**TABLE OF CONTENTS**

**Item Page**

**Chapter 1. Purpose and Need**

> 1.1 Background
> ................................................................................
> 4
>
> 1.2 Purpose and
> Need........................................................................
> 4
>
> 1.3 Park Fire Management Goals and
> Objectives..................................... 5
>
> 1.3.1 Enabling Legislation
>
> 1.3.2 Resource Management Plan Goals and Objectives
>
> 1.3.3 Park Fire Management Goals
>
> 1.4 Park Fire
> History...........................................................................
> 7
>
> 1.5 Scoping, Issues and Impact
> Topics...............\.................................... 7
>
> 1.5.1 Scoping
>
> 1.5.2 Issues Considered
>
> 1.5.3 Impact Topics Addressed and Analyzed
>
> 1.5.4 Impact Topics Considered and Dismissed

**Chapter 2. Alternatives**

> 2.1 Alternatives Considered and
> Analyzed.............................................. 13
>
> 2.1.1 Alternative 1, No Action
>
> 2.1.2 Alternative 2, Minimum Management Action
>
> 2.1.3 Alternative 3, Preferred Action
>
> 2.1.4 Comparison of Alternatives
>
> 2.1.5 Additional NEPA Compliance Needed
>
> 2.2 Alternatives Considered and
> Dismissed............................................ 14
>
> 2.2.1 Alternative that Includes Prescribed Fire for Fuels Reduction
>
> 2.2.2 Alternative that Includes Prescribed and Wildland Fire for
> Resource
>
> Benefits
>
> 2.3 Environmentally Preferred
> Alternative............................................... 15

**Chapter 3. Methodology and Impact Definitions**

> 3.1
> Methodology...............................................................................
> 16
>
> 3.2 Impact Definitions Specific to Cultural
> Resources\...\...\...\...\...\...\...\...\...\...\...\..... 16
>
> 3.2.1 Direct Impacts
>
> 3.2.2 Indirect Impacts
>
> 3.2.3 Observed Effects
>
> 3.3 Impact
> Definitions\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...
> 17
>
> 3.4
> Impairment\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\...\.....
> 18

**Chapter 4. Environmental Analysis and Mitigation**

> 4.1
> Soils..........................................................................................
> 20
>
> 4.1.1 Affected Environment
>
> 4.1.2 Environmental Consequences
>
> 4.1.3 Mitigation Measures
>
> 4.1.4 Conclusion
>
> 4.2 Air
> Quality...................................................................................
> 22
>
> 4.2.1 Affected Environment
>
> 4.2.2 Environmental Consequences
>
> 4.2.3 Mitigation Measures
>
> 4.2.4 Conclusion
>
> 4.3
> Soundscapes................................................................................
> 24
>
> 4.3.1 Affected Environment
>
> 4.3.2 Environmental Consequences
>
> 4.3.3 Mitigation Measures
>
> 4.3.4 Conclusion
>
> 4.4 Water
> Resources..........................................................................
> 27
>
> 4.4.1 Affected Environment
>
> 4.4.2 Environmental Consequences
>
> 4.4.3 Mitigation Measures
>
> 4.4.4 Conclusion
>
> 4.5 Threatened and Endangered
> Species................................................ 30
>
> 4.5.1 Affected Environment
>
> 4.5.2 Environmental Consequences
>
> 4.5.3 Mitigation Measures
>
> 4.5.4 Conclusion
>
> 4.6 Vegetation and
> Wildlife....................................................................
> 33
>
> 4.6.1 Affected Environment
>
> 4.6.2 Environmental Consequences
>
> 4.6.3 Mitigation Measures
>
> 4.6.4 Conclusion
>
> 4.7 Visitor
> Use....................................................................................
> 39
>
> 4.7.1 Affected Environment
>
> 4.7.2 Environmental Consequences
>
> 4.7.3 Mitigation Measures
>
> 4.7.4 Conclusion
>
> 4.8 Wildland Urban
> Interface.................................................................
> 41
>
> 4.8.1 Affected Environment
>
> 4.8.2 Environmental Consequences
>
> 4.8.3 Mitigation Measures
>
> 4.8.4 Conclusion
>
> 4.9
> Caves..........................................................................................
> 43
>
> 4.9.1 Affected Environment
>
> 4.9.2 Environmental Consequences
>
> 4.9.3 Mitigation Measures
>
> 4.9.4 Conclusion
>
> 4.10 Cultural
> Resources.......................................................................
> 45
>
> 4.10.1 Affected Environment
>
> 4.10.2 Environmental Consequences
>
> 4.10.3 Mitigation Measures
>
> 4.10.4 Conclusion

Glossary of Terms

> Fire
> Management................................................................................
> 53
>
> Hawaiian............................................................................................54

Planning
Team........................................................................................55

Consultants............................................................................................
55

Environmental Assessment
Recipients........................................................ 56

References.............................................................................................57

**LIST OF TABLES**

**Table Page**

1 Summary of
Alternatives..................................................................
13

2 Table of
Species............................................................................
52

**List of Figures**

**Figure Page**

1 Vicinity, Island and Park
Map.......................................................... 12

**CHAPTER 1.** **PURPOSE AND NEED**

### 1.1 Background 

Pu'uhonua o Honaunau National Historical Park (NHP) is located on the
southwestern coast of the Big Island of Hawaii (Figure 1). The
pu\'uhonua was a sanctuary where, up until the 19^th^ century, Hawaiians
who broke a *kapu* (sacred law) and others from Hawaiian society could
seek refuge. The Park also contains the royal grounds outside of the
pu'uhonua, archeological resources, and Ki'ilae village.

The 181-acre park was established in 1961. The enabling legislation for
Pu'uhonua o Honaunau NHP (16 USC Chapter 1, Subchapter XLIII, § 397)
established that the park be set aside for "the benefit and inspiration
of the people."

The Park contains a wealth of cultural and historic resources that
together, serve to re-create the atmosphere of Hawaiian life prior to
contact with Western civilization. In particular, the park preserves a
complex of archeological sites, including temple platforms, royal
fishponds, sledding tracks, and coastal village sites.

Although the Park was created largely to preserve the cultural history
it illustrates, there are also notable natural resources. The topography
was formed primarily from prehistoric lava flows emanating from flank
and summit eruptions of Mauna Loa Volcano, which is located to the east
of the park. Habitat exists for many wildlife species, including native
species and those species considered threatened and endangered.

**1.2 Purpose and Need**

This programmatic environmental assessment documents the potential
environmental impacts from the proposed actions in the parks Fire
Management Plan and site specific analysis of prescribed fire.

This EA has been prepared in compliance with:

-   The National Environmental Policy Act (NEPA) of 1969 (42 United
    States Code (USC) §4321 et seq.), which requires an environmental
    analysis for major Federal Actions having the potential to impact
    the quality of the environment;

-   Council of Environmental Quality Regulations at 40 Code of Federal
    Regulations (CFR) 1500-1508, which implement the requirements of
    NEPA;

-   National Park Service Conservation Planning, Environmental Impact
    Analysis, and Decision Making; Director's Order (DO) #12 and
    Handbook.

Key goals of NEPA are to help Federal agency officials make
well-informed decisions about agency actions and to provide a role for
the general public in the decision-making process. The study and
documentation mechanisms associated with NEPA seek to provide
decision-makers with sound knowledge of the comparative environmental
consequences of the several courses of action available to them. NEPA
documents, such as this EA, focus on providing relevant information to
assist the agency in making appropriate decisions. In this case, the
Superintendent of Pu'uhonua o Honaunau NHP is faced with a decision
about the fire management activities to be included in the park's Fire
Management Plan.

The primary purpose of the park's fire management program is to protect
people, property, and natural and cultural resources from the effects of
fire and to integrate with other park programs.

The park does not have an approved Fire Management Plan. National Park
Service (NPS) policy specifies that every NPS Unit with burnable
vegetation will have an updated Fire Management Plan (FMP) approved by
the Superintendent. NPS Policy, which adheres to the federal policy,
recognizes wildland fire as an important ecological and evolutionary
force in many terrestrial ecosystems. It also recognizes the need for
wildland fire to be managed in order to fulfill the agency's goals to
protect, perpetuate or recreate natural environments and historic
scenes/landscapes.

Fire management strategies for Pu'uhonua o Honaunau NHP must be designed
based on park specific characteristics, legislative obligations,
environmental and social considerations, cultural, and natural resource
objectives.

**1.3 PARK Fire Management Goals and Objectives**

The park fire management goals and objectives are derived from the
enabling legislation that created Pu'uhonua o Honaunau NHP and other
federal laws that affect the management of the park, the park's Master
Plan, and the park resource management goals and objectives.

**1.3.1 Enabling Legislation for Pu'uhonua o Honaunau National
Historical Park**

Pu'uhonua o Honaunau NHP was established by an act of Congress on July
26, 1955, "for the benefit and inspiration of the people". Enabling
legislation that led to the establishment of this National Historical
Park and its significance are:

-   The Organic Act of August 25, 1916, §102, established the National
    Park Service (NPS) and defined the purpose of the agency as "to
    conserve the scenery and the natural and historic objects and the
    wildlife therein and to provide for the enjoyment of the same in
    such manner and by such means as will leave them unimpaired for the
    enjoyment of future generations.\"

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-   National Trust Act of March 27, 1978 (P.L. 96-250) in which
    "Congress declares that ...... the protection, management, and
    administration of ...... (the National Parks)... shall be conducted
    in light of the high public value and integrity of the National Park
    System and shall not be exercised in derogation of the values and
    purposes for which these various areas have been established, except
    as ... directly and specifically provided by Congress."

**1.3.2 Resource Management Plan Goals and Objectives**

The Pu'uhonua o Honaunau NHP Resource Management Plan (RMP) identifies
the park's primary resource goal and discusses objectives recommended to
meet that goal. The RMP, derived from the park's Master Plan, was
written in 1994, and revised in 1999.

The overall management goal for this historical park is for the
resources to accurately represent a slice of time ranging from
pre-contact (circa 1700) to about 1926 when Ki'ilae Village was
completely abandoned. This plan stresses the pre-contact period and the
preservation of resources which relate to the later periods. Objectives
developed to meet that goal are threefold in that they focus on
preservation, stabilization, and restoration of the parks significant
cultural and natural resources:

The following resource management objectives serve as a basis for
resource planning and guide the fire management in the park:

-   Preserve and interpret selected historic structures through
    stabilization and historical restoration.

-   Continue detailed studies on specific prehistoric features for
    park-wide interpretive programs and preservation. Protect and
    preserve these archeological features through stabilization.

-   Restore the historic scene.

-   Continue and encourage the traditional Hawaiian uses of the land and
    sea.

-   Develop and maintain an upland garden to preserve native plants and
    to produce plant materials for cultural demonstrations.

-   Continue studies of alien vegetation as a basis for implementing an
    urgent control program and a program for replanting native
    vegetation.

-   Give special attention to ecological research on the intertidal zone
    and the means of giving it adequate protection for interpretation.

-   Provide fire protection for the reconstructed Hale-o-Keawe without
    affecting the aesthetics and authenticity of this thatched
    structure.

**1.3.3 Park Fire Management Goals**

-   Firefighter safety is the highest priority of every fire management
    activity.

-   Suppress all wildland fires regardless of ignition source to protect
    the public, private property, natural, cultural and historic
    resources of the unit.

-   Utilize suppression methods/tactics least damaging to resources and
    the environment.

-   Use prescribed fire where and when appropriate as a tool to meet
    resource objectives within the unit.

-   Maintain the highest standards of professional and technical
    expertise in planning and safely implementing an effective wildland
    fire management program.

-   Fire personnel will be equipped with personal protective equipment
    appropriate to incident assignment.

-   All NPS employees assigned to wildland fire incidents, or used with
    prescribed fire, will meet training and qualification standards for
    that position, set by the National Wildfire Coordinating Group (NWCG
    310-1).

-   Mutual aid cooperators, responding to NPS fires under Memoranda of
    Agreement, will meet their respective personal protective equipment
    and qualifications during initial action operations. However, during
    project fire or extended operations, cooperators will meet NWCG
    qualification standards.

-   Educate employees and the public about the scope and effect of
    wildland fire management, including fuels management and resource
    protection.

-   Integrate fire management with all other aspects of park management.

**1.4 PARK FIRE HISTORY**

The fire history of the park extends from the mid-late 1970s to present.
There were a total of two wildfires and three prescribed burns.

The most recent wildfire occurred in March of 2004. A small fire was
discovered near the old dump area, within a tenth of a mile southeast of
the maintenance shop. The second wildfire occurred sometime prior to
1986 in the coconut grove located mauka (towards the mountain) of the
pu'uhonua. Both fires were detected early, less than one tenth of an
acre in size, ignited from an unknown/undetermined source, and
extinguished within the same day with the assistance of the Hawai'i
County Fire Department.

A prescribed research burn was conducted on January 7, 1998, at 6:00
p.m. by Jack Minassian, retired NPS Fire Management Officer. The goal
and objective for the burn was to study the effects of fire on pili
grass, conducted by Linda Pratt. The burn occurred in the visitor center
parking lot island where pili grass was planted. Total area burned was
one tenth of an acre, which lasted approximately 30 minutes.

Two prescribed burns were conducted in the late 1980's. Both burns were
located south of the Alahaka Ramp to the Ki'ilae boundary. The first
burn occurred makai (towards the sea) of the 1871 trail and the second
burn covered mauka of the 1871 trail. Each of the two burns lasted for
one week. No further historical information is available on these fires.

**1.5 SCOPING, ISSUES AND IMPACT TOPICS**

**1.5.1 Scoping**

The Planning/Interdisciplinary Team met on several occasions from April
through September 2005. The team identified four issues, developed five
alternatives, three of which are analyzed in this environmental
assessment, and two that were dismissed from further consideration
(Chapter 2). The team also reviewed impact topics to be analyzed
(section 1.5.2) and determined which topics needed no further
consideration (section 1.5.3).

**1.5.2 Issues Considered**

-   Issue: The Park must have an approved FMP.

