Site scout · Confidential · Prepared for the principal

The Last Legal Lodge

You asked for a beautiful boutique surf lodge in Hawaii on a $4M acquisition budget. I scouted all four counties. The finding that should drive your wire: the business you want to run is now illegal at almost every address in the state. Buy where it is legal first, and the waves — conveniently — come with it.

Scouted June 10, 2026 · All listings live as of that date, with links · Every coordinate pastes into Google Maps · Parcel, zoning & hazard calls pulled from the State of Hawaii GIS, not from brochures

The verdict, up front

Buy 78-111-A Holua Road, Keauhou, Kailua-Kona — a fee-simple, five-bedroom-plus-guest-studio compound that sleeps 14, with a pool, on 0.6 acres, a two-minute walk above the surf cove of Heʻeia Bay, holding the one asset money can no longer buy in Hawaii: a registered short-term-rental use that survives the sale. Ask is $4.45M after two cuts from $4.995M; roughly a year of cumulative market time says the seller meets a disciplined buyer. Offer $3.9M, walk at $4.2M. Full case below.

Backup: take a backup-offer position on 75-5976 Aliʻi Dr — oceanfront, resort-zoned V-1.25 by right, asking $1.895M and under contract today. If it falls out of escrow you get a legal oceanfront lodge seed at half budget. Details.

01 · The market nobody pricesLegality is the scarce asset

Every buyer scouting "surf lodge" inventory looks at waves, then at houses. Hawaii has spent the last four years making both irrelevant. Since 2022, three of the four counties have outlawed or are actively phasing out short-stay lodging outside a handful of resort-zoned pockets — and in 2024 the state legislature (Act 17) explicitly blessed counties phasing out even grandfathered rentals. A lodge is a nightly-stay business. Where nightly stays are banned, you don't own a lodge; you own a liability with a sea view.

CountyThe ruleWhat it means for a new lodge
Oʻahu Ord. 22-7 (2022): short-term rentals only in resort zones + a few mapped apartment pockets; unpermitted B&Bs can't rent under 90 days; fines to $10,000/day. New nonconforming certificates: none since 1989. Dead outside Waikīkī/Ko Olina/Turtle Bay. The North Shore is residential.
Kauaʻi County code 8-17: vacation rentals prohibited outside Visitor Destination Areas; the nonconforming list closed March 30, 2009; outside the VDA even a room can't rent under 180 days. Dead in Hanalei/Haena (banned there since 2008). Princeville condos only.
Maui Ord. 5909 ("Bill 9", signed 12/15/2025): ~6,200 grandfathered "Minatoya" units lose rental rights — West Maui 1/1/2029, everywhere else 1/1/2031. Litigation pending; no injunction. An island actively un-zoning the business. Skip entirely.
Hawaiʻi (Big Island) Ord. 25-50 (2025): registration regime (deadline July 1, 2026), fees $250–500 — but no zoning rollback. Rentals remain legal by right in resort/hotel (V) zones, and registered nonconforming uses continue — including through a sale, if the buyer re-registers within 90 days. The last county where a $4M buyer can still legally open a lodge.

So the search isn't "Hawaii." The search is: parcels where nightly lodging is legal, within walking or trivial driving distance of a real wave, under $4M, for sale right now. That filter eliminates almost everything — and what survives is concentrated on one road: Aliʻi Drive, Kailua-Kona, on the Big Island, where the county's V-1.25 resort-hotel zoning runs in pockets along eight kilometers of lava-rock coastline with five named surf breaks on it.

02 · Ground truth from aboveThe Aliʻi Drive corridor

Below is the whole thesis in one satellite frame: town and pier at the north, a string of breaks down the coast, and the two legal plays marked in amber. Red marks the cautionary tale — an oceanfront $4.2M listing two parcels outside the legal zone.

candidate (legal lodging) surf break / landmark hazard or rejected

Annotated satellite image of the Kailua-Kona coastline from Kailua Pier to Keauhou Bay, with surf breaks and candidate properties marked
Kailua-Kona to Keauhou, June 2026 imagery. Paste any label's coordinates from the appendix table into Google Maps and you will land on what I claim is there. Imagery: Esri World Imagery (Maxar/Earthstar Geographics).

