI concluded that the erosion abatement structure would protect the lawn area from surge waves that can reach the shoreline during times of storms or tsunami. GCI further concludes that the proposed project would have no environmental impact to shoreline processes, or shoreline or marine habitats. In the event of especially large surge waves, such as tsunami waves, they would overtop the proposed structure, which would prevent erosion.

Huang ( 2005), in the Coast Hazard Mitigation Guidebook, recommends that all hazards facing coastal areas, not just erosion, be considered when planning for land use and coastal construction in Hawaii. ( Fletcher et al. 2002) evaluated general coastal zone hazards for much of the State of Hawaii. They rate the hazards for the project vicinity as represented in Table 1.

Table 1. Project Vicinity General Coastal Hazards Summary Hazard Type Relative Threat Scale( 1- 4) Tsunami High 4 Stream Flooding Medium- High 3 High Waves Medium-Low 2 Storms Medium- High 3 Erosion Medium- low 2 Sea Level Change Medium- High 3 Volcanic/ Seismic High 4 Overall Hazard Assessment High 6( on scale of 1- 7)

3. 1. 3 Water Quality

Existing Environmental, Impacts, and Mitigation Measures As discussed in the preceding section, the project site is adjacent to the shoreline. No water features such as streams, springs, or anchialine ponds are found on or near the subject property. Construction of the erosion abatement structure will have a minor, long-term positive impact on coastal water quality by reducing the rate at which soil enters the ocean from the Kona Reef property. In the event of a major tsunami, the proposed project is likely to have a significant positive impact on coastal water quality in the project site vicinity relative to the No Action Alternative.

Construction of the erosion abatement structure will include practices to minimize the potential for sedimentation, erosion and pollution of coastal waters. The bottom of the

15 structure would be well above sea level; therefore construction is not likely to reach groundwater.

As construction of the structure would disturb soil during the construction phase, the potential exists for polluted storm water runoff to leave the site and enter the ocean. No material will be stored or stockpiled within the shoreline setback, including excavated soil and rocks, which will be stored off-site by the contractor. Additionally, in order to minimize the potential for polluted stormwater runoff the contractor will implement Best Management Practices ( BMPs), including covering all areas of disturbed soil with plastic sheeting during non- work hours and during periods of rain. Further, all concrete washing and cleaning of tools and equipment will be performed off-site and wash water will not be allowed to enter storm drains, or allowed to otherwise runoff to areas where it could eventually reach the ocean.

The applicant will ensure that his contractor performs all earthwork in conformance with the following ordinances:

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 Hawaii 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.

No Action Alternative

The obvious costs of the No Action Alternative would be foreseeably adverse to water quality and shoreline/ coastal habitats, and potentially significant adverse impacts during major coastal flooding events. Without stabilization the soil will enter the ocean and result in polluted stonn water runoff. Furthermore, both the residents of the Kona Reef Condominiums and members of the public would lose some, or all, of the lawn area. As the project site is free to be used by members of the public for shoreline access, this resource would be degraded and possibly lost.

3. 1. 4 Flora and Fauna

Existing Environment, Impacts and Mitigation

The project site is located within the coastal strand, and in pre- contact or pre- settlement times would have contained plant species of the coastal strand habitat. However, as the project site has been highly modified by activities that include construction of the Kona Reef Condominiums, the project site now contains largely non-native and ornamental plants.

On March 5, 2016 Dr. Grant Gerrish performed a flora and fauna survey of the project site. A report documenting these surveys is attached as Appendix F. Table 2 lists the plant species observed within the project site.

16 Table 2. Plant Species Identified on the Project Site

Scientific name Common name Origin/ Status

Axonopus compressus Tropical Carpet Grass Introduced

Bougainvillea sp. Bougainvillea Introduced Cynodon dactylon Manienie, Manienie Haole, Introduced Bermuda Grass

Cyperus brevifolius Kilioopu Introduced

Cyperus polystachyos No common name Indigenous

Elusine indica Goose grass Introduced Fimbrystilis dichotoma Forked Fimbry Indigenous

Poa sp. Blue Grass Introduced

Stenotaphrum secundatum St. Augustine Grass, Introduced Buffalo Grass

Of the ten plant species identified within the project site three are considered indigenous, or native, species. None of these three is considered rare, or threatened or endangered, and all three species are common ( Smithsonian 2012). This is reflective of the fact that the species observed are landscaped ornamentals. Therefore, the project would not impact any plant species of concern, rare, threatened, or endangered.

Directly adjacent to the project site are three coconut palms whose root systems may extend into the project site, and may be impacted by the construction activities. These were planted as part of the Kona Reef Condominiums landscaping and are not representative of pre- existing habitat. As project design may include a buffer of 12 inches or more from the certified shoreline, the project would be moved a sufficient distance mauka so that one or more of the coconut trees present may not be impacted.

A number of common introduced bird species were observed within the project site and on adjacent areas. These included the House Sparrow( Passer domesticus), Saffron finch Sicalis,flaveola), Common Waxbill (Estrilda astrild), and Zebra Dove( Geopilia striata). All of these species are common and non- native bird species in urban environments on the Island of Hawaii. The fauna survey further noted that it is possible that the indigenous Kolea, or Pacific Golden Plover ( Pluvialis fulva) would forage within the lawn area. The flora/ fauna report further noted that no non-human mammals were observed on the project site, nor would any be expected to be found in the area due to its highly modified nature.

The shoreline area adjacent to the project site may occasionally be visited by sea turtles including the Pacific Green Sea Turtle ( Chelonia mydas), the Hawksbill Turtle Eretmochelys imbricate), and the Hawaiian Monk Seal ( Neomonachus schauinslandi), species protected by the Marine Mammal Protection Act. Therefore, if these species use

17 the shoreline area during construction, work should halt until the animal leaves the area. The contractor will monitor for the presence of protected sea turtles and monk seals. As afificiaf li htin may adversely affect fauna no artificial lighting would be used durin construction. and construction activities would be limited to da ht hours.

3. 1. 5 Air Quality and Noise

Existing Environment, Impacts and Mitigation

Air pollution in West Hawaii is mainly derived from volcanic emissions containing sulfur dioxide, which convert into particulate sulfate and produce a volcanic haze, or" vog", that routinely blankets North and South Kona.

Noise on the project site is low and derived principal from natural sources such as surf and wind, as well as from residential activities, recreational activities and some traffic noise from Alii Drive.

Project construction would involve excavation with a small excavator, compressors, a portable concrete mixer, and vehicle traffic. These would produce short- term and minor noise and air- quality impacts. Such activities can generate noise exceeding 95 decibels at times, impacting nearby sensitive noise receptors in the immediate vicinity, including the residents of the Kona Reef Condominiums. Whenever construction noise is expected to exceed the Department of Health' s ( HDOH) " maximum permissible" property line noise levels, contractors will be required to consult with HDOH as per Title 11, Chapter 46, HAR ( Community Noise Control) prior to construction. HDOH would then review the proposed activity, location, equipment, project purpose and timetable, in order to decide whether a permit is necessary and what conditions and mitigation measures, such as restriction of equipment type, maintenance requirements, restricted hours, and portable noise barriers, will be necessary. The contractor would consult with HDOH to determine what permit restrictions are necessary. However, due to the proximity to the Kona Reef Condominiums, the contractor will adhere to restrictions on work hours of 8: 00 am to 5: 00 pm Monday through Saturday.

The proposed project would have no long-term noise or air quality impacts.

3. 1. 6 Hazardous Substances, Toxic Waste and Hazardous Conditions

Existing Environment, Impacts, and Mitigation Measures The proposed project is not likely to encounter any hazardous substances, toxic waste, or hazardous conditions. Construction activities would use small quantities of fuels and other chemicals ( i. e., hydraulic fluid) for power generators and construction equipment. These would be stored away from equipment and potential sources of ignition in a secure location.

18 3. 1. 7 Scenic Resources

Existing Environment, Impacts, and Mitigation Measures Due to the project site' s proximity to the ocean, the vicinity is appreciated for its view planes of the ocean where not obstructed by structures. The project site itself affords impressive vistas of the ocean and of the shoreline towards the north towards Kailua Bay.

The Natural Resources Section of the Hawaii County General Plan ( County of Hawaii Planning Department 2005) notes no sites known for their natural beauty in the immediate vicinity of the project site. However, viewplanes to the makai direction from the Kuakini Highway are noted.

As the project would produce no modification to surface features of the project site, it would not result in any modification of viewplanes from the project site, or from areas in the vicinity towards the ocean, and would not result in any adverse impact to scenic resources.

3. 2 Social and Cultural Environment

3. 2. 1 Land Use, Designations, and Controls

Existing Setting, Impacts and Mitigation Measures

The property has a zoning designation of V-0.75 ( Resort- Hotel) by the County of Hawaii and is located within the State Land Use Urban District. The County of Hawaii General Plan Land Use Pattern Allocation Guide ( LUPAG) maps show the project site and vicinity designated as high density urban. The project site is located within the shoreline setback area, which is defined by Hawai` i Revised Statutes Section 205A-43( a) and Planning Department Rule 11- 5, as extending inland from the shoreline a minimum distance of 40 feet. The proposed project would be located within the shoreline setback and would therefore require a shoreline setback variance. As a result, the proposed project triggers the environmental review requirements under Chapter 343, Hawai` i Revised Statutes, known as the " Hawai` i Environmental Policy Act" The authority to determine whether an Environmental Impact Statement is required is the accepting authority, the County of Hawaii Planning Department.

As a recruit of the certified shoreline survey portions of the Kona Reef Condominium structures now are within the 40-foot shoreline setback. These encroachments are labeled in the certified shoreline stove ' resented in An. endix C. This encroachment will be addressed in the shoreline variance application As noted in the coastal erosion evaluation Appendix E), the shoreline margin as defined b the ed• e of the lawn area, has moved little in the oast few decades. Instead,ibis encroachment is more likely to be due to adoption of the certified shoreline rule in 2002, as stated in Hawaii Administrative Rules H Chanter 13- 222 which defines the shoreline as " the upper reaches of the wash of

19 the waves other than storm or seismic waves at hi• h tide, during the season of the war in which t i• hest wash of the waves occurs usuall evidenced b the edge of vegetation growth or the upper limit of debris left by the wash of the waves."

Activities b dr Kona Reef ondominiums in the shoreline setback area fronting the

r ert have involved a number ofpermittingactions. Wes m e i n follows:

1979- 1980 Kona Reef Condominiums Constructed with a total of 12_9 units.

I•: 1 An HRS 343- corn. liant Environmental Assessment dated A. 1 22 1981 was prepared considering the environmental impacts of construction of a 3- foot hi• h seawall installation of a s uinkler s stem and fillin• the area with a.. roximate_ 800 c b c , d of topsoil for the landscapin• of the 40- foot shoreline setback area At the public meeting held on June 25. 1981 the request was withdrawn and the project was not completed.

1981 Shoreline Setback Variance Permit No. 610 issued Julys 1981_ applicant Gentry

by • • Homes Ltd. . Il. • fir wn it •.o ' r withi he h• reline setback area of the Kona Reef Condominiums:

Retention of existing sections of the 3- foot high concrete reinforce masonry LCRMI wall at the mauka end of the shoreline parcel that encroached int. the 40 foot. setback area and related lapdsca.in:= m. r• vement within the h. reline setback area. This CRM wall wa not a seawall nit a landsca. in• and privacy wall constructed at the same time as the condominium structures Portions of this wall encroached into the shoreline setback area.

Implementation of a Shoreline Access Plan consistin• of a delineated pedestrian Basement along the north property line at least 10 feet wide and provisions for

arta across the seaward portions of the subject area

1981 SMA Minor permit 81- 12 issued Jul 15 1981 to applicant Gentr Homes @ermitted landsca.' n• im• rovements in the shoreline setback area for the Kona Reef Condominiums.

1985 Shoreline Setback Variance No. 610 amended Januar 22 1985 as Hart of a ne• otiated settlement between Gen Homes Ltd and the Count of Hawaii' s Corporation Counsel regarding Shoreline Setback violations allowed for amendment of the Shoreline Access Plan to include a public pedestrian access way to the shoreline alone the northern . rose line of the . rose at least 10 feet wide. This amendment als. eliminated the re. uirement to dedicate easements.

2011 Special Management Area Use Permit ApplicationjSAA 11- 000687) dated June 20 2011 for the demolition and new construction replacement of a courtyardgazebo SMA minor permit# SMM 11- 00187 was issued on August 4 2011.

20 2011 ) retial Management Area Use Permit Assessment Application ( SAA 11- 000708 for construction of a wall was later withd tw . the a.. licant becau it did not accurately depict or conve the property owners' desired results and scopelliescope project.

2012 As a re. uir- men or . h. reline urve Certification, on dated March 20, 2012 the Hawaii State Surve ors office , no ated the demolition and remo al . f. 3- foot b 3- foot concrete slab at the south end of t.- • ose n and also removal of info . ti. nal and waminu signs that were aorounder the existing Shoreline Setback Variance # 610 Work was_comoleted on or about August 10. 2012. This certified shoreline survey was certified onAugust 17. 2012.

2012 BestM. na• ement Practices a.. roved for the remov. l . f a concrete and boulder revetment. This removal was required for the shoreline curve certification approval.

211 • ecial Management Area Minor Permit SMM- 000•' 5 wa issued for the re. air of concrete s. allin• and cracks.

2013 On August 6, 2013 permission was received from the Hawaii Count Planninv De. artment to address the re. uirement b the Haw. ii tate Land urve Office to demolish and remove a concrete and boulder revet e tha were encroachin_ onto state lands. This was a o dition of c- rtificati. n . f the shoreline surve . A bond was ec ed in 2012 which allowed the 2012 surve to be certified . rior • corn. Ietion of the demolition in 2013.

2014 Special Management Area Assessment Application ( SAA- 001112) was submitted for demolition and replacement of 13 garden trellises. It was determined by_County of Hawaii Planning Department that a permit was not required for the . roject.

2015 An SMA permit was issued on March 10, 2015 for the removal of a 14- foot section of sea wall encroaching onto stag lap s, he Department of Landand Natural Resources required the removal as a eon. iti. n fir certification of a shoreline surve .

2015 A_bu_ildin•_. ermit was i sued on March 25 2015 for the removal of the 14- foot section of sea wall encroachin• onto state land.

2015 A Wes Thomas Associates submitted shoreline surve was certified on J. 1:

2015.

2016 Wes Thomas Associates contracted to do a new shoreline surve as the previous surve had ex. ired.

2017 The current Shoreline Survey was certified on March 1. 2017.

3.2. 2 Socioeconomic Characteristics and Recreation

Existing Setting, Impacts and Mitigation Measures

The project site is located within the district of North Kona in an area dominated by tourism and recreational activities. The North Kona District is a Census County Division

21 CCD), and according to the United States Census ( United States Census Bureau 2014), and was estimated to have a resident population of 40,480 in 14, 374 households in 2014. Much of this population is resident in single- family homes, with condominiums being more typical of makai areas along Ali' i Drive and in central Kailua-Kona. Areas mauka of Ali' i Drive are predominantly residential.

The shoreline setback area fronting the Kona Reef Condominiums is a turf/lawn area used for sunbathing and public access to and from the shoreline as well as the adjacent Waiaha ( Honl' s) Beach Park. Popular surfing spots are found both in the ocean in front of the Kona Reef Condominiums and Honl' s Beach Park.

The proposed project is expected to have a negligible effect upon the socioeconomic character ofthe project vicinity. However, as the proposed project would serve to protect the visual character of the turf/lawn area and its usefulness for recreation and shoreline access, it would also serve to protect the value of the Kona Reef Condominium property.

3. 2. 3 Cultural and Historic Resources

The cultural value of the project site, and potential impacts to that value resulting from the proposed project, was assessed as part of this EA. The purpose of this assessment was to determine whether the subject property supports any traditional gathering uses, was vital for access to traditional cultural sites, or has other important symbolic associations for native Hawaiians.

It should be emphasized that the proposed project is limited to a narrow corridor of about 220 feet of length of a landscaped lawn area, and that the proposed project would not appreciably modify the physical characteristics of the project site. As the project site is frequently used to access offshore surfing areas, this assessment included a records search for the ahupua`a of Wai` aha 1, as well as observations of the site.

Historical and Cultural Background

The Kona District, as well as the project vicinity, figures prominently in the history of the Hawaiian Islands. Kona became a residence of many of the alii (chiefs) of the Island of Hawaii beginning with Umi- a- liloa, who unified the island circa 1525. By this time, the island was divided into six districts or moku- o- loko ( Fornander 1973— Vol. II: 100- 102). On Hawaii Island, the district of Kona is one of six major moku- o- loko within the island. Kona, like other large districts on Hawaii, was further divided into smaller land divisions i. e., ` okana or kalana), including that of Kona ` akau( North Kona), which extended from Lanihau to Pu' uohau.

Like Umi- a- liloa centuries before upon unification of Hawaii, Kamehameha I also moved his court to Kona after unification of all the islands to Kamakahonu in the ahupua' a of Lanihau ( present- day Kailua-Kona). Here Kamehameha spent the last years of his life and died in 1819 ( Menton 1994: pp. xv-xvii).

22 The project area is located within the ahupua' a of Waiàha 1, meaning " gathering water" Pukui, 1976). Haun & Henry( 2016) state that this name is possibly derived from Maò Heiau, a heiau located on the north side of Waiàha Bay. Rechtman ( 2002) stated that this ahupua' a contained ceremonial complexes and high status residences with the majority of pre- contact and early post- contact sites situated in the coastal portion of Wai` aha. Maly( 1996) translated portions of the Hawaiian newspaper Ka Hoku o Hawaii between 1914 and 1977, including the following account that signifies the agricultural importance of Wai` aha:

The story is set in about the 13th century, in the time of Pili-a- Ka`aiea ( Pili), sovereign chief of all Kona, the narrative identifies the lands between Lanihau [ Kailua] and Puapua' a as an integral component of Pili' s royal domain. Pili was a great advocate of contests in debating, fighting and physical strength, and Hinakahua at Puapua' a was the site of the chiefs longhouses and contest field which supported those activities. While Pili was at Hinakahua, he was supported by the agricultural and natural resources of the surrounding ahupua' a including Kahului, Waiaha, Pua` a, Auhaukea` e, Hinaloli ( Hienaloli), Honuala, Keopu, Moeauoa and Lanihau. Pili' s royal compound was at Niumalu, his canoe fleets

were harbored at Oneo ( and his wealth-houses, where tribute was kept until it was needed, were situated at Ahu' ena. t--\

Wai`aha' s importance to the Hawaiian royalty continued after western contact, and Queen Emma, wife of Alexander Liholiho ( Kamehameha 11), had a residence and associated gardens in inland Wai` aha.

A portion of the Kona Reef condominium property along Kahakai Road was formerly composed of Land Commission Award 7481, and was awarded to Kalae as Royal Patent 3682, a 1. 61- acre claim comprised of two partially cultivated land sections.

The advent of tourism marked the next significant change for the Kona District, marked by the construction of Kona' s first major hotel, the Kona Inn, in 1928 ( Menton 1994). The old Kona airport was constructed in 1945, abandoned in 1970, and made a State park in 1975.

As the project site is now developed and largely modified from pre- existing times, and to a greater degree, pre- contact times, and contains no surface archaeological sites ( see Existing Archaeological Resources below) the cultural associations of this portion of Waiaha I, are generally not evident. The project site' s location adjoining the shoreline suggests that the area may be used for the traditional activities of fishing and gathering of ocean resources within the coastal strand habitat. The project site, however, does not contain habitat that would be of interest to gatherers, however, and has not been used for

Native Hawaiian ceremonial purposes, although the project site might be used by j

23 individuals to access the shoreline for fishing or gathering of ocean resources. These practices would not be adversely impacted by the proposed project. ft is anticipated that the proposed project would preserve shoreline access for those using the lawn area to access shoreline areas, as the proposed project would preserve the condition of the lawn

area.

Commercial agriculture in the form of sugar cane cultivation came to Kona and Wai`aha in the late 1800s and early 1900s ( Kelly 1983), although remained above approximately 600 feet elevation. The Kona Sugar Company mill, constructed in 1902, was located in upland Waiaha, overlooking Kailua at about 700 feet of elevation. Haun& Henry ( 2016) stated that as the 1970' s brought development related to tourism to North and South Kona, the use of the Kona Reef condominium site was probably limited to cattle ranching. In 1927, rancher Manuel Gomes brought tracts of land in Wai`aha and Kahului and used these lands for cattle grazing until the 1960s( Rechtman 2002).

In an attempt to gather information concerning cultural uses of the project site and vicinity, Native Hawaiian cultural organizations were contacted including the Kona Hawaiian Civic Club and the Office of Hawaiian Affairs. However, no responses were received. It is apparent that traditional cultural practices of fishing and gathering of ocean resources such as limu and opihi, in addition to surfing, are likely to occur in the project vicinity.

C- 3. 2.4 Archaeology and Historic Sites Environmental Setting, Impacts and Mitigation Measures

No sites are listed on the National and State Register of Historic Places either on or directly adjacent to the subject property, according to published lists of Register sites maintained by the State Historic Preservation Division. The nearest sites listed on the National and State Register of Historic places are Kamakahonu, located approximately 0. 8 mile north-northwest of the project site, and the Kamoa point sites, located

approximately two miles south-southeast of the project site.

In order to evaluate the potential for subsurface archaeological resources to exist in the project site, Haun & Associates was retained to perform an archaeological inventory study ( Appendix D). Haun & Associates excavated a set of square test shovel holes along the erosion abatement structure corridor. These holes revealed that a layer of fill of thickness varying from 0. 16 m to 0. 93 m, covered native beach sand deposits of thickness varying from 0. 16 m to 0. 89 m, over pahoehoe bedrock. Excavation of the native sand layer revealed the remnant of a subsurface cultural deposit ( Site 50- 10- 28- 30493), a deposit containing pre- and/or post- contact traditional Hawaiian material. Haun & Associates concluded that the site is significant for its information content and recommended no further work or preservation due to the disturbed nature of the deposit.

24 Sub- surface archaeological resources may exist in the projects site, and project construction may inadvertently reveal these resources. If archaeological resources or human are encountered during project construction, work in the immediate area of the discovery should be halted and DLNR-SHPD contacted as outlined in Hawaii Administrative Rules § 13- 275- 12. Although DLNR- SHPD has not responded to the consultation by Hauna & Associates by the time of this writing, a period of approximately 10 months, the archaeological inventory survey has been prepared to fulfill the requirements of Hawaii Administrative Rule 13- 13- 276 and DLNR-SHPD implies concurrence with the findings and recommendations of the Archaeological Inventory Report.

3. 3 Public Facilities, Public Access and Utilities

Environmental Setting, Impacts and Mitigation Measures

Kahakai Road passes along the north side of the Kona Reef Condominiums, and Ali' i Drive forms the eastern property boundary. The site is serviced by underground power and telephone lines from HELCO and Hawaiian Telcom. Water service is provided by the County of Hawaii Department of Water Supply. Wastewater disposal is through the County municipal sewage system. Waiaha County Beach Park is adjacent to the Kona Reef Condominiums property, and provides no services to users. No other public facilities are present. No adverse impact to public facilities or utilities would occur.

Shoreline Setback Variance No. 610, as amended, required preparation of a Shoreline Public Access Plan, which allows ( 1) public access at least 10 feet wide through the north Kona Reef property boundary to the shoreline; and ( 2) lateral public access through the lawn area. As the proposed project would preserve the lawn area and would therefore preserve lateral public access through the lawn area, it would therefore facilitate the preservation of public access to the shoreline and lateral access along the shoreline.

3. 4 Secondary and Cumulative Impacts

The small scale of the proposed project would not produce any secondary impacts, such as population changes or effects on public facilities. Cumulative impacts result when several projects that individually have limited impacts combine to produce more significant impacts that may require coordination for mitigation. However, the scope of the proposed project is very limited in scale, and none of the impacts are expected to occur in areas outside of the project site and the Kona Reef Condominium property. Therefore, the proposed project is not of the type that would result in cumulative impacts.

The adverse effects of construction of the proposed erosion abatement structure on the subject property are very minor and include temporary disturbances to air quality, noise, and visual quality during construction. Other than the precautions for preventing any effects to water quality during construction listed above in Section 3. 1. 3, no special mitigation measures should be required to counteract any small, adverse cumulative iJ

25 effect of nearby construction. It is particularly important to note that the project is expected to generate negligible scenic impact, no long-term adverse impact to public use and enjoyment of adjacent shoreline areas, and no effect to historic or cultural properties. There would thus be no risk of cumulative impact to these resources.

3. 5 Required Permits and Approvals

County of Hawai` i

Shoreline Setback Variance

Special Management Area Permit or Exemption

Plan Approval

Building Permit

State of Hawai` i

Certified Shoreline Survey

3. 6 Consistency with Government Plans and Policies

3. 6.1 County of Hawaii General Plan The General Plan for the County of Hawai` i is the document expressing the broad goals and policies for the long-range development of the Island of Hawaii. The plan was adopted by ordinance in 2005. The General Plan is organized into thirteen elements, with policies, objectives, standards, and principles for each. There are also discussions of the specific applicability of each element to each of the nine judicial districts comprising the County of Hawai` i. Below are pertinent sections followed by a discussion of conformance of the proposed project to each.

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 Hawaii.

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.

Discussion: Construction of the erosion abatement structure would not be out of balance with the County' s natural and social environments, would create temporary construction jobs for local residents, and would indirectly have a minor positive impact to the economy through construction industry use of local vendors for materials and equipment. A multiplier effect takes place when these employees spend their income for food,

26 housing, and other living expenses in the retail sector of the economy. Such activities are in keeping with the overall economic development of the island.

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.

ENVIRONMENTAL QUALITY POLICIES

a) Take positive action to further maintain the quality of the environment.

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 t

ordinances or as conditions of approval.

c) Federal and State environmental regulations shall be adhered to.

Discussion: The proposed project would not have a significant adverse effect on the environment and would not diminish the valuable natural resources of the region. The erosion abatement structure would prevent adverse water quality impacts in the long- term, and short-term potential impacts would be mitigated with implementation of Best Management Practices during construction. The project would not cause pollution and adverse shoreline impacts would not occur.

FLOODING AND OTHER NATURAL HAZARDS GOALS

b) Prevent damage to man-made improvements.

c) Control pollution

d) Prevent damage from inundation.

e) Reduce surface water and sediment runoff.

I) Maximize soil and water conservation.

FLOODING AND OTHER NATURAL HAZARDS POLICIES

27 d) Any development within The Federal Emergency Management Agency designated flood plain must be in compliance with Chapter 27.

Discussion: The proposed project would serve to prevent damage to the lawn area, would control sediment pollution of the ocean by preventing sediment runoff, and would prevent damage to the lawn area, in the event of inundation of the project site from storm surge or tsunami inundation.

HISTORIC SITES GOALS

a) Protect, restore, and enhance the sites, buildings, and objects of significant historical and cultural importance to Hawaii.

b) Appropriate access to significant historic sites, buildings, and objects of public interest should be made available.

HISTORIC SITES POLICIES

a) Agencies and organizations, either public or private, pursuing knowledge about historic sites should keep the public apprised of projects.

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: It has been determined through consultation with the State Historic Preservation Division that no archaeological or cultural sites recommended for preservation appear to be present on the project site or would be affected by the proposed

action.

FLOOD CONTROL AND DRAINAGE 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.

FLOOD CONTROL AND DRAINAGE POLICIES

a) Enact restrictive land use and building structure regulations in areas vulnerable to severe damage due to the impact of wave action. Only uses that cannot be located

28 elsewhere due to public necessity and character, such as maritime activities and the necessary public facilities and utilities, shall be allowed in these areas. 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.

Discussion: The proposed project is consistent with land use and building structure regulations, and the erosion abatement structure will be anchored to underlying bedrock. The proposed project will result in no net increase in runoff. The proposed project would directly prevent damage from inundation and would control pollution by reducing sediment runoff.

FLOOD CONTROL AND DRAINAGE STANDARDS a)" Storm Drainage Standards," County of Hawaii, October, 1970, and as revised. b) Applicable standards and regulations of Chapter 27, " Flood Control," of the Hawaii 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 Hawaii County Code.

7 e) Applicable standards and regulations of the Natural Resources Conservation Service and the Soil and Water Conservation Districts.

Discussion: The project site is within the AE Zone, or areas within the 100- year Floodplain as determined by detailed methods in the community flood insurance study, according to the Flood Insurance Rate Maps ( FIRM). The improvements are subject to review by the Hawai` i County Department of Public Works to ensure that all relevant standards of Chapter 27 and Chapter 10 of the Hawaii County Code are addressed.

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.

NATURAL BEAUTY POLICIES

a) Increase public pedestrian access opportunities to scenic places and vistas.

b) Develop and establish view plane regulations to preserve and enhance views of scenic or prominent landscapes from specific locations, and coastal aesthetic values.

29 Discussion: The proposed project would maintain the integrity of the lawn area fronting the Kona Reef Condominiums, and would therefore maintain the natural beauty of the area. Maintenance of the lawn area would directly maintain public access to the shoreline and adjoining Wai` aha Beach Park.

NATURAL RESOURCES AND SHORELINES GOALS

a) Protect and conserve the natural resources from undue exploitation, encroachment and damage.

b) Provide opportunities for recreational, economic, and educational needs without despoiling or endangering natural resources.

c) Protect and promote the prudent use of Hawaii's unique, fragile, and significant

environmental and natural resources.

d) Protect rare or endangered species and habitats native to Hawaii.

e) Protect and effectively manage Hawaii' s open space, watersheds, shoreline, and

natural areas.

f) Ensure that alterations to existing land forms, 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. l - 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.

c) Maintain the shoreline for recreational, cultural, educational, and/ or scientific uses in a manner that is protective of resources and is of the maximum benefit to the general

public.

d) Protect the shoreline from the encroachment of man-made improvements and

structures.

h) Encourage public and private agencies to manage the natural resources in a manner that avoids or minimizes adverse effects on the environment and depletion of energy and natural resources to the fullest extent.

