RE: HART Honolulu High Capacity Transit Corridor Project Section 106 Programmatic Agreement, Honolulu Hawaii July 16, 2015 Meeting
The subject properties: Rail route, stations and support facilities on important farmland located in the West Oahu Farrington Highway (WOFH) segment.
Clarification of FTA issue the “Farmland Conversion Impact Rating” (NRCS-CPA-106) brought up during the July 16, 2015 Kanehili Hui TCP Meeting.
Dear Mr. Rogers, Mr. Matley and Mr. Grabauskas:
Kanehili Cultural Hui (KCH) as a PA consulting party has previously brought up its concern about the Section 4(f) issue regarding the NRCS “Farmland Conversion Impact Rating.”
It has been brought up numerous times in PA meetings: the March 2nd Annual HART-FTA Programmatic Agreement meeting and again at the April 16th PA meeting.
The issue is that the “Farmland Conversion Impact Rating” (NRCS-CPA-106) done by rail contractor Parsons Brinkerhoff in 2008 appears to be a fraudulent rating based upon all of the Hawaii State agricultural lands documentation now and at that time.
It appears to be a “management decision” by the rail contractor to have FTA approve rail construction over very valuable farmland using the Section 4(f) NRCS rating form to declare the West Oahu Farrington Highway (WOFH) farmland as agriculturally substandard.
A formal letter on this was sent on April 21, 2015 to Mr. Ted Matley and Mr. Leslie Rogers, FTA Region 9, with copies also sent to all of the PA consulting parties.
That letter and this letter specifically show documentation that an independently done evaluation came to a very different conclusion, which we have attached again to this letter.
While this was stated by FTA in the PA meetings to not be a Section 106 issue, Mr. Matley did state he would “look into it.”
When it was brought up again Mr. Matley stated “he receives a lot of emails so send it again.” This letter is to ask again for a formal reply from FTA about this issue.
Again, the issue is that HART Rail contractor Parsons Brinkerhoff graded the West Oahu Ewa Plain rail right of way lands, in US Natural Resource Conservation Service Farmland Impact Conversion Rating Form (NRCS-CPA-106), as being SUB PAR and LOW AG VALUE, while five agricultural experts rated the same lands using NRCS-CPA-106 as nearly twice as high and exceeding the Important Ag Land standard.
All of this farmland will be completely covered over in asphalt and concrete
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The Natural Resources Conservation Service “Farmland Conversion Impact Rating” (NRCS-CPA-106) the Farmland Protection Policy Act (FPPA) subtitle I of Title XV, Section 1539-1549. The FPPA is intended to minimize the impact Federal programs have on the unnecessary and irreversible conversion of farmland to nonagricultural uses.
Projects are subject to FPPA requirements if they may irreversibly convert farmland (directly or indirectly) to nonagricultural use and are completed by a Federal agency or with assistance from a Federal agency.
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All of this farmland will be completely covered over in asphalt and concrete
Kanehili Cultural Hui can agree that an at grade rail line would have had much less farmland impact as such corridors, like a two lane county road, are fairly narrow and necessary for transportation purposes.
However, the elevated bi-directional HART railway shows a much wider ground footprint and shadow that significantly increases the amount of prime agricultural land permanently removed from farming. In addition three rail stations are being created on farmland with power substations and large parking lots- all on prime farmland.
It is very important to remember that in 2008 this land was shown as prime agricultural land under active farming, as it still is today. The farm plots are all identifiable fields, by field number that go back to an Ewa plantation map from 1939. In some cases the plots still have signs with field numbers that correspond to the 1939 map.
So, KCH’s point is that the Parsons Brinkerhoff evaluation is false and we believe fraudulent based upon all of the evidence. And that while this may be defined as a Section 4 (f) issue, it has direct, indirect and cumulative effects on the Traditional Cultural Property agricultural farmland that has been farmed in the same place for hundreds of years.