-   Issue: Current practice of wildfire suppression without an approved
    FMP does not provide an adequate level of protection for park
    resources, persons and property from wildfire and suppression
    efforts.

-   Issue: Burnable fuel and biomass loading presents a higher risk of
    wildfire starts and a higher intensity fire which could destroy
    native plant seed banks and promote greater spread of exotics such
    as kiawe and ekoa.

-   Issue: Prescribed fire has been used in the past to manage pili
    grass with positive results.

**1.5.3 Impact Topics Addressed and Analyzed**

> Soils*.*
>
> NPS Management Policies (2001) require the consideration of impacts on
> topography and soils. Soils may be potentially affected by fire;
> therefore, it is included as an impact topic.

Air Quality**.**

The Clean Air Act and subsequent amendments (42 USC §7401 et seq.)
stipulates that federal land managers have an affirmative responsibility
to protect a park's air quality from adverse pollution impacts. Air
quality in the park and the surrounding community would be affected by
either wildfire or a prescribed fire incident within the park and is
therefore analyzed as an impact topic.

> Soundscapes*.*
>
> NPS Management Policies (2001) require that parks maintain their
> natural soundscapes. Fire management activities may impact natural
> soundscapes; therefore, soundscapes will be considered as an impact
> topic.
>
> Water Resources.
>
> NPS policies require protection of water resources consistent with the
> Clean Water Act. No perennial streams flow in the park. One small
> intermittent stream crosses the park at the southern end and drains
> into the ocean. The park does have anchialine pools and this topic
> will be analyzed further.

Threatened and Endangered Species.

The Endangered Species Act requires disclosure of impacts resulting from
management actions on all federally threatened or endangered species.
There are four threatened or endangered vertebrate species found within
in the park boundaries. The park contains anchialine pools and therefore
may contain associated invertebrate candidate endangered species.
Additionally, the endangered palm, loulu (*Pritchardia affinis)* has
been reintroduced to the park. These threatened and endangered species
may be impacted by fire incidents in the park and will be analyzed
further.

> Vegetation and Wildlife*.*
>
> NEPA requires analysis of impacts on all affected components of the
> ecosystem, including native biotic communities of plants and animals.
> NPS Management Policies (2001) requires maintenance of native
> ecosystems and communities, including their natural abundance,
> diversity and ecological integrity. Incidents of fire within the park
> will affect vegetation and wildlife which will be analyzed as an
> impact topic.
>
> Visitor Use.
>
> The mission of the NPS, as described by its Organic Act of 1916,
> states the purpose of all parks is to ". . . conserve the natural and
> historic objects and the wildlife therein and to provide for the
> enjoyment of the same . . . ." Scenic values, recreational activities,
> and general visitation within and around fire-treated areas may be
> temporarily impacted, thus visitor use will be considered as an impact
> topic.
>
> Wildland/Urban Interface*.*
>
> DO-18, Wildland Fire Management, stipulates that firefighter and
> public safety must be first priority in all fire management
> activities. The Wildland/Urban Interface (WUI) will be considered as
> an impact topic.
>
> Caves*.*
>
> The Federal Cave Protection Act of 1988 and NPS Management Policies
> (2001) require federal agencies to protect cave resources. There are
> several caves in the park which may be affected by fire or fire
> suppression activities, therefore caves will be included as an impact
> topic.

Cultural Resources.

The National Historic Preservation Act (NHPA) and the NPS Cultural
Resources Management Guidelines and Policies (Director's Order 28)
require the assessment of effects to cultural resources listed or
eligible for listing on the National Register of Historic Places. The
park is listed on the National Register of Historic Places, contains
archeological and cultural resources that may be affected by the park's
fire management program, and is therefore included as an impact topic.

# 1.5.4 Impact Topics Considered and Dismissed

> Environmental Justice.
>
> Executive Order 12898, Federal Actions to Address Environmental
> Justice in Minority and Low-Income Populations, broadly states that
> federal activities, programs, and policies should not produce
> disproportionately high and adverse impacts on minority and low-income
> populations, nor should these populations be denied the benefits of or
> excluded from participation in these activities, programs, and
> policies. The 2000 Census Demographic Profile for Honaunau-Napoopoo
> indicates that the community is neither predominantly minority or
> low-income. The alternatives considered in this EA will not adversely
> affect minority or low-income populations or communities, and will not
> be addressed further.
>
> Public Safety*.*
>
> There is a Memorandum of Understanding between the Hawaii County Fire
> Department (HCFD) and the NPS that provides for assistance during
> emergencies for the protection of life and property. Protection of
> life is of the utmost importance and people will be evacuated as
> needed by the most expeditious means during wildfire incidents with
> available resources of the HCFD and the NPS. Public safety will be
> assessed prior to prescribed fire activity. Therefore, public safety
> is not an issue to be analyzed in this environmental assessment.
>
> Firefighter Safety*.*
>
> The safety of firefighters is the highest priority in the Fire
> Management program. Safety protocols and standards will be described
> in the Fire Management Plan. Safety considerations will not be
> compromised; therefore, this subject will not be addressed further.
>
> Indian Trust Resources.
>
> Secretarial Order 3175 requires federal agencies to address
> environmental impacts of their preferred actions on Indian Trust
> Resources in any environmental document. There are no Indian Trust
> Resources in Hawai\`i. Therefore this topic is dismissed as an impact
> topic in this document.

## Socioeconomics. 

## Park visitors may provide some financial contribution to the nearby business and community, but the amount is minimal and short term. Should visitation to the park be temporarily halted due to fire management activities, the effect on the local area/business would be very minimal. Fire incidents within the park may bring a short-term need for additional personnel, but it would be minimal (less than 5-10 people) and would not affect the community's overall income or employment basis. 

> Prime or Unique Farmlands.
>
> The Council on Environmental Quality requires federal agencies to
> assess the effect of their actions on farmland soils classified by the
> U.S. Department of Agriculture's Conservation Service (NRCS) as
> "prime" or "unique." Prime or unique farmland is defined as soil that
> particularly produces general crops such as common foods, vegetables,
> and nuts. There are many farms in the Honaunau area, however, the
> limited scope of fire operations within the park, and the park's
> location down slope of local farms, will not affect farm land soils.
> Therefore, prime or unique farmlands will not be analyzed.

**Figure 1. Vicinity, Island, and Park Map**

![](media/image1.png){width="6.5569444444444445in"
height="8.470138888888888in"}

**cHAPTER 2. aLTERNATIVES**

**2.1 ALTERNATIVES CONSIDERED AND ANALYZED**

Five alternatives were considered for Pu'uhonua o Honaunau NHP's fire
management program, three of which were analyzed in Chapter 4. An
alternative that included the use of prescribed fire for fuel reduction
and an alternative that included the use of prescribed and wildfire for
resource benefits were considered and dismissed from further analysis.
Through the Environmental Analysis in Chapter 4, Alternative 3 was
identified as the environmentally preferred alternative.

**2.1.1 Alternative 1-No Action**

The park would continue the fire management program that exists today,
which is immediate suppression of all wildfire without an approved Fire
Management Plan (FMP). This Alternative is not a viable choice since it
does not provide for the required approved FMP. The existing impacts of
Alternative 1, No Action, sets a baseline of existing impacts continued
into the future against which to compare the impacts of Alternatives 2
and 3.

**2.1.2 Alternative 2-Minimum Management Action**

This alternative includes the completion of an approved Fire Management
Plan as required by Director's Order #18. This alternative also includes
the suppression of all natural and human ignited wildfires.

**2.1.3 Alternative 3-Preferred Action**

This alternative includes the completion of an approved Fire Management
Plan as required by Director's Order #18. This alternative also includes
the suppression of all natural and unplanned human ignited fires.
Prescribed fire will be limited to small scale research fires to
determine the prescription for the establishment and regeneration of
pili grass (*Heteropogon contortus*).

This alternative involves a strategy of a formalized annual review.

**Table 1. Summary of Alternatives**

  ----------------- -------------- --------------- --------------------------
  **Alternative**   **FMP**        **Wildfire      **Prescribed Fire**
                                   Suppression**   

  Alternative 1     No             Yes             No

  Alternative 2     Yes            Yes             No

  Alternative 3     Yes            Yes             Yes. Limited to small
                                                   scale research burns to
                                                   establish and regenerate
                                                   pili grass,
  ----------------- -------------- --------------- --------------------------

Alternative 3 is the park's preferred alternative.

**2.1.4 Comparison of Alternatives**

Common to the above three alternatives is the suppression of wildfire.
Alternative 1, No Action, does not provide for a FMP, required by
Director's Order #18. Alternative 2, Minimum Management Action, and
Alternative 3, Preferred Action, satisfy the requirement of a FMP. Only
Alternative 3, Preferred Action, provides for prescribed research burns
to establish and regenerate pili grass. Refer to Table 1, Summary of
Alternatives.

**2.1.5 Additional Compliance Needed**

This programmatic environmental assessment provides for generalized
level of impact from the proposed actions in the parks Fire Management
Plan and site specific analysis for the use of prescribed fire for pili
grass. However, it does not address all possible actions. For example,
Alternative 3, Preferred Action, allows for prescribed research burning
of pili grass in the visitor center parking lot, but it does not allow
for prescribed burning of pili grass elsewhere in the park. Expanding
the use of prescribed fire in areas of the park that is not analyzed in
this document may require additional NEPA compliance. Section 106
compliance to NHPA will also be conducted for all affected cultural
resources.

**2.2 ALTERNATIVES Considered and Dismissed**

**2.2.1 An alternative that includes the use of prescribed fire for the
reduction of burnable biomass and fuels.**

This alternative was considered and dismissed. Fuel reduction would
consist primarily of kiawe wood, also known as mesquite, (*Prosopis
pallida*) (which is substantial in size) and coconut fronds. Fire use to
eliminate kiawe and coconut fronds would burn very hot over a long
period of time, producing a fire that may be difficult to contain, and
may present an increased risk of impacts to cultural and natural
resources. The park currently removes the debris in high visitor use
areas (primarily the pu'uhonua, royal grounds, coconut grove located
mauka of the picnic area access road), and both sides of the picnic area
access road manually. The waste/burnable fuel is hauled out by a local
contractor. The current method of removal is preferred over the
increased risk of burning, and risk to cultural and natural resources.

**2.2.2 An alternative that includes the use of both prescribed fire and
wildland fire for resource benefits.**

This alternative was considered but dismissed for the lack of
information regarding the impacts of landscape scale use of fire, either
beneficial or adverse, to park resources at Pu'uhonua o Honaunau NHP.

**2.3 ENVIRONMENTALLY Preferred Alternative**

The NPS is required to identify the environmentally preferred
alternative(s) for any of its proposed projects. That alternative is
that which would promote the national environmental policy expressed in
NEPA (Section 101 (b)). This includes alternatives that:

> 1\) fulfill the responsibilities of each generation as trustee of the
> environment for succeeding generations;
>
> 2\) ensure for all Americans safe, healthful, productive, and
> esthetically and culturally pleasing surroundings;
>
> 3\) attain the widest range of beneficial uses of the environment
> without degradation, risk of health or safety, or other undesirable
> and unintended consequences;
>
> 4\) preserve important historic, cultural, and natural aspects of our
> national heritage and maintain, wherever possible, an environment that
> supports diversity and variety of individual choice;
>
> 5\) achieve a balance between population and resource use that would
> permit high standards of living and a wide sharing of life's
> amenities; and
>
> 6\) enhance the quality of renewable resources and approach the
> maximum attainable recycling of depletable resources.

In essence, the environmentally preferred alternative would be the
one(s) that "causes the least damage to the biological and physical
environment; it also means the alternative which best protects,
preserves, and enhances historic, cultural, and natural resources" (CEQ,
1978).

In this case, Alternative 3, Preferred Action, is the environmentally
preferred alternative for Pu'uhonua o Honaunau NHP since it best meets
goals 1, 2, 3, and 4 described above. Common to all three alternatives
is the suppression of wildfire which undoubtedly is beneficial to the
park, resources and community and best meets goals 1, 2, and 3. However,
Alternatives 2 and 3 are the only viable alternatives with the inclusion
of a FMP. Alternative 3 is the environmentally preferred alternative as
it is the only alternative that furthers the park's long term resource
management goals and objectives to help protect and preserve a native
plant community (pili grass) in the park, and is the alternative that
best meets goal 4 as described above.

**CHAPTER 3. methodology and impact definitions**

**3.1 METHODOLOGY**

Impact topics were analyzed for each alternative based on published and
unpublished reports, expertise and judgment of the Interdisciplinary
Team, and consultation with resource specialists. Impacts are described
by direct, indirect, and cumulative effects, type (beneficial or
adverse), duration (short or long term), and intensity (negligible,
minor, major, or impairment).

**3.2 impact definitions SPECIFIC TO Cultural Resources**

In addition to the procedures for assessing impacts described below,
cultural resources were further assessed in accordance with the Advisory
Council on Historic Preservation's regulations implementing Section 106
of the NHPA (36 CFR Part 800, *Protection of Historic Properties*),
impacts to archeological resources and the cultural landscape were
identified and evaluated by (1) determining the area of potential
effects; (2) identifying cultural resources present in the area of
potential effects that were either listed in or eligible to be listed in
the National Register of Historic Places; (3) applying the criteria of
adverse effect to affected cultural resources either listed in or
eligible to be listed in the National Register; and (4) considering ways
to avoid, minimize, or mitigate adverse effects.

# 

# 3.2.1 Direct Impacts

Direct impacts to cultural resources are caused by wildland fires and by
the human efforts to suppress them. The direct effects of fire depend
primarily on burn severity that is in turn dependent upon available
fuels, terrain, and weather conditions. Direct impacts to stone
artifacts and stone surface structures include thermal fracturing and
spalling, and destabilization of surface structures by either burning of
organic material embedded within the structure or by fire weakened trees
and limbs falling on structures. Other impacts include the alteration of
shell midden deposits and pollen remains within habitation complexes and
agricultural features. Rock art sites including petroglyphs are
susceptible to fire effects by sooting, discoloration, or in more severe
burns cracking and spalling. Historic structures (wooden and thatched
structures, fence lines, trail signage, etc.) are particularly
vulnerable to fire effects regardless of burn severity. Impacts to
glass, ceramics, and metal objects result from direct exposure to fire.
Fire effects with the highest potential to impact sites and features
include fire deadened or weakened trees and root burn out that can
destabilize surface architectural remains. To date, fire research
concerning cultural resources has focused primarily on individual
artifact classes and has not examined broader cultural landscape effects
except for overall environmental degradation within the post-fire
environment.

