HAR §15-215-88
HAR §15-215-88. Minor [changes
Length: 20,586 wordsOfficial source
Cite as Haw. Code R. § 15-215-88
] amendments to
permits. (a) After final approval of a [rules
clearance, improvement permit, development permit,
conditional use of vacant land permit, conditional use
permit, master plan permit or variance,] permit, the
executive director may allow minor amendments to the
application without submittal of a new or amended
[application when the requested amendment(s) does
not:] application, in order to address administrative
corrections or minor adjustments or refinements to the
approved project design.
(b) Examples of allowable minor amendments to
permits include, but are not limited to:
(1) Administrative corrections to typographical
errors, names, or mailing addresses; and
(2) Minor adjustments or refinements to project
architectural design features such as façade
treatments, type or location of landscaping,
size or location of interior rooms.
(c) In order to qualify as a minor change, the
requested amendment(s) may not:
(1) [Increase] Materially increase the number of
allowable dwelling units, [allowable] floor
area, height, or any additional land-use
disturbance;
(2) Introduce different land uses;
(3) Request larger land area;
(4) Request any variance[;] or increase an
approved variance;
(5) Allow any diminution in buffer or transition
areas, reduction in landscaping, reduction
of required yards, or any significant change
in the design characteristics or materials
used in construction of the structures; or
(6) Reduce or eliminate conditions attached to
the subject development approval.
(d) Changes to development permits shall require
a new public hearing, if the amendment concerns a new
issue that would have itself required a public hearing
prior to issuance of the original permit.
(e) For minor changes to improvement and
development permits, the applicant must also submit
documentation as to how the amendment would still
advance the purposes of redevelopment and be
Page: 106
Author: JacobK Subject: Highlight
Date: 9/8/2025 2:14:36 PM
There are some design variances that might not be understood at the beginning of the project - example
variance on fence height for FDR.
Author: JacobK Subject: Highlight
Date: 9/8/2025 2:42:28 PM
Recommend limiting this to street tree count and reinforcing that substitutions are allowed within the city's
approved list.
Rationale: Development applications for large parcels are going be completed 2-4 years before vertical
construction begins. This leaves several reasons a landscaping plan will evolve with a project: (1) civil
constraints (2) nursery availability and (3) pests.
Civil layouts dictate a lot about where larger plants and trees can be planted because electrical ducts and
plumbing lines need space from the root ball of even medium sized trees.
Species availability (especially if certain caliper sizes are required) can sometimes require very late stage
substitution because there is a limited supply on island and bringing in plants from outside brings many
hurdles.
Lastly, Hawaii regularly faces the threat of pest introductions.
For example the longhorn beetle in 2018 attacked kukui trees, and the rhinoceros beetle that has attacked
palms since 2014. (The state of Hawaii Plant Industry Division issues "new pest advisories" and has issued at
least 12 in the last decade. (https://dab.hawaii.gov/pi/ppc/new-pest-advisories/).
The ability to react and change specific species in real time is critical which may include substitutions and
should be allowed and encouraged without additional bureaucratic hurdles to clear. The curtailing of palms
due to the rhinoceros beetle is a good example because the root structure of palm is shallow and cannot be
easily replaced like for like with even small deciduous trees given power and water distribution layouts on
site.
State intervention into the design of private property should remain circumscribed to the public realm of
street trees which the City and County is already equipped to regulate and enforce.
FIGURE 4: BUILDING DEVELOPMENT STANDARDS
July 2025
T2
Rural Zone
T3
Mixed-Use
Zone
T4
General
Urban Zone
T5
Urban
Center Zone
Building Types (See Figures BT.1 - BT.10 for details on each type)
Front yard house (BT.1)
-
-
-
Side yard house (BT.2)
-
-
-
Townhouse (BT.3)
-
Duplex, triplex, and quadplex (BT.4)
-
Flex-loft (BT.5)
-
Industrial barn (BT.6)
Courtyard (BT.7)
-
Urban block (BT.8)
Lei building (BT.9)
-
Tropical urban court (BT.10)
-
Frontage Types (See Figures FT.1 - FT.8 for details on each type)
Lanai and front yard (FT.1)
-
-
Stoop (FT.2)
-
Dooryard (FT.3)
-
-
Forecourt (FT.4)
-
Shopfront (FT.5)
-
Terrace (FT.6)
-
Raised Terrace (FT.7)
-
Gallery (FT.8)
-
Maximum Building Height
Primary building
28’
60’
75’
90’
Accessory building
14’
28’
28’
90’
Legend
Permitted
-
Not permitted
15-217-118
Page: 121
Author: JacobK Subject: Highlight
Date: 9/8/2025 2:44:08 PM
Recommend removal of frontage types; see earlier comments for rationale
July 2025
T2
Rural Zone
T3
Mixed-Use
Zone
T4
General
Urban Zone
T5
Urban
Center Zone
Floor Area Ratio (FAR)
Maximum
0.35
1.5
2.5
4.5
Building placement (See Figure 8)
Build-to line
N/S
10-15’*
5-10’
5-10’
Frontage occupancy at build-to line
N/S
50%
minimum**
60%
minimum
75%
minimum
Side yard setback
N/S
5’
0’
0’
Rear yard setback
N/S
5’
0’
0’
FIGURE 5: SITE DEVELOPMENT STANDARDS
*Build-to-line is 5-10' along Saratoga main street frontage overlay zone
**Minimum of 60% frontage occupancy within Saratoga main street frontage overlay zone
Legend
N/S
Not specified
N/A
Not applicable; does not apply
15-217-119
Page: 122
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:13:05 PM
Recommend (25' zone) from 10'-35' see rationale in other comment
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:12:46 PM
Recommend (25' zone) from 5'-30' see rationale in other comment
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:12:30 PM
Recommend 5'-30' (25' zone)
Rationale: The rules should be setting the regulatory floor, not be a prescribing design and as such needs
more flexibility.
This should be expanded to allow enough articulation to recess light wells that can adjust for multi-bedroom
apartment typologies and indented storefronts. If a possible depth of a unit might be as large as 40' on the
large end, then a 25' zone would accommodate most typologies without a variance including in places
where street curvature or other elements create the need to adjust orientation.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:19:28 PM
Strongly recommend removal but if not possible, request uniform 50% in all zones within enlarged 25' wide
zone with occupancy counted for public plazas and amenities.
Designing to overly stringent build-to-line rules and frontage types was the hardest part of making Kaulu
work and the most important issue to revising design rules for Gentry.
Development is stalled in Kalaeloa and past rules (now 13 years old) have not produced significant new
development. The state should be willing to make the changes necessary to help projects move forward if
results have fallen short of the vision while the housing deficit continues to grow.
Author: JacobK Subject: Highlight
Date: 9/8/2025 2:47:37 PM
Recommend Removal, this is counter to the language in 15-215-49(b)(2)(A) to articulate the facade including
"indentation in plane." Max should be as low as possible to allow for the most flexibility in design.
Frontage Occupancy
Encroachment
Side Yard Setback
Rear Yard Setback
Frontage Occupancy
Encroachment
Building
Pedestrian Zone
Expanded
Pedestrian Zone
Alley
Figure 8-A: Illustrative building placement diagram
for residential uses
Alley
A
A
B
B
C
D
A
B
B
C
D
A
A
Roadway
Sidewalk
Roadway
Sidewalk
Roadway
Roadway
FIGURE 8: BUILDING PLACEMENT AND ENCROACHMENTS
Horizontal Distance Requirement
Build-to Line (Front) Encroachments
Awnings
No more than 10’ or 66% of the distance from the building face to the curb,
whichever is less.
Signage
No more than 3’ or 33% of the distance from the building face to the curb,
whichever is less.
Gallery / Arcade
No more than 2' from the face of the encroachment to the curb.
Balcony
No less than 2' from the face of the encroachment to the lot line.
Residential Porch
No less than 4' from the face of the encroachment to the lot line.
Bay Windows and Architectural
Features
No less than 4' from the face of the encroachment to the lot line.
Side and Rear Encroachments
Balconies, Porches, and
Architectural Features
No less than 4' from the face of the encroachment to the lot line.
July 2025
Table 8-C: Encroachments
Build-to Line
Lot Line
The hardscaped area between the
build-to line and lot line is used to
activate the pedestrian realm with
such amenities as cafe seating,
product displays, and bicycle parking.
Building
Pedestrian Zone
Build-to Line
Lot Line
Figure 8-B: Illustrative building placement diagram
for non-residential Uses
15-217-122
Page: 125
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:25:24 PM
Recommend removing all horizontal distance requirements for all encroachments.
Rationale: Why limit awning depth? This only helps to create more shade. Absolutely silly.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:23:00 PM
Recommend removing all horizontal distance requirements for all encroachments.
Rationale: There is no discernible public good created by these rules.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:27:15 PM
Recommend removal sim to others
Balcony depth and porch depth need to be driven primarily by the project brief and structural
considerations.
FIGURE 12
FRONTAGE TYPES
July 2025
15-217-126
Page: 129
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:27:50 PM
Recommend removing all. See rationale in other comments
A single-unit structure, detached on both
sides, located on a private single-family
lot. The unit may vary in size and can be
complemented by an auxiliary building for
storage, covered parking, or an accessory
dwelling. It is the least dense housing
typologies.
A. Pedestrian Access
1. The principal entrance to the principal building shall
be directly from the street, through the front yard.
2. The principal entrance to the accessory dwelling shall
be accessible directly from a frontage line, through
the side yard setback of the principal building or from
an alley.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
C. Open Space
1. At least twenty per cent of the lot area shall be
provided as open space. At least one-third of this
requirement shall be provided at-grade.
D. Frontage
1. Permissible frontage types are: Lanai and Front
Yard (Figure FT.1), Stoop (Figure FT.2), and Dooryard
(Figure FT.3).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches or balconies, or plane break
that cumulatively occupy at least ten per cent of the
facade.
2. Principal buildings shall be one- or two-stories in
height.
3. Accessory dwellings located above garages shall be
limited to one story above the garage with a 12-foot
maximum floor-to-floor height.
4. Accessory dwellings located at grade shall be limited
to one story with 12-foot maximum floor-to-floor
height.
5. Accessory dwellings shall have a maximum floor area
of 800 square feet and shall not exceed fifty per cent
of the principal building’s floor area.
Figure BT.1-1 Front Yard House, illustrative
axonometric view
FIGURE BT.1 FRONT YARD HOUSE
Figure BT.1-2 Front Yard House, illustrative plan view
Prinicipal
Prinicipal
Building
Building
Prinicipal
Building
Accessory
Accessory
Dwelling
Dwelling
Unit*
Unit*
Accessory
Dwelling
Unit
July 2025
15-217-127
Page: 130
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:32:25 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:30:58 PM
Remove
A single-unit structure, detached on one
side, located on a private single-family
lot. The unit may vary in size and can be
complemented by an auxiliary building for
storage, covered parking, or an accessory
dwelling. It is one of the least dense housing
typologies.
A. Pedestrian Access
1. The entrance shall be directly from the street, through
the side yard, along the elevation facing the side lot
line.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
3. If driveway is along the side yard, the driveway should
have a permeable surface, such as pavers.
C. Open Space
1. Open space shall be located along the side yard with
an area of no less than twenty per cent of the lot.
D. Frontage
1. Front facades shall have a minimum fenestration of
fifteen per cent in order to prevent blank walls facing
the street.
2. Permissible frontage types are Lanai and Front Yard
(Figure FT.1), Stoop (Figure FT.2), and Dooryard
(Figure FT.3).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches or balconies, or plane break
that cumulatively occupy at least five per cent of the
facade.
FIGURE BT.2 SIDE YARD HOUSE
Figure BT.2-1 Side Yard House, illustrative
axonometric view
Figure BT.2-2 Side Yard House, illustrative plan view
July 2025
15-217-128
Page: 131
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:31:30 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:32:09 PM
Remove.
A multi-unit, continuous structure
comprising several housing units, each
located on private lots with independent
rear yards and separate entrances. Unit sizes
may vary and can be complemented by a
stacked residential addition.
Covered parking, storage, playgrounds,
and other amenities can be provided in
shared communal spaces, protected by the
boundary formed by the row housing. This
is a mid-density typology that fosters social
interaction and creates an urban streetscape.
A. Facade Width
1. Each townhouse may be a maximum of 26-feet wide,
except that the facade of a townhouse on block
corners may be up to 40-feet wide.
2. A maximum of ten attached townhouses per facade
string is allowed.
B. Pedestrian Access
1. The entrance shall be accessible from the street,
through the frontage line.
C. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47,
parking and loading.
D. Open Space
1. At least twenty per cent of the lot area shall be
provided as open space.
2. The open space may be located on patios or decks, or
on a roof garden.
3. Private patios and balconies are allowed in any yard.
E. Frontage
1. Permissible frontage types are Lanai and Front Yard
(Figure FT.1), Stoop (Figure FT.2), and Terrace (Figure
FT.6).
F. Building Massing
1. At least one encroaching element, such as a lanai or
balcony, or a plane break, shall occupy at least fifteen
per cent of the front facade.
2. In a three-story building, a two-story townhouse can
be stacked over a separate ground floor dwelling.
FIGURE BT.3 TOWNHOUSE
Figure BT.3-1 Townhouse, illustrative axonometric
view
Figure BT.3-2 Townhouse, illustrative plan view
July 2025
15-217-129
Page: 132
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:33:29 PM
Remove.
Rationale: Let the unit layout drive the depth. There is absolutely no reason for the state to interject here.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:33:57 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:34:11 PM
Remove
A residential structure containing two,
three, or four housing units, arranged either
side-by-side or stacked over two floors.
The units may share common spaces such
as a backyard, parking area, lanai, laundry,
or storage. This is a mid-density typology
compatible with a more suburban lifestyle,
offering a convenient way to accommodate
diverse types of ʻohana while maintaining a
degree of independence.
A. Pedestrian Access
1. The entrance shall be directly accessible from the
street, through the frontage line.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
C. Open Space
1. Each ground floor unit shall have at least 150-square
feet of private or semi-private yard space in the rear
yard, side yard, or integrated into the building area
through courtyards and gardens. One-third of this
requirement shall be provided at-grade.
2. Units above the ground floor may have access to roof
garden space for passive and active recreation, patios,
decks, and courtyards.
D. Frontage
1. Permissible frontage types are: Lanai and Front Yard
(Figure FT.1), Stoop (Figure FT.2), Forecourt (Figure
FT.4), and Terrace (Figure FT.6).
E. Building Massing
1. A minimum of fifteen per cent of the front facade
shall be occupied by at least one encroaching
element, such as a lanai or balcony, or a plane break.
