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HomeMy WebLinkAbout2020-07-14_pc_agenda INDEX OF Correspondence File No. Assigned Deputy: Deputy Case No.: CC-2017-4 Case Name: Patricia D. McConnell vs. Planning Department Case Description: TMK: (4)5-8-005:5, Hā‘ena, Kaua‘i Appeal Decision of Planning Director related to Notice of Violation and Order to Pay Fines for the Operation of Illegal Transient Accommodation Use Page 1   DATE DESCRIPTION PARTY INDEX 7/6/17 Letter memorializing actions taken by Planning Commission Michael A. Dahilig A 7/24/17 Letter to Gregory Kugle regarding assignment as Hearings Officer Nadine Y. Ando B 10/4/17 Request for additional information from Hearings Officer Nadine Ando Gregory W. Kugle C 7/31/18 Referral Letter to Boards and Commissions Michael A. Dahilig D 11/1/18 Referral Letter from Boards and Commissions to Hearings Officer Nicholas Courson E 7/22/19 Ltr to Hearing Officer re continuance of contested case hrg Gregory Kugle F INDEX OF PLEADINGS File No. 2 Assigned Deputy: Deputy Case No.: CC-2017-4 Case Name: Patricia D. McConnell vs. Planning Department Case Description: Appeal Decision of Planning Director related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use TMK: (4) 5-8-005:5, Hā‘ena Kaua‘i Page 1 DATE DESCRIPTION PARTY INDEX 6/9/17 Petition for Appeal of Planning Director’s Decision Gregory Kugle 1 12/14/18 Schedueling Order; Certificate of Service Harlan Kimura 2 7/5/19 Amended Scheduling Order, Certificate of Service Harlan Kimura 3 7/9/19 Respondent Planning Dept. of the COK's Motion for Summary Judgment Maryann Sasaki 4 7/19/19 Second Amended Scheduling Order Harlan Kimura 5 8/14/19 Petitioner Patricia D. McConnell’s Memorandum in Opposition to Respondent Planning Department of the County of Kauai’s Motion for Summary Judgment; Declaration of Joanna C. Zeigler; Exhibit “1”; Certificate of Service Gregory Kugle 6 8/15/19 Agency Hearing Notice (McConnell; CC-2017-4) Harlan Kimura 7 8/20/19 Planning Dept Reply to Petitioner s Memorandum in Opposition Maryann Sasaki 8 8/23/19 Respondent's Prehearing Statement; Certificate of Service Maryann Sasaki 9 8/23/19 Respondent's Witness List; Certificate of Service Maryann Sasaki 10 8/23/19 Respondent’s Exhibit List; Certificate of Service Maryann Sasaki 11 8/23/19 Petitioner’s Pre hearing Statement; Certificate of Service Gregory Kugle 12 8/23/19 Petitioner’s Witness List; Certificate of Service Gregory Kugle 13 8/23/19 Petitioner’s Exhibit List; Certificate of Service Gregory Kugle 14 9/3/19 Minutes of Contested Case Hearing Harlan Kimura 15 10/9/19 Minute Order Regarding Pending Matters; Certificate of Service Harlan Kimura 16 11/4/19 Second Minute Order Regarding Pending Matters; Certificate of Service Harlan Kimura 17 11/18/19 Notice of Appearance of Counsel for Planning Dept.; COS John Mackey 18 INDEX OF PLEADINGS File No. 2 Assigned Deputy: Deputy Case No.: CC-2017-4 Case Name: Patricia D. McConnell vs. Planning Department Case Description: Appeal Decision of Planning Director related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use TMK: (4) 5-8-005:5, Hā‘ena Kaua‘i Page 2   DATE DESCRIPTION PARTY INDEX 12/30/19 Transcription of 08/30/19 Contested Case Hearing Anela Segreti 19 01/21/20 Petitioner’s Closing Arguments; Proposed Hearing Officer Report and Recommendation; Certificate of Service Gregory Kugle 20 01/22/20 Planning Department’s Supplemental Exhibit List; Exhibit G; Certificate of Service John Mackey 21 1/31/20 Planning Department’s Closing Argument_ Proposed Findings of Fact and Conclusions of Law_ Certificate Of Service John Mackey 22 2/7/20 Petitioner's Reply to Respondent Planning Department of the County of Kauai’s Closing Arguments & Proposed Findings of Fact & Conclusions of Law, Certificate of Service Gregory Kugle 23 4/1/20 Hearings Officer’s Report and Recommendation of a Contested Case Harlan Kimura 24 PLANNING COMMISSION CONTESTED CASE INFO SHEET Case Name: Patricia D. McConnell vs. Planning Department Case No.: CC-2017-4 TMK: (4)5-8-005:5, Hā‘ena, Kaua‘i Assigned Deputy: SELECT Choose an item. Planning Contact: INSERT Planning contact person Case Description: Appeal Decision of Planning Director related to the Notice of Violation and Order to Pay Fines for the Operation of Illegal Transient Accommodation Use Prehearing Conference INSERT Enter date @ 9am Contested Case Hearing INSERT Enter date @ 10am Prehearing (Position) Statement INSERT Enter date by 4:30pm Witness List INSERT Enter date by 4:30pm Exhibit List and Exhibits INSERT Enter date by 4:30pm Prehearing Motions INSERT Enter date by 4:30pm Responses to Prehearing Motions INSERT Enter date by 4:30pm Replies [Due 3 business days upon receipt of Responses] INSERT Enter date by 4:30pm Hearing on the Prehearing Motions (if applicable) to be held immediately prior to the Contested Case Hearing PARTIES Attorney for Applicants/Petitioners: Damon Key Leong Kupchak Hastert Gregory W. Kugle Joanna C. Ziegler 1300 Bishop Street, Suite 1600 Honolulu, Hawai‘i 96813-6452 Tel. No. (808) 531-8031 Fax. No. (808) 533-2242 Hearings Officer: Harlan Y. Kimura, Esq. Central Pacific Plaza 220 South King Street, Suite 1660 Honolulu, HI 96813 Tel. No. (808) 521-4134 (Office) Tel. No. (808) 564-0811 (Direct) Tel. No. (808) 226-2225 (Cell) Fax No. (808) 521-0361 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 HEARING OFFICER’S SCHEDULING ORDER; CERTIFICATE OF SERVICE HEARING (Scheduled): Date: August 6-7, 2019 Time: 9:00 a.m. on both days HEARING OFFICER’S SCHEDULING ORDER On December 12, 2018 at 1:30 p.m. the Prehearing Conference was held herein by telephone pursuant to Rule 1-6-7 of the Rules of Practice and Procedure of the Kaua‛i County Planning Commission (“Commission Rules”). Gregory W. Kugle and Joanna C. Zeigler appeared on behalf of Petitioner 2 PATRICIA D. McCONNELL (“Petitioner”) and Maryann S. Sasaki appeared on behalf of the PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”). No other parties appeared. Based upon the Prehearing Conference the following schedule shall apply: 1. Contested Case Hearing to be held on August 6-7, 2019, 2019, commencing at 9:00 a.m. on both days; 2. Prehearing Statement due no later than July 29, 2019 at 4:30 p.m.; 3. Witness List due no later than July 29, 2019 at 4:30 p.m.; 4. Exhibit List and Exhibits due no later than July 29, 2019 at 4:30 p.m. Petitioner shall use Numbers to identify her Exhibits and the Planning Department shall use Alphabets to identify its’ Exhibits; 5. Prehearing Motions as deemed necessary by any party shall be due no later than July 8, 2019 at 4:30 p.m.; 6. Responses to any Prehearing Motions due by July 22, 2019 at 4:30 p.m.; 7. Replies due by 4:30 p.m. no later than three (3) business days after service of the Response; and 3 8. Hearing on any Prehearing Motions to be held immediately prior to the commencement of the Contested Case Hearing, unless an Order ruling on the same is issued prior thereto. Any and all of the above-described pleadings shall be served by email or facsimile transmission, with a hard copy served by regular mail, postage prepaid, to all the parties and the Office of Boards and Commissions for the County of Kaua‛i. The times set forth above are based upon Hawaiian Standard Time (“HST”). A Further Prehearing Conference may be requested by either party to address any issues or concerns related to this Contested Case. DATED at Honolulu, Hawaii, December 14, 2018. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on December 14, 2018. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com Attorneys For Petitioner PATRICIA D. McCONNELL MARYANN SASAKI, ESQ. Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: msasaki@kauai.gov Attorney for Ka‛āina S. Hull, Director, County of Kaua‛i, Department of Planning MATTHEW M. BRACKEN, ESQ. County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: mbracken@kauai.gov ncourson@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X / / 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov lagoot@kauai.gov X DATED at Honolulu, Hawaii, December 14, 2018. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 HEARING OFFICER’S FIRST AMENDED SCHEDULING ORDER; CERTIFICATE OF SERVICE HEARING (Scheduled): Date: August 7, 2019 Time: 9:00 a.m. HEARING OFFICER’S FIRST AMENDED SCHEDULING ORDER On July 5, 2019 at 1:30 p.m. a Prehearing Conference was held herein by telephone pursuant to Rule 1-6-7 of the Rules of Practice and Procedure of the Kaua‛i County Planning Commission (“Commission Rules”) at the request of Maryann S. Sasaki, Counsel for the PLANNING DEPARTMENT OF THE 2 COUNTY OF KAUA‛I (“Planning Department”), because she has a scheduling conflict with the present Contested Case Hearing Date of August 6, 2019. Counsel for Petitioner PATRICIA D. McCONNELL (“Petitioner”), Gregory W. Kugle, also has a scheduling conflict with that date. Ms. Sasaki and Joanna C. Zeigler participated in the Prehearing Conference. No other parties appeared. Based upon the Prehearing Conference the Hearing Officer’s Scheduling Order dated December 14, 2018 is hereby amended as follows: 1. Contested Case Hearing to be held on August 7, 2019, commencing at 9:00 a.m.; 2. Prehearing Statement due no later than July 30, 2019 at 4:30 p.m.; 3. Witness List due no later than July 30, 2019 at 4:30 p.m.; 4. Exhibit List and Exhibits due no later than July 30, 2019 at 4:30 p.m. Petitioner shall use Numbers to identify her Exhibits and the Planning Department shall use Alphabets to identify its’ Exhibits; 5. Prehearing Motions as deemed necessary by any party shall be due no later than July 9, 2019 at 4:30 p.m.; 6. Responses to any Prehearing Motions due by July 23, 2019 at 4:30 p.m.; 3 7. Replies due by 4:30 p.m. no later than three (3) business days after service of the Response; and 8. Hearing on any Prehearing Motions to be held immediately prior to the commencement of the Contested Case Hearing, unless an Order ruling on the same is issued prior thereto. Any and all of the above-described pleadings shall be served by email or facsimile transmission, with a hard copy served by regular mail, postage prepaid, to all the parties and the Office of Boards and Commissions for the County of Kaua‛i. The times set forth above are based upon Hawaiian Standard Time (“HST”). A Further Prehearing Conference may be requested by either party to address any issues or concerns related to this Contested Case. DATED at Honolulu, Hawaii, July 5, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on July 5, 2019. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com JCZ@hawaiilawyer.com Attorneys For Petitioner PATRICIA D. McCONNELL MARYANN SASAKI, ESQ. Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: msasaki@kauai.gov Attorney for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov DNakamatsu@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X DATED at Honolulu, Hawaii, July 5, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i MATTHEW M. BRACKEN 10267 County Attorney MARYANN SASAKI 10458 Deputy County Attorney Office of the County Attorney, County of Kaua'i 4444 Ptice Street, Suite 220 Lrhu'e, Hawai'i 96766 Telephone: (808) 241-4930 Email: rnsasaki@kauai.eov Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL. Petitioner, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, cc-20t7-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI'S MOTION FOR SUMMARY JUDGMENT; MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT; DECLARATION OF MIKE LAURETA; EXHIBITS A-E; DECLARATION OF BRITNI LUDINGTON-BRAUN; EXHIBIT I ; DECLARATION OF COUNSEL; CERTIFICATE OF SERVICE HEARING: Date: August 7,2079 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura, Esq ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Respondent. vs. RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI'S MOTION FOR SUMMARY JUDGMENT Respondent, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I (the "Planning Department"), by and through its undersigned attorneys, hereby submits this Motion for Summary Judgment on the Petition to Appeal Decision of the Planning Director Relating to the Petitioner's failure to comply with Kauai County Code $ 8- l 8. I (b) on the grounds that there are no genuine issues as to any material fact or matter of law in the above-entitled case. This motion is made pursuant to the Rules of Practice and Procedure of the Kaua'i Planning Commission Rule l-6-16 and is supported by the attached Memorandum in Support of Motion for Summary Judgment; Declaration of Mike Laureta, Declaration of Britni Ludington- Braun, Declaration of Counsel, Exhibits, the record and files herein, and such other matters as may be presented at the hearing and considered by the Hearing Officer. DATED: Llhu'e, Kaua'i, Hawai'i, July 9, 2019 MATTHEW M. BRACKEN County Attorney B MARYANN SASAKI Deputy County Attorney Attomeys for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitior-rer, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent. BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I cc-2017-4 TMK: (4) 5-8-005:005 MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT VS. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) MEMORANDUM IN SUPPORT OF M OTION FOR SUMMARY JUDGMENT I. STATEMENT OF FACTS Much as Ordinance 864 was implemented because the County found a compelling need to regulate family transient vacation rentals on Kaua'i to visitor designated areas ("VDA"), because their unregulated growth was causing significant negative impact to certain residential neighborhoods [Ordinance 864, enacted March 7,2008], Ordinance No. 1002 was passed to address the same issues regarding homestays and prohibiting any homestays from operating outside of VDAs. In bringing the instant appeal, Patricia D. McConnell ("Petitioner") owner of the subject property located 4813 Ananalu Road, Hanalei, Hawai'i TMK No. (5) 8-005:005 (the "Subject Property") seeks to flout the explicit provisions regarding homestays in the Kaua'i County Code ("KCC" or the "Code") by operating a homestay transient vacation accommodation outside a VDA absent any permits and in direct violation of the Comprehensive Zoning Ordinances Chapter 8, KCC, 1987 as Amended (CZO.) There are no mitigating circumstances here. As set forth in the Air BnB Evidence Checklist - TVR Inspections and the Investigation Report ofRespondent dated January 28,2076 and January 10,2017, respectively, prepared by the Planning Department, the Petitioner has never possessed a homestay zoningpermit, a nonconforming use certificate and operates outside a visitor designation area in violation of KCC $ 8-18.1(b). On January 71,2017 , the Respondent via a Cease and Desist Letter from the Planning Department, notified the Petitioner that she ought to stop operating the Subject Property as a transient accommodation and cancel all transient accommodation commitments for the Subject Property. The Cease and Desist Letter also informed the Petitioner that she would be subject up to a $ 10,000 fine, and $ 10,000 for every day the violation should persist. On May 23,2017,via a Notice of Violation & Order to Pay Fines, the Planning Department informed Petitioner that she was in continued breach of the ZoningCompliance Notice, and fines could continue to accrue up to $ 10,000 per day. On or around Aprll 12,2017 , a memorandum was prepared contemporaneously with a meeting with Petitioner in which Petitioner stated that she did not see how she was violating the law. 2 On June 9,2017 another Investigation Report was prepared by Respondent indicating the Petitioner was continuing operations of her illegal homestay. III. STANDARD OF REVIEW The purpose of a motion for summary judgment is to expedite matters where there is no genuine issue of material fact. Flint v. Mackenzie,53 Haw. 673,672,501 P.2d 357,357 (1972). Here, the Planning Commission should expedite this case and resolve the Petitioner's challenge to the Zoning Compliance Notice and the Notice of Violation and Order to Pay Fees. The Petitioner's argument cannot present a genuine material issue of fact. She is operating her homestay outside of every parameter of the law. There is no factual dispute with respect thereto. IV. LEGAL ANALYSIS Where the terms of a statute are plain, unambiguous and explicit, a Court is not at liberty to look beyond that language for a different meaning. Instead, their sole duty is to give effect to the statute's plain and obvious meaning. State v. Stan's Contracting. Inc.. I 1 1 Hawai'i 17,24, 137 P.3d 331, 338 (2006). Here the Code could not have been clearer. "Homestay operations are prohibited outside of the Visitor Destination Area (Ord. 987, June 19,2015; Ord. No. 1002. May 18,2016). Incidents of continued violation of the law seem to extend from at least January 28,2016 to March 16,2017 . V. CONCLUSION Petitioner must be compelled to cease operations of this homestay, and perhaps more effective than a threatened injunction would be an appropriate fine. In this matter where the behavior has gone on for years and Petitioner persists on flouting the law and admits she is doing so despite all efforts by the Planning Department, Planning Department, pursuant to KCC $ 8- aJ 3.5(bXlXB)-(C), seeks ONE HUNDRED FIFTY THOUSAND DOLLARS ($150,000.00) in fines and an order that the Petitioner Cease and Desist the operation of the her homestay. DATED: Lrhu'e, Kaua'i, Hawai'i, July 9, 2019. MATTHEW M. BRACKEN County Attorney ilW,{nil//ti MARYANN SASAKI Deputy County Attorney Attorneys for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 4 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 DECLARATION OF MIKE LAURETA; EXHIBIT A - E ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. MoCONNELL, Petitioner, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent. DECLARATI ON OF MIKE LAURETA I, MIKE LAURETA, based upon personal knowledge, do declare under penalty of law, that I have personal knowledge that the following is true and correct: 1. I am employed by the County of Kaua'i, Planning Department as a Program Manager. 2. I am in charge of inspecting for and enforcing violations of the Comprehensive Zoning Ordinance. VS. 3. Pursuant to Hawai'i Rules of Evidence Rule 803(b), I am custodian of records of the Planning Department. 4. The annexed documents were made at or near the time by someone with knowledge thereof. 5. Making the record is a regular practice of that activity. 6. Annexed hereto as Exhibit A, is a true and correct copy of a Planning Department Air Bnb Evidence Checklist - TVR Inspections dated January 28,2016. 7 . Annexed hereto as Exhibit B, is a true and correct copy of a Planning Department Investigation Report dated January 1,2017 8. Annexed hereto as Exhibit C, is a true and correct copy of the Zoning Compliance Notice dated January 11, 2017. 9. Annexed hereto as Exhibit D is a true and correct copy of Notice of Violation & Order to Pay Fines dated May 23,2017 . 10. Annexed hereto as Exhibit E, is a true and correct copy of a Planning Department Investigation Report dated after March 12.2017. I I . The Subject Property is located outside of the visitor designation area, and does not possess a valid permit or non conforming use certificate. I declare under penalty of perjury under the laws of the State of Hawai'i that the foregoing is true and correct. DATED: Lihu'e, Hawai'i, July 9, 2019. 2 Program Manager AlRbnb Evidence Checklist - TVR lnspections Date:1ngtrcTMK: saoosoos lnvestigation Type: RequestI Complaint f] Homestay EJtirgl" fimily or I multi-familyorTVR Owner Name:pATRlClA D, MCCONNELL Operation Name:"THE SONG OF THE JUNGLE" TVR Property Address:4813 ANANALU RD Researched by:Bambi AlRbnb #: Site Manager's Name: Contact Phone: Contact Email Address Was the TVNC & SP #'s listed on AlRbnb? NCUC/ TVR permit# / Plannin g Dept TVNC if a ows17o7oa9-01Dept. Taxation GET rnr[4 # lnternet Advertisi list all found Personalweb e BREG- Business Registration {Other vrbo.coml481 1 78 & vrbo.com/'l 30810 Are the TVNC & SP # listed on web?Yes No ffi neal Property Assessment / Classification VACATION RENTAL fl nentat Cars- COK DMV (List License & Date)Verified? I Zoning (ie. VDA, Commercial, Residential) Open - North Shore Special Planning Area dev. plan Comments: Attachments/ Exhibit f Version 7 AlRbnh EXHIBIT A Requirements vesf rvolJ ves[_l r.ro[-l I ON REPORT S:T :580 5005 ON :o ,PATRICIA D WEB SITE: airbnb rt t-ac ()uts v DATE: 1l1ill17 1. Research of online "com found the su transient matchi the 262248 the noted with Realwithand lwas able to determirrerecords CONTACT: EXHIBIT B :. :: : :: ..j' I Rernard ['. Carvalho, .fr. Iv,[ayor Wallace G. Rezentes, Jr. Ivlanaging l)irector Michael Dirdctor of Ka'[ina S. Hull Dcputy Dircctor of Planning PLANNING DEPARTMENT I!nforcement Division Countl' of K:rua'i, State of Hawai'i {.1-14 Rice Strccr. Suire A-47i, Lil'ru'e. Hawai'i 96766 l'Er- ({,t08) 21r-4050 Ftu\ (S08) ?1t-6699 ZONING COI\,IPLIANCE NOTI CIi CI'ITTIFIEI)rJAit 1 1 l}fi Prtricia D. N{cConnell 104 llndlich Dr. Santa Cruz, CA 95060 SIIB.IECT: Zaning Yiolation for Transient Accommodation flse at: .{813 Ananalu Rd TMK: 5-8-005:005 l'he Plaming Department conducted an investigation of the subject property and found the establishrnent of a vacatiotr rental operation. This is considered a violation of the following provisions of the Comprehensive Zoning Ordinance, Chapter 8, Kaua'i County Code, i987, as Amended (CZO): OI{DINANCE and VIOLATIONS t. Section 8-8.1(b) Gcneral Provisions for Homestays Homestay'operations ure prcthibitecl ctutside of the k'isitor De stinution,4rea (1/D.4). 2. Section 8-17.8 Singlc Famill'Transient Vacation Rentals. ilolu'ithstantling em1' untlerly'ing zoning designation uncl w'itlt the exception oJ'properties on the Natianal or State Resister of ltistoric Places, single family transient yac{ttion renluls cre prohibited in all areos not designatecl as llisitor Destination Areas. Violation; Thc unauthorized use of the subject propertl, for Transient Accommodation outside of the designated visitor Designation Area constitutes a vioration. EXHIBIT C :.\ Pursuant to Chapter 8, Kaua'i Count-v Code, you are tlirected to complv rvith the follorving requircmen ts immediatell': I. Ce:rsc and desist the use of the subject property as a 'I'ransient Accommodation(s); 2. Cancel rll 'l'ransient Accomnrodations commitrnents for the propertv. Please lind attached Count-r,Ordinance No. 1002 ibr y'our ret'erence. lncluding but not linrited to Section 8-17.8 citerl above, Orclinance |io. 904 specifically regulates the use and prohibition of homestays on Kauai. (Chapter 8, Kaua'i County Code, 1987. as amended). Pursuant to Coung Ordinirnce *-o. 919 (also attached), any' violation(s) of the Comprehensive Zoning Ordinance (C.ZO) may result in a line of up 1r: $ 10,000.00 andior up to $ 10,000,00 per day, should the violation(s) persist. (L-haplcr 8, Kaua'i Countv Code, 1987, as anrcnded). Please contact the Planning Departmefit at 741-4051, or ernail Bambi Einayo of my staff at aemayo@kauai.gor', u,ithin 14 calendar days uporl receipt ol this letter to provide an acknorvledgenrent ol the termination of the subject TVR. Failure to do so provides us rvith no other altenrative but to pursue enlorcement action. KA' l)cputy l)irector of Plaming cc: County Attome,v Attachrnents Bcrnard P. Carvalho, Jr. \ [al or Wallace G. Rezentes, Jr I\lanaging f)irector CERTIFIED IVI;\IL Patricia D. llcConnell 10.{ Entllich Dr. Santa ('nrz, CA 95060 PI,ANNING DEPARTMENT Enforcement Division Coun$' of Kaua'i, State of Harvai'i 414.1 Ricc Street, Suite A-,17J, Lrhu'c, Harvai'i 96766 rBr- (80E) 24r-4050 FAX {808} 24t-6699 l\{ichucl A. Dircctor of Ka'Iiaa S. I{ull [)cputl Director of Plinning I'IAY 2 3 ZAfi NO'TICE OF YIOLATION & ORDER TO PAY FINES Patricia D. il{cConnell .1813 Annnalu Rd. Hanalei, HI96714 SUIiJECT: Zoning Violation for Transient Acconrmodation Use at: 4813 Ananalu Rd'tllK: 5-8-005:005 On March 31,2017, you rcceived the Depanment's Zoning Compliance Notice (ZCN). The ZCN instructed you to immediately Cease and Desist the use of the subject property lbr transienl accommodations. You were instnrcted to cancel all transient accommodation conrmitments for the property. On April 12.2017. the Department met with you (Patricia N{cComell). o\\,ner and administrator o['the transient flccommodation operation. The Planning Departrnent cont']rmed that the continued transieut accommodation operation (Homestay) use at the subject property is a violation of the Cornprehensive Zoning Ordinance, Chapter 8, Kaua'i County Code, 1987, as Amended (CZO): ORD INAIiCE :rnd VI OL;\'l I 0.r* 1. Scction 8-18.1(b) General Provisions for Homestays I'lomestul'tstrterations are prohibitecl oulsicle of tke L'isitor Destination Area (l/DA) An Equal Opportunit;,* Enplol'er EXHIBIT D PY Notice 201 7 I I I I I Violation: The Planning Department has confirmed that the subject property is currently bcing used for a llomcstay operation. The continued use of the subject property for a Homestay operation outside of the designated Visitor Designation Area constitutes a violation, Pursuant to: Sec.8-3.5 Enforccment, Legal Procetlures and Penalties (b) Civil Fines (l) If the Director of the Planning deternine that any person, firm or corltoratiort is not complying with a nolice of violation, the Direclor may have the party responsible for lhe violctliott served, by matl or dcliv,ery, vith an order purntant to this section. The order ma1, require the part.v respansihle ./br the violation to clo uny or all of the following: (A) Correct the violation v,ithin lhe time specified in the order; (B) Pay a civil fine not to exceed 810,A00 in the nunner, at tlze place, and before the clate specified in the order; (C) Pa)'a cinilfine up to 510,000 per drrr--fo, each day in whtch the violation persists, in the rnanner and ut the time and place specified in the order. (2) l'he order shall actvise the party respansible for the violatian th$t the order .shall become final 30 days after the clqte of its de[ivery. The order shcll alsa advise tlrut the Director's aclion may be appealed lo lhe Planning C'ommission. (3) The provisions o.f the order is.suecl by the Director under this sectian shall become final 30 culendar clays after lhe sertice <tf the order. The purties responsible for the violation nuy ultpeul the oreler lo the Planning Commtssion pursucurt to its nies. The Jbrnt af this appeal rnusl confornt to the PlanningComnissiort's rules, However, anappettl to the Plunning Commission shall not stay unlt provision of order. (4) T'he Direclor nray inslitute u civil aciion in any court oJ'cornpetent Jurisdiction for erlforcement oJ'any order issued pursuanl to this section. LVhere the ciyil action has been in.ttituted to enJbrce the civilfine imposed by said order, lhe Director need only shot, that the nolice of violatiott ancl order v'ere served: thol a civilfine y,as imposed; the amount of the civil fine imposed has not been paid; thttt either has not heen appealed or that il' appeoled, the order was sustained by the Commissian wtd/or any Court action. You are herein levied and ordered to pay a fine of te:r thousand dollars ($10,000.00) for the aboye notetl violations to thc Planning Department. You are hereby' ordered to cease and dcsist the illegal activities being conducted/performcd on and from the premiscs as requircd b.v- larv. You rrre hereby ordered to correcl the above use violations(s) rvithin 14 days of the date of this notice. Should the violations not be remcdied rvithin 14 days from the date cf the Notice of Yiolation .t Ortler to Pa.v Fines: r This mattcr will be fonvarded to the Office of the Prosecuting Attorney; r An additional fiae of S10,000 per violation, per d:ry, for cach day in ryhich sueh yiolation prrsists sh*ll be levied. A i.vtitten response to the Planning Department rvithin 14 days fiam the date cf this Notice of Violation & Order to Pay Fines to address this issue is mandatory. Payment of the $10,000 civil fine is also due rvithin 14 days from the date of this notice. Failure 1o address this issue rvill provide the Department rvith no other choice but to continue lelying li:res each day the violaticn persists. This detern:ination n"ray be appealed to the Planning Commission pursuant to Chapter 9 of the Rules of Praslice and Procedure of the Planning Commission (R.PPPC), The time for any appeal olan action of the Planning Director commences 21 days from the rlate of the adverse deeision (RPPPC Ruiel-9-Z). An appeal of any action of the Planning Director must contain the requiremenls oiRPPPC Chapter 9 to he considered by the Planning Commission. l'he Rules of Practice and procedure of thc Planning Commission (RPPPC) are available online lluough thc Planning Department's u,ehsite at: http://r+rru,.kauai,gov/Goraernrnent,{)epanrnents/PlanningDepartnlent/tabirV6l lDeftrult.aspx. Should you have any que:ticns, please leel free to contact Supervising lnspector Bambi Emayc (808-241-4051), emailat rcmayo@kauai.gav or call Enforcernent Program Manager h{ichael Laureta (808-24 I -407 I ). I(A'AINA S. HULL Deputy Director of Plaming Cc: Otfice of the Ivlayor Cor:nty Attorney LJ INVESTIGATI ST BUS T NAME:tr?HE SONG OF fHE JUNG],E" (X) Web Re ?1r*:TMK:58005005 I,AND AREA LoC: WailapaDi5": Hanalei ZONING: O OWNER: MCCONNETL, FA?R.ICIA D MNGR Co.SLUC DIST SITE ADDR:48 3LOC # }4&}IAGIHG COMPAIiIY;OWNER: NAME: PATRICIA D, MCCONNELL A}DIT:.BDDR: 104 ENDLICH DR sAlsrA cRUz, cA 95060 HaIe'lan"I,ani oLFHONE: of tshe Jungle"WEB SITE: v sit,orgent ac t on opera tion INSPECTOR: Bambi Notice Of Violation Repo* 5116|17 1. Zoninq Compliance Notice (ZCN) dated V1y17 was issued to Patricia D. McConnell forthe establishment of the Transient Accommodatian Operation on 4813-Ananalu Rd., TMK: 5-8-005:005, outside of the designated Visitor Desigll ation Area 2. Meetinq response at the Planning Dept. on 4/1417 a. Met with Patricia D. McConnell (owner) who crnc€ded to operating a Translgn! Accommodation at $275 a night. b. The Planning Dept. has offered a remedial aetion plan to rectrfy the violation EXHIBIT E rl U ri, { i I i I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitior-rer, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I cc-2017-4 TMK: (4) 5-8-005:005 DECLARATION OF BRITNI LUDINGTON. BRAIIN; EXHIBIT 1 VS ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) DECLARATION OF BR LUDINGTON-BRAUN I, BRITNI LUDINGTON-BRAUN, do declare under penalty of law declare that the fbllowing is true and comect l. I am an ADU/TVR Enforcement Specialist with the County of Kaua'i Planning Department. 2. On April 12,2017, the Planning Department met with owner Patricia D McConnell regarding the operation of her illegal home stay located at 48 13 Ananalu Rd Wailapa, Hawai'i 3. Despite being informed orally and in writing that the operation of a homestay outside a visitor designated are is illegal, Ms. McConnell could not see how she had a violation. 4. Although Ms. McConnell made the representation she would comply with the Planning Department, as of the date hereof, she has not 5. No remedial action plan was agreed upon; Ms. McConnell appeared reluctant to correct the noted violations 6. Annexed hereto as Exhibit l, is a memorandum drafted contemporaneously with the meeting, it accurately and fairly reflects the meeting I declare under penalty of perjury under the laws of the State of Hawai'i that the foregoing is true and correct. DATED: Lrhu'e, Kaua'i, Hawai'i, July 9, 2019. Britni CZM Permit T Declarant 2 Patricia D, NlcConncll TMK: 58005005 4813 .4nanalu ltd. !\/ailapa RE: l\{ecting to rectifl'violations on subject propertl D*u1ll22Al7 On April L2,2OL'7 the Planning Department met with the property owner (Patricia D, McConn ell) in response to the complia nce notice dated Jan ua ry 1l,2OL7 . The following attended; Bambi Emayo, Patricia McConnell, and Britni Ludington-Braun. The following are notes and observations of said meeting: r ln the meeting Patricia told us that she will be running her operations till March 2018. r Patricia doesn't see how she has a violation because according to her, the Sovernment keep changinS the laws. , On a couple accounts in the meeting Patricia threated, "if we stop her from operating she's going to take off her clothes, leave them on the beach, and swim out to the sharks and let them eat her." . Patricia also made a racist remark implying that the Planning Department are trying to get rid of the haole people. . Patricia nrade a conrment to Bambi Emayo that he is heartless for stopping her from oPerating. r Patricia said she is going to work with the Planning Department toward zoning cornpliance o lt is noted, no remedial action plan has been agreed upon. The violator (Patricia McCcnnell) is reluctant to correct the noted violations. These are my observations noted. BITITNI llIL,\.U.r- ADU/TVR En{orcement Specialist EXHIBIT 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in H6'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 DECLARATION OF COUNSEL ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. MoCONNELL, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I. Respondent DECLARATIO OF COUNSEL I, MARYANN SASAKI, do declare under penalty of law that the following is true and correct to the best of my knowledge and belief. 1. I am an attorney licensed to practice law in all courts of the State of Hawai'i and the United States District Court for the District of Hawai'i. I am a member VS in good standing of all of the aforementioned courts Petitioner, I declare under penalty of perjury under the laws of the State of Hawai'i that the foregoing is true and correct. DATED: Lrhu'e, Kaua'i, Hawai'i, July 9, 2019. Nfifffi,{n" MARYANN SASAKI Deputy County Attorney Declarant 2 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. MoCONNELL, Petitioner, PLANNING DEPARTMENT OF THE COLINTY OF KAUA'I, Respondent. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date set forth below, a copy of the above cited document, was duly served by email and depositing the same in the U.S. mail, postage prepaid, upon the following: VS. GREGORY W. KUGLE, ESQ, JOANNA C, ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, Hawai'i 96813-6452 Email: ewk@,ha waiilawver.corn jcz@hawaiilawycr.com Attomeys for Petitioner PATRICIAL MCCONNELL Attorney for Planning Commission of the County of Kaua'i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua'i 4444Ptrce Street, Suite 150 Lrhu'e, Kaua'i, Hawai'i 96766 Email: eching@kauai.eov asegreti@kauai.gov HARLAN Y. KIMURA, ESQ. Central Pacific Plaza 220 South King Street, Suite 1660 Honolulu, Hawai'i 968 I 3 Email : hlrk@harlankimuralar,v.corn Hearing Officer for the Planning Commission of the County of Kaua'i 2 NICHOLAS R. COURSON, ESQ. Deputy County Attorney County of Kaua'i 4444 Rice Street, Suite 220 Lrhu'e, Kaua'i, Hawai'i 96766 Email : ncourson@kauai. gt-rv DATED: Lrhu'e, Kaua'i, Hawai'i, July 9,2019 B MATTHEW M. BRACKEN County Attorney tywffij,^ MARYANN SASAKI Deputy County Attorney Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I J 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 HEARING OFFICER’S SECOND AMENDED SCHEDULING ORDER; CERTIFICATE OF SERVICE HEARING (Scheduled): Date: August 30, 2019 Time: 9:00 a.m. HEARING OFFICER’S SECOND AMENDED SCHEDULING ORDER On July 19, 2019 at 10:00 a.m. a Prehearing Conference was held herein by telephone pursuant to Rule 1-6-7 of the Rules of Practice and Procedure of the Kaua‛i County Planning Commission (“Commission Rules”) at the request of Gregory W. Kugle, Counsel for Petitioner PATRICIA D. McCONNELL 2 (“Petitioner”), because Petitioner will be unavailable on the present Contested Case Hearing Date of August 7, 2019 due to her Goddaughter’s Wedding. At the Prehearing Conference Petitioner was represented by Mr. Kugle and Joanna C. Zeigler, and Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”) was represented by Maryann Sasaki. No other parties appeared. Based upon the Prehearing Conference the Hearing Officer’s First Amended Scheduling Order dated July 5, 2019 is hereby amended in its entirety as follows: 1. Contested Case Hearing to be held on August 30, 2019, commencing at 9:00 a.m.; 2. Prehearing Statement due no later than August 23, 2019 at 4:30 p.m. (1 week before); 3. Witness List due no later than August 23, 2019 at 4:30 p.m. (1 week before); 4. Exhibit List and Exhibits due no later than August 23, 2019 at 4:30 p.m. (1 week before). Petitioner shall use Numbers to identify her Exhibits and the Planning Department shall use Alphabets to identify its’ Exhibits; 5. Prehearing Motions as deemed necessary by any party shall be due no later than August 1, 2019 at 4:30 p.m.; 3 6. Responses to any Prehearing Motions due by August 15, 2019 at 4:30 p.m.; 7. Replies due by 4:30 p.m. no later than three (3) business days after service of the Response; and 8. Hearing on any Prehearing Motions to be held immediately prior to the commencement of the Contested Case Hearing, unless an Order ruling on the same is issued prior thereto. Any and all of the above-described pleadings shall be served by email or facsimile transmission, with a hard copy served by regular mail, postage prepaid, to all the parties and the Office of Boards and Commissions for the County of Kaua‛i. The times set forth above are based upon Hawaiian Standard Time (“HST”). A Further Prehearing Conference may be requested by either party to address any issues or concerns related to this Contested Case. DATED at Honolulu, Hawaii, July 19, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on July 19, 2019. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com JCZ@hawaiilawyer.com Attorneys For Petitioner PATRICIA D. McCONNELL MARYANN SASAKI, ESQ. Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: msasaki@kauai.gov Attorney for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov DNakamatsu@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X DATED at Honolulu, Hawaii, July 19, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i PLANNING COMMISSION HEARING OFFICER AGENCY HEARING NOTICE APPLICANT/PETITIONER: PATRICIA D. McCONNELL APPLICATION NO. PETITION TO APPEAL DECISION OF THE PLANNING DIRECTOR’S DECISION RELATED TO THE NOTICE OF VIOLATION AND ORDER TO PAY FINES FOR THE OPERATION OF AN ILLEGAL TRANSIENT ACCOMMODATION USE FOR PROPERTY SITUATED IN HĀ`ENA, KAUA`I, HAWAI`I, IDENTIFIED BY KAUA`I TMK NO. (4) 5-8-005:005 CONTAINING 26,092 SQUARE FEET; CC-2017-4 DATE OF AGENCY HEARING: August 30, 2019, 90:00 a.m., Līhu‘e Civic Center, Moikeha Building, Conference Room 3, 4444 Rice Street, Līhu‘e, Kaua‛i, Hawai‘i 96766 NOTICE IS HEREBY GIVEN pursuant to Section 1-6-5 of the Rules of Practice and Procedure of the Planning Commission, and Hawai`i Revised Statutes §91-9, that the following is scheduled for a contested case hearing before Hearing Officer Harlan Y. Kimura, Esq.: In the Matter of the Petition To Appeal the Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua`i, Hawai`i, identified by Kaua`i TMK No. (4) 5-8-005:005 containing 26,092 square feet; CC-2017-4. This matter concerns an Appeal of the Decision of the Planning Director to issue the Notice of Violation and Order to Pay Fines for the operation of an Illegal Transient Accommodation Use for property located in Hā‛ena, Kaua`i, Hawai`i. The particular sections of the statutes and/or rules involved include, but not limited to: (1) Ordinance Nos. 904, 919, and 1002; (2) Sections 8-1.5, 8-2.4, 8-17.8 and 8-18.1(b) of the Comprehensive Zoning Ordinance for the County of Kaua‛i (“CZO”); and (3) Chapter 8, Article 17, of the CZO. Any party may retain counsel if the party so desires, and an individual may appear on his own behalf, or a member of a partnership may represent the partnership, or an officer or authorized employee of a corporation or trust or association may represent the corporation, trust, or association. NOTE: Special accommodations and sign language interpreters are available upon request five (5) days prior to the meeting date, to the County Planning Department, 4444 Rice Street, Līhu‘e, Hawai‘i 96766. Telephone (808) 241-4050. MATTHEW M. BRACKEN 10267 County Attomey MARYANN SASAKI 10458 Deputy County Attorney Office of the County Attorney, County of Kaua'i 4444 Rice Street, Suite 220 Lrhu'e, Hawai'i 96766 Telephone: (808) 241 -4930 Email : msasaki(@kauai.gov Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I ) cc-2017-4 ) TMK: (4) 5-8-005:005 ) ) ) RESPONDENT PLANNING DEPARTMENT ) OF THE COUNTY OF KAUA'I'S REPLY ) TO PETITIONER PATRICIA ) MCCONNELL'S MEMORANDUM IN ) OPPOSTTTON TO RESPONDENT ) PLANNING DEPARTMENT OF THE ) couNTY oF KAUAI'S MOTION FOR ) SUMMARY JUDGMENT; CERTIFICATE ) OF SERVICE ) ) HEARING: ) Date: August 30,2019 ) Time: 9:00 a.m. ) Hearing Officer: Harlan Y. Kimura ) ) ) ) ) VS Respondent. Petitioner, RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S REPLY TO PETITIONER PATRICIA MCCONNELL'S MEMORANDUM IN OPPOSITION TO RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI'S MOTION FOR SUMMARY JUDGMENT It is irnpossible not to envy thc man u.ho can disrniss reason, although we know how it must tum out at last. - Charles Sanders Peirce I. INTRODUCTION Patricia McConnell ("McConnell") has been operating an illegal bed and breakfast or homestay for many years. As of January 28,2016, according to the Planning Department's Investigation Report attached as Exhibit A to the Declaration of Mike Laureta, the Planning Department ascertained that McConnell was operating an illegal homestay that was listed on Air BnB in violation of KCC $$ 8-l7.ll and 8-17.8. The violation notice dated May 23,2017 gives McConnell notice she is violating KCC $$ 8.18.1(b) and 8.35 levies a f,rne of $10,000 plus $ 10,000 per day for continued violation. It is incontrovertible that McConnell operated January 28, 2016 through May 16, 2017 . McConnell herself conceded that she was operating an illegal vacation rental at $27 5 per night on March 12, 2017. This stretch of illegal activity alone subj ects McConnell to a $150,000 fine, ie a continuing violation subject to penalties of $10,000 per day. There is no evidence that Ms. McConnell has ceased operations. There is no evidence that she plans to cease operations. II. ANALYSIS A motion for summary judgment must be granted when there is no genuine issue of material fact. In this case there is no dispute regarding the facts or the law. Here were McConnell herself admitted guilt and the Code regulates transient rental stays outside of the visitor destination area, it is impossible for the Hearing Officer to find other than McConnell was operating an illegal transient rental and to fine her accordingly 2 McConnell's memorandum in opposition contains a litany of petty complaints which do not alter these facts. We will briefly review some of the "issues" raised by McConnell. A. Admission of Evidence. Petitioner misunderstands the legal standard regarding the admissibility of evidence in this matter. The documents appended to Mr. Laureta's declaration are subject to the following. (6) Records of regularly conducted activity. A memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses, made in the course of a regularly conducted activity, at or near the time of the acts, events, conditions, opinions, or diagnoses, as shown by the testimony of the custodian or other qualified witness, or by certification that complies with rule 902(11) or a statute permitting certification, unless the sources of information or other circumstances indicate lack of trustworthiness. Haw. Rev. Stat. Ann. $ 626-1, Rule 803 (West). The Br.rsiness Exception rule further provides (l l) Certified records of rezularly conducted activity. The original or a duplicate of a domestic or foreign record of regularly conducted activity that would be admissible under rule 803(b)(6), if accompanied by a written declaration of its custodian or other qualified person, certifying that the record was: (A) Made at or near the time of the occuffence of the matters set forth by, or from information transmitted by, a person with knowledge of those matters; (B) Kept in the course of the regularly conducted activity; and (C) Made by the regularly conducted activity as a regular practice. Haw. Rev. Stat. Ann. $ 626-1, Rule 902 (West) The "someone" named "Bambi" in McConnell's motion is Bambi Emayo a senior investigator for the Planning Department. McConnell was notified in the Notice of Violation that he should be contacted with respect to the fines levied on McConnell. Mr. Laureta is Bambi Emayo's supervisor and the custodian of such records. Moreover, the investigative report is sufficient to establish that the instant homestay was outside the VDA. The following hearsay exception applies. (8) Public Records. A record or statement of a public office if: (A) it sets out: J (i) the office's activities; (ii) a matter observed while under a legal duty to report, but not including, in a criminal case, a matter observed by law-enforcement personnel; or (iii) in a civil case or against the government in a criminal case, factual findings from a legally authorized investigation; and (B) the opponent does not show that the source of information or other circumstances indicate a lack of trustworthiness. Fed. R. Evid. 803 (ernphasis added), In this case, the declaration authenticates factual findings from a legally authorized investigation McConnell has not indicated any reason the source of this information might be untrustworthy. The Planning Department has no motive to misrepresent the location of the subject property within the VDA. [C]onsidering whether the sources of information recorded are trustworthy, a trial court should also consider whether the sources had a motive to rnisrepresent the information. Faqan v. Newark, 78 N.J.Super. at320,188 A.2d al 441. Warshaw v Rockresorts. Inc., 57 Haw. 645, 652, 562 P.2d 428, 434 (1977) The weakness of McConnell's case is also highlighted by McConnell's insistence that a minor inconsistency between the documents taints all the evidence produced. Indeed, it is not material whether or not McConnell signed a remediation agreement. It is clear that in either case, she did not remediate the problem. In any case, Hawai'i courts disagree with McConnell that such irregularities void all evidence. [N]ot all mistakes, or allegations of mistake, in a company's business records will render that company's record-keeping practices untrustworthy, and therefore render their records inadmissible. In State v. Forman, the ICA held that "the vague testimony that [a company] 'kept bad paperwork,' without more, [did] not warrant a conclusion that the company's records as a whole were untrustworthy[,] Nationstar Morte. LLC v. Kanaheh , 144 Haw . 394, 404, 443 P .3d 86, 96 (2019). Moreover, The Rule 56(e) requirement of personal knowledge and competence to testify may be inferred from the affidavits themselves. See Barthelemy v.Lines Pilots Ass'n, 897 F.2d 999, 1018 (9th Cir.1990) (holding that it was proper for court to 4 rely on affidavits of defendant's representatives in negotiations because their "personal knowledge and competence to testify are reasonably inferred from their positions and the nature of their participation in the matters to which they swore"); Lockwood v. Wolf Corp. , 629 F .2d 603, 6l I (9th Cir.1980) (holding that because attorney negotiated and handled legal transactions, it was "reasonable to assume that he had personal knowledge of nonpayment). Consequently, [the defendants] could attest to facts as to which it could be reasonably inferred they would have personal knowledge as a result of their "positions and the nature of their participation[.]" Barthelemy, 897 F.2d at 1018. fDefendant] stated that he had "been President of Marine Planning International, Inc. the developer of the Maui Isana Resort from 1987 to the present" (declaration signed December 2, 1998). He made the declaration "from personal knowledge." As the president of the development company, it may be reasonably inferred that he had personal knowledge of the operation of the Resorl. fDefendant] stated that he "was the Deputy Planning Director of the County of Maui from 1980 to 1984." He also ctated th4t he ty4s "Plauning Director from 1986 to 1991." Thus. from his position as Deputv Planning Director and Planning Director of theleOunty of Maui, it nq.ay lealsonabl-y be inferred that Hart had personal knowledge of the policy with respect to hotel districts. Stallard v. Consol. Maui. Inc., 103 Haw. 468, 47 5-7 6, 83 P.3d 731, 738-39 (2004). We also note that according to the Rules of Practice and Procedure I -6-9, the Presiding Officer shall not order or approve civil style discovery between parties. HRCP 56(f) says that the court pqgy order discovery - discovery is not an imperative. B. Reliable Probative Evidence. Aside from McConnell's own admission against interest that she was, in fact, conducting an illegal homestay, the Investigation Report dated January 10,2017 sets forth the evidence determining McConnell's violation. She was found to be advertising on Air BnB and an examination of Pictometry confirmed the property was indeed McConnell's. Thereby, and as usual custom and practice, the investigator was able to determine that McConnell was in violation of the law. That Investigation Report also indicates the specific provisions of the Code that McConnell was violating. Equating that investigation with the statement of an unidentified man (as McConnell does in her motion) is a puerile attempt to ignore the actual evidence. 5 Discussions with neighbors, discussions with renters and proof of monetary transactions are not necessary. In addition, we note that McConnell does not have a nonconforming use certificate and the Planning Department does not know if she has been paying taxes on her transient vacation rental. McConnell is simply operating outside the law. Indeed, aparty moving for summary judgment under Federal Rules of Civil Procedure Rule 56 need not support his or her motion with affidavits or similar materials that negate his or her opponent's claims, but need only point out that there is [an] absence of evidence to support the opponent's claims. For if no evidence could be mustered to sustain the nonmoving party's position, a trial would be useless. Exotics Hawaii-Kona, Inc. v. E.I. Du Pont De Nemours & Co., 116 Haw.277 ,301, 172 P.3d 102r,1045 (2007) C. The Law. It is very clear from the Motion for Summary Judgment, particularly the exhibits, which laws McConnell is violating. The Planning Department does not have McConnell's penchant for lugubrious verbiage. Verbatim citations are anathema to a succinct statement of the law and issues. Considering McConnell's own admission, the investigation reports and the various letters addressing her violations, the citation "Homestay operations are prohibited outside of the Visitor Destination Areas pursuant to Ord. 987, June 19, 2015 and Ord. No. I 002, May I 8, 201 6" should suffice. However, if McConnell requires the text of the laws violated, that is easy to provide. To wit: KCC $8.18(b) provides. A property owner that has obtained a homestay zoningpermit shall apply to renew the zoning permit annually on the date of issuance of the homestay zoning pennit in accordance with the following regulations: (a) Each application to renew shall include proof that there is currently a valid State of Hawaii general excise tax license and transient accommodations tax license for the homestay operation. Failure to meet this condition will result in the automatic denial of the application for renewal of the homestay zoning permit(s). The applicant may reapply for renewal within the annual time allotment by 6 presenting a currently valid State of Hawaii general excise tax license and transient accommodation tax license for the homestay operation; (b) Each application to renew shall include proof that the primary residential structure(s) used for the homestay operation is the owner's primary residence, and the respective owner is benefiting under Sec. 5,A.-l I of this Code for a homeowner's exemption for the homestay site in the year preceding the date of renewal; (c) Upon renewal, the Planning Department may initiate re-inspection of properties for compliance with other provisions of this chapter or other pertinent land use laws, and may withhold approval of a renewal application and issue cease and desist notices to the applicant until all violations have been resolved; (d) The applicant shall pay a renewal fee of seven hundred fifty dollars ($750.00) to the Director of Finance. All renewal fees shall be deposited to the Transient Accomrnodation Enforcement Account within Fund 251; and (e) Enforcement of this section shall be subiect to Section 8-3.5 of the Kauai CounW Code 1987. as amended. (Ord. No. 1002. May 18. 2016) (emphasis added) Synopsis: A homestay zoningpermit is required. The owner shall provide: a valid GET, proof of primary residence, be subject to inspection; submit a renewal fee. McConnell is in non-compliance with all these provisions. Moreover, enforcement is subject to the following: KCC $ I 8-l 8. I (b) provides: (b) Homestav operations are outside of the Visitor Destination 9 20t5 Ord. No. 1002 M I 2 (emphasis added). McConnell is not in compliance with this provision either. D. Fines. KCC $8-3.5(b) gives the Planning Department the right to impose fines up to $10,000 per day. The argument that only the Planning Department can impose such fines is specious given the fact that the Motion for Summary Judgment is by the Planning Department. The Planning Department seeks to enforce the fine by obtaining a recommendation from the Hearing Officer 7 that $150,000 is appropriate given the continuous, willful violation of the law. Moreover, the County could have, and still may, seek injunctive relief from the Fifth Circuit. III. CONCLUSION Irrespective of the inappropriate editorial comments and vituperative epithets included by McConnell in her memorandum in opposition, McConnell still fails to make her case. By skirting every detail and ignoring the obvious issue, McConnell seeks to continue to operate her illegal homestay outside the law. That is why McConnell must be ordered to cease operations and pay a fine of $ 150,000 that shall be levied against her by the Planning Department. DATED: LIhu'e, Kaua'i, Hawai'i, August 20,2019. MATTHEW M. BRACKEN County Attomey B MARYANN SASAKI Deputy County Attorney Attomey for Respondent PLANNING DEPARTMENT OF THE COLINTY OF KAUA'I 8 Mxtg{,:, BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. McCONNELL, Petitioner, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent. The undersigned hereby certifies that on the date set forth below, a copy of foregoing document was duly served by email and depositing the same in the U.S. mail, postage prepaid, upon the following: Gregory W. Kugle, Esq. Joanna C. Zeigler, Esq. DAMON KEY LEONG KUPCHAK HASTERT 1003 Bishop Street, Suite 1600 Honolulu, Hawai'i 96813-6452 Email: ewk@hawaiil awver.cotll VS j cz@thawai ilawyer. com CERTIFICATE OF SERVICE Attorneys for Petitioner PATRICIA D. McCONNELL NICHOLAS R. COURSON, ESQ Deputy County Attomey County of Kaua'i 4444 Rice Street, Suite 220 Lfhu'e, Kaua'i, Hawai'i 96766 Email : ncourson@kauai. gov Attorney for Planning Commission of the County of Kaua'i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua'i 4444 Rice Street, Suite 150 Lrhu'e, Kaua'i, Hawai'i 96766 Email : echine(Dkauai.eov lagoot(Dkauai.gov HARLAN Y. KIMURA, ESQ. Central Pacific Plaza 220 South King Street, Suitel660 Honolulu, Hawai'i 968 I 3 Email : hyk(L0harl ankirnuralaw.corn Hearing Officer for the Planning Comrnission of the County of Kaua'i DATED: Lrhu'e, Kaua'i, Hawai'i, August 20,2019 MATTHEW M. BRACKEN County Attorney B ftfu*,lrtb t, ,., MARYANN SASAKI Deputy County Attorney Attomey for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 MATTHEW M. BRACKEN 10267 County Attorney MARYANN SASAKI 1.0458 Deputy County Attomey Office of the County Attomey, County of Kaua'i 4444 Ptice Street, Suite 220 LIhu'e, Hawai'i 96766 Telephone: (808) 241 -4930 Ernail : rnsasaki({ikauai. gov Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAIJA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, McConnell, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, cc-2017-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S PREHEARING STATEMENT; CERTIFICATE OF SERVICE HEARING: Date: August 30,2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Respondent. VS. PLANNING DEPARTMENT'S PREHEARING STATEMENT Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I (the "Planning Department"), by and through its undersigned attorneys, respectfully submits its Prehearing Statement in response to Petitioner PATRICIA D. McCONNELL's ("McConnell"), Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet. The Notice of Appeal was received by the Planning Commission on June 13,2017. The contested case hearing on the matter is scheduled for August 30, 2019, at 9:00 a.m. The Department respectfully submits its Prehearing Statement pursuant to Chapter 6 of the Rules of Practice and Procedure of the Kaua'i County Planning Commission, Rule 7 of the Hawai'i Rules of Civil Procedure ("HRCP"), Rule 7 of the Circuit Courts of the State of Hawai'i ("RCCH"), and the exhibits, records, and files herein. I. INTRODUCTION In 2008, the Kaua'i County Council concluded that there was "a compelling need to regulate single-family transient vacation rentals on Kaua'i" because "the uncontrolled proliferation of vacation rentals in residential and other areas" outside of designated Visitor Destination Areas (VDAs) "is causing significant negative impacts to certain residential neighborhoods."l Accordingly, the Council enacted Ordinance 864 to establish a regulatory framework for the operation of single-family transient vacation rentals (TVRs). 2 I Ordinance No. 864, Bill No. 2204,Draft 4, adopted by Council February 21,2008, and approved by Mayor March 7,2008. 