Operational impacts include suppression techniques such as construction
of hand line or machine line, explosive line construction, bucket drops,
and mop-up rehabilitation efforts. Direct impacts can also occur as a
result of landscape modification for spike camps (designated camp and
staging areas for fire fighting personnel) and associated facilities,
equipment staging areas, landing zones, and safety zones. Black lining,
or creating a back fire to consume available fuels in front of the
fire's path, and hose lays may also affect cultural resources within the
fire environment. Operational effects with the highest potential to
effect sites within the park include hand line construction that can
disturb sub-surface cultural remains or may collapse surface
architectural features. Hand line construction and bucket drops are the
predominant fire line suppression techniques that may be used within the
park. Explosive line and dozer line are not utilized within the park's
boundary as suppression tactics.

## 

## 3.2.2 Indirect Impacts

Indirect impacts are negative effects that occur in post fire
environments and include increased surface runoff and erosion, increased
tree mortality, and carbon contamination. Fire rehabilitation activities
such as outplanting to restore vegetation communities may also create
negative effects. Increased surface visibility of archeological remains
and surface artifacts may contribute to increased site disturbance and
looting activity within the fire area. Indirect effects most likely to
impact sites include carbon contamination and rehabilitation efforts
that result in ground disturbing activities.

# 3.2.3 Observed Effects

Fire effects on archeological resources (temporary habitation features
including C-shapes, terraces, platforms, habitation shelters and caves,
trails and trail markers, petroglyphs, enclosures, walls, and
agricultural features including mounds and excavated pits) were most
closely observed during the 2002 Kupukupu Fire at Hawaii Volcanoes
National Park. These effects were documented on pre-and post-burn forms
that recorded pre-existing site conditions and post-burn conditions for
located archeological features. Burn severity was primarily restricted
to low-moderate severity. No vandalism was noted during the post fire
assessment, and three types of fire effects were noted on feature types
that include smoke/soot damage, stump/root holes, and tree(s) on walls
or rubble. Few suppression impacts were noted during the survey and they
were limited to the Kalapana Trail (Site 20443). Impacts consisted of
the dislocation of basalt cobbles that lined portions of the trail; the
impacts represent an insubstantial alteration of the non-maintained
trail route.

**3.3 IMPACT DEFINITIONS**

[Negligible effects]{.underline}**.** No resources are present. If
resources are present, the effects would be less than detectable or
measurable.

[Minor effects.]{.underline} Direct or indirect impacts that would
result in detectable or measurable, localized, and temporary effects.

[Major effects.]{.underline} The action would have permanent direct
and/or indirect impacts on resources that are substantial and highly
noticeable.

[Direct effects.]{.underline} An impact that occurs as a result of the
action in the same place and time as the action.

[Indirect effects.]{.underline} Reasonably foreseeable impacts that
occur as a result of the action later in time or space.

[Cumulative effects.]{.underline} Cumulative impacts are the impact on
the environment, which results from the incremental impact of the action
when added to other past, present, and reasonably foreseeable future
actions regardless of what agency or person undertakes such other
actions.

[Mitigation Measures]{.underline}. An action taken to alleviate adverse
environmental impacts that may occur as a result of fire management
activities. Mitigation measures are common to all alternatives unless
otherwise specified.

If there are indirect impacts or cumulative impacts in the following
analysis, they will be specifically referenced by these terms. If these
terms are not used in the analysis, then indirect and cumulative impacts
are not expected.

**3.4 Impairment**

An impairment finding is required for each resource as part of the
environmental analysis of project alternatives (*Director's Order #12:
Conservation Planning, Environmental Impact Analysis, and
Decision-Making*). The National Park Service Management Policies (2001)
state that impairment is an impact that would harm the integrity of park
resources or values. Whether an impact meets this definition depends on
the particular resources and values that would be affected; the
severity, duration, and timing of the impact; the direct and indirect
effects of the impacts; and the cumulative effects of the impact in
question and other impacts. An unmanaged or unmitigated impact to any
park resource or value hypothetically could result in impairment. An
impact would be more likely to constitute impairment to the extent that
it affects a resource or value whose conservation is:

• Necessary to fulfill specific purposes identified in the establishing
legislation or proclamation of the park;

• Key to the natural or cultural integrity of the park or to
opportunities for enjoyment of the park; or

• Identified as a goal in the park's general management plan or other
relevant National Park Service planning documents.

An impact would be less likely to constitute impairment to the extent
that it is an unavoidable result, which cannot reasonably be further
mitigated, of an action necessary to preserve or restore the integrity
of park resources or values. Hypothetically, a prohibited impairment may
occur from visitor activities, NPS activities in the course of managing
a park, or from other government agencies, concessionaires, contractors,
cooperators, or others operating in the park. Therefore a determination
on impairment is made for all resource impact topics.

**Chapter 4. environmental analysis and mitigation measures**

**4.1 SOILS**

**4.1.1 Affected Environment**

The park is located at the base of the western slope of Mauna Loa and
extends from the shoreline to about 100 feet in elevation at the eastern
boundary, except for the Keanae'e Pali, which rises dramatically to
about 120 feet in elevation near the coast. Barren pahoehoe lava flows
make up most of the park's terrain and very little soil is present in
the park. Pockets of soil average four to six inches deep, and rarely
exceeds ten inches in depth (NPS 1976).

The park's substrate is made up of three lava flows. The largest and
most recent is the 750-1500 year old flow that extends from the northern
part of the park to the Keanae'e Cliffs. The 3000-5000 year old flow
extends from the Keanae'e Cliffs to the southwestern boundary of the
park. The 1500-3000 year old flow covers the southeastern tip of the
park.

2.  **Environmental Consequences**

    1.  [Alternative 1, No Action]{.underline}

> Suppression of all wildfires would have both a direct, beneficial,
> short term, minor effect to soils as well as a direct, adverse, short
> to long term, minor to major impact to soils. Beneficial effects
> include reducing the size of the burn by suppression and therefore the
> amount of soil available for erosion. Soils would be subjected to
> potential erosion as a result of fire and fire suppression activities
> for a short time because of rapid regrowth of vegetation. Adverse
> effects from suppression activities include scraping soil to bedrock,
> displacing minimal amount of soils within the park.
>
> 4.1.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The impacts to soils as a result of wildfire suppression are stated in
> Alternative 1.
>
> The required Fire Management Plan will improve the park's ability to
> suppress or reduce wildfire incidents and lessen the adverse effects
> of wildfire suppression stated above in Alternative 1. Suppression
> activities under this alternative will produce direct beneficial minor
> long term effects by addressing multiple aspects of wildfire,
> including, safety, prevention, preparedness, initial attack, and
> non-fire fuel reduction. MIST would also identify techniques that
> would reduce disturbance to soils from fire suppression activities.
>
> 4.1.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The impacts of wildfire suppression and a Fire Management Plan are
> stated above in Alternatives 1 and 2.
>
> Small-scale research burning of pili grass would have direct,
> beneficial, minor, long term localized impact to soils. The park has
> planted pili grass within the median island of the Visitor Center
> parking lot. Low intensity fires are desired for the regeneration of
> pili grass (C. Daehler, pers. communication). Fuel accumulation is
> light, consisting primarily of fine fuels generated by the pili grass
> itself. Heavier fuels (limbs, fronds) generated by trees within the
> island are regularly removed as a part of the park's maintenance
> operation and should keep the fire intensity low. A burn plan will be
> established for prescribed fire which will assess environmental
> conditions to determine suitability for burn operations prior to
> ignition. Soils will not be negatively impacts as stated in
> Alternative 1 for wildfire suppression. The low intensity of the fire
> and positive response of pili grass to fire, would maintain a stand of
> native species less volatile and susceptible to unplanned wildfire
> than exotic grasses, thus providing minor long term localized benefits
> to soils.

**4.1.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to soils the
following would be adhered to:

-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   No hand line construction.

-   Use water saturation where practical during mop-up to avoid scraping
    to bedrock, stirring, mixing, or otherwise disturbing the soil
    within the burn area.

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on park soils.

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and to reduce
    the negative impacts to soil from fire.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.1.4 Conclusion:**

Alternative 1, No Action: Suppression of all wildfires would have both a
direct, beneficial, short term, minor effect to soils as well as a
direct, adverse, short to long term, minor to major impact to soils.

Alternative 2, Minimum Management Action: The impacts to soils as a
result of wildfire suppression are stated in Alternative 1. Mitigating
the impacts of suppression activities under this alternative will
produce direct beneficial minor long term effects through a FMP and
MIST.

Alternative 3, Preferred Action: The impacts of wildfire suppression and
a Fire Management Plan are stated above in Alternatives 1 and 2.
Small-scale research burning of pili grass would have direct,
beneficial, minor, long term localized impacts to soils.

Ultimately, the suppression of wildfire will have an overall beneficial
impact to soils. Wildfire suppression under Alternative 1 would have
both beneficial and adverse impacts to soils. Alternative 2, improves
the park's ability to suppress or reduce a wildfire incident and to
reduce adverse effects caused by suppression activities. Alternative 2
provides greater benefits to soils than Alternative 1. Alternative 3
would produce direct, beneficial, minor, long term localized impacts to
soils by maintaining pili grass (a native species) in the park.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

##### 4.2 AIR QUALITY

####### 

####### **4.2.1 Affected Environment**

####### The park is a Class Il airshed under the Clean Air Act. Air quality is an important resource in the park however, depending upon prevailing wind patterns, it is often influenced by natural pollutants. Trade winds are the prevailing winds in Hawaii, except for the Kona coast of Hawai'i Island. The leeward, or Kona Coast, is protected from the trade winds by Mauna Loa, Mauna Kea, and Hualalai mountains. Pu'uhonua o Honaunau National Historical Park is located at the western base of Mauna Loa volcano, and is effectively blocked from the trade winds. The Kona coast is reliant on the diurnal sea and air circulation system that drives wind flow down slope and offshore from early evening to late morning, and upslope from late morning to early evening (Juvik and Juvik, 1998). The active volcano, Kilauea, located on the southeast portion of Hawai'i Island, produces gases locally called "vog" (a combination of "volcano" and "fog"). Halemaumau, located within Kilauea crater and Pu'u 'O'o, on the East Rift of Kilauea emit particulates. Lava entering the ocean produces very large quantities of sulfur dioxide and sulfate particulates. Vog is carried by the trade winds over the south end of the island and becomes trapped in the leeward/Kona area. At times, the diurnal wind pattern is not sufficient to clear the air of vog. 

**4.2.2 Environmental Consequences**

> 4.2.2.1 [Alternative 1, No Action]{.underline}
>
> Wildfire and suppression activities could have direct, indirect and
> cumulative adverse and beneficial impacts to air quality. During a
> wildfire incident, air quality within the park would experience
> direct, adverse, short term, minor impacts. Air quality in community
> areas surrounding the park would suffer indirect, adverse, temporary
> minor effects. A wildfire may have cumulative negative effects to air
> quality if vog is present. Immediate suppression of all wildfire would
> also produce direct and indirect beneficial effects on air quality by
> eliminating the source of particulate matter introduced into the
> atmosphere, thus reducing the duration of the impacts to air quality.
>
> 4.2.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> As in Alternative 1, immediate suppression of wildfire could produce
> direct, indirect and cumulative short term, minor impacts to air
> quality, as well as beneficial impacts. Additionally, the required
> Fire Management Plan will improve the park's ability to suppress or
> reduce wildfire incidents by addressing multiple aspects of wildfire,
> including, safety, prevention, preparedness, initial attack, and
> non-fire fuel reduction.
>
> 4.2.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The benefits of a required Fire Management Plan and immediate
> suppression of wildfire are stated above in Alternatives 1 and 2.
>
> Prescribed fire for pili grass would produce direct and indirect,
> adverse, short term minor impacts to air quality. The median island of
> the visitor center parking lot is about one half acre in size and
> consists of about one tenth acre of pili (dominant species) and exotic
> grasses. The fine burnable fuels would produce a relatively quick
> burning, low intensity (backing) fire that is conducive to the growing
> conditions of pili grass (Daehler, personal communication). Burning
> would be conducted under a prescription and burn plan that would
> further analyze the impacts of the prescribed fire on air quality
> given actual conditions. The presence of vog, or particulates, gasses
> and fumes produced by the active volcano, Kilauea, will also be
> analyzed on site through the Burn Plan. Unacceptable impacts on air
> quality will halt burning activities until favorable conditions
> prevail.
>
> A prescribed pili grass research burn was conducted in 1998. The fire
> was extinguished in 30 minutes. The burn was conducted during evening
> hours, with zero wind speed, and, "A convection column went straight
> up" (Minassian, Prescribed Burn Unit Plan, 1998.).
>
> It is highly unlikely that prescribed fire activity will have
> cumulative affects on air quality as the effects will be analyzed in
> the burn plan with actual conditions.
>
> The low intensity of the fire and positive response of pili grass to
> fire, would maintain a stand of native species less volatile and
> susceptible to unplanned wildfire than exotic grasses, thus providing
> minor long term benefits to air quality.

**4.2.3 Mitigation Measures**

Immediate suppression of wildfire in all three alternatives will produce
the greatest benefits to air quality.

In order to minimize the effects of prescribed fire to air quality, the
following will be adhered to prior to conducting any prescribed fire
activity:

-   State of Hawaii Department of Health will be contacted for possible
    burn bans associated with poor air quality due to vog.

-   Off shore winds are preferred for prescribed fire activity.

-   Air quality will be assessed on site through the Burn Plan.