FIGURE BT.4 DUPLEX, TRIPLEX, AND QUADPLEX
Figure BT.4-1 Duplex, Triplex, and Quadplex,
illustrative axonometric view
Figure BT.4-2 Duplex, Triplex, and Quadplex,
illustrative plan view
July 2025
15-217-130
Page: 133
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:35:47 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:36:01 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:36:10 PM
Remove
A multi-unit, continuous structure
comprising several housing units, on a
common or separate private lots, and
separate entrances. Unit sizes and types
may vary and can be complemented by a
stacked residential addition or subdivisions.
Parking, storage, and other amenities can be
provided in shared communal spaces. This
is a mid-density typology that fosters social
interaction and creates an urban streetscape.
A. Facade Width
1. Each flex-loft can be a maximum of 30-feet wide
2. A maximum of ten attached flex-loft buildings per
facade string is allowed.
B. Pedestrian Access
1. The entrance shall be accessible directly from the
street, through the Frontage Line.
C. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
D. Open Space
1. At least twenty per cent of the lot area shall
be provided as open space. One-third of this
requirement shall be provided at-grade.
E. Frontage
1. Permissible frontage types are: Lanai and Front Yard
(Figure FT.1), Stoop (Figure FT.2), Forecourt (Figure
FT.4), Shopfront (Figure FT.5), Terrace (Figure FT.6),
Raised Terrace (Figure FT.7), and Gallery (Figure FT.8)
F. Building Massing
1. Facades shall have at least one encroaching element,
such as a lanai or balcony, or plane break occupying at
least fifteen per cent of the facade.
2. Building elevations abutting side yards shall provide at
least one horizontal plane break of at least three feet,
and one vertical break of at least two feet.
FIGURE BT.5 FLEX-LOFT
Figure BT.5-1 Flex-Loft, illustrative axonometric view
Figure BT.5-2 Flex-Loft, iIllustrative plan view
July 2025
15-217-131
Page: 134
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:36:31 PM
Remove; see comment on townhouses.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:36:43 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:36:55 PM
Remove
A one- or two-story open-span structure
designed for light industrial or commercial
use, with flexible interior layouts. This low-
density typology, typical for a suburban
context, supports operational efficiency and
allows a wide integration between closed,
covered, and open spaces.
A. Pedestrian Access
1. The entrance shall be accessible from the street,
through the Frontage Line.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
C. Open Space
1. For lots between 10,000 and 20,000 square feet, the
minimum open space is proportional to the lot size
and provided in Table BT.6-1.
2. For lots greater than 20,000 square feet, at least
twenty per cent of the lot area shall be provided as
open space. One-third of this requirement shall be
provided at-grade.
3. Permeable-pavement parking areas can count
towards the open space requirement for this
building type.
D. Frontage
1. Permissible frontage types are Lanai and Frontyard
(Figure FT.1), Stoop (Figure FT.2), Dooryard (Figure
FT.3), Shopfront (Figure FT.5), Terrace (Figure FT.6),
Raised Terrace (Figure FT.7), and Gallery (Figure
FT.8).
FIGURE BT.6 INDUSTRIAL BARN
Figure BT.6-1 Industrial Barn, illustrative axonometric
view
Figure BT.6-2 Industrial Barn, illustrative plan view
Table BT.6-1 Minimum Open Space
Lot Area
(square feet)
Minimum Open Space
(percent of lot area)
15,001 to 20,000
10%
10,001 to 15,000
5%
less than 10,000
0%
July 2025
15-217-132
Page: 135
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:38:36 PM
This is too typology specific and hard to follow
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:37:11 PM
Remove
A continuous structure comprising several
housing units, retail or industrial spaces, on
common or separate private lots, accessible
from one or multiple shared courtyards that
serve the units’ access directly or through
lobbies.
The open courtyard can be designed as a
“safe space” with services for the community
such as covered parking, storage, swimming
pools, and gardens. This is a mid- to
high-density typology that fosters social
interaction and creates layers of privacy.
A. Pedestrian Access
1. Ground floor courtyard(s) shall be accessible from the
street through the frontage line and through an open
or covered passageway.
2. Raised courtyards shall be accessed through a lobby,
accessed directly from the principal frontage.
3. The principal entrance to each ground floor unit at the
principal frontage shall be directly from the frontage
line, or from a courtyard.
4. Access to units above raised courtyards shall be
through a lobby with direct access to each courtyard.
Upper floor exterior corridors should be less than
25-feet in length. Longer corridors should be
enclosed.
5. All retail spaces should be accessed from a ground
floor, single-tenant entry along a street, courtyard, or
passageway.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
3. If accommodated in an above-ground garage, parking
shall be concealed from view at the public frontage
through a liner of habitable space.
C. Open Space
1. At least twenty per cent of the lot area shall be
provided as open space in the form of one or more
courtyards open to the sky.
D. Frontage
1. Permissible frontage types are Lanai and Frontyard
(Figure FT.1), Stoop (Figure FT.2), Shopfront (Figure
FT.5), Terrace (Figure FT.6), and Gallery (Figure FT.8).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches or balconies, or plane break
that cumulatively occupy at least ten per cent of the
facade.
FIGURE BT.7 COURTYARD
Figure BT.7-2 Courtyard, illustrative plan view
Figure BT.7-1 Courtyard, illustrative axonometric view
July 2025
15-217-133
Page: 136
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:40:26 PM
Remove. Absurdly specific.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:43:30 PM
Remove - very hot in Kalaeloa shade should be encouraged.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:40:19 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:40:36 PM
Remove
A typology that is typical for an industrial
building, possibly complemented by
commercial spaces or offices, in an urban
context. It is usually a single development
with an open frontage facing the main street,
which provides access. The side facades and
rear of the volume, located at the center
of the block, contain service spaces such as
parking, storage, or manufacturing.
A. Pedestrian Access
1. Entrances to upper floors shall be accessed through
an interior lobby, which is accessed directly from the
street.
2. All retail spaces should be accessed from a ground
floor, single-tenant entry along a street, courtyard, or
passageway.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
3. If accommodated in an above-ground garage, parking
shall be concealed from view at the public frontage
through a liner of habitable space for at least the first
21 feet of building height; service streets and alleys
excluded.
4. Above-ground garages above 21 feet in height shall
be screened from view at the public frontage by
landscaping, green screens, or cladding, or concealed
from view through a liner of habitable space.
C. Open Space
1. At least twenty per cent of the lot area shall be
provided as open space and shall be open to the
sky. One-third of this requirement shall be provided
at-grade.
D. Frontage
1. Permissible frontage types are Lanai and Frontyard
(Figure FT.1), Stoop (Figure FT.2), Dooryard (Figure
FT.3), Shopfront (Figure FT.5), Terrace (Figure FT.6),
and Gallery (Figure FT.8).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches or balconies, or plane break
that cumulatively occupy at least ten per cent of the
facade.
FIGURE BT.8 URBAN BLOCK
Figure BT.8-2 Urban Block, illustrative plan view
Figure BT.8-1 Urban Block, illustrative axonometric
view
Garage
Garage
July 2025
15-217-134
Page: 137
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:42:03 PM
Remove - very hot in Kalaeloa shade should be encouraged.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:40:57 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:40:48 PM
Remove
A continuous structure comprising single or
multiple housing units, retail, or industrial
spaces on common or separate private lots.
It is usually a single development, accessible
from one or multiple shared lobbies.
As a lei, the frontage facing the main street,
the side facades and rear of the volume, are
open and host active functions. The center
of the block contains service spaces such as
parking, storage, or manufacturing. This mid-
to high-density typology activates the street
while hosting service spaces.
A. Pedestrian Access
1. Entrances to upper floors shall be accessed through
an interior lobby, accessed directly from the street.
2. All retail spaces should be accessed from a ground
floor, single-tenant entry along a street, courtyard, or
Passageway.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
3. If accommodated in an above-ground garage, parking
shall be concealed from view at the public frontage
through a liner of habitable space on at least three
sides of the building. Where exposed to the street,
above-ground garages shall be screened from view at
the public frontage by landscaping, green screens, or
cladding.
C. Open Space
1. At least twenty per cent of the lot area shall be
provided as open space and shall be open to the
sky. One-third of this requirement shall be provided
at-grade.
2. Each open space shall have a minimum dimension of
thirty feet on any one side.
3. Projections into the open space are permitted on
all sides of the space, provided that the thirty-foot
minimum dimension is maintained.
D. Frontage
1. Permissible frontage types are Lanai and Frontyard
(Figure FT.1), Stoop (Figure FT.2), Shopfront (Figure
FT.5), Terrace (Figure FT.6), Raised Terrace (Figure
FT.7), and Gallery (Figure FT.8).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches or balconies, or plane break
that cumulatively occupy at least ten per cent of the
facade.
FIGURE BT.9 LEI BUILDING
Figure BT.9-2 Lei Building, illustrative plan view
Figure BT.9-1 Lei Building, illustrative axonometric
view
Garage
Garage
July 2025
15-217-135
Page: 138
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:44:24 PM
Remove - very hot in Kalaeloa shade should be encouraged.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:45:34 PM
Remove - there is no justification for enshrining this in law.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:45:43 PM
Remove
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:45:58 PM
Remove
FIGURE BT.10 TROPICAL URBAN COURT
A single- or multi-unit structure, detached
on one side, located on a single or multi-
family lot. The unit may vary in size and can
be divided horizontally or vertically into
multiple apartments or retail spaces that
are accessible from a habitable shared lanai.
It can be complemented by an auxiliary
building for storage or covered parking.
This is a mid- to high-density typology that
fosters social interaction, offers an open
covered space for encounter, and creates
layers of privacy.
A. Pedestrian Access
1. Circulation to all upper floors shall be through an
exterior corridor, lobby, or courtyard.
2. All retail spaces should be accessed from a ground
floor, single-tenant entry along a street, courtyard, or
passageway.
B. Parking Design and Location
1. Where provided, parking shall be located in the third
layer (See Figure 9).
2. Parking access shall be as per section 15-215-47
(parking and loading).
C. Open Space
1. At least twenty per cent of the lot area shall
be provided as open space. One-third of this
requirement shall be provided at-grade.
2. Open space shall have a minimum dimension of thirty
feet on any one side.
3. Projections into the open space are permitted on
all sides of the space, provided that the thirty-foot
minimum dimension is maintained.
D. Frontage
1. Permissible frontage types are: Lanai and Front Yard
(Figure FT. 1), Stoop (Figure FT.2), Dooryard (Figure
FT.3), Shopfront (Figure FT.5), Terrace (Figure FT.6),
Raised Terrace (Figure FT.7), and Gallery (Figure FT.8).
E. Building Massing
1. Front facades shall have at least one encroaching
element, such as porches, balconies, or a plane break
that cumulatively occupy at least ten per cent of the
facade.
Figure BT.10-2 Tropical Urban Court, illustrative plan
view
Figure BT.10-1 Tropical Urban Court, illustrative
axonometric view
July 2025
15-217-136
Page: 139
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:46:54 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:46:35 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:46:14 PM
Remove.
Author: JacobK Subject: Highlight
Date: 9/8/2025 3:46:22 PM
Remove.
Hunt Development Group, LLC
737 Bishop St., Suite 2750
Honolulu, HI 96813
808-585-7900
September 16, 2025
Craig Nakamoto, Executive Director
Via Email Only
Hawaiʻi Community Development Authority
547 Queen Street
Honolulu, Hawaiʻi 96813
Email: dbedt.hcda.contact@hawaii.gov
Re:
Comments to HCDA’s Kalaeloa Master Plan and Rules Amendments dated July 2025
Dear Mr. Nakamoto,
The following comments are made on behalf of Hunt Communities Hawaii LLC, Kalaeloa Ventures, LLC (and its
successors int interest), HCHP1 LLC, VA Aloha, LLC, Wakea Garden Apartments, LLC, KVP6AC, LLC and KVP11,
LLC (collectively, "Hunt"), owners or lessees1 of parcels located within the Kalaeloa Community Development
District (“KCDD”).
Hunt is in favor of the new Kalaeloa Master Plan and Rules being approved. The adoption of clear, finalized
rules is critical for effective planning and development to occur in Kalaeloa. When rules remain in draft form,
it is challenging to move forward with development, as the standards remain uncertain. Clear and predictable
rules that facilitate the creation of homes and commercial opportunities for local families and businesses are
fully aligned with Hunt’s objectives in Kalaeloa. Since the plan and rule amendment process began in 2020, we
have actively participated in numerous work sessions with HCDA and appreciate the collaborative and
transparent approach that has characterized this process.
Please find our comments on the July 2025 Kalaeloa Master Plan and Kalaeloa Rules described below,
respectively.
Kalaeloa Master Plan (Attachment A)
Hunt supports HCDA’s vision for the Kalaeloa Master Plan, which aims to create social value, foster economic
development and employment, and encourage more housing through smart planning and balanced
development. We appreciate the plan’s increased flexibility, which takes into account the urban infill nature of
redeveloping a former Naval Air Station, thus providing a means for an incremental approach and the ability to
respond to market conditions as Kalaeloa takes shape. Of the comments listed in Attachment A, we would like
to reiterate two key points from our August 6, 2024 comment letter concerning HCDA’s July 2024 Kalaeloa
Master Plan and Rules Amendments, specifically regarding a) infrastructure financing and b) site drainage.
1 Under that certain Real Estate Ground Lease for Barbers Point made by a Hunt affiliate and the United States of America,
Department of the Navy, dated October 6, 2008, as amended.
Page 2 of 4
1. Infrastructure Financing: Hunt appreciates HCDA’s reference to the ongoing Infrastructure Master Plan
and acknowledges its leadership in regional infrastructure planning. We look forward to reviewing the
updated plan and would like to emphasize the importance of using current data and ensuring fair
infrastructure financing. The cost and availability of infrastructure remain major barriers to housing in
Kalaeloa. Continued progress will require strong support from all levels of government to ensure
resources are distributed equitably. The 2006 Kalaeloa Master Plan estimated infrastructure costs to
be approximately $470 million, a twenty-year figure that has likely increased significantly. Given the
scale of investment and the area’s diverse land ownership, it is essential that federal and state agencies
contribute their fair share, whether through direct funding or in-kind support such as Payment in Lieu
of Taxes (PILT)2. We respectfully request that the Master Plan include language recognizing the
importance of equitable infrastructure financing and affirming HCDA’s commitment to securing
contributions from federal and state agencies.
2. Drainage: Hunt appreciates HCDA’s revisions to the drainage description3 which clarify that not all
runoff currently received by the former NASBP Coral Pit located on Hunt land is accounted for or
approved. However, we note that similar references on page 93 of the July 2025 Draft KMP lack this
clarifying language. We request that HCDA add the same clarification to the section on page 93 to
ensure consistency and accuracy. For the record, Hunt reiterates that it is not aware of any recorded
easements or executed agreements facilitating drainage to parcels identified as TMK (1) 9-1-13:093
and TMK (1) 9-1-13:094, which are privately owned by Hunt and intended for economic development.
We object to any implication in the Master Plan Draft that such agreements exist.