2 As set out in Kaua'i County Code ("KCC") S 8-1.5, "Transient Vacation Rental" means a dwelling unit which is provided to transient occupants for compensation or fees, including club fees, or as part of 2 Pursuant to Ordinance No. 864 beginning on March 7,2008, TVRs "are prohibited in all areas not designated as Visitor Destination Areas."3 Notwithstanding this general prohibition, any TVR outside a VDA in lawful use prior to March 7,2008, was allowed to continue operation "subject to obtaining a Nonconforming Use Certifi cate."4 After March 30, 2009, no TVR operations are permitted outside the VDA without a Nonconforming Use Certificate. Ordinance 864 was implemented because the County found a compelling need to regulate family transient vacation rentals on Kaua'i to VDAs because their unregulated growth was causing significant negative impact to certain residential neighborhoods IOrdinance 864, enacted March 7 ,20081, Ordinance No. 1002 was passed to address the same issues regarding homestays and prohibiting any homestays from operating outside of VDAs fOrdinance 1002, enacted June 3, 2006). After December 3 7,2076, unpermitted homestays were not permitted outside the VDA. The Kaua'i County Code 1';KCC" or the "Code') $ 8-18.1(b) explicitly sets forth the connection between homestays and TVRs. To wit: (b) Homestay operations are prohibited outside of the Visitor Destination Area (VDA). (Ord. No.987, June 19,2015; Ord. No. 1002, May 18,2016) McConnell owns and operates a homestay outside of the VDA. McConnell's operation is therefore unlawful. Once notified that she was in violation of the CZO, McConnell openly disregarded the Planning Department's notice to cease and desist operations and continues to do interval ownership involving persons unrelated by blood, with a duration of occupancy of one hundred eighty (l 80) days or less. 3 The provision of Ordinance No. 864 barring TVRs outside of the VDA is now codified, as amended, in KCC $ 8-17.8 et seq. 4 The provisions of Ordinance No. 864 relating to the continued operation of lawful TVRs outside the VDA subject to Nonconforming Use Certificates are now codified in KCC $ 8-17.10. aJ so. The Planning Department justifiably issued a Notice of Violation and Order to cease and desist her homestay operations. II. STATEMENT OF THE CASE In bringing the instant appeal, McConnell, owner of the subject property located 4813 Ananalu Road, Hanalei, Hawai'i TMK No. (a) 5-8-005:005 (the "Subject Property") seeks to flout the explicit provisions regarding homestays in the Code by operating a homestay outside a VDA absent any permits and in direct violation of the Comprehensive Zoning Ordinances Chapter 8, KCC, 1987 as Amended (CZO.) There are no mitigating circumstances here. As set forth in the Air BnB Evidence Checklist - TVR Inspections and the Investigation Report ofRespondent dated January 28,2016 and January 10,2017, respectively, prepared by the Planning Department, McConnell has never possessed a homestay permit and operates outside a visitor designation area in violation of KCC $ 8-18.1(b). (See Exhibits A and B, annexed hereto.) On January I I , 2017 , the Respondent via a Zoning Compliance Notice from the Planning Department notified McConnell that she ought to stop operating the Subject Property as a transient accommodation and cancel all transient accommodation commitments for the Subject Property. The Zoning Compliance Notice also informed McConnell that she would be subject up to a $ 10,000 fine, and $ 10,000 for every day the violation should persist. (See Exhibit C, annexed hereto.) On May 23,2017 , via a Notice of Violation & Order to Pay Fines, the Planning Department informed McConnell that she was in continued breach of the Zoning Compliance 4 Notice, and fines could continue to accrue up to $10,000 per day. (See Exhibit D, annexed hereto.) On May 23,2017, another Investigation Report was prepared by the Planning Department indicating McConnell was continuing operations of her illegal homestay. (See Exhibit E, annexed hereto.) On or around April 12, 2077, a memorandum was prepared contemporaneously with a meeting with McConnell in which McConnell stated that she did not see how she was violating the law. (See Exhibit F, annexed hereto.) UI. POSITION STATEMENT By McConnell's own admission, she was conducting an illegal homestay, the Investigation Report dated January 10,2017 , sets forth the evidence determining McConnell's violation. She was found to be advertising on Air BnB and an examination of Pictometry confirmed the property was indeed McConnell's. (See Exhibit B, annexed hereto.) Thereby, and as usual custom and practice, the investigator was able to determine that McConnell was in violation of the law. That Investigation Report also indicates the specific provisions of the Code that McConnell was violating. As to the constitutionality of County ordinances relating to the designation of VDAs and TVRs, state law expressly grants County's the zoning authority to regulate the use of land within the County. See HRS $ 46-4. Zoningis "a legislative act subject to the deference given to legislative acts," including a "presumption of validity " Save Sunset Beach Coal. v. Citv & Ctv of Honolulu, l02Hawai'i 465,474,78 P.3d 1, 10 (2003). McConnell cannot overcome the high bar required to show unconstitutionality of this provision. Under KCC $ 8- l7.l I (b), "Advertising of any sort which offers a property as a transient vacation rental shall constitute 5 prima facie evidence of the operation of a transient vacation rental on said property and the burden of proof shall be on the owner. . . to establish that the subject property is not being used as a transient vacation rental or that it is being used for such purpose legally." Here, it is undisputed that McConnell was advertising her homestay. This constitutes prima facie evidence of unlawful transient vacation rental activity. Having received a Notice of Violation ordering McConnell to cease homestay use of the property, McConnell took no action to carry her burden in establishing that her property was not being used as a TVR. HRS $ 46-a@) grants the counties the zoning power to enact ordinances governing the areas in which various land uses may take place or otherwise be subject to restriction. This zoningpower is to be "liberally construed in favor of the county exercising" it. Id. Act 186, 1980, provided that "the several counties shall, by amendment of their zoning ordinances, limit the location of time share units, time share plans and other transient vacation rentals, within such areas as are deemed appropriate." 1980 Haw. Sess. Laws Act 186, $ 4 at 306. Pursuant to Act 186, the County Council enacted Ordinance 436 "for the purpose of designating locations, referred to as 'Visitor Destination Area,' in which transient vacation rentals, time share units and time share plans are to be allowed." By extension, following the enactment of Ordinance 436 transient vacation rentals, time share units and time share plans were prohibited outside designated Visitor Destination Areas (VDAs). Maps delineating the boundaries of VDAs in Po'ip[, Lrhu'e, Wailua-Kapa'a, and Princeville were incorporated into Ordinance 436. Additionally, Zoningmaps containing designated VDAs are available for public viewing at the Planning Department. 6 In creating these VDAs the County Council enumerated eight specific factors that were considered: 1. The General Plan, Development Plan andZoning designations for such areas. 2. The suitability of such areas for visitor related uses. 3. The existence in such areas of lands designated for Resort use in the General Plan or having Resort zoning. 4. The availability of public services and facilities in such areas. 5. The potential for conflict with other uses in such areas 6. The availability in such areas of large numbers of hotel and multifamily dwelling units suitable as accommodations by temporary visitors. 7 . The availability in the areas of outdoor or commercial recreational facilities, such as beaches, golf courses, tennis courts, and other facilities. 8. The availability in the areas of tourist related comrnercial facilities, such as gift shops, food stores, recreational equipment and service shops, tour and transportation service terminals, restaurants, bars, night clubs, cabarets, shopping centers, theaters, auditoriums, and other similar facilities. [ord.436] When initially enacted in 1982, VDAs only related to the operation of multi-family transient vacation rentals. In 2008, however, Ordinance 864 established a regulatory framework barring the operation of single-family transient vacation rentals outside of established VDAs. To constitute a deprivation of due process, a civil statute must be "so vague and indefinite as really to be no rule or standard at all." Paul v. Dep't of Transp.. State of Hawai'i, I l5 Hawai'i 416, 431, 168 P.3d 546, 561 (2007). Uncertainty in a statute "is not enough for it to be unconstitutionally vague; rather, it must be substantially incomprehensible." Id. at 431,168 P.3d at 561 (intemal citations and brackets omitted) (emphasis added). 7 There is nothing "substantially incomprehensible" about the designation of VDAs by the Kaua'i County Council. They are clearly set out in Ordinance 436, and are currently defined in KCC $ 8-1.5 as "those areas designated as Visitor Destination Areas on County of Kaua'i ZoningMaps," which are available to the public at the Planning Department. Even if McConnell never availed herself of the opportunity to view the Zoning Maps containing VDA designations at the Planning Department, persons owning property within a State are charged with knowledge of relevant statutory provisions affecting the control or disposition of such property." Texaco. Inc. v. Short, 454 U.S. 516,532 (1982), see also Hawaiian Bell Tel. Co. v. Oriental Telephone Co., 6 Haw. 393,401 (1883) ("Everyone is presumed to know the law."). Moreover, McConnell received direct notice that her home was outside the VDA in the Zoning Compliance Notice she received shortly in January 2017. She chose to ignore this notice and continued homestay operations. The Hawai'i Supreme Court has held that section 9l-10(l), "is intended to direct administrative agencies to admit any and all evidence presented to thern 'limited only by considerations of relevancy, materiality and repetition."'Chock v. Bitterman, 5 Haw. App. 59, 65,678 P.2d 576,581 (1984). The purpose of section 91-10(1) is to "free administrative agencies from the bounds of any technical rules of evidence, and its intent was to require agencies to admit evidence that would have been inadmissible in common law trials." Chock v. Bitterman, 5 Haw. App. 59, 65,678P.2d.576,581 (1984) (internal quotes and citations omitted). Accordingly, the Hawai'i Rules of Evidence, and in particular, the hearsay rules within the Rules of Evidence, do not apply to contested case proceedings. The Hearing Officer is free to admit and consider "any oral or documentary evidence," and it was up to them as the triers of fact to weigh the evidence received. 8 V. CONCLUSION McConnell must be compelled to cease operations of this homestay, and perhaps more effective than an injunction in the Fifth Circuit would be an appropriate fine. In this matter where the behavior has gone on for years and McConnell persists on flouting the law and admits she is doing so despite all efforts by the Planning Department, the Planning Department pursuant to KCC $ 8-3.5(bXlXB)-(C), seeks ONE HUNDRED FIFTY THOUSAND DOLLARS ($150,000) in fines and an order that McConnell Cease and Desist the operation of the her homestay. DATED: Lrhu'e, Kaua'i, Hawai'i, August ?? ,2019. MATTHEW M. BRACKEN County Attorney -tW MARYANN SASAKI Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 9 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. MoCONNELL, McConnell, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date set forth below, a copy of RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S PREHEARING STATEMENT, was duly served by email and depositing the same in the U.S. mail, postage prepaid, upon the following: Gregory W. Kugle, Esq. Joanna C. Zeigler, Esq. DAMON KEY LEONG KUPCHAK HASTERT 1003 Bishop Street, Suite 1600 Honolulu, Hawai'i 96813-6452 VS. Email : gwk({Dhawaiilawver. corn j cz({0hawai il awyer. com Attorneys for McConnell PATRICIA D. MCCONNELL NICHOLAS R. COURSON, ESQ Deputy County Attomey County of Kaua'i 4444 P.ice Street, Suite 220 Lrhu'e, Kaua'i, Hawai'i 96766 Emai I : nco r.rrso nf(Dkauai. qov Attomey for Planning Commission of the County of Kaua'i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua'i 4444 Rice Street, Suite 150 LThu'e, Kaua'i, Hawai'i 96766 Email: cchine@kauai.eov aseereti@kauai.gov HARLAN Y. KIMURA, ESQ. Central Pacific Plaza 220 South King Street, Suite1660 Honolulu, Hawai'i 96813 Email : hyk(@harlankimuralaw.corn Hearing Officer for the Planning Commission of the County of Kaua'i DATED: Lfhu'e, Kaua'i, Hawai'i, August 9b ,rOrg MATTHEW M. BRACKEN County Attomey a fV/n4/vUn MARYANN SASAKI Deputy County Attorney Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 MATTHEW M. BRACKEN 10267 County Attorney MARYANN SASAKI 10458 Deputy County Attorney Office of the County Attorney, County of Kaua'i 4444 Price Street, Suite 220 LIhu'e, Hawai'i 96766 Telephone: (808) 241-4930 Emai I : rnsasaki@kauai.qov Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, cc-2017-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S WITNESS LIST; CERTIFICATE OF SERVICE HEARING: Date: August 30,2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura VS. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Respondent. PLANNING DEPARTMENT'S WITNESS LIST Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I (the "Planning Department"), by and through its undersigned attorneys, respectfully submits its Witness List regarding the above-referenced matter. WITNESSES Ka'aina S. Hull, Director Planning Department, County of Kaua'i Clerk to the Planning Commission c/o Office of the County Attomey 4444 Rice Street, Suite 220 LIhu'e, Hawai'i 96766 This witness is expected to testify as to the processes and procedures of the Department, in general, and as related to this specific case, including, but not limited to, zoning map designations and the practice and procedures of the Department. This witness is expected to testify with regard to the Petitioners' witnesses and/or rebuttal testimony Mike Laureta, Program Manager Planning Department, County of Kaua'i c/o Office of the County Attorney 4444 Pttce Street, Suite 220 LIhu'e, Hawai'i 96766 This witness is expected to testify as to the processes and procedures of the Department, in general, and as related to this specific case, including, but not limited to, zoning map designations and the practice and procedures of the Department. This witness is expected to testify with regard to the Petitioners' witnesses and/or rebuttal testimony. Andres (Bambi) Emayo, Senior Investigator Planning Department, County of Kaua'i c/o Office of the County Attorney 4444 Rice Street, Suite 220 Lrhu'e, Hawai'i 96766 1 2. -') 2 This witness is expected to testify as to the processes and procedures of the Department, in general, and as related to this specific case, including, but not limited to, zoning map designations and the practice and procedures of the Department. This witness is expected to testify with regard to the Petitioners' witnesses and/or rebuttal testimony. Joan Ludington-Braun, Inspector Planning Department, County of Kaua'i c/o Office of the County Attorney 4444 Plice Street, Suite 220 LThu'e, Hawai'i 96766 This witness is expected to testify as to the processes and procedures of the Department, in general, and as related to this specific case, including, but not limited to, zoning map designations and the practice and procedures of the Department. This witness is expected to testify with regard to the Petitioners' witnesses and/or rebuttal testimony. The Department reserves the right to call and hereby name (l) any and all witnesses named, identified or called by the Petitioners in this matter; (2) any and all witnesses named and/or identified as a result of discovery or investigation conducted by any party; and (3) all rebuttal witnesses, as necessary, at the hearing hereof. DATED: Lthu'e, Kaua'i, Hawai'i, August A,7', ,2)lg. MATTHEW M. BRACKEN County Attorney 4 M MARYANN SASAKI Deputy County Attorney Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 3 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, cc-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PATRICIA D. MoCONNELL, Petitioner PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I, Respondent CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date set forth below, a copy of RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S WITNESS LIST, was duly served by email and depositing the same in the U.S. mail, postage prepaid, upon the following: Gregory W. Kugle, Esq. Joanna C. Zeigler, Esq. DAMON KEY LEONG KUPCHAK HASTERT 1003 Bishop Street, Suite 1600 Honolulu, Hawai'i 96813-6452 VS Email: gwk@hawaiilawyer.corn icz@hawaiilawyer.com Attorneys for Petitioner PATRICIA D. MoCONNELL NICHOLAS R. COURSON, ESQ. Deputy County Attomey County of Kaua'i 4444Rice Street, Suite 220 Lrhu'e, Kaua'i, Hawai'i 96766 Email : ncourson@kauai. gov Attorney for Planning Commission of the County of Kaua'i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua'i 4444Piice Street, Suite 150 Lfhu'e, Kaua'i, Hawai'i 96766 Email: eching@kauai.qov aseqreti@,kauai. gov HARLAN Y. KIMURA, ESQ. Central Pacific Plaza 220 South King Street, Suitel660 Honolulu, Hawai'i 968 1 3 Email: hyk@harlankimuralarv.corn Hearing Officer for the Planning Commission of the County of Kaua'i DATED: Lrhu'e, Kaua'i, Hawai'i, August 29 ,ZOtg MATTHEW M. BRACKEN County Attomey i B MARYANN Deputy County Attorney Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 MATTHEW M. BRACKEN 10267 County Attomey MARYANN SASAKI 10458 Deputy County Attorney Office of the County Attorney, County of Kaua'i 4444 Rice Street, Suite 220 LThu'e, Hawai'i 96766 Telephone: (808) 241-4930 Email: rnsasaki@kauai. gov Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, PLANNING DEPARTMENT OF THE COLINTY OF KAUA'I, cc-20t7-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I'S EXHIBIT LIST; EXHIBITS A - F; CERTIFICATE OF SERVICE HEARING Date: August 30,2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura VS ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Respondent. PLANNING DEPARTMENT'S EXHIBIT LIST Pursuant to request of Hearing Officer Harlan Y. Kimura ("Officer"), Respondent PLANNING DEPARTMENT OF THE COLINTY OF KAUA'I ("Department"), by and through its undersigned attorneys, respectfully submits its Exhibit List containing Exhibits A - F, in response to Petitioner PATRICIA D. McCONNELL ("Petitioners"), Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hd'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (a) 5-8-005:005 containing26,092 square feet, received by the County of Kaua'i Planning Department on June 13,2017 . The contested case hearing on the matter is scheduled for August 30, 2019, at 9:00 a.m. DATED: LIhu'e, Kaua'i, Hawai'i, August 23 ,2}lg. MATTHEW M. BRACKEN County Attomey Ytt8tfr,/^,1tu1 l B MARYANN SASAKI Attomey for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 COUNTY OF KAUA'I PLANNING COMMISSION EXHIBIT LIST cc-2017-4 TMK: (4) 5-8-005:005 PETITIONERS PATRICIA D. McCONNELL PETITIONERS' ATTORNEY (Narne, Address and Tel. No.) GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, Hawai' i 96813 -6452 Telephone: (808) 53 l-8031 RESPONDENT PLANNING DEPARTMENT OF THE COLINTY OF KAUA'I RESPONDENT ATTORNEY (Name, Address and Tel. No.) MARYANN SASAKI, Deputy County Attorney Office of the County Attorney, County of Kaua'i 4444 Rice Street, Suite 220 LrhtLe, Hawaii 96766 Telephone: (808) 24 l -4930 DATE OF HEARINC August 30,2019 HEARINC TIME 9:00 a.m. PREPARING CLERK DEPARTMENT EXHIBIT NO. IDENTIFY NO. CODE PETITIONER iRgspoNoENr lI!oFtazdPztr=o Ld,t'lL-< U!LU Z o!! !J.,] U>z r^ u..l >d.a z ! IF DESCRIPTION OF EXHIBIT DATE R=RETURNED D:DESTROYED OTHER COMMENTS A AIRbnb Evidence Checklist - TVR Inspections dated January 28,2016 B Investigation Report dated January 10,2017 C Zoning Compliance Notice dated January 1 1, 20t1 D Notice of Violation & Order to Pay Fines dated May 23,2017 E Investigation Report dated }llay 23,2017 F Memorandurl re Meeting between Planning Department and Property Owner dated April 12, 20t7 FOR OFFICE USE ONLY PAGE oFl_ \J AlRbnb Evidence Checklist - TVR lnspections TMK: 5g0osoo5 Date: 1tZBl16 I lHomestay I Asingle family or [-J multi-familyorTVR Owner Name: pATRICIA D, MCCONNELL Operation Name:,'THE SONG OF THE JUNGLE" TVR Property Address:4813 ANANALU RD Researched by:Bambi AlRbnb # Site Manager's Name: Contact Phone: Contact Email Address: Was the TVNC & SP #'s listed on AlRbnb? Planning Dept [-l r,rcuc/ TVR permit# / TVNC if any Dept. Taxation cET rarffi ows17o7oa9-01 [_J f neC- Business Registration # lnternet Advertising (list all found ) Personalwebpage {Other vrbo.com/481 1 78 & vrbo.com/130810 Are the TVNC & SP # listed on web?Yes No ly'lJ neal Property Assessment / Classification VACATION RENTAL I I nental Cars- COK DMV (List Licenie S. O.tei Verified? Open - North Shore Special Planning Area dev. plan Comments: Reguirements Attachments/ Exhibit S Version 7 AlRbnb EXHIBIT A lnvestigation Type: RequestI Complaint f, ves[-J r'rolj Yes[-l ruo [-l fl Zoning (ie. VDA, Commercial, Residential) INVESTIGATION REPORl 58005005 DIST: Hanale:.LOC: Wailapa ZONING: O OWNER: MCCONNEI,L, PATRICIA D $LUC DTST: LOG #SfTE ADDR:{813 ANANALU RI) CWNER: NAME: PATRICIA D, MCCONNELL NAME: airbnb ADDR: IO{ ENDLICH DR SAN?A CRUZ, CA 95060 WEB SITE: airbnb "Lani O1i HaIe" WEB SI?E:"The Song of the Jungle'r TransienL accornmodation operation outside of lhe visiLor INSPECTOR; Bambi ARRIVE:DATE: 1110117 DEPART INFORMAL CONTACT: OESCRIPTION OF INVESTIGATION: 1. Research of online website www.airbnb.com found the subject transient accomrnodation: 2. By matching the airbnb's website (hfips:/Arww.airbnb.comlrooms/12622481) and piclures with Pictometry and cross checking the noted parcel with Real Property Division records (Tax Classification - Vacation Rental) , lwas able to determine the Tax Map Key and Property Owner of the transient accommodation operation. rMK 58OO5OO5, PATRICIA D, MCCONNELL EXHIBIT B 3. Research Findi accommodationT on is located outside of the VDA Transient accommodation Useration does not have and active Non-Conformi orana iticableCertificate as a TVR shallsort which offers aofaAdvertis4. KCC Sec 8-17,11 on of a TVR on saidfacie evidence of theconstitute n Found: K.C.C. Sec'8-17.8:5. Violatio rohibited in all areas not d inated as VDATVRs arele fami5l 6. Violation Found: K.C.C. 1.Sec- 8-8.1 b bited outside of theVDA.rations areHomestao / ,o/,tDate'. /Signature: Iteal Property Division ltecorcl I'itgc I ol'l Owner Name/ Type Mailing Address Locatlon Address Tax Classific.tion Neighborhood Code Legal Informatioo Recent Sal6 ln Neichborheell BerenlsdeiitrIrsa Pravioue Parcel Nert Parael Owner and Parcel Information LlYlng Ar€ 164 Retlro- ta -I'taiLssarcLPncE frualHffn-e :.:|: :.fr ,ri.v F :r c t I lr/ tp I MCCONNELL,PATRICIAD / TeOwneT to4 EtlDt tcH DR 5AN-rA CRUZ, CA 95060 .1813 ANANALU RD VACATIOI{ RENTAL 582r'1 LOT 272 RP 71 LC AW r1216:5 0.599 AC DES Today'5 Date Parcel Number Project Name Parcel Map Land Area (acres) Land ar€, (approximate sq tt) Assessment Information ltliM Htdortol atmdtr Total Assess6d value t 709,400$ 709,400 Improvem6nt lnformataon Liylng Ar@ Bedrms,/full Bath/H.lt Bath 1,887 2/lit. Y@r 2017 fax Clarslfication Total Market Value Total E!emption sc 0.599 26,O92 Y@r Built 1993 fotel Nct Tarable' value $ 709,400 Y@r Built 1987 EfiEtive Y@. Built 1 995 Yaar Built r995 EftetlYG YG.r Bullt r 995 VACATION RENTAL Dcicrlptron FRAME UTILITY SHED Other Euilding and Yard lmprovements Quantity 1 Permit Information Sketch BGdl'Ms/f ull B.th/Half B.th Illio Sketctr Building I I Sketch :i.:i ir ii r l r,,1 .' ] PGmit anount $ 61,000 t 30,000 $ 100 t 280 t 168 $ 55.000 15 Drt€ 06t05/2002 06t0512002 09/301r993 09la2/1993 09t0211993 oy2alt9al Pemlt Numbcr 0200000847 0200000845 9310002295 93 l 0004 746 9310004745 25474 Ro16 RENOVATION RELOC^NON P2 DEMOLITION DEMOLITION DWELUNG Sales Information Sale Date Price tnstrument ,, Instrum€nt Type tdstrument D6cription Oate Recorded Oocument # Cert # gook/Page ConveYance T.x Dcument TyP€ 05/01/2004 $ 830,000 04-127502 FEE CONVEYANCE 06l24l2OO4 2016 lri P.ffitr 8t0 Tax Pariod 2016-2 2016-2 Tar Cr€dit5 $000 I 0.00 $ 0.0o t 0.00 t 0.00 $ 0.00 $ 0.00 f 0.00 t 0.00 Amount DUG 13,3r4.77 t 108,00 t 3,422 ']'t current Tax Bill Information Dcsc.lPtlon origintl DUG Drte Real Prop€rty Tar 02/2012417 . TRASH: BASE &/OR COLL FEE 02/20/2017 Tlr bill cmput€d lo OLI?l/lotl Taxaa Aas6rmant | 3,314 77 5000 s 3,3t4.77 SniliIcsd,rl-lrrr I* Poarty t 3,314 77 ' 0.00 I 108 00 t 0.00 i 3,422.7? t 0.00 Interest Other ffi Prrldr-prrti nrsrrrEi tfrrnbrrtit.'di?ro. r.rlal-thr The Kauar County Tax Assessor's Ofiice mak6 every efort to produc€ the m6t accurate Infarmatrs possrble No warGnties, exprssed or,mpled, are provtded for the data herern, rts u* o.,nterpretatron Website Updated: .]aduary 10, 2017 o ,010 6y th. t(d.i ('@oiy Trr A!*sr'! Ollk! I wib.iE d.iitn by i&&lit{d lrttp://qpublicg.qpublic.nct/hi_kauai_displal'.php'/county=hi kauai&KIY=5800500-50000 ltlOl2017 J. 99 t3 16:lt rEl LaXGsRNrrs'rsn US C€nsus Ocd. mey nd malch por€13 erad,y w 'L'il{r + {t.q' -- 3830 o@ @ 20oa.060.l R{eF Odc E . 10,t Et$LlcH DR g$rTA GRUZ. Cl 05GO IIB KtM Cofiy Astro/r Oficr dlo. .6ry .{b.i b ,.o(l*. 6a ipa{ EUrr. i*cfi.tDo po..ril ,,lo r6xlhr. Grgrt.tad d hpaad. 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C\l.;: o ; EC53(oo3 gt o- o *oooo*a +,*,o:ooc 3 -92 oo-ro$C\a lq Ee5I 6x 5 t g I E ; t il III R ait I.t oL! fI !I I T '{ .! ,., g IiIIi I I a H I qJ OL H* - BdEs ,n t"r* ar fiil.,ci - wr.rdorr tt*srct f,slo.u D.w*kd b, eqr*, ol (il.1 http, dtnb,c@ Ommor*ro,. lgrtrknrro... l$rt.tr*o"... l'go".",ro... l'gs**c*... l.3c"*ctuno I K*i,{s...| "* co,r:clE... I 3x.r-orur | "-L*onqg6lc9.(r},..rt 'I v Et, - 2.cc - 5.rety - ledr. f) - " ) Ka u a'i Listing Location ' 'rtr) ) $245 Por Nrshr Requcctto Book r TMK: saoosoos lnvestigation Type: Request Complaint f Date: 1l21l16 V single family or Llrulti-family t-- Homestay or TVR Owner Name: pATRICIA D. TVICCONNELL Operation Name:"THE SONG OF THE JUNGLE" TVR Property Address: 4813 ANANALU RD Researched by:Bambi AlRbnb # Site Manager's Name: Contact Phone: Contact Email Address: Was the ryNC & SP #'s listed on AlRbnb?Ye No 0w51707089-01 vrbo.com/481 178 & vrbo.com/130810 # Plannin g Dept lnternet Advertisin list all found NCUC/ TVR permit# / TVNC if an Dept. Taxation BREG- Business Registration { Personal webpage Other Yes ,/VACATION RENTAL Are the TVNC & SP # listed on web? Real Property Assessment / Classification Rental Cars- COK DMV (List License & Date) No Open - North Shore Special Planning Area dev. plan Comments Ye Verified? Requirements Attachments/ Exhibit f Zoning (ie. VDA, Commercial, Residential) Vcrsion 7 AIRbnb AlRbnb Evidence Checklist - TVR lnspections crrf rnr[y] No I,agc I trl'l n.4at S.la In i.Lhborlrdd l6ts.ld ln rd OwnET I{.mC MCCONNEL|,PATRICIA LI Mairins addrcss ;?ifi'?il? ?l nrouo Locatlon Addr6s 4813 aNANALU RD Trx ClaBslflotlon VACATION RENTAL Prdi.ous Parel Xa{ PrrcC Owner and Parcel Infotmation Today's Date Parcel Number Projact Namc Parcel MaP Land Area (acr6) l,and A.et (.pproxlmatc sq ft) Assessment Information t{EnEfdlr.frf{3sl. $ 749,1 00 $ 749,100 Improvemnt lnformation livlng Ar@ lcdrcms,/Full grth./Hall trth r.887 212/0 Ertr|.[-fr-fta|asr.Irtlrrt Lol l5.rr. lanuary 27, 20r6 580050050000 .I HE SONG O; THE ]UNCLE" TVR shm Prc6l MrpJ nGlghborhood Cod. 5821 1 Laeal tntomition LOT 272 RP 7194 LC aW 1r216.5 0.599 AC DES Totrl Ermption $0 0 599 26,O92 Ycrr Euilt 1993 Total Net T.x.blc v6luG $ 749,100 Yar 20r6 T,x Clarsitiatiod Total Market V.lue Tot!l Acaersed value Yer Built l98/ E''6tiY€ Yar Built 1995 Y@r Bullt 1995 Crr6tlvc Ycar Built t995 VACATION RENTAL DGriPtion FRAME UTILIT} SHED Other Suilding and Yard Improvemsta Quantity 1 Permit Information Living Arca BGdrooms/Full Aath/Hrlt B€th tirl0 Sketch Sketch Eurldrng 1 I Sketch Skelch Building 2 | Ara DatG 06/0s/2002 06l05/2002 091301199) 09l02/r993 09/02/1993 ay2al19a7 Pmn t{umbs 0200000847 0200000845 93 10002295 9310004746 93 I 0004745 254?4 Ruil RENOVATION nrlcicrnon ?2 DEMOLINON DEMOTITION DWELUNG Pcmlt Am@nt I 51,000 t 30,000 t 100 $ 280 t 168 $ 66,000 Srl€ Oate PrlcG lnrtrumant ,' Instrumant fypG Instrumcnt Dc$rlptlon DatG Rctrded OocumGnt, Cert t AooL/PagG Conveyance Tax Dcsmsnt Typ€ 06/0r/2001 t 830,ooo 04.127502 FrE coNvEYANcE 06/24/2004 830 Current Yax Bill lnf*matlon r.x pcriod D6crrpdon "',ilt*?L ^*tjlff"*2015-2 Real Property Tar 0212012Ot6 t 1,162 99 2Ot5-2 'TRASH FEE" O2l2Ol2OL6 S 0 00 rlx blll cmputod to 01/1112016 I 3.162 99 Irllrlrrnrr aar-*rrElllr .,I,i." lr"l p.n.ny $ 0.00 $ 1,162 99 t 0.00 l0o0 t10800 t0.00 I 0 00 $ 1.270 99 t 0.00 Intffit J000 ,000 t000 Oth€r I 0.00 t 0.00 $ 0.00 Amount Du€ $ 3,162.99 $ 108.00 t 3,270 99 Ricant Sala in ildghborhood REdt SrlGr in Ars PIffiosllilrll llrxl P..cal Raturn to lllln Sarch Paoc Xruai Homa Th€ (auai County Tar As*s's Ofiice ruk6 every efftrt to prodwe the m6t Murate informatron 9G$ble. No warrant€s, exored or lmplied, Ere groYided for the data herern, tts use or rnterpretattr. weBte Updatd: ,anuary 6, 2015 cart& kdcq ln -drfti!fi.brrb!dEtl.a f,irI http:r,'qpublie9.qpublic.nct4ri kauai .displar php'lcountr'=hi kauai&KHY.58(X)5(X)50(XX)I 27',2016 ",r u I : *IIIa ; , i I I I{ /I 1oit 'q ai ,,..Iroi,ir l,$ Ol : t I l) t h ts I 1 L ,( { I,{ 9 l \l ll ilr si, r ,a fj { {I t ! ) it .rl {j $j f It II I Ir,;!,i lt: ^! I ! a ,\ "\ \ 1q g s R L\ $ It I 6 I ,! H f Y { t ; a iI I t t i :.'':.i'!.i g $liltr :!' ,r6 It &d ii *$ o t (,, I I \ I l" i;ii ir 1q /19I q I ,1 : oN -6po -------dtfi a:--drt-d7lt uI' n '.."1t{L-J i ) { ( l1- a ! t I IIi,3l *, { I 'lr i,{i'ji{ \i ni "..,1 i{i\ t (lt + ir il {o o n \\ \\ i'; Irt, .J I : (IIt I$ !ildiE EEIIEEE oErErsE EH E* 1 a I 6i B a F tI ooF ?IIq<Jrs it : riti iri' !l ili $i* (J azoN 5o aI : I 1 1_ , i II a I I l irr l.icc:nsc Suaruh - [)o I ar l'agc I ol'2 ft Department of Taxation (http://tax.hawaii.gov) Tax License Search Hawaii Department of Taxation License Details Taxpayer Name: PATRICIA D. McCONNELL DBA Name: Taxpayer lD: w51707089-01 Former Taxpayer ID: Business Location: Tax Type: Transient Accommodations Tax Status. Closed Business Began: 07t01t2007 C Back to Results (searchResults) Q, New Search (app) Tax License Search Hawai'i Department of Taxation Deoartment of Taxation (htto.//www hawaii.oov/tax) State of Hawaii (http://www.hawait.oov) Terms of Use {htto:t/oo(al ehawaii.oov^erms{f-use html) Privacv Policv lhtto.//oortal.ehawaia.oov/orivacy-oolicv.html) Contact lnfo (htto:/lwww6.hawaii.oovnax/a8 contad.htm) Feedback (htto.//oortal ehawaii.oov/feedback html?aoolicationld='!09) Copyright @ 2013 State of Hawai'i. All rights reserved. Powered by e{howoi i . gov} (http: //hic. ehowoi i . gov) https:i1(l()ta\-cha\\ ai i.go\ /tlsidctai ls'lintlcx:5 5 l,'28,',20 I 6 'l ax l.iccnst Sctrch - [)o.l ar l)agc I ol'2 $ Department of Taxation (http.//tax hawaii.gov) Tax License Search Hawaii Department of Taxation License Details Taxpayer Name: PATRICIA D. MCCONNELL DBA Name: Taxpayer lD. w51707089-02 Former Taxpayer lD. Busrness Location: Tax Type: General Excise and Use Tax Status: Open Business Began. 12104t2015 C Back to Results (searchResults) Q, New Search (app) Tax License Search Hawai'i Department of Taxation Deoartment ot Tax;tion (htto:/Al/ww.hawaii.oov/tax) State of Hawaii thttD,//www hawali.oov) Terms of Use {http.lloortal ehawaai.oov/terms{luse.html) Privacy Policv (htlp://portal.eha,vaii.oovionvacv-oolicv.html) Contact lnfo (http /lrww6 hawait.oov/tara8 contracl.htm) Feedback (ht1p://oortal.ehau€ri oovfeedbacfi.html?aoolicationld=109) Copyright O 2013 State of Hawai'i All rights reserved. Powered by: e{howoii. gov} (http://hic.ehowoii. gov) https:,/r'dotax.chau ai i. gov/tlsldctails?indcr. 56 l,'2tt, 2() r 6 VRBO toghr ,t*v ttllo{Prqirq, https ://wu,rv.vrbo.com/48 I I 78 0s,O I doit lm da. ti liE S.rrd: O$uo Sea Turtle Cottaqe Ovcrrf* *,a6fr 9e Cdanalr lr(doo Orrcr ldo Pt$ta ."*i br t$.z.i.,a-tf.a trydor*rlm 33 *: forf dr cora.?3roto t/RSri g.t ,inarlrrde LeoBn 3* 5}/c s tnyf,rstt(' i-rsr 9..|. L4qr idrDfl B4r.ty tyr M (hE? ujltf,rc: E{7 lxrlr: &1r* utta e t tJ *rsgoaaatirt frrrlarlsr RsgEa ra. fiIh cw4r,atr!,d iu}jll',f, Jw*,tnt* fh-drrr Lr* lr${r** trJ&rur*r t.r s' :.i : ,* ItI Cr- I t r) I l *l I ,f .il hll-,$ .C t ltt l! -.t [.,tt'lT*flr r q i "i W . ,r", tt" tt,:i i. | , l' , Ttrrs vert 6p.tsta'tfe*hc4r'c tt,/lc cattage r",ll fjAt'€ r'O! fA',r.g rfi Cre t8ti a 5de :{ Hae{a r!,.c:f k€l rnvmore I+,lthoughrnodcrnandbcrutfultyarcrtr<tred ltoffcrttt.tJuiglcept3vc,u Evcnyiarrn,dawfe*cks out to trogcal I'ush bcauty. A wrap air.aurd r,r:r?e{\ed amr 6}/€r'rocrkng ual'c'? and tt}oufirill{' pr(rr''ds, t$rc gcrfect aettrng fcr rorylanttr cljcffr,g drn,rg or rrlrrrrh4g (offce End lungie t.o,flg b'rd r*ucrng, Thc llrfic krtchcflctta rc x'ell rr.rppliad wrth rtay d h€rr€ cf}rt*{:.&q,n rn}nd ,q.ri the rY}61 arntztng nofth th6re bcach.cc as well aa th. fa{r}ous Kr,lrhu Trr}r a.e mcrc n.trr,Jtcs crrray tnd if yo* want to fcci r liGla rdvcrtlrrous yoL, crn *.a{k to Ht: rrvsr for an tven ng dip rn the &r/redt cffrmrrurq holc, Takc your c!{ncra b*cauet th+ riucr tirde !r. b.ruhfid. 6.rt of dl rs thr bg c€rr*y krrq bcd md ttlc etrr g.zrng llqy'€ftt lbovc rou. tl,ornla*t y., r!9{Et TAT Wo26.58273-AL Why VRBO &f,d to.r7 bcrt vrcrl,m r*r F.ar, o.er I mill,c,r rertals ..-."rld.',ft 6ooL rith corr#&rrr Feisr ard zqls,t yc{t fla-f cr*.F dn conftmr oJ tlld.el E1tc.,. th€ trccd>r at a r'-catiot ranl-l ar*rorrli red cre.ri.ffa. lrcr-: srl,-re i& !,( .tLatta'l Propcrty Typ. Ccttrgc 5@:q ft, lccornarodililrn Typc vacrtlofi Rentrl LG.fr Gucctr Prsyldc Ttrcrr Own Mcdr (}l|rltc AcrviGc- lfouoct{.cper @irl.d lsrritlbetrty Chrtdrcn Wclcomc 8cdrooru, 0 ehdroorn6, Slccpe 2, dsfq 2 Bcdrpoon 1: 1 kvrg Cottrgc rrrtfr t(mq bcd Brtlrroornr: I E throo{n B*hrrrom t: to{ict. 8t}oryar. Ercfic trger.vood rtrorrcr lnd brttlroo.n Gnclc.sad b"* h.Irlt rrla ttc flo* af th! ,,rflg$c Er*(rrltsanmcrrt 8ool.s OVD fiaycr TlEr"r Advcnturc a$dgct Awny Frofl lt All lftlrr.*iorrt B&lnierl Gardcn Churdrec tt rltfy'Scrr6y 59. t-ocal llcr-rraccr I ArraltE t6 ATlUBank Gro<crr(}5 lrtc.r*r fcl,rrfiGr Antqurn{, Bca<frornHnC Brd lvrtcrl.ng Boatrrg eco Torrnirn lJb.u-Y l.lrarnt P{qgtatad rtocgral }lasso. Tf€raptst tEta5.ci R drrC t!tr.E t+f}lrtstE Gdf Paddtc Boetlng Sccnk Dnvcs Spqt6 & Actrvrtier To{rr6t Att adrcars Rrcrcrtrdl Ccntct R.f,ta,rr'rts r'rcmc P!flas Mcd'ca.l Strvrccc ShrtIrp Stl€p{ing tcr&b^g r^fid! rt4dlino Snoddtn€./Drving Sornd/Bey F,ehdrO fudtJ,lkiag Sud Fr6}xn9 Sr.trfine 9totrvmng win+*tfirq l-oc.l,ofl Typc l.lortril Yiai W f AArcr*rtclffic. Cyd*q l.rt*)rqg Dccpcca Frchrng ,tlorrtdn &klrn Freiuog ito.rTttn drrntlng ' Fly Fl.hrng P.?.glid!fi,g frcehrr.tcr Fr.hino ParEa*rinf Hrlgag 5ar!*9 Hrtrtrn€ tc,ti6E dvvta or s*''io.kat,Ig Jct S|airg *od<Arrg Rura , .i.6,E DanaT|O D,r rn g:&nrr{ Arca Scrtrrrg fq 4 WOlc irei:<rcl Cl.dtcr Dryer Hair Drycr lrtcfflet Xifdrar Crfte.M*cr t)$tlcs e ltrcrsr{c :.'.:a', '" l(tdl.nl (}rtrille &cyclcs 6,d;I Ovm:: -: - Prrt y ltltn' R*$cralg': Y,at*. I t"xtot'. '.. ... : '<: . ,: t-urar / Gazcbo Ltwn / Gardqt Oddoor Ciflll tfrrtcr Sports G.a s{r*t*C@ l-{ou6cl(repcr O$tmel Revrews 4.5 ffi from 13 traveler rflieu,s \'trlx a t?i ?,\ Exotic jurygle sanctuary ****t I travel to Kauir a co{rp€ !,ft€s a year and tirs rs oae d my favoctle fpot6 so far, Its seauded but doae to llanare'. nrcely furniafed, end surroundcd by a lush prqle prcrrcltl Il'6. m.grcd tracc, Tha re6 turtle o'erlookcd thc lunglc valley, was cozy aod ciean, ard I :uct fe{t well ta}cr, carc o{ a g+cct ov*rall" I dar.'t trelally wntG rev:ews but I iusn t.arted ts errygr. mt t.&s for a greal tac:lti'ta, I raq't.'ilart lo .;rfirc ba(*- Crr;r*!,* 2ItLs t-trrlocrbr 27, mr,l5 frc* fi30 frcmdd fgr Drofr *rh i,gb'li:,rr, gghit .ltre, {tdt g*r,nrl dlGn.rl..rkr"r ACc !5- F!fil.nqt efirlry, Faa?i],ag drdi faarrfgfS rE ttr rrritu irct'u:r t r'eE O l+r !rc:h 5en Fr,r*txo cA.rugt l.lBy 2(,16 March 2(}16 Iurrc 2O16 ,anuary 2(}to February 201Ci + ( lait:I-t (1a i t-+ {9r, g) tt, $tr fH }n April 2C16 *rt I ta tr rx lR $a ?:t ,4 ,5 '6 2' t3 11 r5 a7 ,a 2q 30 3l s *) rl, s lx trt $l 6' 3 lo L' 24 .1 ll .'tal ,5 t4 2l ,a rn I a t5 77 ,q SA 2 I l6 7a 10 tl.r 3 lo t, wll 1 ll t6 ,5 lrr 5 ,, t9 26 fL 6 l3 20 27 t4 5 t, l9 7G 6 t3 20 a, , la ,t 7A TE I a r5 7' 2q ttt , I l6 ,a 30 ,L 3 l(, l, 24 rt *+ ,6 6 a II t8 ,5 78 ,2 ,et{ l+ 9rI}tbffil}t 3r, x) t? a9 It t6 )& $it -{t r u Locatton 56 t) l:, 26 )7 Go Sh ,<, 3(} 3t llrg ,4 Q, '.el' Fz,{* Trmdui E+arrt+stg ,Lar.f,t Airport Lllttr€ Arrlott Xc..rft Got{ Pdn(eviik 4, Hlles llcarcat Barp.rb 3 Niles icar.n lotorury Xuhro I l.tlles lqul.r?w Xc..cri Ferry Itarrilirtli 45 },liles Xcarert lcatilrilf 2 Hll€' Ledtterrao€an crourrn€{ Ourner Mernber srnce: 2OO7 Speaks: English Send email Response time Response rate Calendar last updated Within a few hours 8Oo/o oL/ 2s/ 2Ot6 J snon phone number Ii F FPI ffi llverview Photos R€vt€ws ,{ates Cal€nda 1-p(it,qn Qwner Info ', l r .f , rl ix c h el '.- si ^t # I i -\iIIf i, /<? tt*-; J E'i lj : l q.lPt =r lr{L4 t\ tI I I u$ II BJtothr hnql:hkrg -; I - -,-.1 r€ t * !', r-!r- gg_, 'tM..w mid * {\lr ldBi,!he / r]/ Hf,# Fk I '/, ffi rrrid tt0rririo ,Qri$* tlElei- r.kF, slvxd, ,r!,riJ,)s.{l drLl.r, !lhv.F. VRBO #t181178 This li*ing was first published here in 2013, Date last modified - Tuesday, lanuary 26, 2016 ( f., I irir-j,l: li I i:l i r: li, h tt http ://www.vrbo.cclnr/ I 308 I 0 0t 128116 Secluded Hillside Abode with Unobstructed Jungie and Valley Vrews bntl.r, {onh Sh@, Hrw.rr r.dv, ' hF &r&als:! 'ratd '1195 T' !r tu ,^ rd.d qd. hr*...4a* utu'q'tu-6&d6wdrc&l*n tu. M Iinimum rt.yr I nternct: Pcta coaa&lscdr Utccl chair rcccdhlcl ,l nrghts Yet VRBO C-D @ !r!r{ ldr{ kl4brr Fll d FnFdu G h. ;t*-li*+i.--l , ;l;t'iiv, ti',(I: i,,1, .. Th. Song of th. Jungl€ is bu{lt high up on thc hi!l$d. that ovarlookr tha runglas. mountllns and vrliay. tt 16 !t tocatcd ,t the Gnd of r county llnc rnd rr raroundcd by thoutrnd3 ot !<r.6 of troplcll rornfiorast !t It 1,/4 milG oF thG matn road so li rrac of trdTl< nolsa rno thc acncial hum of paopla noita. Yo! crn hear tha rlvar balow , tha ocaan wtvG3 brOaklng and tha Jungla rcng blrd3. Tha Song of tha JunglG ti radud.d , prtvrts and very qui€t. Ir is 6n ohanr' cott ga unit bullt rt thc far stda of tha mrtn hou'. ro t3 tuckad !tray, rtfa and cr,3y. It h't lt'r ot{n antranca lnal Prlvrcy lndudlno prlv.t. glrdan r[a3. It looka out orto tha JurEl., garr,anr uid a]rtarulva umbstrudad mountlln and vrllry vl.wr. lt i3 ld.al br onc or t!.vo pGrion or r flmlly yvfth r drlld. It lr comPn..d of tbcxn 10m !q ft cnd har 6orrr roomr plut 2 kirlir. Thar. i3 a lrgo brdroom/rtttlrB !rt. wlth ! qua.n b.d. Fr.nch doort l.ad toryl tha badroo.n ot.c onto r n?.rat andoaad t nrl th& ovarlooks tha vrllay lnd rungla' Thls anclomd lrn.t h!6 a illtro tlui for romrnttc dlnlng lnd d.yb.d fior thot r,yho wtrh to d..P wrtchlng ttr. rt rt. Th. kttch.n rr.a 13 rfl.dium rlad w{th a full frldgn, h@l.t lnd to.rt r ovxl. lt hat !n .ndorld outdoor lu'ru !ru. !t wall wtn r BBQ lrd propam cook rtoya/ovan. Tha hdoor bathroom hat r Showal but no tub, Thar. l| ,lso ! privat ly locrt d orrtdoor Ogarf,lod strmet ln th.glrdan rr.!' Thc ktEhrfl lookt out onto tha axtanttva galdan tral. Th. 'Song' 13 l1a mll. from r groc.ry ;tor. hub, !t rhl glrl t k.out, 91ft *ora rnd baacfifront. The Song of tl|. lunglr ls ! qsLt tnd p..drrl world Bi.t llvr. up to lts nattl.. You wrk. up to ! ryrnphory of tropkll birdt mlngld witr th. dlstar* r.xrMr of th. rly.r b.lof, cnd tn. o.atn r{tvs bnoklng . Thr rnlcord lanlt lt r wonrtrrful dac. to injoy your momlng b...kfatt 3urroun&d by thr trodc.l gErdafir rrd unobrtn {t d mot,rt ln rnd valby vl.rYt wh.m whlt .gr.tr glld! mld3t thc P.lrm, A 1/{ mtla walk down tha county lrna tak.3 yOU to Uta cornar grocry dor. , aJshl glrl takrrut' lnd b.rudful Wllntha Ba.ch. A quH drsr. or . 20-30 minw. wDlk wtll g.t ydi to 3om. ot th. b.!t b.!dr.! ln th. wortd: Tunndr, Xa'a, Lumrhlf! ar w.ll !a thr famour h{aLLu Trrll. Thrx mllB !w!y It ll.illd totf,n whrr. chopplng, th. r.ttaurrnts, lnd .v.n a lltda nlght a{ton Grn ba found ln a @ry baodltown .tmo.ph.r.. Thlr proP.fty lr r hom.stlY. t9/t81 TAT hr02658273-01 Kayworcl3: hvlta ,ungla Ohrna w{rt rwcso.TL ralnlorcd lnd mountrln vle}'rg Prop..ty Typ. Bunglrlos StlO 3q. Q. Ac.omdrod.tion Typ{ Vaeatlon P'..tal x.r}| Gsdtr Provl& Trrdr Orrn Flcolr ooita Earvlca. Houxkaapar O*lonll l.1!3r!g! Suitrbillty Childr.n W.kom r5n Srnoklrg Onty P.tt t{ot Allo*.d wh.dcr[lr Acc.tclbla ledroonrr: 1 Eadroom, sl-pt 3, 8.dt for 3 Badrodn I slrPlno Ln.i: I tldn/ 1'l0h Tlrar. ir ! t*tn day bad h U,!.dldo.- ldr.i 3nEr qt l dt Od (l), Dorroar ldl (1) s,Ittll &uU. b.d ln k td.'l ril, E b, Crib (11 lloE out crlbl Pl.yP.n Oth.r A,'roiti6 Tha propartii i3 ! callcd !n Ohana Eungalo which in H!#aii 19 simrlar to a moth€r ln lar, unlt. lt functlont compl€taly on its own tiough rnd saparata from thc riain portion of fha hom.. It i5 6t thr back portior: of the mrln horfte io hag rtl own ancloSad lanrr tL, 15'arall a3 lts own grrd€n arca, bbq araa, outdoor thowar and wlshar and dryar Entart inmGra OvO Play.r 5!t llit. / c.bl. Thom. Advcntura Away Frorr It All Attr.diont Botrnlcal Garoan Churchs3 Clnrmrt Local sG{Yio* t Suairanar ATFr/8rnk Groccdai Lrigrr Activiticr Arillqul(,!9 B..cfic6r',btng 8lrd watching Bo.ung Eco Touri3rn Locatioo Typo Hountrln Viar{ Spo.t f Adrrrrtrr. Advttir Cyclint D..p..! Rthhg Flrhlng Fr..hw*ar n.hlng @rl Hlking J.t S{lng XayoUr.be Talavl3lon vcn R.oma./tk SporB e Activtti.. H.rlth/8.rrry 5p. Ub..ry i4!r|nr Hodpltrl Mlrlaer Thcr.plst Horxb.d( Rdlng Llrut HinlGirra Golf Pr.rdt Boring Scnlc Drlva3 Rur!l mountlln Biklng Mount in cllmblng Hdlrt tn-dng Por!0,idlng hr! dling Rrftn9 tod( Oimung s!lllng Vldco Ubr.ry Tourlst Attractlons Pl!yground Rart6ur!nts Medical sarvlc.i Sh.lllng Shopplng Sight S.Ci69 W.lklm Wh.l. Wrtchlng wldlif. Vl.win0 S.rrb! Olvhg Or Snork.lhg Snork.llng Snort(.lln9/Uvhg SoundlBcy Flrning +dunklng surfirtg SwlmmlrB Wlnd-5urflng Dlnlng Dlning:s.dng lor 4 pooPl! Out id. Blcyd€. D*k / Patb: Ltnai I Glzcbo: Galf : lrr,Yn l6.rdon Outdoor Grlll Outdoor 6rlll Ga5K.yak I Crno.: I{evi€iws .{.4 ffff* C?om 20 tr.vrlrr rrYirwl P6rkl^9 For RV/Bo.trf r.ilGr falaphon. Wathlng Flachln.; Prntry lttrni r(-c Rafrlgsratot Stov. lor'fi.( P!tlo ,tw.,! 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Ilon't forgrct yorr vacallon protoctlon! Get protected nosr Addlng our Vacation prctection services can make sure y6{rr getaway goer crnoothly, no rnittter vrhrt. We offer Cancellatioo Prot€{ilon, Carefree Rental Guarantee, and Oamage Protection 5t} you can trulY relax. g protecr yo{Ir payments in case M Guarantee the rental me€t5 [ Ensure you'rc prep,dred in case - yo, need to cancel. your expeclattons. - of accidental damage. 5rJ rao i r:[)ru;]ry 1r; i b r;j\t (rtj(larttd - ,' : .' 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Lft.l fadE ra 2 ffi6 tt dtrfan r Gorrtnat ( ,nh ,o.a, lu'.u ) !'..,,rt'! ,s) Overylelfl Rsliews Rates Calenaa{ L0fatr0n Or"rs l*fi Phot0s 0wner info Yeir P$!dBcd! 2004 f&on &c ornen .l movd t0 Kiua, m$ rry dar.$na n 2004 fN kdh reron, tly hrilth greasy mpoved ( (en u good for tlut) rd my da$iler ffflt bad t0 the mdnhnd h univasty. This lurne searnd a ht hg for rc alorc so I began $anng n f,[h travelers , gues h0use $yle, I rErl am Uesd ts rE€t amaang peopb from dl around tlr wsld. Peryle rrio dose th6 pla{e teld t0 be uuql€, gatdf rerle rtu fit into ttrc locd dmocphcre vith ease and grace. It hrs been a lot d fun for rne. mt 0E ofrltr chorc tlanalel: I rxrrer &ose a vacatl00 refitd hoxefsr I dtoct t E h0(6e hele be(ause I am a wryld tnvdls and &n flace rs ure of tlre m0st amathg places, on many lerels , ftat I hate e{K0r.mtered in my l,fe. [s tt]e bcals sy, lt has' good mafla' TIE U& lrrrcfrr al tidr ilr$r: I am a nflte{ aod a pfffographer ,Ihe posstht{ret are d rrlU ca be ciptued on ftlm and h ilords rrfe are , eo& day, mdcsly, trflEles$y fre$. Ihe o{tan, SE Jstgl€ md fE nyers ae all f{lt tiefe. Atld 0rc redtrer, rell, tretty &rn e0sy to hke, Cmlrclr sgerts Engkh C[d Here to sce AII iry Renhl tisting - . ,. :. $195 Save to my favontes Om€r ileinbr since: 1007 Se1d email Resffns€ trme Within l2 ho{trs Re$onse rate r"aiendar Eq uF*ed oli t5l1016 rl strox phone number {10'rit Get an ifflant quote a, '.",\,$ : . ). r s ot idc r.m rond !d,l F{d} I - r,*.," -..1,q.r Lne ffi rd"} a . ..1E&Jrd I t 'L I I I id#'Ei.* j'i'-,'' 'a' i.d it : l' /t ryt :. t'! l.r' vRao #l}dl8to This listing ',.las first puhlished h'ere in 2O07. Date last rnodrfiled - Thursday, January ?fl, 2&16 ftH L -r-- 'ttr . "ifr'ff{ & t.daaaH Andres Emayo From: Sent: To: Craig Arzadon Thursday, May 07, 2015 11:40 AM Andres Emayo TMK s-8-00s 005Subject: htto:/lwww.vrbo.com/481178 This a link from VRBO for the Round hexagon unit on her property htto:/lwww.vrbo.com/130810 This a link to the main house from VRBO. Thank you, C.raig kzadon Real Estate Appraisal ll County of Kauai- Finance Division Real Property Assesment Divion carzadon@kauai.ggy 808-241-4231 CONflOfl{TlAl COMMITNICATI(}N: Thi\ messats (and any altarhments} ii int€nded only for the ure ot the deliBnated recipient named above. It the r*ader of thi! message it not lhe intended re(ipt€nt, you aro hereby notitied that you have received this dorum€nt tn errot, and that any ;evtew, dissemination, diJtrlbution o( copyirtg, o{ this morilge is stnctly prohibned. ll you receive this communication rn error, please nolrfy us rnrmedrately by telt'phonc and delete thls message and any attachmentr. MAHAto. I f Bernard P. Carvalho, .Ir. N{ayor Wallace G. Rczcntes, Jr. illanaging [)irccior Michael A. Director of Ka':lina S. Hull f)cpuq' f)ircctor of Planning PLANNING DEPARTII{ENT Enforcement Division County of Kaua'i, State of Ha*'ai'i 1.144 Rice Srruct. Surte A-l?i. Lihu'e. Harvri'i 96766 TEL i808) l.l l-.r0i0 t"A-\ (808i 2.1 r -6699 ZONIN(; CONTPLTANCB NOTICE c[,R]'rFuir)IJAlll I I 2rI7 P:rtricia D. NlcConnell l0-1 lindlich Dr'. Santa Cruz, CA 95060 StiBJIIC'I': Zoning Violation for Transient Accommodation Use at: .l8l3 r\nnnalu ltd TMK: 5-8-005:005 The Plaming Department conducted an investigation of fie subject property and found the establishment 01'a 'r,acation rental r.rperation. This is considered a violation of the following provisions of thc Conrprehensivr' Zoning Ordinance. Chapter 8. Kaua'i Countl,' Code. 1987, as Arnended (C7.Cr): ORDINT\NCE and VI0L.i\TIONS 1. Section 8-8.1(b) General Provisions for Homestays tlrtmesttty'ope ruliotts ura prohihited outside af the L'i.sitor Destirtulion Arect (VD,4) 2. Section 8-17.8 Singlc Family'Transicnt Yacation llentals. Nottyitlulonding etny' unclerll,ing zrsning clesignalion uncl witlt the exception of properties on the i'rtational or Stctte Register of lltstori<: Plcces, single family transient vctcctlion rentals are prohibited in all oreas ,'tot designurecl as llisitar Destination Areas, Violation: Thc unauthorized use of the subject proper3_v for Tr:rnsient Accommodation outside of the designatcd Visitor Designation Area conslitutes a l'iolation. ,MPPY EXHIBIT C \ \.1' Pursuant to Chapter 8, Kaua'i Countv Code, you are directed to comply with the follorving requirements immediately: 1, Cease and desist the use of the subject properfu' as a Transient Accomnrodation(s); 2. Cancel all Transient Accommodations commitments for the propert-v. Please t-rnd attaehed County Ordinance No. 1002 for your reference. Including but not limited to Section 8-17.8 cited above, Ordinance No. 904 specifically regulates the use and prohibition of homestays on Kauai. (Chapter 8, Kaua'i County Code, 1987, as amended). Purstunt to County Ordinance No. 919 (also attached), any'violation(s) of the Comprehensive Zoning Ordinance (CZO) may,result in a fine of up to $10,000.00 an#or up to $10,000,00 per day, should the violation(s) persist. (Chapter 8, Kaua'i County Code, 1987, as arnended). Please contact tire Plaming Departmenl at241-4051, or email Bambi Einayo of my staff at aemayo@kauai.gov, within 14 calendar days upon receipt of this letter to provide an acknowledgement of the termination of the subject TVR. Failure to do so provides us w'ith no other altemative but to pursue enforcement action, Dcputy Director of Planning County Attomey Attachments f Bernard P. Carvalho, .Ir. N{ayor Wallace G. Rczcntes, Jr. illanaging [)irccior Michael A. Director of Ka':lina S. Hull f)cpuq' f)ircctor of Planning PLANNING DEPARTII{ENT Enforcement Division County of Kaua'i, State of Ha*'ai'i 1.144 Rice Srruct. Surte A-l?i. Lihu'e. Harvri'i 96766 TEL i808) l.l l-.r0i0 t"A-\ (808i 2.1 r -6699 ZONIN(; CONTPLTANCB NOTICE c[,R]'rFuir)IJAlll I I 2rI7 P:rtricia D. NlcConnell l0-1 lindlich Dr'. Santa Cruz, CA 95060 StiBJIIC'I': Zoning Violation for Transient Accommodation Use at: .l8l3 r\nnnalu ltd TMK: 5-8-005:005 The Plaming Department conducted an investigation of fie subject property and found the establishment 01'a 'r,acation rental r.rperation. This is considered a violation of the following provisions of thc Conrprehensivr' Zoning Ordinance. Chapter 8. Kaua'i Countl,' Code. 1987, as Arnended (C7.Cr): ORDINT\NCE and VI0L.i\TIONS 1. Section 8-8.1(b) General Provisions for Homestays tlrtmesttty'ope ruliotts ura prohihited outside af the L'i.sitor Destirtulion Arect (VD,4) 2. Section 8-17.8 Singlc Family'Transicnt Yacation llentals. Nottyitlulonding etny' unclerll,ing zrsning clesignalion uncl witlt the exception of properties on the i'rtational or Stctte Register of lltstori<: Plcces, single family transient vctcctlion rentals are prohibited in all oreas ,'tot designurecl as llisitar Destination Areas, Violation: Thc unauthorized use of the subject proper3_v for Tr:rnsient Accommodation outside of the designatcd Visitor Designation Area conslitutes a l'iolation. ,MPPY EXHIBIT C \ \.1' Pursuant to Chapter 8, Kaua'i Countv Code, you are directed to comply with the follorving requirements immediately: 1, Cease and desist the use of the subject properfu' as a Transient Accomnrodation(s); 2. Cancel all Transient Accommodations commitments for the propert-v. Please t-rnd attaehed County Ordinance No. 1002 for your reference. Including but not limited to Section 8-17.8 cited above, Ordinance No. 904 specifically regulates the use and prohibition of homestays on Kauai. (Chapter 8, Kaua'i County Code, 1987, as amended). Purstunt to County Ordinance No. 919 (also attached), any'violation(s) of the Comprehensive Zoning Ordinance (CZO) may,result in a fine of up to $10,000.00 an#or up to $10,000,00 per day, should the violation(s) persist. (Chapter 8, Kaua'i County Code, 1987, as arnended). Please contact tire Plaming Departmenl at241-4051, or email Bambi Einayo of my staff at aemayo@kauai.gov, within 14 calendar days upon receipt of this letter to provide an acknowledgement of the termination of the subject TVR. Failure to do so provides us w'ith no other altemative but to pursue enforcement action, Dcputy Director of Planning County Attomey Attachments Bernard P. Can alho, Jr. Itlayor Wallace G. Rezcntes, Jr fvlanaging Dircctor CERTII-IED IVIAIL Pnlricia D. l{cConnell l0{ Endliclt l)r. Santn Cruz, CA 95060 PLANNING DEPARTI\I EI.IT Enforcement Division County of Kaua'i, State of Harvai'i 41.14 Rice Sreet, Suite A-471. l.ihu'c, llarvai'i 9(1766 IEL (808) 2.{ l-{050 F"\X (808) 24 l-6699 llich:rel A. Director of Ka'*ina S. Hull Dcputy Director ol Planning tlAY 2 3 20tl NOTTCE OF VIOLATION & ORDEII TO PAY FINES Patriciir D. NlcConnell -1813 Ananalu Rd. Hanalei, HI 96714 SUS.IECT: Zoning Violation for Transient Accommoclation Use at: 48t3 Ananalu Rd TMK: 5-8-005:005 On March 3l, 2017. you received lhe Department's Zoning Cornpliance Notice (ZCN). The ZCN instructecl you to imnrediately Cease and Desist the use ot' thc subject property tbr transient acconrmodations. You rvere inslructed to cancel all transient accornmotlation commitnrents lbr lhe properl.y. On April 12,2017. the Department met rr.ith yrou (Patricia N'lcConr]ell), o\vner and admitristrator of the transient accommodation operation. J'he Planning Departnrent confirured that the continucd transient accor:rmodation operation (Homestay) use at the subject property is a violation of the Comlrrshsnsive Zoning Ordinance, Chapter 8. Kaua'i Cor:ntv Code. 1987. as Ameuded GZA): ORI)lN,\l{C[- ;rntl VI0L.\'tlO\ l. Scction 8-18.1(b) General Provisions for Homestays I-{omestul,operations are prohibited outside of the L'isitor Destination Area (7'DA) An Equcl Opportunig Enrytlaver EXHIBIT D Violation: The Planning Department has confirmed that the subject property is currently being used for a [Iomestay operation. The continued use of the subject property for a Homestay operation outside of the designated Visitor Designation Area constitutes a violation. Pursuant to: Sec. 8-3.5 Enforcement, Legal Procedures and Penalties (b) Civil Fines (1) If the Director of the Planning determine that any person, firm or corporation is not complying wtth a nottce of violation, the Director moy have the party responsible for the violation served, by moil or delivery, y,ilh an order pursuant to this section. The order may reqttire the party responsible for the violation to do any or all of the following. (A) Correct lhe violatian witltin the time specified in the order; (B) Pay a civil fine not to exceed 810,000 in the manner, at the ploce, and before the clate specified in the order; (C) Pay a cinil fine up to 510,000 per day for each dalt in v,hich the violation persists, in the manner and at the time and place speci,fied in the order. (2) The order shall arlvise the party responsible for the violation that the orcler shall became final 30 days after the dale of its delivery. The order slnll also advise thqt the Director's actiott may be appealed lo the Planning Cornntissiotr. (3) The provisions o.f the order i.ssued by lhe Director under this section shall become .final 30 cslendar days after the service of the order. The parties responsible for the violation ftitt), oppeal the order to lhe Planning Comrnission pursuont to its nileg The fornt of this appeal must conform to the Planning Commissiort's rules. However, an appeal to the Plunntng Cornntission shall not slay any provision of order. (4) The Director moy institute a civil action in ony court of competent Jurisdiction for enforcement oJ'any order issued pursuant lo this section. IYhere the civil action has been insttfuted to enforce the civil fine imposed by said order, the Director need only show that the notice af violation and order v,ere served: that a civil fine was imposed; the amount of the civil fine imposed has not been paid; that either has not been appealed or that if appealed, the order was sustained by the Commission and/or any Court action. You are herein levied antl ordered to pay a fine of ten thousand dollars (S10,000.00) for the ahoye noted violations to the Planning Dcpartment. You are hereby ordercd to ceasc and dcsist the illegal acfivities being conducted/performed on and from the prcmises as required by larv. You are hereby ordered to correct the above use violations(s) rvithin 14 days of the date of this notice. Should the violations not be remedied within 14 days from the date of the Notice of Violation & Ordcr to Pay Fines: o This matter will be forryarded to the Office of the Prosecuting Attorney; o An additional fine of S10,000 per violation, per day, for each day in rvhich such violation persists shall be levied. A written response to the Planning Deparlment rvithin 14 days from the date of this Notice of Violation & Order to Pay Fines to address this issue is mandatory. Payment of the $10,000 civil fine is also due r.vithin 14 days from the date of this notice. Failure to address this issue r.vill provide the Department rvith no other choice but to continue levying tines each day the violation persists. This determinalion may be appealed to the Planning Commission pursuant to Chapter 9 of the Rules of Practice and Proeedure of the Planning Commission (RPPPC). The time for any appeal of an action of the Planning Director commences 21 days from the date of the adverse decision (RPPPC Rulel-9-2). An appeal of any action of the Planning Director must contain the requirements of RPPPC Chapter 9 to be considered by the Planning Commission, The Ruies of Practice and procedure of the Planning Commission (RPPPC) are available online tkough thc Planning Department's website at: http://wrvw.kauai.gov/Governrnent/Departments/PlanningDepartrnentltabid/61/Def-ault.aspx. Should you have any questions, please feel free to contact Supervising Inspector Barnbi Emayo (808-241-4051), email at aemayo@kcrucri.gov or call Enforcement Program Manager lv{ichael Laureta (808-24 1 -407 1 ), KA'AINA S. HULL Deputy Director of Planning Cc Office of the lvtayor County Attorney I NVF S I'IGAI'ION R E PORT Drsr Hanal-e i 58005C05 I,iai lapa SLUC DTST: NAI\,IE: PATRICIA D, MCCONNELL ".lEB SITE: ai.rbr:b "f,Erli 0Ii llale" Transier"rt accomrnodatioil operaLicn outside of t.he Visitor Notice Of Violation Report 5116/17 1. Zoning Compliance Notice (ZCN) dated 1111117 was issued to Patricia D McConnetl for the eslablishment of the Transient Accommodation Operation on 4813 Ananalu Rd", ation 2. Meeting response at the Planning Dept on 4112117 Accornmodation at $275 a night llanning Dept. has offered a remedial action plan to rectify the vrolationb. The nnell has accepted and signed the terms to remediat* (Schedule EXHIBIT E 1-rl.\.i.i c. Althouqh the owner has agreed to the ternr to renrediate, she has arliculated that she will continue the transient accommodation operation until March of !0!Q The owner has made comments that she doesn't intend to cease and desist the use of the subiect property as a Transient Accommodation 3. Letter response on meeting 4113117 from Patricia McConnell a. No documentation submitted to demonstrate that website ads have been terminated. b. No doc umentation submitted to demonstrate that allfuture commitments for use of the property as Transient Accommodation have been terminated. 4. Research of online website www.airbnb.com found the subjecllt?!sient accommodation still in operation on 5/18/17 n m/rooms/1 5. Research Finding a. Ongoinq Homestay operation is located outside of the VDA b. Ongoing Homestay accommodation operation does not have an applicable pery!!- 5. Violation Found: K.C.C. 1. 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't) oo-c o!-c U)'o L o F rc{) G C,o.J .2 O).c-xoo a o (, o o)p oc .2 .9 (o tr o .g .9 (o-o8 Bs q) (5 a 'i3 o),: C:),:'6 3(l5I.: c)(! C I Eq) (ooo .9 a) Eo -oC 3(D aft t I I t t I I ! A .rooo o 3lttroc I.9z (l,a Letter Response meeting 4/13/17 April 13th,2017 1? N713 /? z Dear Bambi. RECrr . -- ' On April 1st , 2017 your currier came to my home at 4813 Ananalu Boad, Hanalei, Hi and delivered a letter to me that was lrom your planning deparlment regarding county ordinances for TVR;s and Homestay B&B's on Kauai and necessary compliance issues, I'm writing this to acknowledge receipt ol that letter and the date it was delivered. I wish to say mahalo for meeting with meApril 12th regarding lhat letter and the new county ordinances therein. I appreciated the time you gave to me over this issue. It is my beliel , however, thal lhave not, and have never, been in violation of any of the older county ordinances. However it is now my understanding that there have been some recent new changes in those county ordinances that may eflect my life and property, and that may also require me to make some changes in how I share my home with others. I have yet to fully research and comprehend all the new ordinances , which I undersland are in transition and are still subiect to possible ongoing ammendments. I wish to assure you that i am, and will, make every atlempl possible to assure I am in compliance with ordinances that would apply to me and my home here in Kauai My Kauai home at 4813 Ananalu Road has been my principle residence since I boughl it in 2004. I will check with the county property tax department in case, as you have inlormed me, they do not have the correct inlormation regarding my homeowner exemption status and my mailing address. I did notice that my property taxes have undergone a large increase of late so it is possible they are not applying the appropriate home owner tax exemption lor which lqualily, I am presently seeking advise lrom sources such as the Mayor's otlice as lo what is required ol me and what the procedure is in regards to obtaining use permits and applications lor these. ln further inlormation and assistance on this that you can offer would be welcomed and appreciated, Mahalo Nui Loa Aloha, Patricia McConnell t k </// at g .1 G1(&) / l/t I/r, dtt,l, saru^l 3uqaa11 Schedr-rlc' Meeting l)atc ,1 IL t1 ItlrSI'}ONSl: 'l'0: Zoning Compliance Notice (ZCN), Date Notice of Violation and Order to P ay'Fines. Datc: l-iVIK: (.1)o Property r\ddress: _ Writtcn co cc plan t7 iPfr 12 Ali :2: RErrc:r'y';.;' .1 t,, I p otlt e t o tD L IRemoval] l'irnc tablc Datc- [Schc'dulc]Sitelnspection IDatc] ISubmission] Zoning Applicatiorr/ plansil'ccs IWrittenl Cornpliance Plan. pending acccptance l-1 ot-0 ['fime] Tinrc table Datc Time tahle Dirtc Pcr your signature, failure to comply rvith your rvritten compliance plan gives this Department no altemative but to issue a Notice of Violation and Order to Pay lrines and refer this matter to the County and Prosecuting Attorney's Office. ?x(*rc,,, e Mc 9--,-l.L*r) /< Sierrature t7 I) n Date /'7 I {o- I l)ursuant to Counh Ordinancc \o.919. r'ou are hcl'cbr notilictl that lailurc 1u rcnrcdr the violatiorr rnav rcsult in a fine of ull to S10,000.00. irnd/or ull to Sl(1.