Why this coast beats the postcard coasts for a lodge (not a surf trip):

03 · The verdict78-111-A Holua Rd — "Kinohi at Heʻeia"

Close satellite view of 78-111-A Holua Rd above He'eia Bay, Keauhou
The parcel sits on the low rise a short block from Heʻeia Bay's surf cove, with Keauhou Bay's boat ramp and canoe club five minutes' walk south — and the green of Kona Country Club behind. Paste 19.56373, -155.96435 into Google Maps to verify.
Listing$4,450,000 · MLS 729517 · fee simple · Locations Hawaii / Coldwell Banker Island Properties – Kona
Price historyListed May 30, 2025 at $4,995,000 → cut to $4,450,000 (Mar 2026), relisted May 4, 2026. ≈1 year cumulative market time.
The physical plant5 bd / 4 ba main house + separate studio guest house · 2,976 sq ft interior · sleeps 14 · pool, gazebo, mature fruit trees · 0.6-acre lot (county GIS: 0.5972 ac)
The licenseTransferable short-term-vacation-rental registration (operating, multi-year track record per listing). This is the moat — see "the catch."
Parcel (county records)TMK 3-7-8-012-045 · tax record · assessed $2,543,700 (land $1,651,400 + improvements $892,300) · taxes $28,961/yr
Hazard screen (state GIS)Lava Zone 4 (Hualālai — moderate) · FEMA flood Zone X (outside special flood hazard area) · inside the mapped tsunami evacuation zone · inside the SMA (matters only for expansion permits)

Why this is the one

It is the only property I found in the state that is simultaneously: (a) actively for sale, (b) already configured as a lodge (six rentable keys across two structures, 14 guests, pool, half-acre of grounds — not a beach shack you'd spend two years permitting), (c) legally rentable nightly from day one, and (d) within walking distance of surfable water, in this case the bodyboard/surf cove at Heʻeia Bay (~150 m on foot) with Kahaluʻu's beginner reef 1.9 km and Banyans/Lyman's a few minutes' drive up Aliʻi Drive. Keauhou is the quiet, green end of the corridor — country-club calm instead of condo-wall Kona — which is exactly the register a "small, beautiful" lodge brand wants.

On price: you are buying $2.5M of assessed real estate plus the license and the configuration. The seller has already conceded 11% and carried the property for a year. In a Kona market with inventory growing and regulation tightening everywhere else, the pool of buyers who can fully exploit this specific asset (nightly rental at scale) is thin — but for that pool, of which you are one, it is nearly irreplaceable. That spread is your negotiation. Open at $3.9M with proof of funds and a short close; be prepared to win at $4.0–4.1M; walk above $4.2M and fall back to the backup below.

The catch we found (and why it's also the moat)

The brokerage marketing says "resort zone." The county's own GIS says the parcel is zoned RS-10 — residential. The rental right is real but it doesn't come from zoning: it's a registered nonconforming STVR use under Ordinance 2018-114 (Bill 108), which required proof the rental operated before April 1, 2019. Under the current rules (Planning Dept. Rule 23 and Ord. 25-50), that registration expires 90 days after a change of ownership unless the new owner re-registers.

So: make the purchase contract contingent on (1) the county confirming the registration is current and in good standing, and (2) acceptance of your re-registration filing — your attorney will draft this in a day. Do not waive it; without the registration this is a $4M residential house. The flip side: no new certificates have been issued since 2019. Every year that passes, the supply of legally rentable compounds like this shrinks toward the resort zones. You are buying a license that regulation keeps making scarcer — the same dynamic that has an Oʻahu NUC home with $500K/yr gross asking $5.995M (comp).

What the money does (scout's sketch — verify with an operator)

Run as a six-key surf lodge (5 suites + studio) at a blended $300–375/night and 60–70% occupancy — conservative against Keauhou's resort-corridor comparables and the property's own "proven multi-year track record" (listing's words) — gross lands in the $400–550K/yr range before management; whole-compound buyouts (sleeps 14) for surf camps, retreats and Ironman week price $1,200–1,800/night. On a $4.0M basis that is a plausible 6–9% gross yield with the real upside being the brand: the only walkable-to-water legal lodge product in Keauhou. Demand a trailing-12 P&L in diligence; the listing advertises one.