Additional comments to the July 2025 Draft KMP are included as Attachment A.
Kalaeloa Rules (Attachment B)
There are many positive elements in the current draft rules some of which include the removal of minimum
FAR requirements, the introduction of a Renovation Permit and right-sizing of the permitting process, updates
to the Regulating Plan (Figure 4) and Land Use table (Figure 7), and the continued allowance for light industrial
uses which support job creation and provide space for these businesses to continue fueling economic growth
in the region.
However, there are several comments that remain outstanding and are outlined in Attachment B. We continue
to discuss these with staff and look forward to them being satisfactorily addressed so that Hunt can provide
strong support at the November hearing date. Of these, our high-priority comments are as follows:
1. Restrictions on fence heights and materials for industrial uses: Hunt requests that HCDA review and
revise the regulations on fence heights and allowable materials for industrial properties. Security and
safety are paramount for industrial tenants and operations, and the current restrictions limit the ability
to adequately secure sites. Lower fences increase the risk of unauthorized access and theft, and create
a safety issue for the public, particularly in areas where materials or equipment are stored. Without
2 https://www.doi.gov/sites/default/files/documents/2025-06/2025nationalsummarypilt062025-508.pdf
3 July 2024 KMP (page 28) and July 2025 KMP (page 30)
Page 3 of 4
this flexibility, properties may face increased security risks, reduced market competitiveness, and a
higher likelihood of needing variances, which can delay projects and increase costs.
2. ʻEwa Battlefield Overlay language: Hunt appreciates the thoughtful edits made to the ʻEwa Battlefield
Overlay section in the July 2025 draft and thanks HCDA for its ongoing engagement with Hunt, the
Navy, and historic partners. However, two key issues remain. Hunt recommends that the designated
preservation areas within the overlay zone be limited to those previously discussed and agreed upon
with stakeholders, specifically the compass rose, swimming pool, and the extant portion of the warm-
up mat. In addition, we request the removal of references to Philippine Sea Street, as it is not currently
designed to City & County standards and may require realignment in the future. Expanding
preservation requirements beyond these areas or including unclear references can create uncertainty
for future development and may conflict with infrastructure planning and site access.
3. Historical and cultural sites language: Hunt requests that the rules governing historical and cultural
sites be revised to align with the established review process under HRS §6E-42 and HAR §13-284-1.
Specifically, the requirement for State Historic Preservation Division (SHPD) review should begin after
a permit application is submitted, not before. This change will clarify the sequence of review, reduce
confusion, and ensure compliance with state law. Additionally, we ask that the language regarding
developer responsibilities for maintaining historic and cultural sites be clarified to reflect reasonable
standards for upkeep, consistent with the age and condition of the properties.
4. Validity period of Conditional Use of Vacant Land and Renovation Permits: Hunt requests that HCDA
extend the allowable duration for certain permit types to better reflect the realities of development in
Kalaeloa. For the Conditional Use of Vacant Land permit, we recommend that the permit remain
effective until the area is redeveloped in conformance with the underlying transect zoning. This permit
has proven to be a valuable tool for reactivating Kalaeloa properties during interim periods, before
market conditions make redevelopment feasible. This flexibility helps bring people, jobs, and economic
activity to the district ahead of full redevelopment. For Renovation Permits, we recommend allowing
time extensions, as permitting and other delays often exceed the one-year approval period. Providing
the option for extensions will help ensure that projects are not unnecessarily stalled due to
circumstances outside the applicant’s control.
5. Consolidate Light Industrial and Warehousing Land Uses: Hunt requests that warehousing be included
under the broader category of “light industrial” in the Land Use Table, rather than having a separate
row. Warehousing is a typical component of light industrial operations and is already cited as an
example within HCDA’s definition of “light industrial.” Creating a separate category for warehousing
could inadvertently restrict flexibility and limit the ability to respond to market needs.
6. Proposed Warehouse Overlay Zone: Hunt requests that HCDA include a new section establishing
development standards for a Warehouse Overlay Zone. This addition is necessary to address the
recent determination by the Keeper of the National Register of Historic Places, which found that
eleven WWII-era storage buildings are eligible for listing as contributing resources to a potential
warehouse historic district. By adopting clear standards, HCDA can help guide the preservation,
interpretation, and redevelopment of these historic resources. This will ensure that the buildings are
July 31, 2025
KALAELOA
MASTER PLAN
DRAFT
Hawaii Community
Development Authority
Attachment A: KMP (July 2025) with Hunt Comments
Summary of Comments on Comments - Hunt
20250916.pdf
Page: 5
Author: Hunt
Subject: Rectangle
Date: 9/2/2025 10:53:24 AM
Attachment A: KMP (July 2025) with Hunt Comments
8
KALAELOA MASTER PLAN
DRAFT
1.0 Plan Overview
1.0.1 Background of the Master Plan
Amendment
In June 2002, Governor Benjamin Cayetano
signed into law Senate Bill 2702 (becoming
Act 184) which transferred responsibility for
Kalaeloa from the Naval Air Station Barbers
Point (NAS Barbers Point) Redevelopment
Commission to the Hawai‘i Community
Development Authority (HCDA). Pursuant
to Act 184, the Kalaeloa Community
Development District (KCDD) was established,
comprising approximately 3,700 acres of land
that included all of the land within the former
NASBP (see Figure 1-1).
Hawai‘i Revised Statutes (HRS) Chapter 206E
required that a master plan be developed
following establishment of the KCDD and
the original Kalaeloa Master Plan (Plan) was
adopted by the Authority in 2006. The Plan
recognized a unique opportunity to redevelop
the former NAS Barbers Point based on a
strategic vision of Kalaeloa as a “Center for
Excellence” or Wahi Hoʻokela within the ‘Ewa
region of O‘ahu. To implement this vision,
the HCDA adopted a set of core values and
principles to guide the redevelopment of
Kalaeloa. The planning framework, written
into the 2006 Plan, remains valid and is
reiterated in this amended Master Plan.
In adopting the 2006 Plan, there was full
acknowledgement that the redevelopment
process would be complex, including the
likelihood of successes and setbacks along the
way and unpredictable events and fluctuating
market cycles. Since then, the rail line is under
construction with operations underway in the
western half of the system; major housing and
commercial projects have been completed
throughout the ‘Ewa Plain even as the high
cost of housing remains a top concern; and
stewardship of cultural resources has moved
forward with establishment of the ‘Ewa Plain
Battlefield Memorial and Kalaeloa Heritage
Park.
This Master Plan Amendment has been
undertaken with particular attention to the
following objectives:
y Identify relevant changes from 2006 to
the present within and surrounding the
KCDD
y Identify favorable and detrimental
conditions to redevelopment in the KCDD
y Refresh the information and data in the
Master Plan and coordinate with the
amendments to the Administrative Rules
y Update the Regulating Plan which
establishes the pattern of land uses
within the KCDD and serves as the official
land use map to be implemented by the
Administrative Rules
y Reevaluate priorities to inform public
investments over a 20-year planning
horizon
1.0.2 The Kalaeloa Master Plan
In 2020, the HCDA began the process of
amending the 2006 Plan to respond to
current and anticipated challenges facing
redevelopment and chart an economically
feasible and realistic course over a 20-year
timeframe.
The planning team reviewed the 2006 Plan and
Urban Design Guidelines along with ancillary
plans, studies, and other reference documents
completed during the intervening period. The
planning team also conducted interviews with
stakeholders, met with government agencies,
and held community workshops to receive
feedback on various planning concepts.
The amended Master Plan was written to distill
this information into a planning document
that provides an overview of the opportunities
and vision for Kalaeloa and explains how they
are linked to the implementing Administrative
Rules. In this regard, the Master Plan is
organized in the following manner:
y Setting the Stage - Understanding the
Pieces: Chapter 1 reviews the history
of Kalaeloa beginning with the closure
of NASBP and past planning efforts.
Chapter 1 also includes a description
of the current setting of Kalaeloa in
terms of land ownership, land uses,
schools, transit, infrastructure, physical
characteristics, protected species and
Page: 12
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 11:14:21 AM
listing of the 'Ewa Plain Battlefield in the National Register of Historic Places and establishment of the
Kalaeloa Heritage Park.
24
KALAELOA MASTER PLAN
DRAFT
Landowner
Land Area
(acres)
Percent
Federal
Federal
782.7
21.2%
Federal (pending transfer to
unidentified parties)
213.0
5.8%
State of Hawaii
Department of Hawaiian Home
Lands
552.5
15.0%
Department of Education
14.5
0.4%
Department of Transportation -
Airports Division
808.7
21.9%
Hawaii Community Development
Authority
161.9
4.4%
Hawaii Public Housing Authority
12.3
0.3%
University of Hawaii
2.4
0.1%
City of County of Honolulu
Board of Water Supply
20.0
0.5%
Department of Parks and Recreation
395.6
10.7%
Various
Right-of-way
179.5
4.9%
Landowner
Land Area
(acres)
Percent
Private Landowners
Aloha Properties Unlimited
0.9
0.0%
Eagle River Investors Hawaii LLC
9.5
0.3%
Gentry Kalaeloa LLC
21.3
0.6%
Hawaii Conference of 7th-Day
Adventists
1.2
0.0%
Henkels and McCoy Inc
2.0
0.1%
Hunt Communities Hawaii (includes
pending transfers)
396.1
10.7%
Kaimana Kalaeloa Owner LLC
17.7
0.5%
Kalaeloa Water Company LLC
3.7
0.1%
Mahana Kalaeloa Owners LLC
15.9
0.4%
Makai Kalaeloa Owner LLC
44.5
1.2%
U.S. VETS
5.1
0.1%
VA Aloha LLC
9.5
0.3%
Wakea Garden Apartments LLC
25.0
0.7%
Total Land Area
3,695.7
100.0%
Data as of 4/30/24; Source: City and County of Honolulu GIS
Table 1-2: Kalaeloa Land Ownership Detail
Page: 28
Author: Hunt
Subject: Highlight
Date: 9/1/2025 8:24:31 PM
We recommend HCDA review and update this table before the Masterplan is adopted.
Author: Hunt
Subject: Sticky Note
Date: 9/1/2025 2:25:36 PM
We request the area for Hunt Communities Hawaii, VA Aloha LLC, and Wakea Garden Apartment LLC
be combined, and represented under 'Hunt Companies, Inc.'
Author: Hunt
Subject: Sticky Note
Date: 9/2/2025 11:24:40 AM
When comparing against the FY26 Land Owner Assessment Table 2, there appears to be some
outdated information. https://dbedt.hawaii.gov/hcda/files/2025/04/2-2025.05.07-Staff-Report-for-
Kalaeloa-Landowner-Assessment_final.pdf
DRAFT
25
KALAELOA MASTER PLAN
HDOT-A
FAA
DPR
Navy
Aloha Properties
Unlimited LLC
USPS
US Vets
HCDA
Cloudbreak
UH
Hawaii Conference of
Seventh-Day Adventists
Gentry
VA Aloha
DOE
Mahana Kalaeloa
Owners LLC
Kaimana
Kalaeloa
Owner LLC
Eagle River
Investors
Hawaii LLC
HPHA
Makai Kalaeloa
Owner LLC
Coast Guard
Henkels and McCoy, Inc
BWS
HCDA
HCDA
HCDA
Kalaeloa Water Company
Navy
Navy
USFWS
Kapolei Infrastructure LLC
DHHL
DHHL
DPR
DHHL
DHHL
DHHL
DHHL
DHHL
Hunt
Hunt
Hunt
HIANG
DPR
Federal
DHHL
HDOT-Airports
HCDA
Other State of Hawaii
City and County of
Honolulu
Hunt Development
Corporation
Other landowner
Pending Transfer
Ewa Plain Battlefield
Kalaeloa District
Boundary
Legend
July 2024
Midway
Midway
Lexington
Lexington
Yorktown
Yorktown
Saratoga Ave
Saratoga Ave
Enterprise
Enterprise
Shangrila
Shangrila
Midway
Midway
Coral Sea Rd
Coral Sea Rd
Malakole St
Malakole St
Roosevelt Ave
Roosevelt Ave
Boxer Rd
Boxer Rd
Copahee Ave
Copahee Ave
Hornet Ave
Hornet Ave
Franklin
Franklin
Kalaeloa Blvd
Kalaeloa Blvd
Tripoli
Tripoli
Essex Rd
Essex Rd
Geiger Rd
Geiger Rd
‘ola‘i
‘ola‘i
Fort Barrette Rd
Fort Barrette Rd
Kamokila Blvd
Wakea
Wakea
Kapolei Pkwy
Kapolei Pkwy
Tulagi Ave
0
0.5 Miles
0.25
Figure 1-6: Kalaeloa Land Ownership, 2024
Page: 29
Author: Hunt
Subject: Highlight
Date: 9/1/2025 2:30:46 PM
We recommend HCDA review and update this map before the Masterplan is adopted. In the legend, please
change Hunt Development Corporation to Hunt Companies, Inc. Additionally Parcel 12 is pending transfer,
VA Aloha is owned by Hunt, P1 increment 3 is Gentry.
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 1:05:19 PM
Note that the HCDA legend color should be pink, BWS is not CCH, and US Vets & Cloudbreak should be
reviewed.
28
KALAELOA MASTER PLAN
DRAFT
1.2.2.3 City and County of Honolulu
1.2.2.3.a
Board of Water Supply – Desalination
Facility
The Honolulu Board of Water Supply (BWS)
acquired 21 acres of land in the southwest corner
of Kalaeloa through a public benefit conveyance
for the purpose of developing a reverse osmosis
desalination plant to supplement O‘ahu’s
potable water supply. The BWS has entered into
an agreement to design, build, operate, and
maintain a facility that will deliver 1.7 mgd of
potable water for industrial users at Campbell
Industrial Park. An adjoining 10-acre parcel has
also been identified for transfer to the BWS.
1.2.2.3.b
Department of Parks and Recreation
During the BRAC process, the City expressed
interest in receiving approximately 485 acres
through a public benefit conveyance for the
establishment of beach parks, community parks
and other recreation facilities. The park areas
include one parcel in the downtown area, four
parcels east of the airport runway and six parcels
along the coastline. Conveyances of all of these
parcels were completed in 2024. The Department
of Parks and Recreation is also under a licensing
agreement with the Navy for two baseball parks
(at Pointer Field) and one beach park in Kalaeloa.
1.2.2.4 Private Entities
1.2.2.4.a
HUNT Companies
Hunt Companies currently has—or is expecting
transfer of—fee interest in approximately 396
acres in Kalaeloa, making it the single largest
private developer within the Kalaeloa District,
and second only to DHHL with approximately 552
acres of developable land. The Hunt properties
form a swath across the northern edge of the
District and span the District’s eastern and
western boundaries. Many of the parcels front
Roosevelt Avenue and/or Saratoga Avenue, two
major thoroughfares. Because Hunt’s holdings
comprise large, contiguous parcels of land,
future development and redevelopment offers
the potential for holistic planning and design.
