Bill 57- Ko‘olau Poko Sustainable Communities Plan

The O‘ahu Group submitted the following written and oral testimony regarding the Ko‘olau Poko Sustainable Communities Plan before the Council’s Transportation and Planning Committee on August 1, 2017. There were several proposed amendments to the bill that we addressed in our comments:

 

The Committee considered several of our comments and aligned with our position- they did not extend the Community Growth Boundary into the DeReis property in Kahalu‘u, they approved transferring ownership of the Stairway to Heaven from the Honolulu Board of Water Supply to the City and County, and although they approved the expansion of the Hawaiian Memorial Park, they included an amendment to ensure the protection of any “rare, threatened, or endangered species” that may potentially be affected by the proposal. Hawaiian Memorial Park has also hired a entomologist to complete a biological survey of the expansion area to locate the habitat of the endangered Hawaiian Blackline Damselfly and assess the impacts of the development in the project’s EIS. We will stay updated with this process to ensure Hawaiian Memorial Park is held accountable to the commitments they made before the community and Council. Bill 57 passed third reading on August 9th, 2017.

Haleiwa Plantation Village- Bill 55 and Bill 56 (2017)

The O‘ahu Group submitted the following testimony in opposition to the proposed Haleiwa Plantation Village in Bill 55 (2017) and Bill 56 (2017). The Zoning and Housing Committee unanimously deferred both bills at the August 3rd, 2017 Special Committee Meeting in Haleiwa. More information about the Bills and the result of the hearing can be found in the Civil Beat article below. Many thanks to North Shore residents Jen Homcy, Blake McElheny, and Kathleen Elliot for their guidance on this issue to the O‘ahu Group:


Aloha Chair Pine, Vice Chair Anderson, and members of the Zoning and Housing Committee,

On behalf of the Sierra Club O‘ahu Group’s 8,000 members and supporters, we oppose Bill 55 (2017) and Bill 56 (2017), which would rezone land in Haleiwa from agricultural to urban/residential for the proposed Haleiwa Plantation Village (HPV) project. We respectfully request that the Zoning and Housing Committee oppose Bill 55 and Bill 56 in light of the following inadequacies and issues:

Development on agricultural lands- The O‘ahu Group of the Sierra Club is generally opposed to up zoning agricultural lands for development because we believe it is an urgent priority to increase food production on O‘ahu. In this we take our cue from researchers and faculty at the University of Hawai‘i at Mānoa, who are increasingly sounding the alarm about the need to rapidly increase the amount of food grown in Hawai‘i. This is to meet the mounting threat of global food shortages and food price inflation as a result of climate change, as well as the threat to the just-in-time food distribution network from the anticipated increase in frequency and destructiveness of severe weather events. The HPV proposal would convert valuable agricultural land to urban uses in rural Haleiwa. The applicant argues that the land is unfit for farming, however, the land is currently being farmed! It is planted with fruit trees and adjacent areas around the Haleiwa Marsh currently farm taro, lotus, and other crops. Furthermore, a portion of the land has been proposed for designation as Important Agricultural Land by the City & County of Honolulu, while most of the Northern Property has soils that are rated Prime, meaning that they are regarded as high-quality soils.

Affordable housing uncertainty- The HPV project purports to add 29 lots with up to 35 homes within R5 zoning. New rules administered by the Honolulu Department of Planning and Permitting would potentially permit additional Accessory Dwelling Units, which would increase the number of allowable homes in the development area. While the Sierra Club understands the need for new affordable housing for local families on the North Shore and indeed supports construction of housing within the urban core of the legacy towns of La‘ie, Kahuku, and Haleiwa, we believe that such development should occur in denser configurations that are pedestrian and transit oriented, not as traditional single family homes. The law requires that 30 percent of the lots be made affordable to people earning not more than 140 percent of area median income, but because these will be individually sold as vacant lots, there is no guarantee that the homes that are ultimately built will in fact be occupied by local families in need of “workforce” housing.

