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.
Elliot Van Wie
Executive Committee Member, Conservation Chair & Smart Growth Chair, Sierra Club O‘ahu Group