1)  The Hearing Officer ("HO") is biased!  She hid the fact that she was a longtime member of Imiola Astronomy Center, a part of UH-Hilo - the Applicant (App) to build the TMT.  After being called out - she claimed that she didn't know the connection.
2) The HO's 300 plus page document is full of half-truths and skirts legal logic.  She emasculated cogent oppositional arguments.
3) The CDUA (application) of 2010 should have been amended to update it - including use of a 2011 revision of DLNR rules, or that there was a "new" 3rd party beneficiary (3rdPB).
4) She obliterated corporate law by allowing TMT Int'l Obs to be substituted (w/o any supporting documents) for TMT Obs Corp (TIO) the "designated" 3rdPB of the CDUA. 
5) The 2017 Auditor's Report - that proves mis-management is not considered.
6) TIO is presently in violation of the De-Commissioning Subplan.
7) The App has the burden of proof and didn't prove its case.
8) The Maui case is not the TMT case.
And it goes on and on.