Letter to the Honolulu City Council: Hoopili Doesn’t Fit

Mahalo to Honolulu Civil Beat for publishing my Letter to the Honolulu City Council: Hoopili Doesn’t Fit.

This version includes the pictures in Appendices A and B.

I concluded by saying that it baffles me beyond belief that the Honolulu City Council is serially approving future development such as Ho'opili and transportation projects like the rail that are certifiably calamitous for our island community.

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.

Brief Insight on the Kakaako Development and Honolulu's Trifecta of Failures

Up to 5,000 new apartment and condominium units are being planned by the HCDA in Kakaako, Honolulu. This section of Honolulu is already the most traveled and congested. What would be the likely impact of such concentrated, high density development?

In the field of transportation planning and engineering we rely on the Trip Generation Manual produced by the Institute of Transportation Engineers headquartered in Washington, D.C. I have the 8th edition issued in 2008. 

It says that High Rise Apartments (land use 222) generate 0.30 trips per unit during the peak hour between 7 and 9 AM. The peak period in Kaka'ako is roughly the same. Of these trips, 75% are outbound (leaving the building) and 25% are inbound. Given that Kakaako is at a location near the center of the city and Waikiki, quite a few of these trips will be on foot, bike or bus. So instead of assuming that 90%-95% of the trips will be by auto, let's assume that 80% of the trips will be by auto.

If 5,000 new units were occupied in Kaka'ako "tomorrow", then there would be: 

5,000 x 0.30 x 0.75 x 0.80 = 900 new vehicle trips during the morning peak hour

If we stack all of them on Kapiolani Blvd., this estimate means that an exclusive new lane would be needed just to maintain similar congestion conditions as now. But there is no room for lane additions so the traffic impact will be immense.

This is similar to the situation prevailing today: Because of sewer work, contraflow on Kapiolani Blvd. was not in effect until past McCully St. (town-bound from Kaimuki) so it took me three cycles to go past the Kapiolani/Date traffic light. Over five minutes to traverse one major intersection! 

As I have frequently mentioned, Honolulu is the most lane deficient city of about one million people in the US (per capita, it is worse than LA, Chicago, etc.) Adding more density will cause the central road network to seize. It already does when there is major rainfall or a couple of typically uncoordinated lane closures on major streets.

The "Establishment" supported and thrived with the quick profiteering from the Second City. Second City profit-making has subsided due to the lack of road capacity and it will collapse with the mess of 10+ years of rail construction due to lane closures. After destroying the Ewa Plains, and causing major infrastructure liabilities, now it is time for the Establishment to come back and densify Kakaako and Kalihi. 

A dense urban ribbon between Waikiki and the airport should have been the original plan instead of the Second City 22 miles away from Waikiki. That plan should have come with high rises, urban underpasses, large underground parking, and possibly a 10-mile underground metro from Waikiki to Airport and perhaps to Aloha Stadium. The plan should have had new utility lines installed in secondary streets such as Waimanu Rd. and Queen St. instead of under major arterial streets such as Ala Moana and Kapiolani Boulevards. 

If you recall, since 1995 Kapiolani Blvd. has been a continuous construction zone. Now Ala Moana Blvd. is another work zone. As long as main utilities are under them, labe closures will never stop and pavement will be a patchwork. 

With the 

1. Second City/Ewa Development Plan, 
2. The Rail and,
3. The HCDA/Kakaako Development 

the Establishment has created the ultimate trifecta of (predictable) failures at a time when Honolulu can least afford to make mistakes and start new massive liabilities while the massive liabilities of

• Sewer EPA consent decree
• One water main break a day
• The worst pavement condition in the last 30 years
• Public employee pension unfunded liability
• Public employee health coverage unfunded liability

are here and 100% real.

The Ho'opili TIAR is Unacceptable

A critical element in approving any land use changes is the Traffic Impact Analysis Report or TIAR. The Friends of Makakilo and Save Oahu's Farmlands Alliance asked me to review B. R. Horton's TIAR submitted to the state's Land Use Commission (LUC) as part of the process for obtaining the approval to convert prime agricultural land to a residential development.

Let me quickly dispense the argument that my review of the Ho'opili TIAR may have been biased by the fact that Ho'opili contains two rail stations and is being billed as an exemplary Transit Oriented Development (TOD) of the proposed rail which I oppose.