Lack of community support- The Honolulu Planning Commission recommended that the City Council reject the HPV proposal in March 2017. Additionally, the North Shore Neighborhood Board passed a Resolution in October 2016 opposing the State Land Use Boundary change from Agriculture to Urban. The Sierra Club is bound by its bylaws to support community concerns on environmental issues wherever possible. We believe the Council should show deference to the concerns of the community as expressed by the Neighborhood Board.

We appreciate that a special Zoning and Housing Committee meeting is being held in Haleiwa, so that community members directly affected by the proposed housing project will be given an opportunity to raise their concerns. We ask that you consider the issues above and vote against Bill 55 (2017) and Bill 56 (2017).


Council Committee Defers Proposal To Develop Haleiwa Farmland

Two bills would have rezoned seven acres of agricultural land to urban or residential and allowed for up to 35 homes
By Natanya Friedheim / August 2, 2017

The Honolulu City Council zoning committee deferred two bills Tuesday night that would have rezoned seven acres of agricultural land in Haleiwa to either residential or urban.

Scott Wallace, who bought the land in 2010, said he wanted to divide it into 29 lots and sell each for an estimated price of $175,000 to $200,000. Bills 55 and 56 would have allowed him to do so.

The land sits along Achiu Lane, just off Kamehameha Highway makai of the North Shore Marketplace.

The nearly three-hour meeting at a gym in Haleiwa lasted till nearly 10 p.m.

Scott Wallace purchased the Haleiwa property in 2010 with the intention of developing it residentially. Courtesy of Malia Evans.

After the public testimony, the room grew tense as Councilman Ernie Martin, who represents the North Shore but is not a member of the committee, stated his opposition to the proposed development despite considering Wallace a “good friend.”

“There’s overwhelming consensus against the project,” Martin said. “I’ve been very reluctant to support any type of development in my district … I subscribe to that philosophy that growth should be more directed towards urban Honolulu as well as the second city.”

The majority of attendees who testified opposed the bills. Many argued they would set a dangerous precedent for rezoning agricultural land for housing.

There also were concerns about Haleiwa’s already heavy traffic.

In March, the Honolulu Planning Commission also opposed the proposal and recommended the council reject it.

“I see that this project could provide some solid opportunities for affordable housing,” said Councilman Ikaika Anderson. However, he added, “it’s obvious that the community still has a lot of concern here.”

Anderson was one of thee committee members at the meeting. He and Councilman Brandon Elefante supported committee Chair Kymberly Pine’s call to defer the bill.

Councilman Ron Menor, who attended but is not a committee member, said the decision demonstrated the council’s consideration of public interests.

“I hope that tonight’s recommendation from the chair and this committee’s support for her recommendation demonstrates that as council members we do listen to the public, we do listen to the community,” he said.

Support for Two New Affordable Housing Measures

The O‘ahu Group supports two new Honolulu City Council bills that will help create a better affordable housing strategy for Honolulu.

Bill 58 (2017) relating to affordable housing requirements would increase the production of affordable housing, to encourage dispersal of affordable housing throughout the City and County of Honolulu, and to maintain the units as affordable for a long period of time. Please see our testimony below:


Bill 59 (2017) relating to affordable housing incentives would to provide financial support for the creation and maintenance of affordable dwelling units that are provided through compliance with bills and ordinances relating to an Affordable Housing Requirement, Planned Development-Transit  permits, and Interim Planned Development-Transit permits, and qualifying rental housing projects pursuant to Hawaii Revised Statutes. Please see our testimony below:

 

Star Advertiser: Erosion could imperil sewage outfall

Honolulu Star Advertiser | By Gordon Y.K. Pang | June 1, 2017


Photo: CINDY ELLEN RUSSELL / CRUSSELL@STARADVERTISER.COM
Shoreline erosion could eventually expose and compromise the Sand Island Wastewater Treatment Plant outfall pipeline and cause devastating health, environmental and economic consequences, according to city officials.