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.

30 Discussion: The proposed project would protect shoreline habitat by reducing Tong- term soil loss and sedimentation from the project site to the adjacent shoreline area.

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.

LAND USE POLICIES

c) Allocate appropriate requested zoning in accordance with the existing or projected needs of neighborhood, community, region and County.

LAND USE, OPEN SPACE GOALS

a) Provide and protect open space for the social, environmental, and economic wellbeing of the County of Hawai` i and its residents.

b) Protect designated natural areas.

LAND USE, OPEN SPACE POLICIES

a) Open space [ in the County of Hawai` i] shall reflect and be in keeping with the goals, policies, and standards set forth in the other elements of the General Plan.

Discussion: The proposed project does not detract from the open space in the area ( i. e. Wai`aha Beach Park). Lateral access, frequently used by the public, would be maintained.

3. 6. 2 Special Management Area

The project site is located within the Special Management Area ( SMA). After the conclusion of the EA process, Kona Reef AOAO will apply for a Special Management Area minor permit with this Environmental Assessment attached. However, the proposed action complies with provisions and guidelines contained in Chapter 205A, Hawaii Revised Statutes ( HRS), entitled Coastal Zone Management. The proposed action would be consistent with Chapter 205A because it would not adversely affect historic resources, scenic and open space resources, economic uses, coastal hazards, or public access to recreation areas, as discussed below.

Recreational Resources: The project site is located mauka ( i. e., uphill of) of the shoreline, and is currently maintained as a flat, lawn area used primarily by recreational users from the Kona Reef condominiums as well as members of the public. As the proposed project is intended to preserve this lawn area from degradation by erosion, it would serve to protect both recreational use of the project site itself, and access to recreational resources, including both the adjacent shoreline, Honl' s Beach, and offshore areas used for surfing and water sports.

31 i Historic Resources: An archaeological inventory survey of the project site has been completed and no sites appear to be present on the surface. The archaeological inventory survey identified a subsurface cultural deposit, and the site consisting of this deposit was assessed as significant for its information content only, and no further work or preservation is recommended. DLNR-SHPD has implied its concurrence with the recommendations and findings of this work.

Scenic and Open Space Resources:

Rule 9 of the Hawaii County Planning Commission Rules intends to prevent development that would " substantially interfere with or detract from the line of sight toward the sea from the State Highway nearest the coast or from other scenic areas identified in the General Plan." As the proposed structure would be built flush to the existing ground surface it would not obstruct any views of the ocean or any other scenic areas.

Coastal Ecosystems:

The project site and property are adjacent to the shoreline. The proposed project would minimize the potential for soil and polluted storm water runoff to enter the ocean by stabilizing the soil underlying lawn area.

3. 6. 3 Shoreline Setback Rules

Rule 11 ( Shoreline Setback) of the Hawaii County Planning Department Rules of Practice and Procedure governs uses within the Shoreline Setback Area. Pursuant to Rule 11- 6( b), all structures and activities that do not qualify under section 11- 7( a) through ( c) are prohibited in the shoreline setback area, unless the applicant obtains a Shoreline Setback Variance or the Planning Director determines that it is a " minor activity... that does not adversely affect the shoreline" in the context of the rules and is thus exempt."

Planning Commission Rules of Practice and Procedure, which provide for the variance process in section 8- 8 and defines the criteria for approving a variance in Section 8- 10. Section 8 10( b) ( 3) states that:

c) No variance shall be granted unless appropriate conditions are imposed as

applicable: 1) To comply with Chapters 10 and 27 of the Hawaii County Code relating to Erosion and Sedimentation Control and Flood Control, respectively; 2) To maintain safe lateral access along the shoreline or adequately substitute for its loss; 3) To minimize risk of adverse impacts on beach processes; 4) To minimize risk of structures failing and becoming loose rocks or rubble on public property; and 5) To minimize adverse impacts on public views to, from, and along the shoreline. that conforms to the purpose of Rule 8, Section 8- 2. The erosion

32 abatement structure would prevent any encroachment onto the shoreline area, the proposed structure is at grade and would not be perceived as " massing of concrete." The proposed action would not cause the loss of sand, coral or rocks from the shoreline. The proposed improvement would not endanger any residential dwellings. Section 8- 10( b)( 3) continues:

Discussion: The erosion abatement structure will comply with Chapters 10 and 27 of the Hawaii County Code, pertaining to Erosion and Sedimentation Control and Flood Control, respectively. The proposed project will reduce the potential for adverse impacts on beach process, notable the potential for discharge of polluted storm water runoff to shoreline areas. The proposed project would not adversely impact public views to, from, and along the shoreline, as it would be built flush to the existing ground surface. The proposed project would have no encroachment on the shoreline area, and would be built above the certified shoreline, would not cause the loss of sand, coral, or rocks from the shoreline, and would not endanger any residential dwellings.

3. 6. 4 Kona Community Development Plan

The Kona Community Development Plan ( CDP) encompasses the judicial districts of North and South Kona, and was developed under the framework of the February 2005 County of Hawai` i General Plan. Community Development Plans are intended to translate broad General Plan Goals, Policies, and Standards into implementation actions as they apply to specific geographical regions around the County, and to serve as forums for community input. The General Plan now requires that a Community Development Plan shall be adopted by the County Council as an " ordinance," giving the CDP the force of law. This is in contrast to plans created over past years, adopted by " resolution" that served only as guidelines or reference documents to decision-makers. The Kona CDP was adopted in September 2008 by the County Council. The version referenced in this Environmental Assessment is at: http:// www.hawai icountvcdp.info/ north-and-south-kona-cdp/ cdp- final- drafts/Final% 20KCDP Sept% 202008 text. pdf/view

The Plan has many elements and wide- ranging implications, but there are several major strategies that embody the guiding principles related to the economy, energy, environmental quality, flooding and other natural hazards, historic sites, natural beauty, natural resources and shoreline, housing, public facilities, public utilities, recreation, transportation and land use.

The erosion abatement structure is consistent with, or not inconsistent with, all aspects of the Kona CDP. The project' s purpose reflects Section 4. 3. 2, Environmental Resources, which calls for managing the impacts of development on natural resources, and is detailed in Objective ENV- 1: Managing Impacts:

33 In order to minimize impacts on the land, make use of best management planning practices for any land-based endeavor by balancing public and private rights, and taking advantage of an ever-improving knowledge of resource sensitivity and natural processes.

The proposed project is consistent with this section of the Kona Community Development Plan as it preserves the lawn area used by the public, in a manner that also prevents potential future adverse impacts on the land and ocean.

4. 0 DETERMINATION, FINDINGS AND REASONS

4. 1 Determination

Based on the findings below, and upon consideration of comments to the Draft EA, the County of Hawaii Planning Department has determined that the proposed action will not have any significant effect in the context of Chapter 43, Hawaii Revised Statutes and section 11- 200- 12 of the State of Hawaii Administrative Rules, and has issued a Finding of No Significant Impact ( FONSI). The findings below present the reasons the proposed project is not expected to have any significant effect in the context of Chapter 343, Hawai` i Revised Statues and Section 11- 200- 12 of the State Administrative Rule.

4. 2 Findings and Supporting Reasons

1. The proposed project will not involve an irrevocable commitment or loss or destruction of any natural or cultural resources. No valuable natural or cultural resource would be involved, committed or lost. No native ecosystems or historic sites are present. No valuable cultural resources or practices such as coastal access, fishing, gathering, hunting, or access to ceremonial activities would be affected in any way. 2. The proposed project will not curtail the range of beneficial uses of the environment No restriction of beneficial uses would occur.

3. The proposed project will not conflict with the State's long-term environmental policies.

The State' s long- term environmental policies are set forth in Chapter 344, HRS. The broad goals of this policy are to conserve natural resources and enhance the quality of life. The project is minor and its impacts are negligible, and it is thus consistent with all elements of the State' s long-term environmental policies. 4. Theproposedproject will not substantially affect the economic or social welfare of the community or State.

The project would not have any substantial effect on the economic or social welfare of the Kona community or State.

34 5. The proposed project does not substantially affect public health in any detrimental way.

The project would not affect public health and safety in any way.

6. The proposed project will not involve substantial secondary impacts, such as population changes or effects on public facilities.

As the project is minor, it would not involve any substantial secondary impacts, including population changes or effects on public facilities.

7. The proposed project will not involve a substantial degradation of environmental quality.

The project is minor, environmentally benign, and it would thus not contribute to environmental degradation.

8. The proposed project will not substantially affect any rare, threatened or endangered species offlora orfauna or habitat. The project site has been previously modified, is landscaped, and supports almost entirely non- native plant species, with the exception of several coconut palms. No rare, threatened or endangered species of flora or fauna are known to exist on the project site, and none would be affected by any project activities. 9. The proposed project is not one which is individually limited but cumulatively may have considerable effect upon the environment or involves a commitment for larger actions.

The adverse effects of constructing the erosion abatement structure are very minor and involve temporary disturbance to scenery and noise during construction, primarily affecting residents of the Kona Reef Condominiums. The project is not related to other activities in the region in such a way as to produce adverse cumulative effects or involve a commitment for larger actions. Other than the precautions for preventing any effects to water quality during construction listed above, no special mitigation measures would be required.

10. The proposed project will not detrimentally affect air or water quality or ambient noise levels.

No substantial effects to air, water, or ambient noise would occur. Brief, temporary effects could occur during construction and will be mitigated. 11. The project does not affect nor would it likely to be damaged as a result of being located in environmentally sensitive area such as a flood plain, tsunami zone, erosion- prone area, geologically hazardous land, estuary,fresh water, or coastal area. The project is inside the flood zone, according to FIRM maps, but all improvements will conform to appropriate regulations development within such zones. Although concerning t l

35 the proposed project would be located in a zone exposed to earthquake and volcanic hazards, there are no reasonable alternatives that would avoid such exposure. The proposed erosion abatement structure is unlikely to be damaged in the event of a tsunami. 12. The project will not substantially affect scenic vistas and viewplanes identified in county or state plans or studies. The project is low-profile, would be build flush to the existing ground surface and would not impact views to, from or along the shoreline, nor any views listed in the Hawaii County General Plan or other plans.

13. The project will not require substantial energy consumption. Small amounts of energy input would be required for construction and operation.

36 5.0 REFERENCES

Bindoff, N., et al. 2007. Observations: Oceanic climate and sea level, in Climate Change 2007: The Physical Science Basis. Contribution ofWorking Group Ito the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, edited by S. Solomon, D. Qin, M. Manning, Z. Chen, M. Marquis, K. B. Averyt, M. Tignor, and H. L. Miller, Cambridge Univ. Press, Cambridge, U. K.

County of Hawaii Planning Department. [ February 2005 ( as amended)]. The County of Hawaii General Plan. Hilo, Hawaii.

FEMA 2017. FEMA Flood Map Service Center. Downloaded April 5, 2017 from https:// msefema.gov/ portal

Fletcher, C. H., et al. 2002. Atlast of Natural Hazards in the Hawaiian Coastal Zone: USGS, Geologic Investigations Series Map 1- 2761. Washington, D.C.: U.S. Geological Survey. Fomander, A. 1973 An Account of the Polynesian Race, Its Origin and Migrations. Rutland, Vermont and Tokyo: Charles E. Tuttle Company. GCI 2016. Geologic and Marine factors that Affect Shoreline Erosion, Kona Reef Condominiums, North Kona District, Hawaii. Volcano, Hawaii.

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 Hawaii. Bulletin of the American Meteorological Society 94:313- 316. Haun, A., & Henry, D. 2016. Draft Archaological Inventory Survey, Kona Reef Condominium Erosion Abatement Structure Project, Report 932- 041516. Kailua-Kona: Ham& Associates.

Huang, D. 2005. Hawaii Coastal Zone Mitigation Handbook: Hawaii Coastal Zone Management Program. Honolulu: State of Hawaii, Department of Business and Economic Development.

Intergovernmental Panel on Climate Change. 2014. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and UI to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [ Core Writing Team, R.K. Pachauri and L.A. Meyer( eds.)]. IPCC, Geneva, Switzerland, 151 pp. Kelly, M. 1983 Na Mala 0 Kona: Gardens of Kona. A History of Land Use in Kona, Hawai` i. Departmental Report Series 83- 2. Department of Anthropology, B.P. Bishop Museum, Honolulu. Prepared for the Department of Transportation, State of Hawai` i. Maly, K. 1996 Appendix A- Historical Documentary Research. Archeological Inventory Survey, Hienaloli 3 and 4, North Kona District, Island of Hawai' i (TMK: 7- 5- 11: 2) by Henry, J. D., T.R. Wolforth, and P. H. Rosendahl. PHRI Report 1348- 032996. Prepared for Maryl Development, Inc.

37 Menton, L. K. 1994. Kona in History: A Guide to Resources. Honolulu: History and Humanities Program of the State Foundation on Culture and the Arts in cooperation with the Kona Historical Society

Moore, J. A. 1984. Drowned Reefs as Indicators of the Rate of Subsidence of the Island of Hawaii. Journal of Geology v. 92, pp. 752- 759. Pukui, M. E. 1976. Place Names of Hawaii. Honolulu: University of Hawaii Press. Rechtman, R. 2002 An Archaeological Inventory Survey of TMK: 3- 7- 5- 18: 08, Wai' aha 1st Ahupua' a, North Kona District, Island of Hawai` i. Prepared for Dan Bolton.

Smithsonian. 2017. Flora of the Hawaiian Islands. Downloaded April 5, 2017 from http:// botany.si. edu/pacificisl andbiodiversity/hawaiianflora/

US Census. 2017. American Fact Finder. Downloaded April 5, 2017 from https:// factfinder.census. gov/ faces/ nav/jsf/pagesiindex.xhtml. USDA 2016. Web Soil Survey. United States Department of Agriculture Natural Resources Conservation Service. Downloaded April 5, 2017 from https:// websoilsurvey. sc.egov. usda. gov/ App/HomePage.htm

USGS. 2016. Earthquakes in Hawaii: What you need to know. Downloaded April 5, 2017 from https:// hvo.wr.usgs.gov/ products/ PPT_EQ% 20in%20Hawaii_ 2015- 2019.pdf Wolfe, E. W., & Morris, J. 1996. Sample data for the geologic map of the island of Hawaii ( No. 2524- B).

Wright, L. W., et al. 1992. Map Shoring Lava- Flow Hazard Zones, Island of Hawaii, USGS Miscellaneous Field Studies, Map MF-2193. Washington, D.C.

38 APPENDIX IA: COMMENT LETTERS IN RESPONSE TO EARLY CONSULTATION William P. Kenoi Mayor Duane Kanuba Director

Bobby Command Deputy Director

Wal Hawaii Office

74- 5044 Ana Kedwkalok HwyEnvIOl Hawaii Office Kailtu-Kma. Hawaii 96740 of Hawaii ilii 1116. n0 Phone( 808) 323- 4770 County Phone( 8MB) 961- 8288 Fag( 808) 327-3563 PLANNING DEPARTMENT Fru( 808) 961- 8742

August 20, 2014

Graham Paul Knopp, Ph.D. P. O. Box 131 0- Honoka' a, HI 96727

Dear Dr. Knopp:

SUBJECT: Accepting Agency for an Environmental Assessment Shoreline Setback Variance for Erosion Abatement Project Landowner: AOAO Kona Reef Inc. Tax Map Key: 3) 7-5-018:071: North Kona. llawai`i

This is to acknowledge receipt on August I1, 2014 of your request for confirmation that the County of Hawaii will act as the accepting agency for an environmental impact assessment prepared per Chapter 343, Hawaii Revised Statutes, as a requirement for a shoreline setback variance application. Per Planning Department Rules of Practice and Procedure, Rule I1- 10, the Planning Department shall be the approving agency for all environmental assessments prepared in fulfillment ofthe requirements ofa shoreline setback variance application. As such, this letter will confirm our responsibility as the accepting agency for the subject request.

Please direct further communications regarding the environmental assessment and shoreline setback variance application to our Planning Division manager, Mr. Daryn Arai, at 961- 8142 or Darvn.ArniAhawailcounty.gov.

Sincerely, el p u- lam; DUANE :) Planning s vector

LM: cs P: 1wpww60136key< nwaaoquiry rt) 5 018 071.doc

cc: Mr. Daryn Arai, Planning Department

WNW. COMA amiina4ea. wm Hawaii is an Equal Provider Caunly Opportunity and Employer da 6 otunii hli 6111li ' IP 1, ILL ar NI. unr Or

19' x9 , i.: y 1 M1YAU Ei LI

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t STATE OF HAWAII k+ T' cMHn. DEPARTMENT OF LAND AND NATURAI. RE40LRCFS w r or c Of FR: ntsERVA1 ION ANI) COASI AL LANDS u,. POSt OFFICE 10X 621 i5. 11. A11L. L II PA11 OLsizt DLNR, OCCL, NF Correspondence HA- 16- 9d

Graham P. Knopp. Ph. D. OK Environmental, LLC P. O. Box 1363 NOV 2 0 X015 I- lonokaa. I-II 96727

St IBlECT: Early Consultation for the Kona ReefCondominium Erosion Abatement Structure Draft Environmental Assessment, Located at 75- 5R88 Alii Drive, Kailua-Kona. lowed_ Tax Map Key: ( 3) 7- 5- 018:071

Dear Mr. Knopp.

The Department of Land and Natural Resources ( DL-NR), Office of Conservation and Coastal Lands ( OCCL) is in receipt of your letter dated November 9, 2015 regarding an early consultation for the draft environmental assessment for a proposed project at the Kona Reef Condominiums located at TMK (3) 7-5- 018:071. Your firm. GK Environmental. LLC. has been retained to perform the environmental assessment for the proposed project. As stated in your letter. the purpose of the proposed project is to prevent the erosion of soil into the ocean and maintain the lawn area fronting the subject property. According to your letter. the proposed project involves constructing a 200- foot long concrete- rubble masonry erosion abatement structure that would match the existing grade. and would be located rnauka of the previously determined shoreline. For half of the length of the proposed strucDve the top surface would meet the existing grade on both sides, so that neither the ntauka or makai faces would be exposed. In the makai areas where the grade is lower than the top ofthe structure, the lava rock veneer would be exposed, You included a map with your letter that shows the approximate size and location of the proposed structure, As stated in your letter, the environmental assessment will examine the impacts to shoreline resources, public access. Bum and fauna. water quality. historic properties, cultural impacts, and other considerations, While preparing the environmental assessment, OCCL recommends that you assess how the proposed structure will abide by the rules and objectives set forth in Hawaii Revised Statutes FIRS) Chapter 205A Coasta) Zmre Management and examine how the proposed structure will atTect coastal resources and public access. In addition, OCCL recommends that you conduct a thorough analysis of alternative options for managing shoreline erosion.

U rtex71 : Graham P. Knopp, Ph. D. Correspondence 11. A- I6- 94

Thank you for the opportunity to comment on the proposed project. OCCL kindly requests that you include us throughout the environmental assessment process and provide our office with copy of the Draft Environmental Assessment.

Should you have any questions, please feel free to contact Coastal Lands Program Specialist Natalie Farinholt in the Office of Conservation and Coastal Lands at ( 808) 587- 0399 or via email at Natalie. A. FarinhoktrThawaii. gov.

Sincerely.

L J. LEM, O, Administrator Office of Conservation and Coastal Lands

Cc: Hawaii LAND County of Hawai i. Planning William P. Kenai yap,. Harry S. KtiImpel t radio- n,,,., J

Paul K. Ferreira nry, o, y P. q4^ Clio r County of Hawai' i POLtcE DEPARTMENT 9V rwpinhn, Stitt, • I IJa Hunm' t 967 t). PNF December 4, 2015 OM, 4; 5- 3111 • rm tFn+ t 9,• L: 3a9

Mr, Graham Paul Knopp, Ph. D. GK Environmental LLC P. O. Box 1363 Honoka' a, HI 96727 ookno0Dtalgmail. cam

SUBJECT: EARLY CONSULTATION FOR KONA REEF CONDOMINIUM EROSION ABATEMENT S I RUCTURE IN THE SHORELINE SETBACK DRAFT ENVIRONMENTAL ASSESSMENT, TMK ( 3ra) 7- 5- 018: 071

Dear Dr. Knapp:

This is in response to your correspondence regarding a request for comments on the 1. proposed project on the shoreline setback to prevent erosion of soil into the ocean at the above- mentioned location.

Thank you for allowing the Hawaii Police Department to make comments regarding this project during this draft environmental assessment phase. At this time, the Hawai'I Police Department has no comments.

Should you have any questions or concerns please contact Captain Randal M. Ishii, Commander of our Kona District, at 326. 4646, extension 299.

Sincerely,

HARRY S. KUBOJIRI POLICE CHIEf

PAMH K&ALOHA, JR. ASSISTANT POLICE CHIEF AREA II OPERATIONS

RMI/jaj RS! 50763

t t. ; II i I r.an Eawl oma ttvmy tht%amuan Plot da Cpl„ vu DAVID Y, IGE sOpir WssN

STATE OF HAWAII OFFICE OF ENVIRONMENTAL. Q11ALrrY CONTROL Departmentoffealtt as South eeMMniaSiteel, Sultana fkMaulu. Mowatt 94111 Tekgioou GUN 448.418.SS Facsimile( 1108) 4664186 Not o.a hoot go*

December 14, 2015

Graham Paul Knopp, PhD. GK Environmental LLC P. O. Box 1362 Honoka' a. Hawaii 96727

Dear Dr. Knopp,

SUBJECT Pre-Assessment Consultation for Draft Environrnental Assessment (EA) re: proposed Kona Reef Condominium Erosion Abatement Structure, Kaiiva- Kona, Hawaii

The Office of Environmental Quality Control( OEQC) has reviewed the brief information contained in your undated letter about the subject project, and offers the following comments for your consideration.

Pursuant to Chapter 343, Hawaii Revised Statutes ( HRS), and theimplementing provisions of Chapter 11- 200, Hawaii Administrative Rules, the subject project appears to be an Applicant Action that presumably will be submitted to the County of Hawaii Department of Planning. This agency would be considered the "Approving Agency" that implements the environmental review process for this project by either 1) anticipating a Finding of No Significant Impact and then preparing a Draft EA for public review and comment, ore) based on their judgment and experience, deciding to by-pass the EA step and proceeding directly to the Environmental Impact Statement( EIS) Preparation Notice step if significant effects may occur from the project. In the event the Approving Agency makes a determination to require an EIS, either initially or if significant impacts are identified in the Final LA, then the same agency, as the "Accepting Authority," would determine the acceptability of the subsequent Final EIS.

As The letter provides little detail about the project, OEQC reserves substantive comments until the opportunity to review the Draft EA. In the Draft EA, please be sure to include dear and accurate information regarding the project's required permits and approvals, as wall as its location relative to the property boundaries, State Land Use District Boundaries, Certified Shoreline. and relevant shoreline setback areas. Please also Graham Paul Knopp, Ph.D December 14. 2015 Page 2 of 2 include information indicating adjacent property ownership, thejustification for the project, the HRS Chapter 343 trigger, and an objective consideration of alternatives available to accomplish the project' s goals. Due to the project's shoreline location, an assessment of the impact of future climate change and rising sea level upon the project would be beneficial. Also, as your information indicated over 100 feet of the structure would be built so that neither the mauka nor the makai faces would be exposed ( I. e., fully below grade), please provide information describing construction methods-

As you prepare to submit documents for publication and public review in The Environmental Notice, we appreciate your diligence in using the correct and recently revised publication forms available online. If you have any questions as you navigate this process, please consult our website at htin ifheaith.hawall gov/ oegc( see in particular the link to the Environmental Assessment Preparation Toolkit on the right panel) or contact our office at (808) 586- 4185.

Sincerely,

Scott Glenn Interim Director C9 TEIIA259

I Wllliun P_ Kenai l" r,••::. :. Duane Kaauba Mayor Mar

Gabby Command r! Dcpwi Dlrceor

Fan Ilan.' i( mice Wen Hawsrl Nike III I Pouch Simi, Sulk 3 74- 5044 Ane Kmlmkalnk Hwy Hawaii Hilo. Nowa?' 067: 0 Kanto- Kona. County of Palm:( 1M 323-47711Ptoaclf le 401. 8238 DEPARTMENT Fax 130813274363 PLANNING FOA 13031 061• e742

December 17, 2015

Graham Paul Knopp, Ph.D. GK Environmental LLC P. O. Box 1363 Honoka`a HI 46727

Dear Dr. Knopp:

SUBJECT: Pre-Consultation on Draft Environmental Assessment Applicant: AOAO Kona. Reef Inc. Project:- Kona Reef Condominium Erosion Abatement Structure Tax Mao Key: ( 3) 7-5-018:071, North Kona, Hawaii

This is to acknowledge receipt of your letter received un November 16, 2015 requesting comments from this office regarding the preparation of a Draft Environmental Assessment DEA) for the subject project.

Proposed is the construction of a 220-foot concrete rubble masonry structure that would be located within the shoreline setback area. This would prevent further erosion of soil into the ocean and to protect the existing lawn urea

The subject 3. 082 parcel is designated Urban by the State Land Use Commission and zoned Resort Hotel ( V-.75) by the County. In addition, the Howell County General Plan Land Use Allocation Guide ( LUPAG) Map designates the parcel as Open and Resort Node. It is in the Special Management Arra ( SMA) and is located in a " shoreline area" as defined by Section 205A-41, Hawaiai Revised Statutes( HRS),

We have the following to offer:

I. Describe how the proposed use is consistent with the goals, policies and standards of the County of Howell General Plan, as amended in 2005.

2. The project site is located in the Kona Community Development Plan ( CDP) planning area. Review and include discussion of the pmposed project' s consistency with its overall goals, objectives, policies and actions.

1. 64. r1ed 4° 11° nWauu ymAW' v¢ v—. Iinf86>NY' 1 I': an, ffaxasY(' oursry it en Lard rJpryMxalry 4t.' la/ Graham Paul Knopp, Ph. D. OK Enviramnenlal LLC Page 2 December 17, 2015

3. lite project must be reviewed against SMA rules and regulations. Further, as the project site will be located within the shoreline setback arca, a current certified shoreline survey is required to be submitted with the SMA application,

4. If the structure is proposed seaward of the shordine, the development will he under the jurisdiction of the Department of Land and Natural Resources, Office of Conservation and Coastal Lands.

5. Discuss how the proposed development will affect the approved Shoreline Public Access Plan required by amended Variance Na610 6, The subject parcel is adjacent to Hones, a popular surfing and bodyhoarding County Beach Park, on TMK: (337-5- 018: 020 Therefore, the County of Hawaii, Department of Parks and Recreation as well as the surfing community should be consulted.

Thank you for the opportunity to provide preliminary comments. Please provide us with a copy of the Draft Environmental Assessment ibr our review and file. Our email address is tilanning@cmhawaii. hi. us.

If you have questions, please contact Esther Imamura of our office at 1808) 961- 8139.

Sincerely,

DUA kANUH'A Planning Director

ET1: klt Kona Reel Sewellkrr e: tWowmwITl`F'aareaprcCnnainK r' ip VIRGINIAum.. ; :,vaaserza. ec ws, ur,. DANDY. ISE 8 F nawa,ue

HAWAII STATE OF aW , DEPARTMENT OF HEALTH rh P. 90x 7578 0. EPO 15105 7 011013333 HI 95801. 3978

December 31, 2015

Graham Paul Knopp, Ph. Q. GK Environmental LLC P.O Box 1363 Hendee, Hawaii 96727

Dear Dr. Knopp_ Erosion Abatement Structure to the SUBJECT: Consultation ECorEnvironmentalKona ofnAssessment EarlySh yetanon Setbackio (Draft The Department of Heatth( D(3N), Environmental Planning Office( EPO), acknowledges receipt of yourEC to our officeon November 16, 2015. Thank you forallowing us toreview and comment on the proposed project EPO recommends that you review the standard comments arid available strategies to supportsustainable and healthy design provided at httpimeatlh.hawail.00vleodlanduse. Projects are required to adhere to allapplicablestandard r comments. EPO alsoencourages you to examine and utilize the Hawaii Environmental Health Portal The porta provides links tooure-Permitting Portal Environmental Health Warehouse,Groundwater Contamination Viewer, Hawaii Emergency Response Exchange, Hawaii State and Local Emission Inventory System, Water Pollution Control Viewer, Water Duality Data, Warnings, Advisory and Postings. The Portal is continually updated. Please visit it regutady at httoslleha-coud.doh.hawaGAov We request thatyou utilize all of this information on your proposed project to Increase sustainable, innovative, inspirational, transparent and healthy design.

Mabalo nui lea,

Laura Lelaloha Philips Mcl , AICP Program Manager, Environmental Planning Office

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Qtountp of Jatnattt HAWAFT FIRE DEPARTMENT 25 a ppual Street Suit 2501• inlb, ilbnai 1.%720 808) 9121988 t Fat 1898i9.Le 29.' 8

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Mr. Graham Paul Knopp. Ph. D OK Environmental LLC P. O. Box 1363 Honoka' a, Hawaii 96727

Dear Mr. Knopp.

SUBJECT: EARLY CONSULTATION FOR KONA REEF CONDOMINIUM EROSION ABATEMENT STRUCTURE IN THE SHORELINE SETBACK DRAFT ENVIRONMENTAL ASSESSMENT J

The Hawaii Fire Department has no comments or issues with regards to the Early Consultation as noted above.