-   Large fuels will be removed prior to prescribed fire activity.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.2.4 Conclusion:**

Common to all three alternatives is wildfire suppression. The above
alternatives would produce beneficial and adverse direct, indirect and
cumulative impacts to air quality. Adverse effects to air quality
resulting from a wildfire event will be minimized by suppression
activities, which provide the greatest benefit to air quality.
Suppression of wildfire in Alternative 1 would produce direct and
indirect beneficial short term, minor impacts to air quality by
eliminating the source of particulate matter introduced into the
atmosphere, thus reducing the duration of adverse impacts to air
quality. Suppression of wildfire under the guidance of a Fire Management
Plan as in Alternative 2, would improve the park's ability to suppress
or reduce wildfire incidents, increasing benefits to air quality as
noted in Alternative 1. Alternative 3 would have direct and indirect,
adverse, short term, minor effects on air quality, as noted on the
previous burn in 1998. However, maintaining a stand of native species
that is less volatile and susceptible to unplanned wildfire than exotic
grasses would ultimately provide long term benefits to air quality. The
on site analysis of impacts to air quality will ensure that fire
operations will not proceed if adverse impacts are unacceptable.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.3 SOUNDSCAPES**

**4.3.1 Affected Environment**

Natural soundscapes have not yet been identified for the park. Park
soundscapes can be divided into two general areas, coastal and inland.

Natural sounds at the coastal areas of the park are dominated by the
ocean. Surf can almost always be heard at the coast. During high surf
events, the waves crashing against the cliffs located near the southern
portion of the park can be heard booming throughout the coastal areas of
the park. At times the wind may also be a dominant part of the
soundscape near the coast. During the day birds are usually heard in the
coastal areas of the park.

Vegetation is generally heavier in the parks inland areas and less
accessible to visitors. Natural sounds are primarily bird, insect, and
wind sounds through open and closed vegetation canopy.

Existing intrusions to the park's soundscapes include the administrative
use of power tools and vehicles for other park purposes and air traffic.
Visitor services and facilities also experience associated impacts to
soundscapes such as tour buses and passenger vehicles in the visitor
center parking lot and picnic area. These are not expected to change.

**4.3.2 Environmental Consequences**

> 4.3.2.1 [Alternative 1, No Action]{.underline}
>
> Suppression of wildfire will have both adverse and beneficial impacts
> to the park's soundscapes.
>
> Immediate suppression of wildfire will create direct, adverse, short
> term minor impacts to the park's soundscapes. Motorized vehicles and
> hand tools, such as chain saws, weed eaters, pumps, and other fire
> vehicles and apparatus' may be necessary. Helicopter use may be
> necessary for the evacuation of people and suppression of wildfires
> located in remote sections of the park. Helicopter support may also be
> required to suppress aggressive wildfires.
>
> The park does not have an aviation program and will not order the use
> of helicopter support during fire operations. The Hawaii County Fire
> Department may utilize helicopter support during fire operations which
> will be governed by their policies, procedures and designated landing
> areas. Helicopters will not land in the park except for emergency
> landings. Should the need for a helicopter landing area arise for
> other than emergency purposes, prior approval must be obtained from
> the park superintendent and the designated area approved by a resource
> advisor or the chief of resource management and the chief ranger.
> Helicopter operations will present direct adverse short-term
> negligible to minor impacts to soundscapes. Helicopter operations for
> wildfire suppression will generally occur in areas that will be closed
> to the public as a result of wildfire and managed by a qualified
> manger.
>
> There are cumulative adverse, short term minor impacts to soundscapes
> with wildfire suppression because of existing impacts of other sound
> sources such as the administrative use of power tools and vehicles for
> other park purposes and air traffic. Visitor services and facilities
> also experience associated impacts to soundscapes such as tour buses
> and passenger vehicles in the visitor center parking lot. These are
> not expected to change.
>
> Wildfire suppression will have a direct, beneficial, minor long term
> impact to park soundscapes by reducing the destruction of vegetation,
> hence, maintaining habitat for bird, insect, and wind sounds.
>
> 4.3.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The effects of wildfire suppression on the park's soundscapes are
> stated in Alternative 1.
>
> The addition of a required Fire Management Plan will create direct
> beneficial, long term minor impacts to the park's soundscapes by
> increasing the park's ability to more efficiently suppress or reduce
> wildfire incidents by taking an organized and coordinated approach to
> wildfire prevention and suppression.
>
> Cumulative impacts with this alternative are the same as for
> Alternative 1.
>
> 4.3.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The benefits and impacts of a Fire Management Plan and suppression of
> wildfire are stated in Alternatives 1 and 2.
>
> Prescribed fire will have both adverse and beneficial effects to the
> park's soundscapes. Equipment used to conduct prescribed pili grass
> research burns will have a direct, adverse, temporary minor localized
> impact on the park's soundscape. Motorized vehicles and hand tools
> could include a propane torch and vehicular water pumping units. These
> impacts to the soundscape are expected to be detectable or measurable,
> but to a lesser degree than wildfire suppression and very short in
> duration. The low intensity of the fire and positive response of pili
> grass to fire, would maintain a stand of native species less volatile
> and susceptible to unplanned wildfire than exotic grasses (C. Daehler
> personal communication), thus providing indirect localized minor long
> term benefits to soundscapes.
>
> There are cumulative adverse, temporary minor impacts with wildfire
> suppression because of existing impacts of other sound sources such as
> the administrative use of power tools and vehicles for other park
> purposes and air traffic. Visitor services and facilities also
> experience associated impacts to soundscapes such as tour buses and
> passenger vehicles in the visitor center parking lot. Prescribed fire
> is not expected to occur during peak visitation hours or during the
> most active times of administrative sound impacts. Therefore,
> prescribed fire activity will have cumulative adverse, temporary minor
> impacts to the park's soundscapes.

**4.3.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to
soundscapes the following would be adhered to:

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and to reduce
    operational and mop-up time.

-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   No hand line construction.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.3.4 Conclusion:**

Alternative 1, No Action: Immediate suppression of wildfire will create
direct and cumulative, adverse, short term, negligible to minor impacts
and; direct, beneficial, minor long term impact to park soundscapes.
There are cumulative adverse, short term minor impacts to soundscapes
with wildfire suppression and existing intrusions to the park's
soundscapes.

Alternative 2, Minimum Management Action: The effects of wildfire
suppression on the park's soundscapes are stated in Alternative 1. The
addition of a required Fire Management Plan will create direct
beneficial, long term minor impacts to the park's soundscapes.
Cumulative impacts with this alternative are the same as for Alternative
1.

Alternative 3, Preferred Action: The impacts of wildfire suppression and
a Fire Management Plan are stated above in Alternatives 1 and 2.
Equipment used to conduct prescribed pili grass research burns will have
a direct, adverse, temporary minor localized impact on the park's
soundscape and indirect localized minor long term benefits. Prescribed
fire activity will have cumulative adverse, temporary minor impacts to
the park's soundscapes.

Wildfire and suppression activities will have both adverse and
beneficial impacts to the park's soundscapes. However, the adverse
impacts of suppression activities are short term and necessary to
preserve the existing natural, plant and animal sounds, and are
ultimately beneficial to the park's soundscapes. An approved Fire
Management Plan (Alternative 2 and 3), is expected to reduce the
potential for wildfire and reduce the adverse impacts associated with
suppression efforts.

Alternative 3 includes prescribed research fire for pili grass. The
impacts to soundscapes are expected to be direct, adverse, temporary
minor and localized, with minor long term beneficial impacts by
maintaining a stand of native vegetation and associated sounds.

All three alternatives will have adverse cumulative impacts that are
negligible to minor and temporary to short-term.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.4 WATER RESOURCES**

**4.4.1 Affected Environment**

The lava flows and scattered soils in the park are very porous and
consequently surface water features are absent. There are no perennial
streams or wetlands within the park. A single intermittent stream of
moderate sized drainage crosses the southern portion of the park next to
Ki'ilae village before emptying into the ocean. Stream flow is
infrequent and the result of exceptionally heavy rainfall in the
uplands.

There are anchialine pools within the park. The anchialine pools are
relatively small inland sources of water that are influenced by tides
and springs, causing water levels and salinity within the ponds to vary.

The park does not own or have jurisdiction over ocean waters. The park's
boundary is from the high water mark inland. Waters below the high water
mark are under the jurisdiction of the State of Hawaii.

**4.4.2 Environmental Consequences**

> 4.4.2.1 [Alternative 1, No Action]{.underline}
>
> Wildfire and suppression activities will have direct and indirect
> beneficial and adverse impacts to water resources.
>
> Suppression of wildfire may have direct and indirect, adverse, minor
> to major, short term to long term, impacts to water resources. The
> park contains one intermittent stream, and anchialine pools. The park
> does not have wetlands, or coastal inshore waters. Should a wildfire
> occur or spread near anchialine ponds, suppression efforts, such as
> the use of foam or water additives may be deposited into the ponds and
> stream bed and intermittent stream flow and tidal changes in the
> anchialine pools may carry the chemicals into the ocean. Wildfire
> suppression efforts may also utilize anchialine ponds as a source of
> water supply.
>
> The potential for fire spread near anchialine ponds is extremely low.
> The ponds located in the Royal Grounds do not have fuels to carry
> fire, and much of the ground nearby is saturated. The pond located
> south of the Chief's Complex does have fuel nearby, however, the
> ground remains saturated and fire spread is unlikely. Because the
> potential for erosion is low after fire, the risk of contamination and
> sedimentation in the ponds is low. Retardants are not used in fire
> suppression and therefore pose no threat to the ponds.
>
> The suppression of wildfire will have a direct and indirect,
> beneficial, minor, short term impact on water resources. Suppressing
> the spread of wildfire will reduce the probability of fire near the
> park's anchialine pools and reduce the likelihood of fire related
> debris, foam or water additives from being deposited into the
> anchialine pools.
>
> 4.4.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The beneficial and adverse impacts of wildfire suppression on water
> resources are stated above in Alternative 1.
>
> Wildfire suppression, near the parks water resources, under the
> guidance and preplanning of a Fire Management Plan will have direct
> and indirect, beneficial, minor long term impacts to water resources.
> Strategies for wildfire prevention will be addressed in the plan,
> resource advisors will be used on fires and MIST will be addressed and
> utilized to avoid the adverse impacts stated above in Alternative 1.
>
> 4.4.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The benefits of a Fire Management Plan in the suppression of wildfire
> and its effects on water resources are stated in Alternatives 1 and 2.
> Prescribed fire activity will not occur near water resources and will
> therefore have no effect.

**4.4.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to water
resources the following would be adhered to:

-   Natural water resources within the park will not be used to supply
    water for fire suppression.

-   Foam or water additives utilized for wildfire suppression will not
    be deposited in or near the anchialine pools, intermittent stream
    bed and generally within 200' of water sources in the park.

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-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   No hand line construction.

-   The park will continue exotic vegetation removal in the primary
    visitor use areas of the park to reduce the opportunities for
    wildland fire. Most of the anchialine pools within the park are
    located within primary visitor use areas.

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on water resources.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.4.4 Conclusion:**

Alternative 1, No Action: Suppression of wildfire may have direct and
indirect, adverse, minor to major, short term to long term, impacts to
water resources and direct and indirect, beneficial, minor, short term
impact on water resources.

Alternative 2, Minimum Management Action: Mitigating the impacts of
wildfire suppression activities will have direct and indirect,
beneficial, minor long term impacts to water resources.

Alternative 3, Preferred Action: The benefits of a Fire Management Plan
in the suppression of wildfire and its effects on water resources are
stated in Alternatives 1 and 2. Prescribed fire activity will not occur
near water resources and will therefore have no effect.

Wildfire suppression activities in Alternative 1 can present adverse
impacts to the park's water resources while Alternatives 2 and 3 provide
the best protection of the parks water resources with a Fire Management
Plan, resource advisors and MIST. Prescribed fire activity contained in
Alternative 3 will not be conducted near water resources and therefore
will have no effect.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.5 THREATENED AND ENDANGERED SPECIES**

**4.5.1 Affected Environment**

Three threatened or endangered vertebrate species are found within in
the park boundaries (green sea turtle, *Chelonia mydas*; Hawaiian monk
seal, *Monachus schauinslandi*; and Hawaiian hoary bat, *Lasiurus
cinereus semotus*). Bats have been seen feeding over the inshore waters
at Alahaka Bay and the Visitor Center parking lot (Parish personal
communication). The green sea turtle is often seen in the inshore waters
of Honaunau Bay, Keone'ele Cove, and the coastal area fronting the
pu'uhonua. The turtles are also seen on the sandy shores and barren
pahoehoe flows near the high water mark. The Hawaiian monk seal is
rarely seen near the park and has not been sighted within the park for
the last five years.

The park contains anchialine pools and therefore may contain
(unconfirmed) associated candidate endangered species, a damselfly and
three crustaceans, (orangeblack damselfly, *Megalarion xanthomelas*; the
shrimp *Metabetaeus lohena*; *Palaemonella burnsi ,Calliasmata
pholiodota*). The presence of these species have been recorded on the
west coast of Hawaii Island but are currently unconfirmed pending a
biological inventory report. Additionally, the endangered palm species,
loulu (*Pritchardia affinis*), has recently been reintroduced to the
park.