04 · The backup75-5976 Aliʻi Dr — oceanfront, legal by right, half the budget

Satellite view of 75-5976 Alii Dr on the Kailua-Kona shoreline
The house sits where Aliʻi Drive hugs the lava bench — part of the structure literally overhangs the water. 19.62384, -155.98577.

$1,895,000 · 4 bd / 4 ba · 2,518 sq ft · oceanfront · MLS 726123 (Hawaii Life). This one is zoned V-1.25 resort-hotel — I verified the zoning polygon at the parcel in the county GIS, and cross-checked the parcel ID the old-fashioned way: TMK 3-7-5-019-016's assessed value ($2,007,500) times the county's 11.11/$1,000 rate equals $22,303 — the listing discloses $22,302 in taxes. Same parcel. Here the rental right comes from zoning itself: no nonconforming-certificate fragility at all. It runs today as a successful vacation rental.

It is Active Under Contract as of June 10, 2026 — someone else read this market the same way. Hawaii deals fall out of escrow constantly. Have your broker lodge a backup offer at list this week. If it comes back: you acquire a legal, oceanfront, income-producing seed asset at $1.9M and hold ~$2M of the budget for a second V-zoned building or a to-the-studs conversion — a two-building lodge instead of one. Eyes open: it's a 1976 build on 0.07 acres with one parking stall, FEMA Zone AE, inside the tsunami evacuation zone, and salt-air maintenance is forever. It's the opportunistic play, not the safe one — which is why it's the backup.

05 · Eyes openThe beautiful traps I'm telling you not to buy

59-75 Hoalua St, Sunset Beach, Oʻahu — $3,950,000

Satellite view of Sunset Beach, Oahu showing the listing and the Ke Nui Road erosion strip
The postcard, from above. The amber pin is the listing (21.67566, -158.03902); the red pin marks the Ke Nui Rd strip where oceanfront homes collapsed into the surf in 2022 and 2024. Note how little sand separates the house row from the lineup.

Sand-in-front-of-the-lanai oceanfront on the most famous wave on earth, at $3.95M (MLS 202605480, listed April 13, 2026). This is the listing your friends will forward you. Three reasons I won't let you wire on it:

5-7094 Kuhio Hwy, Hanalei, Kauaʻi — $3,999,000

Satellite view of Hanalei Bay, Kauai with the Waikoko listing, surf breaks, and floodplain marked
Hanalei Bay. The listing (amber, 22.22065, -159.54520) sits at Waikoko on the bay's west arm; Waikokos reef breaks out front, Pine Trees and the pier bowl across the bay. Red: the Hanalei River floodplain.

Beachfront with a pool near Waikoko, walking distance to a real reef wave (MLS 724741). And: zoned R-4 (county GIS), outside the Visitor Destination Area, where vacation rentals have been prohibited since 2008 and the grandfather list closed in 2009. Kauaʻi is the county that banned rentals in this exact neighborhood by name. Then geography: one two-lane road and a string of one-lane bridges connect it to the rest of the island; in April 2018 this coast took ~50 inches of rain in 24 hours (a U.S. record, measured at Waipā, 4 km away), severed the road for months, and the parcel itself screens FEMA VE + tsunami evacuation zone. Paradise, structurally incompatible with hospitality revenue.

78-6600 Aliʻi Dr, Kailua-Kona — $4,200,000 (the near-miss that proves the method)

Gated oceanfront main-plus-guest-house compound at Kahaluʻu (MLS 721460, 336 days on market) — 350 m from the beginner reef, looks perfect. County GIS: RS-7.5 residential, no STVR certificate advertised, FEMA VE at the shoreline, $42,770/yr in taxes. On this corridor the legal boundary moves parcel by parcel: this one is a few hundred meters — and one zoning polygon — away from being investable. That's the entire discipline of this hunt in one listing: the map decides, not the photos.

