Ewa Farmland Conversion Impact Rating
John Bond, Kanehili
Cultural Hui
HART Rail Covers Over 1000 Year Old Ewa Farmland, Top Rated Volcanic Alluvial Soil
This
correspondence to FTA is specifically about the Farmland Conversion Impact
Rating that was applied to the Honouliuli Ewa Plain farmland which is now planned
to have three transit stations and Transit Oriented Developments as part of the
FTA funded Honolulu Authority Rapid Transit (HART) system.
The issue is that the Farmland Conversion Impact Rating done by the contracted project engineering company was erroneous, very possibly intentionally so, which resulted in no subsequent important prime farmland mitigation.
This led to the
HART rail project constructing an elevated fixed guide way through this very
important farmland. FTA may argue that the guide way itself has a “de minimus” (no
or minimal effect) impact on this traditional agricultural farmland, however
the next planned rail construction phases are three stations and planned TOD’s:
East Kapolei, UH-West Oahu and Hoopili.
The issue is that the Farmland Conversion Impact Rating done by the contracted project engineering company was erroneous, very possibly intentionally so, which resulted in no subsequent important prime farmland mitigation.
Kanehili
Cultural Hui (KCH), HART PA consulting party had identified a very important
Section 4f discrepancy with the “Farmland Conversion Impact Rating”
(NRCS-CPA-106) a fundamental requirement and farmland rating document for all
Federally funded transit corridor type projects which uses prime or unique agricultural
land.
As a consulting party Kanehili Cultural Hui (KCH) specifically brought this issue up at the Annual HART Programmatic Agreement meeting on Monday, March 2, 2015 at the HART Ali`i Place, Suite 150 conference room to discuss Implementation of the PA over 2014 and planned activities for 2015.
During that meeting KCH president John Bond asked Ted Matley of FTA if the West Oahu Farrington Highway (WOFH) Farmland Conversion Impact Rating decision could be revisited again because of very credible evidence that the Farmland Conversion Impact Rating was very erroneous and quite possibly intentionally so.
As a consulting party Kanehili Cultural Hui (KCH) specifically brought this issue up at the Annual HART Programmatic Agreement meeting on Monday, March 2, 2015 at the HART Ali`i Place, Suite 150 conference room to discuss Implementation of the PA over 2014 and planned activities for 2015.
During that meeting KCH president John Bond asked Ted Matley of FTA if the West Oahu Farrington Highway (WOFH) Farmland Conversion Impact Rating decision could be revisited again because of very credible evidence that the Farmland Conversion Impact Rating was very erroneous and quite possibly intentionally so.
Area of Potential Effect - APE for West Oahu Farrington Highway (WOFH)
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What is a 4(f) "use"?
In discussing 4(f), "use" may mean either a direct use or constructive use. A direct use occurs when land is permanently incorporated into a transportation facility or when there is a temporary occupancy of land that is adverse to a 4(f) resource. Constructive use occurs when a project's proximity impacts are so severe that the protected activities, features, or attributes that qualify a resource for protection under Section 4(f) are "substantially impaired".
TCPs are “places of religious and cultural significance” (NHPA Section 101 and NHPA regulations, Section 106). NHPA guidance (Parker and King 1990:1) defines a TCP as a property “… that is eligible for inclusion in the National Register because of its association with cultural practices or beliefs of a living community that (a) are rooted in that community’s history, and (b) are important in maintaining the continuing cultural identity of the community.” TCPs derive their importance from the practices or beliefs of a community because they are integral to the community’s history and identity. The people who are best able to identify these places and their importance are the members of the community that understand their value.
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The KCH analysis
is twofold: 1. The original very low farmland rating document done by rail
contractor Parsons Brinkerhoff does not reflect the obvious reality of the Ewa
Plain farmland based on observation and known published criteria of what
constitutes prime or valuable Oahu farmland in Hawaii. Our shared drive links
provide the documents, maps and photos to support this analysis.
FTA support for important farmland
destruction is a social and environmental injustice and not Smart Growth.
Instead of rail transit the Ewa Plain community is getting massive new urban
sprawl, vast environmental damage, a huge increase in highway traffic and an
important food security safeguard completely eliminated.
