Kula
Community Association
P.O. Box 417 - Kula, HI 96790
The vision of the Kula Community Association is to preserve
open space, support agriculture, maintain a rural residential atmosphere,
and to work together as a community.
The specific purpose of this association is to improve the
quality of life for the residents of Kula, to promote civic welfare
and generally to benefit the community of Kula.
June
6, 2002
Jeffrey
H. Overton, Chief Environmental Planner
Group
70 International, Inc.
925
Bethel Street, 5th Floor
Honolulu,
HI 96813-4307
Dear
Mr. Overton:
Subject:
Upcountry Town Center (UTC) Draft Environmental Impact Statement (DEIS)
The Kula Community Association (KCA) Board
of Directors met on June 6, 2002 to discuss the Upcountry Town Center DEIS. The
KCA Board wishes to place on the official DEIS record the following general
comments, specific comments, and recommendations. We expect that the Final EIS
will address both our concerns and questions. Furthermore, we ask that the Office
of Environmental Quality Control and the Maui County Planning Department and
Planning Commission seriously consider the issues which we raise.
General Comments
I.
We request that the Final EIS reflect and respect the
thought that went into developing the Makawao-Pukalani-Kula Community Plan
revision adopted as an ordinance in July, 1996.
The triangular shaped parcel where the 40
acre UTC is being proposed was thoroughly reviewed and discussed during the
initial stages of the Makawao-Pukalani-Kula Community Plan 1990's
update. At that time the members of the Citizen Advisory Committee (CAC)
recognized a need for additional Upcountry commercial space, senior housing, a
cultural site/museum, park/open space, and light-industrial. However, the CAC
members recommended an alternative Kulamalu site as being a superior location
for most of those activities and an area near the Kula Post Office as a
designated light-industrial site.
Among the reasons for selecting the other
sites were: the desire to avoid having commercial activities so close to the
new King Kekaulike High School - in other words, to provide a large open-space
buffer; the determination that the three roads which surround the proposed UTC
would be negatively impacted by bringing so much traffic to the area; and the
concern that the proposed commercial area would have anchor stores that would
negatively impact the old-time, mom-and-pop stores and the Upcountry lifestyle
which they reflect. When the thoughts and concerns of the CAC were made clear,
Maui Land and Pine (ML&P) graciously withdrew their proposal.
The CAC, Maui Planning Department and
Planning Commission, and the County Council all confirmed the community�s wish
to leave this area in agriculture. Now, only six years since the Community
Plan was adopted, (ML&P) is again proposing to re-designate their
40-acre parcel at the Pukalani Triangle. The Final EIS should explain what is
different now from when the Community Plan was adopted.
II.
The DEIS fails to include a realistic discussion of
the existence and effects of the large Kulamalu commercial, senior housing, and
park development. Water source development and a transmission system were
completed several years ago; zoning was applied for and approved; and site
development has been on-going for over a year. If the DEIS had accurately
described the scale of the Kulamalu project, we believe that a very different
and more accurate DEIS would have been produced.
For example, the main portion of the DEIS
neglects to fairly consider the Kulamalu commercial, senior housing, and park
designations; the map on page 8-4 even cuts most of it out and does not label
it; and, finally, the Market Study minimizes its impact. The KCA Board of
Directors asks that the Final EIS correct the omission and discuss the proposed
UTC in light of the ongoing Kulamalu development as well as the designated
light-industrial area in Kula.
The DEIS, in Table 10 of the Market Study,
indicates Competitive Floor Space for the nearby Kulamalu commercial
development at only 54,000 square feet. Our discussions with the developer, Everett
Dowling, indicate plans for considerably more floor space. Please confirm the DEIS
estimate with the Kulamalu developer and, if necessary, provide a recalculation
and reanalysis within the Market Study.