To date, Hunt has developed the Kalaeloa
Professional Center and VA Clinic, which are
major employment centers, and retrofitted
several Navy-built structures for residential,
commercial, and recreational uses.
1.2.2.4.b
Blackstone Group (Kaimana Kalaeloa
Owner) - Orion, Makai, and Orion
Park Housing
In April 2016, Blackstone Group acquired the
fee interest in three housing areas at Kalaeloa,
including: Orion, Makai, and Orion Park. Orion
encompasses a 13-acre site that contains 116
multi-family units. Makai covers a 43-acre parcel
and contains 280 multi-family units. Orion Park
housing is a 16-acre parcel and contains 120
multifamily units.
1.2.2.5 Unallocated Land
During the BRAC process, several government
agencies withdrew their interest in receiving
lands in Kalaeloa. The U.S. Fish and Wildlife
Service (USFWS) withdrew interest in three of the
four parcels it was designated to receive. These
parcels, totaling approximately 200 acres, are
relatively undeveloped and contain wetlands and
habitat for endangered plant and bird species
and archaeological sites. The HDOT-Airports and
the University of Hawai‘i expressed interest in
receiving a parcel, leaving the third and largest
parcel (about 146 acres) unallocated.
Similar undeveloped parcels in the eastern
portion of Kalaeloa, totaling 135 acres were
previously designated for public benefit
conveyance to the State Department of Land and
Natural Resources (DLNR) to HCDA. However,
the State later withdrew their interest. Two of
the parcels were previously used by the Navy as
skeet and trap ranges. As a result, the surface
soils were heavily contaminated with lead and
were subsequently removed and encapsulated
in the Navy’s landfill parcel in the western
portion of Kalaeloa. These parcels also contain
archaeological sites and have been designated as
a critical habitat for the endangered ʻakoko plant.
Page: 32
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 2:34:52 PM
Recommend updating the acreage to align with Table 1-2: Kalaeloa Land Ownership Detail.
Author: Hunt
Subject: Cross-Out
Date: 9/2/2025 11:01:25 AM
The baseball parks are within Hunt's property and are not leased to the Department of Parks and Recreation
DRAFT
29
KALAELOA MASTER PLAN
Kapolei Pkwy
Kalaelo a Blvd
Kamokila Blvd
Roosevelt Ave
Wakea St
Geiger Rd
Roosevelt Ave
Saratoga Ave
Coral Sea Rd
Fort Barrett Rd
Enterprise St
N
Keoneula Blvd
Malakole St
Tripoli Rd
1.2.3 Existing Infrastructure
This section describes conditions of existing
infrastructure and challenges to the
development of Kalaeloa. Readers should
note that an infrastructure master plan for
the Kalaeloa CDD, expected at the end of
2025, will contain additional information
about existing infrastructure systems as well
as proposed improvements to meet projected
future demand.
1.2.3.1 Streets
There are more than 20 miles of existing
roadways at Kalaeloa in various states of
repair, many lacking sidewalks. Through a
Memorandum of Agreement (MOA) between
the former Barbers Point Redevelopment
Commission, the State DOT, and the City,
the major roadways within Kalaeloa were
transferred from the Navy as shown in Figure
1-7 and form the backbone of the District.
1.2.3.2 Public Transportation
Public transportation in the ‘Ewa region is
primarily provided by the City’s “TheBus”
system of fixed routes (trunk, local, and
express), transit hubs, and the HandiVan
special services (see Figure 1-8).
A transit hub to the north of Kalaeloa in
Kapolei is connected by TheBus to the transit
hub in ‘Ewa, with a limited number of transit
Figure 1-7: 2006 Master Plan Existing and Proposed streets
Page: 33
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 2:41:37 PM
Legend is missing.
30
KALAELOA MASTER PLAN
DRAFT
LEGEND
416 - Kapolei Circulator
West Oahu / Farrington Hwy Section
413 - Campbell Industrial Park
Every 40 mins
Every 60 mins
Every 35 mins
Ever
Only on weekdays 4-5 pm
y 60 mins
Weekdays 3-6 pm every 30 mins
Weekends every 60 mins
Every 60 mins
Every 40 mins
94 - Villages of Kapolei - Express
44 - Waipahu-Ewa Beach
40 - Honolulu-Mak
415 - Kapolei Transit Center
41 - Kapolei-Ewa Beach
aha
Bus Stations
95 - Kapolei Homesteads
stops along Roosevelt Avenue in Kalaeloa. The
current terminus of the Skyline rail transit line
is at Kualakaʻi (East Kapolei) station, which is
roughly 1.5 miles from the northern boundary
of the District.
1.2.3.3 Drainage
In 2017, a Drainage Report was prepared by
R.M. Towill Corporation (RMTC). Although a
draft report, it remains the most thorough
assessment that has been done in Kalaeloa to
date. The information in this section is based
on that report.
Kalaeloa partially falls within the City of
Kapolei watershed and the Kaloi Gulch
watershed. The lower limit of the Kapolei
Village watershed is the NAS Barbers Point
coral pit, located makai of Roosevelt Avenue
and east of Enterprise Street on land owned
by Hunt Companies. This facility receives all
excess runoff not retained in the watershed.
Some of the runoff conveyed to this facility
was accounted for and approved as the region
developed, and some of the drainage is not.
The regional watershed boundaries and the
limits of Kalaeloa are illustrated in Figure 1-9.
Previous development of Kalaeloa was
mainly intended for the Navy’s use and the
existing drainage system and roadways were
not constructed in accordance with State or
City standards. The existing drainage system
consists of 253 drywells that were located
Figure 1-8: Existing public
transit network
Page: 34
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:20:53 PM
Please add: It should be noted that there are no recorded easements
or executed agreements facilitating drainage to the NAS Barbers
Point coral pit, which is owned by Hunt and intended for economic
development.
32
KALAELOA MASTER PLAN
DRAFT
Figure 1-10: Existing Water Supply Network. Source: Draft Kalaeloa Potable Water Master Plan, R.M. Towill
Corporation, June 2016.
Water for Kalaeloa is provided by existing
wells and reservoirs located 3 miles north of
Kalaeloa. According to the 2015 data from
the flowmeter at the wells, the estimated
average daily flow is approximately 2.2
million gallons per day (mgd). The water
meter readings are closer to 1.0 mgd. Further
investigation is underway to determine
the cause of this discrepancy or location of
system leakage. Most of the existing water
demand is generated in the northern housing
area, the downtown industrial area located
north of Midway Street, and the golf course.
Water from the two wells is conveyed by a
24-inch transmission main which terminates
in a vault mauka of Roosevelt Avenue across
from the northern housing area. From there,
distribution is split and water to the northern
housing area, golf course, Coast Guard and
beach areas is from an 18-inch main and
water to the downtown, airport and western
industrial areas and school is from a 24-inch
main.
The Kalaeloa water system is also connected
to the BWS transmission line on Fort Weaver
Road. A pressure booster pump located on
Geiger Road, at the southern perimeter of
the Honouliuli Wastewater Treatment Plant
(WWTP), is operated when there is a need to
use the BWS water source. The use of BWS
water occurs only during emergencies.
Water to the downtown area and Kalaeloa
Airport is distributed by a 24-inch waterline
and a system of 12-inch and 8-inch distribution
mains. Water to the eastern portion of
Kalaeloa, the Coast Guard station and beach
areas is from an 18-inch waterline with 12-
inch and 8-inch distribution lines. Figure 1-10
shows the major water lines of the existing
water system.
The source of Kalaeloa’s potable water is a
well shaft located mauka of the H-1 Freeway.
Kalaeloa has a permitted water allocation or
pumpage limit of 2.3 mgd. Also located in
the mauka area outside the District are two
reservoir sites each with one underground
reservoir. One of the reservoir sites is co-
Page: 36
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:23:45 PM
We feel today's readings should be closer to 1.9 MGD. Please verify with KWC or note that this estimate will
be verified in the Infrastructure Master Plan.
DRAFT
39
KALAELOA MASTER PLAN
1.2.4 Existing Structures and Recent
Development
Figure-ground diagrams are drawings that
illustrate the relationship between the built
and the unbuilt environment within the study
area. Land coverage of buildings is visualized
as grey solid mass (figure), while public spaces
formed by streets, parks and plazas are
represented as voids (ground). Such diagrams
are used to explore built form patterns and the
continuity of open space (see Figure 1-17).
Development in Kalaeloa has been relatively
slow since the adoption of the 2006
Master Plan, presumably due to proximity
to the various military uses, inadequate
infrastructure, and airport land-use
considerations. Meanwhile, neighboring areas,
namely Kapolei to the north and Hoakalei to
the east have seen significant development.
The 2020 figure ground diagram illustrates the
“grain” and scale of new development at that
time, of which the most significant was the FBI
Field Office, meant to serve as a gateway and
catalyst for new construction in the area.
Since 2020, the pace of development and
redevelopment has picked up. Figure 1-18
provides an overview of major assets within
the District. The Kalaeloa Professional Center
on Shangrila Street provides almost 50,000 SF
of Class A office space for financial, medical,
and other professional services, and includes
a wing for the Warrior Ohana medical facility.
A former Navy Exchange furniture store
was redeveloped and now houses Five Star
Transportation, a large distribution company.
Also redeveloped was the former Navy
Bachelor Officer’s Quarters (BOQ) which
currently provides 100 affordable rental units.
The BOQ mess hall was transformed into an
educational facility for DreamHouse Public
Charter School. Other building renovations
have resulted in upgraded spaces for the
convenience store and gas station and bowling
alley.
New construction includes the Daniel K. Akaka
VA Outpatient Clinic with approximately
Figure 1-17: Kalaeloa figure ground diagram. Source: HCDA, 2020
Page: 43
Author: Hunt
Subject: Comment on Text
Date: 9/16/2025 4:47:13 PM
Info not current. Five Star Logistics is not the tenant anymore. Perhaps note the use (commercial/industrial)
rather than the tenant name.
Author: Hunt
Subject: Comment on Text
Date: 9/16/2025 4:47:21 PM
(replace/insert) "......DreamHouse Public Charter School as well as the former Navy fitness center which is
leased to American Renaissance Academy. Other building renovations have resulted in upgraded spaces for
the bowling alley and numerous warehouses for local businesses."
48
KALAELOA MASTER PLAN
DRAFT
The DreamHouse Academy is located in rehabilitated former Bachelor Officer Quarters (BOQ) mess hall.
for solar projects. A deterrent to residential
development is the inadequate state of
existing infrastructure.
1.3.4.1.d
Honolulu Board of Water Supply
Kalaeloa’s potable water needs are currently
being met by Hawaii sWater Company, a
private company. Although BWS has no plans
to take over water supply, it is planning to
construct a desalination plant within the
District that is expected to be completed by
approximately 2028 and operate for at least
20 years.
1.3.4.1.e
Kalaeloa - Hawaiʻi Department of
Transportation
Kalaeloa Airport is a resource for businesses,
training, and recreational aviation activities.
It plays a critical role improving safety and
efficiency at Honolulu International Airport
by accommodating many of the general
aviation operations that would otherwise
occur there. Statewide, the airport supports
emergency activities, such as U.S. Coast Guard
marine search and rescue as well as Hawaii
National Guard rapid deployment from their
Kalaeloa facilities. Because Kalaeloa Airport
is recognized as an important asset for the
state’s aviation system, the Kalaeloa Airport
Development Plan identifies ongoing and
future safety and security enhancements and
capital improvement projects.
1.3.4.1.f
Honolulu Authority for Rapid
Transportation (HART)
Given changes in the rail project’s construction
timeline, it is premature to designate a specific
route for the rail extension into Kalaeloa.
Regardless, a pedestrian-friendly environment
would bolster future transit developments by
rail and/or bus.
1.3.4.1.g
Honolulu Fire Department (HFD)
The HFD does not have a station at Kalaeloa at
present, but will require one in the future. The
department has identified what it considers
an ideal site, adjacent to the FBI facility, which
would provide land for a new station, indoor
classrooms, storage, and a large outdoor
training facility.
1.3.4.1.h
Barbers Point Elementary School
Barbers Point Elementary School has a
capacity for 700 students, but the facility
is outdated and needs refurbishment. Off
campus, surrounding streets lack continuous
sidewalks and there are no streetlights.
Development of safe pedestrian and bike
routes to and from the school would greatly
benefit the students.
1.3.4.1.i
DreamHouse Academy Public
Charter School
DreamHouse Academy opened in July 2020
in a leased building adjacent to Wakea
Apartments. The school will be moving in 2024
to a permanent facility in Kapolei which will
allow expanded enrollment.
Page: 52
Author: Hunt
Subject: Inserted Text Date: 9/16/2025 4:46:16 PM
(spelling) Hawaii Water Co.
Author: Hunt
Subject: Cross-Out
Date: 9/16/2025 4:47:31 PM
a private utility company.
DRAFT
49
KALAELOA MASTER PLAN
Kaʻulu by Gentry single detached homes.
1.3.4.1.j
Kapolei High School
Although Kapolei High School is located
outside the CDD, it is an important local
stakeholder in planning for Kalaeloa. In 2021-
22, there were slightly over 2,000 students
enrolled in grades 9 through 12. Kapolei High
School will experience enrollment pressures
as residential growth continues in the school’s
catchment area. The high school itself is
located within a 20-minute walk of most
areas slated for residential development in
Kalaeloa and is within a 30-minute bicycling
area of almost the entire District. There are
opportunities to develop safe routes to school
for both modes, including a safe crossing
through the nearby intersection of Roosevelt
Avenue and Enterprise/Fort Barrette Road.
1.3.4.2 Private Entities
1.3.4.2.a
Hawaiian Electric (HECO)
The electrical grid in Kalaeloa is owned by the
Navy, run by a subcontractor, and powered
by a HECO substation. HECO is interested
in acquiring ownership of the grid. Climate-
change-induced sea level rise is not projected
to affect existing electrical infrastructure.
1.3.4.2.b
Hunt Companies Hawai‘i
Hunt owns the majority of developable land
in Kalaeloa and frequently produces planning
studies to guide development on their parcels.
Hunt’s insights and community comments
Page: 53
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:28:39 PM
, if the grid is upgraded to HECO standards.
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 2:51:50 PM
Hunt Companies, Inc.
Author: Hunt
Subject: Cross-Out
Date: 9/2/2025 2:29:06 PM
Please replace with: Hunt is the largest private landowner in Kalaeloa.
DRAFT
57
KALAELOA MASTER PLAN
The 20-minute city is the key concept that
will help Kalaeloa become a Center for
Excellence by:
y Placing emphasis on what people love
about cities: their vibrant streets and
neighborhoods, and their convenience.