(10[).(X) nc.r tlav thc violittion pcrsists. rvhich nr:rvhe :rlrlrcirlahlc. Dtrrsuiurt lo thc rulcs ol thc l)lanning Conrnrission. I'ou nrav also be suhicct to crilninal Drosccution. \---= I':rtricia [), NI cC--on ncl I 'l'NlK: 580051105 {lilJ Aurtnrrlu Ikl. \\'ailapa IlF.: Ilcctillg to rectif.l r iolrtions olr subje ct llrollcrtr' l)rte : -lll2t21ll7 On April L2,201-7 the Planning Department met with the property owner (Patricia D, McConnell) in response to the compliance notice dated January 1"1.,2017. The following attended; Bambi Emayo, Patricia McConnell, and Britni Ludington-Braun. The following are notes and observations of said meeting: r ln the meeting Patricia tolo us that she will be running her operations till March 201.8, r Patricia doesn't see how she has a violation because according to her, the government keep changing the laws. r On a couple accounts in the meeting Patricia threated, "if we stop her from operating she's going to take off her clothes, leave thern on the beach, and swim out to the sharks and let them eat her." o Patricia also made a racist remark implying that the Planning Department are trying to get rid of the haole people. r Patricia made a comment to Bambi Emayo that he is heartless for stopping her from operating. r Patricia said she is going to work with the Planning Department toward zoning compliance r lt is notecl, no remedial action plan has been agreed upon. The violator (Patricia McConnell) is reluctant to correct the noted violations' These are my observations noted I}t{ITNI I,III)N - lt tt.\tr\ ADU/TVR Enforcement Specialist &r-(_ Patricia D, McConnell TMK: 58005005 4[ll3 Arranalu Rd. Waitapa RE,: IHecting to rcctifl'violations on suhject propert]- I)*e:4ll2l20l'7 On April L2,2OL1 the Planning Depafiment met with the property owner {Patricia D, McConnell) in response to the compliance notice dated Janua ry 17,2017. The following attended; Bambi Emayo, Patricia McConnell, and Britni Ludington-Braun. The following are notes and observations of said meeting: r ln the meeting Patricia told us that she will be running her operations till March 2018. r Palricia doesn't see how she has a violation because accordingto her, the government keep changing the laws, . On a couple accounts in the meetin8 Patricia threated, "if we stop her from operating she's going to take off her clothes, leave them on the beach, and swim out to the sharks and let them eat her." r Patricia also made a racist remark implying that the Planning Department are tryingto get rid of the haole peop[e. . Patricia made a cornment to Bambi Emayo that he is heartless for stopping her from operating. r Patricia said she is going to work with the Planning Department toward zoning compliance r lt is noted, no remedial action plan has been agreed upon. The violator {Patricia McConnell) is reluctant to correct the noted violations. l'hese are my obse rvalions noted BRITNI I,TlI)-I}RALT\ ADU/TVR Enforcement Specialist EXHIBIT F BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA 'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PA TRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA'!, Respondent. ) CC-2017-4 ) TMK: (4) 5-8-005:005 ) ) ) CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) -----------) CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date set forth below, a copy of RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA'l'S EXHIBIT LIST; EXHIBITS A -F, was duly served by email and depositing the same in the U.S. mail, postage prepaid, upon the following: Gregory W. Kugle, Esq. Joanna C. Zeigler, Esq. DAMON KEY LEONG KUPCHAK HASTERT I 003 Bishop Street, Suite 1600 Honolulu, Hawai'i 968 I 3-6452 Email: gwk@hawaiilawyer.corn i cz@,hawai ilawyer. com Attorneys for Petitioner PATRICIA D. McCONNELL NICHOLAS R. COURSON, ESQ Deputy County Attorney County of Kaua'i 4444 Piice Street, Suite 220 LIhu'e, Kaua'i, Hawai'i 96766 Ernai I : ncourson(dkauai. qov Attorney for Planning Commission of the County of Kaua'i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua'i 4444Rice Street, Suite 150 LThu'e, Kaua'i, Hawai'i 96766 Email: echine@kauai.eov asegretif@,kauai. eov HARLAN Y. KIMURA, ESQ. Central Pacific Plaza 220 South King Street, Suitel660 Honolulu, Hawai'i 968 I 3 Email : hlzk@,harlankirnuralaw.com Hearing Officer for the Planning Commission of the County of Kaua'i DATED: LIhu'e, Kaua'i, Hawai'i, August 7 3 , ZOtg MATTHEW M. BRACKEN County Attorney fng^tuil^B MARYANN SASAKI Deputy County Attorney Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I 2 ORDINANCE NO.1002 BILL NO.2619 Draft 2 A BILL FOR AN ORDINANCE AMENDING CHAPTER 8, KAUA’I COUNTY CODE 1987,AS AMENDED, RELATING TO HOMESTAYS (County of Kaua’i,Applicant) BE IT ORDAINED BY THE COUNCIL OF THE COUNTY OF KAUA’I,STATE OF HAWAI’I: SECTION 1.Findings and Purpose:The Council finds the 2000 Kaua’i General Plan recognized the need “to develop a clear policy regarding B&Bs and vacation rentals.”The General Plan recommended an implementing action to amend the CZO to facilitate the permitting of existing,nonconforming alternative visitor accommodations.The Council complied with the policy of the General Plan and grandfathered existing single-family transient vacation rentals (SFTVRs)that registered and met the prior use requirements established in Article 17 of the CZO. In Ordinance No.864,the Council further found that: This bill does not apply to a bed and breakfast unit (“Home stay”).It is the intention of the Council to address these units as a separate matter after establishing a regulatory framework for single-family transient vacation rentals.Homestays are presently regulated through the use permit process. Although the Council bifurcated the issues of homestays and SFTVRs,it is now appropriate to adopt a clear and specific standard and review parameters under which homestay applications can be processed. The purpose of this bill is to restrict homestay operations to the Visitor Destination Areas (VDAs)and to establish additional standards under which homestays operate. SECTION 2.Chapter 8,Article 2,Section 8-2.4 of the Kaua’i County Code 1987,as amended,is hereby amended by adding two uses to the “Table of Uses” to read as follows: 1 “ARTICLE 2.DESIGNATION OF DISTRICTS,METHOD AND EFFECT OF ESTABLISHMENT OF DISTRICTS,AND ZONING MAPS Table 8-2.4 TABLE OF USES ZONING DISTRICT Sec.USE Residential Commercial Industrial R-1 IR-lo to to R-6 j R-20 RR CN CG IL j IG AG 0 8-2.4(u)(1)Homestay Homestay located in the Visitor Destination Area8-2.4(u)(2)P p p P P”VDA),pursuant to Article 18 of this Chapter SECTION 3.Chapter 8,Article 18,Section 8-18.1 of the Kaua’i County Code 1987,as amended,is hereby amended to read as follows: “Sec.8-18.1 General Provisions for Homestays [On a first-come-first-serve basis of applications deemed complete by the Planning Department,no more than ten (10)new applications for homestay operations shall be accepted for review by the Planning Commission in each of the calendar years 2015 and 2016.The limitation on the number of applications shall expire on December 31,2016,or upon passage of an amendment to this section, whichever occurs first.No homestay may be operated on land located in the State Land Use Agricultural District unless the owner obtains a special permit pursuant to Section 205-6 of the Hawai’i Revised Statutes.] A homestay operation shall operate under the following regulations: ifi Transient accommodations are provided for visitors for twenty-nine (29)days or less: Homestays shall be limited to no more than three (‘3)guest rooms per homestay operation: 2 During homestav operations,the owner(s)benefiting under Sec.5A-11 of this Code for a homeowner’s exemption for the homestay site must be physically within the County of Kaua’i,residing at the home stay operation site,and physically available for the needs and concerns of their respective homestav guests:and No other individual or designated representative may act on the owner(s)behalf to meet the requirements of Sec 8-18.1(a)(3). Q Homestay operations are prohibited outside of the Visitor Destination Area (VDA).” SECTION 4.Chapter 8,Article 18,of the Kaua’i County Code 1987,as amended,is hereby amended by adding a new Section 8-18.2 to read as follows: “Sec 8-18.2 Development Standards for Homestays Development standards for homestav operations shall be the same as those for residential dwellings in Section 8-4.5 through 8-4.8 of this Code,inclusive,with the following additions: Each bedroom used for homestav purposes shall require one (1) additional paved and designated off-street parking stall: )At a minimum,the residential structure(s)used for the homestay operation shall be serviced by a septic system approved by the State Department of Health: ç)The owner(s)benefitting under Sec. 5A-11 of this Code for a homeowner’s exemption for the respective homestay site shall be available on a 24-hour,7-days-per-week basis during homestay operations.The owner(s)shall provide the name and contact information to neighbors adjacent to and directly across the subject homestay,the Planning Department,the Kaua’i Police Department,the Kaua’i Civil Defense Agency,and the Kaua’i Visitors Bureau upon issuance of a homestay zoning permit: One (1)outdoor sign no larger than one (1)square foot shall be posted in a visible place on a wall,fence,or post immediately inside or on the front boundary of the property where it is easy to see,for the purpose of providing the current homestay zoning permit number and the 24-hour contact information.No other signs shall be allowed and there shall be no direct illumination of the reciuired sign.The numbers on the sign shall be no smaller than two inches (2”)in height: 3 The homestay operator shall provide a list of requirements and information entitled “For the Safety and Comfort of You and Your Neighbors.”This shall provide essential information to the visitor and shall seek to reduce negative impacts on the surrounding neighborhood.This information piece shall be provided to the Planning Department at time of application and shall be posted in a conspicuous place in the guest’s sleeping quarters along with a copy of the zoning permit number.The list shall include,but not be limited to,suggested curfews, guidance with respect to the character of the neighborhood and gatherings and noise,and what to do in cases of emergency and natural disaster.For those homestavs located in the tsunami evacuation zone,renters must be informed that the homestay is located in the tsunami evacuation zone and of the corresponding evacuation procedures: ffi All print and internet advertising for homestay operations,including listings with a rental service or real estate firm,shall include the zoning permit number and give notice that the homestav operation is located in the tsunami evacuation zone where applicable: A copy of the zoning permit shall be displayed on the back of the front door of the sleeping quarters:and )A site and floor plan shall be filed with the application.” SECTION 5.Chapter 8,Article 18,of the Kaua’i County Code 1987,as amended,is hereby amended by adding a new Section 8-18.3 to read as follows: “Sec.8-18.3 Renewal of Homestay Zoning Permits A property owner that has obtained a homestay zoning permit shall apply to renew the zoning permit annually on the date of issuance of the homestay zoning permit in accordance with the following regulations: Each application to renew shall include proof that there is currently a valid State of Hawaii general excise tax license and transient accommodations tax license for the homestay operation.Failure to meet this condition will result in the automatic denial of the application for renewal of the homestay zoning permit(s). The applicant may reapply for renewal within the annual time allotment by presenting a currently valid State of Hawaii general excise tax license and transient accommodation tax license for the homestay operation: Each application to renew shall include proof that the primary residential structure(s)used for the homestay operation is the owner’s primary residence,and the respective owner is benefiting under Sec.5A-11 of this Code for a 4 homeowner’s exemption for the homestay site in the year preceding the date of renewal: ç)Upon renewal,the Planning Department may initiate re-inspection of properties for compliance with other provisions of this chapter or other pertinent land use laws,and may withhold approval of a renewal application and issue cease and desist notices to the applicant until all violations have been resolved: The applicant shall pay a renewal fee of seven hundred fifty dollars ($750.00)to the Director of Finance.All renewal fees shall be deposited to the Transient Accommodation Enforcement Account within Fund 251;and )Enforcement of this section shall be subject to Section shall be 8-3.5 of the Kauai County Code 1987,as amended.” SECTION 6.Chapter 8,Article 18,of the Kaua’i County Code 1987,as amended,is hereby amended by adding a new Section 8-18.4 to read as follows: “Sec.8-18.4 Transient Accommodation Enforcement Account There is hereby established and created an account to be known as the “Transient Accommodation Enforcement Account”within Fund 251.The fees collected pursuant to Section 8-18.3 are hereby deemed appropriated upon receipt and may be expended to retain independent contractors to assist in the enforcement of illegally operating transient accommodations.The fees may also be expended for materials,supplies,equipment,and training that facilitate inspection and enforcement of such violations.Council notification is required for any single expenditure from this account which exceeds $10,000.Any fines collected when the account has an excess of $250,000.00 in uncommitted funds shall be transferred and deposited into the General Fund at the close of the fiscal year.The Planning Department shall annually report to the Council,as part of the Mayor’s budget submittal on March 15 of each year,the expenditures and outcomes of said account.” SECTION 7.If any provision of this Ordinance or the application thereof to any person or circumstance is held invalid,the invalidity does not affect other provisions or applications of the Ordinance which can be given effect without the invalid provision or application, and to this end,the provisions of this Ordinance are severable. SECTION 8.Ordinance material to be repealed is bracketed.New ordinance material is underscored.When revising,compiling,or printing this ordinance for inclusion in the Kaua’i County Code 1987,the brackets,bracketed material,and underscoring need not be included. 5 SECTION 9.This Ordinance shall take effect upon its approval. Introduced by:Is!MASON K.CHOCK (By Request) DATE OF INTRODUCTION: March 9,2016 Lihu’e,Kaua’i,Hawai’i V:\BILLS\2014-2016 TERM\Bill No.2619,Draft 2 PM_cy.docx 6 CERTIFICATE OF THE COUNTY CLERK I hereby certify that heretofore attached is a true and correct copy of Bill No.2619,Draft 2,which was adopted on second and final reading by the Council of the County of Kaua’i at its meeting held on May 18,2016 by the following vote: FOR ADOPTION: AGAINST ADOPTION: EXCUSED &NOT VOTING: RECUSED &NOT VOTING: Lihu’e,Hawai’i May 19,2016 Chock,Kagawa,Kaneshiro, Kuali’i, Hooser,Yukimura,Rapozo None None TOTAL -4, TOTAL-3, TOTAL-0, TOTAL-0. Mel Rapozo Chairman &Presiding Officer DATE OF TRANSMITTAL TO MAYOR: May 19,2016 Approved this1Zi day of u.-,‘/2016. b’rnard P.(arvalh , Mayor County of Kaua’i Jade Fountain-Tanigawa County Clerk,County of Kaua’i ATTEST: 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 MINUTES OF CONTESTED CASE HEARING; CERTIFICATE OF SERVICE HEARING (Held): Date: August 30, 2019 Time: 9:00 a.m. MINUTES OF CONTESTED CASE HEARING The Hearing on the above-entitled Contested Case were held on August 30, 2019 commencing at 9:00 a.m. in the Līhu‘e Civic Center, Moikeha Building, Conference Room 3, 4444 Rice Street, Līhu‘e, Kaua‛i, Hawai‘i 96766-1300 (“Contested Case Hearing”). Gregory W. Kugle appeared on behalf 2 of Petitioner PATRICIA D. McCONNELL (“Petitioner”), who was also present. Maryann Sasaki appeared as Counsel for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”), along with its duly authorized representative Andres “Bambi” Emayo. Petitioner’s Request For Records. During the Contested Case Hearing testimony was presented by the Planning Department indicating it did not receive Petitioner’s Request for Government Records dated July 10, 2019 made pursuant to Haw. Rev. Stat. §§ 92F-11 and 12 (“Request For Records”). A copy of the Request For Records is attached as Exhibit 1 to Petitioner Patricia McConnell’s Memorandum In Opposition To Respondent Planning Department Of The County Of Kauai’s Motion For Summary Judgment dated August 14, 2019 (“Memorandum In Opposition”). Therefore, Petitioner requested leave to submit another Request For Records to the Planning Department, and depending upon the response thereto, may further request the Contested Case Hearing be resumed to receive evidence related to that Request For Records. Based upon above, and pursuant to Rules 1-6-1(b) and 1-6-3 of the Rules of Practice and Procedure of the Kaua‛i County Planning Commission (“Commission Rules”), by 4:30 p.m. on September 30, 2019 Petitioner shall file a Status Report on the Request For Records and whether she requests the Contested 3 Case Hearing be resumed for further evidence to be taken regarding the same (“Status Report”). Thereafter, a Minute Order will be issued by the undersigned Hearing Officer either: (1) scheduling a Telephone Conference to discuss whether the Contested Case Hearing will be resumed to receive further evidence; or (2) setting forth a briefing schedule for the submittal of Closing Arguments and/or Proposed Findings Of Fact And Conclusions Of Law. Continuance Of Contested Case Hearing. Based upon the above, and pursuant to Rule 1-6-3 of the Commission Rules, the Contested Case Hearing is hereby continued until further order of the undersigned Hearing Officer. Any and all of the above-described pleadings shall be served by email or facsimile transmission, with a hard copy served by regular mail, postage prepaid, to all the parties and the Office of Boards and Commissions for the County of Kaua‛i. The times set forth above are based upon Hawaiian Standard Time (“HST”). DATED at Honolulu, Hawaii, August 31, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on August 31, 2019. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com Attorneys for Petitioner PATRICIA D. McCONNELL MARYANN SASAKI, ESQ. Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: msasaki@kauai.gov Attorney for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X / / / / 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X DATED at Honolulu, Hawaii, August 31, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 MINUTE ORDER REGARDING PENDING MATTERS; CERTIFICATE OF SERVICE HEARING (Held): Date: August 30, 2019 Time: 9:00 a.m. MINUTE ORDER REGARDING PENDING MATTERS Based upon the Status Report1 from Counsel for Petitioner PATRICIA D. McCONNELL (“Petitioner”) received on September 30, 2019 concerning the 1 All capitalized terms shall be as defined in the Minutes Of Contested Case Hearing dated August 31, 2019. 2 Request For Records, Petitioner is directed to provide another Status Report by 4:30 p.m. on October 30, 2019 regarding the compliance by Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”) with respect to the same. Thereafter, further instructions will be provided to the parties by the undersigned. DATED at Honolulu, Hawaii, October 9, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on October 9, 2019. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com JCZ@hawaiilawyer.com Attorneys for Petitioner PATRICIA D. McCONNELL MATTHEW BRACKEN, ESQ. County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: mbracken@kauai.gov Attorney for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X DATED at Honolulu, Hawaii, October 9, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 SECOND MINUTE ORDER REGARDING PENDING MATTERS; CERTIFICATE OF SERVICE HEARING (Held): Date: August 30, 2019 Time: 9:00 a.m. SECOND MINUTE ORDER REGARDING PENDING MATTERS 2 On November 1, 2019 Counsel for Petitioner PATRICIA D. McCONNELL (“Petitioner”) submitted a Status Report1 advising that although the Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”) has rejected her Request For Records in its entirety, she is inquiring as to the basis of that action. Based upon the Planning Department’s rejection of Petitioner’s Request For Records presumably pursuant to Rule 1-6-9(b) of the Rules of Practice and Procedure of the Kaua‛i County Planning Commission (Codified May 2014) (“Commission Rules”), Petitioner is directed to submit a Final Status Report by 4:30 p.m. on December 2, 2019 regarding her Request For Records. In that Final Status Report Counsel for Petitioner shall also provide three (3) dates and times they available to participate in a Telephone Conference to be held no later than December 16, 2019 to determine the briefing schedule for submittal of Closing Arguments and/or Proposed Findings of Fact And Conclusions of Law. Within forty-eight (48) hours of submission of that Final Status Report, Counsel for the Planning Department shall advise of their availability with respect to those three (3) dates and times. Thereafter, the undersigned Hearing Officer will advise the parties of the date and 1 All capitalized terms shall be as defined in the Minutes Of Contested Case Hearing dated August 31, 2019. 3 time for that Telephone Conference, or provide further instructions to the parties based upon the Final Status Report. DATED at Honolulu, Hawaii, November 2, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on November 2, 2019. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: gwk@hawaiilawyer.com JCZ@hawaiilawyer.com Attorneys for Petitioner PATRICIA D. McCONNELL MATTHEW BRACKEN, ESQ. County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: mbracken@kauai.gov LISA A. BAIL, ESQ. Goodwill Anderson Quinn & Stifel 999 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: lbail@goodsill.com Attorneys for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I X X X / / / / / / / / 3 U.S. Mail Hand Delivery Email NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov Attorney for Planning Commission of the County of Kaua‛i ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X X DATED at Honolulu, Hawaii, November 2, 2019. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i GOODSILL ANDERSON QUINN & STIFEL A LIMITED LIABILITY LAW PARTNERSHIP LLP JOHN S. MACKEY jmackey@goodsill.com CHRISTOPHER P. ST. SURE cstsure@goodsill.com First Hawaiian Center, Suite 1600 999 Bishop Street Honolulu, Hawai'i 96813 Telephone: (808) 547-5600 Facsimile: (808) 547-5880 Attorneys for Respondent 7006-0 10001-0 PLANNING DEPARTMENT, COUNTY OF KAVA 'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNT OF KAUA 'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAVA 'I, Respondent. 7759680.1 CC-2017-4 TMK: (4) 5-8-005:005 NOTICE OF APPEARANCE OF COUNSEL FOR PLANNING DEPARTMENT OF THE COUNTY OF KAUA'I; CERTIFICATE OF SERVICE CONTESTED CASE HEARING: Date: August 30, 2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura NOTICE OF APPEARANCE OF COUNSEL FOR THE PLANNING DEPARTMENT OF THE COUNTY OF KAVA ~I NOTICE IS HEREBY GIVEN of the entry of appearance of JohnS. Mackey and Christopher P. St. Sure of the law firm of Goodsill Anderson Quinn & Stifel, A Limited Liability Law Partnership LLP, as counsel for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA 'I ("Respondent") in the above action. Notice and copies of pleadings, papers and other material relevant to this action should be directed and served upon: JOHN S. MACKEY jmackey@goodsill.com CHRISTOPHER P. ST. SURE cstsure@goodsill.com First Hawaiian Center, Suite 1600 999 Bishop Street Honolulu, HI 96813 DATED: 2 Attorney for Respondent PLANNING DEPARTMENT, COUNTY OF KAUA'I BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNT OF KAUA 'I In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaua'i, Hawai'i, identified by Kaua'i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA 'I, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date and by the method of service noted below, a true and correct copy of the foregoing was served on the following at their last known address: 7759680.1 GREGORY W. KUGLE gwk@hawaiilawyer.com JOANNA C. ZEIGLER JCZ@hawaiilawyer.com Damon Key Leong Kupchak Hastert 1 003 Bishop Street, Suite 1600 Honolulu, HI 96813 Attorneys for Petitioner PATRICIA D. McCONNELL NICHOLAS R. COURSON ncourson@kauai.gov First Deputy County Attorney County of Kaua' i 4444 Rice Street, Suite 220 Lihu'e, HI 96766 Attorney for Planning Commission, County ofKaua'i ELLEN CHING, Administrator eching@kauai. gov asegreti@kauai. gov Office of Boards and Commissions County of Kaua' i 4444 Rice Street, Suite 150 Lihu'e, HI 96766 HARLAN Y. KIMURA hyk@harlankimuralaw.com Central Pacific Plaza 220 South King Street, Suite 1660 Honolulu, HI 96813 Telephone: (808) 564-0811 Hearing Officer Planning Commission, County ofKaua'i U.S. MAIL 2 HAND DELIVERY EMAIL X X X X DATED: Honolulu, Hawai'i, November 13,2019. 3 Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA 'I KAUA‘I PLANNING COMMISSION CONTESTED CASE HEARING MINUTES August 30, 2019 The contested case CC-2017-4 hearing of the Planning Commission of the County of Kaua’i was called to order by Hearings Officer Harlan Y. Kimura at 9:00 a.m., at the Lihue Civic Center, Liquor Control Conference Room 3. The following were present: Harlan Y. Kimura, Hearings Officer Greg Kugle, representing the petitioner Patricia McConnell Patricia Dawn McConnell, petitioner Maryann Sasaki, representing the Planning Department of the County of Kaua‘i Petition to Appeal the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the operation of an Illegal Transient Accomodation Use for Property Situated in Haena, Kaua‘i, Hawaii, identifeied by Kaua‛i TMK No. (4) 5- 8-005:005 containing 26,092 square feet. CALL TO ORDER Mr. Kimura: It is now 9 o’clock. We’ll begin the contested case hearing. Patricia D. McConnell vs. the County of Kaua‘i Planning Department. CC-2017-4. Ms. McConnell is appealing the decision of the planning director’s decision related to the notice of violation and ordered to pay fines for the operation of an illegal transient accommodation used for property situated in Ha‘ena, Kaua‘i, Hawaii identified as Kaua‘i TMK Number Island (4)5-8-005-parcel- 005. Containing 26,092 sq. ft. May I have your appearances for the record beginning with council for Ms. McConnell. Mr. Kugle: Good morning, Your Honor. Greg Kugel on behalf of the petitioner, Patricia Dawn McConnell, and Ms. McConnell is present with me this morning. Mr. Kimura: Okay. Thank you. Mrs... Ms. Sasaki: Maryann Sasaki, on behalf of the Planning Department of the County of Kaua‘i. Mr. Kimura: Ms. Sasaki will there be a representative from the planning... Ms. Sasaki: Yes, there should be two witnesses. I was going to text them but then the buzzer went off so I didn’t. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 2 Mr. Kimura: You will have two witnesses for the planning department but … Ms. Sasaki: Right. Mr. Kimura: Will there be a representative that will be sitting at your table during the entire course... Ms. Sasaki: I don’t know. I would say no, nobody’s said that they were going to come. Mr. Kimura: Okay. So, uh, we can proceed without a representative present? Ms. Sasaki: Yes. Mr. Kimura: Okay. Now, before the evidentiary portion of the hearing takes place, there is the planning department’s motion for summary judgment that we need to address. In this regard I do have the motion from the planning department, Ms. McConnell’s memorandum and opposition, as well as the reply from the planning department. Are there any other documents that need to be reviewed for the motion? Ms. Sasaki: No I don’t have any. Mr. Kugle: No. Mr. Kimura: Mr. Kugle? Mr. Kugle: No. Mr. Kimura: Okay. That being the case I will receive brief arguments on the more salient points starting with Ms. Sasaki. Ms. Sasaki: I think there’s really only one salient point in this matter and that is that Ms. McConnell has been operating an illegal homestay over at least the course of the past 9 years. And despite notices from the planning department and meetings with the planning department apprising her of her situation, she continues to operate this transient vacation unit. There’s no dispute that that - I don’t think there’s a dispute in facts, that she met with the planning department, the planning department sent her an NOV. She continues to operate without the requisite permit. So it’s the argument. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: To clarify some of Ms. Sasaki’s statements and then I will very briefly argue. The notice of violation was issued in May of 2017. So there is no 9 year history of illegal use, or anything like that. I guess the, you know, we - other KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 3 than that, I think our memorandum and opposition set out a number of arguments about why the summary judgment should be denied. I’m not going to repeat those because I know you, you ’ve read that material, but there were a host of reasons why summary judgment should be denied. And then finally as a practical matter I would point out, that one of our arguments is that Ms. McConnell is actually entitled to a contested case hearing under the statute. That’s what we’re here today to do and therefore, I think, as a practical matter, if for no other reason, the motion should be denied because we’re here ready to take testimony and conduct the contested case hearing. Ms. Sasaki: May I just briefly reply? Mr. Kimura: Yes Ms. Sasaki Ms. Sasaki: Okay. I just, I didn’t indicate that Ms. McConnell had 9 years of illegal operation. I merely indicated that she’s been operating a homestay without a permit for at least 9 years. And I find that information in the petitioner’s papers. So that’s something Mr. Krugle misstated. She’s just been operating without a permit since before the ordinance was passed. Mr. Kimura: Anything further Ms. Sasaki? Ms. Sasaki: Nothing. Mr. Kimura: Mr. Kugle? Mr. Kugle: I have nothing further other than I think to say that it will be one of the issues that will be decided by the planning commission is the fact that there wasn’t a permit requirement before a certain period of time in 2016. So, uh, again, you know, that’s the underlying issue. Mr. Kimura: Okay. Now, as far as the ruling, unlike the contested case hearing where the burden is upon the petitioner, in this motion for summary judgment it’s the planning department’s burden. And the planning department must establish that there are no genuine issues of material facts and it is entitled to judgment as a matter of law. There are two material facts that need to be established. One is that petitioner’s operating a homestay defined in Kaua‘i County Code Section 8-1.5 which is defined as quote, “Means an owner occupied running unit in which overnight accommodations are provided to transient guests within the same dwelling unit in which the owner resides and a respective owner currently benefits from Section 5A-11 of the comprehensive zoning ordinance from homeowners exemption for the homestay site,” closed. The second point that the planning department is required to establish and that there will be no general issue on is that the property is operated as a homestay in a location that is not in a visitor destination area. Now, the planning KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 4 department has submitted declarations of the program manager in charge of inspecting and enforcing violations of the comprehensive zoning ordinance, Mr. Mike Laureta, and also the EVU - I’m sorry, the AVU TVR enforcement specialist, Ms. Britni Lud ington-Braun. Now these declarations must affirmatively show that the declarants are competent to testify to the facts stated in them and they have personal knowledge of these facts. The declarations that were submitted met both of these requirements. The planning department has not met its burden establishing there are no general issues of material fact and it is entitled to judgment as a matter of law. Now with respect to the Laureta declaration, Mr. Laureta does not state that he is competent to testify. So this requirement in Hawaii rules of civic procedure Rule 56B is not met. Second, there are many conclusively facts in the Laureta declaration which cannot be utilized in support of the planning department’s motion for judgment. According to the GECC Financial Court case reference in petitioner’s memorandum in opposition. For instance, the Laureta declaration concludes the subject property is located outside of the visitor designation area and does not possess a valid permit or non-conformity use certificate. I presume it should’ve been, and this is a typo, graphical error, should’ve been visitor destination area, instead of visitor designation area. Ms. Sasaki: That’s correct. Mr. Kimura: Nonetheless, in Mr. Laureta’s declaration there is no address of the property. There is no determination of a visitor destination area. There is no reference to what ordinance determines the visitor destination area. And there is no specific facts as to what is a valid permit of a non-conforming use certificate which the petitioner purportedly does not have. Lastly, there are no maps to indicate and identify the visitor destination areas and where the subject property is located in reference to those visitor destination areas to determine whether or not the subject property is in or out of those visitor destination areas. Alternatively, there is no request by the planning department for mandatory judicial notice to acknowledge those visitor destination areas as well as where the subject property is located in reference to those areas. So all of these are genuine issues of material fact. Similarly, the Ludington-Braun declaration does not state that she is competent to testify to the facts set forth in her declaration. So, for those reasons, the planning department’s motion for summary judgment is denied. Now there are a few more preliminary matters before the evidentiary portion of the contested case hearing begins. The first order of business is whether there are any interveners and I note for the record none are present in the hearing room. Next, whether there are any members of the general public wishing to be heard on this appeal. And also note for the record there are no individuals from the general public present in this contested case hearing. Now before we begin there is the issue regarding the exhibits that were proposed by petitioner and also the planning department. Beginning with petitioners Exhibits 1 through 5, is there an agreement that KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 5 they be stipulated into evidence? Or will there be testimony? Mr. Kugle: We don’t have a stipulation admitting anything into evidence so I presume that we will go ahead and authenticate them and admit them in the normal course of the testimony. Mr. Kimura: Ms. Sasaki, response? Ms. Sasaki: Well, I’m fine, if he wants to stipulate to the exhibits but... Mr. Kimura: Okay. So, Mr. Kugle then would Ms. McConnell be willing to stipulate Exhibits 1 through 5 into evidence? Mr. Kugle: Um, we... Mr. Kimura: And, I mean part of your case in chief you can make reference to them. Mr. Kugle: Yeah, we would stipulate 1 through 5. I have some problems with some of the county’s exhibits. Um... Mr. Kimura: Okay. Well let’s take one thing at a time. So... Mr. Kugle: Okay. Mr. Kimura: ...first of all, plain- petitioner’s Exhibits 1 through 5 will be admitted into evidence by stipulation. Now for the planning department’s Exhibits A through F, I presume there’s also no agreement, so Mr. Kugle you mentioned that you have objections to one or more of those exhibits? Mr. Kugle: Yes. So I should, let me eliminate the ones that I don’t have an objection to. I don’t have an objection to D, and would stipulate that into evidence. I think that’s the same as petitioner’s Exhibit 1. That is the only that I don’t have a problem with. And let me just explain what the problem is. There are, um... Mr. Kimura: Okay. Well - well first of all... Mr. Kugle: Sure. Mr. Kimura: ...okay so, Exhibit D, petitioners of the planning department’s exhibit will be admitted into evidence by stipulation and as stated by Mr. Kugle Exhibit D is virtually identical with Exhibit 1. Okay. Now Mr. Kugle starting with Exhibit A, your objection? Mr. Kugle: Yeah. So my objection is we were not given the opportunity to do discovery in this case. And the remainder of the exhibits, the county Exhibits A, B, C, E KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 6 and F, appear to be documents out of the planning department files I presume. We did not get those until August 23, despite the fact that we had submitted a, um, we’ve been forced in these cases when the county will not - or, the planning department will not agree to do discovery, we’ve been forced to use the Uniform Information Practices Act request process to obtain a copy of the pertinent county files. And there has been no response to our UIPA request yet. So we’ve never seen these documents. Portions of some of these documents were attached to the summary judgment motion that was filed a few weeks prior. But there are significant portions of these such as, apparently internet ads and other things in some of the exhibits that we’ve never seen before. And I think it is, you know, it is unfair and it’s trial by surprise to, despite having requested these formally through the UIPA process and not having gotten a response, and no documents being produced through that process, that’s my concern with these exhibits. Mr. Kimura: Okay. Ms. Sasaki? Ms. Sasaki: Well as Mr. Kugle well knows, discovery in these contested case hearings is by stipulation of the parties. And, uh, he not only has he not made a motion to do discovery, but he’s never even suggested to me that he wanted certain documents or he needs certain documents. So, his discovery argument is, uh, come short of the mark I think. As with respect to the element of surprise, these documents were probably available online. Uh, most of the - the ones that he’s taking specific issue with. The internal reports are - I believe were attached to the motion for summary judgment, which was filed, uh, well before, uh, look - I’m just see the date. I don’t know the, uh, oh okay. So the - it was filed on July 9. So he well had opportunity to examine this material and be aware that this material was going to be introduced into this contested case hearing. And finally evidentiary rules in contested case hearings are flexible. They’ve been drafted so the maximum amount of information to be used by the hearing officer in determining the cases so I believe that these exhibits are absolutely proper and admissible. Mr. Kimura: Okay. Mr. Kugle? Any... Mr. Kugle: I... Mr. Kimura: ...reply? Mr. Kugle: Yes. Just real briefly. So, you know, our opposition to the motion for summary judgment on Page 9, we explained that discovery was needed and that was a separate reason for not granting the motion. And we also attached as Exhibit 1, the UIPA request that was served on the planning department on July 10. Seeking exactly the type of documents that were submitted as exhibits for this hearing. Um, and - and I, uh, would just note that one of the KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 7 issues that we preserved for appeal, notwithstanding the fact that the planning commission changed its rules to prohibit discovery for which the planning department would never stipulate and never has in any case I’ve handled, I believe that deprives parties of due process. And so strict adherence to the rules, the rules are what the rules are, but it deprives a party of the ability to defend the allegation and the notice of violation. And so, you know, that’s probably an issue for appeal. But, that is one of our arguments. Mr. Kimura: Okay. So, as far as my ruling, what I am going to be ruling is that the planning department as the present their case in chief, you know, can offer any of these exhibits that they wish to do so, and then appropriate objection at that time can also be made by Mr. Kugle. However, as the parties fully are aware, the rules of evidence do not apply necessarily in a contested case like this according to the commission rules. However I will note that if Mr. Kugle does state a valid reason why possibly this case may need to be continued because there’s exhibits that would be admitted that would require additional research or preparation to counter them, I will entertain a request at that time from Mr. Kugle for a continuance if need be. Okay. Now, anything further before we begin the contested case hearing? Mr. Kugle: Not from us. Ms. Sasaki: Nothing. Mr. Kimura: Okay. Now knowing that there were no other parties in the contested case hearing room we did not invoke the witness exclusionary rule. But, if someone does come in during the course of the hearing we will invoke it at that time. So, now we will begin the evidentiary portion of the contested case hearing. Beginning with the petitioner’s case in chief followed by the planning department’s case in chief. Then if deemed appropriate the petitioner may also have a brief rebuttal case. Now Mr. Kugle, you ready to proceed with your first witness? Mr. Kugle: We are. Mr. Kimura: Okay. Mr. Kugle. Mr. Kugle: Petitioner calls to the stand, Dawn McConnell. Dawn take... Mr. Kimura: Mr. Kugle? Mr. Kugle: Yeah. Mr. Kimura: Please proceed anytime you’re ready. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 8 Mr. Kugle: Oh, do you want to put the witness under oath? Mr. Kimura: Yes, thank you for reminding me. Ms. McConnell could you please stand and raise your right hand? Do you solemnly swear to tell the truth, the whole truth and nothing but the truth? Ms. McConnell: I do. Mr. Kimura: Okay. Please be seated. Mr. Kugle: Good morning Dawn. Just for the record would you state your full name? Excuse me. Ms. McConnell: Patricia Dawn McConnell. Mr. Kugle: Okay. And you go by Dawn? Ms. McConnell: Yes. Mr. Kugle: Okay. Mr. Kugle: Dawn, when did you first purchase your home? Ms. McConnell: 2004. Mr. Kugle: Okay, and where is it located? Ms. McConnell: It’s located in Wainiha. Mr. Kugle: Okay, and in, pardon my poor understanding of Kauai geography but is that basically at the end of the road, Kuhio Highway way out toward, um, uh, the end of the road? Ms. McConnell: It’s probably two and a half miles from the end of the road, It’s right by the (unintelligible) grocery store. Mr. Kugle: Okay. Uh, but it’s past - you drive through Hanalei to get there? Ms. McConnell: Yes. Mr. Kugle: Okay. Now do you reside in the home? Ms. McConnell: Yes. Mr. Kugle: And that’s your permanent residence? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 9 Ms. McConnell: Yes. Mr. Kugle: Do you have mail delivery out there? Ms. McConnell: No we have rural - we have PO box. Mr. Kugle: Okay. Now when did you begin, um, we’re going to use some terms and I want to make sure that - that we all kind of understand and use them the same. So what’s your understanding of a homestay? Ms. McConnell: Uh, that the owner is in the home. Mr. Kugle: Okay. And that’s, a lot of people will refer to that also as a bed and breakfast or B&B. Is that your understanding? Ms. McConnell: Yes. Mr. Kugle: So if I use either one of those terms, homestay or B&B or bed and breakfast, I’m referring to the same thing. Ms. McConnell: Yes. Mr. Kugle: And - and your understanding for all is that the homeowner lives in the home? Ms. McConnell: Yes. Mr. Kimura: Okay. So Ms.McConnell can you speak into the microphone so it picks up? Ms. McConnell: Is it - the mic’s not on. Is it on? Mr. Kugle: Um, so Dawn when did you begin, um, renting your home as a homestay? Ms. McConnell: In 2005. Mr. Kugle: And, um, did you, um, get a transient accommodation tax license? Ms. McConnell: Yes. Mr. Kugle: And that’s from the State of Hawaii, Department of Taxation? Ms. McConnell: Yes. Mr. Kugle: Okay. And did you also get a general excise tax license? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 10 Ms. McConnell: Yes. Mr. Kugle: Also from the State of Hawaii, Department of Tax? Ms. McConnell: Yes. Mr. Kugle: Now when you started this, um, renting in 2005 did you ever speak to anybody at the planning department about what you were doing? Ms. McConnell: Yes. Mr. Kugle: Uh, tell me about that. Ms. McConnell: I just remember going down, to find out what I was supposed to do and, uh, it was a - it was a really nice man, Mario, had told me where to go to get the TAT license and the GE license. Mr. Kugle: Okay. So Mario told you, um, you explained to Mario that you were wanting to operate your home as a bed and breakfast or a homestay? Ms. McConnell: Yes. Mr. Kugle: And you asked Mario whether there was any county permit associated with that? Ms. McConnell: I asked him what I was supposed to do to be able to do that. And he said get a TAT and a GE. Mr. Kugle: Okay. And he didn’t tell you that there was some county permitting process associated with that? Ms. McConnell: No. Mr. Kugle: Did he tell you basically that yes it’s legal in Kaua‘i to operate a homestay at that time? Ms. McConnell: I don’t really remember the full conversation. I just was going to rent and I needed to know what to do. So I went down. I was talking to him, um, and - and that - that’s what I wanted to do. And then he said, “Okay. You have to get the TAT and then directed me where to get them. Mr. Kugle: Okay. And then so as a result of that conversation you got the TAT and the GET tax licenses and you began... Ms. McConnell: Yes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 11 Mr. Kugle: ...to rent? Mr. Kimura: Ms. McConnell, can you move the, um, microphone I guess to your right so when you’re facing Mr. Kugle... Ms. McConnell: Oh. Mr. Kimura: ...you would be speaking into the microphone? Ms. McConnell: Okay. Mr. Kugle: And so, um, just kind of an overview so between 2005 and 2016 you ’ve been continuously operating your homestead? Ms. McConnell: Yes. Mr. Kugle: Do you have a name for your homestay? Uh, do you call it something? Ms. McConnell: Not really. Mr. Kugle: Okay. Um, now during that time period, 2005 to 2016, did anybody from the county planning department ever tell you that what you were doing was not legal? Ms. McConnell: No. Mr. Kugle: Now did it come to your attention that in 2008 the county passed a bill related to transient vacation rentals? Ms. McConnell: Yes. Mr. Kugle: You’ve paid attention to those things? Ms. McConnell: Yes. Mr. Kugle: Um, and did you take any action in 2008 to determine, and I’ll call that ordinance 864, did you take any steps in 2008 to determine whether Ordinance 864 applied to you and whether you had to go in and get the nonconforming use certificate? Ms. McConnell: Yes. Mr. Kugle: What did you do? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 12 Ms. McConnell: I hired, um, a draft person who did the paperwork and came back and said I was homestay and it didn’t apply to me. Mr. Kugle: Okay. So he went down to the planning department and they said, well this is a homestay, so Ordinance 864 doesn’t apply to you? Ms. McConnell: Yes. Mr. Kugle: And so after that you continued to operate just as you had prior to 2008? Ms. McConnell: Yes. Mr. Kugle: Now, did you do you recall when it was in time that you received the first correspondence or communication from the planning department questioning your use of the property? Ms. McConnell: Yes I recall that. Mr. Kugle: And do you remember when that was? Ms. McConnell: Yes. It was April 1st and the server came to my door and, um, 6 in the morning or something. So it’s easy to remember ‘cause he was bashing the door and then delivered a piece of paper to me. Mr. Kugle: Okay. And that was April 1, 2017? Ms. McConnell: Yes. Mr. Kugle: And let me, um, just have you, um, flip in the exhibit binder in front of you toward the back half there’s an Exhibit C. Ms. McConnell: Yes. Mr. Kugle: And is that the paper that was delivered to you on April 1st? Ms. McConnell: Yes it is. Mr. Kugle: Ms. McConnell I note that it’s dated, January 11, 2017. You didn’t get it in January did you? Ms. McConnell: No. Mr. Kugle: Okay. Mr. Kugle: First time you saw it was when it was handed to you? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 13 Ms. McConnell: Yes. Mr. Kugle: I see they sent it certified mail according to the words above your name. Um, did you have to sign for something on - on April 1st when they delivered it? Ms. McConnell: No it was a server. Mr. Kugle: Oh. Ms. McConnell: He just bashed on my door and then just handed it. Mr. Kugle: Okay. And, um, looks like your mailing address that the county was using is 104 Endlich Drive, Santa Cruz, California. Ms. McConnell: Yes. Mr. Kugle: But that’s not where you live. Ms. McConnell: No. Mr. Kugle: Um, you live at this property in Wainiha? Ms. McConnell: Yes. Mr. Kugle: Now, and so you got this paper and you obviously read it. Ms. McConnell: Yes. Mr. Kugle: I was confused by reading this, because it says that there’s violations of both homestay and single family transient vacation rental. And it refers to two different code sections at the bottom of the page. Do you see that? Ms. McConnell: Yes. Mr. Kugle: Did that cause you to wonder what you were being accused of? Ms. McConnell: Yes. Mr. Kugle: And what did you do in response to receiving this letter in April? Ms. McConnell: I made an appointment and went into the planning department. Mr. Kugle: Okay. Do you remember what day that you went down to the planning department? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 14 Ms. McConnell: Yes. It was, uh, Ap-April 11, 2017. Mr. Kugle: Okay. And, did you meet with at the planning department? Ms. McConnell: I met with a man named Bambi and a woman, uh, named I think Joan. Mr. Kugle: Okay. Joan Ludington Braun? Ms. McConnell: I remember she had a long last name so that would... Mr. Kugle: Okay. And, um, just if - if you can kind of tell us in summary how that meeting went or what happened at that meeting? Ms. McConnell: Well, they take you to the back room. And basically it’s like an interrogation. First Bambi was there, just him. And then went out and got the lady. And they just told me I had to give them $10,000 because I was in violation. Mr. Kugle: And so were they saying that that was a fine or - or they just said you got to pay - pay them or pay the planning department $10,000? Ms. McConnell: You know, it’s hard to remember exactly because it was - it was quite traumatic to be truthful because it was, uh, it was intim- it was so intim- there was a - there was an in- I felt there was an intent to intimidate. So I was intimidated. And so, um, I think it seemed I was being accused of something that I - that I did not believe I - I had done. And I was supposed to give this money. Mr. Kugle: And did you tell Bambi and Joan that you, um, had been renting your house legally prior to that April meeting? Ms. McConnell: I told them I was - I was legal and that I was paying all my taxes. Mr. Kugle: Okay. And after that meeting did you then send a letter to the planning department? Ms. McConnell: Yeah I took it in the next day. Mr. Kugle: Okay. And can you just flip in the exhibits to Exhibit 3 which is more toward the front of the binder? Uh, and is that the letter that you, you had - excuse me, hand carried to the planning department on the 13th? Ms. McConnell: Yes. Mr. Kugle: And this is your summary in response - summary of that meeting and response KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 15 to the zoning compliance notice? Ms. McConnell: Yes. Mr. Kugle: And so in kind of the middle of that first page of that letter you say, “It is my believe however that I, um, have not and never have been in violation of any of the, excuse me, older county ordinances.” You see that? Ms. McConnell: Yes. Mr. Kugle: And by that you meant that, you had been operating a homestay legally before the law was changed to prohibit it in certain areas. Is that - is that what you were conveying with this letter? Ms. McConnell: Yes. Mr. Kugle: Um, and then you go on to - to mention in the next paragraph that there’d been some changes in the law. Um, that, uh, so that - that was - is that in reference to, um, the ordinance that the planning department was pointing out and saying that you’d violated? Ms. McConnell: Yes. Mr. Kugle: And that was what we’ll call the Homestay Ordinance, Ordinance 1002. Ms. McConnell: Yes. Mr. Kugle: Did you in that meeting with the planning department clarify with them that you were not operating a single family transient vacation rental where the owner doesn’t live on the property? Ms. McConnell: Yeah I was really clear about that. Mr. Kugle: Okay. Ms. McConnell: Because I talked with Bam about the island. We talked - we talked a little about the island and my, you know, my life on the island. Mr. Kugle: Okay. Now when you went to that meeting and when you wrote this letter, were you represented by an attorney? Ms. McConnell: No. Mr. Kugle: Okay. That was just Dawn McConnell from Wainiha goin’ down to the planning department and trying to explain things? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 16 Ms. McConnell: Exactly. Mr. Kugle: And did you think that by going down there and explaining the situation to them that this would resolve everything? Ms. McConnell: Yes. Mr. Kugle: Did you get any letter or phone call in response to your April 13th letter? Ms. McConnell: Nothing. Nothing ever came. Mr. Kugle: Eventually though you did get a notice of violation, an order to pay fines letter. Do you recall that? A second letter from the planning department? Ms. McConnell: No I don’t recall that actually. I don’t recall getting a second letter. Mr. Kugle: Okay. And... Ms. McConnell: But I - I just don’t remember. Mr. Kugle: Okay. Let me have you turn to, um, Exhibit 1 in that binder, the very first exhibit. So this is the letter that I was referring to, um, and you say you just don’t actually have an actual memory of receiving it. Ms. McConnell: No, I don’t. Mr. Kugle: Unlike the earlier letter that had been sent to California, this one indicates that they were sending it - it has two addresses for you. Both the Santa Cruz, California address as well as 4813 Ananalu Road, Hanalei, 96714. Correct? Ms. McConnell: Yes. Mr. Kugle: But again, you don’t get mail delivered down there. Ms. McConnell: No. It would have to have a PO box or it gets sent back. Mr. Kugle: Okay. Let me have you, in that same binder in front of you turn to Exhibit 4. And can you just describe for the hearings officer what Exhibit 4 is? Ms. McConnell: Uh, it’s a copy of my tax return reconciliation. Mr. Kugle: Okay. And so, the first page of Exhibit 4 is for calendar year 2005? Ms. McConnell: Yes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 17 Mr. Kugle: And although it has sums, actual numbers blocked out, does that reflect rental income from your homestay operation? Ms. McConnell: Yes. Mr. Kugle: And then how about the second page of Exhibit 4? Turn to that one. It says in handwriting up at the top it says, “Tax Year Ending 2006,” written in there. Do you see that? Ms. McConnell: Yes. Mr. Kugle: And so this, does this also reflect the payment of taxes from rental income from your homestay operation? Ms. McConnell: Yes. Mr. Kugle: Third page same thing right? That’s a general excise tax, use tax return for 2006. Ms. McConnell: Yes. Mr. Kugle: And that also reflects rental income. Ms. McConnell: Yes. Mr. Kugle: And do you have similar records for all the years that you were operating? Ms. McConnell: Yes, I do. Mr. Kugle: Okay. And ever since you went to the planning department in 2005 and they told you get a GET and TAT license from the state and pay that tax, that’s what you ’ve been doing? Ms. McConnell: Yes. Mr. Kugle: And so we didn’t want to clutter the record with all of that but let me have you turn to Exhibit 5. Um, and the first and second page of Exhibit 5 is a State of Hawaii income tax return for a resident for 2015. Is that right? Ms. McConnell: Yes. Mr. Kugle: And this is your tax return. Ms. McConnell: Yes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 18 Mr. Kugle: State tax return for 2015. Um, this has underneath your name in the middle of the page it has PO Box 641 Hanalei. Is that your PO Box? Ms. McConnell: Yes. Mr. Kugle: So that’s where you receive mail? Ms. McConnell: Yes. Mr. Kugle: Um, and on the second page of this it shows that you’re paying tax, income tax, and it notes the business as property manager. Is, um, I note that this was prepared by Stephen Ching. Who’s Stephen Ching? Ms. McConnell: That’s my accountant. Mr. Kugle: Okay. Um, and so that was his description or your description of what you do when you manager your property? Ms. McConnell: It’s his, it’s how he described it. Mr. Kugle: Okay. And the third and fourth pages of Exhibit 5, is that, um, tax, um, GE tax and TAT tax reconciliation totals for a number of years? Ms. McConnell: Yes. Mr. Kugle: Okay. And so, as I look down the columns on the left hand side, there are entries for years ending ‘07, ‘08, ‘09, ‘10, ‘11, ‘12, ‘13, ‘14 and ‘15. Ms. McConnell: Yes. Mr. Kugle: Okay, and just so I’m clear, were you continuously using your property as a homestay from 2005 through 2017 when you had your interactions with the county? Ms. McConnell: Yes. Mr. Kugle: And, had you ever abandoned or discontinued that use during those years? Ms. McConnell: No. Mr. Kugle: You never stopped doing it for 12 months or more? Ms. McConnell: No. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 19 Mr. Kugle: You were telling me about the location of your house in relation to Hanalei. So you have to drive on Kuhio Highway through Hanalei. Is that correct? And that’s the only way to get in. Ms. McConnell: Yes. Mr. Kugle: Do you recall the floods and landslides that began in April of 2018? Ms. McConnell: Yes. Mr. Kugle: And it’s my understanding that the county actually restricted vehicular access, beyond Hanalei for about 14 months. Is that correct? Ms. McConnell: Yes. Mr. Kugle: And do you know what a - so you had to have a sticker or a permit to get out there to get to your house. Is that correct? Ms. McConnell: Yes. Mr. Kugle: And do you know what agency was administering those permits, those access permits? Ms. McConnell: The planning department. Mr. Kugle: The planning department. And did, um, so you obviously had a sticker on your car and you were able to get access? Ms. McConnell: Yes. Mr. Kugle: Did the planning department, was it issuing stickers or permits for people who were gonna be staying in transient vacation rentals or homestays out beyond the road closure? Ms. McConnell: No. They did not. Mr. Kugle: Okay. And so, you didn’t have any rentals during that time period that the highway was closed from April of 2018 until about June of 2019? Ms. McConnell: No I had no rentals... Mr. Kugle: Okay. Ms. McConnell: ...during that time. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 20 Mr. Kugle: Because the planning department wouldn’t let anybody come through. Ms. McConnell: Exactly. Mr. Kugle: Dawn I have no further questions. Thank you. Mr. Kimura: Thank you. Ms. Sasaki? Ms. Sasaki: I have a question about the letter that you sent to the planning department? The return address on that letter was your post office box? Ms. McConnell: Um, I’d have to look at that (unintelligible). I - I - I actually delivered it to them. Ms. Sasaki: So they would really have no way of knowing - since you didn’t - okay. So... Ms. McConnell: Yeah but I put the phone number on it too. Ms. Sasaki: Okay. What is your understanding, I know you said you were, uh, when the TVR ordinance was passed you came down and you asked whether you had to, um, comply with, uh, and - or do any paperwork or get a permit or not with the - when the - when Ordinance 864 is passed. That’s correct right? Ms. McConnell: In 2008. Ms. Sasaki: Mm-hm. Okay. When Ordinance 1002 is passed, what was your understanding of what you needed to do that time? Ms. McConnell: I - I didn’t - I never even knew it was passed. Ms. Sasaki: Well how did you know that Ordinance 864 was passed but you didn’t know Ordinance 1002 was passed? Ms. McConnell: Because when they passed Ordinance, what is it, 84... Ms. Sasaki: 864. Ms. McConnell: 864, everyone knew. They told us all. They - they gave the information to everyone. They told us who - who - how to go about the process... Ms. Sasaki: They personally s- told you? Ms. McConnell: It came... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 21 Ms. Sasaki: Who’s th... Ms. McConnell: ...I... Ms. Sasaki: First of all let’s say who’s they? Ms. McConnell: Um, the - the county planning somehow or another we all knew. Because... Ms. Sasaki: Well... Ms. McConnell: ...we got le- certain people got letters I think. And then we passed... Ms. Sasaki: But did you get a letter? Ms. McConnell: Um, you know, I don’t remember in that time. But I do remember that, um, they told us that - that we all knew. It was either coconut wireless or some - some people got letters and spread the word. And so it was very prevalent and - and who we went between each other. Who do you get to help you with this... Ms. Sasaki: So is it your position... Ms. McConnell: ...(unintelligible)... Ms. Sasaki: ...that the Coconut Wireless failed with respect to Ordinance Number 1002? Ms. McConnell: Absolutely. It totally failed us. Ms. Sasaki: And - and do you rely on your, um, obligations under the law with respect to your business on the Coconut Wireless exclusively? Ms. McConnell: No absolutely not. Ms. Sasaki: So how do you - how do you - how do you determine whether you’re in compliance or not? Ms. McConnell: Well, you just... Ms. Sasaki: No. Ms. McConnell: ...you c... Ms. Sasaki: ...but you. Not one. You. Ms. McConnell: Well, I, you know, I would assume that the same process would be in place in KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 22 2016 as it was in place in 2018 where - where it was in the paper, it was everywhere that we knew. And it was not like that in 2016. Ms. Sasaki: Would you be dis- surprised to discover that with respect to Ordinance 1002, um, people who had been operating homestays were permitted to obtain permits at that time? Ms. McConnell: I remember reading in the paper where the - there - where it said was very obscure and there was nothing specific that he was - I remember it was titled something - or someone told me about the thing that, um, homestays were fine. It was the word was always out homestays were fine. We just always believed we were safe and fine. And not doing anything wrong. And then suddenly I got this. Ms. Sasaki: So when you were informed that you were in fact in violation of the ordinance, you ceased operations? Ms. McConnell: When - when Bambi... Ms. Sasaki: Well when you got the original - when you got the original cease and desist letter, zone - the zone and compliance notice, which that da- well dated January 11th but you said you didn’t receive it ‘till May? Ms. McConnell: April 1st. Ms. Sasaki: April 1st. Okay. At - on April 1st when you had actual notice of that letter, did you cease and desist from renting your property pursuant to the notification of the planning department? Ms. McConnell: I believed they were in error so I made an appointment and went down and talked to them. Ms. Sasaki: But you continued renting. Ms. McConnell: I went and - I went down and talked to them and continued renting because I... Ms. Sasaki: You continued renting. Ms. McConnell: ...thought it was in... Ms. Sasaki: Okay. So despite a zoning compliance notice from the planning department that directed you to stop and provided the sections of the code which you could’ve then looked up to b- assure yourself you were correct, you continued operating because you thought well, they’re not right. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 23 Ms. McConnell: No you ’re - you’re incorrect. Because there was still nothing for homestays. Ms. Sasaki: Well, let - why don’t you turn to - I guess it’s my Exhibit C. Um, I’m not sure is it you r Exhibit 1? The zoning compliance notice? Is that right? Mr. Kugle: No. Ms. Sasaki: Memory serves? Mr. Kugle: No. Uh, Exhibit 1 was the May cease and desist letter. Ms. Sasaki: Okay. Well - well then I’d like to show, uh, the witness Exhibit C. The zoning compliance notice if I may? Mr. Laureta: Oh this is the place. Bambi. Ms. Sasaki: Uh, Mr. Kimura? Mr. Kimura: Yes. Ms. Sasaki: Okay. I’d just like to show you our Exhibit C, respondent’s Exhibit C, and perhaps you could read the first paragraph and the second paragraph? Out loud. Mr. Laureta: Oh thank God. Ms. McConnell: The planning department conducted investigation... Mr. Kimura: O- okay, um, could - could we, um, hold on a second okay? So now, let the record reflect that we have Mr. Mike Laureta and his - his... Mr. Laureta: And Bambi’s coming too. Mr. Kimura: ...well is Mr. Laureta the duly authorized representative of the planning department? Ms. Sasaki: He’s here as a witness today. Mr. Kimura: Well even though... Mr. Laureta: Okay. Mr. Kimura: ...if - even though he’s a witness, if he is the duly authorized representative, he can remain. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 24 Ms. Sasaki: Well... Mr. Laureta: Yes. Ms. Sasaki: Okay. Mr. Laureta: Um... Mr. Kimura: Okay. But - but... Mr. Laureta: And Bambi too. Mr. Kimura: ...Bambi - Bambi who is a witness would not be permitted to be... Ms. Sasaki: I couldn’t have two duly appointed... Mr. Kimura: No. You can... Ms. Sasaki: ...authorized representatives? Mr. Kimura: ...only have one. Mr. Laureta: Um... Ms. Sasaki: It’s Bambi. Mr. Laureta: Yeah Bambi. Ms. Sasaki: Yeah. Mr. Laureta: Okay. Okay, you ’re gonna be - you’re gonna be the (unintelligible) witness. Okay. Ms. Segreti: Representative. Mr. Laureta: Yeah representative. Okay. ((Crosstalk)) Mr. Kimura: Okay. So let the record reflect that Mr. Emayo will be the authorized... Ms. Sasaki: Representative. Mr. Kimura: ...representative. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 25 Ms. Sasaki: …of the planning department, yes. Mr. Laureta: Bambi get your phone. No? Mr. Emayo: Go bring em. Ms. Sasaki: Okay. Um, just could you read the first two paragraphs of the zoning notification letter? Ms. McConnell: Uh, the planning department conducted an investigation of the subject property and found an establishment of a vacation rental operation. This is considered a violation of the following provisions of the comprehensive zoning ordinance of 1987 of Chapter Hawaii Code 1987 as amended - as amended CZO Section 8A, General Provisions of Homestay operations are prohibited are prohibited outside the visitor designation area. Ms. Sasaki: So when you received this letter you thought the planning department was incorrect with respect to the law? Ms. McConnell: I thought that their process was incorrect because when 2008 everyone was given the chance to file for a permit... Ms. Sasaki: Well you said the... Ms. McConnell: ...and (unintelligible)... Ms. Sasaki: ...Coconut Wireless w- I mean do you think the planning department is in... Mr. Kimura: Okay. Ms. - Ms. Sasaki, let, um... Ms. Sasaki: Her speak. Mr. Kimura: ...Ms. McConnell... Ms. Sasaki: Yeah. Mr. Kimura: ...finish her answer and you can ask your next question. Ms. McConnell: Um... Mr. Kimura: Go - go right ahead Ms. McConnell. Ms. McConnell: Um, where - what was she... Mr. Kimura: Okay. So, um, Ms... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 26 Ms. Sasaki: You... Mr. Kimura: ...Sasaki can ask... Ms. Sasaki: Okay. Mr. Kimura: ...the question again. Ms. Sasaki: What, were you under the impression that when the planning department sent the zoning compliance notice and cited the specific provision with respect to homestays outside the visitor destinar- destination area, you - did you th- think - what was your position that they were incorrect? Ms. McConnell: It was my position that I didn’t think they knew what they were doing and the process did not seem appropriate, uh, because I had followed through the 2008 both with myself and with my friend down the road. And, um, that process was kind of pretty cohesive. Whereas this process was suddenly being thrown that oh, some point or another, s- perhaps maybe this ordinance had been changed or was in the process of being changed. And a new system was in place. But it could apply to TVR but maybe not homestay. It - there was nothing very clear and furthermore, the process in 2008 it allowed for people to be grandfathered in. So it wouldn’t make any sense whatsoever that you would then say that time in 2008, oh, well later we will deal with homestays later on. Ms. Sasaki: Did you... Ms. McConnell: And then suddenly... Ms. Sasaki: ...(unintelligible). Ms. McConnell: Excuse me. And then suddenly all of a sudden the homestays weren’t even given an opportunity to be grandfathered in. That didn’t seem the process to me. Uh, from what I know of the world and the laws, it - this did not make any sense. And it was - even when I talked to, um, one of the people at the planning department besides Bambi, I said, “What - what’s the permitting process if we want to apply to get a permit? If we need to apply for the permit like we did in 2008?” “Oh there is none.” So everybody tells you something different. Ms. Sasaki: Are you an attorney? Ms. McConnell: I don’t think you need to be an attorney... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 27 Ms. Sasaki: Are you - are... Ms. McConnell: ...to understand. Ms. Sasaki: ...you an attorney? Ms. McConnell: Excuse me? Ms. Sasaki: Are you an attorney? Ms. McConnell: No. Ms. Sasaki: Did you consider consulting an attorney when you... Ms. McConnell: I did. I - right away. Ms. Sasaki: You consulted an attorney when you got the zoning compliance notice? Ms. McConnell: I - I consulted an attorney after I met with Bambi and then gave the letter to the planning department and they said that there’s no permitting process. We don’t have one. So then I consulted an attorney to figure out what is going on because there was so many gray areas and so much unclarity and non-clarity. Ms. Sasaki: S- well, the, uh, I think the gray area - it - gray areas, uh, the law is ver- very clear actually. Homestay operations are prohibited outside of the visitor destination area. I don’t know how much clearer that could be. Mr. Kugle: Objection. Argumentative. Mr. Kimura: Sustained. Ms. Sasaki: But, you did it in fact when you re- s- ordered by the planning department to stop operations, in - in 2017, you di- you - although you weren’t a lawyer, although you didn’t consult a lawyer, you determined that i- this law was inapplicable to you. Ms. McConnell: It wasn’t like that. When I talked to Bambi, he - they just told you give you the $10,000 and go underground. Like don’t advertise. But I said what I’m no- but I’m legal. I’m a homestay and I’m legal. Ms. Sasaki: So is it your testimony that when you met with the planning department, they sought $10,000 from you and for... Ms. McConnell: No they didn’t - I didn’t pay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 28 Ms. Sasaki: They sought. Yeah sought $10,000 from you. And their recommendation was that you continue to operate illegally? Ms. McConnell: It was - it was like, you just can’t ha- you just - yeah. S- I guess. It was kind of like that. But then I was legal in my mind. I was legal. And I also thought that I had every right because all these years here - here I was believing that if the law, if they decided to do homestay down the road, which they said they were going to at some point, that we would be given the same, um, process that they were given in 2008. Which was I believe that, you know, you ’d be notified, you have a right to - to apply for a permit, and you would be grandfathered the same as everyone else. I mean the idea - I understood that the idea for the visitor destination area. And I went through paperwork and read it. And the idea is to build on a community. To build the community. To allow people to have their homes and live in their community and not be inundated by a bunch of homes that are not occupied by anyone other than those outside of the community. And so my - we all believed that th- this was - this ordinance was for us, to protect us, to keep us safe, to keep us in our homes, to keep us with building our community. It never occurred to me for a minute that there would be anything other than that, that would occur. So I never thought that - I thought I should be grandfathered in. Of course. Like everyone else was. Ms. Sasaki: Well, I ha- what is your understanding of how everyone else was grandfathered in? Ms. McConnell: Um, when everyone in our community applied in 2008 with the TVR’s there was - they - they got the draft persons and helped with all the paperwork, who helped them do the applications, then the place then - then they got to buy the permit and then the permit gran- I mean I think out of our community of 400, 80 were grandfathered in as TVR’s and they don’t live in - in the area. Ms. Sasaki: Where - where - how do you derive at this system? Ms. McConnell: That was through a flood independent information. During the flood information that we had meetings and how many people are TVR’s that - of people who live outside the island. Ms. Sasaki: Are you aware that when - when Ordinance 1- 1004 was passed that homeowners had an opportunity to obtain licenses pursuant to that - or, sorry, Ordinance 1002 was passed that o- that homestay owners were - had the opportunity to obtain the necessary permits to - to have a homestay? Ms. McConnell: Can you repeat that? Ms. Sasaki: Okay. When - when Ordinance 1002 was passed, were you aware that KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 29 homestay owners had the opportunity just this TVR owners had the opportunity when 864 was passed to obtain necessary permitting for them to continue their business? Ms. McConnell: When I asked the county planning after meeting with Bambi they said there wasn’t permit. That I couldn’t apply. There was no application. Ms. Sasaki: Because? Ms. McConnell: They just said there is none. There was a tall guy, 6’1”, (light hair). Ms. Sasaki: Um, okay. So you testified that from June - April 2018 to June 2019, uh, you - there was no rental owing to, uh, flood damage or - or a consequence of the rain in April? Ms. McConnell: As a consequence of the federally declared disaster. Ms. Sasaki: Yes. The rainstorm. Um, in - so now let me ask you, uh, between June ni- 2019 and the present, have you been renting your homestay and advertising your homestay? Mr. Kugle: Objection. Irrelevant. This, uh, purpose of this hearing is on the May, uh, 2017 notice of violation. Ms. Sasaki: I disagree. I disagree because the - the clearly the petitioner doesn’t understand what the law is and - and - and continues to flout it because she thinks it’s wrong. So I mean this just goes to the fact that she’s continuing - despite the best efforts of the planning department and they’ve taken enormous efforts with her, she insists on continuing this - this - this, uh, behavior. And they’ve been taking enormous efforts to notify her, to give her an opportunity to mediate, to no avail. Mr. Kimura: Okay. Mr. Kugle, any... Mr. Kugle: Um, yeah. This is a single violation that was issued, uh, on May of 2017. There’s no violation for any continuing violation or anything like that. Ms. Sasaki: Well the... Mr. Kugle: So we’re - what we’re litigating is the May 2017 notice of violation. Ms. Sasaki: The notice of violation says that you can pay a civil fine not to exceed $10,000 and your liable to pay a civil fine up to $10,000 per day. So that’s not a facture there was a single violation. The petitioner was warned not only in person by the planning department personally, but by a letter that ongoing KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 30 behavior would be subject to continued - continued fines. And she still didn’t believe that that was the law. Mr. Kimura: Okay. Objection overruled. So you may proceed... Ms. Sasaki: Okay. Mr. Kimura: ...Ms. Sasaki. Ms. Sasaki: Okay. So, between tw- June 2019 and the present, have you been renting out of your homestay? Ms. McConnell: Um, presently? Um... Ms. Sasaki: Not presently. From June 2019 to the present, have you ever rented out - have you rented your homestay? Ms. McConnell: 2019 when they opened the road in June? Ms. Sasaki: To the present. Ms. McConnell: Now if it’s friends that come can I have friends come stay at my home? I mean am I allowed to have visitor in my home? Ms. Sasaki: I’m not here to answer the questions. You’re here to answer the questions. Have you rented out your o- your house as a homestay or advertised it as a homestay between June 2019 and the present? Ms. McConnell: I had some friends stay (unintelligible) because I’m still under - I’m still in recovery phase from this federal declared disaster. I have tremendous expenses that have to take care of. So I do have friends who stay with me. Uh, right now no. No not right now. Ms. Sasaki: So you have. So the answer is yes I’ve had friends and people stay with me. Ms. McConnell: I’ve had friends and people stay with me, um... Ms. Sasaki: So you - no so you... Ms. McConnell: ...(unintelligible). Ms. Sasaki: ...can defray the costs of the damage of the storm. Ms. McConnell: Yeah. I have to. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 31 Ms. Sasaki: Okay. So that - so then the answer is yes. Ms. McConnell: Mm-hm. Ms. Sasaki: Okay. Um, so you’ve got notice by mail that your operation is illegal. You had notice you were in a meeting with the planning department that your operation is illegal. There was a finding by the planning department that you’re subject to $10,000 fine and $10,000 per day because your operation was illegal. What - what will stop you from operating an illegal bed and breakfast? I mean... Mr. Kugle: Objection. Badgering a witness. Ms. Sasaki: I - I - I don’t think it’s badgering but... Mr. Kimura: It’s, um, sustained. Ms. Sasaki: Okay. What - when will you - okay. Do you currently believe that there’s a law in place preventing homestay operating outside a visitor destination area? Ms. McConnell: Um, it appears that the planning department is putting something in place to prevent people who live in their home from being able to rent their home out as they please. That’s my understanding. I... Ms. Sasaki: Okay. So you disagree... Ms. McConnell: ...(unintelligible). Ms. Sasaki: ...with the law. You... Ms. McConnell: I... Ms. Sasaki: ...disagree with it. Ms. McConnell: You know, also do you disagree with the law that we should have the right to be grandfathered if we’ve been doing business for many, many years? Is that a law? You’re a lawyer. Is that a law? Ms. Sasaki: I’m not here to answer the questions. You’re here to answer the questions. Ms. McConnell: Well you ’re asking me if I’m disagreeing with the law. And I’m asking you if you are. Because I’m understanding that I have the right to be grandfathered in. Ms. Sasaki: What - how... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 32 Ms. McConnell: At least given that choice. Ms. Sasaki: Yeah. The planning department has sent you a notice of violation. The planning department has sent you a - a zoning compliance notice. The planning department has had a meeting with you indicating that this is not against the - this is against the law. So what leads you to think it’s not against the law? Ms. McConnell: Because I have the right to be grandfathered in. Everyone else did. Everyone else had that right. Why wouldn’t I? Ms. Sasaki: Okay. So is it your intention to continue renting out your homestay? Ms. McConnell: I have a lot to think about because like I said, we just went through 14 months of being traumatized with a financially and psychologically with a disaster. I don’t know if you ’ve ever read the international laws around that. But there are guidelines to be followed to help us during recovery. I don’t see any help coming for recovery. I have to try and figure out how am I going to recover this. I have loss - huge losses and damages that were not - I got no help, recovery bills. And I don’t know what to do. Basically I have to take care of my property. I have to take care of myself. I’m isolated where I’m at. I’m - I have nobody. I’m isolated. Ms. Sasaki: And in 2017 when you were operating your homestay, that was before the storm so what compelled you to operate the homestay in 2017, uh, versus the notices from the planning department? Ms. McConnell: To - to keep - to keep my property maintained. To maintain my mortgage payment, my taxes. The county assessor that had increased my taxes to cover the, um, as a hotel. So my taxes had tripled I believe they went from $2000 something, they went to $8000 something. I have so many more expenses. So and also at the assessor’s office is charging me that for a hotel when... Ms. Sasaki: So your position is that you’re entitled because you have bills to- that - to break the law. Mr. Kugle: Ob- I’m going to finally object because I mean it’s been asked and answered. She has said... Ms. Sasaki: Sh... Mr. Kugle: ...time and time again that she believed that she was grandfathered. And... Ms. Sasaki: She - but believing you ’re grandfathered and actually being... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 33 Mr. Kimura: Uh, Ms. - Ms. Sasaki, let Mr... Ms. Sasaki: All right. Mr. Kimura: ...Kugle finish. Mr. Kugle: So she believed - she explained in the meeting with the planning department that she believed she was grandfathered. And that’s the answer to these questions. And I don’t know how many times - it’s getting repetitive. I don’t know if you’re going to expect a different answer but that’s been asked and it’s been answered. Mr. Kimura: Ms. Sasaki? Ms. Sasaki: Well, what I’m trying to get at is, um, whether your client thinks that her wishes or desires or hopes for what the law ought to be, um, supersede what the law actually is, that’s where I - that’s what I - what I’d like to know. Because you said she believed it or - and sh- she be- she believed it. She continues to believe it. So how - what - what is the planning department - what - what did - what - what - what are they - how are they obligated to give notice to a person who refuses to understand what the law is? Mr. Kimura: Okay. Um, the objection is sustained. Um, Ms. McConnell did answer. Um, what you ’re asking for I guess is her rationale. But - but I think it’s clearly... Ms. Sasaki: I think it... Mr. Kimura: ...(unintelligible)... Ms. Sasaki: ...that’s clear. Mr. Kimura: ...already answered the question so... Ms. Sasaki: Yeah. Mr. Kimura: ...you can move on... Ms. Sasaki: I - okay. Mr. Kimura: ...Ms. Sasaki. Ms. Sasaki: Uh, I think - actually I think I have nothing further Your - Your Honor. Mr. Kimura: Okay. Thank you. Mr. Kugle redirect? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 34 Mr. Kugle: Just very briefly some redirect questions. Dawn you were being asked about the difference - your understanding of the difference in the process that occurred in 2008 versus in 2016. Do you recall those questions? Ms. McConnell: Yes. Mr. Kugle: And, I think i- and correct me if I’m wrong, your explanation was that you felt that if homestays were going to be rendered illegal outside of the VDA as TVR’s had been in 2008, that there would be a similar, non-conforming use process. Ms. McConnell: Yes. Mr. Kugle: And I think you mentioned a number of 480 or so TVR’s that were grandfathered following the 2008 change in the law. Ms. McConnell: In - in our particular community, Wainiha. Mr. Kugle: Okay. Ms. McConnell: There’s - we have like around 400 homes I suppose it is. And I think it’s - it’s somewhere between 77 and 80 that are TVR’s non-owner occupied and most of those homeowners live - all of them live outside of our area but many of them live off the island. Mr. Kugle: Okay. And, um, I - I - you were being asked, um, you know, what your belief or understanding was. Now you expressed in the meeting with the planning department that you thought that you were legal before the change in the law. And that that should be respected. Is that what you explained to the planning department? Ms. McConnell: Yes. And I - I actually thought I was still - I thought I was still legal ‘cause I - there was no opportunity to - to do a permit or - or processing in place. Mr. Kugle: Okay. And, um, I - I have no further questions. Thank you. Mr. Kimura: Okay. Is there any re-cross Ms. Sasaki? Ms. Sasaki: I have no re-cross. Mr. Kimura: Okay. Um, thank you Ms. McConnell. Okay.Mr. Kugle your next witness? Mr. Kugle: We rest. We have no other witnesses. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 35 Ms. Sasaki: I’d like to call Mike Laureta as my first witness. Mr. Kimura: Okay. Please do. Ms. Sasaki: Is he outside? Mr. Emayo: No. Ms. Sasaki: Oh. Mr. Emayo: You got to call him up. Ms. Sasaki: Oh call him? Mr. Emayo: Yeah. Ms. Sasaki: Could we - could we take a break while I contact, Mr. Laureta’s not outside. Mr. Kimura: Okay. Ms. Sasaki: So... Mr. Kimura: So, we’ll take a 5 minute recess. Recess from 10:13am – 10:24am Man: (Unintelligible). Ms. Sasaki: Okay. Mr. Kimura: (Unintelligible) then. Man: (Unintelligible) Mr. Kimura: Okay. Ah, raise your right. Do you please swear to tell the truth, the whole truth, and nothing but the truth? Mr. Laureta: Yes, I do. Mr. Kimura: Okay, thank you. Please have a seat. Ms. Sasaki: Mr. Laureta, what is your position with the Planning Department? What is your posi- what is your... Mr. Laureta: Okay. Wait, wait, wait. Let me downshift here. My - it’s... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 36 Ms. Sasaki: Well let - maybe I can... Mr. Laureta: ...Planning Program Manager in charge of enforcement. Ms. Sasaki: Okay. So as Planning Program Manager in charge of enforcement, you are well aware of the rules governing homestays in - on Kaua‘i? Mr. Laureta: Well aware. Ms. Sasaki: Right, right, right. Mr. Laureta: I am aware. Ms. Sasaki: Okay. So can you tell me basically what ordinance... Mr. Laureta: Oh boy. Ms. Sasaki: Okay. Well okay, just tell me what the law is vis-à-vis homestays in Kaua‘i. Mr. Laureta: As they are now? Ms. Sasaki: As they are now. Mr. Laureta: You can only have them in the visitor destination area. Ms. Sasaki: Right. So operating outside a visitor destination area would be illegal. Mr. Laureta: Illegal. (Unintelligible) Ms. Sasaki: When the law changed in 2016, were - were - was there a grandfathering component to that law, or were the people able to get - ah, obtain permits if they were outside the VDA? Mr. Laureta: No. Ms. Sasaki: Okay. And the legislature’s quite clear about this? Mr. Laureta: County Council. Ms. Sasaki: County Council -- well yes, yes. Mr. Laureta: Yes. Ms. Sasaki: Um, okay. Ca- the Song of the Jungle TVR - well okay, I don’t know if that’s KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 37 a - ah, 4813 Anan - Ananalu Road, which is the subject property in this - in this hearing, is - is it located outside the visitor destination area? Mr. Laureta: Yes. Ms. Sasaki: Okay. How - could you tell us why - how you know that or why that’s so? Mr. Laureta: Ah, we’re quite familiar with what’s in the VDA and what’s not. When the proposed bill came before the County Council, there was a flood of applications trying to beat the deadline. And there - whatever got in under the bell got processed. Everything that came after, we did not process. There was no such thing as grandfathering. Ms. Sasaki: Okay. Mr. Laureta: It was you apply or you don’t. So once the bill was signed by the powers that be that was the end of homestays outside the VDA. Ms. Sasaki: So - but homestays had - did have - before the - the - the law, homestays did have the opportunity to be properly permitted. Mr. Laureta: Yes. Ms. Sasaki: Yes. Mr. Laureta: And that’s where the rush was, when people... Ms. Sasaki: Right. Mr. Laureta: ...realized whoever had a homestay, ah, applied to come in. Ms. Sasaki: Ah, what - can you describe some of the - or how publicized was the changing of the law? Was it we- well known within the... Mr. Laureta: Oh, it was in the front page. You - it was - it was dominant because the County Council was trying to get a handle on these transient accommodations. And they were hearing from both sides of the- of the aisle, I mean people for, people against, people who had existing and they were concerned that they were gonna get cut off. It was like all of the planning related matters before the Planning Commission first- - excuse me -- it was well publicized in hearing notices and in the newspapers of what the approach was, the proposed bill, and the deadlines proposed in that bill. And, it was everybody who knew - everybody who wanted consideration applied. But what we found was the same thing that we found in TVRs, that no matter how well it was publicized continuously in the newspaper, on the radio, there were still gonna be people KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 38 who were gonna come in and say, “I don’t get the newspaper. I don’t listen to the radio.” Um, and we’ve had that with TVRs and homestays. We continue to have them. Ms. Sasaki: Right. Mr. Laureta: ...that when we cite that when we bust them, they’ll say - we’ll ask them, “Did you know you had an opportunity to make this legal?” Ms. Sasaki: Right. Mr. Laureta: “Oh no, I don’t read the newspaper - I don’t get the newspaper.” I’m like, “Okay.” Ms. Sasaki: Well would you agree that the obligation of a homeowner is to understand - to know and understand the law as it applies to his or her home? Would you agree? Mr. Laureta: Yes, I would agree. Ms. Sasaki: Yeah. Okay, Safe Hawaii does too, so. That’s all, I just wanted to set the stage because now we (unintelligible). So thank you. Oh you - ah, you (unintelligible). Mr. Kimura: Okay. Mr. Kugle, cross? Mr. Kugle: Yeah, I do have some questions. Mr. Laureta, your, um -- hi, Mike. Mr. Laureta: Hi, Greg. Mr. Kugle: Good to see you again. Mr. Laureta: Good seeing you. Mr. Kugle: Um, your declaration submitted in support of the motion for summary judgment, um, indicates that you’re the custodian of records for the Planning Department. Mr. Laureta: I am the spear point, yes. I like to delegate where possible. Mr. Kugle: Okay. And did the Planning Department receive a Uniform Information Act request for government records from Ms. McConnell’s lawyer relative to this property and this proceeding? Mr. Laureta: I don’t recall that. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 39 Mr. Kugle: Okay. Um, and do you, um - so you would also not recall whether the Planning Department actually produced any records for... Mr. Laureta: Yes, um, let me also say that in charge of OIP requests it’s another planner, Marisa. Mr. Kugle: And that’s Marisa Valenciano? Mr. Laureta: Yes. She could tell you definitively if we got it and what happened to it because she’s quite on point when it comes to deadlines regarding OIP. Mr. Kugle: Okay. And, so let me - let me just show you what, is Exhibit 1 to the motion for summary judgment. Um, and just let me ask if you had any involvement with handling that or responding to that UIPA request. Mr. Laureta: If this is twenty-nine- oh, July 10, 2019, that was like pretty recent. Mr. Kugle: Yeah. Mr. Laureta: She would have come to me for a file, if one existed. And the only file that would have existed would have been the cite - what do they call that, cita- the citation file. We didn’t - there was no application. Internal document communications, there wouldn’t have been any since there was no application. Um, so the only file we would have had would be the... Mr. Kimura: Enforcement file. Mr. Laureta: ...enforcement file. Okay. Now the other thing to that is because the enforcement file - there was also - this - it also applied to this, not specifically, but enforcement files that are in process, we tend to go through those with a stricter comb because the enforcement process is still in process. So it’s not a complete file. But what I’m thinking -- I’m thinking off my feet here -- is that, if letters had been issued, then those would be part of the public file that would have been available. But this one just doesn’t ring a bell. Mr. Kugle: Okay. All right. I’ll take that. Mr. Laureta: And this is - this is pretty recent too. Mr. Kugle: Ms. Sasaki was asking you about the ordinance - the homestay ordinance. Was that, um - do you know the ordinance number? Mr. Laureta: I just brought that one, Ordinance #1002. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 40 Mr. Kugle: Okay. And that - ah, what was the effective date of that? Mr. Laureta: June 3, 2016. Mr. Kugle: And when you were testifying earlier about the homestay ordinance, that’s the one you’re referring to. Mr. Laureta: This is the one that’s been out and came onto our radar screen because there was a whole bunch of discussions. And the enforcement guys do not get involved with this stuff. That’s - that’s the regulatory guys. Whatever their target or their intent was, um, it would have been driven by the regulatory section. Mr. Kugle: Yeah. Mr. Laureta: So as this came out, it just, okay, here it is, no more homestays. So the way it was told to me is no more homestays, that’s it, outside of VDA. Anybody wants to do it inside of VDA, that’s a freebee ‘cause it’s gonna be outright permitted. But - so the next question that always pops in my mind is can someone apply for it after this date? And I was told no. It ’s the same with transient vacation rentals, whatever that date was. Mr. Kugle: Right. Mr. Laureta: Can you apply for use permit, variance permit in Ag district, or the residential district, or open district? And I was told no. Okay, cool, and we just keep goin’ forward. Mr. Kugle: So you described a process that you could come in apply for a permit under this ordinance. Wasn’t it limited to like 10? Mr. Laureta: That may have been another ordinance, but this is the one that pops up that probably pro- precede- followed that - that - whatever - whatever or number it was. This one doesn’t say numbers. Mr. Kugle: Okay. And, um, but - but that was the process that you were referring to when you were testifying about, um, the bill was out there and people came rushing in to apply. Mr. Laureta: Well yeah, so whatever the number was that made the application to beat the deadline, whatever the deadline was gonna be based on when it was signed, after that could you apply, and they said you could apply - you could apply, but the Planning Department would not recommend approval. So in theory the one answer could be yes you can, but we’re not gonna support it, or the answer is no don’t even waste your breath. But since the date - from these date KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 41 of signings, we’ve never had one. Mr. Kugle: Mm-hm. Mr. Laureta: Nobody’s ever applied for a TVR outside of VDA or a homestay outside of VDA. Mr. Kugle: And, you were comparing the Ordinance 864 and the TVR restrictions to the homestay. And you , I think you testified, so you’d probably confirm for me, that unlike Ordinance 864 in 2008 for TVRs that had the grandfathering provision or the non-confirming use certificate process... Mr. Laureta: Right. Mr. Kugle: ...um, that Ordinance 1008 had none of that. You said no grandfathering. Mr. Laureta: 1002. Mr. Kugle: I’m sorry. You’re correct -- 1002. Mr. Laureta: Yeah. Yeah, there was no grandfathering. So there was discussion regarding previous homestays that were approved by the Planning Commission that pre- dated all this. Um, those weren’t thrown into this mix. It was just I can confirm what you just said, that there was no non-conf- um, non-conforming consideration. Mr. Kugle: Okay. And so the Planning Department didn’t look at, CZO Section 8-13.2, the general non-conforming use provision and say well that would apply to Ordinance 1002. Mr. Laureta: I have no idea who did what to whom and where. Mr. Kugle: Mm-hm. Mr. Laureta: Yeah, we don’t, enforcement section, we weren’t asked regarding this intent or deadlines, the numbers. Mr. Kugle: Mm-hm. Mr. Laureta: Um, we just get told to enforce. And it’s the same thing with development plans. They don’t ask us... Mr. Kugle: Mm-hm. Mr. Laureta: ...like the potential, what’s your ideas, what’s your recommendations, it’s... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 42 Mr. Kugle: So the, um... Mr. Laureta: What we get is what we get, and we don’t have input on it. Mr. Kugle: So did, um - does this ordinance supersede Section 8-13.2, the general non- conforming use? You - you’re familiar with what I’m talking about when I talk about the general non-confirming use provision? Mr. Laureta: The non-conforming use provision, yes. Mr. Kugle: Right. And that says -- and I’ll put it my terms or lay terms -- it basically says that, if there’s a change in the zoning law, then a previously lawful use can continue, um, and that the new change is not going to, ah, prohibit it. And it’s subject to some restrictions. Mr. Laureta: I get - I get what you’re saying. Yeah, I have no clue. I - I don’t have a - an idea how that’s gonna work. But I know you asked, and I point - I pointed to the County Attorneys. Mr. Kugle: Okay. And - and by the same token, the State Zoning Enabling Act Chap- Chapter, ah, HRS 46-4, which says, “Counties can’t use their zoning power to prohibit a non-confirming use,” um, you didn’t do any assessment about what - how that applies to this situation to Ordinance... Mr. Laureta: No. Mr. Kugle: ...1002? Mr. Laureta: No. Mr. Kugle: Other than your testimony today that Ms. Sasaki asked you about this overall scheme and, um, aside from your declaration that you put in in support of the motion for summary judgment, I just want to get clear whether I should be asking these questions to you or - or to, ah - to Bambi, so did you have any other involvement in Ms. McConnell’s case with the investigations or the issuance of the notice of violation, um, anything like that? Mr. Laureta: They - when the inspectors do their -- I call it hunting -- when they hunt the websites, the World Wide Web, and they come up with hits, then we talk about what’s the next step. So the research that’s done before, um - to - to make the file, they research the file and they research whatever we have in terms of permitting. Historically do we have anything in our cavern of files? And then the decision is made, okay, here’s what we got. And once it meets the threshold that there’s no permit, they made no application, they are KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 43 advertising, and they have, ah, reviews, issue the zoning compliance notice. Once the zoning - once the enforcement process starts, timelines are in play. So you have to respond, call the department to do a remediation plan. If there had been a problem, a consideration such as you mentioned, then the applicant would have or should have said in the reme- in the contact in the remediation process, um, I’m grandfathered. Here’s what I have. Do I have any consideration? What are - what are my possibilities? I was - I’ve been in business since whatever the date was that we could have said, okay, bring that forward, let’s give it first - first review, give it to the boss. Let’s see what he says. Then he - he would probably say, okay, send it up to the attorneys, let’s see what they say. And then we would take it from there. As... Mr. Kugle: Okay. Mr. Laureta: ...I recall, there was no - nothing like that came into play. Mr. Kugle: So for - for Ms. McConnell’s case you weren’t involved in the remediation process or the meeting at the Planning Department? Mr. Laureta: I would have been told if something unique had popped up like a claim towards, um, not grandfathering because for all of the enforcement cases that we have that - it’s - it - we kind of remember which ones pop up, and we have to consider for the future that I was not involved with the first meeting of the zoning compliance notice. Mr. Kugle: Mm-hm. And you don’t have any recollection of being involved, um, where maybe the inspectors who met with Ms. McConnell as part of the remediation process said she’s claiming that this law doesn’t apply to her, that she had a prior established use. Mr. Laureta: I’m not aware of that one. Mr. Kugle: Okay. Mr. Laureta: ‘Cause I would have told them bring it up the chain though the boss to the Planning Director and the County Attorney. Let’s see what they say. Mr. Kugle: Mm-hm. So other than what you’ve just described, you didn’t have any other, ah - or you don’t have any memory, I should say, of having other involvement in Ms. McConnell’s enforcement file or violation file? Mr. Laureta: Other than if - if - to get from zoning compliance notice and then the - for an NOV, notice of violation to be issued, that means there was a failure on the part of the applicant to meet the thresholds of the zoning compliance notice. So - and it could have been - we also take into account that the use did not KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 44 cease, that evidence was not - the documentation was not provided, the use was continuing, okay, issue the NOV. Mr. Kugle: Okay. And, I recall from another case -- and it might have been yourself or it might have been Ms. Ludington-Braun -- um, explaining to me what the zoning compliance notice is as opposed to the - the NOV that you mentioned. Mr. Laureta: Okay. Mr. Kugle: Um, and it was explained to me -- and maybe you can confirm this -- that - that the zoning compliance notice is like a warning letter. It says we think this is what’s goin’ on. It’s not a notice of violation. Is that correct? Mr. Laureta: Right. Right. A notice of - zoning compliance notice gives you the opportunity to come in, sit down, and we talk about it. And then we put everything up on the table, and we can consider it. And if we need to move forward, if we’ve got hard and fast evidence, then the zoning compliance notice is quite explicit as what has to occur. You have to stop the operation. You have to remove your advertising from World Wide Web. You need to submit that documentation to us. You have to cancel all of your commitments. Mr. Kugle: Mm-hm. Mr. Laureta: And if you don’t do it within a - whatever the time period is, then NOV. Mr. Kugle: Mm-hm. Mr. Laureta: And then we - many, many, many, many cases where people want to slide some dates past their - their timeframe. And people stay there, and they make comments on the website, “Yes, I enjoyed my stay.” And it’s - right there is the evidence that’s prima facie that the use never stopped, especially after the - the date of the ZCN when we expected the requirements to be met. Mr. Kugle: So I think you were talking in generalities and not Ms. McConnell’s case, but, let’s be clear. So, are you familiar with what the basis of the evidence for the initial zoning compliance notice and the eventual notice of violation was in Ms. McConnell’s case? Mr. Laureta: For this case? Mr. Kugle: Yes. Mr. Laureta: Yes. No. Mr. Kugle: Okay. And, like for the zoning compliance notice, that - that doesn’t trigger KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 45 the right to appeal to the Planning Commission or challenge, right? That all... Mr. Laureta: Yeah. Mr. Kugle: ...comes from the notice of... Mr. Laureta: Notice of violation. Mr. Kugle: You know, I - I was - you’d think I understand this better having done it for a while, but I was a little confu- I was a little confused about the process as I read it in the zoning code versus what seems to be followed in practice. And that is I read the zoning code, and specifically Section 8-3.5 on enforcement, as having a two-step process. It specifically references the issuance of a notice of violation. And then it says, if that’s not corrected, the Department can issue a notice of order. Um, and I’m wondering in - in this case that seems to be compressed, um, into one document, one warning, which is a notice of violation and order to pay fines. Mr. Laureta: It’s a two-step process, and it got hammered into us by the attorneys that, in order to preserve the applicant’s due process rights, it had to be two steps. So the first step is zoning compliance notice, which - which advises the owner of a problem, and it gives them the opportunity to come in and correct it. And if it can’t be corrected within that timeframe, then it’s a second step, notice of violation. So the notice of violation then says, okay, um, we’re gonna fine you, and you can appeal. But in the zoning compliance step there is no appeal process because it’s just a warning letter. Mr. Kugle: And so just so, I know you said you weren’t really involved with this one. But let me show you what’s been marked as - or admitted as Petitioner’s Exhibit 1. It’s also a county exhibit, Exhibit D. That is the notice of violation and - and order that you were referring to. Mr. Laureta: Okay. So she - Ms. McConnell was told to stop. You were instructed to cancel all transient accommodation commitments. On April 12, the Department met with her, confirmed that the continued transient accommodation use is a violation. So the use didn’t stop. So because the use didn’t stop, the NOV was issued and the order to pay fines. Mr. Kugle: Mm-hm. Mr. Laureta: So the ZCN is very explicit in what it requires, and if anything continues, then the NOV goes. Mr. Kugle: Okay. And - and I guess I was just - so getting back to my question about the procedures in the ordinance talking about a notice of violation to be followed KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 46 by a notice of order, um... Mr. Laureta: The - notice of order? Mr. Kugle: Yes. So, in other words, so read, ah, the second page of that notice of violation. Right? It sets out Section 8-3.5. Mr. Laureta: Okay. Mr. Kugle: And, it starts off in subparagraph one talking about the Planning Director determines somebody’s not complying with a notice of violation, then the Director may have the party responsible for the violation served by mail or delivery with an order pursuant to this section. And then that does certain things, imposes a fine, orders corrections and so forth. Right? Mr. Laureta: So order is the notice of violation. Mr. Kugle: Okay. So there is no separate order? Mr. Laureta: No, it - it’s - that’s what’s called - see, because in 3.5a, correct the violation within time specified. She did not. And then because she did not, then the $10,000 fine was put into play. And then the possibility of a $10,000 per - per day fine is a back end, ah, tool that we can use for the real onerous applicants - owners. Mr. Kugle: And who determines what the amount of the fine would be, if there’s one imposed? Mr. Laureta: The, um - we start off at 10. If there’s any effort towards compliance, we start off at 10, and during the remediation phase without the NOV in the ZCN phase, if there’s any effort, any willingness to remediate by providing us documentation, we would say we could reduce the fine depending on how fast you can remediate. So depending on how long it takes to provide us documentation that you’ve cancelled all your commitments, that you removed your website, we would offer up a reduced fine consideration. If there is no effort to do any of that and the use continues, especially after the ZCN meeting, then it’s like, nah, you know, 10. We stay at 10. Let them appeal the 10 because they made no effort to remediate, which includes no effort to cancel the website, cancel future commitments, and try and get into compliance. Mr. Kugle: Okay. Couple of questions for you on that. Um, so the - the ordinance provides a range from $500 to 10,000 for zoning code violations. Right? Mr. Laureta: Right. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 47 Mr. Kugle: Um, and so you ’re telling me it’s the Department’s policy to start with the maximum and work down. Mr. Laureta: Yes. Mr. Kugle: And, um, does the department give any explanation for why it chooses 10,000, or 500, or anything in between? In other words, is there a rationale given or an explanation for why the maximum is, or the minimum, or somewhere in between is chosen. Mr. Laureta: It depends on the willingness to work with the department. It’s - it’s more like did you earn a reduction by working with us? And if you didn’t, then okay, we’ll keep it at 10. Mr. Kugle: Okay. And is the process that you just described, you were talking specifically about something like this, like a homestay violation or you might have been referring to transient vacation rental too. Is that true for other zoning violations? Mr. Laureta: Oh yeah. Oh yeah. Mr. Kugle: So - so every zoning violation you start at 10,000 and work down? Mr. Laureta: Yes. Mr. Kugle: Okay. Mr. Laureta: And we run into people who are very onerous and we’re - we are not - we haven’t quite put into play the $10,000 a day, but we are. We’re starting it now because there are some people who believe what they want to believe, and we just say, well, you know, now that we have a possibility to put a lien on the house, we’re gonna play. We’ll play hard. And if you don’t want to meet whatever the - the zoning code, the requirements, the law, however you want to put that, if you don’t want to meet us halfway and we have to go to the NOV, and you keep the use continuing, you keep advertising, and the reviews keep proving you’re still in operation, then we will go - we can you with 10. We’ll serve up another NOV of 10. And if it still continues and we have cases, then it’s like okay, now we go 10,000 per day, and then we’re gonna work off a lien. We’re gonna put a lien on the property. Mr. Kugle: And does the, um - when you do that, you know, the daily, um, is that based on any evidence that it was actually being rented in the case of an illegal rental? Um... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 48 Mr. Laureta: I’d rather not disclose. But what - they need evidence. You need evidence to take to procure these steps. And it’s in the Inspector’s report... Mr. Kugle: Mm-hm. Mr. Laureta: ...that whatever evidence they found, however they found it, it’ll be in that report. Mr. Kugle: Okay. All right. Let me just look at my questions. I might be done. Thank you that’s all the questions I have... Mr. Kimura: Okay. Thank you. Um... Mr. Kugle: ...Mr. Laureta. Mr. Kimura: ...Ms. Sasaki, you may recross? Ms. Sasaki: Yes, please. Thank you. Mr. Kimura: I mean - redirect. Ms. Sasaki: Thank you. Would you say that in a case such as this where the homestay owner was - if she was notified on January 11, 2017 that she was in violation of a code... Mr. Kugle: Objection, misstates the evidence. Ms. Sasaki: It doesn’t actually, because according to Ms. McConnell, she did not get this until 2017 - 4-1-2017. But the - according to our records, this was just sent out on January 11, 2017. Now why she didn’t get it ‘til April, I don’t know. But we can’t start - that’s not when - when the Department first notified her. Mr. Kimura: According to the testimony so far, the first notice that Ms. McConnell got it was on April 1st because... Ms. Sasaki: Received. Mr. Kimura: Received. Ms. Sasaki: Right. Mr. Kimura: Because when it was mailed out, it was mailed out to her address, which she testified she does not receive mail at her address. So we’d have to go on that assumption. Okay? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 49 Ms. Sasaki: Okay. Let’s go on that assumption- okay. So would you say from a - a person such as Ms. McConnell, who on April 1, 2017 was notified of the zoning compliance notice that she - that she was, ah, in violation of the Section 8 - 8- 8.1(b) of the, KCC, who continued through ‘til 2017 through some of 2018 through some of 2019, would that be an onerous case? Mr. Laureta: Yes. Ms. Sasaki: Okay. So an onerous case warrants the imposition of 10,000 per - dollar per say fine. Ah, would you - is that - is that - if I understood your testimony, that’s what I thought you were saying. Mr. Laureta: Yes. Ms. Sasaki: Yeah. And, ah, it is the policy now of the Planning Department where people just flout the law, just ignore the law because they don’t think the law’s right or it doesn’t apply to them, we - the Planning Department imposes a $10,000 per day fine? Mr. Laureta: We can. Ms. Sasaki: Yeah. Mr. Laureta: Now the issue - well... Ms. Sasaki: Yeah, ah... Mr. Laureta: I won’t go there. Ms. Sasaki: ...okay. I - that’s - I’m done. Mr. Kimura: Okay. Um... Mr. Kugle: A brief - brief recross. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: The Planning Department was in charge of the Kuhio Highway passes for homeowners beyond the flood-damaged area. Correct? In April - April... Mr. Laureta: Oh... Mr. Kugle: ...2018. Mr. Laureta: Okay, the flood. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 50 Mr. Kugle: Yeah. Mr. Laureta: Okay. Okay. Yes, we issued passes. Mr. Kugle: And how long was that restricted access to the north shore, um, in place? Mr. Laureta: Not the north shore, just Wainiha and Haena. Mr. Kugle: Okay. Mr. Laureta: Um, I couldn’t give you the dates, but I can give you the frustration. Mr. Kugle: You were actually involved in handing out those permits. Right? Mr. Laureta: Yes. Mr. Kugle: And, um, you would not have given out any permits to anybody who was going to a transient vacation rental or a homestay. Right? That was just simply prohibited during the time period that access was restricted. Correct? Mr. Laureta: That was the theory that got put into play. But we heard a lot of conflicting testimony from the residents out there, that illegal TVR - legal and illegal TVRs were getting their people in by boat or by false documentation at our counter, that the homeowner would come in for a - their car -- they would say their car -- and give it to their clients. Mr. Kugle: Now with respect to Ms. McConnell, you have no evidence that that happened. Right? Mr. Laureta: No, no, no. Mr. Kugle: No. Okay. Um, and then that condition was recently... Mr. Laureta: Well, Greg, wait. Specifically her... Mr. Kugle: Yes. Mr. Laureta: ...on my memory banks no, but because I had the rest of my enforcement team there, somebody like - there were one - wait -- Jodi, Chance, Joan, Bambi, Bill, and then Alfred -- six others I oversaw, and they - Joan would know pretty specifically who the illegals were that were sliding in people because she took it - I don’t know how - how she had the energy for it, but we dealt with a lot of complaints, and we - we didn’t have the energy to chase those. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 51 Mr. Kugle: Okay. Mr. Laureta: But... Mr. Kugle: Okay. So it... Mr. Laureta: ...specifically... Mr. Kugle: Yeah. Mr. Laureta: ...me no, but there’s five others on that team could or would. Mr. Kugle: Okay. So they - that person might come in here and testify and tell us, “Yes, Ms. McConnell was one of those violators during that time period,” but... Mr. Laureta: I could go ask if Joan is in - Joan, Bill, Bambi may or may not know, Alfred may or - yeah, he’s no longer with the department. Mr. Kugle: Okay. Mr. Laureta: ...um, Jodi and Chance. So I can go back and - and, if I find ‘em if they say yes, then I’ll tell ‘em, you go - go to the hearing. Mr. Kugle: Well then I’d object ‘cause they’re not on the witness list. Mr. Laureta: Yeah. Ms. Sasaki: Well Joan is on the witness list. Joan Ludington Braun is on the witness list. Mr. Laureta: She is? Mr. Kugle: Yeah. Ms. Sasaki: Yes. Mr. Laureta: Okay. Mr. Kugle: Yup. All right. Um, just so I understand the process, if somebody disagrees with the notice of violation, an order that they get, um, that says that they’ve done something the Planning Department believes is in violation of the zoning code, they have the right to appeal that. Mr. Laureta: Yes. Mr. Kugle: And that’s where we are right now for this case -- right -- in the Planning KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 52 Commission appeal process? Mr. Laureta: Right. Mr. Kugle: And the Planning Commission will ultimately decide whether the Department was correct. Mr. Laureta: Well it’ll be based on the hearing officer’s recommendation. Mr. Kugle: Yeah. Mr. Laureta: The hearing officer’s recommendation will go to the Planning Commission, and then the Planning Commission will make a decision. Mr. Kugle: Yeah. Mr. Laureta: So if there’s still any disagreement over whatever the process, whatever the evidence was, then the Planning Commission can request final arguments to hear a vote before they make a decision. Mr. Kugle: Yeah. Mr. Laureta: But the best time to resolve an issue would be upon receipt of the zoning compliance notice, no matter when you get it, because whenever you get it, you can always come in and say, “Look, there’s a date of this, and I was in Tahiti for five months. I didn’t get my mail. I just got back on this date. I can show you my ticket. Um, I need to come in and we talk about this thing because, um, can we - can we reset dates - the requirements?” Mr. Kugle: Okay. Mr. Laureta: So it’s basically that zoning compliance notice puts you on notice, we found a problem, it’s best that you come in. But if you disagree or agree, whatever, that’s when you - you come in and sit down and talk with us and tell us. Mr. Kugle: And, um, just so I understand the Planning Department policy, just so we don’t have kind of questions like this, those zoning compliance notices and notices of violation tend to be sent out Certified Mail. Correct? So you have an actual signed receipt so we actually know when somebody received it. Mr. Laureta: Well because we have so many people playing games on us now on - in the enforcement process, when we have the opportunity, we send out the ZCN, we also email you, if we have an email address. If it’s an NOV, we’ll email you an advanced copy. If we have - if you have, um, representation, we’ll send a email to whoever is your representative plus Certified Mail because KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 53 we’ve had so much problem with Certified Mail previously going strictly to the owner and then the owner won’t pick it up that we proposed an administrative change to the law where we don’t need to send you certified mail. We can send you Certified Mail. You don’t pick it up, it gets returned to us in three to four weeks. Then we’re just gonna straight - we can - we have now the opportunity to post the property, to put a notice in the newspaper saying what we tried. Um, those are the two biggest ones... Mr. Kugle: Yeah. Mr. Laureta: ...that we - we won’t play the game anymore when you don’t pick up your mail. We’ll just post the property, and that’ll count. Mr. Kugle: Mm-hm. Mr. Laureta: And when we run a classified ad in a newspaper, that will count. It’ll start... Mr. Kugle: And... Mr. Laureta: ...the clock. Mr. Kugle: And so things like the return receipt for the Certified Mail or the emails, if it was emailed to a homeowner, that would be in the Planning Department’s files. Mr. Laureta: Yes. Mr. Kugle: You’d keep copies of that so that... Mr. Laureta: Yes. Mr. Kugle: ...so that... Mr. Laureta: If we had - if we had an email address on you, that’s always... Mr. Kugle: Mm-hm. Mr. Laureta: ...part of the - the file. Mr. Kugle: Okay. Okay. Um, thanks, Mike. I don’t have any further questions. Mr. Laureta: Okay. Mr. Kimura: Okay. Thank you, Mr. Laureta. Anela, can you turn the air on please? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 54 Ms. Segreti: Yeah. Mm-hm. Ms. Segreti: (Unintelligible) Mr. Kugle: Yeah. Mr. Kimura: Okay. Ah, Ms. Sasaki, your next witness? Ms. Sasaki: I’d like to call, um, Mr.... Mr. Laureta: Thanks, Greg. Ms. Sasaki: Andres Bambi Emayo. Mr. Kugle: See ya. Mr. Kimura: Okay. Mr. Emayo. Okay. Could you please raise your right hand? Do you solemnly swear to tell the truth, the whole truth, and nothing but the truth? Mr. Emayo: I do. Mr. Kimura: Thank you. Please be seated. Ms. Sasaki: Good morning. Good af... Mr. Emayo: Morning. Ms. Sasaki: Yeah, good morning still. Could you state your position at the Planning Department? Mr. Emayo: I am the supervising inspector for the enforcement section of the Planning Department. Ms. Sasaki: So would it be correct to say that you oversee investigations with respect to illegal TVRs and homestays, and things... Mr. Emayo: Yes. Ms. Sasaki: ...things of that nature? Okay. Could you describe to me the sort of timeline, the process of your introduction and interaction with Ms. McConnell? Starting with the zoning comply- well perhaps it - it prece- there was, ah, the investigation that preceded the zoning compliance notice. But, can you just tell me the events that led up to the zoning compliance letters and the NOV? Mr. Emayo: Okay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 55 Mr. Kugle: I’m - I’m gonna object, if he’s gonna be testifying from documents that I don’t have, I’m not sure about that file that just got opened. Mr. Kimura: Okay, so... Ms. Sasaki: Well I - I... Mr. Emayo: Well... Ms. Sasaki: ...I think he was gonna use this, so I’ll - this is - this is our Exhibit B, ah, the investigation report. Mr. Kimura: Okay, yeah. Okay, so he can use Exhibit B to refresh his recollection. And then if you ’re gonna be admitting that, then you need to do so. Ms. Sasaki: Okay. Mr. Kimura: Um... Ms. Sasaki: Actually, I’m gonna start with Airbnb evidence checklist dated 1-28. That’s Exhibit A. And then I’m gonna go onto Exhibit B, which is the investigation report. I think this is probably what (unintelligible)... Mr. Emayo: Okay. A report was made on January of 2016 that The Song of the Jungle TVR was fined... Mr. Kugle: I’m going to object, lack of foundation. He’s testifying from a document that’s not been admitted. Mr. Kimura: Okay. So Ms. Sasaki? Ms. Sasaki: I’d like to admit Exhibit A and Exhibit B - submit Exhibit A and... Mr. Kimura: Um... Ms. Sasaki: ...Exhibit B. Mr. Kimura: ...shouldn’t you elicit testimony to determine whether or not it’s admissible of coming in authenticated? Ms. Sasaki: Can you - can you talk to... Mr. Emayo: Okay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 56 Ms. Sasaki: Can you tell me about how - how - what these documents are and how they were - how they were drafted? Mr. Emayo: Okay. Ah... Ms. Sasaki: And were they drafted in the course of your regular business? Mr. Emayo: Okay, in our first section, we go according to findings from, prima facie evidence, any kind of advertising from the website. What we did is we pulled one of the findings is, ah, this case, which was found in 2016. We noted it, recorded it, and once it is noted and found that it was a homestay outside of the VDA, we sent a notice of - a - a zoning compliance notice to the property owner. Ms. Sasaki: Okay. So I’d like to submit Exhibits A, B, and C, which are the Airbnb evidence checklist, the investigation for it, and the zoning compliance notice prepared by the Planning Department. Mr. Kimura: Ah, Ms. Sasaki, you should do one exhibit at a time. Ms. Sasaki: Okay. Mr. Kimura: And first of all, you show the exhibit to the witness, have him or her - have him identify... Ms. Sasaki: Okay. Mr. Kimura: ...what it is and if... Ms. Sasaki: I’m - I’m show... Mr. Kimura: ...he’s familiar with it. Ms. Sasaki: I - okay. Can you describe to me what Exhibit A is? Mr. Emayo: Okay. Exhibit A is an Airbnb evidence checklist for TVR inspections. Exhibit A shows Tax Map Key 58005005, using of transient accomodations outside of the VDA. Ms. Sasaki: This was prepared as a consequence of an investigation made of one Ms. McConnell. Mr. Emayo: Yes. Ms. Sasaki: I’d like to submit Exhibit A as evidence that an investigation was performed KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 57 on Ms. McConnell. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: I think that still lacks foundation for admitting this document. Ms. Sasaki: Well this document was appended to the motion for summary judgment., so as an exhibit to the motion for summary judgment. So it’s not a new revelation to Mr. Kugle. Mr. Kimura: Well, ah, he would - may be - Mr. Kugle may be objecting to is that Mr. Emayo did not acknowledge that this is a true and correct copy of the original of the document in the enforcement file in the Department of Planning. Ms. Sasaki: Okay. Is this a true and correct copy of a - of the document in the - of the original of the document in the file of the Department of Planning? Mr. Emayo: I did create this Airbnb evidence checklist, um... Ms. Sasaki: Right. Mr. Emayo: ...(unintelligible)... Ms. Sasaki: So I’d like to submit Exhibit A as respondent’s Exhibit A. I’d like to submit the Airbnb evidence checklist TVR inspections as respondent’s Exhibit A. Mr. Kimura: Okay. Ah, Mr. Kugle? Mr. Kugle: No, objection. Mr. Kimura: Okay. Exhibit A is received into evidence. Ms. Sasaki: Could you - could you, ah, say whether this investigation report is a true and correct copy of an investigation report prepared by you, the original of which is in the Planning Department? Mr. Emayo: This is an investigation report submitted 1-10-2017 prepared by myself findings of an illegal operation outside of the VDA of homestay... Ms. Sasaki: And it’s a true and correct copy... Mr. Emayo: ...transient accommodation. Ms. Sasaki: ...of the original report? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 58 Mr. Emayo: Yes. Ms. Sasaki: I’d like to submit respondent’s Exhibit B as a true and correct copy of the investigation report prepared by Mr. Emayo. Mr. Kugle: I am going to renew the objection that I made earlier on the record for this one, which is there’s significant number of pages of this that we’ve never seen before. And I mean, in fact, aside from portions of it being attached to the summary judgment motion, we got this on August 23, not withstanding an un- responded to UIPA request that’s out there. So, that’s back to my element of unfair surprise. Ms. Sasaki: Well Mr. Kugle knows that generally there’s no discovery contested case hearings on absolute agreement of the parties. And, um, let me just, ah - just I have one - just bear with me. Okay. The Hawaii Supreme Court has held that Section 91-10(1) is intended to direct administrative agencies to admit any and all evidence presented to them limited only by considerations of relevancy, materiality, and repetition. And that’s Chalk v. Bitterman, 5 Hawaii Appeals Court 59 - ah, 65 at - at Page 59. The purpose of 91-10 (1) is to free administrative agencies from the bounds of any technical rules of evidence. And it’s intent was to require agencies to admit evidence that would have been admissi- inadmissible in common law trials. It - um, so I - so I submit that the contested case hearings have relaxed evidentiary standard and that pursuant to the holding of the Hawaiian court, ah - the Hawaiian I guess it’s the Circuit Court - okay - no, Appellate Court, ah, I say. Um, these documents ought to be admitted. Mr. Kimura: Okay. So Ms. Sasaki, before I move on Exhibit B, I don’t believe the witness authenticated the remaining pages of Exhibit B aside from just the first two pages. Ms. Sasaki: Well I was just using the pages on the, um - of the - of the, ah - I - I have - would have to go get the re- I mean you ca- I can give - I can take the remaining pages, but I - but I just was gonna use these, the ones attached to the motion of summary judgment. Mr. Kimura: Wait. Okay. So I guess - okay. So then my question is are you just requesting only Page 1 and 2 of Exhibit B to be admitted into evidence? Ms. Sasaki: No, actually I want all the - all of the exhibit admitted into evidence. So if you can... Mr. Kimura: You mean all the pages of Exhibit B. Ms. Sasaki: Right. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 59 Mr. Kimura: Right. So shouldn’t the witness authenticate the other pages in Exhibit B. Ms. Sasaki: Right. But - well then I - then I’d ask for a - a brief break so I can go and get them. I don’t have them with me. I thought we would stipulate to the admission of the evidence, so... Mr. Kimura: Okay. Um, yes, okay, so I guess you need to get, um... Ms. Sasaki: I’ll - I’ll get - I’ll get the - the exhibits. Mr. Kimura: Okay. Ms. Sasaki: Okay. Mr. Kimura: Why - why don’t you get your exhibits then? Ms. Sasaki: Okay. Okay. Mr. Kimura: Okay. So we’ll take a break. Recess from 11:19am-11:27am Ms. Sasaki: Okay. Mr. Kimura: Okay. So, well, Ms. Sasaki, you’re gonna show the exhibits to... Ms. Sasaki: Okay. Mr. Kimura: ...Mr. Kugle first. Mr. Kugle: I- is that the... Ms. Sasaki: It’s... Mr. Kugle: ...the same Exhibit B that - that, ah... Ms. Sasaki: That’s, ah... Mr. Kugle: ...you sent me that... Ms. Sasaki: ...submitted... Mr. Kugle: ...last week? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 60 Ms. Sasaki: Yeah. Mr. Kugle: Okay. Ms. Sasaki: It’s Exhibit B. Mr. Kimura: Okay. You can go ahead, Ms. Sasaki. Ms. Sasaki: Okay. So, just could you authentic - this is the, a true and correct copy of the, of the original, which is kept at the Planning Department of an investigation report and, ah, this supporting materials with respect to that report? Mr. Emayo: I acknowledge that this investigation report Exhibit B is findings that I’ve submitted January 10, 2017, along with all of the supporting pages for Exhibit B. Ms. Sasaki: For the investigative report? The petitioner would like to submit the investigation report and supporting documents at Exhibit B. Mr. Kimura: Okay. Ah, Mr. Ku... Ms. Sasaki: (Unintelligible)... Mr. Kugle: Um... Ms. Sasaki: ...respond (unintelligible)... Mr. Kugle: ...I don’t, um, have an objection as to the foundation that was laid, but I do, reiterate my objection that we asked for discovery. Discovery’s not agreed to by the Planning Department. We’re forced to serve a UIPA request on the Planning Department. And as of today, we still haven’t gotten documents produced. So I think it’s unfair surprise and should be excluded for that basis. Ms. Sasaki: Well if Mr. Kugle wants, we can continue this hearing until he has copies of all the documents until the UIPA report is given to him, if this request for documents is are rendered to him, if that’s the case. Mr. Kimura: Okay. I will admit Exhibit B over objections of the planning - of the petitioner. And as I did mentioned earlier, you know, if Mr. Kugle needs additional time after questioning Mr. Emayo and looking at Exhibit B, you know, I will entertain a request at that point in time for a continuance of this hearing. So, with that ruling, we’ll proceed, Ms. Sasaki. Ms. Sasaki: I would like you to authenticate whether this is the zoning compliance notice. It was sent to, ah, Ms. McConnell in January of 2017, received by her in April KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 61 2017. Mr. Kimura: Okay, is that part of Exhibit B? Ms. Sasaki: That’s Exhibit C. That’s Exhibit C. Mr. Kimura: Oh, Exhibit C. Mr. Emayo: I acknowledge that Exhibit C is a zoning compliance notice that was date stamped January 11, 2017. Zoning compliance notice to Patricia McConnell – Patricia McConnell. Ms. Sasaki: Respondent respectfully requests to submit Exhibit C, the zoning compliance notice from the Planning Department to Ms. McConnell. Mr. Kimura: Okay, Exhibit... Ms. Sasaki: C. Mr. Kimura: ...C is... Mr. Kugle: I - I just... Mr. Kimura: ...already admitted into... Mr. Kugle: ...renew... Mr. Kimura: ...evidence by stipulation. Mr. Kugle: ...renew my objection. Oh, I don’t think we did do Exhibit C. I think we did Exhibit D. Ms. Sasaki: D. Mr. Kimura: Oh, I’m sorry. Exhibit D? Ms. Sasaki: D is the same as... Mr. Kugle: As - as one. D and one are the same. Mr. Kimura: Oh, okay, okay. My, ah - okay. So anyway, Mr., ah, Kugle? Mr. Kugle: Um, yeah, my objection is to the late disclosure and the UIPA request alone. And so if maybe we can expedite things. If I have that running objection for the other exhibits that we’ll get to, then I won’t repeat that, if your ruling is KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 62 going to be as it was for Exhibit B. Mr. Kimura: Okay. So, I will admit Exhibit C over objections of the petitioner and note for the record that Mr. Kugle on behalf of the petitioner will have a running objection on all of the other exhibits offered into evidence by the Planning Department, and note that for the record. Ms. Sasaki: So should I submit - submit the rest of the exhibits for the record? Should I - I should - or is he su- is he accepting the rest of the exhibits, or should I submit them? Mr. Kimura: No. Well you still have to authentic all the... Ms. Sasaki: Authenticate, okay. Mr. Kimura: ...other exhibits. Ms. Sasaki: Okay. Mr. Kimura: So Exhibit C is admitted. Ms. Sasaki: Okay. D I think we already agreed. Could you authentic Exhibit E, the investigation report dated 5-16-17? Mr. Emayo: I acknowledge Exhibit E which was submitted by myself on my investigation report for the notice of violation. It ’s a notice of violation report dated 5-16-17 for ongoing homestay operation outside of the VDA. Mr. Kimura: Ah, as well as the, ah, other doc... Mr. Emayo: As we as the - along with the... Ms. Sasaki: Supporting documents here. Mr. Emayo: ...supporting documents. Mr. Kimura: Okay. So Exhibit E will be admitted into evidence over the running objection of the petitioner as previously stated. Ms. Sasaki: Um, okay. Well as I indicated earlier, could you please just describe the process of the investigation and investigation of this homestay, this illegal homestay and the steps that the Planning Department took with respect to enforcing the law, you know, with respect there too? So if you need these, I can give... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 63 Mr. Kugle: Ah, I would like to - I guess it’s not an objection, but we didn’t deal with Exhibit F to which I would have a different objection, and that was that Mr. Emayo did not prepare... Ms. Sasaki: Uh-huh. That’s why I didn’t... Mr. Kugle: ...Exhibit F. Ms. Sasaki: ...authentic it. That’s why I didn’t submit it. Mr. Kugle: Okay. Mr. Kimura: Okay. So, um... Ms. Sasaki: So, just being, if you can review the procedure with respect to the investigation of this illegal homestay... Mr. Kugle: I - the - I do - I’m sorry to interrupt again. Ms. Ludington-Braun’s statement which is Exhibit F, is also - appears to be perhaps the final page of Exhibit E and since Mr. Emayo did not prepare that, that should not, if that is, in fact, the last page of Exhibit E as well as an independent Exhibit F, it should not come in. Ms. Sasaki: I think that was inadvertent error of my secretary. So I’m more than willing to not include the letter from Britni Ludington-Braun that’s cited as Exhibit F but is contained in Exhibit E. Mr. Kimura: Okay. So, um, for Exhibit E, it will not include the last page, which would be the note to file dated April 12, 2017... Ms. Sasaki: Correct. Mr. Kimura: ...by Ms. Ludington-Braun. Ms. Sasaki: Correct. Mr. Kimura: Okay, Ms. Sasaki. Ms. Sasaki: Mr. Emayo, could you recap for the hearing the process by which you investigate illegal operating homestays? Mr. Emayo: The process is basically - what we have done in this case, we, ah - we found, ah, homestay use on the website, prima facie evidence of operation. Ah, and then what we did is in - in January of 2017 we sent out a zoning compliance notice to Patricia McConnell. The establishment of findings of a transient KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 64 accommodation operation on 4813 Ananalu Road, Tax Map Key 58005005, the use of transient accommodation operation outside of the designated VDA. Then a meeting for a response by Patricia McConnell was held on April 12, 2017. Ms. Sasaki: Let me just stop you here for one second. Mr. Emayo: Okay. Ms. Sasaki: So at the meeting of April 12, 2017, did you discuss the zoning compliance notice? Mr. Emayo: Yes. Ms. Sasaki: And what did you tell Ms. McConnell with respect to that notice? Mr. Emayo: We reiterated the zoning compliance notice dated January 20... Ms. Sasaki: Well it’s August 4’s proceeding. Mr. Emayo: ...January 2017. Ms. Sasaki: Yeah. Mr. Emayo: Which is - I don’t have the zoning compliance notice I think. Ms. Sasaki: You don’t? Mr. Emayo: No. Ms. Sasaki: I could give it to you. It should be in there. Right? Here it is. Exhibit C, zoning compliance notice. Mr. Emayo: We went over the homestay operation, which was prohibited outside of the VDA destination, ah, visitor destination area. The unauthorized use of the subject property for transient accommodation outside of the designated VDA constituted a violation. Ms. Sasaki: And, ah, this zoning compliance notice asks the homeowner to take which - what kind of action? What do they want the homeowner to do? Mr. Emayo: I got ‘em on the zoning complaints list. Ms. Sasaki: (Unintelligible) KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 65 Mr. Emayo: Pursuant to Chapter 8, Kaua‘i County code, Ms. McConnell was directed to comply with the following requirements. Immediately cease and desist the use of the subject property as transient accommodations. Cancel all transient accommodation commitments for the property. Ms. Sasaki: So she was ordered to cease, ah - cease... Mr. Emayo: Cease and desist the use... Ms. Sasaki: ...the use. And, did she, in fact, cease and desist using it as a homestay - a - a illegal homestay? Mr. Emayo: According to our findings, we found that the - the use of transient accommodations homestay has been continued. Ms. Sasaki: So she didn’t stop upon notification, ah... Mr. Emayo: Until March of 2018. Ms. Sasaki: Okay, so as a consequence of Ms. McConnell’s cease - failing to cease operations, was a notice of violation and order to pay fines transmitted to her? Mr. Emayo: Because of the findings of the use, in 5-16-17, Planning Department sent a notice of violation in order to pay fines on May 23, 2017. Ms. Sasaki: Okay. So basically from May - no, from April of 2017 through March of 2018 there were continual operations of this homestay? Mr. Emayo: I believe - well, it says that she has articulated that she was gonna keep operating in our meeting through March. Our findings for the notice of violation is up ‘til 5-16-17. Ms. Sasaki: But pursuant to that notice of violation was another notice of violation rendered? Mr. Emayo: The notice of violation that we submitted to her was on... Ms. Sasaki: Is this all - this all - that’s all one? Mr. Emayo: On May 23, 2017. Ms. Sasaki: Okay. So it’s your understanding then that Ms. McConnell’s in violation of the law because she is operating a homestay outside the VDA and continues - has - has refused up to this point to cea- stop operating one? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 66 Mr. Emayo: The notice of violation in order to pay fines was sent out to her because of the findings of the continued use of homestay operation outside of the VDA up to the point of May 23, 2017. Ms. Sasaki: And then was another investigation held in - in May of 2017? Mr. Emayo: We have continued opera- um, continued, ah, ah, investigations on the pro- property as long as the operation continued. Ms. Sasaki: Okay, so has - has Ms. McConnell ever attempted to remediate the issue within her - with her homestay? Mr. Emayo: We have no, ah.. Ms. Sasaki: No evidence? Mr. Emayo: ...evidence of that. Ms. Sasaki: Okay. All right. I’m - that’s fine. Thank you. Mr. Kimura: Okay. Ah, Mr. Kugle? Mr. Kugle: Thank you. Good morning, Mr. Emayo. Is that... Mr. Emayo: Yes. Mr. Kugle: ...pronouncing? Okay. Thank you. And you go by Bambi as... Mr. Emayo: Yes. Mr. Kugle: ...your first - nickname. Okay. Um, the first exhibit that you authenticated and that we looked at was Exhibit A, which was the Airbnb evidence checklist. Do you recall that, or do you have a copy of that in front of you? Mr. Emayo: Yes. Mr. Kugle: And you prepared that document? Mr. Emayo: I did. Mr. Kugle: Okay. ‘Cause it says, “Researched by Bambi.” Mr. Emayo: Yeah. Mr. Kugle: So, now I was trying to, ah, the second line, it’s - so it’s dated January 28, KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 67 2016. Correct? Mr. Emayo: Okay. Mr. Kugle: Which means you did this research on or about that time. Mr. Emayo: Yes. Mr. Kugle: And what specifically were you doing in terms of research? Mr. Emayo: This was, ah, ah, earlier when Mr. Laureta was explaining one of the methods used to find illegal operations. He called it hunting I believe. While we were researching the internet, the World Wide Web for transient accommodations on the island of Kaua‘i. Mr. Kugle: Okay. And so on second line it - there’s - it has investigation type with a check off box of either request of complaint. You checked off complaint. Mr. Emayo: Okay. Mr. Kugle: What does that mean? Mr. Emayo: One of the ways that we were taking in possible illegal operations was 1) through the Internet and - and always through the Internet to verify. But sometimes we would get, what I call. “complaints” through people or in this case I believe it was through real property assessments who assessed this property as a vacation rental. Mr. Kugle: Okay. So is that saying then that somebody complained about it? Mr. Emayo: Ah, we could have got it from outside or from our real property, which we still do. Mr. Kugle: Okay. Mr. Emayo: We still, um... Mr. Kugle: So do you know where this one came from? Mr. Emayo: This was - this was a real property check. Mr. Kugle: Okay. So in other words, somebody in the real property tax section... Mr. Emayo: We will periodically get assessments from the real property, if they’re doing vacation rentals to match up with our legal non-conforming uses outside of the KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 68 VDA. Mr. Kugle: Okay. And so you heard, ah -- or maybe you didn’t -- but Ms. McConnell testified earlier that the county had increased her real property taxes and was assessing her at a hotel rate. Is that consistent with what would happen if somebody’s operating some type of a transient vacation? Mr. Emayo: I have no idea of their operations. Mr. Kugle: Okay. Um, well let’s go, um - sticking with Exhibit A, it looks like you determined that she did, in fact, have a GE tax and a transient accommodation tax license. Yes? Mr. Emayo: Yes. The numbers is over the - the number is W51707089-01. Mr. Kugle: Okay. And, on the first line it’s - was the TV- oh, oh, that’s w- strike that question. And then you have Internet advertising, if found, and you’ve checked other. Correct? Mr. Emayo: Yes, I checked... Mr. Kugle: And... Mr. Emayo: ...other, being it VRBO.com #481178 and VRBO.com #130810. Mr. Kugle: Okay. And then in the next line down you checked real property tax assessment classification as vacation rental. Mr. Emayo: Yes. Mr. Kugle: So the tax people assess vacation rentals as vacation rentals, and that’s a higher tax rate than say residential. Is that your understanding? Mr. Emayo: I have no understanding of that. Mr. Kugle: Okay. So you just got that word vacation rental from the real property tax department? Mr. Emayo: No. I got a real property assessment classification off the Internet. We have the, um - what - what do they call it? They have checks or - or some kind of sheet - spreadsheet on each property... Mr. Kugle: Mm-hm. Mr. Emayo: ...on the real property (unintelligible). And their assessment of it was vacation KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 69 rental I guess. Mr. Kugle: So - so the - the county’s online property records... Mr. Emayo: Yeah. Mr. Kugle: ...um, is what you - that database you checked. And it had - um, it’s... Mr. Emayo: Vacation rental. Mr. Kugle: ...listed down as vacation rental. Mr. Emayo: Yeah. Mr. Kugle: Um, and so you - you don’t know how the tax department works, but that’s what they’re calling it. Mr. Emayo: Yes. And the reason it’s complaint - we use it as a complaint is because whatever they assess as vacation rental, we cross check it with our database on who’s a legal, non-conforming use TVR or use permit homestays. And if they’re not in there, we do further research to verify the illegal use. Mr. Kugle: Okay. And then - and just so I understand the rest of this form and - you check off boxes where you’ve done things or found things, and then you don’t check ‘em if they don’t apply. So... Mr. Emayo: Yes. Mr. Kugle: So in this case you didn’t go out and - or check for rental cars, um, ‘cause that box isn’t checked off. So... Mr. Emayo: Yes, we did. Mr. Kugle: Okay. And it’s - this is a kind of a form you fill out when you ’re doing, like you said, the hunting or just online... Mr. Emayo: Online checks, yes. Mr. Kugle: Yeah. And so this was January 28, 2016. That’s before Ordinance 1002 was passed -- correct -- which was June 3... Mr. Emayo: Yes. Mr. Kugle: ...2016. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 70 Mr. Emayo: Correct. Mr. Kugle: So I was gonna ask you why didn’t you issue a zoning compliance letter on January 28, 2016? Mr. Emayo: Could be verification - we needed more verification. Ah, the investigation wasn’t complete. Along with this World Wide Web check we have to complete a investigation report, which would be Exhibit B. Mr. Kugle: Okay. But that wasn’t done until a year later in January... Mr. Emayo: Yes. Mr. Kugle: ...2017. Mr. Emayo: Yes. Mr. Kugle: Was the reason why you didn’t do the next step, which was the investigation report, because on January 28, 2016 what Ms. McConnell was doing wasn’t illegal? Mr. Emayo: Not at all. Ah, we just had a - we have a whole bunch like this. And then we put it on the side until we get to it. And then when the next one comes up, then we do the investigation for it. Mr. Kugle: Okay. All right. So it wasn’t a question of the Planning Department waiting until Ordinance 1002 was passed six months later. Mr. Emayo: We had no idea if it was gonna pass or not or what. Mr. Kugle: Okay. But it was - apparently it was well publicized that it was coming up. Mr. Emayo: Yeah. But we don’t focus on that. Mr. Kugle: Mm-hm. Okay. Um, let’s talk about Exhibit B, which is, I think you test- testified that that was your investigative report. Mr. Emayo: Yes. Mr. Kugle: And so you in addition to filling out the first two pages, you collected the backup material that is kind of tabbed and sectioned in the back. Is that correct? Mr. Emayo: Ah, supporting the... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 71 Mr. Kugle: So the in- in... Mr. Emayo: ...supporting the face page, yes. Mr. Kugle: Yeah. Okay, and so what did you do in terms of an investigation, which generated this report? What was your process? Mr. Emayo: To find evidence for the property, to verify if the property was an illegal use - illegal, transient accommodations use outside of the VDA. Mr. Kugle: Okay. And so for this one it looks like you looked at Airbnb.com. Mr. Emayo: Ah, for the prima facie evidence, yes. Mr. Kugle: And when you say prima facie evidence, just so we understand what you’re talking about, that means that you’re searching the Internet looking for an advertisement, which you then deem to be evidence that there’s an illegal operation. Mr. Emayo: Evidence of the operation - ah, transient accommodation operations, yes. Mr. Kugle: So for in this investigative report, you didn’t, um - it was based on just that evidence of the Airbnb advertisement? Mr. Emayo: Compilation of all of the different evidence we have. According to this case, we had Airbnb, we had VRBO, we had GET taxes, and TAT taxes, along with real property assessment as vacation rental. Mr. Kugle: And just so I’m clear, who does the real property tax assessment? Is that the state of Hawaii or the County of Kaua‘i? Mr. Emayo: It is the County of Kaua‘i. Mr. Kugle: So a year later - a year before this you had a VRBO site, but in January of 2017 it was Airbnb? Mr. Emayo: Yes. Mr. Kugle: And so other than that, other than the things you just described, the existence of a GE tax license, a TAT tax license, the Airbnb ad, and the fact that the county classified this as vacation rental for real property tax purposes, that was what this investigative report was based on? Mr. Emayo: Along with the maps of the - the Tax Map Keys and zoning maps to show that the property is outside of the VDA. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 72 Mr. Kugle: Okay. I didn’t see within Exhibit B in the back up pages, the zoning map. Mr. Emayo: I believe is - I didn’t, um - I didn’t page it, but it’s in there. It’s in there after the real property page after the Airbnb website page. Mr. Kugle: Mm-hm. Mr. Emayo: It’s towards the end of the... Mr. Kugle: Okay. So that’s the one that says, “Special planning area north shore... Mr. Emayo: Yes. Mr. Kugle: ...Wainiha Valley”? Mr. Emayo: It would show - it would show the property outside of the VDA. Mr. Kugle: I’m looking at that map. I don’t see the VDA designated on it. Mr. Emayo: The VDA designation is not on it. There was no VDA around that area. Mr. Kugle: Okay. And when you refer to the VDA map, you’re talking about the maps that exist in the county that have the timeshare boundary. Is that right? A - a line des... Mr. Emayo: Yeah, they used to call them the timeshare boundaries. Mr. Kugle: Yeah. Mr. Emayo: Yes. Mr. Kugle: And that’s what it’s still on. the maps today it’s labeled timeshare... Mr. Emayo: Yeah, VDA. Mr. Kugle: ...boundary? Mr. Emayo: Yes. Mr. Kugle: So as part of the investigation which resulted in Exhibit B you didn’t actually talk to Dawn McConnell at that point in January of 2017? Mr. Emayo: Not yet. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 73 Mr. Kugle: And, you didn’t talk to any neighbors of hers? Mr. Emayo: No. Mr. Kugle: Um, you didn’t go out to the property? Mr. Emayo: No. Mr. Kugle: You didn’t talk to any people who claimed to have been renting her rooms? Mr. Emayo: I don’t - it would have been in the report. Mr. Kugle: It - it would be in the report, if you did. Mr. Emayo: It’s not in the report. Mr. Kugle: Yeah, so you didn’t at that point go out and observe rental cars in the driveway or receive a log of rental cars from neighbors or somebody else? Mr. Emayo: In this case, no. Mr. Kugle: And, you didn’t find any evidence of an actual financial transaction like an actual rental, rental contract, payments, checks, anything like that? Mr. Emayo: No. Mr. Kugle: So as a result of doing that investigation and completing that report, it looks like the following day you issued the zoning -- well when I say you, I’m talking about the Planning Department -- issued the zoning compliance notice or at least dated the zoning compliance notice. Is that right? Mr. Emayo: Okay, yes. Mr. Kugle: And that’s Exhibit C. Now I did have some questions about that as well. You usually stamp that on the date it’s prepared, so that January 11, 2017 date is the date is was prepared? Mr. Emayo: The stamp is the day that the secretary sends - send it... Mr. Kugle: Okay. Mr. Emayo: ...the actual date of, ah, that it’s sent - it’s sent out. Mr. Kugle: In Exhibits A and B I saw that, um, the reports listed both an address for Ms. McConnell in Santa Cruz, California as well as the Wainiha property address. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 74 Do you know why this Exhibit C, the zoning compliance notice was sent only to Ms. McConnell in Santa Cruz, California? Mr. Emayo: The reason why it’s sent to only to Patricia McConnell, 104 Endlich Drive, Santa Cruz, California is that it’s the address given on the real property contact person. And that is the, um - how we get the address to... Mr. Kugle: Mm-hm. Mr. Emayo: ...send our - all of our notices out. That is our first, ah - yes, yes, it’s - this - this is the first address that we get on the ownership of the property. And the - according to what we have is the owner, who is Patricia D. McConnell, 104 Endlich Drive, Santa Cruz, California 95060. Mr. Kugle: Okay. And, we don’t have any copy of a return receipt or anything else indicating the date it was received by Ms. McConnell. Mr. Emayo: Ah, we have a copy of that. However, we didn’t put ‘em in the evidence. Ah, I don’t know if it went to this property, but we usually have the green card, which we can we have the numbers for it, and they can - they’ll pop up on the - on the computers, ah, on the date of... Mr. Kugle: The - the tracking number. Mr. Emayo: Tracking number - tracking number of... Mr. Kugle: Okay. Mr. Emayo: ...who received it, when or where. Mr. Kugle: Okay. But - so that may exist, but we don’t have that in, ah... Mr. Emayo: Yeah. Mr. Kugle: ...the evidence here. Mr. Emayo: Yeah, I don’t. Mr. Kugle: Um, the - you heard - maybe you heard. Were you present this morning when Ms. McConnell testified that she actually received it on April 1st of 2017? Mr. Emayo: Yes. Mr. Kugle: Okay. And you have no reason to disbelieve that? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 75 Mr. Emayo: No. Mr. Kugle: Would the Planning Department use a process server or somebody like that to physically go hand a zoning compliance notice to a homeowner at the street address? Mr. Emayo: We do. Mr. Kugle: Okay. So the process she described could have happened here. Mr. Emayo: Could have. Mr. Kugle: Um, would your records indicate whether you had to use that process instead of the registered mail? Would that be in the file? Mr. Emayo: Yeah. Um, sometimes we put ‘em in, sometimes we don’t. Mr. Kugle: Okay, now I had a question. So you did your investigation. And the report was Exhibit B. Um, and this is alleging that there might be two different violations, Section 8-8.1(b) and Section 8-17.8. You see that? Mr. Emayo: Yes. Mr. Kugle: Um, and one relates to homestay, and the other relates to single family transient vacation rental. Mr. Emayo: Yes. Mr. Kugle: Um, well what was it that the Planning Department was claiming that Ms. McConnell was doing that was unauthorized? Mr. Emayo: Ah, we said the violation was the unauthorized use of the subject property for transient accommodations outside of the VDA, meaning, um, ah, both uses. Mr. Kugle: Okay. And which one - based on your investigation, which one did you believe she was doing at the time? Mr. Emayo: At the time we must have seen both, a house and a portion of the house, which is a house, which will be transient vacation rental and, the portion of the house, which would be a homestay. Mr. Kugle: Okay. But if it was a house, she could be living in the house, and that would then just be homestay. Mr. Emayo: She could rent out the house and live in the house or whatever. That would be KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 76 a transient vacation rental. The whole house would be a transient vacation rental. A portion of the house, would be a roo- like a room or something that. Mr. Kugle: Okay. So - so in other words, if I... Mr. Emayo: That would be homestay. Mr. Kugle: ...if I try to understand the difference between a single family transient vacation rental and a homestay, a homestay you’re renting out a portion of the house or rooms while you remain on the premises versus a single family transient vacation rental there’s no requirement that the owner be on the premises, and the whole house... Mr. Emayo: That doesn’t matter Mr. Kugle: Yeah. Mr. Emayo: (Unintelligible) where the home is. Mr. Kugle: Okay. Mr. Emayo: Transient accommodation is for a single family residence... Mr. Kugle: Mm-hm. Mr. Emayo: ...house, yeah. Mr. Kugle: So you were just being safe and covering all the bases saying it’s either a homestay or a transient vacation... Mr. Emayo: I think what happened was the, VRBO showed it was a house not clarifying the specific rooms, and the Airbnb pointed out to us that it was a homestay operation. Mr. Kugle: Now... Mr. Emayo: Being - both of ‘em being transient accommodation outside of the VDA, we cited both sections, 8-8.1, which is a homestay, and 8-17.8, which is a TVR, sections of the CZO. Mr. Kugle: Okay. The second page - so just so I’m clear, Exhibit C is not complete. You sent more than just this two-page letter. Is that right? And I ask that because on the second page it says, “We’ve attached Ordinance 1002 for your reference.” KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 77 Mr. Emayo: I believe so, yes. Mr. Kugle: And that 1002 is the one that we’ve been referring to previously in this hearing. That was the June 3, 2017 -- I’m sorry -- June 3, 2016 ordinance that said no homestays outside the VDA that Mr. Laureta testified about. Mr. Emayo: Yes. Mr. Kugle: And you would agree with Mr. Laureta that Ordinance 1002 has no mention of nonconforming use process? Mr. Emayo: I don’t agree with him. And I’m not sure. Mr. Kugle: Well let me ask it this way, and you can look at that, but, um, let me ask it this way. You’re familiar with the, um, Ordinance 864 that was past in... Mr. Emayo: Yes. Mr. Kugle: ...2008. And, ah, it’s probably been part of your job to, ah, deal with those TVRs that got nonconforming use certificates under that ordinance from 2008. Correct? Mr. Emayo: Yes. Mr. Kugle: And so it is your understanding that Ordinance 1002 relative to homestays is very different than Ordinance 864 dealing with transient vacation rentals because the homestay ordinance doesn’t have that nonconforming use certificate registration process like the TVR ordinance did? Mr. Emayo: Yes. The Ordinance 1002, the homestay ordinance did not - to my understanding they did not make an opening for people coming to certify the grandfather use because it was always open for anybody to go in to get a - what they used to call it a B&B use through a use permit process. So it was - it - you could always go in and - for a use permit. And we do have some use permits from before the ordinance for B&Bs. Mr. Kugle: Okay. And was there ever a time that the Planning Department would tell a B&B owner that there is no permitting process from a county standpoint for a B&B or a homestay? Mr. Emayo: Well at the time we didn’t have a process for homestay because the terminology wasn’t in existence. So we had. But B&B was always open. Ah, you could come in and get a use permit for a B&B, which they entertain a few before. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 78 Mr. Kugle: Okay. And so, if somebody like Ms. McConnell had come in in 2005 and talked to the Planning Department and said I bought this house, I want to operate a bed and breakfast or a homestay, whatever the term you want to use what would she have been told? Mr. Emayo: She would have been directed to the use permit process to get a B&B use permit. Mr. Kugle: Okay. And there would - I would of course, be able to go back into the 2005 version of the zoning code and find a reference to a B&B use permit. Mr. Emayo: No. That is why you could get a usage - you could try for a use permit because there is no, um - it’s not permitted in any of the zones. So that would - that would – anything not permitted or cited somehow, you could try and get a use permit process. Mr. Kugle: Okay. So if Ms. McConnell went and looked at the zoning code, she wouldn’t have found any reference to a bed and breakfast permit or a homestay permit in 2005? Mr. Emayo: There wouldn’t be. Mr. Kugle: Now, Ms. McConnell eventually contacted you after receiving the zoning compliance notice. Correct? Mr. Emayo: I believe she contacted Britni Ludington-Braun who was working with us as a contract hire to do these, these World Wide Web searches. Ah, so who I believe she created the meeting dates. Mr. Kugle: Okay. And if I remember, Britni, her real name is Joan or - or... Mr. Emayo: No. Ms. Sasaki: No, just... Mr. Emayo: Britni is a different person. That’s Joan’s daughter. Mr. Kugle: Okay. Okay. So, Britni set up a meeting, but you had a meeting - you and - well initially you and Ms. McConnell alone had a meeting on what, I guess that was April 12th of 2017. Mr. Emayo: Um, myself, and, ah, Ms. McConnell, and Britni was in the meeting. Mr. Kugle: Okay. And can you just describe to me, um, how that - obviously the purpose of that was to come in in response to the zoning compliance notice that... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 79 Mr. Emayo: Yes. Mr. Kugle: ...says, “Contact our office in 14 days.” Right? Mr. Emayo: Uh-huh. Mr. Kugle: And so how did that meeting transpire? What went on in that meeting? Mr. Emayo: We - the - at the meeting we offered clarification for remedial action for the zoning compliance notice sent on January of 2017. We basically had three directions to remedy the situation. Number 1, which would be a written response to the zoning compliance notice with our some kind of remedial action plan. Number 2 was to remove the prima facie evidence. Number 3 was to work with the Planning Department to rectify the violation. And the submission to the - to the remedial action plan would be on April 14, 2017. Mr. Kugle: Okay. And, um, so after that meeting, Ms. McConnell did prepare a letter and submit that on April 13, 2017. Mr. Emayo: Okay. Yes, I think so. Mr. Kugle: Ah, yeah, and that’s part of - part of your file of Exhibit E. Mr. Emayo: Okay. Mr. Kugle: Um, and I’m assuming that in that meeting on April 12th she told you and Britni that she didn’t believe that she believed she was legal under the prior laws and that she should be grandfathered under Ordinance 1002. Is that a fair summary of her position? Mr. Emayo: I think she was trying to prove that point, yes. Mr. Kugle: And, did you or Britni ask her to submit some evidence of that as a result of that meeting? Mr. Emayo: Ah, that could have - um, I remember her saying that. That could have been just write it down as part of your remedial action plan that you would submit before April 14 of 2017. Mr. Kugle: Okay. And so when she submitted her letter on April 13th - when she hand carried that down here. Right? Mr. Emayo: Mm-hm. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 80 Mr. Kugle: Um, and that was in response to your meeting on April 12th the next day (unintelligible)... Mr. Emayo: Yes. Mr. Kugle: And she was explaining in that letter again how, I think she said in her words, “It is my belief, however, that I have not and would never been in violation of any of the older county ordinances.” And then she explains that there’s been this change in the law. Right? Mr. Emayo: Mm-hm. Yes. Mr. Kugle: And did, um - did you or Britni kick this upstairs to Mike Laureta - and I don’t mean physical upstairs, I’m not sure where his office is. but talk that over with him, and say that she’s claiming she’s nonconforming or she’s grandfathered? Mr. Emayo: No, I don’t think so. Mr. Kugle: And your report on the first page of Exhibit E, says that,“Planning Department offered a remedial action plan to rectify the violation. Pat McConnell has accepted and signed the terms to remediate.” You see that at the bottom of Exhibit E? Mr. Emayo: Yes. Mr. Kugle: And, I’m looking at the last page of Exhibit E which begins at the top of the, page, scheduled meeting. Do you see that? It’s actually - you may have a letter from Britni Ludington Braun. That wasn’t part of Exhibit E. So go to the second to the last page, which is scheduled meeting. You see that one? Mr. Emayo: Scheduled meeting? Mr. Kugle: Yeah, it’s a page that begins at the top. It says scheduled meeting, and then it has the date, and it has some compliance plan terms. Mr. Emayo: Yes. Mr. Kugle: Ah, and so did you, um - did you ever, ah, talk to Britni about how that meeting went? Mr. Emayo: I was in that meeting. Mr. Kugle: Okay. Did... Mr. Emayo: This is my writing. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 81 Mr. Kugle: Um, did Britni ever tell you that Ms. McConnell did not sign a remedial action plan or agree to one? Ms. Sasaki: Objection (unintelligible). Mr. Kimura: Um, the rules of evidence don’t necessarily apply. Ms. Sasaki: Okay. Mr. Emayo: What was the question? Mr. Kugle: The question was did Britni tell you and also, this is admission by a party opponent, did Britni tell you that she didn’t think Ms. McConnell ever signed that action plan? Mr. Emayo: No. I didn’t - I - I cannot recall anything. She did si- um, I - this is her signature I believe. Mr. Kugle: Okay. Did you ever read a meeting report that Britni prepared about that April 12th meeting? Mr. Emayo: I think I did. Mr. Kugle: Okay. And... Mr. Emayo: Ah, I... Mr. Kugle: ...do you... Mr. Emayo: ...I cannot find that report though, that letter. Mr. Kugle: Yeah. And do you recall whether Britni said in that letter that Ms. McConnell didn’t sign the remedial action plan? Mr. Emayo: No. No, I don’t remember. Mr. Kugle: Um, you - you ’ve been handed something. Does that refresh your recollection? Mr. Emayo: No, but I see - I - I see it. Mr. Kugle: Okay. Okay. So - so you - Britni might have thought she didn’t sign that. Mr. Emayo: Okay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 82 Mr. Kugle: Um, so earlier you were telling us about the things that you wanted Ms. McConnell to do as part of her remedial action plan. And you ticked off three items. Those are the ones that are listed on this page that’s titled scheduled meeting dated April 12, 2017. Correct? Mr. Emayo: Okay, yes. Mr. Kugle: Which is a written response - so first a written response to the zoning compliance notice with a remedial action plan. Mr. Emayo: Yes. Mr. Kugle: And then secondly, remove prima facie evidence, which you explained to us means the Airbnb advertising. Mr. Emayo: Yes. Mr. Kugle: And then third, work with Planning to rectify the violation. Mr. Emayo: Yes. Mr. Kugle: Um, I just - I didn’t understand the last one. If she - if she did - if she removed the prima facie evidence and did a written response what more is there to do to rectify the violation? Mr. Emayo: We didn’t, um - we didn’t note what further actions we would need to come into compliance. Mr. Kugle: Okay. And so after the date of this form and this meeting, she did, in fact, submit a written response to the zoning compliance notice and addressed her concerns about it. Right? Mr. Emayo: Yes. Yes. Mr. Kugle: And did she, um, remove the prima facie evidence? Mr. Emayo: Not at that time, no. Mr. Kugle: Okay. And, after you folks received her written letter on - ah, that was delivered on the 13th, did, um - what was the next step from the Planning Department? Mr. Emayo: To get compliance. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 83 Mr. Kugle: And - and by that you mean you did another investigation... Mr. Emayo: Yes. Mr. Kugle: ...which ultimately ended up in the issuance of the notice of violation and order. Mr. Emayo: Yes. Mr. Kugle: And, that is Exhibit E, right? That was done in - in May after the meeting. Mr. Emayo: Yes. Mr. Kugle: And just so I understand, and that was dated May 23, 2017. Mr. Emayo: Yes. Mr. Kugle: And, in that investigative report, similar to the questions I asked you before on the zoning compliance notice, the evidence that you relied on to generate the notice of violation was a continuing Airbnb ad that was present on May 18, 2017. Mr. Emayo: Yes. Mr. Kugle: And, as part of this investigation you didn’t go out and talk to any of Ms. McConnell’s neighbors. Mr. Emayo: No. Mr. Kugle: And, you didn’t go out to the property itself. Mr. Emayo: Nope. Mr. Kugle: You did not observe any rental cars or have reports or logs of rental car activity at the site. Mr. Emayo: Instead of logs or reports, what we do is we have reviews of people who stayed on the property using the third party host website to review on the property. Mr. Kugle: So a comment posted on Airbnb or... Mr. Emayo: Yes. Mr. Kugle: ...VRBO. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 84 Mr. Emayo: Yes. Mr. Kugle: And do you contact the person who posted that on the Internet? Mr. Emayo: According to - um, we’ve made a contact with Airbnb. And according to Airbnb, people who can put their reviews onto the website are only the people who rented the property through that third party host - third party hosting companies. Mr. Kugle: Okay. So - but you don’t do anything to verify whether that’s a real person or whether they actually stayed there? Mr. Emayo: No. Mr. Kugle: Um, and by like terms you don’t have any evidence of any actual financial transaction or rental, exchange of money in exchange for a room. Mr. Emayo: Again we use the th- um, ah, when - when talking to Airbnb the people who put reviews have to do the transactions through the third party host, meaning VRBO, or Airbnb, or whatever.com. Mr. Kugle: And so who - who talked to Airbnb and VRBO? Mr. Emayo: I myself did once on - on one of the meetings that we had. Mr. Kugle: And when was that? Mr. Emayo: Oh, I’m cannot remember the date. It was a general information meeting on the phone. Mr. Kugle: And do you know who you spoke with? Mr. Emayo: No. Mr. Kugle: Ah, let me then have you look at Exhibit D, which was, um, titled, “Notice of Violation and Order to Pay Fines.” Mr. Emayo: I don’t have it. Okay Ms. Sasaki: You do. Mr. Emayo: A, B, C, I don’t have D. Mr. Kugle: I’ll give you a copy of D, if I may approach. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 85 Mr. Kimura: Ah, yes you may. Mr. Emayo: I do, I do, I do have it. Mr. Kugle: Okay. And that’s the one with the date stamp of May 23, 2017? Mr. Emayo: Yes. Mr. Kugle: Now this, um - did you prepare this? I - I know it’s not your signature on it. But did you prepare that notice of violation? Mr. Emayo: I did. Mr. Kugle: And, unlike the zoning compliance notice, this one is addressed to Patricia McConnell both at the Wainiha address as well as the Santa Cruz address. Mr. Emayo: Yes. Mr. Kugle: Okay. And, was this one sent Certified Mail? Mr. Emayo: Yes, all of our documents that are sent are sent by Certified Mail. Mr. Kugle: Okay. Do you know when it was received by Ms. McConnell? Mr. Emayo: I don’t think so. Mr. Kugle: Okay. Um, ‘cause we don’t have the return receipt or anything in the - in these exhibits. Mr. Emayo: I don’t think we put it in. Mr. Kugle: Yeah. So in the second paragraph of the notice of violation and order to pay fines, the part that starts off on April 12th talking about your meeting, it goes on to say the Planning Department confirmed that the continued transient accommodation operation (homestay) - you said the subject property is a violation. Um, and - and what was that determination based on? Mr. Emayo: Ah, an investigation on... Mr. Kugle: Well maybe I can help you. That was based on the investigation report that you did that was dated May 23, 2017 and that we looked at as... Mr. Emayo: Yes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 86 Mr. Kugle: ...Exhibit E. Mr. Emayo: Yes, Exhibit - what was - C? Mr. Kugle: E. Ms. Sasaki: E. Mr. Emayo: Okay. Yes, that’s the one. Mr. Kugle: Okay. And so, but Exhibit E was not sent to Ms. McConnell as part of the notice of violation. Mr. Emayo: No. Mr. Kugle: So she doesn’t know what, um - what other - what evidence there was to support the conclusion. She just gets the determination that it was being violated on that day. Mr. Emayo: Yes. Mr. Kugle: And I think you’ve testified earlier about that day. It was either May 16 or May 17 of 2017. Correct? Mr. Emayo: Yes. Mr. Kugle: Um, unlike the zoning compliance notice, this one says she’s only violating Section 8-18.1 on the homestays. Mr. Emayo: Yes. Mr. Kugle: And why - how - what changed between the time you issued the zoning compliance notice and this notice of violation, um, for you to go from the two violations to the one? Mr. Emayo: I sent the notice of violation according to the notice of violation investigation, which is Exhibit C. C, yeah? Mr. Kugle: No. Mr. Emayo: E. E. Mr. Kugle: E. Mr. Emayo: E -- which is Exhibit E. Ah, the findings were the continued operation of a KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 87 homestay. Ah, we didn’t know if the TVR violation had ceased or not. We had no evidence of continued use. So the notice of violation went only towards continued use of the noted, the notation from Exhibit E. Mr. Kugle: Okay. And - and that’s what you then explain -- violation -- the Planning Department has confirmed that the subject property is currently being used for a homestay operation. Continued use of the subject property for a homestay operation outside of the designated VDA constitutes the violation. Mr. Emayo: Yes. Mr. Kugle: I was a little confused because that letter goes on to quote the enforcement section of the Zoning Code 8.3.5 that talks about first there’s an - ah, it says that if somebody’s not complying with a notice of violation, the Director may have that party served with an order, and the order may require the party to correct the violation, pay a civil fine, ah, or pay civil fines per day. Correct? Mr. Emayo: Yes. Mr. Kugle: So I was confused because that - that is what this - this letter does both. Right? It is a notice of violation saying she’s done a violation. And then it is an order that she pay a $10,000 fine to the Planning Department. Mr. Emayo: No. Ah, the - the first letter that we sent was the zoning compliance notice, and they may call it something else in 8.3.5. Ah, but the first letter that we sent is the zoning compliance notice that was sent in January of 2017, which specifically states that a violation of Section 8.18.1, homestay, is illegal outside of the VDA. Mr. Kugle: Okay. And the, um - this, ah, Exhibit D then levies and orders a fine of $10,000 for that violation. Correct? Mr. Emayo: Yes. Mr. Kugle: And how did the Planning Department determine that it should be - isn’t there a range of fines available for zoning code violations? Mr. Emayo: Yes. Mr. Kugle: And the minimum being? Mr. Emayo: Five hundred to... Mr. Kugle: And the ma... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 88 Mr. Emayo: ...$10,000. Mr. Kugle: Okay. And how did, um, the Director or the Department determine that it should be 10,000 and not, um, something less? Mr. Emayo: We have a fine schedule actually, which is in-house, that was created to guide is in, um - on the ways that we are allowed to fine them. Mr. Kugle: Okay. And, does that fine schedule talk about different fines for different types of zoning violations? Mr. Emayo: Yes. Mr. Kugle: And does it talk about some factors or some criteria that the director would consider as to when a lesser or a greater fine should be imposed? Mr. Emayo: Yes, basically our fine schedule shows the specific sections that we fine on. And it’s, a range of when the remedial action is taken. Mr. Kugle: So in other words there’s - there are fines associated with each provision of the zoning code, like the homestay provision or like building setback provision. Mr. Emayo: Yes. Mr. Kugle: And so what is the fine or the range of fines for a violation like this, which is of the homestay ordinance? Mr. Emayo: The continued use, not cease, there’s no cease and desist of the illegal operation, continued use is the maximum, which is $10,000. It can be ongoing according to what we have, which we’ve never used is $10,000 per day for continued use. Mr. Kugle: Mm-hm. And, um - and just so I’m clear, Mrs. McConnell was never issued a - a prior notice of violation say for this same thing. This was the first time. Mr. Emayo: I believe this is the first notice of violation in order to pay fines, yes. Mr. Kugle: And does the fine schedule provide for like, you know, repeated violations that you have an increasing amount of a fine or... Mr. Emayo: The fine goes up to $10,000. Ah, how many times is something else. But according to what we have is the fine is from 500 to $10,000. Mr. Kugle: And, in this case the final page of the notice of violation, it, informs Ms. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 89 McConnell of her right to if she disagrees with this determination, to appeal it to the Planning Commission. Correct? Mr. Emayo: Yes. Mr. Kugle: And, I notice that the appeal period referenced in this letter is 21 days. But, it’s my understanding that the actual appeal period is 30 days. Is that your understanding as well? Mr. Emayo: I have no understanding of that. That’s, um... Mr. Kugle: So in other words, this one references a rule of the planning commission, and it says you have 21 days from the date of the adverse decision. And you don’t know if that’s been changed, or if it’s now 30 days, or anything like that? Mr. Emayo: No, this is just the part that the attorneys put in for us. Mr. Kugle: Just give me one minute to review my notes. I might be through. I’m sorry. I do have, I think one more question. You have not issued any more notices of violation to Ms. McConnell since the one that we are discussing, Exhibit D. Is that correct? Mr. Emayo: I believe we have a zoning compliance notice that was sent out for the same violation, but it’s not in none of these though. Mr. Kugle: And do you recall when that was? Mr. Emayo: I have no idea. It wasn’t sent by me. Ah, it was sent be, I believe it was Vil - Vil Balisacan. Mr. Kugle: Okay. Mr. Emayo: I only know that because it came across my desk. Mr. Kugle: Okay. I have got no further questions. Thank you. Mr. Kimura: Okay. It’s 12:40. How much more do we have to go? Ms. Sasaki: Well I have Joan Ludington-Braun, is going to testify. Mr. Kimura: Okay. Ms. Sasaki: And, we have, with respect to the Freedom of Information Act or the, the information requested, we have somebody that can testify with respect to that. It’s Marisa Valenciano. I’m - I can - I would move that she be able to testify, KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 90 since that’s been such a big subject of conversation during this hearing. According to Marisa the Department never received a request. Mr. Kimura: Well okay - well no. I mean talking about for planning purposes, so we’re gonna break for lunch. Ms. Sasaki: Mm-hm. Mr. Kimura: Um, and then we still have the redirect of... Ms. Sasaki: Right. Mr. Kimura: ...ah, Ms. Emayo - Mr. Emayo. Ms. Sasaki: And Joan Ludington-Braun, another witness. Mr. Kimura: Right. Ms. Sasaki: And I would respectfully request that Marisa Valenciano be able to testify because she can testify with respect to the - if - if, um, information were UIPA -- I always get confused -- UIPA request that Mr. Kugle has been referring to. Mr. Kimura: Okay. Well... Mr. Kugle: I don’t have an objection to having her come in for that. Mr. Kimura: Okay. And then... Ms. Sasaki: Okay. Mr. Kimura: ...after that the Planning Department would rest. And then Mr. Kugle, are you gonna have a rebuttal or rest for the evening? Mr. Kugle: I think it would be a very brief rebuttal, yes. So I don’t think there’s much more time after lunch. Mr. Kimura: Okay. So why don’t we break now, and let’s resume at 1:15 (unintelligible), yeah. Lunch Recess 12:41pm Contested Case Hearing Resumed at 1:15pm Mr. Kimura: So, um, Mr. Emayo, you’re still under oath, and you’re gonna begin with the redirect by Ms. Sasaki. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 91 Mr. Emayo: Thank you. Ms. Sasaki: One second. I just want to go back to the meeting of April 12, 2017 with Ms. McConnell - with Britni, you, and Ms. McConnell. And I just, were you clear with Ms. McConnell that the operation of her homestay was in violation of the KC- the Kaua‘i County code? Mr. Emayo: In April? Ms. Sasaki: April 12th. Mr. Emayo: Yes. Ms. Sasaki: Yes. Okay. Did she give you any indication whatsoever that she would stop? Mr. Emayo: The inquiry was to what was this about. So we offered remedial and - a remedial action plan. Ms. Sasaki: Okay. But as far as you know, she never took the remedial action plan. She never - she never did - did the remedial - the remedial? Mr. Emayo: Ah, as far as what we have is the evidence of continued operation. Ms. Sasaki: Okay. Did Ms. McConnell threaten if you tried to stop her, that she would run off into the ocean and take off her clothes, be eaten by sharks? Is that true? Is it? That’s what it says here. If we stop her from operating, she’s gonna take off her clothes, leave ‘em on the beach, and swim out to the shark and let them eat her. Do you recollect that? Mr. Emayo: When we come into, um, ah, these remedial action meetings... Ms. Sasaki: Mm-hm. Mr. Emayo: ...um, people are sometimes, without understanding what’s going on. Ms. Sasaki: Mm-hm. Mr. Emayo: Ah, sometimes, um - so - but specifically I had - I don’t remember ‘cause everybody reacts differently. Ms. Sasaki: Right. Okay. Mr. Emayo: But I had seen all kind extremes. But I don’t remember specifically what... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 92 Ms. Sasaki: But my point - but Ms... Mr. Emayo: I believe she could have been, um - I remember I was - she - she probably was upset at the - at the violation there. Ms. Sasaki: Um, but your general sense of the meeting is that she was reluctant to, she was reluctant to comply with any remedial action or to change her business as she was performing it at that time. Mr. Emayo: The evidence we have is the continued operation of the illegal... Ms. Sasaki: Right. Mr. Emayo: ...operation. Ms. Sasaki: I have no further questions. Mr. Kimura: Okay. Mr. Kugle, recross? Mr. Kugle: No, I don’t’ have any further questions. Mr. Kimura: Okay. Thank you, Mr. Emayo. Ms. Sasaki: If you’d just give me a minute, I’ll call Marisa. She needs to be here in person. Mr. Kimura: So you’re gonna have Marisa as your next witness? Ms. Sasaki: Yeah, because Joan is - is - had an appointment, but she’s coming back. So I thought I would call out of order... Mr. Kimura: Okay. Ms. Sasaki: ...just for, ah... Mr. Kimura: Is that okay with you, Mr. Kugle? Mr. Kugle: That’s fine. Yes. Ms. Sasaki: I’m trying to be... Mr. Emayo: Was I pau for the day or... Ms. Sasaki: No. Well you - you should sit. ((Crosstalk)) KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 93 Ms. Sasaki: Hi. We’re ready. Yes, thanks. Bye. Thank you, bye. She’ll be here in a second. Mr. Kimura: Oh, she’s at the o- in the other building? Ms. Sasaki: She’s just around - she’s where we usually are. You know, what our - she’s like in that - that section. Mr. Kimura: What section? Ms. Sasaki: Marisa. You know, she’s in the Planning Department building, which is near... Mr. Kimura: Oh okay, okay. Ms. Sasaki: ...where our usual... Mr. Kimura: Right, right, Moikeha. Ms. Sasaki: ...you know. Mr. Kimura: Right. Yeah, yeah. Okay? So can you remain standing and raise your right hand? Do you solemnly swear to tell the truth, the whole truth, and nothing but the truth? Ms. Valenciano: Yes. Mr. Kimura: Okay, please be seated. Ms. Sasaki: Hi. Could you state your name for the record? Ms. Valenciano: Marisa - is it on? Ms. Sasaki: I think so. Ms. Valenciano: Marisa Valenciano. Ms. Sasaki: And what’s your position with the Planning Department? Ms. Valenciano: I’m a long range planner. Ms. Sasaki: And one of your tasks as a long range planner is to answer information requests from - I always forget - is it called OPA, O-I, U-I? Ms. Valenciano: Office of Information Practices, yes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 94 Ms. Sasaki: Now earlier on in this hearing Mr. Kugle had repeatedly indicated that he had made a request and that it went unanswered. And since you’re in charge of that section I thought it would behoove us to have - to speak to you and ask what you received and when - if you answered it, when you answered it. Ms. Valenciano: So should I talk about general procedures and what we do... Ms. Sasaki: Yeah. How... Ms. Valenciano: ...about things? Ms. Sasaki: Yeah. Ms. Valenciano: Okay. So general procedures is when we get a request, um, you know, we can receive a request either by mail or email, um, over the counter. Either way it typically flows just through myself. Um, you know, and then from there I sign off to the division heads depending on the type of request that is received. Um, from there, you know, then we got ahead. By law we have 10 days - business days to then respond to that whether or not we can grant that request or not or if we can deny in part and/or grant with certain exceptions based on, I think, it’s 92F. And so with that said, we have 10 business days to respond to the applicant at that point. And from there, depending on what the ultimate conclusion is with that request, in the case of if we are able to grant it, then we would work with the applicant to grant it, to process it. Um, if it’s denied - we have to send a response at the end of the day. And so usually that’s within 10 business days. And that’s typically the procedure we are obliged to follow by law. Ms. Sasaki: Okay. So was Mr. Kugle’s request denied or was it received? Ms. Valenciano: Um, you know, to my recollection, the last request that I received was back in June 2019, and that was related to I believe a separate case, that was for James’s TVR. Ms. Sasaki: Okay. Ms. Valenciano: Anything, I haven’t received anything prior - or anything after that. That was the last request I received. Ms. Sasaki: I think Mr. Kugle said that he made the request somewhere around July 3, so that obviously... Ms. Valenciano: I haven’t received any. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 95 Ms. Sasaki: ...follows June. Ms. Valenciano: No. I haven’t received any. The last request I received was in June 2019. That was related to the James’s file. Ms. Sasaki: Is there any chance that somebody else would have gotten the request or... Ms. Valenciano: Well I don’t know who. Again, I don’t know what the request - who it was addressed to within the Planning Department. But, typically like, if it is OIP, procedure is for it to be sent to me or someone. And so I haven’t seen anything that crossed my desk related to this particular case... Ms. Sasaki: Okay. Ms. Valenciano: ...around that date. Ms. Sasaki: All right. Okay. Thank you. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: Yeah. Hi, Ms. Valenciano. Let me have you just take a look at the page we’ve been talking about. I’m gonna hand you what’s been marked as Exhibit 1 to the memo and op to the motion for summary judgment. Ms. Valenciano: Okay. Mr. Kugle: Does that refresh your recollection about whether the Planning Department received such a letter on or about July 10? Ms. Valenciano: No, I have never seen this request. Mr. Kugle: Okay. And who is that addressed to? Ms. Valenciano: It’s addressed to Kaaina Hull. Mr. Kugle: And in the normal procedure that you described, do requests come in addressed to yourself, or are they normally addressed to the Director of the Planning Department? Ms. Valenciano: It just depends on who they give the request - who they request it to, but it’s usually the Planning Department. Mr. Kugle: Okay. And would, if it went to Director Hull, would he then route it to you? Is that what would happen, if it did go to him? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 96 Ms. Valenciano: It could - correct. It would filter to myself. Mr. Kugle: And so as far as you know, this one has not made it to your desk? Ms. Valenciano: No. Mr. Kugle: And if it would get to your desk, would, in a case like this where it involves an enforcement action, would the Planning Department’s response be to provide a copy of the file or would it be to deny the request? Ms. Valenciano: Well we’re - we would treat all - all requests equally under the law. It would be - it would all go under 92F. And so if the requests were made, we would have to go through that process and, you know, determine at that point whether we can disclose the cause, allow it for inspection based on the exceptions that are provided through OIP. So I cannot make a statement like that where it would go one or the other. It just depends again on the case and, you know, what the applicant would be asking for information wise. Mr. Kugle: Okay. So like it might be the frustration exception to 92F? Ms. Valenciano: That’s one of ‘em. Mr. Kugle: And if a letter was sent by Certified Mail... Ms. Valenciano: Mm-hm. Mr. Kugle: ...um, as this one appears to be and is directed to Director Hull, would it be received and signed off by him, or would it just come in the regular Planning Department mail and the Certified return receipt be signed by anybody? Ms. Valenciano: That I have no idea who does that. And I don’t - I guess on this paper and what I’m looking in front of me there’s no indication that it was sent Certified. Mr. Kugle: Okay. At the top of the first page right where it says Director... Ms. Valenciano: Okay. It says Certified Mail. Mr. Kugle: Yeah. Ms. Valenciano: But I don’t see any receipt... Mr. Kugle: Yeah. Ms. Valenciano: ...or I don’t see... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 97 Mr. Kugle: Yeah. Ms. Valenciano: ...any - the green card that usually comes with it. So I see - I see the Certified Mail, but I don’t see the other receipts or the other parts of it that would indicate... Mr. Kugle: Yeah. Ms. Valenciano: ...it was Certified Mail. Mr. Kugle: No, the receipts not there, so... Ms. Valenciano: Right. Mr. Kugle: Um, I’m hoping to get it any second now. But, ah... Ms. Valenciano: Okay. Mr. Kugle: ...um, I don’t, and I don’t want to keep you any longer. So, basically you’re not in the process of sorting through or responding to that because you ’ve never seen it before today. Ms. Valenciano: No. And if I received it, you know, we would. again like all requests, we would process it accordingly. Mr. Kugle: Yes, you’ve done that before for me. Ms. Valenciano: I have done requests for you, so you know the procedure. Mr. Kugle: I do. Ah... Ms. Valenciano: We - we are pretty diligent about responding, making sure you get a response. Mr. Kugle: You are. Ms. Valenciano: Okay. Mr. Kugle: I don’t have any further questions. Mr. Kimura: Okay. Any redirect? Ms. Sasaki: No. Mr. Kimura: Okay. Thank you. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 98 Ms. Valenciano: Thank you. Ms. Sasaki: I’m gonna call Joan Ludington-Braun. Ah, and she should... Mr. Kimura: Is it Joan, or is it Britni? Ms. Sasaki: No, Joan Ludington-Braun is on my exhibit list - Joan. Mr. Kimura: Oh, okay. Ms. Sasaki: Um, Britni’s her daughter as we (unintelligible)...Well this - this - she’s a very important witness. Um, and she isn’t answering, so let me - okay, I’m texting her. Okay. Somebody’s going to get her. Mr. Kimura: I’m sorry? Ms. Sasaki: Somebody’s going to get Joan Ludington-Braun. Mr. Kimura: Oh okay. Ms. Sasaki: Okay. She was supposed to have been back by 2 o’clock - I mean 1 o’clock, but she doesn’t seem to have gotten back yet. Now I’d really like to call her as a witness. Could we wait for her? Is that possible? Mr. Kimura: Okay. Um... Ms. Sasaki: I mean it should be not too long. She should be coming back within 5 or 10 minutes. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: Um, so are we gonna just take a recess? I mean I’m not sure what she’s gonna testify about, and she hasn’t been involved in any of the proceedings that - ah, or any of the documents that we’ve looked at. So I’m not sure, um... Mr. Kimura: Okay. Well, Ms. Sasaki, why don’t you provide an offer of proof? Ms. Sasaki: Okay. Um, that’s what she’ll testify about? Mr. Kimura: What she would testify to. Ms. Sasaki: She, Ms. Ludington-Braun’s prepared to testify to the fact that Ms. McConnell did, in fact, rent her homestay during the time that she purportedly didn’t because of the flooding or the rain in April 2018. Um, so I don’t - that’s all I - I know. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 99 Mr. Kugle: So, again I don’t think that’s relevant to the notice of violation that we’re litigating today. Um... Ms. Sasaki: It’s directly in opposition to what the witness said. And it’s... Mr. Kimura: Well - well... Ms. Sasaki: ...it goes to the... Mr. Kimura: ...Ms. - Ms. Sasaki... Ms. Sasaki: ...credulity of... Mr. Kimura: ...Ms. Sasaki, let Mr. Kugle finish, and then you can respond. Mr. Kugle: Well yeah, that’s it, it’s irrelevant to the May 23, 2017 notice of violation that’s on appeal. So I would just say it’s irrelevant. Ms. Sasaki: But... Mr. Kimura: Okay, now Ms. Sasaki. Ms. Sasaki: I’m sorry. Yeah. And I apologize again. Um, well it’s proof of continued use, and I think that it undermines the credibility of the witness and given that that’s a question, the - what - what else - other things that she might have testified to maybe as well be questioned - in question. Mr. Kimura: Okay. So in terms of she testifying, she would have personal knowledge to the investigation being done by the Planning Department. Ms. Sasaki: Yes. Mr. Kimura: But she did not have any personal contact with Ms. McConnell. Ms. Sasaki: I don’t know that actually. I don’t know the answer to that. Mr. Kimura: Okay. Well why don’t we take a recess, and we’ll resume at 1:45 and see if... Ms. Sasaki: Okay. Mr. Kimura: ...ah, Ms. Ludington-Braun... Ms. Sasaki: Oh, she’s coming. She’s coming right now. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 100 Mr. Kimura: Oh, she’s coming now? Ms. Sasaki: Do you want to still take the recess or... Mr. Kimura: Ah, no, no. We’ll just wait for her. ((Crosstalk)) Ms. Sasaki: She said she was heading over. Mr. Kimura: She knows it’s in this room (unintelligible)... Ms. Sasaki: Liquor commission, yeah. Mr. Kimura: Moikeha - she knows that? Ms. Sasaki: Yeah. Mr. Kimura: Yeah. Okay. Ms. Sasaki: Just in case. They said she was coming from her department, so - yeah, Joan, hello? Y- ah, yeah, is Joan there? (Unintelligible) I’m gonna just check the other room. Okay? Is that okay? Ms. Segreti: She - she knows it’s here. Ms. Sasaki: She does know it? Ms. Segreti: She came here earlier. Ms. Sasaki: Oh okay. Mr. Kimura: Okay. Ms. Segreti: She came with Mike earlier. Ms. Sasaki: Oh okay, with Mike, okay. ((Crosstalk)) Mr. Kimura: Okay. Ms. Sasaki: Oh. Hi. Ms. Ludington: Hello. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 101 Ms. Sasaki: Hi. Mr. Kimura: Hi. Okay. So, could you remain standing and raise your right hand? Do you solemnly swear to tell the truth, the whole truth, and nothing but the truth? Ms. Ludington: Yes. Mr. Kimura: Okay. Thank you. Please be seated. Ms. Sasaki: Good afternoon. Ms. Ludington: Good afternoon. Ms. Sasaki: Could you state your name? Ms. Ludington: I’m Joan Ludington. Ms. Sasaki: And could you say your position with the Planning Department? Ms. Ludington: I’m a Planning Inspector for the Enforcement Division. Ms. Sasaki: Now today we’re, um - the contested case hearing concerns Ms. Patricia D. McConnell and with the property - her property in Hanalei. Are you familiar with this investigation? Ms. Ludington: I am familiar with her property... Ms. Sasaki: Mm-hm. Ms. Ludington: ...um, and a little bit with the investigation. Ms. Sasaki: Okay. Well I - um, it was Ms. McConnell’s testimony earlier that during the period, that the road to Hanalei was closed -- and I - I think I wrote that down - ah, June - April 2018 to June 2019 she did not have any rentals in her, ah - in her homestay. Um, do you have - do you have any knowledge of rentals in her homestay during that period? Ms. Ludington: Okay. Because I’m an enforcement inspector, so I monitor the Web constantly. I was also one of the, ah - we issued those passes in Wainiha and as I say, I monitor the Web. And I had came across Ms. McConnell’s website advertisement. And I did notice that she did have a review in the month of May of 2018. Now because I’m in enforcement I did do clippings of this, ah, review that came in on May of 2018. So yes, I do have paper evidence of a review that came in on May of 2018. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 102 Ms. Sasaki: And advertising on the Web is prima facie evidence... Ms. Ludington: Correct. Ms. Sasaki: ...of - ah, and do you know anything about how the issuance of passes - how that might have been accomplished or... Ms. Ludington: I also received complaints of Ms. McConnell having passengers within her vehicle. Now these were only hearsay from the complaints that were put into the department. Ms. Sasaki: Mm-hm. Ms. Ludington: Did not see it, but there was a complaint with them being in her vehicle with her. Mr. Kugle: Move to strike the hearsay. Ms. Sasaki: Rules of evidence don’t apply. I’ve... Mr. Kimura: Overruled. Ms. Sasaki: So basically you are here today to discuss this period of time and what you know about this period of time and that there was evidence on the Web of Ms. McConnell’s renting her homestay... Ms. Ludington: Right. Ms. Sasaki: ...as evidenced by a review. Yeah? Ms. Ludington: Right. Ms. Sasaki: And, the department received complaints that there were more than one pa- passenger in the car. Were the cars - were they supposed to only have one passenger or... Ms. Ludington: Um, we did not regulate how many people were in the vehicles. Ms. Sasaki: Okay. Ms. Ludington: But I guess she - people know Ms. McConnell within the Wainiha area and did make a complaint that... Ms. Sasaki: Okay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 103 Mr. Laureta: ...she had people in her vehicle. Ms. Sasaki: Okay. Um, thank you. I am done. Mr. Kimura: Okay. Mr. Kugle? Mr. Kugle: Thank you. So, Ms. Ludington-Braun when did you review this website that you mentioned? Ms. Ludington: My clippings was taken on July 10, 2018. Mr. Kugle: And you mentioned that there was a comment that was posted. Who posted the comment? Ms. Ludington: I have the evidence right here. I printed it up from my computer. It was a guest that stayed at her property, and it was left on the reviews. Mr. Kugle: Okay. And, who was the person? Ms. Ludington: Mm, it does not say who the person was. Mr. Kugle: Okay. So that was an anonymous posting? Ms. Ludington: I don’t know. This was what was on VRBO. Mr. Kugle: And, Ms. Braun, did it say that - that rental occurred in March of 2018? Ms. Ludington: It was submitted June 3, 2018, and it was a stay from May 2018. That’s what the website advertisement indicated. Mr. Kugle: Okay. So it said May? Ms. Ludington: Yes, May 2018. So at that time the road was closed. Mr. Kugle: Right. That’s why I’m... Ms. Ludington: Um... Mr. Kugle: ...having trouble understanding how... Ms. Ludington: Correct. Mr. Kugle: ...somebody - because I... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 104 Ms. Ludington: Well we searched the World Wide Web - I - every day. Mr. Kugle: Yeah. Ms. Ludington: I constantly search for new illegals and also for existing illegals. Mr. Kugle: So - so yeah, my question I guess is this. I mean there was a physical choke point on the road that would have physically prevented anybody who did not either live in the area affected... Ms. Ludington: Mm-hm. Mr. Kugle: ...um, or long-term renters who had had a prior rental contact, and it was actually the Planning Department that was monitoring that. Is that right? Ms. Ludington: I monitor everyone. I monitor, as I say, all illegals and legals. Mr. Kugle: No, no, I’m talking about the actual access down Kuhio Highway. Ms. Ludington: Ah, we issued the passes to the residents at that time. Mr. Kugle: Mm-hm. Ms. Ludington: Yes. Mr. Kugle: Okay. And so are you saying that the Planning Department issued a pass to a guest or a tenant of Ms. McConnell’s? Ms. Ludington: Ah, no, because we had to verify with residents and license plates. The - the - whoever was coming to get passes needed to provide proper documentation for the Planning Department. I’m not sure how this person got in. As I say, we also got complaints of people being in Ms. McConnell’s vehicle. Um, I just know that I was at that time clipping reviews. Mr. Kugle: Okay. And so do you know who the person or people were that was - was in Ms. McConnell’s vehicle or when that was? Ms. Ludington: No, I don’t. No, I don’t. Mr. Kugle: And, I have, um - oh, and just so I’m clear, you didn’t actually contact that person who posted that thing on the Internet. You don’t have any way to contact that person. Ms. Ludington: No. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 105 Mr. Kugle: And did you, um - so this - ah, the time period you’re talking about in May of 2018 would have literally been three weeks after, ah, the landslides and flood. Ms. Ludington: Right. Mr. Kugle: Um, and wasn’t the road like virtually actually physically impassible, not just because the Planning Department, you know, was monitoring who came and went. But I mean I’ve seen the pictures of the landslides, and some of those parts were literally obstructed. Right? Ms. Ludington: It was accessible to local residents only... Mr. Kugle: From... Ms. Ludington: ...at that point. Mr. Kugle: From what day? Ms. Ludington: From the day we started issuing passes, which was when DOT gave us the okay to go ahead. We down at the Hanalei Colony issuing passes out there. Mr. Kugle: Yeah. And - but that was how many days or weeks after the April 14, 15, 16 storms and landslides, um, did you begin issuing passes? Ms. Ludington: Ah, you know, I can’t really remember. I think it was - I know we were down - we were brought in by Michael Dahilig to issue passes down at the Colony. Mr. Kugle: Mm-hm. Ms. Ludington: I would want to say a week or so after the - and when they started opening up the roads. ‘Cause we were actually transporting people in and out with the county vehicles. Mr. Kugle: Mm-hm. Ms. Ludington: And that was in April. Mr. Kugle: It was in April that you were taking people in county vehicles. And then it was in May that you began issuing... Ms. Ludington: No, no, it was April. Mr. Kugle: ...passes. Ms. Ludington: It was April that we were issuing the passes. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 106 Mr. Kugle: Okay. Ms. Ludington: The minute DOT opened up the road to the public we started issuing passes that exact day. I was down at the Colony issuing the passes. Mr. Kugle: And you ’re pretty sure it wasn’t like May 9? Ms. Ludington: No, not - no. Mr. Kugle: Okay. And was, um - you said you were familiar with Ms. McConnell’s property. Was it damaged in the rain and the flooding? Ms. Ludington: I did not go up - I did not physically look at her property. I just know her property through the website advertisements. And then we were stationed down in Wainiha. You know, I remember Ms. McConnell coming in and to complain about people turning around in her driveway. She came down to the Colony and talked to Michael Dahilig. Mr. Kugle: Yeah. And... Ms. Ludington: So actually being at her property, I have not seen the damage that she sustained, no. Mr. Kugle: And, her complaint was that it was county vehicles coming and turning around in her driveway and front yard. Ms. Ludington: It was with Michael Dahilig. Mr. Kugle: Oh. Ms. Ludington: I was not part of the conversation, but I do know that she made a complaint with - to Michael Dahilig. Mr. Kugle: Okay. Okay. I don’t have any further questions. Mr. Kimura: Okay. Any redirect, Ms. Sasaki? Ms. Sasaki: No, I don’t have anything. Mr. Kimura: Okay. Thank you very much. Ms. Ludington: Would you like me to submit my, ah... Mr. Kimura: Um, that would be up to the County’s attorney. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 107 Ms. Sasaki: Um, well I think this is a pertinent piece of evidence, so... Mr. Kugle: I... Ms. Sasaki: ...let’s see. Mr. Kugle: And I - I would object. I’ve never seen that before today. Ms. McConnell: It’s also not true, so that’s not fair to me... Ms. Sasaki: The - the - so... Ms. McConnell: ...’cause it’s not true. Ms. Sasaki: ...I would offer the clipping day - the - okay, so you got the website information on this date. Ms. Ludington: Mm-hm. Ms. Sasaki: Okay. So the website information was obtained 7-10-2018. And the review was... Ms. McConnell: (Unintelligible) Mr. Kugle: (Unintelligible) Ms. McConnell: (Unintelligible) Ms. Sasaki: Okay. Ms. McConnell: (Unintelligible) Ms. Sasaki: Okay. So - and the date of review... ((Crosstalk)) Ms. Ludington: ...day was... Ms. Sasaki: May 2018. So this is - I - I just think that this calls into question - it’s very significant ‘cause it calls into question Ms. McConnell’s credibility. And I think it’s definitive proof that she has never intended to cease operations. She just is going to continue operations irrespective of the law or any conditions whatsoever. So I offer website information of 7-10-2018 into evidence. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 108 Mr. Kimura: Okay. So, Ms. Sasaki, please show it to Mr. Kugle. Ms. Sasaki: Oh okay. Ms. McConnell: There’s no way. I didn’t rent it. So how could (unintelligible)? The road was completely closed. It’s not even... Mr. Kugle: Okay. Ms. McConnell: ...possible. I know I didn’t. I know 100% (unintelligible)...it wasn’t. (Unintelligible) and they can review it a year later. She could have (unintelligible)...could have been them writing it. (Unintelligible) it’s just (unintelligible)...That’s when they - that’s when she posted. That’s not when she stayed. That’s when she posted. People can post a year later. There’s no name, and it’s - they always put their name. They have to because then I have to respond. Mr. Kugle: So, I still object to this for the reason I stated, and then depending on your ruling, I would - as this is the first time I’ve seen this right now, I would like the opportunity to cross examine the witness based on the document, if over my objection it’s admitted. Mr. Kimura: I will admit the evidence over the plaintiff’s objection - over the petitioner’s objections. But yes, Mr. Kugle, you can always question Ms. Ludington- Braun on that. Mr. Kugle: Ah, so Ms. Braun, you testified that - that you performed this Internet search of VRBO.com on July 10, 2018. And why did you do that that day? Ms. Ludington: As I say, I search the Web every day constantly. So I monitor illegals. Um, and I know the road is closed, ah, but I still monitored the Wainiha area as well as the rest of the island. And when I came across the review, I did notify my director of the findings. But nothing was ever done. So I put it into my case file, and that’s where it’s been. Mr. Kugle: Okay. And is that separate from the, a separate file than the regular Planning Department files about this enforcement case? Ms. Ludington: Um, as I say, I monitor the Web, and any time I find some type of a situation, I’ll go ahead and clip it and put it into my files. Mr. Kugle: Okay. But so would this go into Planning Department files such that, if there was a Uniform Information Practices Act request to the county to produce everything related to Dawn McConnell or her property, would that be one of the files that would be reviewed and either produced or objected to? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 109 Ms. Ludington: Um, at the time, because the director said we were not enforcing Wainiha, I just kept that particular file on my computer and - and a copy of it in the file, yes. Mr. Kugle: Okay. And - and why was it that you -- excuse me -- chose to, um, search for Ms. McConnell’s on July 10? Ms. Ludington: I - I search everyone. I search all the illegals. I’m constantly hitting the sites. It’s just a - a routine thing that I do when I get in. Mr. Kugle: Mm-hm. And so you referred to an anonymous comment, which I think I’m looking at on the - on the final page, that again, you said it was submitted on June 3. Um, do you know what day this person, um, actually stayed in the unit? Ms. Ludington: No. Mr. Kugle: And there was no, um, follow up to go find out who stayed out there, to go out... Ms. Ludington: It says, “Stayed in May,” and the review was in June - was submitted in - online in June. Mr. Kugle: I - I understand that that’s what somebody typed in to the Internet somewhere. I mean my skepticism is I don’t trust the Internet all that much because anybody can post anything, you know. And, so, for instance, is it your understanding of the Internet that, ah, I can post something online out there somewhere and call myself Jim Doe or John Doe, and I could say untrue things about something, and there’s no fact checker. Ms. Ludington: Well working with VRBO and Airbnb, I do know that the guests that stay at the residence are the ones that make the reviews. I’ve had cases in other cases where, um, I’ve had situations, and it was confirmed that the guests did stay at the - the people’s residence. So yeah, it comes from the guests who stay. They have a opportunity to post after their stay of their stay. And they’re the ones that will post. Mr. Kugle: Mm-hm. Um, and so you are - are trusting what somebody put when they say their stay was in May of 2018, but you didn’t independently confirm that at all? Ms. Ludington: I - I trust whatever was put onto the Web... Mr. Kugle: Okay. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 110 Ms. Ludington: ...from that people that stayed at the residence. Mr. Kugle: Well but how do you know that this person stayed at that residence on that date? And I mean there is not even a date listed here. Right? Ms. Ludington: Ah, well this is the information that I collected. Mr. Kugle: Yeah. So you’re saying it was posted on June 3, but there’s no date or dates in May that are identified. Ms. Ludington: Um, you know, because I clipped that, I only printed what I had at that time. I - I would have to go back to the rest of my clippings to see if there was an actual calendar. I only clipped the review and the evidence of it being on that website. Mr. Kugle: Okay. Ms. Ludington: I could probably go back and obtain the calendar also. I’m - I would have to go back to my - my file. Mr. Kugle: I have no further, ah, questions for this witness. Mr. Kimura: Okay. Ms. Sasaki: Okay one - one quick question. Is it your understanding that anybody can post on Ver- VRBO or B- Airbnb, anybody in the world can post whatever they want? Could you just describe the procedure or - or as you know it or as it’s been explained to you? Ms. Ludington: So from my understanding is, if you’re gonna be a guest of mine, we have our communication through VRBO or Airbnb. Ms. Sasaki: Mm-hm. Ms. Ludington: Once you stay at my residence, there is an option or opportunity for you to comment on your stay at my residence. And then that is posted online through my website... Ms. Sasaki: I see. Ms. Ludington: ...for Airbnb or VRBO. So someone else couldn’t come in and post or get into that connection of yours and my connection. Ms. Sasaki: So it’s limited to - it... KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 111 Ms. Ludington: Right. Ms. Sasaki: ...ah, they do a job of trying to limit it... Ms. Ludington: Right. Ms. Sasaki: ...to each... Ms. Ludington: Right. Ms. Sasaki: ...like and compartmentalize it (unintelligible). Ms. Ludington: Right. Ms. Sasaki: Okay. Thank you. I have nothing further. Mr. Kugle: A little redirect on that - or recross. Um, where - you said that’s your understanding of how Airbnb and VRBO work. Where did you get that understanding from? Ms. Ludington: Ah, from other cases that I’ve had to deal with getting evidence or information that they have shut down their website and what their requirements were with Airbnb or VRBO. Mr. Kugle: Okay. So do you - you spoke with somebody at Airbnb or VRBO about that? Ms. Ludington: Not at Airbnb or VRBO, but I’ve, ah... Mr. Kugle: Okay. Ms. Ludington: ...talked with the people that had their listings on those sites, VRBO and Airbnb. Mr. Kugle: Okay, so... Ms. Ludington: They’re led to provide information to me. Mr. Kugle: And you have no, you know, written instructions, or terms and conditions, or privacy policies - policies or anything else from any hosting platforms that, describe for you in writing what you just told us? So you gathered that just from talking with their people. Ms. Ludington: That had listings with Airbnb or VRBO. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 112 Mr. Kugle: Okay. Ms. McConnell: (Unintelligible) Mr. Kugle: I have... Ms. McConnell: (Unintelligible) Mr. Kugle: I have no further questions. Mr. Kimura: Okay. Thank you. Ms. Sasaki: Okay. Thank you so much. Thank you. Mr. Kugle: Um, since this is the only copy, I’m not sure what... Ms. Sasaki: I’ll... Mr. Kimura: Okay. I... Mr. Kugle: ...we do. Mr. Kimura: I was just gonna explain how we’re gonna take care of that. Okay. So in regards to Exhibit G, what I request Ms. Sasaki that you do a subsequent filing, do a supplemental exhibit list, include Exhibit G, and email it to all the parties as well as mail a hard copy, like the regular procedures. Ms. Sasaki: Okay. Mr. Kugle: I’ll ask who wrote these. Ms. McConnell: Okay, yeah. Ms. Sasaki: Okay. I will do that. Mr. Kimura: And - and your next witness, Ms. Sasaki? Ms. Sasaki: That’s - we’re done. Mr. Kimura: Okay. So you rest? Ms. Sasaki: We rest, Your Honor. Mr. Kimura: The County rests. Ah, so Mr. Kugle, will there be any rebuttal? KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 113 Mr. Kugle: Yes, brief rebuttal testimony by Ms. McConnell. Mr. Kimura: Okay, go right ahead. So Ms. McConnell, you already under oath, so you can proceed, Mr. Kugle. Mr. Kugle: Ah, Ms. McConnell, you heard, ah, what Ms. Ludington-Braun said about both her VRBO search as well as who you were traveling with in vehicles and as well as when the road was open and closed. Do you recall that? Let’s start with the road closure. You lived out at the end. So you had to deal with that every day. Is that right? Ms. McConnell: Yes (unintelligible)... Mr. Kugle: And what is your understanding or recollection of when private vehicles were allowed through the Planning Department checkpoint? Ms. McConnell: Well what I remember was that we were completely closed and couldn’t get in other than by boat. I thought it was like May 6 to like May 9 they actually opened it that we were allowed to get into town, because we were getting food, you know, shipped into us. And, um, I didn’t leave my home. You couldn’t leave your home. Mr. Kugle: Okay. And, eventually when they did open the road to private vehicles such as yours, you obtained a pass from the Planning Depart- excuse me... Ms. McConnell: Yeah. Mr. Kugle: ...the Planning Department. Ms. McConnell: We went down to the - like she said, to the Hanalei Colony. You took your vehicle, and then they wrote you up and put the sticker on your car. And they put a distinct sticker on my car that said, “No visitors.” So they would have - if I would have had a visitor that wasn’t allowed to come in, they would have checked my vehicle ‘cause they distinctly did that to me and a few other people that were TVRs. Mr. Kugle: Okay. And did at some point did you, well let me ask you first about the damage to your property. What kind of damage did you sustain, you know, during the flooding and storm? Ms. McConnell: The - the - um, one big mudslide came down on one portion of my property. Um, the road coming into my property had a big, huge sinkhole, and I had to fill it with rocks. That’s why I didn’t want the county co- you know, coming into- running over my sinkholes making them deeper and gouging it. I had - my whole driveway’s very steep. It turned into a waterfall, so all the - so all KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 114 the asphalt and everything came out. And my roof was leaking, and my whole bottom part of my house was filled with mud, and I was by myself and cleaning it up by myself. And for her to sit there and say I’m bringing in visitors, like my God. I (unintelligible) with - you don’t even know how hard this thing was for us. So they sit in the other side and don’t even check or even - I’m sorry. It’s just like wow. I just think wow. Mr. Kugle: Okay. So your property was damaged and your house was flooded and damaged as well. Ms. McConnell: Yeah, the - the hill mud came rushing in the bottom part. And then the insurance said, “Well we don’t do ground water.” So the whole thing was filled with mud. My one whole lower floor was filled with mud... Mr. Kugle: Okay. Ms. McConnell: ...this thick. Mr. Kugle: Okay. Ms. McConnell: And it’s still - I cleaned it up, but the driveway’s still ruined. My roof is still leaking, and I still have - you know, I nev- I had to - the county never came and helped me. They told me they would help me with the driveway when - ‘cause they could see they were driving in there. They said they’d help me. But they never did. I did it all by myself. Mr. Kugle: Okay. Ms. McConnell: I got the gravel put in, and I got the shovel, and I filled all those sinkholes with stones and everything by myself. Mr. Kugle: Okay. Now you heard Ms. Ludington-Braun also testify that you had gone into the Planning Department office at - where they were issuing the permits and complained about vehicles turning around on your property. Ms. McConnell: I actually called the Department of Transportation and said that they keep coming in. Because I’m at the very end of the road, I’m isolated way off in the jungle. And they’re - I’m at the very end of the road. So if people come down, there’s nowhere for them to go. So they come onto my property and turn around and go back out. So they were doing this constantly, the big trucks and everything like that. And so I called the Department of Transportation and said, “My road is getting really - it was bad, but it’s really exacerbating here. And then they came, sent a guy out. I’ve got his name written down. I just forget it. And he came out. He was the guy that was on the - on the - on the thing with the mudslides here ‘cause he was telling me what it was like that KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 115 night. And he said, “Oh yeah, I could see what you’re talking about.” And he took pictures, and he said, “As soon as we’re - as soon as we’re done, we’ll, ah, fix this.” But then they told me to go down and talk to Michael Dahilig, go down and talk to him because he could be the one that or- can orchestrate getting it fixed now or something. And then when I went and talked to Michael, he just sat there and said, “Well if you sign your property over us, the - then we’ll fix it.” He was very -- what’s the words where you’re -- disrespectful. Mr. Kugle: Okay. And so your concern was it was county and state vehicles that were coming out and turning around and... Ms. McConnell: Yeah, other people did too, but the county and state vehicles were the worst because they were bigger and heavier. Mr. Kugle: Mm-hm. Okay. Um, now... Ms. McConnell: They still do. Mr. Kugle: Okay. Now, um - and they still haven’t come out and fixed it for you. Ms. McConnell: No. Mr. Kugle: Let’s talk about how VRBO works and your understanding of that, and how this comment that we just looked at, what’s the significance of that. Ms. McConnell: Yeah, this woman is - I - this is disturbing for me because she’s making judgments about people, and she doesn’t understand this process. She’s getting information that’s not accurate. VRBO - with the VRBO system you can - you can pay a yearly fee, and you can do your rentals all on your own. They’ll - they’ll go through them, so it’s verified so people feel safe and you feel safe, but, um, somebody could post something with VRBO three years later. Like sometimes, you know, people just don’t get around to it or somethin’ like that or whatever. And - and you could - so say somebody booked through some other website, ‘cause a lot of people have multiple websites. So they - that person from that other website could contact VRBO and say - write the letter to say oh, I stayed at this particular - but I never, ever knew that they can use an anonymous letter. That’s - that wouldn’t happen because when they do it, then the name has to go there because, if a person writes a review that’s negative, you can respond more positive. You can respond and say something to it. So she’s got wrong information. It ’s not like that. She - if someone wanted to trap someone, they could just go in and write whatever they want. If someone’s mad at someone, they could go and say this is a horrible place. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 116 Mr. Kugle: And was - during this time of the flood and the landslides between April of, um, 2018 and when the road was reopened, did you ever then have to go to the mainland? Ms. McConnell: Ah, yeah, I had to go to the mainland to get a job because I couldn’t pay the - make the payment. Mr. Kugle: Okay. And - and do you remember the dates - the approximate dates that you were on the mainland? Ms. McConnell: Yeah. It’ll be like - it was either mid-July or end of July. Mr. Kugle: Okay. And then when did you come back? Ms. McConnell: And I came back April. Mr. Kugle: Okay. Okay. So you were gone for three-quarters of a year. Um, okay. And did you have to have a friend house sit your house for you? Ms. McConnell: Yes. Mr. Kugle: Okay. Ms. McConnell: And I got permission from the mayor for that. Mr. Kugle: Okay. You had to go get a special dispensation to have somebody stay in your house while you were on the mainland. Ms. McConnell: Yeah, ‘cause they wouldn’t let me have any permits for anybody. They wouldn’t let me have permits to bring in people to fix things or - I had to go through the mayor, ‘cause the one place was filled with bees. And I had to go through the mayor to even get the beekeeper out to take care of it. Mr. Kugle: Okay. I have no further questions. Mr. Kimura: Okay. Cross examination, Ms. Sasaki? Ms. Sasaki: I have no cross-examination. Mr. Kimura: Okay. No question. Thank you. Mr. Kugle: I have no further witnesses. Mr. Kimura: Okay. No further witnesses, okay. So now, Mr. Kugle, I did mention earlier that, you know, based upon the contested case hearing and the exhibits KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 117 admitted, you know, if there is any need to continue this hearing because there is additional preparation you need to do for some of the exhibits that were introduced. Do you have any inclination on that issue? Mr. Kugle: Well, what I would like to do is to get to the bottom of my UIPA request and - and get a copy, not of the self-selected exhibits that the Planning Department wanted to use, but, a copy of all of that file. And if there’s anything else significant for me in that, you know, I would want the opportunity to be able to submit that. Mr. Kimura: Okay. Now you’ve heard the testimony of Ms. Valencia that she didn’t get the request. So I presume you’re gonna be originating another one and sending it directly to her, and then she would respond within the time period required. So, how much time would you need before the determination could be made? Mr. Kugle: Well, they usually, as she said, they have to respond in a fairly tight window or short window of time. And if her testimony was 10 days, that’s probably right because... Mr. Kimura: Mm-hm. Mr. Kugle: ...she knows that job. So, I think that it would be fairly quick assuming they actually produce the records for me. So if I get a response to the UIPA request when I get back to the office, we will resend the one that was submitted on July 10. It’s not gonna change. So I think she said that they respond within 10 days - um, you know, I just want to make sure that there’s nothing else that I don’t have access to that I wanted to use for today. And if I can make that determination then that’s all I need. So I would guess that that’s probably two to three weeks. Mr. Kimura: Okay. Two to three weeks -- so assuming that there’s additional documents that are produced that you wish to have introduced or because of that, have the further evidentiary hearing on the case you would need to make a separate request. So what I’ll do is I won’t close the hearing. And I will give you 30 days to respond either with a request for a continued contested case hearing based upon the documents that the Planning Department would produce to you, if they do produce documents, or request that the contested case hearing be closed at that point. Now this is a little unusual because it’s not really contemplated by the rules. But I believe as the hearing officer, you know, I do have the opportunity and authority to modify it in certain situations. So that’s, my original inclination, ah... Mr. Kugle: That would be fine with us. Mr. Kimura: Okay, and then within 30 days you would provide your response. And based KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 118 upon your response, I would issue a minute order accordingly setting forth dates and times depending on what kind of response I get from the petition. Ms. Sasaki, do you have any comment to that procedure? Ms. Sasaki: Well I just want the opportunity like to respond, if Mr. - I mean are we gonna - is Mr. Kugle intending to brief the issues or I mean - or just continue the hearing and - I don’t understand. I don’t - I’m just unclear about what the process would be. If he - say he got - say he got, um, disclosure and he thought that there was something that further needed to be examined at an evidentiary hearing. What would the process be then? Mr. Kimura: Okay. And at that - well depending on what Mr. Kugle says in response, at that point in my minute order I may then schedule another pre-hearing and then we can talk about whether we’re gonna have to have a continued hearing and then do supplemental briefings, do additional exhibits, and in whatever... Ms. Sasaki: Okay. Mr. Kimura: ...times it takes. So that’s the first step. Ms. Sasaki: Okay. That’s - that’s... Mr. Kimura: So that’s why... Ms. Sasaki: ...I just want to have - make sure we have the opportunity to do that, if that’s the case. Mr. Kimura: Well - well depending upon what Mr. Kugle... Ms. Sasaki: Yeah. Mr. Kimura: ...replies, yes. Ms. Sasaki: Okay. That’s fine. Mr. Kimura: Okay. Is that satisfactory? Mr. Kugle: That’s fine. Mr. Kimura: Okay. So I will issue the minutes based upon today’s contested case hearing set for the procedures I just mentioned, and I’ll have the specific date in there. So 30 days would take you to September 30th, which is a Monday. Okay? Mr. Kugle: That’s fine. KAUA‘I PLANNING COMMISSION CONTINUED CONTESTED CASE HEARING MINUTES August 30, 2019 Page 119 Mr. Kimura: So, you could do response via email and also mail the hard copies. You know in the proper format, you know, just state a request or statement. Ah, well you - you know. You can just... Mr. Kugle: Yes. Mr. Kimura: ...draft something up. Mr. Kugle: Yeah, okay. Yes. Mr. Kimura: And then based upon that, you know, I will issue a minute order about what we will do after that. Mr. Kugle: Okay. Yes, understood. And so conceivably if there was nothing further that needed to be done, we’d notify you of that, and you’d follow kind of, ah, the normal, ah, process that you’ve done with submissions, and proposed findings, and closing arguments. Or if there is - if I am making such request, I think, Ms. Sasaki would have the change to respond to it, and we’d deal with that... Mr. Kimura: Yes. Mr. Kugle: ...next step. Mr. Kimura: And, um, depending upon your response, we would then have to order the transcripts for the contested case hearing. And if there will be no further, I will close it, then we’ll get the, ah, transcripts out and in the normal process, you know, either within 14 days after receipt of the transcript or 30 days, whichever’s longer, would be when the petitioner’s proposed findings of fact and conclusions of law and closing arguments would be due then 14 days after that... Ms. Sasaki: Mm-hm. Mr. Kimura: ...in the Planning Department. And then 7 days would be the reply. Mr. Kugle: That’s fine. Mr. Kimura: Okay? Ms. Sasaki: Yes. Mr. Kimura: Is that acceptable? Ms. Sasaki: Acceptable. GOODSILL ANDERSON QUINN & STIFEL A LIMITED LIABILITY LAW PARTNERSHIP LLP JOHN S. MACKEY jmackey@goodsill.com CHRISTOPHER P. ST. SURE cstsure goodsill.com First Hawaiian Center, Suite 1600 999 Bishop Street Honolulu, Hawai`i 96813 Telephone: (808) 547-5600 Facsimile: (808) 547-5880 7006-0 10001-0 Attorneys for Respondent PLANNING DEPARTMENT, COUNTY OF KAUAI BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUAI In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kauai, Hawaii, identified by Kauai TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUAI, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI'S SUPPLEMENTAL EXHIBIT LIST; EXHIBIT G; CERTIFICATE OF SERVICE CONTESTED CASE HEARING: Date: August 30, 2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura 7867425.1 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI'S SUPPLEMENTAL EXHIBIT LIST Pursuant to the direction of Hearing Officer Harlan Y. Kimura at the contested case hearing on August 30, 2019, Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUAI ("Department") hereby submits its Supplemental Exhibit List and Exhibit G. DATED: Honolulu, Hawai`i, January 17, 2020. S. MA KEY STOPHER P. ST. SURE Attorney for Respondent PLANNING DEPARTMENT, COUNTY OF KAUAI 2 COUNTY OF KAUA‘I PLANNING COMMISSION EXHIBIT LIST (SUPPLEMENTAL) CC-2017-4 TMK (4) 5-8-005:005 PETITIONERS PATRICIA D. McCONNELL PETITIONER ATTORNEY (Name, Address and Email) GREGORY W. KUGLE, ESQ. JOANNA C. ZEIGLER, ESQ. Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, Hawai‘i 96813 Email: gwk@hawaiilawyer.com RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUA‘I RESPONDENT ATTORNEY (Name, Address and Email) JOHN S. MACKEY, ESQ. Goodsill Anderson Quinn & Stifel LLP 999 Bishop Street, Suite 1600 Honolulu, HI 96813 Email: jmackey@goodsill.com DATE OF HEARING August 30, 2019 HEARING TIME 9:00 a.m. PREPARING CLERK DEPARTMENT EXHIBIT NO. IDENTIFY NO. CODE _PETITIONER √RESPONDENT OFFERRED FOR IDENTIFI- CATION RECEIVED IN EVIDENCE WITHDRAWN DESCRIPTION OF EXHIBIT DATE R=RETURNED D=DESTROYED OTHER COMMENTS A X AIRbnb Evidence Checklist – TVR Inspections dated January 28, 2016 B X Investigation Report dated January 10, 2017 C X Zoning Compliance Notice dated January 11, 2017 D X Notice of Violation & Order to Pay Fines dated May 23, 2017 E X Investigation Report dated May 23, 2017 F Memorandum re Meeting between Planning Department and Property Owner dated April 12, 2017 G X Investigation Report dated July 10, 2018 PAGE 1 OF 1 PAGES EXHIBIT G BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNT OF KAUAI In the Matter of: Petition to Appeal Decision of the Planning Director's Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha'ena, Kaual, Hawaii, identified by Kaual TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUAI, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date and by the method of service noted below, a true and correct copy of the foregoing was served on the following at their last known address: 7867425.1 GREGORY W. KUGLE gwk@hawaiilavvyer.com JOANNA C. ZEIGLER JCZ@hawaiilawyer.com Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Attorneys for Petitioner PATRICIA D. McCONNELL NICHOLAS R. COURSON ncourson@kauai.gov First Deputy County Attorney County of Kauaei 4444 Rice Street, Suite 220 Lihu`e, HI 96766 Attorney for Planning Commission, County of Kaua`i ELLEN CHING, Administrator eching@kauai.gov asegreti@kauai.gov Office of Boards and Commissions County of Kauai 4444 Rice Street, Suite 150 Lihu`e, HI 96766 HARLAN Y. KIMURA hyk@harlankimuralaw.com Central Pacific Plaza 220 South King Street, Suite 1660 Honolulu, HI 96813 Telephone: (808) 564-0811 Hearing Officer Planning Commission, County of Kaua`i HAND U.S. MAIL DELIVERY X X X X EMAIL X X X X 2 DATED: Honolulu, Hawai`i, January 17, 2020. JOHN-8. MACKEY CHRISTOPHER P. ST. SURE Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUAI 3 7877294.3 GOODSILL ANDERSON QUINN & STIFEL A LIMITED LIABILITY LAW PARTNERSHIP LLP JOHN S. MACKEY 7006-0 jmackey@goodsill.com CHRISTOPHER P. ST. SURE 10001-0 cstsure@goodsill.com First Hawaiian Center, Suite 1600 999 Bishop Street Honolulu, Hawai‘i 96813 Telephone: (808) 547-5600 Facsimile: (808) 547-5880 Attorneys for Respondent PLANNING DEPARTMENT, COUNTY OF KAUAʽI BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUAʽI In the Matter of: Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Haʽena, Kauaʽi, Hawaiʽi, identified by Kauaʽi TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUAʽI, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI’S CLOSING ARGUMENTS; PROPOSED FINDINGS OF FACTS AND CONCLUSIONS OF LAW; CERTIFICATE OF SERVICE CONTESTED CASE HEARING: Date: August 30, 2019 Time: 9:00 a.m. Hearing Officer: Harlan Y. Kimura 2 RESPONDENT PLANNING DEPARTMENT OF THE COUNTY OF KAUAI’S CLOSING ARGUMENTS The Hearings Officer should recommend that the Planning Commission AFFIRM the Planning Director’s issuance of the Notice of Violation and Order to Pay Fines dated May 23, 2017 (“NOV”) to Petitioner Patricia McConnell because: 1. Petitioner admitted to running a homestay operation; 2. Petitioner’s property falls outside the Visitor Destination Area (“VDA”); 3. Petitioner did not have a homestay use permit; 4. Kaua‘i County Code (“KCC”) § 8-18.1(b) expressly prohibits homestay operations outside of the VDA; 5. Article 18 of the KCC does not contain a nonconforming use provision. To the extent that Petitioner asks the Hearing Officer to rewrite the Code to allow for “grandfathering,” such request is beyond the scope of this Appeal; 6. Prior to the enactment of Ordinance 1002, Petitioner’s homestay use was not a lawful use because she was operating without a Use Permit pursuant to KCC § 8-3.2(b) (“[n]o person shall undertake . . . any activity for which a Use Permit is required. . .without first obtaining a Use Permit”); and 7. Assuming, arguendo, that prior to Ordinance 1002, KCC § 8-13.2 could “grandfather” prior homestay uses without a Use Permit, Petitioner has failed to prove that she was continuously operating a valid homestay. The record shows that she habitually advertised a dwelling that she, as the owner, was not also staying in. Petitioner owns the property at 4813 Ananalu Road, Hanalei, Kaua‘i 96714 (the “Subject Property”). See Ex. “B,” at 4. The Subject Property is located outside of the VDA. Hearing Transcript (“Tr.”) at 71-72. The Subject Property is comprised of two structures—a main house and a separate octagonal unit, as reflected in Ex. “G”: 3 These two structures can also be seen on the Pictometry images: Exhibit “G”. At the Contested Case hearing, Petitioner claimed “continuous” homestay use at the Subject Property since 2005. See Hearing Tr. at 11. In contradiction, the evidence shows that Petitioner was running a much larger short-term rental operation. In fact, Petitioner offered the main house for rent on a short term basis and also offered the separate octagonal structure for rent on a short term basis. Specifically, in her Airbnb advertisement, Petitioner offered to rent the main house for $245 per night. See Ex. “B.” 4 The ad specifically informed prospective tenants they will be renting the entire home and that the owner lives in a separate studio: The Planning Department’s investigation file also includes Petitioner’s VRBO advertisement which also offers the separate octagonal structure for rent on a short term basis ($185 per night) as the “Sea Turtle Cottage.” See Ex. “B.” The photos included in this advertisement show the unmistakable octagonal structure of the ceiling/roof of the Sea Turtle Cottage: 5 Based upon its investigation, the Planning Department properly concluded that Petitioner was in violation of Sections 8-18.1(b) and 8-17.8. Section 8-18.1(b) prohibits homestays outside of the VDA. KCC § 8-18.1(b). Petitioner also violated Section 8-17.8 because she advertised a single family vacation rental outside of the VDA. See KCC § 8-17.8(a) (“Notwithstanding any underlying zoning designation and with the exception of properties on the National or State Register of Historic Places, single family transient vacation rentals are prohibited in all areas not designated as Visitor Destination Areas.”). Petitioner’s advertisements establish these violations. See Section 8-17.11(b) (“[a]dvertising of any sort which offers a property as a transient vacation rental shall constitute prima facie evidence of the operation. . .”). Thereafter, the Planning Department issued Petitioner a Zoning Compliance Notice dated January 11, 2017 (the “Zoning Compliance Notice”). See Exhibit “C.” The Zoning Compliance Notice clearly informed Petitioner of her violations. Id. Petitioner testified that she 6 received the Zoning Compliance Notice on April 1, 2017 and scheduled a meeting with the Planning Department. Hearing Tr. at 12-13. On April 12, 2017, Petitioner met with Andres “Bambi” Emayo and Britni Ludington-Braun of the Planning Department on April 12, 2017. At this meeting, they discussed the Zoning Compliance Notice and how the violation could be remedied. See Hearing Tr. at 64. Petitioner admitted to the homestay use and said she would continue. See Ex. “E” (last page). Record evidence shows that she did continue. See Exhibit “E” at 2 (May 18, 2017 investigation showing ongoing homestay operation outside of the VDA without an applicable permit). Ex. “G” also shows that Petitioner continued to offer short term rentals at Petitioner’s “Romantic honeymoon jungle and mountain view cottage” from October 2017 through May 2018, e.g.: However, Petitioner testified that she did not have any rentals during the time the highway was closed from April of 2018 until about June of 2019. Hearing Tr. at 19. As a result of Petitioner’s willful defiance, the Planning Department correctly issued the NOV and clearly stated Petitioner’s admitted violation: “[t]he Planning Department has confirmed that the subject property is currently being used for a homestay operation.” Exhibit “D”. The NOV levied a fine of ten thousand dollars ($10,000.00) and ordered her to cease and desist. Id. 7 Here, Petitioner has not carried her burden to show that the Planning Director’s decision was wrong. The evidence proves the opposite. Petitioner admitted that she was conducting a homestay operation at the Subject Property. See Hearing Tr. at 9. Petitioner also did not contest the Planning Department’s determination that the Subject Property was outside of the VDA. Instead, Petitioner argues that the NOV was improper because her homestay operation was a nonconforming use under KCC § 8-13.2. Petitioner’s argument lacks evidence and legal support. KCC § 8-18 does not allow grandfathering of prior non-conforming uses outside of the VDA. Mike Laureta, the County’s Division Program Manager in charge of enforcement, testified that the Council was clear when it passed Ordinance 1002: “you can only have [homestays] in the visitor destination area” and “there was no grandfathering component.” See Hearing Tr. at 36. Mr. Laureta further explained that while there was no grandfathering, homestays did have the opportunity to become properly permitted before the new law. See Hearing Tr. at 37. The County received a “flood of applications.” Id. Petitioner was not one of the applicants. The County’s interpretation and enforcement of this ordinance should be afforded deference. See Camara v. Agsalud, 67 Haw. 212, 216, 685 P.2d 794, 797 (Haw. 1984) (“[a]n agency's interpretation of its rules receives deference unless it is plainly erroneous or inconsistent with the underlying legislative purpose”). In addition, even if KCC § 8-13.2 applied, Petitioner’s homestay operation was not a nonconforming use because she never obtained a Use Permit prior to enactment of Ordinance 1002. See KCC § 8-1.5 (a nonconforming use “means a lawful use of a building or land . . .) (emphasis added); see also Hearing Transcript (Mr. Emayo: “Ordinance 1002, the homestay ordinance did not . . . make an opening for people coming to certify the grandfather use because it was always open for anybody to go in to get a . . . B&B use through a use permit 8 process.”). Moreover, Petitioner failed to introduce credible evidence of a continuous valid homestay operation. Aside from her own testimony as to continuous use (which should be found self-serving and not credible), there is substantial evidence introduced by the Planning Department that Petitioner was, at times, not operating within the definition of a homestay because she advertised dwellings, one of which is a 164 sq. ft. room, that was not a “owner occupied dwelling unit”). See KCC § 8-1.5 (Homestay “means an owner occupied dwelling unit in which overnight accommodations are provided to transient guests within the same dweling unit in which the owner resides . . .”). Without any other evidence (i.e., accommodation records, booking statements, payments, etc.) to corroborate her inconsistent testimony, Petitioner has not established that her homestay operation was a nonconforming use prior to the prohibition of homestays outside the VDA. There also is no constitutional due process violation resulting from issuances of the NOV. See, e.g., Korean Buddhist Dae Won Sa Temple of Hawaii v. Sullivan, 87 Hawaiʻi 217, 243, 953 P.2d 1315, 1341 (1998) (“The basic elements of procedural due process of law require notice and an opportunity to be heard at a meaningful time and in a meaningful manner.”). Petitioner admitted to receiving a copy of the January 11, 2017 Zoning Compliance Notice and scheduled a meeting with the Planning Department to discuss the nature of her violations. Petitioner has not been deprived of due process. See Sullivan, 87 Hawaii at 243, 953 P.2d at 1341 (Due process requires only notice and an opportunity to be heard). Rather, she was merely unsuccessful in convincing the Planning Department to make an exception for her prior unlawful use of the Subject Property. Thereafter, Petitioner failed to comply with the Zoning Compliance Notice and, in fact, continued homestay operations (see Exhibit “E”). Accordingly, the Planning Department correctly issued the NOV. Lastly, the $10,000 fine levied by the Planning Department was within its discretion and authority under KCC § 8-3.5(b). See KCC § 8-3.5(b) ("The order may require the party responsible for the violation to do any or all of the following: (A) correct the violation within the time specified in the order; (B) pay a civil fine not to exceed ten thousand dollars ($10,000.00) in the manner, at the place, and before the date specified in the order; (C) pay a civil fine up to ten thousand dollars ($10,000.00) per day for each day in which the violation persists. . .). The Planning Department's fine of $10,000 and the additional fine of $10,000 per violation, per day, were within its discretion to do so and should be affirmed. See Kilakila '0 Haleakala v. Bd. of Land, 138 Hawai`i 383, 401, 382 P.3d 195, 213 (2016) ("A determination made by an administrative agency acting within the boundaries of its delegated authority will not be overturned unless 'arbitrary, or capricious, or characterized by a clearly unwarranted exercise of discretion.") Petitioner has not met her burden to prove that the Planning Director acted erroneously, arbitrarily, or manifestly abused his discretion when he issued the NOV to Petitioner. Respectfully, the Planning Department's issuance of the NOV should be affirmed and Petitioner's Appeal should be dismissed. DATED: Honolulu, Hawai`i, January 1, v 020. S. MA KEY CHRISTOPHER P. ST. SURE Attorney for Respondent PLANNING DEPARTMENT, COUNTY OF KAUA' I 9 7874834.2 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUAʽI In the Matter of: Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Haʽena, Kauaʽi, Hawaiʽi, identified by Kauaʽi TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUAʽI, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, DECISION AND ORDER CONTESTED CASE HEARING: Date: August 30, 2019 Time: 9:00 a.m. Hearings Officer: Harlan Y. Kimura PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, DECISION AND ORDER I. INTRODUCTION This Contested Case arises from the Notice of Violation & Order to Pay Fines dated May 23, 2007 (“NOV”) issued by Respondent COUNTY OF KAUAʻI PLANNING DEPARTMENT (“Planning Department”), to Petitioner PATRICIA D. McCONNELL (“Petitioner”). See Exhibit “A.”1 The Notice of Violation advised Petitioner that, among other things, she was in 1 All Exhibits referenced numerically were introduced by Petitioner and all Exhibits identified alphabetically were submitted by the Planning Department by stipulation at the August 30, 2019 Kauai Planning Commission Contested Case Hearing. 