The decades-long erosion of the shoreline just outside the city’s Sand Island Wastewater Treatment Plant leaves the facility’s outfall pipeline in a precarious situation where “failure or damage to the outfall could have catastrophic health, environmental and economic consequences,” according to an environmental report made public by the city last month.

To shield the land-side portion of the outfall pipe from damage, the city Department of Environmental Services wants to rebuild a sloping, bermlike barrier “to armor the shoreline” and to shield the land-side portion of the outfall pipe from damage.

City officials insisted that the planned structure, technically called a “revetment,” not be called a wall. It uses materials and a construction form similar to the Kapahulu Groin and the berms that protect the inner portion of Magic Island and the Ko Olina lagoons.

Ross Tanimoto, deputy city environmental services director, told the Honolulu Star-Advertiser on Wednesday that a sea wall is designed to protect the shoreline while the revetment being proposed is aimed at shielding the outfall pipe. “A revetment is usually angled, too, so the waves come up and expend their energy along the inclined area,” he said.

The city needs federal, state and city permits to build the structure, and the draft Environmental Assessment, completed by SSFM International and filed with the state Office of Environmental Quality Control on May 23, concludes the project would not cause any adverse environmental impacts.

Photos and maps included with the report show how the shoreline fronting the plant has eroded dramatically over the past few decades. The study estimates the shoreline receded about 150 feet from 1955 to 2015. While the erosion continues, it appears to be doing so at a slower pace than in the past.

The goal of the $3.7 million project is to protect the 84-inch ocean outfall pipe, the only one of its kind on Oahu.

It extends about 1,450 feet on land before it bends and stretches about 12,500 feet offshore — buried in a trench excavated into the fossil reef. It’s there, about 2.3 miles offshore, that sewage that has been given primary treatment enters the ocean about 200 feet below the surface.

But it’s a 400-foot shoreline section of the pipe that is the source of concern because it is currently only 2.2 feet below grade. “Therefore, the land portion of the outfall is relatively unarmored and vulnerable to damage should the section become exposed to wave activity,” the report said.

Tanimoto said the project should be done sooner rather than later. “To wait to see what sea level is doing to it wouldn’t be prudent,” he said.

During storms, “lots of stuff moves around — rocks, some boulders — that could ram into the pipe if that’s exposed,” Tanimoto said. If left exposed and unprotected, the outfall pipe could even rupture. “Say for example, a boat got run aground along the shoreline, it could ram into the pipe if the pipe was exposed … to prevent that occurrence, we put the revetment over it,” he said.

The outfall is deemed “critical infrastructure” because it discharges 66 million gallons of sewage daily. “The progressive shoreline erosion is a serious potential threat that could eventually expose and compromise the outfall pipeline,” the report said.

The city is proposing to put up a 450-foot revetment, defined in the report as “a sloping, un-cemented structure constructed of wave-resistant materials.” Specifically, there would be a sloping structure consisting of boulder-size rocks sitting atop a mound of smaller rocks and rubble, the report said. It would stretch from near where the outfall extends into the ocean northward along the shoreline to a dredged channel, the report said.

An original revetment was constructed when the outfall was first built in 1975. A “stop gate,” which houses a type of shutoff valve for the pipeline in case of an emergency, was installed more than 150 feet inshore of the shoreline but is now located near the waterline due to erosion, the report said.

“There is concern that continued shoreline erosion, particularly in conjunction with a potential tropical storm, may begin to remove cover material and expose the trench and possibly damage the outfall,” the report said.

The gate itself also is being relocated 20 feet inland, the report said.

The city is hoping to obtain all necessary approvals by June 2019 and have the project completed within six months of that. Estimated cost of construction is $3.7 million.

Jodi Malinoski, Oahu coordinator for the Sierra Club of Hawaii, said her organization is reviewing the draft Environment Assessment and has yet to come up with a formal position.

“We do recognize that this project may be inevitable,” Malinoski said. “But we would encourage our state to do more to prevent climate change and sea level rise.”