Shorter travel times mean more time
for recreation and family, and more
money saved.
y Improving the quality of life and
promoting equality and diversity by enhancing accessibility to services.
y Fostering healthy lifestyles by encouraging human-powered transportation, such
as biking and walking, which have proven health benefits. The 20-minute city
enhances walkability which results in fewer pedestrian and vehicular crashes and
can also help alleviate loneliness by making it easier to meet and interact with
neighbors.
y Relying on less pollution-emitting and less carbon-intensive forms of mobility,
which have proven environmental benefits. Sprawling urban development is very
energy intensive whereas a compact urban form thrives on accessible, multimodal
transportation options.
Cities as disparate as Portland, Oregon and Melbourne, Australia have already been
working on “20-minute neighborhoods” that employ these very concepts. And in recent
years, the market has been sending a clear signal: homes in walkable neighborhoods
are at a premium. Smart Growth, a U.S. advocacy group, argues this indicates that there
is not nearly enough supply. 20-minute cities produce livable, equitable, healthier and
environmentally-friendly benefits - all befitting a Center for Excellence.
ranging from rural to urban center (see Section
3.2). The land uses and densities permitted
within each type of transect form a compatible
mix and contribute to the character of that
transect.
2.3.3 Interim Uses
Interim land uses, such as storage and
maintenance facilities, are temporary,
acceptable land uses that do not preclude
the intended long-term, preferred land uses
from occurring. Allowing interim land uses
offers short- to medium-term benefits to
Kalaeloa while reserving maximum benefit for
future uses. Interim uses shall be reviewed
and coordinated with landowners in Kalaeloa
for appropriateness, ability to align with the
strategic goals and objectives, and ease of
redevelopment to the preferred land use.
Thus, interim uses that do not contribute
to the appropriate mixture of land uses or
immediate benefit of the community shall be
restricted.
2.3.4 Potential Relocations
Another opportunity to facilitate and enhance
redevelopment is the potential relocation
of existing uses. While many existing uses
are encumbered by deed restrictions placed
at the time the properties were conveyed,
possibilities exist for the HCDA to work with
landowners and the Federal government to
optimize land use within Kalaeloa over the
Why the “20-Minute City?”
Page: 61
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 8:26:13 PM
Recommend using 'should' instead of 'shall' as the Kalaeloa Rules is the appropriate place for including
requirements.
60
KALAELOA MASTER PLAN
DRAFT
Plan (SCORP) which is prepared on a 5-year
cycle.
Although dedicated open spaces and corridors
are vitally important for passive and active
recreation, a community’s street network
should also be enhanced to provide public
amenities. Shade, either from trees or
structures, should always be incorporated
to not only foster walkability, but also help
reduce the heat island effect. Shared paths
and cycle tracks provide mobility options,
and are active transportation options that
promote healthy lifestyles. Public art can
provide additional interest and expressions
of local meaning in the streetscape. Street
networks are usually the biggest landholding
in the public realm, and presents the greatest
opportunities for equitable public access
to shade, recreation, mobility, and civic
aesthetics.
2.3.5.2 Cultural Resources - Kalaeloa’s Living
Heritage
Kalaeloa and the broader ‘Ewa region are
rich in cultural history and significance. The
presence of archaeological sites, endangered
species, and native plants on relatively open
land in proximity to the Kalaeloa coastline
presents an opportunity to revisit the native
Hawaiian cultural traditions that existed in the
region prior to Western contact and to educate
the broader community about the ‘Ewa
region’s rich history.
Early Native Hawaiian Period
Cultural and archaeological sites of Ewa Plain’s
earliest inhabitants have been conserved and
protected through collaborative efforts that
created the Kalaeloa Heritage Park (KHP). The
HCDA partnered with the Kalaeloa Heritage
and Legacy Foundation (KHLF) to establish
the park. Through KHLF’s stewardship, the
park is a remarkable living heritage site which
represents an authentic educational setting
and medium for the preservation of Hawaiian
cultural traditions and practices. KHP’s
programs actively engage the community with
hands-on participation through its service
and work-study opportunities. One of its
educational programs with the University of
Hawaii West O’ahu’s Botany program resulted
in the cultivation and reforestation of native
plants such as ‘ahinahina o ‘Ewa.
Ewa Plantation Era
The extant tracks within the historic OR&L
railroad right-of-way along the northern
boundary of Kalaeloa are owned by the
State of Hawaii and managed through the
dedicated stewardship of the Hawaiian Railway
Society (HRS). The collaboration between
HRS and the government agency is crucial
for the education and appreciation of the rail
system’s contributions at Kalaeloa. The HCDA
recognizes the importance of stakeholders’
participation in the decision-making processes
for the future development of this viable mode
of transportation at Kalaeloa.
Military in the Pacific and World War II
The period of military presence at Kalaeloa
played an important role to bolster the United
States’ defense capabilities during the period
of tension evolving in the Pacific, throughout
World War II and the subsequent Cold War
period .
On May 2016, Ewa Field was placed on the
National Register of Historic Places (NRHP)
as the ʻEwa Plain Battlefield. Proposed
renovations and new work will conform to
the Secretary of the Interior’s Standards
for Rehabilitation and Guidelines for the
Treatment of Cultural Landscapes. Respectful
treatment of historically significant sites
is essential to recognize the bravery and
sacrifices of those who served during this
period in American history. Kalaeloa’s pivotal
role during World War II can be honored
by thoughtful remembrance through
preservation, education, interpretation, and
commemoration.
2.3.5.3 Natural Resources
According to the Division of Forestry and
Wildlife under the State’s Department of Land
and Natural Resources, Hawai‘i is home to
more than 1,400 native vascular plant taxa,
90% of which are not found anywhere else.
Page: 64
Author: Hunt
Subject: Cross-Out
Date: 9/2/2025 2:37:45 PM
Proposed renovations and new work should receive the appropriate
approvals from SHPD and abide by any applicable covenants, and
Federal and State laws and requirements.
DRAFT
63
KALAELOA MASTER PLAN
of the “Second City” of Kapolei and
the overall ‘Ewa district provides a
large market for quality fresh fruits and
vegetables.
y Greenhouses and aquaponics farms
could be relatively small in scale and
could blend in with future plans and
developments for light industrial and
related land uses in Kalaeloa. These
forms of intensive agriculture do not
require large volumes of irrigation water
– a plus factor for farms in the hot, dry
‘Ewa district.
y Programs could be developed for the
restoration of Kalaeloa coastal fisheries
and limu. Limu is a form of ocean algae
that was traditionally an important
source of nutrition for native Hawaiian
people. Limu restoration programs would
have cultural, educational, and food
value.
2.3.6 Addressing Regional Traffic
Congestion
Due to increased development and the
necessity to commute to school and work,
traffic on existing arterial roadways and the
H-1 Freeway is congested on a daily basis.
Roadways such as Farrington Highway,
Roosevelt Avenue, and Geiger Road provide
some relief in the east-west direction but
are also frequently congested. Construction
of Kualaka’i Parkway and completion of
the Kapolei Parkway have improved ingress
and egress; however, additional measures
are necessary to reduce regional traffic
congestion. One of these measures is the
development of Kalaeloa according to the
principles of the 20-minute city. Convenient
and efficient mass transit service is also
critical.
Consistent with the principles of the 20-minute
city, another approach to reducing regional
traffic congestion is to increase employment
opportunities in the ‘Ewa region, thereby
reducing the necessity for area residents to
commute outside the region to work.
2.3.6.1 Streets & Roadways
Improvements to the street network
within and adjacent to Kalaeloa present an
opportunity to enhance regional connectivity
both east-to-west and north-to-south
and improve vehicular traffic flow within
the ‘Ewa region. In addition to current
regional transportation plans and ongoing
road improvement projects, several new
improvements are proposed (Refer to Figure
2-1). Any streets crossing historic resources,
such as the Historic Hawaiian Railway at
Renton Road, must receive the appropriate
approvals from SHPD and other relevant
agencies and abide by all Federal and State
laws and requirements.
y Develop Saratoga Avenue as the major
urban corridor through Kalaeloa. The
alignment should avoid the ‘Ewa Plain
Battlefield Memorial.
y Enhance vehicular circulation and
connectivity on Fort Barrette Road,
including refinements to intersection
operations at Roosevelt Avenue and Fort
Barrette/Enterprise Roads.
y Extend Wakea Street into Kalaeloa and
provide a direct link to the H-1 Freeway
interchange.
y Develop a roadway connection to
Campbell Industrial Park and Kalaeloa
Harbor via Malakole Street.
y Develop a mauka-makai connection on
the east side of Kalaeloa in the vicinity of
Ka Makana Aliʻi.
In 2016, the City of Honolulu released the
Complete Streets Design Manual to ensure
that public streets and surrounding spaces
serve everyone’s transportation needs,
whether by car, bike, bus, rail, or foot. New
streets in Kalaeloa should reflect this vision
and be built to such standards. Additional
street standards are part of the City and
County of Honolulu’s Subdivision Rules and
Regulations and apply to construction plans
needing review by the Department of Planning
and Permitting.
Page: 67
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:38:35 PM
Please add: to the extent feasible.
DRAFT
69
KALAELOA MASTER PLAN
This conceptual illustration of a view
looking west shows how elements of the
historic ʻEwa Plain Battlefield, such as the
warming-up mat, could potentially be
preserved alongside interpretations of the
old runways (as recreational open space)
within a new mixed-used neighborhood
incorporating residential, commercial, and
light industrial uses..
maintenance support. Also located downtown
were public services, such as the post office,
that benefited from a central location. The
historic downtown is roughly bounded by
Midway Street with Enterprise Street serving
as a central spine. The street pattern reflects
the layout of the airfield with streets angled
to fit within the crook of the crossing runways.
The historic downtown continues to provide
ample opportunities for infill development to
enrich the mix of land uses.
Beyond the historic downtown, however, the
Regulating Plan envisions the mixed-use area
expanding northward to Roosevelt Avenue.
A cluster of blocks in the downtown area is
in the general urban transect (T4) to enable
future infill development. Heading north,
parcels located between Saratoga Avenue
and Roosevelt Avenue are in the urban center
transect (T5)and would form a defined hub
or “new downtown.” Concentrated urban
activiteis and denser urban form would anchor
a multi-modal corridor and potential transit-
oriented development.
A long-term redevelopment objective is
to upgrade Saratoga Avenue into a linear,
promenade type mixed-use area. This
objective is supported by a land use overlay
called the Saratoga Frontage Zone to promote
development that will activate and enliven the
street scene.
A primary objective for the mixed-use area,
or downtown Kalaeloa, is to create a physical
environment that supports the evolution of
the 20-minute city. To that end, this area will
be a place where:
y Residents can walk or bike to work,
school, the local transit station or
mobility hub, or to the essential services
needed for day-to-day life as well as
to enjoy the cultural amenities of the
Kalaeloa community.
y A variety of mobility options allow for
ease of movement within the area and
connections to the region at large.
y Neighborhood streets are valued
beyond their ability to carry traffic, but
as significant urban places in and of
themselves, because they are where
neighbors, friends and colleagues meet
and socialize. They are supported by
streets with sidewalk cafes, lively plazas,
and restful parks.
On the east side of Kalaeloa, another overlay
zone will support the perservation and
interpretation of historic resources within
theʻEwa Plain Battlefield Historic District.
Overlay regulations are intended to integrate
history within the development of private land
uses.
Page: 73
Author: Hunt
Subject: Comment on Text
Date: 9/16/2025 4:47:40 PM
Recommend that statement include more specificity on type of conceptual illustration; which in this case is a
massing diagram intended to show massing/scale of buildings utilizing potential heights/densities. It does
not necessarily depict a development site plan.
Option:
"This massing diagram is a conceptual illustration intended to depict....."
Author: Hunt
Subject: Cross-Out
Date: 9/2/2025 3:01:20 PM
70
KALAELOA MASTER PLAN
DRAFT
Outdoor restaurant seating can help activate the urban environment
3.1 Neighborhoods
The mixed-use neighborhood is the building
block of the 20-minute city, in which many of
life’s daily needs are a 20-minute walk, bike,
or bus-ride away, and a key to supporting
walkable urban places. This, in turn, will
support economic development by helping
to attract new employers and employees,
to live, work, shop and play in Kalaeloa
neighborhoods.
Four key strategies will be critical in realizing
the vision for Kalaeloa as a community of
neighborhoods. These include:
y Saratoga Avenue and other framework
streets are key to linking neighborhoods
to each other. Serving as Kalaeloa’s new
main street, Saratoga has the potential
to become the area’s signature main
street - an iconic and memorable place.
Pedestrian-friendly building frontages
and wide sidewalks are particularly
important along Saratoga, as with
the primary thoroughfares linking
neighborhood centers to one another.
y Multi-modal connectivity between
neighborhoods and activity centers is key
to unlocking the value of mixed-use infill
developmentand offering convenient
access to nearby jobs, housing,
recreation and commercial amenities.
Bus routes will need to be reconfigured
to connect these neighborhoods, while
region-wide transit, such as an extension
of the rail transit line, should be
prioritized for the future.
y Placemaking is a planning concept that
carefully links the circulation and open
space network (core elements of the
public realm) with existing and new
private development. Making great
places is the payoff for connected, mixed-
use development, as each increment
adds value to surrounding properties.
On top of this, great places arise as
new developments contribute to the
distinctive character of an area.
y Pedestrian-friendly design can bring
daily necessities within an easy walk of
many residents, stimulating economic
activity while reducing the stress
on transportation systems. Thus,
neighborhoods should be limited in size
to the distance a pedestrian can walk in
Page: 74
Author: Hunt
Subject: Inserted Text Date: 9/16/2025 4:47:50 PM
development and
DRAFT
71
KALAELOA MASTER PLAN
Figure 3-1: Conceptual activity centers
Figure 3-2: Illustrative conceptual
neighborhood (East Saratoga)
five minutes—roughly 1/4 mile from the
center of a neighborhood to its edge—as
well as provide a street network that
prioritizes pedestrian safety and comfort.
Local streets should be woven into the
network to create walkable block-sizes.
Building design should reinforce the
pedestrian orientation of the neighborhoods
by gently framing the streets and public spaces
to provide visual delight that makes walking a
joy. General development standards that are
part of the Kalaeloa community development
district rules include form-based code
requirements to promote consistent, quality
urban environments in the respective transect
zones. In general, development standards
seek to accomplish the following objectives:
y New development should always front
streets with human-scale, pedestrian-
oriented frontages, an ensemble that
is tailored to specific street types and
includes sidewalks, curbs, plantings,
bicycle facilities, and street trees that
provide shade.
y Design should emphasize the continuity
of public frontages with buildings or
landscape edges while discouraging large
surface parking lots and blank walls.
To accomplish these objectives, the plan
identifies several conceptual neighborhoods
Page: 75
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 2:55:59 PM
Does the gray bold represent Saratoga Overlay? If so, should align with
the regulating plan.