**4.5.2 Environmental Consequences**

> 4.5.2.1 [Alternative 1, No Action]{.underline}
>
> Suppression of wildfire will have both beneficial and adverse impacts
> to threatened and endangered species. These impacts are both direct
> and indirect.
>
> Suppression of wildfire will have direct and indirect, beneficial,
> minor, short term to long term, impacts to threatened and endangered
> species and habitat. Wildfire suppression will reduce the destruction
> of vegetation, insects, and habitat that may support the endangered
> Hawaiian hoary bat within the park. Suppressing the spread of wildfire
> will reduce the probability of fire near the park's anchialine pools
> and reduce the likelihood of fire related debris, foam or water
> additives from being deposited into the anchialine pools, which may be
> habitat for endangered inverterbrates.
>
> Suppression of wildfire may have direct and indirect, adverse, minor
> to major, short term to long term, impacts to anchialine pools and the
> resources within. Should a wildfire occur or spread near anchialine
> ponds, suppression efforts, such as the use of foam or water additives
> may be deposited into the ponds and affect the resources within.
> Retardants are not used in fire suppression and therefore pose no
> threat to the ponds. Wildfire suppression efforts may also utilize
> anchialine ponds as a source of water supply.
>
> The potential for fire spread near anchialine ponds, habitat for the
> endangered orangeblack damsel fly, is extremely low. The ponds located
> in the Royal Grounds do not have fuels to carry fire, and much of the
> ground nearby is saturated. The pond located south of the Chief's
> Complex does have fuel nearby, however, the ground remains saturated
> and fire spread is unlikely. Because the potential for erosion is low
> after fire, the risk of contamination and sedimentation in the ponds
> is low.
>
> Endangered loulu palms have been planted in primary use areas, which
> are maintained for exotic vegetation. It is unlikely that wildfire or
> fire suppression activities will impact the loulu palms within the
> park.
>
> The Hawaiian monk seal and green sea turtle are not expected to be
> impacted by wildfire or fire suppression activities as neither species
> are known to utilize areas with, or in close proximity to burnable
> vegetation, nor are any indirect adverse impacts expected.
>
> 4.5.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The beneficial and adverse impacts of wildfire suppression on
> threatened and endangered species are stated above in Alternative 1.
>
> Wildfire suppression under the guidance and preplanning of a Fire
> Management Plan will have direct and indirect, beneficial, minor long
> term impacts to threatened and endangered species. Strategies for
> wildfire prevention will be addressed in the plan, resource advisors
> will be used on fires and MIST will be addressed and utilized to avoid
> the adverse impacts stated above in Alternative 1.
>
> 4.5.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The impacts of wildfire suppression, an approved Fire Management Plan,
> and potential impacts to threatened and endangered species are stated
> above in Alternatives 1 and 2.
>
> Research prescribed fire may have direct and indirect beneficial
> negligible to minor impacts to endangered loulu palms and adverse
> negligible impacts. Loulu palms have been planted within the pili
> grass stand located in the median island of the parking lot. In 1998,
> the park conducted a prescribed research fire in the median and none
> of the palms were lost as a result of the burn. Fuel accumulation in
> the pili dominated stand is light, consisting primarily of fine fuels
> generated by the grass which should produce a low intensity fire.
> Heavier fuels from trees within the island are regularly removed as a
> part of the park's maintenance operation. Therefore any adverse
> affects to the loulu palms will be minimal as in the previous burn.
>
> Research prescribed fires would determine the prescription for the use
> of prescribed fire to promote the vigor of the pili grass stand and
> maintain an area of native grass that is less flammable and burns at
> lower intensity than exotic grasses (Mohr 2001) which would produce
> long term benefits for the loulu planted in the stand.
>
> Research prescribed fire will occur primarily in the median island of
> the parking lot fronting the Visitor Center. The Hawaiian hoary bat
> has been seen in the parking lot area. If bats are present when
> prescribed fire is scheduled, the burn will not occur until the area
> is clear of bats.
>
> The Hawaiian monk seal and green sea turtle are not expected to be
> impacted by prescribed fire activities as neither species are known to
> utilize the area selected for pili grass burn operations.
>
> Prescribed fire will not occur near anchialine pools and therefore
> potential endangered species within the ponds are not expected to be
> impacted by prescribed fire activity.

**4.5.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to
threatened and endangered species the following will be adhered to:

-   Natural water resources within the park will not be used to supply
    water for fire suppression.

-   Foam or water additives utilized for wildfire suppression will not
    be deposited in or near the anchialine pools and generally within
    200' of water sources in the park.

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and reduce
    the negative impacts to loulu palms from fire.

-   Fuels will be removed manually from the base of living trees within
    the pili grass prescribed burn area and wetted down with water to
    avoid unacceptable adverse impacts to loulu palms during pili grass
    prescribed burn operations.

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-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   No hand line construction.

-   The park will continue exotic vegetation removal in the primary
    visitor use areas of the park to reduce the opportunities for
    wildland fire.

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on threatened and endangered species.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.5.4 Conclusion:**

Alternative 1, No Action: Suppression of wildfire will have direct and
indirect, beneficial, minor, short term to long term, impacts to
threatened and endangered species and habitat. Suppression of wildfire
may have direct and indirect, adverse, minor to major, short term to
long term, impacts to anchialine pools and the resources within.

Alternative 2, Minimum Management Action: Adverse impacts of wildfire
suppression on threatened and endangered species are stated above in
Alternative 1. Mitigating the impacts of wildfire suppression will have
direct and indirect, beneficial, minor long term impacts to threatened
and endangered species.

Alternative 3, Preferred Action: The impacts of wildfire suppression, an
approved Fire Management Plan, and potential impacts to threatened and
endangered species are stated above in Alternatives 1 and 2. Mitigating
the impacts of research prescribed fire may have direct and indirect
beneficial negligible to minor impacts to endangered loulu palms and
adverse negligible impacts.

All three alternatives have direct and indirect, beneficial and adverse
impacts to threatened and endangered species. The benefits, however,
increase with each alternative. Alternative 3, Preferred Action,
provides the greatest benefit as it includes the benefits of wildfire
suppression in Alternative 1 with an approved Fire Management Plan in
Alternative 2, and includes maintaining a segment of the cultural
landscape/scene with a stand of less flammable native grass.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.6 VEGETATION AND WILDLIFE**

Threatened and endangered plants and animals were addressed in Section
4.5 as a separate impact topic, affected environment and analysis of
alternatives.

**4.6.1 Affected Environment**

**Vegetation**

Of the 134 vascular plant species currently known in the park, there are
23 native species, 15 Polynesian introductions, and 96 alien species.
The park has four native plant species that are considered common. The
'uhaloa (*Waltheria indica*) is a low shrub that is commonly seen
throughout the park. Makaloa (*Cyperus laevigatus*) grows on the banks
of the anchialine pools in the park. The naupaka kahakai (*Scaevola
taccada*) is concentrated in the sandy beach areas, and mau'u
(*Frimbristylis cymosa*) on the pahoehoe flats near the ocean (Pratt
1998).

The pu'uhonua and Royal Grounds have been, for the most part, cleared of
alien vegetation. Native and Polynesian introduced plants have been
reintroduced near the Visitor Center and Royal Grounds. Native plant
reintroductions include 'akia (*Wilkstromia pulcherrima*), a'a'li'i
(*Dodonea viscosa*) and Pohinahina (*Vitex rotundifolia*). Polynesian
introductions include ki or ti (*Cordyline fruiticosa*), kamani
(*Callophyllum inophyllum*), ko (*Saccharum officinarum*) and wauke
(*Broussonetia papyrifer*). These species are appropriate to recreate
the historic scene and "contribute to the interpretation of the park"
(Pratt 1998).

The median island of the parking lot fronting the Visitor Center is
landscaped with native and Polynesian introduced plants. The park
planted pili grass, loulu, noni (*Morinda citrifolia*), kamani, and
coconut palms (*Cocos nucifera*) within the median island.

Coastal areas of the park south of the picnic area to the Alahaka Ramp
consist of coconut palms, naupaka kahakai and scattered alien
vegetation. The picnic area to the northern boundary is clear of
vegetation, except for coconut palms, a few kiawe (*Prosopis pallida*),
noni, scattered kou (*Cordia subcordata*), hala (*Pandanus tectorious*),
and other alien species.

The coconut grove located mauka of the picnic area access road is
primarily coconut palms, noni, and 'uhaloa, with scattered 'opiuma
(*Pithecellobium dulce*) shrub and alien ground cover.

The area east (mauka) of the 1871 Trail remains dominated by alien shrub
predominantly ekoa (*Leucaena leucocephala*), klu (*Acacia farnesiana*),
and 'opiuma. Natal redtop (*Rhynchelytrum repens*) and Guinea grass
(*Panicum maximum*) are the dominant alien ground cover.

The Ki'ilae Village extends from the top of the Alahaka Ramp to the
southern boundary of the park. Kiawe, ekoa, and Guinea grass dominate
this area.

**Wildlife**

Birds

Twenty six bird species have been recorded in the park, most of which
are alien, Japanese white-eyes (*Zosterops japonicus*) and common mynas
(*Acridotheres tristis*), being the two most detected species (Morin
1996).

There are six indigenous bird species reported in the park. Of the six,
only three species are common in the park, the kolea (*Pluvialis
fulva*), 'ulili (*Heteroscelus incanus*), and 'akekeke (*Arenaria
interpres*). The 'auku'u (*Nycticorax nycticorax hoacti*), previously
seen every two to five years, is now seen more frequently by park staff.
The 'a (*Sula leucogaster plotus*), protected by the Migratory Bird Act,
was seen a few times a year, and the kioea (*Numenius tahitiensis*) was
seen only once or twice (Morin 1996).

Other

Mongoose, feral cats, rats, and mice are commonly seen in the park.

Inventories of invertebrates have not been conducted.

Reptile and amphibian inventory field work was done in 2004 as part of
the Inventory and Monitoring program, report is forthcoming.

The environmental analysis of wildfire and suppression activities on the
park's anchialine pools and the wildlife contained within are addressed
in Sections 4.4, Water Resources and 4.5, Threatened and Endangered
Species.

**4.6.2 Environmental Consequences**

> 4.6.2.1 [Alternative 1, No Action]{.underline}
>
> Suppression of wildfire will have direct and indirect, beneficial,
> minor, short term to long term, impacts to vegetation and wildlife.
> Wildfire suppression will reduce the destruction of vegetation,
> wildlife and habitat within the park. By minimizing the size of
> wildfire, opportunities for exotic plant infestation or the emergence
> of new or previously eradicated exotic plant species are also reduced.
>
> No plant species or plant community appears to be dependent on fire,
> at least in the time frames of fire effects and plant community
> monitoring conducted at Hawaii Volcanoes National Park by park staff
> or researchers. The exclusion of fire would therefore not adversely
> affect the regeneration of native plants or perpetuation of native
> plant communities. However, pili grass, while not fire-dependent, is a
> fire-stimulated species and has a history of responding to fire.
>
> 4.6.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The beneficial impacts of wildfire suppression on vegetation and
> wildlife are stated above in Alternative 1.
>
> Wildfire suppression under the guidance and preplanning of a Fire
> Management Plan will have direct and indirect, beneficial, minor long
> term impacts to vegetation and wildlife. An approved Fire Management
> Plan will improve the park's ability to suppress or reduce wildfire
> incidents by addressing multiple aspects of wildfire, including, fuels
> management, prevention, preparedness, and initial attack. Strategies
> for wildfire suppression will also be addressed in MIST.
>
> Herbicide use to control of hazardous fuels such as alien grasses and
> shrubs has a positive effect on park native plant communities. Recent
> control efforts of ekoa have resulted in the natural revegetation of
> ilima and uhaloa. Pili grass has also been noted in previously treated
> areas, although to a lesser degree than ilima and uhaloa. Non-target
> effects of chemical treatments on native vegetation would be
> negligible to minor. Treated areas would be confined to areas
> dominated by alien grasses and shrubs, or spot treatments applied in
> proximity to native plants. Chemical sprays are used on alien grasses
> while shrubs are cut and the stumps treated then left to decay.
> Integrated Pest Management guidelines would be used to ensure that the
> lowest dosage of non-restricted use herbicide that is effective in
> treating grasses and cut stumps is applied, and that impacts to the
> surrounding area would be minimized. Fuel breaks will also be cleared
> using non-fire applications.
>
> Salt water helicopter bucket drops may be used by Hawaii County Fire
> Department to suppress fire at Pu'uhonua o Honaunau NHP. Plants in
> this area are exposed to high ambient levels of salt spray and salt
> water helicopter bucket drops made during suppression operations at
> Hawaii Volcanoes National Park appear to have had no adverse impacts
> on vegetation. The plants are presumed to have adapted to higher salt
> levels as they don't exhibit the expected signs of salt impact, which
> would be uprooting, bleaching, loss of vigor, and mortality.
>
> The park does not have an aviation program and will not order the use
> of helicopter support during fire operations. The Hawaii County Fire
> Department may utilize helicopter support during fire operations which
> will be governed by their policies, procedures and designated landing
> areas. Helicopters will not land in the park except for emergency
> landings. Should the need for a helicopter landing area arise for
> other than emergency purposes, prior approval must be obtained from
> the park superintendent and the designated area approved by a resource
> advisor or the chief of resource management and the chief ranger.
> Should a landing area be established in the park, it will be managed
> by a qualified manager.
>
> 4.6.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The beneficial impacts of wildfire suppression and an approved Fire
> Management Plan are stated above in Alternatives 1 and 2.
>
> Prescribed research fire for the establishment and regeneration of
> pili grass will have direct, beneficial, minor, localized long term
> impacts to vegetation. Pili grass was a preferred thatching material
> and may have dominated the landscape at Honaunau during pre-contact
> native Hawaiian occupation of the area until historic times, when it
> was displaced by exotic vegetation (Pratt 1998). Traditional Hawaiian
> management of the grass included the use of fire to maintain pili
> grasslands (Loh unpublished and Pratt 1998).
>
> The median island of the parking lot fronting the Visitor Center is
> landscaped with native and Polynesian introduced plants including a
> stand of pili grass which is a representative sample of what the early
> Hawaiian landscape might have looked like at Honaunau. Impacts of
> limited use of prescribed fire on vegetation are expected to be
> positive for plant communities that are pili-alien grasslands where
> the impacts of fire on resources are minor. Research prescribed fires
> would determine the schedule for the use of prescribed fire to promote
> the vigor of the stand and maintain an area of native grass that is
> less flammable and burns at lower intensity than exotic grasses (Mohr
> 2001).
>
> Fuel accumulation in the stand is light, consisting primarily of fine
> fuels generated by the pili grass. Heavier fuels from trees within the
> island are regularly removed as a part of the park's maintenance
> operation. The island is surrounded by an asphalt paved parking lot
> and serves as a human-made fire break for the purposes of burn
> operations. In 1998, the park conducted a prescribed research fire in
> the median. None of the trees or palms was lost, and the pili grass
> responded positively to the fire, resulting in greater coverage of the
> pili with a reduction in Natal redtop (Pratt 1998 and Bell personal
> communication).
>
> Pili grass research was conducted by Curtis C. Daelher, Department of
> Botany, University of Hawaii. The following is a summary of his
> writing as it relates to prescribed fire use for pili grass.
>
> Fire has been used on a limited basis in a seed nursery area for pili
> grass at Pu'ukohola Heiau NHS and in the cultivated area near the
> Pu'uhonua o Honaunau Visitor Center Parking Area. It appears fire is
> beneficial in creating a seedbed and/or stimulating rejuvenation of
> this grass in sufficient amount to compete and become the more
> dominant species with existing alien grasses.
>
> Pili grass (*Heteropogon contortus)* was once a dominant component of
> the vegetation at many dry, leeward coastal sites in the Hawaiian
> Islands. Today, most pili grasslands have been replaced by
> near-monocultures of introduced African grasses. The goal of the
> research project at Pu'ukohola Heiau NHS is to develop methods for
> restoring pili grasslands. Fire is being used in this project as a
> means to give pili grass a reproductive and competitive edge over the
> alien buffel grass (*Cenchis ciliaris)* that now dominates the park.
> Pili grass is well adapted to fire. From previous observations, fire
> stimulates pili grass growth. It is hypothesized that a certain fire
> regime will favor pili grass over buffel grass.
>
> In February 1998, two 25 x 10 meter plots at Pu'ukohola Heiau NHS
> dominated by buffel grass were prescribed burned and then seeded with
> pili grass. In the fall of 1998 young pili grass plants were
> transplanted in an adjacent area. These plants have survived extremely
> well and more transplanting of pili grass plants has been done.
>
> To date almost a pure stand of pili grass exist in the seedbed area.
> One aspect of this research project is to use fire in the seedbed
> area, to determine the effects of burning on pili grass growth,
> flowering and seed production. The objective is to expand the size of
> the seedbed, harvest seed from the plant, lessen the buffel grass and
> strive to maintain a composition primarily of pili grass throughout
> the park.
>
> With an adequate supply of pili seed, projects are anticipated that
> may utilize a pre-treatment of herbicide to kill existing areas of
> alien species, followed by a light intensity prescribed burn to
> consume existing biomass and create a seedbed for pili grass
> establishment. In some situations, fire may not be used prior to the
> seeding of pili, as part of this research project.
>
> In the long term, efforts will be made to use a combination of
> activities (herbicide, seeding and transplanting of pili grass, and
> periodic prescribed burns), in order to identify the best methods for
> restoring and perpetuating pili grasslands on a larger scale.
> (Daehler, 1998 and Daehler and Goergen, In Press)
>
> Prescribed research fire for the establishment and regeneration of
> pili grass may occur elsewhere in the park, however, will be approved
> on a case by case basis and may require site specific analysis of
> effects and further consultation.
>
> Prescribed research fire will have no effect on wildlife.