If nothing else, she said, the need for the project reinforces the importance for the city to have a fully staffed Office of Climate Change, Sustainability and Resiliency. After initially cutting seven staff positions for the newly formed office, the Honolulu City Council Budget Committee on May 16 restored the positions. Oahu voters in 2016 approved an amendment to the Honolulu Charter establishing the new agency.

Bill 67 related to Bike Facilities signed into law

Success! Bill 67 (2016), CD1, relating to bicycling facilities, was passed unanimously by the council and signed into law by Mayor Caldwell on Friday, May 26, 2017. The Sierra Club O‘ahu Group and Hawai‘i Bicycling League supported this measure, which requires certain new or converted office buildings located near rail stops in the Transit Oriented Development zone to include showers to accommodate bicycle commuters.

“This law will make it possible for commuters to bike to their neighborhood rail stop on their way to the office, with shower facilities available at work in new buildings,” said Mayor Caldwell.

The idea of providing bicycling facilities for office employees was originally introduced by O‘ahu’s Group’s Gary Gill when he was a Councilmember (nearly 25 years ago) and was re-invented by Councilmember Carol Fukunaga in Bill 67.

“We are thrilled that Honolulu is making great progress in transforming our city into a more bike and pedestrian friendly place to live,” wrote Gary Gill.

Sierra Club’s policy intern and avid biker Will Giese giving testimony in support of Bill 67 related to bike facilities

 

 

 

Punalu‘u Shoreline Revetment Project

Aloha, below are the comments that the O‘ahu Group submitted to  in response to the “Punalu‘u Beach Homes Shoreline Protection Project Draft Environmental Assessment Anticipated Finding of No Significant Impact” posted in the April 8, 2017 Environmental Notice:
TO: Department of Permitting and Planning

CC: Punalu‘u Beach Lots Business Management Association,

Group 70 International, Inc. (dba G70)

 

RE: Punalu‘u Beach Homes Shoreline Protection Project Draft Environmental Assessment Anticipated Finding of No Significant Impact

 

To whom it may concern:

The Sierra Club of Hawai‘i’s O‘ahu Group offers the following comments under HRS §343 on the DEA (AFONSI) to construct a 634-foot-long shore protection structure on seven residential beachfront lots along 53-215 to 53-239 Kamehameha Highway in Punalu‘u.

Our review of the draft environmental assessment (DEA) for building a 634-foot-long concrete rubble masonry shore protection structure which will require a Shoreline Setback Variance Permit, a Special Management Area (Major) Permit, a Certified Shoreline Survey, Building Permits, and Grading, Grubbing, Trenching and Stockpiling Permits reveals various inadequacies and points of concern. We would appreciate it if the agency and/or applicant’s consultant could follow up with further analysis and answers to the questions below in a revised draft EA.

Problematic section: In Section 3.2 Soils and Shoreline Erosion Conditions, the DEA asserts that “in the long term, the new shoreline revetment will absorb wave energy, promote sand accretion, and slow the impacts from rapid erosion along the shoreline fronting the seven properties. The placement of this structure is not anticipated to cause adverse effects to the shoreline of adjoining properties.”

Discussion and Questions regarding Section 3.2: Claiming that a rubble mound revetment will absorb wave energy is unrealistic. It is easy to see reflected waves heading seaward from any similar revetment on local shorelines. This reflected wave interacts with incident waves to create increased scour in the nearshore zone, making sand deposition less likely. The claim that this structure will “absorb wave energy” is misleading.

Given the likelihood of reflected waves and increased sand scour, how can the DEA claim that the revetment will promote sand accretion? This is the sort of unsupported argument that has been used for years to justify armoring the O‘ahu shoreline and as a result we have an epidemic of beach narrowing, beach loss, reduced public access to the shoreline, and reduced open space – all of which are are intended to be increased and enhanced under the stated objectives of the City and County setback policy.