2 breach of the Zoning Compliance Noticed issued to her on January 11, 2017, ordered her to pay a fine of $10,000.00 and notified her that fines would continue to accrue up to $10,000 per day, for each day in which such violation persists. See Exhibit “D.” II. PROCEDURAL HISTORY On June 13, 2017, Petitioner filed her Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Ha‘ena, Kaua‘i, Hawai‘i, identified by TMK No. (4) 5-8-005:005 containing 26,092 square feet (the “Appeal”). See Petitioner’s Appeal. By Order of the Planning Commission, Contested Case No. CC-2017-4 (“Contested Case”) was assigned to Hearing Officer Harlan Kimura, Esq. (“Hearing Officer”). Thereafter, pursuant to the Hearing Officer’s First Amended Scheduling Order dated July 5, 2019, the contested case hearing was set for August 30, 2019. On July 9, 2019, the Planning Department filed Plaintiff Department of the County of Kaua‘i’s Motion for Summary Judgment (“Planning Department’s MSJ”). The Planning Department’s MSJ requested judgment in its favor pursuant to Rule 1-6-16 of The Rules of Practice and Procedure of the Kaua‘i Planning Commission (“RPPPC”) affirming the Planning Department’s Zoning Compliance Notice and the Notice of Violation. In response, on August 14, 2019, Petitioner filed her Memorandum in Opposition to Respondent Planning Department of the County of Kaua‘i’s Motion for Summary Judgment (“Opposition”). On August 23, 2019, Petitioner filed Petitioner Patricia McConnell’s Prehearing Statement and Petitioner Patricia McConnell’s Exhibit List with Exhibits 1-5. On August 23, 2019, the Planning Department filed its Respondent Planning Department of the County of Kaua‘i’s Prehearing Statement and Respondent Planning Department of the County of Kaua‘i’s Exhibit List, together with Exhibits A-F. On January 17, 2020, the Planning Department 3 submitted Respondent Planning Department of the County of Kaua‘i's Supplemental Exhibit List, together with Exhibit G, as permitted by the Hearing Officer at the Contested Case Hearing. See Hearing Transcript at 112. On August 30, 2019, prior to the commencement of the Contested Case Hearing and after hearing argument from counsel, the Hearing Officer orally denied the Planning Department’s MSJ. III. PRELIMINARY MATTERS The Contested Case Hearing (“Hearing”) of the Planning Commission of the County of Kaua‘i took place on August 30, 2019 at 9:00 a.m., at the Lihue Civic Center, Liquor Control Conference Room 3. See Hearing Transcript, page 1. Greg Kugle, Esq. represented Petitioner who was also present. Id. Maryann Sasaki, Esq. represented the Planning Department and Mr. Michael Laureta was also present as its authorized representative. Id. Petitioner and the Planning Department stipulated to admit Exhibits “1”-“5” and “D” in each party’s respective pre-hearing briefs into evidence. Id. at 5. During the Hearing, Planning Department’s Exhibits “A,” “B,” “C,” and “G” were admitted into evidence. See Hearing Transcript at pages 55-63 and page 108 for Exhibit “G.” Planning Department’s Exhibit “E” was admitted into evidence without the last page. Hearing Transcript at 63. Petitioner submitted Closing Arguments and/or Proposed Findings of Fact and Conclusions of Law by January 15, 2020 as required by the Minute Order Regarding Telephone Conference filed December 12, 2019. In turn, the Planning Department submits these Closing Arguments and/or Proposed Findings of Fact and Conclusions of Law. Both of those filings were timely received. 4 IV. FINDINGS OF FACT A. The Parties and the Subject Property. 1. Petitioner is the owner of the real property that is the subject of this Contested Case located at 4813 Ananalu Road, Hanalei, Hawaii 96714, TMK No. (4) 8-005:005 (“Subject Property”). 2. The Subject Property is located outside of the Visitor Destination Area. See Hearing Transcript at 36-37. 3. The Planning Department is the governmental agency responsible for enforcing, among other things, the provisions of the Comprehensive Zoning Code set forth in Chapter 8 of the Kaua‘i County Code. B. Notice of Violation And Order To Pay Fines For The Operation Of An Illegal Transient Accommodation Use For Property Situated In Ha‘ena, Kaua‘i, Hawai‘i, Identified By TMK No. (4) 5-8-005:005 Containing 26,092 Square Feet. 4. Petitioner admitted to conducting a homestay operation at the Subject Property. See Hearing Transcript at 11. 5. The Subject Property is Petitioner’s permanent residence. See Hearing Transcript at 9. 6. On January 10, 2017, the Planning Department found that Subject Property was operating a homestay operation located outside of the Visitor Destination Area and prepared an Investigation Report regarding the Subject Property (“January 10th Report”). See Exhibit B. The January 10th Investigation Report was prepared by Mr. Andres (“Bambi”) Emayo (“Emayo”). Id. 7. The January 10th Report detailed the investigation process undertaken by the Planning Department and subsequent findings: 5 1. Research of online website www.airbnb.com found the subject transient accommodation: https://www.airbnb.com/rooms/12622481 2. By matching the airbnb’s website (https://www.airbnb.com/rooms/12622481) and pictures with pictometry and cross checking the noted parcel with Real Property Division records (Tax Classification- Vacation Rental), I was able to determine the Tax Map Key and Property owner of the transient accommodation operation. TMK: 58005005, PATRICIA D. MCCONNELL 3. Research Finding: Transient accommodation operation is located outside of the VDA Transient accommodation operation does not have an[ ] active Non-Conforning Use Certificate (NCU) or an applicable permit. See Exhibit “B” at 2 (emphasis added). 8. The January 10th Report contained a clipping from an Airbnb advertisement for the Subject Property that disclosed: “[t]he owner lives in a separate studio on the property and is available to assist guests with island and home questions and issues.” Id. at 15. 9. The Pictometry and the Kaua‘i Real Property Division Records for the Subject Property demonstrate that there are two dwellings on the Subject Property—the main house and a separate octagonal structure. Id. at 3-9. 10. Based on this investigation, the Planning Department determined that Petitioner was in violation of two ordinances: ORDINANCE and VIOLATIONS 1. Section 8-8.1(b) General Provisions for Homestays Homestay operations are prohibited outside of the Visitor Destination Area (VDA). 6 2. Section 8-17.8 Single Family Transient Vacation Rentals. Notwithstanding any underlying zoning designation and with the exception of properties on the National or State Register of Historic Places, single family transient vacation rentals are prohibited in all areas not designated as Visitor Destination Areas. Violation: The unauthorized use of the subject property for Transient Accommodation outside of the designated Visitor Designation Area constitutes a violation. Exhibit “C.” 11. Mr. Emayo further clarified that the Planning Department’s determination was based on, among other things, the 2016 Checklist, the Airbnb advertisement, the existence of a GE tax license, a TAT tax license, and the “Tax Map Keys and zoning maps that show that the property is outside the VDA.” See Hearing Transcript at 71. 12. By letter dated January 11, 2017, entitled “Zoning Compliance Notice,” the Planning Department advised Petitioner that it had conducted an investigation of the Subject Property and found that she was operating a vacation rental operation outside of the Visitor Designation Area in violation of Section 8-8.1(b) (General Provisions for Homestays) and Section 8-17.8 (Single Family Transient Vacation Rentals). See Exhibit “C”. Petitioner was ordered to (1) cease and desist the use of the subject property as a Transient Accommodation, and (2) cancel all Transient Accommodations commitments for the property. Id. 13. The Zoning Compliance Notice further advised Petitioner that pursuant to County Ordinance No. 919, any “violation(s) of the Comprehensive Zoning Ordinance (CZO) may result in a fine up to $10,000.00 and/or up to $10,000.00 per day, should the violation(s) persist.” Id. at 2. 14. Plaintiff acknowledged receipt of the Zoning Compliance Notice on April 1, 2017. See Hearing Transcript at 12-13. 7 15. Following the receipt of the Zoning Compliance Notice, Petitioner made an appointment with the Planning Department for April 12, 2017. See Hearing Transcript at 78. 16. On April 12, 2017, Petitioner met with Planning Department representatives Bambi Emayo and Britni Ludington-Braun regarding the Zoning Violation Notice (the “April 12th Meeting”). See Hearing Transcript at 78. 17. At the April 12th Meeting, Petitioner and the representatives of the Planning Department discussed the Zoning Compliance Notice and how the notice could be remedied. See Hearing Transcript at 64. 18. Mr. Emayo testified that they informed Petitioner that “[w]e basically had three directions to remedy the situation. Number 1, which would be a written response to the zoning compliance notice with some kind of remedial action plan. Number 2 was to remove the prima facie evidence. Number 3 was to work with the Planning Department to rectify the violation.” See Hearing Testimony at 79. 19. At the April 12th Meeting, Petitioner admitted that she was operating a homestay. See Exhibit “E” at 1. Petitioner further stated that “she will continue the transient accommodation operation until March of 2018” and “made comments that she doesn’t intend to cease and desist the use of the subject property as a Transient Accommodation.” Id. at 2. 20. On April 13, 2017, Petitioner responded to the Planning Department stating that: “[i]t is my belief, however, that I have not, and have never, been in violation of any of the older county ordinances However, it is now my understanding that there have been some recent new changes in those county ordinances that may effect [sic] my life and property, and that may also require me to make some changes in how I share my home with others.” Exhibit “3” at 1. 8 21. Petitioner’s response did not state that she would comply with the Zoning Violation Notice or cancel all Transient Accommodations commitments for the property. Id. 22. Despite receiving the Zoning Violation Notice, Petitioner continued to rent out rooms in the Subject Property as a homestay operation outside of the Visitor Destination Area. See Exhibit “E” at 2. 23. On May 18, 2017, the Planning Department conducted another investigation and discovered that the Subject Property was being advertised on Airbnb without an applicable permit to do so. Exhibit “E” at 2. 24. Accordingly, the May 23, 2017 Notice of Violation & Order to Pay Fines (“NOV”), concluded that the Subject Property was still being used for a Homestay operation. See Exhibit “D.” 25. The NOV stated, among other things, that: The Planning Department has confirmed that the subject property is currently being used for a Homestay operation. The continued use of the subject property for a Homestay operation outside of the designated Visitor Designation Area constitutes a violation. [. . .] You are herein levied and ordered to pay a fine of ten thousand dollars ($10,000.00) for the above noted violations to the Planning Department. You are hereby ordered to cease and desist the illegal activities being conducted/performed on and from the premises required by law. You are hereby ordered to correct the above use violations(s) [sic] within 14 days of the date of this notice. Should the violations not be remedied within 14 days from the date of the Notice of Violation & Order to Pay Fines: Exhibit “D,” at 2-3. 26. In addition, Petitioner was notified that an additional fine of $10,000 9 would accrue per violation, per day, for each day in which such violation persists. Id. 27. As explained by Mr. Laureta, the Planning Department uses a two-step process before a fine can be issued: “first step is zoning compliance notice, which – which advises the owner of a problem, and it gives them the opportunity to come in and correct it. And if it can’t be corrected within that timeframe, then it’s a second step, notice of violation.” See Hearing Transcript at 45. 28. The Planning Department’s fines start with $10,000. From there, the Planning Department considers whether efforts to return to compliance should reduce the fine. See Hearing Transcript at 46. 29. Petitioner did not dispute that she operated a homestay operation outside of the Visitor Destination Area. Instead, Petitioner argued that the Planning Department should recognize that her use as a homestay operation under a nonexistent grandfathering provision. C. Petitioner’s Appeal Of Planning Department’s NOV. 30. By letter dated June 9, 2017 addressed to the Kaua‘i Planning Department, Petitioner submitted Petitioner’s Notice of Appeal and Demand for Contested Case Hearing from Zoning Violation for Transient Accommodation Use at: 4813 Ananalu Road; TMK: 5-8-00, pursuant to Chapter 9 of the Rules of Practice and Procedure of the Kaua‘i Planning Commission (“Notice of Appeal”). See Notice of Appeal at 1. The Notice of Appeal focused primarily on the arguments that: (1) the Kaua‘i County Council arbitrarily banned homestays in Petitioner’s neighborhood through Ord. No. 987, June 19, 2015 and Ord. No. 1002, May 18, 2016, codified as Sec. 8-18.1 of the CZO; and (2) the Homestay Ordinance does not contain a grandfathering provision to cover preexisting operations and does not provide guidance on preexisting legal uses. 10 D. Petitioner’s Continued Violation Of County Ordinances. 31. In the month of May of 2018, Ms. Ludington-Brown discovered that there were reviews from guests that stayed at the 164 square foot cottage at the Subject Property in May of 2018. Hearing Transcript at 103; see also Exhibit “G.” 32. The Investigation Report dated July 10, 2018 shows that Petitioner was operating an illegal transient vacation rental outside of the Visitor Destination Area from October 2017 through May 2018. See Exhibit “G” at 19-22. 33. The advertisement for the Subject Property was observed on VRBO and described the rental as being a 500 foot studio that sleeps two and has a “kitchenette”. Id. at 13. 34. One of the comments for a stay in September of 2017 stated, in part, “The cottage is very private and we loved the setup. The caretaker Matty was very accommodating and helped to make our stay even better.” Id. at 22. 35. Another comment for a stay on November 2017 observed: “Matty was great to deal with and helped me to feel at home and get me anything I needed.” Id. at 23. 36. Based upon Ms. Ludington-Braun’s investigation, there was prima facie evidence presented by the Planning Department that Petitioner was continuing to operate a Transient Vacation Rental operation at the Property. See KCC § 8-17.11(b) (“[a]dvertising of any sort which offers a property as a transient vacation rental shall constitute prima facie evidence of the operation of a transient vacation rental on said property and the burden of proof shall be on the owner . . . to establish that the subject property is not being used as a transient vacation rental or that it is being used for such purpose legally.”). E. Relevant Authorities and Pertinent Legislative History. 37. Haw. Rev. Stat. § 46-4 provides in pertinent part: (a) This section and any ordinance, rule, or regulation adopted in accordance with this 11 section shall apply to lands not contained within the forest reserve boundaries as established on January 31, 1957, or as subsequently amended. Zoning in all counties shall be accomplished within the framework of a long-range, comprehensive general plan prepared or being prepared to guide the overall future development of the county. Zoning shall be one of the tools available to the county to put the general plan into effect in an orderly manner. Zoning in the counties of Hawaii, Maui, and Kauai means the establishment of districts of such number, shape, and area, and the adoption of regulations for each district to carry out the purposes of this section. In establishing or regulating the districts, full consideration shall be given to all available data as to soil classification and physical use capabilities of the land to allow and encourage the most beneficial use of the land consonant with good zoning practices. The zoning power granted herein shall be exercised by ordinance which may relate to: . . . (2) The areas in which residential uses may be regulated or prohibited; . . . (4) The areas in which particular uses may be subjected to special restrictions; (5) The location of buildings and structures designed for specific uses and designation of uses for which buildings and structures may not be used or altered; . . . (12) Other regulations the boards or city council find necessary and proper to permit and encourage the orderly development of land resources within their jurisdictions. The council of any county shall prescribe rules, regulations, and administrative procedures and provide personnel it finds necessary to enforce this section and any ordinance enacted in accordance with this section. The ordinances may be enforced by appropriate fines and penalties, civil or criminal, or by court order at the suit of the county or the owner or owners of real estate directly affected by the ordinances. . . . The powers granted herein shall be liberally construed in favor of the county exercising them, and in such a manner as to promote the orderly development of each county or city and county in accordance with a long-range, comprehensive general plan to ensure the greatest benefit for the State as a whole. This section shall not be construed to limit or repeal any powers of any county to achieve these ends through zoning and building regulations, except insofar as forest and water reserve 12 zones are concerned and as provided in subsections (c) and (d). [This paragraph shall hereafter be referred to as the “Liberal Construction Provision.”] Neither this section nor any ordinance enacted pursuant to this section shall prohibit the continued lawful use of any building or premises for any trade, industrial, residential, agricultural, or other purpose for which the building or premises is used at the time this section or the ordinance takes effect; provided that a zoning ordinance may provide for elimination of nonconforming uses as the uses are discontinued, or for the amortization or phasing out of nonconforming uses or signs over a reasonable period of time in commercial, industrial, resort, and apartment zoned areas only. In no event shall such amortization or phasing out of nonconforming uses apply to any existing building or premises used for residential (single-family or duplex) or agricultural uses. Nothing in this section shall affect or impair the powers and duties of the director of transportation as set forth in chapter 262. [This paragraph shall hereafter be referred to as the “Continued Lawful Use Provision.”] Haw. Rev. Stat. § 46-4 (emphasis added). 38. Act 186 provided that “the several counties shall, by amendment of their zoning ordinances, limit the location of time share units, time share plans and other transient vacation rentals, within such areas as deemed appropriate.” 1980 Haw. Sess. laws Act 186 § 4 at 306. 39. Pursuant to Act 186, the County enacted Ordinance 436 “for the purpose of designating locations, referred to as “Visitor Destination Area,” in which transient vacation rentals, time share units and time share plans are to be allowed.” By extension, following the enactment of Ordinance 436, transient vacation rentals, time share units and time share plans were prohibited outside of designated Visitor Destination Areas. 40. Ordinance 1002, adopted by the Council on May 18, 2016, provided the express purpose of the Bill as follows: The Council finds the 2000 Kaua‘i General Plan recognized the need “to develop a clear policy regarding B&Bs and vacation rentals.” The General Plan recommended an implementing action to amend the CZO to facilitate the permitting of existing, nonconforming alternative visitor accommodations. The Council complied with the policy of the General Plan and grandfathered existing single-family transient vacation rentals (SFTVRs) that 13 registered and met the prior use requirements established in Article 17 of the CZO. In Ordinance No. 864, the Council further found that: This bill does not apply to a bed and breakfast unit (“Homestay”). It is the intention of the Council to address these units as a separate matter after establishing a regulatory framework for single-family transient vacation rentals. Homestays are presently regulated through the use permit process. Although the Council bifurcated the issues of homestays and SFTVRs, it is now appropriate to adopt a clear and specific standard and review parameters under which homestay applications can be processed. The purpose of this bill is to restrict homestay operations to the Visitor Destination Areas (VDAs) and to establish additional standards under which homestays operate. (emphasis added). 41. Ordinance 1002 invited applications for homestay operations: On a first-come-first-serve basis of applications deemed complete by the Planning Department, no more than ten (10) new applications for homestay operations shall be accepted for review by the Planning Commission in each of the calendar years 2015 and 2016. The limitation on the number of applications shall expire on December 31, 2016, or upon passage of an amendment to this section, whichever occurs first. (emphasis added). 42. KCC § 8-18.1 provides, in relevant part: (a) A homestay operation shall operate under the following regulations: (1) Transient accommodations are provided for visitors for twenty-nine (29) days or less; (2) Homestays shall be limited to no more than three (3) guest rooms per homestay operations; 14 . . . (b) Homestay operations are prohibited outside of the Visitor Destination Area (VDA). Ordinance 1002 (with emphasis). 43. Homestay “means an owner occupied dwelling unit in which overnight accommodations are provided to transient guests within the same dwelling unit in which the owner resides and the respective owner currently benefits under Sec. 5A-11 of this Code for a homeowner’s exemption for the homestay site. A guest house may not be used as accommodations for transient guests in a homestay operation. See Section 8-1.2 of the KCC (emphasis added). 44. A Dwelling Unit “means any building or any portion thereof which is designed for occupancy by one (1) family or persons living together or by a person living alone and providing complete living facilities, within the unit for sleeping, recreation, eating and sanitary facilities including installed equipment for only one (1) kitchen.” Id. 45. Transient “means any person who owns, rents, or uses a dwelling unit or a portion thereof for one hundred eighty (180) days or less[.]” Id. 46. Section 8-3.5 of the KCC provides for penalties as follows: (1) If the Director of the Planning determines that any person, firm or corporation is not complying with a notice of violation, the Director may have the party responsible for the violation served, by mail or delivery, or by posting on the property which address is the most current address reflected in the Real Property tax records, or by publishing such notice in a newspaper of general circulation in the County of Kauai should previous notification efforts not be accepted, with an order pursuant to this section. The order may require the party responsible for the violation to do any or all of the following. (A) Correct the violation within the time specified in the order; (B) Pay a civil fine not to exceed $10,000 in the manner, at the 15 place, and before the date specified in the order; (C) Pay a civil fine up to $10,000 per day for each day in which the violation persists, in the manner and at the time and place specified in the order. (2) The order shall advise the party responsible for the violation that the order shall became final 30 days after the date of its delivery. The order shall also advise that the Director's action may be appealed to the Planning Commission. (3) The provisions of the order issued by the Director under this section shall become final 30 calendar days after the service of the order. The parties responsible for the violation may appeal the order to the Planning Commission pursuant to its rules. The form of this appeal must conform to the Planning Commission's rules. However, an appeal to the Planning Commission shall not stay any provision of order. KCC §8-3.5 (emphasis added). 47. KCC § 8-13.2, adopted by the Council on November 14, 2012, as part of Ordinance No. 935 to update the Comprehensive Zoning Code, provides in pertinent part: (a) A nonconforming use of land, buildings, or other structures may continue to the extent that the use existed on September 1, 1972 or any amendment hereto, as provided in this Section, provided that the Planning Commission may, after hearing, order the termination of a nonconforming use that creates substantial danger to public health or safety. (b) If any nonconforming use ceases for any reason for continuous period of twelve (12) calendar months or for one (1) season if the use be seasonal, then the use shall not be resumed and any use of the land or building thereafter shall be in full conformity with the provisions of this Chapter … 48. Under KCC § 8-17.11(b), “[a]dvertising of any sort which offers a property as a transient vacation rental shall constitute prima facie evidence of the operation of a transient vacation rental on said property and the burden of proof shall be on the owner. . . to establish that the subject property is not being used as a transient vacation rental or that it is 16 being used for such purpose legally.” 49. If any Finding of Fact herein should be designated as a Conclusion of Law, the same shall be deemed to have been identified as such. V. CONCLUSIONS OF LAW A. The Planning Department’s Zoning Compliance Notice and NOV Was Proper . 1. An executive branch government agency possesses only the authority granted to it by the legislative branch. See, e.g., Paul’s Elec. Serv., Inc. v. Befitel, 104 Hawaiʻi 412, 417, 91 P.3d 494, 499 (2004) (“Administrative agencies are created by the legislature, and the legislature determines the bounds of the agency’s authority. An administrative agency can only wield powers expressly or implicitly granted to it by statute. Thus, before we can determine whether an agency abused its discretion pursuant to HRS § 91-14(g)(6), we must determine whether the agency determination under review was the type of agency action within the boundaries of the agency’s delegated authority.”) (internal quotation marks and citations omitted). See also Morgan v. Planning Dept., County of Kauai, 104 Hawaiʻi 173, 184, 86 P.3d 982, 993 (2004) (applying same principles to county agency). 2. Here, the legislative branch is the County Council, and the Planning Department is an agency of the County’s executive branch. Kauaʻi County Charter, Art. III, § 3.01 (“The legislative power of the county shall be vested in and exercised by the county council[.]”); Art. VI, § 6.01 (executive branch). 3. The County Charter establishes the fundamental structure of county government; outlines how a bill becomes a law; and creates its executive branch agencies. Art. I, § 1.03 (elections); Art. IV, § 4.02 (passage of ordinances); Articles X-XVIII; XXVIII-XXXI (departments, commissions, and agencies) 17 4. Among these County agencies is the Planning Department, which is tasked with (among other things) reviewing and enforcing the county’s zoning ordinances. County Charter Art. XIV, § 14.01 (“There shall be a planning department consisting of a planning commission, a zoning board of appeals, a planning director, and the necessary staff.”); Art. XIV § 14.03(A)-(H) (duties and functions of the planning commission). In enforcing the county’s zoning laws, the Charter specifies that variances can be granted “pursuant to provisions established by the council by ordinance.” Art. XIV § 14.03(D). 5. Neither the Department nor the Commission has the authority to offer a variance from the requirements of the zoning code unless that variance was first enacted into law as an ordinance by the County Council. Id. 6. The agency cannot act beyond its delegated authority and thus the Commission cannot have erred in determining it did not possess the authority to ignore the prohibition of homestay operations outside of the Visitor Destination Area in § 8-18.1(b). 7. In fact, respecting the limits of its delegated authority is precisely what the agency should do. See HRS § 91-14(g)(2) (agency acting in “excess of the statutory authority or jurisdiction” is grounds for reversal or modification of agency decision); Kilakila ʻO Haleakala v. Bd. of Land, 138 Hawaiʻi 383, 401, 382 P.3d 195, 213 (2016) (“A determination made by an administrative agency acting within the boundaries of its delegated authority will not be overturned unless ‘arbitrary, or capricious, or characterized by a clearly unwarranted exercise of discretion.”) (citations, internal quotation marks, brackets and ellipses omitted) 8. The express language of KCC § 8-18.1(b) unambiguously prohibits the operation of a homestay outside of the Visitor Destination Area. 9. Michael Laureta, the County’s Division Program Manager in charge of 18 enforcement, testified that the Council was clear when it passed Ordinance 1002: “you can only have [homestays] in the visitor destination area” and the County’s interpretation was that “there was no grandfathering component.” See Hearing Transcript at 36 (emphasis added). 10. The County’s interpretation and enforcement of this ordinance should be afforded deference. See Camara v. Agsalud, 67 Haw. 212, 216, 685 P.2d 794, 797 (Haw. 1984) (“[a]n agency's interpretation of its rules receives deference unless it is plainly erroneous or inconsistent with the underlying legislative purpose”). 11. Any violation of Article 18 “shall be subject to Section 8-3.5 of the Kaua‘i County Code, as amended.” See KCC § 8-18.3(e). 12. Petitioner had “the burden of proof, including the burden of producing evidence as well as the burden of persuasion” under a preponderance of the evidence standard to demonstrate that she had not violated KCC § 8-18.1(b). See HRS § 91-10(5). 13. Under KCC § 8-17.11(b), “advertising of any sort which offers a property as a transient vacation rental shall constitute prima facie evidence of the operation of a transient vacation rental on said property.” 14. Petitioner did not present any evidence to rebut this prima facie evidence that she was engaged in a homestay operation outside of the Visitor Destination Area. 15. Petitioner failed to present any evidence that the Subject Property was outside of the Visitor Destination Area. 16. It is further undisputed that Petitioner advertised the Subject Property on two separate websites, Airbnb and VRBO, and continued to do so after receiving the Zoning Compliance Notice. See Exhibits “B,” “E,” and “G.” 17. Due to the Planning Department’s unrebutted evidence, the Planning 19 Department was correct to issue its Zoning Compliance Notice dated January 11, 2017. See Exhibit “C.” 18. Petitioner admitted to receiving a copy of the Zoning Compliance Notice by at least April 1, 2017. See Hearing Transcript at 12. 19. The Zoning Compliance Notice specifically required Petitioner to: (1) cease and desist the use of the subject property as a Transient Accommodation; and (2) cancel all Transient Accommodations commitments for the property. See Exhibit “C.” 20. Petitioner failed to present any evidence that she complied with the Zoning Compliance Notice. 21. KCC § 8.3(b) provides, in pertinent part, for the following action to be taken when any person fails to comply with a notice of violation: (1) If the Director of the Planning determines that any person, firm or corporation is not complying with a notice of violation, the Director may have the party responsible for the violation served, by mail or delivery, or by posting on the property which address is the most current address reflected in the Real Property tax records, or by publishing such notice in a newspaper of general circulation in the County of Kauai should previous notification efforts not be accepted, with an order pursuant to this section. The order may require the party responsible for the violation to do any or all of the following. (A) Correct the violation within the time specified in the order; (B) Pay a civil fine not to exceed $10,000 in the manner, at the place, and before the date specified in the order; (C) Pay a civil fine up to $10,000 per day for each day in which the violation persists, in the manner and at the time and place specified in the order. (emphasis added). 22. After observing continued advertisements of the Subject Property on Airbnb, the Planning Department mailed Petitioner the NOV, notifying her that she had failed to 20 comply with the Zoning Compliance Notice and ordering her to pay a fine of $10,000. See Exhibit “D.” 23. Contrary to Petitioner’s argument that the Planning Department failed to comply with Section 8.3(b) of the KCC, the Planning Department followed the required process by providing Petitioner with a warning and opportunity to comply and then, only after Petitioner failed to comply with the warning, issued a fine of $10,000 and a fine of $10,000 per day should the violation persist after 14 days. 24. Accordingly, the Planning Department has not acted erroneously, arbitrarily, and did not manifestly abuse its discretion when it issued the NOV. B. Petitioner’s Homestay Operation is Not A Lawful Nonconforming Use. 25. Instead of presenting evidence that Petitioner was not running a homestay operation when she was issued the NOV, Petitioner alternatively argued that her use was a lawful nonconforming use that existed prior to Ordinance 1002. 26. “The counties of our state derive their zoning powers from HRS § 46-4(a), referred to as the Zoning Enabling Act.” Kaiser Hawaii Kai Dev. Co. v. City & County of Honolulu, 70 Haw. 480, 483, 777 P.2d 244, 246 (1989). 27. One of the central canons of statutory construction is that all portions of a statute must be given effect. See, e.g., Ferris, 138 Hawaiʻi at 310, 378 P.3d at 1026 (“Courts are bound to give effect to all parts of a statute, and that no clause, sentence, or word shall be construed as superfluous, void, or insignificant if a construction can be legitimately found which will give force to and preserve all words of the statute.”) (citations and internal quotation marks omitted). 28. Under this statute, the counties have been delegated significant authority 21 over zoning, including establishing districts; determining where business may be conducted; determining where residential uses may be undertaken; and the power to enact “necessary and proper” regulations, as the counties’ respective councils determine. HRS § 46-4(a) (see language emphasized above). 29. These are the grants of authority that “shall be liberally construed in favor of the county” under the terms of the statute itself. Id. (emphasis added). The statute explicitly states that it does not “limit or repeal any powers of any county[.]”). Id. Thus the counties are granted substantial authority over zoning in their respective jurisdictions, and all the tools they need to implement that authority. 30. Petitioner testified that she ceased homestay operations from April of 2018 to June 2019. See Hearing Transcript at 19. Accordingly, Petitioner’s use has been abandoned and cannot lawfully continue even if Petitioner was correct that KCC § 8-13.2 applied to KCC §18.1(b). 31. KCC § 8-13.2(a) provides a nonconforming use “may continue to the extent that the use existed on September 1, 1972.” (Emphasis added). However, if that “nonconforming use ceases for any reason for a continuous period of twelve (12) calendar months or for one (1) season if the use is seasonal, then the use shall not be resumed.” KCC § 8-13.2(b) (emphasis added). Therefore, the continuation of the nonconforming use is discretionary,2 but once abandoned, it is mandatory that this nonconforming use shall not be resumed.3 Id. 32. The public policy embodied in zoning ordinances dictates “the firm 2 “The term ‘may’ is generally construed to render optional, permissive, or discretionary the provision in which it is embodied.” State v. Kahawai, 103 Hawaiʻi 464, 465, 83 P.3d 725, 728 (2004) (emphasis added). 3 “As used in statutes, contracts, or the like, this word [(i.e. shall)] is generally imperative or mandatory.” Leslie v. Board of Appeals of County of Hawaii, 109 Hawaiʻi 384, 394, 126 P.3d 1071, 1081 (2006) quoting Black’s Law Dictionary 1375 (6th Ed. 1990) (emphasis added). 22 regulation of nonconforming uses with a view to their eventual elimination.” Bastian v. City of Twin Falls, 104 Idaho 307, 309, 658 P.2d 978, 980 (Ct. App. 1983). A nonconforming use does not possess any inherent right to be extended or enlarged and “[t]his corollary is recognized in nearly all states.” Id 33. KCC § 8-13.2 should not apply to homestay operations in effect prior to enactment of Ordinance 1002 because Petitioner has not offered credible evidence of a continuous homestay operation before May 18, 2016, nor has she described her homestay operation prior to May 18, 2016 with sufficient specificity to conclude that she was running a homestay operation. 34. Moreover, substantial evidence was presented by the Planning Department that raises doubt as to the credibility of Petitioner’s testimony of continuous homestay because she was, at least at some times, renting a dwelling that she did not also reside in. 35. KCC § 8-1.5 defines a homestay as “an owner occupied dwelling unit in which overnight accommodations are provided to transient guests within the same dwelling unit in which the owner resides. . .” 36. Exhibits “B,” “E” and “G” contain advertisements wherein Petitioner rents out the main portion and also the octagonal cottage on the Subject Property. Although the advertisements describe the Sea Turtle Cottage as 500 square feet, the real property records actually list the building as 164 square feet. 37. Aside from Petitioner’s admission to the homestay use that led to the NOV, Petitioner has failed to establish that her use should be grandfathered pursuant to KCC § 8-13.2. 38. Moreover, even if Petitioner had submitted credible evidence of her 23 continuous use prior to the enactment of Ordinance 1002, Petitioner’s homestay use would not have been “lawful” because Petitioner admittedly did not have a use permit as required by KCC Section 8-3.2(b). See KCC Section 8-3.2 (“[n]o person shall undertake any construction or development, or carry on any activity or use for which a Use Permit is required by this Chapter, or obtain a building permit for construction, development, activity or use for which a Use Permit is required by this Chapter, without first obtaining a Use Permit.”) (emphasis added). 39. On the identification of lawful nonconforming uses, “previous lawfulness” should be “determined by reference to the zoning ordinances in existence at the time of a property owner’s structure or use of property was rendered unlawful under a change to the zoning laws.” Waikiki Marketplace Inv. Co. v. Chair of Zoning Bd. of Appeals of the City & County of Honolulu, 86 Hawaiʻi 343, 355, 949 P.2d 183, 194 (App. 1997). 40. KCC Section 8-3.2 provided the following standards for the issuance of a Use Permit: 1) A Use Permit may be granted only if the Planning Commission finds that the establishment, maintenance, or operation of the construction, development, activity or use in the particular case is a compatible use and is not detrimental to health, safety, peace, morals, comfort and the general welfare of persons residing or working in the neighborhood of the proposed use, or detrimental or injurious to property and improvements in the neighborhood or to the general welfare of the community, and will not cause any substantial harmful environmental consequences on the land of the applicant or on other lands or waters, and will not be inconsistent with the intent of this Chapter and the General Plan. (2) The Planning Commission may impose conditions on the permit involving any of the following matters: location, amount and type and time of construction, type of use, its maintenance and operation, type and amount of traffic, off-street parking, condition and width of adjoining roads, access, nuisance values, appearance of the building, landscaping, yards, open areas and other matters 24 deemed necessary by the Planning Commission. 41. Mr. Emayo explained that prior to the enactment of Ordinance 1002 uses other than those allowed under the applicable zoning district would have to apply for a Use Permit: The Ordinance 1002, the homestay ordinance did not - to my understanding they did not make an opening for people coming to certify the grandfather use because it was always open for anybody to go in to get a - what they used to call it a B&B use through a use permit process. So it was -it- you could always go in and - for a use permit. And we do have some use permits from before the ordinance for B&Bs. See Hearing Transcript at 77. 42. Accordingly, given the absence of any evidence of a Use Permit for the Subject Property, Petitioner may not rely on KCC § 8-13.2(a) as a basis to challenge the NOV issued by the Planning Department. 43. The powers of the Hearing Officer originate from the Planning Commission, and the Planning Commission does not have authority to recognize Petitioner’s prior homestay use as a lawful nonconforming use, nor can the Planning Commission disregard the prohibition contained in KCC § 8-18.1(b). C. The Planning Department’s NOV Did Not Violate Petitioner’s Due Process. 44. Petitioner next argues that the NOV did not provide her with due process by failing to provide specific facts to support the violation. 45. Due process does not entitle a litigant to a particular result; it entitles a litigant to process. See, e.g., Korean Buddhist Dae Won Sa Temple of Hawaii v. Sullivan, 87 Hawaiʻi 217, 243, 953 P.2d 1315, 1341 (1998) (“The basic elements of procedural due process of law require notice and an opportunity to be heard at a meaningful time and in a meaningful 25 manner.”) (citations and internal quotation marks omitted). 46. The Planning Department provided Petitioner with due process of law by providing her with the Zoning Compliance Notice that informed her the she was in violation of KCC § 8-18.1(b). After providing such notice, the Planning Department met with her on April 12, 2017 to further discuss the basis of her violation. See Hearing Transcript at 64. 47. The evidence further demonstrates that Petitioner was not confused about the allegations contained in the Zoning Compliance Notice. Rather, she disagreed with the Planning Department’s interpretation of its rules because she believed that she should have been grandfathered in. See Hearing Transcript at 28 (“It never occurred to me for a minute that there would be anything other than that, that would occur. So I never thought that – I thought I should be grandfathered in.”). 48. When asked what her position was when she received the Zoning Compliance Notice, Petitioner testified that “[i]t was my position that I didn’t think they knew what they were doing and the process did not seem appropriate. . .” See Hearing Transcript at 26; see also Exhibit “3” (“It is my belief, however, that I have not, and have never, been in violation of any of the older county ordinances.”). 49. Due process requires only notice and an opportunity to be heard. Sullivan, 87 Hawaiʻi at 243, 953 P.2d at 1341. Petitioner has been afforded such an opportunity. Petitioner clearly disagrees with the Planning Department’s interpretation of Article 18, but differing opinions on the law do not rise to the level of a due process violation. 50. Accordingly, there was no due process violation in the Planning Department’s issuance of the NOV. D. The Fines Imposed By The NOV Were Authorized by KCC Section 8-3.5. 26 51. Finally, the Petitioner argues that the Planning Department acted erroneously, arbitrarily, and manifestly abused its discretion when it issued the NOV and imposed an excessive fine against Petitioner. 52. In the event of a homestay violation, KCC Section 8-18.3(e) states that “[e]nforcement of this section shall be subject to Section 8-3.5 of the Kauai County Code.” 53. KCC Section 8-3.5 provides the authority for the Planning Department’s issuance of a civil fine of $10,000 and the imposition of a civil fine up to $10,000 per day for each day the violation persists. See KCC § 8-3.5(b)(1). 54. Mr. Laureta explained the Planning Department’s fining procedure as follows: “we start off at 10. If there’s any effort towards compliance, we start off at 10, and during the remediation phase without the NOV in the ZCN phase, if there’s any effort, any willingness to remediate by providing us documentation, we would say we could reduce the fine depending on how fast you can remediate. So depending on how long it takes to provide us documentation that you’ve cancelled all your commitments, that you removed your website, we would offer up a reduced fine consideration. If there is no effort to do any of that and the use continues, especially after the ZCN meeting, then it’s like, nah, you know, 10. We stay at 10. Let them appeal the 10 because they made no effort to remediate, which includes no effort to cancel the website, cancel future commitments, and try and get into compliance.” See Hearing Transcript at 46. 55. It is undisputed that Petitioner failed to make any effort to return to compliance. 56. The Planning Department was within its authority to levy a $10,000 fine and impose a $10,000 fine per day that the violation continues as authorized by KCC § 8-3.5. See HRS § 91-14(g)(2) (agency acting in “excess of the statutory authority or jurisdiction” is 27 grounds for reversal or modification of agency decision); Kilakila ʻO Haleakala v. Bd. of Land and Natural Resources, 138 Hawaiʻi 383, 401, 382 P.3d 195, 213 (2016) (“A determination made by an administrative agency acting within the boundaries of its delegated authority will not be overturned unless ‘arbitrary, or capricious, or characterized by a clearly unwarranted exercise of discretion.’ ”) 57. Petitioner has not presented evidence that the Planning Department did not act erroneously, arbitrarily or manifestly abuse its discretion by imposing the fines contained in the NOV. 58. If any Conclusion of Law herein should be designated as a Finding of Fact, the same shall be deemed to have been identified as such. VI. CONCLUSION Based upon the foregoing, it is recommended that the Planning Commission AFFIRM the decision of the Planning Director in issuing the Notice of Violation & Order to Pay Fines dated May 23, 2017, and DISMISS Petitioner’s appeal because Petitioner has not met her burden to establish that the action by the Planning Director was based on an erroneous finding of a material fact, or that the Planning Director acted in an arbitrary or capricious manner, or abused his discretion. RPPPC Rule 1-9-2(b)(6). DATED: Lihue, Hawaii, ___________________. _______________________________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‘i 7874834.2 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUAʽI In the Matter of: Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Haʽena, Kauaʽi, Hawaiʽi, identified by Kauaʽi TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUAʽI, Respondent. CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE The undersigned hereby certifies that on the date and by the method of service noted below, a true and correct copy of the foregoing was served on the following at their last known address: 2 U.S. MAIL HAND DELIVERY EMAIL GREGORY W. KUGLE gwk@hawaiilawyer.com JOANNA C. ZEIGLER JCZ@hawaiilawyer.com Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Attorneys for Petitioner PATRICIA D. McCONNELL X X NICHOLAS R. COURSON ncourson@kauai.gov First Deputy County Attorney County of Kauaʽi 4444 Rice Street, Suite 220 Lihuʽe, HI 96766 Attorney for Planning Commission, County of Kauaʽi X X ELLEN CHING, Administrator eching@kauai.gov asegreti@kauai.gov Office of Boards and Commissions County of Kauaʽi 4444 Rice Street, Suite 150 Lihuʽe, HI 96766 X X HARLAN Y. KIMURA hyk@harlankimuralaw.com Central Pacific Plaza 220 South King Street, Suite 1660 Honolulu, HI 96813 Telephone: (808) 564-0811 Hearing Officer Planning Commission, County of Kaua‘i X X DATED: Honolulu, Hawai`i, January , 2020. J S. M CHRISTOPHER P. ST. SURE Attorney for Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUAI 3 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 HEARING OFFICER’S REPORT AND RECOMMENDATION OF CONTESTED CASE; CERTIFICATE OF SERVICE HEARING (Held): Date: August 30, 2019 Time: 9:00 a.m. HEARING OFFICER’S REPORT AND RECOMMENDATION OF CONTESTED CASE I. INTRODUCTION. This Contested Case arises as a result of the letter stamp-dated May 23, 2017 entitled “NOTICE OF VIOLATION & ORDER TO PAY 2 FINES” (“Notice of Violation”) issued by Respondent PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I (“Planning Department”) to Petitioner PATRICIA D. McCONNELL (“Petitioner”). Exhibit D1. The Notice of Violation advised Petitioner to immediately Cease and Desist the use of her property located at 4813 Ananalu Road in Hanalei, Kauai for “transient accommodations”2 because it is in a location not designated as a Visitor 1 All Exhibits identified by Alphabets were introduced by the Planning Department. Conversely, all Exhibits referenced by Numbers originated from Petitioner. Hearing Officer’s Scheduling Order dated December 14, 2018 (“Scheduling Order”) at 2. 2 “Transient Accommodations” as used in the Notice of Violation refers to a “Homestay” as defined in Kaua‛i County Code (“KCC”) § 8-1.5. A Homestay is “an owner occupied dwelling unit in which overnight accommodations are provided to transient guests within the same dwelling unit in which the owner resides and the respective owner currently benefits under Sec. 5A-11 of this Code for a homeowners’ exemption for the homestay site. A guest house may not be used as accommodations for transient guests in a homestay operation. Id. (emphasis added). A Dwelling Unit is defined as “any building or any portion thereof which is designed or intended for occupancy by one (1) family or persons living together or by a person living alone and providing complete living facilities, within the unit for sleeping, recreation, eating and sanitary facilities, including installed equipment for only one (1) kitchen.” Id. (emphasis added). Transient is “any person who owns, rents, or uses a dwelling unit or a portion thereof for one hundred eighty (180) days or less, and which dwelling unit is not the person’s primary residence under the Internal Revenue Code. . . .” Id. (emphasis added). A Guest House is “a building with a floor area of no more than five hundred (500) square feet, may contain a kitchen, and is used for dwelling purposes by guests, tenants, or owner(s). A guest house shall not be used for a transient vacation rental (TVR) or homestay operation within or outside of the visitor destination area (VDA).” Id. (emphasis added). A Building is defined as “a roofed structure, built for the support, shelter or enclosure of persons, animals, chattels or property of any kind. The word ‘building’ includes the word ‘structure.’” Id. (emphasis added). A Kitchen is defined as “any room used or intended or designed to be used for cooking and preparing food.” Id. Visitor Destination Areas or VDAs “are those areas designated as Visitor Destination Areas on County of Kaua‛i Zoning Maps.” Id. and See also Ordinance No. 436 adopted on September 7, 1982 by the County of Kaua‛i County Council (“Ordinance No. 436”). 3 Destination Area. Id. at 1. After receiving the Notice of Violation, Petitioner submitted a timely Notice of Appeal and Demand for Contested Case Hearing dated June 9, 2017 through her counsel, Gregory W. Kugle, Esq., and Veronica A. Nordyke, Esq., of the law firm of Damon Key Leong Kupchak Hastert (“Notice of Appeal”). II. PROCEDURAL HISTORY. Pursuant to the Hearing Officer’s First Amended Scheduling Order dated July 5, 2019 (“First Amended Scheduling Order”), the Planning Department submitted Respondent Planning Department Of The County Of Kauai’s Motion For Summary Judgment dated July 9, 2019 (“Planning Department’s MSJ”) arguing there is no genuine issue of material fact that Petitioner is operating the Subject Property as a homestay outside of a VDA in violation of KCC § 8-18.1(b). Attached to the Planning Department’s MSJ is the Declaration of Mike Laureta (“Laureta Declaration”), the Program Manager and Custodian of Records for the Planning Department.3 The Exhibits appended to the Laureta Declaration contained copies of documents in the Investigation File offered in support of the A Structure is defined as “anything constructed or erected which requires location on the ground or which is attached to something having location on the ground . . .” Id. 3 See Transcript of the Contested Case Hearing held on August 30, 2019 in this Contested Case; CC-2017-4 (“Transcript”) at 35-36. 4 Notice of Violation. Finally, the Declaration of Britni Ludington-Braun (“Ludington-Braun Declaration”), ADU/TVR Enforcement Specialist with the Planning Department,4 sets forth the details regarding Petitioner’s meeting with her and Mr. Andres “Bambi” Emayo (“Emayo”), Supervising Inspector for the Enforcement Section of the Planning Department,5 on April 12, 2017 as a result of the Zoning Compliance Notice stamp-dated January 11, 2017 (“Zoning Compliance Notice”). Petitioner Patricia McConnell’s Memorandum In Opposition To Respondent Planning Department Of The County Of Kauai’s Motion For Summary Judgment dated August 14, 2019 (“Memorandum In Opposition”) responded that the Planning Department’s MSJ should be denied on five (5) grounds. First, the Planning Department’s MSJ is “factually unsupported” because the Laureta Declaration and Ludington-Braun Declaration are deficient and void of facts to support the Zoning Compliance Notice and/or Notice of Violation. Memorandum In Opposition at 5. Second, the Planning Department failed to submit evidence of “an actual violation.” Id. at 6-7. Instead, the Notice of Violation is supported by Internet postings of advertisements for daily rental of the Subject Property and reviews of guests allegedly having stayed at that location. Id. Third, the 4 SeeTranscript at 101. 5 See Transcript at 54. 