IMG_4115 IMG_4116 IMG_4118 IMG_4119 IMG_4119 IMG_4120 IMG_4122 IMG_4123 IMG_4124 IMG_4125 IMG_4126 IMG_4127 IMG_4128 IMG_4129 IMG_4134 IMG_4131 IMG_4133 IMG_4134 IMG_4136 IMG_4137 IMG_4138 IMG_4141 IMG_4142 IMG_4143 IMG_4144 IMG_4145Most guys still refer to it as Wailea 670, the original name before apparently the Wailea Association said it is not part of Wailea, so you can’t use that name. Now it is Honua’ula, but regardless of the name, it remains a controversial project for a number of reasons, including preserving the environment, including effect on endangered species at the 670 acre site.

So the agency came to Maui, (but not South Maui) to receive testimony last evening (7/27/16) in Wailuku at the Cameron Center, where about 20 some concerned testifiers showed up. Those caring who missed the opportunity can submit written testimony, so long as received by 8/8/16.

The meeting was conducted by Scott Fretz, DOFAW Maui District Manager and a power point presented by Kate Cullison, the Protected Species Habitat Conservation Planning Associate.

KCA did both, oral & written testimony, expressing concerns about the Community Plan (KMCP) violations. Our written testimony is available below..



To: Endangered Species Recovery Team Re: Habitat Conservation Plan for Proposed Honua’ula Project Date: July 27, 2016

Applicant: Honua‘ula Partners, LLC Charles Jencks, 381 Huku Li‘i Place, Suite 202, K?hei, Maui 96753

Approving Agency: Department of Land and Natural Resources: Kate Cullison, 1151 Punchbowl Street Room 325, Honolulu, Hawaii, 96813

Consultant: SWCA Environmental Consultants, Jaap Eijzenga, Bishop Square: ASB Tower, 1001 Bishop Street, Suite 2800, Honolulu, Hawaii 96813    

Mahalo for this opportunity to comment on the Habitat Conservation Plan for the Honua’ula Project in South Maui. The Kihei Community Association (KCA) is a non-profit community benefit organization that has served the South Maui area and its residents for over 60 years. KCA is very gratified to know that a significant preserve area is being set aside to protect the rare and endangered plants and numerous cultural sites found on the site of the proposed Honua’ula (Wailea 670) project. We have reviewed the Honua’ula Habitat Conservation Plan. It discusses some very thorough and admirable goals to enhance native plant species in the proposed preserve; however, it appears to overlook the fact that there is ongoing and current cultural practice associated with the land involving both the cultural sites and the native plants found on the site. KCA has had community presentations by native Hawaiian’s who described their cultural practices on the Wailea 670 land. These cultural practices include traditional ceremonies, caring for archaeological sites, caring for native plants, gathering seeds and documenting additional cultural sites as discovered. Our Kihei-Makena Community Plan emphasizes the importance of cultural sites and cultural practice to the south Maui region. On page 23 under Cultural Resources the Kihei-Makena Community Plan states:

Goal Identification, preservation, enhancement, and appropriate use of cultural resources, cultural practice, and historic sites that: a. provides a sense of history and defines a sense of place for the Kihei-Makena region; and b. preserves and protects native Hawaiian rights customarily and traditionally exercised for P.O. Box 662 ? Kihei, Maui, Hawaii 96753 ? Phone: 508.499.9996


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subsistence, cultural, and religious purposes in accordance with Article XII, Section 7, of the Hawaii State Constitution, and the Hawaii Supreme Court’s PASH opinion, 79 Haw. 425 (1995).

Objectives and Policies c. Encourage and protect traditional…cultural practices… d. Protect those areas, structures and elements that are a significant and functional part of Hawaii’s ethnic and cultural heritage. g. Recognize and respect family ancestral ties to certain sites. We feel that a document like the Honua’ula Habitat Conservation Plan needs to also respect the intent of our Community Plan and include a discussion about the role of cultural practitioners who currently utilize the proposed Native Plant Preservation Area (NPPA). It is our understanding that information about current and past cultural use of the site is not easily accessible in the project’s Historic Preservation documents, but is readily available from cultural organizations and individual practitioners. It is our understanding that state law and the legal decisions which have helped define the laws, both require every state agency decision on a proposed action to consider the impacts on traditional and customary use by native Hawaiians associated with the proposed site. This area certainly should be recognized as being currently utilized for cultural practices in the HP Habitat Plan. Without this information, the HCP is incomplete. Maui County council placed Conditions of Zoning on the land in 2008 that first set the requirement for a native plant and cultural preserve of up to 130 aces to be created on the land and also requires Conservation/Preservation plans. This condition reads in part: “A commitment from Honua’ula Partners, LLC, its successors and permitted assigns, to protect and preserve the Easement for the protection of native Hawaiian plants and significant cultural sites worthy of preservation, restoration, and interpretation for public education and enrichment consistent with a Conservation Plan for the Easement developed by Honua’ula Partners, LLC and approved by the State Department of Land and Natural Resources, the United States Geological Survey, and the United States Fish and Wildlife Service; and with a Cultural Resource Preservation Plan, which includes the management and maintenance of the Easement, developed by Honua’ula Partners, LLC and approved by the State Department of Land and Natural Resources (collectively, the “Conservation/Preservation Plans”). It is clear from this language that the preserve area and the easement that protects it is meant to address both cultural sites and native plants. The HCP, however, describes stewardship activities on the land as being focused on the native plants, and mentions various types of use, but refers only to “features associated with Hawaiian culture” not any cultural practice.

“Stewardship in the context of traditional Hawaiian uses was focused on survival of the inhabitants in a subsistence economy. However, in the present day, preservation of resources is approached from a conservation, educational, cultural, historic, and recreational perspective. Stewardship, therefore, integrates preservation of archeological resources and conservation of natural resources, so future generations can appreciate the historic subsistence communities, and P.O. Box 662 ? Kihei, Maui, Hawaii 96753 ? Phone: 508.499.9996



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adaptability of the historic residents, as well as see remnants of native dry shrub land. This plan focuses specifically on management actions to enhance and conserve native plants in the

property. Preservation of cultural resources will be addressed in the forthcoming native plant historic preservation plan and cultural resource preservation plan, which will be complementary to this plan.” (HCP p. 82) This statement illustrates that the HCP does not recognize the native plants as cultural resources and does not recognize that lineal descendants and cultural practitioners have a relationship with those plants and the cultural sites that are part of the overall project landscape which is also a cultural landscape. This relationship must be honored and included in the HCP. The ongoing cultural use of the Honua’ula/ Wailea 670 site needs to part of the Habitat Conservation Plan. We also note that Fig 2 “concept map” in the HCP shows a proposed new road segment to be constructed in the western area of the 134 Native Plant Preservation Area (NPPA). This does not seem to be a compatible use in the highly protected NPPA. We would suggest that the HCP discuss the possibility of omitting that road relocation. Thank you for your consideration of our comments.


Mike Moran

President, KCA