Ho'opili Development on the Island of Oahu--Comments to DPP

This is a picture of today (left) and the proposed development of Ho'opili (right.)  DPP is poised to issue permits for Ho'opili to begin construction on prime agricultural lands on Oahu.

I sent the following comments to the Department of Planning and Permitting of the City and County of Honolulu.  The bottom line is that with or without rail, the Ho'opili Development will be a traffic impact disaster for Central Oahu and no meaningful road capacity accommodations are planned, therefore no permits should be granted. My main comments against the (untruthful) assessments of Ho'opili's traffic impacts are as follows.

• The traffic models used to assess the impacts of the Ho'opili development are too limited in scope relative to the size and regional impacts of this very large development. Most outputs in the TIAR are unacceptable underestimations.
• In Ho'opili-related traffic analyses, the H-1/H-2 freeway merge which is a critical bottleneck in the region was completely ignored and no mitigation to the existing severe congestion has been proposed.
• Most analyses I have reviewed present year 2020 projections with only about 1/3 of Ho'opili developed. Comprehensive analyses with the full 100% of the project developed are not available. This is an obvious “salami” tactic and under-representation of the development’s full scale of impacts.
• The Ho'opili TIAR claims that the OMPO model allows them to take an up to 30% trip reduction in trip generation by the development due to the “integrat-ed character” of the Hoopili community. However, there is no proof that this is a valid or prudent assumption. I cannot think of a more integrated community than Kalilhi with its rich mix of light industrial, services, offices, storage, retail, food, school and residential land uses. Arguing that Kalihi folks make 30% fewer trips than the rest of Oahu is wrong. At any rate, there is no proof, so Ho'opili taking such huge “discounts” in traffic generation is wrong.
• Ho'opili’s generation of trips by transit is not large. For example, the number of trips made by rail is the equivalent of a few bus loads in the morning peak. Regardless of whether rail is fully operational by 2020 (which is unrealistic in my opinion,) Hoopili’s traffic impact will be immense with or without rail. Well over 90% of the commuting trips generated by Hoopili residents will be made by auto, bus or bike, all of which require lanes. Only localized but no regional lanes are proposed to be added, therefore Hoopili will cause huge increases in traffic congestion in the region.