DARREN J. ROSARIO Fire Chief

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November 20, 2015

Graham Paul Knopp, Ph. D. GK Environmental LLC P. D. Box 1363 Honokaa. HI 96727

Subject: Early Consultation for an Environmental Assessment Kona Reef Condominium Erosion Abatement Structure in the Shoreline Setback TMK: ( 3) 7- 5- 018:071

We reviewed the subject, dated November 9, 2015 and have the following comments: i 1 The environmental assessment should include a topography survey in the area of the proposed structure and a site plan that shows the proposed location, drawn to scale.

Development within a Special Flood Hazard Area may be subject to the requirements of Chapter 27 - Flood Plain Management, of the Hawaii County Code. The proposed structure will not be subject to regulation under Chapter 27. if it does not rise above existing grade as described in your 11! 9115 letter and is landward of mean high tide. No building permit is required for the structure if it retains less than 4 feet measured from finished grade to finished grade.

AD earthwork and grading shall conform to Chapter 10, Erosion and Sediment Control. of the Hawaii County Code. A grading permit may be required.

Should there be any questions concerning this matter, please contact Kiran Emler of our Klan? Engineering Division office at 323-4851,

a.8n Ishii, Division Chief Engineering Division

KE Copy: Planning Director ENG- Hilo/Kona

nlu,,,,, unn Lnnh„ r I.. rml.. l, lawa„„ ATI bryr. l Orr, Prm APPENDIX 1B: COMMENTS TO DRAFT EA AND RESPONSES

C l This page intentionally left blank.]

1 Ilan ' Knn r Michael Yee 1 >

04.::o aDm ., s, e

4751144 16311/ 343313131-165 C 11 - ' 111Rv 4661133- 16633. 1133613, Sr30 vnmcleaxtta} tna County of Hawaiilw vnd a. a. i:1 r land 127. 356,1 PLANNING DE PARTNItNT r Fat I Ylpnwx13615]361S75251

November 8, 2017

Graham Paul Knopp, Ph. D. GK Environmental LLC P. O. Box 1363 Honoka' a, HI 90727

Dear Dr. Knepp:

SUBJECT: Consultation on Draft Environmental Assessment Applicant: AOAO Kona Reef Inc. Project: Kona Reef Condominium Erosion Abatement Structure Tax Map kev: ( 3) 7- 5- 018: 1171, North Kona, Hawaii ibis is to acknowledge receipt of your Drat( Environmental Assessment( DEA) requesting comments from this office fur the subject project. We appreciate that you have incorporated the information in our pre-consultation letter within We DLA.

As mentioned in our pre-consultation letter, the proposed project is the construction of a 220-that concrete- rubble masonry structure that would be located within rhe shoreline setback area- This would prevent further erosion ofsuil into the ocean and m protect the existing lawn area. The subjcet 3. 082 parcel is designated Urban by the State Land Use Commission and zoned Resort Hotel( V-. 7s) by the County. In addition, the Ilawai' i County General Plan land Use Allocation Guide( LUPAG) Map desi gnates the parcel as Open end Resort Node. It is in the Special Management Area( SMA) and is located in a" shoreline area as defined by Section 205A- 4I, Hasyai' i Revised Statutes( I IRS).

We have the following comments to offer after review of the DEA;

I. Please provide a section in the Final EA that provides a brief history of the Kona Reef Condominiums with construction dates and permitting history, including major building permits and land use permits, including the variances and Special Management Area SMA) Minor Permits.

v i,In t9 rrn, u„(„ E(,. peqt,., ten", vrorvw. amrcr, mb., n aJ Gen.n, rl,. n_ m¢. e1WV' tt ani} P..: 11 Graham Paul Knopp, Ph. D. GK Environmental LLC PageNovember2 S, 2011

1 hank you for the opportunity to provide comments_ Please provide us with a copy Attie Final Environmental Assessment fur our review and file.

If you have questions, please contact Jeff Darrow of our office at( HOE) 961- 8158.

S inncceJrrrellyy,

q(_ ICMIIALLYE Planning Director

JVVD: mnd P x0331000 C H] U 2017[ K, 00743JFan mnnluiwern9uum 0Dc linmm LL.

C rtO wa1y'- DAVID Y ICE OFFICE OF PLANNINGGOVERNOR C t LEO R. ASUNCION 4 STATE OF HAWAII ea, Pu„°

235 South Street, 6th Floor, Honolulu, Hawaii 96813 Telephone k : `` Mailing Address. P. O. Box 2359. Honolulu, Hawaii 96804 Fax. BOB)609) 5137-56] 2B4629242824 Web. Rttp honerrig( lateen eee,

1) 1820171212] I OONA

December 13, 2017

Mr. Graham Paul Knopp, Ph. D. Proprietor GK Environmental LLC P. O. Box 1310 Honoka`a, Ilawai`i 96727

Dear Mr. Knopp:

Subject: Draft Environmental Assessment for Kona Reef Condominiums Erosion Abatement Structure in the Shoreline Setback, Kailua-Kona, North Kona, Hawaii; Tax Map Key:( 3) 7- 5- 018: 071 ( por.)

Thank you for the opportunity to provide comments on the subject Draft Environmental 1 Assessment ( Draft EA), transmitted via letter received November 28, 2017.

According to the Draft EA, Association of Apartment Owners of Kona Reef, Inc, proposes to build an erosion abatement structure within the shoreline area as defined in Hawaii Revised Statutes( FIRS) § 205A- 41. The requirement of HRS Chapter 343 is triggered by such shoreline area use.

The subject structure is proposed to prevent erosion of soil underlying the lawn area fronting the Kona Reef Condominiums. The structure is expected to preserve the lawn area for the public and condominium residents' use, including sunbathing, whale watching, and lateral access to the shoreline Makai ( seaward) of the lawn arca, and the adjacent beach and surfing area.

As designed, the proposed concrete-rubble masonry structure is approximately 12 to 18 inches wide on the top- surface and 24 to 36 inches at the base, and would be built to grade surface at the same height as the surrounding lawn area. The structure would roughly parallel the certified shoreline for approximately 220 linear feet.

The Office of Planning has reviewed the Draft EA and has the following comments to offer.

I. The Draft EA, page 9, states that" without stabilization, the soil underlying the lawn area will enter the ocean and result in polluted storm water runoff." The Final EA should provide an assessment with sufficient information on the erosion of soil underlying the lawn area. Such assessment with supporting information is necessary 1 reretania Mr. Graham Paul Knopp, Ph.D. December 13, 2017 Page 2

to support the purpose and need, and justify the size and linear scope of the proposed erosion abatement structure along the shoreline.

We note that the Appendix E— Coastal Resource and Erosion Assessment, June 2016. concluded that no significant erosion of the shoreline fronting the Kona Reef Condominiums has taken place in historical time. Minor erosion of a lawn fronting the subject property is caused by the infrequent storm surge or tsunami waves that reach or extend beyond the shoreline.

2. Page 17, the Draft LA states that the shoreline area adjacent to the project site may occasionally be visited by sea turtles and the Hawaiian Mop]: Seal, species protected by the Marine Mammal Protection Act. The Final EA should discuss the marine environment fronting and adjacent to the property, and assess the potential impacts of the erection of the proposed hardening structure on the habitat of these marine mammals. If necessary, the United States Fish and Wildlife Service should be

consulted.

3 The project site is a narrow corridor located Mauka( inland) of the shoreline certified on March 1, 2017. The Draft EA, page 31. states that"[ Tithe proposed project would have no encroachment on the shoreline area, and would be built above the certified shoreline, would not cause the loss of sand, coral, or rocks from the shoreline. and would not endanger any residential dwellings." The Final HA should provide an assessment with supporting information tojustify such statement, and specifically assess whether proposed hardening structure within the shoreline area will cause adverse impacts on the shoreline processes fronting and adjacent to the property. including at Wai`aha Beach Park.

4. One of the policies of Hawaii' s Coastal Zone Management( CZM) Law. I IRS § 205A-2( c)( 9)( A), is to` locate new structures inland from the shoreline setback to conserve open space, minimize interference with natural shoreline processes, and minimize loss of improvements due to erosion.` Pursuant to HRS § 205A-46, the counties may grant a variance from the prohibition of structures within the shoreline area provided that private facilities or improvements are clearly in the public interest. or the authority fords that that shoreline erosion is likely to cause hardship to the applicant if the facilities or improvements are not allowed within the shoreline area.

Please note that increasing the number and scope of shoreline hardening structures in a region would adversely affect beach processes, impact shoreline public access, and impact public views to, from. and along the shoreline. Mr. Graham Paul Knopp, Ph.D. December 13, 2017 Page 3

5. Please note no artificial light associated with the subject property and the proposed action, except as provided in FIRS §§ 205A- 30.5( b) and 205A- 71( b), shall be directed to travel across property boundaries toward the shoreline and ocean waters.

If you have any questions regarding Ibis comment letter, please contact Shichao Li of our Coastal Zone Management Program at( 808) 587- 2841.

Sincerely,

Leo It Asuncion Director o DAVID Y. IEE litX4105 " . aFa" Or t, OFFICE OF PLANNING t , LBO R. ASUNCION I p' tioa STATE OF HAWAII arxaaryANNua J f / 235 South Barataria Street, 6th Floor, Honolulu, Hawaii 96813 T& ejnona: 608) 58722648 r 96804 Fax. 008) 5m- 2024 s Se'' Mailing Address: P. O. Box 2359, Honolulu, Hawaii a. Web: tittp'Hptanninghawdllgay/

DTS20171212I 100NA

December 13, 2017

Mr. Graham Paul Knopp, Ph. D. Proprietor GK Environmental LLC P. O. Box 1310 Honoka` a, llawai`i 96727

Dear Mr. Knopp:

Subject: Draft Environmental Assessment for Kona Reef Condominiums Erosion Abatement Structure in the Shoreline Setback, Kailua-Kona, North Kona, Hawaii; Tax Map Key: ( 3) 7- 5- 018: 071 ( por.)

Thank you for the opportunity to provide comments on the subject Draft Environmental Assessment( Draft EA), transmitted via letter received November 28, 2017.

According to the Draft EA, Association of Apartment Owners of Kona Reef, Inc. proposes to build an erosion abatement structure within the shoreline area as defined in Hawaii Revised Statutes( HRS) § 205A-41. The requirement of HRS Chapter 343 is triggered by such

shoreline area use.

area

As designed, the proposed concrete-nibble masonry structure is approximately 12 to 18 inches wide on the top-surface and 24 to 36 inches at the base, and would be built to grade surface at the same height as the surrounding lawn area. The structure would roughly parallel the certified shoreline for approximately 220 linear feet.

The Office of Planning has reviewed the Draft EA and has the following comments to offer.

1. The Draft EA, page 9, states that" without stabilization, the soil underlying the lawn area will enter the ocean and result in polluted storm water runoff.” The Final EA should provide an assessment with sufficient information on the erosion of soil

underlying the lawn area. Such assessment with supporting information is necessary Mr. Graham Paul Knopp, Ph.D. December 13, 2017 Page 2

to support the purpose and need, and justify the size and linear scope of the proposed erosion abatement structure along the shoreline.

2. Page 17, the Draft LA states that the shoreline area adjacent to the project site may occasionally be visited by sea turtles and the Hawaiian Monk Seal, species protected by the Marine Mammal Protection Act. The Final EA should discuss the marine environment fronting and adjacent to the property, and assess the potential impacts of the erection of the proposed hardening structure on the habitat of these marine mammals. If necessary, the United States Fish and Wildlife Service should be

consulted.

3 The project site is a narrow corridor located Mauka( inland) of the shoreline certified on March 1, 2017. The Draft EA, page 31. states that"[ Tithe proposed project would have no encroachment on the shoreline area. and would he built above the certified shoreline, would not cause the loss of sand. coral, or rocks from the shoreline. and would not endanger any residential dwellings." The Final HA should provide an assessment with supporting information to justify such statement, and specifically assess whether proposed hardening structure within the shoreline arca will cause adverse impacts on the shoreline processes fronting and adjacent to the property, including at Wai` aha Beach Park.

4. One of the policies of Hawaii' s Coastal Zone Management( CZM) Law. I IRS § 205A- 2( c)( 9)( A), is to" locate new structures inland from the shoreline setback to conserve open space, minimize interference with natural shoreline processes, and minimize loss of improvements due to erosion." Pursuant to HRS § 205A-46, the counties may grant a variance from the prohibition of structures within the shoreline area provided that private facilities or improvements arc clearly in the public interest. or the authority finds that that shoreline erosion is likely to cause hardship to the applicant if the facilities or improvements are not allowed within the shoreline area.

Please note that increasing the number and scope of shoreline hardening structures in a region would adversely affect beach processes, impact shoreline public access, and impact public views to, from. and along the shoreline. t Mr. Graham Paul Knopp, Ph. D. December 13, 2017 Page 3

5. Please note no artificial light associated with the subject property and the proposed action, except as provided in HRS §§ 205A- 30. 5( b) and 205A-71( b), shall be directed to travel across property boundaries toward the shoreline and ocean waters.

If you have any questions regarding this comment letter, please contact Shichao Li of our Coastal Zone Management Program at( 808) 587- 2841.

Sincerely,

Leo R. Asuncion Director a a ENVIRONMENTAL L c

phone: ( 808) 938- 8583 P. O. Box 1310 Honoka' a, Hawaii 96727

email: [email protected]. com

Leo R. Asuncion, Director State of Hawaii Office of Planning 235 South Beretania Street, 61' Floor Honolulu, Hawaii 96813 January 5, 2018

Dear Director Asuncion:

Thank you for your comments concerning the Kona Reef Condominiums Erosion Abatement Structure Draft Environmental Assessment, published in the Office of Environmental Quality Control' s Environmental Notice on November 23, 2017. We respond to your specific comments individually below.

1. The coastal erosion study ( Appendix F) prepared by Geohazards Consultants International, Inc. assesses erosion affecting the lawn area, and states, " The only active erosion that was observed was caused by storm wave surges that reach the margin of the lawn fronting the KR Property. This lawn is underlain by fine-grained fill material that was used as a substrate for lawn that was planted inshore from the shoreline about 35 years ago. Sapping of fine- grained material from under the lawn causes the lawn grass to subside and creep seaward." Further the C Figure 9 reads, " Erosion of lawn margin fronting the KR Property. Storm surges are not capable of moving the boulders located here at the shoreline, but do erode the fine sediments underlying the lawn." And, Figure 10 states," Detail of eroding lawn fronting the KR Property. Surges associated with the tsunami of March 11, 2011 removed fine materials surrounding the cobbles that underlie the lawn, and caused the lawn to retreat as much as six inches in places." The GO report states that this erosion is" very minor"( Appendix F, page 15). The GCI report concludes that, " Minor erosion of a [ sic] lawn fronting the KR Property is caused by the infrequent storm surge or tsunami waves that reach or extend beyond the shoreline. That erosion can be mitigated by the construction of a low stone wall( Erosion Abatement Structure) immediately mauka of the shoreline." The latter statement justifies the linear scope of the structure. The erosion abatement structure' s length is limited because the lawn area slope change becomes smaller on the northern portion of the lawn area. 2. The GCI report makes the statement that, " Such a structure would have no negative environmental impacts or effects on adjoining areas." Inclusive of this statement is the idea that the erosion abatement structure would have no adverse effect upon the shoreline area fronting the project site, and would positively affect this area by reducing the potential for sediment from the lawn area to reach the shoreline area. The discussion in Section 3. 1. 2 is pertinent to your comment. Specifically, page 13, paragraph 2 states, " Therefore there is not a physical connection between the variable sand deposits on the pahoehoe shelf fronting the project site and other lateral areas beyond the project site, including Honl' s Beach ( Waiaha Bay). Also relevant is the discussion found on page 15 of the DEA, first paragraph, " GCI further concludes that the proposed project would have no environmental impact to shoreline processes, or shoreline or marine habitats." So, as the proposed project would have no impact on shoreline process, it would have no impact on Waiaha Beach. 3. The proposed project would be constructed entirely within the shoreline setback, and would not be constructed within the shoreline area. Further, the purpose of the project is essentially to maintain the lawn area by preventing erosion, and would therefore not cause the loss of sand, coral, or rocks from the shoreline, but would result in the opposite effect. 4. Please note that the proposed project would not affect beach processes, and would not harden the shoreline, as it would not be constructed within the shoreline. Furthermore, the proposed project would positively affect shoreline public access through its maintenance, and would not adversely impact public views to, from, and along the shoreline. 5. The proposed action would not use artificial lighting as work would be conducted during daylight hours, as stated in Section 3. 1. 5 of the DEA. We have added a statement to Section 3. 1. 4 clarifying this.

Mahalo for your interest in the project.

Sincerely

Graham Paul Knopp, Ph. D.

GK Environmental LLC

l DAVID SE 1S Y. ICE Iy AOANNEA. CSE dS¢[ M1.VM Or BMW A/ 6P ciallIVERSON S^ WARD OFLAND M'DNAIDL11APeD[ PCE¢. R..' 1 I• S cU m, ls{ IOFQV NATrnrsONKt T l - tI } M NAGGICK D, L SJ 1l1-4 tY

STATE OF HAWA1 sAnm, wl) DEPARTMENT OF LAND AM) NATURAL RESOURCES LAND DIVISION

POST OFFICE BOX 621 MONO' nI.O_ HAWAII 04RI9

December 28, 2017

GK Environmental LLC

Attention: Mr. Graham Paul Knopp, Ph. D. via email: gtknopu(n)tkenvIIc.com P. O. Box 1310 Honokaa, Hawaii 96727

Dear Mr. Knopp:

SUBJECT: Draft Environmental Assessment for the Kona Reef Condominiums Erosion Abatement Structure

Thank you for the opportunity to review and comment on the subject matter. The Department of Land and Natural Resources' ( DLNR) Land Division distributed or made available a copy of your report pertaining to the subject matter to DLNR Divisions for thein review and comments.

At this time, enclosed are comments from the ( a) Division of Boating & Ocean Recreation, ( b) Land Division — Hawaii District, ( c) Engineering Division, ( d) Division of Aquatic Resources and ( e) Office of Conservation & Coastal Lands on the subject matter. Should you have any questions, please feel free to call Lydia Morikawa at 587- 0410. Thank you.

Sincerely,,

Russell Y. Tsuji Land Administrator

Enclosure( s)

cc: Central Files lyy LIZANKEACASE DAVID V. IGE G •' SOYMMON OARGOVIAMANO NATURAL A4GGE[ TS GWQIWFGFNWN n COKUI,SSIONONWMf6RRES01/ ix MANAGNMRNT i

0 ,_, 4ii) STATE OF HAWAII

tato dila DEPARTMENT OF LAND AND NATURAL RESOURCES LAND DIVISION

POST OFFICE BOX 621 HONOrUIU, HAWAII 96809

December 1, 2017 I MEMORANDUM

TO: DLNR Agencies: X. Div, of Aquatic Resources X Div, of Boating& Ocean Recreation X Engineering Division Div. of Forestry& Wildlife Div. of State Parks X Commission on Water Resource Management X Office of Conservation& Coastal Lands X Land Division— Hawaii District X Historic Preservation n / FROM: Russell V. Tsuji, Land Administrator SUBJECT: 4 Draft of Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback of the Kona Reef Condominiums LOCATION: 75- 5888 Ali9 Drive, Kailua-Kona, island of Hawaii; TMK: (3) 7- 5-018: Por. 071 APPLICANT: GK Environmental LW on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is Information on the above- referenced subject matter. We would appreciate your comments on this project which can be found at:

1. httpsj/hawaiioimt.sharepoint.com/sites/ dlnr- Id( using the Chrome browser) 2. Usemame: your Hawflfi. gov email address 3. Password: outlook password ( if you do not know it, please contact IT by email to reset and get a new password) 4. Click on: Request for Comments, then click on the subject link. 5. If you cannot access the document, please scan this Memo and email to Quoc Le at [email protected] to grant you access.

Please submit any comments by December 27, 2017. If no response is received by this date, we will assume your agency has no comments. If you have any questions about this request, please contact Darlene Nakamura at587- 0417. Thank you.

We have no objections. b.f.?We have no comments. Comments ar: aft h=•.

Signed

Print Name: Gdw dl` ( r![' /ta.'o1j Date: 45 )))t Attachments cc: Central Files

115=+1 irgpiv i1: CANNED. CASs WRWREpN DAVID Y. IGE 5cseeit pW3119ppG1 pYp0 6, BOARD Of LANDANDNAMMAIMOWS! ff yCOMMMBIMHON GAMOW: I/ ROE MANAGEMENT el lir

STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES LAND DIVISION 1011 DEC - E. P 12 bb

POST OFFICE BOX 621 RECEED HONOLULU, HAWAII 96809 LAND DIVISIONDI HILD. Ail December 1, 2017

MEMORANDUM

TO: DLNR Agencies: X Div. of Aquatic Resources X Div. of Boating& Ocean Recreation 1 X Engineering Division Div. of Forestry& Wildlife Div. of State Parks X Commission on Water Resource Management X Office of Conservation& Coastal Lands X Land Division- Hawaii District X Historic Preservation

FROM: Russell Y. Tsuji, Land Administrator SUBJECT: Draft of Environmental Assessment for Erosion Abatement Structure In the Shoreline Setback of the Kona Reef Condominiums LOCATION: 75-5858 Ail' I Drive, Kallua- Kona, Island of Hawaii; TMK:( 3) 7- 5- 018: Por. 071 k> APPLICANT: GK Environmental LLC on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information on the above- referenced subject matter. We would appreciate your comments on this project which can be found at:

1. https:// hawaiioimt. sharepoint.com/ sltes/dlnr-Id( using the Chrome browser) 2. Usemame: your Hawall. gov email address 3. Password: outlook password ( if you do not know it, please contact IT by email to reset and get a new password) 4. Click on: Request for Comments, then click on the subject link. 5. If you cannot access the document, please scan this Memo and email to Quoc La at uuoc. le@ hawail. eov to grant you access.

Please submit any comments by December 27, 2017. If no response is received by this date, we assume will your agency has no comments. If you have any questions about this request, please contact Darlene Nakamura at 587-0417. Thank you. I

e have no objections. We have no comments. Comments areare attac_

Signed:

Print Name: may G. H6-!j- Date: L//// r Attachments cc: Central Files VISIO I RIHEERRIG SWANNEED CAMS Y. 101 a' CTLORDAVID y+ ., IIW SIQAO WATER OOVEPNX OF HWAII RIIIM4) 1) IIIYI ON 0.RESOURCE_Fi(1110.f.R 1 alAV1CfMFM d

STATE OF HAWAII vyyni DEPARTMrtNT.OF LANDAND NATURAL RESOURCES LAND DIVISION

POST OFF10E11OX 621 HONOLULU, HAWAII 96809

December 1, 2017

MEMORANDUM

201---0: DLNR Agencies: X Div. of Aquatic Resources 0XLEngineeringX Div. of Boating&Division.Ocean Recreation Div. of Forestry& Wildlife Div. of State Parks X Commission on Water Resource Management X Office of Conservation& Coastal Lands cX Land Division— Hawaii District X Historic Preservation n ' F M: A' 1 Russell Y. Tsuji, Land Administrator SUBJECT: " ill Draft of Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback of the Kona Reef Condominiums C LOCATION: 75- 5888 Alii Drive, Kailua- Kona, Island of Hawaii; TMK:( 3) 7-5- 018: Por. 071 APPLICANT: GK Environmental LLC on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is Information on the above-referenced subject matter. We would appreciate your comments on this project which can be found at

1. https:// hawaiioimt,sharepoint.com/ sites/ dinr-ld( using the Chrome browser) 2. Username: your Hawali. gov email address 3. Password; outlook password( if you do not know if, please contact IT by email to reset and get a new password) 4. Click on: Request for Comments, then click on the subject link. 5. If you cannot access the document, please scan this Memo and email to Ouoc Le at quoc, eghawaii.gov to grant you access.

Please submit any comments by December27, 2017. If no response is received by this date, we will assume your agency has no comments. If you have any questions about this request, please contact Darlene Nakamura at 587- 0417. Thank you.

We have no objections. We have no comments. Comments Rac

Signed: l/[ / ' FR Print Name: 1 `- A A 7 L„,... " Date; 121/47/!7 Attachments cc: Central Files I3T04PPIttOr? DEPARTMENT OF LAND AND NATURAL RESOURCES ENGINEERING DIVISION

LD/ Russell V. Tsuji Ref: Draft of Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback of the Kona Reef Condominiums, 75-5888 Alii Drive, Kailua- Kona, Island of Hawaii; TMK (3) 7- 5- 018: Por. 071

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 Ana( high risk areas). I3e advised that 44CFR 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 NFTP standards.

The owner of the project property and/ or their representative is responsible to research the Flood Hazard Zone designation for the project. Flood Hazard Zones are designated on FEMA' s Flood Insurance Rate Maps ( FIRM), which can be viewed on our Flood Hazard Assessment Tool WHAT) ( http:// gis.hawaiinfip.orgIFHAT).

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- 7253.

o Kauai: County of Kauai, Department of Public Works( 808) 241- 4846.

Signed:

TT!' CX 1 r .S, CC NG, CIRF,F ENGINEER

Date: _( 7 / 1r--// - 7 WA

oP 4r ' vim- ty LPN W nirF„ 2( pr Himont. hvTfosin 1f Agynor k - p 1 IIYVIYpM APPA Y fR l;.f.

@. STATE OF HAWAII rwsrmI .. Ls/Vt munra DEPARTMENT OF LAND AND NATURAL RESOURCES k-AliWual,winanwrmwe. un Ieerhd DIVISION Or AQUATIC RESOURCES 1151 PUNCIRioWLS Raf, ROOM 330 r,RMus NONOI ULU, HAWAII 96813 Date: I I Dec 2017 DAR# 5651

MEMORANDUM TO: Bruce S. Anderson, PhD DAR Administrator

William Walsh FROM: LALi Aquatic Biologist

SUBJECT: Draft of Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback of the Kona Reef Condominiums Request Submitted by: Russell Y. Tsuji, Land Administrator Location of Project: 75- 5888 Alii Drive, Kailua-Kana, Island of Hawaii; TMK: (3) 7- 5- OI e: Por

Brief Description of Project:

Association of Apartment Owners of Kona Reef, Inc. (Kona Reef AOAO) proposes to build an erosion abatement structure within the lawn area fronting the Kona Reef Condominiums, located mauka( i. e. uphill or inland) of the certified shoreline and within the shoreline setback. The purpose of the structure would be to prevent erosion of soil underlying the lawn area, and consequent loss of the use of the lawn arca. The structure would parallel the certified shoreline for approximately 220 linear feet, would be anchored inbedrock, and would be built flush to grade( at the same height as the surrounding lawn area).

Comments: 0 No Comments ® Comments Attached

F Thank you for providing DAR the opportunity to review and comment on the proposed project. Should there be any changes to the project plan, DAR requests the opportunity to review and comment on those changes.

Comments Approved: _,. r-.. t. 1,4n44-4 Date: ll./leL// 7 Bruce S. Anderson, PhD DAR Administrator y mawIMAM ( 0Att0 5651

Commune

I) AIR' s uvu.erns mirror the recommendations made iii the Plum and fauna Study by ( i flint lerrish, 1' 11. 0, namely:

Ilest Management Pruct ices fad all other necessary actions should be taken to ensure than no soil, 511 or any other material from the proposed acliva enter the wnIet of the I' aci lie Ocean.

In the unlikely even) Ihut a scu ILII thu or it coal is observed on the project site or nn the hunch or anywhere else near the project site, Jill construction actio iliox shlWd be stopped until the animal voluntarily returns to the ocean. Murine manuals and larles sbnald nil be ciixhabed or h;vassetl in any way. II is reconmmoded that DO(' ARE and the [ Iti fish and WileUile service he notified ii' any such animals are xcca ncnr the prijuet silc.

0 RECEIVEDSIVARIC W„ DAVID y WYVMOHOFNPWNI BWINRDOFIANDAWtht, C A DORi11S DECI Lull INNIDE,'A W. . BOR6 O STATE OF HAWAII DEPARTMENT OF IANDAND NATURAL RP-SOURCES LAND DWLSION

POST OFFICH BOX 621 HONOLULU, HAWAII 96819

December 1, 2017

MEMORANDUM

TO: DLNR Agencies: X Div. of Aquatic Resources X Div: of Boating& Ocean Recreation X Engineering Division Div. of Forestry& Wildlife Div. of State Parks X Commission on Water Resource Management_ X Office of Conservation& Coastal Lands X Land Division— Hawaii District X Historic Preservation

FROM: Russell Y. Tsuji, Land Administrator SUBJECT: 4'' Draft of Environmental Assessment for Erosion Abatement Structure In the Shoreline Setback of the Kona Reef Condominiums LOCATION: 75-5888 Alli Drive, Kailua-Kona, Island of Hawaii; MK:(3) 7-5- 018: Por. 071 APPLICANT: GK Environmental LLC on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information on the above-referenced subject matter. We would appreciate your comments on this project which can be found at:

1. https:// hawaiioiriltshareoointcom/ sites/ dlnr-Id( using the Chrome browser) 2. Usemame: your Hawaii.gov email address 3. Password: outlook password( if you do not know 0, please contact IT by email to reset and get a new password) 4. Click on: Request fpr Comments, then click on the subject link. 5. If you cannot access the document, please scan this Memo and email to quos Le at quoc. leehawailciov to grant you access.

Please submit any comments by December27, 2017. If no response is received by this date, we will assume your agency has no comments. If you have any questions about this request, please contact Darlene Nakamura at 587-0417. Thank you.

