The Hawaiʻi Intermediate Court of Appeals ordered the Maui Planning Commission Thursday to reconsider whether developers of the Honuaʻula master-planned community in South Maui—formerly known as Wailea 670—need to prepare a supplemental environmental impact statement, although the court upheld the commission on other points raised by groups challenging the project.

In a summary disposition order issued Aug. 6, a three-judge panel found the commission applied the wrong legal standard when it approved Phase II of the roughly 670-acre project in 2022. Rather than asking whether Maui County law expressly required a supplemental environmental review, the commission should have determined whether the project had substantively changed in “size, scope, intensity, use, location, or timing” since its original environmental impact statement was approved in 2012, the court said.

Hoʻoponopono O Mākena and the Maui Tomorrow Foundation appealed the commission’s November 2022 approval of Honuaʻula Partners LLC’s preliminary site plan. A 2nd Circuit Court judge upheld that approval in 2024, prompting the appeal.

The appeals court’s order sends the matter back to the planning commission. It must determine whether the project’s changes since 2012 warrant a supplemental environmental review before its Phase II approval can stand.

The judges, however, rejected several other arguments raised by the community groups. They affirmed the commission’s finding that the developer’s drainage plan complied with the project’s conditions of approval, citing expert testimony that the plan provided more capacity than the county required. The court also rejected claims that the commission violated due process by allowing the developer to submit updated drainage plans shortly before a contested case hearing, and found the commission did not improperly delegate its authority to the developer.

Separately, the court ruled that disputes over the project’s required number of workforce housing units and a golf course were moot, after the Maui County Council amended the relevant ordinances in August 2025. The amendment set a minimum requirement of 288 workforce housing units and removed golf course requirements from the project’s conditions.

Maile Luʻuwai, president of Hoʻoponopono O Mākena, said the ruling affirms that significant changes to a development should not bypass environmental review, adding that “Honuaʻula’s cultural, natural and community resources deserve a transparent and lawful determination that a supplemental EIS is required.”

Attorney Bianca Isaki, who represented the community groups along with Lance Collins and Ryan Hurley, said the ruling requires the commission to decide whether the changed project needs updated environmental review before its approval can stand.

Collins said the groups are “gratified that the court recognized the commission got it wrong,” and they are evaluating whether to seek further review from the Hawaiʻi Supreme Court.

Honuaʻula attorney Cal Chipchase said the Honuaʻula project will provide substantial community benefits for South Maui, including at least 288 workforce housing units, a cultural center, first responders’ memorial park, joint police and fire station and offsite improvements, such as the widening of Piʻilani Highway.

“The decision on appeal largely affirms the Maui Planning Commission and validates the hard work of the commission when it considered and unanimously approved the project after months of hearings,” Chipchase said. “We respect the court’s decision that the commission is also required to determine whether a supplemental environmental impact statement should be prepared. We believe that the existing environmental and cultural studies and the reductions in the project’s scope, including several hundred fewer market rate units and the removal of the golf course, support a determination that further environmental review is not required. We look forward to the hearing before the commission.”

The County of Maui said it does not comment on pending litigation.

Clyde Wadsworth served as presiding judge, and Kimberly Guidry and Daniel Gluck served as associate judges for the appeals court panel.