It should
not ever be forgotten that during the early Honolulu rail design and
engineering process there was an enormous amount of political pressure (and
still is) placed on government agencies and employees to “get on board” and not
be the odd nail that needs to be hammered down by powerful land development
interests that want rail construction moved forward as fast as possible, no
matter what had to be done to make that happen.
At the time key project reviews were being made the State Historic Preservation Division was in a very weak and understaffed situation and considered the worst SHPO in the United States- on verge of being shut down and taken over by the NPS.
KCH asks: How
could the Hawaiian Island’s largest and most profitable sugar plantation – Ewa
Plantation, thrive and prosper for over 100 years on the Ewa Plain if it didn’t
have an ideal combination of abundant sunshine, pure spring water and rich
Waianae volcano soil (rated A and B quality) which caused it to be an
agricultural powerhouse? At the time key project reviews were being made the State Historic Preservation Division was in a very weak and understaffed situation and considered the worst SHPO in the United States- on verge of being shut down and taken over by the NPS.
It is no surprise to see that the
very flawed Farmland Conversion Impact Rating form was run through with few if
any questions asked
Please review the link to the Historic Ewa Villages which show that the Ewa plantation was a major historic and culturally important community in the Hawaiian Islands known worldwide. It’s fame and fortune was all a result of the very valuable agricultural lands that sustained it and providing thousands of jobs.
Not fairly and honestly addressing these major obvious discrepancies while there is still time, however short, will forever be a dark stain on the HART project and the involvement of the Federal Transit Administration in sponsoring the destruction of a very valuable and a culturally very important agricultural TCP.
The Honolulu City Council INTENDED
that these Ewa TCP Farmlands be identified and mapped- even when in an already
designated Urban Boundary
The Honolulu City Council passed a
resolution in 2011 to advocate establishment of an Agricultural Liaison:
RESOLUTION
URGING THE CITY ADMINISTRATION TO CREATE AN AGRICULTURAL LIAISON POSITION – CCR
11-70.
The Honolulu City Council also passed
a resolution in 2012 to expedite the identifying and mapping of important
agricultural lands:
RESOLUTION
URGING THE CITY’S AGRICULTURAL LIAISON TO EXPEDITE THE IDENTIFYING AND MAPPING
OF IMPORTANT AGRICULTURAL LANDS AND ENSURE THAT THE CITY WORKS TO PRESERVE THE
AVAILABILITY OF AGRICULTURAL LANDS FOR FARMING – CCR 12-23.
It is very
important to note that the resolution contained a Further Resolved clause: “that the process of identification and
mapping of important agricultural lands also consider agriculturally productive
lands within urban growth boundaries
that are classified as prime agricultural lands, provided adequate water supply
is available;
This
highlighted statement is very important because it says that even IF the agriculturally
productive
lands are in a designated urban growth boundary, as the three HART Rail
stations and TOD’s will be, the lands that meet the prime agricultural lands
criteria must be mapped- and they HAVE NOT BEEN.
This is because there has been direction from the Honolulu Mayor’s office to City Department of Planning and Permitting to prevent this Important Agricultural Lands (IAL) identification. Mayor Caldwell supports this valuable farmland destruction.
This is because there has been direction from the Honolulu Mayor’s office to City Department of Planning and Permitting to prevent this Important Agricultural Lands (IAL) identification. Mayor Caldwell supports this valuable farmland destruction.
The
Federal Transit Administration most likely knows by now that there is a great
deal of unhappiness and dissatisfaction about the HART Rail project- how over
budget it is, etc. However, FTA management may not be aware that one of the
single greatest issues is the HART Rail project creating a massive urban sprawl
development project that will pave over and destroy West Oahu’s largest
contiguous farmland – the remaining Ewa Plantation lands.
The
Honouliuli Ewa Plain agricultural farm lands MUST be seen in their full
ecological, cultural environmental, and historic cumulative context and not as
a single abstraction. In Hawaii this is the “Konohiki” viewpoint and also the
“ahupua’a” sustainability concept because islands have limited space and
resources.