We have no objections. We have no comments. A Comments are attached.

Signed: f t,. .u_

Print Name: Bruce S. Andetson, PhD, DAR Administrator

Date: 2/ 7

Attachments cc: Central Fifes r r • 1' V I IIF SIIL.INNCP CUE EMMY. ME n1 q CSIAMPoFLMT. NONAI NWNLflSOWNJS' u r eM, wnovxm+ e mm] aMON wrtrlaR oU%Le 1' Lw.fr enr

cal ntc:t AP J STATE OFHAWAU 4. DEPARTMENT OF LAND AND NATURALRE50 teorta f" _ LAND DIVISION' L4 p L. ) 0

POSTOFMCBBOX 621 HONOLULU, HAWAII 96809

December 1, 2017

Vii MEMORANDUM

DLNR Agencies: X Div. of Aquatic Resources X Div. of Boating& Ocean Recreation X Engineering Division Div. of Forestry& Wildlife Div. of State Parks X Commission on Water Resource Management 2 7 20 X Office of Conservation& Coastal Lands QE+ X Land Division— Hawaii District X Historic Preservation

PROM: Russell Y. Tsuji, Land Administrator SUBJECT: 4 ' Draft of Environmental Assessment far Erosion Abatement Structure in the Shoreline Setback of the Kona Reef Condominiums LOCATION: 75- 5888 Alii Drive, Kaiiva-Kona, Island of Hawaii; TMK:( 3) 7-5- 018: Por. 071 APPLICANT: GK Environmental LLC on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information on the above- referenced subject matter. We would appreciate your comments on this project which can be found at:

1. htlps:// hawailolmt. sharepolnt.com/ sites/ dlnr-Id( using the Chrome browser) 2. Username: your Hawali. gov email address 3. Password: outlook password( if you do not know it, please contact IT by email to reset and get a new password) 4. Click on: Request for Comments, then click on the subject link. 5. If you cannot access the document, please scan this Memo and email to Ouoc Le at quoc.le@ hawali. aov to grant you access.

VA—u/ 0( i{ We have no objections. a c X) We have no comments. VRA1c4- 1 Comments err- -• ed si•t>7a.E>ric. r6 uta) — Signed: k/ D vakziK /kJ SL14 CAJOSdytvitTI rU DLS• Print Name: K Re)Y

Date: 2- - 21- -1q- IAttachments cc: Central Files 4. t;t

ENYIMGMYCR.LL LLC

phone: ( 808) 938- 8583 P. O. Box 1310 Honoka' a, Hawaii 96727 email: gpknopp@gkenvllc. com. com

Russell Y. Tsuji, Administrator State of Hawaii Department of Land and Natural Resource PO Box 621 Honolulu, Hawaii 96809 January 5, 2018

Dear Mr. Tsuji:

Engineering Division' s comment regarding flood regulations is very pertinent, as the design of the proposed project was constrained by Hawaii County Code Chapter 27, which states that construction within flood zone AE cannot increase the water surface elevation of the base flood. The proposed erosion abatement structure, therefore, could not be constructed above grade. This is discussed in Section 3. 1. 2 of the DEA( page 12).

Regarding DAR' s comments regarding BMPs to ensure than no soil, fill, or any other material from the proposed action reached the ocean, we agree that due to the proximity to the ocean it is especially important to prevent soil, fill, or any other material from reaching the shoreline and ocean. We believe that the DEA has addressed these issues adequately, as they are discussed in Section 31.2 of the DEA. Further, we also believe that DAR' s comments regarding the potential presence of fauna, in particular marine mammals and sea turtles, are definitely of serious concern, and have been addressed in Section 3. 1. 4 of the DEA, which states," Therefore, if these species use the shoreline area during construction, work should halt until the animal leaves the area. The contractor will monitor for the presence of protected sea turtles and monk seals."

Mahalo for your interest in the project,

Graham Paul Knopp, Ph.D.

GK Environmental LLC ti DAVID IGE s VIMIMIccfME45lFA,NIA N. P. _.... cnlBn'waflupu OFFEALTd

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STATE OF HAWAII 6, t" DEPARTMENT OF HEALTH 11ew '"' P. O. BOX 3370 HONOLULU, HI 06001- 3978 EPO 17- 204

December 14, 2017

Graham Paul Knopp, Ph. D. GK Environmental LLC P.O. Box 1310 Honokaa, Hawaii 96727 Email: gpknopp@gkenvlic. com

Dear Dr. Knopp:

SUBJECT: Draft Environmental Assessment( DEA) for Kona Reef Condominiums Erosion Abatement Structure in the Shoreline Setback, North Kona, Hawaii TMK: ( 3) 7- 5-018:071

The Department of Health( DOH), Environmental Planning Office( EPO), acknowledges receipt of your DEA to our office via the OEQC link: httpa/oegc2.dch.hawaii. gov/EA EIS Library/2017- 11- 23- HA-DEA- Kona- Reef-Condominiums-Erosion- Abatement. pdf

We understand from the OEOC publication form project summary that The purpose of the structure would be to prevent erosion of soil underlying the lawn area, and consequent loss of the use of the lawn area. The project would maintain the lawn area and protect it for users, who include both members of the public and Kona Reef condominium residents. The structure would parallel the certified shoreline for approximately 220 linear feet, would be anchored in bedrock, and would be built flush to grade( at the same height as the surrounding lawn areal

Hawaii' s environmental review laws require Environmental Assessments( EAs) and Environmental Impact Statements( EISs) to consider health in the discussion and the mitigation measures to reduce negative impacts. In its definition of' impacts;§ 11. 2004, Hawaii Administrative Rules( HAR) includes health effects, whether primary direct), secondary( indirect), or cumulative. Further,§ 11. 200- 12( b)(5), HAR, lists public health as one of the criteria for determining whether an action may have a significant impact on the environment.

We advocate that you consider health from a broad perspective; one that accounts for the social, economic, and environmental determinants of health and wellbeing. Community wed-being can be impacted by access fo physical activity, health care, feelings of social connectedness and safety. Design solutions that take these factors into consideration positively contribute to the social determinants of health in a community, improving the wellbeing of those who live there by influencing health promoting behaviors. Social determinants contribute to preventable chronic diseases such as asthma, diabetes, obesity, and cardiovascular disease.

In the development and implementation of all projects, EPO strongly recommends regular review of State and Federal environmental health land use guidance. State standard comments to supped sustainable healthy design are provided at: httpa/health. hawaii.govlepo/ anduse. Projects are required to adhere to all applicable standard comments.

We suggest you review the requirements of the Clean Water Branch( Hawaii Administrative Rules( HAR}, Chapter 11- 54- 1. 1,- 3, 4-8) and/or the National Pollutant Discharge Elimination System( NPDES) permit( HAR, ChapAer1155) at: http: l/health.hawaii. uovlcwb. If you have any questions, please contact the Clean Water Branch( CWB), Engineering Graham Paul Knopp, PhD. Page 2 December 14, 2017

Section at( 808) 586-4309 or cleanwaterbranch@doh. hawaii.gov. If your project involves waters of the U.S., it is highly recommended that you contactthe Army Corps of Engineers, Regulatory Branch at:( 808) 835-4303.

II temporary fugitive dust emissions could be emitted when the project site is prepared for construction and/or when construction activities occur,we recommend you review the need anWor requirements for a Clean Air Branch( CAB) permit( HAR, Chapter 11- 60.1 " Air Pollution Control"). Effective air pollution control measures need to be provided to prevent or minimize any fugitive dust emissions caused by construction work from affecting the surrounding areas. This includes the off-site roadways used to enter/exitthe project. The control measures could include, but are not limited to, the use of water wagons; sprinkler systems, and dust fences. For questions contact the Clean Air Branch via e- mail at: Cab.General@doh. hawaii iov or call( 808) 588-4200.

Any waste generated by the project( that is not a hazardous waste as defined in state hazardous waste laws and regulations), needs to be disposed of at a solid waste management facility that complies with the applicable provisions( HAR, Chapter 11- 58.1 " Solid Waste Management Control"). The open burning of any of these wastes, on or oft site, is strictly prohibited. You may wish you review the Minimizing Construction& Demolition Waste Management Guide at: httpJmealth. hawaii.gov/shwa/filesr2016/05/constdem16.pdf Additional information is accessible at: http// health.hawaii.pov/shwb. For specific questions call( 808) 586-4226.

If noise created during the construction phase of the project may exceed the maximum allowable levels( HAR, Chapter 11- 46," Community Noise Control") then a noise permit may be required and needs to be obtained before the commencement of work. Relevant informationis online at: htlo:/ health. hawaii. 00v/Irhb/ noise EPO recommends you contact the Indoor and Radiological Health Branch( IRHB) at( 808) 586-4700 with any specific questions. Owners/tenants must comply with Stale Law( HRS, Chapter 128D," Environmental Response Law", Chapter 451, State Contingency Plan"). To Identify HEER records related to the property, visit http:// eha-web.doh.hawaiLoov/eha- cma/ Leaders/HEER/ public-records. For information on site assessment and cleanup programs review: htp9/eha- web.doh.hawaii.goWehacma/Leaders/HEER/sjte-assessment-and-cleanup-programs. Any specific questions should be directed to the HER office at( 808) 586-4249.

EPO also encourages you to examine and utilize the Hawaii Environmental Health Portal at: htlps://ehacloud.doh.hawaii. 00v. This site provides links to our e-Permitting Portal, Environmental Health Warehouse, Groundwater Contamination Viewer, Hawaii Emergency Response Exchange, Hawaii State and Local Emission Inventory System, Water Pollution Control Viewer, Water quality Data, Wamings, Advisories and Postings. Hawaii's climate is changing. Sea level rise and the associated coastal impacts have the potential to harm an array of natural and built environments in Hawaii. For additional information on projected sea level rise in Hawaii, EPO recommends that you visit the following informative links:

State of Hawaii Climate Adaptation Poral: httri/climateadaptation.hawau.gov University of Hawaii, Manoa, School of Ocean and Earth Sciences and Technology, Coastal Geology Group: httm/Avww.soest.hawaii. edufcoastsindex.html

To better protect public health and the environment, the U.S. Environmental Protection Agency( EPA) has developed an environmental justice( EJ) mapping and screening tool called EJSCREEN. It is based on nationally consistent data and combines environmental and demographic indicators in maps and reports. EPO encourages you to explore, launch and utifize this powerful tool in planning your project. The EPA EJSCREEN tool is available at: httpllwww.epa.nov/ eiscreen. Graham Paul Knopp, PhD. Page 3 December 14, 2017

We hope this information is helpful, If you have any questions please contact us at [email protected] or call us at( 808) 586-4337. Thank you for the opportunity to comment.

Mahalo nui lea,

rPdi y/' Laura Leialoha Phillips McIntyre, AICP Environmental Planning Office

LM:nn c: Ray Pieri, Association of Apt Owners of Kona Reef, Inc. ( via email: pierir001 @hawaii. rr.com) Michael Yee, County of Hawaii Planning Dept.( via email: planning@hawaiicounlKaov) DOH: DHO HI, CWB, IRHB, CAB ( via email only)

Attachment: U. S. EPA EJSCREEN Report for Project Area Please be advised: The Environmental Planning Office( EPO), along with the Clean Air, Clean Water, and Wastewater Branches have moved to Waimano Ridge. The new address, for EPO, as of December 1, 2017, is: Environmental Planning Office, DOH, Hale Ola, 2827 Waimano Home Road# 109, Pearl City, Hawaii 96782 Please feel Tree to come and visit our new offices anytime. Please note that there is a security guard at the bottom of the hill( before entering DOH properly). Our office phone numbers, email and website will all remain the same.

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ma) NATA- Diesel PM Oa/ 0133 0149 69 0.918 < 50th 0.938 60th

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Demographic Index 45% 5% 29 47% 48 96% 68

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For additional information, see, www.epa. gov/ enaironmentafjustice

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phone: ( 808) 938- 8583 P. O. Box 1310 Honoka' a, Hawaii 96727

email: gpknopp@gkenvllc. com. com

Laura Leialoha Phillips McIntyre, AICP Environmental Planning Office Department of Health State of Hawaii PO Box 3378 Honolulu, Hawaii 96801- 3378 January 5, 2018

Dear Ms. McIntyre:

Thank you for your general comments concerning the Kona Reef Condominiums Erosion Abatement Structure Draft Environmental Assessment, published in the Office of Environmental Quality Control' s Environmental Notice on November 23, 2017. We have reviewed the EPOs standard comments, and the DEA has adequately addressed all of these, including potential impacts including, but not limited to, wastewater, temporary fugitive dust emissions, solid and hazardous waste, and noise,

Mahalo for your interest in the project.

Sincerely,

Graham Paul Knopp, Ph. D.

GK Environmental LLC comments on June 2017 Draft Environmental Assessment for Erosion Abatement Structure in the Shoreline Setback, Kona Reef Condominiums comments due December 26, 2017 from Cory Harden, Hilo 333cory@gmail. com

Approving Agency: County Of Hawaii Planning Department, Michael Yee, PlanninceHawaiicountv.Gov 808) 323- 4770, 101 Pauahi Street, Suite 3, Hilo, Hi 96720

Applicant: Association Of Apartment Owners Of Kona Reef, Inc. 0/ O Ray Pied, PierirooeHawaii.Rr Com 808) 989- 7439, 75- 1029 Henry Street,# 202, Kailua- Kona, Hawaii 96740

Consultant: Graham Paul Knopp, Ph. D., Gk Environmental LLC, Gpknopp(WGkenvllc.Com 808) 938- 8583, Po Box 1310, Honokaa, Hi 96727

l am sympathetic to the difficult choices faced by owners of seaside properties as sea levels rise.

Please consider these comments:

Though the stated intent of the project is to prevent erosion from foot traffic, storms and rising sea levels may cause it to function as a sea wall, reflecting waves which then erode other shoreline areas. Approving this may set a precedent for projects elsewhere.

The DEA should utilize these sources: 2017 Hawaii Sea Level Rise Vulnerability and Adaptation Report https://climateadaotation. hawaii.gov/wp- content/uploads/ 2017/ 12/ SLR-Report Dec2017.pdf January 2017 Sea Level Viewer from National Oceanic and Atmospheric Administration at https://coast noaa.gov/data/ digitalcoast/pdf/slr-faq- hi.pdf

General information from the Sea Level Rise Report states: it is vital that the magnitude and rate of sea level rise is tracked as new projections emerge, plan for 3. 2 feet of sea level rise now, and be ready to adjust that projection upward.... global sea level rise will not stop at the year 2100, but will likely continue on for centuries." Hawaii Sea Level Rise Vulnerability and Adaptation Report, 2017, p. vi

Parts of the project will only be about 9% inches above this sea level rise. The elevation of the project site is approximately 4- 8 feet above mean sea level" DEA p. 12

The DEA seems to assume less sea level rise: GCI [ Geohazards Consultants International, Inc.] considers that a larger value of 6. 0— 7. 0 mm/ year is reasonable for Hawaii Island, resulting in an estimation of about 0. 3 m[ of sea level rise], or about one foot, in 50 years as a rough estimate" DEA p. 14

The DEA should analyze how large storm waves reflecting off the project area will affect Waiaha Beach and other shoreline areas. In the event of a major storm surge or tsunami, it is possible that much of the volume of the soil underlying the lawn area may be eroded and transported to the shoreline area and ocean." DEA p. 2

on approximately[ 110 feet] the northern 1/ 2 of its length the structure would be exposed on the makai side." DEA p. 9

GCI concluded that the erosion abatement structure would protect the lawn area from surge waves that can reach the shoreline during times of storms or tsunami." DEA p. 15

U ENVIRONMENTAL LL[

phone: ( 808) 938-8583 P. O. Box 1310 Honoka' a, Hawaii 96727 email: [email protected]. com

Cory Harden Hilo, Hawaii 333cory@gmail. com January 5, 2018

Dear Ms. Harden:

We acknowledge that you believe that the erosion abatement wall may effectively function as a sea wall apparently at some point in the indefinite future. This is not the intent of the wall whatsoever, the wall would not be designed to receive wave energy, and given reasonable expectations of sea level rise, the point at which wave energy would be normally received by the wall would be well past the expected lifetime of the Kona Reef Condominiums. The data sources you mention all agree that sea level rise for Hawaii Island has been approximately 3 mm/ year, or about one foot in 50 years. Please note that sea level rise is site-specific and varies widely as it is the combination of local and global i.e., isostatic and eustatic) sea level rise factors. So, assuming twice this value, we find that the value assumed in the GCI report, for the next 50 years is reasonable. The DEA evaluates how large storm waves, " reflecting off the project area will affect Waiaha Beach and other shoreline areas" Due to the extensive pahoehoe shelf fronting the project site storm wave energy is largely dissipated before reaching the shoreline margin. During periods of extraordinary waves incident on the project area fraction of wave energy incident, and therefore also reflected from the erosion abatement wall, would be very small compared to the wave energy incident from such a powerful ocean swell. While you are entirely correct that wave energy is reflected off of hard structures, this would only occur during extraordinary conditions such as a tsunami, and during these events, wave energy would be reflected from the entire coastline, in addition to other structures impacted by such a tsunami.

Mahalo for your interest in the project.

Sincerely,

7± 47.5 Graham Paul Knopp, Ph.D.

GK Environmental LLC APPENDIX B: ENGINEERING DRAWINGS ENGINEERING PARTNERS, INC.

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OF ATE PHOTOGRAPHS ASSOCIATES PROJECT NO.: 16497. 11 OCTOBER 28, 2016 WES THOMAS TAK MAP KEY.: 7- 5- 018:071 Surveyors - Lend 3R0 DNISION) 75- 5749 Kalawo Street TIME OF PHOTOGRAPHS Katlua- Keno, Howetl 98740- 1817 3:50 P.M. TEL ( 908) 329- 2353 FAY ( 808) 129- 51.8: EMAIL aurVey$OwfoSowad.com it APPENDIX D: ARCHAEOLOGICAL INVENTORY SURVEY HAUN& ASSOCIATES

C . This page intentionally left blank.] Report 932- 070816

DRAFT

ARCHAEOLOGICAL INVENTORY SURVEY

KONA REEF CONDOMINIUM

EROSION ABATEMENT STRUCTURE PROJECT

l: a .-

WAI`AHA 1 AHUPUA'A, NORTH KONA DISTRICT

ISLAND OF HAWAI' I

TMK: ( 3) 7- 5- 018: POR. 071

HAUN & ASSOCIATES ARCHAEOLOGICAL, CULTURAL, AND HISTORICAL RESOURCE MANAGEMENT SERVICES 73- 1 168 KAHUNA At ROAD, KAILUA-KONA HI 96740 PHONE: 808-325-2402 FAX 808-325- 1 520 Report 932- 070816

DRAFT

ARCHAEOLOGICAL INVENTORY SURVEY

KONA REEF CONDOMINIUM

EROSION ABATEMENT STRUCTURE PROJECT

WAI'AHA 1 AHUPUA'A, NORTH KONA DISTRICT

ISLAND OF HAWAI' I

TMK: (3) 7- 5- 018: POR. 071

By:

Alan E. Haun, Ph. D.

and Dave Henry, B. S.

Prepared for: Kona Reef Condominium c/ o Dr. Graham Knopp P. O. Box 1363 Honokaa, HI 96727

July 2016

HAUN & ASSOCIATES ARCHAEOLOGICAL, CULTURAL, AND HISTORICAL RESOURCE MANAGEMENT SERVICES 73- 1 168 KAHUNA No ROAD, KAILLJA-KONA HI 96740 PHONE: 808-325-2402 FAX: 808-325-1520

1 TMK : ( 31 7 - 5 - 018. 071 Report No 932 - 070816

MANAGEMENT SUMMARY

Haun & Associates conducted an archaeological inventory survey of a 0. 314 acre portion of the Kona Reef Condominium development in TMK: ( 3) 7- 5- 018: 071, Wai' aha 1 Ahupua' a, North Kona District, Island of Hawaii.

The objective of the AIS was to satisfy current historic preservation regulatory review inventory requirements of the Department of Land and Natural Resources- State Historic Preservation Division ( DLNR- SHPD), as contained within Hawaii Administrative Rules, Title 13, DLNR, Subtitle 13, Chapters 276 and 284, State Historic Preservation

Rules( DLNR 2003).

The survey identified the disturbed remnant of a subsurface cultural deposit ( Site 50- 10-28- 30493) during shovel testing within the project area. This deposit contains pre- and/ or early post- contact traditional Hawaiian cultural material mixed with historic and modern materials. Documentary research and consultation with an adjacent landowner indicates that the Site 30493 deposit represents the original ground surface prior to the introduction of fill material that occurred during multiple episodes between the 1960s and 1980s.

The site is assessed as significant for its information content. It has yielded information important for understanding prehistoric habitation in the area. The documentation of the Site 30493 cultural deposit adequately records it and no further work or preservation is recommended because the disturbed nature of the deposit precludes the potential to obtain additional archaeological information.

Cover photo: Overview of project area( view to north-northwest)

HAUN & ASSOCIATES l TMK '. ( 3 ) 7 5 - 018 '. 071 Report No 932- 070816

Contents

MANAGEMENT SUMMARY

INTRODUCTION 1

1 Scope of Work

Project Area Description 1

Methods 7

ARCHAEOLOGICAL AND HISTORICAL BACKGROUND 7

Historical Documentary Research 7

Previous Archaeological Work 13

PROJECT EXPECTATIONS 17

CONSULTATION 17

FINDINGS 18

CONCLUSION 24

Discussion 24

Significance Assessments 24

Treatment Recommendations 24

TRANSLATION OF HAWAIIAN WORDS

REFERENCES 25 APPENDIX A— SHPD LETTER 30 O

Figures

Figure 1. Portion of USGS 1998 7. 5' USGS Kailua Quadrangle showing project area 2 3 Figure 2. Tax Map Key 7- 5- 16 showing project area Figure 3. March 8, 2013 Aerial view of project area( from Google earth) 4

Figure 4, Project area overview( view to northwest) 5 5 Figure 5. Project area overview( view to south)

shovel tests locations 6 Figure 6. Plan map of proposed erosion abatement structure and 8 Figure 7. Ahupua' a boundaries and Land Commission Awards 10 Figure 8. Portion of Emerson' s 1880 map of Kailua

project area 12 Figure 9. Portion of 1928 USGS Kailua Quadrangle showing

Figure 10. Profiles of STs 1- 6 19

Figure 11. Profiles of ST- 7- 10 20 Figure 12. Coral file from 5T- 8...... 21

Tables

Table 1. Land Commission Awards in Wai' aha 11

Table 2. Previous archaeological work.. 13 18 Table 3. Summary of shovel test stratigraphy Table 4. Summary of cultural material from shovel testing 22 r‘ S

HAUN & ASSOCIATES I ii TMK _ (3 ) 7- 5- 018 : 071 Report No 932 - 070816

INTRODUCTION

At the request of Dr. Graham Knopp on behalf of the Kona Reef Condominium, Haun & Associates has prepared an archaeological inventory survey of a 0. 314 acre portion of the 3. 082 acre TMK: [ 3] 7- 5- 018: 071 located in Wai aha 1 Ahupua' a, North Kona District, Island of Hawaii( Figure 1 and Figure 2). The project objective is to comply with historic preservation regulatory review requirements of the Department of Land and Natural Resources - State Historic Preservation Division ( DLNR- SHPD), as contained within Hawaii Administrative Rules, Title 13, DLNR, Subtitle 13, State Historic Preservation Rules ( HAR, Chapters 276 and 284; DLNR 2003). The current project was done in conjunction with an environmental assessment for an erosion abatement structure to be constructed within the shoreline setback.

Scope of Work

Based on DLNR- SHPD rules for inventory surveys the following specific tasks were determined to constitute an appropriate scope of work for the project:

1. Conduct background review and research of existing archaeological and historical documentary literature relating to the project area and its immediate vicinity--icinity— including examination of Land Commission Awards, ahupua' a records, historic maps, archival materials, archaeological reports, and other historical sources;

2. Conduct 100% pedestrian survey coverage of the project area;

3. Conduct detailed recording of all potentially significant sites including scale plan drawings, written descriptions, and photographs, as appropriate;

4. Conduct limited subsurface testing ( manual excavation) at selected sites to determine feature function;

5. Analyze background research and field data; and

6. Prepare and submit Final Report.

Project Area Description

The Kona Reef Condominium complex is a 3. 082 acre development located along the seaward side of Alia Drive in the coastal portion of Wai aha 1 Ahupua' a. Figure 3 is an aerial view of the project area vicinity taken on March 8, 2013. The Kona Reef Condominium is located south of Kahakai Road and the Hale Kona Kai Condominium, and north of Waiaha Bay and Honi s Beach. The development is a 129- unit complex comprised of condominium buildings, a swimming pool and parking areas. A maintained grass lawn extends along the seaward side of the development bordered by a discontinuous berm of boulders and cobbles. Coconut palms( Cocos nucifera) and bougainvillea ( Bougainvillea spp.) bushes are planted along the berm. Examples of the project area are presented on the cover of this report and in Figure 4 and

Figure 5.

The proposed project consists of the installation of an erosion abatement structure along the certified shoreline, in the southern portion of the development. This approximately 0. 314 acre area is located seaward of the existing condominium buildings. The location of the proposed erosion abatement structure is shown in Figure 6.

According to Sato et al.( 1973: 52 and Sheet 85), the soil in the project area is Waiaha extremely stony silt loam on 6- 12% slopes. It has a 4" surface layer of very dark brown extremely stony silt loam, over a 14"

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HAUN & ASSOCIATES 15 x] 0816 TM K '. 13 - 5 - 018 ': 071 Report No 932-

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thick subsoil of dark brown very stony silt loam, over pahoehoe bedrock. It has a moderately rapid permeability, a slow runoff and a slight erosion hazard. It is classified as suitable for pasture. The underlying pahoehoe lava was deposited more than 10, 000 years ago from Hualalai Volcano ( Wolfe and Morris 2001). Annual rainfall in the vicinity of the project area ranges from 750 to 1, 350 mm( 29. 5 to 53 inches— Giambelluca et al. 2013). The mean average temperature in this general area is c. 75 degrees F ( Juvik and

Juvik 1989: 51). There are no apparent surface water sources on the property.

Methods

The survey fieldwork was conducted March 2 through March 7, 2016 by Haun & Associates Project Supervisor Solomon Kailihiwa, M. A and a crew of three archaeologists, under the direction of Dr. Alan Haun. Approximately 9 labor- days were required to complete the fieldwork portion of the project. The area of the proposed erosion abatement structure was carefully examined, with no surface archaeological remains present.

The project consisted of excavating ten shovel tests spaced 6. 4 to 7. 8 meters apart ( average 6. 9 meters apart). The location of the shovel tests is depicted in Figure 6. The shovel tests were excavated in stratigraphic layers and were terminated on bedrock. Standardized excavation records were prepared after the completion of each stratigraphic layer. The soil removed during excavation was screened through % inch mesh hardware cloth. Portable remains collected were placed in paper bags labeled with the appropriate provenience information. Following the excavation, a section drawing depicting the stratigraphy was prepared and post- excavation photographs were taken. The tests were described using standard terminology, referencing Munsell Soil and Rock color notation. Texture and inclusion content were also noted. Following documentation the tests were backfilled.

Recovered cultural material was transported to Haun & Associates' office for analysis. The recovered artifacts and food remains were qualitatively and quantitatively analyzed. Artifacts were analyzed to determine morphological type, condition, degree of completion and material. Standard typological classifications were used for all artifacts. Food remains were identified to the family level, or to the genus and species level when possible. Quantitative analysis included a determination of total weight and total number of identified fragments( TNF) per taxon.

ARCHAEOLOGICAL AND HISTORICAL BACKGROUND

Historical Documentary Research

The project area is located within the ahupua' a of Wai' aha 1 ( Figure 7). This Kona ahupua' a means gathering water"( Pukui et al. 1976: 219), a name potentially derived from Mao Heiau, a heiau located on the north side of Wai' aha Bay. According to Pukui et at, this heiau was built to start or stop the rain. Thrum' s examination of the heiau identified holes in the upper portion of the heiou' s platform where rain was said to have been cooked( 1908: 43).

The ahupua' a contained ceremonial complexes and high status residences with the majority of pre- Contact and early post- Contact sites situated in the coastal portion of Wai' aha ( Rechtman 2002: 5). Maly 1996) translated portions of the Hawaiian newspaper Ka Hoku o Hawaii between 1914 and 1917. The following account written in the newspaper by Hawaiian historians John Wise and J. W. I. Kihe included, cites the agricultural importance of Wai' aha:

The story is set in about the 13th century, in the time of Pili- a- Ka' aiea ( Pili), sovereign chief of all Kona, the narrative identifies the lands between Lanihau IKailual and

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HAUN & ASSOCIATES 18 11 ^oII TMK : ( 3 ) 7- 5- 018 : 071 Report No 932- 070E16

Puapua' a as an integral component of Pill' s royal domain. Pili was a great advocate of contests in debating, fighting and physical strength, and Hinakahua at Puapua' a was the site of the chief' s longhouses and contest field which supported those activities. While Pili was at Hinakahua, he was supported by the agricultural and natural resources of the surrounding ahupua' a including Kahului, Waiaha, Pua' a, Auhaukea' e, Hinaloli( Hienaloli), Honua' la, Keopu, Moeauoa and Lanihau. Pill's royal compound was at Niumalu, his

canoe fleets were harbored at Oneo ( and his wealth- houses, where tribute was kept

until it was needed, were situated at Ahu' ena( 1996: A- 2).