Additionally, there is no mention of the problem of flanking. At both ends of 634 feet of new revetment the structure will be almost vertical (12:1) and there will be accelerated erosion on unprotected lands. How will this be handled? How will the increased erosion elsewhere on this shoreline as a result of this armoring be mitigated?

Problematic section: In Section 3.5 Biological Resources, the DEA notes that “due to the site’s location, some threatened or endangered marine species may be present on the site or in the vicinity of the site”

Discussion and Questions regarding Section 3.5: As sea level rise threatens sandy shoals in the Northwestern Hawaiian Islands, the continued building of armored shoreline in the main Hawaiian islands greatly limits the habitat options for threatened or endangered marine species, such as native monk seal and green sea turtles. In the National Oceanic Atmospheric Association’s (NOAA) Pacific Islands Region Main Hawaiian Islands Monk Seal Management Plan, NOAA asserts that “coastal development may negatively affect the coastal habitats Hawaiian monk seals depend on by decreasing and degrading available shoreline habitat needed for resting, pupping, rearing, nursing, and molting. Less shoreline habitat, along with increased human presence in coastal areas, also increases the chances of human-seal interactions and seal disturbances.”

Has the applicant’s consultant and/or agency consulted with NOAA in consideration of monk seal and turtle habitat needs along the Punalu‘u coastline before submitting the DEA? If we know that threatened or endangered marine species may be present at the affected site, how does the DEA justify that there will be an AFONSI in regards to our impact to marine species, whose habitat may be negatively affected by coastal development?

Problematic Section: In Section 3.10 Traffic and Roadways, the DEA notes that “the construction of the shoreline revetment will not alter public roadways. While the project is not expected to have significant traffic impacts, the following mitigation measures are recommended for optimal traffic conditions during construction: 1) construction activities and construction material or waste should be located and stored away from vehicular traffic. Sight lines for drivers on the roadway should be carefully maintained. 2) Trucks delivering construction material and disposing of construction waste should be scheduled on weekdays during times of non-peak commuter periods (9:00 AM to 3:00 PM).

Discussion and Questions regarding Section 3.5: The two-lane Kamehameha Highway that will be used to bring in the necessary machinery, equipment, and supplies for the revetment project is highly utilized and frequently congested. This highway is the only access point to the Ko‘olauloa District and Punalu‘u area. Will the applicant adhere to the proposed mitigation measures to locate and store construction activities and materials away from the vehicular traffic, maintain sight lines for drivers, and deliver and dispose of construction waste during the suggested times of 9:00 AM to 3:00 PM?

Problematic Section: In Section 3.13.2 Cultural Resources, the two Hawaiian traditional practitioners that were interviewed by Keala Pono in the Ethnographic Survey noted observed changes in the Punalu‘u area. They noted that “the beach has eroded; and fish, limu, and other resources are scarcer than in previous years.” In addition, they shared concerns about this shoreline revetment project: “One concern is that the project could affect the shoreline in Punalu‘u, possibly further eroding the surrounding lands. Another voiced concern was that the walls near the Kamehameha Schools beach lots were believed to have had a negative impact on the rest of the shoreline.”

Discussion and Questions regarding Section 3.13.2: How is the agency and/or applicant’s consultant responding to the concerns raised by both of the community residents interviewed that a) this project will erode the surrounding lands and b) shoreline hardening structures near the Kamehameha Schools beach lots have had a negative impact on the rest of the shoreline? Is there evidence that the shoreline adjacent to the Kamehameha Schools beach lots have not been negatively impacted by shoreline hardening structures to justify the DEA (AFONSI) for this new revetment project?

Problematic Section: In Section 3.15 Potential Cumulative and Secondary Impacts, the DEA notes that “Erosion has occurred for decades along the Punalu‘u Shoreline. Due to the shoreline protection of properties to the south, the beach area has retreated. Placement of a sloping rock revetment at the subject properties will help to stabilize this shoreline section and will not affect shoreline processes at other sections of the Punalu‘u shoreline. Additionally, the action to stabilize these properties will reduce future erosion threats to Kamehameha Highway at this location.”