DRAFT
73
KALAELOA MASTER PLAN
Figure 3-3: Existing conditions - makai view
Figure 3-4: Illustrative build out - makai
Figure 3-5: Existing conditions - mauka view
Figure 3-6: Illustrative build out - mauka
Illustrative Conceptual Buildout
Page: 77
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 2:56:55 PM
Is there a date for 'existing conditions' photos?
74
KALAELOA MASTER PLAN
DRAFT
Figure 3-7: Conceptual parks and open space plan
Parks and Open Space
Ewa Plain Battlefield
Kalaeloa District
Boundary
Legend
July 2024
Midway
Midway
Lexington
Lexington
Yorktown
Yorktown
Saratoga Ave
Saratoga Ave
Enterprise
Enterprise
Shangrila
Shangrila
Midway
Midway
Coral Sea Rd
Coral Sea Rd
Malakole St
Malakole St
Roosevelt Ave
Roosevelt Ave
Boxer Rd
Boxer Rd
Copahee Ave
Copahee Ave
Hornet Ave
Horne t A ve
Franklin
Franklin
Tripoli
Tripoli
Essex Rd
Essex Rd
Geiger Rd
Geiger Rd
‘ola‘i
‘ola‘i
Fort Barrette Rd
Fort Barrette Rd
Kamokila Blvd
Wakea
Wakea
Kapolei Pkwy
Kapole i Pkw y
Tulagi Ave
0
0.5 Miles
0.25
Figure 3-7 Parks and Open Space Plan
illustrates the publicly-accessible open
space network. An equitable distribution of
open spaces in neighborhood centers and
within the fabric of the neighborhood itself
will ensure a livable and lively public realm.
These spaces will be fronted by streets and
buildings ensuring “eyes on the park.” Public
spaces in neighborhood centers are generally
hardscaped to easily accommodate various
activities, such as farmers markets and
festivals.
Alternatively, public spaces within the
neighborhood fabric are generally landscaped
for recreation, such as sports fields, parks,
and playgrounds. An area of approximately
220 acres along Saratoga Avenue, tentatively
known as Kalaeloa Regional Park – Mauka,
has the potential to provide significant space
for active sports fields, such as baseball and
soccer, play courts for basketball and tennis,
dog park, and a swimming center, passive
recreational facilities and open areas for
picnicking and public events.
Another assemblage that includes the existing
Kalaeloa Beach Park, and a future Kalaeloa
Regional Park - Makai, bracket both sides
of Tripoli Road. The campground could be
expanded to include enhanced bathroom and
shower facilities, as well as additional camp
sites. New parking areas and connecting lanes
(for example, the completion of Eisenhower
Road) would allow enhanced access by the
Page: 78
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:16:22 PM
We request HCDA remove the park located on Parcel 13 as this figure
illustrates the publicly-accessible open space network.
76
KALAELOA MASTER PLAN
DRAFT
Malakole St
N
Tripoli Rd
Kapolei Pkwy
Kalaeloa Blvd
Kamokila Blvd
Roosevelt Ave
Wakea St
Geiger Rd
Roosevelt Ave
Saratoga Ave
Coral Sea Rd
Fort Barrett Rd
Enterprise St
Keoneula Blvd
Shared Use Path
Bike Lane
Shared Roadway
Buffered Bike Lane
Shoulder Bikeway
Protected Bike Lane
LEGEND
Existing and Proposed Bicycle Facilities
Figure 3-9: 2019 Oʻahu Bike Plan - Existing and Proposed facilities
Figure 3-9 shows the existing and proposed
network of bicycle facilities, based on the 2019
Oʻahu Bike Plan. Corridors for separate and
shared bicycle facilities will help to determine
where additional curb-to-curb width may be
needed as the profiles of Kalaeloa roads take
their finished form.
Page: 80
Author: Hunt
Subject: Rectangle
Date: 9/1/2025 3:17:51 PM
This should be dotted as it is not open the public currently.
DRAFT
79
KALAELOA MASTER PLAN
3.2.1.1 T2 Rural Zone
The T2 zone is comprised of large lots with
natural landscapes, beaches, developed and
undeveloped park areas, pedestrian and
bicycle trails and limited agricultural use.
The T2 zone consists primarily of lots along
the ocean, lots reserved for regional parks
or open space. Cultural, archaeological, and
environmental uses and sites, such as the
Kalaeloa Heritage Park and the ‘Ewa Plain
Battlefield, are located within the T2 zone.
Properties located within the T2 zone may also
various outdoor recreation facilities, such as
aquatic centers, beach parks, campsites, and
associated parking facilities.
3.2.1 Transect Zones
Properties in T2 also include “eco-industrial”
uses defined as environmentally-compatible
industries that benefit the island-wide
population. Industries such as solar or
hybrid energy generation, bio filtration,
hydroponic farming and other such
sustainable technologies are compatible
in these parcels. These industries require
large land areas and can be located within
the airport’s runway protection zones (RPZ)
where height restrictions limit development
or, in some areas, where noise contours
resulting from airport activities exceed
65-decibel day-night average sound levels
(DNL). Any occupied structures built
within these areas must comply with FAA
requirements for development.
3.2.1.2 T3 Mixed Use Zone
The T3 Mixed Use Zone is characterized
by lower density development with a
wide mix of activities. Some areas may be
predominantly residential, characterized by
single-family homes, duplexes, townhomes,
and small apartment buildings. These areas
may also include live-work spaces, home-
offices, studios, and bed and breakfast inns.
Limited local-serving retail and commercial
uses, such as health care providers,
neighborhood cafes, and small office
buildings, are also permitted in the T3 zone.
Generally, buildings would not be taller than
three stories and surface parking would
be provided on the side or rear of the lot.
Residential densities are expected to range
from 8 to 20 dwelling units per acre and
commercial uses are not to exceed a floor
area ratio (FAR) of 1.5.
Page: 83
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 3:20:16 PM
Remove this reference as P18/19A are in T3, or specify that "portions of
the 'Ewa Plain Battlefield are located within the T2 zone."
80
KALAELOA MASTER PLAN
DRAFT
3.2.1.3 T4 General Urban Zone
The T4 General Urban zone contains a
diverse mix of uses at higher intensities
than T3. Residential building types generally
include townhomes and urban apartment
buildings, as well as live-work spaces. Retail,
hotel, and office uses are permitted.
Generally, buildings are not taller than five
stories and may have a mix of garage and/
or surface parking in the rear of the lot or
the middle of the block, screened from
view. Residential densities would range
from 16 to 40 dwelling units per acre and
commercial uses do not exceed 2.5 FAR.
3.2.1.4 T5 Urban Center Zone
The T5 Urban Center Zone includes a
diverse mix of uses at higher intensities
than T4 with the highest allowable density
and height, containing a mix of retail,
office buildings, civic uses, and residential.
The T5 zone is the vibrant and bustling
heart of Kalaeloa. Buildings are set close
to the sidewalks to activate street life
and sidewalks are wider to accommodate
outdoor dining and public street furniture.
Buildings are generally not taller than
seven stories and will have garage parking
screened from view along primary streets.
Residential densities range from 40 to 100
dwelling units per acre and commercial
uses do not exceed 3.5 FAR. Civic spaces
include urban parks, plazas and squares.
Tree-lined streets include curbs, sidewalks
and landscaping on smaller-sized blocks and
traffic-calming techniques implemented
throughout.
Other T3 areas may contain more
commerical and light industrial uses than
residential neighborhoods. Such uses could
include professional offices, logistics and
warehousing, and commercial recreation.
The objective of the T3 zone is to meet an
array of community and economic needs,
while maintaining healthful levels of air and
noise impacts and visual compatibility with
surrounding development.
Where commercial and light industrial
development results in larger-sized blocks
or buildings that are set back farther
from the street, sidewalks will need to be
designed to maintain a pedestrian friendly
quality. Vegetative screening is required
to wrap large areas of parking, loading, or
buildings with blank walls. Sites with large
surface parking lots are opportunities for
incorporating photovoltaic panels, both as a
source of renewable energy and to reduce
the heat island effect.
Page: 84
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:21:15 PM
Align with Site Development Standard (4.5 FAR)
84
KALAELOA MASTER PLAN
DRAFT
3.3 Connectivity
Wakea Street
Extension*
Saratoga Avenue
Extension*
Roosevelt-Saratoga
Connector*
Geiger Road
Connector**
North-South
Connector**
Kamokila Blvd
Extension*
Malakole Street
Extension*
Major street, boulevard
or avenue
Proposed major street,
boulevard, or avenue*
Main street
Legend
July 2024
Ewa Battlefield Historic
District
Kalaeloa District Boundary
Street or secondary street
Proposed street*
Existing street right-of-way
to be evaluated**
Existing private street,
local street, or alley subject
to future development plans
Lexington
Lexington
Yorktown
Yorktown
Saratoga Ave
Saratoga Ave
Enterprise
Enterprise
Shangrila
Shangrila
Midway
Midway
Coral Sea Rd
Coral Sea Rd
Malakole
Malakole
Roosevelt Ave
Roosevelt Ave
Boxer Rd
Boxer Rd
Copahee Ave
Copahee Ave
Hornet Ave
Hornet Ave
Franklin
Franklin
Kalaeloa Blvd
Kalaeloa Blvd
Tripoli
Tripoli
Essex Rd
Essex Rd
Geiger Rd
Geiger Rd
Fort Barrette Rd
Fort Barrette Rd
Kamokila Blvd
Wakea
Wakea
Kapolei Pkwy
Kapolei Pkwy
Tulagi Ave
Midway
Midway
Olai
Olai
Nassau
Belleau
Woods
*Conceptual alignment subject to
design refinement
**To be evaluated for need; subject
to design refinement
0.5 Miles
0
0.25
The Plan envisions new streets to be woven
into the existing street grid, as shown in Figure
3-11. Proposed new regional thoroughfares,
including the extension of Wakea Street and
connection of Saratoga Avenue to Coral Sea
Road, would greatly increase connectivity
within the district.
Given the listing of the ʻEwa Plain Battlefield on
the National Register of Historic Places in 2016,
however, the planned City and State roadways
east of Coral Sea Road are being re-evaluated.
Instead of continuing Saratoga Avenue east
to Geiger Road, for example, it could be
connected mauka to Roosevelt Avenue outside
of the Battlefield. The future extension
of Kualakaʻi Parkway also needs to be
reconsidered to avoid the historic elements of
the ʻEwa Field which are to be preserved. The
City- and State-owned rights-of-way through
the ʻEwa Field could potentially be exchanged
for alternative alignments or other uses.
3.3.1 Street Grid
The map depicted in Figure 3-11 is conceptual
in nature. As each parcel is developed, streets
are expected to be added, subtracted, or
moved from where they are shown on this
map. The street network can be viewed as
an arrangement of blocks defined by their
perimeters or the sum of all sides. In general,
block sizes decrease as area land uses diversify
and/or intensify. As such, block-size perimeters
Figure 3-11: Conceptual thoroughfare Plan
Page: 88
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:48:40 PM
key historic elements
86
KALAELOA MASTER PLAN
DRAFT
A multi-year demonstration project in Fairfax County, Virgina utilized an autonomous shuttle to connect the
Dunn Loring Metrorail Station with the Mosaic District, a 31-acre urban mixed-use retail development.
the near future, autonomous shuttles could
also provide on-demand first- and last-mile
connectivity between mobility and residential
developments.
3.3.2 Thoroughfare Standards for
Complete Streets
All new and upgraded thoroughfares should
be designed under the City of Honolulu’s
“Complete Streets” policy. Streets should
generally consist of vehicular lanes and
public frontages. Bicycle lanes will also be
appropriate on some streets. Public frontages
contribute to the character of the Transect
Zone, and should include the types of
sidewalks, curbs, planters, bicycle facilities,
and street trees that contribute to a walkable,
multimodal thoroughfare. Streets should
be designed in context with the urban form
and desired design speed of the Transect
Zones through which they pass. Streets may
include vehicular lanes in a variety of widths
for parked and for moving vehicles, including
bicycles. Within Transect Zones T3 through
T5, pedestrian comfort shall be a primary
consideration of street design.
Design conflicts between vehicular and
pedestrian movement generally shall be
decided in favor of the pedestrian. To
discourage fast, cut-through traffic, traffic
calming measures should accompany the
interconnected street network called for in
these standards. A large measure of traffic
calming would be provided through the use
of appropriately dimensioned travel and
parking lanes. (Excessive street width has been
identified as a major contributor to higher
vehicle speeds and a higher incidence of
severe injuries). Additional techniques may be
employed to calm traffic further, for pedestrian
safety and convenience.
3.3.2.1 Articulated Crosswalks
At crosswalks, visual and physical articulation
signal the special needs of pedestrians to
motorists. Articulation can be created through
the use of special pavers and textured or
colored concrete. Like speed humps, raised
intersections change the vertical plane and
force motorists to slow down. Crosswalks
that are placed at the same level as abutting
sidewalks signal that pedestrians take
precedence.
3.3.2.2 Bulbouts
Bulbouts extend curbs and replace portions
of the parking lane. They are especially
warranted at intersections and other
pedestrian crossings, where they slow
motorists, provide a pedestrian refuge, and
reduce pedestrian crossing distances.
Page: 90
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:51:42 PM
please revise this to should
92
KALAELOA MASTER PLAN
DRAFT
4.1 Infrastructure
4.1.1 Public Dedication
The Master Plan anticipates that all future
utility systems at Kalaeloa will be operated by
local utility providers such as HECO, Kalaeloa
Water Company, BWS, Hawaiian Telcom, and
others. New roads, drainage, water supply, and
wastewater systems will need to be designed
to the standards of the organizations or
agencies with jurisdiction.
4.1.2 Thoroughfares
The Master Plan identifies the classification for
each existing and proposed thoroughfare of
the Master Plan. All thoroughfares, (except for
private streets) are intended to be constructed
to City of Honolulu standards. Some existing
thoroughfare rights-of-way at Kalaeloa do not
conform to existing standards and will require
the transfer of additional land to governmental
entities to expand the ROWs. The HCDA will
lead the coordination of the construction of
these thoroughfares with costs being borne
by both the public and private sectors. In
accordance with City Ordinance Section 33A-
1.3, traffic impact fees would be assessed on
developers within Kalaeloa to provide regional
transportation improvements.
4.1.3 Public Transit
There are two primary types of public transit
proposed for Kalaeloa: expanded bus service
and rail connection.
4.1.3.1 Bus Service
Bus service should be enhanced to link
downtown Kapolei to the Kapolei Transit
Center and the Kualakaʻi (East Kapolei)
Skyline rail station in order to provide high
quality connections to downtown Honolulu
and other locations. This would potentially
include improving existing route 415 of
TheBus to 15-minute headways, as well as
adding two routes: one that runs the length
of Saratoga Ave and another that runs along
Coral Sea Road (to the beach parks), both with
15-minute headways during peak periods.