The importance of Wai' aha to the Hawaiian royalty continued into the post- Contact period. In her later years, Queen Emma, wife of Alexander Liholiho( Kamehameha II), had a residence and associated gardens in inland Wai' aha. Figure 8 is a portion of Emerson' s 1880s map of Kailua. This map depicts Queen Emma' s house in the inland portion of the ahupuo' a.

Hawaii was first unified under the rule of' Umi- a- Liloa and Kona was selected as a dwelling place of chiefs Kamakau 1961). The area lies within the realm of the traditional Hawaiian political authority that was centered in the Kailua- Keauhou area from at least the 15th century to the reign of Kamehameha I.

Schilt ( 1984) summarizes Kailua' s early historic period. In the late 1700s to early 1800s, Kamehameha monopolized foreign commerce including the provisioning of trading and whaling ships and beginning in 1811 the sandalwood trade. The first missionaries arrived in Kailua in 1820, but only stayed a few months. They returned in 1823 and were given land to establish missions and by 1825 schools in Wai' aha. According to Soehren, " A large part of Wai' aha 1st was subsequently awarded to the American Board of Commissioners for Foreign Missions during the Mahele to most likely provide rental income for the support of mission schools"( 1981: 4).

The gradual shift from subsistence farming to a market economy began with the introduction of coffee, corn, pumpkins, cotton, pineapple, and Irish potatoes in the 1820s to 1840s. Introduced early historic crops cultivated in the vicinity of Kailua below 500 ft elevation included melons, cabbage, onions, oranges, and tobacco. The introduction of cattle ranching and commercial coffee production in the mid- 1800s caused further change to the traditional agricultural system. The Kuakini Wall ( Site 6302), which was built to control the movement of livestock, extends through Wai' aha, at approximately 85 to 100 ft elevation ( see Figure 7). The wall' s construction began in the early 1800s. Its completion in the mid- 1850s is attributed to Governor Kuakini.

In the 1840s, political acts of the Hawaiian Kingdom government would change the land tenure system in Hawaii. All lands were segregated into one of three categories:" Crown Lands" owned by the occupant of the throne, " Government Lands" controlled by the state, and " Konohiki Lands" controlled by the chiefs; and " were all subject to the rights of native tenants" ( Chinen 1958: 29, Beamer 2014: 143). In 1846, King Kamehameha III appointed a Board of Commissioners commonly known as the Land Commissioners, to confirm or reject all claims to land arising previously to the 10th day of December, AD 1845." Notices were frequently posted in The Polynesian ( Moffat and Kirkpatrick, 1995); however, the legislature did not acknowledge this act until June 7, 1848( Chinen 1958: 16; Moffat and Kirkpatrick 1995: 48- 49) and the act is known today as The Great Mahele. In 1850, the Kingdom government passed laws allowing foreigners to purchase fee simple lands ( Speakman 2001: 91). The Kuleana Act of 1850 allowed for fee simple land ownership by commoners.

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HAUN & ASSOCIATES I 10 aptlPkt'aoh1esLNiUiichpeAAmtstartrupuwn ---mama TMK : ( 31 7 - 5 - 018 : 071 Report No 932 . 070816

A review of the Waihona' Aina( 2000) Mahele Database; which is a compilation of data from the Indices of Awards ( Indices 1929), Native Register ( NR n. d.), Native Testimony ( NT n. d.), Foreign Register ( FR n. d.) and Foreign Testimony( FT n. d.); indicates that the majority of the ahupua' o of Wai' aha 1 was awarded to Seth Andrews as Land Commission Award ( LCA) 387 ( see Figure 7). Ten claimants registered for parcels within Wai' aha, although it appears that only eight of the ten received awards ( excluding LCA 6376 and 7714- B). The awarded kuleana parcels ranged from 0. 06 acres to the large unstated acreage of LCA 387.

Table 1. Land Commission Awards in Wai' aha LCA claimant AM1upuaa g Land Use p2tl GIer Acreage

387 Seth Andrews Waiaha I Majority of ahupua' a- 1 house lot and cow yard - N/ A

6376' Lono Waiaha House lot

5 sections of cultivated land and one house lot Puuko 0] 5 6699 Lumaa we Wa is ha 1 with 2 houses and 1 enclosure

Muku 2 kihipai 0. 25

1 section of cultivated land mauka 6402 Ka nabele Wale hat

2 house lots 0. 77

7241- 8 Ka la ma Wa is ha 1 1 House Lot and hula land 046

7481 Ka I ae Wa is ha 1 Ka muku 2 partially cultivated land sections 1. 61

7714- 8' Kekualwa Walaha N/ A

Ka No Wa is ha 2 Ka u a 11 o 1 land section 1839 Laiwahine 108 7912

Kanail oa 1 land section

Liawahine Houma uul oa 1 land section 1824 Faaea 0. 29 7912- C Waia ha 2 1 land section

House lot 1. 77

7913 KaaneM1e Waiaha 2 hand section 0. 06

I land section 0. 55

Claim not awarded The awarded parcels are concentrated in two areas. One cluster of two parcels is situated at the coast. The other cluster of eight parcels is located in the inland portion of Wai' aha situated between 1, 500 ft and 2, 600 ft elevation. Seven claims included house lots with at least 8 houses. The claims also list one enclosure and one cow yard. The testimonies refer to 13 cultivated sections or kihapai.

LCA 7481 is located in the northeastern portion of the Kona Reef Condominium development. This was awarded to Kalee as Royal Patent 3682 and consisted of a 1. 61 acre claim comprised of two partially cultivated land sections. This area is currently covered by an asphalt parking area( see Figure 3).

Emerson' s 1880s map of Kailua ( see Figure 8) shows the seaward boundary of the inland forest was at approximately 600 ft elevation in Wai' aha. Commercial sugar cane cultivation in the Kailua area was attempted in the late 1800s and early 1900s ( Kelly 1983). The Kona Sugar Company was established in 1899 and built the first mill in 1901, in upland Wai' aha overlooking Kailua. The mill was situated above the Kahului- Hienaloli Road at approximately 700 ft elevation. The mill is shown on the 1928 USGS Kailua

Quadrangle ( Figure 9). According to Maly, the sugarcane fields "... extended south from Wai' aha to Hdlualoa- Kaumalumalu, on fee and leasehold lands. With the success of the sugar crop, the plantation fields were soon expanded south in favorable localities, including the kula lands between Honalo and Kalukalu- Onouli"( 2001: 283).

A railroad line, constructed to transport sugar cane to the mill originated at the mill and extended 11 miles to the south where it terminated in Keopuka in South Kona( see Figure 9). Construction of this

HAUN & ASSOCIATES I 11 TMK _ ( 3 ) 7- 5- 018071 Report No 932- 070816

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HAUN & ASSOCIATES I 12 APIlj‘ _.--.‘\11111 TMK : i3 ) 7- 5 - 013 '. 071 Report No 932- 07 0 81 6

substantial railroad line began in 1901 by the West Hawaii Railway Company ( Conde and Best 1973). According to Burtchard:

during its short life span the sugar line was most impressive, at least architecturally. The stone work used to span ravines and other irregularities in Hualalais rough western slope provides a number of excellent examples of dry- laid dressed stone masonry over a rubble core berm. The constructed berm ranges from less than one to as much as 15 m 50 feet) in height. The stone work in this feature is uniformly well executed. In recognition of the historical significance of the rail line, the site is listed on the Hawaii Register of Historic Places( Site 50- 10- 37- 37- 7214).( 1996: 49)

Despite the efforts required to construct the mill and railroad line, the venture was not successful. " The railroad record disappears in 1918 and the sugar company went into receivership in 1926" ( Burtchard 1996: 49).

By the 1970s, the rapidly developing tourism industry began to transform the region' s land use from ranching and commercial agriculture, except coffee production, to subdivisions, resorts, and commercial establishments. The use of the present Kona Reef Condominium area was probably limited to cattle ranching. In 1927, rancher Manuel Gomes bought tracts of land in Wai' aha and Kahului and used these lands for cattle grazing until the 1960s( Rechtman 2002).

Previous Archaeological Work

Limited archaeological research has been conducted within the Land of Waiaha. A search of the DLNR archives indicates that 14 archaeological projects have been conducted in the Land of Waiaha. Figure 7 shows the locations of the projects and Table 2 summarizes the projects. Not included in the figure are the general studies by Thrum ( 1908) and Stokes ( cited in Stokes and Dye 1991), which focused on major sites, primarily heiou, throughout Hawaii Island, and the West Hawaii survey by Reinecke( 1930). These researchers each identified Ma' o Heiau, located along the shoreline on the north side of Waiaha Bay. This heiau would have been in dose proximity to the present project area; however according to Stokes, it had been partially destroyed by the construction of the coastal government road ( 1991:8- 9). According to Thrum( 1908), the heiau was constructed by Kiwala' o. As previously discussed, Ma' o Heiau functioned as a rainmaking heiou used to start or stop the rain( Pukui et al. 1976: 219).

Table 2. Previous archaeological work

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HAUN & ASSOCIATES 113 Wand TMK : ( 3 ) 7- 5- 018 '. 071 Report Na 93 2- 07 0 8 16

The majority of the archaeological studies have been conducted in the seaward portion of the ahupuo' o. These include three reconnaissance surveys conducted by Soehren( 1979, 1981) and Barrera( 1991) below 100 ft elevation. These studies each examined parcels that had been bulldozed and in which no sites were present. The Soehren( 1981) survey was located adjacent to the present project area to the south.

Head et al. ( 1994) conducted a survey of the Ali' i Drive Sewer project that consisted of a 0. 34- acre corridor in Puaa 3 and a 2.06- acre parcel located in Wai' aha 1. The survey identified 20 sites and 38 features comprised of one permanent habitation, 11 temporary habitations, eight agricultural feature, five probable burials, four ritual feature, one trail, seven livestock control features and three indeterminate features. Charcoal was submitted from two sites yielding date ranges from AD 1640- 1955.

Rechtman ( 2002) undertook an inventory survey of a 19- acre parcel of coastal Wai' aha 1, situated inland of Ali' i Drive and seaward of Walua Road. The study identified 28 sites with 42 individual features, consisting of 18 identified during this survey and 10 sites previously noted by Head et al. ( 1994). Probable prehistoric to early historic traditional Hawaiian sites were identified consisting of a heiou, five permanent habitations, five temporary habitations and two agricultural sites. Human remains were observed in two of the habitation sites. The remaining sites consisted of historic period sites consisting of ranch walls and corral enclosures. Most of the walls and corrals were interpreted as facilities of the Gomes Ranch, active from 1927 to the 1960' s. Subsurface testing was undertaken at seven sites by Rechtman( 2002) during the inventory survey. Radiocarbon dates were obtained for two sites, indicating use of the parcel from A. D. 1640 through 1955( Rechtman 2002: 13, 21).

Data recovery was subsequently conducted in the Rechtman ( 2002) parcel by Haun et al. ( 2007). This project consisted of hand- excavating a total of 27. 0 sq m at nine sites. Ten radiocarbon samples were

analyzed. radiocarbon age The determinations indicate that prehistoric use of the parcel post- dates A. D. i—\ 1280 and that the majority of the surface features investigated were constructed after A. D. 1635. t J Four sites containing human remains were identified during the data recovery excavations. Following consultation with the DLNR- SHPD Burial Sites Program staff the human remains from three of these sites were re- interred to a crypt constructed at the heiau site. The remaining site with human remains was preserved in place.

Corbin and Gothar ( 2001) conducted an archaeological inventory survey of 5.4- acres located below the Kuakini Highway and inland of Walua Road, above the Rechtman ( 2002) parcel. The survey identified 27 sites and 41 features with functional types consisting of agriculture( 13), temporary habitation ( 8), animal husbandry ( 7), boundary ( 4), possible burial ( 3), storage ( 2), indeterminate ( 2), recreation ( 1) and ceremonial ( 1). The 27 sites consisted of 19 identified by Corbin and Gothar ( 2001) and 8 previously recorded by Head et al. ( 1994). Corbin and Gothar( 2001) assessed all of the sites as significant for their information content. Two sites, a possible shrine and a cave containing possible burial mounds were provisionally assessed as significant for their cultural value pending further investigation. Data Recovery was subsequently conducted within the Corbin and Gothar ( 2001) study area by Kerrigan et al. ( 2007). Six sites were remapped and a total of 17. 75 sq m was excavated in ten features at five sites. During the mapping phase at one site, human remains were identified on the lava tube floor and in consultation with SHPD it was determined that the proposed data recovery excavations were likely to disturb additional shallowly buried human remains, so no excavation was undertaken. Scattered and fragmentary human skeletal elements were encountered in a surface and subsurface context at another lava tube. These were left in situ or replaced in their original locations in consultation with SHPD staff. Five charcoal samples were submitted for analysis. One site was determined to be in use by the mid- 15`"

HAUN & ASSOCIATES 114 TMK : ( 3 ) 7- 5- 018 : 071 Report Na 932- 070816

Century and was continuously used into the early historic period. A lava blister was in use between AD 1450 and 1650, and a large platform was constructed between AD 1670 and 1780.

Schilt ( 1984) conducted an inventory survey of the Kuakini Highway Realignment Corridor. This survey extended between Lanihau Ahupua' a in the north and Holualoa in the south and documented hundreds of archaeological features. An estimated 10. 5 acres of the Schilt ( 1984) survey area were located within Waiaha 1 and 2. Schilt documented five sites in Wai' aha, all of which are livestock control walls.

A portion of the wall on the boundary between Wai' aha 1 and Pua' a 3 was also noted by Barnette( 2011) during a survey of a 4. 2 acre parcel located adjacent to the present project area to the north, in Pua' a 3 see Figure 7). This survey documented four historic livestock control walls, including the one located on the Wai' aha 1/ Pua' a 3 boundary.

Four studies are situated in the interior portion of Waiaha. Haun and Henry ( 2015) conducted an archaeological inventory survey of two easement corridors in Wai' aha 1 and 2 Ahupua' a that total 1.98 acres in area. The survey documented six single feature sites consisting of an agricultural modified outcrop, a surface and subsurface cultural deposit, a scatter of surface remains, and three ranch walls.

Bevan et al. ( 2004) conducted an inventory survey of a 1, 750 meter long proposed roadway that extended between the Kahului- Hienaloli Road and the North Kona Belt Road. This survey identified two sites consisting of a portion of the West Hawaii Railroad and an agricultural and ranching complex with 52 features. Two water tank sites situated adjacent to the proposed roadway were subsequently examined by Kouneski et al. ( 2006). This study identified three sites consisting of two pre- contact agricultural complexes with a total of 17 features and an historic water pipeline.

Haun ( 2008) conducted an inventory survey of a 2. 0 acre parcel in Wai' aha 2 just seaward of the Kahului- Hienaloli Road. This survey identified six single features sites comprised of four livestock control walls, an historic habitation artifact scatter and a permanent habitation terrace.

The projects in Table 2 cover more than 70 acres of Wai' aha identifying 78 sites with 173 features. To aid in reconstructing settlement patterns, features were quantified by probable age and function, and the studies are ordered by elevation. Traditional Hawaiian features were categorized as habitation, agricultural, burial( including possible burials), and ritual. Features not assignable to these categories were categorized as miscellaneous/ indeterminate. Traditional sites in this category include ahu and features with indeterminate functions. Habitation sites are further subdivided into temporary and permanent for studies making this distinction.

Density values are given for sites, features, and habitation and agricultural features. The studies have identified 29 habitation features, 41 agricultural features, five burials and two ritual features. The majority of the features ( 93) are historic features were not segregated by function. The majority of the historic features are ranch walls. Overall feature density values range from 0. 26 to 16. 51 features per acre with an average of 5. 24.

The project area lies within the kula zone of the Kona Field System, SIHP Site 6601 ( Newman 1970, Kelly 1983, Schilt 1984, Cordy 1995). This site extends north to Ka' u Ahupua' a, south to Honaunau, and from the coastline to the forested slopes of Hualalai. The area was intensively cultivated and served as the resource base for the large number of chiefs and retainers that occupied the Kailua- Keauhou coast. The characteristics and general locations of the elevation zones of the system described by Newman ( 1970) have been confirmed and elaborated on by subsequent ethnohistorical investigations ( Kelly 1983). The system is subdivided into four elevation zones.

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The kula zone extends from sea level to 500 ft elevation. Cordy( 1995) has suggested that the upper limit of this zone may be higher between 600- 700 ft elevation. This lower elevation zone traditionally was used for habitation and cultivation of sweet potatoes, paper mulberry ( wauke), and gourds. Agricultural features, including clearing mounds, planting mounds, planting depressions, modified outcrops, and planting terraces, are common in this zone ( Hammatt and Clark 1980; Hammatt and Folk 1980; Schilt 1984). Habitations are scattered throughout the kula, but they are concentrated along the shoreline portion of the zone ( Cordy 1995). The shoreline portion, extending approximately 200 m inland, was the focus of permanent habitation and activities such as burial, canoe storage, ritual, and marine exploitation. Royal centers and chiefly residences were also situated near the shoreline. These complexes included residences for high status individuals and their supporters and attendants, heiau, places of refuge, holua

slides, and other structures.

The kolu' ulu zone extends from 500 to 1000 ft elevation. The zone was used for cultivating sweet potatoes, paper mulberry, and especially breadfruit. Archaeologically, this zone is not distinguishable from the adjacent ' apa' a zone ( Cordy 1995). The ' opoa zone is situated between 1000 and 2500 ft elevation. This zone traditionally was used for dryland cultivation of taro, sugar cane, sweet potato, and ti. Permanent habitations were present in the ' apa' a zone, but were infrequent ( Cordy 1995, Burtchard 1996). Dwellings were observed by early historic chroniclers, but most were probably for temporary use in conjunction with agriculture, bird hunting, and collecting of plant resources. Burials and ritual sites are rare in the upper elevation zones( Kawachi 1989).

Kuo' iwi are prominent agricultural features of the kolu' ulu and' apa' a, zones( Cordy 1995, Newman 1970). These are broad, linear piles of rocks built from stones cleared from the adjacent slopes that also served as field boundaries. Kua' iwi are oriented inland- seaward often interconnected with perpendicular, soil- retaining walls and terraces forming rectangular grid patterns of fields. Kuo' iwi also served to control rainfall runoff( Kirch 1985). These formal fields contrast with more informal garden areas characterized by scattered agricultural features in very rocky areas, such as young lava flows, and much of the kula zone.

The ' ama' u zone extends from 2500 ft to 4000 ft elevation. The zone was associated with banana and plantain cultivation. The archaeological traits of the zone have not been well defined, but temporary habitations were probably present associated with agriculture and exploitation of forest resources ( Allen 1984).

No previous archaeological work has been conducted within the project area; however an Environmental Assessment was conducted by Fuke( 1981) that provides insight into the development history of the Kona Reef Condominium. According to Fuke:

Kona Reef Condominium submitted preliminary plans in February 1974 for the development of a 129- unit condominium and its related improvements. Final plan approval was granted in June 1975 for the proposed development. A Building Permit to construct the foundation was issued in November 1975. Work was continued on the project site and in February 1979, the Building Permit to construct the condominium building itself was issued.( 1981: 1)

Fuke indicates that the seaward portion of the subject parcel was extensively impacted during the construction of the Kona Reef Condominium. These impacts include depositing approximately 800 cubic meters of topsoil, the installation of a sprinkler system and outdoor lighting and landscaping.

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SHPD archaeologist Michael Vitousek examined the shoreline of the property in December 2011 and identified a possible archaeological cultural deposit in the northern portion of the development ( Log No. 2011. 3365, Doc. No. 1112MV27 - Appendix A). According to Mr. Vitousek, The deposit consists of a darkened anthropogenic sandy layer that includes marine shell, echinoidea, and charcoal. The cultural layer appears to be eroding out of the face of the shoreline bank and, while most noticeable in the north end of the project area, may extend the entire length of the ocean frontage." Based on this inspection, SHPD requested that an archaeological inventory survey be conducted to further examine this cultural deposit and determine if it had been impacted by the construction of the Kona Reef Condominium.

PROJECT EXPECTATIONS

The project area is situated in the coastal portion of the kola zone of the Kona Field System. Based on previous archaeological research and historical documentary research, evidence of permanent habitation, burial, canoe storage, ritual, and marine exploitation are typically expected in the coastal areas. Royal centers and chiefly residences were also situated near the shoreline; however, because the project area was extensively impacted by the development of the Kona Reef Condominium, it is unlikely that any surface sites would be encountered during the present project. It is possible that subsurface cultural deposits, similar to those identified during the SHPD December 2011 inspection, would be present.

CONSULTATION

Haun & Associates Project Supervisor Solomon Kailihiwa, M. A. conducted an interview with longtime Kona resident Mr. lames Paul on March 11, 2016. Mr. Paul is the former owner of the land where the Kona Reef Condominium is situated. He currently lives in a house located adjacent to the Kona Reef CCondominium to the northwest. He purchased the property in the 1950s and at that time it was all pasture. He built his house in 1958 and bulldozed the Kona Reef lot during the 1960s. During the bulldozing he made two large piles of kiawe, koo hoole, and grass, and burned them in a large bonfire. Mr. Paul was friends with everyone in the fire department who were on hand to ensure that the blaze did not get out of control. They used material from the upslope portion of the property to fill in the seaward portion. This material was placed on top of a beach deposit that covered the seaward portion of the area. After the lot was bulldozed he leased the land to Mr. Tom Gentry, who eventually constructed the Kona Reef Condominium. Mr. Paul recalls that Mr. Gentry also bulldozed the lot.

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FINDINGS

Surface survey of the proposed erosion abatement structure project area did not identify any surface sites or cultural material. This area is currently a grass lawn bordered by a discontinuous berm of boulders and cobbles on the seaward side of the condominium buildings( see Figure 4 and Figure 5).

The area of the proposed erosion abatement structure was examined by excavating ten 0.5 by 0.5 meter shovel tests on the inland side of the vegetation along the certified shoreline. These shovel tests were spaced GA to 7.8 meters apart ( average 6. 9 meters) and were excavated to bedrock. The shovel test locations are depicted on Figure 6.

The shovel test excavations revealed similar soil stratigraphy. This stratigraphy is summarized in Table 3 with profiles of the shovel tests shown in Figure 10 and Figure 11. All ten shovel tests encountered a surface layer of fill with roots from the grass lawn ( Layer I). This deposit ranges in thickness from 0. 09 to 0.36 meters, with an average thickness of 0. 13 meter. Layer I varies in texture from silt to silty sandy clay and in color from black to very dark grayish brown.

Table 3. Summary of shovel test stratigraphy

Depth rntdnesa Soil type unit Soil Color Munsell Texture Inclusions rA lonba1 ( cm) 636 36 Very dark grayish brown 1OYR 3/ 2 Silt 35% pebbles

0- 9 9 Very dark brown 10YR 2/ 2 Silty sandy clay 10% cobbles and pebbles

5i3 0. 10 10 Dark brown 7. 513 3/ 2 Silty sandy day 80% cobbles and pebbles

5 613 Very dark brown I00812/ 1 3% cobbles

51.5 0. 10 0 Very dark grayish brown 100R 312 15% cobbles 1 1 ST6 0- 13 ® Very dark brown 10YR 2/ 2 Silty sandy day 15% boulders and cobbles 51.7 97 a Black 10YR 1/ 1 Silt 10% cobbles ST8 0- 16 16 Very dark brown 10712 7/ 2 Silty sandy clay 10% boulders and cobbles

ST9 662 12 Black 10YR 2/ 1 Silt 10%cobbles

5 0- 7 7 Dark brown 101R3/ 3 Silty sand 15% cobbles

sTz bW ______Very dark grayish brown SOYR 3/ 2 Silty sand 15% cobbles and pebbles STd m® Dark brown 7. 5YR 3/ 2 Silt 15% cobbles and pebbles ST4 ® 13 Very dark grayish brown 10YR 3/ 2 silty sand 60% boulders and cobbles sT5 n 18 Dark brown 75YR 3/ 2 Silt 00% boulders, cobbles and pebbles 5T6 ® 39 Very dark grayish brown 10YR 3/ 2 Silty sand 606 boulders and cobbles C 35 Dark brown 10YR 3/ 3 Silt 50% boulders and cobbles ST8 E 78 Very dark grayish brown 10YR 3/ 1 Silty sand 70% boulders and cobbles 5T.9 C 34 Dalt brown 10YR 3/ 3 silt 76% boulders and cobbles Sid0 ®' 10 Omit yellowish brown IOYR3/ 4 Silty sand 10% cobbles ST10 I 14 yellowish brown 10YR 5/ 4 Silty sand 10% cobbles 85 5 106 67 pgdt yellowish brown 10Th 6/ 4 coarse sand 3% cobbles

44 66 Very dark grayish brown 10YR 3/ 2 Coarse sand 30% pebbles

5T- 9 ® 89 Light yellowish brown 10YR 6/ 4 Coarse sand 40% boulders and cobbles

ST- 5 16130 82 yellowish brown toys 5/ 4 Coarse sand 25% cobbles and pebbles

Bearhsand deposit Sib ® 75 Light yellowish brown 10YR 6/ 4 Coarse sand 10% pebbles

5 36108 69 Very dark grayish brown 10YR 3/ 2 Coarse sand 30% boulders, cobbles and pebbles

sT0EEE 19 Light yellowish brown 10YR 6/ 4 Coarse sand 20% boulders and cobbles SF9En 68 Very dark graykM1 brown 10YR 3/ 2 Coarse sand 30% boulders, cobbles and pebbles

ST- 10 ®. 16 Verydark hmwn 10YR 7/ E Coarse sand 20%boulders and cobbles

SRB ®® Dark brown 7. 5YR 3/ 3 Silt 15% boulders and cobbles I l ' r SL9 1101E9 18 Dark brown 10YR 3/ 3 Silt 35% boulderscobbles and pebbles

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Table 4 summarizes the cultural material recovered from shovel testing. Cultural material from Layer I consists of bottle glass fragments, fragments of porcelain ceramics, a wire nail or spike, volcanic glass and waterworn marine shell reef rubble.

Layer Ila is an underlying fill deposit present in nine of the ten shovel tests( excluding ST- 1). This deposit is 0. 1 to 0. 78 meters thick ( average 0.32 meters) and is a silt to silty sand that varies in color from dark brown to dark yellowish brown. In ST- 2 and ST- 3 the cultural material from the upper portions of Layer Ila were mixed with the remains from Layer I. The mixed remains from Layer I/ Ila in these units consist of a corroded penny of indeterminate date, bottle glass fragments, clear plastic, a brass cylinder, volcanic glass, and waterworn marine shell reef rubble. Cultural material recovered exclusively from the Layer Ila deposit consists of bottle glass fragments, an aluminum beverage can, a wire nail, charcoal, and waterworn marine shell reef rubble.

Layer Ilb is an underlying fill deposit present in only 5T- 10 and is overlain by the Layer la fill. This deposit is a yellowish brown silty sand with no cultural material.

Layer III is a layer of coarse beach sand present in nine of the ten STs ( excluding ST- 1). This deposit is a 0. 16 to 0. 89 meter thick (average 0. 56 meters) of a yellowish brown to very dark grayish brown coarse sand. An intrusive PVC pipeline is present in Layer III in 5T- 9. Cultural material recovered from the Layer III deposit consists of a Coca Cola bottle, a Miller High Life bottle, bottle glass fragments, an aluminum ring

pull tab, iron nail fragments, volcanic glass, charcoal, a Cellana talcosa shell, waterworn marine shell reef rubble, an sea urchin spine, and a coral file. The file is 41. 2 mm long, 16. 6 mm wide and 11. 3 mm thick

Figure 12). IL '

Figure 12. Coral file from ST-8

HAUN & ASSOCIATES I 21 TMI( : ) 3 ) 7- 5- 018: 071 Report No 932- 070816

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HAUN & ASSOCIATES 122 of TMK : 13 ) 7- 5 - 018 : 071 Report No 932- 070816

Layer IV is a deposit of dark brown silt present beneath Layer II in ST- 8 and 5T-9. This layer is 0. 18 to 0. 53 meters in thickness and overlies bedrock. No cultural material is present in Layer IV.

The results of the subsurface testing indicates that the upper deposits ( Layers I, Ila and IIb) are imparted fill material. This material represents either the fill material the prior landowner ( Mr. James Paul) bulldozed into the area during the 1960s, and/ or portions of the 800 cubic yards of soil that were used to topsoil the area in the 1980s. The mixed historic, modern and pre- and/ or early post-contact cultural material confirms that these deposits are not intact cultural layers.

The Layer III coarse sand deposit is interpreted as a naturally deposited sand layer. This sand was present on the surface of the area in the 1960s, before it was disturbed by bulldozer activity. This deposit has been designated as Site 50-10-28- 304931 and interpreted as a pre- and/ or early post-contact cultural deposit that was disturbed by the historic use of the area. This interpretation is based on the presence of the volcanic glass, the coral file, marine shells, and sea urchin spine present in the Layer III deposit. The abundance of historic materials recovered from this deposit indicates it has been significantly impacted.

As discussed, the present project was conducted because an apparent cultural deposit was observed at the northern end of the Kona Reef Condominium by SHPD staff. This area was not examined during the current project as it is outside the area to be impacted by the proposed erosion abatement structure. Based an the results of subsurface testing, the Site 30493 cultural deposit originates between ST- 1 and ST- 2 in the south, and extends 61. 5 meters to the north, beyond ST- 10. It is likely that the deposit continues to the north to the area observed by SHPD staff. The extent of Site 30493 in the area examined is shown in Figure 6. The site is altered and in poor condition. It is assessed as significant per HAR 413- 284- 6 under Criteria d( information content).