Discussion regarding Section 3.15: It is widely understood that coastal hardening deflects wave energy and causes erosion elsewhere. Shoreline hardening structures are notorious for their documented contribution to the loss of beaches throughout Hawai‘i. For example, an estimated 25% of the length of beaches on O‘ahu has been permanently lost due to seawalls and shoreline hardening, along with many miles of shoreline on Maui.

The DEA asserts that shoreline protection to the south has resulted in retreating beach. How then can the DEA rationalize that this project will “help stabilize the shoreline section” and promote sand accretion, when there is evidence that protection measures to the south have resulted in the beach area retreating?

Problematic section: In Section 5.0 Plans and Policies, the DEA discusses the project’s consistency with applicable land use policies set forth in the State Environmental Policy, Hawai‘i State Plan, State Land Use Law, State Coastal Zone Management Program, City and County of Honolulu General Plan, City and County of Honolulu Land Use Ordinance, City and County of Honolulu Ko‘olauloa Sustainable Communities Plan, and Special Management Area.

Discussion and Questions regarding Section 5.0: The DEA completely omits a critical policy that applies to the Shoreline Setback Variance Permit that needs to be granted to complete the proposed project. We remind the Department of Planning and Permitting of the Revised Ordinances of Honolulu, Chapter 23 Sec. 23-1.2 regarding the purpose of Shoreline Setbacks:

(a)  It is a primary policy of the city to protect and preserve the natural shoreline, especially sandy beaches; to protect and preserve public pedestrian access laterally along the shoreline and to the sea; and to protect and preserve open space along the shoreline. It is also a secondary policy of the city to reduce hazards to property from coastal floods.

(b)  To carry out these policies and to comply with the mandate stated in HRS Chapter 205A, it is the specific purpose of this chapter to establish standards and to authorize the department of land utilization to adopt rules pursuant to HRS Chapter 91, which generally prohibit within the shoreline area any construction or activity which may adversely affect beach processes, public access along the shoreline, or shoreline open space.

(c)  Finally, it is the purpose of this chapter to name the director of land utilization as the council’s designee to exercise some of the powers and functions granted, and duties imposed, pursuant to HRS Chapter 205A, Part III.

The Department of Planning and Permitting has disregarded their responsibility under this law for several decades as they approve the armoring of shoreline all over O‘ahu. It is unreasonable to assume that this new revetment is going to meet the objectives of the law when the same type of construction has resulted in the exact opposite in multiple locations around the island.

Why was the Revised Ordinances of Honolulu, Chapter 23 Sec. 23-1.2 regarding Shoreline Setbacks not included in the discussion of the DEA? How does the Department of Planning and Permitting address our concerns that they are not fulfilling the primary policy of the city regarding shoreline setbacks?

Please address the above concerns in any subsequent EA.  It is in the public’s interest to protect our shorelines and access to our beaches.  The existing land use and zoning rules are designed to guarantee the public’s trust interests and must be observed.

Mahalo,

Jodi Malinoski

Sierra Club O‘ahu Group Coordinator

O‘ahu General Plan

Aloha, below are the comments the O‘ahu Group submitted in regards to the 2nd draft of the O‘ahu General Plan. The O‘ahu General Plan sets forth the long-range objectives and policies for the general welfare and, together with the regional development plans, provides a direction and framework to guide the programs and activities of the City and County of Honolulu. More information about the O‘ahu General Plan can be found at the Honolulu Department of Planning and Permitting website here.

To: HHF Planners
Attn: O‘ahu General Plan

Aloha HHF Planners,

On behalf of our 8,000 members and supporters on O‘ahu, mahalo for considering the comments of the Sierra Club O‘ahu Group regarding the O‘ahu General Plan draft. In general, it should be said that we are pleased with the proposed changes in the General Plan update as many of the Sierra Club O‘ahu Group’s concerns have been given attention. We found the addition of new areas focusing on climate change, sea level rise and renewables to be positive inclusions. Additionally, we welcome the increased focus on mass transit, transit-oriented development, and an Age-Friendly/Complete Streets development approach. Finally, stronger language surrounding the urban growth boundary, preserving the character of certain neighborhoods while still recognizing the need for density, and the inclusion of a substantial amount of language promoting agriculture are appreciated. We hope that the language proposed in these areas is preserved in the final version. However, we do have some concerns.