5 $150,000.00 fine imposed by the Notice of Violation is not supported by the facts and unconstitutionally excessive. Id. at 7-9. Fourth, the Planning Department refused to comply with Petitioner’s Discovery Request and therefore, on or about July 10, 2019 submitted a Uniform Information Practices Act Request For Government Records to obtain the requested documents (“UIPA Request”).6 Compare Id. at 9, with Exhibit 1 attached to Memorandum In Opposition. Finally, Summary Judgment would deny Petitioner’s right to a Contested Case Hearing pursuant to RPPPC Rule 1-9-3 and Chapter 91 of the Hawai‛i Revised Statutes. Memorandum In Opposition at 9-10. In reply to the Memorandum In Opposition, the Planning Department noted Petitioner admitted to operating a homestay outside of a VDA. Respondent Planning Department Of The County Of Kaua‛i’s Reply To Petitioner Patricia McConnell’s Memorandum In Opposition To Respondent County of Kauai’s Motion For Summary Judgment (“Planning Department’s Reply”) at 2. Secondly, the Comprehensive Zoning Ordinance (“CZO”) prohibits homestay operations outside of VDAs pursuant to KCC § 8-18.1(b). Id. at 7-8. Finally, KCC § 8-3.5(b) permits the Planning Department to impose fines of up to $10,000.00 per day. Id. at 7-8. 6 The Planning Department is permitted to refuse Petitioner’s Discovery Request pursuant to Rule 1-6-9(b) of the Rules of Practice and Procedure of the Kaua‛i County Planning 6 The Planning Department’s MSJ came on for hearing before this Hearing Officer at 9:00 a.m. on August 30, 2019 (“MSJ Hearing”). Gregory W. Kugle appeared on behalf of Petitioner. Maryann Sasaki appeared on behalf of the Planning Department, along with its duly authorized representative Emayo joining her later in these proceedings. Transcript at 24-25. Although the Agency Hearing Notice for this Contested Case was prepared and filed with the Office Of The County Clerk, County of Kaua‛i, State of Hawai‛i, and timely posted pursuant to RPPPC Rule 1-6-5 and Haw. Rev. Stat. § 91-9, no other parties or members of the general public appeared at the Hearing. Transcript at 4. After receiving arguments summarizing the respective positions of the Planning Department and Petitioner, this Hearing Officer DENIED the Planning Department’s MSJ. Id. at 3-4. The Planning Department’s MSJ was denied because neither the Laureta Declaration nor the Ludington-Braun Declaration stated those declarants were competent to testify to the matters set forth in their declarations. Id. at 4. Moreover, the Laureta Declaration was conclusory in nature, rather than setting forth specific undisputed facts which support the Planning Department’s arguments that it should be entitled to judgment as a matter of law. See Memorandum In Opposition at 4 citing GECC Financial Corporation. Commission (Codified May 2014) (“RPPPC”). 7 v. Jaffarian, 79 Hawai‛i 516, 521, 904 P.2d 530, 535 (Haw.Ct.App. 1995) and Transcript at 4.7 The final preliminary matter concerned the exhibits to be admitted into evidence. Transcript at 4-5. First, Exhibits 1 through 5, and Exhibit D, were admitted into evidence by stipulation. Id. at 5. Second, Petitioner objected to Exhibits A, B, C, E, and F on grounds they appear to be documents from the Planning Department’s Investigation File which were not previously provided to her.8 Id. at 5-7. Therefore, Petitioner argued “it is unfair and it’s trial by surprise” by not having advance copies of those exhibits. Id. at 6. This Hearing Officer OVERRULED Petitioner’s objections to those exhibits because the Hawai‛i Rules of Evidence do not apply to these proceedings under RPPPC Rule 1-6-17(a) and therefore, would permit their introduction by the Planning Department.9 Transcript at 7. To address Petitioner’s claim of “unfair surprise,” this Hearing Officer offered to continue the evidentiary portion of the hearing (“Hearing”) should she determine additional research or preparation would be required to adequately oppose the evidentiary value of those exhibits. Id. 7 The denial of the Planning Department’s MSJ on these grounds dispenses with the need to address the other arguments set forth in the Memorandum In Opposition. 8 See footnote no. 6, infra. 9 Exhibits A, B, C, and E were in fact offered and admitted into evidence. See Transcript at 55-63. However, the Planning Department did not offer Exhibit 7 into evidence. See Id. at 1-120. 8 III. DEVELOPMENTS DURING HEARING. During the Hearing the Planning Department also offered Supplemental Exhibit G into evidence. Id. at 108. Exhibit G is the Planning Department’s Investigation Report dated July 10, 2018 concerning the transient accommodations at the Subject Property. Id. at 101-07. On January 17, 2020, the Planning Department provided a Supplemental Exhibit List and Exhibit G to all the parties as previously directed by this Hearing Officer. Transcript at 112. Also during the Hearing testimony was presented that the Planning Department did NOT receive the UIPA Request. Minutes Of Contested Case Hearing dated August 31, 2019 (“CCH Minutes”) at 2 and Transcript at 94-96. Therefore, upon conclusion of the Hearing Petitioner requested leave to submit another UIPA Request (“UIPA Request II”). CCH Minutes at 2 and Transcript at 117. At stated times, Petitioner was requested to provide Status Reports regarding the Planning Department’s response to UIPA Request II. CCH Minutes at 3 and Minute Order Regarding Pending Matters dated October 9, 2019 at 2-3. Since Petitioner subsequently reported the Planning Department rejected UIPA Request II, the Hearing was closed pursuant to RPPPC Rule 1-6-11(j) and a briefing schedule issued for submission of Closing Arguments and/or Proposed Findings of Fact and Conclusions of Law. Minute Order Regarding Telephone 9 Conference dated December 12, 2019 at 2-3. The requested Closing Arguments and/or Proposed Findings of Fact and Conclusions of Law were timely received.10 IV. FINDINGS OF FACT. A. The Parties and Subject Property. 1. Petitioner is the owner of the real property located at 4813 Ananalu Road, Hanalei, Kaua‛i, Hawai‛i 96714, TMK No. (4) 8-005:005 which is the subject of this Contested Case (“Subject Property”). Exhibit A at 1. 2. The Subject Property is located outside any of the Visitor Destination Areas. Transcript at 36-37 and see also Ordinance No. 436 at 1 and 8-11. 3. Petitioner has been residing at the Subject Property as her principal residence since she purchased it in 2004. Exhibit “3” at 1 and Transcript at 8-9. She began operating the Subject Property as a homestay from 2005 (“Homestay Operation”). Transcript at 9. 10 The issuance of this Report and Recommendation has been delayed due to the: (a) COVID-19 Pandemic; (b) Proclamation issued by the Governor of the State of Hawai‛i dated March 4, 2020, Supplementary Proclamation dated March 16, 2020, Second Supplementary Proclamation dated March 21, 2020 and Third Supplementary Proclamation dated March 23, 2020; and (c) Proclamation COVID-19 [Novel Coronavirus] dated March 4, 2020 issued by the Mayor of the City and County of Honolulu, Supplemental Proclamation Of Emergency Or Disaster (COVID-19 [Novel Coronavirus]) dated March 18, 2020, Emergency Order No. 2020-01 (COVID-19 [Novel Coronavirus]), and Emergency Order No. 2020-02. 10 4. In 2005 Petitioner inquired with the Planning Department as to the requirements for the Homestay Operation. Id. at 10. At that time only a State of Hawai‛i General Excise Tax License and Transient Accommodations Tax License were required for the Homestay Operation. Compare Id., with Ordinance No. 935 adopted by the County of Kaua‛i County Council (“Council”) on November 14, 2012 and codified as KCC § 8-3.2, as amended. 5. The Homestay Operation which began in 2005 continued through the date of the Hearing. Compare Id. at 11, with 30-31. 6. The Planning Department is the governmental agency responsible for enforcing, among other things, the provisions of the CZO set forth in Chapter 8 of the Kaua‛i County Code. The Charter Of The County of Kaua‛i (2018 Codified Version), Article XIV, Section 14.05. B. Zoning Compliance Notice. 7. On January 10, 2017, Emayo began an investigation of the Subject Property to determine its compliance with the CZO. See generally Transcript at 54-66. He prepared an Investigation Report dated January 10, 2017 based upon his discovery that transient accommodations were being offered at the Subject Property (“Report I”). Exhibit B. 11 8. Report I contained a printout of an Airbnb advertisement (“Advertisement”) of a “luxury jungle retreat cottage . . . of about 1400 sq[uare] feet of space and has two bedrooms, a living room, a full kitchen, and enclosed lanai, a full bathroom and an outdoor shower.”11 Exhibit B at 15. There was also a separate cottage built onto the back of the house on the ground floor that could be rented out to other guests and identified as the “Sea Turtle Cottage.”12 Id. and see also Exhibit G at 13-23. 9. “By matching the airbnb’s website (https://www.airbnb.com/rooms/12622481) and pictures with Pictometry and cross checking with Real Property Division records (Tax Classification – Vacation Rental), [Emayo] was able to determine the Tax Map Key and Property Owner of [that] transient accommodation operation.” Id. at 1. It was the Subject Property owned by Petitioner. Id. 10. Petitioner and the Subject Property were not issued a Non-Conforming Use Certificate or applicable permit to conduct this transient accommodation outside a Visitor Destination Area and therefore, was in violation of KCC §§ 8-17.8 and 8-18.1(b). Exhibit B at 2. 11 The Advertisement also indicated the “luxury jungle retreat cottage” would be available to rent because Petitioner lives in a separate studio on the property. Exhibit B at 15. 12 11. By letter stamp-dated January 11, 2017 entitled “ZONING COMPLIANCE NOTICE”, the Planning Department advised Petitioner its investigation revealed the Subject Property was being used “for Transient Accommodation outside the designated Visitor Designation Area [and therefore,] constitutes a violation.” Exhibit C at 1. The ordinances cited were KCC § 8-18.1(b) related to homestay operations, and § 8-17.8 for Transient Vacation Rentals.13 Id. 12. The Zoning Compliance Notice further directed Petitioner to immediately “[c]ease and desist the use of the [S]ubject [P]roperty as a Transient Accommodation(s) . . . [and] Cancel all Transient Accommodations commitments for the property.” Id. at 2. Petitioner’s failure to comply with this directive “may result in a fine up to $10,000.00 and/or up to $10,000.00 per day, should the violation(s) persist.” Id. 12 It is unclear from the evidence introduced at the Hearing whether the “Sea Turtle Cottage” is the separate studio Petitioner lives in and referenced in the Advertisement. See footnote 11, infra. 13 A “Transient Vacation Rental” or “TVR” is defined as “a dwelling unit which is provided to transient occupants for compensation or fees, including club fees, or as part of interval ownership involving persons unrelated by blood, with a duration of occupancy of one hundred eighty (180) days or less.” Id. (emphasis added). Apparently this violation was also included in the Zoning Compliance Notice because the Advertisement noted the “entire portion of the main house [(i.e. the luxury jungle retreat cottage) would be available to rent because Petitioner] . . lives in a separate studio on the property . . .” Compare Exhibit B at 15, with Transcript at 75. 13 13. The Zoning Compliance Notice was addressed to Petitioner at 104 Endlich Dr., Santa Cruz, CA 95060. Id. This was also the mailing address of Petitioner as of January 10, 2017 according to the records of the Real Property Assessment Division of the County of Kaua‛i. Exhibit B at 4 and Transcript at 74. 14. Petitioner acknowledged receipt of the Zoning Compliance Notice on April 1, 2017 when a person came to the Subject Property and personally served her with it. Transcript at 12-13. 15. At the request of Petitioner, on April 12, 2017 she met with Emayo and Ms. Britni Ludington-Braun (“Ludington-Braun”) to discuss her response to the Zoning Compliance Notice (“Meeting”). Transcript at 78. According to Emayo, to remedy the violation Petitioner could either: (a) submit a written remedial action plan; (2) remove the internet advertisement for the homestay rental of the Subject Property; and/or (3) “work with the Planning Department to rectify the violation.” Transcript at 79. 16. Following the Meeting, Petitioner submitted a letter dated April 13, 2017 to the Planning Department stating her belief is that she “have (sic) not, and have (sic) never, been in violation of any of the older county ordinances.” Exhibit E at 12. Petitioner was of that opinion because she assumed the Homestay Operation at the Subject Property was “grandfathered” from the prohibition of homestays outside of VDAs pursuant to Ordinance No. 1002 adopted by the 14 Council on May 18, 2016 (“Ordinance No. 1002”). See Transcript at 14 and 79. Nonetheless, in her own words she further stated “I wish to assure you I am, and will, make every attempt possible to assure I am in compliance with ordinances that apply to me and my home here in Kauai.” Id. C. Notice of Violation. 17. On May 16, 2017 Emayo conducted a follow-up investigation to determine whether Petitioner ceased the Homestay Operation at the Subject Property and cancelled all future bookings (“Report II”). Exhibit E. Emayo found website advertisements continuing to offer the Subject Property as a Transient Accommodation. Id. at 4-6. There were also two (2) reviews of guests staying at the Subject Property in April 2017. Id. at 7. 18. Based upon Report II, Emayo prepared the Notice of Violation reminding Petitioner that the Zoning Compliance Notice required her to “Cease and Desist the use of the [S]ubject [P]roperty for transient accommodations [and cancel all future commitments for such use].” Exhibit D at 1. The Notice of Violation also referenced the Meeting and confirmed “the continued transient accommodation operation (Homestay) use at the [S]ubject [P]roperty is a violation 15 of the Comprehensive Zoning Code, Chapter 8, Kaua‛i County Code, 1987, as Amended”.14 Id. 19. Due to Petitioner’s refusal to comply with the Zoning Compliance Notice and instructions at the Meeting, Petitioner was “ordered to pay a fine of ten thousand dollars ($10,000.00) for the above noted violations to the Planning Department”. Id. at 2 (emphasis in original). If those violations were not remedied within 14 days of the Notice of Violation, “[a]n additional fine of $10,000.00 per violation, per day, for each day in which such violation persists shall be levied.” Id. at 3 (emphasis in original). D. Appeal Of Notice of Violation. 20. By letter dated June 9, 2017 Counsel for Petitioner appealed the Notice of Violation to the Kaua‛i Planning Commission (“Commission”) pursuant to RPPPC Chapter 9 on two (2) grounds. See Notice of Appeal. First, Petitioner argued “[u]pon implementation of the Homestay Ordinance [(i.e. Ordinance No. 1002 codified as KCC § 8-18.1)], [her] business became a vested, non-conforming use. Thus, she is not subject to Sec. 8-18.1 of the CZO, or subject to the associated fines.” Notice of Appeal at 2. Second, “the Director [of the 14 Unlike the Zoning Compliance Notice, the Notice of Violation only referenced the Homestay Operation because the Planning Department “had no evidence of continued use [of the Subject Property as also a Transient Vacation Rental].” Transcript at 87. 16 Planning Department] acted erroneously, arbitrarily, and manifestly abused his discretion when he ignored [Petitioner’s] valid concerns about the applicability [of the] Homestay Ordinance to her business and issued the [Notice of Violation].” Id. E. Relevant Authorities and Pertinent Legislative History. 21. Haw. Rev. Stat. § 46-4(a) provides in pertinent part: (a) This section and any ordinance, rule, or regulation adopted in accordance with this section shall apply to lands not contained within the forest reserve boundaries as established on January 31, 1957, or as subsequently amended. Zoning in all counties shall be accomplished within the framework of a long-range, comprehensive general plan prepared or being prepared to guide the overall future development of the county. Zoning shall be one of the tools available to the county to put the general plan into effect in an orderly manner. Zoning in the counties of Hawaii, Maui, and Kauai means the establishment of districts of such number, shape, and area, and the adoption of regulations for each district to carry out the purposes of this section. In establishing or regulating the districts, full consideration shall be given to all available data as to soil classification and physical use capabilities of the land to allow and encourage the most beneficial use of the land consonant with good zoning practices. The zoning power granted herein shall be exercised by ordinance which may relate to: . . . (2) The areas in which residential uses may be regulated or prohibited; 17 . . . (4) The areas in which particular uses may be subjected to special restrictions; . . . (12) Other regulations the boards or city council find necessary and proper to permit and encourage the orderly development of land resources within their jurisdictions. The council of any county shall prescribe rules, regulations, and administrative procedures and provide personnel it finds necessary to enforce this section and any ordinance enacted in accordance with this section. The ordinances may be enforced by appropriate fines and penalties, civil or criminal, or by court order at the suit of the county or the owner or owners of real estate directly affected by the ordinances. . . . The powers granted herein shall be liberally construed in favor of the county exercising them, and in such a manner as to promote the orderly development of each county or city and county in accordance with a long-range, comprehensive general plan to ensure the greatest benefit for the State as a whole. This section shall not be construed to limit or repeal any powers of any county to achieve these ends through zoning and building regulations, except insofar as forest and water reserve zones are concerned and as provided in subsections (c) and (d). [(This paragraph shall hereafter be referred to as the “Liberal Construction Provision”.)] Neither this section nor any ordinance enacted pursuant to this section shall prohibit the continued lawful use of any building or premises for any trade, industrial, residential, agricultural, or other purpose for which the building or premises is used at the time this section or the 18 ordinance takes effect; provided that a zoning ordinance may provide for elimination of nonconforming uses as the uses are discontinued, or for the amortization or phasing out of nonconforming uses or signs over a reasonable period of time in commercial, industrial, resort, and apartment zoned areas only. In no event shall such amortization or phasing out of nonconforming uses apply to any existing building or premises used for residential (single-family or duplex) or agricultural uses. Nothing in this section shall affect or impair the powers and duties of the director of transportation as set forth in chapter 262. [(This paragraph shall hereafter be referred to as the “Continued Lawful Use Provision”.)] (emphasis added). 21. KCC § 8-17.8 adopted by the Council on February 20, 2008 as part of Ordinance No. 864 provided in pertinent part: Sec. 8-17.8 Single Family Transient Vacation Rentals. (a) Notwithstanding any underlying zoning designation and with the exception of properties on the National or State Register of Historic Places, single-family transient vacation rentals are prohibited in all areas not designated as Visitor Destination Areas. (second emphasis added). 22. KCC § 8-17.10 also adopted by the Council as part of Ordinance No. 864 provided in pertinent part: Sec. 8-17.10 Nonconforming Use Certificates for Single-Family Vacation Rentals. (a) The purpose of this section is to provide a process to identify and register those single-family transient vacation rentals as nonconforming uses which have been in lawful use prior to the 19 effective date of this ordinance and to allow them to continue subject to obtaining a nonconforming use certificate as provided by this section. (b) The owner, operator or proprietor of any single- family transient vacation rental which is operating outside of a Visitor Destination Area on the effective date of this ordinance shall by March 30, 2009, obtain a nonconforming use certificate for single family vacation rentals. . . . (f) Failure to apply for a nonconforming use certificate by October 15, 2008 or failure to obtain a nonconforming use certificate by March 30, 2009, shall mean that the alleged nonconforming use is not a bona fide nonconforming use, and it shall be treated as an unlawful use, unless the applicant demonstrates to the satisfaction of the Planning Commission that the alleged vacation rental use meets the criteria under Section 8-17.10(c) and (d). The Planning Director shall prepare an application form which shall be available to the public by March 30, 2008. (emphasis added, except for “Sec. 8-17.10 Nonconforming Use Certificates for Single-Family Vacation Rentals.”). 23. The intent of the Council in adopting Ordinance No. 864 was, in pertinent part, as follows: SECTION 1. Findings and Purpose. The Council of the County of Kaua'i finds that there is a compelling need to regulate single-family transient vacation rentals on Kaua'i. Single-family transient vacation rentals are occurring at a greater rate and inflicting a larger impact on the community of Kaua'i than was ever anticipated in the County's original Comprehensive Zoning Ordinance. While this type of visitor unit could be compatible with the character and nature of Kaua'i and while it has certain positive advantages to the community and is desirable in terms of offering a mix of accommodations to the visitor, 20 the uncontrolled proliferation of vacation rentals in residential and other areas outside the Visitor Destination Areas (VDAs) is causing significant negative impacts to certain residential neighborhoods, foreshadowing similar potential impacts on other areas of the island[.] The County General Plan, updated in the year 2000, recognizes this need by its policy for "Alternative Visitor Accommodations," which reads as follows: "4.2.8.2 Alternative Visitor Accommodations (a) The County of Kaua'i shall recognize alternative visitor accommodations, such as B&Bs, vacation rentals, inns, cabins, and retreat centers. (b) The County shall enact clear standards and permit processes for regulating alternative visitor accommodation structures and operations in Residential, Agriculture, Open, and Resort zoning districts. . . . Census data shows that seasonal rentals account for 45% of the new housing units built on Kaua'i between 1990 and 2000, a greater percentage than housing built for long-term renters (14%) or for owner-occupied use (36%). Since 2000, out of the 2,050 new residential units, 1,070 have been built for the seasonal homes market and less than half have been for local families to rent (46) or own (936). The potential for vacation rental use increases the value and thus the selling price and investment rating of property on Kaua'i, which increases prices and adds another potential layer of speculation in the real estate market. This also means that the limited available infrastructure and resources on Kaua'i, including roads, water, sewer capacity, building materials, and contractor time are being used primarily for expensive second or third homes rather than the primary home needs of local residents. In oceanfront or other places of premium real estate value, second and third homes and vacation rentals (often one and the 21 same) are displacing traditional neighborhoods where people of low and moderate income have been able to live in the past. Besides contributing to a lack of affordable housing in the community, this is changing the social character of neighborhoods where neighbors used to know each other. This has tended to make these neighborhoods more vulnerable to crime. While regulating single-family vacation rentals will not guarantee more affordable housing, it will dampen speculation and bring a halt to uncontrolled growth and cumulative impacts of vacation rentals which have affected the traditional neighborhoods of 'Anini and Ha'ena, and which could or are beginning to also affect neighborhoods such as Waimea Valley, Kekaha, and the makai side of Kapa'a Town. . . . The purpose of this bill is to restore a balance between primary residences and single-family transient vacation rentals by: 1) requiring registration of vacation rentals or nonconforming use certificates and setting standards for all vacation rentals, 2) explicitly prohibiting new single-family vacation rentals outside visitor destination areas (multi-family vacation rentals are already so prohibited), and 3) identifying and allowing nonconforming uses where single-family vacation rentals have been operating lawfully prior to approval of this bill. (emphasis added). 24. With respect to Homestays, Ordinance No. 864 indicated that: This bill does not apply to a bed and breakfast unit (“Homestay”). It is the intention of the Council to address these units as a separate matter after establishing a regulatory framework for single-family transient vacation rentals. Homestays are presently regulated through the use permit process [pursuant to KCC § 8-3.2]. (emphasis added). 22 25. As indicated by the Council, Ordinance No. 1002 was adopted on May 18, 2016 to address regulation of Homestays, and provided in pertinent part: SECTION 1. Findings and Purpose: The Council finds the 2000 Kaua‛i General Plan recognized the need “to develop a clear policy regarding B&Bs and vacation rentals” The General Plan recommended an implementing action to amend the CZO to facilitate the permitting of existing, nonconforming alternative visitor accommodations. The Council complied with the policy of the General Plan and grandfathered existing single-family transient vacation rentals (SFTVRs) that registered and met the prior use requirements established in Article 17 of the CZO. . . . Although the Council bifurcated the issues of homestays and SFTVRs, it is now appropriate to adopt a clear and specific standard and review parameters under which homestay applications can be processed. The purpose of this bill is to restrict homestay operations to the Visitor Destination Areas (VDAs) and to establish additional standards under which homestays operate. Sec. 8-18.1 General Provisions for Homestays. (a) A homestay operation shall operate under the following regulations: (1) Transient accommodations are provided for visitors for twenty-nine (29) days or less; (2) Homestays shall be limited to no more than three (3) guest rooms per homestay operation; (3) During homestay operations, the owner(s) benefiting under Sec. 5A-11 of this Code for a homeowner’s exemption for the homestay site must be physically within the County of Kaua‘i, 23 residing at the homestay operation site, and physically available for the needs and concerns of their respective homestay guests; and (4) No other individual or designated representative may act on the owner(s) behalf to meet the requirements of Sec 8-18.1(a)(3). (b) Homestay operations are prohibited outside of the Visitor Destination Area (VDA). (emphasis added, except for “Sec. 8-18.1 General Provisions for Homestays.”). 26. Visitor Destination Areas were first established by Ordinance No. 436 adopted by the Council on September 7, 1982 and provided in pertinent part, as follows: SECTION 1. Findings and Purpose. Pursuant to the authority of Act 186, Session Laws of Hawaii, 1980, the County Council enacts this ordinance for the purpose of designating locations, referred to as “Visitor Destination Areas”, in which transient vacation rentals, time share units and time share plans are allowed. These Visitor Destination Areas include lands in Poipu, Lihue, Wailua-Kapaa and Princeville and are delineated on Visitor Destination Area Maps incorporated as part of this ordinance. (emphasis added). 27. KCC § 8-13.2 adopted by the Council on November 14, 2012 as part of Ordinance No. 935 in its effort to update the CZO by focusing on, as a first step, the organizational and format changes, provides in pertinent part: (a) A nonconforming use of land, buildings, or other structures may continue to the extent that the use existed on September 1, 1972 or any amendment hereto, as provided in this Section, provided that the Planning Commission may, after hearing, 24 order the termination of a nonconforming use that creates substantial danger to public health or safety. (b) If any nonconforming use ceases for any reason for continuous period of twelve (12) calendar months or for one (1) season if the use be seasonal, then the use shall not be resumed and any use of the land or building thereafter shall be in full conformity with the provisions of this Chapter. (emphasis added). 28. Enforcement authority, and penalties, of the above Ordinances are set forth in three (3) separate Sections of the Kaua‛i County Code. They are in pertinent part: Sec. 8-3.5 Enforcement, Legal Procedures and Penalties. (a) Enforcement, Legal Procedures and Penalties. . . . (2) It shall be the duty of the Planning Commission and Planning Director to enforce the provisions of this Chapter and it shall be the duty of all law enforcement officers of the County of Kaua‘i to enforce this Chapter and all the provisions thereof. . . . (b) Civil Fines. (1) If the Director of the Planning Department determines that any person, firm or corporation is not complying with a notice of violation, the Director may have the party responsible for the violation served, by mail or delivery, or by posting of the property which address is the most current address reflected in the Real Property tax records, or by publishing such notice in a newspaper of general circulation in the County of Kaua‘i should previous notification 25 efforts not be accepted, with an order pursuant to this Section. The order may require the party responsible for the violation to do any or all of the following: (A) correct the violation within the time specified in the order; (B) pay a civil fine not to exceed ten thousand dollars ($10,000.00) in the manner, at the place, and before the date specified in the order; (C) pay a civil fine up to ten thousand dollars ($10,000.00) per day for each day in which the violation persists, in the manner and at the time and place specified in the order. All civil fines shall be deposited to the Planning Enforcement Account within Fund 251. (2) The order shall advise the party responsible for the violation that the order shall become final thirty (30) calendar days after the date of its delivery or posting on the property, or publishing of such notice in a newspaper of general circulation in the County of Kauai. The order shall also advise that the Director’s action may be appealed to the Planning Commission. (3) The provisions of the order issued by the Director under this Section shall become final thirty (30) calendar days after the service or posting on the property, or publishing of such notice in a newspaper of general circulation in the County of Kaua‘i, of the order. The parties responsible for the violation may appeal the order to the Planning Commission pursuant to its rules. The form of this appeal must conform to the Planning Commission’s rules. However, an appeal to the Planning Commission shall not stay any provision of the order. (emphasis added, except for “Sec. 8-3.5 Enforcement, Legal Procedures and Penalties.”) Sec. 8-17.6 Penalty. An owner of any unit which is operated in violation of this Article, and/or any other person, firm, company, association, partnership or corporation violating any provision of this Article, shall each be fined not less than five hundred dollars ($500.00) nor more than ten thousand dollars ($10,000.00) for each offense. This civil fine may be in addition to any criminal fines. If any person fails to cease such violation within one (1) 26 month, such person shall be subject to a new and separate violation for each day the violation continues to exist. (emphasis added, except for “Sec. 8-17.6 Penalty.”). Sec. 8-17.11 Enforcement Against Illegal Transient Vacation Rentals. a) In addition to other penalties provided by law, including, but not limited to, Secs. 8-3.5(a) and 8-17.6, the Planning Commission Rules, as amended, the Planning Director, or any member of the public who has duly obtained standing pursuant to rules promulgated by the commission, may initiate proceedings to revoke or modify the terms of a Nonconforming Use Certificate pursuant to the Rules of Practice and Procedures of the Planning Commission, as amended. Violations of conditions of approval or providing false or misleading information on the application or in any information relating thereto at any time during the application process shall be grounds for revocation or cease and desist orders. (b) Advertising of any sort which offers a property as a transient vacation rental shall constitute prima facie evidence of the operation of a transient vacation rental on said property and the burden of proof shall be on the owner, operator, or lessee to establish that the subject property is not being used as a transient vacation rental or that it is being used for such purpose legally. If any unit is found to be operating unlawfully, penalties established in Secs. 8-3.5(a) and 8-17.6 shall apply. (emphasis added, except for “Sec. 8-17.11 Enforcement Against Illegal Transient Vacation Rentals.”). 29. If any Finding of Fact herein should be designated as a Conclusion of Law, the same shall be deemed to have been identified as such. / / / / 27 V. CONCLUSIONS OF LAW. A. Principles of Statutory Construction. 1. “Courts are bound to give effect to all parts of a statute, and that no clause, sentence, or word shall be construed as superfluous, void, or insignificant if a construction can be legitimately found which will give force to and preserve all words of the statute.” Robert D. Ferris Trust v. Planning Com’n of County of Kauai, 138 Hawai‛i 307, 310, 378 P.3d 1023, 1026 (2016) quoting State v. Kaakimaka, 84 Hawai‛i 280, 289-90, 933 P.2d 617, 626-67 (1997). 2. “The general rule is that repeals by implication are not favored and that if effect can reasonably be given to two statutes, it is proper to presume that the earlier statute is to remain in force and the later statute did not repeal it.” Reefshare, Ltd. v. Nagata, 70 Hawai‛i 93, 97, 762 P.2d 169, 172 (1988) quoting State v. Pacariem, 67 Hawai‛i 46, 48, 677 P.2d 463, 465 (1984). 3. “[W]here there is a plainly irreconcilable conflict between a general and specific statute concerning the same subject matter, the specific will be favored. However, where the statutes simply overlap in their application, effect will be given to both if possible, as repeal by implication is disfavored.” Mahiai v. Suwa, 69 Hawai‛i 349, 356-57, 742 P.2d 359, 366 (1987) (internal quotation marks and citations omitted). 28 4. Another “cardinal rule of statutory construction is that [the courts] must ascertain and give effect to the intention of the legislature, and [they] must read statutory language in the context of the entire statute and construe it in a manner consistent with its purpose.” Roaring Lion, LLC v. Exclusive Resorts PBL 1, LLC, 2013 WL 1759002 at 10 (Haw. Ct. App. 2013) citing Haole v. State, 111 Hawai‛i 144, 149, 140 P.3d 377, 382 (2006). 5. “Laws in pari materia, or upon the same subject matter, shall be construed with reference to each other. What is clear in one statute may be called upon in aid to explain what is doubtful in another.” In the Interest of CM, 141 Hawai‛i 348, 353, 409 P.3d 752, 757 (2017) quoting State v. Young, 107 Hawai‛i 36, 39-40, 109 P.3d 677, 680-81 (2005) (citations, internal quotations marks, brackets, and ellipses omitted; format changed). 6. In addition to all these rules of statutory construction, statutes and ordinances must be interpreted, if possible, to avoid violating constitutional provisions. Ferris Trust¸ 138 Hawai‛i at 314, 378 P.3d at 1029 citing Life of the Land, Inc. v. West Beach Dev. Corp., 63 Hawai‛i 529, 531, 631 P.2d 588, 590 (1981). 7. “When interpreting county charters, municipal ordinances, and administrative rules, the general principles of statutory construction apply.” Ferris 29 Trust, 138 Hawai‛i at 310, 378 P.3d at 1026 quoting Kellberg v. Yuen, 131 Hawai‛i 513, 527, 319 P.3d 432, 446 (2014) (brackets omitted). 8. “It is a well established rule of statutory construction that, where an administrative agency is charged with the responsibility of carrying out the mandate of a statute which contains words of broad and indefinite meaning, courts accord persuasive weight to administrative construction and follow the same, unless the construction is palpably erroneous.” Hyatt Corp. v. Honolulu Liquor Com’n, 69 Hawai‛i 238, 242-43, 738 P.2d 1205, 1208 (1987) (brackets omitted). 9. “Zoning laws, whether statutes or ordinances, inasmuch as they curtail and limit uses of real estate and are in derogation of the common law must be given strict construction and the provisions thereof may not be extended by implication. Nevertheless, they should be read according to the natural and most obvious import of the language when there is no manifest legislative intent contrarywise.” Ferris Trust¸ 138 Hawai‛i at 311, 378 P.3d at 1027 quoting Maui Cty. v. Puamana Mgmt. Corp., 2 Haw.App. 352, 356, 631 P.2d 1215, 1218 (1981) (ellipsis omitted). / / / / 30 B. Interpretation and Application of Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2 to KCC § 8-18.1(b). 10. Petitioner first argues the Homestay Operation is a “Lawful Nonconforming Use” permitting her to continue that use notwithstanding the Subject Property is located outside of a Visitor Destination Area in violation of KCC § 8-18.1(b) (“Lawful Nonconforming Use Argument”). See Petitioner’s Closing Arguments; Proposed Hearing Officer Report And Recommendation dated January 15, 2020 (“Petitioner’s Proposed R&R”) at 5-6.15 In support of the Lawful Nonconforming Use Argument Petitioner relies upon Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2(a). Id., ¶¶8-11. Additionally, Petitioner cites “the Fifth Amendment of the United States Constitution and Article I, § 5 of the Hawaii Constitution [because they] both provide that no person shall be deprived of property without due process of law, nor have property rights taken or damaged without compensation.” Id. at 6, ¶12 citing Waikiki Marketplace Inv. Co. v. Chair of Zoning Bd. Of Appeals, 86 Hawai‛i 343, 353, 949 P.2d 183, 193 (Haw.Ct.App. 1997). 11. The Planning Department counters that the Lawful Continued Use Argument is inapplicable on five (5) grounds. Respondent Planning 15 Although Petitioner’s Proposed R&R does not contain any page numbers, references to the same is based upon the number of the page following the first (1st) page of that document. 31 Department Of The County Of Kauai’s Closing Arguments; Proposed Findings Of Facts And Conclusions O Law dated January 31, 2020 (“Planning Department’s Proposed R&R”) at 20-24, ¶¶25-43. Those five (5) grounds are: a. First, Haw. Rev. Stat. § 46-4(a) grant of authority to the counties “shall be liberally construed” and therefore, that statute may not usurp the zoning ordinances promulgated thereby;16 b. Second, Petitioner admitted to discontinuing the Homestay Operation from April 2018 to June 2019 and therefore, has abandoned that use prohibiting her from resuming it under KCC § 8-13.2(b);17 c. Third, the Homestay Operation is not continuous “because [Petitioner] was, at least sometimes, renting a dwelling that she did not reside in”;18 d. Fourth, even if the Homestay Operation was not abandoned or discontinued, the same “would not have been ‘lawful’ 16 Planning Department’s Proposed R&R at 20-22, ¶¶25-33. 17 Id. at 21, ¶30. 18 Id. at 22, ¶34. Such use would deem the Subject Property to be a “Transient Vacation Rental” in violation of KCC § 8-17.8(a). 32 because Petitioner admittedly did not have a use permit as required by KCC Section 8-3.2(b)”;19 and e. Finally, the “powers of the Hearing Officer originate from the Planning Commission, and the Planning Commission does not have authority to recognize Petitioner’s prior homestay use as a lawful nonconforming use, nor can the Planning Commission disregard the prohibition contained in KCC § 8-18.1(b).”20 12. Principles of statutory construction resolves the issue whether Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2(a) permit Petitioner to continue the Homestay Operation after passage of KCC § 18-18.1 in 2016. 13. Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2 are general in nature because they address all types of nonconforming uses, but KCC § 8-18.1(b) deals only with homestays outside of Visitor Destination Areas. Therefore, the specific provisions of KCC § 8-18.1(b) is favored with respect to homestays over Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2(a) which govern all other nonconforming uses. See Mahiai, 69 Hawai‛i at 356-57, 742 P.2d at 366 (A general rule of statutory construction is that the specific statute will be favored over a general statute of the same subject matter, but both may be given effect if 19 Id. at 22-24, ¶¶38-42. 20 Id. at 24, ¶43. 33 possible because repeal by implication is disfavored.), Reefshare, Ltd., 70 Hawai‛i at 97, 762 P.2d at 172 (“The general rule is that repeals by implication are not favored and that if effect can reasonably be given to two statutes, it is proper to presume that the earlier statute is to remain in force and the later statute did not repeal it.”) and In the Interest of CM, 141 Hawai‛i at 353, 409 P.3d at 757 (“Laws in pari materia, or upon the same subject matter, shall be construed with reference to each other. What is clear in one statute may be called upon in aid to explain what is doubtful in another.”). 14. KCC § 8-13.2(a) also provides a nonconforming use “may continue to the extent that the use existed on September 1, 1972”. (emphasis added). However, if that “nonconforming use ceases for any reason for a continuous period of twelve (12) calendar months or for one (1) season if the use is seasonal, then the use shall not be resumed” (Discontinuance Requirement”). Id. at § 8-13.2(b) (emphasis added). Therefore, continuation of that use is discretionary,21 but once that nonconforming use ceases for twelve (12) 21 “The term ‘may’ is generally construed to render optional, permissive, or discretionary the provision in which it is embodied”. State v. Kahawai, 103 Hawai‛i 464, 465, 83 P.3d 725, 728 (2004) (emphasis added). 34 consecutive calendar months or one (1) season if this use is seasonal, it is mandatory that this nonconforming use shall not be resumed. 22 Id. 15. Petitioner admitted not having any rentals from April 2018 until June 2019. Transcript at 19. Therefore, the Homestay Operation ceased for a continuous period of at least twelve (12) calendar months prohibiting that nonconforming use from resuming. KCC § 8-13.2(b).23 16. Haw. Rev. Stat. § 46-4(a) and KCC § 8-13.2 do not prevent the enforcement of KCC § 8-18.1(b) with respect to the Homestay Operation at the Subject Property because they both apply to all types of nonconforming uses, but KCC § 8-18.1(b) specifically governs homestays prohibited outside of Visitor Destination Areas. Alternatively, the Homestay Operation was discontinued for at 22 “As used in statutes, contracts, or the like, this word [(i.e. shall)] is generally imperative or mandatory.” Leslie v. Board of Appeals of County of Hawaii, 109 Hawai‛i 384, 394, 126 P.3d 1071, 1081 (2006) quoting Black’s Law Dictionary 1375 (6th ed. 1990) (emphasis added). 23 Enforcement of this Discontinuance Requirement appears to have been suspended during the relevant period of time pursuant to the Proclamation of April 15, 2018 by the Governor of the State of Hawai‛i, and all Supplementary Proclamations issued thereafter as a result thereof, related to the disaster occurrence of heavy rains and flooding beginning April 14, 2018 that caused extensive damage to private and public property impacting the County of Kauai (“April 2018 Flooding”), and Emergency Proclamation of April 14, 2018 by the Mayor for the County of Kauai, and all Supplementary Emergency Proclamations issued thereafter as a result thereof, related to the April 2018 Flooding, However, this argument is waived because it was not raised in Petitioner’s Reply To Respondent Planning Department Of The County Of Kauai’s Closing Arguments And Proposed Findings Of Fact And Conclusions Of Law dated February 7, 2020. See generally State v. Moses, 102 Hawai‛i 449, 456, 77 P.3d 940, 947 (2003) (“[I]f a party does not raise an argument at trial, that argument will be deemed to have been waived on appeal; this rule applies in both criminal and civil cases.”). 35 least twelve (12) consecutive months and therefore, cannot be resumed under KCC § 13.2(b).24 C. Proper Notice Given By The Notice of Violation. 17. Petitioner next argues the Notice of Violation is defective because it does not set forth the specific facts to support a violation of KCC § 8-18.1(b). See generally Petitioner’s Proposed R&R at 7-8, ¶¶16-25. Therefore, the Notice of Violation infringes upon Petitioner’s procedural and substantive due process rights. Id. 18. The Planning Department responds that procedural due process only requires that Petitioner is provided with “notice and an opportunity to be heard.” Planning Department’s Proposed R&R at 25, ¶49 citing Korean Buddhist Dae Won Sa Temple of Hawaii v. Sullivan, 87 Hawai‛i 217, 243, 953 P.2d 1315, 1341 (1998). This Contested Case and the Hearing has provided Petitioner with that notice and opportunity to be heard. Id. 19. The provisions of RPPPC Chapter 6 affords Petitioner adequate notice and the opportunity to present the grounds advanced in her Notice of Appeal. Moreover, KCC § 8-17.11(b) provides that the 24 Petitioner’s “grandfather” argument is dispensed with under both alternatives of this 36 Advertisement of the Subject Property as a Homestay and/or Transient Vacation Rental “shall constitute prima facie evidence of the operation of a transient vacation rental [and/or homestay rental] on said property and the burden of proof shall be on the owner . . . to establish that the subject property is not being used as a transient vacation rental [and/or homestay rental] or that it is being used for such purpose legally.” (emphasis added). Therefore, an “actual violation” to commence enforcement action need not be established, but the ultimate burden of proof always remains with the Planning Department. See generally Adams v. CDM Media USA, Inc., 135 Hawai‛i 1, 43, 346 P.3d 70, 111 (2015) (Once a prima facie case has been established, the burden of producing evidence shifts to the other party, but the burden of proof always remains with the first party). 20. Substantive due process guards against “the government’s action [being] clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare. Petitioner’s Proposed R&R at 7, ¶20 citing In re Herrick, 82 Hawai‛i 329, 349, 922 P.2d 942, 962 (1996). Such action may be clearly arbitrary and unreasonable if the government’s action is not supported by credible Conclusion of Law No. 16. 37 evidence of a sufficient quality and probative value to enable a person of reasonable caution to support a conclusion.” Id. citing Dao v. Zoning Board of Appeals, 144 Hawai‛i 28, 44, 434 P.3d 1223, 1239 (Haw.Ct.App. 2019). 21. The Planning Department presented reliable, probative, and substantial evidence that the Homestay Operation was being conducted at the Subject Property. First, the Advertisement is “prima facie” evidence of the Homestay Operation at the Subject Property. Compare Exhibit B at 11-18, with KCC § 8-17.11(b). Second, Petitioner admitted at the Meeting she was conducting the Homestay Operation at the Subject Property since 2005. Transcript at 11 and 30-31. Third, the Homestay Operation at the Subject Property continued after the Meeting. Transcript at 30-31 and Exhibit G at 13-23. 22. Further, enforcement of KCC § 8-18.1(b) has a substantial relation to the public health, safety, morals, or general welfare of the resident of Kaua‛i as articulated in Ordinance No. 864.25 25 See Finding of Fact No. 23, infra. The Findings and Purpose of Ordinance No. 864 applies with equal force to Ordinance No. 1002 and KCC § 8-18.1 because the Council concluded Homestays would be addressed at a later time, but the need to do so was already articulated in Ordinance No. 864. 38 23. The Notice of Violation, RPPPC Chapter 6, and KCC § 8-18.1(b), satisfy Petitioner’s due process rights, both procedurally and substantively. D. The Notice of Violation’s Compliance With KCC § 8-3.5. 24. Petitioner next argues the Notice of Violation does not comport with the requirements of KCC § 8-3.5 because the “Notice of Violation and Order to Pay Fines [is] in one letter.” Petitioner’s Proposed R&R at 9, ¶27. Instead, “under the CZO[,] the Planning Department must first give notice of a finding of a violation and then if the violation is not cured enter an order, which may require the payment of a fine.” Id. at ¶28. 25. The Planning Department explains that the Zoning Compliance Notice is the “notice of violation” contemplated by KCC § 8-3.5(b)(1) and the Notice of Violation contains the “order [to pay fines] pursuant to this Section.” See generally Transcript at 43-46, and Compare with KCC § 8-3.5(b)1). See also Hyatt Corp., 69 Hawai‛i at 242-43, 738 P.2d at 1208 (“It is a well established rule of statutory construction that, where an administrative agency is charged with the responsibility of carrying out the mandate of a statute which contains words of broad and indefinite meaning, courts accord persuasive weight to administrative 39 construction and follow the same, unless the construction is palpably erroneous.”) (brackets omitted). 26. The language of the Zoning Compliance Notice comports with the “notice of violation” contemplated by KCC § 8-3.5(b)(1) because it sets forth the Ordinances deemed to have been violated, advises Petitioner she has fourteen (14) days to terminate the unauthorized “vacation rental operation”, and instructs her to notify the Planning Department of that termination within the stated time period. Exhibit C attached to Planning Department’s MSJ. Failure to do so within those fourteen (14) days would result in enforcement action subjecting her to “a fine of up to $10,000.00 and/or up to $10,000.00 per day, should the violation(s) persist.” Id. at 2. 27. The Notice of Violation also comports with KCC § 8-3.5(b)(1) as the “order” to the extent it directs Petitioner to: (a) correct the violation within fourteen (14) days of the date of that “order”; (b) pay a civil fine of $10,000.00 to the Planning Department for that violation within 14 days of the date of the date of that “order”; and (c) pay a civil fine of $10,000.00 per day or each day after the aforesaid fourteen (14) days if the violation is not remedied within that time period. Exhibit D at 2-3. 28. Although the text of KCC § 8-3.5(b) is included in the Notice of Violation, it did not separately advise Petitioner that this “order shall become 40 final thirty (30) calendar days after the date of its delivery” as required by KCC § 8-3.5(b)(2).26 Compare Exhibit D at 1-3, with KCC § 8-3.5(b)(2). 29. Since the Notice of Violation did not notify Petitioner that this order shall become final thirty (30) days after the date of delivery as mandated by KCC § 8-3.5(b)(2), the Planning Department may not impose the civil fine of $10,000.00, nor $10,000.00 per day for each day the Homestay Operation continues at the Subject Property.27 E. Constitutional Grounds Advanced By Petitioner. 30. Petitioner finally argues the continued nonconforming use of the Subject Property as a homestay operation is guaranteed under the “Fifth Amendment of the United States Constitution and Article I, § 5, of the Hawaii Constitution [because] both provide that no person shall be deprived of property without due process of law, nor have property rights taken or damaged without 26 This requirement in KCC § 8-3.5(b)(2) that “[t]he order shall advise the party responsible for the violation that the order shall become final thirty (30) days after the date of its delivery” is MANDATORY. See generally Leslie, 109 Hawai‛i at 394, 126 P.3d at 1081. 27 Petitioner’s related argument that the Notice of Violation imposed an excessive fine for the violation need not be addressed because this Report and Recommendation concludes no civil fines may be imposed upon her since the same did not comply with KCC § 8-3.5(b)(2). See Petitioner’s Proposed R&R at 9, ¶30-33. Additionally, this Report and Recommendation need not decide the issue whether the Director was arbitrary, capricious, and abused his discretion in finding a “continuing violation” of the Homestay Operation at the Subject Property. See Dao, 144 Hawai‛i at 47, 434 P.3d at 1242 (“[F]or a determination that a violation of the [CZO] occurred for a continuous period of time to be upheld, there must be credible evidence of a 41 compensation.” Petitioner’s Proposed R&R at 6, ¶12. In support of this argument, Petitioner cites to the Waikiki Marketplace Case for the proposition that “due process principles protect a property owner from having his or her vested property rights interfered with, and preexisting lawful uses of property are generally considered to be vested rights that zoning ordinances may not abrogate.” 86 Hawai‛i at 353-54, 949 P.2d at 193-94 (emphasis added). 31. “Black’s Law Dictionary defines abrogate as abolish (a law or custom) by formal or authoritative action; to annual or repeal.” MW Builders of Texas, Inc. v. City of Wichita Falls, 2009 WL 2365443 at 7 (N.D. TX 2009) quoting Black’s Law Dictionary (Westlaw 2009) (italics in original, internal quotations omitted, and bold emphasis added). 32. KCC § 8-18.1(b) prohibiting the Homestay Operation at the Subject Property did not abrogate or abolish that nonconforming use. Instead, the Homestay Operation ceased for twelve (12) consecutive months from April 2018 to June 2019 and therefore, KCC § 8-13.2(b) mandated that nonconforming use “shall not be resumed.” Therefore, KCC § 8-13.2(b) did not abrogate or abolish sufficient quality and probative value to enable a person of reasonable caution to support a conclusion that the violation occurred throughout that period of time.”) (emphasis added). 42 the Homestay Operation as argued by Petitioner, this ordinance merely prohibited that operation from starting up again.28 33. “Taking” of Petitioner’s interest in the Subject Property also did not occur because the Homestay Operation ceased due to the April 2018 Flooding, rather than with the passage of Ordinance No. 1002. Compare Transcript at 19-20, with KCC § 8-18.1(b).29 34. Petitioner’s constitutional due process rights were not violated by the enforcement of KCC § 8-18.1(b) because that ordinance did not abrogate or abolish the Homestay Operation at the Subject Property, but merely prohibited it from resuming pursuant to KCC § 8-13.2(b). There was also no “taking” for the same reason. Finally, no constitutional violations occurred with the passage of Ordinance No. 1002 because the Homestay Operation was not a prior lawful use since Petitioner did not have a use permit pursuant to KCC § 8-3.2 and/or permit under Ordinance No. 987.30 28 See footnote 23, infra. Further, the Homestay Operation at the Subject Property was not a lawful use prior to passage of Ordinance No. 1002 because Petitioner did not obtain a permit for that use pursuant to Ordinance No. 987. See Waikiki Marketplace Inv. Co., 86 Hawai‛i at 354, 949 P.2d at 194 (“Since [Haw. Rev. Stat. § 46-4] refers expressly to uses of a building or premises at the time a zoning ordinance takes effect, the protection afforded a property owner under [that statute], relates, on its face, to lawful uses of a building or premises under existing zoning ordinances.”) (emphasis added). 29 See also footnote 28, infra. 30 Petitioner should have been aware homestays were regulated by KCC § 8-3.2 prior to the adoption of Ordinance No. 864, and the Council would also be acting on this issue at a later 43 35. If any Conclusion of Law herein should be designated as a Finding of Fact, the same shall be deemed to have been identified as such. VI. CONCLUSION. Based upon all the foregoing, it is recommended that the Planning Commission AFFIRM IN PART the decision of the Planning Director to the extent the Notice of Violation ordered Petitioner to Cease and Desist the Homestay Operation at the Subject Property. However, it is further recommended the Planning Commission REVERSE IN PART the decision of the Planning Director to assess civil fines against Petitioner because the Notice of Violation did not comply with the requirement of KCC § 8-3.5(b)(2) to advise her that “order shall become final thirty (30) calendar days after the date of its delivery”. / / / / / / / / / / / / time, because she knew of the passage and effect of Ordinance No. 864. Compare Transcript at 20-21 and Finding of Fact 24, with Finding of Fact 24. 44 It is further recommended that the Planning Commission REMAND THIS CONTESTED CASE TO THE PLANNING DEPARTMENT for issuance of an “Order” fully complying with all the requirements of KCC § 8-3.5(b) as a condition precedent to any Civil Action against Petitioner should she fail to terminate the Homestay Operation at the Subject Property within the time period stated in that “Order.” DATED at Honolulu, Hawaii, March 30, 2020. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i 1 BEFORE THE HEARING OFFICER OF THE PLANNING COMMISSION OF THE COUNTY OF KAUA‛I In the Matter of : Petition to Appeal Decision of the Planning Director’s Decision Related to the Notice of Violation and Order to Pay Fines for the Operation of an Illegal Transient Accommodation Use for Property Situated in Hā‛ena, Kaua‛i, Hawai‛i, identified by Kaua‛i TMK No. (4) 5-8-005:005 containing 26,092 square feet, PATRICIA D. McCONNELL, Petitioner, vs. PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I, Respondent. ______________________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CC-2017-4 TMK: (4) 5-8-005:005 CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was duly served upon the following parties listed below, in the manner described thereto, at their last-known addresses, on March 30, 2020. 2 U.S. Mail Hand Delivery Email GREGORY W. KUGLE, ESQ. gwk@hawaiilawyer.com JOANNA C. ZEIGLER, ESQ. JCZ@hawaiilawyer.com Damon Key Leong Kupchak Hastert 1003 Bishop Street, Suite 1600 Honolulu, HI 96813 Attorneys for Petitioner PATRICIA D. McCONNELL JOHN S. MACKEY, ESQ. jmackey@goodsill.com CHRISTOPHER P. ST. SURE, ESQ. cstsure@goodsill.com Goodsill Anderson Quinn & Stifel First Hawaiian Center, Suite 1600 999 Bishop Street Honolulu, HI 96813 Attorney for Ka‛āina S. Hull, Director, PLANNING DEPARTMENT OF THE COUNTY OF KAUA‛I NICHOLAS COURSON, ESQ. First Deputy County Attorney County of Kaua‛i 4444 Rice Street, Suite 220 Līhu‘e, Kaua‛i, HI 96766 Email: ncourson@kauai.gov Attorney for Planning Commission of the County of Kaua‛i X X X X X X 3 U.S. Mail Hand Delivery Email ELLEN CHING Administrator Office of Boards and Commissions County of Kaua‛i 4444 Rice Street, Suite 150 Līhu‘e, Kaua‛i, HI 96766 Email: eching@kauai.gov asegreti@kauai.gov X DATED at Honolulu, Hawaii, March 30, 2020. __/s/ Harlan Y. Kimura______________ HARLAN Y. KIMURA Hearing Officer for the Planning Commission of the County of Kaua‛i