**4.6.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to
vegetation and wildlife the following would be adhered to:

-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   No hand line construction.

-   Personnel conducting non-fire fuel reduction projects will be
    informed of cultural and natural resources awareness to avoid
    impacts to such resources.

-   The park will continue exotic vegetation removal to reduce the
    opportunities for wildland fire.

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on vegetation and wildlife.

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and reduce
    the negative impacts to vegetation from fire.

-   Fuels will be removed manually from the base of living trees within
    the pili grass prescribed burn areas. Living trees will be wetted
    down with water to avoid unacceptable adverse impacts during pili
    grass prescribed burn operations.

-   Natural sources of water within the park will not be used for fire
    suppression activities.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.6.4 Conclusion:**

Alternative 1, No Action: Suppression of wildfire will have direct and
indirect, beneficial, minor, short term to long term, impacts to
vegetation and wildlife.

Alternative 2, Minimum Management Action: Wildfire suppression under the
guidance and preplanning of a Fire Management Plan will have direct and
indirect, beneficial, minor long term impacts to vegetation and
wildlife.

Alternative 3, Preferred Action: The beneficial impacts of wildfire
suppression and an approved Fire Management Plan are stated above in
Alternatives 1 and 2. Prescribed research fire for the establishment and
regeneration of pili grass will have direct, beneficial, minor,
localized long term impacts to vegetation.

All three alternatives have direct and indirect, beneficial, short to
long term impacts to vegetation and wildlife. The benefits, however,
increase with each alternative. Alternative 3, Preferred Action,
provides the greatest benefit as it includes the benefits of Alternative
1 and 2, and maintaining a segment of the cultural landscape/scene with
a stand of native grass.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.7 VISITOR USE**

**4.7.1 Affected Environment**

Pu'uhonua o Honaunau National Historical Park has year-round visitation
with peaks at Christmas, spring break, and summer. Visitation from 1992
to 2002 averaged over 436,000 recreational visitors annually. Visitation
in 2003 increased to 520,135 recreational visitors and in 2004, the park
enjoyed a 38% increase for 839,700 recreational visitors. Visitors
access the park by private or commercial vehicles for day visits.

Primary visitation areas in the park are the Visitor Center, the Royal
Grounds, and the pu'uhonua. A segment of visitors use the picnic area
and the 1871 Trail, while fewer visitors utilize the backcountry areas
beyond the Alahaka Ramp.

**4.7.2 Environmental Consequences**

> 4.7.2.1 [Alternative 1, No Action]{.underline}
>
> Wildfire and suppression activities will have both adverse and
> beneficial impacts to visitor use. Wildfire and suppression activities
> will have direct, adverse, short term, minor impacts to visitor use.
> Wildfire suppression activities may include area closures beyond the
> actual wildfire to facilitate suppression support. Visitors may also
> be subject to noise and smoke, and to an increase of personnel and
> vehicles generated by suppression activities.
>
> Suppression of wildfire incidents will have direct, beneficial, long
> term, minor impacts to visitor use by decreasing the extent of the
> area and resources affected by wildfire, and reduce the length of
> areas closed to the public.
>
> 4.7.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> Wildfire and suppression activities will have both adverse and
> beneficial impacts to visitor use as stated above in Alternative 1,
> although to a lesser degree. An approved Fire Management Plan will
> improve the park's ability to suppress or reduce wildfire incidents by
> addressing multiple aspects of wildfire including prevention,
> preparedness, and initial attack. Strategies for wildfire suppression
> will also be addressed in MIST.
>
> 4.7.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The effects of wildfire suppression under the guidance and preplanning
> of a Fire Management Plan on visitor use is noted in Alternatives 1
> and 2.
>
> Prescribed research fire for the establishment and regeneration of
> pili grass will have a direct, adverse, short term, localized minor
> impact to visitor use. Visitors may be subjected to fire suppression
> activities as noted in the above alternatives, however, it would be
> localized and very short in duration. Prescribed pili grass burning
> will occur primarily in the visitor center parking lot, and will not
> affect visitor use and enjoyment of primary park resources. Scarring
> left from the burn would be short in duration as the pili grass
> responds well to low intensity burning (C. Daehler, personal
> communication).
>
> Prescribed research burning of pili grass will have direct,
> beneficial, long term minor effects. Maintaining a stand of pili grass
> serves as a representative sample of what the park's landscape may
> have looked like during pre-contact Hawaii. Pili grass was the
> preferred thatch material, and Hawaiians did burn pili grasslands to
> foster growth (Loh unpublished data, Pratt 1998). The traditional and
> current use of fire to manage pili grass can be woven into the park's
> interpretive program.

**4.7.3 Mitigation Measures**

In order to minimize the effects of fire activity to visitor use the
following would be adhered to:

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and to reduce
    operational and mop-up time.

-   Prescribed fire activities will not be scheduled during high visitor
    use times and special or evening programs.

**4.7.4 Conclusion:**

Alternative 1, No Action: Wildfire and suppression activities will have
direct, adverse, short term, minor impacts to visitor use. Suppression
of wildfire incidents will have direct, beneficial, long term, minor
impacts to visitor use.

Alternative 2, Minimum Management Action: Wildfire and suppression
activities will have both adverse and beneficial impacts to visitor use
as stated above in Alternative 1, although to a lesser degree.

Alternative 3, Preferred Action: The effects of wildfire suppression
under the guidance and preplanning of a Fire Management Plan on visitor
use is noted in Alternatives 1 and 2. Prescribed research fire for the
establishment and regeneration of pili grass will have a direct,
adverse, short term, localized minor impact to visitor use and direct,
beneficial, long term minor effects.

Suppression of wildfire under each alternative will have minor adverse
short term effects to visitor use, but the adverse effects of
Alternatives 2 and 3 will be to a lesser degree than in Alternative 1.
All of the three alternatives will have beneficial long term impacts.
Alternative 3 is the only alternative that allows for prescribed fire to
manage and maintain pili grass.

**4.8 Wildland Urban Interface.**

**4.8.1 Affected Environment**

The lands surrounding the park are primarily agricultural land with few
homes located near the park's north boundary. Fuels at the north
boundary consist mostly of large coconut, hala, and exotic trees. The
area contains numerous lava outcrops and archaeological stone structures
which break up the continuity of fine fuels.

Ranch and unoccupied lands are located at the east (mauka/upslope) and
south boundary. Ekoa shrub and exotic grasses dominate both the east and
south boundaries.

Development within the park is located in three areas, the visitor
center, entrance kiosk, and administrative buildings. The visitor center
and entrance kiosk benefit from the paved parking lot which serves as a
partial fire break for both structures. Light fuels surrounding the
visitor center is disrupted with lava outcrops and the results of exotic
plant eradication efforts. Noni, hala, naupaka and coconut are the most
common trees surrounding the visitor center. The entrance kiosk is
located in the median of the parking lot at the north end. There is a
stand of crawling ilima (*Sida fallax*), pili grass, native and
Polynesian introduced plants located within the median.

**4.8.2 Environmental Consequences**

> 4.8.2.1 [Alternative 1, No Action]{.underline}
>
> Suppression of wildfire will have a direct, beneficial, long term,
> minor to major impact to the wildland urban interface. Wildfire
> suppression provides for maximum protection of life and property by
> reducing the impacts of wildfire ignited within and outside of park
> boundaries.
>
> 4.8.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The benefits of wildfire suppression are stated above in Alternative
> 1.
>
> An approved Fire Management Plan will improve the park's ability to
> suppress or reduce wildfire incidents by addressing multiple aspects
> of wildfire, including, safety, prevention, preparedness, initial
> attack, and specifically the wildland urban interface.
>
> 4.8.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The benefits of wildfire suppression and a Fire Management Plan on the
> wildland urban interface are stated in above in Alternatives 1 and 2.
>
> Prescribed fire will have indirect adverse temporary negligible
> impacts to the park's wildland urban interface. The entrance kiosk is
> located within the median island on the north end, which does have a
> buffer of about fifteen feet of crawling ilima between the kiosk and
> pili grass. The Visitor Center is about thirty feet south of the
> island, separated by the paved roadway and pedestrian walk area.
> Either structure could be subject to smoke and ash which would very
> quickly disperse.
>
> The 1998 prescribed pili grass fire posed no threat to the Visitor
> Center or entrance kiosk, nor were any extraordinary measures taken to
> protect either structure from the prescribed fire.
>
> Prescribed fire will not occur if there are any obvious potential
> threats to the wildland urban interface that can not be mitigated. The
> wildland urban interface will be further analyzed in the burn plan
> under actual conditions.
>
> Prescribed fire within the park would not affect the wildland urban
> interface at the park/community boundary.

**4.8.3 Mitigation Measures**

In order to minimize the effects of fire activity to the wildland urban
interface the following would be adhered to:

-   Prescribed fire will not occur if there are any obvious potential
    threats to the wildland urban interface that can not be mitigated.

-   Heavy fuels will be cleared manually from pili grass prescribed burn
    areas prior to ignition to keep the fire intensity low and reduce
    potential impacts to the wildland urban interface from fire.

-   Dead fuels will be manually removed from the stand of ilima at the
    kiosk prior to prescribed fire operations.

-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

-   The park will continue exotic vegetation removal in the primary
    visitor use areas of the park to reduce the opportunities for
    wildland fire.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.8.4 Conclusion:**

Alternative 1, No Action: Suppression of wildfire will have a direct,
beneficial, long term, minor to major impact to the wildland urban
interface.

Alternative 2, Minimum Management Action: The benefits of wildfire
suppression are stated above in Alternative 1. An approved Fire
Management Plan will improve the park's ability to suppress or reduce
wildfire incidents.

Alternative 3, Preferred Action: The benefits of wildfire suppression
and a Fire Management Plan on the wildland urban interface are stated in
above in Alternatives 1 and 2. Prescribed fire will have indirect
adverse temporary negligible impacts to the park's wildland urban
interface. Prescribed fire within the park would not affect the wildland
urban interface at the park/community boundary.

Wildfire suppression in all three Alternatives have direct beneficial,
long term minor to major impacts to the wildland urban interface. An
approved Fire Management Plan, in Alternatives 2 and 3 increases the
benefits to the wildland urban interface by addressing multiple aspects
of wildfire prevention and suppression. Prescribed fire in Alternative 3
will be conducted only when there are no obvious potential threats to
the park's wildland urban interface that can not be mitigated.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.9 CAVES**

**4.9.1 Affected Environment**

Networks of lava tube caves underlie many areas of the park. Lava tubes
originate when cooling crust forms over underlying molten lava streams.
The crust insulates the moving lava, but eventually the sources of the
flow cease and the tubes empty of molten material creating a cave. Caves
contain a number of unique geological formations, as well as cultural,
paleontological, and biological resources.

Thirteen caves have been identified within the park. However, none have
been inventoried.