4.1.3.2 Rail Service
Direct rail service to Kalaeloa could be
developed as part of an extension of the
Skyline rail transit system from the Kualakaʻi
(East Kapolei) Station to a terminus in West
Kapolei. The City and County of Honolulu’s
Locally Preferred Alternative (LPA) that was
adopted in 2006 included an alignment with
stations near Saratoga Avenue at North-South
Road, Fort Barrette Road, and Wakea Street.
This alignment through Kalaeloa, however,
does not follow the existing streets or block
patterns and requires extensive new rights-
of-way. To minimize impacts to existing
and planned development, an alternative
alignment could follow Roosevelt Avenue
or the parallel drainage channel. Because
such an alignment could serve both Kalaeloa
and Kapolei, it could potentally have higher
ridership than the 2006 LPA.
A rail station and interim terminus at the Ka
Makana Aliʻi shopping center integrated with
a transit center and a park-and-ride facility
would also improve transit service to Kalaeloa.
Note that the 2006 Kalaeloa Master Plan
originally envisioned the rail transit extension
running in a center median along Saratoga
Ave. This would be appropriate as an at-grade
light rail transit (LRT) or bus rapid transit
system, and could be designed to enhance a
pedestrian-oriented urban community. Future
transportation planning efforts will have to
revisit the potential safety, cost, ridership,
and technology aspects of these and other
potential alternatives for providing direct
transit service to Kalaeloa.
Page: 96
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:54:50 PM
Recommend stating: may require the transfer of additional land to governmental entities to expand the
ROWs.
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:30:02 PM
Will these apply to federal and state agencies as well?
DRAFT
93
KALAELOA MASTER PLAN
4.1.4 Drainage
Managing drainage during implementation of
the Master Plan is two-fold: regional drainage
from the mauka watershed that flows into
Kalaeloa and run-off within Kalaeloa. In June
2017, the R.M. Towill Corporation (RMTC)
produced a drainage report of Kalaeloa
that was commissioned by Hunt Companies
that addressed both of these issues. The
recommendations below represent key
elements of the 2017 drainage report.
4.1.4.1 Regional Drainage
RMTC recommended regional drainage
improvements to channel offsite runoff from
the Kapolei Village watershed and prevent
flooding within Kalaeloa during large storm
events.
The existing four 6-feet x 4-feet box culverts
that convey offsite flows from the lower
channel/basin to the NASBP coral pit under
Roosevelt Avenue were proposed to be
demolished and upgraded to three 9-feet x 10-
feet box culverts. The proposed box culverts
would be designed to accommodate a peak
flow rate of 3,900 cubic feet per second (cfs)
entering Kalaeloa from the Kapolei Village
watershed. The proposed box culverts would
provide adequate freeboard to meet City
Storm Drainage Standards and alleviate the
flooding that currently occurs in the vicinity.
The NASBP coral pit is an integral part of the
regional drainage system design for Kalaeloa
because it captures and disposes of all offsite
runoff from the Kapolei Village watershed and
there is no outlet to the Pacific Ocean. A total
runoff volume of 1,150 acre-feet enters the
coral pit from the Kapolei Village watershed
and onsite areas within Kalaeloa. The volume
of runoff from the Kapolei Village watershed
and areas within Kalaeloa under the proposed
condition is not expected to change. The
resulting excess capacity of the NASBP coral pit
is estimated to remain at approximately 243
acre-feet. Any future use of the NASBP coral
pit must receive all appropriate permits and
clearances.
4.1.4.2 On Site Drainage
RTMTC recommended that drainage areas
within Kalaeloa continue to follow the
existing drainage patterns during large storms
exceeding the capacity of the proposed onsite
drainage facilities and no other regional type
of drainage facilities are required.
The storm drainage system within Kalaeloa
was broken up into three basic areas: 1) large
existing sump areas, 2) developable parcels,
and 3) areas within the proposed HCDA/City of
Honolulu right-of-way.
y Existing Sump Areas. The large existing
sump areas would remain in place, with
the exception of one, which is proposed
for development but would be replaced
by two drainage basins. Proposed City
roadways and parcels would be served
by a backbone drainage collection
system consisting of roadway catch
basins and underground drain culverts
that convey runoff to existing sumps or
proposed retention basins located in
Kalaeloa. Existing parcels not planned
for development would be served
by the backbone drainage collection
system where possible. The remaining
existing parcels would continue to follow
the existing drainage patterns. The
environmental advantage of maintaining
the sump areas as part of the drainage
plan is that using the existing sumps as
percolation/retention basins to hold the
100-year, 24-hour storm event would
exceed the City of Honolulu storm water
quality standards.
Page: 97
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:29:54 PM
a draft drainage report
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:30:37 PM
Restate the following that was previously mentioned :
Although a draft report, it remains the most thorough assessment that
has been done in Kalaeloa to date.
Author: Hunt
Subject: Comment on Text
Date: 9/16/2025 4:51:41 PM
We believe in this in reference to P12, in which case, it should be stated that future design/engineering will
determine # of drainage basins. It could end up being > 2.
However, if this is in reference to P13. We object to this statement.
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:20:15 PM
Restate the following after this sentence: Some of the runoff conveyed
to this facility was accounted for and approved
as the region developed, and some of the drainage is not. It should be
noted that there are no recorded easements or executed agreements
facilitating drainage to the NAS Barbers Point coral pit, which is
owned by Hunt and intended for economic development.
Author: Hunt
Subject: Comment on Text
Date: 9/16/2025 4:47:58 PM
I believe "Kapolei Village" is supposed to be Villages of Kapolei (VOK). If so, all references to Kapolei Village
should be replaced with VOK.
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:32:48 PM
RMTC
DRAFT
95
KALAELOA MASTER PLAN
4.1.5 Potable Water
In September 2016, RMTC prepared the Draft
Kalaeloa Potable Water Master Plan. This
master plan identified the need for Kalaeloa’s
water system to be improved and expanded
to meet BWS standards and accommodate
anticipated future water demands, the latter
of which was projected to triple over current
usage to 3.266 million gallons per day (mgd).
This increase in demand was predicated
on new housing units being constructed
at Kalaeloa, but mitigated by the HCDA’s
mandate to utilize reclaimed or non-potable
water for irrigation. The RMTC plan assumed
a buildout that was less than the maximum
buildout that would be allowed. Demand for
potable water was derived by applying a land
utilization factor to parcels to account for site
conditions such as topography and previously
identified areas of cultural or biological
significance which limited development to less
than maximum permitted densities.
It is important to reassess those buildout
assumptions to ensure that the demand
estimates in the 2016 RMTC plan are still
applicable. It is also recommended that
the 2016 plan be reviewed and updated as
necessary to reflect any other changes in
existing conditions, updated assumptions,
or operational issues that have been made
since the system was acquired by the Kalaeloa
Water Company (KWC), which is a subsidary of
Hawaii Water Service Company, Inc.
The RMTC plan (2016) stated that:
The anticipated 3.226 mgd demand
is higher than the present 2.337 mgd
water allocation for the Barbers Point
Wells. Additional water source of 0.930
mgd must be requested from the BWS in
order to accommodate the increase in
water demand for ultimate development.
Another option would be to petition
the Commission on Water Resources
Management to increase the Barbers Point
water allocation. (p. 8-1)
The RMTC plan also advised that the “request
for 0.930 mgd of average daily flow is sizeable”
and requests for water service should be
made by the HCDA after approval of the
Kalaeloa Master Plan amendment. While
the water may not be required immediately,
the request will allow KWC to evaluate their
water resource situation and determine if
water can be made available from the existing
system or if additional water wells need to be
drilled and permitted. If additional wells need
to be drilled and permitted, the request for
water may require negotiation between the
HCDA and BWS. Development and operation
of the potable water system will be under
the auspices of KWC in accordance with the
Honolulu BWS standards. Major components
of the system will include source, storage, and
transmission.
It is proposed that none of the existing Navy
lines be incorporated into the water system on
a permanent basis, primarily because these
lines are about 50 years old and are generally
too small to service the planned densities.
Indeed, the RMTC plan (2016) stated that:
With the exception of the 24-inch line from
the wells to Kalaeloa and along Roosevelt
and Enterprise and the 18-inch line along
Roosevelt and Coral Sea, most of the
existing water lines in Kalaeloa do not
have sufficient capacity to meet existing
and projected fire flow requirements
and are proposed to be removed or
abandoned. (p. 8-1)
For full buildout of the Kalaeloa Master Plan
to be realized, water will need to be obtained
from KWC, who will only provide service
to portions of the water system where the
water lines have been upgraded to meet
BWS standards. It should be noted that since
assuming ownership of the water system,
KWC has made significant improvements
to the existing water lines, including a
comprehensive leak detection and repair
program to reduce water loss. IN 2025, KWC
initiated a project to evaluate and design
replacement water mains, beginning in the
downtown area.
Page: 99
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:56:15 PM
Include mention of desalinization; BWS recently received a grant to explore this.
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:56:46 PM
Restate the following that was previously mentioned :
Although a draft report, it remains the most thorough assessment that
has been done in Kalaeloa to date.
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 3:56:54 PM
RMTC's 2016 report proposed
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:57:02 PM
KWC standards
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 3:58:57 PM
HCDA, BWS, CWRM, and KWC.
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 2:58:52 PM
Typo: In
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:00:36 PM
KWC standards
96
KALAELOA MASTER PLAN
DRAFT
To receive additional permanent water
allocation, KWC will require the payment
of facilities charges and a commitment to
discontinue the use of potable water that is
used for irrigation when non-potable water
becomes available. This will require the
construction of a separate non-potable water
system as the water system is upgraded to
meet BWS standards. Developers at Kalaeloa
will be required to pay Hawai‘i facility charges
prior to connecting to the water system. KWC
will also award “credits” to the HCDA for water
infrastructure improvement expenditures.
The RMTC plan stated that the existing water
wells are in good condition, but the existing
reservoirs would need to be renovated and
additional reservoir capacity of 3.75 million
gallons would be required. The existing water
well and reservoir site is the preferred location
for the new reservoir. Due to site constraints,
this location must be thoroughly investigated.
KWC has agreed to provide interim water
to the Kalaeloa area from a master meter
off Kamokila Boulevard to facilitate the
development of parcels located between
Roosevelt Boulevard and Saratoga Avenue. As
the water distribution system is brought up to
BWS standards, additional parcels can receive
KWC service. During the conversion from the
original system to BWS standard water lines,
the water systems may have to be operated
separately. Fire protection for industrial
parcels would have to be provided by the
original system during the transition.
For existing Kalaeloa developments that
disconnect from the Navy water system and
connect to the proposed KWC system, either
master meters or individual building meters
could be installed, depending on the situation.
If master meters are used, the owner of
the system served by the meter would be
responsible for billing individual users and
paying the KWC for water supplied through the
master meter.
4.1.6 Reclaimed (Non-Potable) Water
for Irrigation
The BWS has been providing a supply of
reclaimed (or R-1) water for irrigation use.
BWS owns the R-1 recycling facility and
distribution system (referred to as the “purple
pipe”). Secondary effluent from the Honouliuli
wastewater treatment plant is delivered to the
recycling facility for tertiary treatment. The
supply of R-1 water is currently available to the
edge of Kalaeloa. Although R-1 is flowing, it is
estimated to be approaching capacity.
Page: 100
Author: Hunt
Subject: Cross-Out
Date: 9/2/2025 10:55:54 AM
KWC
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 4:02:58 PM
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:02:04 PM
KWC standards
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 4:01:56 PM
KWC
DRAFT
97
KALAELOA MASTER PLAN
N
To take advantage of R-1 water to irrigate parks
and landscaped areas, non-potable water lines
will need to be extended to individual parcels
within the District. This can be achieved after
the City increases R-1 supply.
In December 2016, RMTC prepared a Draft
Kalaeloa Non-Potable Water Master Plan,
based on buildout projections at the time. The
RMTC plan concluded that there would be an
increase in demand for reclaimed water to
1.583 mgd or 2.5 times current usage (which,
at the time, was limited to the Barbers Point
Golf Course) to support the full development
of Kalaeloa. However, the RMTC plan
assumed a buildout that was less than what
was allowed, based on parcel-specific land
utilization factors.
The RMTC plan asserted that the existing
Kalaeloa non-potable water system would
require significant improvements to meet
BWS standards and accommodate anticipated
future water demand of an additional 0.983
mgd of non-potable water for ultimate
development. The most appropriate source is
the BWS R-1 reclaimed water system. RMTC
proposed to use as much of the existing
system when the lines are replaced. Non-
potable R-1 water is presently available but
new developments are likely to require the
generation of additional R-1 water supply.
The BWS currently produces reclaimed
water that exceeds its current commitments
(including full buildout of the City of Kapolei)
by 2.7 mgd. This capacity is expected to
increase when the City improves its secondary
treatment capacity at the Honouliuli
Wastewater Treatment Plant (scheduled
completion in 2025) and the BWS expands its
reclaimed water facility. Most of the current
supply is allocated to existing developments.
The preliminary R-1 projection of 0.983 mgd
average daily flow is sizeable and requests for
non-potable water service should be made
after approval of the Kalaeloa Master Plan
update. While the non-potable water may not
be required immediately, the request would
allow the BWS to evaluate their non-potable
water resource situation and work with
the City on the expansion to the Honouliuli
WWTP, to determine when additional non-
potable water can be made available to the
existing system or if new users must wait until
additional water reclamation facilities are
constructed.
The BWS has agreed to provide R-1 non-
potable water when it is available. For a
private system, the R-1 non-potable water
will be provided by a meter off Kamokila
Boulevard, where Roosevelt Avenue meets
Geiger Road. As KWC brings the potable water
distribution system up to current standards,
it would be most cost-effective if the non-
potable system were upgraded at the same
time so that additional parcels can receive
KWC potable and BWS non-potable water.
During the conversion from the original system
to KWC standard water lines, the dual water
systems may have to be operated separately.
The replacement of the existing water lines as
identified in Section 4.1.5, above, may provide
the opportunity to rehabilitate the existing
lines for non-potable water distribution. With
the exception of the 24-inch line from the
wells to Kalaeloa, along Roosevelt Avenue and
Enterprise Street and the 18-inch line along
Roosevelt Avenue and Coral Sea Road.
Most of the remaining existing water lines
in Kalaeloa may be used for the non-potable
water system if these pipes fall within the
future road rights-of-way. The Navy has stated
that these pipes are cast or ductile iron and
it may be possible to rehabilitate these pipes.
However, because these pipes are currently
owned by KWC, their rehabilitation and reuse
would have to be coordinated with KWC.
4.1.7 Sewer
In July 2016, RMTC prepared a Pre-Final
Kalaeloa Sewer Master Plan. The plan
concluded that Kalaeloa’s sewer system
will require modifications and upgrades to
accommodate anticipated future sewage
flows. Like the potable water system, the
sewer system is owned and operated by KWC.