Specific Concerns and Questions
1. We suggest more analysis in the DEIS of the effect on existing Upcountry
businesses if the UTC is built. What will be the impact of the addition of the
proposed business/retail/commercial space on Makawao Town business district,
Pukalani Shopping Center, Pukalani Square, the many stores along the Old
Haleakala Highway and nearby Makawao Avenue, and in Pulehu, Waiakoa, and Keokea?
Please address the potential loss of business and the siphoning of tenants from
present locations.
2. What will be the effect that chain stores and urban-type businesses and
visitor-oriented retail shops and restaurants will have on the rural character
of the region?
3. What will be the effect of ML&P drilling for water in close
proximity to sites where the County of Maui Department of Water Supply plans to
drill?
4. The proposed UTC is on the highest quality agricultural lands. (Please
see the DEIS Page 4-12, last three paragraphs.) We are concerned, just as the
State Land Use Commission should be concerned, that this valuable resource will
be lost forever from the State�s inventory of prime agricultural lands. (Please
see the Makawao-Pukalani-Kula Community Plan Page 25, #2.).
5. The DEIS has totally ignored the impact of the UTC on its major
neighboring land owner, King Kekaulike High School. Similarly, there is no
analysis of the impact of the large high school on the UTC project. This
omission is particularly glaring when the list of consulted parties indicates,
not only no contact with the King Kekaulike High School and its parent/teacher
association, but no contact at all with the Department of Education. (Please
see DEIS Page 10.1).
6. Traffic flows and impacts are a major concern. We are concerned about
all three of the neighboring roadways, the intersections, and several specific
traffic patterns:
a) School Traffic: There is a need to estimate the traffic flows to the new, nearby
Kamehameha School which will soon have an enrollment of 1200 to 2000 students.
Kamehameha is now building the middle school and the high school campus, and
most of the students and staff will pass by the UTC site during the morning
peak and at 2pm-3pm. There also will be increasing traffic to and from the
Kamehameha pre-school.
b) Tourist Traffic: The DEIS Market Study indicates 3,000 visitors (65,000 square feet of
supplemental tourist demand) accessing the project. What is the source of this
data? This raises two traffic issues. Many tourists will be coming down from
Haleakala after watching the sunrise, during the peak morning commuter rush and
at the time when the students will be driving to school. Exactly what route
will they use to get to the UTC? What will be the impact of tourists trying to
make a U-turn into the Maui Fresh site on the Pukalani Bypass? We are concerned
that many inexperienced student drivers will be coming around the turn and up
the hill where these U-turns are being made by tourists unfamiliar with the
risks.
c) Makawao Avenue: (Please see the Makawao-Pukalani-Kula Community Plan Page 34,
#14.) The DEIS describes a business corridor in Pukalani along Makawao Avenue.
We would point out that there is no corridor at present, but there is already
considerable congestion and a dangerous traffic pattern. If new stores (in the
proposed UTC project) are constructed opposite the present Pukalani Superette,
a corridor will be created and the traffic situation may be made much worse. We
point out this potential effect on Makawao Avenue because of our observation of
the terrible congestion on narrow Makawao Avenue in the town of Makawao. We
also would like to understand the effects of the many large tourist buses on
Makawao Avenue as they enter and leave the UTC site.
7. We believe that under no circumstances should this project have any
access to the Pukalani Bypass Highway. (Please see the Makawao-Pukalani-Kula
Community Plan Page 34, #13 and Page 23, #9.) The church site below the
proposed UTC project was based on a State Department of Transportation decision
which ignored the Community Plan. That decision should, in no way, be
relied upon as a precedent for putting the access to the Maui Fresh business on
the Pukalani Bypass. The proposed UTC is very different from the church below
where traffic is limited and does not involve tourists, tour buses, or a large
volume of cars.
8. Have the projected traffic counts considered the types of businesses
that may be built, such as gas stations and fast food restaurants that generate
heavy traffic?
9. The DEIS proposes a relocation of Pukalani Superette to the UTC site.
What are the potential uses for the present Pukalani Superette site? What if
Pukalani Superette chooses to remain at its present location? These decisions
will impact the UTC project and traffic, especially if the old Pukalani
Superette site contains a gas station, and/or fast food restaurant(s), with or
without drive-through windows.