1 50= State of Hawaii, 10= Island of Hawaii, 28= Kailua quadrangle

HAUN & ASSOCIATES 123 TMI( . ( 3 ) 7 - 5 - 018 : 071 Report No 932 - 070816

CONCLUSION 1

Discussion

The survey identified the disturbed remnant of a subsurface cultural deposit ( Site 30493) during shovel testing within the project area. This deposit contains pre- and/ or early post- contact cultural material, mixed with historic and modern materials. Documentary research and consultation with an adjacent landowner indicates that the Site 30493 deposit represents the original ground surface prior to the introduction of fill material that occurred during multiple episodes between the 1960s and 1980s.

Significance Assessments

The sites identified during the survey are assessed for significance based on Hawaii Administrative Rules HAR) § 13- 284- 6. According to ( HAR) § 13- 284- 6 ( b), a site must possess integrity of location, design, setting, materials, workmanship, feeling, and association and shall meet one or more of the following criteria:

1. Criterion " a": Be associated with events that have made an important contribution to the broad patterns of our history; 2. Criterion" b": Be associated with the lives of persons important in our past; 3. Criterion " c": Embody the distinctive characteristics of a type, period, or method of construction; represent the work of a master; or possess high artistic value; 4. Criterion " d": Have yielded, or is likely to yield, information important for research on prehistory or history; 5. Criterion " e": Have an important traditional cultural value to the native Hawaiian people or to

another ethnic group of the state due to associations with traditional cultural practices once I J carried out, or still carried out, at the property or due to associations with traditional beliefs, events or oral accounts—these associations being important to the group' s history and cultural identity.

The site identified during the present project is assessed as significant under Criterion " d" based on the above criteria. The site has yielded information important for understanding prehistoric habitation in the area.

Treatment Recommendations

The present project was conducted in conjunction with the construction of a proposed erosion abatement structure in the coastal portion of the Kona Reef Condominium development. The recording of the Site 30493 cultural deposit adequately documents it. No further work or preservation is recommended because the disturbed nature of the deposit precludes the potential to obtain additional archaeological information.

1 )

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TRANSLATION OF HAWAIIAN WORDS'

ahupua' a- traditional Hawaiian land unit usually extending from the uplands to the sea

oli'i- chief, chiefess, officer, ruler, monarch, peer, headman, noble, aristocrat, king, queen or commander

hale- house, building, institution, lodge, station, hall

heiau- pre-Christian place of worship, shrine

konohiki— headman of an ohupuo o land division under the chief

Kuhino nui - powerful officer in the days of the monarchy

kuleana- small piece of property, as within an ohupuo 0

M6hele- land division of 1848

mokai— towards ocean

pahoehoe— Smooth, unbroken type of lava, contrasting with a8

from wehewehe. org

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1984 Archaeological Reconnaissance Survey, Waiono Meadows Development Project Area, Puapua' a 1st and 2" d, Holualoa 1st and 2nd, North Kona, Island of Hawaii (TMK: 7- 5- 15:2, 12 and 7- 6- 2: 1, 14), PH RI Report 119- 070584. Prepared for Waiono Meadows Ranch, Ltd.

Barnette, B.

2011 An Archaeological Inventory Survey, Innovations Public Charter School, Queen Ka' ahumanu Highway( State Route 11), TMK: ( 3) 7- 5- 010: 001. Pua' a Ahupua' a, North Kona District, Island of Hawaii. Sims and Associates report 16590 prepared for Innovations Public Charter School,

Barrera, W.

1991 Archaeological Reconnaissance Survey, Wai' aha 2, North Kona ( TMK: 3- 7- 5-18:7). Prepared by Chiniago Inc.

Berrigan, D., A. Haun and D. Henry

2007 Archaeological Data Recovery, Sites 15512, 15513, 15515, 15516, 22041, 22042 and 22046, Land of Wai' aha 1, North Kona District, Island of Hawaii ( Haun & Associates report 120 prepared for Tom Bolton, Kailua- Kona,

Bevan, A, M. Elmore and J. Kennedy

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Burtchard, G. 1 1996 " Population and Land- Use on the Keauhou Coast: the Mauka Land Inventory Survey, Keauhou, North Kona, Hawaii Island, part I: Narrative." IARII, Honolulu. On file at DLNR- SHPD.

Chinen, Jon J.

1958 The Great Mahele: Hawaii' s Land Division of 1848. University of Hawaii Press.

Conde, J., and G. Best

1973 Sugar Trains: Narrow Gauge Rails of Hawai' LFelton, California: Glenwood Publishers

Corbin, A., and B. Gothar

2001 Archaeological Inventory Survey, Walua Apartment Project, Land of Wai aha 1", North Kona District, Island of Hawaii( TMK: 3- 7-5- 18: 7). PHRI Report prepared for Maryl Group, Inc.

Cordy, R.

1995 Central Kona Archaeological Settlement Patterns. State Historic Preservation Division, DLNR, State of Hawaii. Prepared for the Planning Department, County of Hawaii

DLNR( Department of Land and Natural Resources)

2003 Hawaii Administrative Rules, Title 13. Department of Land and Natural Resources, Subtitle 13, State Historic Preservation Division Rules.

n. d. Foreign of Register Kuleana Claims Recorded by the Board of Commissioners to Quiet Land 1 Titles in the Hawaiian Islands. Manuscript. Hawaii State Archives.

n. d. Foreign Testimony Recorded by the Board of Commissioners to Quiet Land Titles in the Hawaiian Islands. Manuscript. Hawaii State Archives.

Fuke, S.

1981 Environmental Assessment/ Negative Declaration for Variance for Development within the Shoreline Setback Area. Prepared for Environmental Quality Commission, Office of Governor, Honolulu.

Giambelluca, T.W., Q. Chen, A. G. Frazier, J. P. Price, Y.- L. Chen, P.- S. Chu, LK. Eischeid, and D. M. Delparte

2013 Online Rainfall Atlas of Hawaii. Bull. Amer. Meteor. Soc. 94, 313-316, doi: 10. 1175/ BAMS- D- 11- 00228. 1.

Hammatt, H., and S. Clark

1980 Archaeological Testing and Salvage Excavations of a 155 Acre Parcel in Na Ahupua' a Pahoehoe, La' aloa, and Kapala' aea, Kona, Hawaii. Archaeological Research Center Hawaii Report 14- 152 III. Prepared for Pacific Basin Resorts, Inc.

Hammatt, H., and W. Folk

1980 Archaeological Survey, Phase I: Portions of Keauhou- Kona Resort, Keauhou and Kahaluu, Kona Excavations within the Proposed Keahole Agricultural Park, Kalaoa- Ooma, Kona, Hawaii.

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Archaeological Research Center Hawaii Report 14- 177 II. Prepared for Kamehameha Investment Corp.

Haun, A., D. Henry and D. Berrigan

2007 Archaeological Data Recovery, Sites 15517, 15518, 21988, 21991, 21994, 21996. 22067, 22068 and 22069, Land of Waiaha 1, North Kona District, Island of Hawaii. Haun & Associates Report 185 prepared for Sunstone Realty Partners, LLC, Kailua- Kona.

Haun, A.

2008 Archaeological Inventory Survey, TMK: ( 3) 7- 5- 17: Por. 004, Land of Wai' aha 2, North Kona District, island of Hawaii. Haun& Associates report 580 prepared for Mr. Stanley Games.

Head, 1., S. Goodfellow and P. Rosendahl

1994 Archaeological Inventory Survey, Alii Drive Sewer Project, Lands of Puapuaa 2" and 3d, and Waiaha 1" and 2" d, North Kona District, Island of Hawaii( TMK: 7- 5- 18, 7- 8).

Indices

1929 Indices ofAwards Made by the Board of Land Commissioners to Quiet Land Titles in the Hawaiian Islands. Territory of Hawaii, Honolulu.

Juvik, S. P., and 1. 0. Juvik( editors)

1998 Atlas of Hawoi'i, Third Edition. University of Hawaii Press. Honolulu.

Kamakau, S.

1961 Ruling Chiefs of Hawaiy. Honolulu: The Kamehameha Schools Press.

Kawachi, C. T. 1989 An Upland Habitation and Agricultural Complex in North Kona, Hawaii Island. Master' s thesis, Department of Anthropology, University of Hawaii. Kelly, M.

1983 Na Mala 0 Kona: Gardens of Kona. A History of Land Use in Kona, Hawaii. Departmental Report Series 83- 2. Department of Anthropology, B. P. Bishop Museum, Honolulu. Prepared for the Department of Transportation, State of Hawaii.

Kirch, P. V. 1985 Feathered Gods and Fishhooks: An Introduction to Hawaiian Archaeology and Prehistory. Honolulu: University of Hawaii Press.

Kouneski, E., D. Grant and J. Kennedy 2006 An Archaeological Inventory Survey Report for TMK: 7- 5- 16: 35 ( POR.) in Wai' aha 1" Ahupua' a, North Kona District, Island of Hawaii. Archaeological Consultants of the Pacific, Inc. report prepared for Mr. Brian Takeda, R. M. Towill Corp, Honolulu. Maly, K.

1996 Appendix A- Historical Documentary Research. Archeological Inventory Survey, Hienalali 3 and 4, North Kona District, Island of Hawaii ( TMK: 7- 5- 11: 2) by Henry, 1. D., T. R. Wolforth, and P. H. Rosendahl. PHRI Report 1348-032996. Prepared for Maryl Development, Inc.

HAUN & ASSOCIATES 127 TMK : ( 3 ) 7 - 5- 018. 071 Report No 932 - 070816

2001 HE WAHI MO' OLELO NO NA' AINA, A ME NA ALA HELE I HEHI ' IA, MAI KEAUHOU A I KEALAKEKUA, MA KONA, HAWAI' I . A Historical overview of the Lands and Trails traveled between Keauhou and Kealakekua, Kona, Hawaii. Kumo Pono Associates report

Moffat, R. M. and G. L. Kirkpatrick

1995 Surveying the Mahele: Mapping the Hawaiian Land Revolution. Palapalcidina. Editions Limited, Honolulu.

NR n. d. Native Register of Kuleana Claims Recorded by the Board of Commissioners to Quiet Land Titles in the Hawaiian Islands. Manuscript. Hawaii State Archives.

NT n. d. Native Testimony Recorded by the Board of Commissioners to Quiet Land Titles in the Hawaiian Islands. Manuscript. Hawaii State Archives.

Newman, T.

1970 Hawaiian Fishing and Farming on the Island of Hawaii in AD 1778. Department of Land and Natural Resources, Division of State Parks.

Pukui, M., S. Elbert and E. Mo' okini

1976 Place Names ofHawaii. University of Hawaii Press, Honolulu

Rechtman, R.

2002 An Archaeological Inventory Survey of TMK: 3- 7- 5- 18: 08, Waiaha 1" Ahupua' a, North Kona D District, Island of Hawaii. Prepared for Dan Bolton.

Reinecke, 1. E.

1930 Survey of Sites on West Hawaii. Ms. In Bishop Museum( 1930).

Sato, H. H., E. W. Ikeda, R. Paeth, R. Smythe, and M. Takehiro 1r.

1973 Soil Survey of the Island of Hawaii. U. S. Dept. of Agriculture, Soil Conservation Service and University of Hawaii Agricultural Experiment Station. Washington D. C. Government Printing Office.

Schilt, A. R.

1984 Subsistence and Conflict in Kona, Hawaii. An Archaeological Study of the Kuakini Highway Realignment Corridor. Departmental Report Series 84- 1. Department of Anthropology, B. P. Bishop Museum, Honolulu. Prepared for Department of Transportation, State of Hawaii. Experiment Station, Washington, D. C.: Government Printing Office.

Speakman, C. E., 1r.

2001 An Informal History of the Hawaiian Island. San Rafael: Pueo Press.

Soehren, L

1979 Reconnaissance Survey, TMK: 7- 5- 18: 5 & 29, Waiaha 2, North Kona, Hawaii. Captain Cook, Hawaii. U

HAUN & ASSOCIATES I 28 TMI(: i3l 7- 5- 018 : 071 Report No 932- 070816

1981 Archaeological Reconnaissance Survey: Wal aha 1, North Kona, Hawaii ( TMK: 7- 5- 18: 20 and 87). Captain Cook, Hawaii.

Stokes, J. F. G and T. Dye

1991 Heiau of the Island of Hawaii. Bishop Museum Bulletin in Anthropology 2. Bishop Museum Press, Honolulu.

Speakman, C. E., Jr.

2001 An Informal History of the Hawaiian Island. San Rafael: Pueo Press.

Thrum, T. G.

1908 Heiaus and Heiau Sites Throughout the Hawaiian Islands, island of Hawaii. The Recognized Book of Authentic Information on Hawai' i, Combined with Thrum' s Hawaiian Annual and Standard Guide 38-47, Honolulu Star- Bulletin, Honolulu.

Waihona' Aina Corporation

2000 The Mahele Database, waihona. com.

Wehewehe. org

2016 Hawaii Electronic Library - Na Puke Wehewehe' Olelo Hawoi' i

Wolfe, E., and]. Morris

2001 Geological Map of the Island of Hawaii. U. S. Department of the Interior. U. S Geological Survey.

HAUN & ASSOCIATES 129 TMK : ( 3 ) 7- 5- 018: 071 Report No 932- 070816

APPENDIX A - SHPD LETTER

atNEXNEaolatylvaI mama. p• vanaraDomauurnumn

tt STATE OF HAWAII g, EHEEE DEPARTMENT OF LAND AND NATURAL RESOURCES mLV•IckixtRYwovaeumwmmw POST OFFICE BON 621 mmutt mnruu HONOLULU'. HAWAII 96809

January 5. 2012

PuledK. Dahlberg LOG NO: 20113364 pdahlbergn,hawaii. rrcom DOC NO: 1112MV27 Archaeology Dear Mr. Dahlberg.

SUBJECT: Chapter6E- 12Historic Preservation Review- Grading Permit Application fora Seawall at the Kona Reef Condominium Hotel Waiaha Ahupn& ar North Kona District, Island of Hawaii TMK: 1317- 5- 018: 071

Thank you for the opportunity to review this Grading Permit Application that was received by our office on November 29, 2011 We apologize for the delayed review and thank you for your patience. According to the application 0. 314 acres of the 3.082 acre properly will be graded to facilitate the construction of a new seawall al the Kona Reef Condominium Hotel. A review of our records indicates that there has been no archeological inventory surrey completed on this parcel and we have no information on this parcel in our correspondence files. Our records show that in 2011, Iwo separate inadvertent discoveries of human skeletal remains occulted in connection with the construction of seawalls on Alii Drive- one at Kona Bali Kai. and one at the Banyan Tree Condos.

SHPD archaeologist Michael Vilonsek conducted a site visit to the proposed seawall consimclion area on December 23. 2011. The site visit was necessary due to the lack of information on this parcel and the recent discoveries in the area. During the inspection. what appears to be an exposed archeological deposit was identified along the shoreline al the north cad of the project arca. The deposit consists of a darkened anthropogenic sandy layer that includes marine shell, echinoidea and charcoal. The cultural layer appears to be eroding out of the face of the shoreline bank and, while most noticeable in the north end of the project area, may extend the entire length of the ocean frontage. It was difficult l0 determine the exact location of the cultural layer due to the presence of stacked stones that had been placed in front of the= ding bank across most of the shoreline. Subsurface cultural layers in sandy shoreline deposits have a high probability for containing human burials.

In light of this information SHPD requests that an archaeological inventory survey( AIS) be conducted in order to identify the density and distribution of this cultural Layer and determine H Ilk cultural layer retains its historic significance or has been modified by construction of the condos. If significant historic proper ies axe potentially located in Ods project sea the AIS should outline an appropriate course of [ Mt/gallon SHPD requests the opportunity to review and accept the results of the MS prior to the issuance of any permit from the county that may facilitate the destruction of historic properties on this subject parcel. For a list of ie approved archeological consultants in the state of Hawaii please visit the Historic Preservation Division' s website hlloaliawail govldim/ hpd/

Please contact Mike Vitousek at( 808) 652- 1510 or Micheal.Vitousekr?Ha aii.gov if you have any questions or concerns regarding this letter.

Aloha

Theresa K. Donham Acting Archaeology Branch Chief Historic Preservation Division

HAUN & ASSOCIATES 130 APPENDIX E: COASTAL RESOURCE AND EROSION ASSESMENT GEOHAZARDS CONSULTANTS INTERNATIONAL, INC. This page intentionally left blank.]

l i

GCI

GEOHAZARDS CONSULTANTS INTERNATIONAL, INC. Appraisal ofhazards—reduction of risk

GEOLOGIC AND MARINE FACTORS THAT AFFECT SHORELINE EROSION

Kona Reef Condominiums North Kona District, Hawaii TMK: (3) 7- 5- 018: 071

J. P. Lockwood, Ph.D. Timothy E. Scheffler, Ph. D.

June, 2016

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P.O. BOX 479- VOLCANO, HAWAII 96785- USA TEL:( 8oB) 967-8579- FAX:( EMI 967- 8525. email: aeahaz5lhzwaiin. net

1 TABLE OF CONTENTS

Introduction- Study Requirement P. 3

Field Inspections p. 4

Geologic Description p. 4

Effects of Subsidence and Sea- level Rise P. 7

Wave environment along the Kona Coast P. 8

Erosion Mechanisms p. 10

Erosion Rate p. 15

Erosion Mitigation Strategies p. 16

Potential Impact of Proposed Erosion Mitigation Strategies p. 16 0

Coastal Zone Hazards p. 16

Conclusions p. 17

References Cited p. 17

U 2 Introduction - Study requirement

Coastal erosion is a potentially serious problem anywhere along Hawaii' s coastlines, although the most serious problems reflect the vulnerability of sand beaches to erosion( DLNR, 2000), and are thus mostly of concern on the older islands of the State( Kauai, Oahu, and Maui). Erosion is of less concern on Hawaii Island, where rocky shorelines are the norm, and are for the most part immune to significant erosion.

Tsunamis and storm surges can, however, impact rocky coastlines on Hawaii, causing nearshore erosion. Significant damages along much of the western shoreline of Hawaii were caused by a tsunami associated with the devastating Japan earthquake of March 11, 2011. This tsunami caused minor damage at the Kona Reef Condominiums( hereafter referred to as the" KR Property"), as multiple tsunami surges overtopped and partially destroyed a loose stone wall that was built along the KR Property frontage at the boundary between its lawn and the adjoining shoreline( Fi. 1).

Figure 1. Debris thrown up over the lawn of the Kona Reef Condominiums by tsunami wave surges related to the Japan earthquake of March 11, 2011. The surges caused minor erosion of the lawn, and caused damages to lower floor moms. Note the low stone wall( arrow) that was partially destroyed and contributed to the debris.

In order to prevent future erosion of the lawn area, and to mitigate the effects of the rare storm or tsunami surges that could cross the shoreline, a low" Erosion Abatement Structure" ( EAS) has been proposed to be constructed fronting the KR Property mauka of the shoreline. This report documents the nature of erosion and shoreline migration at the KR Property, based on quantitative measurements and observations obtained through field inspection, aerial photography, satellite imagery, and review of the geologic literature. Potential environmental impacts of the proposed EAS

3 is evaluated, particularly as to any impact on coastal processes or on adjoining properties. Original data are reported in both English and metric units, and we will cite those data in their original format in our discussions, whether in feet, meters, inches, or millimeters.

Field Inspections John Lockwood and Tim Schelller initially visited the KR Property in May, 2015 to make geologic observations and inspect evidence for storm surge erosion. We have visited again on multiple occasions in 2016 to make detailed inspections of coastal' geologic structures and to observe and photograph wave activity during normal tides as well as during periods of strong storm wave surge.

Geologic Description

Lava substrate

The entire offshore frontage of the KR Project area is underlain by an irregular shelf of dense, near flat-lying pahoehoe lavas, lavas that also underlie the Kona Reef Condominium buildings and form the solid basement on which the building foundations are excavated( Figure 2). These lavas are part of a single voluminous flow that originated from vents at the summit of Hualalai volcano, 9 miles to the east. The age of this flow, unit" f2f' on the Hualalai geologic map of Moore and Clague( 1991) is estimated to be in the range 10- 25, 000 years. Moore and Clague describe this unit to be an ' a' a flow, with about 8% plagioclase, but along the coast the JJ flow consists entirely of" tube-fed" pahoehoe, with only about 3% plagioclase and minor olivine. It is thus possible that the flow at the KR property is not the same flow as labelled by Moore and Clague on their map, but it must be closely related, and is in the same sequence of old Hualalai summit-derived lavas.

This pahoehoe is uniformly dense, even-grained, and is characterized by uniformly distributed, subrounded vesicles ( gas bubbles), typically 1- 3 mm in size, and commonly stretched parallel to flow surfaces. The vesicles are hematite- lined, and frequently stained yellow-orange near the surface. The flow contains about 3% plagioclase as fine subhedral laths averaging 0. 5 mm in length. Minor( 0. 5- 1%) subhedral yellow-green olivine is present in all samples.

These lavas emplaced as multiple relatively thin, complexly interfingering flow units Figure 3), and presently dip seaward about 2 degrees. Because the Island of Hawaii has been subsiding relative to sea level for the past several hundred thousand years ( Campbell, 1986, Moore, 1970) this area was far inshore from the coastline that existed when the flows were emplaced. This area was at least 150 m higher above sea level at that time, assuming that these flows are at least 13, 000 years old( see discussion on" Effects of Subsidence and Sea Level Rise on Shoreline Position" below).

4 CAMS Shoreline lapplokl 1

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a 1 \ N KONA REEF[ ONUOMINIUMS 1 ' 1 VI 7 1Q 1

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r\ hoehoe M t shell m Shoreline NPP oA 1E/ ef P h ehoe reposed s? I in kande e meq,_ Th; Coral Sand 4 % WNONIIvehPat\ s 1 LEGEND i . yxer sudmry, 1.

PACIFIC OCEAN

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Figure 2. Kona Reef Condominiums- Coastal Features

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Figure 3. Internal layering of the lava flow fronting the KR Property as exposed during low tide. These individual layers and" lava fingers" can be mechanically eroded by powerful storm surge waves, and are the sources of the rounded boulders found along the shoreline.

Unconsolidated sand and boulder deposits

Close to the shoreline, the pahoehoe lava shelf fronting the KR Property is overlain by irregular pockets of unconsolidated of sand and boulders. The subrounded to rounded boulders Figure 4) are derived from mechanical erosion of the pahoehoe shelf, and are relatively stable in their position— they are only subject to movement by the most powerful storm surge waves that impact the coast. In contrast, the sand deposits can be moved about by less powerful surge waves, and are frequently smoothed over and move around the stationary boulders during high tides.

The sand deposits are derived from the mechanical and biologic erosion of offshore coral colonies, and are variable as to their quantity and distribution. A review of Google Earth images taken at various times of the year suggest that these sand deposits may be more extensive during summer months, and are depleted during winter, when storm surge waves are more common along the Kona coast. The source reservoirs for these sand deposits is not known, however it appears from review of satellite images that shallow sand deposits may be located just offshore of the edge of the pahoehoe platform that borders the KR Property. There is no evidence that sand is moving laterally across the pahoehoe platform, even from the adjacent large sand deposits at nearby Honl' s Beach( Figure 2).

U 6 1 _ a ,

sa/ t.YF+ MIY .

Figure 4. View looking seaward from the KR Property, during a period of strong surge, showing breaking waves at the edge of the pahoehoe platform about 150 feet from the shoreline. Note the subrounded to rounded storm boulders in the foreground, overlain by coral sand. These boulders are only moved by especially powerful storm waves, and are derived from the hydraulic excavation of pahoehoe from farther out on the platform.

Effects of Subsidence and Sea Level Rise on Shoreline Position

An overall global rise in sea level of 3. 3 feet by the end of the 21st century has been proposed by Fletcher et al( 2010), although locally these figures vary greatly in the short term because of climatic factors. The U. S. Army Corps of Engineers maintains a website with a" Sea level Change Calculator" based on historical tide station data that provides low, medium and high probability outcomes for sea- level rise over the next century. Their estimates for sea level rise over the next 80 years at Hilo, Hawaii( the nearest tide station) by( Figure 5) vary from 1 to 5 feet.

Hwang et al ( 2007) use a figure of. 16 in( 4 mm)/ yr for global sea level rise in their assessments, but these figures do not account for the apparent sea level rise relative to shorelines on the Island of Hawaii. Relative sea- level rise on a sinking island is a result of the combined

7 global sea level rise and land subsidence. Because of isostatic settling into the underlying mantle, the entire island of Hawaii has been subsiding since volcanoes began growing in this area over a million years ago, at rates that have been estimated at between 1. 8 and 2. 4 min/yr. for the past several thousand years( Campbell, 1986). A drowned reef terrace west of Kealakekua Bay, 10 miles south of the KR Property, formed about 13, 000 years ago, but is now at 150 m water depth, showing that this area has subsided at an absolute rate of 1. 8- 3 mm/yr( Moore and Fornari. 1984). These authors assumed a value of 1. 8 mm/ yr global sea level rise, but the higher 4 mm/ yr value proposed by Hwang et all ( 2005) is more realistic, especially considering the recently observed impact of global warming on sea level rise. A rise in relative sea level of at least 6- 7 mm( 0. 25 in)/ yr is thus the most reasonable value to assume for the near- term future in this area. At this rate( about a foot rise in 50 years), the effects on the shoreline fronting the KR Property should be minimal during its expected future lifetime. The offshore pahoehoe platform will still be present, and waves will break at its margin, so that relatively low- energy storm surges will remain the problem to be dealt with.

RehBeeaea Level change ProjMon.- eaupe: 10177€ 0, aee: Heu bar: ltuhla Bay. HI puma) esceueuswemucnewp; 5 I 1 m 4 0

2000 2020 PNp 2030 2080 2100 2010 2030 2050 2070 2000

Year

Figure 5. Projected sea level change at Hilo, Hawaii for this century http:// www.corpsclimate. us/ ccaceslcurves.cfm)

Wave environment along the Kona Coast

The" wave climate" of Kailua-Kona, HI has been described by Dollar( 1982) and Grigg 1998). The wave climate is the combination ofconditions including wave energy, frequency, geology and topography of a specific site. Generally speaking, Kailua-Kona is completely sheltered from the Northwest Trade wind seas that batter the windward side of the islands. Hurricane generated swells can have impacts on the Kailua coast as can tsunami generated waves. Storm waves associated with regional swells that impact the Kailua- Kona area can be classified into three types:

8 1) South Pacific and Indian Ocean storms in the southern hemisphere winter( Hawaii' s summer) can generate large south swells that impact the coast.

2) North Pacific storms in the winter generate some of the largest waves to impact the shoreline, on occasion having wave heights in excess of ten meters. However, these storms must contain a significant westerly element in order to impact Kailua directly, as the islands of Maui, Lanai and Molokai create a sort of wave-shadow shielding west Hawaii.

3) " Kona storms", locally generated storms and low pressure fronts moving from northwest to southeast, that are extremely unpredictable and variable in strength but can also produce significant waves with periods between 8— 10 seconds and( deep water) heights from 3 — 5 meters ( Table 1)

North Pacific waves are the largest and most destructive, exceeded only by the potential for large hurricane surf. However, the return interval for very large hurricane events on the island is roughly 40 years, while large winter swells can be expected annually ( Grigg 1998; Figure 6). Of the major storms that have impacted West Hawaii over the past 60 years( Table 2), four have occurred since the Kona Reef Condominiums were constructed in 1980, but none have caused serious damage. Major waves were also associated with the March, 2011 Japan tsunami. C

Table 1. Estimated average unretracted wave characteristics for three wave types on the west coast of island of Hawaii( bottom slope x 1: 8. 3)

Wave Deepwater Deepwater Breaker Breaker period wave wave height depth s[ height length m] m] m] m]

South 20 1 682 2.4 1. 7 swell North 15 2 384 4.6 3. 3 Pacific

swell Kona 9 6 138 7.7 6.0 storm

Table 1. Characteristics of waves that can impact the west coast of Hawaii Island( Dollar, 1982).

9 10

0 6 5°e co

tir w 6 — m a o°° It 4

South Swell - a.a 2— 0 w -

0 I I I iiiit I I I 5 10 50 RETURN PERIOD ( years)

Fig. 3. Plots of deepwater wave heights( upper 10th) as function of average return period of storm events. ( From Rochlemi and Sullivan, un- published data, 1981)

Figure 6. Average return periods of storm waves that can impact the Kona Coast( figure reprinted in Dollar, 1982).

Hurricane Date Major Kona Date Tsunami Date Name Storms Source Nina December, Unnamed January, Kamchatka 4 November, 1957 1974 1952 Dot August, 1959 Unnamed January, Japan 11 March, 2011 1980 Iwa November, Unnamed December, 1982 2010 Iniki September, 1992

Table 2. Major hurricanes, winter storms, and tsunami that have impacted the west coast of Hawaii Island during the past 60 years.

Erosion Mechanisms

The lava platform that fronts the entire KR Property( Figure 2) serves as a wave buffer. Incoming waves break on the margin of this platform where most of their energy is dissipated Figure 7) so that only wave surges travel over the platform and reach the shoreline.

10 delrOtt° Figure 7. Large surf impacting the coastline fronting the KR Property on February 25, 2016. Note that incoming waves break on the edge of the lava platform about 150 feet offshore, and that only low- energy surges reach the shoreline. Regardless of incoming swell and wave directions, surges travel over this platform in a direction normal to the shoreline; there are no lateral, longshore currents at the shoreline.

