More than three years ago, the Hawai‘i Supreme Court issued its ruling in a case that many observers thought would halt commercial aquarium fish collection, at least for a time. The high court determined in Umberger v. Dep’t of Land and Natural Res. that any permits that the Department of Land and Natu- ral Resources issued pursuant to Hawai‘i Revised Statutes Section 188-31 could not be valid until the department complied with the Hawai‘i Environmental Policy Act (HEPA), requiring an environmental impact statement or environmental assessment describing the effect of the practice . . .
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