**4.9.2 Environmental Consequences**

> 4.9.2.1 [Alternative 1, No Action]{.underline}
>
> Wildfire and suppression activities may have beneficial and adverse
> impacts to caves. Suppression of wildfire will have direct,
> beneficial, minor, short term to long term, impacts to caves. Wildfire
> suppression will reduce the destruction caused to the environment by
> wildfire. By minimizing the size of wildfire, opportunities for
> adverse impacts to caves are reduced.
>
> Wildfire and suppression activities may have direct and indirect,
> adverse minor, short to long term impacts to caves. Fire fighters may
> explore caves and cause damage to the resources within. Wildfire may
> burn over cave areas within the park, denuding it of vegetative cover,
> and enticing exploration by visitors who may also cause damage to
> caves or the resources within.
>
> 4.9.2.2 [Alternative 2, Minimum Management Action]{.underline}
>
> The beneficial and adverse impacts of wildfire suppression on caves
> are stated above in Alternative 1.
>
> Wildfire suppression under the guidance and preplanning of a Fire
> Management Plan will have direct, beneficial, minor, short to long
> term impacts to caves. An approved Fire Management Plan will improve
> the park's ability to suppress or reduce wildfire incidents by
> addressing multiple aspects of wildfire, including, prevention,
> preparedness, and initial attack. Strategies for wildfire suppression
> will also be addressed in MIST and the formalized involvement of
> resource advisors can mitigate some of the adverse impacts of wildfire
> suppression to caves as stated in Alternative 1.
>
> 4.9.2.3 [Alternative 3, Preferred Action]{.underline}
>
> The impacts of wildfire suppression and an approved Fire Management
> Plan are stated above in Alternatives 1 and 2.
>
> Prescribed research fire for the establishment and regeneration of
> pili grass will have no impact to caves as prescribed fire will not
> occur near caves.

**4.9.3 Mitigation Measures**

The following measures will not apply to Alternative 1, as there is no
provision for a Fire Management Plan to formalize and implement such
measures. In order to minimize the effects of fire activity to caves the
following would be adhered to:

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on caves.

-   Firefighters are prohibited from entering caves.

-   Priorities for wildfire suppression near caves, will as much as
    possible, preserve existing vegetation above, around, and at cave
    entrances.

