MKRUG Submitts Testimony on Kulani NARS

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The Mauna Kea Recreational Users Group (MKRUG) submitted the following testimony on the proposed expansion of the Puu Makaala Natural Area Reserve. This proposal would add 6600 acres of the former Kulani Correctional Facility’s 7700 acre TMK parcel. The remainder is believed to be reserved for State DOD use reportedly to run a Youth Challenge Academy.

The testimony submitted:

July 12, 2010

Laura Thielen, Chairperson
Department of Land and Natural Resources
P.O. Box 621
Honolulu, Hawaii 96809

ATTN: Emma Yuen

Dear Chairperson Thielen:

Submitted herewith is testimony on the proposed extension of the Puu Makaala Natural Area Reserve in which certain amendments are requested.

It is understood that the hearing of July 12, 2010 is for the purpose of accepting public testimony on a proposal to place land formerly occupied by the Kulani Correctional Facility and administered by the Department of Public Safety into the Natural Area Reserves System administered by the Department of Land and Natural Resources, with the exception of certain core areas that are to be transferred to the Hawaii Department of Defense. Areas excluded from the NAR “include the main campus of the facility, the Boy’s School, and other disturbed areas or roads”, according to the proposal.

There have apparently been no other proposals suggested nor hearings held on alternative uses for the former prison site. While we have concerns over lack of public involvement in the process that led to the subject hearing, we could support the proposal if the following conditions are met:

First and most importantly, reasonable public vehicular access needs to be provided to and through the proposed NAR. After an absence of 60 years, the public owners are entitled to visit these former forest reserves. Roads excluded from the NAR and open to the public should include that which originates at the terminus of Stainback Highway and proceeds past the Boy’s School to Powerline Road and the 1942 Lava Flow. An additional road open to public access should be that which follows the northeastern boundary fence adjacent to the Upper Waiakea Forest Reserve. The latter road would support hunting where “high populations of pigs occur in Forest Reserve lands to the east”, reducing animal pressure on the NAR eastern boundary fence. Jurisdiction over these roads should remain with DOFAW, exclusive of NAR control.

In April 2010, 5,795 acres were added to the Kahaualea NAR, increasing the size of the Hawaii Island Natural Area Reserves System by 7 percent to 88,330 acres. The proposed Puu Makaala NAR extension would constitute an additional 7 percent increase, raising NARS total island land area to 94,930 acres. There has been no additional staff or supporting resources identified to accommodate this increased management responsibility, nor is any deemed likely in the foreseeable future. Planned NARS staff and budgetary reductions were discussed at the Natural Area Reserves System Commission meeting of August 25, 2009. Increasing land management responsibility while reducing resources does not seem a logical progression.

Land in the proposed extension has been described as “probably the finest and highest quality forest on the island of Hawaii”, and would presumably require a proportionately high level of NARS management attention. As an additional stipulation for support, we propose the mitigating measure of removing an approximately equal-sized substandard portion of the existing Puu Makaala NAR and returning it to forest reserve status. Such action would provide an adequate level of land protection, permit concentration of available NARS resources on priority management objectives, and enhance public access.

Past attempts have been made to remove the easternmost portion of the existing Puu Makaala NAR on the basis that it does not qualify as a “unique natural resource … as relatively unmodified as possible”, as stated in the relevant statute [Hawaii Revised Statutes, Chapter 195, Natural Area Reserves System, §195-1]. This former forest reserve is populated with ash and eucalyptus trees as part of a timber management area, and contains major infestations of non-native palm grass, waiawi, and rubus. Citing obstacles to effective management due to marginal land condition, a previous NARS island manager recommended departmental discussion on removal of that portion of the NAR.

The aforementioned section of the existing NAR is immediately adjacent to, and shares a boundary with the Olaa Rainforest section of Hawaii Volcanoes National Park, in seeming contradiction to NARS management policy:  “the Natural Area Reserves System shall not include unnecessary duplications of ecosystems or geologic features already protected in Federal Wildlife Refuges, National Parks, or private conservation groups.” [Management Policies of the Natural Area Reserves System, dated May 23, 1997; Appendix C – Reserve Designation Process, Number of Areas, Page 2].

Should the former Kulani Correctional Facility be incorporated into the existing Puu Makaala NAR, we propose its easternmost section be simultaneously returned to the Olaa Forest Reserve. The suggested western boundary of the excluded portion would follow the National Park boundary north to the Puu Makaala Aku Unit, align with the Aku Unit’s eastern boundary, and proceed north along Army Road. The proposed exclusion is estimated to comprise 5,600 acres, yielding a Puu Makaala NAR net land increase of 1,000 acres.

It is further requested that the Board meeting considering this proposal be scheduled for Hilo, where persons most affected by its actions are afforded the opportunity to participate.

Respectfully submitted,

Wayne Blyth, Chairman

cc: Rob Pacheco
Hawaii Forest and Trail
74-5035B Queen Kaahumanu Highway
Kailua Kona, HI 96740


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