Haw. Code R. § 6-20-18
The executive director, within thirty days after receiving the notice of hearing, shall file a memorandum advising the board or hearing officer of the executive director's position and responding to the points raised in the petition. The executive director shall recommend whether the board should grant or deny the petition, and state the legal and factual reasons for the recommendation. Other parties recognized by the board, within thirty days after receipt of the notice of hearing, may also file and serve upon the board or hearing officer and all parties a memorandum responding to the petition, advising the board of the parties' position and stating concisely and fully the parties' legal position or contentions and reasons, including legal authorities.
Haw. Code R. § 6-20-18