Interfaces between individual flow units form zones of weakness ( Figure 3) can allow breaking waves at the platform margin and storm surges that move over the platform to break off rock fragments and move them shoreward. Most of these fragments, preserved as near-shore boulders, are well- rounded ( Figure 4) indicating that such mechanical erosion is infrequent otherwise fragments would be angular in shape). Original surface features on the lava platform are preserved in many places on the platform (Figure 8), showing that little surficial erosion has taken place since the lava flows were formed, and that wave erosion has been minimal.

11 i yy{ y9n . s, ` a •"' fit

er. I r/, 2016

Figure 8. Ropy pahoehoe texture on the surface of lavas exposed on the platform fronting the KR Property, demonstrating that little wave erosion is taking place in this area.

The only active erosion that was observed was caused by storm wave surges that reach the margin of the lawn fronting the KR Property( Figures 9, 10). This lawn is underlain by fine- grained fill material that was used as a substrate for lawn that was planted inshore from the shoreline about 35 years ago. Sapping of fine-grained material from under the lawn causes the UJ 12 lawn grass to subside and creep seaward.

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Figure 9. Erosion of lawn margin fronting the KR Property. Storm surges are not capable of moving the boulders located here at the shoreline, but do erode the fine sediments underlying the lawn.

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rias;.;.

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Figure 10. Detail of eroding lawn fronting the KR Property. Surges associated with the tsunami of March 11, 2011 removed fine materials surrounding the cobbles that underlie the lawn, and caused the lawn to retreat as much as six inches in places.

U 14 lr Erosion Rate

Available aerial photographs of the area date back only to 1954( Table 1). Inspection of these photographs indicate that the general features of the coastline fronting the KR Property have not changed for the past 62 years, but the small scales of the photos would not reveal small changes(< ca. 15 feet) that may have occurred.

Date Agency Flight Line Frames Approx. Scale 1954 USN-USGS 017 09, 10 1: 35, 020 1976 USGS GS- VEEC 8 59, 60 1: 37, 410 2010- 2015 Google Earth Variable

Table 3 Stereographic aerial photography available for determination of erosion rates in the Property area.

Erosion of the lawn area mauka of the shoreline by rare storm or tsunami-related surges is a problem that has resulted in minor retreat of the lawn. The presence of coconut palm trees along the lawn frontage ( Figure 11), trees that were planted in the 1980' s, shows that any lateral erosion of this area has been very minor over this period.

Figure 11. View northward along the shoreline fronting the KR Property. l

15 Erosion Mitigation Strategies C1

A low" Erosion Abatement Structure"( ERS) has been proposed to be constructed mauka of the shoreline, at the margin of the lawn area, to prevent further erosion of the lawn, and to prevent fine- grained landfill underlying the lawn from entering the sea( See Section [ Graham Report] for details). Such a low structure would serve to protect the lawn area from surge waves that can reach the shoreline during times of storms or tsunami.

Potential Impact of Proposed Erosion Abatement Structure

The ERS will have absolutely no environmental impact, other than the beneficial effect of eliminating the potential for fine- grained fill material from beneath the KR Property lawn to be eroded out into the sea. Especially large surge waves( such as those associated with the March, 2011 tsunami) will be able to overtop this low structure, but wave energy will be further dissipated, preventing any erosional effects, and probably preventing rock materials from being thrown onto the lawn.

General Coastal Zone Hazards

Hwang( 2005) recommends that all hazards facing coastal areas, and not just erosion, should be considered when planning for land-use and coastal construction in Hawaii. Fletcher et at ( 2002) portray generalized hazards assessments for long areas of Hawaii' s coastlines; they rate the specific hazards for the area of South Kona fronting the KR Property as follows ( Table 4). The Property is located in Lava Flow Hazard Zone 4 of Wright and others( 1992), but is in an area not impacted by lava flows in over 10, 000 years.

Hazard Type Relative Threat Scale ( 1- 4) Tsunami High 4 Stream Flooding Medium-high 3 High Waves Medium- low 2 Storms Medium-high 3 Erosion Medium- low 2 Sea Level Change Medium- high 3 Volcanic/ Seismic High 4 Overall Hazard Assessment High 6( on scale of 1- 7)

Table 4. Natural hazards impacting the coastline fronting the KR Property( from Fletcher et al., 2002, p. 173)

IJ 16 Conclusions

No significant erosion of the shoreline fronting the Kona Reef Condominiums has taken place in historical time, although global sea level rise and continuing subsidence of Hawaii Island could result in inland migration of the shoreline over the next century. Minor erosion of a lawn fronting the KR Property is caused by the infrequent storm surge or tsunami waves that reach or extend beyond the shoreline. That erosion can be mitigated by the construction of a low stone wall ( Erosion Abatement Structure) immediately mauka of the shoreline. Such a structure would have no negative environmental impacts or effects on adjoining coastal areas.

References Cited

Apple, R. A. and G. A. Macdonald, 1966, The rise of sea level in contemporary times at Honaunau, Kona, Hawaii: Pacific Science v. 20, pp. 125- 136.]

Campbell, J. F., 1986, Subsidence rates for southeastern Hawaiian Islands determined from submerged terraces: Geo- marine Letters, v. 6, pp. 139- 146.

DLNR, 2000, Coastal Erosion Management Plan ( COEMAP): State of Hawaii Department of Land and Natural Resources Unnumbered Report, Honolulu, Hawaii, 90 pp.

Dollar, S. J., 1982, Wave stress and coral community structure in Hawaii: Coral Reefs v. 1, no. 2 pp. 71- 81.

Fletcher, C. H., Boyd, R., Neal, W. J., and Tice, V.,2010, Living on the Shores of Hawaii— Natural Hazards, the Environment, and our Communities: University of Hawaii Press, 371 pp.

Fletcher, C. H. , Grossman, E. E, Richmond, B. M. and Gibbs, A. E., 2002, Atlas of Natural Hazards in the Hawaiian Coastal Zone: U. S. Geological Survey, Geologic Investigations Series Map I- 2761, scale 1: 50, 000.

Grigg, R. W., 1998, Holocene coral reef accretion in Hawaii- a function of wave exposure and sea level history: Coral Reefs, v. 17, n 3, pp. 263- 272.

Hwang, D. J., 2005, Hawaii Coastal Zone Mitigation Handbook: Hawaii Coastal Zone Management Program, DBED, State of Hawaii, 216 pp.

Kopp, R. E., Kemp, A.C., Bittermann, IC, Horton, B.P., Donnelly, J. P., Gehrels, W.R., Hay, C.C., Mitrovica, J. X., Morrow, E.D. and Rahmstorf, S, 2016. Temperature- driven global sea- level variability in the Common Era. Proceedings ofthe National Academy ofSciences, p.201517056.

Moore, J. G, 1970, Relationship between subsidence and volcanic load, Hawaii: Bulletin of Volcanology, V. 34, pp. 562- 576.

17 Moore, J. G and Fomari, D. J., 1984, Drowned reefs as indicators of the rate of subsidence of the Island of Hawaii: Journal of Geology, v. 92, p. 752- 759.

Moore, R. B. and Clague, D. A., 1991, Geologic Map of Hualalai Volcano, Hawaii: U. S. Geological Survey Misc. Investigations Map 1- 2213, 1: 50,000.

Wright„ T L., Chun, J. Y.F., Esposo, Joan, Heliker, C., Hodge, J, Lockwood, J. P., and Vogt, S. M., 1992, Map showing Lava- flow Hazard Zones, Island of Hawaii: U. S. Geological Survey, Misc. Field Studies Map MF-2193, 1: 250, 000.

18 APPENDIX F: FLORA AND FAUNA STUDY GRANT GERRISH, PH.D.

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0 Flora and Fauna Study Kona Reef Condos Erosion - Control Structure

TMK (3) 7- 5- 018: 71

i April 18, 2016

Prepared For:

Associatiton of Apartment Owners of Kona Reef, Inc. 75- 1029 Henry Street, #202 Kailua- Kona, Hawaii 96740

Prepared By:

Grant Gerrish, Ph. D P. O. Box 91 Paauilo, HI 96776 Flora and Fauna Study Kona Reef Condos Erosion - Control Structure

1. 0 INTRODUCTION

1. 1 Purpose of This Flora and Fauna Study

This flora and fauna survey supports an environmental assessment for a proposed erosion abatement project. This environmental assessment will be submitted to the County of Hawaii Planning Department, the accepting agency. The goal of this study is to describe the plants and animals that are presently on the project site or making use of it as habitat. Plants and animals and their habitats are recognized as" biological resources." Attention is also directed to areas surrounding the project site where biological resources might be affected by the proposed action. The status of plants and animals as " native" or" introduced," or as listed" endangered or threatened is noted.

1. 2 Brief Description of the Proposed Action

l The owners of the Kona Reef Condos( Kona Reef AOAO) propose the construction of an J erosion- control structure near the ocean- ward boundary of their oceanfront property in Kailua- Kona. This property, on Kahakai Road and Alii Drive, is designated by TMK ( 3) 7- 5- 018: 071. The proposed structure would be a mortar and rubble wall, approximately 220 feet long and 1. 5 feet wide, seated on bedrock. The top of the wall would be level with the existing grade. The entire structure and all construction activity would be within the subject parcel.

1. 3 Existing Conditions of the Project Site

The term, " project site," refers to the specific location that would contain the proposed structure and all of the nearby area that would be affected by direct construction impacts, such as excavation and trampling by workers and equipment.

The project site is part of an oceanfront property situated in urban Kailua- Kona, Hawaii County, coordinates N 19° 37' 45" W155° 59' 20" ( GPS coordinates). This neighborhood

U Kona Reef Condos Flora and Fauna Page 2 includes well- used streets and thoroughfares (Ali' i Drive and Kuakini Highway), multi- unit residential buildings, resorts, and a resort Hotel (the Royal Kona Resort). ( Figure 1.) The vegetation within the neighborhood is mostly managed landscapes of ornamental plants and lawns. The project site is entirely within a well- maintained grassy lawn between the seashore and the buildings and other constructed features of the Kona Reef Condos. The ocean- ward towards the ocean) boundary of the property and project site is very near the certified shoreline at the upper limits of the shore. The adjoining seashore is a moderately sloping, boulder and sand beach, that stretches down to a small bay, called Wayaha, south of Kailua Bay and part of the Pacific Ocean ( USGS 1982).

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Figure 1. Google Earth image of location and surroundings. Project Area is between the ocean and the building labeled " Kona Reef Resort." Kona Reef Condos Flora and Fauna Page 3

The project site is within a strip of lawn about 15 to 30 feet wide between the 1 constructed features and the sea shore ( Figure 2.). The lawn is used recreationally by residents of the Kona Reef Condos as well as members of the public walking along the shore. A narrow strip of more natural beach vegetation grows at the upper limit of the seashore, outside the project site. The ocean and marine environments lie beyond the beach.

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Figure 2. Site Photo. Project site is the grassy strip running from upper- left to center bottom between the blue and white structure and the black lava beach. Google Earth image.

C. Kona Reef Condos Flora and Fauna Page 4

2. 0 STUDY METHODS

The biologist, Dr. Grant Gerrish, Ph. D. spent approximately 2 hours at the project site and in the near vicinity on March 5, 2016. Plants and animals on the site and in the near vicinity were observed and recorded at that time and several photos were taken.

Dr. Gerrish was shown the site by the applicant' s representative, Mr. Ray Pieri. Mr. Pieri indicated the property boundary, showing Dr. Gerrish recent survey marks that he stated showed certified shoreline and the property boundary. Mr. Pieri further stated that the proposed erosion- control structure would be located within the applicant' s property, approximately one foot above the certified shoreline.

Other sources of information include the County of Hawaii website and Google Earth and Google Maps images. The websites of US Fish and Wildlife Service (www.fws.gov) and National Marine Fisheries Service ( www.nmfs. gov) were consulted for information concerning marine reptiles and marine mammals known to live in the waters near the project site and the protection status( eg. " threatened" or " endangered") of these animals. The scientific names of plants are in accordance with the Smithsonian Institute Department of Botany Checklist of Hawaiian Plants( Smithsonian 2012). Common names are, for the most part, taken from Wagner, Herbst and Sohmer( 1990). Bird names are in accordance with Hawaii Audubon Society ( 2005).

3. 0 RESULTS

3. 1 Plants Within the Project Site

The vegetation within the project site is entirely a lawn maintained at a very low height Figure 3). The dominant grass species is a cultivated form of Bermuda grass( Cynodon doctylon). Four other introduced grass species were identified within the lawn as well as three species of sedges. Two of the sedges, Fimbrystilis dichotoma and Cyperus polystachyos, are common indigenous species while the third sedge is an introduced species. A couple of ornamental bougainvillea shrubs are planted at the upper edge of the project site. ( Table 1.) Kona Condos Flora and Fauna Reef Page 5

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Figure 3. The Project site view looking north. Kona Reef Condos on right. Coconut trees and naupoka are outside the project area. Photograph by Grant Gerrish.

3. 2 Animals Observed On and Near the Project Site

A number of common introduced bird species were seen within the project site and on adjoining areas with similar landscaped vegetation. Those species seen and recorded during the site visit were House Sparrow( Passer domesticus), Saffron Finch (Sicalis flaveola), Common Waxbill ( Estrilda astrild), and Zebra Dove ( Geopilia striata). These are common bird species in urban environments on the Island of Hawaii. Undoubtedly, several more species of similar introduced urban birds would be observed with a longer observation period. It is possible that the indigenous Kolea (Pacific Golden Plover: Pluviales fulva) would forage within this lawn.

No non- human mammals were seen on the project site during the survey. Undoubtedly, mongoose, mice, rats and domestic dogs and cats are occasionally on or near the site. This urban site possesses no habitat resources that would make it attractive or particularly useful to native Hawaiian vertebrate species, other than possibly the Kolea, mentioned above. Kona Reef Condos Flora and Fauna Page 6

Table 1. Plant Species Within the Project Site.

Scientific Name Common Name Origin

Axonopus compressus( Sw.) P. Beauv. Introduced tropical carpet grass

Bougainvillea Comm. ex Juss. sp. Introduced Bougainvillea

Cynodon dactylon( L.) Pers. Manienie, Manienie haole, bermuda grass Introduced

Cyperus brevifolius( Rottb.) Hassk.

kili' o' opu Introduced

Cyperus polystachyos Rottb.

no common name Indigenous

Elusine indica ( L.) Gaertn.

goose grass Introduced

Fimbrystilis dichotoma( L.) Vahl

no common name Indigenous

Poo L. sp.

blue grass Introduced

Stenotaphrum secundatum( Walter) Kuntze St. Augustine grass, buffalo grass Introduced

3. 3 Plants and Terrestrial Animals on the Beach Outside the Project Site

The width of the beach, defined as the average distance from the certified shoreline to the edge of the ocean water, is about 8. 5 m (30 feet). The change in vegetation between the lawn within the project site and the beach vegetation outside the project site is abrupt (Figure 4). The grasses in the lawn completely cover the soil surface but the sandy and rocky substrate is below exposed the shoreline. A narrow band of beach plants grows along part of the Kona Reef Condos Flora and Fauna Page

certified shoreline below the project site. These are primarily two indigenous species, naupaka Scaevola taccada) and beach morning glory( Ipomoea pes-caprae). Four coconut trees (Cocos nucifera) also grow just below the shoreline. From their location and spacing, it appears that these four trees were planted. ( Table 2.)

One bird species, the indigenous Akekeke ( Ruddy Turnstone: Arenaria interpres), was observed on the beach near, but outside, the project site. It is likely that other indigenous shore birds, such as the ' Ulili( Wandering Tattler: Heteroscelus incanus), may occasionally use this beach.

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Figure 4. Photo of the beach and interface with project site lawn, view looking south. Project site is entirely within grassy area. The certified shoreline is at the top of the rocky beach. Coconut trees and shrubs are outside the project site. Building at left is Kona Reef Condos. Wai'aha County Beach Park in background( near center of photo). Photograph by Grant Gerrish.

U Kona Condos Flora and Fauna Reef Page 8

It is possible, but highly unlikely, that marine animals such as sea turtles or seals, could bask on the beach. It is considered highly unlikely because of the high level of human activity nearby. These animals are further described and evaluated in Sections 3.4 and 4.3 as marine animals.

Table 2. Plant Species on Beach Outside Project Site

Scientific Name Common Name Origin

Boerhavia coccinea Mill.

no common name Introduced

Cocos nucifera L.

niu, coconut Polynesian

Heliotropium foertherianum Diane& Hilger

tree heliotrope Introduced

Ipomoea pes-caprae( L.) R. Br. subs. brasiliensis( L.) Ooststr. beach morning glory, pohuehue Indigenous

Leucaena leucocephala (Lam.) de Wit subs. leucocephala koa haole Introduced

Scaevola taccoda( Gaertn.) Roxb.

naupaka kahakai Indigenous

3.4 The Marine Environment and Marine Animals

The project site for the proposed action is separated from the waters of Wai'aha and the Pacific Ocean by the beach described in the section above. The near-shore waters are not part of the project site and were not surveyed for this proposed action. Significant biological resources in the off-shore waters are listed in this section so that potential adverse impact outside the project site can be evaluated. Literature indicates a large number of invertebrate and vertebrate animals occur in the ocean waters along the Kona Coast( Juvik and Juvik 1998). Species protected the State and Federal by endangered species regulations that maybe found Kona Reef Condos Flora and Fauna Page 9

in these and other Hawaiian waters include the Pacific green sea turtle (Cheloniamydas: 1 threatened species),( hawksbill turtle (Eretmochelys imbricate: endangered species), Hawaiian monk seal ( Neomonachus schauinslandi: endangered species) and the humpback whale( Megaptera novaeanglioe: endangered species). ( www. fws.gov; www. nmfs.gov).

The critical habitat that was designated for the Hawaiian Monk Seal in September, 2015, includes certain sections of the beach and shoreline on Hawaii Island ( Federal Register 2015). The beach and ocean waters in front of the Kona Reef Condos is part of a segment defined as South of Oneo Bay through to Holualoa Bay area" between markers HA 91 and HA 92 and further defined as the shoreline between two points designated by the coordinates 19° 38' 10" N, 155° 59' 29" W and 19° 36' 31" N, 155° 58' 41" W. The critical habitat, quoting the Federal Register, "... include(s) marine habitat from the 200- m depth contour line, ...through the water' s edge 5 m into the terrestrial environment from the shoreline..." Thus, the critical habitat extends into the project site on the property owned by Kona Reef Condos AOAO.

4.0 DISCUSSION AND RECOMMENDATIONS

4. 1 Flora: Plant Resources on and Near the Project Site.

4. 11 Discussion of Plant Resources All of the plants within the project site are very common species that have no importance for the conservation of Hawaiian biodiversity. These plants are valuable for the stabilization of the soil and for the esthetic values provided to the people who use the area.

The plants outside the project area, at or below the certified shoreline, include indigenous species that are typical of the shoreline habitat. These shrubs and coconut trees may help reduce wave- erosion near the shoreline. Although these are all species that are common and widespread on Hawaii island, their presence here provides the esthetic value of an authentic native Hawaiian plant community in a neighborhood with few native plant species.

4. 12 Recommendations for Plant Resources

The plant-life on the project site should be maintained or replaced after construction to minimize soil erosion and to preserve the recreational and esthetic values of the area.

l t. Kona Condos Reef Flora and Fauna Page 10

Construction activities should avoid damaging the plants on the beach, outside the project area. Any inadvertent damage to the beach plants should be restored, if so directed by appropriate authorities.

4. 2 Fauna: Terrestrial Animal Resources on and Near the Project Site

4.21 Discussion of Terrestrial Animal Resources

Only introduced bird species were observed within the project survey. The project site does not contain any important resources, such as nest sites or special food sources that would attract bird or mammal species. Individual birds may easily avoid the proposed construction activities, thus avoiding injury.

Construction activities may temporarily frighten indigenous shore birds from this section of the beach. Loss of the use of this portion of the habitat for brief periods would not have an adverse impact of the wellbeing of these birds or their species.

4.22 Recommendations for Terrestrial Animal Resources

No discernible adverse impact on terrestrial animals is anticipated. No

recommendations are made.

4.3 Marine Environment and Marine Animals

4.31 Discussion of Marine Resources

The purpose of the proposed action is to prevent or reduce erosion at the shoreline that might adversely affect water quality in the marine environment. It is beyond the scope of this biological report to determine if the proposed erosion- control structure when completed will achieve this goal or to determine what, if any, post-construction impact it may have on the marine environment. Any such impacts cannot be evaluated in this section of this report.

Possible construction- related impact on the marine environment that can be anticipated would be pollution of the near-shore water by uncontrolled runoff of soil or construction materials. Kona Reef Condos Flora and Fauna Page 11

It is possible that marine mammals or reptiles could move onto the beach from the ocean while construction is taking place. These animals could include the endangered Hawaiian monk seal and the endangered and threatened turtles listed in section 3. 4. As proposed, the construction would not physically endanger these animals, however, the noise and activity of construction could frighten them back into the water. It would bean infraction of the Endangered Species Act to disturb any of these animals.

4. 32 Recommendations for Marine Resources

Best Management Practices and all other necessary actions should be taken to ensure that no soil, fill or any other material from the proposed action enter the water of the Pacific Ocean.

In the unlikely event that a sea turtle or a seal is observed on the project site or on the beach or anywhere else near the project site, all construction activities should be stopped until the animal voluntarily returns to the ocean. Marine mammals and turtles should not be disturbed or harassed in any way. It is recommended that the US Fish and Wildlife Service be notified if any such animals are seen near the project site.

REFERENCES

Federal Register. 2015. Endangered and Threatened Species: Final Rulemaking to Revise Critical Habitat for Hawaiian Monk Seals. Document Number 2015- 20617, 50 CFR 226. August 21, 2015.

Hawaii Audubon Society. 2005. Hawaii' s Birds. 6th ed. Island Heritage Publishing. Waipahu, Hawaii.

Smithsonian. 2012. Flora of the Hawaiian Islands. Hawaiian Vascular Plant Updates: A Supplement to the Manual of the Flowering Plants of Hawai' I and Hawai' i' s Ferns and Fern Allies—Version 1. 3, 12 April 2012. botany.si. edu/ pacificislandbiodiversity/ hawaiianflora/.

Juvik S. D. and J. O. Juvik, eds. 1998. Atlas of Hawaii. 3rd Edition. University of Hawaii Press. Honolulu, Hawaii.

USGS. 1982. Kailua Quadrangle. 7. 5 Minute Series (Topographic). U. S. Geological Survey, Denver, Colorado. Map. Kona Condos Reef Flora and Fauna Page 12

Wagner W. L., D. R. Herbst and S. H. Sohmer. 1990. Manual of the Flowering Plants of Hawai' i. University of Hawai' i Press/ Bishop Museum Press. Honolulu, Hawaii. www.fws. gov. US Fish and Wildlife Service Website. http:// www.fws.gov/ pacificislands/. www.Hawaiicounty. Hawaii County Website. http:// www.hawaiicounty.gov. www.nmfs.gov. National Marine Fisheries Service Website.

www. nmfs. noaa. gov/ pr/ http:// species/ and http:// www. nmfs. noaa. gov/ pr/ species/ criticalhabitat. htm. II Ur IP ILL

MIR. Rik RI IM

I STATE OF HAWAII wJ DERU21' NIF\ T OP I AND AND NATURAL RESOURCES

SI AlI.,III.STORIC PRESERVATION DIV95 ON I is KAKUII IHEWA BIM DING 601 KAMOKILA VINO. SIE 555 KAPOI GI, HAWAII 96701

November 19, 2020 IN REPLY REFER 10: Michael Yee, Planning Director Log No. 2020. 02499 Doc. No. 201 I SN IO County of Hawaii 101 Pauahi Street, Suite 3 Archaeology Hilo, III 96720

Russell Tsuji, Land Administrator DLNR- Land Division EI' n 2 2020 PO Box 621 Honolulu. H1 96809 c/ a Darlene Nakamura RECEIVED OOWITySHINGOf HAWAII Dear Mr. Yee and Mr. Tsuji: r(A, rT

SUBJECT: Chapter 6E42 Historic Preservation Review- Shoreline Setback Variance( SSV 20- 000012) SMA Use Permit Application( SMA 20- 000076) AOAO Kona Reef Inc. 1Vaiaha I Ahupua' a, North Kona District, Island of Hawaii TMK:( 3) 7- 5- 0i8: 071 ( por.)

This letter provides the State Historic Preservation Division' s( SIIPD'.$) review of the subject applications to allow construction of a 220- it- long concrete rubble masonry ( CRM) wall approximately 1 ft. inland of the certified shoreline seaward of the Kona Reef condominium complex located at 75- 5888 Aii' i Drive. Kailua- Kona, Hawaii. The SIIPD received this request for comments on October 20, 2020 which included a DLNR Land Division Memorandum, a County of Hawaii Planning Department Memorandum, a Final Environmental Assessment, a response letter from AOAO Reef, Inc., and application for the SSV and SMA permits. The project area is a 0.314- acre portion of the 3. 082- acre parcel.

Project Description The submittal provides information relating to the proposed construction of a 220- ft.- long CRM wall and the request by AOAO Kona Reef, Inc. to clarify previous correspondence between the applicant and the County of Hawaii regarding a request for a shoreline variance and SMA permit for the proposed project. The submittal also indicates that previous ground disturbance within the project area is unknown.

Findings In a letter dated January 5, 2012( Log No. 2011. 3364, Doc No. 1112MV27), S} IPD requested that an archaeological inventory survey( AIS) be conducted for a proposed grading permit. A review of our records did not indicate that an AMS has been conducted. SHPD' s also indicated that SHPD staff conducted a site visit of the project location and identified an archaeological deposit, along the shoreline, in the northern portion of the proposed project area- The cultural layer appeared to be eroding out of the face along the shoreline bank. Based on that discovery. SHPD requested an MS be conducted for the proposed project.

On December 5. 2017( Log No. 2017.02701), the applicant submitted a Draft Environmental Assessment( DEA) to SHPD for the construction of an erosion abatement structure in the shoreline setback. SHPD did not provide comments for the DEA. The current submission includes a Final EA which includes an MS titled, Draft Archaeological Inventory Surrey K. Kona Reef Condominium Erosion Abatement Structure Project, II' ai' aha I Ahupua' a, North Kona District, Aland ofHmvai' i ZdIK: ( 3) 7- 5- 018-Por. 071 ( Hann and Henry July 20] 6). The

Dept. Planning 138024 Exhibit 3l Mr_ Yee November 19, 21120 Page 2

AIS was conduclad on behalf of Kona Reef Condominium to comply with the previous SHPD requeet. 1 he AIS included in the PA was not submitted to SIIP[) for res iew and acceptance with the appropriate review fee, as specified in IIAR a l3- 284- 40)(3y

leterminution At this time. the SIIPD cannot provide meaningful comments for the proposed project until such time that the AN has been res icwcd and accepted and any potential mitigation measures are put in place for the proposed project SHPD requests that the AIS be submitted for review and acceptance in accordance with HAR ( l3- 284- 4( a)( 3), accompanied by the required fee ofS450. 00.

SHPD will notify the DLNR Laud Division and County of Hawaii Planning Department when the MS is accepted, our office has made a FIRS 6E project effect determination, and any required mitigation plans have been accepted, and the permit issuance may proceed.

Please contact Sean Ndleimaile at ( R08) 933- 7651 or at Sean. P. Naleimaile(a Hawaii.gov for any questions or concerns regarding this letter.

Aloha, At& itThWf!ei

Alan S. Downer. PhD Administrator. State Historic Preservation Division Deputy State I listoric Preservation Officer cc: Darlene Nakamura, darlene.k. nakamunairjhawaii. gov Gordon Heit, gor dons.heitROhavai i, gov Alex Roy. alex. roy@hawaiicounty, gov l, DAVIDoaxuaY q` . OFFICE OF PLANNING 1,a`417•11';. 41 CAT:*'` • 41ISTATE OF HAWAII n9

233 South Beretania Street, fith Floor, Honolula, Hawaii 96813 Teiepnone 908) 5S7- 284e Ma. Address: Box 2359, Honolulu, ling HO, Hawaii 96804 Fax 1808) 58) 2824 Wcn Cnn.' pann' n9. n o; aL9ov

DIS 202011040817L1

November 10, 2020

COM PLANNING DEPT Mr. Michael Yee, Director NOV 102020Ph4: 14 Department of Planning REC' D BY EMAIL County of Hawaii East Hawaii Office 101 Pauahi Street, Suite 3 Ililo, Hawaii 96720

Attention: Mr. Alex Roy

Dear Mr. Yee:

Subject: Shoreline Setback Variance Application( SSV 20- 009012) Special Management Area Use Permit ( SMA 20- 000076) Request to Allow Construction of a 220-Foot Long Concrete- Rubble-Masonry Wall Approximately I- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex, Kailua Kona, Hawaii; Tax Map Key: ( 3) 7- 5- 018: 071

Thank you for the opportunity to provide comments on the subject applications for Shoreline Setback Variance and Special Management Area ( SMA) Use Permit to construct a concrete- rubble- masonry ( CRM) wall within the shoreline area, transmitted via memorandum received October 15, 2020.

The Kona Reef Condominium Complex is a roughly 3. 1- acre shoreline parcel, and property' s 6 main buildings have a ground floor elevation of approximately 9. 5 feet above the sea level. According to the subject applications, AOAO Kona ReefInc. proposes to build a continuous 220- foot- long CRM wall within the 40-foot shoreline setback arca to protect the Kona Reef property and the shoreline lawn area fronting the complex from storm waves and surges. The lawn arca has been maintained by the AOAO Kona Reef, Inc. as a public amenity and asset for shoreline lateral public access per a' Settlement Agreement" between the Count) of Hawaii and AOAO Kona Reef, Inc.