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```
-   Use existing natural and human-made barriers, wet line, or cold
    trailing the fire edge.

```{=html}
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```
-   No hand line construction.

-   The incident commander, in consultation with resource advisors, may
    override the above measures in cases where there is a greater threat
    to life, property, and/or resources.

**4.9.4 Conclusion:**

Alternative 1, No Action: Suppression of wildfire will have direct,
beneficial, minor, short term to long term, impacts and direct and
indirect, adverse minor, short to long term impacts to caves.

Alternative 2, Minimum Management Action: The beneficial and adverse
impacts of wildfire suppression on caves are stated above in
Alternative 1. Mitigating the impacts of wildfire suppression activities
will have direct, beneficial, minor, short to long term impacts to
caves.

Alternative 3, Preferred Action: The impacts of wildfire suppression and
an approved Fire Management Plan are stated above in Alternatives 1 and
2. Prescribed research fire for the establishment and regeneration of
pili grass will have no impact to caves as prescribed fire will not
occur near caves.

Wildfire and suppression activities under Alternative 1 may have adverse
impacts to caves. Alternatives 2 and 3 provide the greatest benefits for
the protection of caves from the impacts of wildfire and suppression
activities through a Fire Management Plan, MIST, and the use of resource
advisors. Prescribed fire activity will not occur near caves.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**4.10 CULTURAL RESOURCES**

**4.10.1 Affected Environment**

This section discusses the cultural resources in the park as well as
inventory efforts conducted to identify cultural resources for the
analysis included in this EA. The area of potential effect for the
analysis of cultural resources for this EA was determined to be the 181
acres main park unit.

Pu'uhonua o Honaunau National Historical Park was listed on the National
Register of Historic Places in 1966. The National Register nomination
includes 321 sites, fifteen of which are described in some detail. The
remaining sites are not described, but are indicated as being those
sites/features shown on Ed Ladd's 1964 archaeological base map for the
park. In their overview and assessment of the archaeological resources
of the park, Tuggle and Tuggle (2006) indicate that nearly 1500
archaeological sites/features have been identified. However, the
accounting of these sites is problematic because site numbers have been
applied on a feature basis and with an inconsistent approach, and some
features have never been assigned site numbers. Approximately 1,100 site
numbers have been assigned to sites in the main park unit based on seven
different number systems. In addition, there are an estimated 150 to 200
sites that have not yet been assigned numbers.

The cultural resources present within the park are divided into three
main categories: Traditional Hawaiian Sites, Post Contact Period Sites,
and Cultural Places. These categories, and the information provided
below are derived primarily from the Archaeological Overview and
Assessment (Tuggle and Tuggle 2006) that was recently completed for the
park.

Traditional Hawaiian Sites

Tuggle and Tuggle (2006) have defined the traditional Hawaiian sites in
the park as those sites representing pre European contact Hawaiian
lifeways. These include sites from the pre contact period as well as
sites occupied through the beginning of the 19^th^ century. Site types
representative of this category include Chiefs complexes and residences,
holua slides, other ceremonial sites and residences, agricultural sites,
and specialized sites (Tuggle and Tuggle 2006).

The park contains sites that are part of the chiefly center at Honaunau.
These include the Pu'uhonua and the monumental architectural features
within it, the Kings Residence or Palace Grounds (Kauwalomalie) near
Keone'ele Cove, two other chiefs residences, and three Holua slides. The
park was a favored residence of ruling chiefs of the Island of Hawaii.
More importantly, it was a place of sanctuary. At Honaunau, kapu
breakers, defeated warriors, and noncombatants could flee from any
pursuer and be placed under the protection of the Hawaiian gods. Once
within the walls of the pu'uhonua, people seeking refuge were safe and
given a second chance at life. Noncombatants and defeated warriors could
wait in safety until the battle was over and those who broke the kapu
were absolved of their guilt by a kahuna pule. When they were free to
return to their homes, the protection of the gods went with them.
Pu'uhonua o Honaunau, "the place of refuge at Honaunau" was and still is
considered sacred grounds by the Hawaiians.

Other ceremonial sites in the park include two large temples, Alahaka
Heiau and Oma'o Heiau, and at least eight fishing shrines. Other
residential sites include the archaeological remains of commoner
settlements. These sites are represented by surface structures or
platforms, cave shelters, and areas of buried cultural deposits.
Agricultural sites include animal pens and features associated with the
cultivation of plants. Specialized sites include fishponds, refuge
caves, ahupua'a boundary markers, petroglyphs, trails, and canoe
landings.

Post Contact Sites

Post contact sites are defined as sites/features that represent
occupation of the park area during the 19^th^ and 20^th^ centuries
(Tuggle and Tuggle 2006). These resources include kuleana houselots,
ranching sites, trails, and roads. There are three main clusters of
kuleana houselots in the park. They include Ki'ilae Village, a cluster
of houselots immediately south of the refuge and crossing the
Honaunau-Keokea ahupua'a boundary, and a cluster in central Keokea.
Ranching sites include cattle walls and cattle traps.

Cultural Places

In the archaeological overview, Tuggle and Tuggle (2006) suggested that
the following sites be considered cultural places within the park: 1)
Bernice Pauahi's Coconut Grove; 2) Ki'ilae Trail; and 3) water sources
(springs, wells, and anchialine ponds). Bernice Pauahi's Coconut Grove
was planted around 1867 by Mrs. Charles R. Bishop. It was likely planted
as part of a ceremony conducted when Charles R. Bishop acquired the land
of Honaunau in 1867. Ki'ilae Trail is a mauka-makai (mountain to ocean)
trail that is recommended to be a cultural place or traditional cultural
property based on its association with huaka'i po or night marchers. The
water sources are also suggested to be traditional cultural properties
because they were important sources of water for drinking and other
uses, and many have traditional names.

Three cultural landscapes have been designated in the park by the
National Park Service (NPS), and they are listed in the NPS Cultural
Landscapes Inventory Database. These landscapes include 1) Pu'uhonua and
Royal Grounds, 2) Ki'ilae Village, and 3) Keanae'e Cliffs. The NPS has
not completed inventories of these landscapes so there is no information
presently available about them.

The Visitors Center at Pu'uhonua o Honaunau has been determined to be
eligible for the National Register of Historic Places. It was
constructed between 1968 and 1969, and is one of 107 visitor centers
designed and built by the National Park Service under the Mission 66
program. The Mission 66 program was initiated by the Park Service and
was a ten year project to regenerate and modernize the national parks in
preparation for the fiftieth anniversary of the agency in 1966.

A literature review was conducted for the area of potential effect .In
addition, an archaeological inventory was conducted of the Visitors
Center parking lot which is the area specifically identified for
prescribed burning in this EA. For activities such as wild land fire
suppression, it is not usually feasible to survey an area and determine
National Register eligibility before fire suppression activities begin.
The survey of the parking lot median/prescribed burn area (as proposed
in Alternative 3) covered approximately 0.5 acres, and included all
areas that are not currently covered with asphalt or gravel. Two
archaeological features consisting of petroglyphs were found during the
survey. They include an owl figure and an L shaped figure.

**4.10.2 Environmental Consequences**

4.10.2.1 Alternative 1, No Action

Wildfire suppression will have direct, minor short to long term impacts
to cultural resources. Suppressing the spread of wild fire will have
direct beneficial long term impact to cultural resources by preventing
further destruction of combustible or fragile surface features and
artifacts, subsurface deposits and features, reduced carbon
contamination, and decrease erosion. Wildfire suppression operations
will have direct, short to long term, minor to major, impacts to
cultural resources. Fire suppression activities can result in impacts to
cultural resources. Known cultural resources would be protected by close
consultation with cultural resource specialists and fire personnel. When
possible, cultural resources would be avoided. However, damage to
unknown sites and features through fire suppression activity
(operational impacts) could occur and could include impacts associated
with staging operations, fire line construction, heli-spot construction,
and mop up efforts. Wildland fire suppression activities have the
potential to impact and adversely affect archaeological features and
sites and historic structures, and they can potentially alter
ethnographic resources and cultural landscapes. Fire suppression
activities produce ground disturbing activities that can adversely
affect both surface and buried archaeological remains.

Precautions regarding cultural resource protection are critical given
that only a small fraction of the current park area has been
inventoried, and suppression activities could occur in remote sections
of the park that have received little or no systematic archaeological
inventory. Direct involvement of cultural resources personnel when
choosing location for staging areas, fire lines, establishing fuel
breaks, etc. would substantially help in avoiding or minimizing adverse
impacts. Cultural resources would be avoided when possible. Mitigation
efforts could reduce or eliminate the negative impacts on the parks
known and unknown cultural resources and lessen the chances of adverse
impacts to sites and features.

Under this alternative, there would be no approved fire management plan.
Lack of an approved fire plan would mean that there would be no
organizational structure in place (ie. resource advisors) to insure that
mitigation measures necessary to protect cultural resources would be
implemented.

4.10.2.2 Alternative 2, Minimum Management Action

The impacts of wildfire suppression on cultural resources are the same
as those described above for Alternative 1. Under this alternative, a
fire management plan would establish an organizational structure with
resource advisors who will insure that specific mitigation measures for
cultural resources are implemented.

4.10.2.3 Alternative 3, Preferred Action

The impacts of wildfire suppression with a Fire Management Plan on
cultural resources are stated above in Alternatives 1 and 2.

Prescribed research fires of low intensity for pili grass will have
direct, short term, negligible impacts to cultural resources. The
primary area for prescribed fire is the developed parking lot at the
Visitors Center. The visitor center parking lot median area has two
petroglyphs located on exposed pahoehoe outcroppings within it (as
described in section 4.10.1 above). It is unlikely that fire would reach
the owl petroglyph because it is surrounded by pahoehoe and the nearest
grasses are located 7 meters (23 feet) to the west. However, depending
on wind direction, ash or small embers my fall on it during the burn.
The "L" petroglyph is located on the northeast edge of a pahoehoe
outcropping and is immediately adjacent to burnable fuels. As a result,
it could be affected by burning and/or falling embers.

The current use of pili grass will have beneficial minor impacts to
cultural landscapes. Maintaining a stand of pili grass serves as a
representative sample of what the park's landscape may have looked like
during pre-contact Hawaii, and Hawaiians did burn pili grasslands to
foster growth (Loh unpublished and Pratt 1998).

Areas other than the Visitor Center parking lot that are selected for
prescribed fire will be surveyed for cultural resources. Compliance with
Section 106 of NHPA will be conducted prior to burn activities by the
park's resource manager and will also be addressed in the burn plan for
that designated area.

**4.10.3 Mitigation Measures**

4.10.3.1 Alternative 1, No Action

No mitigation would be implemented under this alternative because there
would be no fire management plan or organizational structure in place
(ie. resource advisors) to insure that mitigation measures necessary to
protect cultural resources would be implemented.

4.10.3.2 Alternative 2, Minimum Management Action

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on cultural resources.

-   Cultural resource personnel will accompany fire fighting crews
    during suppression efforts and prescribed fire activities as needed
    to insure protection of cultural resources.

-   Fire vehicles and appartus' will remain on existing roadways except
    in a life threatening situations.

-   Explosives, bulldozers, or similar ground disturbing equipment will
    not be used to construct fire line.

-   Use existing natural and human made barriers, wet line or cold
    trailing of the fire edge.

-   Utilize MIST as outlined in the Fire Management Plan.

-   No hand line construction.

-   Known cultural resources will be avoided when possible, and would be
    protected by close coordination with cultural resource specialists
    and fire personnel.

4.10.3.3 Alternative 3, Preferred Action

-   Deploy resource advisors on all fires to evaluate suppression
    tactics to maintain consistency with land/resource objectives and to
    minimize impacts on cultural resources.

-   Cultural resource personnel will accompany fire fighting crews
    during suppression efforts and prescribed fire activities as needed
    to insure protection of cultural resources.

-   Fire vehicles and appartus' will remain on existing roadways except
    in a life threatening situations.

-   Explosives, bulldozers, or similar ground disturbing equipment will
    not be used to construct fire line.

-   Use existing natural and human made barriers, wet line or cold
    trailing of the fire edge.

-   Utilize MIST as outlined in the Fire Management Plan.

-   No hand line construction.

-   The petroglyphs located in the Visitors Center parking lot will be
    protected from prescribed fire by manually removing small plants
    growing next to and around them for a sufficient distance to prevent
    potential contact with direct flame from the fire, and by placing a
    wet burlap bag over the features and wetting down the area
    surrounding them with water from a low pressure hose.

-   Areas other than the Visitor Center parking lot that are selected
    for prescribed fire will be inventoried for cultural resources and
    compliance with Section 106 of NHPA will be completed prior to
    implementation of the burn.

-   If a prescribed fire will negatively impact cultural resources and
    the impact(s) could not be mitigated, then the prescribed burn will
    not occur.

**4.10.4 Conclusion**

Alternative 1, No Action: Suppressing the spread of wildfire and
suppression operations will have direct long term minor to major impact
to cultural resources. This Alternative is not a viable choice since it
does not provide for the required approved FMP. The existing impacts of
Alternative 1, No Action, sets a baseline of existing impacts continued
into the future against which to compare the impacts of Alternatives 2
and 3.

Alternative 2, Minimum Management Action: The impacts of wildfire
suppression and suppression activities on cultural resources are stated
above in Alternative 1. Mitigating the impacts of wildfire suppression
operations will have direct, long term minor impacts to cultural
resources. Implementation of this alternative would result in no adverse
effects to cultural resources as mitigation measures would be put in
place to avoid or minimize impacts to these resources.

Alternative 3, Preferred Action: The impacts of wildfire suppression
with a Fire Management Plan on cultural resources are stated above in
Alternatives 1 and 2.

Prescribed research fires of low intensity for pili grass will have
direct, short term, negligible impacts to cultural resources. The
current use of pili grass will have beneficial minor impacts to cultural
landscapes. Implementation of this alternative would result in no
adverse effects to cultural resources as mitigation measures would be
put in place to avoid or minimize impacts to these resources.

Ultimately, the suppression of wildfire will have an overall beneficial
impact to cultural resources. These benefits increase with each
alternative. Alternatives 2 and 3 provide the greatest benefit to
cultural resources because they include wildfire suppression with the
benefits of resource advisors and mitigation measures. Alternative 3
also includes the use of prescribed research fire for the establishment
and regeneration of pili grass to maintain a representative sample of
what the parks landscape may have looked like prior to 1926.

Implementation of alternatives 2 or 3 would result in no adverse effects
to cultural resources as mitigation measures would be put in place to
avoid or minimize impacts to these resources.

The implementation of any of the three alternatives would not impair
park resources or values, including the opportunities that otherwise
would be present for the enjoyment of those resources or values.

**Table 2. Table of Species**

Plants

  ----------------------- ----------------------- -----------------------
  Hawaiian Name           Common Name             Scientific Name

  A'a'li'i                                        *Dodonea viscosa*

  'Akia                                           *Wikstromia
                                                  pulcherrima*

  Ekoa, koa haole                                 *Leucaena leucocephala*

                          Guinea grass            *Panicum maximum*

  Hala                                            *Pandanus tectorious*

  Ilima                                           *Sida fallax*

  Kamani                                          *Calophyllum
                                                  inophyllum*

  Ki                      Ti                      *Cordyline fruiticosa*

  Kiawe                   Mesquite                *Prosopis pallida*

                          Klu                     *Acacia farnesiana*

  Ko                                              *Saccharum officinarum*

  Kou                                             *Cordia subcordata*

  Loulu                                           *Pritchardia affinis*

  Makaloa                                         *Cyperus laevigatus*

  Mau'u                                           *Frimbristylis cymosa*

                          Natal redtop            *Rhynchelytrum repens*

  Naupaka kahakai                                 *Scaevola taccada*

  Niu                     Coconut                 *Cocos nucifera*

  Noni                                            *Morinda citrifolia*

  'Opiuma                 Manila tamarind         *Pithecellobium dulce*

  Pili                                            *Heteropogon contortus*

  Pohinahina                                      *Vitex rotundifolia*

  'Uhaloa                                         *Waltheria indica*

  Wauke                   Paper mulberry          *Broussonetia
                                                  papyrifer*
  ----------------------- ----------------------- -----------------------

Animals

  ---------------- ------------------------- ----------------------------
  Hawaiian Name    Common Name               Scientific Name

  'A               Brown booby               *Sula leucogaster plotus*

  'Akekeke         Ruddy turnstone           *Arenaria interpres*

  'Auku'u          Black-crowned night heron *Nycticorax nycticorax
                                             hoactli*

                   Common mynas              *Acridotheres tristis*

                   Japanese white-eyes       *Zosterops japonicus*

  Kioea            Bristle-thighed curlew    *Numenius tahitiensis*

  Kolea            Pacific golden-plover     *Pluvialis fulva*

  'Ope'ape'a       Hawaiian hoary bat        *Lasiurus cinereus semotus*

                   Orangeblack damselfly     *Megalarion xanthomelas*

                   Shrimp                    *Metabetaeus lohena*

                   Shrimp                    *Palaemonella burnsi*

                   Shrimp                    *Calliasmata pholiodota*

  'Ulili           Wandering tattler         *Heteroscelus incanus*
  ---------------- ------------------------- ----------------------------

GLOSSARY OF FIRE MANAGEMENT TERMS USED IN THIS DOCUMENT

**Cold Trailing -** A method of feeling the edge of a burn area with the
back of an exposed hand to detect heat.

**Fuel Loading -** Amount of burnable biomass, including live fuels and
dead fuels.

**Minimum Impact Suppression Tactics (MIST)** **-** Refers to guidelines
that assist fire personnel in the choice of procedures, tools, and
equipment used in fire suppression and post-fire rehabilitation that
will maintain a high standard of caring for the land. These techniques
reduce soil disturbance, impact to water quality, noise disturbance, and
cutting or trampling of vegetation. NPS guidelines, outlined in DO-18,
are applied to site conditions, and current and expected fire behavior
to determine the appropriate MIST actions.

**Natural Fire -** Fire resulting from natural causes.

**Preparedness -** Activities that lead to a safe, efficient and cost
effective fire management program in support of land and resource
management objectives through appropriate planning and coordination.

**Prescribed Fire -** Any fire ignited by management actions to meet
specific objectives. A written approved prescribed fire plan must be
completed and appropriate NEPA requirements followed prior to ignition.

**Prescription -** Measurable criteria which define conditions under
which a prescribed fire may be ignited, guide selection of appropriate
management responses, and indicate other required actions. Prescription
criteria may include safety, economic, public health, environmental,
geographic, administrative, social or legal considerations.

**Suppression -** A response to wildland fire that results in
curtailment of fire spread and elimination of all identified threats
from the fire.

**Wildfire -** An unwanted wildland fire.

**Wildland -** An area in which development is essentially nonexistent,
except for roads, railroads, power lines, and similar transportation
facilities. Structures, if any, are widely scattered.

**Wildland Fire -** Any non-structural fire, other than prescribed fire,
that occur in the wildland. This term encompasses fires previously
called both wildfires and prescribed natural fires.

GLOSSARY OF HAWAIIAN TERMS USED IN THIS DOCUMENT

The terms listed below may have more translations than noted.

**Kahuna pule--** Priest.

**Kapu -** Sacred law.

**Makai -** Direction towards the sea.

**Mauka -** Direction towards the mountain.

**Pali -** A Hawaiian term referring to a cliff or fault scarp. Singular
and plural is pali.

**Pu'uhonua --** Place of refuge.

PLANNING TEAM

Sallie Beavers, Acting Chief of Resources Management, Kaloko-Honokohau
National Historical Park.

Geraldine Bell, Superintendent, Kaloko-Honokohau and Pu'uhonua o
Honaunau National Historical Parks.

Rick Gmirkin, Archeologist, Research Corporation of the University of
Hawaii, Kaloko-Honokohau National Historical Park.

Les Inafuku, Chief Ranger, Kaloko-Honokohau and Pu'uhonua o Honaunau
National Historical Parks.

Laura Kochanski, Chief of Resource Management, Pu'uhonua o Honaunau
National Historical Park.

Rita Pregana, Management Assistant, Kaloko-Honokohau and Pu'uhonua o
Honaunau National Historical Parks.

Teresa Reveira, Chief of Interpretation, Kaloko-Honokohau and Pu'uhonua
o Honaunau National Historical Parks.

Stanley Sakamoto, Chief of Maintenance, Pu'uhonua o Honaunau National
Historical Park.

Tony Texeira, Chief of Maintenance, Kaloko-Honokohau National Historical
Park.

CONSULTANTS

Curtis Daehler, Professor of Botany, University of Hawaii.

David Foote, Ecologist, U.S. Geological Survey (USGS), Biological
Resources Division (BRD).

Catherine Lentz, Compliance Manager, Hawaii Volcanoes National Park.

Rhonda Loh, Botanist, Hawaii Volcanoes National Park.

Joe Molhoek, Fire Management Officer, Hawaii Volcanoes National Park.

George Parish, Inventory and Monitoring, Bats.

ENVIRONMENTAL ASSESSMENT RECIPIENTS

The environmental assessment will be sent out to the interested and
affected public, agencies and Native Hawaiian organizations for a
thirty-day review. Notice of the environmental assessment's availability
for review will be published in local newspapers and the environmental
assessment will be available at the Visitor Center and posted on the
park's web page for review.

Kai Malino Ranch

Kealia Ranch

Ki'ilae Estates

McCandless Ranch and Cattle Co.

Yee Hop Enterprises

Kamehameha Schools

Kona Hawaiian Civic Club

Kuakini Hawaiian Civic Club of South Kona

Royal Order of Kamehameha

Conservation Council of Hawai\`i

County of Hawaii Planning Department

Department of Land and Natural Resources, State Historic Preservation
Division

Department of Land and Natural Resources, Division of Forestry and
Wildlife

Hawai\`i County Fire Department

Office of Hawaiian Affairs

Hui Malama I Na Kupuna o Hawai'i Nei

Pacific Cooperative Studies Unit, University of Hawai\`i - Manoa, Botany
Department

University of Hawai\`i -- Manoa, Department of Botany

University of Hawai\`i -- Manoa, Department of Zoology

University of Hawai\`i -- Hilo, Office of Mauna Kea Management

Earth Justice

Environment Hawaii Inc.

Hawai\`i Audobon Society

Sierra Club

The Nature Conservancy of Hawai\`i

National Marine Fisheries Service

National Park Service, Pacific Area Office

U.S. Fish and Wildlife Service, Pacific Islands Ecoregion

U.S. Geological Survey, Hawaiian Volcano Observatory

U.S. Geological Survey, Pacific Island Ecosystems Research Center

The Honorable Harry Kim, Mayor of the Island of Hawai\`i

The Honorable Russell Kokobun, State Senator

The Honorable Linda Lingle, Governor of Hawai\`i

Governor's Liaison Officer, East Hawai\`i

37 interested and affected individuals and families

# [References]{.underline}

# 

# City of Refuge National Historical Park, Master Plan. 1972.

City of Refuge National Historical Park, Final Environmental Statement,
Proposed Master Plan. 1975.

# 

# Daehler, Curtis C. Using Fire to Restore and Manage Pili Grasslands at Pu'ukohola NHS, November, 1998. Department of Botany, University of Hawai'i Manoa, Honolulu, HI.

Daehler, Curtis C. and Erin M. Goergen. Experimental restoration of an
indigenous Hawaiian grassland after invasion by *Cenchrus ciliaris*
(buffel grass). In Press.

Developmental Concept Plan/Environmental Assessment, Pu'uhonua o
Honaunau National Historical Park. July 2000.

Glacier National Park, Environmental Assessment for the Fire Management
Plan. 2003.

Hawaii Volcanoes National Park, Environmental Assessment, Wildland Fire
Management Plan. November 2004.

Horseshoe Bend National Military Park. Fire Management Plan
Environmental Assessment. April 2004.

Juvik, S.P., J.O. Juvik, eds. 1998. Atlas of Hawaii (3^rd^ Edition).
University of Hawaii Press, Honolulu. 333 p.

Hulbert, Jim H. & Assoc. "Draft" Environmental Assessment for Haleakala
National Park. February, 2001.

Manzanar National Historic Site, Environmental Assessment, Fire
Management Plan. March 2005.

Minassian, Jack. 1998. Prescribed Burn Unit Plan, Fire Number 9801,
Pu'uhonua o Honaunau National Historical Park.

Mohr, Francis, Thayer, & Eric. MOHR Managed Fire. "Draft" Fire
Management Plan. February, 2001

Morin, Marie P. 1996. Birds of Pu'uhonua o Honaunau National Historical
Park. Technical Report 106. Cooperative Parks Resources Study Unit,
University of Hawaii, Honolulu.

Pratt, Linda. 1998. Vegetation Management Strategies for Three National
Historical Parks on Hawai'i Island. Technical Report 121, Cooperative
Parks Resources Study Unit, University of Hawaii, Honolulu.

Pratt, Linda W., and Lyman L. Abbott. 1996. Vascular Plants of Pu'uhonua
o Honaunau National Historical Park. Technical Report 105. Cooperative
Parks Resources Study Unit, University of Hawaii, Honolulu.

Pu'ukohola Heiau National Historic Site. Fire Management Plan. June,
1992.

Rock, 1974 and Carlquist, 1970. Observations & Comments Regarding Native
Vegetation Change on Island of Hawai'i.

Tomonari-Tuggle, M.J. and H. David Tuggle, 2006. Archaeological Overview
and Assessment for the Three West Hawai'i Island Parks, National Park
Service, Part A: Pu'uhonua o Honaunau National Historical Park.

Tunison, J.T., J.A.K. Leialoha, R.L. Loh, L.W. Pratt, and P.K.
Higashino. 1994. , Fire Effects In The Coastal Lowlands, Hawai'i
Volcanoes National Park. Technical Report 88. Cooperative Parks
Resources Study Unit, University of Hawaii, Honolulu.

United States Department of the Interior, National Park Service
Director's Order #12, Conservation Planning, Environmental Impact
Analysis, and Decision-making. 2001.

U.S.D.I. DO-18 (National Park Service Director's Order),National Park
Service Fire Management Policy. 2000. Report on file.

Zimmerman, G. Thomas (National Park Service) & David L. Bunnell (FS).
1998. Wildland and Prescribed Management Policy - Implementation
Procedures Reference Guide. National Interagency Fire Center, Boise,
Idaho.