12/10/2019: If elements of major new construction occur in accordance with a new City plan for Ala Moana Park, significant historic resources would be permanently harmed, according to an analysis by Historic Hawai‘i Foundation.
HHF provided the technical review and opposition to permits in testimony to the Department of Planning and Permitting for the City & County of Honolulu for a public hearing on an application for a Special Management Area permit.
The public hearing is scheduled for Wednesday, December 18, 2019 at 10:30 a.m. at McCoy Pavilion in the Park.
HHF had previously raised concerns and recommendations with the project during the environmental review phase, providing extensive and detailed comments in 2016 and 2018.
“While HHF is pleased that the City is making strides to address concerns for the longevity, usability and appearance of the Park, we are extremely concerned that the project description in the SMA application is not based on historic preservation standards, guidelines and best practices,” said Kiersten Faulkner, executive director of Historic Hawai‘i Foundation.
Ala Moana Park was constructed in the 1930s and was listed on the Hawai‘i Register of Historic Places in 1988 as part of the multiple property listing of the “City and County of Honolulu Art Deco Parks and Playgrounds.”
The SMA permit application includes 17 projects to be implemented over the span of 10 years to improve the Park’s grounds and facilities. Of these, two are located outside the historic district boundary and only four were submitted to the State Historic Preservation Division for review and concurrence, according the HHF analysis. The remaining 11 projects would harm historic resources if constructed as currently proposed.
In addition, the four reviewed projects included specific requirements attached by SHPD as a condition for its concurrence; the SMA descriptions do not include those conditions as part of the described scope of work.
Faulkner said that the Park’s historic resources include the spatial arrangement of open space and foliage, as well as the landscaping, open lawns, exceptional trees and other vegetation, as well as constructed elements such as roadways, pavilions, terraces, bridges, the canal and ponds, and the Sports Pavilion.
“The SMA applicant proposes adding major new facilities, including the multi-use area at or near the historic lawn bowling green, the proposed playground, and the proposed dog park, and the proposed relocation of maintenance facilities. The direct, indirect and cumulative effect of the major new construction would obliterate the open space design and spatial relationships,” Faulkner said.
“These open areas, vistas and trees are important elements of the historic park design. They need to be safeguarded and treated with respect,” she said.
In addition to the loss of green space, HHF voiced strong concern about the potential effect on significant historic resources from specific elements in the proposed action, including:
- Keyhole Parking Lot Reconfiguration and Expansion
- Widening Loop Road
- Design and location of proposed new entry at Pi‘ikoi Street
- Modifications to Japanese and Hawai‘i Pond edges
- Sports Pavilion rehabilitation
- McCoy Pavilion Dining Facility
- Multiuse Facility at the Lawn Bowling Area
- Lack of overall landscape plan and tree preservation and replacement schedule
The objectives of the SMA program include protection and restoring natural and manmade historic and prehistoric resources in the coastal zone management area, as well as to further overall State policy to protect and restore of historic resources.
HHF found considerable discrepancies, contradictions and gaps between the SMA Application and the Final EIS scope of work, as well as the inadequate compliance with the required historic review process under 6E-8 and HAR Chapter 13-275-8.
“Our evaluation found that the SMA application has not met the requirements for a complete, cohesive description of the work, and the proposed plan does not meet the intent of the SMA statute to safeguard resources,” said Faulkner. “Therefore, Historic Hawai‘i Foundation recommends that the SMA Permit be denied.”
SAMPLE TESTIMONY OPPOSING THE SMA PERMIT
TO:
Department of Planning and Permitting
City & County of Honolulu
650 S. King Street, 7th Floor
Honolulu, HI 96813
FROM:
(NAME)
(CONTACT INFORMATION)
RE: Special Management Area Use Permit No. 2019/SMA-36
Ala Moana Regional Park and Magic Island Improvements
Honolulu, Island of O‘ahu
TMK: (1) 2-3-037:001, 002, 022, 023, 025
HEARING:
Wednesday, December 18, 2019
10:30 a.m.
McCoy Pavilion, Ala Moana Regional Park, 1201 Ala Moana Blvd, Honolulu, HI 96814
I am writing in opposition to the Application for a Special Management Area (SMA) Use Permit from the Department of Design and Construction (DDC) for the proposed park and facilities improvements at Ala Moana Regional Park (AMRP) and Magic Island as described in the Final Environmental Impact Statement.
The project will inflict adverse effects on numerous historic properties and contributing features of the park, and the application lacks specific measures to avoid or minimize the effects.
The objectives of the SMA program include protection and restoring natural and manmade historic and prehistoric resources in the coastal zone management area, and it is both SMA and overall State policy to support protection of historic resources.
I support elements of the Park plan that focus on increased staffing and maintenance; increased security measures; repair and maintenance of irrigation systems and circulation systems; and appropriate repair and maintenance of historic buildings and features.
However, I am extremely concerned with the more aggressive elements of the plan, especially those that will modify or adversely affect historic resources. Therefore, I recommend that the SMA permit be denied until the issues are adequately resolved.
Thank you for the opportunity to comment.
Ala Moana Park Master Plan and Draft Environmental Impact Statement Proposes Changes to Historic Art Deco Park
8/22/2018: The City and County of Honolulu is in the final planning stages of proposed improvements to the facilities and grounds of Ala Moana Regional Park and Magic Island. Ala Moana Park is listed on the Hawai‘i Register of Historic Places (1988) and contains multiple contributing historic resources.
Ala Moana Park was designed by landscape architects Catherine Jones Richards and Robert Oliver Thompson in 1931. Architect Harry Sims Bent was hired in 1933 to design the architectural features of the Richards and Thompson Plan. The resultant park plan was published in 1936 by Charles Lester McCoy, Chairman of the Honolulu Park Board.
Many of the proposed actions would significantly impact the historic features. The City’s 17-point Proposed Action includes changes to the entries and circulation systems, additional parking, new dog park and children’s playground, repairs to the Bridle Bridge and Roosevelt Portal entry, and modifications to McCoy Pavilion and Banyan Court. Long-term plans that are mentioned but not detailed include new buildings or relocation of some facilities.
HHF supports maintenance, repair and preservation projects, especially for the iconic Roosevelt entry portals and bridle bridge. However, we are concerned about plans to widen the roadway to accommodate more parking stalls, which would impact the row of street trees. The keyhole parking lot by the Sports Pavilion would also be eradicated by new parking stalls.
In the Draft Environmental Impact Statement (DEIS) issued in June, the planners acknowledged some effects to historic features, but ignored others. HHF conducted its own analysis and submitted written comments in opposition to actions that would harm or obliterate character-defining features. These include effects on the canal and lagoons; exceptional trees as well as other significant trees and landscaping; the Park Loop Road, including the “keyhole loop” at McCoy Pavilion; the Banyan Court, including the sculptures; site features such as the Roosevelt Entrance Portals, Bridle Path Bridge, the lawn bowling center and the central makai terrace. The Sport Pavilion and McCoy Pavilion would also be diminished under the proposed plan.
The public comment period for the DEIS closed in August. The City is obligated to review and respond to all submitted comments when issuing the Final EIS before proceeding to construction. The project also includes work requiring an EPA permit, which is subject to the National Historic Preservation Act Section 106. HHF will continue to be involved at all future stages.