All proposed construction would take place on Kona Reef's property approximately (- foot inland of the certified shoreline. The proposed wall will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches. and be 12 to 18 inches wide across

Nanning Dept. Exhibit 4- 137533 Mr. Michael vee November 10. 2020 Pace 2

the top. A large part of the wall will top out at a few inches lower than the lawn height, and at no point will the proposed structure exceed the height of the existing lawn. The time needed to build the proposed structure will be between one and two months.

The Final Environmental Assessment for the subject project was published in the Environmental Notice, March 8. 2018.

The Office of Planning ( OP) has reviewed the subject applications. and has the following comments to oder:

I. The SMA Use Permit Application, subject: Best Management Practices, dated September 15, 2020, states that" All construction and supporting activities will he performed entirely above the shoreline except for the placement of silt screens and/ or sand bags as needed for ocean and environmental protection." The applicant should provide the information about the proposed placement of silt screens and/ or sand bags for the proposed construction for a complete assessment.

2. The OP disagrees with the statement that the Kona Reef condominium complex property is a shoreline dependent facility as claimed by the AOAO Kona Reef Inc. The criterion of a shoreline dependent facility is not applicable to the proposed project for a shoreline setback variance.

3. In the interest of the public for a shoreline setback variance, AOAO Kona Reef Inc. shall continue maintaining the public shoreline access per the' Settlement Agreement" between the County of Hawaii and AOAO Kona Reef, Inc., which includes a delineated pedestrian easement along the north property line at least 10 feet wide. and provisions for a lateral easement across the seaward portions of the subject

area.

4. The OP concurs that no refueling or maintenance on equipment should be performed in the shoreline area. Staging area for the proposed construction shall be situated outside the 40- foot shoreline setback area to avoid potential impacts on the ocean.

5. The applicant shall prepare and implement site- specific best management practices with erosion and sediment control measures to confine the proposed construction activities. and prevent potential soil and polluted runoff from adversely impacting the coastal ecosystem, and State waters as specified in Hawaii Administrative Rules Chapter 11- 54. Mr. Michael Yee November 10. 2020 Pave 3

6. Should any archaeological or cultural resources, or burials be discovered during excavation, all construction shall be ceased immediately. Subsequent work shall proceed only upon an archaeological clearance from the State Department of Land and Natural Resources. State Historic Preservation Division.

7. Any exterior lighting and lamp posts associated with the proposed project shall he cut-off luminaries to provide the necessary shielding to mitigate potential light pollution in the coastal areas, and lessen possible seabird strikes. No artificial light. except as provided in HRS §§ 205A- 30. 5( 6) and 205A- 71( h), shall be directed to travel across property boundaries toward the shoreline and ocean.

If you have any questions regarding this comment letter, please contact Shichao Li of our Coastal Zone Management Program at( 808) 587- 2841.

Sincerely,

rno PR u- bans

Mary Alice Evans Director L wsotx ca iYi GOVERNOR V.ISE COJc ON h YRESOURCE j; 116i1MANAGEME T d \« d`" y 51P. 41..?. ; f C.,- 8f / 1 STATE OF HAWAII V,NN,} DEPARTMENT OF LAND AND NATURAL RESOURCES LAND DIVISION

POST OFFICEBOX 621 HONOLULU, HAWAII 96809

October 20, 2020

MEMORANDUM

TO: DLNR Agencies: X Div. of Aquatic Resources( kendall. l. tuckerrahawaii. eov) X Div. of Boating& Ocean Recreation( rlchard.t. howard(ahawaiigov) X Engineering Division( OLNR. ENGR(ahawaii.aov) X Div. of Forestry& Wildlife( rubvrosatterraciorehawali. qoy) Div. of State Parks X Commission on Water Resource Management( DLNR. CWRMc hawaii,gov) X Office of Conservation& Coastal Lands( sharteen. k.kuba(@hawaii. dov) XLand Division— Hawaii District( gordon. c.heit(r9hawaii.gov) X Historic Preservation( DLNR. Intake. SHPD(ahawaii. gov)

FROM: Russell Y. Tsuji, Land AdministratorRu55e/1 Tsuji SUBJECT: Shoreline Setback Variance Application( SSV 20- 000012) and Special Management Area Use Permit( SMA 20- 000076) Request to Allow Construction of a 220- Foot Long Concrete-Rubble-Masonry CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex LOCATION: 75- 5888 Ali') Drive, Kailua- Kona, Island of Hawaii; TMK:( 3) 7- 5- 018: 071 APPLICANT: County of Hawaii on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information on the above-referenced subject matter which can be found at:

httpsY/hawaiioimt- my.sharepoint.com/ personalidarlene k nakamura hawaii qov/ layouts/ 15/ onedrive. aspx? id=% 2Fpersonal% 2Fdarle ne% 5Fk% 5Fnakam ura% 5Fhawaii%5Fgov% 2 FDocuments% 2FAOA0% 20 Kona% 2UReef%20Inc

Please submit comments by November 9, 2020. If no response is received by the above date, we will assume your agency has no comments. Should you have any questions about this request, please contact Darlene Nakamura at darlene.k. nakamura(ahawaii. aov. Thank you.

We have no objections.

CoCommentshave noarecomments.attached.

Signed:

Print Name: IJc )bf ( k rrir,k- Division: y1ht, ? L — O c 1 _

Date: c{ / 2C,1

Attachments cc: Central Files Planning Dept. Exhibit u mnnscw DA 2,117: moo `:,. ra

rzr DEA/ M. art'"^' it I I r; ` d" 4, m. K. a v 3 Mt) - ; STATE OF HAWAII

Sta?" ena DEPARTMENT OF LAM) AND NATURAL RESOURCES Ksw moo maw owv, ia

OFFICE OF CONSERVATION AND COASTAL LANDS L P+•+ POST OFFICE BOX 621 HONOLULU. HAWAII 96809

REF: OCCL: TF COR: HA 21- 46

Russel Y. Tsuji Land Administrator Land Division- DLNR NOV - a 2020 Post Office Box 621 Honolulu, HI 96809

Michael Yee Planning Director County of Hawaii Planning Department West Hawaii Office 74- 5044 Ane Kehokalale Hwy Kailua- Kona, HI 96740

SUBJECT: Review and Comments for Shoreline Setback Variance Application ( SSV 20- 000012) and Special Management Area Use Permit ( SMA 20- 000076) Request to Allow Construction of a 220-Foot Long Concrete-Rubble- Masonry ( CRM) Wall Appmximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex. Located at 75- 5888 Ali' i Drive, Kailua-Kona, HI 96740 Waiaha, North Kona, Island of Hawaii TKIfC:( 3) 7- 5- 018: 071

Dear Mr. Tsuji and Mr. Yee:

The Office of Conservation and Coastal Lands ( OCCL) thanks you for your letters and requests regarding the subject matter. The proposed project involves constructing a 220- foot long concrete- rubble masonry( CRM) wall/erosion abatement structure within the 40- foot shoreline setback area of the parcel with the TMK: (3) 7- 5- 018: 071. The proposed CRM wall/ erosion abatement structure would be built approximately 1- foot inland/mauka of the Hawaii Stale Certified Shoreline ( File No. HA-538, March 2017) and in a manner that would either match the existing grade of the lawn or built to site dictated conditions and backfilled according. The CRM wall/erosion abatement structure will start near the southwest corner of the property and continue in a northwesterly direction roughly parallel to the certified shoreline for approximately 220-feet. REF: OCCL: TF COR FIA 21- 46 Russel Y. Tsuji & Michael Yee SSV& SMA - AOAO Kona Reef, Inc. Erosion Abatement Structure

The snvcmral dimensions of the proposed CRM walVerosion abatement structure will be between 12 to 36 inches wide at its base, vary in height from approximately 12 to 60 inches, and he 12 to 18 inches wide across the top. The ocean face of the proposed CRM walUerosion abatement structure will slope inward. The application notes that the structure' s final dimensions will depend entirely on the depth needed to achieve a solid foundation for anchoring. The applications state that the primary purpose for the proposed CRM walUerosion abatement structure is to protect that lawn area from further erosion caused by human induced erosion, high wave events, and tsunami surges.

Additionally, the AOAO Kona Reef, Inc. is seeking to include under the Shoreline Setback Variance Application ( SSV 20-000012) and Special Management Area Use Permit ( SMA 20-000076) Request that the new encroachments revealed by the recent certified shoreline ( File No. HA- 538, March 2017) be retained, permitted, and recorded with these authorizations.

The OCCL regulates land uses in the State Land Use Conservation District through the issuance of Conservation District Use Permits and Site Plan Approvals to help conserve, protect, and preserve important natural and cultural resources. The OCCL is concerned with the precedent this project may set along the coastlines of Hawaii Island as well as throughout the State of Hawaii.

Our review and interpretation of the application is that this is a shoreline hardening structure. It also appears that the design of the project and its justifications have changed since the project' s inception. The applications state that the wall will be built in a manner to match existing grade and will backfilled in certain areas to help match the existing grade. It is unclear if the proposed project area will be excavated so that the proposed CRM wall/erosion abatement structure will be buried to match the existing grade or if the proposed wall will be built and the immediate surrounding areas will be backfilled to raise the existing grade and in effect create an artificial berm or dune. Additionally, previous representations made in the project' s Environmental Assessment described that approximately half of the proposed CRM walI/erosion abatement structure' s ocean face will be exposed suggesting that the wall will likely not match the current existing grade. The OCCL also has concerns that overwash by high wave run- up may cause further erosion behind or mauka of the structure in areas where the CRM wall/erosion abatement structure will be buried. Further clarification regarding the design of the proposed structure and its impacts is needed.

Shoreline hardening structures have been shown to affect coastal processes and diminish beach accretion potential. While it is unclear to us how or if this structure would impact beaches or induce flanking effects ( because this was not considered in depth in the application), we discourage shoreline hardening, especially in areas where it would modify the natural shoreline landfonns of this part of the Kona Coast. Hawaii Revised Statutes ( HRS) Chapter 205A has been changed to further restrict shoreline hardening along sandy shorelines.

The OCCL has reason to believe that the sand deposits fronting the proposed project area are the result of lateral transport of sand from seasonal wave activity. During the Spring and Summer months, sand is transported to these deposits from the County of Hawaii' s Waiaha Beach Park( Honl' s Beach— a sandy beach) with south swells ( generally April through October). In Fall and Winter, some of the sand material is then transported back to Honl' s Beach with the return of Northwest or West-Northwest swells( generally October through April). The OWL has concerns that the proposed CRM wall/erosion abatement structure could eventually cause flanking to the County of Hawaii Waiaha Beach Park and Honl' s Beach as well as negatively impact the lateral transport of sand and the sand deposits fronting the lawn area. Based on the archaeological excavations performed for the project, it also appears that there OCCL: REF: IT COR: HA 21- 46 Russel Y. Tsuji& Michael Yee SSV& SMA - AOAO Kona Reef, Inc. Erosion Abatement Structure

is sand in the backshore indicating the presence of a perched beach. Sandy beaches are a rare environment and resource on the Island of Hawaii where its coastal areas are mainly composed of rocky shorelines. The rare shoreline areas that contain sandy beaches am popular amenities enjoyed by residents and visitors alike. They should be afforded a high level of scrutiny and protection from shoreline hardening projects that may negatively impact them especially in the context of sea level rise. In addition, the Environmental Assessment, Shoreline Setback Variance Application ( SSV 20- 000012), and Special Management Area Use Permit ( SMA 20- 000076) state that the purpose of the proposed CRM wall/erosion abatement structure is to protect the lawn area and its recreational use. According to these documents, a primary cause of erosion to the lawn area and concern regarding its sedimentation of the nearshore environment is human foot traffic. The OCCL encouraged the applicant to conduct a thorough analysis of alternative options for managing shoreline erosion as part of the early consultation process for the Kona Reef Condominium Erosion Abatement Structure Draft Environmental Assessment see Correspondence HA 16-94). It would appear that a reasonable alternative that should have been analyzed to address erosion to the lawn area caused by foot traffic would have been a foot traffic study and management plan for the area. Directed or dedicated access points from and along the lawn could help stabilize the erosion caused by foot traffic. Alternatively, if sedimentation of the nearshore environment is a primary concern, then another analysis could have focused on the phased removal of lateral sections of the lawn area that have been affected by foot traffic or natural forces over the coming years or decades. Additionally, if soil is leaching into the nearshore area, the applicants could consider removing the fill that is causing the contamination and replace it with suitable/compatible sand and dune plants. This would still allow for reasonable use of the lawn area presently and into the near future. The OCCL encourages the applicant to review HRS Chapter 205A and the recently enacted Senate Bill 2060 Act 16) with regards to the protection of beaches and the proposed project.

Finally, with regards to the new encroachments on State lands revealed by the recent certified shoreline File No. HA-538, March 2017), no authorizations have been granted regarding these improvements and according to the OCCL' s files. Pursuant to FIRS § 115- 5 ( b), the DLNR may require the abutting landowner to remove these encroachments. The OCCL recommends that the landowner consult with our office regarding these encroachments and any proposed land uses makai of the shoreline.

Thank you for the opportunity to comment on these applications and the proposed project. Should you have any questions, please feel free to contact Trevor Fitzpatrick of the Office of Conservation and Coastal Lands at 808- 798- 6660 or trevor.i. fitzpatrick(n;,hawaii. gov .

Sincerely,

LC!/HLS/ f$/O

Samuel J. Lemmo, Administrator Office of Conservation and Coastal Lands

CC: Chairperson Hawaii Division Land Office Hawaii, County of Department of Planning and Permitting DAVID Y. POE 7. 4

ON In II IR . 111

STATE OF HAWAII nkr I' IF\ l OF I NO AND\ ATC it u. RF:wr!WEA t AND DIVISION

rOFI OFHeE Dox b2I EOM/ HIM HAWAII 40109

October 20, 2020 FROM: MEMORANDUM

9— DLNR Agencies: X Div. of Aquatic Resources( kendall. l. tucker(rDhawaii. gov) X Div. of Boating & Ocean Recreation( richard. t. howard( hawaii.gov) X Engineering Division( DLNR. ENGR(& hawaii.gov) X Div. of Forestry& Wildlife ( rubyrosa. t. terrago(alhawaii.gov) Div. of State Parks X Commission on Water Resource Management( DLNR. CWRMOhawaii.gov) X Office of Conservation & Coastal Lands( sharleen. k. kubac hawaii. gov) X Land Division— Hawaii District( gordon.c. heitehawaii.aov) X Historic Preservation ( DLNR.Intake.SHPDahawaii. gov) TO: Rete Russell Y. Tsuji, Land Administrator Russell Tsuji SUBJECT: Shoreline Setback Variance Application ( SSV 20- 000012) and Special Management Area Use Permit( SMA 20- 000076) Request to Allow Construction of a 220-Foot Long Concrete-Rubble- Masonry CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex LOCATION: 75- 5888 AIPI Drive, Kailua- Kona, Island of Hawaii: TMK ( 3) 7- 5018,071 APPLICANT. County of Hawaii on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information on the above- referenced subject matter which can be found at.

https:// hawaiioirnt- mv. sharepoint. com/ personal/ darlene k nakamura hawaii goy/ lavouts115/ onedrive. aspx?id=% 2Fpersona1% 2Fdarlene%5Fk%u5Fnakamura% 5Fhawaii% 5Fgov°/ 2FDocuments% 2FAOAOD/ 20 Kona% 20Reef%201 nc

Please submit comments by November 9, 2020. If no response is received by the above date, we will assume your agency has no comments. Should you have any questions about this request. please contact Darlene Nakamura at darlene. k. nakamura(vlhawaiigov_ Thank you.

We have no objections. We have no comments. V) Comments are attached.

Signed:

Print Name: Carty S. Chang, Chief Engineer

Division. Engineering Division

Date. Nov 4, 2020

Attachments cc: Central Files Planning Dept• Exhibit DEPARTMENT OF LAND AND NATURAL RESOURCES ENGINEERING DIVISION

LD/ Russell 1',- fsu j i Ref: Shoreline Setback Variance Application (SSV 20- 000012) and Special Management Area Use Permit( SMA 20- 000076) Request to Allow Construction of a 220- Foot Long Concrete-Rubble- Masonry ( CRM) Wall Approximately I- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex Location: 75- 5888 Ali' i Drive, Kailua- Kona, Island of Hawaii TMK(s): ( 3) 7- 5-018: 071 Applicant: County of Hawaii on behalf of AOAO Kona Reef, Inc.

COMMENTS

The rules and regulations of the National Flood Insurance Program ( NFIP), 'rifle 44 of the Code of Federal Regulations ( 44CFR), are in effect when development falls within a Special Flood Hazard Area( high risk areas). State projects are required to comply with 44CFR regulations as stipulated in Section 60. 12. Be advised that 44CFR reflects the minimum standards as set forth by the NFIP. focal 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 to research the Flood I lazard Zone designation for the project. Flood Hazard Zones are designated on FEMA-s Flood Insurance Rate Maps ( FIRM), which can be viewed on our Flood Hazard Assessment Tool (FHAT)( http:// gis.hawaiinfip.org/FIIAT)_ I( 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- 7253. o Kauai: County of Kauai, Department of Public Works( 808) 241- 4896.

Signed: C RTYpS. CHANG, CHIEF ENGINEER

4, Dale: Nov 2020 0 r or*'.

flurry Kim nom.+ el DAN id Yamamoto, 1'. P:. tp _ 4iv unr

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Wu: a/ uns/ ion- , Allan C. Simeon. P. E. 4PuvOin.. or l',DHnf J of Pa{nail DEPARTMENT OF PUBLIC WORKS Aupuu Center CDH PLANNING DEPT 101 PaLuhsiren. Sura J non, Hawat i 967204224 8031961, 8321 Fa( 8081961- 8630 NOV 10 2020 PM2: 32 puhlic worksM hawaiianntvgov

MEMORANDUM REC' D HAND DELIVERED

Date: November 10, 2020

To: Michael Yee, Planning Director From: Department of Public Works, Engineering Division 'F- Subject: Shoreline Setback Variance Application ( SSV 20- 000012) Special Management Area Use Permit ( SMA 20-000076) Applicant: AOAO Kona Reef Condominium Complex Request: To Allow Construction of a 220- Foot Long Concrete- Rubble- Masonry( CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex Tax Map Key: 7- 5- 018: 071 We have reviewed the subject request forwarded by your memo dated October 12, 2020 and our comments are as follows: Work is being proposed in Flood zone AE as designated by the Flood Insurance Rate Map FIRM). Development within a Special Flood Hazard Area may be subject to the requirements of Chapter 27 - Flood Plain Management, of the Hawaii County Code. The proposed structure will not be subject to regulation under Chapter 27, if it does not rise above existing grade and is landward of mean high tide. All development-generated runoff shall be disposed of on site and not directed toward any adjacent properties. A drainage plan may be required by the Plan Approval process in accordance with Section 25-2-72(3) of the Hawaii County Code. andConstructionSedimentactivitiesControl. shall comply with the requirements of HCC, Chapter 10, Erosion

ourShouldHilothereEngineeringbe any questionsDivision officeconcerningat 961- 8943.this matter, please feel free to contact Kyle Honda of

KH Planning Dept. Copy: ENG- HILO/ KONA Exhibit 2)

County of HaaiswOpportunityan Equal Opportunity Provide' and Employe 37532 STATE OF HAWAII in Puri\ lb', f 01- LAND AND S“ II RAI. I( I Slll R( I. s t-\ Ni) 01%( SION

PIM 011ICI: BOX 62 HONOLULU. HAWAII ) SSIN

October 20, 2020

MEMORANDUM

TO: DLNR Agencies: X Div. of Aquatic Resources( kendall. 1. tuckerehawaii.gov) X Div. of Boating& Ocean Recreation( richard.t. howard@hawaiigov) X Engineering Division( DLNR ENGR(dhawaiigov) X Div. of Forestry& Wildlife( rubyrosa i. terrago@hawau. gov) Div. of State Parks XCommission on Water Resource Management( DLNR. CWRM@hawail qov) :; X Office of Conservation& Coastal Lands( sharleen.k. kuba(adlhawa& pay) _ : X Land Division- Hawaii District Riordan c heit(' hawaii. gov) p» ca _, V. X Historic Preservation( DLNR. Intake SHPD{rDhawaii( ov) T' rn p rdr Ni OP Russ'/ i 7-51. FROM. Russell Y. Tsuji, Lend Administrator 0 ii r N SUBJECT: Shoreline Setback Variance Application( SSV 20- 000012) andy, . cro Special Management Area Use Permit( SMA 20- 000076) 55:;bon, ICI Request to Allow Construction of a 220- Foot Long Concrete-Rubble es1pary i- : CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline SeaiNdrd of ti& Kona Reef Condominium Complex LOCATION 75- 5888 Ali I Drive, Kailua- Kona, Island of Hawaii; TMK. ( 3) 7- 5- 018: 071 APPLICANT County of Hawaii on behalf of AOAO Kona Reef, Inc.

Transmittedfor your review and comment is information on the above-referenced subject matter which can be found at

https.// hawaiioimt- my. sharepoint.com/ personalldarlene k nakamura hawaii govt layouls/ l5/onedrive.aspx? Id=% 2Fpersonal% 2Fdarlene% 5Fk% 5Fnakam ura% SFhawaii% SFgov% 2FDocuments% 2FA OAO% 20 Kona% 20Reef%201no

f X1 We have no objections. 4 We have no comments. Comments d.

Signed Q. it

Print Name: AMIE r - Division: x • Date: 10/ 2t21 ( lo 2& Attachments cc: Central Files aratac:- a \\, GE

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October 20, 2020

MEMORANDUM

TO. DLNR Agencies: X Div. of Aquatic Resources( kendall.l. tucker(o hawaii.gov) X Div. of Boating& Ocean Recreation( richard. t. howard(alhawali. gov) X Engineering Division ( DLNR. ENGR(ahawaii.goy) X Div. of Forestry& Wildlife( rubyrosa.l terrago(OhawaiLgov) Div. of State Parks X Commission on Water Resource Management( DLNR. CWRM( pghawaii. gov) X Office of Conservation& Coastal Lands( sharleen. k kuba(athawaii. aov) XLand Division— Hawaii District( pordon. c. heit(dlhawalkgov) X Historic Preservation ( DLNR. Intake.SHPD(mhawail ow)

FROM. Russell Y. Tsuji, Land Administrator Russell fsGp SUBJECT Shoreline Setback Variance Application ( SSV 20- 000012) and Special Management Area Use Permit( SMA 20- 000076) Request to Allow Construction of a 220- Foot Long Concrete- Rubble- Masonry CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Complex LOCATION. 75- 5888 Alit Drive, Kailua- Kona, Island of Hawaii TMK: ( 3) 7- 5- 018. 071 APPLICANT County of Hawaii on behalf of AOAO Kona Reef, Inc.

Transmitted for your review and comment is information or the above- referenced subject matter which can be found at https://hawaiioimt- my. sharepoinLcom/personal/darlene k nakamura hawaii qov/ lavouts115/ onedrive.aspx? id=% 2Fpersonal% 2 Fdarlene% 5Fk%SFnakamura% SFhawaii% 5 Fgov% 2FDocuments%2FAOAo%20 Kona% 2OReef% 201nc

Please submit comments by November 9, 2020, If no response is received by the above date, we will assume your agency has no comments. Should you have any questions about this request, please contact Darlene Nakamura at darlenek nakamurac hawaii. gov. Thank you.

We have no objections We have no comments. Comments areora eftach J Signed

Print Name oft VA l Cu # 487-3/

Division' 4. . 7jjji irivn Date: Q.r/2& 20 Attachments OC: Central Files Harry Kim s Paul K. Ferreira vmor Police Ohre/

Kenneth Rugado, dr. I)epuw Police Chief County of Hawai' i POLICE DEPARTMENT 349 Kapi olani Street • Hilo, Hawaii 96720-3998 808) 933- 3311 • Fax( 808) 961- 2389

October 14, 2020

TO MICHAEL YEE, PLANNING DIRECTOR

FROM : ROBERT WAGNIKASSISTANT CHIEF, AREA II OPERATIONS

SUBJECT : SHORELINE SETBACK VARIANCE APPLICATION ( SSV 20- 000012) SPECIAL MANAGEMENT AREA USE PERMIT ( SMA 20- 000076) REQUEST: TO ALLOW CONSTRUCTION OF A 220- FOOT LONG CONCRETE- RUBBLE- MASONARY ( CRM) WALL APPROXIMATELY 1- FOOT INLAND OF THE CERTIFIED SHORELINE SEAWARD OF THE KONA REEF CONDOMINIUM COMPLEX APPLICANT: AOAO KONA REEF, INC. TAX MAP KEY: 7- 5- 018: 071

The above- referenced Shoreline Setback Variance Application ( SSV 20- 000012), Special Management Area Use Permit ( SMA 20-000076) has been reviewed and we offer no comments at this time.

Should you have any questions or concerns, please contact Captain Gilbert Gaspar Jr., Commander of the Kona District, at 326-4646, extension 299.

GG/ jaj 20HQ0854

Hawaii County is an Equal Opportunity Provider and Employer- 126999 DA" r ! GE JADE I BUTAY G9V RNDa 4. t.;,;),'":::‘ Cu'

4 A rD O [ T"` 11 cn 4...a t.::-. . rJ 7 MI iSNN. r SNIF. E,

STATE OF HAWAII n PE. LI vE= eP* o DEPARTMENT OF TRANSPORTATION STP 20- 126 869 PUNCHBOWL STREET STP 8. 3061 HONOLULU. HAWAII 96813- 5097

October 21, 2020

Mr. Michael Yee Director Planning Department County of Hawaii 101 Pauahi Street, Suite 3 Hilo. Hawaii 96720

Dear Mr. Yee:

Subject: Shoreline Setback Variance ( SSV) Application( SSV 20- 000012) Special Management Area( SMA) Use Penn it ( SMA 20- 000076) Construction of a 220- Foot Long Concrete- Rubble- Masonry( CRM) Wall Kona Reef Condominium Complex Kailua- Kona, Hawaii Tax Map Key: ( 3) 7- 5- 018: 071

The State of Hawaii, Department of Transportation( HDOT) has reviewed the subject SSV and SMA Use Permit applications, and understands that the applicant AOAO Kona Reef, Inc. is proposing to construct a continuous 220- foot CRM wall within the 40-foot shoreline setback area of the Kona Reef Condominium Complex property. The purpose for the construction of the CRM wall is for erosion abatement and to protect the property from potential damages from hurricane waves and tsunami surges.

HOOT has determined that based on the project description and location, it appears that the project would have no significant adverse impacts to State highway facilities; therefore, HDOT has no comments,

If there are any questions, please contact Mr. Blayne Nikaido of the HDOT Statewide Transportation Planning Office at( 808) 831- 7979 or via email at blayne.h. nikaido@hawaii. gov.

Sincere) 1 4:it JADE T. BUTAY Director of Transportation

137171 oeve Harry KimIt`40vM... , 1'x. . William A. Kucharski Mayor w- Director

Roy Takemoto 4y^ Diane A. Nada Managing Director Deputy Director County of Hawai' i DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 345 Kekuanao' a Street, Suite 41 • Hilo, Hawaii 96720 Ph:( 808) 961- 8083 • Fax:( 808) 961- 8086 Email: cohdem@hawaiicounty. gov

MEMORANDUM

TO: Michael Yee, Director Planning Department

FROM: William A. Kucharski, Director Environmental Management Department

DATE: October 23, 2020

SUBJECT: Shoreline Setback Variance Application ( SSV 20- 000012) Special Management Area Use Permit ( SMA 20-000076) Request: To Allow Construction of a 220- Foot Long Concrete- Rubble- Masonry CRM) Wall Approximately 1- Foot Inland of the Certified Shoreline Seaward of the Kona Reef Condominium Project Applicant: AOAO Kona Reef, Inc. Tax Map Key: ( 3) 7- 5- 018: 071

The Solid Waste Division has reviewed the subject application and offers the following comments and/ or recommendations (contact the Solid Waste Division for details):

X ) No comments. Commercial operations, State and Federal agencies, religious entities and non- profit organization may not use transfer stations for disposal. Aggregates and any other construction/ demolition waste should be responsibly reused to its fullest extent. Ample and equal room should be provided for rubbish and recycling. Green waste may be transported to the green waste sites located at the West Hawaii Organics Facility and East Hawai' i Organics Facility, or other suitable diversion programs. Construction and demolition waste is prohibited at all County Transfer Stations. Submit Solid Waste Management Plan in accordance with attached guidelines.

County of Hawaii is an Equal Opportunity Provider and Employer 1 : 1 7 1 7 0 Mr. Michael Yee, Director October 23, 2020 Page 2

Existing Solid Waste Management Plan is to be followed. Provide update to the department on current status. Other

The Wastewater Division has reviewed the subject application and offers the following comments and/ or recommendations ( contact the Wastewater Division for details):

X ) No comments. Require connection of existing and/ or proposed structures to the public sewer in accordance with Section 21- 5 of the Hawaii County Code. Require Council Resolution to approve sewer extension in accordance with Section 21- 26. 1 of the Hawai' i County Code. Complete Sewer Extension Application. Require extension of the sewer system to service the proposed subdivision in accordance with Section 23- 85 of the Hawai' i County Code. Check or line out as applicable: f I If required by the Director of the Department of Environmental Management (" Director of DEM"), [ ] applicant shall conduct a sewer study in accordance with the then applicable wastewater system design standards prior to approval to connect to the County sewer system. Applicant shall provide such sewer line or other facility improvements as the Director of DEM may reasonably require, which the sewer study may indicate are advisable for mitigation of impacts of the proposed project. Contact Wastewater Division Chief for details. Other:

WK ref