First, in the Economy section (Objective B, Policy 7) language has been changed from “manage” to “facilitate” with regards to secondary resort areas and the specific destinations of Ko‘olina, Turtle Bay, Hoakalei, Mākaha and La‘ie. The Sierra Club O‘ahu Group is concerned with the stronger encouragement of development in these areas which we believe to be inappropriate. We see this as promoting development outside the primary urban areas and providing a justification for intruding in currently undeveloped areas. This will necessitate further investment of scarce taxpayer resources on infrastructure in rural areas. Given that the city is investing 8 billion dollars on infrastructure in order to concentrate development on the Leeward coast, we believe this encouragement of development in the rural area to be misguided. Moreover, encouraging such increased visitor activity in the Country will place further stresses in areas that have already reached their capacity. For these reasons we strongly recommend that the draft revert to the original language to “manage” these activities.

On a related note, other sections of the General Plan draft have useful language that should be added to the Economy section when evaluating maintenance requirements and proposed construction in resort areas and Waikiki, especially in relation to sea level rise. The Housing and Communities section (Objective C, Policy 6), the Transportation And Utilities section (Objective D, policy 5) and the Public Safety and Community Resilience section (Objective A, Policy 2) contains language addressing the proper evaluation of variables surrounding climate change and development such as: “topography that could be difficult or dangerous, sewer capacity, utility capacity, extreme cost and potential environmental damage.” In these sections, these variables are framed around simply being bad growth that shouldn’t be encouraged or which could potentially incur the City large costs – this framing of perspective should be taken for our tourism economy. This is especially true when talk of establishing beach preservation funds which would use transfer of development rights (TDR) and purchase of development rights (PDR) which could be exorbitantly more costly for the City/State if not guided by language and policy which expects these same considerations from the tourism industry. The addition of this language could help prevent significant financial cost and damage to the environment.

In the Physical Development and Urban Design section, the new addition of Policy 6 on page 50 allows for short-term vacation rentals in TOD areas – the Sierra Club O‘ahu Group does not support this. The O‘ahu Group understands the many values of TOD, one of those being its power to control sprawling and uncontrolled growth by placing our residents closer to where they live, work and play; taking away more of the available area in TOD neighborhoods and giving it to non-residents does not facilitate this. This type of activity should be strictly prohibited outside of our resort areas and Waikiki, as it is counterproductive.

Language relating to deregulation exists in both the Housing Communities section (Objective A, Policy 2) as well as in The Economy section (Objective C, Policy 4). The O‘ahu Group recognizes that some regulation is indeed burdensome, especially for the farmers mentioned in Objective C, Policy 4. We strongly support an increase in local agricultural production, however we would welcome additional language to clarify that this increased activity would not fly in the face of environmental impact, pesticide, water quality, and invasive species regulations.

Finally, the Energy section (Objective A, Policy 6) promotes an impressive suite of renewable energy resources and the Sierra Club O‘ahu Group supports the emphasis on producing renewable energy for O‘ahu. However, it should be mentioned that with regards to geothermal and its listed prospects in both Wai‘anae and Windward, the national Sierra Club supports geothermal, but not hydraulic stimulation or “fracking” which the newest forms of geothermal now use. If language can be added that steers O‘ahu away from this process which can pollute groundwater and increase seismic activity, then it should be done.

Again, the Sierra Club O‘ahu Group thanks you for your time and interest in our comments. If you have additional questions please do not hesitate to contact our staff and board at your convenience.
Mahalo,

Elliot Van Wie

Executive Committee Member, Conservation Chair & Smart Growth Chair, Sierra Club O‘ahu Group