A Continental US farmland rating system for a massive heavy rail transportation project in the very limited confines of traditional island farmlands tied in with vast sprawling home developments and shopping centers under the guise of Transit Oriented Development that FTA is supporting isn’t simply just unfair or inadequate, it is tragic and possibly even criminal in intent.
A Continental US farmland rating system for a massive heavy rail transportation project in the very limited confines of traditional island farmlands tied in with vast sprawling home developments and shopping centers under the guise of Transit Oriented Development that FTA is supporting isn’t simply just unfair or inadequate, it is tragic and possibly even criminal in intent.
The Ho’opili farmland constitutes 31% of all of the farmland on O’ahu currently producing food for the local market.
From the March 2012 Agricultural Liaison
Important Agricultural Lands Progress Report:
FTA transit funds are going into this very
valuable farmland destruction and many West Oahu residents believe this will be
creating a future environmental catastrophe.
Not only will
there be a loss of key valuable traditional open space farmland, a loss of an
important food security safeguard, a massively overcrowded highway system that
even HART rail admittedly cannot adequately address, but also the loss of
native endangered and migratory bird habitats, water runoff pollution of the impervious
surface rail station - TOD development projects which will direct their storm
water runoff into West Loch Pearl Harbor and the Ewa shoreline ecosystem,
poisoning Ewa fisheries, reef system and shoreline habitat of sea birds,
mammals and edible limu. 
ALL of the FTA sponsored HART Rail impacts are VERY
NEGATIVE, a social and environmental INJUSTICE and not SMART GROWTH.
FTA may not know that a large number
of agricultural experts and community groups believe that this great misuse of
very valuable traditional cultural property is tragically WRONG.
FTA and
HART rail are the major sponsors of this valuable agricultural land and TCP
obliteration which frankly appears to be more about real estate development and
land speculation than the public transit system people were lead to believe
they were getting.
It is also not lost on many local
residents that the FTA HART rail agenda has required the decimation of the very
popular TheBus system which has been the only mass transit system to be
recognized twice by the American Public Transportation Association as America's
Best Transit System for 1994–1995 and 2000–2001, beating other transit systems.
From the March 2012 Agricultural Liaison
Important Agricultural Lands Progress Report:
Administrative
Testimony, March 5, 2015 – City Council Bill 3 to Remove Ewa farmland’s Ag-1
designation and replace the land with a HART and FTA funded Transit Oriented
Development.
Testimony
of Kamana’opono Crabbe, Ph.D
Ka
Pouhana, Chief Executive Officer, Office of Hawaiian Affairs (OHA).
The irrevocable loss of this prime
agricultural land from agricultural use raises significant
concerns. Although OHA readily
acknowledges that the Land Use Commission previously
reclassified the project area from the
State Agricultural District to the Urban District in 2012, and that City and
County plans have deemed Kapolei the secondary urban center 2, the continued
loss of agricultural land threatens the future of agriculture in Hawai’i.
Policies supporting increased agriculture must be implemented, rather than policies that result in paving over prime agricultural land.
Policies supporting increased agriculture must be implemented, rather than policies that result in paving over prime agricultural land.
(As
the Department of Permitting and Planning DPP acknowledges “the vast majority
of the project site consists of ‘A’ and ‘B’ rated soils” according to the
University of Hawai’i Land Study Bureau Detailed Land Classification for the
Island of O’ahu; and (“[t]he majority of the project site is classified as
‘Prime’ according to the Agricultural Lands of Importance to the State of
Hawai’i system. DPP, Findings of Fact, Analysis, Conclusions of Law, and
Recommendation on File No. 2014/Z-5, pages 5-6.
(2)
General Plan for the City and County of Honolulu, I. Population, Obj. C, Pol.
2, IIV. Physical Development and Urban Design, Obj. C; ‘Ewa Development Plan,
1-1, 2-3, 2-8, Table 2.2.1.)
Support for agriculture has a direct
connection to Hawai’i’s ability to grow its own food.