10. The State Department of Health should survey the entire parcel for
pesticide/herbicide contamination with the results included in the Final EIS
and prior to any land-use change application.
11. There is a proposed walking trail indicated for the periphery of the
UTC project. (Please see the light blue line on Page 3-2 of the DEIS). We
question the wisdom of putting that recreational walking trail right along the
highway. The fumes and the steady, passing traffic would certainly diminish its
pleasure. Furthermore, the trail does not connect to other upcountry trails.
12. We recognize both the enormous need for senior housing in the upcountry
region and the need to reduce heavy traffic in that location. Consequently, we
request that the Final EIS consider eliminating the multi-family option and
expanding the senior housing complex to include more residential units and
assisted-living capabilities.
Recommendations
Until
the effects of the Kulamalu build-out are accurately ascertained, the KCA Board
of Directors requests the UTC project be delayed. While the KCA Board of
Directors is sensitive to the economic position faced by ML&P, we believe
that circumstances and facts do not warrant proceeding at this time with the
proposed project.
As indicated above, the community planning
process involved the CAC, the Maui Planning Department and Planning Commission,
and the County Council. All confirmed the community�s wish to leave this area
in agriculture and to allow the Kulamalu project to be the Upcountry district�s
next commercial, senior citizen, and park complex. It is unfair to the Kulamalu
developers for ML&P to undercut their efforts by permitting an unexpected
competitor just as they are signing tenants. In fact the mere announcement of
the proposed UTC project has already influenced potential tenants.
The EIS should not try to justify the UTC
project on the premise that this agricultural site is a mere remnant of
ML&P�s pineapple operations and is therefore unsuitable for agricultural
use. When the Pukalani Bypass was built, the State of Hawaii (we taxpayers)
paid Maui Land and Pine a significant amount (reported to be approximately
$4,000,000) because of ML&P�s reduced ability to farm the proposed UTC
site. That amount, if accurate, is greater than the potential value of the land
for agricultural production.
If and when the time is appropriate for
development of additional commercial space as proposed for this parcel, the KCA
respectfully suggests that the land owner, consultants, and State and County
agencies also consider the following:
1. Ensure all structures are built according to
principles of energy conservation. Include an accessible recycling center for
community needs.
2. Incorporate senior housing in the initial phase. Include
affordable senior housing with an assisted living component.
3. Work with the County to develop a transit system that
will use the UTC as one of the bases to provide commuter parking.
4. Help develop a system of connected pedestrian and
bike trails, safe enough for children and with safety assured at intersection
crossings. The UTC trail should connect to trails above and below in a manner
safe for all.
5. Incorporate a museum/community center into one of the
historic Corn Mill Camp structures. Adapt, repair, and reuse all historic
buildings on the site. (The Community Plan suggests a Rural History
Center to record and promote the rich agricultural and cultural histories which
were important to the development of the Upcountry area.)
6. Ensure facilities for child day-care, for a preschool
center, and for senior day-care. Perhaps the County would establish a senior
center similar to the Spreckelsville senior center.
Thank you for your attention to our comments,
questions, and suggestions. The KCA represents Upcountry residents who cherish
the rural atmosphere of the Upcountry region. These wishes are clearly
expressed in the Makawao-Pukalani-Kula Community Plan, as well as in
Kula Community Association�s vision and purpose statements (in the masthead on
this letter). We look forward to your response.
Sincerely,
Elliott Krash, President
Kula Community Association
Cc:����� Maui Land and Pineapple Company
����������� Genevieve Salmonson, Director, Office of Environmental
Quality Control
����������� John Min, Director, Maui County Planning Department
Senator
Avery Chumbley
Senator
J. Kalani English
Representative
Kika Bukoski
Representative
Chris Halford
Mayor
Kimo Apana
Councilmember
Charmaine Tavares
Pukalani
Community Association
Makawao
Community Association