Maui — skipped on principle

Active inventory in budget exists (Haiku estates, ocean-view acreage). But the county just enacted the largest short-term-rental rollback in U.S. history (Ord. 5909), the permit pathway for new single-family rentals is effectively frozen, and the litigation outcome is unknowable. You don't build a hospitality brand on land whose right to host is an open court case.

06 · The surf story, with receiptsWill guests actually score?

A lodge's surf claim has to survive a guest with a Surfline account. Here is the honest version for the Keauhou–Kona corridor:

07 · Risk registerWhat could kill this deal — said plainly

RiskRealityMitigation
STVR registration lapse Registration expires 90 days post-closing if not re-registered; without it the lodge is illegal. Escrow contingency on county confirmation + accepted re-registration (Ord. 25-50 / Rule 23). Non-negotiable.
Bill 147 (pending) County is drafting operational standards/enforcement for rentals; deferred by the Windward Planning Commission June 5, 2026 — still moving. It adds standards (parking, quiet hours, fines), not zoning rollback; a registered, well-run lodge is the constituency it protects. Track it; budget for compliance.
Tsunami The parcel is inside the mapped evacuation zone (as is essentially all of coastal Kona). It is not in the extreme-event-only zone, and FEMA flood is Zone X. Evacuation plan is already a county requirement for rentals; insure accordingly; guest-safety signage. The compound sits back on a rise rather than on the bay frontage that took the brunt of past events (1960, 2011) — but it is in the zone, and the brief says so.
Lava / vog Lava Zone 4 (Hualālai flank — last erupted 1801). Moderate; insurable through standard carriers, unlike Zones 1–2 in Puna. Vog drifts in on light-wind days. Priced into all Kona real estate; disclose in brand honestly ("volcano coast").
Single-asset operations Six keys, one site: occupancy risk is concentrated, and resort-corridor competition (Outrigger Kona, condo rentals) is real. The defensible niche is the surf-lodge program (guides, coaching, boards, dawn-patrol culture) — not generic rooms. Hire the GM before closing.
The ask is over budget $4.45M list vs $4M budget. The price path ($4.995M → $4.45M, ~1 yr exposure, $2.54M assessed) is a seller in motion. If they hold above $4.2M: walk, take the 75-5976 backup, and re-engage in 60 days. Discipline is leverage.

08 · The askWhat I need from you this week

Every fact above is checkable from your desk in minutes — the links are live and the coordinates are real. When something I've written doesn't survive your checking, call me. That's what a scout is for.

— Your site scout · Kailua-Kona corridor survey completed June 10, 2026

AppendixVerify me: coordinates & sources

Paste any coordinate into Google Maps (satellite layer). Listing prices/statuses are as scouted on June 10, 2026 — judge against that date; Hawaii inventory moves.

WhatCoordinatesClaim to check
78-111-A Holua Rd (THE PICK)19.56373, -155.96435 Compound w/ pool on green rise, one block from a small cove (Heʻeia Bay), golf course mauka
Heʻeia Bay19.56330, -155.96480Rocky surf cove SW of the pick
Keauhou Bay19.56120, -155.96300Boat ramp & canoe hale, 5-min walk south
75-5976 Aliʻi Dr (BACKUP)19.62384, -155.98577 House on the makai (ocean) side where road meets the lava bench
Banyans19.60620, -155.97560Reef A-frame off the small bay at Kona Bali Kai
Lyman's19.60140, -155.97480Left point at Kahului Bay's south corner
Kahaluʻu Beach Park19.58030, -155.96820Beginner reef & snorkel bay
78-6600 Aliʻi Dr (REJECTED)19.58553, -155.97023Oceanfront compound, residential zone
59-75 Hoalua St (REJECTED)21.67566, -158.03902Beachfront house row at Sunset Beach
Ke Nui Rd erosion strip21.67000, -158.04780Narrow dune strip; 2022/2024 collapse area
5-7094 Kuhio Hwy (REJECTED)22.22065, -159.54520Waikoko beachfront, west arm of Hanalei Bay

Primary sources