From: Prof. (Emeritus) Dick Mayer, 1111 Lower Kimo Dr. Kula, HI 96790 dickmayer@earthlink.net Cell 808-283-4376 TO:
April 9, 2012
Approving Agency: Federal Highway Administration, P.O. Box 50206 Honolulu, Hawai‘i 96950, Contact: Abraham Wong, telephone (808) 541-2700 Applicant: State of Hawai‘i, Department of Transportation, 650 Palapala Drive, Kahului, Hawai‘i 96732, Contact: Robert Spilker, (808) 873-3376 Consultant: Munekiyo & Hiraga, Inc., 305 High Street, Suite 104, Wailuku, Hawai‘i 96793, Contact: Karlynn Fukuda, (808) 244-2015
RE: Kahului Airport Access Road, Phase I Puʻunene Avenue to Hana Highway (NEPA EA) I believe that the present NEPA EA is deficient in several significant ways. It would be premature to issue a FONSI at this time. It probably would be best to require an EIS, or as a minimum prerequisite, require that a complete EA be prepared and reviewed by the public and the responsible agencies. 1.
Impacts due to incomplete information: Totally missing from the Environmental Assessment are impacts from A&B’s 179 acre Maui Business Park that runs along the access route (on both sides of the Hana Highway) and is now under construction. The Business Park will have many dozen new industrial and commercial entities. It will be the source and destination for considerable new traffic that will impact along this Access Highway, utilizing the intersections. Why was it ignored? In fact the EA incorrectly states,
“. . . the Maui Business Park (MBPII) light industrial subdivision . . . project is located adjacent to the proposed Airport Access Road. As designed, there will be no direct access from the MBPII subdivision to the Airport Access Road. Page 27
For example, much new traffic from growing Maui Lani, Kehalani, Wai’ale, and Waikapu Town Center will all come down Kuihelani Highway and use the Access Highway and turn into the new Maui Business Park II at the Pakaula intersection. There are 7,400 yet-to-bebuilt units in those developments. In addition several thousand new units are planned for West Maui and will use the same approach. (NOTE: I can provide the data source that verifies the expected units. It comes from an A&B source.)
Kahului Airport Access Road, Phase 1
Dick Mayer 4/9/2012
Page 2
2.
Questionable design: Inadequate mention is made of all the roads into and out of A&B’s adjacent Maui Business Park, especially the Hookele and Hana Highway intersection, just east of the Airport Access Highway’s intersection with Hana Highway. The close proximity of these two intersections is significant. Furthermore, It is interesting because the Hawaii Department of Transportation (Highway Division) just this past week testified at the State Land Use Commission that they are requiring at least a half-mile intersection separation in a similar situation on Kuihelani Highway for Wai’ale, another A&B project.
3.
Safety: The new intersection in front of Wal-Mart shows rolling right hand turns. This could be very dangerous since it can be expected that there will be numerous pedestrians crossing the streets at that particular intersection. In fact, no consideration has been given to pedestrians. Maui Police Chief Phillips recommended consideration of pedestrian needs;.
“ . . . there are no improvements to include pedestrian movement. Pedestrian walkways, corridors or overpasses should be included in this plan to ensure the safety of both the pedestrians and motoring public.” (Appendix J, Page 45) However, the EA has chosen to ignore them with the excuse that this is a high-speed, limited access highway. Will there be any sidewalks at the intersection of the highway and Paukala Road? 4.
Segmentation: There is inadequate discussion of the Kahului Airport Access Highway’s other half, the portion being built by Hawaii DOT’s Airport Division. When will it be built? Before? After? Are there any issues in the joining of these highways, e.g., funding, traffic, construction schedules, impacts?
5.
Cumulative Impacts: Hana Highway will be impacted by this project AND all six (6) of the other old intersections (Dairy Road, Pulehu Road, Hansen Road) and new intersections (the new Hookele Road extension, the proposed intersection from A&B’s north portion of the Maui Business Park II behind K-Mart, and the airport’s planned East Ramp Access Road) that are being constructed. This EA totally ignores the cumulative impacts, delays, congestion, safety, etc. This is especially important for the residents/commuters from Haiku, Paia, Makawao, Pukalani and Kula. The EA incorrectly states, “This project
component is viewed as a stand-alone project with no other associated improvements which would yield cumulative impact considerations. (Page 27) 6.
Assumptions: The Maui Business Park II traffic study (See TIAR in Appendix G http://oeqc.doh.hawaii.gov/Shared%20Documents/EA_and_EIS_Online_Library/Maui/2000s/2 004-12-MA-FEIS-MAUI-BUSINESS-PARK.pdf ) assumed that Hana Highway between Dairy
Road and the Hookele Road extension (which includes the Airport Access Highway intersection with Hana Highway) would be upgraded to a 6 lane highway. This EA does not show this improvement and may lead to congestion at the multiple intersections mentioned in #5 above. I hope the above comments are helpful and will lead to an improved EA that can lead to a FONSI, or alternatively, a more comprehensive EIS.