The TIAR shows that Ho’opili’s transit trips are modest. If 50% of transit trips are made by rail, this results in 166 riders in the AM peak hour -- two bus loads and that’s it:
• Ho’opili does not work for rail proponents because it generates manini ridership.
• Ho’opili does not work for rail opponents because deleting it does affect the projected rail ridership substantially.

The first phase of Ho'opili barely justifies a basic bus service and the full development may benefit from limited express bus service. But as a ridership generator for rail, it is worthless, as all suburban TODs are. Suburban development and rail never go together.

Now back to the TIAR and why LUC should reject the petition on the basis of an inadequate TIAR alone.

“The planned year 2020 level of development is expected to occupy approximately one third of the total Ho’opili project site” stated on page E-2 is a hugely important statement. This means that all outcomes presented in the TIAR are only 1/3 of the whole. This is a “salami tactic” to get Ho’opili going without any disclosure of its total effects. A whopping 67% of the Ho’opili’s total effects are nowhere to be found. Therefore, this report should be deemed UNACCEPTABLE without at least an illustrative (approximate) full build-out scenario along with mitigations and final impacts. These numbers are simply “cheating” both decision makers and the community as they omit 67% of the potential impacts.

In the study’s Methodology for Freeway and Junction Analysis, the “… operating conditions were evaluated using the HCM 2000 methodology.” The current version is HCM 2010, but that’s a minor problem. HCM is not an appropriate tool for this application. The Federal Highway Administration (which has H-1 Freeway oversight) does not recommend such simple models for complex corridor and freeway analysis because they ignore congestion effects. The freeway operations in the Ho’opili area are dominated by the H-1/H-2 merge and other secondary bottlenecks. The TIAR’s segment by segment freeway and ramp analysis is entirely inappropriate. Also the H-1/H-2 merge is totally absent, therefore the presented results are UNACCEPTABLE.

The TIAR preparer assumed that Ho’opili will adopt a Traffic Demand Management composed of nine (9) major actions such as extensive biking, carpooling, tele-work, etc. Absolutely no other place in Hawaii has any four of these nine TDM actions occurring at the same time so at best this is a pie-in-the-sky assumption that artificially reduced the traffic impact of Ho’opili.

The TIAR preparer claimed that the Oahu MPO planning model allows them to take an up to 30% trip reduction due to the integrated character of the Ho’opili community. However, there is no proof that this is a valid or prudent assumption. I cannot think of a more integrated community on Oahui than Kalilhi. Arguing that Kalihi folks make 30% fewer trips is baseless and likely wrong. These multiple traffic reductions make the assessment of Ho’opili’s traffic impacts.

The freeway mitigations shown in the study are localized band aids and none of them address the merge of the H-1 and H-2 freeways. Worse yet, I note that the furthest downstream section of their mitigations is always a 3-lane “choker” so all these actions actually force more traffic flow onto bottleneck sections. The proposed freeway mitigations are UNACCEPTABLE.

The LUC Docket A06-771 “2020 TIAR” that I reviewed includes over 300 pages of computer traffic analysis output. All of it with simple Equation Type models, which are inappropriate for congested freeway corridors, as mentioned above. What I found surprising is that the memo for freeway analysis relating to Ho’opili agreed upon by State DOT, and two consultants of B. R. Horton is dated October 9, 2009 but nearly all of the computer outputs were dated August 20, 2009. So: (1) Freeway and ramp analysis was done before the State/Developer MOU, and (2) This TIAR is stamped “April 2011 update” but the traffic analyses are from summer 2009.

The TIAR states that “neither the City and County of Honolulu nor the State of Hawaii have guidelines for identifying the transportation impacts caused by the project.” This is a sad statement for our city and state and it is true. Solid technical criteria for the judgment of properly quantified traffic impacts are absent. Therefore, developers hire consultants to present a picture of the impacts and then government and top level decision makers arrive at an ad hoc determination about what’s wrong with the picture, if anything. This simply perpetuates arbitrary, capricious and favoritism-prone decision making.

Regardless of the lack of City and State criteria, the outputs of this analysis are by and large worthless. The report describes the 2020 plan with only one third of Ho’opili developed. The partial and biased TIAR of questionable methodology should be found UNACCEPTABLE for permitting the conversion of prime agricultural land to any other land use that obliterates the current active agricultural use of the land.