All of this farmland will be completely covered over in asphalt and concrete
Government Maps Show Former Ewa Plantation As Important Agricultural Lands
The State of Hawaii for many decades in the Oahu General Plan identified Ewa Plantation and the proposed Ho’opili development as Agricultural Land classified as “AG-1.”
Historically those lands have been called the “Golden Triangle” because of the ideal conditions of rich soil, abundant water and sunshine.
The State of Hawaii ALISH map shows the HART rail route area as PRIME AG (Agricultural Lands of Importance to the State of Hawaii – ALISH) The State of Hawaii Land Study Bureau (LSB) map shows the HART rail route as top rated soils A & B.
The State’s two agricultural land rating systems. Above ALISH, Below LSB
Kanehili Cultural Hui as a non-profit 501-c-3 works to represent the cultural heritage of the Ewa Plain, known in ancient times as Kanehili and Kaupe’a. These lands where the HART rail project is going in are bordered by Kalo’i Gulch and Honouliuli Gulch. Kalo’i means Kalo (Taro) fields and patches. Honouliuli means dark blue-green and verdant. The names say what Hawaiians did there and how they viewed the landscape.
KCH believes there is a direct relationship between Traditional Cultural Property farmland and how the direct, indirect and cumulative impacts should be determined.
Wide Spread Local Public Opposition To Destruction Of Important Ag Lands
The Office of Hawaiian Affairs has repeatedly testified against the loss of important agricultural lands in the 1500 acre Hoopili project.
The Hoopili project is totally oriented around the HART rail and to take advantage of HART-City Transit Oriented Development. The farmlands are already being advertised by major realtors to be sold off for shopping malls and developments, etc using the magnet of HART rail, stations and “TOD incentives.”
The public connects the dots that HART rail is a land development agenda
Honolulu Star-Advertiser Poll, March 29, 2015 showed overwhelming massive public support for preserving Important Agricultural Lands with 93%, 1,099 votes, to preserve prime, A-B farmland from development.
Testimony in city and state hearings typically runs about 4-to-1 against approving the Ho’opili rail TOD development. Only very major gifts and donations to politicians have gotten these preliminary plans approved.
Currently the Hoopili farmland conversion is before the Hawaii Supreme Court. There is also a new appeal filed with the Hawaii State Land Use Commission.
In addition there could be other lawsuits filed because the Honolulu City Ethics Commission has stated that rail and the Hoopili votes by the Honolulu City Council should be disqualified because of ethics violations.
These farmlands were used for approximately 1000 years as native Hawaiian agricultural lands where Oahu’s largest pre-contact native Hawaiian community thrived on the rich volcanic soils with many natural springs that formed the Konohiki managed ahupua’a food ecosystem.
So again Kanehili Cultural Hui is asking for a formal response from FTA on how a Section 4(f) determination was made showing the farmlands as sub-par and low value in order to approve an elevated concrete heavy railway, elevated concrete stations, parking lots and related power stations, etc. on one of the best documented and most highly rated contiguous plots of important agricultural lands in the entire State of Hawaii.
John Bond
Kanehili Cultural Hui
KCH would like to emphasize that its Traditional Cultural Place (TCP) issues are all directly related to the cultural and historic use of the Honouliuli Ewa Plain farmland for 1000 years for native Hawaiian food crops, the largest and most successful sugar plantation in the entire Hawaiian Islands and today a location that grows approximately 30% of Oahu’s farm fresh table vegetables.
This major Ewa Plain cultural and historic farmland meets all of the criteria for Important Agricultural Land (IAL) as well as highly rated under the State of Hawaii ALISH and LSB agricultural lands rating systems.