One of the targets of the Aloha+
Challenge, which has been supported by OHA, the mayors of the four counties,
and the legislature, and Governor Abercrombie, is to double local food
production by 2030.~ The benefits of supporting agriculture in Hawai’i are
vast, ranging from the obvious—food security, fresher food, maintenance of a
rural landscape, and potential for reduced environmental impacts—to the less
obvious—improved health for consumers and farm workers, a diversified
employment industry, connection to the ‘aina, and sense of community.
In this testimony, which follows up on
OHA’s December 3, 2014 testimony to the Planning
Commission and OHA’s September 19,
2014 comments to DPP, OHA reiterates its concern
about the applicant’s request to
remove prime agricultural lands, with both high soil and
productivity ratings, from all present
and future agricultural use.
(See
more testimony and government documents in the Shared Drive link in this
letter.)
Federal
law concerning major projects like this multi-billion dollar FTA funded railway
requires that in the identification of historic and cultural sites, a
“reasonable and good faith effort” be made. We don’t see this as having been
the case and certainly Federal Judge Wallace Tashima stated in his ruling in 2014
that he was greatly concerned about the identification of ALL Traditional
Cultural Properties (TCP) along the rail route.
Kanehili Cultural Hui provided
to FTA and HART extensive detailed reports on all of these TCP issues for many
years and not once were they acknowledged or taken seriously until we filed our
HART Programmatic Agreement Stipulation 9 objection letter.
The Honouliuli
Ewa Plain was the site of a very important ancient Hawaiian community with kalo
fields feeding many hundreds of thousands of people over 1000 years. Annual
Makahiki Ceremonies and processions along the ancient trail network through
this traditional agricultural property honored the very important god of
agriculture- Lono.
The main waterway through this Ewa Plain farmland is called Kalo’i Gulch (actually the surface feature of a much larger below surface karst waterway that flows to the ocean). The name says what the area was used for: Kalo farming. These Kalo farms were all connected by a series of ancient trails (Malden in 1825 identified the main network but hundreds of smaller trails existed) and this was all managed under a Konohiki land management system in the ahupua’a of Honouliuli.
What can be done to remedy this
situation?
It could not be more clear what a great and tragic injustice is coming to the Ewa Plain- sponsored by the Federal Transportation Administration and the City’s HART Rail project.
FTA should
immediately review and correct the erroneous Farmland Conversion Impact Rating based upon all of the substantial
evidence Kanehili Cultural Hui has submitted in this letter and linked shared
drive.
In
addition, Mayor Caldwell should immediately direct City DPP to accomplish an
honest Important Agricultural Lands
(IAL) identification of Ewa Traditional Cultural Place agricultural farmlands
as was the intent of City Council resolutions CCR-11-70 and CCR 12-23.
Further,
before City Council Bill 3 is passed that will permanently remove and allow
obliteration of these valuable Ewa farmlands, the Ewa TCP issue now under
review through the HART Programmatic Agreement Stipulation IX should be settled
as well as the pending Hawaii Supreme Court case concerning this same issue. 
Ewa Farm Land Conversion To Commercial Development Unconstitutional
City Bill 3 violates Hawaii Constitution, Creates Highway To Hell Death Trap
West Oahu Eco-Disaster: HART Rail Hitting Karst Water, Sea Caves And Polluting Ewa-Honoululi-Waipahu Wetlands
West Oahu's greatest natural apocalypse is unfolding, with hundreds
of 8 foot in diameter, 200 foot deep drill bores, the ancient karst water, sea caves and
wetlands are being fractured and polluted, then to be followed by
a major new asphalt and concrete city based around
three huge HART Rail Transit Oriented Developments.
The already fragile Ewa Plain ecosystem based on natural clean water will be destroyed.
of 8 foot in diameter, 200 foot deep drill bores, the ancient karst water, sea caves and
wetlands are being fractured and polluted, then to be followed by
a major new asphalt and concrete city based around
three huge HART Rail Transit Oriented Developments.
The already fragile Ewa Plain ecosystem based on natural clean water will be destroyed.
HART Rail Ewa Plain Route Drills Into Major 1000 Year Old Native Hawaiian Burial Grounds
By John Bond, Kanehili Cultural Hui
