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United StatesDepartment of the Interior <br />National Park Service <br />Kaloko-Honokohau National Historical <br />73-4786 Kanalani Street, #14 <br />Kailua-Kona, Hawaii 96740 <br />In reply refer to: <br />1.A.l (2018-1) <br />January 9, 2017[sic] <br />Aloha Chair DeFranco and members of the Action Committee: <br />The National Park Service continues to believe that the Kona Community Development Plan has a vision for economic growth, environmental protection, and the perpetuation of cultural practices that is aligned with the NPS mission. In the regard, we would like to share two observations on the proposed changes to the language of the Community Development Plan. <br />First, with respect to environmental protections in the Plan, changes in language throughout the document from affrmative requirements, (eg shall) to optional practices (eg may), will decrease the probability that strong environmental protectionsare implemented in teh development of this area. Depending on the specific circumstances a lack of environmental protectiosn could lead to portential threats to resources at Kaloko-Honokohau National Historical Park, as well as resources throughout West Hawai'i. <br />second, as many of you are aware, the National Park Services continues to be concerned about the impacts of groundwater withdrawal in the areas surrounding Kaloko-Honokohau National Historical Park. The current version of the Plan requires concurrency, which we believe prevents deveopers from receiving entitlements until they have sufficient water resources, and also ensures water resources (sources and infrastructure) for the county water system are in line with the County stated intentions to develop new groundwater wells farther away from the park. The NPS will have concerns if the removal of concurrency requirement in this draft document would allow for addtional water resource development in areas that could negatively affect the fragile natural and cultural resources in the park. <br />Sincerely, <br />[signed] <br />Rhonda Loh <br />Acting Superintendent