Full development of Kalaeloa would
significantly increase the average wastewater
daily base flow from 0.35 mgd to 3.1 mgd.
Page: 101
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 4:03:42 PM
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:04:28 PM
Restate the following that was previously mentioned :
Although a draft report, it remains the most thorough assessment that
has been done in Kalaeloa to date.
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:04:49 PM
Restate the following that was previously mentioned :
Although a draft report, it remains the most thorough assessment that
has been done in Kalaeloa to date.
98
KALAELOA MASTER PLAN
DRAFT
However, as in other utility reports prepared
by RMTC, buildout was assumed to be less
than what was allowed based on parcel-
specific land utilization factors. It is important
to reassess those buildout assumptions to
ensure that the demand estimates in the
2016 sewer plan are still applicable. It is also
recommended that the 2016 sewer plan be
reviewed and updated as necessary to reflect
any other changes in existing conditions,
updated demand assumptions, or operational
issues since that time.
As part of the plan, a hydraulic analysis of the
existing sewer system was undertaken and
concluded that, except for one pump station
located south of the airport’s runways, the
existing pump stations in Kalaeloa do not
have sufficient capacity to meet projected
wastewater flow requirements and are
proposed to be removed or abandoned.
One proposed change to the existing sewage
flow pattern is to discontinue the use of the
30-inch gravity line which conveys flow from
the east and west sewer lines beneath the
runways. Due to air traffic at the airport,
access to the sewer line is restricted and
limited; therefore, the RMTC plan proposed
that wastewater from the east and west
sewer lines converge at the same location
north of the airport, then pumped northward
towards Independence Road where it would
be discharged into a 30-inch gravity line and
conveyed east to the Honouliuli wastewater
treatment plant.
All new sewage facilities including pumping
stations and lines would be designed in
accordance with KWC and City standards.
Pumping stations would require a large
concrete dry pit to house the pumps, a
building over the pit for ancillary equipment,
and a separate room for a standby generator.
Where such stations are visible to the public,
they should be screened with landscaping
or provided with design details that relate to
the architecture of the area. Developers at
Kalaeloa will be assessed sewer facility charges
by the City for offsite wastewater transport,
treatment, and disposal. Therefore, it is
recommended that any sewer master plan be
submitted to the City for approval.
Page: 102
Author: Hunt
Subject: Cross-Out
Date: 9/1/2025 4:05:10 PM
DRAFT
101
KALAELOA MASTER PLAN
4.3 Financing
In the implementation of the Master
Plan, private developers will finance new
development for their projects and public
agencies will finance new improvements on
their lands. The remaining piece of financing
is for the construction of new infrastructure
and utility systems to serve public and private
sector developments.
4.3.1 Grant Sources
The U.S. Department of Commerce’s Economic
Development Administration (EDA), through
its Public Works and Economic Development
Facilities Assistance Program, provides funds
for infrastructure improvements that promote
economic development. Total EDA awards
at other former military bases show that
bases which attracted the most funding each
received between $8 and $11 million.
Major roadways and improvements that
support transit use or alternative modes
of transportation may be eligible for other
funding sources, particularly the Infrastructure
Investment and Jobs Act, also known as the
Bipartisan Infrastructure Law, enacted in 2021.
These funds are typically provided through
regional metropolitan planning organizations
(MPOs). The HCDA will work with the O‘ahu
MPO to secure available funds.
4.3.2 Bond Financing
The remaining cost of infrastructure
improvements will need to be financed
through bond issuances that, depending
upon the type of bond, will be repaid either
from assessments on property owners or tax
revenues generated by new development
at Kalaeloa. A range of bond tools can be
used, but since repayment is based on new
development, their use will be limited to
infrastructure serving new development
projects.
Financing for infrastructure improvements
on lands owned by public agencies could be
accomplished through state-issued general
obligation bonds.
4.3.3 Hawai‘i Community Development
Authority Special Assessment
Bonds
The HCDA, subject to authorization by the
Legislature, may issue and sell bonds to
provide funds to finance public facilities that
are backed by assessment on benefitting
landowners. The salability of these bonds
would likely be based upon the bond market’s
confidence that the landowners directly
affected by the improvements would be able
to cover bond payments, regardless of the
timing of new development.
4.3.4 Community Facilities District
Bonds
The State has provided counties with the
authority to issue Community Facilities
District bonds that can be used to finance
infrastructure improvements (HRS §46-80.1).
Community Facilities District bonds are paid
through assessments on future property
owners and are thus backed by the property
rather than the City. Community Facilities
District bonds also require that the financed
improvements be dedicated to the City.
One limitation of Community Facilities District
bonds is that they tend to slightly reduce the
sale prices and value of new development,
in order to offset the additional assessments
that property owners must pay. These bonds
are backed by the bond market’s confidence
in market conditions and the proposed
development project, and thus may not be
saleable until developers are selected.
4.3.5 Federal Infrastructure Funds
In 2021, President Biden signed the
Infrastructure Investment and Jobs Act “to
authorize funds for Federal-aid highways,
highway safety programs, and transit
programs, and for other purposes.” This Act
and other subsequent funding legislation may
provide opportunities to help finance certain
infrastructure projects in Kalaeloa.
Page: 105
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:08:34 PM
HCDA will play a critical leadership role in planning, coordinating, and
financing regional improvements to improve connections between
Kalaeloa and adjoining areas, including Kapolei, ‘Ewa Beach, and
Campbell Industrial Park.
Author: Hunt
Subject: Comment on Text
Date: 9/2/2025 3:00:37 PM
Public agencies, both federal and state, should pay their fair share of
infrastructure costs, be it through Payment in Lieu of Taxes (PILT), GO
bonds or other. We respectfully request that the Master Plan include
language recognizing the importance of equitable infrastructure
financing and affirming HCDA’s commitment to securing
contributions from federal and state agencies.
102
KALAELOA MASTER PLAN
DRAFT
Tax Increment Finance Bonds
The State has authorized counties to issue Tax
Increment Finance bonds that can be used
to finance infrastructure improvements (HRS
§46-101 et. seq.). A tax increment district is
first established for an area to be redeveloped.
As new development occurs, the incremental
additions in property tax revenues that are
generated (after deducting the costs of new
municipal services such as public safety, public
works, etc.) can be used to finance bonds.
This technique does not result in an increase in
property tax rates, nor does it impact activities
that are currently funded by existing property
tax revenues in the tax increment district.
Because Tax Increment Finance bonds are
repaid from property taxes that new property
owners have to pay, there is no potential
impact on property values as there is with
Community Facilities District financing.
The limitation of Tax Increment Finance
bonds is that there must be an existing tax
increment flow to finance bonds. This means
that Tax Increment Finance bonds may be
more appropriate in later phases in Kalaeloa’s
development.
Page: 106
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:09:28 PM
We request HCDA to add "It is common practice to combine Community
Facilities District (CFD) financing to supplement TIF financing to offset
low property tax revenues in the early years of a district-wide effort."
104
KALAELOA MASTER PLAN
DRAFT
interagency coordination is critical if the
Master Plan is to be successfully implemented.
There are several ways in which this
coordination can occur, which involve varying
degrees of formality. At the most informal
level, agency-to-agency contact through
meetings and written correspondence on
a frequent basis can address many of the
coordination issues involved in development
planning and project implementation.
When specific property maintenance or
development agreements are necessary, more
formal means of coordination are required.
Depending upon the circumstances, a formal
Memorandum of Agreement or contract
between parties may be warranted and can be
negotiated in such a manner that conditions
of the agreement are binding upon the
parties.
Another method is the creation of a Kalaeloa
Redevelopment Leadership Group consisting
of the HCDA, DHHL, HDOT-A, and the Navy
to seek major infrastructure development
funding from federal and State sources. The
funding and implementation of significant
projects by this Leadership Group will
incentivize further investment by other
Kalaeloa landowners, catalyzing development
in the District.
Led by the HCDA, the Leadership Group would
meet regularly to do the following:
y Explore the implementation challenges
to create shared problem framing. These
challenges might involve changing the
status quo.
y Reconnect the long-term and short-term.
This group would be asked to create
specific tactics for moving forward,
(e.g., solving the electrical grid hookup),
identify fundamental changes and
corresponding actions needed to reach
the envisioned future.
y Engage and anchor the vision of the
Master Plan with relevant agencies,
departments, and landowners thereby
relating it to their own objectives and
practices.
The third, and most formal, mechanism for
coordination is through the enactment of
legislation. Depending upon the circumstances
and the parties involved, legislation could
be sought at the federal, State, or City level.
Legislation should be considered when seeking
funding or when there are structural changes
in the authority or relationships between
parties. Since such actions are subject to
public debate and policy making, uncertainties
exist in the process. Further, the timing
required for the passage of legislation may
adversely impact development phasing and
implementation.
Page: 108
Author: Hunt
Subject: Comment on Text
Date: 9/1/2025 4:10:23 PM
Add US Coast Guard, National Guard, and City & County.
Hunt Comments on HCDA’s KAL Draft Rules (July 2025)
Page 1 of 5
High Priority Comments:
#
Section
Comment
1
§15-215-43
Architectural
Standards.
For security and safety reasons, we request that HCDA add the following underlined language:
-
§15-215-43(C)(1)(F): “Within a required yard, walls and fences for industrial uses may be constructed up to
eight feet in height.”
-
§15-215-43(C)(2)(B): “Chain link or barbed wire fences and exposed cinder block walls are prohibited within
front yards abutting any boulevard, avenue, or main street, except when associated with industrial uses”
2.
§15-215-50 Ewa
Plain Battlefield
overlay zone
development
standards.
-
While we acknowledge that additional preservation sites may be required by SHPD in the future, the
preservation sites agreed to, specific to the Battlefield, are limited to 3. Therefore, we request that §15-215-
50(e)(1) be reworded to “The three primary preservation areas of the Ewa Plain Battlefield overlay zone are the
1943 compass rose, swimming pool, and warm-up mat on a portion of the extant runway.’”
-
We request striking “and a through Philippine Sea Street” from §15-215-50(e)(2) and have it read “Development
within the vicinity of these sites shall be compatible with future plans to provide public access to each site.”
Philippine Sea St is not currently designed to City & County Standards and may require realignment in the
future.
-
It appears §15-215-50(d)(5) is inadvertently numbered and should be §15-215-50(d)(4)
3.
§15-215-63
Historical and
cultural sites.
-
We recommend revising the language in §15-215-63(b) to read: “Prior to a permit application being deemed
complete by the authority, a developer shall…”
o
This change better aligns with HRS §6E-42 and HAR §13-284-1, which establishes that the State
Historic Preservation Division (SHPD) review process begins after a permit application is submitted to
a state or county agency. Requiring SHPD review before submittal creates confusion and may conflict
with the legally defined sequence of review. Based upon prior communication with SHPD we
understand that SHPD does not begin review until after a permit application has been submitted,
consistent with the rules.
-
We recommend revising the language in §15-215-63(c) to read: “Developers shall take reasonable steps to
ensure all historic or culturally significant properties are properly maintained and kept in good repair,
consistent with the age and condition of the properties.”
4.
§15-215-80
Conditional Use
of Vacant Land.
§15-215-85
Approval validity
Period
We request that HCDA extend the allowable duration for the following permit types:
-
Conditional Use of Vacant Land (§15-215-80(a)(2)): We recommend amending this section to allow the permit
to remain effective until the area is redeveloped in conformance with the underlying transect zoning. In
practice, this permit has been a valuable tool for reactivating Kalaeloa properties during interim periods (prior
to market conditions that make redevelopment feasible), helping to bring people, jobs, and economic activity
to the district ahead of full redevelopment.
-
Renovation Permits (§15-215-85(a)): We recommend allowing time extensions for renovation permits, as
permitting and other delays often exceed the one-year approval period following HCDA approval.
Hunt Comments on HCDA’s KAL Draft Rules (July 2025)
Page 2 of 5
#
Section
Comment
5.
Figure 7: Land
Use
We request that HCDA consolidate “warehousing” under the broader category of “light industrial” in the land use table.
Warehousing is a typical component of light industrial operations and is already cited as an example within HCDA’s
definition of “light industrial.”
6.
New Proposed
Section:
Warehouse
Overlay Zone
development
standards
We recommend adding the Warehouse Overlay Zone development standards. Proposed language is listed below.
Hunt recognizes that there may be additional ways to address this, such as a Memorandum of Agreement or
Programmatic Agreement, and is open to discussing this further with HCDA, the Navy, and historic partners.
Warehouse Overlay Zone development standards
(a) Purpose. Eleven WWII Storage Buildings are eligible for listing in the National Register of Historic Places as
contributing resources to a potential warehouse historic district associated with WWII-era development of
MCAS-Ewa. The scale and land uses of new development impacting the Warehouse District shall be
compatible with the site's historical significance.
(b) The Warehouse District includes a five-foot perimeter surrounding the exterior surfaces of building slabs of
eleven World War II-era storage buildings: Quonset Huts #1144, #1149, #1150, #1152, #1153, #1562, #1570,
wood-frame warehouses #1142, #1143, #1145, and #1147, and the location of Building #1141. The area is
depicted in the regulating plan (Figure 2) in the Kalaeloa Community Development District (KCDD) Rules.
(c) Proposed undertakings affecting the Warehouse District shall adhere to the following requirements:
(1) Project development and design shall comply with the terms of any applicable historic covenants
attached to the property;
(2) The executive director or the authority may convene a design advisory board to review projects impacting
the Warehouse District, as pursuant to section 15-215-78(f).
(d) Review and approval procedures:
(1) Project reviews shall be initiated through the authority’s permit application processes;
(2) All applications shall include the supporting documentation in accordance with state HRS chapter 6E and
federal regulations, as applicable;
(3) As applicable under HRS sections 6E-8, 6E-10 and 6E-42, the process will follow the prescribed steps and
timelines;
(4) The authority may enforce any applicable protective covenants, and may incorporate applicable provisions
into permit conditions.
(e) Protections of the World War II Storage buildings within the Warehouse District overlay zone:
(1) The World War II Storage buildings determined to be eligible for the National Register of Historic Places
(Buildings 1144, 1149, 1150, 1152, 1153, 1562, 1570, 1142, 1143, 1145 and 1147) shall be retained in a manner
consistent with the Secretary of the Interior’s Standards for Treatment of Historic Properties, until such time
that any of the structures are proposed for removal or renovation.
(2) At the time any of the eleven structures are proposed for removal or renovation, interpretation for the
education of the community will be included in the mitigation of any project’s adverse effects on the
Hunt Comments on HCDA’s KAL Draft Rules (July 2025)
Page 3 of 5
#
Section
Comment
warehouse district. The interpretation shall include the history of the warehouse district buildings and their
context within the WWII buildup and activity at the Marine Corps Air Station-Ewa.
Additional Comments
#
Section
Comment
1.