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Officer or the Federal Preservation Officer not to submit an adequatelydocumented nomination form to the National Park Service after it has been processed by the State or Federal agency; 2) Disagrees with a decision of the State Historic Preservation Officer not to submit an adequatelydocumented nomination form to the State Review Board; 3) Believes that the State Historic Preservation Officer has not scheduled an adequately-documented nomination form for State Review Board consideration within a reasonable period of time consistent with the State'8 priorities for nominations. The Keeper will respond in writing to the request within 30 days. The decision may: • Deny the appeal; • Recommend that the State Historic Preservation Office submit the nomination form to the State Review Board; • Recommend that the State Historic Preservation Officer submit the nomination form to the State Review Board for consideration at an earlier date than scheduled; • Provide notice that the Keeper will consider for listing a nomination form previously approved or disapproved by the State Review Board or a Federal agency nomination form. Current Historic Preservation Issues The preceding sections have concentrated on existing State and Federal laws on historic preserva*.or However, as pointed out in comments received by the Commission, 40/ there are numerous practical problems in t± implementation and enforcement of these regulations. Native Hawaiians are concerned about protection of ancient religious sites—a concern that was voiced to the Commission not only in the writter comments cited above, but in public testimony before the Commission in January 1982. 41/ At the State level, a comment from Kenneth Chan notes that "the State Historic Preservation Plan has not even been adopted into law, and has in fact been shelved for the past three years. There is no_ comprehensive plan adopted and utilized by the State at this time." 42/ Another problem already mentioned above is the removal of 579 sites from the State Register because they were not properly registered. In addition, staffing and funding difficulties also plague the State's historic preservation program. The problems of protecting historic sites of importance to native Hawaiians are not totally administrative, however. An even greater difficulty may be that criteria for eligibility as they now exist do not always address the religious and cultural significance of land regarded as sacred by native Hawaiians. According to one native Hawaiian: The concerns of Hawaiians...are different from the concerns of archaeologists. We are trained in the Western scientific tradition. We see archaeologic sites primarily as repositories of information. This is in 212