Island Transitions LLC Comment Letter June 2016

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ISLAND I RAN51 ]-IONS LLL June 13, 2016 To: Planning Department Staff and Steering Committee for the Hamakua CDP From: Deborah Chang, Island Transitions LLC Aloha Kakou! As you know, I worked on the Public Access Component of the Hamakua CDP from 2010 into 2012 while community input was actively gathered through workshops and meetings. The "Public Access Management" section in Appendix V4A: "'Aina: Natural and Cultural Resource Management Analysis" is the result of substantial community input and research. Being away from the project for the past 4 years enables me to look at it with a fresh perspective. The CDP has many moving parts and is highly complex. Mahalo for the opportunity to comment on the current draft. The following comments focus on Section 4.8 "Establish and Manage Public Access and Trails." I understand that the current draft strives to be concise while relying on the background rationale and details to be supported in the Appendix. I agree with that approach as long as the level of detail in the abbreviated version of the plan is sufficient to support the recommendations, and the reader knows where to find further explanations. • Generally, the January 2016 draft does a good job of highlighting the main policies and actions for Public Access. However, there is noticeably more detail in support of Policy 48, than in Policies 49 — 53. This is inconsistent, and the other policies would benefit from brief supportive statements. Policy 48 Element 10 should read, "....required of landowners," not "....required by landowners." • Similar to Policy 52, Policy 50 would benefit from references to the HRS sections that support this policy, i.e., HRS Sections 115-5 and 46-6.5. • The explanation for Policy 51 would be clearer if the phrase, "best adapted to trail use," were restated as "best adapted to non -motorized trail use." • Policy 52 is an important policy but needs to be supported by more information. How will public access potentials be assessed, documented, and protected and by whom? How and who will ensure that this policy becomes more than just good intentions? • It is unclear why Laupahoehoe Boat Ramp is the only specific location singled out in the policies when there are other locations within Hamakua, and North and South Hilo Districts, which have been identified as having exceptional public access value. Brief justification needs to be added to Policy 53. Won't reconstruction of the Laupahoehoe Boat Ramp require K6kua Action from the State Legislature, among others? • Why is Bishop Estate/Kamehameha Schools the only private landowner listed for Kokua Action 22 or 23? It is unclear which Kokua Action is being referred to here. • In general, the Kokua Actions need clarification. Are the parties listed in bold the only partners needed? Kokua Action 24, which is supported by HRS §171-26, should be distinguished from Policy 52 (HRS §46-1.5). • Throughout the document, the reader is being referred to policy numbers and actions that appear in other sections. There needs to be a way for the reader to locate those related policies and actions with ease. Perhaps the final draft should include a listing by page number and/or section where the policy and action numbers are primarily discussed? • Finally in Appendix V4A (p. 204) "Liability Protection on Unimproved Public Lands," there is good news. Hawaii's Legislature in 2014 made the liability protections in Act 82 (SLH 2003) permanent. This section in the Appendix should be updated. For the details, see HRS §663-52. Deborah L. Chang • Ai?rr yird Pl(m?io • ,1jPr irrlL;i rc hr 'Bail., &:lcce• .� ls.arr, N). Box 202 • P�1'21Lli]O, Iii 96776-0202 • [t;W 776-1316 • I.nrt