All of this farmland will be completely covered over in asphalt and concrete
In 2007, the last year records were kept, Ho`opili land produced more than 40% of Oahu’s fresh broccoli, beans, romaine lettuce, and zucchini, and more than 70% of Oahu’s fresh corn, cantaloupe, pumpkin, and honeydew, along with smaller percentages of a number of other crops. (DOA Statistics 2007)
All of this farmland will be completely covered over in asphalt and concrete
All of this farmland will be completely covered over in asphalt and concrete
Ho’opili’s 1,497 acres constitutes a huge chunk of ag land on O’ahu- 32% of Oahu’s active farm acreage. Hawaii Soil expert Jonathan Deenik has testified, “Close to 90% of the Ho’opili area is composed of high activity clays, which are characterized by very high nutrient retention capacity, and high fertility.
Link to Ewa Farmland TCP documents
Ewa Farmland 
Five very qualified experts rated the Hoopili lands as exceeding the requirements of the “Farmland Conversion Impact Rating” (NRCS-CPA-106)
Rail contractor Parsons Brinkerhoff, who apparently never consulted any agriculture experts or looked at State of Hawaii agricultural lands maps rated this farm land as BELOW the Section 4f impact rating required to provide for farmland preservation. The score arrived at, and thereafter used officially by the City and Parsons Brinkerhoff to justify not evaluating alternative routes, does not correspond to the realities of common observation. The official score for the Rail project is 120. The threshold triggering required alternative evaluation is 160. Five independent third parties scored the impact rating at an average of 226. See their qualifications below.
Qualifications of Third Parties Who
Have Scored the Impact Rating:
University. Many of his 280 publications are on corn genetics and breeding. He founded and directs Hawaii’s Foundation Seed, where many of the 2,500 entries represent his expeditions, collections and breeding. He was recently honored with the National Association of Plant Breeders (NAPB) Lifetime Achievement Award for his exceptional accomplishments over fifty years in research, teaching and collaborations with others. He is an expert witness for Intervenor, The Friends of Makakilo, in the Land Use Commission hearings on the petition of DR Horton.
Glenn A. Martinez is the President of the Hawaii Farmers’ Union. He owns Olomana Gardens – a certified organic farm in Waimanalo. He is also on the Board of Directors of Hawaii Aquaculture and Aquaponics.
Professor Hector Valezuela is a full professor and Vegetable Crops Extension Specialist, with twenty years of experience, now working in the Program on Small Farms, Organic Farming, and Sustainable Agriculture, in the College of Tropical Agriculture and Human Resources at UH Manoa. He has a graduate degree from the University of Florida (Vegetable Crops), and a Ph.D. from Washington State University in Horticulture, IPM, and Agronomy. He conducts statewide educational programs to support commercial vegetable growers.
Professor C.N. Lee is a full professor and an Extension Specialist in the College of Tropical Agriculture at UH Manoa. He received his Ph.D. from the University of Wisconsin – Madison. He has lectured on agriculture all over the world, primarily in Asia and Africa. He has worked with farmers throughout the state, primarily dairy producers, but also vegetable growers and new farmers. Dr. Lee began trips to the site in 1995, then as Executive Director of the Agribusiness Development Corporation (ADC), State of Hawaii. He continues to provide technical assistance to Aloun Farm on location when called upon.
Jimmy F. “Jeno” Enocencio is a third generation farmer and rancher on the Island of Hawai’i. He brings students to his Kalalau Ranch and Victory Garden in Hilo from schools of the island to teach them agriculture, animal science, and aquaculture, and about the ahupua’a system of living, and plantation innovations to farming. For ten years, he has been the Big Island representative on the Native Hawaiian Historic Preservation Council of the Office of Hawaiian Affairs. That Council meets monthly in Honolulu.
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This is the Prime Agricultural Farmland that is going to be covered over in concrete and asphalt. This has been a Traditional Cultural (agricultural) Property (TCP) for 1000 years. Vast acreage of grade A-B volcanic soil from Waianae volcano make this area the “Golden Triangle.” This is a completely “Turn Key” agricultural property with existing roads, running water and power. This type of four crop cycle farmland is NOT cheaply and easily replaceable somewhere else.
All of this farmland will be completely covered over in asphalt and concrete
All of this farmland will be completely covered over in asphalt and concrete
